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Representation involving air permitting issues associated with a new waste energy recovery facility project at an iron and steel production company’s works that will beneficially use blast furnace gas instead of flaring the gas. Actions have included the development of technical and legal arguments and subsequent negotiations with the state agency on many aspects of the air permitting, including the sufficiency of New Source Review net emission reductions and developing permitting strategies to proactively address issues that could not be raised on appeal.