ALEXANDER, J.
[¶ 1] International Paper Company and the Town of Jay (the Town) appeal from a judgment entered in the Superior Court (Kennebec County, Humphrey, J.) in a Rule 80C appeal, affirming in part a ruling by the Board of Environmental Protection (the Board) on International Paper's applications for pollution control tax exemption certifications for an elemental chlorine free (ECF) system and a low
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