Did Maine's state laws give the Department of Environmental Protection enough authority to run a Title V Part 70 air-quality permitting program?

Plain-English summary

Title V of the 1990 Clean Air Act Amendments required each state to run an operating-permits program ("Part 70") for major air pollution sources. EPA would only approve a state program if the state attorney general certified that state law contained adequate authority for every element of the program: licensing, enforcement, public participation, fees, judicial review, and so on. This 1995 opinion is that certification for Maine, addressed to the DEP's Bureau of Air Quality Control as the program submittal moved to EPA Region I.

The AG walked through 21 program elements, each with a one-paragraph statement of the federal requirement, the citation of corresponding Maine statutes and regulations, and a "Remarks" paragraph explaining how Maine law fits. The headline conclusion: yes, Maine has authority on every element. The legal scaffolding combined Title 38 (the air-quality statutes, particularly 38 M.R.S.A. §§ 341-A through 591), the Maine Administrative Procedure Act at 5 M.R.S.A. §§ 8001-11008, and DEP regulations Chapters 100 through 140, with Chapter 140 being the dedicated Part 70 rule the DEP had just promulgated and the AG had just approved as to form.

A few elements required more careful explanation than others. On enforcement, the AG confirmed that Maine could impose civil and criminal penalties up to $10,000 per day per violation, satisfying 40 C.F.R. § 70.11. On conflict of interest, the AG acknowledged that 38 M.R.S.A. § 341-C(2) (which only requires the Board of Environmental Protection to be drawn from "the broadest possible interest and experience") did not automatically satisfy the CAA's requirement that a majority of the licensing body represent the public interest, but explained that in practice the BEP had always been so composed, and that 5 M.R.S.A. § 18 provides additional conflict-of-interest discipline. On default issuance, the AG was explicit that Maine law does not allow a permit to issue just because DEP let an application sit, so there is no default-issuance risk. On judicial review, the AG identified the 30-day and 40-day windows under 5 M.R.S.A. §§ 11001-11002, plus a six-month window for a challenge to DEP's failure to act.

The opinion noted that some federal Part 70 provisions were then in litigation (Clean Air Act Implementation Project v. EPA, D.C. Cir. No. 92-1303), with Maine as a petitioner. The AG flagged that EPA rulemaking might change federal requirements on operational flexibility, license modifications, and similar items, and explained that DEP's broad rulemaking authority under 38 M.R.S.A. §§ 341-D and 590 would let Maine update its regulations to track any new federal rules through its State Implementation Plan.

Currency note

This opinion was issued in 1995. Subsequent statutory amendments, court decisions, or later AG opinions may have changed the analysis. Treat this page as historical context, not current legal advice. Verify current law before relying on any specific rule, deadline, or remedy mentioned here.

Common questions

What is a Part 70 (Title V) operating permit?

A consolidated air-quality permit required under Title V of the federal Clean Air Act for major stationary sources of air pollution. It pulls together all applicable federal and state air-quality requirements affecting a single facility into one license, with monitoring, recordkeeping, reporting, and compliance certification obligations. EPA's implementing rule is at 40 C.F.R. Part 70.

Why does the Maine AG have to sign off on this?

40 C.F.R. § 70.4(b)(3) requires every state to include, with its Part 70 program submittal to EPA, a legal opinion from the state attorney general certifying that the state has adequate legal authority to run the program. Without that AG opinion, EPA cannot approve the program, and the state cannot run delegated Part 70 permitting; EPA would have to run it directly.

Who issued Part 70 permits in Maine under this regime?

Either the Commissioner of DEP or the Board of Environmental Protection (BEP), depending on the source category and procedural posture. Both are subject to the conflict-of-interest provisions of 5 M.R.S.A. § 18.

What were the permit fees?

38 M.R.S.A. § 353-A set the fee schedule: $5 per ton for sources with up to 1,000 tons of licensed allowable emissions, scaling up to $15 per ton for sources over 4,001 tons. Annual fees were capped between $250 and $150,000. There was an additional surcharge of $10 per 1,000 air quality units. Per § 353-A(9), fee revenue could only be used for air pollution control activities.

What was the deal with the three Maine statutes EPA Region I had flagged as possibly conflicting with federal law?

EPA had raised concerns about (1) 38 M.R.S.A. § 587's variance authority, (2) 38 M.R.S.A. § 590(3)'s allowance for excess emissions during cold start-ups and shutdowns, and (3) the 24-month installation period in 38 M.R.S.A. § 590(6). The AG's response: DEP had never granted a § 587 variance; § 590(3) allowances are limited to those "consistent with applicable standards," so they cannot lawfully be used to subvert federal requirements; and § 590(6) functions like a federally permitted compliance schedule. As a backstop, EPA retains a 45-day veto under 40 C.F.R. § 70.8(c)-(d).

Background and statutory framework

The Clean Air Act Amendments of 1990 added Title V (42 U.S.C. § 7661a et seq.), the operating-permits program. Major air pollution sources, including solid-waste incinerators under CAA § 129(e), must hold a Title V permit. EPA's implementing rule is 40 C.F.R. Part 70. Maine's submission consisted of DEP Regulations Chapter 140 (the dedicated Part 70 rule), amendments to Chapters 100 and 115, and the underlying statutory framework at 38 M.R.S.A. §§ 341-A through 591.

The AG's certification was structured as a 21-section document tracking the 21 elements EPA requires. Each section pairs the federal authority (CAA section and 40 C.F.R. citation) with the corresponding state citations and a paragraph of remarks. The opinion is unusually long for an AG opinion because it doubles as the certifying legal document EPA needed.

Maine has the authority to assess civil penalties up to $10,000 per day per violation under 38 M.R.S.A. § 349(2) and (8), and criminal penalties up to the same maximum under § 349(1) and (3) and 17-A M.R.S.A. §§ 34 and 35. The DEP v. Emerson, 616 A.2d 1268 (Me. 1992) decision confirmed that the civil penalty does not require proof of mental state, while the criminal penalty requires "knowingly," matching CAA standards.

Citations

• 42 U.S.C. § 7661a(d) (Title V state program submittal and AG certification)
• 42 U.S.C. § 7429(e) (CAA § 129(e), solid waste incineration units)
• 40 C.F.R. Part 70 (federal Part 70 operating permits regulation)
• 40 C.F.R. § 70.4(b)(3) (AG legal opinion requirement)
• 5 M.R.S.A. § 8056(1)(A) (AG approval of rulemaking as to form)
• 5 M.R.S.A. § 18 (conflict-of-interest provisions for state officers)
• 5 M.R.S.A. §§ 8001-11008 (Maine Administrative Procedure Act)
• 5 M.R.S.A. §§ 11001-11002 (judicial review of agency action)
• 38 M.R.S.A. §§ 341-A through 341-D (Board of Environmental Protection, DEP organization)
• 38 M.R.S.A. §§ 347-A, 348, 349 (DEP enforcement and penalty authority)
• 38 M.R.S.A. § 353-A (air emission license fees)
• 38 M.R.S.A. § 587 (variance authority)
• 38 M.R.S.A. § 590, § 590(3), § 590(6) (air emission licensing, start-up/shutdown allowance, 24-month installation)
• 38 M.R.S.A. § 591 (air contaminant source operating requirement)
• DEP Regulations Chapter 100 (general air emission licensing)
• DEP Regulations Chapter 140 (Title V Part 70 program)
• 17-A M.R.S.A. §§ 34, 35, 1252 (criminal liability and sentencing)
• DEP v. Emerson, 616 A.2d 1268 (Me. 1992) (civil vs. criminal mental state for environmental violations)
• D & J Associates v. Board of Environmental Protection, 560 A.2d 4 (Me. 1989) (no default issuance from agency inaction)
• In re Lappie, 377 A.2d 441 (Me. 1977) (standing for judicial review)
• In re International Paper Co., 363 A.2d 235 (Me. 1976) (environmental standing)
• Fitzgerald v. Baxter State Park Authority, 385 A.2d 189 (Me. 1978) (aesthetic/recreational standing)
• Sierra Club v. Morton, 405 U.S. 727 (1972) (federal standing baseline)

Source

• Landing page: https://www.maine.gov/legis/lawlib/lldl/agops/agops.htm
• Original PDF: https://lldc.mainelegislature.org/Open/AG/Opinions/1995/ag_19951113.pdf

Original opinion text

Best-effort transcription from a scanned PDF. Minor errors may remain, the linked PDF is authoritative. This is a long, structured legal opinion: the verbatim text follows. The full PDF carries the AG signature block and appendices.

95-13

ANDREW KETTERER
ATTORNEY GENERAL

STATE OF MAINE
DEPARTMENT OF THE ATTORNEY GENERAL
6 STATE HOUSE STATION
AUGUSTA, MAINE 04333-0006

November 13, 1995

James Brooks
Director, Bureau of Air Quality Control
State House Station 17
Augusta, Maine 04333

Re: Legal Opinion Concerning Part 70 Program Required by Title V of the Clean Air Act

Dear Mr. Brooks:

Title V of the Clean Air Act Amendments of 1990 requires each state to develop an operating permits program commonly known as a "Part 70 Program" for certain sources of air pollution. See 42 U.S.C. § 7661a(d)(1) and 40 C.F.R. Part 70. As part of Maine's program submittal, the Maine Attorney General must certify that the state laws provide adequate authority to carry out all aspects of the Part 70 operating permit program. See 42 U.S.C. § 7661a(d) and 40 C.F.R. § 70.4(b)(3).

Pursuant to 5 M.R.S.A. § 8056(1)(A), on October 23, 1995 my office approved as to form and legality the Maine Department of Environmental Protection's recent Part 70 Program rulemaking, the promulgation of DEP Regulations Chapter 140 and amendments to Chapters 100 and 115. In accordance with Section 502(d) of the Federal Clean Air Act ("CAA") and 40 C.F.R. § 70.4(b)(3), it is the opinion of this Department that the laws of the State of Maine provide adequate authority to administer and enforce the Part 70 program which the Maine Department of Environmental Protection ("DEP") has submitted to the U.S. Environmental Protection Agency ("EPA") for approval. Specific legal authorities supporting this conclusion include the lawfully adopted and fully effective state laws and regulations identified below.

This opinion consists of the following parts, corresponding to various program elements and legal issues:

1. Authority to Issue Part 70 Licenses
2. Authority to Issue Part 70 Licenses to Noncomplying Sources
3. Conflicts of Interest
4. License Fees
5. License Term
6. Monitoring, Recordkeeping and Reporting
7. Inspection/Entry Authority
8. Incorporation of All "Applicable Requirements" into Part 70 Licenses
9. Reopening of Part 70 Licenses
10. Operational Flexibility
11. Modifications to Part 70 Licenses
12. Public Participation
13. Public Access to Part 70 License Information
14. Enforcement of Part 70 Program Requirements
15. Authority to Enforce Part 70 Licenses after End of License Term
16. EPA License Veto
17. Judicial Review of Agency Failure to Act
18. Default License Issuance
19. Opportunity for Judicial Review of Part 70 License Actions
20. Limitations on Judicial Review

21. Coordination with Acid Rain Requirements

22. AUTHORITY TO ISSUE PART 70 LICENSES

State law provides authority for Department of Environmental Protection ("DEP") to issue Part 70 licenses to all air pollution sources within the State of Maine which are required to have licenses under Section 502(a) of the CAA and 40 C.F.R. Section 70.3 ("Part 70 sources"), including authority to issue Part 70 licenses for solid waste incineration units combusting municipal waste under Section 129(e) of the CAA, and to assure compliance with the requirements of 40 C.F.R. Part 70.

Federal Authority: CAA §§ 129(e), 502(a)-(b), 503, 504(a), 42 U.S.C. §§ 7429(e), 7661a(a)-(b), 7661b, 7661c(a); 40 C.F.R. §§ 70.4(b)(3)(i), 70.4(b)(3)(iv), 70.5(a), 70.6, 70.7(b).

Citation of State Laws and Regulations: 5 M.R.S.A. §§ 8001-11008; 38 M.R.S.A. §§ 341-A(1), 341-D, 347-A, 347-C, 348, 349, 581, 582, 585-A, 585-B, 589, 590, 590-A, 591; DEP Regulations Chapters 2, 20, 30, 100 through 140.

Maine law provides authority for the DEP to issue Part 70 licenses to all air pollution sources within the State of Maine. 38 M.R.S.A. § 590 gives the DEP broad authority to issue licenses to persons that may operate, maintain or modify any air contamination source or emit any air contaminants anywhere in the State; and this broad authority includes authority to issue Part 70 licenses for solid waste incineration units combusting municipal waste under Section 129(e) of the CAA.

The Part 70 license requirements of 40 C.F.R. Part 70 are under revision due to litigation in which the State of Maine is a petitioner. Clean Air Act Implementation Project v. EPA (D.C. Cir., No. 92-1303 and consolidated cases). Maine therefore anticipates that future EPA rulemaking may result in new federal requirements concerning Part 70 licenses. The DEP has broad statutory authority which would allow promulgation of any additional state regulations required to comply with any such federal requirements. See 5 M.R.S.A. §§ 8001-11008; 38 M.R.S.A. §§ 341-A(1), 341-D, 585-A, 590. Such regulations would be subject to EPA review as part of Maine's State Implementation Plan ("SIP"). See 40 C.F.R. Part 52.

EPA Region I has raised a concern that three state statutory provisions might allow noncompliance with "applicable requirements" of 40 C.F.R. Part 70: 1) the variance provision in 38 M.R.S.A. § 587; 2) the requirement of an allowance for excess emissions during cold start-ups and shutdowns in 38 M.R.S.A. § 590(3); and 3) the 24-month installation period allowed by 38 M.R.S.A. § 590(6). As far as this office can determine, DEP has never granted a variance under 38 M.R.S.A. § 587. If a license allowance contemplated by 38 M.R.S.A. § 590(3) is prohibited for a Part 70 source by the CAA, it is unforeseeable that DEP would include such an allowance in a Part 70 license since a prerequisite to such a license allowance is that it be "consistent with applicable standards." See also DEP Regulations Chapter 140 § 3(E)(1). The 24-month installation period provision in 38 M.R.S.A. § 590(6) in effect creates a compliance schedule in much the same manner that Title V allows states to issue licenses to noncomplying sources that have submitted a schedule for achieving compliance in their license applications. Furthermore, the EPA 45-day veto provision would allow EPA to veto any inappropriate variance from CAA requirements should one ever be granted by DEP under 38 M.R.S.A. §§ 587, 590(3) or 590(6).

2. AUTHORITY TO ISSUE PART 70 LICENSES TO NONCOMPLYING SOURCES

State law does not prohibit the DEP from issuing Part 70 licenses to a source which is not in compliance with all applicable requirements, and to include compliance schedules in such a license, if a consent agreement or consent decree which addresses the violations and which includes such a schedule of compliance has been entered into.

Federal Authority: CAA §§ 502(b)(5)(A), 504(a), 42 U.S.C. §§ 7661a(b)(5)(A), 7661c(a); 40 C.F.R. §§ 70.5(c)(8), 70.6(c)(3).

Citation of State Laws and Regulations: 5 M.R.S.A. §§ 8001-8064; 38 M.R.S.A. §§ 341-D(1), 347-A(1), 585-A, and 590; DEP Regulations Chapters 100 and 140 §§ 2(B)(11) and 6(E)(3).

Maine law does not prohibit the DEP from issuing Part 70 licenses to a source which is not in compliance with all applicable requirements, and to include compliance schedules in such a Part 70 license, if a consent agreement or consent decree which addresses the violations and which includes such a schedule of compliance has been entered into. Pursuant to 38 M.R.S.A. § 590(2), the DEP may impose appropriate and reasonable conditions as necessary to secure compliance with ambient air quality standards. If an air emission license renewal or amendment can be granted only if the licensee installs additional emission controls or other mitigating measures, then the licensee may continue to emit pollutants up to the level allowed in its existing license as long as the additional emission controls or mitigating measures are fully operational as soon as practicable but usually no later than 24 months after DEP issues the license renewal or amendment. See 38 M.R.S.A. § 590(6).

3. CONFLICTS OF INTEREST

State law provides that members of the State board or body, which approves Part 70 licenses both in the first instance and upon appeal, shall endeavor to avoid the appearance of a conflict of interest by disclosure or abstention.

Federal Authority: CAA §§ 128(a)(1)-(2), 129(e), 42 U.S.C. §§ 7428(a)(1)-(2), 7429(e); 40 C.F.R. § 70.4(b)(3)(iv).

Federal law requires that any board or body which approves licenses under the CAA shall have at least a majority of members who represent the public interest and do not derive any significant portion of their income from persons subject to licenses or enforcement orders. CAA § 128(a)(1)-(2). All Part 70 licenses are issued by either the Commissioner of DEP or the Board of Environmental Protection. On its face, the Maine statutory requirement that members of the BEP "be chosen to represent the broadest possible interest and experience" does not necessarily fulfill the federal requirement. See 38 M.R.S.A. § 341-C(2). The Board, however, is and traditionally has been composed of at least a majority of members who represent the broad public and do not derive any significant portion of their income from persons subject to licenses or enforcement orders under the CAA. DEP employees and BEP members are further governed by the conflict of interest provisions of 5 M.R.S.A. § 18.

4. LICENSE FEES

State law provides legal authority for DEP to assess and collect annual license fees from all sources within the state which are subject to the requirements of Title V of the CAA and 40 C.F.R. Part 70, and to expend the money collected from annual air emission fees to pay for direct and indirect costs required to develop, administer, and enforce the Maine's Part 70 program.

The per ton annual fee ranges from $5 per ton for licensees with up to 1,000 tons of licensed allowable emissions to $15 per ton for licensees with over 4,001 tons of licensed allowable emissions. 38 M.R.S.A. § 353-A(1). Under Maine law the minimum annual fee is $250 per year and the maximum annual fee is $150,000 per year. 38 M.R.S.A. § 353-A(4). Maine law also allows an annual fee surcharge of $10 per every 1,000 air quality units. 38 M.R.S.A. § 353-A(1) and (4). 38 M.R.S.A. § 353-A(9) requires that money collected from the annual air emission fees be used solely for air pollution control activities.

5. LICENSE TERM

State law provides authority to issue all Part 70 licenses for a fixed term not to exceed 5 years. Maine law requires that all Part 70 licenses have a term of five years after the date of issuance.

6. MONITORING, RECORDKEEPING, AND REPORTING

State law provides authority to incorporate monitoring, recordkeeping, reporting, and compliance certification requirements into Part 70 licenses consistent with 40 C.F.R. § 70.6.

7. INSPECTION/ENTRY AUTHORITY

State law provides authority to incorporate into Part 70 licenses inspection and entry requirements consistent with 40 C.F.R. § 70.6(c)(2).

8. INCORPORATION OF ALL "APPLICABLE REQUIREMENTS" INTO LICENSES

State law provides authority to incorporate into a Part 70 license, upon issuance or renewal, all applicable requirements as defined in 40 C.F.R. § 70.2, and as provided generally in the CAA and 40 C.F.R. Part 70.

9. REOPENING OF PART 70 LICENSES

State law provides authority to terminate, modify, or revoke licenses for cause at any time during the license term, consistent with 40 C.F.R. §§ 70.7(f) and (g). State law provides authority to reopen Part 70 licenses when additional acid rain requirements become applicable, regardless of the remaining license term. State law provides authority to revise all other Part 70 licenses with remaining terms of three or more years to incorporate new "applicable requirements" which become effective after issuance.

10. OPERATIONAL FLEXIBILITY

State law provides authority to issue Part 70 licenses which allow changes within a permitted facility without requiring a Part 70 license amendment under certain conditions. State law provides authority for sources to include alternative operating scenarios in Part 70 licenses.

11. LICENSE MODIFICATIONS

State law provides authority to process Part 70 license modifications in a manner that is substantially equivalent to the procedures set forth under 40 C.F.R. § 70.7(e).

12. PUBLIC PARTICIPATION

State law provides authority supporting public participation in DEP's decisionmaking process concerning the issuance, denial, modification or renewal of a Part 70 license. Public participation under State law includes the opportunity for public comment and the opportunity for a hearing on Part 70 draft licenses in accordance with the requirements of the CAA and 40 C.F.R. § 70.7(h). State law allows affected States to review Part 70 license applications in accordance with the CAA and 40 C.F.R. § 70.8(b). An "affected state" for purposes of the Part 70 Program may include New Hampshire, Massachusetts and Vermont.

13. PUBLIC ACCESS TO LICENSE INFORMATION

State law makes available to the public any Part 70 license application, compliance plan, license, and monitoring and compliance certification report, except for information by law entitled to confidential treatment. State law provides that the contents of a Part 70 license shall not be entitled to confidential treatment.

14. ENFORCEMENT OF PART 70 PROGRAM REQUIREMENTS

State law provides civil and criminal enforcement authority to address Part 70 program violations consistent with 40 C.F.R. § 70.11, including authority to seek injunctive relief and to recover penalties and fines in a maximum amount of not less than $10,000 per day per violation. Maine law provides civil enforcement authority including authority to recover civil penalties and fines in a maximum amount of not less than $10,000 per day per violation. 38 M.R.S.A. §§ 349(2) and 349(8). Maine statutes also provide criminal enforcement authority including authority to recover penalties and fines in a maximum amount of not less than $10,000 per day per violation against any person who knowingly violates any applicable requirement. 38 M.R.S.A. §§ 349(1) and 349(3); 17-A M.R.S.A. §§ 34 and 35. See DEP v. Emerson, 616 A.2d 1268, 1271-72 (Me. 1992).

15. AUTHORITY TO ENFORCE PART 70 LICENSES AFTER END OF LICENSE TERM

State law provides authority to enforce the terms and conditions of a Part 70 license which would have otherwise expired in cases where the Part 70 source has filed a timely and complete application for renewal but the DEP has not yet acted upon that application.

16. EPA LICENSE VETO

State law provides that a Part 70 license will not issue if the Administrator of EPA (or her designee) objects in a timely manner to its issuance pursuant to 40 C.F.R. § 70.8(c) or, if the Part 70 license has been issued, but the Administrator or her designee objects pursuant to 40 C.F.R. 70.8(d).

17. JUDICIAL REVIEW OF AGENCY FAILURE TO ACT

State law provides that any aggrieved party may obtain judicial review in State court for the failure of DEP to take final action on an application for a Part 70 license, license renewal, or license revision. 5 M.R.S.A. §§ 11001 and 11002; 38 M.R.S.A. §§ 344, 344-B, 585-A; Maine Rules of Civil Procedure 80-B and 80-C.

18. DEFAULT LICENSE ISSUANCE

State law does not authorize the issuance, modification, or renewal of any Part 70 license merely because of the passage of a specified time period when DEP has failed to take action on the Part 70 application; nor does State law include any provision providing for default issuance of a Part 70 license. See D & J Associates v. Board of Environmental Protection, 560 A.2d 4 (Me. 1989); 38 M.R.S.A. §§ 344, 344-B(1).

19. OPPORTUNITY FOR JUDICIAL REVIEW OF LICENSE ACTIONS

State law provides any person who is aggrieved by a final Part 70 license action an opportunity for judicial review in State court. Any provisions of State law which limit access to judicial review do not exceed the corresponding limits on judicial review imposed by the standing requirements of Article III of the United States Constitution. See In re Lappie, 377 A.2d 441, 442-43 (Me. 1977); In re International Paper Co., 363 A.2d 235, 238-39 (Me. 1976); Fitzgerald v. Baxter State Park Authority, 385 A.2d 189, 196-97 (Me. 1978); Sierra Club v. Morton, 405 U.S. 727 (1972).

20. LIMITATIONS ON JUDICIAL REVIEW

State law provides that petitions for judicial review of a Part 70 licensing action must be filed within 30 days after receipt of notice of the final license action if appeal is taken by a party to the Part 70 license proceeding. Any other person aggrieved shall have 40 days from the date the decision was rendered to petition for review. State law further provides that if the Part 70 license action being challenged is DEP's failure to take final action, a petition for judicial review may be filed within 6 months of the expiration of the time within which DEP's final agency action concerning the Part 70 license should reasonably have occurred. 5 M.R.S.A. §§ 11001-11002; see Post v. State, 605 A.2d 81, 82 (Me. 1992); Brown v. State Department of Manpower Affairs, 426 A.2d 880, 887-88 (Me. 1981).

21. COORDINATION WITH ACID RAIN PROGRAM REQUIREMENTS

State law concerning Part 70 sources is consistent with the Acid Rain Program requirements of 40 C.F.R. Part 72. Maine law requires that Clean Air Act Title IV (Acid Rain) sources located in Maine obtain a Part 70 license. DEP Regulations Chapters 100 §§ 147 and 148, 140 § 1(B)(5). In DEP Regulations Chapter 140 § 4, Maine adopted and incorporated by reference the provisions of 40 C.F.R. Part 72 as in effect on January 11, 1993 and as amended March 23, 1993.

Sincerely,

ANDREW KETTERER
Attorney General
State of Maine
Six State House Station
Augusta, Maine 04333