State Implementation Plans

Myra Reece

Bureau Chief, Bureau of Air Quality

SC DHEC

Karen Sprayberry

Program Coordinator, Bureau of Air Quality

SC DHEC
OBJECTIVES

• Discuss SC DHEC’s EJ Efforts

• Discuss SC’s Approach to Rule 111(d)

• Discuss State Implementation Plan

• Provide Tips for EJ Communities
EJ & Public Participation

Plan EJ 2014 Goals

• Protect environment & health in overburdened 

communities

• Empower communities to take action to 

improve their health & environment

• Establish partnerships to achieve healthy & 

sustainable communities
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SC’s Partnerships: SC EJ Advisory Committee

• Formation – 2007, H.3733/Act 171

• Governmental Advisory Committee to SC DHEC

 Attorney General’s Office; Agriculture; Commerce; Education; Health & 

Human Services; Labor, Licensing & Regulations; DNR; PRT; Public 

Safety; DOT; USC-Arnold School of Public Health; Clemson University 

– Community & Economic Development; S. C. State University; State 

Ports Authority

• Study & consider EJ issues in economic 

development & revitalization

• January 2010 – Findings/recommendations to 

Governor & General Assembly
SC Partnerships: EJ Cooperative Agreement

• 4 Pilots

• Build capacity while 

identifying 

environmental/social 

justice issues

• Support & Resources 

provided
SC’s Partnerships: SC Environmental 

Leadership Forum

• Build leadership capacity within 

communities with environmental 

concerns

• Educate participants on regulatory 

roles, responsibilities, and 

environmental programs

• Strengthen partnerships among 

community leaders, businesses, local 

government officials, industry, and 

other stakeholders

• Spread awareness of environmental 

justice

• Strengthen environmental justice 

communities from within
South Carolina’s Plan for

Meeting EPA’s Clean Power Plan

Myra Reece, Bureau Chief, BAQ

EPA Community Workshop

October 30, 2014
EPA’S CLEAN POWER PLAN

“Take Aways”

• Most complex, challenging rule yet

• Every single stakeholder has a vested interest in this 

proposal

• “Not your ordinary state implementation plan”

• As a result of the above, states have a lot of work and 

heavy lifting to do....need EJ communities at the table
Most Complex, Challenging Rule Yet

• Politically/emotionally charged issue...messaging 

is key

• Ultimately, states are facing a challenge that 

Congress couldn’t meet... “the ultimate test”

• > 1100 pages (rule & supporting documents)

 Media questions on day 1

 5 months later....still have unanswered questions

• Numerous legal questions.....litigation is evident

 Using Section 111 (Clean Air Act)
Every Stakeholder has a vested interest in 

this proposed rule & their state plan

• SC Leadership: Governor, Attorney General, Congressional 

Delegation, State Legislature

• Electricity Providers/Regulators: Utilities, Electric Cooperatives, 

Public Service Commissions

• State Agencies: Energy Office, Dept of Natural Resources, Coastal 

Resource Management, Governor’s Office of Economic Opportunity 

...

• Small & Large Businesses: Energy consumers, Clean 

Energy/Technology Opportunities, Energy Efficiency 

• Environmental & Health Advocates, Academia

• EJ Communities 

• ALL South Carolinians (energy consumers, students, retirees..)
“Not your ordinary state implementation plan”

• Goes beyond air quality......

 This rule combines energy and environmental policy

• The beginning of a new era for state energy & environmental 

regulators

 Additional regulatory authority may be needed ... 

legislative approval

• SC’s Message: “Will be a STATE PLAN, NOT A 

DHEC PLAN”

 Important for us to get this right, “least cost” approach 

for SC in lieu of a federal plan
SC DHEC’S Approach to Rule 111(d)

“111(d) Utopia”

• Energy coalition formed August 2013: 

 SC DHEC, Utilities, Public Service Commission, Electric 

Cooperatives, Energy Office, Environmental Advocates, EJ 

Community Leaders 

• Data/Building Blocks/Outcomes Workgroups

• Efforts to shape/improve EPA’s proposed & final rule

• Important to SC: flexibility, credit for early actions, 

maintain affordable reliable energy

• Prefer State Compliance Plan (SIP) versus the 

alternative...a Federal Implementation Plan (FIP)...
What SC stakeholders are saying....

• “Making EE/RE federally enforceable is a problem” (legally & 

ethically)”

• “Timeline is too aggressive for putting together such a critical 

& important plan for SC....and one that EPA will approve”

• “Just because we invested in nuclear energy doesn’t mean 

we shouldn’t do more with EE/RE”

• “Regardless of what we do or not do...It’s important that we 

get this RIGHT for SC (guiding principles)”

• “EPA’s treatment of “under construction” nuclear energy is not 

allowing us to take credit for future zero carbon emissions”

• “Just let us keep doing what we are doing”
What’s Happening Right Now?

• Focusing on our 111 (d) comments 

 Coalition consensus & separate comments

 Continuing to ask EPA a lot of detailed questions

• Meetings, dialogue....& presentations

 Clean Energy & Technology businesses; Chamber meetings, 

regional, state & national forums

• Encouraging everyone to submit comments to 

EPA, get engaged and keep up with the latest

 www.scdhec.gov/HomeAndEnvironment/Air/cleanpower/
What Happens Next?

• Not waiting for the final rule or court decisions

• Continuing our collaborative efforts with all 

stakeholders...not developing a plan yet....but 

preparing SC for the final rule

• Branching out....public & local clean air coalition 

meetings...and reducing carbon emissions

 Focusing on energy efficiency (poverty 

counties first)....as we would be doing anyway


EJ Community Tips – Clean Power Plan

• States are “in the driver’s seat” on this one

 Know and build a good working relationship with your 

state air quality regulators and EJ contacts...branch out 

from there to other key partners (utilities, energy 

office,...)

• Do your homework...don’t wait for the final rule

 Find out if your state plan will need legislative approval

 Know your state’s carbon emissions “report card”

 Acknowledge past, present & future opportunities
HOMEWORK EXAMPLES...



24

SC Electrical Generation by Fuel, 2013

2% 2%
Our Strategy as the process continues... 

25

A Dialogue/Collaborative Spirit ...
TIPS for EJ Communities

• Who are your stakeholders?

 Think outside the box for this Rule

• Begin a dialogue and work towards building 

relationships

 Consensus?!?

• Provide Useful/Factual Comments

• Education is not easy, but is key!

• Messaging is even more important!
Myra Reece – reecemc@dhec.sc.gov Karen Sprayberry - spraybkj@dhec.sc.gov