December 7, 2021
Via electronic mail
Air Regulation and Data Analysis Section
Bureau of Air Quality
2600 Bull Street
Columbia, SC 29201
Re: Requesting Extension of Comment Period for South Carolina’s Regional Haze State Implementation Plan for the Second Implementation Period
On behalf of the National Parks Conservation Association, the Sierra Club, and the Coalition to Protect America’s National Parks1See public notice https://apps.dhec.sc.gov/Environment/PublicNotices/SearchAndDisplay/Display/21057 . Specifically, we ask that the current deadline for comments be extended by 30 days to Friday February 4th, 2022.
For review of the proposed SIP, SCDHEC has provided interested stakeholders with just 40 days to evaluate and provide comment regarding over 250 pages of legal and technical analysis, as well as numerous appendices with VISTAS modeling information, state consultations, and so forth2See South Carolina pre-hearing draft SIP and appendices https://scdhec.gov/environment/air-quality/regional-haze-program . Further, those 40 days include winter holidays during which the Conservation Organizations’ employees will not be working. Given the scope, volume, and complexity of this information, the Conservation Organizations believe that the current comment period is not sufficient to fully analyze the potential impacts of the proposed SIP and provide meaningful comment. Reviewing SCDHEC’s legal and technical analysis along with its modeling, conducting any necessary analysis, and developing comments will take more time than allowed by the current comment period, which ends on January 5th, 2022.
Our need for an extension is further justified by the fact that among the documents and appendices provided by the state, critical information is missing. SCDHEC did not include their responses to Federal Land Manager (FLM) comments in the information made publicly available on their site3See Appendix H-1, Federal Land Manager Comments and Responses https://scdhec.gov/environment/air-quality/regional-haze-program . This information is necessary for the Conservation Organizations to respond fully and accurately to the proposed state implementation plan. We request that in addition to a 30-day extension, responses to FLM comments be made publicly available as soon as possible.
An extension of time will not adversely impact any other party. A 30-day extension of the deadline will not prejudice any regulated entity and will not materially affect SCDHEC’s ability to submit its SIP to EPA within a reasonable time. The additional time, by allowing Conversation Organizations to meaningfully participate, would aid SCDHEC from having the benefit of our contributions for their consideration and thus allow SCDEHC to make a more informed decision in the end. Conversely, given the scope and complexity of the proposed SIP, the current deadline for comments will effectively preclude the Conservation Organizations from reviewing all of the relevant technical data supporting the rule, fully analyzing those voluminous files, and providing meaningful legal and technical comments. Moreover, if finalized without our ability to give the proposal full due diligence, the proposed SIP could adversely affect the Conservation Organizations’ interests in pollution reduction and the environment, as well the health and welfare of our members and their use and enjoyment of protected national parks and wilderness areas.
We appreciate your considering this request and respectfully ask that you grant our request by December 10, 2021, so that we can plan comments most efficiently.
|Lilly Anderson |
Southeast Clean Air Coordinator National Parks Conservation Association
|Josh Stebbins |
Coalition to Protect America’s National Parks
- 1See public notice https://apps.dhec.sc.gov/Environment/PublicNotices/SearchAndDisplay/Display/21057
- 2See South Carolina pre-hearing draft SIP and appendices https://scdhec.gov/environment/air-quality/regional-haze-program
- 3See Appendix H-1, Federal Land Manager Comments and Responses https://scdhec.gov/environment/air-quality/regional-haze-program