The South Carolina Office of Regulatory Staff (ORS) offers these comments for consideration and respectfully requests that the Environmental Protection Agency (EPA)

(1) withdraw or reconsider its proposed rule and

(2) request the Federal Energy Regulatory Commission (“FERC”) to have the North American Electric Reliability Corporation (“NERC”) perform a detailed reliability assessment to evaluate the impacts of the Proposed Rule, including any suggested modifications to add flexibility to ensure reliable, affordable electric generation while simultaneously encouraging further carbon reductions.

ORS Initial Brief - EPA Rule 111

• Exhibit A

• Exhibit B

• Exhibit C

• Exhibit D

• Exhibit E

• Exhibit F

• Exhibit G

• Exhibit H