The Attorneys General of six northeastern states, plus California and D.C., are urging the South Carolina Department of Health and Environmental Control (SCDHEC) not to issue an air quality permit to Santee Cooper for a proposed new 1320 MW coal-fired power plant on the Great Pee Dee River without first putting in place mechanisms to reduce CO2 emissions from the proposed facility. In a letter to the SCDHEC dated January 22, 2008, the attorneys general conclude that the facility as proposed would emit more than 9 million tons of CO2 per year, thus more than cancelling out the CO2 reductions obtained by RGGI through its operative time frame. In reliance on Massachusetts v. EPA, the letter asks the agency to place BACT emissions limits on CO2, and also requests that the agency consider siting, "so as to allow for full-scale carbon capture and sequestration" and/or requiring the facility to employ IGCC technology.