Dear Ms. Sabasteanski,

Last summer, Dominion Energy announced a transmission constraint in Eastern Loudoun County

that could impact energy availability. The Data Center Coalition (DCC)[1] appreciates that the Virginia Department of Environmental Quality (DEQ) is seeking to help address this constraint by putting forward the concept of a temporary variance as a tool for Dominion, PJM, and the data center industry to work together to minimize any impacts. The variance would allow data centers to continue to serve their customers, maintain the integrity of the internet, and alleviate demand on the electric grid during periods of acute stress, if necessary, through the use of on-site emergency back-up generators.

Several states provide formal demand response, load curtailment, and similar programs that allow large users of electricity the option of shedding load to benefit other commercial and residential customers when there is acute grid stress or occasional demand peaks. Virginia does not currently have a formal program. The proposed variance is intended to provide greater resiliency, redundancy, and robustness within our regional electrical grid while long-term solutions are developed and implemented.  

It is important to note that utilization of the variance will be optional and only available in the event a utility provider signals it is necessary. Furthermore, emergency back-up generators will continue to be subject to active monitoring, reporting, and regulatory oversight during any limited periods of run-time. This ensures accountability and effective communication and coordination to minimize the use of emergency generators while collecting critical data required to further strengthen the grid. 

We recognize that DEQ proposed the variance extend to the counties of Prince William and Fairfax out of an abundance of caution. However, given Dominion’s assurance that the impact of the transmission constraint is limited to Eastern Loudoun County, we believe there is an opportunity to be more precise in addressing potential risks. We respectfully request that DEQ limit the scope of the variance and order specifically to Loudoun County as a mitigation strategy to address the electrical transmission capacity constraint within Eastern Loudoun between the months of March 2023 and July 2023.  

DCC appreciates the support of the Administration and DEQ in working with the industry, Dominion, PJM, and other stakeholders in continuing to identify and implement solutions to address the Eastern Loudoun transmission constraint and ensure a strong, resilient, and reliable power grid for all customers.

Thank you for providing the opportunity to comment.