Fewer is better, but still not good enough. We need to change the practice of using diesel generators as a back-up power source NOW and then consider a variance.

It is past time for the data center industry to stop using diesel generators as a back-up power source even without a variance. There is far too high a concentration of data centers near homes and WAY too many more coming for the industry to continue this general practice, let alone allow those generators to be used even more extensively. Poor government planning has created a malaise of fear and loathing for this industry as citizens wonder if their homes will be the next ones inundated with industrial noise and toxic fumes.

It is in everyone's best interest, even the industry's, that the response be to heed citizens' calls to cease using diesel generators and move to a more sustainable and health-risk-free alternative and then you can have your variance. Stop solving corporate problems on the backs of citizens, and we will all get through this new industrial revolution of digital infrastructure more peacefully and with better relationship to industry.

Again, please don't set the precedent of allowing more diesel pollution during our worst air quality days and so near our homes. Put the onus on this billion dollar industry now instead of further burdening citizens with further health risks and even further diminished quality of life. The litmus test should be would you allow entire banks of diesel generators next to your home to run for extended periods of time while your kids played 100 feet away? If not, don't set that precedent for us.

Please do not approve 

Simple.  The citizens get nothing out of data centers being allowed to pollute.  I suggest every time a data center is allowed to pollute government exempt citizen’s vehicles from emission standards for that period as well, and prorate our mandatory emissions tests costs.

Yeah I didn’t think so.  So no to allowing data centers exemptions either.

DEQ’s minor backtracking on its ill-advised proposal to allow “data centers a measure of relief from existing regulations” is a shameless attempt to repackage a lousy idea.  If we didn’t like data center’s full-strength poison, we don’t want their reduced calorie version either. 

I’m still waiting to see any concession whatsoever from the data center industry to address the problem they have created.  So far, all we have seen from them is relentless lobbying for special favors.  When will DEQ provide the public a “measure of relief” from them?

DEQ is supposed to protect the health and well-being of Virgina's citizens, not the profit margin of wealthy corporate predators.

Do your job, please.

Please do the right thing for the future of our lives and planet.  Do not decrease regulations. We need to breathe to survive, let alone thrive.

Thank you.

What are the environmental permits and regulations required for Data Centers and where is this published?  

Given that the citizenry in the atmospheric area are likely to be subject to known asthma-inducing and cardiovascular-impairing particulates from generators due to an energy shortage in the grid, primarily caused by Data Centers, where is the accountability for reporting out the energy usage by this sector?  As part of the DEQ emergency action, for transparency to the public, and to inform future planning decisions related to capacity, all Data Centers, and/or the energy providers, should be required to report out energy usage to the public.

Similarly, a usage that may impact the region’s drinking water supply should also be reported out to the public through the local water companies and data center operators to DEQ.

Generators require Diesel fuel - are they considered “hot spots” and are there any requirements for oil separators or concrete containment curbs for the fuel storage?

Are they subject to the noise ordinances of the localities?

Since when does pollution and air quality have boundaries?  Removing PWC & Fairfax from the proposal doesn't address the issue.  Polluted air and global warming don’t have  boundaries.  The air quality in Loudon impacts the entire area including PWC & Fairfax.  How could anyone think otherwise?

Carol Cuddihy

6123 Beton Ct

Gainesville, VA

We have lived here in Prince William County since 2000 and the air pollution and the quality of life here has gotten worse every year.  I'm opposed to allowing generators for not only the air pollution but the noise.  With the removal of so many trees here and the addition of asphalt our air quality is so bad we have more summer days when senior citizens are warned about heat stroke etc.  I cannot believe that you are allowing something so blatantly awful to be added to our quality of life.  

Thanks.

The data centers are a blight on the Rural Crescent in Prince William County and in violation of what a demonstrated majority of Prince William County residents want as well as the established comprehensive development plan.  I am against any accommodation to data centers in our air quality non-attainment area, inclusive of DEQ's proposed revised environmental variance.  For DEQuality to worsen air quality makes DEQ an oxymoron.

Virginia rates 8th in the country in air toxins. According to the figures in this variance, if each generator in Loudoun County ran the average of 24 hrs per year, that is over 17,000,000 (seventeen million) gallons of diesel fuel vapors emitted into the atmosphere releasing hazardous pollutants contributing to irritation of the eyes and nose, headaches and nausea, respiratory disease, and lung cancer.  From the EPA website: "Environment - Emissions from diesel engines contribute to the production of ground-level ozone which damages crops, trees and other vegetation. Also produced is acid rain, which affects soil, lakes and streams and enters the human food chain via water, produce, meat and fish." The health and welfare of citizens in our Commonwealth are more important than the Almighty Dollar from data centers. Do not allow the implementation of this Variance

There is absolutely no science to allow a government agency like DEQ to have the ability to waive critical pollution control measures in favor of a multibillion dollar data center industry.

Small particulate diesel pollution becomes embedded in the lungs of people with the elderly and children most affected. In addition the small particles easily cross into the blood vessels of the body and travel to various organ systems potentially leading to cancer.

Is your agency really willing to sacrifice entire populations because a local government issued too many building permits for energy hungry data centers?  It sounds like the stuff that lawyers would love to litigate- "JUST SAY NO" to any DEQ variances to allow diesel generators to run during energy shortages.

If data centers can't maintain their availability standards it may cost them money when they don't meet the service level agreements they committed to in their contracts.  It could cost them money.  That is how it should be.  It will provide financial incentive for better planning relative to data center development in line with grid capacity.  If the DEQ bails them out with a pollution solution, not only does the DEQ incentivize future poor planning, you ask the citizens to cover these mistakes with their health and quality of life.  It would be wrong and it would encourage more problems like this in the future.  Data center developers and local governments created this problem.  Do not ask the citizens to pay for it with their health.

PEC president Chris Miller says that information is of limited value. “Without information about how many hours and how many generators are expected to run and where they will be running,” he wrote in response to the update, “we don't have enough information to really understand the impact of this proposal. The regulated emissions [listed in the new variance) are precursors that contribute to regional ozone formation and particulate pollution that affects public health and the broader environment.”

Miller remained skeptical about DEQ’s assertion that it doesn’t anticipate that “any data center will need to use this variance.” He and others have asked why, if that’s the case, the variance is needed — and whether the department has encouraged the industry to seek alternative options, such as reducing operations for a season.

“The Virginia Department of Environmental Quality protects and enhances Virginia’s environment and promotes the health and well-being of the citizens of the commonwealth. We are committed to cleaner water, improved air quality and the productive reuse of contaminated land.”

I continue to oppose the requested variance.  Although the geographic area has been limited since the original proposal, insufficient information has been provided regarding the environmental and public health impacts of increased air pollution on the neighboring counties.  It is difficult to comment intelligently on the revised proposal without more information. 

If the prevailing winds carry the pollutants from the diesel generators in Loudoun County into Fairfax County or elsewhere, what are the consequences?  Those impacts are not sufficiently explained to the public in the revised notice.   Until the effects on the environment and public health are known, and clearly explained to the public, including the impacts to Fairfax County, it is both premature and irresponsible for DEQ to authorize an increase in air pollution, even if it were limited to the Loudoun County data centers alone. 

Are the additional pollutants that will be released from the diesel generators known carcinogens?  Are the pollutants the type of chemicals that reduce the ozone layer?  What are the effects of these particulates on cardiovascular and respiratory health, including asthma and allergies?  What are the effects of these chemicals on vegetation and water quality?  What responsibility does the industry have for additional illnesses or hospitalizations resulting from increased air pollution, and how will that responsibility be determined after any variance is granted?  These important questions have not been answered.

If the existing electrical infrastructure is insufficient to handle the electrical needs of the data centers already constructed, that is the fault of the politicians responsible for the approvals.  The burden ought to be on the data center industry to resolve their problems within existing pollution standards.  That burden ought not be shifted to the lungs of the public.  The data center industry also must aggressively develop cleaner technology for backup power, and not rely on dirty diesel generators.   

DEQ's responsibility is to protect the public from the polluters.  DEQ ought not fashion excuses for the data centers to violate air pollution standards, temporarily or otherwise.  And the expense of any upgrades to the electrical infrastructure should be borne by the industry generating the problem, not on the consumers who are the victims of this unnecessary situation.  Until adequate information can be provided to the public regarding the impacts of the proposed variance, the request should be denied.

We are adamantly opposed to the governor's plan to withdraw Virginia from the Regional 

Greenhouse Gas Initiative!!!!

Affording any exception to allow for the running of diesel generators 24/7 is irresponsible to our environment and the residents of loundon county. 

Please do not allow this. How  are you going to possibly protect the homes and citizens nearby?

Even if the waiver is limited to just Loudoun County, it does not eliminate the issues - air pollution and noise issues.  Both can negatively impact the health of residents.   Why should residents be impacted when data center developers and Dominion did not plan accordingly.

To add, there are other potentially serious environmental impacts.  DEQ HAS THE RESPONSIBILITY TO TAKE THE LEADERSHIP IN THIS AREA.  Study first.   Understand the impacts.  Protect residents!

Roger Yackel

HOA Roundtable

The electric grid will not be stable for several more years and VA residents should not bear the additional burden of air pollution due to local and state greed for revenue and their continued willful disregard of power availability prior to approval of Data Centers literally in homeowners back yards. Approval of this revised Variance could establish a precedent for years and I urge you to not approve it. 

It doesn’t matter where you run the generators, it will pollute the air and have detrimental affects on the humans, wildlife, water and air quality.  Please do not think that the residents of PWC, Loudoun or Fairfax are ok with running generators anywhere! We are all people who deserve to be protected by the DEQ, our local leaders, and our communities. 

The DEQ must not be compormised by Big Business who wants to circumvent environmental safety measures for the benefit of Data Center operators. The amount of pollution per generator is staggering and to have thousands in operation during peak energy demands will compromise the health of the entire region especially children and the elderly.  NO to the variances- period.

TOXIC DIESEL EXHAUST

On an equal horsepower basis, Diesel Exhaust is 100 times more toxic than gasoline exhaust even when carbon monoxide is considered.  Diesel Exhaust contains multiple other known carcinogens for humans as determined by the International Agency for Research on Cancer (IARC) of the World Health Organization of the United Nations as presented in their List of IARC Group 1 Carcinogens. 

 

Diesel Exhaust is a mixture of gases, vapors, liquid aerosols and substances made up of particles. 

 

Diesel Exhaust may contain Carbon (soot), Carbon Monoxide, Carbon Dioxide, Oxygen, Water Vapor, Ammonia, Nitrogen, Oxides of Nitrogen (e.g., Nitrogen Oxide, Nitrogen Dioxide), Oxides of Sulphur (e.g., Sulphur Dioxide), Alcohols, Aldehydes, Ketones, Hydrocarbons,  Aromatic Compounds such as Benzene and Polycyclic Aromatic Hydrocarbons (PAHs), Diesel Particulate Matter; Arsenic,  Benzene, Formaldehyde, Nickel and Toluene. 

 

Diesel Exhaust is a Group 1 carcinogen causing lung cancer and has a positive association with bladder cancer.  It is also a major source of “Fine-Particle” pollution, especially hazardous to the elderly and people with COPD, emphysema, asthma, plus chronic heart and lung disease.  

 

Diesel Exhaust particles and gases are suspended in the air and exposure occurs whenever a person inhales them.  These microscopic particles (less than one-fifth as thick as a human hair) are small enough to penetrate deep into the lungs and contribute to many health problems. 

 

Diesel Particulate Matter (DPM) is primarily made up of Soot Particles, Carbon, Ash, Polycyclic Aromatic Hydrocarbons (PAHs), Metallic Abrasion Particles and Sulfates with most being Respirable (particles in the air that are breathed-in) that travel deep into the lungs with normal inhalation.   

 

Exposures are highest where diesel traffic is heaviest, such as along major highways, near major construction sites and large diesel generators. 

 

People spending time on or near roads and freeways, major construction sites, near large diesel generators, plus truck loading and unloading operations face exposure to higher levels of Diesel Exhaust and face higher health risks with the very young, the very ill and Senior Citizens at greater risk here. 

 

G. Allen Weaver, DVM, PhD, Esq

Gainesville, VA  20155

 

I am writing in support of the proposed variance. I trust the VA DEQ to evaluate the emissions generated and if a variance is warranted for the limited duration, I trust the scientists and decision makers at the DEQ to make those calls. 

I read through the Notice and it appears to impact only data centers in Loudoun County, and does not affect other data centers in other counties such as Prince William.  As citizens we count on DEQ to rigorously follow the science and data in making decisions on issues like this, and to not consider comments motivated by political or personal interest for those decisions. 

There is a loud group of NIMBY (Not In My Back Yard) and BANANA (Build Absolutely Nothing Anywhere Near Anything) interests in Prince William who are throwing every objection they can dream up to stop the Prince William Digital Gateway project for their own personal interest.  This project has already been through multiple rounds of review by multiple government agencies and has more yet to go.  An aggressive communications and misinformation program has rallied people to its cause.  There is also a less organized group of property owners who would stand to benefit economically if the project were to be completed.  These people have weighed in on occasion but in more muted terms and actions.

My encouragement to the Department is that neither of these opinions should have bearing on decisions that are supposed to be made on environmental and broad (state or county level) economic criteria.  Please evaluate your sources of information carefully.  If environmental considerations support the waiver being issued, political agendas and personal interests should not stand in the way of approval.  And if similar waivers are needed elsewhere (such as Prince William) they should be subject to the same criteria.

It isn't clear how this variance -- which extends diesel generator use to the data center industry in an already crumbling infrastructure -- will improve our state carbon footprint. One would think our health and collective carbon footprint would be better served by requiring the data center industry to come up with more practical and environmentally friendly alternatives that do not toss out harmful pollutants. 

Virginia Department of Environmental Quality was created to protect the public -- not to meet the needs of a billion dollar industry that has the money, abilities, and one would think research and development to properly run their centers in an environmentally way that lowers, not heightens, possible health impacts to humans and wildlife. Prince William Conservation Alliance urges DEQ to require the data center industry fall in line with existing guidelines. Whether or not it costs the data center industry should not be of our or DEQ's concern. The cost of human health and environmental safety should be paramount, concurrent with the DEQ mission. 

We strongly oppose the proposed variance that would allow backup use of diesel generators by data centers in Loudoun County, even though the variance no longer includes Prince William and Fairfax Counties.

To quote the DEQ website, "DEQ's Mission is to protect and enhance the Commonwealth's citizens, residents and visitors in accordance with applicable laws and regulations."

"DEQ's Vision is that all Virginians enjoy cleaner water, better air quality and the productivereuse of land that was once contaminated."

The Prince William Board of County Supervisors, in its headlong rush to approve a massive data center complex in an environmentally sensitive and populated area, is already running roughshod over the DEQ's mission and vision.  A variance allowing use of diesel generators in Loudoun County will likely be viewed as precedent-setting, encouraging them to seek a DEQ revisit and approval of a Prince William variance as well. And that, of course, would open the floodgates for other Virginia localities where data center proposals are already cropping up.

The widespread data center footprint currently in place or envisioned for Northern Virginia will damage air quality, water quality, the environment and quality of life in general.  Adding proliferation of diesel generators will only make matters worse in terms of noise and air pollution (including carbon monoxide).

We strongly urge the DEQ to take a firm stand against the Loudoun variance and stop this environmental menace in its tracks.  In short, simply adhere to your own mission and vision.

As a resident of Loudoun County for 39 years I strongly urge that you not to allow a variance for Dominion Energy to operate diesel generators to run data centers 24/7 simply due to poor planning.  To allow this is simply absurd.

Virginia Department of Environmental Quality was created to protect the public -- not to meet the needs of a billion dollar industry that has the money, abilities, and one would think research and development to properly run their centers in an environmentally way that lowers, not heightens, possible health impacts to humans and wildlife. I urge DEQ to require the data center industry fall in line with existing guidelines. Whether or not it costs the data center industry should not be of our or DEQ's concern. The cost of human health and environmental safety should be paramount, concurrent with the DEQ mission. 

I strongly urge the DEQ to take a firm stand against the Loudoun variance and stop this environmental menace in its tracks.  In short, simply adhere to your own mission and vision.

DEQ's mission is to protect the environmental Virginia in order to promote the health and well-being of the Commonwealth citizens, residents and visitors in accordance with applicable laws and regulations. The proposed DEQ variance is directly opposite its proposed mission. If you think polluted air will NOT drift to PWC and Fairfax County you are sorely incorrect. Put the onus on the billion-dollar industry to develop technologies that will not be so power greedy. Allowing a variance is a slippery slope that allows undue health risks to the Commonwealth. I am opposed to this variance. 

I do not support any variance to run diesel engines at the data centers. This is exactly why there should be a moratorium on building more data centers in this area. The health and welfare of the environment and the people that live here should not be sacrificed for recklessness and irresponsibility of DEQ, the data center industry and our corrupt politicians who cater to their invested interest in greed.

PWC resident 

Allowing the air to be polluted affects all surrounding localities since air, and the pollution in it, travels. Requiring Data Centers to contribute to the expansion of the grid and having a rotational schedule with strict time/day limits might be a better alternative.

Unfortunately, this variance also relies on on self-monitoring.  Given the “fraud triangle” (https://uvamagazine.org/articles/honor_up_close) is self-monitoring wise? Where is the check and balance?

No one will live or die if 50% of the data centers cannot operate but someone may die if their air is polluted. Let's avoid that and find other solutions.

Regards,

-Cynthia Shang

Having a lot of data centers in Ashburn which needs a lot of water for cooling itself is a big drawback. We also have enough fiber optic running under ground. Lot of greenery has also been removed by deforestation. Why are we being so greedy as a county? Aren't we getting enough revenue? Is there something that the public is missing that the county officials have? 

Can we atleast save the environment by saying no to diesel? Really in this era and world we are living in do we need more pollution? 

The challenge of pollution and global warming is no longer the science, or the rate of innovation, but the rate of implementation: We have the clean solutions; let's bundle them and install them. Please reconsider the implementation and use of Diesel Generators in Loudoun county, with a population of 65,000 or more. Why? 

Exposure to diesel exhaust can lead to serious health conditions like asthma and respiratory illnesses and can worsen existing heart and lung disease, especially in children and the elderly.  These conditions can result in increased numbers of emergency room visits, hospital admissions, absences from work and school, and premature deaths. Emissions from diesel engines contribute to the production of ground-level ozone which damages crops, trees and other vegetation.  Also produced is acid rain which affects soil, lakes and streams and enters the human food chain via water, produce, meat and fish. The negative impacts are endless......... 

The government, organizations should be advocating for cleaner energy resources and not revert back to the resources which from time to time have been proven to be harmful to human kind. Let's leave a better place for our generations to come. 

Please stop this from happening. It’s a big health risk for people living around ashburn and nearby towns. Please put people interest first over big businesses. 

No diesel generators

airpollution

noise pollution

living standards

kids

I oppose DEQ's proposed variance to allow data center diesel generators to operate continuously during periods of peak electrical load. 

High risk to lives, health and happiness index for loudoun county

Solve energy issues permanently instead of relying on cheap hazardous alternatives 

I oppose DEQ’s proposed variance to allow data center diesel generators to operate continuously during periods of peak electrical load.  Let the data centers develop a plan for selective service reductions to address the problem THEY are causing.

The DEQ’s mission is to protect and enhance the environment of Virginia to promote the health and well-being of the Commonwealth’s citizens, residents, and visitors in accordance with applicable laws and regulations.

After reading the details, These DG sets are not built to the stringen standards laid down by EPA. They are a cheaper solution to the expensive Gas based ones. The gas based ones are less polluting and environmentally friendly.

I oppose DEQ’s proposed variance to allow data center diesel generators to operate continuously during periods of peak electrical load.  Let the data centers develop a plan for selective service reductions to address the problem THEY are causing.

The DEQ’s mission is to protect and enhance the environment of Virginia to promote the health and well-being of the Commonwealth’s citizens, residents, and visitors in accordance with applicable laws and regulations.

Having so many data centers and airport it’s life with chlorofluorocarbons which is dangerous and causes health risks , so please rethink about having to many data centers in one county. 

Please do not allow these Data Centers to pollute our air. They are already destroying our communities and neighborhoods. Do not grant them the permission to spread deadly pollutants into the air surrounding our homes. ENOUGH IS ENOUGH!!!

Diesel generators substantially reduce air quality in the nearby regions.

It is not good for the health of the people who live in nearby area.

We should leave better environment for our children.

Please do not allow proposed variance.

I oppose DEQ’s proposed variance to allow data center diesel generators to operate continuously during periods of peak electrical load.  Let the data centers develop a plan for selective service reductions to address the problem THEY are causing. 

The DEQ’s mission is to protect and enhance the environment of Virginia to promote the health and well-being of the Commonwealth’s citizens, residents, and visitors in accordance with applicable laws and regulations.”

In terms of environment, we already reached a point that would demand drastic changes in our lifestyles across globe. I am not sure whether next generation can enjoy this Mother Earth as much as current generation did. I strongly believe that we should try and do our best to fix this mess before we hand it to our kids..

Exposure to diesel exhaust can lead to serious health conditions like asthma and respiratory illnesses and can worsen existing heart and lung disease, especially in children and the elderly.  These conditions can result in increased numbers of emergency room visits, hospital admissions, absences from work and school, and premature deaths. Emissions from diesel engines contribute to the production of ground-level ozone which damages crops, trees and other vegetation.  Also produced is acid rain which affects soil, lakes and streams and enters the human food chain via water, produce, meat and fish. The negative impact is heavy.

We should go with cleaner energy approach and create healthy environment.

Loudoun County has the highest concentration of data centers in the world. It is their high power consumption that has resulted in grid instability and an increasing frequency of power warnings and alerts. Due to concerns that there may not be a sufficient amount of electricity for data centers this year, DEQ is proposing an order that will allow this industry to operate backup diesel generators outside of state air pollution control regulations.

Uncontrolled access to the land parcels for building data centers is not acceptable, that also needs to be curbed.

THIS ALLOWACE WILL LEAD TO A CLEAN AIR ACT VIOLATION. PLEASE PAY DUE ATTENTION AND APPLY DUE DELIGNECE.

This exemption will result in an unknown increase in air pollution and emissions. Contaminants such as NOx, CO, VOC, SO2, and particulate matter are known to have severe impacts on human health, the environment, and the climate.

I hope you do not follow through on this order.

However, at a minimum, DEQ needs to provide:

- More information about the potential impact on public health and the environment,
- An analysis including a calculation of greenhouse gas emissions
- Maintain some sort of regulation on operation when the variance is triggered,
- Require real-time monitoring of pollutants, and establish an alert system that notifies residents of affected communities (especially children, elderly, and those with underlying conditions) when generators will be running so they can take precautions.

As data centers continue to be built in Northern Virginia the pressure on the grid will likely increase resulting in more of these orders exempting the industry from state air pollution control regulations. For this reason, I would also urge DEQ to develop a regulatory plan for requiring the industry to phase out diesel generators and replace them with battery storage and less polluting back-up power systems.

Thank you for considering my concerns.