February 27, 2023

Karen G. Sabasteanski
Office of Air Data Analysis and Planning
Department of Environmental Quality
PO Box 1105
Richmond, VA 23218

Dear Ms. Sabasteanski,

On behalf of the more than 1,200 member businesses and other employers of the Prince William Chamber of Commerce, I write in support of a temporary local variance for the operation of emergency generators by data centers in the Counties of Fairfax, Loudoun, and Prince William.

The proposed Department of Environmental Quality (DEQ) variance is limited in the scope of geography and duration to address electrical transmission capacity constraints between March and July.

The proposed variance will enable regulators and industry partners to address the transmission capacity challenges without unnecessary risk or emissions. Data centers are uniquely suited to provide emergency capacity to the electrical grid in times of constraint, as they are capable of operating on backup generation and removing themselves from traditional power distribution.

Any utilization of the variance remains optional and contingent on notice from utility providers, to ensure generators are subject to active monitoring, reporting, and regulatory oversight during any limited periods of run-time.

The proposed temporary variance offers a valuable opportunity for electric utilities, PJM Interconnection and the data center community to work in partnership to create to strengthen our regional electrical grid while a long-term solution to our capacity challenges are worked out.

Although Virginia is the global leader in data center infrastructure, the Commonwealth lacks a formal “Demand Response” or “Load Curtailment” program, such as California and Texas have. These programs require time, resources, and considerable effort to establish. The Prince William Chamber considers the variance to be a reasonable step to ensure service reliability to residential and commercial ratepayers.

Thank you for providing the opportunity to comment.

Sincerely,

Robert Sweeney

President & CEO

Prince William Chamber of Commerce

9720 Capital Court

Suite 203

Manassas, VA 20110