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.