Hello.  My name is Natalie Pien and I am writing to oppose issuing AN ORDER GRANTING A TEMPORARY LOCAL VARIANCE FOR THE OPERATION OF TIER II AND TIER IV EMERGENCY GENERATORS BY DATA CENTERS LOCATED IN LOUDOUN DURING PERIODS OF PJM INITIATED ALERTS.  As a resident of Loudoun County, I will be subjected to additional, harmful air pollution, which the variance does not evaluate in sufficient detail.  Impacts from diesel exhaust and diesel emissions on human health, environment, climate change, and environmental justice impacts are well known, yet not addressed in this Variance.  The number of PJM alerts have increased dramatically, one in 2019, followed by 10 in 2020, 30 in 2021, and 82 in 2022.  The revised variance does not take this information into account.

There are 12 concerns for the Revised Variance permit which I enumerated in an earlier comment.  I’d like to list additional concerns.

• The Revised Variance does not require Data centers to reduce their electricity demand
• There is no prioritization for which data centers should be allowed to use the Revised Variance.
• A local newspaper reports that the Data Center Coalition requests the DEQ withdraw the policy change proposal for backup generators because
  • “[T]here are important and unresolved technical, federal regulatory, and operational challenges with this [proposal],” Data Center Coalition President Josh Levi wrote in a March 27 letter to the DEQ,
  • “Due to these issues, no DCC member has indicated they would use the variance,”
  • Levi’s letter noted that the coalition is unaware of any Dominion program that would provide a framework for when and how data centers should go off the main grid temporarily, programs that exist in some other areas
• Operating data centers on emergency backup generators does not address the electricity transmission problem.
  • DCC members are willing to work with state regulators and utility companies to develop a systemic program to “address the transmission constraint in Eastern Loudoun County and ensure a strong, resilient, and reliable grid.”
• The obviously dysfunctional data center approval process followed by many entities must not result in polluting Loudoun County with toxins documented to have negative impacts on human health, the local environment, and climate change.
• The Revised Variance will increase greenhouse gas emissions from Loudoun County and  is in direct denial and opposition to the most recent report from the Intergovernmental Panel on Climate Change to reduce greenhouse gas emissions.
• Increasing greenhouse gas emissions from Loudoun is in opposition to the adopted Metropolitan Washington Council of Governments climate goals.
• Increasing GHG emissions is not consistent with the Virginia Clean Economy Act.

The DEQ must uphold its mission “to protect and improve the environment for the health, well-being and quality of life of all Virginians.”  This Variance violates DEQ’s mission.  Do not issue the revised Variance.