Hello.  My name is Natalie Pien.  I am a member of the Boards of Directors for the Piedmont Environmental Council as well as the Chesapeake Climate Action Network, on the Executive Committee of the Sierra Club Great Falls Group and the Loudoun Climate Project.  I am writing on my own behalf to oppose the Revised Variance for data center diesel backup generators.  As a resident of Loudoun County, I do not want to be subjected to additional, harmful air pollution that the Revised Variance will allow.  Negative impacts from diesel exhaust and diesel emissions on human health, environment, climate change, and environmental justice are well known yet not evaluated in this Variance.  In addition, the number of PJM alerts to trigger the variance have increased dramatically, one in 2019, followed by 10 in 2020, 30 in 2021, and 82 in 2022. 

Here are my concerns:

• The Revised Variance does not require Data centers to reduce their electricity demand.  Instead, Loudoun will be subjected to diesel emissions pollution.
• Analysis by the Piedmont Environmental Council shows that the Revised Variance will apply to over 4,000 diesel backup generators.  Yet, 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
• Variance alternatives have not been explored, as evidenced by the DCC letter to the DEQ:
  • “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.”
• Operating data centers on emergency backup generators does not address the electricity transmission problem, which Dominion Energy says will continue to be a problem until 2025.   
• The obviously dysfunctional data center approval process must not result in releasing extremely harmful pollutants to Loudoun County’s air resource.
• Instead of considering a Variance, a moratorium on further data center development should be instituted.  A competent and comprehensive approval process must be developed based on studying and evaluating data center impacts to Virginia’s natural resources, land use, economy, and greenhouse gas emissions reductions as mandated in the Virginia Clean Economy Act law.  This is the only prudent course to take given today’s situation.
• Increasing greenhouse gas emissions caused by the Revised Variance ignores the most recent report from the Intergovernmental Panel on Climate Change to reduce greenhouse gas emissions.
• Increasing greenhouse gas emissions from Loudoun is the wrong way to go per the adopted Metropolitan Washington Council of Governments climate goals.

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.