Virginia Regulatory Town Hall
Agency
Department of Environmental Quality
 
Board
Department of Environmental Quality
 

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2/6/23  10:31 am
Commenter: Elizabeth Ward

The Public Must be notified and Monitoring must be included
 

This is a critical public health issue and there needs to be real time publicly accessible air quality monitoring to. According to CARB  “Diesel particulate matter (PM) emissions from an average industrial diesel generator (~800 hp), operating at an average load of ~300 kW for 1 hour, is equivalent to driving nearly 660 miles in an average heavy duty diesel truck.” We are talking about 300 diesel generators per data center operating as a stationary source. This could be thousands of diesel generators operating for extended periods of time. DEQ is only asking the Data Center operators notify the DEQ when they are operating their  generators under the order’s provisions and to calculate the air pollution emitted by those generators during those times. The pollution should be measured in real time at the very least and the public notified of an air quality emergency.

 

Health effects can result from both short-term and long-term exposure to particulate pollution. People most sensitive to particulate pollution include infants and children, the elderly, and people with existing heart and lung disease. The smallest particles can penetrate deepest, causing the greatest harm. Researchers are still trying to identify which types and sources of particles are most hazardous to human health. Particles created from combustion soot tend to be fine particles with diameters smaller than 2.5 microns (PM 2.5) which are the most dangerous because it lodges in the lungs.

 

The U.S. Environmental Protection Agency, EPA, requires states to monitor air pollution to assess air quality and ensure that they meet minimum air quality standards. The US EPA has established both annual and 24-hour PM2.5 air quality standards (as well as standards for other pollutants). The annual standard established in 2012 is 12 µg/m³ (an AQI of 39). The 24-hr standard remained at 35 µg/m³ (an AQI of 99) and will remain unchanged.

 

Exceeding the 24 hour standard could cause acute health impacts especially since these data centers are often adjacent to residential communities. There are other air quality rules that might come into play here specifically the Clean Air Non-Road Diesel Rule of 2004.

CommentID: 208768
 

2/23/23  9:32 am
Commenter: RACHEL ELLIS

NO diesel generators NO more data centers
 

Why is Prince William County considering even allowing MORE data center development if the DEQ fears Northern Virginia lacks the electricity to power them?  It is time for this county and this state to say NO MORE.  We are already experiencing unforeseen consequences regarding power, noise and carbon emissions.  It is RECKLESS and NEGLIGENT to continue down this path.  A proposed waiver/variance does NOT solve the issue- it exacerbates it as MORE pollution is introduced into the environment.  The continued decimation of hundreds of acres of rural land in favor of data centers is removing more trees- our natural miracle to clean our air and protect against climate change.  

STOP putting Virginia citizens' health and our environment at RISK.  Please place the VALUE of Virginia and its residents OVER data centers.  We deserve and demand better! We get ONE chance to PROTECT our ENVIRONMENT AND QUALITY OF LIFE.  

DO NOT allow Data Centers to run dirty diesel generators because they have overextended our electric grid. Virginia is worth more than their profits! 

 

CommentID: 208997
 

2/23/23  10:16 am
Commenter: Dr Steve T Pleickhardt, Amberleigh Station HOA Bristow Virginia

DO NOT GRANT EMISSION WAIVERS TO DATA CENTERS DURING CRITICAL ENERGY DEMAND
 

Our communities are being  beseiged by data centers operating next to homes and schools.

Allowing continuous use of generators during energy constraints will negativley affect the health of hundreds of thousands of residents in Virginia. This is the WRONG decision by the DEQ. Better to issue State wide restraints on new data center construction then to modify the current regulations.

 

Thank you,

Dr. Steve Pleickhardt, President

Amberleigh Station HOA

 

 

CommentID: 208998
 

2/23/23  11:39 am
Commenter: Leigh Bravo

NO MORE DATE CENTERS IN OUR COMMUNITIES AND HISTORIC SITES!!!
 

My family moved to PWC 24 years ago. The main reason we chose PWC over other locations was the comprehensive plan supporting the rural crescent. Now with the current Democrats on the BOCS, they have reversed this policy and are in the process of destroying the western side of the county. Why would any one who cares about the county or its citizens, agree and push to develop these massive data centers in our neighborhoods and communities, surrounding our schools and destroying our National Historic parks and areas? What about our water shed, the noise, the pollution,  the strain on our power grids? None of this makes sense. The BOCS doesn't seem to care that the people of PWC do not want these monstrosities in our communities, yet they ignore our wishes and support these data centers, only listening to the unions, the data centers and those individuals standing to make millions on property sales while they sell out their own neighborhoods. STOP THIS MADNESS.... If not, you will lose the majority of the families that live here now. We will move! This is a non partisan fight. The PEOPLE of PWC DO NOT WANT OUR COMMUNITIES DESTROYED.

CommentID: 208999
 

2/23/23  3:46 pm
Commenter: Virginia Chamber of Commerce

In Support of Order and Local Variance for the Operation of Emergency Generators by Data Centers
 

The Virginia Chamber of Commerce is the leading non-partisan business advocacy organization in the Commonwealth with more than 29,000 members. Blueprint Virginia 2030 is the Virginia Chamber’s strategic plan to ensure the Commonwealth secures its position as a leader in the global economy and remains a top state for business. Blueprint Virginia was developed with input from more than 7,000 business leaders across the Commonwealth and highlights the importance of dependable and reliable energy supply for economic development and business continuity.  It is with these goals in mind that the Virginia Chamber writes 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 variance proposed by the Department of Environmental Quality (DEQ) is limited in both scope of geography and duration to address the electrical transmission capacity constraint within eastern Loudoun County between the months of March and July. These limitations are well-crafted and will enable regulators and industry partners alike to be intentional and measured in implementing policies without introducing unnecessary risk or emissions. Importantly, any utilization of the variance will be optional and contingent on notice from utility providers to ensure that generators will be subject to active monitoring, reporting, and regulatory oversight during any limited periods of run-time. These guardrails will ensure that industry and utility partners communicate and coordinate effectively while collecting critical data required to further strengthen the grid.

The proposed temporary variance provides a valuable opportunity for electric utilities, PJM Interconnection, and the data center community to partner in their efforts to create greater resiliency, redundancy, and robustness within our regional electrical grid while long-term solutions are worked out. Data centers are uniquely suited to provide emergency capacity to the electrical grid in times of constraint, as these facilities are partially or fully capable of operating on backup generation and removing themselves from traditional power distribution.

Although Virginia is the global leader in data center infrastructure, the Commonwealth lacks a formal “Demand Response” or “Load Curtailment” program which other states, such as California and Texas, have. These programs require time, resources, and considerable effort to establish. The Virginia Chamber considers the variance to be an important step to ensure additional protections and service reliability to residential and commercial ratepayers of all sizes. Data centers have a unique and important role to play as community partners across Virginia, and this initiative is a meaningful way to explore new forms of partnership with electric utilities, PJM Interconnection, and the Commonwealth.

CommentID: 209002
 

2/24/23  6:21 am
Commenter: Daniel Gossin

No more data centers/No to the use of generators
 

There is no reason for such HUGE tracks of land to be used for data centers. Why are there no new parks being built for the communities that are springing up all over PW/Loudon/Fauquier and other counties in Virginia.

I live in the Delaplane area of Virginia and lose power often. I have lost power on bright sunny days for no reason. Probably because of the amount of energy that these data centers are using. 

We need to just say No to the data centers and no use of generators that will add much pollution into the environment.

CommentID: 209020
 

2/24/23  6:25 am
Commenter: Anonymous

Opposed to Massive Data Centers
 

These data centers do not belong in the areas you are putting them.  They are noisy, health hazards!  Is money really worth what burden you will be placing on tax paying citizens?  Please change my mind about politics and corruption.  Are there still good politicians on either side that actually care about the people?  Beneficiaries do not count, in this case, and should not even get a say so!

CommentID: 209021
 

2/24/23  8:48 am
Commenter: Roger Yackel

Health Impact
 

Residents are not typically subject matter experts on technical issues.   In this particular case, residents have done research and are bringing informed opinions!   We need government officials to support us and push back on the Data Center development near houses, schools, and national parks.   Data Centers bring noise and diesel exhaust emissions with the serious health effects.  DEQ and other agencies should take the lead against the bullying and misinformation of developers and government officials who have bought into this.  Can you imagine the air pollution and noise from thousands of generators?   I can’t.  

CommentID: 209022
 

2/24/23  10:15 am
Commenter: Cheeryl Saggers

no more Data Centers until energy and water issues are resolved
 

Data Centers do not have enough water and electricity to operate.  Building more data centers before you have the infrastucture available is poor planning.

CommentID: 209023
 

2/24/23  12:17 pm
Commenter: Mary and Len Winsky

No Variance for Diesel Generators
 

Please do NOT grant data centers a variance to use diesel generators. The possible need for them demonstrates their glut.  They are already dangerous enough to the health of our citizens and environment.

Thank you.

Mary and Len Winsky

Gainesville

CommentID: 209025
 

2/24/23  12:50 pm
Commenter: Jim and Pat Kennedy

variance/diesel
 

Do not allow a variance for the diesel generators.

CommentID: 209026
 

2/24/23  12:53 pm
Commenter: Cynthia Shang

Noise/air oversight, public notification needed. Variance needs to be dropped.
 

This variance will also increase noise pollution as generators are loud, so why is that not being addressed?

EPA, requires states to monitor air pollution so why is this variance pushing that responsibility off to the data centers? Given: “each affected data center shall provide to the department as soon as practicable a calculation of the emissions of air pollutants from its Tier II and Tier IV emergency generators during the periods they operated under the provisions of this order and local variance.”, this variance is relying on data centers to self monitor and report when? “as soon as practicable” could be 1 month, 1 year, 5 years, 10 years. This open-ended reporting is unacceptable. There needs to be stricter reporting requirements with more oversight from outside the data center industry.

There is no limit to the duration of the “emergency”. If the electrical grid is already overloaded, then the “emergency” could go on for days or weeks. If March through July is considered the period of the emergency then what is to prevent a data center from simply running their generators as much as they can?

There are many data centers near homes which will more adversely affect those residents. There needs to be strict requirements for informing the public, not only in advance but in real time, regarding the actual levels of air and noise pollution.

We have limits on air and noise pollution for a reason. There is no need for every single data center to be allowed to run their generators when they cannot pull power from the grid. A long term solution could be to have these data centers contribute to a fund to expand the electrical grid or to provide air or solar power themselves. In the short term, the data centers must still be required to adhere to current air and noise pollution limits; those that cannot should be fined.

I oppose this entire variance. Counties have caused this problem by not taking the electrical requirements of data centers into account before allowing the over-building of such. If data centers cannot all function during certain times, I don’t think our society will collapse but people might. Please rescind this variance or at the very least, define and implement more strict duration limits, reporting, notification and oversight.

 

CommentID: 209027
 

2/24/23  1:46 pm
Commenter: John Lyver, Ph.D.

Do not Allow unlimited Polution from Data CEnter Diesel Generators
 

The proposal is making the issue of lack of electrical power worse.  Rather than controlling need for adequate electric supply to northern Virginia, the proposal admits that the growth of data centers is extreme and beyond what the infrastructure can handle.  The Commonwealth should be attacking the REAL problem of nearly unlimited growth of data centers and the impending brown-outs and black-outs in Northern Virginia.  Additionally, the allowance of diesel-electric generators to run 24/7 will create two distinctly deadly issues:  (1) the unchecked amounts of diesel engine pollution (e.g.; NO) added into our air and (2) the extreme noise that each diesel generator will generator.  The average data center building produces between 60 and 65 decibels each.  Each data center building has 20-30 diesel generators producing 100-110 decibels of noise.  We already have a toxic level of noise in our neighborhoods near data centers already causing documented stress induced noise related medical issues.  Running these diesel generators 24/7 will make this issue drastically worse.  PLEASE do not approve this proposal - PROTECT or citizens should be your FIRST priority.

CommentID: 209028
 

2/24/23  3:14 pm
Commenter: Fred Spurlock

Do not grant a waiver for Data Centers to use diesel generators during brown outs.
 

DEQ should be giving more attention to protecting the citizens of VA from the Brown Outs instead of giving waivers for air quality violations to the very companies that are contributing to the brown outs.

This situation should be viewed as a RED FLAG.  If we don't have enough power to supply the needs of VA with the EXISTING DATA CENTERS, why are we even considering approving rezoning applications for 75-100 more Data Centers?

DEQ should initiate a STATEWIDE POWER STUDY to determine the impacts of data centers on our existing power grid and then build the infrastructure according to a PLAN.  No more data centers should be approved until the impact of the centers has been determined.

This variance should be stopped the Operators should be required to find a better solution than to just run their generators.  Maybe they have to SPEND MORE OF THEIR MONEY TO SOLVE THIS PROBLEM THAN SPENDING OUR TAX DOLLARS.

CommentID: 209031
 

2/24/23  5:06 pm
Commenter: Maureen Clark

Diesel generators
 

I am opposed to the proposed variance for diesel generators to be used by data centers.

CommentID: 209032
 

2/24/23  6:13 pm
Commenter: Gary A Campbell

NO!!! Typical bureaucratic response to potential problem: Create several more problems.
 

Do you know how absurd you sound to make exceptions to existing environmental protection measures?  You now contemplate doing so at the whim of careless bureaucrats and greedy big business. 

This is all too typical of today's lazy, complacent, mediocre, crooked, corrupt, ignorant, thoughtless (and often "woke") officials and policy-makers:  If the rules don't suit you, you'll just ignore them.

Disgusting !!!!!!!!!!!!!!!!

CommentID: 209034
 

2/25/23  4:20 am
Commenter: Lois Ann Montgomery (Education Chair Prince William Wildflower Society)

No variance for data centers
 

Data Centers represent habitat loss for native plant and animal species in Prince William County.  Allowing diesel engine pollution during some months will further erode the delicate balance in the ecosystem.  We demand that you STOP this shameful degradation of the precious ecology of our environment.

CommentID: 209035
 

2/25/23  6:59 am
Commenter: Bill Wright

Proposed Variance to Allow Data Centers to Operate on Diesel Generators
 

DEQ's website states its mission “is to protect and enhance the environment of Virginia in order to promote the health and well-being of the Commonwealth's citizens, residents, and visitors in accordance with applicable laws and regulations.”

 

I question how DEQ's mission squares with the accommodation being proposed to permit a single wealthy industry to hazard our health and well-being.

 

My skepticism about DEQ’s blind eye toward data center growth goes back some time.  On November 21, 2021, I asked regional director Tom Faha whether he intended to respond to a requested review of the Prince William Digital Gateway proposal. Despite the unprecedented scope of this project, Mr. Faha replied that: “Such proposals are considered local zoning matters and outside of the agency’s regulatory purview.”

 

In my follow-up e-mail to Mr. Faha on November 22, I stated: “While I understand that DEQ does not have direct jurisdiction over zoning matters in Prince William County, you are the state’s environmental experts and I expect that DEQ will at least render an opinion on the environmental risks and impacts of a project of this scope in order to protect the state’s equities and its citizens’ safety.” 

 

On December 16, after DEQ declined to submit a review, I wrote Mr. Faha again, lamenting that DEQ’s reluctance to engage until very late in the game “is like saying this poison might kill you, but I won’t know for sure until I conduct the autopsy after you’re dead.” 

 

On March 31, 2022, I wrote DEQ Director Mike Rolband imploring DEQ to engage in the review of the Prince William Digital Gateway after Fairfax County’s concerns made it a state issue.  His reply to me on April 6 stated: “it is premature for DEQ to offer opinions in advance of necessary permit applications.”

 

DEQ’s established pattern of after-the-fact engagement constitutes gross negligence that violates its mission and will hazard Virginia’s citizens.  Uncontrolled data center growth and irresponsible approvals by willfully ignorant local governments did not sneak up on anybody.  The crisis in electrical grid strain we are facing was not unforeseen.  And the current data center capacity causing this crisis is a fraction of what Prince William County has already recklessly approved, but not yet built out.  How many variances are in our future?

 

At what point will some local, state or federal agency step up and acknowledge what any child can see?  The data center industry is way out over its skis and requires more careful regulation.

 

As for this insulting variance, I suggest DEQ instead propose a temporary ceiling on cat videos and pictures of food, and recommend internet users catch up on their summer reading. 

 

Thank you.

CommentID: 209037
 

2/25/23  9:11 am
Commenter: Lorraine Schooner

VA DEQ Variance
 

I am opposed to the variance to lift restrictions on backup diesel generators for Data Centers because of the human health impact from both noxious diesel fumes and noise. 

I am surrounded by Data Center where I live

Hope you are concerned about this issue as I am

Dr. Lorraine Schooner

CommentID: 209038
 

2/25/23  10:46 am
Commenter: Camille Blankenship

Stop creating more problems for our community and our environment
 

Stop the creation of even more problems with noise and pollution for my community and my environment, don't allow the Diesel Variances. Our children are not permitted to play outside at school when the air quality is dangerous. Allowing this variance would only exacerbate the poor air quality of our region. Please vote against allowing the Diseal Variance for the data industry.

CommentID: 209039
 

2/25/23  1:46 pm
Commenter: Sonya M

No Diesel generators OR data centers in my background
 

Please consider those with small families like mine under 7 who will be living next to these hazardous waste with the hunter project. Please just don’t.

 

CommentID: 209040
 

2/25/23  1:55 pm
Commenter: Elspeth McCormick

PLEASE do not approve this proposal - PROTECT uor citizens
 

If the existing power grid does not have enough power for all of the data centers, the answer should be to limit data centers NOT to allow the running of generators 24/7. 

The allowance of diesel-electric generators to run 24/7 will creates two very distressing situations.  1. the unchecked amounts of diesel engine pollution added into our air 100' from schools and homes.  2. the extreme noise that each diesel generator will make, again 100' from our homes and schools.  We already have a toxic level of noise in our neighborhoods near data centers already causing documented stress induced noise related medical issues.  Running these diesel generators 24/7 will make this issue drastically worse.  PLEASE do not approve this proposal - PROTECTING our citizens should be your FIRST priority.

CommentID: 209041
 

2/25/23  1:56 pm
Commenter: T Petrine

Data Center variances and proliferation
 

When did catering to special interests supersede responsible management of our environment?  STOP adding data centers to our communities that intensify many problems including adding to existing clean water challenges.  STOP careless ordinance changes that endanger us, YOUR constituents.  SERVE us FIRST, not last.  Pay attention: February, 2023 = 80 degrees one day and snow fall 48 hours later?  This is NOT normal.  Covid is NOT normal.  Running roughshod over massive public objection is NOT normal.  Acting as if someone or some time in the future will 'fix' the problems YOU are creating now is morally reprehensible.  Unless you are morally bankrupt and want to advertise that, JUST STOP.  Election year and we are watching and will continue to watch. 

CommentID: 209042
 

2/25/23  2:23 pm
Commenter: David Peterson

Issues to Resolve Prior to Considering Local Air Quality Variances
 

Dear VA DEQ,

Thank you for this public comment opportunity. While there are many concerns around a proposal for allowing local variances in air quality, here are three significant issues that warrant much greater investigation prior to VA DEQ considering local air quality variances:

The first issue is the lack of sufficient historical and current air quality data upon which to base an informed decision. For example, if you review the “Virginia Ambient Air Monitoring 2021 Annual Report” (accessed at https://www.deq.virginia.gov/air/air-quality-monitoring-assessments/air-quality-reports) it provides data on nine different criteria pollutants – but this data is reported only for a handful of sites within your statewide monitoring network. The available data is too sparse and insufficient to establish a reliable baseline of local-level air quality in the neighborhoods, schools, parks and other locations adjacent to/nearby data centers.  Even 3rd-party air quality mapping sites such as https://aqicn.org/city/usa/virginia/ do not provide the data resolution needed by Virginia residents to fully understand their current air quality.

The second issue concerns the breadth of potential air quality impacts across Loudoun, Prince William and Fairfax Counties given the number of data centers located in these counties.  (e.g., see https://www.datacentermap.com/usa/virginia/map.html)  If the local air quality variances are granted and applied to all of the data centers in these three counties:

  1. How many data centers are under consideration?
  2. How many and what type/size of emergency diesel generators will be operated?
  3. What is the predicted air quality impact of the emissions from these emergency diesel generators if they’re allowed to operate 24/7 for up to 5 months?
  4. Given the low resolution of Virginia’s existing air quality network, will the VA DEQ be expanding its air quality network to actively monitor local-level locations subjected to these additional emissions?
  5. If the local variances are granted, will VA DEQ also establish an upper limit for the different criteria pollutants, such that, if the pollutant limit is breached then the responsible data center(s) will lose their qualification for further emergency diesel generator operation until such time that the generator(s) emissions are remediated and again within allowable limits?

The third issue concerns noise pollution.  Although VA DEQ has historically viewed noise pollution as an issue for local jurisdictions, as the state agency authorizing emergency diesel generator operation through local air quality variances, then VA DEQ should also monitor and be ready to address all potential negative impacts resulting from their decisions.  Local jurisdictions aren’t resourced for the likely wide-scale, deleterious noise impacts resulting from 24/7 emergency diesel generator operations.  The VA DEQ needs to develop and implement a noise control plan in conjunction with any local air quality variances that it authorizes.

Thank you!

CommentID: 209043
 

2/25/23  2:54 pm
Commenter: Doreen Maher

Data centers
 

So the noise and unsightly view isn’t enough let’s just let throw in smell and filthy soot in our air!!! HELL NO!!   

CommentID: 209044
 

2/25/23  2:54 pm
Commenter: John Toepfer

Enough Of This!
 

How many different ways do we as citizens have to express our outrage before someone will listen to us? Now, we have to speak out against diesel generators. Seriously? Everything about this process reeks of greed and corruption from changing the zoning under cover of a worldwide pandemic to Stanley Martin and technology companies padding the pockets of the board of supervisors.

"Do you hear the people sing? Singing the songs of angry men...(women, children...ALL OF US!)

CommentID: 209045
 

2/25/23  4:42 pm
Commenter: Anonymous

NO TO DIESAL GENERATORS AND DATA CENTERS
 

Please -no more data centers and no generators. This is out of control, the noise, the chemicals, the stress, the light disturbance. 

CommentID: 209047
 

2/25/23  5:26 pm
Commenter: James Hart

Data Center air pollution
 

I strongly oppose the requested order lowering the air pollution standards in the three counties, for the data centers.  The public ought not be exposed to the additional particulates from the diesel generators.  If the local electrical grid is insufficient to support the data center operations, and if they need backup generators to maintain service, they need to aggressively implement cleaner technologies for their facilities, not make excuses  or seek forgiveness for the mess they have created.  

Too many data centers are already constructed or approved locally, with unmitigated and insufficiently understood impacts on the environment and infrastructure.  Lowering the air pollution standards, even temporarily, to accommodate mistakes that have already been made endangers the health of the residents and our quality of life.  If our existing infrastructure is insufficient to handle the data centers, and if they cannot implement cleaner technologies, such as backup batteries and solar power, they need to go elsewhere, or shut down.  Their impacts need to be mitigated before DEQ considers changing the rules to accommodate additional air pollution.  The burden should be on the data centers, not on the general public.

I also am concerned that the public may not be fully aware of the significance of what is being requested, on short notice.  Many folks would object if they knew the full impact of the data center operations.  The public depends on DEQ and others to uphold environmental standards, not to make exceptions for polluters who have expanded too quickly, without regard for the impacts of their pollution on the community.  Please do not lower the existing pollution standards.

CommentID: 209049
 

2/25/23  5:58 pm
Commenter: Donna Jacobson

The Effects of Data Centers on Health & Resources
 

Data centers bring noise and diesel exhaust emissions, which have serious health effects.  They should not be located near communities nor national/state parks.
Data centers also need electricity and water to operate.  Additional data centers should not be approved until the impact of data centers on our existing resources has been determined.

CommentID: 209050
 

2/25/23  7:07 pm
Commenter: Keith Edward Snyder

EU STAGE V Emissions Standards/Diesel Particular Filters (DPFs) Are Crucial Due to Gas Volume
 

Carbon Point Systems Gas Recovery Systems

Emissions 101 Caterpillar Diesel

It is important to understand that emergency generator systems do not have the emissions control standards at an acceptable level in order to perform 24 hours a day. If this were one or two data centers under consideration, perhaps this might be an acceptable solution.  With 100 plus data centers under consideration you have an entirely different animal that has never performed under these conditions. The most stringent emissions standards need to be implemented for multiple reasons.

EU Stage V Emissions standards need to be met in order to meet current greenhouse gas standards simply due to the sheer volume of exhaust gasses that you are considering to allow.

While I do not agree at all with allowing emergency diesel generators to operate as a standard for the summer months, I do understand that the power supply is not available for Loudon, Fairfax & Prince William counties. In order to consider allowing the sheer mass of the data centers that will have to perform in this 24/7 manner EU Stage V Emissions need to be required in order to bring down the emissions of Oxides of Nitrogen(NOx), Hydrocarbons(HC), Carbon Monoxide(CO) & Particulate Matter(PM). There now exists technology to concentrate and capture CO2 for utilization or sequestration.

Enhanced Energy Group operating as Carbon Point Solutions operates out of Rhode Island. Carbon Point Solutions has recently been acquired by Caterpillar in 2021. They are the industry leader in this department and need to be consulted in this specialized field immediately before proceeding further. 

CommentID: 209051
 

2/25/23  7:25 pm
Commenter: Jeff Flading

NO. This is not the solution to poor planning by data center developers and county governments.
 

Data center developers, aided by local county governments, have planned poorly.  This has led to the issue at hand.  You can't put this pollution solution in place to attempt to cover their mistakes.  Data center development should stop until developers and county governments can do the math to match capacity to the available resources to support them.   Putting this pollution solution in place will feed the problem by allowing them to get by while they keep building even more data centers without proper planning.  If you approve this year's "emergency" it becomes likely this will be an attempted fix for future self-induced "emergencies." 

CommentID: 209052
 

2/25/23  9:43 pm
Commenter: Amy Hambleton

Diesel generators pollute the air, make a terrible noise, and are dangerous to our health.
 

I have one small data center  very near my house. The noise from the generators when they run is terrible. Not to mention the diesel we breathe!

Do not give a variance to the data centers for diesel generators. Why does big business get to change the rules whenever they don’t like them? Why would you even consider letting them. If they can’t get enough power then they’ll have to wait till they can. It’s horrific that they are being built in our backyards and now diesel generators are going to be running all the time in the warmer months? It should not even be a consideration!

CommentID: 209053
 

2/26/23  7:34 am
Commenter: Kay and Ben Cooper

Opposition to Proposed DEQ variance
 
We are strongly opposed to this proposed variance.  If passed, it would have huge negative impacts on the environment by increasing air, water, and noise pollution and, consequently, will be harmful to  the health & safety of residents. Fairfax, Louden and Prince William Counties are already home to so many data centers with more being proposed daily.  The data center market in these areas is  saturated and by DEQ’s own admission is overwhelming the electric grid. So the solution is NOT to add more data centers and relax standards for usage but to stop adding more data centers.  If the current trend continues, our area will soon be the largest provider of data centers in the world. Such massing of data centers in one area is not only unfair to its residents due to their negative impact on quality of life, but also presents enormous problems for the power grid, and disturbingly is dangerous for  our country’s national security.
 
The DEQ’s website states its purpose as follows:
"The Department Environmental Quality (DEQ) administers state and federal laws and regulations for air quality, water quality, water supply and land protection. In addition, other programs cover a variety of environmental activities, such as improving the ability of businesses and local governments to protect the environment and prevent pollution.” 
 
By DEQ’s own admission, “data center operation relies on the use of large amounts of electricity from the grid . . .This proposed order and local variance would provide data centers located in three-county area a measure of relief from existing regulations and permit provisions."
 
Therefore,  this proposed variance is in direct opposition to DEQ’s stated mission.  
We are absolutely stunned  that an agency created specifically to protect the environment and prevent pollution would even consider proposing  a variance to relax environmental standards and controls at a time when global warming caused by human actions  is creating environmental catastrophes throughout the world.  What is the rationale?  Such a variance is certainly NOT in the best interests of residents or the environment, so if one follows the money, it’s pretty clear who stands to benefit—the people who sell their land at hugely elevated prices and the corporations  involved in building and running these behemoth data centers who will benefit financially with huge profits.  So much money is being used to lobby local governments to take actions that are completely counter to what is best for residents and the environment. 
We certainly hope that the DEQ staff is not being bullied into submission by wealthy data center developers who are applying political and financial pressure through our local leaders to relax much needed environmental standards. 
 
We’ll be watching with great interest to  find out what is decided and sincerely hope that reason will prevail to reject this outrageous proposal  and to allow the  DEQ staff to carry out its stated mission of environmental protection.
We appreciate the opportunity to express our views and to view the comments of others. Good governance cannot exist without such collaboration with residents and transparency.
 
Respectfully submitted
Kay and Ben Cooper, residents of Fairfax County since 1973
6511 Crosswoods Drive
Falls Church, VA 22044
(703)642-3444
 
 



CommentID: 209054
 

2/26/23  7:47 am
Commenter: Anonymous

VOTE NO on lifting restrictions on backup diesel generators for data centers
 

Dear Sir/Ma'am,

 

I am vehemently opposed to the VA DEQ lifting restrictions on backup diesel generators for Data Centers from March to July, or at any other time.

The adverse impact between diesel fumes and extreme noise will be intolerable.  How can you in good conscious even consider allowing this to happen?  Please VOTE NO.

 

-Dana B.

Bristow Resident

CommentID: 209055
 

2/26/23  7:52 am
Commenter: Anonymous

No variance on data centers!
 

Enough!  These data centers are being placed in residential areas and next to schools and now you want to allow them to pollute our air because you realize there is not enough power to run them?  Much less our homes? Idiotic!  Stop the madness and listen to the people that live here.  No data centers in residential areas!

CommentID: 209056
 

2/26/23  10:16 am
Commenter: Mustafa Kaya

We don’t want data centers near homes. We don’t want them running diesels.
 

Data centers should be placed away from homes. Noise pollution creates many problems…people can’t sleep at night. And now they want to run diesels?? What else proof do you need: they don’t belong here and they are more than the infrastructure can provide for. I don’t want my family to breathe those particles. What about the noise they will produce? Do something for the citizens: stop this data center menace… our well being is more important than data centers. 

NO TO DATA CENTERS. NO TO THEIR DIESELS.  

CommentID: 209057
 

2/26/23  10:18 am
Commenter: Patricia Leone

DEQ Variance
 

I applaud the DEQ's foresight in planning for emergencies and times of excessive strain on our power grid. The temporary variance to current restrictions on the use of data center backup generators will protect residential customers from outages and ensure the integrity of the internet. 

CommentID: 209058
 

2/26/23  10:33 am
Commenter: Ally Stoeger

Additive Impact of Multiple Clusters of Mega Data Center Campuses
 

Recent approvals of multiple clusters of mega data center campuses  in Prince William County  have resulted in 47 million square feet of data centers built or zoned. Of this 47 million square feet, only 12%  has been built to date. The MEGA data center campuses that have been approved adjacent to homes and schools have barely started construction.   

Even WITHOUT a diesel pollution variance residents of Manassas, Gainesville, Bristow and Haymarket are at risk for diesel pollution due to:

  1. Heavy construction machinery for 10 – 15 years of multiple clusters of mega data centers being built close to each other and adjacent to homes and schools.
  2. Busy truck routes on I-66, Route 29, Route 234, Linton Hall Road -- even before data center construction truck traffic for these massive projects is added.  Adding so many more construction trucks to the already heavy commuter congestion on these roads will result in even more stop-and-go construction truck traffic, and will be another additive source for diesel pollution.
  3. Heavy loss of treed areas surrounding major roads because these are the very same areas being cleared for data center construction. Previously these heavily treed areas  helped filter diesel pollution on these heavy truck and commuter routes.  That filtering mechanism is being lost throughout Gainesville and Bristow along I-66 and Route 29 due to data center and other recent construction.
  4. A new commuter lot has opened adjacent to I-66 and Route 29  and will increase stop and go traffic congestion in this area.  Again, heavily treed areas around 66 and 29  were cleared for this project.
  5. A new Sheetz gas station is being built at Route 29 and University.  Given the proximity to so much data center construction, this Sheetz station may function more as a truck stop, with high levels of diesel pollution due to stop and go diesel construction truck traffic.  And  again, heavily treed areas adjacent to I-66 and Route 29 were cleared for this project.
  6. A second asphalt plant has been added to Gainesville. Again,  a heavily treed area in Gainesville along I-66 was cleared for this project. 
  7. Thousands of diesel generators for these mega data center campuses will require testing resulting in serious community noise and diesel pollution.  

The bottom line is that even WITHOUT a variance we are looking at neighborhoods in Manassas and Western Prince William County  at high risk for diesel and particulate matter.  Of note is that unlike working adults, children and seniors are at even higher risk because they spend almost all their time in their neighborhood.

This proposed variance increases the present danger of diesel and particulate pollution in Northern Virginia and would also set a dangerous precedent that county planning officials and Supervisors, particularly in PWC,  can count on support from DEQ to continue the frenzied zoning pace and approve even more mega data center campuses.  

I urge DEQ  to pay close attention to the safety of the citizens of Manassas, Gainesville, Bristow and Haymarket as a practically contiguous zone of massive clusters of data centers is being zoned around them.  I further urge DEQ to stand up for the people of this community as PWC officials look to double down on this crisis by approving the largest data center alley in the world, rezoning of the PW Digital Gateway. 

Zoning approvals of data centers at never-before-seen numbers being paired with blind faith that this many data centers would be environmentally sustainable on any level, including the electrical grid, are  a high risk gamble.

Ally Stoeger, OD

Director, Health and Safety Policy

HOA Roundtable of Northern Virginia

CommentID: 209059
 

2/26/23  10:42 am
Commenter: Alysha Gawhary

DEQ variance illegal, unhealthy and unethical
 

The DEQ should be prosecuted for malfeasance if they allow the variance and definitely sued by those of us in close proximity to the data center. Especially the families of the schools surrounded by these diesel monsters. The average data center consumes 200W of power per square foot. For every 1 million square feet of data center, they would have to produce 200MWh of power from their generators. Generators of that size consume about 78gal of diesel for every MWh produced. That is 15,600 gals of diesel for every hour they are running. Using the EPA formula for Co2 emissions, that is 158.8 Metric Tons of Co2, per hour. Apparently they are only allowed to run them for 100 hours a year, if that is true then that is 15,880 Metric tons of Co2 per year. The Devlin Tech proposal is for 4 million square feet. So multiply those numbers by 4. We are not going to stand for this! Make the right decision please!!!

CommentID: 209060
 

2/26/23  10:43 am
Commenter: Madge Gill

Say no to lifting restrictions on diesel generators for data centers
 

Vote no on lifting restrictions on diesel generators for massive data centers.  The generators will  greatly add to the damage caused to air quality, noise levels, and the environment already caused by the construction and operation of data centers themselves.

CommentID: 209061
 

2/26/23  11:19 am
Commenter: Doreen Mizrahi

No to lifting restrictions
 

It’s bad enough that we will be surrounded by unsightly data centers and will be subjected to whatever noise they produce. But to try and allow the use of diesel generators which will not only increase the amount of noise pollution we will be dealing with, it will also now provide a poisonous environment with any fumes these will give off. In addition to this, how much dirt will these generators spew all around us?

Be responsible. People live here. If it is so great, put it behind your homes. 

CommentID: 209062
 

2/26/23  11:36 am
Commenter: Elena Schlossberg, Coalition to Protect PWC

Protect Virginians' not the Data Center Industry or Dominion Energy
 
Dear Ms. Sabasteanski,
 
I am submitting my questions and comments regarding the proposed DEQ Variance
 
 
This proposed order and local variance would provide data centers located in three-county area a measure of relief from existing regulations and permit provisions that limit the use of Tier II and Tier I)WV emergency generators to periods of a PJM declared emergency.  This order proposes to allow such Tier II and Tier IV generators to operate during periods that PJM has initiated a "Maximum Generation Emergency/Load Management Alert" for the area under procedures established in Section 2.3 of the PJM Manual 13: Emergency Operations Revision 86, November 3, 2022.
 
I have some specific questions first on process.  
 
1)Why is DEQ now the arbiter of power delivery?  Where is the communication from PJM to Dominion Energy to DEQ ?  
 
2)Where is the actual chain of communication that alerted DEQ to this impending violation that would cause these warnings of overload?
 
3)The language in the variation says "allow" which implies this is a choice for data centers. Is this a choice?
4)If the generators are NOT "allowed" to kick on, what will happen?
 
5) The primary job of DEQ is the health and welfare of citizens, how is DEQ fulfilling that role if they allow dirty diesel generators to be utilized en masse near homes, schools, and other areas that will impair air quality?
 
6)There is clearly coordination with the utility companies, but where is DEQ's coordination with local elected leaders? with citizens? DEQ is not offering an alternative, just giving notice?
 
7)What does a "Maximum Generation Emergency/Load Management Alert mean and what happens if the data centers do NOT switch to dirty diesel?
 
8)Given DEQ's most important job is the health and well-being of citizens by ensuring clean air and clean water, what alternatives can DEQ recommend other than dirty diesel to power a private industry?
 
9)How is DEQ measuring, EVERY time the generators kick on, and during the duration and sometime thereafter the exact number of particulates AND other pollution matter that will be emitted into the air that citizens are breathing.
 
10)Exactly what is the radius of those who are most at risk in in proximity to these thousands of generators and in what way will you be sending a public warning system to those at risk so they are prepared to protect their health. Will you recommend staying indoors? Wearing masks?
 
11)Given that the peak load alerts occur on the hottest days and will also coincide with air quality alerts, what are the impacts of adding dirty diesel to the air during those code red days?
Here is how I am viewing this entire debacle, totally irresponsible, from Dominion Energy's lack of transparency all the way to our elected leaders that now find themselves in this unthinkable position. In July of 2022, PJM identified there was an immediate need:
 
*Reliability violations are observed in 2024, continue in 2025 even with  supplemental upgrades and into 2027. • *11 planned supplemental projects 2 planned baseline upgrades are not  sufficient to address the reliability needs in 2025.  • *Without further transmission upgrades, in 2024/25: – The area will not have sufficient transmission capability under Gen  Deliverability, N-1 and N-1-1 outage conditions in 2024 and beyond
 
As far back as 2016, The Coalition to Protect PWC, as a respondent in the SCC ( Amazon) - Haymarket Transmission Line Case, was advocating to protect the community by requiring  these bulk load customers pay for their own power infrastructure.  In fact, our position was so strong the State Corporate Commission agreed:The Virginia State Corporate Commission legal staff said it best in the Haymarket Amazon Transmission line hearing when they noted the commission “may wish to require [Amazon] to put some of its own skin into the game. Otherwise, the general public [all of us], already burdened by the environmental and aesthetic impacts of otherwise unneeded transmission projects, [are] also burdened with 100% of the otherwise unnecessary costs.”  
 
Now, not only are we bearing the brunt of paying for these bulk load customers' infrastructure AND dealing with new transmission line impacts, but now detrimental health risks are ALSO being foisted upon citizens - all to profit a monopoly utility AND some of the richest corporations in the world?! Totally unacceptable. Why is DEQ allowing themselves to be the fall guy due to the ineptitude of others? Where is Dominion Energy in this conversation?  THEY should be front and center. Cleary, I asked questions that I do not believe are in the purview of DEQ, but instead, should be answered by Dominion Energy. The Coalition to Protect PWC is formally on the record now, and we say NO to harming citizens and protecting these corporate interests.  Tell Dominion Energy and these bulk load customers to identify an alternative. 
 
This variance is a pandoras box DEQ is opening, with no resolution in site, considering the number of data centers that have been approved and have yet to be built...................
 
Sincerely,
 
Elena Schlossberg
 
Coalition to Protect PWC
CommentID: 209063
 

2/26/23  11:39 am
Commenter: Elena Schlossberg, Coalition to Protect PWC

Will Data Centers financially benefit from turning on their dirty diesel generators?
 
Dear Ms. Sabasteanski,
 
In addition to my previous questions, is there now, or will there be, at any time in the future, a Demand Response Strategy that will financially benefit ANY data center or data center cluster that turns on their Tier II or Tier IV diesel generators, including, but not limited to, even a Post Contingency Local Load Relief Warning?
 
“This order also proposes to allow such Tier II and Tier IV generators to operate during periods that PJM has declared a "Post Contingency Local Load Relief Warning" for those counties under procedures established in Section 5.4 of PJM Manual 13.  A "Maximum Generation Emergency/Load Management Alert" is called by PJM in anticipation of an imminent emergency but does not itself constitute a declaration of emergency under PJM’s Manual 13.  Likewise, a "Post Contingency Local Load Relief Warning" does not constitute a declared emergency by PJM either.  The order would authorize the data centers' on-site generators to operate during times that fall short of a PJM declared emergency but when transmission constraints and strain on the electric grid nevertheless would be acute, thereby allowing the data centers to continue to serve their customers, maintain the integrity of internet, and alleviate demand on the electric grid during periods of stress.”
 
California authorizes summer reliability fixes despite concerns over backup diesel generation | Utility Dive
 
  • Regulators in California authorized a suite of demand and supply-side strategies to prevent blackouts during the summer months at a meeting on Thursday, despite concerns that the plan would include back-up diesel generation.
  • The proposal unanimously approved by the California Public Utilities Commission (CPUC) would implement an emergency load reduction program to encourage customers to reduce their usage during grid emergencies. But the pilot will also compensate customers if they do so using fossil fuel resources like diesel back-up generators.
Is DEQ willing to be complicit in incentivizing the possible profit making of the very industry that is at the core of this problem?So my question is clearly also for Dominion Energy, are there any plans now, or in the future, to incentivize/compensate the Data Center Industry during the times they kick on dirty diesel to relieve stress on the grid? 
 
The concerns of the Coalition to Protect PWC, from the outset eight years ago, was the burden regular citizens face bearing the negative consequences of the "extension cords" for these energy hogs.  So now, once again, not only are we forced to sacrifice our homes, our private property, our green spaces, our environment, our historical resources, and increases in our utility bills....... but now possibly our health? And to rub salt in the wound, these bulk load customers may actually be rewarded financially?
 
This is akin to a pyromaniac being rewarded for putting out the fire they started.
 
I am going to reiterate; it is not the role of DEQ to provide cover for Dominion Energy or the Data Center Industry.  It is the role of DEQ to protect the welfare of Virginians across the commonwealth. 
 
My reaction to this self-induced power crisis is "Necessity is the mother of all inventions" . Force Dominion Energy and the Data Center Industry to figure out how THEY reduce THEIR load demand during peak hours by denying this variance. 
 
Relying on solar and wind for these bulk load customers is a grain of sand on a beach when it comes to the gigawatts of power they demand.  Which is EXACTLY why dirty diesel is their back up.  
 
A final question. Who was the advisor(s) from Dominion Energy that provided the language for this variance?
 
Sincerely,
Elena Schlossberg
 
Coalition to Protect PWC
 
CommentID: 209064
 

2/26/23  11:43 am
Commenter: Monica Plaza

No to the special approval
 

I cannot believe they are considering this with no research behind it and no end date set. With money they are planning to buy an approval that can put citizens at risk. I wonder if one citizen were to ask for approval before all of this would we have gotten it. No and there would have been a list of reasons. Yet they are willing to approve for how many data centers for an unknown length of time for 24 hours a day. Give me break. The reasons these restrictions are in place are for a reason. You can’t just approve when it lines your pockets and then claim to care about your citizens. 

CommentID: 209065
 

2/26/23  11:54 am
Commenter: Tiffany Johnson

NO TO DATA CENTERS, NO TO DIESEL
 

It’s extremely frustrating but mostly UNBELIEVABLE that we are having these conversations and debates about something that is clearly unethical, unhealthy, and not in the best interest for our residents. We all know data centers will produce noise levels that are disturbing to the residents and students in schools, we all know they give off radiation/EMF that is harmful to the environment, and NOW we all know the diesel emissions are unhealthy and will contaminate air and water quality. This is getting worse and nothing that I’m stating is new or false information. YOU KNOW AND DONT CARE!!!  Please stop these data centers. They don’t belong here and they aren’t welcome here. 

CommentID: 209066
 

2/26/23  12:07 pm
Commenter: Lauren Anderson

Keep our community healthy!
 

It is unethical to knowing put our residents and community at risk of unnecessary health concerns!

CommentID: 209067
 

2/26/23  12:20 pm
Commenter: Danielle Bencivenga

Say NO to diesel generators and NO to data centers in residential areas.
 

Say NO to diesel generators and NO to data centers in residential areas. Please consider the daily lives of residents near data centers. The quality of the air and of our lives in general will go down if you allow this to pass.

CommentID: 209068
 

2/26/23  12:22 pm
Commenter: Anonymous

Please vote no to diesel generators during brown outs
 

Please vote no to lifting current restrictions for diesel generations during power grid strain. The pollution and noise will affect the quality of life for PWC residents. 

Thank you,

Katy

CommentID: 209069
 

2/26/23  12:33 pm
Commenter: Carlos Seda

NO TO THE VARIANCE
 

I am against the variance lifting restrictions for backup diesel generators for Data Centers. Continuous running of these diesel generators with their horrible diesel fumes and noise will have a harmful & negative effect on our community. I say "NO TO THE VARIANCE"!!

CommentID: 209070
 

2/26/23  12:47 pm
Commenter: Lovisa Taylor

No to data center and use of diesel during brownouts
 

It is insane to even think of allowing diesel fumes out in around neighborhoods at Devlin Rd and Linton Hall Rd. No one wants to have deisel smoke lingering 24/7 for brown outs. My vote is that this is all postponed until Dominion power can sustain the power grid for the data centers or find other suitable areas for the data centers. Not close to neighborhoods where it can harm all who live close by and the children. We also need to think of the wild life. Stop this madness. There is more to life than money..

CommentID: 209071