I am writing to express my strong opposition to the proposed change that would expand the use of data center backup diesel generators to include planned outage events. The current regulation, which restricts the use of these generators to "sudden and reasonably unforeseeable events" or maintenance, correctly reflects their status as one of the most polluting forms of energy generation and must be upheld.
The DEQ's primary mission is, and must remain, protecting public health above all else. This proposed change, which would allow data centers to potentially turn on hundreds to thousands of diesel generators for foreseeable events, directly compromises this core responsibility by significantly increasing air pollution and putting the public at greater risk.
The stated reason for this proposal—expediting timelines and avoiding more expensive, less-polluting alternatives—is a matter of utility convenience and cost savings, not public health necessity.
The emergency generator allowance should not be broadened to include planned outage events. Planned outages, by definition, provide operators with sufficient time to seek alternative, less-polluting options, such as:
Renting mobile Tier IV gas generators with superior pollution controls.
Retrofitting existing Tier II generators with SCRs (selective catalytic reduction systems) to meet higher emission standards.
Broadening this allowance will contribute to more unnecessary pollution and sets a dangerous slippery slope. It could lead to future proposals to use these generators for demand response during periods of grid stress, which is fundamentally not their intended emergency use and would transform backup power into regular operational power.
If DEQ chooses to move forward with any change that would permit the use of these polluting generators during planned outages, it must incorporate strict limitations and regulations to mitigate the inevitable public health impact:
Tier II Generator Restrictions near Sensitive Receptors: Tier II generators must be prohibited from being run for planned outages near “sensitive receptors,” including schools, hospitals, parks, trails, and residential areas.
Public Notice Requirement: The public must be given clear, advanced notice about where and when these generators will be running, and for how long they will be utilized.
Daily Site Inspection and Monitoring: Each site where emergency generators are running for a planned outage should be inspected daily to monitor fuel usage and operational hours. Furthermore, each site must be equipped with continuous air quality monitoring for the entire duration of their usage, with data made immediately public.