Virginia Regulatory Town Hall
Agency
Department of Environmental Quality
 
Board
Air Pollution Control Board
 
Guidance Document Change: DEQ Guidance Memo APG-578 addresses the use of emergency generators in the case of “sudden and reasonably unforeseeable events” as the result of a planned electric outage.
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11/24/25  3:11 pm
Commenter: Sieren Ernst, Whistler Meadow Farm

Protect Virginia’s Air and Rural Communities: Oppose Expanded Use of Diesel Generators
 

As both a working farmer in the Shenandoah Valley and an environmental professional with more than twenty years of experience in land use, air quality, and ecological restoration, I strongly oppose DEQ’s proposed rule change that would allow data centers to run backup diesel generators during planned outage events. These generators exist for true emergencies not for convenience or cost-saving measures by very large corporations.

Air quality, public health, and productivity impact

Diesel exhaust is one of the most harmful forms of air pollution: fine particulate matter, NOx, VOCs, and a suite of hazardous air toxics that contribute directly to cardiac disease, asthma, COPD, reduced lung development in children, impaired concentration, and overall declines in productivity and quality of life.


Farmers feel this acutely. We work outdoors; we depend on clean air for our own health, for our livestock, and for the people who visit our farms. Many rural communities in the Piedmont and Valley are already downwind of transportation corridors and industrial sources. Allowing hundreds or even thousands of diesel generators to intentionally operate during foreseeable outages fundamentally shifts the pollution burden onto the public.

 

Utilities and data center operators have alternatives. Planned outages are known well in advance, and there is sufficient time to rent mobile Tier IV gas generators, which have substantially higher pollution controls, or to retrofit Tier II diesel generators with SCR systems. DEQ’s proposal would simply let operators avoid these costs, with the health of Virginians paying the price.

 

The economic and ecological value of rural Virginia

 

The forests, mountain views, rivers, and working farms of the Piedmont and Shenandoah Valley are not just aesthetic, they are critical to the economic growth and livelihood of the region. 


Agriculture and agrotourism in this region create distributed economic benefits: farm-stays, pick-your-own operations, wineries, cideries, markets, trail networks, local food systems, and small businesses that support them. This model keeps value circulating within rural communities instead of flowing out to distant shareholders.

 

By contrast, data centers generate enormous construction booms and then a sharp drop-off, with the long-term jobs primarily limited to technicians employed by large corporations. Air quality impacts, noise, visual impacts, and land-use conflicts remain in the host community long after the construction crews leave.

 

Our regional identity, and our economic resilience, depend on maintaining clean air and a healthy landscape. Visitors come here for the views, the farms, the outdoor recreation, and the rural character. Many of us who live and work on the land are investing our own resources in soil health, stream restoration, native grassland recovery, and regenerative agriculture. The state should not undermine this work by sanctioning widespread diesel emissions for the convenience of a single industry that brings little benefit to most Virginians while already imposing real costs in the form of higher electric bills and shortsighted land-use choices.

 

Because planned outages are foreseeable and manageable, the use of uncontrolled diesel backup generators should not be permitted except in true emergencies. At a minimum, if DEQ moves forward, the rule must be strictly limited, tightly regulated, and conditioned on:

  • Demonstrated unavailability of Tier IV rental units
  • Mandatory pollution-control retrofits (SCRs) on existing generators
  • Transparent reporting, monitoring, and community notification
  • Geographic and temporal limits to ensure cumulative impacts remain low
  •  

Our communities deserve clean air and thoughtful regulation, not weakened standards that shift the cost of pollution onto rural residents, farmers, schoolchildren, and visitors who are sustaining the very landscapes that make Virginia unique.

 

I urge DEQ to protect public health and uphold the original intent of the emergency-use-only rule.

CommentID: 237971