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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11/29/25  5:39 pm
Commenter: James Hart

Diesel generator air pollution (Memo APG-578)
 

I oppose expanding the definition of "emergency" to allow additional air pollution from data center backup diesel generators.  A planned outage is not a "sudden and reasonably unforeseeable event."  Environmental regulations ought not be relaxed for planned outages.  If data centers cannot handle planned outages within the current environmental regulations, then they need to go somewhere else.  14 days advance notice makes no difference to the public; the particulate levels are just as bad, whether or not notice is provided.  Public health and environmental protection ought not be jeopardized or sacrificed for data center operation.

Data centers also ought to be encouraged to use cleaner technology to reduce the conflicts between their operation and public health.  By expanding the "emergency" definition, and relaxing environmental standards to allow additional backup diesel generator operation, you instead incentivize continued use of dirty technology, weakening what the regulations are intended to accomplish.  Increased degradation of air quality from diesel generators could be avoided if the existing air pollution standards are upheld.  

CommentID: 238121