I am writing to state firm and unequivocal opposition to DEQ Guidance Memo APG-578, which would allow data centers to operate diesel backup generators during planned, non-emergency utility outages. This proposal flatly contradicts DEQ’s mission to “protect and enhance the environment” and your stated vision of achieving “better air quality” for all Virginians.

Diesel generator emissions—NOx, particulate matter, and other toxins—are well-known health hazards. Allowing data centers to operate these high-pollution machines for non-emergency events is an unnecessary and dangerous setback for public health. It is difficult to understand how granting wealthy technology companies permission to generate avoidable pollution aligns with DEQ’s stated environmental goals. It does not.

Moreover, the policy direction that enables routine reliance on diesel generators undermines the Commonwealth’s environmental commitments, incentivizes energy practices that are neither sustainable nor efficient, and contradicts the statewide push for cleaner technologies. Diesel generators are intended to be a last-resort safeguard—not an operational strategy for well-resourced corporations capable of investing in cleaner alternatives.

I urge DEQ to: prohibit generator use except in true emergencies, require cleaner alternatives for planned outages, and assess cumulative air impacts in data-center corridors. In addition, transparency and public-notification requirements for any instance where non-emergency generator use is permitted should be enforced. 

I look forward to DEQ’s continued commitment to safeguarding clean, healthy air for all Virginians.