I am writing as a Virginia resident who is deeply concerned about DEQ’s proposal to allow data centers to operate diesel backup generators during planned outage events. Diesel generators were intended to be used in this manner only for true emergencies.. “sudden and reasonably unforeseeable events.” Normalizing their use On such a large scale is inconsistent with DEQ’s mission to “protect and enhance the environment of Virginia” and its vision of improving air quality for all Virginians.

My concerns are the following:

1. Planned outages are, by definition, foreseeable. If operators know an outage is coming, they also have time to pursue cleaner, safer alternatives such as mobile Tier IV gas generators with modern pollution controls or retrofitting existing diesel generators with SCR systems. DEQ’s proposal appears to remove the incentive for operators to choose the cleaner option simply because it is cheaper to rely on uncontrolled diesel.

2. No clarity on the scale of emissions in affected communities. DEQ should provide estimates of how many diesel generators could be running simultaneously in any given locality under this change, particularly in rapidly growing data-center corridors. Without that information, the public cannot meaningfully evaluate the health impacts of this rule.

3. Lack of required public notification. Residents deserve to know if hundreds or thousands of diesel generators will be operating near their homes, schools, or workplaces. What specific notification, if any, will be required before generators are turned on? What protections are in place for sensitive populations such as children, older adults, or individuals with respiratory conditions?

4. Air-quality monitoring and transparency remain unclear. If DEQ intends to authorize planned burning of diesel fuel in such high quantities, will on-site or fence-line air-quality monitoring be mandated? How will that data be shared with the public in real time? Without monitoring requirements, communities have no way to understand or verify the air quality impacts.

5. Operating limits must be explicit and protective. If DEQ moves forward with any allowance for planned generator use, strict limits on total hours of operation - and clear enforcement mechanisms - are essential. The proposal as written does not provide adequate safeguards against extended use or repeated planned events.

6. The proposed rule shifts environmental and health burdens onto nearby communities. Allowing companies to rely on the dirtiest, most polluting option when cleaner, available alternatives exist effectively transfers the cost of corporate convenience onto residents’ air quality and health. That is fundamentally at odds with DEQ’s stated mission and with the public trust responsibilities of the agency.

For these reasons, I urge DEQ to withdraw or substantially revise the proposal. Any rule that expands diesel generator use should require operators to demonstrate that they have pursued cleaner alternatives first and should include strict public-health protections, monitoring requirements, and transparency measures.