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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12/3/25  12:15 pm
Commenter: Lakshmi Fjord, PhD

VA must reject diesel generators for data centers
 

There is no place for diesel generators in data center energy uses, nor for fracked gas plants, or any other planned industrial uses of diesel generators. If regular or emergency operations require electricity shut-downs and back up energy sources, then these must be from best available control technologies- BACT -- to minimize or eliminate PM 2.5 and the other most hazardous energy source emissions. The evidence from the scientific and environmental health literature about the hazardous health impacts of breathing emissions of diesel PM and PM 2.5, CO and Co2e from diesel sources is uncontested and long-standing. There is no case for using diesel (or fracked gas for that matter) in this day and time when alternative sources of electrical energy are available. Why is DEQ accepting applications that have requirements to use diesel generators for known shut-downs and back up uses? It is as if DEQ is operating in not even the 20th century but back in the 1800s, when major uses if hydro-electric power and steam was overturned by the interests of coal in the U.S. 

It was truly astonishing and horrifying to witness the wealth of misinformation presented by a Dominion-sponsored gas alliance about the safety and reliability of fracked gas vs. solar and wind and state-of-the-art battery storage presented in anecdote after anecdote with no research literature to back up statements made by a slate of paid engineers decrying the reliability of renewables to perform in freezing and high temperature conditions. When it was fracked gas that failed by a far higher degree in both Texas and California blackouts -- because of the large water content that remains in fracked gas from frackings required thousands of gallons of water use to break apart shale rock to unpack bubbles of gas. This goes into the gas pipelines used at every stage of its transmission process.  

Since renewables do NOT cause millions of deaths every year by toxic pollution emissions by those breathing Diesel PM and PM 2.5, CO and Co2e daily by proximity to fossil fuel emissions, according to the World Health Organization; nor the disastrous numbers of childhood asthma, developmental and immune impacts, and lung cancers cited by the American Lung Association; heart disease early mortalities, and in recent studies, causally linked with diabetes and autism -- why is DEQ not focusing on how to ensure the fewest of these emissions are planned for Virginians to breathe as part of BACT requirements? 

That is, why are data centers not required by DEQ to  produce their own electrical energy? As has been so successfully done in other states by requiring their site choice in their application allows them to include rooftop and solar arrays with necessary agrivoltaics to ensure no erosion and sedimentation occurs to ground water shared by other landowners; or on-site wind energy such as American farms used even in my childhood in Illinois and Ohio? With the advanced battery storage capabilities each needs to perform reliability.

That is surely BACT in action. BACT is always going to be renewables with most up-to-date battery storage -- now used throughout the world and the U.S.

The people of Virginia have proven over and over that when given a voice in permits or a choice in polls, that the large majority do not support fossil fuel energy sourced electricity. It has been DEQ and state and county level elected officials who bow to Dominion and other corporate sponsors and deny the wishes of their constituents to stop using fossil fuel sources for utility electricity and data centers. We must not bow in abeyance to corporate profit-making over the health of Virginians, the futures of our children and grandchildren to have air quality that our generation has been able to achieve with great efforts to end coal powered electricity; to lessen diesel PM at ports most often closest to environmental justice communities.  

DEQ must put front and center the uncontested scientific proof of the disastrous health impacts of diesel from diesel PM and PM 2.5 and fracked gas and oil as energy sources.  Virginia no longer has time to coddle industrial uses of 19th Century fossil fuel energy sources, including diesel, in a rapidly heating climate caused in large part by fossil fuel emissions. When fossil fuel emissions have incurred disastrous levels of toxic pollution-related early mortality and exacerbations of pre-existing health conditions. DEQ must consider the environmental health and justice impacts of using diesel generators for data centers

DEQ must not "normalize" requests by industries to create new sources of toxic pollution, such as the "new" industry of data centers. When Virginia is more than capable of producing sufficient renewable energy sources. IF the Virginia Assembly will pass better solar utility requirements to include agrivoltaics to prevent loss of agricultural uses and prevent erosions and sedimentation -- DEQ can work with applicants to fulfill their energy requirements by taking a great deal of responsibility for their inequitable uses of public utility electricity.

I realize this is up to us as voters in Virginia. But, DEQ has a large role here. Please act in best interests of the health of Virginians over the profits of corporate entities who act as if it is their "rights" to pollute Virginia for their benefit, while most often living elsewhere. 

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