This guidance document would allow data centers to run their backup diesel generators during planned outage events. Currently, a data center may use the backup generators only during "sudden and reasonably unforeseeable events." This proposed change would result in an increased in emissions of pollutants such as particulate matter, carbon monoxide, nitrogen oxides and VOCs among others. I support continuing the current practice. Changing this rule for data centers, in particular, would directly impact local communities. The increased emissions will directly impact  public health. I don't understand how this proposal benefits anyone other than the data center. What public purpose does it serve?  None that I can see. 

Another aspect of this change is that if the state goes forward with this proposal, generators could meet less stringent standards for the above listed pollutants. As I understand it, many of these data centers are using backup generators even though data centers are currently only using 7% of their permitted capacity. And the state has not even attempted to determine the impact of these generators operation for extended periods of time. Clearly, more work needs to be done to determine whether this is even needed. 

Diesel fuel usage has dropped across the US. There are no longer cars that run on diesel. I see no reason why the state should introduce additional usage of diesel generators when it is known and understood to increase emissions into the environment that is known to have a negative impact on public health. There is no public benefit to this proposal and should be withdrawn.