Virginia Regulatory Town Hall
Department of Environmental Quality
Department of Environmental Quality
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2/26/23  11:39 am
Commenter: Elena Schlossberg, Coalition to Protect PWC

Will Data Centers financially benefit from turning on their dirty diesel generators?
Dear Ms. Sabasteanski,
In addition to my previous questions, is there now, or will there be, at any time in the future, a Demand Response Strategy that will financially benefit ANY data center or data center cluster that turns on their Tier II or Tier IV diesel generators, including, but not limited to, even a Post Contingency Local Load Relief Warning?
“This order also proposes to allow such Tier II and Tier IV generators to operate during periods that PJM has declared a "Post Contingency Local Load Relief Warning" for those counties under procedures established in Section 5.4 of PJM Manual 13.  A "Maximum Generation Emergency/Load Management Alert" is called by PJM in anticipation of an imminent emergency but does not itself constitute a declaration of emergency under PJM’s Manual 13.  Likewise, a "Post Contingency Local Load Relief Warning" does not constitute a declared emergency by PJM either.  The order would authorize the data centers' on-site generators to operate during times that fall short of a PJM declared emergency but when transmission constraints and strain on the electric grid nevertheless would be acute, thereby allowing the data centers to continue to serve their customers, maintain the integrity of internet, and alleviate demand on the electric grid during periods of stress.”
California authorizes summer reliability fixes despite concerns over backup diesel generation | Utility Dive
  • Regulators in California authorized a suite of demand and supply-side strategies to prevent blackouts during the summer months at a meeting on Thursday, despite concerns that the plan would include back-up diesel generation.
  • The proposal unanimously approved by the California Public Utilities Commission (CPUC) would implement an emergency load reduction program to encourage customers to reduce their usage during grid emergencies. But the pilot will also compensate customers if they do so using fossil fuel resources like diesel back-up generators.
Is DEQ willing to be complicit in incentivizing the possible profit making of the very industry that is at the core of this problem?So my question is clearly also for Dominion Energy, are there any plans now, or in the future, to incentivize/compensate the Data Center Industry during the times they kick on dirty diesel to relieve stress on the grid? 
The concerns of the Coalition to Protect PWC, from the outset eight years ago, was the burden regular citizens face bearing the negative consequences of the "extension cords" for these energy hogs.  So now, once again, not only are we forced to sacrifice our homes, our private property, our green spaces, our environment, our historical resources, and increases in our utility bills....... but now possibly our health? And to rub salt in the wound, these bulk load customers may actually be rewarded financially?
This is akin to a pyromaniac being rewarded for putting out the fire they started.
I am going to reiterate; it is not the role of DEQ to provide cover for Dominion Energy or the Data Center Industry.  It is the role of DEQ to protect the welfare of Virginians across the commonwealth. 
My reaction to this self-induced power crisis is "Necessity is the mother of all inventions" . Force Dominion Energy and the Data Center Industry to figure out how THEY reduce THEIR load demand during peak hours by denying this variance. 
Relying on solar and wind for these bulk load customers is a grain of sand on a beach when it comes to the gigawatts of power they demand.  Which is EXACTLY why dirty diesel is their back up.  
A final question. Who was the advisor(s) from Dominion Energy that provided the language for this variance?
Elena Schlossberg
Coalition to Protect PWC
CommentID: 209064