Virginia Regulatory Town Hall View Comments

Department of Environmental Quality

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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11/19/25 4:31 pm

Commenter: Miriam Bishop

I oppose the Virginia Department of Environmental Quality (DEQ) Proposal re Data Center Generators

I am submitting comments in opposition to DEQ's guidance memo APG578 regarding Sudden and Reasonably Unforeseeable Events in the Context of Planned Electric Outages, which proposes to change the definition of " Sudden and Reasonably Unforeseeable Events" to include the use of emergency generators for planned outages. I oppose the proposal for several reasons.

This proposal does NOT protect public health. It will allow data centers to run emergency diesel generators unnecessarily and will cause increased pollution, namely the formation of ground level ozone, including fine particulate matter (PM10 and PM2.5), carbon monoxide (CO), nitrogen oxides (NOx), sulfur dioxide (SO2), and volatile organic compounds (VOC). Emergency generators only have to meet Tier II emission standards because of the limited amount of time that they are expected to be used.
If DEQ wants to allow data centers more flexibility to use diesel generators during planned outages or to reduce their grid electricity usage during peak periods, DEQ must impose strict limitations and regulations including:

Not allowing Tier II generators to be run for planned outages/peak periods near schools, hospitals, parks, trails and residential areas;
Giving the public notice about where and when these generators will be running and for how long; and
Requiring that each site where emergency generators are running be inspected daily to monitor fuel usage and air quality for the duration of their usage.

CommentID: 237784