Virginia Regulatory Town Hall
Department of Environmental Quality
Department of Environmental Quality
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2/23/23  3:46 pm
Commenter: Virginia Chamber of Commerce

In Support of Order and Local Variance for the Operation of Emergency Generators by Data Centers

The Virginia Chamber of Commerce is the leading non-partisan business advocacy organization in the Commonwealth with more than 29,000 members. Blueprint Virginia 2030 is the Virginia Chamber’s strategic plan to ensure the Commonwealth secures its position as a leader in the global economy and remains a top state for business. Blueprint Virginia was developed with input from more than 7,000 business leaders across the Commonwealth and highlights the importance of dependable and reliable energy supply for economic development and business continuity.  It is with these goals in mind that the Virginia Chamber writes in support of a temporary local variance for the operation of emergency generators by data centers in the Counties of Fairfax, Loudoun, and Prince William.

The variance proposed by the Department of Environmental Quality (DEQ) is limited in both scope of geography and duration to address the electrical transmission capacity constraint within eastern Loudoun County between the months of March and July. These limitations are well-crafted and will enable regulators and industry partners alike to be intentional and measured in implementing policies without introducing unnecessary risk or emissions. Importantly, any utilization of the variance will be optional and contingent on notice from utility providers to ensure that generators will be subject to active monitoring, reporting, and regulatory oversight during any limited periods of run-time. These guardrails will ensure that industry and utility partners communicate and coordinate effectively while collecting critical data required to further strengthen the grid.

The proposed temporary variance provides a valuable opportunity for electric utilities, PJM Interconnection, and the data center community to partner in their efforts to create greater resiliency, redundancy, and robustness within our regional electrical grid while long-term solutions are worked out. Data centers are uniquely suited to provide emergency capacity to the electrical grid in times of constraint, as these facilities are partially or fully capable of operating on backup generation and removing themselves from traditional power distribution.

Although Virginia is the global leader in data center infrastructure, the Commonwealth lacks a formal “Demand Response” or “Load Curtailment” program which other states, such as California and Texas, have. These programs require time, resources, and considerable effort to establish. The Virginia Chamber considers the variance to be an important step to ensure additional protections and service reliability to residential and commercial ratepayers of all sizes. Data centers have a unique and important role to play as community partners across Virginia, and this initiative is a meaningful way to explore new forms of partnership with electric utilities, PJM Interconnection, and the Commonwealth.

CommentID: 209002