Virginia Regulatory Town Hall
Department of Environmental Quality
Department of Environmental Quality
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2/25/23  7:07 pm
Commenter: Keith Edward Snyder

EU STAGE V Emissions Standards/Diesel Particular Filters (DPFs) Are Crucial Due to Gas Volume

Carbon Point Systems Gas Recovery Systems

Emissions 101 Caterpillar Diesel

It is important to understand that emergency generator systems do not have the emissions control standards at an acceptable level in order to perform 24 hours a day. If this were one or two data centers under consideration, perhaps this might be an acceptable solution.  With 100 plus data centers under consideration you have an entirely different animal that has never performed under these conditions. The most stringent emissions standards need to be implemented for multiple reasons.

EU Stage V Emissions standards need to be met in order to meet current greenhouse gas standards simply due to the sheer volume of exhaust gasses that you are considering to allow.

While I do not agree at all with allowing emergency diesel generators to operate as a standard for the summer months, I do understand that the power supply is not available for Loudon, Fairfax & Prince William counties. In order to consider allowing the sheer mass of the data centers that will have to perform in this 24/7 manner EU Stage V Emissions need to be required in order to bring down the emissions of Oxides of Nitrogen(NOx), Hydrocarbons(HC), Carbon Monoxide(CO) & Particulate Matter(PM). There now exists technology to concentrate and capture CO2 for utilization or sequestration.

Enhanced Energy Group operating as Carbon Point Solutions operates out of Rhode Island. Carbon Point Solutions has recently been acquired by Caterpillar in 2021. They are the industry leader in this department and need to be consulted in this specialized field immediately before proceeding further. 

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