Virginia Regulatory Town Hall
Department of Environmental Quality
Department of Environmental Quality
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2/26/23  11:36 am
Commenter: Elena Schlossberg, Coalition to Protect PWC

Protect Virginians' not the Data Center Industry or Dominion Energy
Dear Ms. Sabasteanski,
I am submitting my questions and comments regarding the proposed DEQ Variance
This proposed order and local variance would provide data centers located in three-county area a measure of relief from existing regulations and permit provisions that limit the use of Tier II and Tier I)WV emergency generators to periods of a PJM declared emergency.  This order proposes to allow such Tier II and Tier IV generators to operate during periods that PJM has initiated a "Maximum Generation Emergency/Load Management Alert" for the area under procedures established in Section 2.3 of the PJM Manual 13: Emergency Operations Revision 86, November 3, 2022.
I have some specific questions first on process.  
1)Why is DEQ now the arbiter of power delivery?  Where is the communication from PJM to Dominion Energy to DEQ ?  
2)Where is the actual chain of communication that alerted DEQ to this impending violation that would cause these warnings of overload?
3)The language in the variation says "allow" which implies this is a choice for data centers. Is this a choice?
4)If the generators are NOT "allowed" to kick on, what will happen?
5) The primary job of DEQ is the health and welfare of citizens, how is DEQ fulfilling that role if they allow dirty diesel generators to be utilized en masse near homes, schools, and other areas that will impair air quality?
6)There is clearly coordination with the utility companies, but where is DEQ's coordination with local elected leaders? with citizens? DEQ is not offering an alternative, just giving notice?
7)What does a "Maximum Generation Emergency/Load Management Alert mean and what happens if the data centers do NOT switch to dirty diesel?
8)Given DEQ's most important job is the health and well-being of citizens by ensuring clean air and clean water, what alternatives can DEQ recommend other than dirty diesel to power a private industry?
9)How is DEQ measuring, EVERY time the generators kick on, and during the duration and sometime thereafter the exact number of particulates AND other pollution matter that will be emitted into the air that citizens are breathing.
10)Exactly what is the radius of those who are most at risk in in proximity to these thousands of generators and in what way will you be sending a public warning system to those at risk so they are prepared to protect their health. Will you recommend staying indoors? Wearing masks?
11)Given that the peak load alerts occur on the hottest days and will also coincide with air quality alerts, what are the impacts of adding dirty diesel to the air during those code red days?
Here is how I am viewing this entire debacle, totally irresponsible, from Dominion Energy's lack of transparency all the way to our elected leaders that now find themselves in this unthinkable position. In July of 2022, PJM identified there was an immediate need:
*Reliability violations are observed in 2024, continue in 2025 even with  supplemental upgrades and into 2027. • *11 planned supplemental projects 2 planned baseline upgrades are not  sufficient to address the reliability needs in 2025.  • *Without further transmission upgrades, in 2024/25: – The area will not have sufficient transmission capability under Gen  Deliverability, N-1 and N-1-1 outage conditions in 2024 and beyond
As far back as 2016, The Coalition to Protect PWC, as a respondent in the SCC ( Amazon) - Haymarket Transmission Line Case, was advocating to protect the community by requiring  these bulk load customers pay for their own power infrastructure.  In fact, our position was so strong the State Corporate Commission agreed:The Virginia State Corporate Commission legal staff said it best in the Haymarket Amazon Transmission line hearing when they noted the commission “may wish to require [Amazon] to put some of its own skin into the game. Otherwise, the general public [all of us], already burdened by the environmental and aesthetic impacts of otherwise unneeded transmission projects, [are] also burdened with 100% of the otherwise unnecessary costs.”  
Now, not only are we bearing the brunt of paying for these bulk load customers' infrastructure AND dealing with new transmission line impacts, but now detrimental health risks are ALSO being foisted upon citizens - all to profit a monopoly utility AND some of the richest corporations in the world?! Totally unacceptable. Why is DEQ allowing themselves to be the fall guy due to the ineptitude of others? Where is Dominion Energy in this conversation?  THEY should be front and center. Cleary, I asked questions that I do not believe are in the purview of DEQ, but instead, should be answered by Dominion Energy. The Coalition to Protect PWC is formally on the record now, and we say NO to harming citizens and protecting these corporate interests.  Tell Dominion Energy and these bulk load customers to identify an alternative. 
This variance is a pandoras box DEQ is opening, with no resolution in site, considering the number of data centers that have been approved and have yet to be built...................
Elena Schlossberg
Coalition to Protect PWC
CommentID: 209063