Virginia Regulatory Town Hall
Department of Environmental Quality
Department of Environmental Quality
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3/7/23  4:03 pm
Commenter: Renee Grebe (Nature Forward)

Nature Forward opposes diesel-powered data centers

The origins of today’s variance request lie in the underregulated past. Data centers have been authorized to be built in Fairfax, Loudoun, and Prince William at a breakneck pace and in a way that apparently allows them to put a too-great strain on the electric grid at certain times. Perhaps this is because local land use planners, the DEQ, and energy regulators haven’t required these data centers to apply energy saving measures or alternative backup systems such as geothermal or solar power to the maximum extent practicable. Because of this, now that there are so many data centers, there will be times during the summer of potentially acute stress on the transmission capacity of the grid (e.g. when it’s too hot and air conditioning units will be pulling more energy). Without having planned for this eventuality upfront, or slowed the pace of construction of these energy-hungry facilities, data centers apparently will need to then switch over to using diesel-powered backup generators which themselves may be exempted from air pollution regulations.


This is unacceptable. In the face of our climate crisis, the Virginia Department of Environmental Quality is asking Virginians if it’s ok to spew pollution and greenhouse gases (further aggravating the climate crisis) in NOVA when legislators could have instead been requiring data centers to be built more responsibly and sustainably.


While we appreciate that this variance proposal has been updated as of 3/7/23 to be limited in scope to Loudoun County, this variance would still apply to an estimated 4,021 diesel-fueled Tier II generators and 130 Tier IV generators. DEQ states that they “do not anticipate that any data center will need to use this variance”, but the reality is that they might, and variances can be extended.


DEQ states that just one hour of operation of a single typical Tier II generator consumes approximately 174 gallons of diesel fuel. Not only does the burning of that fuel cause pollution and climate impacts, but the transportation of the fuel to run the generator will further pollute these locales. While not all generators are expected to be needed, the math is easy to see:  the total number of generators running x hours of operation * (174 gallons of fuel + transportation impacts for moving the fuel) = a significant impact to rural communities. Big corporations will benefit, rural communities will have their local air quality impacted, and all Virginians and everyone on earth will suffer from the increased climate change from the GHGs.


There are broader land-use issues at play here. This variance is intended to fix the problem of the growth of Northern Virginia’s data center development and electrical demand outpacing the available capacity of the broader grid. The risk of diesel generators being used more frequently as a stop-gap measure in the future is a significant concern for NOVA being able to adequate address causes of the climate crisis, and all while risking the health of local communities.


Allowing this variance could not only send our Northern Virginia locales tumbling backwards in our climate goals, but also has the potential to raise pollution to dangerous levels for all of us, especially the elderly, children with asthma, and people living in rural and lower-income communities.


Nature Forward opposes the local variance and diesel-powered generators for data centers.

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