Virginia Regulatory Town Hall
Department of Environmental Quality
Department of Environmental Quality
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3/9/23  6:00 pm
Commenter: Mark Berkowitz


While it may seem necessary to allow data centers to operate emergency generators during periods of electricity transmission constraints, there are several concerns with this proposal.

Firstly, allowing Tier II and Tier IV emergency generators to operate during non-emergency periods goes against established regulations and permit provisions. This could set a dangerous precedent for other industries to bypass regulations and undermine the regulatory process.

Secondly, the proposal fails to address the root cause of the issue - the inadequate electricity transmission infrastructure in the three-county area. Allowing data centers to continue operating during periods of stress on the grid may alleviate demand in the short term, but it does not address the long-term issue of the need for improved transmission infrastructure.

Furthermore, the proposal could have negative environmental impacts, as Tier II and Tier IV emergency generators are typically powered by fossil fuels and emit greenhouse gases. Allowing these generators to operate more frequently could contribute to increased air pollution and harm public health.

Instead of allowing data centers to bypass regulations and rely on emergency generators, efforts should be focused on addressing the underlying issue of inadequate transmission infrastructure. This could include investing in renewable energy sources, improving transmission capacity, and implementing energy efficiency measures. 

CommentID: 211303