Loudoun County has the highest concentration of data centers in the world. It is their high power consumption that has resulted in grid instability and an increasing frequency of power warnings and alerts. Due to concerns that there may not be a sufficient amount of electricity for data centers this year, DEQ is proposing an order that will allow this industry to operate backup diesel generators outside of state air pollution control regulations.

This exemption will result in an unknown increase in air pollution and emissions. Contaminants such as NOx, CO, VOC, SO2, and particulate matter are known to have severe impacts on human health, the environment, and the climate.

I hope you do not follow through on this order. However, at a minimum, DEQ needs to provide:

- more information about the potential impact on public health and the environment;

- an analysis including a calculation of criteria pollutants released under higher, lower, and equivalent scenarios as compared to 2022;

- require additional restrictions on operation near sensitive receptor locations;

- require real-time monitoring of pollutants;

- and establish an alert system that notifies residents of affected communities (especially children, elderly, and those with underlying conditions) where and when generators will be running so they can take precautions.

As data centers continue to be built in Northern Virginia the pressure on the grid will likely increase resulting in more of these orders exempting the industry from state air pollution control regulations. For this reason, I would also urge DEQ to develop a regulatory plan for requiring the industry to phase out diesel generators and replace them with battery storage and less polluting back-up power systems. 

Thank you for considering my concerns. If DEQ chooses to move forward, it must adjust the proposed order accordingly.