Virginia Regulatory Town Hall
Agency
Department of Environmental Quality
 
Board
Air Pollution Control Board
 
Guidance Document Change: DEQ Guidance Memo APG-578 addresses the use of emergency generators in the case of “sudden and reasonably unforeseeable events” as the result of a planned electric outage.
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11/23/25  1:31 pm
Commenter: Julie Kimmel

Relaxing standards on data center generators puts our children's health at risk
 

 

I am writing as a parent gravely concerned about air pollution from data centers. This proposal to allow data centers to run backup diesel generators during planned outage events could potentially lead to hundreds (maybe thousands?) of diesel generators in Northern Virginia alone running at once, putting public health at greater risk. This change should not be allowed or, at the very least, strictly limited and regulated.

DEQ’s mission is to protect the environment for the health of its citizens. This proposal is in direct opposition to this mission. Diesel pollution contains nitrogen oxides, carbon monoxide, sulfur oxides, hydrocarbons, and particulate matter. This pollution can enter the lungs and bloodstream and wreak havoc on health—especially in children, whose bodies are still developing.

My family lives a short drive from dozens of data centers with backup diesel generators. If all these generators are operating at the same time, it will put my daughter’s health at risk—not to mention the health of the 39,000+ children in Loudoun, Fairfax, and Prince William with asthma. Our counties already get C and D grades for particle pollution from the American Lung Association, meaning our children are already exposed to pollution that can trigger asthma attacks, allergies, lung infections, heart problems, cancer, and premature death. Shouldn’t we be doing everything we can to improve the air in our communities—for the sake of our children?

The emergency generator allowance should not be broadened to include planned outage events. This will not only create more unnecessary pollution but will put us on a slippery slope that could lead to these generators being used for demand response during periods of grid stress, which is not their intended use.

If DEQ does make this change, it should incorporate strict limitations and regulations including the following:

    • Tier II generators should not be allowed to run for planned outages near “sensitive receptors” (e.g., schools, hospitals, parks, trails and residential areas)
    • The public should be given notice about where and when these generators will be running and for how long.
    • Each site where emergency generators are running should be inspected daily to monitor fuel usage and should be equipped with air quality monitoring for the duration of their usage.

Please put our children front and center as you consider this proposal. Their health is what’s at risk here.

CommentID: 237932