I am writing to request DEQ withdraw the proposed plan to allow data centers to run backup diesel generators during planned outage events. I am very concerned about the negative health impacts that will occur when up to 9,000 diesel generators are running at any given time. Allowing data centers to use backup generators was proposed in 2023. In the time since that was withdrawn, and this new proposal has been submitted, I do not see any qualitative, scientific data on the specific questions that were asked about the impact this would have on our land, air and water quality. Nor does the new proposal address how the noise impact on people and wildlife be mitigated.

DEQ's mission is "to protect and enhance the environment of Virginia in order to promote the health and well-being of the Commonwealth citizens". This proposal will have a direct negative impact in many ways to the citizens of Virginia, and our neighboring states as well.

Here are just a few questions that I have about this proposal. I am not an environmental scientist, but as a 'regular" person, I want to know the potential impact this new policy will have. My questions include the following: What is the cumulative effect of more than one generator running and at what point does the quantity of generators running, and length of time they are running, cause an aggregate toxic level of pollutants in the air? What monitoring will be done at an individual generator level, and then cumulative level as more and more generators are running? What is the impact on the water that we drink as the pollutants fall from the air to our drinking water? How will any changes in the water quality be correlated to the running of the generators? Who will be responsible for "cleaning" the water to bring it to acceptable levels? Who will be monitoring the air and water quality? How often will monitoring occur? Who will pay for the monitoring and are there enough testing tools available for all the monitoring that will need to take place? What is the process to shut down the generators when unhealthy levels of toxins are detected? Who will decide which generators will go back on the grid if unhealthy levels are detected?   What noise studies have been done to understand the noise impact on nearby residents and wildlife when multiple generators are running?  What is the financial impact of this policy change? Will our electric bills go up to pay for the compensation the data centers will receive as a result of coming off the grid? What is the expected manpower cost to monitor and manage this new policy, and who will pay that? What process will be used to notify local residents when the generators will be allowed to run? How much notice will citizens be given? What visibility will residents have to the testing data collected during the monitoring (that I assume will occur)?

These are just a very few questions that come to mind. As a life-long citizen of Virginia, I implore DEQ to provide answers to these questions, and the many other questions that will be poised by individuals much more familiar with the technical implications this policy change will have.

I request that DEQ withdrawal this policy change until answers can be provided to the citizens. I request that DEQ hold a meeting, or hearing, to discuss the impact this policy change will have, and how DEQ will uphold its mission to protect the environmental quality we are entitled to.

Thank you for your consideration.  Nancy Armour