I am writing to oppose any change that would allow diesel generators at data centers to run during planned power outages or for “operational flexibility” beyond a true emergency. Permitting non-emergency use of these generators is unacceptable and fundamentally incongruent with DEQ’s mission to “protect and enhance the environment of Virginia” and its stated vision of “better air quality” for all Virginians.

This proposal appears to prioritize the convenience and profits of private data center operators over the health and safety of nearby residents. I urge DEQ to explain how expanding non-emergency diesel use aligns with its own mission and values. 

I also have several specific concerns and questions that deserve clear, public answers:

• How many data centers in a given region could be running diesel generators during a planned outage under this change, and what would the cumulative air quality impacts be for surrounding neighborhoods?

• What kind of warning, if any, will nearby residents receive before multiple large diesel generators are turned on, especially in communities that already experience high traffic, noise, and pollution burdens?

• What air quality monitoring will be required when generators are operating, who will conduct it, and how will that data be shared in a timely and accessible way with the public?

• Will there be a strict, enforceable time limit on how long diesel generators can operate during any non-emergency use, and what penalties will apply if those limits are exceeded?

• Why is DEQ making it easier for private data centers to burn diesel, a dirty fossil fuel, instead of requiring cleaner alternatives and more resilient, climate-conscious planning from these companies?

If DEQ moves forward with a rule that allows non-emergency generator use, it risks normalizing diesel pollution as a routine feature of data center operations rather than an absolute last resort in genuine emergencies. That is not consistent with protecting and enhancing Virginia’s environment or ensuring better air quality for all.

I respectfully urge DEQ to reject any provisions that authorize diesel generator operation during planned power outages. Data centers should be required to plan and invest in cleaner, more responsible solutions rather than shifting the environmental and health costs onto Virginia communities.