Dear Virginia Department of Planning and Budget,

I am a computer scientist and former diesel enthusiast who has been doing climate and clean-air advocacy for almost six years now.  I look back in horror at the damage my passion for diesel did to countless people and animals, all because I was completely unaware of just how devastating its impacts truly are.

Earlier today, I was informed by the Piedmont Environmental Council of your proposal to allow "emergency" diesel generators at data centres to operate more often and under weaker regulations.  I quote-delimited "emergency" because in this context it appears as though that term is being used to justify longer operating times for such gensets even though the justification (planned outages) doesn't appear to meet the dictionary definition of an emergency.  Even Qulliq Energy Corporation in Nunavut (Canada) - which, ironically, almost exclusively uses diesel gensets for its power plants - has a clear distinction between planned and emergency outages.

Diesel exhaust - it goes without saying - is extremely toxic.  Even with filters and selective catalytic reduction, the emissions still damage our health, affecting every cell and organ in our bodies and causing every disease known to science.  As with all air pollution, there is no safe level of it, and the only way to stop it is to not produce it in the first place (i.e. stop burning stuff).

Many communities all over the world depend on diesel gensets for their electricity, and the consequences are dire: higher electricity rates (for example, 72 cents CAD per kilowatt-hour in communities in Nunavut here in Canada), aesthetic harm (the smell of diesel exhaust), and health impacts.  Sadly, these communities often don't have much of a choice, as while they may be able to partially offset their use of diesel fuel for electricity the hard truth is that it takes time to develop and deploy non-polluting alternatives at the scale that is required to fully displace diesel.

That brings me back to the issue of diesel gensets for data centres.  Instead of running data centres on diesel fuel, they should instead be forced to delay expansion until there is adequate clean-grid capacity, and their emergency power should come from batteries/UPSes instead of polluting gensets.  Additionally, the roof space on data centres should be covered with solar panels to the maximum extent practicable to supplement the grid and (during emergencies) battery power.

Please prioritize public health and require data centres to use clean electricity for both normal and emergency operations.  The technology exists to allow this - all that is needed now is the political and corporate will.

The fewer diesel gensets there are in operation, the happier, healthier, and wealthier we will all be.

Thank you for accepting my comment and take care.

(I am electing to withhold my address for fear of retaliation due to the surprisingly sensitive nature of air pollution, particularly surrounding diesel)