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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11/30/25  5:51 pm
Commenter: James Higgins

Prohibit data center diesel generator use during planned outages
 

Dear Virginia Department of Environmental Quality: 

My name is James Higgins, and I am a resident of Greene County. While as of yet we do not have any data centers operating in our county, the planned construction of a reservoir in the next 4-5 years would create a permanent water source that our Department of Planning and Zoning feels would be attractive to data center planners. Accordingly, the issue of allowing data centers to run diesel generators during planned outages has potential impacts on the quality of life in Greene County.

I am writing to ask that the DEQ prohibits the operation of diesel generators during planned outages. Diesel generators should only be operating in 'emergency' situations where supplying power is necessary to prevent fires or catastrophic mechanical complications to the facility.

There is abundant evidence (selected citations below) that running diesel generators can cause significant air pollution, with deleterious consequences both for public health and carbon emissions. Allowing data centers in Virginia to run diesel generators during planned outages will contribute to these problems.

If the DEQ decides to allow diesel generators to run during planned outages, then I would ask that the agency place restrictions on when and where such operations are allowable:

There should be no planned outage use within a half-mile (0.8 km) of proximity to hospitals, parks, schools, residential areas, and nursing homes. Planned outage diesel generator use strictly should be prohibited on those days when the local Air Quality Index (AQI) is predicted to exceed a value of 50. There should be a public notice of when the planned outage is to be scheduled and either DEQ, or an independent, credentialed organization or company, should perform daily monitoring of the generators during the entirety of the planned outage. Monitoring results should be disclosed to the public within 48 hr of completion.

Such measures would offer a degree of protection to the health of the people who reside near data centers. 

Thank you for your consideration,

James Higgins, Barboursville, VA

 

selected citations:

(1)
Danelski, D. AI’s deadly air pollution toll | UCR News | UC Riverside. UC Riverside News. https://news.ucr.edu/articles/2024/12/09/ais-deadly-air-pollution-toll (accessed 2025-11-30).
(2)
Cardenas, A.; Fadadu, R. P.; Van Der Laan, L.; Ward-Caviness, C.; Granger, L.; Diaz-Sanchez, D.; Devlin, R. B.; Bind, M.-A. Controlled Human Exposures to Diesel Exhaust: A Human Epigenome-Wide Experiment of Target Bronchial Epithelial Cells. Environmental Epigenetics 2021, 7 (1), dvab003. https://doi.org/10.1093/eep/dvab003.
(3)
Martin, A. Data Centers’ Use of Diesel Generators for Backup Power Is Commonplace—and Problematic. Inside Climate News. https://insideclimatenews.org/news/12112025/data-center-diesel-generators-noise-pollution/ (accessed 2025-11-30).
(4)
Hwang, S. Diesel Generators are the Next Frontier in Curbing Carbon Emissions. American Security Project. https://www.americansecurityproject.org/diesel-generators-are-the-next-frontier-in-curbing-carbon-emissions-asp/ (accessed 2025-11-30).
(5)
Kaeding, D. Microsoft to use diesel-fired generators as backup power for data centers. WPR. https://www.wpr.org/news/microsoft-to-use-diesel-fired-generators-as-backup-power-for-data-centers (accessed 2025-11-30).
(6)
Hesterberg, T. W.; Long, C. M.; Bunn, W. B.; Sax, S. N.; Lapin, C. A.; Valberg, P. A. Non-Cancer Health Effects of Diesel Exhaust: A Critical Assessment of Recent Human and Animal Toxicological Literature. Critical Reviews in Toxicology 2009, 39 (3), 195–227. https://doi.org/10.1080/10408440802220603.
(7)
Tong, Z.; Zhang, K. M. The Near-Source Impacts of Diesel Backup Generators in Urban Environments. Atmospheric Environment 2015, 109, 262–271. https://doi.org/10.1016/j.atmosenv.2015.03.020.

 

CommentID: 238132