To whom it may concern,

DEQ's job mission is to protect and enhance the environment of Virginia in order to promote the health and well-being of the Commonwealth's citizens, residents, and visitors and it's vision is that all Virginians enjoy cleaner water, better air quality and the productive reuse of land that was once contaminated. The proposal to change to allow data centers to run during planned outages explicitly goes against both these guiding statements.

DEQ's regulation of data center generators is already too lax and is potentially harming communities near data centers, especially since the cumulative impact of the associated generators and their location relative to sensitive receptors is not considered during the permitting process. The emergency generator allowance should not be broadened to include planned outage events.

This will contribute to more unnecessary pollution and 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 chooses to make this change, it should incorporate strict limitations and regulations including:

• • Not allowing Tier II generators to be 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.

I respectfully ask that DEQ not go through with these proposed changes and instead consider more stringent regulations regarding data center generator operations to increase protections for communities that are all already impacted by this use and to protect communities that do not yet realize the impact data center generators will have on their health and well-being.