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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12/1/25  4:35 pm
Commenter: Tyler Ray, SaveBrenMar Coalition

Keep Backup Generators for “sudden and reasonably unforeseeable events” and maintenance only
 

As the founder and leader of the SaveBrenMar coalition that was created as a direct result of a data center campus proposal the SCC has called "unusually close to residents" and the Joint Legislative Audit and Review Commission (JLARC) singled out as "too close to residential zones" I write to urge the DEQ to keep backup generators ONLY for "sudden and reasonable unforeseeable events" or maintenance. 

The DEQ legal 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 in accordance with applicable laws and regulations.”  

Past actions has made clear that the data center industry when faced with the decision to enact stronger environmental protections that promote health and well-being or pursue cost-saving, profit driving decisions, profit wins every time. 

My community of Bren Mar in Fairfax County illustrates this perfectly. In it's site plan the data center developer intentionally made the choice to place backup diesel generators off-ground in order to avoid additional local regulation that was specific to ground mounted infrastructure and would've been more costly but would've significantly mitigated impact to residents by placing the generators behind the data center building and away from residents. Instead the developer located the generators on the first story roof of it's data center which places them as close as possible to adjacent residents at an even height with homes and without any barriers in between.

This example is the typical rule and not exception for data center developers. It is only through DEQ action that you can effectively protect and enhance the environment of Virginia in order to promote the health and well-being of the Commonwealth's citizens, residents, and visitors in accordance with applicable laws and regulations.”   

To that end I am asking that:

  • 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.

 

CommentID: 238178