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  4:59 pm
Commenter: Ivy Main

Don't increase use of uncontrolled Tier II generators by expanding emergency language
 

Expanding the definition of "emergency" to include planned outages would increase the number of hours and days that data centers could run their Tier II generators. I'm already concerned about air quality in Northern Virginia communities, which will only get worse under the proposed revision. DEQ should be doing everything possible to move data centers away from Tier II generators entirely. While a substation outage can be a serious problem for customers, all data centers should be expected to have at least 4 hours of energy storage onsite. For outages that last longer, Tier IV generators are a viable, lower-polluting option, and should be what DEQ requires.

CommentID: 238185