To the VA Department of Environmental Quality: 

As a resident of eastern Loudoun County, and is someone who has children attending a public school and a daycare close to numerous data centers, I strongly urge you to not allow data centers to use tier 2 generators for emergency backup purposes. As you know, Tier 2 generators lack the more robust pollution controls that tier 4 generators have. If requiring data center, developers and operators to implement tier 4 generators in their data center campuses means that they have slower “speed to power” then so be it. That is a small price to pay compared to the health of the public and especially of our children that live, learn, and play close to where these data centers operate. Frankly, I continue to be surprised that the data center companies focus only on diesel generators as back up solutions when there are a variety of alternative or complementary technologies available to them. I see no reason why each data center can’t have rooftop solar paired with battery storage to use in peak events or blackouts, thereby reducing reliance on only generators as a back-up solution. 

Hold the line and protect our public health, and Virginia’s environment, by continuing to require that data center owners and operators are only able to use tier 4 generators.