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  10:48 pm
Commenter: George Shoffstall

Why are we not considering Tier 3?
 

I'm all about advancing our way of life, but with mindfulness of the environment and the future. I decided to take a moment to do proper research on what these tiers meant and why are we not looking at Tier 3?

 

Tier 2 generators have to be shut down during maintenance whereas a tier 3 and tier 4 do not have to be shut down. In the world of data centers, I believe that would be an imperative and needed option between the two. 

 

I also see the interest of less maintenance, less upfront cost and less staffing to maintain those tier 2 generators. I also understand that tier 2 generators are for single path power and tier 3 and 4 are for multiple lanes of power which I believe is essential for data centers. 

Economically speaking tier 3 should be the lowest a data center should be allowed. I'm not concerned about the diesel as I'm sure many people who make comments on this forum and especially in the state in many others are driving diesel trucks for no essential reason at all. Those are the real issues regarding diesel. I'm concerned about the reliability factor in regards to the specific needs of the industry that data centers are in. Tier 2 is not the way to go. These data centers are too large and too important for other businesses to be allowed to downgrade their Central backup power. 

CommentID: 238235