Thank you for the opportunity to comment. DEQ's "About Us" page state that the agency is "[r]esponsible for administering laws and regulations related to air quality, water quality, water supply, renewable energy and land protection." Nowhere in that description is DEQ responsible for uninterrupted energy to data centers. DEQ's mandate is "environmental quality." Therefore, the primary reason this guidance memo should be eliminated from consideration is because enacting this guidance will have only negative effects on air quality, water quality, and land protection.

Renewable energy is also part of DEQ's regulatory mandate. If the owners and operators of the data centers find it necessary to use on-site generators for continuous energy provision during planned outages, DEQ should make it clear that they can run their battery generators or other non-greenhouse gas emitting generators as often as they feel is necessary. The data centers should also feel free to develop renewable energy projects on data center property and support community-scale renewable energy projects to power the center in the event of an outage. The idea that diesel generators are the only proposed solution to the underlying concern points to a lack of creativity.

In summary, enacting this guidance is against DEQ's own mission. And there are creative ways to address the underlying concern without making it even more difficult to meet the VCEA goals, which is currently state law.