Prince William Conservation Alliance urges DEQ to delay any action on this proposal until local governments and the communities most affected by data-center expansion have the opportunity to meet directly with DEQ staff. Given the scope and stakes of this decision, meaningful public involvement is essential.
Communities need clarity on what is driving these planned outages
Before any guidance is adopted, DEQ should clearly explain why these additional generator allowances are being requested. Northern Virginia is currently experiencing rapid growth in data-center energy demand, and utilities have publicly identified this load growth as a major factor behind transmission constraints and construction timelines. Residents cannot evaluate this proposal in a vacuum. They deserve an honest, transparent explanation of how often planned outages are expected, how they relate to new transmission-line projects, and whether alternative solutions were explored.
The proposal creates significant public-health concerns
Emergency diesel generators are permitted under less-restrictive Tier II standards because they are expected to run infrequently and only when true emergencies occur. Expanding their use to planned outages i.e. events that utilities know well in advance, changes the basic premise under which these permits were granted.
This shift could expose nearby communities to elevated levels of particulate matter, nitrogen oxides, and other pollutants. It is especially concerning in areas where data centers are concentrated, and thousands of diesel generators already exist in close proximity to homes, schools, parks, and other sensitive locations.
A policy of this scale should consider cumulative impacts
Allowing generator use during planned outages could mean large numbers of diesel units operating at the same time. Without a cumulative-impact analysis, DEQ and the public cannot fully understand the air-quality implications. This gap is especially notable given previous proposals in Virginia to allow generator operation during grid-stress events. Any expansion of allowed generator use must be evaluated with long-term regional impacts in mind.
If DEQ moves forward, stronger guardrails are required
Should DEQ decide to advance this guidance, PWCA believes several protections are essential:
Tier II generators should not be permitted for planned outages near places where pollution poses greater risks, such as residences, parks, hospitals, and schools.
Communities should receive advance notice about when and where generators will operate and for how long.
Sites using generators should be inspected while they are running, and independent air-quality monitoring should be required to track pollution levels over the duration of use.
DEQ should regularly report on generator deployments and ensure enforcement does not depend on resident complaints.
These measures would help ensure that the burden of data-center expansion is not disproportionately shifted onto surrounding communities.
DEQ’s core responsibility is to protect the health and environment of the Commonwealth. Any policy that could increase industrial air pollution, particularly in densely developed parts of Northern Virginia, requires careful scrutiny and full public transparency.
We respectfully ask DEQ to pause this proposal, engage directly with the localities most affected, and provide a clear accounting of the underlying grid challenges prompting this request. Only with that information can residents and decision-makers evaluate whether this change is necessary and in the public interest.