Dec 3, 2025

The Virginia Department of Environmental Quality (DEQ)

On behalf of the 5,000-member Northern Virginia Bird Alliance, we are writing to express our organization’s opposition to the proposal to permit data centers to use their emergency diesel generators during planned outages. The proposal is unnecessary and will harm public health.

Until now, these generators - one of the most polluting forms of energy generation – have been permitted to be used only during emergencies to provide backup power at “sudden and reasonably unforeseeable events” or maintenance. The proposed relaxation of the restrictions on diesel generator usage is driven by electric utilities to save money because of having to buy additional energy from the PJM interconnection. DEQ should not give utility costs a higher priority than the protection of public health.

The proposal to relax the restrictions on data centers’ use of diesel generators could result in hundreds to thousands of diesel generators in Virginia operating at the same time, risking our health. We believe this change should not be allowed or, at the very least, should be strictly limited and regulated so that it applies only to generators that are located more than half a mile from people and places that are particularly vulnerable to the harmful effects of air pollution, such as schools, hospitals, parks, trails and residential areas.

Respectfully,

                                                 /s/

Tom Blackburn                                                              Maryam Dadkhah

Advocacy Committee Chair                                 Advocacy Committee Member

Northern Virginia Bird Alliance                            Northern Virginia Bird Alliance