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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12/3/25  7:49 pm
Commenter: George Stewart, Gainesville District Supervisor

Do not extend permitting for diesel generators. AIR QUALITY FIRST!
 

Gainesville District is home to critical environmental, historical, cultural and resources for local/state and national interest.  These data center campus are located near schools, homes, daycares, assisted living, retirement communities.  All of which are vulnerable to the risks of air quality degradation.

 

The article below identifies the crisis our grid is experiencing.   The amount of time these generators would need to run is extending far beyond emergency backup with no data on the scale of potential harm to our air quality.

https://www.utilitydive.com/news/solving-pjms-data-center-problem/805600/?fbclid=IwY2xjawOdLB5leHRuA2FlbQIxMQBzcnRjBmFwcF9pZBAyMjIwMzkxNzg4MjAwODkyAAEeSZcQA5L1WXJoon-1Vk9LqC9T3idQwd_e1n-eauWcMzE7H0MAhEUSukVI1As_aem_1UIb-ioH5cO6QkAts0g74g

 

Prior to any expansion of use of diesel generators as de-facto microgrids, there must be concrete data collected, analyzed and shared with the public on the quality of air they will be breathing.

How many data centers are using tier 2 generators?  How many of those will be included in the planned outages?  What is DEQs plan to collect the air quality data of the data centers that will utilize the generators?  There is no current legislation that requires the data center industry to use tier 4 generators.  Will tier 2 generator be grandfathered?

 

The risk to the community is JUST TO HIGH to even consider the expanded use of onsite generators beyond a TRUE emergency use.  The mission of DEQ is quite clear:

 

“DEQ's Mission is to protect and enhance the environment of Virginia in order to promote the health and well-being of the Commonwealth's citizens, residents, and visitors in accordance with applicable laws and regulations.”

 

I respectfully ask that DEQ not adopt the guidance to allow any use of onsite generators for PLANNED OUTAGES. 

CommentID: 238403