Proposed DEQ Guidance Memo APG-578:

It is disappointing to again see an effort by the Department of Environmental Quality (DEQ) that undermines public health, specifically the air quality of Virginians.  The effects of diesel pollutants and toxics are well-known, but appear to be secondary considerations of this "guidance."  The open ended nature of this proposal seems to suggest there will be increasingly less daylight between "planned" outage events and extended use of backup diesel generators to facilitate the energy needs of the data center build out.  The following are just a few health protective measures missing from the "guidance" that should be thoroughly addressed before de facto relaxing emergency generator use in the state:  

1. The data centers are notified about a "planned" outage, but impacted residents are not.  Residents and other businesses with a quarter of a mile of the generators should be given the same notice along with the data centers.
2. There appears to be no time limitation associated with this change.  How long can a "planned" outage linger on and how do we know when a planned outage ends?
3. This proposed change does not seem to be supported by science-based health impact studies - ensuring that we Virginians will at the least be assured by state government charged protecting our air quality - that this change will in no way diminish air quality, especially in the highly populated Northern Virginia jurisdictions.
4. This proposed changes does not appear to consider the cumulative impacts of the nearly 10,000 diesel generators now permitted by your agency, with thousands more on the way.
5. This proposed change does not appear to take into consideration the negative impacts of increased diesel fuel truck emissions associated with transportation of diesel fuel for extended usage.
6. With little local air monitoring in our most populated jurisdictions, especially Loudoun, Prince William and Fairfax Counties, how will DEQ know if Virginia's most vulnerable residents, young and old, are not at increased risk for asthma, lung issues and generator noise-related impacts?  

This proposed guidance puts industry needs over resident's health and is a non-starter.  Diesel should be a non-starter.  Solving the power needs of data centers cannot come at the expense of our health and increasing reliance on dirty, toxic fuels to run data centers is harmful.  DEQ should honor its mission by putting the health of Virginians first and it can do that by shelving this proposal and exploring far cleaner alternatives that maintain public health.