Data Centers to be Allowed to Run on their Diesel Generators More Often

There will be a public hearing on February 27, 2023 at 11:00 am at the DEQ offices in Woodbridge, VA. It will be in the Conference Room of the DEQ Northern Regional Office at:  13901 Crown Court, Woodbridge VA, at 11:00 a.m. The meeting is to discuss and hear comments on the proposal to allow datacenters in Northern Virginia to operate during times of constrained power on their thousands upon thousands of backup generators. The generators are stationary sources of air pollution equivalent to thousands of heavy duty diesel trucks running in our backyard. This could be a critical public health issue for many and should be treated as such. 

Loudoun County has courted data and cloud companies making development and land use decisions that has resulted in Loudoun County having the highest concentration of data centers in the world. These data centers provide a very significant amount of revenue to the county through real estate and business personal property taxes. In recent years, Prince William County has copied Loudoun County’s approach and approved many data centers. Data center growth in Prince William County has increased significantly and is poised to take off.  

However, data center operation relies on the use of large amounts of electricity from the grid. Dominion Energy has informed Loudoun County that it will not be able to provide power to new data center projects in Ashburn at this time. They lack  adequate transmission capacity and building it could delay new data centers coming online by a year or more. Virginia is concerned that the Counties of Fairfax, Loudoun, and Prince William may not have sufficient electricity for data centers in the next couple of years due to severe, localized constraints in electricity transmission.  Dominion has already informed the counties that a transmission constraint exists in the area which may affect the ability to provide enough electricity to data centers through 2025.  In particular, the period between March and July 2023 has been identified as a time of potentially acute stress on the transmission capacity of the grid.

Now, the VA Department of Environmental Quality (DEQ) has issued a notice of action that would authorize the data centers' on-site generators to operate during times that fall short of a PJM declared emergency but when transmission constraints and strain on the electric grid would be acute and thereby allow the data centers to continue to operate instead of shutting down to alleviate demand on the electric grid. While Dominion can buy electricity from the PJM members (Pennsylvania and West Virginia who generate electricity by natural gas and coal) there is simply inadequate transmission lines to meet all the demand in Loudoun, Prince William and Fairfax at this time. So, they are going to produce the needed electricity in the dirtiest way possible. 

According to the California Air Resources Board: “Standard gasoline and diesel generators emit a lot more pollutants and greenhouse gas than some other options…Diesel particulate matter (PM) emissions from an average industrial diesel generator (~800 hp), operating at an average load of ~300 kW for 1 hour, is equivalent to driving nearly 660 miles in an average heavy duty diesel truck.” Each data center has 250-300 diesel generators. What the DEQ is proposing is to have the equivalent of thousands of heavy duty diesel trucks running (not idling) in one spot in our counties for hours or possibly days.

Health effects can result from both short-term and long-term exposure to particulate pollution. People most sensitive to particulate pollution include infants and children, the elderly, and people with existing heart and lung disease. The smallest particles can penetrate deepest, causing the greatest harm. Particles created from combustion soot tend to be fine particles with diameters smaller than 2.5 microns (PM 2.5) which are the most dangerous because it lodges in the lungs.

The U.S. Environmental Protection Agency, EPA, requires states to monitor air pollution to assess air quality and ensure that they meet minimum air quality standards. The US EPA has established both annual and 24-hour PM2.5 air quality standards (as well as standards for other pollutants). The annual standard established in 2012 is 12 µg/m³ (an AQI of 39). The 24-hr standard remained at 35 µg/m³ (an AQI of 99). Exceeding the 24 hour standard could cause acute health impacts. In addition, there are other air quality rules that might come into play here specifically the Clean Air Non-Road Diesel Rule of 2004.

In 2020 electricity used in Virginia in 2020 was 30% more than the electricity used in 2010. The one growing sector of electricity demand in Virginia is data centers. In 2018 power demand for data centers was just over 1 gigawatt of power, by 2022 that had reached 2 gigawatt of power and is projected to reach 3 gigawatts by 2025 with projects already under way. The current power usage by data centers is more than to the power usage of 1.5 million houses which is almost half of all Virginia households. 

Virginia is the data center capital of the  world resulting in electricity use growing faster here than other states. Now the DEQ is proposing to turn us at least sporadically into the air pollution capital. Governor Youngkin has just trumpeted and praised the announcement from Amazon that they plan to invest $35 billion in data centers in Virginia. The largest private investment in the state’s history. With that investment Amazon will take control of the grid without any planning and has apparently also captured the VA DEQ. What the DEQ is proposing is to have the equivalent of thousands of heavy duty diesel trucks idling in one spot in our counties for hours or possibly days. 

The DEQ proposal only asks the Data Center operators notify the DEQ within three hours when they are operating their emergency generators  and to calculate the air pollution emitted by those generators during those times after the fact. The pollution should and must be measured in real time and  at the very least available for public viewing as all air monitors are; and the public notified immediately when pollution exceeds regulatory standards of an air quality emergency so that they can limit their exposure. Power shortages are only likely to happen on the hottest or coldest days. Summer heat waves are some of the worst air quality days and will only be made worse by the thousands upon thousands of diesel generators running in our backyard.

DEQ Notice of action: The Department of Environmental Quality (DEQ) is considering the issuance of an order and local variance for data centers located in the Counties of Fairfax, Loudoun, and Prince William.  A variance is an exception to a general rule. This notice is given in accordance with the requirements of § 10.1-1307 C of the Code of Virginia. 

Regulations affected: The primary regulation affected by this action is 9VAC5-80-1110 C of 9VAC5-80 (Permits for Stationary Sources). 

Purpose of notice: DEQ is seeking comments on the proposed variance. 

Public comment period: January 26 to March 14, 2023 at this link

Public hearing: Conference Room, Northern Regional Office, 13901 Crown Court, Woodbridge VA, at 11:00 a.m., on February 27, 2023.