Sunday, April 16, 2023

DEQ Cancelled Data Center Generator Variance

 Last week the Virginia Department of Environmental Quality(DEQ) posted a notice that read in part:

“In response to public comment, a proposed variance for data centers located in Loudoun County was withdrawn by the Department on April 12, 2023.”

They went on to say “DEQ is cancelling the public notice and not moving forward at this time with the consideration of an issuance of an order granting a temporary local variance for data centers located in Loudoun County. …The proposal was intended to be an option to allow the data centers to continue to serve their customers, maintain the integrity of internet, and alleviate demand on the electric grid during periods of extreme stress. Given further discussion with stakeholders and public comment on the proposal, DEQ believes that these issues are now being addressed between the data centers, the utilities, and the regional transmission organization (PJM interconnect).If needed in the future, DEQ stands ready to assist in ensuring that Virginians have a reliable, affordable, clean, and growing supply of energy.”

Apparently, according to DEQ this variance hard fought by the public and NGO community was not necessarily. This variance would have provided data centers located in Northern Virginia originally and in the revised form after the first public hearing, only in Loudoun County to operate their Tier II and Tier IV generators during periods that PJM has initiated a "Maximum Generation Emergency/Load Management Alert" or during periods that PJM has declared a "Post Contingency Local Load Relief Warning" for Loudoun County.

According to the Washington Post: “Since 2020, three “Maximum Generation Emergency Load Alerts” have been issued — all of them last year, according to the PJM website.” The second category, “Post Contingency Local Load Relief Warnings” — are issued far more common, with 90 occurring in Dominion’s coverage area last year.  

This proposal did not include a demand response program like they have in California. In such a program Dominion and NOVAC or possibly the regional grid operator would provide financial incentives for data centers to reduce demand on the grid by shifting to on-site generation. These kind of  demand response programs usually include critical peak pricing, variable peak pricing, real time pricing, and critical peak rebates. Demand response programs also include programs for smaller users which provide the ability for the power companies to cycle air conditioners, heat pumps and water heaters on and off during periods of peak demand to manage the load.

Near the end of July last summer, Dominion Energy informed  data center companies and Loudoun County that power for some new facilities in Eastern Loudoun County would be delayed until 2026 due to inadequate transmission infrastructure. In 2022 Northern Virginia added 772 Megawatts (MW) of data centers. The grid in Northern Virginia has not kept pace with the massive data center growth in the region. 

During the first comment period lots of the public and community environmental groups spoke against the variance, but two of the most effective comments came from the Data Center Coalition and the Southern Environmental Law Institute. Josh Levi, president of the Data Center Coalition, pointed out that the variance was only necessary for eastern Loudoun County, the area that Dominion had given “assurance that the impact of the transmission constraint” would be limited.

Southern Environmental Law Institute Attorney Morgan Butler was very effective and specific in his comments, asking DEQ  to detail how many generators the data centers would be running, how long they would run and the volumes and types of additional air pollution they would contribute to the local environment.

In the revised notice DEQ estimated that there are approximately 4,021 diesel-fueled Tier II generators (older and of higher emissions) and 130 Tier IV (lower emissions) generators located at data centers in Loudoun County. The likely potential pollutants from a generator could include nitrogen oxides (NOX), particulate matter (PM10 and PM2.5), carbon monoxide (CO), volatile organic compounds (VOCs), and sulfur dioxide (SO2). Federal regulations limit the amount of nitrogen oxide emitted by permit holders to 100 tons per year and DEQ estimate the emission per hour per generator. With those restraints all the generators could have run approximately 5.13 days each before reaching the permit limit.

It was reported by the Bay Journal and the Virginia Mercury that on March 27, Josh Levi, president of the Data Center Coalition sent a letter to DEQ asking for the withdrawal of the variance altogether, citing “unresolved technical, federal regulatory and operational challenges.” Mr. Levy went on to say “Due to these issues, no DCC member has indicated they would use the variance.” 

The proposal has been cancelled, but the problem with the electrical grid infrastructure being adequate to meet the demand for transmission and power for data centers is still unresolved. In the first half of 2022, a record of 514 MW of data centers went operational in Northern Virginia (mostly Loudoun). However, in July 2022, Dominion Energy informed Loudoun County and various other entities that they  would no longer be able to support new data center developments in Eastern Loudoun due to limitations in transmission - their ability to distribute sufficient power to substations. This issue could delay projects currently planned or under active construction until at least 2024 if not further out. For the rest of 2022 only 208 MW of additional data centers came online. 

Demand for data centers in the region has not slowed. There are expected to be 965 MW of additional data centers coming online in 2023. This will bring the total northern Virginia regional load to more than 3,000 megawatts. To give you some idea of what that means: Dominion Energy has four nuclear reactors at two sites. The two Hog Island in Surry County reactors can generate a total of 1,638 megawatts. Two nuclear reactors in Louisa County near Lake Anna can generate a total of 1,863 megawatts. Those four reactors have historically generated 30% of Virginia’s power. By estimates provided by Cushman and Wakefield the demand for power from datacenters will surpass that by 2024.

The growth in data center power demand is ensuring that there is simply no path for Virginia to successfully meet the requirements and timeline of the Virginia Clean Economy Act (VCEA)with data centers growing demand for electricity. The energy needs of the Commonwealth, its businesses and its families are changing – and growing at a breath taking rate. Virginia is already the data center capital of the world and the industry is exploding along with the demand of 24 hours a day 7 days a week power needed to run them.

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