The document summarizes a community meeting about data centers and diesel generators in Loudoun County, Virginia. It discusses how the Virginia Department of Environmental Quality is proposing a variance to allow backup diesel generators at data centers to run more frequently, which would impact air quality and public health. The meeting covered background on regulations, health impacts of pollutants, concerns about the variance, and calls for the community to submit comments opposing the variance to DEQ and calling on elected officials and industry to take action to address the problem.

1. Loudoun Community Meeting:
Data Centers & Diesel Generators
March 28, 2023
Julie Bolthouse - Director of Land Use

2. We’ve got a problem.

3. How we deal with it will impact:
● Our air
● Our health
● Our electric bills
● Our climate
How much? The answer is being shaped right now.
Photo by PEO ACWA on Flickr

4. The Virginia Department of Environmental
Quality is proposing a variance to allow backup
diesel generators at data centers to run more
frequently this coming summer - setting a
dangerous precedent.

5. The DEQ variance would apply to more than
4,000 commercial sized diesel generators in
Loudoun County.

6. What we’ll cover tonight…
● Information about data centers and our energy system
● How and why air pollutants are regulated
● How DEQ’s proposed variance threatens public health
● Why the variance was proposed
● What the variance would do
● What action you can take

7. 1. To DEQ: Say ‘NO’ to more frequent and longer duration
usage of emergency generators.
2. To our elected officials: hit ‘pause’ and protect your
constituents.
3. To industry: Adjust your operations, pursue energy
efficiency and install less polluting backups.
What’s the “ask”?

8. First, some background…

9. Clean Air Act
The Clean Air Act (CAA) is the comprehensive federal law that regulates air
emissions from stationary and mobile sources. Among other things, this
law authorizes EPA to establish National Ambient Air Quality Standards
(NAAQS) to protect public health and public welfare and to regulate
emissions of hazardous air pollutants.
Photo credit: Jimmy Thomas via Wikimedia Commons Wikimedia Commons

10. Source: National Park Service -
https://www.nps.gov/subjects/air/sources.htm

11. Source: National Park Service -
https://www.nps.gov/subjects/air/sources.htm

12. Source: EPA -
https://www.epa.gov/ground-level-ozone-pollution/ground-l
evel-ozone-basics
Source: The contribution of particulate matter to respiratory allergy: A review
of current evidence. February 2020. Asian Pacific journal of allergy and
immunology / launched by the Allergy and Immunology Society of Thailand.

13. Source: Sources, characteristics, toxicity, and control of ultrafine particles: An overview. Geosciences Frontier.
Volume 13, Issue 1, January 2022, 101147.

16. Weʼve made significant progress… cars and trucks are 98-99% cleaner
than they were in the late 1960s for smog-related pollutants…
Source: EPA - https://www.epa.gov/greenvehicles/light-duty-vehicle-emissions

17. Non-Attainment Area
A non-attainment area is an area considered to have air quality worse
than the National Ambient Air Quality Standards as defined in the
Clean Air Act Amendments of 1970 (P.L. 91-604, Sec. 109).
Non-attainment areas must have and implement a plan to meet the
standard, or risk losing some forms of federal financial assistance. An
area may be a non-attainment area for one pollutant and an
"attainment area" for others.

19. Loudoun has been
ozone nonattainment
going back to 1992.
Increased generator
emissions will only
exacerbate this issue.

21. Why we are concerned:
● Human Health - Exposure to diesel
exhaust can lead to serious health
conditions like asthma and respiratory
illnesses and can worsen existing heart
and lung disease, especially in children
and the elderly.
● Environment - Emissions from diesel
engines contribute to the production
of ground-level ozone which damages
crops, trees and other vegetation. Also
produced is acid rain, which affects soil,
lakes and streams and enters the
human food chain via water, produce,
meat and fish. These emissions also
contribute to property damage and
reduced visibility.
• Global Climate - CO contributes
indirectly to climate change because it
participates in chemical reactions in
the atmosphere that produce ozone,
which is a climate change gas. CO also
has a weak direct effect on climate. For
these reasons, CO is classified as a
short-lived climate forcing agent.
• Environmental Justice – The health
implications of diesel emissions can
disproportionately impact lower
income communities and communities
of color who may face more barriers to
health care and larger financial
consequences for being absent from
work and school, and statistically face
higher levels of premature death.

24. Not enough information or consideration…
● Did not initially provide number generators (info obtained through FOIA and
pulled from over 100 air permit files by PEC)
● Did not provide location of generators (info pulled together by PEC)
● Did not provide information about number of hours the "Maximum
Generation Emergency/Load Management Alert" or a "Post Contingency
Local Load Relief Warning“ ran in the area (info pulled together by PEC)
● No analysis/modeling provided
● No information quantifying why this would not result in risk to public health
● No alternatives considered
● No community outreach
● Meeting is being held in Woodbridge instead of Loudoun County

25. Variance – Why?
“DEQ is concerned that Loudoun County is an area in which there may not
be a sufficient amount of electricity for data centers due to severe, localized
constraints in electricity transmission. A transmission constraint issue exists
in the area which may affect the ability to provide enough electricity to data
centers through 2025.”

37. Translation:
A doubling of peak load within 14 years due
entirely to increased data center
consumption!

38. 2.6 GW

39. Current Proposals:
Loudoun County:
●Nearly 30 mill sq ft
currently
●Around 10 mill sqft can
build out by-right in
Loudoun
●Additional rezonings
under consideration
y

40. Variance – What does it do?
● Allows Tier II and Tier IV emergency generators to operate outside of an
emergency within their annual emissions limits contained in their permits
and within EPA regulations
● Specifically when PJM has initiated a "Maximum Generation
Emergency/Load Management Alert" or a "Post Contingency Local Load
Relief Warning" for the area through July 31st
, 2023
● Applies to data centers in Loudoun

41. Emergency Diesel
Generators

42. Home Generator vs. Commercial
Commercial diesel generators
being used at data centers
range in size between 600 kW
to 3500 kW, which is much
larger than your typical
whole-house residential diesel
generator, typically between
10 kW to 26 kW.
Credit PEO ACWA on Flickr

43. To qualify as an emergency generator, the unit can only
operate when there is an “emergency”. In
Virginia, “emergency” is defined as:
A condition that arises from "sudden and reasonably
unforeseeable events" where the primary energy or power
source is disrupted or disconnected due to conditions
beyond the control of an owner or operator of a facility.

44. Emergency use standards are reduced because
these generators were never meant to run for
long periods of time.

45. Emergency vs. Non-Emergency Standards

46. Emergency vs. Non-Emergency Standards

47. Emergency vs. Non-Emergency Standards

48. Cumulative Impact of Annual Emissions in
Ashburn/Sterling alone
➢ NO2
- 3779.85 tons/year
➢ CO - 1497.94 tons/year
➢ VOC - 420.63 tons/year
➢ PM 10/2.5 - 141.72 tons/year

49. Variance – What does it do?
● Allows Tier II and Tier IV emergency generators to operate outside of an
emergency within their annual emissions limits contained in their permits
and within EPA regulations
● Specifically when PJM has initiated a "Maximum Generation
Emergency/Load Management Alert" or a "Post Contingency Local Load
Relief Warning" for the area through July 31st
, 2023
● Applies to data centers in Loudoun

50. How Frequently Do Those Alerts Happen?
137 hours from May 19 to May 22 in 2022!

51. Variance – What does it do?
● Allows Tier II and Tier IV emergency generators to operate outside of an
emergency within their annual emissions limits contained in their permits
and within EPA regulations
● Specifically when PJM has initiated a "Maximum Generation
Emergency/Load Management Alert" or a "Post Contingency Local Load
Relief Warning" for the area through July 31st
, 2023
● Applies to data centers in Loudoun

52. There are over 4,000 commercial sized diesel generators in Loudoun County!

53. Many of these generators are in close proximity
to sensitive areas…

56. This is not a “precautionary and redundant measure” as
described by DEQ
It is a threat to public health to accommodate
unprecedented electricity consumption by data centers.

57. Tell DEQ NO to allowing more frequent and longer duration usage of
emergency generators BUT no decision should be made until DEQ
provides:
• Provide more information about the potential impact on public health and the environment
• An analysis including calculations of primary pollutants released under higher, lower, and
equivalent scenarios as compared to 2022
• Require additional restrictions on operation near sensitive receptor locations
• Require real-time ambient monitoring of pollutants in affected areas
• Establish an alert system that notifies residents of affected communities (especially children,
elderly, and those with underlying conditions) where and when generators are running so they can
take precautions
• Develop a regulatory plan for requiring the industry to phase out Tier II diesel generators if this is
how they will be used

58. DEQ Public Hearing on Variance
Date: April 6th
Location:
Conference Room, Northern Regional Office,
13901 Crown Court, Woodbridge VA,
Time: 11:00 a.m.

59. DEQ Written Comments on Variance
Comments Received Until: April 21st
Submit to: Karen G. Sabasteanski,
karen.sabasteanski@deq.virginia.gov
Written comments must include the full name,
address and telephone number of the person
commenting and be received by DEQ by the last
day of the comment period.

60. ● How much data center space is approved in Northern Virginia?
● How much power does it demand?
● What infrastructure upgrades will be necessary to meet it?
● How much will it cost?
● Who will pay for it?
Also tell the state, agencies, utilities, and localities
to hit pause and start studying this issue: