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Subject: PJM CIFP Fast Tracking — Comments & Recommendations — Coalition to Protect Prince Willam County
Importance: High
November 10, 2025
The Coalition to Protect Prince William County fully concurs with the recommendations outlined below by Protect Fauquier.
PJM declares “Service with Integrity” as their guiding principle.
NO RESIDENT in our state or in the PJM territory, deserves to have our regional transmission organization breaking from that guiding principle by pushing “fast tracking” approvals of power generation to support unprecedented data center load growth. The unknown cost of this approach will likely lead to increased usage of diesel and gas generators at data centers, risking the health and welfare of families in neighborhoods, schools, and other areas across the PJM region in close proximity to the data center proliferation threatening our communities.
Elena Schlossberg Karen Sheehan
Executive Director Director
*********************************
Date: 11/10/2025 10:00 AM EST
Subject: PJM CIFP Fast Tracking Data Centers — Comments & Recommendations from Protect Fauquier by 5 pm Today to PJM re “Fast Tracking” data centers
November 10, 2025
On behalf of the 1700 members of Protect Fauquier — and millions of other Virginia residents — we respectfully submit these recommendations on the PJM CIFP “fast track” options for allowing more data centers (aka “large loads”) and power generation to be approved:
- Document risk of increased use of polluting and noisy diesel generators at data centers in the PJM region: It is likely that most of the “fast track” options under consideration will lead to an increase in usage of diesel and natural gas generators at data centers. Data center emergency generators are the size of railroad boxcars, entail dozens or hundreds of such generators at different data center locations, and most are highly polluting and noisy “Tier II” generators. In many cases, data centers are located in close proximity to residential neighborhoods, schools, and recreation areas and parks — as close as a few hundred feet.
The existing MW of data center back-up generators is enormous, especially in Virginia, and highly concentrated geographically. Based on VA DEQ’s database of data center back-up generator permits, we estimate that there is:
12 GW of back-up generation in Loudoun County VA alone;
22 GW of back-up generation in the state of VA
already approved through minor air permits from VA DEQ — most of which are highly polluting Tier II diesel generators — and with many more GW in the pipeline from pending and planned data centers.
Prior to finalizing any “fast track” recommendation, the PJM Board should ensure a thorough analysis of the existing and likely increased use of back-up diesel and natural gas generators and their potential air and noise emissions. The PJM Board should also establish a means to track the use and impacts from existing and future use of back-up generators by data centers. In particular:
(a) Document the MW of back-up diesel and natural generators currently operating or approved for operation, by locality and by state, and by type of generator;
(b) Estimate the potential increase in MW for additional generators, by state and locality) under current policies;
(c) Estimate the potential increase in MW for additional generators under a new “fast track” PJM policy, by state and locality, by generator type, and by year;
(d) For each of (a), (b), and (c), estimate the emissions of NOx, PM 2.5, CO2, CO, and noise likely to be emitted by the associated generators, under multiple scenarios, including scenarios of steadily increasing climatic temperatures and extreme weather events which increase grid risk;
(e) Conduct discussions with state environmental agencies and document policy changes in process or under consideration that will allow wider use of such diesel and natural gas generators than previously allowed (such as the VA DEQ guidance issued on 9/30/25 that allows broader use of back-up generators than previously allowed);
(f) Enter into agreements with state environmental agencies that ensure advance notification of any future policy changes affecting the use of back-up generators by data centers in the PJM region;
(g) Ensure that there is a mechanism for PJM to be notified of any and all use of back-up diesel and natural gas generators, including data center location and operator, number and type of generators activated, and dates and hours of activation, together with estimated amount of air quality and noise emissions produced;
(h) Maintain a public data base of the above information, organized by state and locality, and data center entity;
(i) Issue an annual report each year of the above information; and
(j) make it a condition for any new “fast tracked” data center and power generation plant that reliable monitoring devices are installed — at the expense of the relevant data centers — to measure both noise and air quality emissions and be posted to a public database.
During PJM’s many CIFP meetings, a Protect Fauquier member has raised concerns about generator use and their health impacts several times — but there has been no apparent consideration or follow-up by PJM staff — in contrast to the intense, detailed, and prolonged responsiveness to the concerns and interests of data center and utility stakeholders on other matters.
- Evaluate and document the percent of actual data center load in MW as a percent of approved MW of capacity. During PJM CIFP meetings, PJM asserted that there is “historical data” on actual data center load as a percent of approved capacity and that the historical data supports a 70% default factor. However, no such evidence has been provided — and there has been no analysis of the likelihood that over time this 70% factor will increase over time.
An increase in the 70% factor for existing and new data centers could substantially increase the actual load on the grid from data centers — and thereby exacerbate grid reliability risks, costs, and back-up generator usage. Therefore, we call on PJM to:
(a) Provide public evidence supporting the PJM assertion that current actual data center load is at 70% of approved capacity once a data center complex is fully ramped up — together with evidence as to whether this factor increases over time;
(b) Evaluate how this 70% factor (or variations used by individual utilities) is a reliable basis for existing and future load estimates, including considering reliability risks from significant variations in intensity of the factor from peaking effects;
(c) Especially evaluate whether, over time, actual usage as a % of approved capacity is likely to rise — collectively, across all data centers in PJM territory — as a result of (i) increasing climate temperatures that drive up summer cooling load; and (ii) increased use of AI as more and more applications and users come into play– driving up intensity of usage of servers and other data center equipment;
(d) ensure that any “fast track” policy recommended or adopted by the PJM board is not affected by an undercounting of present and future data center load from inadequate assumptions about intensity of use.
During PJM’s many CIFP meetings, a Protect Fauquier representative has raised this concern, but, again, there has been no apparent response or consideration, in contrast to the treatment of issues and questions raised by data center and utility stakeholders on their interests.
Submitted by the Executive Board of Protect Fauquier (Virginia):
Mike Fultz
Cindy Burbank
Denise Schefer
PJ Leary