Senator Mark Warner
Senator Tim Kaine
Representative Don Beyer
Representative Gerry Connolly
Representative Abigail Spanberger
Representative Jennifer Wexton
Representative Rob Wittman
September 20, 2022
Dear Virginia Senators and Northern Virginia Representatives,
As many of you know, the proposed Prince William Digital Gateway (PWDG) is a Comprehensive Plan Amendment (CPA) in Prince William County to designate over 2,100 acres for data center development in a currently rural area, directly adjacent to Manassas National Battlefield Park (Battlefield) and Conway Robinson State Forest. We are writing to alert you that Prince William County is moving quickly to approve this massive and irreversible proposal despite significant opposition and many unanswered questions. The County’s Planning Commission voted to recommend approval at its September 14th meeting and the CPA is now on a fast track for approval by the Prince William Board of Supervisors as early as mid-October. This proposal is opposed by more than 30 environmental and historic preservation nonprofits, thousands of community members, the National Park Service, the Virginia Department of Forestry, and dozens of regional Homeowner Associations.
While this might appear at first glance to be primarily a local issue, it differs from other land use decisions in its proximity to a national park and state forest, and that it risks inflicting significant and negative impacts on those resources, damaging the region’s drinking water supply and accelerating the rise of carbon emissions in Prince William County, undermining state and regional targets. Further, such action will distinguish Prince William County as the jurisdiction which is reversing its commitment to maintaining a protective down zoned area in its Rural Crescent.
As concerned environmental, national park, smart growth, natural resource and conservation and historic preservation organizations, we are extremely concerned that allowing a huge complex of data centers and industrial development just a stone’s throw from the Battlefield will irreparably harm the visitor experience to the park and undermine the decades of collaborative efforts that have gone into protecting this nationally important historic landscape. In addition, the proposal implicates road widening and road connections that reflect a key segment of the age- old outer beltway proposal (Bi-County Parkway). It would also have severe visual and noise and huge additions of impervious surfaces necessary to accommodate an additional 27 million square feet of data centers. Perhaps most concerning to the Northern Virginia region is the fact that Prince William County houses the largest portion of the land within the Occoquan Watershed (40 percent) with over one-third of that forested land.
Our groups and local residents have consistently weighed in on this proposal and there is no indication that decision-makers are listening to the levels of concern expressed. The CPA language prepared by county staff and approved by the Planning Commission is woefully inadequate to protect against impacts to the Battlefield and address the other concerns raised above. Local water authorities and neighboring jurisdictions have also weighed in to express concerns about maintaining drinking water quality.1Letter from Fairfax Water to Rebecca Horner, Prince William Deputy County Executive, March 21, 2022.
There is a history of Congress intervening in local matters when national parks and public lands are at risk from short-sighted development proposals. In fact, this occurred in 1988 when Congress purchased the Brawner Farm along Pageland Lane to avert the construction of a mall. Today, with the decline of conventional shopping malls, we can only imagine the fate of the once-proposed mall adjacent to the park. It raises the question of when this generation of data centers will be outmoded and will the national park and its visitors be left with dilapidated industrial buildings as new technology replaces this generation of servers?
The broad array of organizations listed below reflects the high level of concern with this proposal. We ask that you add your voices and work with the Board of County Supervisors to guide this type of proposal to a more suitable location in the County, such as the existing Prince William Data Center Overlay District.
As always, members of our groups, including those signed below, are happy to discuss this further with you and your staff and provide any additional information or answer your questions.
Thank you for your service to our community and for your response to this letter.
Sincerely,
| Kate West, Director Sierra Club Virginia Chapter Joseph Eaves, President Manassas Battlefield Trust Elizabeth Kostelny, Chief Executive Officer Preservation Virginia Kim Hosen, Executive Director Prince William Conservation Alliance Stewart Schwartz, Executive Director Coalition for Smarter Growth Julie Bolthouse, Director of Land Use Piedmont Environmental Council Nancy Vehrs, President Virginia Native Plant Society Elizabeth Merritt, Deputy General Counsel National Trust for Historic Preservation Renee Grebe, Audubon Naturalist Society David V. Brotman, Executive Director Friends of the North Fork of the Shenandoah River Anne Little, Executive Director Tree Fredericksburg Glenda Booth, President The Friends of Dyke Marsh Mark Perreault, President Citizens for a Fort Monroe National Park Claudia Thompson-Deahl, Conservation Chair Prince William Wildflower Society Elizabeth Lyons, President Audubon Society of Northern Virginia Jim Campi, Chief Policy and Communications Officer American Battlefield Trust David Sligh, Conservation Director Wild Virginia | Kyle Hart, Mid-Atlantic Program Manager National Parks and Conservation Association Robin Broder, Deputy Director Waterkeepers Chesapeake Skip Stiles, Executive Director Wetlands Watch Eric Goplerud, Chair Faith Alliance for Climate Solutions Michael Murray, Chair Coalition to Protect America's National Parks Lee Francis, Deputy Director Virginia League of Conservation Voters Morgan Butler, Senior Attorney Southern Environmental Law Center Frank Washington, Director Coalition To Save Historic Thoroughfare Leighton Powell, Executive Director Scenic Virginia Pat Calvert, Sr Policy + Campaign Manager Virginia Conservation Network Hope Cupit, Executive Director Southeastern Rural Community Assistance Project Reed Perry, Manager of External Affairs Chesapeake Conservancy Alexander M. Nance, Executive Director Virginia Piedmont Heritage Area Nancy Stoner, President Potomac Riverkeeper Network John Clewett, Co-Lead Lewinsville Faith in Action Conservation Advocate Northern Virginia William W. Sellers President/CEO Journey Through Hallowed Ground National Heritage Area |
September 20, 2022
Northern Virginia State Senators
Northern Virginia State Delegates
Fairfax County Board of Supervisors
Dear Northern Virginia State and Local Elected Officials,
As many of you know, the proposed Prince William Digital Gateway (PWDG) is a Comprehensive Plan Amendment (CPA) in Prince William County to designate over 2,100 acres for data center development in a currently rural area, directly adjacent to Manassas National Battlefield Park (Battlefield) and Conway Robinson State Forest. We are writing to alert you that it appears that Prince William County is moving quickly to approve this massive and irreversible proposal despite significant opposition and many unanswered questions. The County’s Planning Commission voted to recommend approval at its September 14th meeting, and the CPA is now on a fast track for approval by county officials. Following the Planning Commission vote, all signs point to a rapid approval by the Prince William Board of County Supervisors (BOSC) as early as mid-October. This proposal is opposed by more than 30 environmental and historic preservation nonprofits, hundreds of community members, the National Park Service and Virginia Department of Forestry2December 23, 2021 Letter from Commonwealth of Virginia Department of Forestry Forestland Conservation Coordinator Sarah Parmelee to Board of County Supervisors Chair Ann Wheeler. , and dozens of regional Homeowner Associations.
While this might appear at first glance to be primarily a local issue, it differs from other land use decisions in its proximity to a national park and state forest, and that it risks inflicting significant and negative impacts on those resources, damaging the region’s drinking water supply and accelerating the rise of carbon emissions in Prince William County, undermining state and regional targets.
As concerned environmental, national park, smart growth, natural resource and conservation and historic preservation organizations, we are extremely concerned that allowing a huge complex of data centers and industrial development just a stone’s throw from the Battlefield will irreparably harm the visitor experience to the park and undermine the decades of collaborative efforts that have gone into protecting this nationally important historic resource. In addition, the proposal implicates road widening and road connections that reflect a key segment of the age- old outer beltway proposal (Bi-County Parkway). It would also have severe visual and noise impacts and huge additions of impervious surfaces necessary to accommodate an additional 27 million square feet of data centers. Further, such action will distinguish Prince William County as the jurisdiction which is reversing its commitment to maintaining a protective down planned area in its Rural Crescent.
Perhaps most important to the Northern Virginia region is the fact that Prince William County houses the largest portion of the land within the Occoquan Watershed (40 percent) with over one-third of that forested land. For residents in Eastern Prince William, the City of Alexandria, Fort Belvoir and parts of Fairfax County, the Occoquan Reservoir is the primary source of drinking water.
Fairfax Water, which treats drinking water for over 2 million residents and in Northern Virginia, has expressed serious concerns with the PWDG and requested that “Prince William County request that the Occoquan Basin Policy Board convene and oversee a Comprehensive Study of the proposed Planning initiatives – the Comprehensive Plan Update, Digital Gateway Corridor, and the Data Center Opportunity Overlay District – to evaluate their impact on water quality in the Occoquan Reservoir.” Fairfax Water has asked the county “to embrace a holistic and comprehensive approach” using its Watershed Model “as an essential input to the land use decision process.”3Letter from Fairfax Water to Rebecca Horner, Prince William Deputy County Executive, March 21, 2022. The Board of County Supervisors recently agreed to a study, but the findings of that study will not inform their decisions, since results will be available long after the Digital Gateway CPA will come to the BOCS for a vote.
Our groups and local residents have consistently weighed in on this proposal and there is no indication that decision-makers are listening to the levels of concern expressed. The draft CPA language prepared by county staff and approved by the Planning Commission is woefully inadequate to protect against impacts to the Battlefield and Conway Robinson.
The Commonwealth of Virginia subsidizes the data center industry without knowing the true costs to the Virginia taxpayer.4http://jlarc.virginia.gov/pdfs/reports/Rpt518-1.pdf Between FY 2010-17, state tax exemptions for data centers cost taxpayers $417.47 million. That figure could be well over $1 Billion by now. While localities are wooed by local tax revenue, we know two things: revenue diminishes over time and it does not cover the long-term tangible and intangible environmental costs.
- Who will pay to address a degradation in water quality?
- Who will be responsible for the rise in carbon emissions and who pays to mitigate
increases in carbon emissions? - To what extent will ratepayers incur increases in electricity bills to pay for new data
center infrastructure?
The broad array of organizations listed below reflects the high level of concern with this proposal. We ask that you add your voices and work with the Board of County Supervisors to guide this type of proposal to a more suitable location in the County, such as the existing Prince William Data Center Overlay District.
Local and State leaders will increasingly be confronted by these questions. We have the opportunity to make changes now before irreversible land use decisions are made.
As always, members of our groups, including those signed below, are happy to discuss this further with you and your staff and provide any additional information or answer your questions. Please contact Ann Bennett at an************@gm***.com regarding this matter.
Thank you for your service to our community and for your response to this letter.
Sincerely,
| Kate West, Director Sierra Club Virginia Chapter Joseph Eaves, President Manassas Battlefield Trust Elizabeth Kostelny, Chief Executive Officer Preservation Virginia Kim Hosen, Executive Director Prince William Conservation Alliance Stewart Schwartz, Executive Director Coalition for Smarter Growth Julie Bolthouse, Director of Land Use Piedmont Environmental Council Nancy Vehrs, President Virginia Native Plant Society Elizabeth Merritt, Deputy General Counsel National Trust for Historic Preservation Renee Grebe, Audubon Naturalist Society David V. Brotman, Executive Director Friends of the North Fork of the Shenandoah River Anne Little, Executive Director Tree Fredericksburg Glenda Booth, President The Friends of Dyke Marsh Mark Perreault, President Citizens for a Fort Monroe National Park Claudia Thompson-Deahl, Conservation Chair Prince William Wildflower Society Elizabeth Lyons, President Audubon Society of Northern Virginia Jim Campi, Chief Policy and Communications Officer American Battlefield Trust David Sligh, Conservation Director Wild Virginia | Kyle Hart, Mid-Atlantic Program Manager National Parks and Conservation Association Robin Broder, Deputy Director Waterkeepers Chesapeake Skip Stiles, Executive Director Wetlands Watch Eric Goplerud, Chair Faith Alliance for Climate Solutions Michael Murray, Chair Coalition to Protect America's National Parks Lee Francis, Deputy Director Virginia League of Conservation Voters Morgan Butler, Senior Attorney Southern Environmental Law Center Frank Washington, Director Coalition To Save Historic Thoroughfare Leighton Powell, Executive Director Scenic Virginia Pat Calvert, Sr Policy + Campaign Manager Virginia Conservation Network Hope Cupit, Executive Director Southeastern Rural Community Assistance Project Reed Perry, Manager of External Affairs Chesapeake Conservancy Alexander M. Nance, Executive Director Virginia Piedmont Heritage Area Nancy Stoner, President Potomac Riverkeeper Network John Clewett, Co-Lead Lewinsville Faith in Action Conservation Advocate Northern Virginia William W. Sellers President/CEO Journey Through Hallowed Ground National Heritage Area |
cc:
Jamie Bain Hedges, P.E. General Manager, Fairfax Water
Robert Lazaro, Executive Director, Northern Virginia Regional Commission
Addressees:
Senator Jeremy McPike
Senator Scott Surovell
Senator George Barker
Senator John Bell
Senator Richard Stuart
Senator Dave Marsden
Senator Chap Petersen
Senator Adam Ebbin
Senator Jennifer Boysko
Senator Janet Howell
Senator Richard Saslaw
Senator Barbara Favola
Delegate Candi King
Delegate Danica Roem
Delegate Dan Helmer
Delegate Luke Torian
Delegate Elizabeth Guzman
Delegate Michelle Maldonado
Delegate Briana Sewell
Delegate Suhas Subramanyam
Delegate David Bulova
Delegate Vivian Watts
Delegate Eileen Filler-Corn
Delegate Kathy Tran
Delegate Mark Sickles
Delegate Charniele Herring
Delegate Paul Krizek
Delegate Elizabeth Bennett-Parker
Delegate Karrie Delaney
Delegate Kaye Kory
Delegate Alfonzo Lopez
Delegate Marcus Simon
Delegate Rip Sullivan
Delegate Kathleen Murphy
Delegate Ken Plum
Delegate Irene Shin
Chairman Jeff McKay
Supervisor Dan Storck
Supervisor Rodney Lusk
Supervisor Penny Gross
Supervisor Patrick Herrity
Supervisor Kathy Smith
Supervisor Dalia Palchik
Supervisor James Walkinshaw
Supervisor John Foust
Supervisor Walter Alcorn