December 11, 2023
Prince William County Board of Supervisors
1 County Complex Ct
Woodbridge, VA 22192
RE: Prince William Digital Gateway Rezoning Applications
Chair Wheeler, Vice Chair Angry, and Members of the Prince William Board of Supervisors:
We, the undersigned 33 organizations, write to you today regarding the rezoning applications for the Prince William Digital Gateway corridor, including Digital Gateway North and South, REZ2022-00032 and REZ2022-00033, and Compass Datacenters Prince William County Campus 1, REZ2022-00036 (collectively, the PWDG Rezonings). We write, once again, in strong opposition to these proposed rezoning applications, and urge you to vote no on all three applications on December 12, 2023.
Collectively, we are a combined group of local, regional, statewide, and national nonprofit organizations, dedicated to protecting our environmental, historic, and cultural resources, our human health, and our climate. We represent nearly four million members and supporters in Virginia and beyond, and combined we have centuries of experience protecting our precious natural resources. The negative impacts to environmental, historic, cultural, and natural resources that this project poses to Prince William County, Virginia, and beyond cannot be understated.
1. This project would have immediate and direct impacts on Conway Robinson State Forest and Manassas National Battlefield Park, which are public lands entrusted to the county to protect for future generations.
2. Commitments made by the applicants for community parks, wildlife corridors, natural open space, and more are severely lacking in the applications, and fall well below the standards set forth in the Prince William Digital Gateway Comprehensive Plan Amendment (PWDG CPA).
3. The project would require a tremendous amount of energy and new energy infrastructure. New transmission lines and new generation facilities could impact communities not only directly but also indirectly through utility rate increases and increased carbon pollution which the applicant has failed to offset in any meaningful way.
4. The negative impacts of air pollution, carbon emissions, local water pollution, decreased water supply, and utility rate increases as well as the degradation of public park land associated with this project have far reaching negative impacts that predominantly harm low-income communities and communities of color.
5. The impacts to the Occoquan Reservoir, the drinking water supply for more than 300,000 people in the region, have not been fully studied, but it is known that a project of this size will increase sediment and polluted runoff, particularly salinity levels, in the reservoir.
6. The staff have recommended denial because there’s not enough information or commitments from the applicant to ensure the environmental protections and other standards put forward will come to fruition.
We have gone in depth to these numerous concerns below, and we urge you to vote no on these applications on December 12.
1. Impacts to the Manassas National Battlefield Park and Conway Robinson State Forest:
The PWDG CPA restricted building heights in the southern district to 45 feet and restricted them to 85 feet in the northern district. This was made out of recognition of the significance of the resources closest to the southern district, the Manassas National Battlefield Park and Conway Robinson State Forest. Despite these restrictions and previous comments made by Prince William County Planning Staff, Manassas National Battlefield Park staff, and other concerned groups and agencies about proposed building heights exceeding these limits, the PWDG Rezonings continue to propose building heights significantly above the CPA-restricted heights. In their fifth submission, QTS is proposing a 70-foot height restriction in the southern district and a 93-foot height restriction in the northern district. Compass Data centers’ application even goes beyond this, proposing a 100-foot height restriction.
In the applicants’ own viewshed impact analysis, building facades and proposed electrical substations in the southern district “are anticipated to be visible from Manassas National Battlefield Park” and Conway Robinson State Forest. The applicants claim that these impacts will be minimal, but lack of information about the site layout, building footprints and building elevations make it impossible to determine the actual impact. Further, the screening planned is likely to take some time to be even minimally effective and the visual impact from the park will be significant. For example, the applicant is proposing to construct a reforested area between the Battlefield and the substation in Land Bay B of the PWDG South. Without this reforested area, the entirety of the electrical substation will be visible from the battlefield. This means that the 75 foot substation will most likely be highly visible for some time as reforestation takes years to complete and grow following project construction
As has been discussed by the Prince William Historical Commission and other historic preservation agencies, numerous historic sites are poised to be impacted by this project. For Digital Gateway South, Land Bays A and B lie entirely within the boundaries of the Manassas Battlefield Historic District, a Nationally Registered Historic District. Much of Land Bays C and D lie within the American Battlefield Protection Program identified Core Battlefield Area. That Core Battlefield Area extends northeast from Land Bays C and D to land owned by the American Battlefield Trust. Despite the known historical significance of these areas, the applicants continue to downplay the significance of these sites while pushing forward a plan that will destroy them in their entirety. Numerous historical reports brought forward by the County Historical Commission, confirmed by the National Park Service and the County Archaeologist, indicate the high likelihood of dispersed burials throughout the project corridor, but especially so in Digital Gateway South. Despite this fact, the applicants have made almost no changes to their applications to address these concerns.
We are also opposed to the impacts that long-term construction of this project will have on the battlefield and state forest, both human visitors to these sites and wildlife native to the area. Data center construction is an extremely intensive activity, involving heavy machinery, cranes, dump trucks, and more. Project construction in the corridor will be ongoing for many years. The applicants have done nothing to seek to mitigate or reduce the impacts to important viewsheds during this extended period, nor have they sought to mitigate the extensive noise and traffic project construction will bring to the corridor. The applicant should be required to be within the CPA-proposed height and noise restrictions throughout the entire construction period.
Expert after expert has made it abundantly clear that this project will have far reaching negative impacts on historic resources, a national park, and a state forest. Despite this fact, the applicants have not made any serious concessions to protect these resources. In fact, they blatantly ignore limits set forth in the PWDG CPA designed to protect these resources. This alone should be enough to warrant rejection of all three rezoning applications.
2. Inconsistency with the Comprehensive Plan around proposed County Parks, Trails, Open Space, and Wildlife Corridors:
During discussions surrounding the PWDG CPA, representatives from QTS and Compass Data Centers, both at public hearings and in private meetings with county and federal staff members, continually touted the dedication of several large interpretive parks as one of the benefits of the PWDG project. These parks, referred to as the Natural Cultural Resources Park and Southern Community Park in the applicants’ own conceptual plans, are notably absent from the current rezoning submissions. Without these large parks, the rezonings remain out of step with the PWDG CPA..
Beyond this, mapped trails in the applicants’ conceptual plans provided to county staff continue to show trails proceeding through neighboring properties not included in the rezoning applications, including property owned by the American Battlefield Trust (ABT). Applicants have not engaged with these landowners to negotiate consent or how they would cover the cost for placement, design, or construction of these trails, indicating that there is little evidence that these trails would actually come to fruition in the long run as it would be unfair and inappropriate to place this responsibility and cost on ABT and other adjoining landowners. In addition, we are concerned that maintenance of the large network of trails has not been fully determined and that a trail system through an industrial corridor with numerous transmission lines and substations is unlikely to be heavily used which may lead to it falling into disrepair if left to the applicants to maintain. We believe that, like the proposed large parks, this is yet another community benefit touted by the applicants to garner support for their disastrous proposal that will likely never actually be delivered as envisioned in the Comprehensive Plan.
Another place where this application is out of step with the approved PWDG CPA is in the Natural Open Space set aside to be preserved. The CPA had a target of 30% natural open space. All three of these applications fall far short of that percentage. Digital Gateway South includes 21.8% natural open space, Digital Gateway North includes a mere 15.9%, while Compass Data Centers include 16.9%. These totals are not even close to the goals set forth in the CPA.
Finally, original conceptual designs of the PWDG, along with requirements set forth in the CPA, showed clear wildlife corridors, which would have allowed animals to move freely about the area both north to south and east to west. Recent maps indicate large data center buildings where these wildlife crossings were originally planned, resulting in a fragmented smattering of inadequate wildlife corridors, which do not meet the desired goals set forward in the Comprehensive Plan. It is clear that the applicants have not met the goals or intent of the Comprehensive Plan and have prioritized maximizing profit over meeting the County requirements We believe this is wholly unacceptable. .
3. Sustainability, Energy, and Climate:
Climate change is the biggest threat to our region, state, and world in the 21st century. From longer droughts, more frequent wildfires, more intense storms, sea level rise, and more, the negative impacts of climate change are already being felt and will only get worse if nothing changes in the coming years. Anthropogenic climate change is caused entirely from the continuous burning of fossil fuels to power our homes and businesses, and a complete transition to 100% renewable, carbon-free electricity must be accomplished by 2050 to avoid the worst negative impacts of climate change. The current rezoning documents submitted by QTS and Compass Data Centers do nothing to advance the county, Virginia, or the nation’s stated climate goals, and the applicants’ commitments to sustainability are a pitiful attempt to rectify the massive energy needs this project will certainly have.
The applicant has provided no information about their energy usage or the type or number of back up generators they will have. Given the dearth of information, our own environmental nonprofit experts have estimated the project’s expected power demand using industry trends and energy usage of other data centers in the Northern Virginia area. These experts estimate that the PWDG project, including all three rezoning applications, will require at least 2.9 gigawatts of power to operate. This is the approximate amount of energy required to power more than 717,000 homes at peak load, more homes than Prince William and Fairfax Counties combined. Despite this, the applicants have made paltry commitments to sustainability, and rather than advancing our shared climate goals forward, they will drag us massively backwards in our fight against climate change.
First and foremost, the applicant should proffer a complete clean and carbon-free power purchase agreement for the entirety of their electricity needs. Without that clear and legally binding commitment, the Board must reject this proposal outright. Moreover, this proffer should include a provision for submitted proof that prior to energizing their first data center building, all renewable electricity sources must be constructed and operational. This is the only way for Prince William County to ensure that it is meeting the climate and clean energy goals stated in the county’s Comprehensive Plan and the approved PWDG CPA.
Beyond the clear lack of clean energy commitments, the applicants’ sustainability proffer statement lists sixteen possible sustainability measures the applicants may undertake. Unfortunately, the applicants only commit to executing five of these commitments for the entire project. Such provisions include the installation of LED light bulbs, inside and outside. Incredibly, the QTS Data Centers even divided the installation of LED light bulbs into two different sustainability measures and commits only to 85% LED coverage. This means that simply installing 85% LED light bulbs both inside and outside would be sufficient to meet two- fifths of the current sustainability measures proffered by QTS. Other paltry commitments include the installation of heat-reflective roofing, a small handful of EV chargers, and rain gardens. This low bar of commitment to sustainability is unacceptable. This Board of Supervisors should be satisfied with no less than all sixteen listed sustainability measures. Moreover, as stated above, the power purchase agreement proffer must include a clean energy commitment for 100% of the energy for the entire project, not just an undefined portion.
Many questions remain regarding the energy infrastructure that will be required to support this project. The applicants and project proponents have repeatedly stated that the existence of Dominion power lines along the PWDG corridor will support the project at full build-out. Energy experts have repeatedly disputed this claim, stating that the construction of a new electric corridor of a similar size may need to be constructed to support the project. Dominion and NOVEC have also confirmed that new transmission lines would still be needed to connect the substations even if the existing 500 kV lines do have enough capacity to serve the full build out (which is very unlikely given the data center growth in Loudoun and south of this site in other parts of Prince William). The large-scale power lines that will be needed will further degrade the viewshed and potentially require additional right-of-way from the Manassas National Battlefield, Conway Robinson State Forest, and other nearby properties. These impacts have been blatantly ignored by the applicants and provide yet another reason why this application must be rejected.
Also of note is the applicants’ proposed backup power generation plans. Action strategy DGSU 1.5 in the PWDG CPA encourages “the use of less carbon intensive or carbon neutral energy generation for backup generator systems.” This action strategy has taken on even greater importance following the waiver that the Virginia Department of Environmental Quality (DEQ) proposed earlier this year to grant data centers in Prince William, Fairfax, and Loudoun Counties greater leeway to use their emergency generators during periods of increased strain on the electric grid. Although DEQ narrowed and then ultimately withdrew that waiver proposal, the fact that the agency even proposed it evidences the added pressure that data centers are placing on the electric grid in northern Virginia—and growing concerns that data centers will need to rely on their emergency power sources more frequently than they have in the past. Given the harmful health impacts that the emissions from diesel-powered emergency generators can have on nearby communities and visitors and wildlife within Manassas National Battlefield Park and Conway Robinson State Forest—particularly with the number of generators that would be needed to provide backup power for the massive scale of data center development proposed here – it is clear that this application must be rejected as-is. The applicants’ unwillingness to move away from diesel generators is a clear indication of their priorities, and it certainly is not mitigating climate change and protecting clean air.
It is also worth noting that many of these same concerns were raised by your own Sustainability Commission, who passed a unanimous resolution, Res. No. 23-037 on September 28, 2023, supporting better climate measures in the PWDG Rezonings. Despite this resolution, no serious progress has been made in these applications.
4. Environmental Justice and Public Health:
The prospective approval of this massive data center campus raises concerns about the project’s disproportionate impact on marginalized communities, manifesting in escalated levels of air and water pollution and an upswing in electricity costs. The sustained reliance on fossil fuel plants, rather than transitioning to renewable alternatives, exacerbates these issues, adversely affecting both communities proximate to such facilities and exacerbating the broader implications of climate change. The ongoing advocacy led by the Virginia Sierra Club against the Chesterfield “peaker plant” underscores the dual challenges posed by heightened fossil fuel usage and associated health risks within local communities.
The peaker plant is proposed by Dominion Energy, who points solely to massive energy needs generated by large data center projects like the Prince William Digital Gateway as the impetus for this new gas-fired power plant. If built, this project would be the largest in Virginia, generating 7 billion pounds of climate change causing CO2 a year. Peaker plants like the one Dominion is proposing are also known for emitting pollutants harmful to human health such as small particulate matter, nitrous oxides, and ozone. Dominion plans to construct this project within two miles of neighborhoods that are historically disadvantaged and primarily composed of communities of color. QTS and Compass’ lack of firm commitments to 100% renewable energy sources for this project ensures that massive carbon-producing projects like the Chesterfield peaker plant will continue to power this project for years to come and push the impacts of generating this harmful power source onto Virginia’s most historically disadvantaged communities. Moreover, the climate change that comes from gas and coal power plants to fuel data centers results in people getting sick and dying from extreme heat, forest fires, weather catastrophes, drought and other climate change related problems. The negative impacts of climate change will be born most acutely by low-income communities and communities of color, both in the United States, and across the globe.
Furthermore, the reliance on diesel generators as backup energy sources in these applications adds another layer to the environmental injustice equation. In culmination, this project will require the existence of upwards of 1,000 or more massive diesel generators to supply backup power to the project. In the event of a power outage or high electric grid strain, these generators could all turn on at once, creating a massive amount of harmful air pollution in a short period of time. As laid out above, the energy needs for this project surpass the number of households in Prince William County and Fairfax County combined. In the event of an outage, enough diesel generators would be running simultaneously to power nearly the entire Northern Virginia region. This kind of air pollution would have devastating effects on the nearby users of trails and parks. It will also drift across the entire area, impacting all of the communities in its path. Air pollution is the 4th major cause of mortality worldwide causing ischemic heart disease events, heart attack, stroke, lung cancer, COPD, lower respiratory infections, Type 2 diabetes, pregnancy outcomes
and related infant mortality, with greater risk to those with asthma and COPD at baseline and low-income communities. The Digital Gateway will only exacerbate this problem.
Finally, the far-reaching financial ramifications of this project are equally significant. On top of Dominion Energy’s plans for continued reliance on fossil fuels to meet the demand of poorly- planned data center developments like the Digital Gateway, Dominion has acknowledged that all of its ratepayers will pay the price of the new electric infrastructure needed to meet this demand. In Dominion Energy’s 2023 Integrated Resource Plan, the company admitted that the typical residential ratepayer’s bill would double as a result of exploding energy demand from large data center projects like this one, rising at the rate of 5% annually until 2035. This projection of a 5% annual increase in rates will disproportionately affect economically disadvantaged communities, thereby intensifying environmental and economic inequities. Of course, this could be rectified by the applicants committing to sourcing 100% renewable energy for this project, and paying for the construction of those energy sources and the needed transmission lines to get that energy to the project location, but the applicants have failed to make that commitment.
5. Clean Water and the Occoquan Reservoir
Over the years since the PWDG was first proposed, many individuals, nonprofits, experts, and even Fairfax Water Authority have all raised concerns about this project’s potential impact to our regional water supply. The proposed rezonings would convert more than 1,500 acres of currently pervious surface, like fields and forests where water can penetrate into the ground and recharge groundwater, into impervious surface, like buildings, parking lots, and roads where the water runs off the surface and into waterways. Even Fairfax Water expressed concern about increased salinity levels and sediment from additional construction and stormwater runoff, and yet the county has still not completed the encouraged study of this project’s impacts on the Occoquan Reservoir. While many claim that this study will turn up nothing of note regarding PWDG, the public has still not yet heard from the experts conducting the study. It is not prudent of the Board to approve these applications without this study first being completed and reviewed by County staff and the Board.
Recent concerns have been raised about elevated levels of salt and PFAS (also known as forever chemicals) in the Occoquan Reservoir. Continued development of the Reservoir’s upper-most headwaters will only exacerbate this problem. A study conducted by CEA Engineers indicated that at full build-out, the project could increase stormwater runoff by nearly 300 million gallons per year. Stormwater runoff is likely to carry salts, toxins, and sediment downstream, through Bull Run and into the Occoquan Reservoir. The applicants have not committed to designs that would retain and infiltrate 100% of stormwater onsite, meaning that this polluted runoff will end up downstream in the regional drinking water supply. The increase of pollutants and sedimentation into the Occoquan Reservoir will likely lead to increased costs by the Fairfax Water Authority to filter the water and deliver drinkable water to its ratepayers. These costs will inevitably be passed on to Fairfax Water’s ratepayers. Much like the increased electricity infrastructure costs, this increased cost will be the most impactful to low income communities. This is an unacceptable outcome for Northern Virginia residents.
6. Lack of Information and Commitments:
The County planning staff has recommended denial of all three rezonings citing a lack of critical information and excessive flexibility in the proffers allowing the applicants to modify their plans after approval. Due to the scale and scope of these applications there are thousands of pages of material and few have been able to read the entire thing. This is why the planning staff’s professional assessment is critical here. Planning is a professional field that exists to review developers proposals and determine if they are consistent with the localities policies, protect public health, safety, and welfare, and provide adequate commitments to ensure that what is verbally promised is actually required. They’re not giving their personal opinion, they are giving a professional assessment, and their assessment in this instance is that the application does not provide enough information or commitments to ensure the development will come to fruition as planned.
They cite several shortcomings which we completely agree with. Rather than providing the building footprint and layouts the applicant only proffered the illustrative images of “typical land bays” in the Master Corridor Plan which the staff explained does not provide enough information or meet the requirements of the zoning ordinance. The building elevations are subject to a high level of variability making the commitment to ‘substantial conformance’ misleading. Without detail on these things the staff recommended denial of the waiver of the Special Use Permit for data centers outside of the Data Center Opportunity Zone Overlay. They continue to be concerned with the amount of flexibility the applicant gives themselves and the ability for the applicant to make adjustments post-approval without further review.
This lack of information and commitments is alarming for a project of this scale requiring massive infrastructure upgrades.
After reviewing these applications, it is clear that these rezonings if approved would have a devastating impact on Manassas National Battlefield Park, Conway Robinson State Forest, and locations far beyond those properties in close proximity. It is also clear that they have failed to meet the standards set forth in the PWDG CPA, failed to provide enough information or commitments to ensure the development would come to fruition as described, and failed to demonstrate a commitment to responsible data center development. Supporters of this project have repeatedly stated that Prince William County does development well and protects the environment in the process. However, these applications fail to meet that standard and thus should be rejected.
County staff and the Planning Commission have raised serious concerns and urged you to reject these applications. They have been rushed forward to meet artificial deadlines set by the applicants when the applications are far from complete. The Board should heed the recommendations of their county staff, county Planning Commission, Sustainability Commission, Historical Commission, and concerns raised by hundreds of community members, the National Park Service, Department of Forestry, Fairfax Water, and the 33 nonprofits who’ve signed on to this letter and vote no on these three rezoning applications.
Sincerely,
Jim Campi
Chief Policy and Communications Officer
American Battlefield Trust
Tom Blackburn
Chair, Advocacy Committee
Audubon Society of Northern Virginia
Mark Whitenton President
Bull Run Civil War Round Table
Jody Couser
Senior Vice President of Communications
Chesapeake Conservancy
Jennifer Cole
Executive Director
Clean Fairfax
Stewart Schwartz
Executive Director
Coalition for Smarter Growth
Michael B. Murray
Chair
Coalition to Protect America’s National Parks
Frank Washington
Director
Coalition To Save Historic Thoroughfare
Elena Schlossberg
Executive Director
Coalition to Protect Prince William County
Rev. Dr. Jean Wright
Co-Founder
Faith Alliance for Climate Solutions
Lynn Wilson
President
Henrico Conservation Action Network
William W. Sellers
President
Journey Through Hallowed Ground National Heritage Area
Eleanor Kluegel
Clean Streams Coordinator
Litter Free Virginia
A. Scott Neese
President of the Board
Manassas Battlefield Trust
Kyle Hart
Program Manager, Mid-Atlantic Region
National Parks Conservation Association
Elizabeth S. Merritt
Deputy General Counsel
National Trust for Historic Preservation
Lydia Lawrence
Director of Conservation
Nature Forward
Alan Rowesome
Executive Director
Northern Virginia Conservation Trust
Julie Bolthouse
Director of Land Use
Piedmont Environmental Council
Nancy Stoner
President
Potomac Riverkeeper Network
Dean Naujoks
Potomac Riverkeeper
Elizabeth S. Kostelny
CEO
Preservation Virginia
Ashley Studholme
Executive Director
Prince William Conservation Alliance
Chris Colvin
President
Protect Catlett
Mike Fultz
President
Protect Fauquier
Hope F Cupit
CEO
Southeastern Rural Community Assistance Partnership Inc (SERCAP)
Susan Bonney
Chair
Sierra Club, Great Falls Group
Connor Kish
Director
Sierra Club Virginia Chapter
Paul DiLorenzo MD FACC
Member, Steering Committee
Virginia Clinicians for Climate Action
Lee Francis
Deputy Director
Virginia League of Conservation Voters
Nancy Vehrs
President
Virginia Native Plant Society
Alexander Nance
Executive Director
Virginia Piedmont Heritage Area
Robin Broder
Deputy Director
Waterkeepers Chesapeake