Case Comments for PUR-2024-00135
State Corporation Commission
Application of Dominion Energy Virginia for electric
transmission facilities in Fairfax County:
230 kV Lines #210 and #243 Extension and 230-34.5 kV Edsall Substation
December 5, 2024 Testimony by Ann Bennett Data Center Issues Chair, Virginia Sierra Club
Dear SCC Hearing Examiner,
Thanks for the opportunity to testify. As the Virginia Chapter Sierra Club Data Center Chair, I follow these projects all over the Commonwealth and it is hard to find one that is more ill-suited based on its location and site configuration. This industrial project undermines basic environmental protections, climate goals and lacks a common-sense respect to adjacent residents. We ask that you deny this application in its current form.
Location/Environment
The proposed substation and 120 ft. transmission lines would run directly next to three urban communities, two already struggling streams, near a public park and community pool. That should be enough to deny this inappropriate site for a two massive and noisy data centers and their power facilities. But there’s more.
Turkeycock Run and Backlick Run feed into the Chesapeake Bay and certainly will not be improved by this new, industrial infrastructure. Transmission in the Resource Protection Area (RPA) with grass replacing the existing trees planted around the large poles will provide no relief to a stream under pressure already. The purpose of the RPA is to protect the streams. We believe that proposed transmission lines should be moved well away from Turkeycock Run and specifically any development should be required to restore the RPA to at least a 100 foot wide buffer as spelled out in the The Chesapeake Bay Preservation Act (Bay Act). This law was enacted by the Virginia General Assembly to protect and improve water quality with the implementation of effective land use management practices. We do not see that at work here.
(9VAC25-830-80. Resource Protection Areas.)**
By removing mature trees, aesthetic protections and natural noise mitigation will be gone as will the benefit that trees bring to air quality and carbon reduction. In your consideration of the “probable effects of the line on the health and safety of the persons in the area concerned,” keep in mind that the new data center use will be more intense and will be much taller at 75 feet as will the substation, replacing a parking lot and current building. This contrasts with the current warehouse use, in its close proximity and the new exposure residents will have to toxic diesel generator emissions and fumes and 24/7 noise from chillers and generators already planned to be adjacent to the transmission lines. Not to mention the diesel emissions from delivery trucks on Edsall Road and at Plaza 500 where small kids play near their homes and at the community pool.
Fairfax County is an ozone non-attainment area under the Clean Air Act and this project will make attainment that much more out of reach.
Jurisdictions with data centers are seeing huge jumps in carbon emissions. Reducing carbon emissions is also in the public interest.
Site Configuration
It does not pass a common-sense test to propose or allow a substation to be sited and operating 80 feet from established residences. Residents could not have imagined that electricity infrastructure would be proposed where they can practically reach out and touch it. The proposed placement of the substation is clearly only in the applicant’s interests and is incompatible with the existing residential.
Should you move forward with this proposal in some form, we ask that you require that the substation and the transmission lines be moved away from both adjacent communities to the south and east portion of the property.
Cost
In the November 15, 2024 SCC directed Integrated Resources Supplement (IRP), we learned that:
1. Data centers are driving the demand for new power, and
2. The 230 kV transmission line proposed here is for the interconnection of new data center load. This means that this project is simply to benefit one customer - in this case Amazon’s proposed 2 data centers - while transferring the cost to ratepayers who subsidize the project to Amazon’s financial benefit. (Edsall 230 kV Delivery – DEV)
Dominion’s 2024 IRP to the SCC states that ratepayers can expect high increases in electricity rates, and that is only based on projects in the pipeline now. Analyzing its favored scenario using the methodology directed by the SCC, Dominion projects residential bills will rise over the next 15 years from an average of $142.77 today to $315.25 in 2039, which we do not believe to be in the public interest of Virginia ratepayers.
So, this ethnically, socioeconomically, religiously, and otherwise diverse community gets to pay twice: 1. To live unprotected from the harmful and the negative impacts of adjacent industrial power infrastructure, and 2. subsume increased electricity bills to help pay for Amazon’s data centers. If this isn’t an economic and environmental injustice, I don’t know what is. Please reject this application.