Data Centers/Clean Air Act: Washington Department of Ecology Draft Area-Specific General Order

The Washington Department of Ecology (“WDE”) has proposed an air quality general order for data centers in certain areas of the State of Washington.

The draft order applies to data centers that use emergency generators powered by diesel.

Data centers are often described as a centralized physical facility that stores businesses’ critical application and data. The common data center definition is a location where computing and networking equipment is used to collect, process, and store data, as well as distribute and enable access to resources.

A data center’s components typically include cyber security systems, firewalls, routers, servers, storage systems, and switches. A server will be a high-performance computer with a significant amount of memory. Of particular relevance is the power equipment such as backup batteries and generators and uninterruptable power supplies. Further, cooling systems and equipment to handle air quality and temperatures such as air handlers, chillers, fans, sensors, and water pipes and tanks are required for the facility to run efficiently.

The Trump Administration recently issued an Executive Order whose stated objective is to ensure that artificial intelligence infrastructure can be built expeditiously. See Winning the Race AMERICA’S AI ACTION PLAN. A quote from the Action Plan references:

… Streamlined Permitting for Data Centers, Semiconductor Manufacturing Facilities, and Energy Infrastructure while Guaranteeing Security.

Regardless, various states have or are putting in place measures to address air emissions and other issues generated by data centers.

The draft WDE general order would require the following:

• Regulates emissions from future data centers.
• Requires an applicant to meet specific conditions and compliance measures.
• Limits installation to up to 21 emergency diesel engines. Each engine must not be higher than 4,423 brake horsepower (bhp).

Emissions from the emergency generators includes both criteria air pollutants and toxic air pollutants. Emissions are specified for:

• Ammonia (NH3)
• Carbon monoxide (CO)
• Diesel engine exhaust particulate (DEEP)
• Nitrogen dioxide (NO2)
• Nitrogen oxides (NOx)
• Particulate matter (PM)
  • PM2.5 
  • PM10
• Sulfur dioxide (SO2)
• Volatile organic compounds (VOCs)

WDE describes an air quality general order as a group permit that simplifies the air permitting process by allowing the agency to issue a general order when several sources of air pollution are similar, rather than a series of individual permits.

A copy of the draft general order can be downloaded here.