Wednesday, December 13, 2023

Comments to the Board on PWDG

The following were our comments delivered to the Board of County Supervisors on December 12 in opposition to 3 rezoning applications collectively referred to as the Prince William Digital Gateway.

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I understand that many of you have already formed your opinions on the rezonings we are discussing today. The allure of hundreds of millions of dollars in tax revenue is undeniable. I also acknowledge that this has been a long day, and it's a challenge to ask anyone to remain engaged for such an extended period. Yet, I implore you to pause for a moment. This is not a process to be endured simply to cast a vote at the end. There is wisdom in this process, and there is wisdom in the voices standing up for sustainability and our environment. 

Let's not forget that even with the approval of the Comprehensive Plan Amendment, these proposals are not inevitable.  Fairfax County, for example, took a decisive step by downzoning, - not just replanning, but downzoning 41,000 acres in order the protect the Occoquan reservoir - a decision was upheld by the courts. Here in Prince William County, our primary strategy to protect the drinking water that the eastern end relies on - me included - has been to maintain the rural area that reduces development pressures on the reservoir. 


Now, we have heard that there are data centers within the Occoquan Reservoir watershed as justification for this proposal. But we’re talking about expanding development further. What we’re witnessing here is a slow death by a 1000 cuts. If we do not hold the line who will? Are we willing to put our drinking water on the line before conducting a study as Fairfax Water suggests? 

It is no secret that we, along with many other environmental and historic preservation organizations speaking tonight, have been against developing the Pageland corridor for data centers from the beginning. But, what we’re seeing here goes well beyond siting issues. These proposals fall short of even the minimum requirements promised in the Comprehensive Plan Amendment (CPA). Staff outlined these shortcomings in their presentations, I would like to now take a moment to expand on what has been noted in addition to several discrepancies in the process. 

From the beginning, this process valued potential economic gains over consideration for the environmental consequences. In reviewing the 5th submission, I was alarmed by the applicant's statement “to expect substantially greater detail at this stage in the development  process ignores the size and scope of the design, engineering, and market influences that come with developing over 11 million square feet of nonresidential development over a 15 to 20 year time period.” I would say, that it is because of its size and scale that we need more information to adequately assess impacts to our water supplies, our grid, and the surrounding area. 

This massive proposal would be the largest data center complex in the world, in an era marked by climate change, mass extinction, and numerous other environmental challenges, the traditional paradigm of placing economic development above all else is no longer tenable and hasn’t been for a long time. As custodians of this county, you are tasked with a profound responsibility—to pioneer a more progressive, sustainable approach that not only propels economic development but also protects our environment and the health of our residents. 

By adopting a more progressive approach, we can position our county as a beacon of sustainable development, attracting businesses and investments that align with our commitment to environmental responsibility. This is not just an idealistic aspiration; it is a strategic imperative in the face of a changing climate and a global push toward sustainability. I don’t see how you can champion sustainability and support these rezonings. 

These proposals are simply business as usual…it's just bigger and they just have more money behind it. If there is so much to be gained, why not encourage more investment in our community and ecological and historical preservation from the outset? From what I have seen, both applicants submit revision after revision to find the lowest common denominator - what’s the least they can do to get this through? And after the staff report recommended denial, they again submitted a letter pleading with the county to approve this project, claiming that they do “not intend to develop” the southern end and claim that one potential theme is Freedom Park. Again, this is not proffered, there are no guarantees, especially with weak words like “intend” and “potential”. Prince William County, the land, the residents, and wildlife deserve more than just crumbs and development leftovers. 

The fluid nature of the proposals, characterized by last-minute submissions and revisions, makes it challenging for the public to thoroughly review.  This hurried pace has demanded so much from the staff and jeopardizes the proper evaluation of legal requirements and compliance with the Comprehensive Plan, undermining the transparency and due diligence essential to this decision-making process. 

Staff has repeatedly made clear to both applicants that they are required to submit a waiver request to the Board of Supervisors due to their refusal to provide the location of all buildings and other structures on their Master Zoning Plans. As of the December 7 staff report, none of the applicants had submitted a waiver request, and to the best of our knowledge this is still the case—despite the County Code’s clear requirement, and despite County staff’s clear instruction, to do so.

The applicants' proffers fall short of the County Code's "strict accordance" requirement, potentially allowing for deviations. The applicant may claim that they want to have the freedom to implement cutting-edge technology and sustainability measures. But if their commitment to sustainability were genuine, we would have seen stronger proffers for Natural Open Space, Wildlife Corridors, utility crossings, renewable energy, air or closed-loop cooling systems, and stormwater mitigation. The deliberate choice of "strict accordance" in the County Code is crucial, as lower standards like "substantial conformance" or mere "accordance" provide too much flexibility for applicants, complicating proffer enforcement for the County.

The proposed Natural Open Space allocation is significantly below the 30% goal outlined in the Comprehensive Plan Amendment (CPA). Protecting these spaces is crucial, and mere token gestures of planting a tree elsewhere are insufficient. To diminish it to one tree here for one tree there fails to understand the rich ecology of these wooded areas and the length of time it’s required to be established and offer all the environmental services that they provide including clean air, clean water, carbon sequestration and more.

We see this very plainly in the misalignment of the wildlife corridor in the Compass rezoning. This map shows the difference between what was approved with the CPA and what is being proposed with the rezoning. The adjustment shifts the corridor from an established wooded corridor to diverting wildlife to the Pageland Rd. 



During the Planning Commission public hearings, the applicants, along with a utility representative, argued that the customary practice involves planning the location of electric transmission lines after the submission of a final site plan. However, county staff has emphasized that the planning of these transmission corridors is not only possible but also highly encouraged at the rezoning stage of development. Given the immense scale and scope of these proposals, insisting on this planning upfront could proactively address and mitigate foreseeable issues.

The Virginia Mercury reported today that a State Corporation Commission utility regulator recommends rejecting Dominion Energy’s recent long-term plan. This plan includes new natural gas plants in response to the projected increase in power demand from data centers in Northern Virginia. Given these rezonings' massive scale, we’re looking at the power equivalent of adding 750,000 homes (5x more than in PWC) to raise concerns. Simple energy-saving measures the applicants are proposing as part of their sustainability effort won't offset this demand. Further information should be required to understand the impact on the grid and Virginia residents' rates on their electric bills. Projected rate increases indicate a potential 100% rise by 2030.

In closing, these proposed rezonings fall woefully short of the minimum standards set by the Comprehensive Plan Amendment. They not only deepen our reliance on fossil fuels but also threaten the destruction of rural lands crucial to our drinking water watershed. It's essential to recognize that the cleaner our water going into the reservoir, the more efficiently we can provide clean drinking water.

If these proposals gain approval, they establish a concerning precedent for further development. While much emphasis has been placed on the potential revenue, we must weigh this against the broader impact on the grid, necessitating more transmission lines, substations, and new natural gas plants. What about our water supply? As we expand, the risks of salinity and sedimentation accumulate, pushing our reservoir toward a dangerous tipping point. The cost to rectify such a scenario is a question we cannot ignore.

I implore each of you to reflect on the long-term implications of this decision. This is an opportunity to set a high bar for sustainability and environmental and historic preservation. Given the scale and scope of this project, it’s critical now more than ever to uphold the county code to the highest standard.  Thank you.



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