Q&A: Data Center Environmental Compliance
Q: What types of environmental permits are required for data centers?
A: Data centers typically need multiple—sometimes dozens—of diesel- or natural gas-fired emergency generators to provide backup power during periods of utility service interruption. These emergency generators emit pollutants into the atmosphere during power outages and routine testing/maintenance. Depending on the size of the data center and the number of emergency generators needed to support operations, a state or federal air quality permit may be required. Federal, state, and local agencies each have their own specific requirements, with some even requiring air quality dispersion modeling as part of the air permit application process. With the EPA’s recent proposal to reduce National Ambient Air Quality Standards for PM2.5 (or fine particulate matter), new data center projects may need to consider investing in additional air pollution control devices or proposing operational limitations for on-site emergency generators. Air pollution control devices have the potential to add additional capital investment to a project and take up prime real estate on a project site.
Q: Are there any other environmental compliance requirements for data centers?
A: Yes. Data centers that utilize diesel-fired emergency generators will likely have aboveground oil storage amounts greater than 1,320 gallons. Facilities that exceed this threshold require a federal Spill Prevention, Control, and Countermeasure (SPCC) Plan, which helps facility personnel prevent an oil discharge into nearby waterways. Lead acid batteries are also typically located at data centers as a tertiary form of backup power. Lead and sulfuric acid are considered extremely hazardous substances and the facility may be subject to annual Tier II reporting under Section 311 of the Emergency Planning and Community Right-to-Know Act. Environmental compliance requirements for data centers are not limited to those mentioned above; other requirements evaluated on a case-by-case basis are associated with waste management, industrial stormwater, and industrial wastewater discharge.
Q: How can environmental compliance requirements impact my data center project?
A: It is essential to begin the air quality permitting assessment and application process early in a project’s pre-development phase. Postponement can result in construction delays, higher capital costs, and even fines or violations. Langan offers data center expertise across several disciplines, including site/civil, geotechnical, and environmental permitting and compliance. This unique combination enables Langan to provide a thoughtful approach to new data center developments and facility expansion projects. Langan’s environmental compliance team can assist in determining the type of air permit and operational restrictions or control devices required, prepare air quality permit applications, perform air quality dispersion modeling, and prepare SPCC Plans and Tier II reports.
Based in our New York City office, Stephanie Friel is an environmental project engineer with diversified environmental compliance and permitting experience.
Brendon Blachowski is based in our Philadelphia office and has six years of experience in environmental compliance and permitting.