October 31, 2022 

Prince William County Board of Supervisors 
1 County Complex Ct. 
Prince William, VA 22192 

Dear Chair Ann Wheeler and Members of the Prince William County Board of Supervisors: 

We, the undersigned thirty (30) organizations, write to you today regarding Comprehensive Plan Amendment #CPA2021-00004, the PW Digital Gateway. On behalf of our millions of members and supporters in Prince William County, the Commonwealth of Virginia, and nationwide, we urge you to vote “No” on this proposal. As you have undoubtedly heard over the past 17 months, this proposal poses grave threats to irreplaceable historic and environmental resources, including impacts to the regional water supply of the Occoquan Reservoir, a national park and state forest, and our global climate health. It is for these reasons, explained in greater detail below, that our combined environmental and historic conservation organizations have joined together to express our strong opposition to this proposal. 

1. Manassas National Battlefield Park: Manassas National Battlefield Park is an approximately 5,000-acre unit of the National Park Service that protects the site of two major Civil War battles, the First and Second Battles of Bull Run. Manassas National Battlefield receives more than 500,000 visitors annually.¹In 2021, the Battlefield created more than $33 million in visitor spending in the local economy and supported 412 jobs in the region.² In December 2021, then-Superintendent of Manassas National Battlefield Park Brandon Bies called the PW Digital Gateway the biggest threat to the Battlefield in nearly three decades. The National Park Service continues to express their firm opposition to this proposal. The proposed PW Digital Gateway is directly adjacent to Manassas National Battlefield, and thus this proposal would have direct viewshed and visitor experience impacts on the Battlefield. Noise from the constant hum of large, industrial data centers would be ever-present on the landscape. Noise analysis done by John W. Lyver, IV, Ph.D. indicates that the Brawner Farm Interpretive Center would see a 12.4 decibel increase at full PW Digital Gateway buildout.³ This would have lasting impacts on the Battlefield, devaluing visitor experience and the interpretive abilities of National Park Service employees. 
   
2. Historic Resources: As pointed out by the county’s own Historical Commission and Racial and Social Justice Commission, properties along Pageland Lane in the PW Digital Gateway have immense historical value and should be preserved. The PW Digital Gateway Corridor contains more than 100 acres of Core Battlefield, designated by the American Battlefield Protection Program. The area also includes extensive amounts of the Manassas Battlefield study area. The area is confirmed with the presence of a Civil War Mass Grave, and likely includes other areas of human remains not currently identified in county resources due the extensive use of the Pageland corridor during the Second Battle of Bull Run as field hospitals, and then later as military training areas impacted by a measles outbreak that led to more than 200 fatalities. The area is also the birthplace and burial place of Jennie Dean, a Manassas woman who was born into slavery and eventually founded the Manassas Industrial School for Colored Youth, which educated thousands of Black high school students from the 1890s through the 1930s. The area also contains multiple historic cemeteries, including the historic Marble Hill slave cemetery. The Pageland corridor contains extensive Civil War and civil rights historical value and is not the proper place to build a massive industrial complex. 

3. Rural Crescent: The Rural Crescent was established with the adoption of the 1998 Comprehensive Plan. It is a vital smart growth tool that has been successful in curbing sprawl development, protecting the Occoquan Reservoir Watershed, and reducing public infrastructure costs, while encouraging investment in the development area where it is most cost-effective. The PW Digital Gateway proposal would remove 2,133 acres from the designated rural area without proposing to add acres elsewhere. Removing such vast amounts of land from the Rural Crescent contradicts the current Comprehensive Plan and would impact the rural character, commitment to open space, and public investment to support the quality of life of residents throughout the county. The Rural Crescent also acts as the county’s de facto climate plan, storing climate pollution and reducing the county’s carbon footprint. The removal of this land from protection to be developed into an industrial area sets the county backwards on its goal of 100% clean energy.
   
4. Water Quality and the Occoquan Reservoir: The Occoquan Reservoir provides drinking water to more than 800,000 people living in the region, and the reservoir is managed by Fairfax Water. On March 21, 2022, Fairfax Water wrote a letter to the Prince William Board of Supervisors expressing their concerns with the PW Digital Gateway’s impact on regional water supply, and requested that Prince William County convene the Occoquan Basin Policy Board and oversee a comprehensive study on the impacts that this development would have on the watershed. Fairfax County reiterated this request in another letter to the Prince William Board of Supervisors on October 24, 2022. Although the Prince William County Board of Supervisors did agree to study these water quality impacts, language ensuring that this critical analysis would take place before the PW Digital Gateway could be approved was removed. Studies by water quality engineers have indicated that a development of this size would lead to extensive increases in sedimentation runoff from heavy construction activities – up to 57,000 tons of sediment if the proper stormwater control practices are not in place and strictly enforced. The PW Digital Gateway would also convert an extensive amount of natural terrain into impervious surfaces. This influx of impervious surfaces will lead to increased stormwater runoff into the Occoquan Reservoir watershed, up to 280 million additional gallons per year.⁴ The extent of development of this size in an existing rural area of the Occoquan Reservoir is unprecedented. Impacts will be felt downstream for years to come.

5. Energy and Climate: Conservative estimates put power needed for the PW Digital Gateway at 4,000 megawatts at full buildout. This would be the equivalent of powering 1,000,000 additional houses. The Metropolitan Washington Council of Governments (MWCOG) reports that between 2005 and 2018, community-wide greenhouse gas (GHG) emissions in Prince William County have increased by 19%⁵. It states that the main drivers for increased emissions are growth in commercial electricity energy intensity, population, and in commercial space. 
   
   Since we know that increases in carbon emissions are tied to energy demand and sources of energy, we expect that massive data center development will continue to increase the area’s carbon emissions and move Prince William County further from its goal “to reduce greenhouse gas emissions from all sources within the county to 50% of 2005 level by 2030, and to be carbon-neutral by 2050.”⁶ This goal has also been codified in the 2021-2024 Strategic Plan. Severe heat in Northern Virginia and throughout the world has again underscored dire warnings issued by the Intergovernmental Panel on Climate Change. Despite these facts, the County has not provided a thorough analysis on how this project would be carbon neutral or what the power sources of these data centers would be. We have yet to see any data explaining how the PW Digital Gateway will impact Prince William County’s climate goals or the climate reduction targets of MWCOG (of which the county is a member). This fact is among one of the key reasons that the county’s own Sustainability Commission expressed strong concerns with the PW Digital Gateway in their October 28, 2022 letter to the Board and urged you to delay a vote on the PW Digital Gateway until this information is available and incorporated into the plan.⁷ To proceed without accurate information on the proposal’s impact on energy demand and increases in total carbon emissions and without provisions in place to mitigate for the rise in carbon emissions is irresponsible.
   
6. The Bi-County Parkway: We stand by our strong concern that approval of the CPA will advance key elements of the highly contentious Bi-County Parkway proposal and generate renewed pressure for its construction. The Bi-County Parkway and its various iterations over the years have always been extremely controversial proposals because they would promote sprawling development, damage water quality, fuel more traffic and air pollution, and harm historic resources of national importance. Specifically, the draft CPA produced by county staff calls for widening Pageland Lane with a very expansive right-of-way that could be used for additional widening to six or more lanes in the future, as well as analyzing a connection between the widened Pageland Lane and I-66. These are both defining elements of the Bi-County Parkway. Although we note that the draft motion of approval included as part of the staff report posted for this item suggests deleting Action Strategy DGM 1.11, which calls for analyzing the connection between Pageland Lane I-66, the approval of the CPA will surely generate new pressure for that connection regardless, particularly with Pageland Lane widened as expansively as the CPA presents. It is just one more example of how approving this CPA would have ramifications that will inflict serious damage on the County both directly and indirectly, and both within the Pageland Lane corridor and well beyond. 

Finally, we must note that as the review process for the PW Digital Gateway has played out since the CPA was first introduced, it has become increasingly clear to our organizations that this proposal must be rejected outright. Our organizations have repeatedly requested reasonable protections be added to the plan,⁸ and we have raised serious questions and concerns that need to be answered.⁹ These requests have been largely ignored. On the flip side, the data center developers have shown, such as in their September 9, 2022, letter to the Planning Commission, that they would place little priority on protecting the County’s invaluable green space, water quality, and historic resources if they are permitted to construct these massive data centers. In short, the proposal is simply not in the best long-term interests of the County and its residents. 

It is clear that the threats to the environmental and historic resources posed by the PW Digital Gateway are too great. For the above reasons, we urge you to vote “No” on the PW Digital Gateway. 

Respectfully, 

Kyle Hart, Mid-Atlantic Program Manager 
National Parks Conservation Association 

Claudia Thompson-Deahl, Conservation Chair 
Prince William Wildflower Society 

Renee Grebe, Northern Virginia Conservation Advocate 
Nature Forward (formerly Audubon Naturalist Society) 

Jennifer Cole, Executive Director 
Clean Fairfax 

Court Squires, Executive Director 
Prince William Conservation Alliance 

Alexander M. Nance, Executive Director 
Virginia Piedmont Heritage Area 

Mike Town, Executive Director 
Virginia League of Conservation Voters 

Michael Murray, Chair, Executive Council 
Coalition to Protect America’s National Parks 

Julie Bolthouse, AICP, Director of Land Use 
Piedmont Environmental Council 

William W. Sellers, President and CEO 
Journey Through Hallowed Ground National Heritage Area 

Andrea McGimsey, Executive Director 
Faith Alliance for Climate Solutions 

Elizabeth S. Kostelny, CEO 
Preservation Virginia 

Stewart Schwartz, Executive Director 
Coalition for Smarter Growth 

Tom Blackburn, Chair, Advocacy Committee 
Audubon Society of Northern Virginia 

Ann Bennett, Land Use Chair 
Great Falls Group of Sierra Club 

Jim Campi, Chief Policy and Communications Officer
American Battlefield Trust 

Nancy Vehrs, President 
Virginia Native Plant Society 

David Sligh, Conservation Director 
Wild Virginia 

Joseph Eaves, Board Chair 
Manassas National Battlefield Trust

Frank Washington, Director 
Coalition To Save Historic Thoroughfare 

Robin Broder, Deputy Director 
Waterkeepers Chesapeake 

Leighton Powell, Executive Director 
Scenic Virginia 

Gustavo Angeles, Acting Director 
Sierra Club, Virginia Chapter 

Reed Perry, Manager of External Affairs 
Chesapeake Conservancy 

Skip Styles, Executive Director 
Wetlands Watch 

Anne Little, Executive Director 
Tree Fredericksburg 

Morgan Butler, Senior Attorney 
Southern Environmental Law Center 

Glenda Booth, President 
Friends of Dyke Marsh 

Hope Cupit, President and CEO 
Southeast Rural Community Assistance Project, Inc. 

Paul W. Edmondson, President and CEO 
National Trust for Historic Preservation