Consideration for the proposed Zoning Ordinance Amendment

Citizen Comment - BOS Meeting July 7, 2026

To the Goochland County Board of Supervisors and Dr. Raley,

I am Linda Moore.

I was encouraged at the Planning Commission meeting held on June 18, 2026 by

Sara Worley comments on the ZOA for M-1 and M-2 outside of the TOD

End of August 2026 to be presented at a  Community Meeting. 

I remember back in April 2019  a timeline was set for  the Zoning Ordinance Rewrite. 

 Community meetings  were held monthly to allow citizens  to review each Article (section by section). Also to ask questions at the end of each article. 

This was done prior to the DRAFT ordinance presented at the Planning Commission Public Hearing. 

I ask the same consideration be made for the proposed  Zoning  Ordinance Amendment (ZOA) 

I ask that  the scope of the ZOA include adding:

1. District Standards - Sec.15-264 - M-1 , Sec.15-273 - M-2 

    Development Standards Sec. 15-266- 15-270- M-1  and Sec.15-274 - 15-280 

2. Data Center - Use Standards - In accordance with Sec, 15-292 DATA CENTERS 

    Sec,15-291 Use Standards and Zoning Districts

3. Add Data Centers to:

    Plan of Development - Sec.15-314 

Here are just some of the specific use standards that should be addressed in the ZOA: 

Article 20- Use Standards

Sec. 15-292 DATA CENTERS

1. Noise Standards

·        Add C‑weighted and 1/3‑octave band limits to address low‑frequency noise from data center cooling systems.

·        Apply tonal and impulsive penalties per ISO 1996‑1 and measure at the nearest dwelling façade, not just property lines.

·        Limit generator testing to mid‑day weekdays, prohibit simultaneous testing across multiple units, and require public posting of testing schedules.

·        Require third‑party post‑occupancy noise verification at 3 and 12 months, then every two years.

2. Air Quality and Backup Power

·        Require compliance with Virginia DEQ’s 2025 data center generator guidance and minor NSR permitting before land disturbance.

·        Mandate Tier 4 Final diesel engines or natural gas alternatives with catalytic controls; prohibit non‑emergency demand‑response operation.

·        Require cumulative air dispersion modeling for all engines on a campus.

·        Require monitoring plan along the boundary of the TOD that includes fully calibrated metering with an online dashboard for residents to access real time data and integrate the monitoring in the Alert system for Goochland County to issue text alerts to residents.

3. Battery Energy Storage System (BESS) Safety

·        Require compliance with NFPA 855 and UL 9540/9540A for all principal and accessory BESS installations.

·        Mandate a Hazard Mitigation Analysis, Emergency Response Plan, and funding for first responder training and specialized equipment.

·        Include provisions for air monitoring (HF, HCN) and post‑incident environmental testing.

4. Small Modular Reactors (SMRs) and Peaking Plants

·        Remove SMRs from the TOD ordinance until a separate nuclear‑specific framework is adopted.

·        If retained, require a minimum 1‑mile setback, independent risk assessment, and decommissioning/financial assurance plans.

·        Increase natural gas peaker setbacks to 2,500 feet and require BACT and continuous emissions monitoring.

5. Buffers, Setbacks, and Visual Screening

·        Make minimum buffers and setbacks non‑waivable by administrative staff; any reduction should require a public hearing.

·        Require earthen berms and evergreen plantings in buffers, and prohibit utility easements running parallel within the outer 50 feet of buffers.

·        Limit lighting to 3000K color temperature, full cutoff fixtures, and curfews for non‑security lighting.

6. Water Use and Cooling

·        Require disclosure of annual and peak water demand and prioritize air‑cooled or closed‑loop systems.

·        If evaporative cooling is proposed, require drift eliminators and prohibit groundwater withdrawals.

7. Enforcement and Transparency

·        Require construction management plans, vibration limits, and real‑time public dashboards for noise, generator operations, and air quality.

·        Establish performance bonds for landscaping survival and automatic penalties for repeated violations.

·        Require enhanced groundwater testing across the TOD linked to an online dashboard and integrated into the Goochland County alert system.

Most important issues are:

1. Backup power and emissions — especially whether diesel generators are allowed, under what limits, and whether cleaner alternatives such as battery storage, fuel cells, natural gas with strong controls, or other non-diesel resiliency strategies are required or incentivized.

2. Air-quality modeling — not just one generator at a time, but cumulative modeling for the full campus, including testing, emergency operation, and worst-case outage scenarios.

3. Generator testing limits — weekday midday only, no simultaneous testing across multiple units, public notice of testing schedules, and annual reporting.

4. Real-time or periodic monitoring — fence line monitoring for PM2.5, NO₂, CO, noise, and potentially other pollutants, with public reporting.

5. Noise standards — especially low-frequency noise from cooling equipment, generators, substations, and transformers. The standard should not be just a simple average dBA number if the concern is a constant hum or tonal noise.

6. CUP/use standards — the County needs enforceable conditions tied to each approval, not just general promises. The key is to make the applicant prove compatibility before approval.

7. Water and cooling — disclosure of peak and annual water demand, preference for dry or closed-loop cooling, and limits on groundwater or excessive potable water use.

8. Emergency response — especially if battery storage, hydrogen, LNG, or other fuel systems are involved.

Rev Lisa Sykes