By Terri I. Erwin-Fitz   June 2, 2017


On May 17, the Advisory Council on Historic Preservation, sent a letter regarding the Midwood Data Center Project, the data center being built by Amazon, to Marshall Smith, chief with the Northern Section of the U.S. Army Corps of Engineers regarding a phone meeting on March 8 in which the data center and the proposed Haymarket substation and 230kV transmission project proposed by Dominion were discussed in relation to the historic value of the area and the project’s impact on that value.

The Historic Preservation Council is an independent federal agency that protects the preservation, enhancement and productive use of the nation’s historic resources.  It also advises Congress and the President on national historic preservation policy.

In the letter, the Council advises that in a phone meeting with “consulting parties” there were concerns expressed regarding the “ground preparation and construction” that would be carried out for the two more data centers that would be added to the grounds near the already constructed building 1 of the data center.

The two buildings are to be built on the 38.5-acre site that will be part of the three-building data center belonging to Amazon.

The letter noted that the site is located “within the core area of the Buckland Mills Battlefield” and that the construction will have an “adverse effect to the battlefield, which has been determined eligible for inclusion on the National Register of Historic Places.”

The letter questions whether the Corps of Engineers has considered the full range of activities that would be considered part of the undertaking for the project, adding that the “component that will be necessary as part of the undertaking of multiple, integrally linked undertakings, and Corps; responsibility to comply . . . for the multiple components that are necessary to make the project viable are unclear.”

Basically, the Advisory Council on Historic Preservation has concerns that the Haymarket data center and substation plans may not follow the National Historic Preservation Act.

The part of the Act in question is Section 106, in that it requires a federal agency to consider “effects on historic properties in the Area of Potential Effect of undertakings they sponsor, authorize or assist.”

The letter also calls into question the consideration of Section 110, which prohibits a “Federal agency from granting a loan, loan guarantee, permit, license or other assistance to an applicant” who has “significantly adversely affected a historic property” to which the granting would relate.

This not only calls into question the building of the three data centers, but also the 230kV transmission line proposed by Dominion and the Haymarket substation.  The letter requests clarification from the Corps on its rationale for considering a permit application and asks how it considered the linkage from the three-building data center and the transmission line.

The letter asks if the Corps of Engineers has considered the long-term effect from this undertaking.

Due to the Historic Preservation Council’s concerns, the letter also was notice that the Council would “formally enter this consultation . . . to assist the Corps, the project proponent, the Virginia State Historic Places Office, and the consulting parties.”

Elena Schlossberg, executive director of the Coalition to Protect Prince William County, says that the meeting came from a permit application Bob Weir found to the Army Corps of Engineers to build a second building.

She says the “consulting parties” included Del. Bob Marshall, the Coalition, Bob Weir, Justin Patton, Prince William County’s archeologist, a representative from Buckland Battlefield, Charlie Grymes with Prince William Conservation Alliance, Amazon engineers and attorneys, Dominion Power representatives and others.

She says that the clearing of the land was claimed by Amazon to be a “staging area” for building number 1 and that Amazon admitted that it would not need the additional power lines until the completion of building number 3.

Schlossberg says that the Corps was told that the need was for the community.  Schlossberg immediately noted that only three percent of the power provided by the lines would be for the community.  She noted that the clearing of the property has already had an “adverse impact” on the historic value of the property.  During the meeting, the Coalition also provided an aerial map of what the land looked like before the clearing and after, noting it was a remarkable difference, calling it “shocking.”

Schlossberg said that Grymes noted that the permits could not just look at the impact of the construction of the data center buildings, but the entire transmission lines since it is needed to power the data center.

Now, Schlossberg says that the project is stalled temporarily.

The Virginia State Corporation Commission has ordered Dominion Power to consult with Prince William County’s Board of Supervisors regarding the construction of transmission lines along the Railroad or Carver Road Route and with questions concerning the permits by the ACHP.

Schlossberg says that regardless of what happens with the BOCS, if the Army Corps of Engineers does not grant permits, then the routes could be blocked.  She noted the historical value of the Carver Road Route including cemeteries, churches and the entire history of the area.

For more information and to read the full letter, please see