Site is one of several in Virginia facing irreparable harm to historic, natural and cultural resources due to unchecked data center development

Press Release from the Wilderness Battlefield Coalition: American Battlefield Trust, Cedar Mountain Battlefield Foundation, Central Virginia Battlefields Trust, Coalition to Protect America’s National Parks, Friends of Wilderness Battlefield, Historic Germanna, Journey Through Hallowed Ground, National Parks Conservation Association, National Trust for Historic Preservation, The Piedmont Environmental Council, Preservation Virginia

Contacts: 
Cindy Sabato, The Piedmont Environmental Council, csabato@pecva.org
Mary Koik, American Battlefield Trust, mkoik@battlefields.org
Ava Hampton, Journey Through Hallowed Ground, ava@jtg.org

Orange County, Virginia (May 1, 2024) – Wilderness Battlefield, site of a pivotal clash that marked a turning point in the Civil War, was named one of the nation’s 11 Most Endangered Historic Places due to the threat of a massive data center development that would irrevocably destroy the historic landscapes fundamental to maintaining the area as a vital educational resource and treasured hallowed ground.

Wilderness Battlefield anchors Fredericksburg and Spotsylvania Battlefields National Military Park in Orange County, Va., welcoming 500,000 heritage tourists and outdoor recreation enthusiasts a year to its forested trails. In making the designation, the National Trust for Historic Preservation (NTHP) noted only a fraction of the historically significant battlefield landscape is federally protected, leaving it vulnerable to the impact of rampant development. Of particular concern is the recent rezoning of adjacent rural land for the Wilderness Crossing project, an unprecedented local expansion of residential, commercial and industrial development, as well as millions of square feet of data centers and their associated noise pollution and transmission lines.

A broad coalition has formed to build legal and public pressure on Orange County officials to reconsider and educate the public on what is at stake. Partners in the Wilderness Battlefield Coalition include the American Battlefield Trust, Central Virginia Battlefields Trust, Cedar Mountain Battlefield Foundation, Coalition to Protect America’s National Parks, Friends of Wilderness Battlefield, Historic Germanna, Journey Through Hallowed Ground, National Parks Conservation Association, National Trust for Historic Preservation, Piedmont Environmental Council and Preservation Virginia.

“We simply cannot allow this potentially catastrophic impact to occur when better planning and thoughtful consideration could preserve such a vital and irreplaceable historic site,” said David Duncan, president of the American Battlefield Trust, which along with Central Virginia Battlefields Trust, Friends of Wilderness Battlefield and neighboring landowners, have filed a lawsuit challenging the rezoning. “We are not against development and know progress and preservation need not be mutually exclusive. We are grateful to the National Trust for drawing attention to the danger.”

“The threat of Wilderness Crossing ripples region-wide and statewide, as it is likely to draw yet more electrical generation and transmission infrastructure to the Piedmont area, particularly the historic-site-rich Route 3 corridor,” said Piedmont Environmental Council President Chris Miller. “This designation for the Wilderness Battlefield Area epitomizes the threats to historic, scenic and cultural resources that result from the proliferation of data centers and associated energy infrastructure.”

The Battle of the Wilderness was fought May 5-7, 1864, and marked the first stage of a major Union offensive toward the Confederate capital of Richmond ordered by the newly named Union General-in-Chief Ulysses S. Grant. Despite his army suffering horrific casualties — nearly 18,000 soldiers killed, wounded or captured in 48 hours — Grant wrote to President Lincoln, “I intend to fight it out on this line if it takes all summer.”

“In response, Lincoln told Grant, ‘Hold on with bulldog’s grip,’ and that is precisely the spirit we carry today. The preservation and conservation community remains resolute in our fight to protect the historic landscapes of the Wilderness,” said Bill Sellers, president of the Journey Through Hallowed Ground National Heritage Area, which spearheaded the competitive application process.

The Wilderness Battlefield is one of several historic sites imperiled by the unchecked explosion of data center development in Virginia, where the concentration of data centers is three times denser than anywhere else in the world. Another proposal adjacent to Manassas National Battlefield Park would convert more than 2,100 acres of farmland into a corridor of 40 data centers, the largest such complex on the planet. Further projects poised to mar historic landscapes are advancing in Caroline, Culpeper, Henrico, Prince William and Surry Counties. The fate of such projects is committed to local officials, as there currently exists no federal or state oversight on the siting and building of these mega warehouses, even when such a facility would jeopardize cultural, natural or historic resources of national significance.

“The explosion of data center development across the Commonwealth is a grave concern for the preservation and public history community,” said Elizabeth Kostelny, chief executive officer of Preservation Virginia. “We have spent years sounding the alarm on this broadly impactful issue and are grateful for the 11 Most designation that will highlight it on the national stage.”

At the Wilderness, some protected lands, including many areas witnessing the most intense combat, are administered by the National Park Service, while the American Battlefield Trust, Central Virginia Battlefields Trust, the Friends of Wilderness Battlefield and the Commonwealth of Virginia also own or steward additional portions of the battlefield. Even these holdings do not cover the full extent of the historic landscape and large areas once used for encampments, entrenchments, hospitals, burial sites, military headquarters and troop movements remain privately owned and vulnerable to development.

In a single vote last April, the Orange County Board of Supervisors rezoned more than 2,600 acres for the massive Wilderness Crossing development at the gateway to the battlefield and partly inside its footprint. This includes by-right entitlement to blanket 732 acres in data centers without any cap on density, a 5-million-square-foot ceiling having been removed at the last minute. The project will also include 500,000 square feet of commercial development and industrial zones, plus 5,000 new dwelling units, which would have an overwhelming impact in a rural county of only 16,000 households. Moreover, proceeding with this massive, unchecked development will almost certainly necessitate the implementation of the Virginia Department of Transportation’s long-stagnant proposal of a major realignment of Route 20 through the historic landscape.

Three of the partners in the Wilderness Battlefield Coalition (American Battlefield Trust, Central Virginia Battlefields Trust and Friends of Wilderness Battlefield) have filed a lawsuit over the April 2023 rezoning, citing multiple failures to comply with county ordinances and Virginia law and lack of consideration of the impact on historic, natural or cultural resources. A second successful lawsuit filed by the Piedmont Environmental Council showed county officials violated the state’s Freedom of Information Act with non-disclosure agreements, redacted communications and other documents related to dealings with Amazon on the project.

“We recognize the need for development and the role data centers play in our everyday lives. But this does not need to come at the expense of historic resources,” said Central Virginia Battlefields Trust President Tom Van Winkle.

There is precedent for reconsideration of data centers. Recently, facing strong public opposition, an approved Amazon data center development in King George County was renegotiated by the Board of Supervisors.

This is the second time the Wilderness Battlefield has been named to the 11 Most Endangered List. In 2010, it faced a different threat: construction of a Walmart Superstore. Ultimately, a win-win solution was found, with Walmart building at a different site several miles away and donating the original site to the Commonwealth of Virginia. In the aftermath, stakeholders — including the owners of the land now proposed for development — created the Wilderness Battlefield Gateway Plan outlining a compatible development vision for the area. It was a model for community engagement and collaborative planning, with elements of the plan officially adopted by the County. However, both the process and recommendations were largely ignored by the County this time around.

The inclusion on the current list was announced immediately before the 160th anniversary commemoration of the battle.

Since 1988, the National Trust for Historic Preservation has produced its list of 11 places in grave danger of destruction or irreparable harm. During that time, the Trust has identified more than 350 sites, and its efforts have helped galvanize support to protect nearly all of them.

Photos are available for download via Dropbox.

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Background and Overview Imminent Data Center Threat

Wilderness Crossing development plan is stark example of the threat posed by the unchecked proliferation of massive data centers on Virginia’s natural, historic and cultural treasures

The naming of Virginia’s Wilderness Battlefield Area as one of America’s 11 Most Endangered Historic Places by the National Trust for Historic Preservation (NTHP) underscores the inextricable link between natural, historic, and cultural resources, and amplifies the critical importance of state and local policy requiring full transparency and thorough assessment of vulnerable resources when considering data centers and other impactful development proposals.

Wilderness Crossing Development Background

• At 2,600 acres, Wilderness Crossing is the largest rezoning in Orange County history, a sprawling, car-dependent, mixed-use development, some of which would be constructed within the historic boundaries of the battlefield. It allows for millions of square feet of noisy, energy- and water-hungry data centers and associated transmission lines and over 500,000 square feet of commercial space on previously undeveloped land perilously near lands where soldiers fought and died and nearly 500,000 heritage travelers and outdoor recreation enthusiasts visit annually to enjoy the serenity of trails, fields, forests and hallowed ground.
  
• Orange County approved the rezoning in April 2023 behind a veil of secrecy and nondisclosure agreements with Amazon Web Services that prevented informed community participation in an enormous land use decision with long-ranging implications and without any serious effort to identify or mitigate foreseeable impacts to historic, scenic, or natural resources.

Traffic

• At buildout, Wilderness Crossing would add at least 11,000 car trips to area roads just during peak hours, with thousands more during the rest of the day and evening. The inevitable additional cut-through traffic anticipated by the National Park Service will crowd low-volume, scenic park roads and significantly threaten the visitor experience at this invaluable recreational asset.

Water

• The Wilderness Crossing rezoning permits millions of square feet of data centers, whose evaporative cooling systems can use enormous quantities of water. The Virginia Department of Environmental Quality in March 2024 said the area’s water supply, which is pulled from the Rapidan River, is insufficient to grant a permit request for increased water withdrawal and that the county would not be able to meet long term increases in water demand, especially during extreme drought conditions, without additional reservoir storage or other backup water supply sources.
  
• Ground and water contamination from mercury and other potential toxins from legacy gold mining operations at the site of the proposed development could worsen with construction and grading.

Historic, Cultural and Scenic

The development of Wilderness Crossing would industrialize an otherwise mostly rural and intact historic landscape.

• A typical data center is more than 100,000 square feet in footprint and 90 feet tall, and the number of data centers that could fit within the proposed industrial areas of Wilderness Crossing would carry an energy demand equaling about 187,500 homes at peak power usage and require at least a mile of new high-voltage transmission line across Virginia Route 3, the historic trade route from Fredericksburg to Culpeper and other parts of Virginia. 
  
• Backup diesel generators and cooling systems bring noise that would be audible for visitors and nearby residents, and extensive security lighting is typical for data center facilities. 
  
• The development, if realized, is also expected to reignite interest in a Virginia Department of Transportation (VDOT) plan to realign Route 20 through a swath of unprotected battlefield land, owned by the Wilderness Crossing developer within the Congressionally authorized park boundary. The realignment, which would funnel traffic directly to the front entrance of Wilderness Crossing, was addressed in the 2012 Wilderness Battlefield Gateway Study and identified as not feasible due to cost, design concerns, and impacts on historic resources. Although the Wilderness Battlefield Gateway Study was a model for community engagement and collaborative planning, and portions officially adopted by the County, it is being ignored in this rezoning. 
  
• Data centers and their associated energy infrastructure constructed at the Wilderness Crossing site are likely to draw yet more of the same to areas nearby. Beyond the immediate impacts to the Wilderness Battlefield Area, Wilderness Crossing increases development pressure along the entirety of Virginia Route 3 into the Rappahannock basin. Historic sites along Route 3 offer illumination into our nation’s past, and its future, while providing critical open space values that benefit visitors and the local community. West of the sprawling development of central Spotsylvania County, this mostly rural route holds numerous other important historic resources, such as the Chancellorsville National Battlefield, Madden’s Tavern, the U.S. Colored Troops memorial at Ebenezer Baptist Church, Pilgrim Baptist Church, Germanna and Spotswood Palace, Salubria, Brandy Station Battlefield, and the complex of resources in and around the proposed 40,000-acre Rapidan River-Clark Mountain Rural Historic District.

Legal Action

• The Piedmont Environmental Council, a member of the Wilderness Battlefield Coalition, successfully filed a lawsuit against the County to bring undisclosed documents to light under the Virginia Freedom of Information Act, revealing nondisclosure agreements signed by 10 local officials, including several elected members of the board of supervisors “for the benefit of Amazon.com, Inc. and its affiliates.” 
  
• Three other partners in the Wilderness Battlefield Coalition (American Battlefield Trust, Central Virginia Battlefields Trust and Friends of Wilderness Battlefield) have filed a lawsuit over the rezoning, citing multiple failures to comply with county ordinances and Virginia law and lack of consideration of the impact on historic, natural or cultural resources. The three nonprofit orgs were joined in the legal action by two local residents as well. 

A Statewide and Regional Issue / Similar Situations Elsewhere:

The threats faced by Wilderness Battlefield are emblematic of a crisis unfolding across Virginia and the Mid-Atlantic region, where the unchecked and unregulated data center industry has exploded, at the peril of dozens of nationally significant battlefields, historic sites, national and state parks, and historic rural communities, in which significant public investment has been made. 

• Manassas National Battlefield Park: The adjacent Prince William Digital Gateway would convert more than 2,100 acres of historic farmland into a corridor of 40 data centers and place drinking water for over 800,000 people in Northern Virginia at risk. A data center complex of this size could use as much power as all of the existing data center space in Loudoun County’s data center alley. Each May, Preservation Virginia releases an annual list of historic places across the Commonwealth that are facing imminent or sustained threats to raise awareness and forward solutions. In May 2022, Preservation Virginia included historic battlefields on that list due to the dire threat posed by data center developments. The National Trust for Historic Preservation’s addition of the Wilderness Battlefield Area to their list of America’s 11 Most Endangered Historic Places highlights the scope of this threat around Virginia. In January 2024, a legal challenge was filed against this proposal too. 
  
• Culpeper National Cemetery: More than two million square feet of data centers, along with overhead transmission lines and the constant drone of an electrical substation, are poised to forever mar the serenity of this final resting place for more than 7,500 veterans and where hundreds of memorial services are held annually. 
  
• Brandy Station: Also in Culpeper County, a proposed data center campus threatens 426 acres of productive farmland along with historic Brandy Station, which is part of the federally recognized Journey Through Hallowed Ground National Heritage Area and National Scenic Byway system, and home of the new Culpeper Battlefields State Park opening July 1. 
  
• Sweet Run State Park: The proposed path of high-voltage transmission lines to serve data centers in Virginia would traverse several national and scenic trails and historic parks, including the newly opened Sweet Run State Park in Loudoun County. 
  
• Savage Station Battlefield: A portion of this historic site in Henrico County is threatened by an immense, 622-acre data center campus proposal, which includes transmission lines that will run through the core of this vulnerable and unprotected battlefield.

The Virginia Data Center Reform Coalition

Despite the many concerns, no direct federal or state oversight exists for the siting and building of these mammoth warehouse-like structures, and the environmental impacts of these facilities on energy production and transmission, water supply and water quality, climate resilience, biodiversity and local food production, and historic and cultural resources are just beginning to come into focus. For these reasons, the Virginia Data Center Reform Coalition launched in December 2023.

The Virginia Data Center Reform Coalition, comprised of more than 20 organizations, homeowners’ groups, and residents, is calling on the state for common sense regulation that includes: better planning and siting of data centers; transparency about their energy demands, water use, and cumulative infrastructure costs; efficiency and sustainability standards; policies that require local governments to consider regional impacts; shift of infrastructure costs from ratepayers to the industry itself; and mitigation for adverse effects on communities and resources.

Today’s announcement by the National Trust for Historic Preservation is a clarion call for immediate action from local and state legislators.

For additional information contact: 

●  11 Most Endangered Nomination: Ava Hampton, Journey Through Hallowed Ground; ava@jthg.org, (978) 809-4455 

●  Wilderness Battlefield history and lawsuit: Mary Koik, Director of Communications, American Battlefield Trust; mkoik@battlefields.org, (202) 558-8971 

●  Wilderness Crossing development proposal: Don McCown, Field Representative, Piedmont Environmental Council; dmccown@pecva.org, 540-347-2334 x7047 

●  Data center and energy/transmission line implications: Julie Bolthouse, Land Use Director, Piedmont Environmental Council; jbolthouse@pecva.org, 540-347-2334 x7042 

●  Data Center Reform Coalition and National Parks impacts: Kyle Hart, Mid-Atlantic Program Manager, National Parks Conservation Association; khart@npca.org, (202) 400-1193