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Evidence-Based

This Is a Data Center Project. Not a Reliability Project.

PJM labeled it a "Data Center Alley Local Solution." SCC Staff confirmed the lines "would NOT be needed but for multiple data centers." Dominion manufactured the urgency, buried the underground analysis, and used escalating threats to make overhead seem inevitable. It isn't.

The Data Center Connection The Manufactured Crisis Fact Check Dominion's Playbook Dual Messaging What Officials Are Saying
The Evidence

Follow the Load. It Leads to Data Centers — Not Your Home.

This project was not triggered by failing service to homes or businesses. It was triggered by enormous new commercial load from data centers — facilities that did not exist a few years ago and whose operators were never required to ask the community's permission. When the only driver is new industrial load, routing through neighborhoods is not responsible — and the precedent this sets applies to every community in Loudoun.

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    PJM's Own Label: "Data Center Alley Local Solution" A September 2023 PJM presentation explicitly names this project as a data center solution — not a community reliability project. The need was known as early as 2022.
  • ⚖️
    SCC Staff Finding: Lines "Would NOT Be Needed" Without Data Centers The SCC's own staff concluded in their post-hearing brief that the lines "would NOT be needed but for multiple data centers in northern Loudoun County." This is not a community claim — it is the regulator's finding.
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    No Reliability Issues for 20+ Years Long-term residents of Loudoun Valley Estates have experienced zero reliability problems. The urgency is driven entirely by new commercial load — not by any deficiency in service to homes, hospitals, or schools.
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    Amazon Buys GW's Ashburn Campus — $427 Million, March 2026 Supervisors said they were "blindsided." GW stopped returning the County's calls over a year ago. This is the same playbook — data center growth happening without community input, and residents left to bear the infrastructure costs.
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    Dominion Selected Both Substation Locations to Serve Data Centers Dominion selected both the Mars and Golden substation locations — both positioned to serve large data center development projects. The need to connect them drives this entire project.
Satirical 'Visit Loudoun — The Data Center Capital of the World' image showing data centers and towers next to a small home
"The lines would NOT be needed but for multiple data centers in northern Loudoun County."
— SCC Staff Post-Hearing Brief, PUR-2025-00056
"Voting for data centers is almost political suicide. Loudoun County voters are done with them."
— Supervisor Briskman (D-Algonkian)
The Timeline

Dominion Manufactured This Crisis

The urgency Dominion used to justify skipping underground analysis was not inevitable. It was the result of deliberate choices — choices Dominion made, that SCC Staff identified, and that the evidentiary record proves.

2022
The Need Was Known

Dominion Identified the Need for This Line

Data center load forecasts were sufficient by 2022 for Dominion to know this project would be needed. Underground planning requires 3–5 years of lead time. That time was available. Dominion chose not to use it.

Dec 2023
PJM Approval

PJM Approves the Project — Labeled a "Data Center Alley Local Solution"

PJM formally approves the project in December 2023. The label is explicit: this is not a reliability project for existing customers. It is infrastructure for data center load.

15+ months
The Gap That Proves Intent

Dominion Waits 15+ Months to File — Then Claims Emergency

Dominion waited more than 15 months after PJM approval before filing its CPCN application with the SCC. Then it claimed there was no time to study underground alternatives. SCC Staff called this out directly: Dominion "effectively ensured that its overhead routes are the only viable options." Dominion's own lead admitted Golden-to-Mars was the most complex project and was filed last.

2024
The VDOT Fiction

One Email. No Proposal. But Claimed as Proof.

FOIA records reveal that Dominion cited VDOT over 40 times in its Feasibility Study, and 'open-cut' appears more than 150 times. Yet the entire VDOT engagement amounts to one September 16 meeting and one September 26 email objecting only to open-cut excavation of Route 606. The standard trenchless methods — horizontal directional drilling (HDD), microtunneling, and jack-and-bore — were never proposed to VDOT. Not once. Dominion selectively engaged VDOT on only the construction method most likely to draw objection, received the predictable answer, and applied that single answer to reject all eleven underground alternatives. Source: THT Letter to SCC, March 29, 2026, Section I; VDOT FOIA Response.

Study
The Altered Feasibility Study

Dominion's Own Engineer Changed "Feasible" to "Infeasible"

County Witness Bob Brown testified that Dominion's Feasibility Study appears to conclude that underground "really seems to be feasible" — but the conclusion was changed to "infeasible." The final edits were made not by the engineering firm (Burns & McDonnell) — but by Dominion's own routing engineer. The independence of that study is compromised.

Now
The Record is Clear

County Engineers Independently Confirmed Underground IS Feasible

Loudoun County's own independent engineering directly contradicts Dominion's feasibility claims and is on the SCC record. The Board's own resolution in January 2025 recognized this. The engineering work has been done. The question now is whether leaders will act on it.

Fact Check

Dominion's Claims vs. What the Official Record Shows

Every major claim Dominion used to justify overhead routing through residential neighborhoods falls apart under scrutiny. These aren't community opinions — they're findings from the SCC's own staff, FOIA records, and sworn testimony.

Dominion Claims What the Official Record Shows
FALSE"No time for underground engineering" FACTPJM approved Dec 2023. Need known since 2022. Dominion waited 15+ months to file, then claimed urgency. Dominion's own lead admitted Golden-to-Mars was the most complex and filed last.
FALSE"Undergrounding is technically not feasible" FACTSCC Staff: Dominion "effectively ensured that its overhead routes are the only viable options." Loudoun County's independent engineering directly contradicts this. Chino Hills, CA built underground 500kV successfully.
FALSE"VDOT ROW is not feasible for underground" FACTFOIA reveals one meeting (Sept 16, 2024) and one email (Sept 26, 2024). VDOT only objected to open-cut excavation. 'Open-cut' appears 150+ times in the Feasibility Study. Horizontal Directional Drilling (HDD), microtunneling, and jack-and-bore — the standard trenchless methods for high-traffic, utility-congested corridors — were never proposed to VDOT. Not once. Dominion cited VDOT 40+ times in the Study based on engagement that amounts to a single meeting and a single email. Source: THT Letter to SCC, March 29, 2026; VDOT FOIA Response.
FALSE"Underground was thoroughly evaluated" FACTCounty Witness Bob Brown testified that Dominion's Feasibility Study "seems to conclude it's feasible" but the conclusion was changed to infeasible. Final edits were not by engineering firm Burns & McDonnell — but by Dominion's own routing engineer.
FALSE"The towers will barely be visible" FACTSCC visual simulations show towers dominating sight lines from homes. Photos shown to the Board in Jan 2025 were taken in summer at peak foliage. Real winter views — and actual Chino Hills photos — tell the true story.
FALSE"Route 1F is a viable alternative" FACTDominion's own counsel told the SCC Route 1F is 'not under consideration.' It was never engineered: no geotechnical analysis, no foundation design, no VDOT approval. The route would place 56-foot crossarms in a 16-foot median, 35 feet from an emergency room, adjacent to childcare facilities and gas stations. LVE's physical constraints analysis (March 29, 2026) documents that Route 1F is not just implausible — it is physically impossible. Source: Feasibility Analysis v6; SCC Hearing Days 9–10.

If Dominion's VDOT claim had no documented basis, what other claims deserve the same scrutiny? The Board and the SCC should demand evidence — not accept assertions at face value. The evidentiary record is closed. The burden of proof should have been higher.

Dominion's Playbook

Accept Harm — or Face Something Worse

Dominion used an escalation tactic: introduce progressively worse options so residents feel pressured to accept the "least bad" overhead route. None of the threats are substantiated. None of the alternatives were real options. The goal was leverage.

Step 1

Routes 3 & 4 Overhead

8.3-mile corridor through neighborhoods and schools. "Least impactful" by Dominion's definition — conspicuously avoiding data center property.

Step 2

Eliminate Underground

Residents told underground is "not feasible." Routes 3 & 4 presented as the only options. In reality: just the options Dominion preferred and controlled.

Step 3

Route 5 — Loudoun County Pkwy

When resistance grew, Dominion added a new route crossing the county's most-traveled road, used by tens of thousands daily.

Step 4

Route 3A Threat

Towers pushed even closer to homes — some placed literally in residents' backyards. Pure escalation to make Route 3 seem "reasonable" by comparison.

Step 5

Route 1F — Towers in the Median

185-foot towers in the Loudoun County Parkway median — 35 feet from an emergency room, next to childcare centers and gas stations. Dominion's own counsel told the SCC it is "not under consideration." It was never real. It was leverage.

None of these escalating threats are substantiated. They are not real. They are leverage tactics designed to make overhead through your neighborhood seem like a compromise.
What They Said vs. What They Did

Dominion Told You One Thing. They Were Doing Another.

What They Told the Community

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    "Committed to public engagement" — Robert Richardson, Dominion Energy, July 2024 Virtual Open House
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    "Your input and involvement are important" — Dominion Project Introduction Letter, June 19, 2024
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    "Consults with key stakeholders to gather feedback" — Dominion Public Engagement Process Document

What They Were Actually Doing

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    Dominion's data center leads described becoming "half real estate agents" They advised developers on areas with available transmission capacity and "supportive" political climate. They prequalified properties based on proximity to transmission, available capacity, and political environment. Their stated top priority: "Above all else, top priority is speed to market."
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    Sources POWERGRID International, October 2024; Washington Post, January 2026.

While Dominion was telling you 'your input is important,' their data center team was advising developers on which parts of the service territory had the most 'supportive' political climate. The community was an obstacle to manage, not a stakeholder to consult.

What Officials Are Saying

The Record Speaks for Itself.

These are not community activists or advocacy groups. These are the regulator's own staff, elected representatives, and county engineers — all reaching the same conclusion.

"Dominion has effectively ensured that its overhead routes are the only viable options — despite the fact that the need for this Project had been known for a much longer period of time."
— SCC Staff Post-Hearing Brief, PUR-2025-00056
"The lines would NOT be needed but for multiple data centers in northern Loudoun County."
— SCC Staff Finding
"We were all blindsided." [On the AWS/GW Campus deal — the same community that was 'blindsided' by this data center decision must also push back on Dominion's overhead lines.]
— Supervisor Turner, on the AWS/GW Campus deal and data center growth without community input
"Your January 2025 resolution said 'advocate for undergrounding within 500 ft of homes where feasible.' Your County engineers confirmed it IS feasible. Your own words. Your own analysis. Your continued support is the only consistent position."
— Greater Loudoun community to the Loudoun County Board of Supervisors
"There are right places for some development and there are wrong places. Precious few places left where we can do those kinds of special things. [Randall and I] agreed that both of us would be laying down in front of bulldozers before we let data centers go there."
— Buddy Rizer, Loudoun County Director of Economic Development (public remarks on Dulles South development)
"Golden-to-Mars has proven to be the most complex. And that informed the order of operations in terms of the construction of this loop."
— Jacob Rosenberg, Dominion Energy, Jan 15, 2026 testimony (Context: Dominion admitted filing the most complex segment last, then citing its own delay as justification for overhead.)

Now you know the truth.

The SCC ruling is expected any day. This is the moment to act — before the decision is made and the towers are built.

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