Questioning an Explosive Forecast: PEC Intervenes in Dominion IRP

Several years into the data center explosion in our region, the big picture is finally becoming clear to both the public and our decision makers. No longer are our communities just hearing The Piedmont Environmental Council’s warnings about the potential future impacts of this growth; we are all facing the full onslaught of those impacts now.

That’s why this year we chose to intervene in the Dominion Energy Integrated Resource Plan, or IRP, and question the reasonableness of the plan and the massive energy demand underpinning it.

Why Dominion’s IRP Matters

The Dominion IRP is a long-term proposal — filed at regular intervals — for meeting energy demand in the state. The most recent IRP was filed with the State Corporation Commission in October 2024, with plans for meeting an unprecedented energy demand that is projected to double Dominion’s entire load in Virginia over the next 15 years. The vast majority of that new demand comes from planned data centers.

When the SCC considers Dominion’s IRP, people and organizations can serve as “interveners,” posing questions and offering additional information the SCC can use in its decision to either approve the IRP or ask for another round of revisions. PEC has stepped up as such an intervener in this most recent IRP.

The ballooning demand for power generation and transmission lines to serve data centers has led to expedited power projects across the state. These power projects not only threaten Virginia’s natural resources, the climate, and many of the Virginia Piedmont’s rural areas, but also could result in more than a doubling of electricity costs for anyone with an electric bill, including residents and small businesses in our communities.

An aerial view of transmission lines coming in to an electrical substation.
The ballooning demand for power generation and transmission lines to serve data centers has led to expedited power projects across the state, including transmission lines and substations. Photo by Hugh Kenny/PEC

Dominion’s IRP seeks to meet the explosive load forecast over the next 15 years with a variety of power sources, including 3.4 gigawatts (GW) of new offshore wind added to the 2.6 GW already in development, 1.3 GW of new nuclear, about 12 GW of new solar, and 6 GW of new methane gas generation, plus 4.5 GW of new battery storage. That’s a total of 25.3 GW of new power solely to serve data centers. To put that in perspective, that is more than the peak demand of the entire Virginia Dominion Energy territory, which extends from the southeast of the state up to northern Virginia and includes 2.7 million households.

PEC’s Feedback for the SCC

Of the many interveners in the SCC case, PEC’s contribution brought in a unique and powerful perspective not covered by others.

  • We argued that Dominion’s proposed IRP is built on an unsustainable and unreasonable energy demand forecast based not on real need, but on Dominion’s own actions. Dominion has actively sought out new data center customers and entered into contracts that today total 40 GW of power for the data center industry, creating an “energy crisis by contract.” The scale of these contracts has pushed the SCC into a corner, forced to reconcile potential impacts on the grid and other utility customers.
  • We highlighted for the SCC and the public that Dominion is agreeing to contracts with unreasonable in-service dates and then using those contracts to justify massive build-out of fossil-fuel infrastructure in a fashion that fails to protect the state and residents. 
  • We argued that Dominion should be required to model a plan with later in-service dates for the power commitments to in the contracts. Extended timelines would ensure that the necessary energy transmission and generation infrastructure is installed in a manner that is consistent with state policies and that protects customers, communities, and natural and cultural resources. This approach would reduce the growing risk of “stranded assets,” leaving Virginians holding the bag for building and energy infrastructure if and when data center companies do not grow as much as they’ve proposed.
Dominion’s IRP plans to meet some of the explosive load forecast from new data center customers with methane gas generation, which could mean more gas pipelines cutting through our rural landscapes. Photo courtesy of Dominion Pipeline Monitoring Coalition

What We’re Doing Next 

Following our action alert on the IRP case in front of the SCC, the public submitted over 300 comments expressing concerns with data center growth and Dominion’s plan for meeting it. Many of those comments were from PEC members like you! Now that we have brought these issues to the SCC, we will continue to build on them in the upcoming SCC biennial review of Dominion rates and transmission line cases.

Intervening in these SCC cases is only one part of PEC’s strategy to protect the northern Piedmont region and all of Virginia from the dangerous impacts of this industry. At the state level, we are persistently advocating for comprehensive data center reform, and at the county level, our land use staff work on the ground daily to educate local decision makers about the risks of continued data center campus approvals without full consideration of energy, water, air quality and quality of life impacts.

We challenge the fundamental fallacy that Virginia must meet the ever growing energy demand of this industry; it is time we start asking how much is actually sustainable. Data centers run our digital world, but Virginia already has the largest data center market in the world, one that stands to quadruple under the many approved projects and Dominion contracts made without any oversight. That growth is threatening our water supplies, deteriorating our air quality and public health, contributing to climate change, degrading our communities, parks, and quality of life, and raising our electric bills. 

The state cannot afford a business-as-usual approach. We will continue to push the SCC, our utilities, our state agencies, our General Assembly and our local elected officials to change their policies to address this crisis.

This article appeared in the 2025 Summer edition of The Piedmont Environmental Council’s member newsletter, The Piedmont View. If you’d like to become a PEC member or renew your membership, please visit pecva.org/join.