Virginia Energy Plan
stakeholder submission.

Public Evidence Project - independent public-interest data project

On behalf of an organization

Energy efficiency and weatherization

More Important

Managing energy demand and peak use

Most Important

Electric-generating resources

More Important

Transmission and distribution infrastructure

Most Important

Distributed energy resources and storage

More Important

Advanced and emerging energy technologies

More Important

Transportation energy and electrification

More Important

Fuel supply, fuel diversity, and energy security

More Important

Workforce development and training

More Important

Siting, land-use planning, and environmental mitigation

Most Important

Agricultural and rural energy solutions

More Important

Virginia's energy planning increasingly depends on comparable public records across agencies and levels of government. Managing demand, transmission and distribution, and siting decisions are especially difficult to evaluate when public records use different units, identifiers, status terms, and reporting periods. The plan should pair these priorities with transparent, source-linked data that allows government, researchers, journalists, and communities to distinguish proposals, permits, construction, operation, modeled demand, and measured outcomes.

• Public acceptance or trust
• Data gaps
• Unclear roles among state, local, federal, utility, and private-sector actors

Virginia must plan for rapid growth in large electric loads while protecting affordability, reliability, and environmental outcomes. A related challenge is that public records are fragmented across agencies and often use different units, identifiers, status terms, and time periods. Proposed facilities, interconnection requests, permits, buildings, campuses, modeled demand, operating load, and measured emissions are not interchangeable. Without explicit definitions and source links, decision-makers and the public cannot reliably compare claims or understand uncertainty.

Virginia should build a durable public evidence architecture for energy planning: stable facility and project identifiers; a common vocabulary for proposed, queued, permitted, constructed, operating, and retired status; downloadable source-linked tables; field definitions; version histories; and documented relationships among SCC, DEQ, utility, local land-use, and federal records. Scenario forecasts should remain clearly separated from observed and measured values. The state should also publish the assumptions and sensitivity tests used for large-load, transmission, generation, and affordability planning.

• Electricity bills
• Upfront costs for energy efficiency or clean energy upgrades
• Utility fees or riders

Electricity bills and utility riders are the most direct channels through which planning and infrastructure decisions affect households and businesses. Upfront efficiency costs matter because cost-effective demand reductions may be inaccessible without practical financing or program support. The plan should make cost allocation, assumptions, time horizons, and uncertainty transparent so that short-term bill impacts are not confused with long-term system costs or benefits.

• Low-income households
• Communities with high energy burdens
• Communities with existing or proposed energy infrastructure projects

These groups can experience the most direct consequences of energy-cost changes and infrastructure decisions while having unequal access to technical records and decision-making processes. Particular attention should include accessible source materials, clear cost-allocation explanations, and a documented account of how community input affected the final plan.

Virginia should document project status, land area, water and air permits, grid and generator infrastructure, cumulative effects, mitigation commitments, and responsible agencies without treating any single record as proof of construction or operation. Public records should use stable identifiers and link related local, state, federal, and utility proceedings. The plan should identify what is measured, modeled, permitted, proposed, confidential, or unavailable, and should preserve the dates and versions of source records.

The plan should publish scenario assumptions for fuel availability, price volatility, extreme weather, generator outages, regional constraints, and backup generation. Permitted backup-generator capacity or operating-hour limits should not be presented as evidence of actual operation, fuel consumption, or emissions. Observed values, modeled scenarios, contractual arrangements, and regulatory limits should remain separate.

Virginia should seek common definitions and downloadable source tables across state agencies, utilities, PJM, and neighboring jurisdictions. For large-load and transmission planning, records should distinguish requested, queued, studied, contracted, withdrawn, energized, and operating status. Regional forecasts should include source dates, scenario assumptions, uncertainty ranges, and change logs so that public users can understand revisions over time.

Virginia should avoid cost shifting, decisions based on stale or incomparable records, and claims that overstate what a permit, queue entry, forecast, or monitoring result establishes. Policies should consider cumulative infrastructure and community effects while preserving project-specific evidence boundaries. Confidentiality should be narrowly described rather than used to obscure the existence, status, unit, or age of planning inputs. The state should also avoid placing the burden of reconciling fragmented public records on affected communities.

Useful Virginia sources include: Virginia JLARC, Data Centers in Virginia (2024), https://jlarc.virginia.gov/landing-2024-data-centers-in-virginia.asp ; Virginia DEQ, Issued Air Permits for Data Centers, https://www.deq.virginia.gov/news-info/shortcuts/permits/air/issued-air-permits-for-data-centers ; and the source-linked Virginia Data Center Air Permit Index and methodology published by Public Evidence Project, https://publicevidence.org/data and https://publicevidence.org/methodology . These sources are complementary: none should be treated alone as a facility census, operating-status register, load forecast, or measure of actual emissions.

Public Evidence Project recommends that the 2026 Virginia Energy Plan establish a consistent, machine-readable public evidence layer for large energy users and data-center infrastructure. Public records should distinguish proposed, queued, permitted, constructed, operational, and measured status. Facility counts, permit records, buildings, campuses, interconnection requests, generator capacity, modeled demand, and actual energy use should not be treated as interchangeable measures. Virginia should publish stable facility identifiers, source-linked records, downloadable tables, version histories, field definitions, and documented relationships among SCC, DEQ, utility, local land-use, and federal records. Where information is unavailable or cannot be publicly disclosed, the plan should identify the data gap rather than imply that no activity or impact exists. These measures would support government planning, independent research, journalism, community understanding, and correction of factual errors without presuming a position for or against individual projects.