Concentrated Benefit, Dispersed Burden: Who Carries Virginia's Data Center Transmission, and What the Cost-Allocation Record Does Not Trace
Virginia's data centers consumed roughly a quarter of the Commonwealth's electricity in 2023, and PJM attributes a ten-gigawatt increase in its 2029 load forecast primarily to them, naming the…
Virginia's data centers consumed roughly a quarter of the Commonwealth's electricity in 2023, and PJM attributes a ten-gigawatt increase in its 2029 load forecast primarily to them, naming the Dominion zone and the eastern PJM footprint as the source of the resulting transmission need. Serving that load requires transmission. This report establishes, from primary sources and original measurement, that the tax benefit of a data center accrues to the locality hosting it, the cost of the wires is spread across an entire utility zone with no reference to geography, and the physical burden falls on a third set of places that appear in neither calculation.
Four findings are new.
One. PJM allocates the Joshua Falls–Yeat 765 kV project under a mandatory two-part formula for facilities at or above 500 kV: half by load-ratio share, half by distribution factor. Dominion's combined share is 44.96 percent as filed with the February 2025 recommendation and 45.29 percent on the 2026 load-ratio vector. The tariff's precision stops at the zone boundary. Below it, recovery references cause only by rate class, and a Commission order of July 31, 2026 directs a filing that would charge a new or expanding large customer for the facilities connecting it to the network. No instrument examined here, at any level, references geography.
Two. Measured against published route geometry, 80.99 percent of the routed line runs through counties with no operating data center, and 45.98 percent through counties with no facility and no proposal in any status. Benchmarked against 2,000 randomly placed 116.47-mile corridors drawn entirely within Virginia, neither figure exceeds chance — the random median is 88.5 and 70.8 percent respectively, placing the observed corridor at the 36th and 17th percentiles, inside the random range on both. The finding is not that burden was steered away from beneficiaries. It is that the allocation instrument does not condition on geography at any step, and this is what the resulting geography looks like.
Three. The corridor counties are cooperative territory, which is unremarkable for rural Virginia (§ 9.1). No source located for this volume shows any of the cooperatives serving the corridor (Rappahannock, Central Virginia Electric, Southside, Mecklenburg Electric) taking part in the PJM process that allocated the cost, and Appalachian Power, present in four counties along the route, sits in the AEP zone, which carries a load-ratio share and a zero distribution factor on this project.
Four. Louisa County adopted an overlay district in 2023 whose qualifying criterion is proximity to 115 kV transmission and in which data centers were permitted by right. All four of its districts lie within 452 meters of a single 230 kV circuit radiating from the North Anna Nuclear Power Station, and 18.9 percent of their area lies within that distance of a qualifying line, against 7.2 percent of the county. No conditional use permit and no state transmission certificate attended the 420 MW campus subsequently entitled there (§ 15.3), and no substantial-accord review of it is established on the record (§ 15.1). The county converted every Technology Overlay District principal use to conditional use permit by Ordinance 2024-11 on August 5, 2024, and removed roughly 2,000 acres; the Louisa case study in this series records both AWS campuses as grandfathered, so the conversion reached neither. Virginia's newest data center siting statute, § 15.2-2209.5, enacted in 2026, triggers only on a rezoning, special exception, or special use permit application — and therefore passes over by-right overlay land entirely.
Garimella (2026), the strongest contrary finding in the field, finds no robust residential bill effect across 24 states and explains that null by cost dilution across large customer bases. That explanation is this report's mechanism, reached independently from the opposite direction.
The zone-level allocation question is live before FERC in Maryland Office of People's Counsel v. PJM , Docket EL26-63, undecided as of October 10, 2026. This report supplies the layer beneath it: sub-zonal geographic burden, measured.