The Lovettsville and Neersville areas of North Western Loudoun County as well as neighbouring Frederick County - from the West Virginia line through Gore and Clear Brook, where a new 500kV substation is proposed and on through Clarke County, Virginia and Hampshire and Jefferson County, West Virginia and Frederick County Maryland all now face the possibility of the existing 500kV and 138kV row expanding into a massive transmission infrastructure corridor 550' to 650' wide to accommodate TWO NEW HVAC transmission lines to support the Data Centers in Eastern Loudoun.
These lines will require both expanding the existing easements and new greenfield easements,
If both transmission lines are approved, property owners along the the 15 mile segment through far North Western Loudoun will be devastated by a ROW almost four times as wide as a football field is wide and Eminent Domain takings of about 365 acres in the Lovettsville and Neersville areas alone!
There are no existing transmission corridors anywhere in the PJM region with a 765kV, two 500kV and a 138kV transmission line co-located in the same corridor.
On top of the destruction of 365 acres of private property (acres calculation is for the 200' greenfield easement for the 765kV), our local environment, an unprecedented level of Electromagnetic Fields (EMFs) for the people forced to live beside it, these structures would cut 185' into the skyline and will be the prominent feature of the view shed for the entire area.
If these are approved people in the Lovettsville and Neersville , Gore Clear Brook and Clark County areas will be living beside:
Per the FirstEnergy open house(s) on the 500kV they do not appear to be expanding the easement in the Lovettsville and Neersville area as of 8/12/2025 the poles will be 185' high! Frederick County and Jefferson County have places where the easements are being expanded as well as new greenfield lines around and between the substations. In Clear Crook the proposed Woodside substation would sit 40 feet from existing homes.
The Mid-Atlantic National Interest Electric Transmission Corridor (NIETC) was cancelled by the DOE 12/16/2024 . If any state denies these transmission lines the Federal Government will not have the authority to site the transmission line and the transmission line will not be built!

Underground HVDC Is An Alternative to Overhead HVAC Transmission Lines
The only viable alternative to overhead HVAC transmission lines that would preserve the value of private property, conservation easements, national and state parks faced with the Gore-Doubs-Goose Creek and Valley Link transmission projects would be underground high-voltage direct current (HVDC).
Read more about Underground HVDC here
Help us get the word out by posting our petition on social media!
Download our flyer about these two projects and our proposed HVDC underground alternative and hand it out to your neighbours and friends in Loudoun, Frederick and Clarke counties in Virginia and encourage them to sign our petition!
HVDC underground is applicable to all of the proposed 500kV and 765kV projects in Virginia.
If underground HVDC technology is adapted it will save thousands of private property owners across Virginia form eminent domain easement takings for transmission lines to provide energy for data centers!

Friday November 21 at 10:00am there will be a Frederick County Historic Resources Advisory Board Review of the Virginia Technology Park Rezoning application.
The rezoning application is for of a total of +/- 238.57 acres (Property Identification Numbers: 33-A88, 33-A-89, 33-A-90, & 33-9-1A) from the RA (Rural Areas) Zoning District to the TM (Technology Manufacturing Park) Zoning District with proffers. The properties are located west of the Interstate 81 Exit 323, west of Zachary Ann Lane (Route 825), and south of Rest Church Road (Route 669) in the Stonewall Magisterial District. This property abuts the Joline Drive Residences. This is a new re-zoning application and an expansion of the "Fruit Hill" project that was withdrawn. The site plan is for 11 data center buildings and 3 - 300 MW substations!
Thats 900MW - the North Anna Nuclear generation plant, Unit 1 generates 980MW. This site needs its own nuclear plant. Where do they think they are going to get that energy from? What about water?
The next Frederick County Board of Supervisors Meeting is December 3, 2025 at 6:00pm - the rezoning application is not on the agenda yet. However , you can still send comments to the board or show up and speak during the general comment portion of the meeting.
Please send comments opposing this rezoning application to:
john.jewell@fcva.us;jason.aikens@fcva.us;rwells@fcva.us;bdunn@fcva.us;robert.liero@fcva.us;jslaughter@fcva.us;michael.bollhoefer@fcva.us;jtibbs@fcva.us;ann.phillips@fcva.us

Dominion's proposal for a 185 mile entirely underground HVDC transmission line to bring energy from the south of Virginia to the data centers in Northern Virginia has made the short list.
Underground HVDC is obviously technically feasible. Once again, PJM referred to this as the "biggest bang for our buck" they explicitly cited that they would be able to use the existing easements and followed up with all the technical reasons HVDC is the superior choice. This is the PJM favorite, even though the HVDC underground solution is 1.6x times as expensive as the overhead 765kV proposals - $4.8B vs $2.6B.
We happen to agree its the superior technology, this is exactly that folks here have been saying, citing multiple recent papers on underground HVDC, readily available and linked on our own Underground HVDC page. We have been pushing underground HVDC for MARL/Gore-Doubs-Goose Creek and Valley Link for almost three years now - for all of the exact same technical reasons plus minimising the impact to national parks, state parks, conservation easements and 6,000+ acres of private property at risk to be taken.
Portfolio 275 1A, the underground HVDC project, proposed by our state energy monopoly Dominion, from an energy generation facility in Virginia to Dominion's customers in Loudoun County's data center alley will be paid for by the standard rate formula - 50% to the Dominion Zone and 50% spread across the rest of the rate payers in PJM. This is the status quo. Other states pay for Loudoun County's economic plan and the energy crisis Loudoun's unconstrained data center development has created. No state other than Virginia will benefit from this line - but they will pay for it.
During the meeting, PJM also announced that the 765kV Valley Link will have a voltage collapse by 2032 - the line they are aware the line they approved last year fails before it is even built. Obviously the overhead HVAC solutions they have put in place thus far are deficient. Will they re-evaluate MARL/Gore Doubs-Goose Creek and Valley Link for a single underground HVDC solution? Nah, they will keep pushing First Energys 50 year old I765 corporate expansion plan. PJM only selects from the pool of projects proposed - no one proposed an underground HVDC during either of those windows so we get multiple massive overhead lines. PJM "picked the best of the proposals that were submitted" and they are standing by that decision, because they are always right . Until one of the states denies the line(s) then they will be proven wrong and PJM will have to solicit bids for a new solution in a new window.

Because what we really need is more data centers!! A 97 acre property bought 4 years ago for $57M has just sold for $615M. Yet another data center site, up to 5, 2 - story data centers for another 1.6 Million square feet of data centers. Dominion has purchased an adjacent lot for $45M for a substation. I believe the cost for the land and substation will be recovered by Dominion from all rate payers in the Dominion zone. According to JK Land Holdings , who sold the property - this will be a financial shot in the arm for the county and have a positive impact and be an "annuity" for the future. Loudoun County got $4M in transfer taxes. No mention of who will ultimately be paying for the substation property and substation and transmission line build out or whose property will be taken to host the lines.
Loudoun Now: Data Center Sale sets New Price Loudoun Price Record
Data Center Dynamics : SDC Capital Partners buys 97 acres of data center zoned land in Virginia for $615M

At the PJM's 11/4 TEAC Meetingit was confirmed that the dual 500kV circuit proposal from NextERA to add a second 500kV line from West Virginia into the Woodside Substation is no longer being considered.

The larger part of the property NextERA bought in Clear Brook, for its proposed Woodside substation; is the Rural Preservation Tract (Lot 3-12-34) of the Ridgeway Estates Subdivision.
The Ridgeway Estates Subdivision, which includes the Rural Preservation Tract, has a deed of covenant which limits the usage and the type of structures that can be built on subdivision properties . A deed of covenant conveys with the purchase of the land, the purchaser agrees to the covenants when the land is bought. The terms of the covenants can only be changed by a majority vote of the homeowners of the subdivision. The homeowners of the Ridgeway Estates Subdivision have voted and unanimously denied to change the covenants to allow a 500kV substation on the Ridgeway Estates Subdivision Rural Preservation Tract. All parties have been notified that if they proceed with what they have proposed, an injunction will be filed in court.
At this point it looks like NextERA will have to find and purchase a different property for the substation.
Frederick County worked behind the backs of the private property owners, with an out of state private private for profit business, made agreements that they had no authority to either make or negotiate and attempted to use a "substantial accord" review to legitimise it. It was clear to all of us that both the planning commission and the board of supervisors had already made up their minds before the public hearing and the vote. Comprehensive Plans are non-binding policy documents that provide guidance and are not binding law. Its purpose is to govern land use applications as submitted to the board of supervisors.
This situation with the Woodside substation, illustrates the issue with Comprehensive Plans and their "substantial accord" review. It implies an authority that a county does not have , and cuts impacted property owners out of the process until after a decision has been made.
This is what is so dangerous about the Loudoun County Electric Infrastructure Comprehensive Plan Amendment that is defining transmission corridors. It gives the appearance of authority the county does not have.
Rather than Limit or constrain the data center growth such as was done in York County which has a data center zoning ordnance that includes provisions for limiting both water use and electricity,
Loudoun County is looking to work with the electric companies to site inter-state transmission lines to power the data centers. This will undoubtedly be negotiated behind the backs of the private property owners. Just like what played out with the Alternate MARL Route that moved the transmission line into North Western Loudoun.
A portion of the York, County Data Center Zoning Ordnance is below, it requires:
1. A letter from the electric utility purveyor indicating sufficient proximity and availability to a substation and transmission lines with sufficient capacity to serve the proposed data center shall be submitted to the Department of Planning and Development Services. The letter shall specify the amount of energy and voltage level the data center will use at full operating capacity.
2. A letter from the public water purveyor indicating sufficient capacity to serve the proposed data center shall be submitted to the Department of Planning and Development Services. The letter shall specify the amount of water the data center will use at full operating capacity.
3. The data center shall submit a letter from the electric utility and public water purveyor every five (5) years, verifying the data center is using the same amount of electricity and water as was approved. Ord. No. 25-16(R) Page 3
4. The data center may expand its usage of electricity or water to no more than twenty-five percent (25%) of the amount originally approved. Any increase of utility use beyond twenty-five percent (25%) shall be subject to the standards and procedures applicable to amendment of special use permits set forth in Section 24.1-115(d) of this chapter.

Thank you all who attended to support the Ridgeway Estates subdivision community, most of the community was there and many of them spoke. It was amazing to see the co
Supervisor McCann-Slaughter has asked the staff to a) Have NextERA hold a public meeting and b) Determine how long the board of supervisors has to take action apparently the statue is not clear but the belief was it would be 30 days . She also indicated that they would have the lawyers review the case. She stated that she would be following the recommendation of the attorneys.
No substation can be built in Virginia without approval from the Virginia SCC , it is not clear how much site work they can do prior to getting approval from the Virginia State SCC . There is a site plan review at the county level and the site has to conform with the zoning - as was said in the meeting the setback appears to be 50 feet. The Frederick County Zoning Part 401 RA Rural Areas District is linked below.
The next Board Of Supervisors Meeting is October 22, 2025 at 7:00pm the agenda will be published Friday October 17 . We won't know if the Woodside Substation Substantial Accord vote will be held at that meeting until next Friday. If it is not we will still have the opportunity to speak during the public comment meeting.
The client always calls the shots in determining whether to defend its actions. The lawyer merely renders a non-binding opinion. If the client wants to defend its actions it is the duty of the lawyer to make the best possible defence. The Board Of Supervisors is not bound by the recommendation of the county lawyer(s).
Please continue to send comments to: osh.ludwigs; @fcva.ujohn.jewell@fcva.us;rwells@fcva.us;bdunn@fcva.us;robert.liero@fcva.us;jslaughter@fcva.us;michael.bollhoefer@fcva.us;jtibbs@fcva.us;ann.phillips@fcva.us
And ask Vaughn, Chad and Mollie to Advocate for the community and speak out or send a letter to the Frederick County Board of Supervisors :
The Berkley Group did a Zoning Ordinance Evaluation, Page 9 states: Currently, there are many instances where provisions of the Ordinance can be waived or modified after a public hearing before the Board of Supervisors.
Frederick County is in the process of a Zoning Ordinance Update
Who wants to suggest updating the part where a 30 acre 500kV substation can be built "by right" with only a 50' setback from existing residential homes?
More than one Frederick County official has commented that Frederick County can "tap into" Woodside Substation and "get a little energy" for Frederick County. This is a transmission substation not a distribution substation and that is not how transmission substations work. The longer the span of an HVAC transmission line the larger the line losses become and the voltage drops. This substation is to step-up the voltage, not to distribute energy in Frederick County.

Frederick County BOS Meeting
Wednesday, October 8, 7:00 p.m
Board room of the Frederick County administration building,
107 North Kent Street
Winchester, Virginia
I called the Frederick County Board Of Supervisors and spoke with the clerk.
As for the agenda for the 10/8 Meeting:
The planning commission said the application was submitted 9/5 and county has 60 days to act on the application or else it is automatically approved. The next board of supervisors meeting is Wednesday, October 22, 2025 the agenda for that meeting will not be posted until Friday, October 17th .
We need to show up and speak up tomorrow night, the Board Of Supervisors will have time to consider our concerns and must ensure they have an agenda item for a vote to deny or an extension for further review on October 22, 2025.
We want the Board of Supervisors to take a vote that the Woodside substation is not in "substantial accord" and they need to hear from us why it is not . The October 22 Board Of Supervisors meeting is the last meeting before the November 5th deadline we need to impress upon them to build the case for denial now so it can be denied or extend the deadline at the October 22 board meeting.
Please continue to send comments to: osh.ludwig@fcva.us; john.jewell@fcva.us;rwells@fcva.us;bdunn@fcva.us;robert.liero@fcva.us;jslaughter@fcva.us;michael.bollhoefer@fcva.us;jtibbs@fcva.us;ann.phillips@fcva.us
For those of you at the planning commission meeting you will recall one comment by a planning commission member was - we don't have another planning meeting before the deadline (November 5) so lets vote to approve now. We don't want the same situation to play out at the October 22 board of supervisors meeting.
Frederick County BOS Meeting
Wednesday, October 8, 7:00 p.m
Board room of the Frederick County administration building,
107 North Kent Street
Winchester, Virginia
The Planning Commission voted the substation to be in "substantial accord" with the Frederick County Comprehensive Plan, their discussion did not justify their decision. Now their recommendation goes to the Frederick County Board of Supervisors.
The Board of Supervisors has to vote on the Woodside substation "substantial accord" and their vote will OVERRIDE the planning commission's recommendation! We need the Frederick County BOS to vote "NO" and override the Planning Commission's "YES".
Contact the Frederick County BOS NOW and tell them you oppose the Woodside substation because it is not in accordance with the comprehensive plan:
Frederick County BOS emails:
josh.ludwig@fcva.us; john.jewell@fcva.us;rwells@fcva.us;bdunn@fcva.us;robert.liero@fcva.us;jslaughter@fcva.us;michael.bollhoefer@fcva.us;jtibbs@fcva.us;ann.phillips@fcva.us
Make the case for denial for them!
It is not in substantial accord with the comprehensive plan because :
1. The Virginia Code calls for the comprehensive plan to be drafted for the purpose of: “guiding and accomplishing a coordinated, adjusted and harmonious development of the territory which will, in accordance with present and probable future needs and resources, best promote the health, safety, morals, order, convenience, prosperity and general welfare of the inhabitants.”
A substation 40 feet from homes does not meet this criteria.
2. There is no mitigation for current residential properties. Just because in 2023 an area was shaded "blue" for future industrial use in 2035 does not mean a 30 acre substation is in accord with that plan 2 years later! This will gut the home equity of every property in that neighbourhood now! This is not a gradual transmission to industrial use.
3. This substation will take up 70 acres but does not produce jobs. It is an industrial use but it is not an industrial business! And it is not fitting for the character of its surroundings - which is residential, offices , contractors, garages are suitable 500kV substations are not! The only reason NextERA chose this property was because this is the only farmer willing to sell their farm and there are transmission line on the property.
There is no 500kV HVAC Substation in the Frederick County plan - it is not a "feature shown".
There were three Planning Commissioners that voted the Woodside substation was NOT in substantial accord each one had valid reasons for opposing this. Ask Vaughn, Chad and Mollie to Advocate for the community and speak at the Frederick County Board of Supervisors Meeting :
Items 12) Planning Commission Business - Public Hearings and 13) Planning Commission Business - Other Business
At a minimum the Frederick County Board Of Supervisors can extend the deadline for review and engage the Frederick County Attorney to develop a case supporting denial !
Show up to oppose the Woodside substation! Speak Up! Fight !!!!
This is an election year write a letter to the editor, call into a radio talk show, contact a local news show !
Comprehensive plans get reviewed every 5 years - this can be reviewed and overturned figure out who is willing to represent the best interests of residents and who is not and spread the word! Contact every Frederick County Board Of Supervisor and their opponents make this an election issue!

The online comment form is limited to 2000 characters and closes on October 1, 2025 at 12:30 PM
Submit Comments even if you plan on attending in person!
My Comments to the Frederick County Planning Commission:
Frederick County is located between the only base load electric plants with excess capacity and the energy demands of Data Center alley. Clear Brook is already in the cross hairs of not one but TWO massive overhead transmission lines.
The 500kV MARL/Gore-Doubs-GooseCreek line - proposed on new 200' easements in places, re-built in other locations in the existing easement with the existing 138kV in the existing easement on 185' towers.
And the 765kV Valley Link line - a retread of the PATH line defeated in 2012 - only worse! Valley Link is proposed on new 200' easements for its entire length and would be built on V-Structures with guyed-wires.
And NOW in its 2025 Window 1 proposals PJM is ALREADY evaluating a proposal to modify the MARL/Gore-Doubs-GooseCreek project to ADD another 500kV line.
The Woodside substation is NextERA's plan for the property you are currently evaluating for re-zoning:
"Convert the 500kV single circuit 502 Junction - Woodside 500kV project under development (PJM Baseline Upgrade ID b3800.102) to a double circuit configuration between Fort Martin and the NEETMA/APS interconnection point in Frederick County, VA, to accommodate Circuit 1 (b3800.102: 502 Junction – Black Oak – Woodside 500kV) and Circuit 2 (Fort Martin – Sandy Creek – Woodside 500kV)."
Make no mistake, if NextERA prevails and is granted the re-zoning request, NextERA has bought 30+ acres and they will fill it - with industrial infrastructure - to its maximum allowed footprint per the zoning ordinance .
The Clear Brook community as well as other rural towns will be "sandwiched" between multiple overhead HVAC lines , hundred acre data center industrial zones and 10 - 30 acre substations. This is the wrong location for a 30 acre substation. Find a location that is already zoned for industrial use.
Don't Ashburn Clear Brook !
The online comment form is limited to 2000 characters and closes on October 1, 2025 at 12:30 PM
Submit Comments even if you plan on attending in person!
My Comments to the Frederick County Planning Commission:
Frederick County is located between the only base load electric plants with excess capacity and the energy demands of Data Center alley. Clear Brook is already in the cross hairs of not one but TWO massive overhead transmission lines.
The 500kV MARL/Gore-Doubs-GooseCreek line - proposed on new 200' easements in places, re-built in other locations in the existing easement with the existing 138kV in the existing easement on 185' towers.
And the 765kV Valley Link line - a retread of the PATH line defeated in 2012 - only worse! Valley Link is proposed on new 200' easements for its entire length and would be built on V-Structures with guyed-wires.
And NOW in its 2025 Window 1 proposals PJM is ALREADY evaluating a proposal to modify the MARL/Gore-Doubs-GooseCreek project to ADD another 500kV line.
The Woodside substation is NextERA's plan for the property you are currently evaluating for re-zoning:
"Convert the 500kV single circuit 502 Junction - Woodside 500kV project under development (PJM Baseline Upgrade ID b3800.102) to a double circuit configuration between Fort Martin and the NEETMA/APS interconnection point in Frederick County, VA, to accommodate Circuit 1 (b3800.102: 502 Junction – Black Oak – Woodside 500kV) and Circuit 2 (Fort Martin – Sandy Creek – Woodside 500kV)."
Make no mistake, if NextERA prevails and is granted the re-zoning request, NextERA has bought 30+ acres and they will fill it - with industrial infrastructure - to its maximum allowed footprint per the zoning ordinance .
The Clear Brook community as well as other rural towns will be "sandwiched" between multiple overhead HVAC lines , hundred acre data center industrial zones and 10 - 30 acre substations. This is the wrong location for a 30 acre substation. Find a location that is already zoned for industrial use.
Don't Ashburn Clear Brook !
If you miss the data for online submission you can send an email to the members of the Frederick County Board of supervisors (listed below) .
Even if you do submit online comments send the Frederick County BOS an email too! They will be voting on the re -zoning
Frederick County BOS emails:
josh.ludwig@fcva.us; john.jewell@fcva.us;rwells@fcva.us;bdunn@fcva.us;robert.liero@fcva.us;jslaughter@fcva.us;michael.bollhoefer@fcva.us;jtibbs@fcva.us;ann.phillips@fcva.us
Frederick County, Virginia planning commission public hearing on the Woodside Substation Zoning
Wednesday, October 1, 7:30 p.m
The meeting will be held in the board room of the Frederick County administration building,
107 North Kent Street
Winchester, Virginia
The Woodside Station is part of the MARL /Gore-Doubs-Goose Creek project to feed the energy demanded by Loudoun County's data center alley. The property proposed for the substation is close to the existing Stonewall substation in Clear Brook in Frederick County.
This new substation would be located across the street from Joline Drive and the Ridge Way Estates subdivision, this area is zoned residential! Once constructed this will be a magnet for additional transmission lines to serve the data centers in Loudoun County!
Attend in person to have your voice heard and / or submit comments online!

Please be sure to enter comments and be on the record opposing Loudoun County's Electric Infrastructure CPAM land grab.
Direct Testimony on behalf of Loudoun County in the Aspen - Golden Docket: Pg 18 Lines 396 - 403 "The County envisions a pilot program that, in addition to undergrounding all or part of the pilot project under application, would initiate a long-term planning initiative that would include comprehensive plan reform in the participating locality, to identify future transmission corridors and specific criteria for selecting underground projects, which would be favored in all cases. This will create a basis for Planning Staff and the Planning Commission to review applications for substantial accord with the comprehensive plan and applicable zoning, which can stand in place of Certificate of Public Convenience and Necessity review in the SCC."
It bears repeating, given what Loudoun's Planning Commissions have done to Ashburn with the completely unrestrained approval of re-zoning requests for data centers, it's mind-boggling to think people are proposing these same individuals should be allowed to etch-a-sketch transmission lines across private property and approve them and take property by eminent domain to ensure the data centers they approved get the energy they demand.
Comments on the Loudoun County Electrical Infrastructure Plan Amendments will be accepted through the online form (available here) .
Apparently two members of the Loudoun County Planning commission were involved with the sale of a Fauquier County property that has become part of a plan to build a 2.2 million sq.ft data campus in Fauquier County.
According to the article, those members were Ron Meyer and Mark Miller. Mr. Miller bought the property on behalf of JAG MK which is an LLC that Eric Combs (another Loudoun County Planning Commissioner) has been on the board of since 2020. One of the Fauquier County Supervisors also sold his property and naturally its being re-zoned.
"Miller is more than just a minor investor in the project – according to Culbertson, the project would never have materialized if Miller had not connected him to Ron Meyer, the former Loudoun County supervisor who put the Remington Innovation Center application together and pitched it to SDC Capital Partners.
As the application inches through Fauquier County’s review process, Meyer’s Loudoun County perspective is front and center – which he projects as an asset.“I represented Data Center Alley,” Meyer told the Fauquier Times"
Eric Combs was appointed by Michael R. Turner (D-Ashburn) and Supervisor Caleb A. Kerschner appointed Realtor Mark Miller.
Hmmm ....
VA SCC Public Hearings for Comments on the Golden-Mars 500kV Transmission line in Ashburn
Will be held at 6:30 p.m. September 18 at Rock Ridge High School, 43460 Loudoun Reserve Drive, Ashburn, Virginia 20148, arrive 15 minutes early to register to speak
A second hearing will be held 9/29, same place and time.
My understanding is that Loudoun County will be proposing an underground pilot for a portion of the Golden-Mars line, I have not seen the details of the pilot yet.
I support undergrounding ALL transmission lines. The only reason our properties are in peril of being criss-crossed with 500kV and 765kV transmission lines are data center energy demands. These are trillion dollar businesses that can afford to pay to underground ALL lines feeding and encircling Data Center Alley - with whatever technology is feasible underground HVAC or underground HVDC . Data Centers must mitigate the effects of their businesses on residents and private property owners!
No easements should be taken by eminent domain from any private property owner, to host any of these lines. I will make an exception for the data center property owners, because data center are the ones benefiting from the lines. These lines should be located on data center property as much as possible and along highways as far away from private residences as possible.
For both the Haymarket line and the W&O Trail line the local elected representatives took bills to the VA General Assembly defining the pilot program and secured funding for the underground project. The Aspen-Golden and Golden-Mars transmission lines have been in the works for two years now and there has not been a bill passed in the VA General Assembly with a pilot for an underground 500kV line and funding for it.
I asked several elected officials why they are only writing letters to the VA SCC when they can write a bill and have it passed through the VA General Assembly and get funding which would assure the pilot would be built but none of them were able to provide a satisfactory answer.
I did intervene in the Aspen-Golden 500kV case at the Virginia SCC last year and Loudoun County did propose an underground 500kV HVAC alternative. The reference case for the underground 500kV HVAC pilot is in Chino Hills California and it is the only reference case for an underground 500kV lines in the entire world - only 3.7 miles of it is underground . Black & Veatch did the engineering for the Chino Hills line.
The pilot Loudoun County proposed for the Aspen-Golden line included a planning component and an approval process using the Comprehensive Plan which would allow Loudoun County to evaluate and approve the siting of the transmission line. This would usurp the power of the VA SCC (The Hearing Examiner required Loudoun County to re-file a "cured" version of the testimony without the "planning component"). The original testimony is still available in the SCC docket. From the pre-filed Direct Testimony of Mr. Giglio on behalf of Loudoun County:
Pg 17 Lines 370 - 373 "Additionally, the pilot program will include a planning component designed to develop protocols to allow the eventual approval of high-voltage underground transmission lines through local planning processes, including substantial accord review and zoning review."
Pg 18 Lines 396 - 403 "The County envisions a pilot program that, in addition to undergrounding all or partof the pilot project under application, would initiate a long-term planning initiative that would include comprehensive plan reform in the participating locality, to identify future transmission corridors and specific criteria for selecting underground projects, which would be favored in all cases. This will create a basis for Planning Staff and the Planning Commission to review applications for substantial accord with the comprehensive plan and applicable zoning, which can stand in place of Certificate of Public Convenience and Necessity review in the SCC."
It remains to be seen what Loudoun County is proposing for this pilot. However, I can state with assurance I will adamantly oppose ANY pilot that contains a "planning component" where Loudoun County Planning Staff and Planning Commission work with electric utilities to site and evaluate and approve the transmission line in standard accord with the comprehensive plan.
The VA State SCC is the only entity with the constitutional authority to evaluate and site transmission lines and issue a certificate that results in the taking of private property for transmission easements.
Given what Loudoun's Planning Commissions have done to Ashburn with the completely unrestrained approval of re-zoning requests for data centers, it's mind-boggling to think people are proposing these same individuals should be allowed to etch-a-sketch transmission lines across private property and approve them and take property by eminent domain to ensure the data centers they approved get the energy they demand.

The proposals to solve the latest projected set of problems caused by the data center demand in Loudoun County's data center alley are to be discussed at the September 9th, PJM TEAC at 10:30 am - 12:30 am
Proposal 20225 - W1 - 896 proposes to add a second 500kV transmission line on to NextERA's MARL transmission line (the current single 500kV circuit would be come a a double circuit 500kV) from the Ft. Martin generation plant to a new substation north of Bruceton Mills and on to Gore, Virginia. From Gore through Frederick County, VA to the currently proposed Woodside station, a new 200' easement would be taken along the side of FirstEnergy's Gore-Doubs-Goose Creek line for another 500kV transmission line.
This would bring the width of the row up to 600' in West VA - the existing 500kV, a double circuit 500kV (MARL+) and the 765kV Valley Link for a total of 2265kV!
In Frederick County, VA there would be the existing 500kV, the Gore-Doubs-Goose Creek 500kv + 138kV the Valley Link 765kV PLUS a new 500kV in a new 200' easement bringing the width of the easement up to 800' to support a total of 2403kV!
PJM will be evaluating this proposal among others in the next several TEAC meetings and will make a decision on which to approve towards the end of the year.

PJM is in the midst of another planning cycle and once again the energy demands from Loudoun's Data Center Alley are leading to overloads ... in 2032 so again PJM has requested transmission proposals because because PJM can not order generation. There are multiple proposals one of which double ups on MARL and adds an additional 200' ROW through Frederick County, VA.
Excerpts from the analysis of the proposals by Keryn at the StopPATHWv blog are below:
"One of the proposed projects is numbered 896. This proposal, which may have been made by FirstEnergy or NextEra, calls for turning MARL into a double circuit 500kV transmission line, and adding a second 500kV line to the first segment of GDGC across Frederick County, Virginia."
"The proposed MARL double circuit begins at FirstEnergy's Fort Martin power station in Morgantown, WV. The new 500kV circuit will be added to MARL's proposed towers so that MARL would consist of TWO 500kV transmission lines, possibly hanging from the same new tower. This includes the entire portion of MARL from a point in Mon County to the place in Frederick County, Virginia where the MARL project ends and the Gore-Doubs-Goose Creek project begins. It would impact Mon, Preston, Garrett, Allegany, Mineral and Hampshire Counties. The proposer says it will use "existing right-of-way" but that right-of-way doesn't actually exist yet and will only exist if MARL is approved and built. "
"Once this new double circuit 500kV line gets to the demarcation point between MARL and GDGC in Frederick County, Virginia, it proposes to run on a new 200 foot right of way for 17 miles across Frederick County until it reaches the proposed Woodside substation owned by NextEra. They can't simply continue the double circuit on the same new towers when they get to Frederick County because that is the point where the Gore-Doubs-Goose Creek line is already planned to be constructed as a double circuit with the existing 138kV line. The second 500kV circuit would need a whole new right-of-way parallel to the existing configuration. And don't forget that Valley Link is coming along behind it and creating its own new 200 ft. right-of-way. Frederick County is looking at not only the new 185 ft. tower for the first 500kV circuit, but the addition of two new lines on parallel rights-of-way that would add 400 feet to the existing 250 foot wide corridor. Total if this is selected and completed: 650 feet wide right-of-way with three 500 kV lines, one 138kV line, and one 765kV"

The 500kV MARL /Gore-Doubs-GooseCreek transmission line has an InService Date of 2032, the 765kV Valley Link transmission line has an InService Date of 2029!!
First Energy is already working on siting the 765kV transmission line! I've heard they expect to have open houses in the Fall. We don't know which transmission line they will be submitting an application to the Virginia SCC for first or the order they will be submitting the applications to the other states!.
Please watch this video of the installation of the Wyoming - Jackson Ferry 765kV transmission line and send it to every elected official in Virginia that you know. This is a direct result of the data center policy of the Loudoun County BOS.
Please watch this video of the installation of the Wyoming - Jackson Ferry 765kV transmission line.
These are the same structures as has been proposed for Valley link and is planned to go through Neersville and the Lovettsville area.
This is the only 765kV transmission line built between West Virginia and Virginia and it is the 90 mile Wyoming - Jackson Ferry 765kV transmission line.
The permitting process for that transmission line began in 1991, the final approval and Environmental Impact Statement from the Forest Service was in 2002 and the line was not energised until June of 2006.
Fifteen (15) years for a transmission line that is 1/3 the length of the proposed Valley Link Transmission Line .
Tell FirstEnergy to evaluate the 500kV and the 765kV line and do ONE underground HVDC solution
No one in Western Loudoun should be forced to host an overhead HVAC Infrastructure corridor to plug data centers in Data Center Alley into West Virginia base load generation sources.
Please include in your comments we do not want any more overhead HVAC lines - especially not multiple lines. FirstEnergy has TWO massive infrastructure projects through our area a 500kV and a 765kV. FirstEnergy MUST re-evaluate BOTH of these projects and provide ONE underground HVDC solution. The link below provides fact sheets that can be printed.
Is HVDC underground feasible for the MARL/ Gore-Doubs Goose Creek 500kV and valley link transmission 765kV lines? The short answer is yes! For the PATH 765kV transmission line Black & Veatch did a study that proved HVDC underground was a feasible solution through our area. Although it was more expensive (at that time) . An added benefit is that HVDC lines do not emit EMFs.
• The full title of that study was : Black & Veatch, "PJM Interconnection Potomac-Appalachian Transmission Highline (PATH) Project, HVDC Conceptual Study, B&V Project No.164996, B&V File 42.2004 , FINAL November 17, 2009 This was entered into the record as part of the Virginia SCC Case PUE 2009-00043 Application of PATH Allegheny Virginia Transmission Corporation
• Concept 2 was to use HVDC Underground along the Jefferson County WV through Loudoun County segment of the Mt Storm - Doubs line
• This is the same location PJM has proposed to locate MARL (500kV) and Valley Link (765kV) through Jefferson County, West VA and Loudoun County , VA and into Frederick , MD from Welton Springs to Doubs
• The HVDC with underground Concept 2 (~25 miles underground ) would have cost 2x the overhead HVAC 765kV option ($1, 767M vs $3,595M) The additional $1,828M amounts to an extra $73.12M per mile
• Recent studies by NextGen Highways indicate the price has come down significantly and the installation space is smaller now.
• The Aspen/Golden Underground alternative proposed by Loudoun County to put 3 miles underground would be an additional $480M over the cost of the overhead line. $160M extra per mile!
=> The HVDC underground solution proposed in 2009 costs less per mile that what the county proposed for the Aspen/Golden HVAC underground alternate route
=> Data Center impact fees and taxes can be used fund the additional cost of under grounding Loudoun County must set aside funds for this purpose . At this point many of these companies are worth hundreds of billions to trillions in market caps (Amazon reached a $2 Trillion Stock Value on June 27, 2024 ) . Their executives and boards are paid 100's of billions of dollars . There is more than enough money to cover the cost of using HVDC and undergrounding these lines
=> FirstEnergy is now responsible for two massive transmission lines targeted through our communities (Valley Link and Gore-Doubs-Goose Creek). Its time to re-evaluate and look at ONE single solution - figure out how much power can be reasonable imported from West Virginia and build A SINGLE INCLUSIVE HVDC Underground solution to solve it.
=> PJM TEAC Charts on the concept are attached, the full engineering study (B&V Project No.164996, B&V File 42.2004 , FINAL November 17, 2009) was filed during the Virginia SCC Case PUE 2009-00043 Application of PATH Allegheny Virginia Transmission Corporation

The interactive maps have been posted on first pass it appears that the placement of the poles will be inside FirstEnergy's existing 150' easement with some exceptions. In particular in Jefferson County West, VA around the Millville and Feagan's Mill substations.
Its not possible to tell from the maps how much additional property will be taken to expand the easement to accommodate the 500Kv transmission line to strip trees and vegetation that could interfere with the lines. The existing Dominion 500kV transmission line is in a standard 200' easement.
Rivers Edge has reported that there was a team of workers from Progressive Solutions, hired by Dominion Energy , spraying chemicals in the utility easement! This is on the Lovettsville side they have already sprayed Catoctin View and part way to Rivers Edge our understanding is that they will be continuing down the easement.
If your property has a utility easement they still need to obtain your permission to spray chemicals .
They are also cutting trees, be sure to tell them not to stray outside the existing easement.
DO NOT eat blackberries picked from in the area around the lines!
Comments on the Loudoun County Electrical Infrastructure Plan Amendments will be accepted through the online form (available here) . Letters in opposition to the BOS Plan Amendments can also be sent to bos@loudoun.gov.
*** Note the online form includes the ability to upload documents.
Please write Supervisor Caleb A. Kershner of the Catoctin District directly at caleb.kershner@loudoun.gov And copy Virginia State Delegate Higgins (DelGHiggins@house.virginia.gov) and Virginia State Senator Perry (senatorperry@senate.virginia.gov) whom as I understand it are also supportive of these comprehensive plan changes. If you find out otherwise please let me know and I will correct this and link to their opposition comments to the Loudoun County BOS!
The Loudoun County BOS has no authority to designate transmission corridors for HVAC transmission lines as features in the comprehensive plan nor do they have any authority to guide or direct how high voltage transmission lines are managed in the county. No county in Virginia has been granted this authority! Multiple counties in Virginia abut Loudoun County as do multiple states. The idea that Loudoun County gets to locate transmission corridors is absurd that would imply routes through other Virginia counties and neighbouring states!
Additionally, Loudoun County has no say or sway for under grounding. The driver is cost and the applicable law can be succinctly stated "beneficiary pays". Loudoun County would have to put aside money to pay to have the transmission lines put underground. This could be paid for by Data Center impact fees or Data Center taxes but Loudoun County is not currently putting aside any funds at all and does not have a plan to put aside funding for under-grounding. Loudoun County is in fact looking to decrease the data center taxes.
Our communities (Lovettsville and Between the Hills) "host" the one and only interstate 500kV transmission line in northern Loudoun County.
This would effectively re-zone our properties for data center infrastructure use.
Designating a "transmission corridor" will result in private properties being taken essentially "at will" by utilities sequentially in swaths of 50', 100' and 200' - in perpetuity,for the county's stated purpose of providing power to the data centers.
The county's actions are essentially re-zoning portions of private property as "Data Center Infrastructure" for a transmission build out to support the data center energy expansion in their economic plan.
This is patently unconstitutional and violates private property due process rights prescribed in the Virginia Constitution Section 11. This would create 2 classes of property owners:
- For one set of private property owners Loudoun County will be expending tax payer money to defend those properties from ever having a transmission line
- For the second private property owners Loudoun County will be expendng tax payer money to cause those properties to be taken to support multiple inter-state transmission lines
- The second set of property owners will be financially bankrupt defending their property on successive transmission line cases and ultimately be forced to sell.
Loudoun County is bypassing due process by essentially "reserving" properties in advance for transmission line siting and working behind property owners backs to effectuate the taking by working with utilities in the proposal stage of these projects IN ADVANCE OF APPLICATIONS BEING SUBMITTED TO THE VIRGINIA STATE SCC.
This action is basically teeing up our communities for utility takings negotiated BY Loudoun County BOS to benefit other county private property owners and businesses to our detriment and behind our backs!
Loudoun County BOS is attempting to codify the behind door meetings we are aware they participated in to push the MARL 500kV transmission line into our communities without any notification or consultation with the property owners.
Our Catcotin Elected Officials support these comprehensive plan amendments as do the representatives of other districts in Loudoun. This will destroy not only our view shed, our environment, the value of our properties and the quality of our lives, it will subject us to repeated eminent domain takings of easements across our properties to support expanding transmission infrastructure to power the data centers.
All of them support the transmission lines, you will see on their webpages letters they wrote in opposition to the prior siting of the MARL transmission line. But no letters opposed to the 500kV line itself or the proposed route and no letters opposing the 765kV line on V-Structure with guyed wires that we are also facing with the PJM project Valley Link!
The Piedmont Environmental Council and other so called historical and preservation groups in the area are also supporting the comprehensive plan amendments. Read their summer update letter here.
Loudoun County has already pitched the concept of amending the Comprehensive Plan with Transmission Corridors at the VA SCC during the Aspen/Golden case and using it as a pilot and was shot down!
The BOS actually proposed using a "standard accord review" of the comprehensive plan IN PLACE OF A VA SCC CPCN!
Pg1: "Q: Let me ask a factual question. If there is a feature shown on the comprehensive plan what does that mean for the approval of the project?
A: So as a feature shown, it would not have to go through the legislative process for review. ... All they would have to do is go through the normal site plan process to go ahead and identify the design they are proposing and because its a feature shown it's already approved at that level, so.. ."
Pg 3: "Q: So the question is does the County believe it has the authority to define and site the transmission corridor?
A: No ..."
Pg 6: "Q: And as part of that concept do you believe that a zoning change would be required to form a transmission corridor ?"
"Q: Is that a zoning change in your mind?
A: No, it is not"
Pg 16: "Q: Okay, So if we continue on 402, you want this application to stand in the place of a Certificate of Public Convenience and Necessity review at the SCC?
A: Correct .... again pre-designating certain areas where we would anticipate transmission corridors ...we do not have the state enabling legislation to do that.
Anyone with property in Loudoun County should take note and oppose this activity!

First Energy is naming the segment of the Mid-Atlantic Resiliency Link (MARL) that they propose to build from the Potomac River through Frederick County and Montgomery County Maryland the "Gore-Doubs-Goose Creek" 500kV transmission line. Word has it that the segment from Frederick County, Virginia, through Jefferson County, West Virginia and Loudoun County, Virginia and on across the Potomac will also be named the "Gore-Doubs-Goose Creek" 500kV transmission line.
First Energy has not scheduled or held any open houses in either Frederick or Loudoun Counties in Virginia or in Jefferson County, West Virginia. There was one and only one First Energy one open house in Maryland held in Frederick County, Maryland. When questioned about when they would be holding open houses in Virginia and West Virginia they would not divulge a date or how many open houses they would be holding. Property owners in Virginia and West Virginia are being intentionally kept in the dark .
A fact sheet from the Maryland open house stated "While the project is mainly using existing rights-of-way, there are “some limited areas” where the rights-of-way will have to be expanded to accommodate new transmission structures".
In a stunning display of cognitive dissonance the Loudoun County BOS has proposed to lower the property tax on data centers and data center personal property tax in particular. Lowering the data center tax rate is a "core element" of their financial plan.
The Loudoun County BOS' justification for lowering the rate is to "rein in the growth of government". They are pointing to the reduced rate for real estate taxes (you know the one where they lowered the tax rate and increased the land assessments that resulted in a larger overall tax bill than last year bill) and the pathetic decrease in personal property taxes on cars (that tax rate was reduced $.38 to $3.09 personal per $100 of the car's valuation.) If your car is worth between $5,000 and $10,000 that is a $14 to $28 annual savings in the "amount you lease the car you paid for" from the county. The county had a $280M surplus that could have been refunded to Loudoun County tax payers, but wasn't.
At the same the same time Loudoun County has appealed to the Virginia Supreme Court to push for under- grounding @3 miles of the Aspen-Golden 500kV line which would cost rate payers in the Dominion Zone an additional $480 million. Meanwhile western Loudoun is facing the loss of 365 acres of private property to host an additional 500kV plus a 765kV transmission line.
How about we charge the data centers more in taxes and impact fees to cover the destruction and loss of quality of life the infrastructure is causing? The data centers must PAY to underground the transmission lines (either HVAC or HVDC whichever is appropriate) being proposed to support their energy demands.
See Loudoun Now: Vol 10, No.36 July 17, 2025article "Rebalance: County Eyes Lower Data Center Taxes"
See Also Loudoun Now: July 10, 2025 "County Staff to Push for Lower Data Center Taxes to Balance Revenues"
And NetChoice: "Jaw-Dropping Numbers: Loudoun's Data Center Tax Revenue Could Top Real Estate Taxes In Just a Few Years"
In other data center news apparently PJM called upon Loudoun Counties data centers to run on their own backup generators to provide relief for the grid. Did you know there are 4000 backup generators in Loudoun County supporting the data centers?
See Loudoun Now: Vol 10, No.36 July 17, 2025article "Generator Use Jumps In Heat Wave; Turner pushes for Tier 4 Upgrades"

Thank you to everyone who wrote letters and / or signed the petition objecting to the incentive rates, these were uploaded to FERC (Docket ER25-1633 Valley Link Incentive Rates). Note that our Virginia Governor Youngkin sent comments in support.
Valley Link had requested a 10.9% return on equity plus an additional .5% for its new membership in PJM Interconnection, for a total interest rate of 11.4%. The project’s $3B cost will be slowly depreciated over perhaps four decades and during that time consumers would pay 11.4% on the remaining balance every year, making the final cost to ratepayers double or triple Valley Link’s actual cost to build.
The Construction Work In Progress (CWIP) in Ratebase incentive combined with the Hypothetical Capital Structure incentive will allow Valley Link to earn extra cash for its project before it is even constructed, all at consumer expense! Valley Link asked the Commission to make consumers “the bank” by loaning Valley Link money during the construction period and also requested that the Commission make consumers “the insurer of last resort” by granting the Abandoned Plant incentive that will charge consumers for Valley Link’s investment in the project even if it is never built! And the Valley Link Proposal had no cost caps! So they can come back every year and increase the cost of the project!
Although Chairman Christie dissented, FERC approved the incentive rates (Construction Work In Progress and Abandoned Plant Incentive) and the .5% for new membership in PJM. FERC set the ROE, formula rate, formula rate protocols and 60/40 Hypothetical Capital Structure incentive for hearing and settlement proceedings. I will be participating and post an update after settlement.
Chairman Christie's dissent stated "another major problem is that FERC’s general practice in granting transmission incentives has become a “check-the-box” exercise.
He continues "For example, I have stated that the Commission’s incentives policies—particularly the CWIP Incentive, which allows recovery of costs before a project has been put into service—run the risk of making consumers “the bank” for the transmission developer; but, unlike a real bank, which gets to charge interest for the money it loans, under our existing incentives policies the consumer not only effectively “loans” the money through the formula rates mechanism, but also pays the utility a profit, known as Return on Equity, or “ROE,” for the privilege of serving as the utility’s de facto lender. Further, just as the CWIP Incentive effectively makes consumers the bank for transmission developers, the Abandoned Plant Incentive effectively makes them the insurer of last resort as well. This incentive allows transmission developers to recover from consumers the costs of investments in projects that fail to materialize and thus do not benefit consumers. Just as consumers receive no interest for the money they effectively loan transmission developers through the CWIP Incentive, they receive no premiums for the insurance they provide through the Abandoned Plant Incentive if the project is never built. And if the CWIP Incentive is a de facto loan and the Abandoned Plant Incentive is de facto insurance—both provided by consumers—then the RTO participation adder, which increases the transmission owner’s ROE above the market cost of equity capital, is an involuntary gift from consumers. There has been and continues to be something really wrong with this picture."
If you have the time I highly recommend reading Chairman Christie's dissent

Loudoun County is in the process of creating a Comprehensive Plan Amendment on transmission corridors. The proposed amendments are from the Loudoun County Transportation and Land Use Committee and include adapting policies to encourage the "grouping of these tall structures within an existing and/or expanded transmission corridor right-of-way." Loudoun County has contracted with an engineering firm (Kimley-Horn) to map all the high voltage transmission lines in the county. This targets the property of every land owner along the existing HVAC transmission lines!!
Virginia is a Dillon Rule state which means a county has no authority except what the state has granted it. Loudoun County has no authority to site HVAC transmission lines or designate transmission corridors. Loudoun County also intends to add an overlay with the transmission lines on the county map. This will have serious implications for our property values and eventually the "By Right" use of our property !
This is a power grab and a land grab on the part of the Loudoun County BOS! It is essentially re-zoning our properties for energy infrastructure for the data centers and is setting us up for loosing our properties by successive Eminent Domain takings piece by piece!
Loudoun County BOS states "we don't have the authority to site the line the VA SCC does". The fact of the matter is they are doing this to influence / pre-empt the VA SCC to have their preferred route proposed in advance of the application submission / hearing.

As to electromagnetic fields (EMFs), the electric utility companies routinely say: nothing to see here. We disagree, particularly where multiple high voltage lines are sited on the same corridor.
Recent decisions by PJM have totally ignored and increased the health risks associated with EMF’s exposure from multiple high voltage lines on a single corridor. In August 2024, PLM approved a 500 kV line to be located in north west Loudoun County (Neersville/Lovettsville). In February 2025, PJM approved a 765 kV line for the same area, an area already burdened with a 500 kV line and a 138 kV line. Four total lines, two of which are 500kV plus the 765Kv, these are massive High Voltage Alternating Current (HVAC) on a corridor that may be as wide as 600 feet. The electromagnetic fields do not end at the edge of the right-of-way!
A world renowned expert on EMFs, Columbia University Professor Martin Blank (now deceased), and author of over 200 papers, submitted testimony before the SCC in the PATH litigation, Case No. PUE 2009-00043, in which he stated: “There can be no doubt that the proposed addition of the 765kV line to the existing 500kV line 138 kV lines would add to the level of EMF and thereby create additional potential risk.” Testimony at 15.
The risk of leukemia in children is real (Page. 3,6) as is “the risk to health of people in the vicinity” of the 765kV line. (Page 6). If these lines are built, a large swat of north west Loudoun will become hazardous to one’s health. Pictured chart is available here: https://emfcenter.com/what-distance-is-safe/
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