Dominion Seeks SCC Blessing for Valley Link Affiliates as FERC Weighs 11.4% ROE Incentives

RICHMOND — Dominion Energy is asking Virginia regulators to bless affiliate contracts that would let shell companies carry a multi-billion-dollar 765-kilovolt build into the Mid-Atlantic — while federal filings seek formula rates and a rich incentive stack that critics say shift risk onto ordinary customers for a PATH remake serving Loudoun data centers.

On December 3, 2025, Virginia Electric and Power Company, Dominion High Voltage MidAtlantic, Inc., and Valley Link Transmission Virginia Development, Inc. petitioned the State Corporation Commission in Case No. PUR-2025-00220 for approval under Chapter 4 of Title 56 to enter affiliate agreements. In comments on that petition, Theresa Ghiorzi of Lovettsville challenged the company’s claim that “PJM selected three of Valley Link’s proposals.” Technically, she wrote, the Valley Link companies did not win anything at PJM. FirstEnergy, Transource, and Dominion were awarded the work as incumbents; only afterward was the portfolio branded Valley Link and state-specific LLCs created. Those Virginia, Maryland, and West Virginia Valley Link entities have no employees — “shell” companies, in her words — formed so a new RTO member could seek an extra 50 basis-point return at FERC. FERC granted that adder over intervenor objections even though the parent incumbents already participate in PJM.

The federal rate case is ER25-1633. On March 14, 2025, Valley Link Transmission Maryland, LLC, Valley Link Transmission Virginia, LLC, and Valley Link Transmission West Virginia, LLC asked FERC for formula rates and transmission incentives under Federal Power Act Section 219. Ghiorzi’s motion to intervene and protest lists the ask: 100 percent abandoned-plant recovery for prudently incurred costs; 100 percent construction work in progress in rate base during development and construction; a hypothetical capital structure of 40 percent debt and 60 percent equity; recovery of pre-commercial costs; and a return on equity set at 10.9 percent — for a stated total ROE of 11.4 percent once the 50-basis-point RTO participation adder is included. The Organization of PJM States, Inc., describing the same filing as covering about a $3 billion portfolio of two 765 kV lines and four new substations, urged the Commission to test whether customers benefit from those incentives individually and together. Virginia’s SCC was among the OPSI members supporting those comments.

Ghiorzi’s SCC comments put the corporate structure in political and engineering context. A northern Valley Link segment of about 260 miles of 765 kV between Putnam County, West Virginia, and Frederick County, Maryland, is, she argues, a regurgitation of the cancelled PATH project and of AEP’s long-running I-765 / Project Mountaineer vision — now marketed as round-the-clock reliability. PJM, she charges, put its finger on the scale, recommending a portfolio even while finding that most short-listed proposals offered comparable reliability merits, citing superior transfer capability from dual 765 kV corridors. The demand driver remains Loudoun’s data center expansion — inventory grown under Democratic Board majorities that repeatedly rezoned, grandfathered, and expanded by-right pathways for campuses that now need interstate imports.

Ratepayer history hangs over the incentive ask. PATH collected generous incentives, then left accounting fights that lasted about 11 years after abandonment; Ghiorzi says customers absorbed roughly $250 million for a line no state approved. Valley Link’s abandoned-plant and CWIP incentives, plus a capital structure tilted toward equity, recreate that risk profile before a single tower is set. Her February 2025 PJM Board letter already argued Proposal #708 underbid with guyed V-lattice structures unlikely to be permitted, lacked cost caps, and cannot meet a 2029 in-service date that constructability reviewers called aggressive — especially after MARL’s related 500 kV scope change slipped to 2032.

The SCC affiliate docket does not by itself certificate the line. It asks whether Dominion may contract with its MidAtlantic high-voltage affiliate and the Valley Link Virginia development entity under Virginia’s affiliate-transaction rules. Ghiorzi’s answer is that regulators should not treat post-hoc shell companies and joint incumbent collaboration as a competitive, customer-protecting design. All Virginia News readers have watched the same pattern on Golden-Mars, Line #514, and MARL: Democratic local votes create the load; utility portfolios socialize the wires; rate cases monetize the risk. PUR-2025-00220 and ER25-1633 are where that bill gets an affiliate stamp and an 11.4 percent return.

Email the Loudoun County School Board:
April Chandler, april.chandler@lcps.org,
Anne Donohue, anne.donohue@lcps.org,
Deana Griffiths, deana.griffiths@lcps.org,
Ross Svenson, ross.stevenson@lcps.org,
Kari LaBell, kari.labell@lcps.org,
Jon Pepper, jonathon.pepper@lcps.org,
Lauren Shernoff, lauren.shernoff@lcps.org,
Sumera Rashid, sumera.rashid@lcps.org,
Amy Riccardi, amy.riccardi@lcps.org,

Email the Board of Supervisors at:
Phyllis J. Randall (Chair, At-Large) – Phyllis.Randall@loudoun.gov,
Michael R. Turner (Vice Chair, Ashburn District) – Mike.Turner@loudoun.gov,
Juli E. Briskman (Algonkian District) – Juli.Briskman@loudoun.gov,
Sylvia R. Glass (Broad Run District) – Sylvia.Glass@loudoun.gov,
Caleb Kershner (Catoctin District) – caleb.kershner@loudoun.gov,
Matthew F. Letourneau (Dulles District) – Matt.Letourneau@loudoun.gov,
Kristen C. Umstattd (Leesburg District) – Kristen.Umstattd@loudoun.gov,
Laura A. TeKrony (Little River District) – Laura.TeKrony@loudoun.gov,
Koran Saines (Sterling District) – Koran.Saines@loudoun.gov