What the Dominion Order Actually Says

On November 25, 2025, the Virginia State Corporation Commission issued its final order in Dominion Energy Virginia's biennial rate review, Case No. PUR-2025-00058. The order creates Rate Schedule GS-5 for the largest customers, effective January 1, 2027. It has been described many times since. We read the 28-page order.

What it requires

• Who qualifies. Customers with measured or contracted demand of 25 megawatts or more on a contiguous site, and a measured or expected load factor of at least 75 percent. Both conditions apply. The second is frequently dropped in summaries.
• Minimum charges. 85 percent of contracted demand for distribution, 85 percent for transmission, and 60 percent for generation. The generation minimum is missing from at least one widely circulated analysis of the order.
• Contract term. Fourteen years for customers signing on or after January 1, 2027, with a ramp period of up to four years at a minimum 20 percent per year. One detail we found nowhere else: if a customer keeps taking service after the fourteen years, the minimum charges continue.
• Collateral. $1.5 million per megawatt — reducible by up to 70 percent based on established credit, with guarantees and letters of credit allowed, one-fourteenth released each year, and interest paid on cash collateral.
• Exit. A customer that ceases operations or defaults owes the outstanding minimum charges over the rest of the term, subject to capacity reassignment.
• Reductions. Up to 20 percent at no cost; another 30 percent if a different customer takes over the capacity; each reduction on 36 months' notice.
• Legacy customers. Customers served before January 1, 2016 are exempt from the minimum demand charges.

Our correction

A week ago, we recorded the $1.5 million per megawatt figure as not established. We couldn't find it in the Commission's release or in any account we could trace to the order, so we marked it not to be cited. It is in the order, on page 25. We have corrected the entry.

The figure is real. It is also a ceiling. With the full credit reduction, a creditworthy customer could post $450,000 per megawatt. Quoting $1.5 million alone overstates the obligation for exactly the customers most likely to qualify for the reduction. Both halves of the sentence matter.

The number the Commission relied on

The order records that under Dominion's own class cost-of-service study, the customers who will make up GS-5 earned a per-books return of 6.28 percent for the test period — the lowest of any class except outdoor lighting — and 3.01 percent on transmission. The remaining large general-service customers earned 20.75 and 22.41 percent.

The Commission attached its own caveat: transmission rates are actually set under a different allocation method than the one this study used. The number depends on the method. That is why the order directs Dominion to develop alternatives to its current allocation approach for the next rate review, and alternative transmission cost allocations for its next transmission filing. The order does not reallocate costs. It orders Dominion to propose how.

Why this matters outside Virginia

GS-5 has become a reference point. Oregon's POWER Act gives its investor-owned utilities similar tools — special tariffs and exit fees — and other states are drafting their own. A template copied from a summary carries the summary's omissions with it.

Calyx Intelligence maintains a public register of data center siting, power, and public finance provisions — each entry marked for whether it was read in the original document and whether it reconciles. register.calyxos.ai