A data center power figure becomes more useful when the project team has to show where it came from. Loudoun County, Virginia, has announced additional documentation for large facilities seeking legislative land use approval, bringing utility discussions and site impacts into the same application process.
The county's October 23 announcement says the requirements apply to current and future legislative applications. It excludes by-right administrative approvals and notes that new data center applications have needed a special exception since March 2025. That makes this relevant to teams preparing new projects as well as those managing pending cases.
The fresh development is the county's implementation announcement. The underlying Virginia legislation was passed earlier in 2026.
What the documentation establishes
Under Virginia Code § 15.2-2209.5, a high energy use facility is one expected, at application filing, to require at least 100 MW from a retail electric utility. The statute calls for utility information about serving substations and anticipated transmission voltage, alongside a sound assessment for homes and schools within 500 feet of the property boundary.
Loudoun's application checklist also requires assessment of effects on water, agricultural resources, parks, registered historic sites and forestland on or immediately beside the site.
The county's disclosure affidavit asks for utility correspondence concerning power and voltage at full build-out. It also requires future correspondence and a review for changed or supplemental information before each hearing.
Analysis: give the power estimate an owner
For an infrastructure team, the practical opportunity is to make the application, electrical design and commercial capacity plan traceable to the same assumptions.
Start by recording what each power number measures. Utility demand, critical IT load and the capacity advertised to prospective tenants answer different questions. A campus presentation should identify the boundary behind its headline figure, along with the supporting document and revision date.
The statutory threshold concerns expected utility demand. Teams should assess it using that definition rather than substitute a rack capacity figure. A consistent demand model would show how the proposed IT deployment, cooling design and other facility loads contribute to the service request. This is an engineering recommendation, not an additional requirement stated in the county announcement.
Assign responsibility for updating that model. If the cooling approach changes during design, somebody should determine whether the utility request, site assessment or hearing material needs revision. Otherwise, several individually plausible documents can describe different versions of the same campus.
Treat the utility form as one milestone
Information about a serving substation helps explain a proposed connection. Buyers should still ask separately what has been committed, what work remains and what conditions govern delivery.
For a capacity purchase, request the documents supporting each commercial milestone. Which assumptions have the utility reviewed? Which facilities require construction? What dependencies sit outside the operator's direct control? How does the proposed load ramp align with tenant deployment?
The answers belong in a delivery review with named owners and dated evidence. A submitted land use document alone should not be used to establish that a particular amount of power will be available on a particular date. The county announcement does not report new energized capacity or promise faster connections.
Bring site impacts into design decisions early
The sound and environmental assessments create another reason to involve facilities engineers before equipment choices become difficult to change.
A useful internal review would compare the operating scenarios behind the acoustic work with the proposed cooling and standby-power design. It should identify which equipment configuration was assessed and whether later substitutions require another review. These are suggested controls for maintaining a coherent design record, rather than a claim about a county-mandated testing procedure.
Apply the same discipline to water assumptions. Keep the design basis, operating scenarios and revision history accessible to the people answering planning questions. Where information is preliminary, label it accordingly instead of presenting an early estimate as a settled operating outcome.
For technical buyers, the most useful consequence could be a more inspectable set of project assumptions. For operators, the immediate task is document coordination: make the utility conversation, engineering design and application describe the same project, then keep them aligned as it changes.
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