Dominion Energy is proposing a 3-gigawatt combined-cycle natural gas plant in rural Cumberland County, Virginia — a facility that would rank among the largest gas plants operating in the United States and directly stress-test the fossil fuel phaseout mandated by the 2020 Virginia Clean Economy Act.

The statute bars new fossil fuel generation and requires all existing fossil plants to shut down within roughly two decades. But it contains an escape clause: utility regulators on the State Corporation Commission can waive those rules if they determine grid reliability is at stake. Dominion used that loophole last year to win approval for a roughly 1-GW gas facility in Chesterfield County, outside Richmond. The Cumberland project would be three times that size.

What's on the table

Dominion announced the Cumberland plant in May. The combined-cycle design would run around the clock, reusing its own waste heat to maximize efficiency, on a site along the James River in a county of 10,000 residents. At 3 GW, the plant would exceed every operating gas plant in the country except a 4.3-GW complex in Florida.

The proposal remains in early permitting. The Cumberland Planning Commission granted its first approval last week; the county Board of Supervisors still must sign off. Dominion also needs two state approvals: an air pollution permit from environmental regulators and a determination from the SCC affirming the plant's need. Dominion says both state processes could stretch into 2028, and the earliest in-service date is 2033.

The demand argument

Dominion's case rests on load growth from data centers. The utility projects data centers will account for half its electricity sales by 2035, and its latest integrated resource plan — accepted by regulators last year — calls for nearly 6 GW of new gas infrastructure by 2036. That plan, with a horizon of 2039, also includes Coastal Virginia Offshore Wind, the largest offshore project in the country, plus other renewables.

Clean energy advocates argue the blueprint falls short of the law's requirements — notably because it does not model the 2045 deadline for Dominion's transition to 100% clean power. Appalachian Voices and the Southern Environmental Law Center hired an independent consultant to rerun the numbers with that deadline included. Even accepting Dominion's own demand projections, the February 2025 analysis found the most economical future generation mix includes more nuclear, more solar and wind, and substantially more battery storage — but no new gas.

"Storage is especially important to keep costs low while meeting the zero-carbon requirement," the consultancy concluded. "Additionally, with more storage resources, the model shows that CO2 emissions can be reduced sooner by replacing the least efficient gas resources."

That study informed Virginia's new battery storage law, which expands Dominion's short-duration storage targets more than fivefold, to 16 GW by 2045. In April, regulators approved more than 1 GW of storage paired with solar in Dominion's territory — "one of the largest approvals of solar and battery storage since the passage of the Virginia Clean Economy Act," company spokesperson Jeremy Slayton said in an email.

The RFP dispute

Critics say Dominion decided it needed the gas plant before seriously evaluating nonfossil alternatives. The company announced Cumberland before issuing a request for proposals for generation in the county; the RFP went out in early July, with proposals due mid-December.

"The biggest concern this RFP raises for me is how Dominion limits eligible resources to its own definition of 'dispatchable,'" said Emma Clancy, an attorney at the Southern Environmental Law Center. As with the Chesterfield RFP, the definition covers only gas and nuclear — excluding grid batteries, which can charge on surplus wind and solar and discharge when needed.

"An economic assessment that looks at only gas and nuclear is almost certain to select gas," Clancy said. "But that outcome shouldn't be construed as evidence that this is actually the best choice for ratepayers — not to mention the Cumberland community."

Local opposition is also building. "We are not only deeply concerned about our own people, land, and water, but also about the health of our neighbors in surrounding counties," Katie Hoffman of Protect Cumberland said in a news release.

Stranded-cost exposure

If the plant enters service in 2033, it would run barely a decade before the 2045 deadline. At that point Dominion would either retrofit it for green hydrogen — an expensive fuel in extremely short supply — or shut it down, leaving ratepayers exposed on a multibillion-dollar asset.

"This is not a piece of infrastructure that's only meant to last 12 years," said Shawn Kelly, Virginia regulatory director for Advanced Energy United. "These things are built to last 30, 40, 50 years."

A third path: the reliability waiver. Asked whether Dominion might convert the plant to hydrogen or close it by 2045, Slayton acknowledged neither. "If it is determined in the future these stations will continue to be needed to maintain reliability beyond 2045, we would petition the Virginia State Corporation Commission at that time."

That answer alarms critics. "By not addressing this critical issue upfront, effectively, the utility is being permitted to plan and build for non-compliance in 2045," said Nate Benforado, senior attorney at the Southern Environmental Law Center. By then, he argued, the reliability exception could be a foregone conclusion.

The decisive milestones are procedural: the Cumberland Board of Supervisors vote, the air permit, and the SCC's need determination — state processes Dominion itself says could run into 2028. How the SCC handles the Clean Economy Act's reliability waiver on a 3-GW asset will determine whether Virginia's 2045 phaseout retains enforceable teeth.