What EO 22 Changes Now
- EO 22 shifts Virginia away from unqualified promotion of data centers and toward greater transparency, coordination, and accountability. Its principal immediate actions are to:
- end most state-agency nondisclosure agreements that conceal project incentives, resource demands, and community impacts;
- withdraw certain discretionary state assistance, expedited permitting, and site-readiness support from new projects of 25 megawatts or more;
- centralize state data center policy under the Office of the Chief Energy Officer; and
- direct agencies to study noise, backup generation, water use, emissions, grid reliability, cost allocation, workforce benefits, and community protections.
What EO 22 Does Not Change
EO 22 is not a moratorium and contains no statewide limit on data center capacity, square footage, or power demand. It does not revoke entitlements, cancel approved site plans, rescind vested rights, prevent local approvals, or direct Dominion Energy or PJM to deny service to entitled projects. Losing state assistance may add cost or delay, but it is unlikely to deter a hyperscale developer from a Northern Virginia site that already has zoning approval, fiber access, and a path to power.Why the Approved Pipeline Matters
Loudoun County reports 233 data center buildings built or under construction, another 35.7 million square feet approved but not yet built—potentially about 115 additional buildings—and 20.7 million square feet still under review. Not every approved project will be constructed, but the pipeline is large enough to sustain years of construction, substations, transmission lines, generators, and additional water and power demand even if new approvals slowed sharply.
Prince William County has also accumulated substantial approved and pending capacity. Its September 2026 zoning amendment limits future expansion of the Data Center Opportunity Zone, but it preserves several pathways for properties and projects already in the development process. The amendment narrows future growth without eliminating the existing pipeline, and landowners have a deadline of December 21, 2026, to finalize their by-right status before it is eliminated. Other than the thousands of acres still in the overlay district, Prince William County has : 57 completed data centers, 30 projects under construction, 53 approved awaiting groundbreaking, and 15 active land-use applications currently under staff and agency review.
A Policy Pivot, Not Yet a Growth-Control Policy
Virginia has actively recruited data centers since 2009 through tax incentives, economic-development assistance, and permissive local land-use policies. EO 22 breaks with the assumption that growth should be encouraged without first accounting for cumulative costs. That is a political and administrative shift.Yet most of the order’s stronger provisions remain studies, planning tools, voluntary standards, agency recommendations, or proposals for future legislation. Transparency and coordination can improve decision-making, but they do not themselves constrain development. The order may affect projects not yet entitled; it is unlikely to produce a visible near-term decline in construction in Loudoun or Prince William.
What Would Bend the Curve
EO 22 will become a true growth-control policy only if it leads to enforceable measures: mandatory discretionary review of large facilities; cumulative regional impact analysis; binding limits tied to available power, water, air-quality, and watershed capacity; full assignment of infrastructure costs to the projects that cause them; authority to defer new utility connections where capacity is inadequate; tighter local zoning; limits on extensions or expansions under old entitlements; and reconsideration of tax incentives that continue to encourage growth.Conclusion: EO 22 changes Virginia’s conversation by recognizing that data center growth carries statewide costs and requires statewide oversight. But the approved and entitled pipeline will continue to drive construction for years. Unless the order is followed by binding legislation, regulation, utility decisions, and stronger local land-use controls, Virginia will have changed its posture without changing its path.






