This past Session, the General Assembly passed SB 1239 sponsored by Senator McDougle. The bill directs the State Corporation Commission to convene a work group to evaluate cybersecurity as it relates to the provision of electric service by investor-owned electric utilities and electric cooperatives.

On July 7, 2025, the Staff of the Commission (“Staff") convened a virtual work group which featured presentations from the following entities:

• U.S. Department of Homeland Security (“DHS")
• Federal Bureau of Investigation (“FBI" or “Bureau"), Richmond Division
• SERC Reliability Corporation (“SERC")
• Virginia Electric Power and Company d/b/a Dominion Energy Virginia (“Dominion")

The attached report summarizes the activities of the workgroup and includes Staff’s recommendations concerning cybersecurity and large load growth and grid impact:

• Relative to cybersecurity risks posed by interconnected large loads, it is recommended that regulated utilities develop and implement formal plans addressing the actions the utilities may take if a customer experiences an emergency condition that, as determined by the utility or cooperative, could compromise the reliability or security of electric service to other customers. Such plans should be updated where necessary, following an adverse event. Utilities should report the effectiveness of these plans to Staff on at least an annual basis.

• Utilities should revise their interconnection standards for large loads to include more robust technical requirements. These requirements should include dynamic modeling data, clearly defined ride-through capabilities, delay logic for event response, and real-time data monitoring. These enhancements will help ensure that large loads can remain stable and online during system disturbances and that utilities have the data needed to manage grid impacts effectively. Toward the same end, utilities should evaluate the use of high-fidelity metering and updated reclosing standards for high load customers where needed.

• Utilities should work with existing large load customers to adjust their equipment trip settings to allow for some level of ride-through capabilities. Dominion’s recent coordination with large load customers has already shown promise in limiting grid disturbances during abnormal conditions.

• Improved coordination and data sharing between utilities and large load customers is essential. Utilities should establish formal agreements with large load customers that ensure timely access to customers’ operational data, event logs, and telemetry. This will support more accurate load forecasting, faster responses to disturbances, and better alignment between customer operations and grid needs.

• Based on the recent large load events, utilities should evaluate the use of FACTS devices, such as STATCOM and SVCs to supplement or replace the process of switching capacitor banks for voltage control, to more rapidly correct for voltage swings in areas of high load, during emergencies.

• Staff supports the ongoing work of the NERC LLTF, particularly its forthcoming Reliability Guideline. Once published, utilities should align their planning and operational practices with LLTF recommendations, especially in areas such as load modeling, event ride-through expectations, and coordination with IBRs.

• Finally, utilities should provide annual reports to Staff detailing the number and size of large load interconnection requests, any operational incidents involving large loads, and their progress in implementing LLTF-aligned practices. This reporting will help track industry adoption and inform future policy decisions.