How it works
Below: two Northern Virginia data center entitlements pulled from the public record, then the same diagnostic run against an ERCOT Batch Zero submission in Texas. Different regulators, same four steps, same cited output.
Fairfax County · PLUS
Public record case file
Case numbers
Loudoun County · LandMARC · Legistar
Public record case file
Case numbers
01
Ingest
Whatever you have. PDFs, narratives, exhibits, staff comment letters, prior filings. Messy is fine.
02
Extract
Every claim pulled into a structured project fact graph with page-level provenance. Unknowns flagged.
03
Cross-reference
The fact graph mapped to Fairfax or Loudoun rules, line by line. Every gap and every mismatch flagged.
04
Ship findings
A cited diagnostic your attorney reviews. Contradictions, missing exhibits, stale assumptions, each citing source pages.
Step 01
Application form, narrative, proffers, exhibits, studies, and any round of county comments. We take whatever the packet already includes and treat every page as evidence.
Fairfax · RZ 2022-SU-00019
8 docs · 196 pp
Loudoun · LEGI-2024-0037
8 docs · 188 pp
Step 02
Parcel, zoning, acreage, MW, generator fleet, cooling, noise, setbacks. Every field traces back to a page in your documents. When a field is missing, we flag it as unknown rather than guess.
Fact graph · LEGI-2024-0037
Extracted project record, with page-level provenance
Step 03
Fairfax adopted a data-center-specific zoning amendment on September 10, 2024. Loudoun eliminated by-right data centers on March 18, 2025 via ZOAM-2024-0001. Prior packets are a starting point, not a template.
Rule check · SE 2022-SU-00038
Fairfax · ZOA September 10, 2024
Building setback from residential
ZOA 09/10/2024 · 200 ft min
Project: 410 ft to nearest R-1 lot
Equipment setback from residential
ZOA 09/10/2024 · 300 ft min
Project: Generators 265 ft from R-1
Distance from Metro station
ZOA 09/10/2024 · 1 mi min
Project: 1.4 mi from Innovation Ctr
Equipment enclosure
ZOA 09/10/2024 · full enclosure
Project: Rooftop chillers open-air
Pre-construction noise study
Data Center handout · §1
Project: Filed, 47 pp
Post-construction noise certification
Data Center handout · §2
Project: Not addressed in packet
Rule check · LEGI-2024-0037
Loudoun · ZOAM-2024-0001
SPEX required (post-3/18/2025)
ZOAM-2024-0001 · IP, GI, MR-HI
Project: 4 SPEX filed + 1 SPMI
Grandfathering eligibility
Accepted before 2/12/2025
Project: Accepted 11/14/2024
500 ft from residential for by-right
Grandfathering resolution
Project: 612 ft to Goose Creek Club
SPEX approval criteria response
ZOAM-2024-0001 · §5.03
Project: 18 pp narrative, 2 criteria unaddressed
Substation & BESS addressed
Phase 1 standards
Project: SPMI-2025-0111 covers BESS
RPA / Goose Creek impact study
Chesapeake Bay PA
Project: 28 pp filed · PEC flagged gaps
Step 04
Contradictions between exhibits. Missing studies. Stale inputs. Unknowns that need expert judgment. Every finding attaches source page numbers so your attorney can verify in one click.
First-round packets in Fairfax and Loudoun routinely come back with 80 to 200 numbered staff comments. This is the report that lets you resolve them before the county does.
Diagnostic excerpt · 5 of 37 findings
Each finding cites source pages in the packet
Generator count disagrees across exhibits
ContradictionStatement of Justification describes 28 gensets (p. 14). Exhibit G equipment schedule shows 32. Proffer §4.b caps at 30.
Post-construction noise certification plan
MissingRequired before Non-RUP issuance under the Data Center noise handout. Packet addresses pre-construction only.
Traffic counts predate Rt 7 widening
StaleTIA uses VDOT 2022 AADT. VDOT published revised 2025 counts in Nov 2025, post Rt 7 widening near Belmont Ridge.
Substation land ownership path
UnknownNarrative implies Dominion conveyance post-approval but does not reference the deed, fee-vs-easement path, or transfer timing.
SPEX approval-criteria response drafted pre-amendment
StaleNarrative cites ZOAM-2023 language for 2 of 9 SPEX criteria. Language replaced in ZOAM-2024-0001 effective March 18, 2025.
Same diagnostic · ERCOT
In Texas, the “packet” is an ERCOT Batch Zero Large Load Interconnection submission with a Provisional CLR election. Different regulator, different artifacts, same four steps, same cited findings. The example below is illustrative. The rules it cites are real and filed.
ERCOT · AEP Texas Central · PUCT Interchange · ERCOT MIS
Public record case file
Case numbers
Batch Zero LLIS · representative packet
8 docs · 302 pp
Fact graph · Batch Zero candidate
Extracted electrical and regulatory record
PGRR145 · NPRR1325 · SB 6 · 58481
Batch Zero / PCLR rule check
Batch Zero submission completeness
PGRR145 §9.7.2 · Jul 15, 2026
Project: LLIS + SIS filed · 3 attestations outstanding
PCLR declaration
NPRR1325 · Jul 24, 2026
Project: Draft rev 2, election not finalized
Shift-factor analysis for ABC bid cap
PCLR ABC formula · Workshop #7
Project: Not computed in packet
SB 6 curtailment-duty registration
TX SB 6 · ≥75 MW after 12/31/2025
Project: Load > 75 MW · compliance path unnamed
QSE + Resource Entity designation
PCLR process, step 5
Project: QSE unnamed in LLIS §7
Financial security posting
PGRR145 §9.7.2 · per MW
Project: $50K/MW cited; matches PUC 58481 Item 122 operative text (Foley's stale $100K was PFP preamble residue)
PUC 58481 (16 TAC §25.194) disclosure
Project 58481 · finalization fall 2026
Project: Not addressed in packet
Diagnostic excerpt · 5 of 22 findings
Each Texas finding cites the rule, the filing, and the source page
Shift factor not computed for top binding constraints
MissingWithout a shift-factor by shadow-price analysis on the top binding constraints affecting this POI, the ABC bid cap under SCED dispatch cannot be estimated. This is the single most important input to the PCLR economics decision.
Foley client alert circulating stale $100K/MW figure
StaleEarlier drafts of this packet flagged a $50K vs. $100K/MW conflict between LLIS §9 and Foley & Lardner's April 2026 client alert. Resolved 2026-04-24 via PUC 58481 Item 122: operative rule text is $50K/MW for intermediate-stage financial security and $50K/MW for the IA interconnection fee. Foley's $100K is stale PFP preamble residue carried over from prior staff draft. The packet's $50K citation is correct; the open risk is that other parties on the deal (counsel, lenders, advisors) are still working from Foley's stale alert and need to be re-baselined before financial close.
QSE designation blank in LLIS §7
MissingPCLR process step 5 requires registration as a Resource Entity with a designated QSE before Approval to Energize. §7 is blank and no QSE is named elsewhere in the packet.
Packet drafted before PUC 58481 Proposal for Publication
Stale16 TAC §25.194 (Large Load Interconnection Standards) was published March 12, 2026 and is expected to finalize in fall 2026. The packet does not address the new disclosure obligations.
On-site flexibility covers Tier 1 for only about 40% of events
UnknownFlexibility plan cites 40 MW BESS and 80 MW BTM gas. Under modeled SCED dispatch frequency, Tier 1 paired-asset coverage is ~40% of events, leaving ~60% in Tier 2 binding curtailment. Compute impact not quantified.
Rules cited are from ERCOT PGRR145 / NPRR1325, PUCT Project 58481 (16 TAC §25.194), and Texas SB 6. The developer, parcel, and per-field values are a composite illustration, not a specific applicant. Primary sources: ERCOT Large Load Interconnection Batch Study Workshop #7 (April 9, 2026); Foley & Lardner client alert (April 2026).
Case study
In August 2025, a Virginia Circuit Court voided Prince William’s Digital Gateway rezoning. 2,133 acres, up to 23M sq ft. The §15.2-2204 public-hearing notice did not meet the statutory minimum, and key rezoning materials were not available at first notice.
A completeness review runs every packet against the published procedural requirements, not just the substantive ones. The findings below are the ones a pre-hearing diagnostic would have surfaced.
Read the full case file on case studies.
Prince William County · Public record · Circuit Court opinion
Public record case file
Case numbers
Retrospective diagnostic · 5 procedural findings
What a §15.2-2204 completeness check would have shown
Public-hearing notice ran only three days before the hearing
Missing§15.2-2204 requires two publications, the first at least fourteen days before the hearing. The notice in the record was published on a schedule that did not meet the statutory minimum and was flagged in the court opinion as the lead defect.
Rezoning exhibits not available at first notice
MissingThe proffers, concept plan, and supporting exhibits were not made available to the public on the date of the first advertised notice. The court treated the absence as a separate procedural defect, independent of the timing issue.
Pre-hearing transmittal outdated relative to filed plan revision
StaleThe staff report referenced earlier proffer text than the revision actually in the applicant packet at the time of the hearing. Inconsistencies between the notice-bundled materials and the filed record compounded the procedural case.
Notice publication chain of custody
UnknownThe record did not clearly document which notice version was delivered to which publication, when, and by whom. A completeness review flags any §15.2-2204 workflow where the publication receipts and the county docket do not reconcile on dates.
Fallback schedule if first notice slipped
MissingNo contingency schedule in the record for re-advertising if the first notice missed the statutory minimum. The defect was therefore unrecoverable at hearing time. Completeness practice includes a re-notice schedule in every packet before the first publication.
Other live markets
Submissions, queues, and water filings across the four other markets developers are actually trying to build in right now. Each one has a specific regulatory handle that determines whether a packet goes anywhere, and each one is already producing the contradictions, gaps, and stale assumptions the diagnostic above is built to catch.
Working on one of these that isn’t on the list? Tell us at /contact.
Atlanta metro · Coweta, Fulton, Douglas
Georgia
3 to 2
Split vote on a staff-inconsistency SUP.
Recent SUP vote split
Regulatory handle
County SUPs + comp-plan consistency
Staff reports now routinely name comp-plan inconsistency on data center SUPs. Coweta Project Sail passed 3-2 with that finding on the record, and every one of 17 dais conditions is now litigation ammunition.
What Cliff reads first
Staff inconsistency findings + condition creep at the dais
Columbus metro · Licking, Franklin, Madison
Ohio
§5709.638
State tax carrot. Local zoning stick.
State vs. local posture
Regulatory handle
Local moratoria + ORC §5709.638 agreements
New Albany and Dublin have debated moratoria on new data centers while the state keeps the sales-tax exemption in ORC §5709.638 alive. On-site generation above 50 MW triggers Ohio Power Siting Board review separately.
What Cliff reads first
Moratorium timing vs. vesting at submission
Maricopa · Mesa, Goodyear, Queen Creek, Chandler
Arizona
100-year
Assured Water Supply test.
Assured-supply headroom
Regulatory handle
ADWR Assured Water Supply + APS queue
ADWR's 100-year Assured Water Supply designation applies to new industrial campuses, and water-intensive cooling is a disclosed risk. APS transmission constraints and interconnection timelines are the second gate.
What Cliff reads first
Water designation + APS Large Load Service terms
Reno-Sparks · Washoe, Storey, Las Vegas Valley
Nevada
LCS
Tariff-native interconnection.
LCS tier-block taper
Regulatory handle
NV Energy LCS tariff + water rights
NV Energy's Large Customer Service tariff governs load interconnection and power-supply election. Water rights under NRS 533 matter north of Reno, where the TRI campus is buildable but thin on surface water.
What Cliff reads first
LCS-eligible MW block + water-right basis
What this is not
Cliff does not file applications, provide legal advice, or substitute for your land-use attorney, environmental consultant, or acoustical engineer. We prepare the evidence layer: the cited, structured, contradiction-free project record. Draft narratives and comment responses are clearly marked as drafts.
Source citations are attached to every claim. Your team signs off before anything goes to Fairfax PLUS or Loudoun LandMARC.
Case details above are from public county records. Our review framing is illustrative; real diagnostics require access to the applicant’s full packet. Start one. Or browse more public-record cases, including ERCOT Batch Zero and Prince William Digital Gateway, on case studies.
Submission diagnostic
We review your data center entitlement package against Fairfax or Loudoun County requirements and send back a cited completeness report within one week.