On April 8, the Planning Commission approved an 11-acre industrial substation behind our farms with no public hearing and no notice to neighbors. Our community organized, spoke out, and fought back. The Board of Supervisors is sending it back for a proper public hearing.
Take Action NowA true “by-right” use requires no discretionary approval — no vote, no judgment call. This substation required a vote by the Planning Commission under Warren County Zoning Ordinance §180-65(B)(1) and Virginia Code §15.2-2232, both of which require an affirmative finding that the facility is “substantially in accord” with the Comprehensive Plan. The Commission voted with one Commissioner absent and one abstaining due to the lack of a public hearing. If this were by-right, no application, no vote, and no Statement of Justification would have been required.
Virginia Code §15.2-2232 requires that a utility facility’s location be “substantially in accord” with the entire adopted Comprehensive Plan — not just one goal about infrastructure. The applicant cited only Goal VI while ignoring at least twelve competing provisions addressing agricultural preservation, rural character, environmental protection, and impact on neighboring properties.
Despite what some Planning Commissioners said on the record — “you’re gonna get a whole lot of fire back from people that can’t really stop us one way or the other” — the law says otherwise. The Planning Commission must evaluate the substation against the totality of the Comprehensive Plan, including: the Growth Management Goal on page 87; Objective M on page 72; the Rural Character Goal on page 86; the Karst Terrain protections on pages 42–43; and the Rockland Community Vision on page 84. None of these were analyzed on April 8th. The Board of Supervisors can overrule the Commission by majority vote under §15.2-2232(B).
A proposal to recharacterize this same 141-acre parcel from agricultural to commercial/industrial use generated enormous public opposition. Not one person spoke in favor. The proposal failed.
The Alliance filed a FOIA request after learning of potentially improper communications between the property seller, REC, and County officials. The County has not substantively responded.
REC filed its application. It appeared on the Planning Commission calendar as a “Comprehensive Plan Review” — not “Approval of Electric Substation.”
The Commission approved the 11-acre substation with one Commissioner absent and one abstaining due to the lack of a public hearing. No public hearing was held. No adjacent landowners were notified. No public input was received.
The North Warren Citizens Alliance filed a formal objection and appeal with the Board of Supervisors, citing six procedural and substantive deficiencies in the Commission’s action.
A member of the Alliance attended the Board of Supervisors special meeting and spoke directly with four of five Supervisors about the substation and our formal objection.
Seven members of the Alliance attended the Board of Supervisors regular meeting. Four spoke publicly during the public comment period demanding a public hearing.
The Alliance was notified by a member of the Board of Supervisors that the Board will remand this matter back to the Planning Commission for a proper public hearing in May or June. Bravo to all Alliance members who attended meetings, spoke out, called, or emailed their Supervisors.
The Alliance sent REC’s counsel a formal letter requesting written responses to 70 questions covering facility specifications, noise, EMF, water, child safety, alternatives, and more — to be answered before the public hearing.
The Planning Commission approved the substation with one Commissioner absent and one abstaining. The abstaining Commissioner stated on the record that he could not support the determination due to the lack of a public hearing. Comments indicated the applicant was rushing due to an expiring purchase contract.
When asked about the details of the proposed substation, the REC representative admitted: “We haven’t designed it yet.”
▶ Watch the Full April 8 MeetingWe thank the Commissioners who raised serious concerns. One appropriately abstained because no public hearing was held.
Note: A substation produces no new power. It merely steps down voltage for distribution.
The Planning Commission approved a facility whose own applicant admitted has not been designed.
Filed Friday, April 10, 2026
The North Warren Citizens Alliance filed a formal objection and appeal with the Warren County Board of Supervisors challenging the Planning Commission's approval.
April 10, 2026
Warren County Board of Supervisors
220 N. Commerce Avenue
Front Royal, VA 22630
RE: S-03-2026 – Formal Objection and Request for Remand and Public Hearing
Dear Chairwoman Cullers and Members of the Board:
We are writing to formally object to and appeal the Planning Commission’s April 8, 2026 approval of a proposed REC electric substation at 386 Ashby Station Road. The decision to provide no notice to neighbors and no public hearing is deeply troubling and potentially creates legal liability for the County.
We respectfully request that the Board remand this matter to the Planning Commission with instructions to conduct a full public hearing. By Virginia law, if you require a public hearing and revote, the Planning Commission is obligated to conduct one.
1. Prior Attempts to Industrialize This Parcel Faced Strong Public Opposition.
Fifteen months ago, this same parcel generated enormous public opposition to recharacterization. Not one person spoke in favor. The Commission correctly removed it. The choice to now forgo a public hearing on a substation on the same parcel cannot be viewed as anything other than a deliberate effort to avoid anticipated opposition.
2. The Agenda Item Was Designed to Avoid Public Attention.
The item was listed as a “Comprehensive Plan Review” – not “Approval of Electric Substation.”
3. The FOIA Request Has Gone Unanswered.
Our January 27, 2026 FOIA request about communications between the seller, REC, and County officials has not been substantively responded to.
4. The “Substantially in Accord” Standard Was Not Met.
The applicant cited only Goal VI while ignoring at least a dozen competing provisions, including the Growth Management Goal (p. 87), Objective M (p. 72), the Rural Character Goal (p. 86), the Environmental Quality Goal (p. 63), Karst Terrain protections (pp. 42–43), and the Rockland Community Vision (p. 84).
5. The Public Was Denied Critical Information.
No member of the public had the opportunity to review site plans, evaluate health effects, or assess environmental and property value impacts.
6. The Applicant’s Urgency Does Not Excuse Deficient Process.
A determination rushed for a private party’s deal timeline exposes the County to legal challenge.
Legal Posture & Request
Virginia courts have held that discretionary authority must be exercised reasonably and not arbitrarily. We respectfully request the Board remand this matter for a full public hearing under §15.2-2204.
Respectfully submitted,
North Warren Citizens Alliance
Sent to REC's counsel, April 23, 2026
To ensure the upcoming public hearing is substantive and productive, the North Warren Citizens Alliance sent REC’s counsel a formal letter requesting written responses to 70 questions — covering facility specifications, noise, electromagnetic fields, lighting, water and environmental impact, traffic, property values, alternatives, community safety, child safety, and the project’s need and timing. We requested responses no later than 14 days before the hearing date.
I. FACILITY SPECIFICATIONS
1. What is the incoming (high-side) voltage of the proposed substation, in kilovolts?
2. What is the outgoing (low-side/distribution) voltage?
3. Does the incoming voltage exceed the Medium Voltage Class as defined by ANSI C84.1? If so, on what basis does the applicant contend this facility qualifies as a “public utility distribution facility” under Warren County Zoning Ordinance §180-8(C)?
4. What is the power capacity of the substation in megavolt-amperes (MVA) at initial build, and what is the ultimate planned capacity at full build-out?
5. How many power transformers will be installed at initial build? At full build-out?
6. What is the physical footprint of the equipment area (the fenced, graveled pad), in acres and square feet?
7. Why does this substation require an 11-acre pad when standard distribution substations typically require 1-3 acres? What specifically explains the additional acreage?
8. What are the maximum heights of all structures, including bus structures, lightning arrestors, incoming/outgoing line towers, and any other vertical elements? Please provide heights in feet above grade.
9. Please provide detailed engineering drawings, site plans, and elevation renderings showing the facility from all cardinal directions, including views from adjacent properties.
10. The applicant’s representative stated at the April 8 hearing that the substation has not been designed. Has a design been completed since that date? If not, how can the Planning Commission evaluate the “character and extent” of a facility that has not been designed, as required by Virginia Code §15.2-2232?
II. NOISE
11. What is the expected continuous noise level generated by the substation at the property boundary, measured in decibels (dBA), under normal operating conditions?
12. What is the expected noise level at the nearest residence under normal operating conditions? Under peak load conditions?
13. What is the expected noise level during transformer energization events, fault conditions, or emergency switching operations?
14. What is the frequency profile of the noise — is it a constant low-frequency hum, and at what Hz does it primarily occur?
15. Will the noise be continuous (24 hours/day, 365 days/year)?
16. What noise mitigation measures, if any, does the applicant propose — such as sound walls, low-noise transformer specifications, or equipment enclosures?
17. Has the applicant conducted or commissioned a noise impact study for this site? If so, please provide it. If not, why not?
III. ELECTROMAGNETIC FIELDS (EMF)
18. What are the projected magnetic field levels (in microtesla or milligauss) at the substation fence line, at 100 feet, at 200 feet, at 500 feet, and at 1,000 feet from the equipment area?
19. What are the projected magnetic field levels at the nearest residence?
20. The World Health Organization’s International Agency for Research on Cancer has classified extremely low frequency electromagnetic fields as “possibly carcinogenic to humans” (Group 2B). What measures, if any, does the applicant propose to minimize EMF exposure to nearby residents, livestock, and agricultural operations?
21. Will the applicant commit to ongoing EMF monitoring at the property boundary and at the nearest residences, with results made publicly available?
22. What are the known and studied effects of continuous electromagnetic field exposure on cattle, including impacts on meat quality, milk production, stress behavior, reproductive performance, and calving rates?
23. At what distance from the substation equipment does the applicant consider EMF exposure safe for continuously grazing livestock? What is the basis for that determination?
IV. LIGHTING AND VISUAL IMPACT
24. What lighting will be installed at the substation? Will it be continuously illuminated or activated only during maintenance?
25. Will the lighting be dark-sky compliant in accordance with the Comprehensive Plan’s provisions for rural character preservation?
26. What is the total height and visual profile of the facility as seen from Winchester Road (Route 340/522), from adjacent agricultural properties, and from nearby residences?
27. What vegetative screening, berms, or visual barriers does the applicant propose? What are the specific species, heights at planting, and mature heights?
28. How long will it take for any proposed vegetative screening to reach effective screening height?
29. Please provide photo-simulations or visual renderings showing the substation as it will appear from at least four surrounding vantage points, including the nearest residences and adjacent farm properties.
V. WATER, ENVIRONMENT, AND KARST TERRAIN
30. How many gallons of transformer oil (mineral oil or other dielectric fluid) will be present on-site at initial build? At full build-out?
31. What is the spill containment plan for transformer oil? Does it meet EPA SPCC requirements?
32. Has the applicant conducted a Phase I or Phase II environmental site assessment for the proposed location?
33. The Warren County Comprehensive Plan identifies karst terrain in the Route 340/522 corridor (Chapter 3, pp. 42-43), and the Cedarville Enterprise Zone Karst Study identified an endangered species (Madison Cave Isopod) in the nearby area. Has the applicant conducted any geologic or hydrogeologic assessment of the site?
34. What stormwater management measures are proposed? What is the total area of new impervious surface?
35. Are there any wells within 1,000 feet of the proposed equipment area? If so, what is the potential impact on groundwater quality?
36. Has the applicant consulted with the Virginia Department of Environmental Quality regarding stormwater permitting?
37. What specific contaminants could enter the groundwater from substation operations, including transformer oil, dielectric fluids, herbicides, and heavy metals from equipment weathering?
38. Several adjacent farm properties rely on private wells for drinking water and livestock watering. What is the depth and direction of groundwater flow at this site?
39. What ongoing groundwater monitoring does the applicant propose, and will the applicant commit to testing adjacent private wells before construction and at regular intervals thereafter?
40. In the event of a transformer oil spill or leak, what is the estimated time for contaminants to reach the nearest private well given the karst terrain?
41. What herbicides or chemical treatments does the applicant plan to use for vegetation management on and around the substation pad?
VI. TRAFFIC AND ACCESS
42. How many vehicle trips per day/week/month will the substation generate during construction? During normal operations?
43. What is the planned access route for construction vehicles, including heavy equipment and transformer delivery?
44. What is the weight of the largest transformer to be delivered, and can existing road infrastructure support that weight?
45. VDOT’s review comments require verification that a VDOT Standard PE-1 entrance can be constructed within the proposed access easement. Have these been provided?
VII. PROPERTY VALUES AND ECONOMIC IMPACT
46. Has the applicant conducted or commissioned any study of the impact of the proposed substation on the market value of adjacent properties?
47. Published research shows property value diminution of 10-45% from proximity to high-voltage electrical infrastructure. What compensation or mitigation does the applicant propose for adjacent landowners?
48. The Comprehensive Plan expressly encourages agritourism (Chapter 4, pp. 85-86). What is the applicant’s assessment of the substation’s impact on the viability of those operations?
VIII. ALTERNATIVES ANALYSIS
49. What alternative sites were evaluated for this substation? How many sites were considered, and why was each rejected?
50. Were any sites in existing industrial or commercial zones considered?
51. Was co-location within or adjacent to existing industrial infrastructure (e.g., Kelley Industrial Park) evaluated?
52. Was a reduced-footprint design evaluated that would require less than 11 acres?
53. Was an enclosed (indoor) substation design evaluated, which would significantly reduce visual, noise, and EMF impacts?
IX. COMMUNITY IMPACT AND SAFETY
54. What is the fire risk profile of the substation? What fire suppression systems will be installed?
55. What is the blast or arc flash risk zone, and does it extend beyond the substation fence line?
56. What security measures will be in place to prevent unauthorized access, including by children?
57. What is the expected operational lifespan of the substation? What decommissioning and site restoration obligations will the applicant accept?
58. Will the applicant enter into a binding agreement with Warren County specifying conditions of approval?
X. NEED AND TIMING
59. What specific load growth projections justify the need for a new substation in this location?
60. What is the current capacity utilization of existing substations serving the Warren County area?
61. When does the applicant project that existing capacity will be insufficient without this substation?
62. Is this substation intended to serve anticipated data center development, industrial expansion, or other specific large-load customers?
63. Dominion Energy is actively working with REC to plan new 230kV electric transmission infrastructure in other parts of REC’s territory. Is the proposed Ashby Station Road substation part of a broader regional transmission build-out?
64. What is the applicant’s projected construction timeline, from ground-breaking to energization?
XI. CHILD SAFETY
65. There are residences with children in proximity to the proposed substation site. What is the minimum safe distance for children from the substation fence line?
66. What measures will prevent children from accessing the substation site?
67. What is the arc flash boundary — the distance at which a person could sustain burns from an electrical arc fault — and does that boundary extend beyond the substation fence?
68. What is the risk and radius of impact from a catastrophic transformer failure, including explosion and oil fire? Are any residences or areas where children are present within that radius?
69. Published research associates continuous residential EMF exposure above 0.3-0.4 microtesla with elevated childhood leukemia risk. At what distance from the substation equipment does projected EMF exposure fall below this threshold?
70. What emergency response protocols will be in place in the event of a fire, explosion, or hazardous materials release at the substation?
Seven members of the North Warren Citizens Alliance attended the April 22 Board of Supervisors regular meeting. Four members spoke publicly during the public comment period about the substation approval, the procedural failures, and the community’s demand for a public hearing.
▶ Watch the April 22 Board of Supervisors MeetingThe North Warren Citizens Alliance was notified by a member of the Board of Supervisors that the Board will remand this matter back to the Planning Commission for a proper public hearing in June.
Bravo to all Alliance members who attended Board of Supervisors meetings and spoke out, and to everyone who called or emailed their Supervisors. This community organized in 15 days, filed a formal legal objection, showed up at two Board meetings, and secured the public hearing the Planning Commission refused to hold. This is what civic engagement looks like.
The fight is not over. The public hearing in May or June is where the community will have the opportunity to examine the site plans, ask questions about health and environmental impacts, and present evidence on the substation’s consistency with the Comprehensive Plan. Stay engaged.
A public hearing is coming in June. In the meantime, keep the pressure on. Let the Board of Supervisors know this community is watching and will show up.
Cheryl Cullers, Chair (South River): 540-551-2045
Tony Carter, Vice Chair (Happy Creek): 540-551-2831
Dr. Richard Jamieson (North River): 540-327-2780
John Stanmeyer (Shenandoah): 540-692-6757
Hugh Henry (Fork): 540-622-3331
Forward this page to your neighbors, your community group, and anyone who cares about protecting Warren County’s agricultural land and rural character. The more voices at the June hearing, the stronger our case.
Stay informed on the substation fight, the May or June public hearing, and how you can help protect our community. We stand alongside the Alliance for the Shenandoah Valley and the Rockland Rural Historic District.