dB SPL is referenced to 20 µPa, not 1 Pa. You might be confused by the fact that the 94 dB SPL (1 Pa) is the default for microphone calibrators and specifying microphone sensitivity.

I was referring to the latter, which is why volts are involved at all. But I suppose if they'd chosen to follow the SPL zero point for the voltage-pressure scale as well as the absolute pressure scale that's would be equally arbitrary in its own way, even if more consistent in another.