VIA HAND DELIVERY. Case No G-PC Hope Gas, Inc. dba Dominion Energy West Virginia

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1 101 South Queen Street Martinsburg, West Virginia Granville Square Suite 400 Morgantown, West Virginia Avery Street Parkersburg, West Virginia James V. Kelsh Telephone - (304) Facsimile - (304) ATTORNEYS AT LAMr 600 Quarrier Street Post Office Box 1386 Charleston, West Virginia (304) www. bowlesrice.com November 7,201 8 Southpointe Town Center 1800 Main Street, Suite 200 Canonsburg. Pennsylvania Chapline Street Wheeling, West Virginia West Jubal Early Drive, Suite 130 Winchester, Virginia Address: j kelsh@bowlesrice.com Ingrid Ferrell Executive Secretary Division Public Service Commission of West Virginia 201 Brooks Street VIA HAND DELIVERY Re: Case No G-PC Hope Gas, Inc. dba Dominion Energy West Virginia Dear Ms. Ferrell: On behalf of the Independent Oil and Gas Association, Inc., please find enclosed the original and twelve (12) copies of the "Independent Oil and Gas Association of West Virginia, Inc. s First Set of Interrogatories, Data Request or Requests for Information to Dominion Gathering and Processing, Inc." JVWdlm Enclosures cc: Linda S. Bouvette, Esquire Brien J. Fricke, Esquire Tom White, Esquire

2 PUBLIC SERVICE COMMISSION WEST VIRGINIA CHARLESTON CASE NO G-PC HOPE GAS, INC. DBA DOMINION ENERGY WEST VIRGINIA Petition for consent and approval of an Agreement with an Affiliate, Dominion Gathering and Processi INDEPENDENT OIL AND GAS ASSOCIATION OF WEST VIRGINIA, INC. S FIRST SET OF INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS TO DOMINION GATHERING AND PROCESSING, INC. Independent Oil and Gas Association of West Virginia, Inc. ( IOGA) hereby requests Dominion Gathering and Processing, Inc. ( DGP ) provide the information detailed in the questions and requests attached hereto by November 28, 201 8, or sooner if practical. If additional time is necessary, please advise so that schedule changes can be arranged. Please begin your response with a reiteration of the number and the question to which the response is addressed. INSTRUCTIONS 1. Where DGP, upon reviewing the items in this Request, determines that it cannot respond to individual items by November 28, 2018, DGP should notify IOGA s attorney immediately so that schedule changes can be agreed upon, where possible. 2. If DGP feels that any of the items set forth in this Request are ambiguous or unclear in any way, it should notify IOGA s attorney as soon as possible so that the item(s) may be properly clarified prior to the preparation of a written response. 3. DGP should view each request item of this Request as being continuing in nature so that as additional, more current, or more accurate information becomes available, that information will be provided to this office without undue delay.

3 4. Each response should be headed with a separate page that presents the following information: ANSWER: The name(s) and title(s) of every person who participated in the preparation of the response, the name(s) and title(s) of the person under whose control or supervision these responses were prepared, and whether or not such person(s) will offer supporting or directly relating testimony; ANSWER: the response; The administrative unit of DGP which maintains the information used in preparing ANSWER: The name of the witnesstes) most likely to testify concerning the material or information contained in the request; ANSWER: ANSWER: The date on which the response was prepared; and DGP response to the requested item. 5. Where the requested information has been prepared using a spreadsheet software program, please provide the requested information on compact disks, with all formulas and cell references intact, using Excel. 6. Where the requested information is not available in the precise format specified or for any of the years indicated, provide all information specified which is currently available on the subject matter along with an explanation of when the remaining information will become available. 7. To the extent that a response to any of the requests can be answered by way of computer printout, please identify each variable contained on the print out that would not be selfevident to a person not thoroughly familiar with the print out. 8. Identify by meter number all meters on the DGP system where insufficient volume or pressure of gas needed to serve farm tap customers was recorded in

4 INTERROGATORIES 1. Please identify each of the five customers by name to which DGP referred in its Information Response No. 2-3 to the Staff of the Commission s Second Set of Interrogatories Data Request or Requests for Information ( Staff s Second Set ). 2. Are any of the customers identified in the foregoing response affiliated with any company within Dominion Energy s family of companies? If so, please identify such companies and the relationship. 3. Please describe the full scope of DGP s business activities in West Virginia and elsewhere in terns of number of customers served, miles of lines which DGP utilizes (by ownership or contract) to provide gathering delivery services, and gross annual revenue. 4. In 2017, what was the volume of production from Dominion Energy Transmission, Inc, in West Virginia which utilized DGP s gathering lines? 5. In 2017, what was the volume of gas carried on DGP s wet gathering system? 6. In 2017, what was the volume of gas carried on DGP s dry gathering system? 7. Please reconcile the statement made in Response to Infomation Response No. 12 to Staffs First Set of Interrogatories, Data Request or Requests for Information ( Staffs First Set ) that [tlhe gathering lines are operated and maintained by Dominion Energy Transmission, Inc. under a service agreement with DGP with the statement in Information Response No. 2-6 to Staff s Second Set that DGP does not have a service agreement with DETI to move gas on the gathering lines. 8. Identify by meter number all meters on the DGP system where insufficient volume or pressure of gas needed to serve farm tap customers was recorded in Identify by meter number all points of interconnection between the DGP system and the DEWV system. 3

5 REOUEST FOR PRODUCTION OF DOCUMENTS 1. Please provide a map showing DGP s wet gathering system in West Virginia and DGP s dry gathering system in West Virginia. 2. Please provide a copy of the Gathering, Aggregation and Processing Agreement and all exhibits thereto referenced in DGP s Infomation Response No. 10 to Staffs First Set of Interrogatories, Data Request or Requests for Information. 3. Please provide a copy of the service agreement with Dominion Energy Transmission, Inc. to which DGP referred in Information Response No. 12 to Staffs First Set. 4. Please provide a map showing farm-tap customers that experienced two or more incidents of interruption of service during due to insufficiency of supply or pressure. INDEPENDENT OIL AND GAS ASSOCIATION OF WEST VIRGINIA, INC. By Counsel orge A. Patterson, 111 ( WVSB #2831) wles Rice LLP 600 Quarrier Street (304) ikelsh@,bowlesrice.com gpatterson@,bowlesrice.com 4

6 PUBLIC SERVICE COMMISSION WEST VIRGINIA CHARLESTON CASE NO G-PC HOPE GAS, INC. DBA DOMINION ENERGY WEST VIRGINIA Petition for consent and approval of an Agreement with an Affiliate, Dominion Gathering and Processing, Inc. CERTIFICATE OF SERVICE I, James V. Kelsh, counsel for Independent Oil and Gas Association, Inc., do hereby certify that a copy of the foregoing Independent Oil and Gas Association of West Virginia, Inc. s First Set of Interrogatories, Data Request or Requests for Information to Dominion Gathering and Processing, Inc. has been served this day of November, 2018, upon the following in the manner indicated: HAND DELIVERY: Linda S. Bouvette, Staff Attorney Legal Division Public Service Commission of West Virginia 201 Brooks Street Post Office Box 8 12 Charleston, West Virginia VIA U.S. MAIL: Brien J. Fricke, Esq. Hope Gas, Inc. dba: Dominion Gathering and Processing, Inc. Senior Counsel 925 White Oaks Boulevard Bridgeport, West Virginia Tom White, Esq. Consumer Advocate Division 700 Union Building 723 Kanawha Boulevard, East es V. Kelsh ( W B #6617) owles Rice LLP 600 Quarrier Street (304) j kelsh@tbourlesrice.com