Public Service Commission of West Virginia 201 Brooks Street, P.O. Box 812 Charleston, West Virginia 25323 Phone: (304) 340-0300 Fax: (304) 340-0325 November 5,20 18 Ingrid Ferrell Executive Secretary Public Service Commission PO Box 812 Charleston, WV 25323 RE: CASE NO. 18-0850-G-PC HOPE GAS, INC. DBA DOMINION ENERGY WEST VIRGINIA Petition for consent and approval of a Service Agreement with Dominion Gathering & Processing, Inc., an affiliate Dear Ms. Ferrell: General Order No. 236.1 In the Matter of the Effects on Utilities of the 2017 Tax Cuts and Jobs Act Enclosed are an original and twelve (12) copies of the Staff Response to Proposed Stipulation in the above-referenced proceeding. A copy has been served upon all parties of record in this proceeding. Sincerely, LSB/bg Enclosures H:\Lbouvette\CasesVO 18\18-0850-G-PIStaff Response to Proposed Stipulation Linda S. Bouvette WV State Bar I.D. No. 5926
PUBLIC SERVICE COMMISSION OF WEST VIRGINIA CHARLESTON CASE NO. 18-0850-G-PC HOPE GAS, INC. DBA DOMINION ENERGY WEST VIRGINIA Petition for consent and approval of a Service Agreement with Dominion Gathering & Processing, Inc., an affiliate General Order No. 236.1 In the Matter of the Effects on Utilities of the 2017 Tax Cuts and Jobs Act STAFF RESPONSE TO PROPOSED STIPULATION Comes the Staff of the Public Service Commission of West Virginia (PSCWV), by counsel, and for its Response to the proposed Stipulation submitted by Hope Gas, Inc. dba Dominion Energy West Virginia, (Dominion Energy), states as follows. First, Staff questions Dominion Energy s motive in filing its proposed Stipulation with the Cornmission after Staff clearly advised Dominion Energy that the Stipulation was unacceptable. As stated in the Final Joint Staff Memorandum, while DGP agreed to waive the collection of its fees for the wet gas during the term of the agreement (an approximate $1.4 million savings), Staff was unable to determine whether the costs set forth in the Agreement are reasonable and in the public interest. The 2016 Agreement resulted in a $160,000 cost which was recovered in the PGA. The total cost under the 2018 Agreement for the first year is estimated at $3.4 million, a dramatic increase.
DGP is not expected to provide any service that was not already being provided under the 2016 Agreement. Since neither Dominion Energy nor DGP could adequately explain the increase in cost for that same service, Staff filed additional discovery responses. Staff may be in a better position to evaluate the Agreement once it reviews the responses to data requests provided by DGP and Dominion Energy. However, Staff remains concerned that DGP is receiving a number of benefits under the agreement at the expense of Dominion Energy s ratepayers: Assignment of the wet gas component of Dominion Energy s gas stream with no consideration; 0 Payment for unrecoverable wet gas consumed by ratepayers; and 0 Payment for foregone gas throughput which occurs when DGP must increase pressure to ensure service to certain field tap customers (a necessary part of the agreement for which DGP is getting paid.) As for an agreement in the GO 236.1 proceeding, Staff contends that Dominion Energy has yet to provide the information and data required by the Commission to reach a proper resolution of the case. WHEREFORE, Staff respectfully requests that the Proposed Stipulation be accepted by the Commission for what it is - an attempt by Dominion Energy to improperly influence the Commission and make Staff look uncooperative. Staff will continue to seek information from Dominion Energy so that it may make an informed, reasonable recommendation to the Commission in both cases. 2
Respectfully submitted this 5th day of November, 20 18. STAFF OF THE PUBLIC SERVICE COMMISSION OF WEST VIRGINIA By Counsel, LINDA S. BOUVETTE WV State Bar I.D. No. 5926 J@-DJ AUVILLE WV State Bar I.D. No. 8057 3
PUBLIC SERVICE COMMISSION OF WEST VIRGINIA CHARLESTON CASE NO. 18-0850-G-PC HOPE GAS, INC. DBA DOMINION ENERGY WEST VIRGINIA Petition for consent and approval of a Service Agreement with Dominion Gathering & Processing, Inc., an affiliate General Order No. 236.1 In the Matter of the Effects on Utilities of the 2017 Tax Cuts and Jobs Act CERTIFICATE OF SERVICE I, Linda S. Bouvette, Counsel for the Public Service Commission of West Virginia, do hereby certify that a copy of the foregoing Staff Response to Proposed Stipulation has been served upon the following parties of record by First Class, United States Mail, postage prepaid this 5th day of November, 2018. Kurt Krieger, Esq. Counsel, Hope Gas, Inc. Steptoe & Johnson PLLC PO Box 1588 Charleston, WV 25326-1588 Brien J. Fricke, Esq. Senior Counsel Hope Gas, Inc. dba: Dominion Energy West Virginia 925 White Oaks Boulevard Bridgeport, WV 26330 Tom White, Esq. Consumer Advocate Division 700 Union Building 723 Kanawha Boulevard, East Charleston, WV 25301 Todd M. Swanson, Esq. Counsel, Hope Gas, Inc. Steptoe & Johnson PLLC PO Box 1588 Charleston, WV 25326-1588
Jacqueline A. Wilson, Esq. Counsel Dominion Gathering & Processing, Inc. Dominion Energy Services, Inc. 925 White Oaks Boulevard Bridgeport, W 26330 George A. Patterson, 111, Esq. Counsel, IOGA Bowles Rice McDavid Graff & Love, LLP PO Box 1386 Charleston, WV 25301 Linda S. Bouvette WV State Bar I.D. No. 5926