Dominion Transmission, Inc.
701 East Cary Street, Richmond, VA 23219
March 15, 2016
Kimberly D. Bose, Secretary
Federal Energy Regulatory Commission
888 First Street, N.E.
Washington, DC 20426
Re:
Atlantic Coast Pipeline, LLC & Dominion Transmission, Inc.
Atlantic Coast Pipeline & Supply Header Projects
Docket Nos. CP15-554-000 & CP15-555-000
OEP/DG2E/Gas 4
§375.308(x)
Dear Secretary Bose:
On September 18, 2015, Atlantic Coast Pipeline, LLC (Atlantic) and Dominion Transmission, Inc.
(DTI) filed abbreviated applications (Applications), under the above referenced dockets, for the
Atlantic Coast Pipeline and Supply Header Projects (Projects) pursuant to Section 7(c) of the
Natural Gas Act, as amended, and Part 157 of the Rules and Regulations of the Federal Energy
Regulatory Commission (“FERC” or the “Commission”).
Atlantic and DTI received a Data Request from Commission staff regarding these Projects dated
February 29, 2016 (2-29-16 Data Request). DTI, on behalf of Atlantic and itself, hereby
submits its response to the 2-29-16 Data Request.
If you have any questions, please contact Angela Woolard at 866-319-3382.
Respectfully submitted,
/s/
Matthew R. Bley
Matthew R. Bley
Director, Gas Transmission Certificates
cc:
Mr. Kevin Bowman, FERC
Mr. Todd Ruhkamp, FERC
Service List
Atlantic Coast Pipeline, LLC & Dominion Transmission, Inc.
Docket Nos. CP15-554-000 & CP15-555-000
Response to Data Request
Dated February 29, 2016
Category:
Atlantic Coast Pipeline, LLC CP15-554-000
Question Number:
1
Question Subpart: a (i-v)
Question:
Supplement your December 30, 2015 response to Staff’s December 15, 2015 Data Request
Question No. 1 to include the following information:
a. Modify the spreadsheet Line No. 1 “Investment in Current Period” to include
the cost categories included on Exhibit K of Atlantic Coast Pipeline’s
application filed on September 18, 2014.
i. List the cost categories and their respective monthly amounts above the
“Investment in Current Period” line such that the total of the cost
categories agrees to the provided “Investment in Current Period” amount;
ii. Indicate in the column header for each month whether the costs are
estimated or actual;
iii. Among the cost categories, separately show amounts for land purchases,
rights of way/easements, site development, engineering, and inspection;
iv. Among the cost categories, add the category “Shareholder Outreach” and
provide the amounts.
v. In a footnote, describe the activities which constitute “Engineering” and
separately the activities which constitute “Inspection”.
Response:
Attachment to ACP Question No. 1 includes the spreadsheet containing the requested
information. Note that the amounts have been updated to reflect those submitted in the
Amendment filed March 14, 2016.
Column headers labeled with “A” indicate each month that the costs are actual and column
headers labeled with “F” indicate each month that the costs are estimated, as requested in subpart
ii. In addition, footnotes have been added to describe the activities which constitute
“Engineering” (i.e., labor, engineering and design firm costs) and “Inspection” (i.e., welding,
corrosion and pipe inspection), as requested in subpart v.
Response Provided By:
Neha Bhatnagar
Sr. Financial Analyst
804-775-5990
Atlantic Coast Pipeline, LLC & Dominion Transmission, Inc.
Docket Nos. CP15-554-000 & CP15-555-000
Response to Data Request
Dated February 29, 2016
Category:
Atlantic Coast Pipeline, LLC CP15-554-000
Question Number:
2
Question Subpart: a-b
Question:
Supplement your December 30, 2015 response to Staff’s December 15, 2015 Data Request
Question No. 2 to describe:
a. The cost components included in the cost category “Other”.
b. The types of labor included in the cost category “Labor” (e.g. legal,
marketing, engineering, etc.).
Response:
a. “Other” includes documentation and filing costs.
b. “Labor” includes engineering and project management labor.
Response Provided By:
Neha Bhatnagar
Sr. Financial Analyst
804-775-5990
Atlantic Coast Pipeline, LLC & Dominion Transmission, Inc.
Docket Nos. CP15-554-000 & CP15-555-000
Response to Data Request
Dated February 29, 2016
Category:
CP15-555-000 Dominion Transmission, Inc.
Question Number:
1
Question Subpart: a (i-v)
Question:
Supplement your December 30, 2015 response to Staff’s December 15, 2015 Data Request
Question No. 1 to include the following information:
a. Modify the spreadsheet Line No. 1 “Investment in Current Period” to include
the cost categories included on Exhibit K of Dominion Transmission’s
application filed September 18, 2014.
i. List the cost categories and their respective monthly amounts above the
“Investment in Current Period” line such that the total of the cost
categories agrees to the provided “Investment in Current Period” amount;
ii. Indicate in the column header for each month whether the costs are
estimated or actual;
iii. Among the cost categories, separately show amounts for land purchases,
site development, engineering, and inspection;
iv. Among the cost categories, add the category “Shareholder Outreach” and
provide the amounts;
v. In a footnote, describe the activities which constitute “Engineering” and
separately the activities which constitute “Inspection”
Response:
Attachment to SHP Question No. 1 includes the spreadsheet containing the requested
information.
Column headers labeled with “A” indicate each month that the costs are actual and column
headers labeled with “F” indicate each month that the costs are estimated, as requested in subpart
ii. In addition, footnotes have been added to describe the activities which constitute
“Engineering” (i.e., DTI labor, engineering and design firm costs) and “Inspection” (i.e.,
welding, corrosion and pipe inspection), as requested in subpart v.
Response Provided By:
Neha Bhatnagar
Sr. Financial Analyst
804-775-5990
Atlantic Coast Pipeline, LLC & Dominion Transmission, Inc.
Docket Nos. CP15-554-000 & CP15-555-000
Response to Data Request
Dated December 15, 2015
Category:
CP15-555-000 Dominion Transmission, Inc.
Question Number:
2
Question Subpart: a-c
Question:
Supplement your December 30, 2015 response to Staff’s December 15, 2015 Data Request
Question No. 2 to describe:
a. The activities and cost components included for “Land Services”.
b. The activities and cost components included for “Environmental Services”.
c. The types of labor included in the cost category “Labor” (e.g. legal,
marketing, engineering, etc.).
Response:
a. “Land Services” activities and cost components include the activities associated with the
vendor that is acquiring right-of-way and land purchases.
b. “Environmental Services” activities and cost components include the activities associated
with the vendor conducting environmental surveys.
c. The types of labor included in the cost category “Labor” is engineering and project
management.
Response Provided By:
Neha Bhatnagar
Sr. Financial Analyst
804-775-5990
Atlantic Coast Pipeline, LLC & Dominion Transmission, Inc.
Docket Nos. CP15-554-000 & CP15-555-000
Response to Data Request
Dated February 29, 2016
Category:
CP15-555-000 Dominion Transmission, Inc.
Question Number:
3
Question Subpart:
Question:
Provide a pro forma copy of any service agreement associated with the Supply Header Project in
which you are requesting a determination be made as to the permissibility of any nonconforming provision. For any agreement, include a redline/strikeout format identifying any
non-conforming provisions for which you seek a preliminary ruling, and file them as public. In
the alternative, provide a list of the non-conforming provisions quoting verbatim the specific
language to be included in the pro forma copies of the service agreements.
Response:
Attachment to SHP Question No. 3 includes a proforma copy of the service agreement between
DTI and Atlantic Coast Pipeline, LLC (Atlantic) for the Project. Atlantic is an Anchor Shipper
in the Project and intends to use the Project capacity to allow its customers access to DTI
markets for further delivery into Atlantic. As noted in redlined form on the attached proforma
agreement, DTI is requesting a determination regarding the permissibility of three nonconforming provisions:
1) Extension rights and if extended, MDTQ reduction rights that mirror the rights Atlantic
provided to its own Foundation and Anchor Shippers (See Application p. 14 and p. 15 for
further detail). These provisions were agreed upon to reflect Atlantic’s use of this Supply
Header capacity.
2) Delivery obligations, including measurement, at the Marts Junction Interconnect and the
nearby Kincheloe M&R Station (See Application p. 13 and 14). This provision is
necessary because Marts Junction is located on unsuitable terrain for the installation of
measurement facilities.
3) Secondary access to the “Applicable Market Center Point” (or South Point) for the
“Access Segment” only (as defined in the GT&C Section 11.A.4.G of the Tariff). The
Rate Schedule FT proforma agreement does not currently provide that the agreed upon
limitation set forth in Section 6.1C of Rate Schedule FT can be limited to only the
“Access Segment”. Without this nonconforming language, the secondary access would
apply on both the Access Segment and Delivery Segment, even though DTI has the
capability to provide primary access on the Delivery Segment.
Response Provided By:
Margaret H. Peters
Assistant General Counsel
804-819-2411
Atlantic Coast Pipeline, LLC & Dominion Transmission, Inc.
Docket Nos. CP15-554-000 & CP15-555-000
Response to Data Request
Dated February 29, 2016
Category:
CP15-555-000 Dominion Transmission, Inc.
Question Number:
4
Question Subpart:
Question:
In order to ensure that existing shippers do not subsidize the Supply Header Project, provide an
analysis showing the impact of the expansion on DTI’s current Fuel Retention Percentage.
Response:
This analysis utilizes a comparison of:
1. the estimated fuel used by the incremental facilities as proposed in this Project to provide
the full amount of Project services to
2. the amount of fuel retained by DTI (using the current system fuel retention rate) to
provide the full amount of Project services.
The Summer Design Day is used to determine the incremental fuel because it is projected to be
the day which will have the highest daily fuel usage by the incremental facilities proposed in this
project. The total estimated fuel used by the incremental facilities as proposed in this Project
during the Summer Design Day is 9,300 Dt/d. Using DTI’s fuel retention rate of 1.95 percent for
the total MDTQ of 1,511,335 Dt/d as proposed in this Project results in a total daily fuel
retention of 30,057 Dt/d.
Since the total daily fuel retention for the Project exceeds the projected maximum daily fuel used
by the proposed incremental facilities on the projected design day for the Project, no
subsidization by the existing customers would occur. Annualizing these results also would
result in no subsidization because on no other day is the fuel usage for the incremental Project
facilities projected to exceed the summer design day.
The table below shows the details of this calculation.
Supply Header Project - (CP15-555)
Calculation of Estimated Fuel Used compared to Fuel Retained
For response to FERC Data Request #4 dated 2-29-16
Summer
Incremental
Hp Utilized
Note 1
Heat Rate
(BTU/Hp Hr.)
Note 2
Station
Name
Incremental
Hp Installed
# of Units
Crayne
7,700
1
5,697
7,965
JB Tonkin
10,915
2
16,462
7,205
Mockingbird
Hill
20,500
2
31,816
7,025
Estimated
Incremental
Fuel Used
Note 3
*
*
*
*
*
*
Total Estimated Incremental Fuel Used
Incremental Fuel
Retained =
Dt/day
2,847
Dt/day
5,364
Dt/day
9,300
Dt/day
MDTQ
DTI Fuel
Retention %
Fuel
Retained
1,511,335
1.95%
30,057
Dt/day
9,300
Dt/day
Total Estimated Incremental Fuel Used =
RESULTS
1,089
Incremental fuel retained is greater than estimated incremental fuel used.
Notes:
Note 1: Hp Utilized is taken from the Exhibit G flowsheet.
Note 2: Heat Rates for compressors were taken from manufacturer (Solar) website.
Note 3: Example of the calculation is as follows:
Crayne Fuel: 5,697 Hp x 7,965 BTU/(Hp Hr) x 24 Hr/day x 1 Dt/1,000,000 Btu = 1,089 Dt/d
Response Provided By:
Daniel P. Fowler
Director, Business & Facility Planning
804-771-4485
Atlantic Coast Pipeline, LLC & Dominion Transmission, Inc.
Docket Nos. CP15-554-000 & CP15-555-000
Response to Data Request
Dated February 29, 2016
Category:
CP15-555-000 Dominion Transmission, Inc.
Question Number:
5
Question Subpart:
Question:
In Exhibit P, Page 3 of 4, Dominion estimates its 1st year Transport Compression O&M
Expenses for this project to total $2,327,490. Provide a breakdown of these expenses by FERC
account number and identify a further breakdown between labor and non-labor costs.
Response:
Attachment to SHP Question No. 5, Page 1, sets forth the breakdown of the $2,327,490 of
Transport Compression O&M Expenses shown on Exhibit P, Page 3 of 4, by FERC Account
Number and between labor and non-labor. As shown, and consistent with the Commission’s
order in Algonquin Gas Transmission, LLC (150 FERC ¶ 61,163), the costs used to derive the
incremental reservation rate did not include any non-labor Transport Compression O&M
expenses.
As shown on Pro Forma Tariff Record Nos. 10.50 and 10.51 included in Exhibit P, DTI
proposed to charge the generally applicable usage rate for service provided under Rate Schedule
FT, which is currently $0.0083/Dt. DTI proposed the use of the generally applicable usage rate
because the estimated non-labor Transport Compression O&M expenses of $2,962,260 would
produce a usage rate of $0.0063/Dt (based on an 85% load factor). However, the originally
submitted Exhibit P did not include the estimated non-labor Transport Compression O&M
expenses. Therefore, DTI has included, as Pages 2 through 5 of Attachment to SHP Question
No. 5, a revised Exhibit P that is inclusive of the non-labor Transport Compression O&M
expenses and demonstrates that the current generally applicable usage rate is sufficient to recover
the non-labor Transport Compression O&M expenses. Finally, Page 6 of the attachment
provides a breakdown, by FERC Account Number, of the labor and non-labor Transport
Compression O&M expenses shown on the revised Exhibit P.
Response Provided By:
Daniel Verdun
Director Regulatory & Pricing
804-771-4426