UNITED STATES OF AMERICA

FEDERAL ENERGY REGULATORY COMMISSION

Northern Natural Gas Company ) Docket No. RP19-59-000

NORTHERN NATURAL GAS COMPANY’S MOTION TO TERMINATE SECTION 5

INVESTIGATION, OR IN THE ALTERNATIVE, HOLD IN ABEYANCE

Pursuant to Rule 212 of the Federal Energy Regulatory Commission’s (“FERC” or

“Commission”) Rules of Practice and Procedures, Northern Natural Gas Company (“Northern”)

hereby moves the Commission to take notice of a significant error in its calculation of Northern’s

return on equity (“ROE”) and terminate, or in the alternative, hold in abeyance, the section

investigation issued in the above-referenced docket on January 16, 2019 (“Investigation Order”).1

Because the decision to initiate or terminate a section 5 investigation is within the Commission’s sole

discretion, the Commission may act on this Motion without considering answers by parties to the

case. In support hereof, Northern states as follows:

COMMUNICATIONS

Northern respectfully requests that all correspondence and communications in connection

with this filing be sent to the following representatives:

Laura K. Demman Daniel J. Poynor

Darla S. Zink Monique L. Watson

J. Gregory Porter Daniel A. Mullen

Northern Natural Gas Company Steptoe & Johnson LLP

P.O. Box 3330 1330 Connecticut Avenue, N.W.

Omaha, NE 68103-0330 Washington, D.C. 20036-1795

laura.demman@nngco.com dpoynor@steptoe.com

darla.zink@nngco.com mwatson@steptoe.com

greg.porter@nngco.com Daniel.mullen@steptoe.com

1 Northern Natural Gas Co., 166 FERC ¶ 61,033 (2019) (“Northern” or “Hearing Order”).

2

MOTION TO TERMINATE

I. The Commission should exercise its discretion to terminate this investigation based on

the significant error in calculations in the Investigation Order.

A. The Commission has broad discretion to open or terminate a section 5

investigation.

The Commission has broad discretion to decide whether to issue an order opening an

investigation under section 5 of the NGA,2 and whether to terminate an investigation in its early

stages. This is especially true where the information on which the Commission based its conclusion

to open the investigation is revealed to be inaccurate. In deciding to investigate Northern’s rates, the

Commission significantly overestimated Northern’s return of equity due to a calculation error

described more fully below.

B. The Commission based its investigation on a significant error in its calculations.

By way of background, on July 18, 2018, the Commission issued Order No. 849,3 a final rule

adopting procedures for determining which jurisdictional natural gas pipelines may be collecting

unjust and unreasonable rates in light of the income tax reductions provided by the Tax Cuts and Jobs

Act.4 Order No. 849 required Northern, like other interstate natural gas companies with cost-based

stated rates, to file a FERC Form No. 501-G, an informational filing. Northern filed its FERC Form

501-G on October 11, 2018, in the above-referenced docket.

Based on Northern’s FERC Form 501-G and the Commission’s own calculations based on

Northern’s Form No. 3-Qs for the first and second quarters of 2018, the Commission initiated an

investigation, pursuant to section 5 of the NGA, to determine whether the rates currently charged by

2 Northern Natural Gas Co., 131 FERC ¶ 61,178 at P 18 n.12 (2010) (“Northern”). 3 Interstate and Intrastate Natural Gas Pipelines; Rate Changes Relating to Federal Income Tax

Rate, Order No. 849, FERC Stats. & Regs. ¶ 31,404 (2018) (cross-referenced at 164 FERC ¶ 61,031). 4 An Act to provide for reconciliation pursuant to titles II and V of the concurrent resolution on the

budget for fiscal year 2018, Pub. L. No. 115-97, 131 Stat. 2054 (2017) (“Tax Cuts and Jobs Act”).

3

Northern are just and reasonable. The Commission erroneously estimated Northern’s return on equity

to be 17.3%. Based upon this figure, the Commission expressed that it is “concerned that Northern’s

level of earnings may substantially exceed its actual cost of service, including a reasonable ROE.”5

The Commission’s estimated ROE contains a significant error in the calculations shown on

Appendix A to the Investigation Order. Table 1 below shows the calculated ROEs Northern discusses

in this Motion.

Return on Equity %

Appendix A to

Investigation Order

Form 501-G

Correction

Adjusted Form 501-G

Correction

Northern’s 2018

Projected Actual

17.3

14.3

13.7

13.5

In Appendix A to the Investigation Order, the Commission adjusted revenues by

$115,386,243 for the changes in all revenue accounts during the first two quarters of 2018. The

Commission failed to recognize that more than half of this revenue increase, $60,774,052, was related

to operational gas sales. Pursuant to the FERC Form 501-G, these gas sales revenues should have

been excluded. The Commission, however, erroneously deducted from total operating revenue only

the $28,436,340 in operational gas sales from calendar year 2017, instead of the $89,210,392 in

operational gas sales through the second quarter of 2018 ($28,436,340 plus $60,774,052). By simply

following the Commission’s form and correctly calculating the FERC-estimated ROE, the estimated

ROE is 14.3%. See Attachment 1 for the corrected abbreviated Appendix A from the Commission’s

January 16, 2019 order. A ROE of 14.3% is well within the zone of reasonableness and well below

the ROEs the Commission has previously relied upon to initiate section 5 investigations of a pipeline’s

5 Northern, 166 FERC ¶ 61,033 at P 9.

4

existing rates.6 Further, had the Commission corrected the flaw in the 501-G as discussed more fully

below, the Commission would have estimated an ROE of 13.7%. This result is very consistent with

Northern’s calculated ROE for 2018 of 13.5%, and considerably below the erroneously calculated

ROE of 17.3%. Had the Commission accurately performed its calculations, it is inconceivable that it

would have then initiated a section 5 proceeding against Northern.

The issue of proper reflection of fuel sales and costs was flagged in BHE Pipeline Group’s

(BHEPG) comments for the Notice of Proposed Rulemaking for Rate Changes Relating to Federal

Income Tax Rate.7 BHEPG requested that the Commission modify the FERC Form 501-G for cost

and revenues associated with fuel and other operational gas sales activity. In Exhibit A to its filed

comments, BHEPG noted “[a]ll appropriate expense and revenue lines should be included in the

FERC Form 501-G form. Some pipelines collect revenues associated with fuel instead of utilizing a

fuel tracker and/or [unaccounted for fuel] UAF. Pipelines without fuel, UAF or other trackers could

have potential gains or losses associated with the fuel revenues collected and sales expenses

associated with such activity (Account 913), which should flow through the cost of service and return

on equity calculations as part of the FERC Form 501-G calculation. Excluding these accounts would

fail to capture those gains and losses. Conversely, pipelines with trackers should not have any gains

or losses on fuel or sales expenses; therefore, including all of these accounts would ensure that the

6 See Attachment 4. Since enactment of the Tax Cuts and Jobs Act, the Commission has instituted

NGA section 5 investigations in two instances. In Midwestern Gas Transmission Co., 162 FERC ¶

61,219 (2018), the Commission initiated the NGA section 5 investigation based on 20.20 % return on

equity after adjusting for the lower federal income tax rate, and in Dominion Energy Overthrust

Pipeline, LLC, 162 FERC ¶ 61,218 (2018), the Commission initiated the NGA section 5 investigation

based on 30.9 % return on equity after reflecting the impact of the Revised Policy Statement on

Treatment of Income Taxes, 162 FERC ¶ 61, 227 (2018). 7 Notice of Proposed Rulemaking re Interstate and Intrastate Natural Gas Pipelines; Rate Changes

Relating to federal Income Tax Rate, notice of proposed rulemaking under Docket No. RM18-11,162

FERC ¶ 61,226 (2018).

5

net amount is zero. In either case, no adjustments are necessary.”8

This concern raised by BHEPG has now been borne out by the Commission’s error in its

section 5 analysis. As Northern has a fuel tracker but is subject to price risk on system balancing and

other operational system gas transactions, the Commission should have left the gas sales revenues in

the FERC Form 501-G, and included the cost of gas and related sales expense, rather than excluding

these. A similar error was identified and corrected in Natural Gas Pipeline Company of America

LLC’s section 5 Rate Investigation (Docket No. RP17-303), where the Commission had a mismatch

of revenues and costs by including the revenue for fuel but then reducing NGPL’s total O&M

expenses by the costs of its “Gas for Compressor Fuel”, resulting in an overstatement of NGPL’s

return on equity. The Commission corrected the return calculation in NGPL’s rate proceeding by

excluding both the revenues and the costs. For the FERC Form 501-G, an accurate result would have

been produced by including both the revenues and the costs in the return calculation as the net margin

on those sales would be expected to be shared with customers, whether the margins are gains or losses.

However, the Commission inexplicably declined to incorporate these corrections in the FERC Form

501-G, resulting in a faulty representation of return on equity.

In Northern’s case, as demonstrated on Attachment 2, the flawed approach in the FERC Form

501-G yielded a relatively minor distortion in 2017, changing the FERC Form 501-G calculated return

from 16.7% to 16.5% and the addendum return from 10.4% to 10.3%. However, when the

Commission made an erroneous assumption to adjust revenue through June 30, 2018, the flawed

approach overstated the Commission-calculated return by 3.6%; the more correct estimated return is

13.7%. This corrected calculation of the return properly reflects the financial impact associated with

8 Comments of Berkshire Hathaway Energy Pipeline Group, which includes two interstate natural gas

pipeline companies, Northern Natural Gas Company and Kern River Gas Transmission Company on

Notice of Proposed Rulemaking under Docket No. RM18-11, filed April 25, 2018.

6

the gas sales and purchases; the gas sales of $89,210,392 (the original amount from 2017 of

$28,436,340 plus the $60,774,052 that the Commission included when it updated for June 30, 2018)

and the costs associated with those gas sales of $99,951,3609 for the twelve months

ended June 30, 2018 should have been considered.

In short, had the Commission properly followed its Form 501-G and excluded the operational

gas sale revenue, Northern’s estimated ROE would be 14.3%. Alternatively, had the Commission

included both the revenue and costs related to operational gas sales as Northern proposed, Northern’s

return would be 13.7%, which Northern believes is a more appropriate and accurate estimation of its

return than 14.3%. As demonstrated in Attachment 4, both of these corrected ROEs are well below

those 20% and above ROEs on which the Commission has previously initiated section 5

investigations.

C. The Commission should terminate the section 5 investigation because the corrected

section 5 analysis provides no support for a finding that Northern’s existing rates are

unjust or unreasonable under the Commission’s historical application of section 5.

Of the 129 pipelines required to file a FERC Form 501-G, the median unadjusted return with

tax reform is 14.2%. As described above, the corrected calculation for Northern yields a return of

13.7%, which is well below any return the Commission has previously considered for action under

section 5. Though the Commission has indicated that additional section 5 actions are planned, surely

it does not intend to initiate a section 5 against all pipelines with a return above 13.7% that have not

otherwise reduced their rates under a limited section 4 rate proceeding.

This calculated return of 13.7%, incidentally, is more consistent with Northern’s projected

return of 13.5% for all of 2018, which was estimated at the end of 2018 and was communicated

9 Accounts 803 through 813, 819, 842.1, 842.2 and 854.

7

publicly by Northern.10 Most importantly, both the corrected return and projected return are well

within the zone of reasonableness for return under the Commission’s historical application of section

5 in evaluating the return of pipelines.11 When Northern files a general section 4 rate increase, as

described below, it anticipates supporting a return of 13.5% or higher in its filing, consistent with

demonstrations made by other pipelines in their FERC Form 501-G filings.

D. If the section 5 investigation proceeds, Northern will file a general section 4 rate

case in 2019, as soon as July 1.

Absent the Commission’s initiation of this investigation, Northern did not have plans to pursue

a rate increase by filing a general section 4 rate case in 2019. Indeed, as explained in its filings relating

to comments on its FERC Form 501-G, Northern has been able to provide the benefit of the lower

federal corporate income tax rate to its customers by deferring a rate increase that would otherwise

be imminent, while making significant investment in its infrastructure modernization. As Northern

described in its Explanatory Statement, Northern will respond to the Commission’s section 5 action

with a section 4 rate filing, resulting in a rate increase to address Northern’s significant investment in

modernization.

Though the Commission declined to consider the impact of 2019 in its section 5 analysis, the

reality is when Northern files a section 4 in mid-2019, the test period will include all of calendar year

2019. Northern currently estimates that the section 4 rate filing will increase rates by more than 30%

for cost of service increases due to 2019 capital, higher depreciation rates, a higher rate of return on

equity and other adjustments.

Northern faced a section 5 action in 2009, and that proceeding concluded with no rate change

10 See Attachment 3. 11 See Attachment 4.

8

pursuant to a joint motion to terminate the section 5 filed by Northern and its customers.12 A similar

outcome will not be an option if the current section 5 investigation proceeds.

II. Alternatively, if the Commission declines to terminate the instant proceeding

immediately, Northern requests that the Commission hold the proceeding in abeyance.

Pursuant to the Investigation Order, Northern must file its cost and revenue study

on April 1, 2019. Northern must also file its FERC Form 2 on April 18, 2019. As stated above,

Northern projects that its return for 2018 will be 13.5%. Moreover, as shown on Attachment 4, since

2009, the Commission has not initiated an investigation pursuant to section 5 against a pipeline or

storage company whose two previous years’ ROEs were less than 16%. Northern, therefore,

respectfully requests that if the Commission declines to terminate the instant proceeding immediately,

that it hold the proceeding in abeyance until after Northern files it FERC Form 2 on April 18, 2019,

and the Commission reevaluates Northern’s return on equity in light of that filing.

This temporary deferment of the proceeding will allow the Commission and Northern’s

customers to evaluate the pipeline’s most recent financial information, while ensuring that the

Commission’s and parties’ resources are used in the most efficient manner. One of Northern’s largest

customers, CenterPoint Energy, specifically requested in comments in this docket that FERC wait

until the Form 2 filing to evaluate the need for a section 5 against Northern.13

12 Northern Natural Gas Co., 131 FERC ¶ 61,178 (2010). 13 Motion to Intervene and Comments of CenterPoint Energy Resources Corp., d/b/a CenterPoint

Energy Minnesota Gas under Docket No. RP19-59.

9

III. Northern respectfully requests that the Commission rule on this Motion

by February 15, 2019.

To allow for efficient allocation of resources by parties to this proceeding, Northern

respectfully requests that the Commission rule on this Motion by February 15, 2019.

CONCLUSION

Northern respectfully requests that the Commission take notice of its error in the calculation

of Northern’s estimated return on equity, and terminate the instant proceeding based on the revised

return on equity calculation. Alternatively, if the Commission declines to terminate the proceeding,

Northern respectfully requests that the proceeding be held in abeyance until after its files its cost and

revenue study, files its 2018 FERC Form 2 on April 18, 2019, and the Commission has the opportunity

to reevaluate its decision to initiate an investigation into Northern’s just and reasonable rates based

on more recent information.

Respectfully submitted,

/s/ Laura Demman

Laura Demman

Vice President, General Counsel & Regulatory

Affairs

Northern Natural Gas Company

P.O. Box 3330

Omaha, Nebraska 68103-0330

(402) 398-7278

Laura.Demman@nngco.com

10

CERTIFICATE OF SERVICE

I hereby certify that I have this day served a copy of the foregoing document on each person

designated on the official service list compiled by the Secretary for this proceeding.

Dated at Omaha, Nebraska, this 28th day of January 2019.

/s/ Laura Demman

Laura Demman

Northern Natural Gas Company

P.O. Box 3330

Omaha, Nebraska 68103-0330

Northern Natural Gas Company Attachment 1

Docket No. RP19-59-000

With Adjusted Tax

Allowance Per Addendum

Form 2

Reference

Original Per

Appendix A

Original Per

Appendix A

Original Per

Appendix A Adjust Gas Sales

Updated With

Margin on Gas

Sales

(a) (b) (c) (d) (e) (f) (g)

1 Total Cost of Service Excl. Return and Taxes 397,181,344$ 449,058,063$ 441,601,219$ -$ 441,601,219$

2 Operating Revenue

3 Total Operating Revenue 693,438,299$ 693,438,299$ 808,824,542$ -$ 808,824,542$

4 (Less) Sales (Acct. Nos. 480-484) Page 300, Lines 1-5 28,436,340 28,436,340 28,436,340 60,774,052 89,210,392

5 (Less) Fuel Related Revenues Incl. in Total Revenues 159,013 159,013 159,013 - 159,013

6 Total Adjusted Revenue 664,842,946$ 664,842,946$ 780,229,189$ (60,774,052)$ 719,455,137$

7 Income Allowance

8 Income Before Income Taxes 267,661,602$ 215,784,883$ 338,627,970$ (60,774,052)$ 277,853,918$

9 (Less) Net Amort. Of Excess(+) and/or Deficient(-) ADIT 9,578,811 9,578,811 9,578,811 - 9,578,811

10 Composite Income Tax 62,362,204 48,418,987 81,436,260 (16,334,607) 65,101,654

11 Net Income 205,299,398$ 167,365,896$ 257,191,710$ (44,439,445)$ 212,752,264$

12 Total Estimated ROE 16.7% 10.4% 17.3% -3.0% 14.3%

13 Composite Tax Rate 26.88% 26.88% 26.88% 26.88% 26.88%

14 Total Rate Base 2,156,877,039 2,599,138,039 2,412,392,039 2,412,392,039 2,412,392,039

15 Percentage of Common Equity 57.00% 61.78% 61.78% 61.78% 61.78%

Per Appendix A

As Adjusted

Northern Natural Gas Company Attachment 2

Docket No. RP19-59-000

Form 2

Reference

Original Per

Appendix A

Margin (Loss) on

Gas Sales

Updated With

Margin on Gas

Sales

Original Per

Appendix A

Margin (Loss) on

Gas Sales

Updated With

Margin on Gas

Sales

Original Per

Appendix A

Margin (Loss) on

Gas Sales

Updated With

Margin on Gas

Sales

(a) (b) (c) (d) (e) (f) (g) (h) (i) (j) (k)

1 Total Cost of Service Excl. Return and Taxes 397,181,344$ -$ 397,181,344$ 449,058,063$ -$ 449,058,063$ 441,601,219$ -$ 441,601,219$

2 Cost of gas sold accounts inappropriately excluded from 501-G

3 Accounts 803-813 Page 320, Line 96 $ 817,390 817,390$ $ 817,390 817,390$ $ 48,969,711 48,969,711$

4 Account 819 Page 320, Line 106 $ 2,902,986 2,902,986$ $ 2,902,986 2,902,986$ $ 3,113,624 3,113,624$

5 Account 842.1 Page 321, Line 131 $ 654,441 654,441$ $ 654,441 654,441$ $ 1,252,903 1,252,903$

6 Account 842.2 Page 321, Line 132 $ 105,130 105,130$ $ 105,130 105,130$ $ 412,568 412,568$

7 Account 854 Page 323, Line 184 $ 27,304,791 27,304,791$ $ 27,304,791 27,304,791$ $ 46,202,554 46,202,554$

8 $ 31,784,738 $ 31,784,738 $ 31,784,738 $ 31,784,738 $ 99,951,360 $ 99,951,360

9 Total Cost of Service Excl. Return and Taxes 397,181,344$ 31,784,738$ 428,966,082$ 449,058,063$ 31,784,738$ 480,842,801$ 441,601,219$ 99,951,360$ 541,552,579$

10 Operating Revenue

11 Total Operating Revenue 693,438,299$ -$ 693,438,299$ 693,438,299$ -$ 693,438,299$ 808,824,542$ -$ 808,824,542$

12 (Less) Sales (Acct. Nos. 480-484) Page 300, Lines 1-5 28,436,340 (28,436,340) - 28,436,340 (28,436,340) - 28,436,340 (28,436,340) -

13 (Less) Fuel Related Revenues Incl. in Total Revenues 159,013 - 159,013 159,013 - 159,013 159,013 - 159,013

14 Total Adjusted Revenue 664,842,946$ 28,436,340$ 693,279,286$ 664,842,946$ 28,436,340$ 693,279,286$ 780,229,189$ 28,436,340$ 808,665,529$

15 Income Allowance

16 Income Before Income Taxes 267,661,602$ (3,348,398)$ 264,313,204$ 215,784,883$ (3,348,398)$ 212,436,485$ 338,627,970$ (71,515,020)$ 267,112,950$

17 (Less) Net Amort. Of Excess(+) and/or Deficient(-) ADIT 9,578,811 - 9,578,811 9,578,811 - 9,578,811 9,578,811 - 9,578,811

18 Composite Income Tax 62,362,204 (899,969) 61,462,235 48,418,987 (899,969) 47,519,018 81,436,260 (19,221,521) 62,214,739

19 Net Income 205,299,398$ (2,448,429)$ 202,850,969$ 167,365,896$ (2,448,429)$ 164,917,467$ 257,191,710$ (52,293,499)$ 204,898,211$

20 Total Estimated ROE 16.7% -0.2% 16.5% 10.4% -0.1% 10.3% 17.3% -3.6% 13.7%

21 Composite Tax Rate 26.88% 26.88% 26.88% 26.88% 26.88% 26.88% 26.88% 26.88% 26.88%

22 Total Rate Base 2,156,877,039 2,156,877,039 2,156,877,039 2,599,138,039 2,599,138,039 2,599,138,039 2,412,392,039 2,412,392,039 2,412,392,039

23 Percentage of Common Equity 57.00% 57.00% 57.00% 61.78% 61.78% 61.78% 61.78% 61.78% 61.78%

Per Appendix A

With Adjusted Tax Allowance Per Addendum As Adjusted

Attachment 3

TSP Name: Northern Natural Gas Company

TSP: 784158214

Notice ID: 043960

Notice Type: Customer Service Update

Subject: 501-G UPDATE

Critical: N

Post Date/Time: 12/19/2018 02:00 PM

Notice Effective Date/Time: 12/19/2018 02:00 PM

Notice End Date/Time: 01/31/2019 08:59 AM

For Gas Day(s): 12/19/2018 - 01/30/2019

Notice Status: Initiate

Required Response Indicator Description: 5-No response required

Notice Text:

In the interest of transparency of information regarding Northern’s 2018 return on equity, the FERC Form 501-G and a possible Section 4 rate increase filing in 2019, Northern provides the following update. With the year almost complete, Northern is able to reliably forecast its return on equity as 13.5% for 2018. This forecast reflects the estimated costs that will be incurred and revenues earned for the year. This year brought both record capital investment and higher than normal revenue. Our capital investment was $430 million this year, with over $330 million of this amount being spent on

pipeline system upgrades and other non-revenue generating capital projects. Northern also had abnormally higher revenue due to a much colder than normal winter and very weak Permian-priced supply that caused wide price spreads from Field Area sources to Demarcation. However, we fully expect reduced revenue levels in 2019 as compared to 2018.

In 2019, the return on equity will be further reduced by 1.8% due to the $330 million of non-revenue generating capital being spent on additional pipeline system upgrades, all else being equal

to 2018. Thus, assuming all else is equal in 2019, when placed in-service, the non-revenue generating investment will reduce Northern’s return on equity to 11.7%.

These results are contrasted with an actual 2017 return of 11.7% and a FERC Form 501-G that showed a calculated return of 16.7% based on 2017 financial data, adjusted for the impact of tax reform and an imputed capital structure.

Northern is providing this forecast of year-end financial information to update and supplement the information that was provided in the FERC Form 501-G filing. Northern is not aware of the FERC’s

perspective regarding the Form 501-G filing or what FERC’s actions might be regarding a potential section 5 order. However, Northern is preparing for a section 4 rate case in 2019 in the event that FERC initiates a section 5 proceeding early next year. As Northern previously stated in its FERC Form 501-G filing, if FERC issues a section 5 proceeding, Northern will promptly file a section 4 rate increase based on 2019 test period data that reflects a rate increase.

1 In Docket No. RP17-303, the Commission initiated a section 5 proceeding after calculating NGPL’s return on equity

to be 20.8 percent. Natural Gas Pipeline Company of America, 158 FERC ¶ 61,044 (2017). After ordering the

investigation, the Commission corrected its calculated return to be 15.7 percent. Natural Gas Pipeline Company of

America, 158 FERC ¶ 61,111 (2017).

Northern Natural Gas Company

Section 5 ROE Analysis

Docket FERC Order Tax Adj

Sec 5 ROE FERC OrderEntity Sec 5 ROE

Natural Gas Pipeline Company of America RP10-147 24.5%

Northern Natural Gas RP10-148 24.4%

Great Lakes Gas Transmission RP10-149 20.8%

Kinder Morgan Interstate Gas Transmission RP11-1494 29.3%

Ozark Gas Transmission RP11-1495 25.6%

Tuscarora Gas Transmission RP11-1823 27.2%

Bear Creek Storage Company RP12-121 29.2%

MIGC RP12-122 57.14%

ANR Storage Company RP12-123 153.71%

Wyoming Interstate Company RP13-184 19.57%

Viking Gas Transmission Company RP13-185 21.99%

Tuscarora Gas Transmission Company RP16-299 24.90%

Empire Pipeline RP16-300 20.20%

Iroquois Pipeline RP16-301 16.30%

Columbia Gulf RP16-302 18.20%

Wyoming Interstate Company RP17-302 19.00%

Natural Gas Pipeline Company of America1 RP17-303 20.80%

Midwestern Gas Transmission RP18-441 __ __ 20.20%

Dominion Overthrust Transmission RP18-442 __ __ 30.90%

Attachment 4