Dominion Energy Overthrust Pipeline, LLC (DEOP): Implementation Procedures
PROCEDURES TO IMPLEMENT FERC ORDER NO. 717
STANDARDS OF CONDUCT FOR TRANSMISSION PROVIDERS
DOMINION ENERGY TRANSMISSION, INC.; DOMINION ENERGY COVE
POINT LNG, LP; DOMINION ENERGY CAROLINA GAS TRANSMISSION,
LLC; DOMINION ENERGY QUESTAR PIPELINE,LLC; QUESTAR
SOUTHERN TRAILS PIPELINE COMPANY; DOMINION ENERGY
OVERTHRUST PIPELINE, LLC; WHITE RIVER HUB, LLC;
VIRGINIA ELECTRIC AND POWER COMPANY (DOMINION ENERGY
I. Definitions (Capitalized terms in these Procedures have the following meanings)
means an entity that controls or is controlled by or is under common control (10 percent or
more) with Dominion Energy, Inc, including a division that operates as a functional unit.
“Control” means the direct or indirect authority, whether acting alone or in conjunction with
others, to direct or cause to direct the management policies of the Affiliate.
Chief Compliance Officer (CCO)
means the employee identified on the Internet Website who is responsible for managing
compliance with the Standards of Conduct. Dominion Energy’s Chief Compliance Officer
is: Carlos M. Brown, Senior Vice President and General Counsel 120 Tredegar Street,
Pump House 3rd Floor, Richmond, VA 23219, (804) 819-2690,
means Dominion Energy, Inc. and its Affiliates.
means employee, contractor, consultant or agent of Dominion Energy.
1 Dominion Energy South Carolina, Inc. has posted separate procedures to implement FERC Order No. 717,
Standards of Conduct for Transmission Providers on its OASIS.
Date: April 29, 2019 Page 2
FERC or Commission
means the Federal Energy Regulatory Commission or any successor agency thereof.
means a location on www.dominionenergy.com where a Dominion Energy Transmission
Provider posts certain information required by the Standards of Conduct. The
Transmission Provider may also use its proprietary Information System (e.g. Dekaflow,
QuestLine) or the OASIS or Electronic Bulletin Board (EBB) to post certain information
required by the Standards of Conduct.
means a location on Dominion Energy’s corporate data network that is accessible only to
Dominion Energy employees. Information on this network may be available to all
employees (e.g. telephone directory, Law Department – Federal Regulation, Ethics
program Intranet Websites, etc.) or may be restricted to certain employees through
software access controls.
means Affiliates of Dominion Energy with Marketing Function Employees, which includes:
For Gas: Dominion Energy Field Services, Inc., Dominion Energy Solutions, Inc., Hope
Gas, Inc., The East Ohio Gas Company, Dominion Energy Fuel Services, Inc., SCANA
Energy Marketing Inc., PSNC Energy, South Carolina Electric & Gas Company and
Virginia Power Services Energy (VPSE).
For Electric: Dominion Energy Generation Marketing, Inc., Dominion Energy Virginia, and
Dominion Energy South Carolina, Inc.
For Gas: means the sales for resale in interstate commerce, or the submission of offers to
sell in interstate commerce, natural gas, subject to the following exclusions: 1) bundled
retail sales; 2) incidental purchases or sales to operate interstate natural gas pipeline
transmission facilities; 3) sales of natural gas solely from a seller’s own production; 4)
sales of natural gas solely from a seller’s own gathering or processing facilities; or 5) onsystem
sales by an intrastate natural gas pipeline, by a Hinshaw interstate pipeline exempt
from the Natural Gas Act, by a local distribution company, or by a local distribution
company operating under 7(f) of the Natural Gas Act.
For Electric: means the sales for resale in interstate commerce, or the submission of
offers to sell in interstate commerce, of electric energy or capacity, demand response,
virtual transactions, or financial or physical transmission rights, all subject to an exclusion
for bundled retail sales, including sales of electric energy made by providers of last resort
(POLRs) acting in their POLR capacity.
Marketing Function Employee (MFE)
means an employee, contractor, consultant or agent of Dominion Energy who actively
and personally engages on a day-to-day basis in marketing functions.
Date: April 29, 2019 Page 3
Procedures means these Procedures designed to Implement FERC Order No. 717,
Standards of Conduct for Transmission Providers pursuant to 18 C.F.R. Section 358.7(d).
Services Company means Dominion Energy Services, Inc.
Standards of Conduct
means the rules governing the relationship between TFEs and MFEs as established
by FERC in Order No. 717, Standards of Conduct for Transmission Providers.
For Gas: means natural gas transportation, storage, exchange, backhaul, or displacement
service provided pursuant to subparts B or G of Part 284 of FERC’s regulations.
For Electric: means electric transmission, network or point-to-point service, ancillary
services or other methods of electric transmission, or the interconnection with jurisdictional
transmission facilities pursuant to Part 35 of FERC’s regulations.
means any eligible customer, shipper or designated agent that (1) can or does execute a
transmission service agreement or (2) can or does receive transmission service, including
persons with pending requests for transmission service or information regarding
means the planning, directing, organizing or carrying out of day-to-day transmission
operations, including the granting and denying of transmission service requests. Directed
at short-term real time operations, including decisions made in advance of real time that
are directed at real time operations. Transmission Functions do not include long-range
Transmission Function Employee (TFE)
means an employee, contractor, consultant or agent of a transmission provider who
actively and personally engages on a day-to-day basis in Transmission Functions. The
Internet Website will identify the job titles and job descriptions of TFEs. Examples of TFEs
include employees in the following areas: Gas Control or System Operations Centers,
System Optimization, Pipeline Operations, Transportation and Customer Services, and
Generally, employees in the following areas are NOT TFEs (unless they are involved in
day-to-day operations): Field, Maintenance and Construction, Engineers, Technical
Support Staff, Human Resources, Information Technology, Storage Engineers, Pipeline
Safety, Measurement, Business Development, Attorneys, Accountants, Risk Management,
Regulatory Personnel, Rate Design, Strategic Planning, Clerical.
Transmission Function Information
means information relating to Transmission Functions, as defined above, that is not
Date: April 29, 2019 Page 4
otherwise also available to the general public without restriction, all users of E-SCRIPT or
the Internet Website, as applicable. This can include, but is not limited to, past, present
and future information about: transmission maintenance schedules, transmission
customer information, curtailments of transmission service, available transmission
capacity, including storage, transmission service requests and request status,
transmission service pricing offers, transmission outages, expansion plans and schedules,
Cove Point LNG ship schedules, transmission line outage information and transmission
loading relief information.
means Dominion Energy Transmission, Inc., Dominion Energy Cove Point, LNG, LP
Dominion Energy Carolina Gas Transmission, LLC, Dominion Energy Questar Pipeline,
LLC, Questar Southern Trails Pipeline Company, Dominion Energy Overthrust Pipeline,
LLC, White River Hub, LLC, Dominion Energy Virginia, and Dominion Energy South
These Procedures implement the Standards of Conduct and apply to the relationship
and communications between TFEs including employees with Transmission Function
Information and MFEs. All TFEs, MFEs, and all other employees, including senior
management and supervisory personnel, are responsible for adhering to these
III. General Principles of the Standards of Conduct
The general principles of the Standards of Conduct are as follows:
A. A Transmission Provider must treat all customers on a not unduly discriminatory
basis, and must not grant undue preferences, especially to its Affiliates;
B. A Transmission Provider’s TFEs must function independently from its Affiliate
C. A Transmission Provider must not disclose or use a conduit to disclose non-public
Transmission Function Information to its Affiliate MFEs; and
D. A Transmission Provider must provide equal access to non-public Transmission
Function Information to all its customers, except in the case of confidential customer
information or Critical Energy Infrastructure Information (CEII).
2 There are six (6) other Codes/Standards of Conduct that are applicable to Dominion Energy Affiliates,
including the FERC Code of Conduct (Affiliate Restrictions), the Virginia Commission Electric Retail Access
Codes of Conduct, the Virginia Commission Electric Functional Separation Code of Conduct, the North
Carolina Commission Code of Conduct, the Ohio Commission Gas LDC Standards of Conduct, and the
South Carolina Commission Code of Conduct. These Procedures are compatible with these other
Codes/Standards, but do not address those requirements. For further detail on these other Codes/Standards,
Dominion Energy employees may consult the Law Department’s Intranet Website. Also, additional
information relating to Dominion Energy’s general corporate compliance program is available on the
Dominion Energy Ethics Program Intranet site.
Date: April 29, 2019 Page 5
IV. General Rules & Requirements of the Standards of Conduct
The general rules and requirements of the Standards of Conduct include the following:
A. Non-Discrimination Requirements (See Section V below)
B. Independent Functioning Rule (See Section VI below)
C. No-Conduit Rule (See Section VII below)
D. Transparency Rule (See Section VIII and XI below)
V. Non-Discrimination Requirements
The Transmission Provider must treat all Transmission Customers, whether affiliated or
not, on a not unduly discriminatory basis, and must not operate its Transmission system
to give preferential benefits to its Marketing Affiliates. This requirement shall be
implemented pursuant to the following standards:
A. The Transmission Provider will strictly enforce all tariff provisions relating to the sale
or purchase of open access transmission service, if these tariff provisions do not
permit the use of discretion.
B. The Transmission Provider will apply all tariff provisions relating to the sale or
purchase of open transmission service in a fair and impartial manner that treats all
Transmission Customers in a non-discriminatory manner, if the tariff provisions
permit the use of discretion.
C. The Transmission Provider may not, through its tariff or otherwise, give undue
preference to any person in matters relating to the sale or purchase of transmission
service (included issues of price, curtailment, scheduling, priority, ancillary services
1. Tariff Waivers – To the extent the Transmission Provider waives a tariff provision
in favor of an Affiliate; it must be posted on its Internet Website. The
Transmission Provider must also maintain a log of such waivers which must be
retained for five years. “Exercises of discretion” that are allowed in the
Transmission Provider’s tariff, or which have been approved by the Commission,
do NOT have to be posted or recorded in the waiver log.
D. The Transmission Provider will process all similar requests for transmission service
in the same manner and within the same period of time.
VI. Independent Functioning Rule
A. GENERAL RULE: TFEs must function independently of any MFEs, which means
they shall not perform any Marketing Functions or perform any work for any MFE,
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except as noted below.
B. GENERAL RULE: MFEs will not conduct Transmission Functions for the
1. If TFEs work in the same building as MFEs, the TFE’s work space shall be
physically separated and restricted to the maximum extent practical from MFEs.
Shared facilities that staff both TFEs and MFEs are listed on the Internet
2. MFEs will not have access to the Transmission Provider’s Gas Control or
System Operations Centers, or any similar Transmission Provider facilities used
for day-to-day transmission operations or reliability functions that differs in any
way from the access available to other Transmission Customers. Access to
these facilities will be restricted by cardkey or other appropriate means on a 24-
3. MFEs will not have access to the Transmission Provider’s commercial function
and system operations area that differs in any way from the access available to
other Transmission Customers. Access to these facilities will be restricted by
cardkey or other appropriate means on a 24-hour basis. MFEs may have access
to these areas upon appropriate registration/sign-in and will be escorted
throughout the visit.
a. CardKey Access
(i) An automated “Employee Transfer/Termination Notification” program will
alert Cardkey administrators to revoke applicable facility access from
employees that have been transferred or terminated from a TFE position.
(ii) Dominion Energy’s Corporate Security or other appropriate personnel will
review cardkey access lists to ensure their accuracy.
4. Emergency Exception
In emergency circumstances affecting system reliability, the Transmission
Provider may take whatever steps necessary to keep or restore system
operation, including exchanging non-public Transmission Function Information
between TFEs and MFEs necessary to maintain or restore operation of the
transmission system or generating units, or that may affect the dispatch of
Record of Communication – Record must be made as soon as practicable.
Please refer to Section VII.D.1 for further details.
5. Reliability Standards Exception
Date: April 29, 2019 Page 7
In order to maintain compliance with the Reliability Standards approved by the
FERC, the Transmission Provider may exchange certain non-public
Transmission Function Information between TFEs and MFEs.
Record of Communication – Contemporaneous record must be made of the
exchange. Please refer to Section VII.D.1 for further details.
VII. No Conduit Rule
A. GENERAL RULE: The Transmission Provider is prohibited from using anyone as a
conduit for the disclosure of non-public Transmission Function Information to its
B. GENERAL RULE: Transmission Provider employees, contractors, consultants or
agents AND employees, contractors, consultants, or agents of an Affiliate with
MFEs are prohibited from disclosing non-public Transmission Function Information
VIII. Information Exchanges
A. Posting of Prohibited Disclosures:
1. Non-Public Transmission Information – The Transmission Provider must
immediately post non-public Transmission Function Information on the Internet
Website if the Transmission Provider inadvertently discloses such information to
2. Non-Public Transmission Customer Information and CEII – The Transmission
Provider must immediately post notice on the Internet Website that the Customer
Information or CEII information has been disclosed.
3. Exceptions to Posting:
a. Customer Voluntary Consent - If a non-affiliated transmission customer
consents in writing to allow the Transmission Provider to share its customer
information with an MFE, the Transmission Provider may share such
information. The Transmission Provider will post notice on the Internet
Website (EBB) of the consent along with a statement that it “did not provide
any preferences, either operational or rate-related, in exchange for the
b. Specific Requests Relating to Transmission Provider Service - The
Transmission Provider is not required to disclose on the Internet Website
information regarding a Marketing Affiliate’s specific request for transmission
service (i.e. confirmations, nominations, schedules with upstream producers,
Date: April 29, 2019 Page 8
interconnecting pipelines), including discussions with the Marketing Affiliate
with respect to the Marketing Affiliate’s participation in capacity expansion or
new development projects. This exception does not apply to outages or
other system conditions. The Law Department- Federal Regulation
recommends that a record of the meeting or communication be made and
retained as best practice. See Section VII.D.1.b. (ii) for further details.
c. Emergencies - The Transmission Provider may share non-public
Transmission Function Information between TFEs and MFEs to maintain or
restore operation of the transmission system or generating units. A record of
any such meetings or communications under this exception must be
maintained. See Section VII.D.1.b.(i) for further details.
d. Reliability Standards Compliance – The Transmission Provider may share
non-public Transmission Function Information between TFEs and MFEs
pertaining to compliance with NERC or other Reliability Standards approved
by FERC. A record of any such meetings or communications under this
exception must be maintained. See Section VII.D.1.b.(i) for further details.
B. Communications Between TFEs and MFEs:
1. GENERAL RULE: Order No. 717 and its regulations permit joint meetings
between TFEs and MFEs as long as non-public transmission function
information is not shared and the meetings do not relate to transmission or
marketing functions. A joint meeting includes, but is not limited to, face-to-face
meetings, telephone and conference calls.
a. Permitted Meetings or Communications Requiring Recordation between
TFEs and MFEs where non-public Transmission Function Information is
shared include the following limited situations (record of meeting or
communication must be made and retained):
(i) the topic of the meeting is in response to an emergency concern that
requires information sharing in order to maintain or restore operation of
the transmission system or generating units; or
(ii) the topic of the meeting is to share non-public transmission information
pertaining to compliance with FERC approved Reliability Standards. See
Section VII.D.1.b. (i) for further details on required recordation.
b. Record of Joint Meetings between TFEs and MFEs
(i) Required Recordation - For exchanges between TFEs and MFEs that are
permissible under Section VII.D.1.a, a contemporaneous record must be
made and maintained for a period of five years. The record may consist of
hand-written or typed notes, electronic records such as e-mails and text
messages, recorded telephone exchanges, and the like; however, the
Date: April 29, 2019 Page 9
record must be retrievable. In an emergency when a contemporaneous
record cannot be made, the record must be made as soon as practicable
after the fact.
(ii) Recommended Recordation – For exchanges between TFEs and MFEs
that are permissible and where non-public Transmission Function
Information is not disclosed, the Law Department recommends a
contemporaneous record be made and maintained for a period of five
years as best practice.3 The record may consist of hand-written or typed
notes, electronic records such as e-mails and text messages, recorded
telephone exchanges, and the like.
(iii) The Law Department recommends that Employees follow the Joint
Meeting Procedures and Checklists which are available on the Law
Department Intranet Website as best practice for both required and
recommended recordation of a meeting or communication between TFEs
(iv) Employees attending the joint meeting must be reminded to comply with
the restrictions on the exchange of Transmission Function Information
beyond what is allowed by the rules and regulations of FERC. Further,
the joint meeting should only be held if the topic of the meeting is one of
the topics permissible as identified in the Joint Meeting Procedures and
Checklists. If it is unclear whether the topic is permissible, seek
clearance from the Law Department - Federal Regulation.
C. Information Access “Best Practices”:
1. To implement the no-conduit requirement, the following “best practices”
procedures should be followed by the Transmission Provider to ensure proper
access to non-public transmission information:
a. The Transmission Provider should use the Internet Website to publicly
disseminate to transmission customers, including its Marketing Affiliates,
information required to be posted pursuant to the Standards of Conduct or
other Commission regulations. All postings shall comply, if applicable, with
the requirements of Part 284 of FERC’s regulations.
b. Dominion Energy’s IT department has erected and maintains appropriate
password requirements, firewalls, and other security measures for all
Transmission Provider’s information systems. The IT department should
3 The Law Department has prepared Joint Meeting Procedures and Checklists that are recommended for all
Dominion Energy Employees to use. The Joint Meeting Procedures and Checklists provide a list of
permissible exchanges between TFEs and MFEs. Intranet Website link to Gas Joint Meeting & Checklist and
Electric Joint Meeting & Checklist
Date: April 29, 2019 Page 10
conduct a periodic review of passwords, firewalls, and other security
measures to ensure that the integrity of the information systems is
maintained. Such measures include:
(i) Transmission Function Information that is accessible via Dominion
Energy’s Intranet Website shall be protected from access by MFEs. The
IT department will ensure that the appropriate MFEs do not have access
to Transmission Function Information on Dominion Energy’s Intranet
(ii) Transmission Function Information accessible via Dominion Energy’s
computer systems shall be protected from access by MFEs. MFEs are
identified with an “M” after their name in the telephone directory and email.
TFEs are identified with a “T” after their name in the telephone
directory and e-mail.
(iii) An automated program monitors employee terminations and transfers
daily and sends a notification to the CCO (or its designee) or applicable
system administrators when a qualifying event occurs. When applicable,
the CCO (or its designee) will adjust access to all affected computer
systems, physical facilities and employee e-mail addresses to prevent
inclusion on prior distribution lists.
IX. Additional Employee Responsibilities
1. All Dominion Energy employees are individually responsible for strict
compliance with Standards of Conduct and these Procedures. Dominion
Energy does not condone or tolerate violations of the Standards of Conduct.
Employees who fail to comply with these Standards of Conducts may be
subject to disciplinary actions up to, and including, termination. In addition to
the requirements set forth in these Procedures, all employees are asked
when appropriate to consider the safeguards described below.
2. Prior to sharing Transmission Function Information with any Dominion Energy
Employee outside of the Transmission Provider organization, employees should
check to see whether the recipient is allowed to receive the Transmission
Function Information under Standards of Conduct. If you are unsure about
whether the information is Transmission Function Information, or whether the
requestor is an MFE, consult the Company Directory, ask your supervisor or
contact the Law Department - Federal Regulation.
3. Employees should clearly mark all e-mails, documents or other communications
that contain Transmission Function Information with the following header or
another substantially similar message: “This communication contains FERC
Date: April 29, 2019 Page 11
Order 717 Transmission Function Information that must be kept
confidential. DO NOT copy or forward to any Marketing Function
Employee without express clearance from Dominion Energy’s Law
4. When possible, Employees should protect Transmission Function Information
that is sent via an electronic method with passwords or non-copying/nonforwarding
features enabled. Employees are encouraged to use the Code of
Conduct Classification Tool within the Company’s electronic mail application.
This functionality enables users to easily classify messages that contain
sensitive content, such as Transmission Function Information. Once the sender
marks a message as sensitive and the message is sent, the mail system
validates each recipient prior to delivery to prevent any violation. This tool is
available to all Dominion Energy Employees. Employees can find more
information on this tool on the FERC Policy and Compliance SharePoint site on
Dominion Energy’s Intranet Website.
5. All Employees also must strictly comply with the “No Conduit” rule. The “No
Conduit” rule means that although certain employees may have access to
Transmission Function Information, they may never be a “conduit” or pass this
Transmission Function Information to MFEs. In particular, employees of
Marketing Affiliates who are not considered MFEs must be diligent not to pass
any Transmission Function Information to MFEs. Also, employees who provide
a corporate service function for both the Transmission Provider and Marketing
Affiliates should not pass Transmission Function Information to any MFE.
6. In summary, Employees should abide by the following requirements:
Know the extent of access you have to Transmission Function Information.
Never act as a “conduit” by providing this information to an MFE.
If you are uncertain about whether the information is Transmission Function
Information, or whether the requestor is an MFE, consult the Company
Directory, ask your supervisor, or the Law Department - Federal Regulation.
Make sure Transmission Function Information received from the
Transmission Provider is clearly marked as such to prevent inadvertent
sharing of information.
Err on the side of caution by playing it safe and sharing Transmission
Function Information only with employees who are clearly TFEs.
B. Marketing Function Employees:
1. MFEs must be aware of the information restrictions and the Independent
Functioning Rules that apply between TFEs and MFEs. Generally, MFEs may
not have access to Transmission Function Information unless it is obtained via a
public source (e.g., the Internet Website). Also, MFEs must operate separately
Date: April 29, 2019 Page 12
from the TFEs.
2. In practice, MFEs should abide by the following requirements:
Do not gain or attempt to gain access to Transmission facilities, including
computer systems, or Transmission Function Information by any means. If
you have access to Transmission facilities or Transmission Function
Information or if you feel you have received access inappropriately, do not
review the information and report the incident immediately to your supervisor,
or the Law Department - Federal Regulation.
If Transmission Function Information is obtained inadvertently or otherwise in
violation of the Standards of Conduct or these Procedures, do not use the
information in any capacity and report the incident immediately to your
supervisor, or the Law Department - Federal Regulation.
X. Chief Compliance Officer (CCO) Responsibilities.
A. Duties of the CCO (or its designee) include:
1. Identify and maintain a list of employees that must receive Standards of Conduct
training. Ensure that all affected employees receive the necessary training on an
2. Provide guidance on the FERC Standards of Conduct to all affected employees.
3. Monitor employee transfers between various Dominion Energy companies and
departments. Ensure that appropriate actions are taken for employees that
transfer into or out of the Transmission Provider organization and change from
TFEs to MFEs, and vice versa. Actions include necessary postings on Internet
Website and restrictions to facilities, including any computer systems.
4. Ensure proper documentation of Standards of Conduct issues and matters.
Ensure that documentation is retained for requisite statutory period.
5. Monitor and update informational postings to ensure that data is current and
correct, consistent with the procedures described in Section 0 below.
XI. Informational Posting Procedures
A. Information to be Posted:
The following information shall be maintained on the Internet Website by the CCO (or
its designee). The CCO will update this information within seven business days of any
change and will post the date the information was updated.
Date: April 29, 2019 Page 13
1. Names and addresses of Marketing Affiliates. This information will be derived
and kept current through communications with the Dominion Energy Corporate
2. Complete list of employee-staffed facilities that are shared by both TFEs and
3. The job titles and job descriptions of all TFEs.
4. Name and address of potential merger partners to the Transmission Providers
that may employ or retain MFEs, within seven days after the potential merger is
announced. For purposes of the Standards of Conduct, once a potential merger
is announced the Standards of Conduct will apply as if the entity were already
acquired or merged.
5. Information on employee transfers. The name of a TFE that transfers to a
position as an MFE, or any transfer of an MFE to a position as a TFE. The
information must be posted on the Internet Website for 90 days, and include the
name of the transferring employee, the respective title held in the Transmission
Function and Marketing Affiliate, and the effective date of the transfer. This
information will be derived and kept current by Human Resources’ information
provided via automated reports.
6. Information Disclosure. The Transmission Providers must immediately post any
non-public Transmission Function Information, non-public Transmission
Customer Information or CEII that was disclosed to MFEs. See Section VII.C
7. Waivers. Notice of each waiver of a tariff provision that a Transmission Provider
grants in favor of an Affiliate, unless such waiver has been approved by the
FERC. See Section V.C.1 above.
8. Name of Chief Compliance Officer. Name and contact information of Dominion
Energy’s FERC Standards of Conduct CCO.
9. Notice of Customer Voluntary Consent. Notice of customer voluntary consent to
allow the Transmission Provider to disclose customer information to MFEs. See
Section VII.C.3.a above.
10. These Procedures. These Procedures will be kept current by the Law
Department in conjunction with the CCO and the Transmission Providers.
XII. Training Procedures.
A. Written Procedures:
Date: April 29, 2019 Page 14
1. The following employees will receive an Intranet Website link to provide
assistance and guidance on compliance. The link will include documents
related to Standards and Codes of Conduct, helpful tools/guides and frequently
asked questions. It will also include these Procedures:
Transmission Function Employees.
Marketing Function Employees.
Officers, Directors, Supervisory and other employees of the Transmission
Providers who are likely to become to privy to Transmission Function
Officers, Directors, Supervisory and other employees of Affiliates of Dominion
Energy (include Services Company Employees) to the extent they are likely
to become privy to Transmission Function Information.
2. All Employees of Dominion Energy have access to these Procedures through
the Internet Website or the searchable Intranet Website.
1. The following employees will be trained regarding FERC Standards of Conduct
annually. These employees are required to certify (by signature or electronic
certification) that they have participated in training:
Transmission Function Employees;
Marketing Function Employees;
Officers, Directors, Supervisory and other employees, contractors, or agents
of the Transmission Providers who are likely to become to privy to
Transmission Function Information; and
Officers, Directors, Supervisory and other employees, contractors, or agents
of Affiliates of Dominion Energy (include Services Company Employees) to
the extent they are likely to become privy to Transmission Function
2. New Employees
New TFEs, MFEs, officers, directors, supervisory employees, and any other
employees, contractors, or agents likely to become privy to Transmission
Function Information will be trained as soon as possible upon commencing
employment, but no later than thirty (30) days after commencement. These
employees are required to certify (by signature or electronic certification) that
they have completed the training.
Date: April 29, 2019 Page 15
FERC has the ability to impose fines of over $1 million per day per violation.
B. Dominion Energy’s Commitment to Compliance:
Dominion Energy does not condone and will not tolerate violations of the Standards
of Conduct. Employees that violate the Standards will be subject to disciplinary
action, up to and including termination.
Employees should report any concerns immediately to your supervisor or the Law
Department - Federal Regulation.
Regulatory Compliance Coordinator:
Nancy W. Adams 8-738-2534 or 804-819-2534
Senior Counsel – Gas:
Lois Henry 8-738-2946 or 804-819-2946
Senior Counsel – Electric:
Cheri Yochelson 8-738-2691 or 804-819-2691
Dominion Energy Compliance Line: 800-628-1798
Dominion Energy Compliance Online: