Freeda Cathcart, FLMI, Dominion Energy Shareholder and Energy Investor

Kimberly D. Bose, Secretary

Federal Energy Regulatory Commission
888 First Street, NE
Washington, DC 20426
Dominion Shareholder Objection to Request for an Extension of Time by Atlantic Coast
Pipeline,
Docket Numbers: CP15-554-000, CP15-554-001, CP15-555-000

July 2, 2020

Dear Ms. Kimberly Bose:

Please formally record my OBJECTION as a Dominion shareholder to the Request for an

Extension of Time, by Dominion Transmission and Atlantic Coast Pipeline​, LLC, dated
June 17, 2020
(Docket #s: CP15-554-000; CP15-554-001; CP15-555-000).

When the ACP received FERC’s certification of necessity the project was predicted to cost $5.1
billion and was expected to be completed in 2019. Now, ​Dominion is estimating the cost will
be $8 billion and is hoping it will be completed in 2022​. ​It would be irresponsible for
FERC to renew the certification for necessity without an updated economic analysis and
a new environmental impact statement as well as allowing ample opportunity for the
public to comment on the new information.

I became a Dominion Energy shareholder after the SCANA merger due to the ​V.C. Summer
boondoggle​. Before the merger was completed I hand delivered a letter of concern to
Dominion’s Board of Directors about the Atlantic Coast Pipeline and asked them to conduct an
economic analysis for the necessity of the project. Other shareholders have also requested
Dominion to reevaluate the project based on our changing economy and environment. All of our
requests have been ignored and Dominion has even suppressed shareholders from being able
to bring their concerns to other shareholders through resolutions to be voted on during
Dominion’s annual shareholder meeting.

In Dominion’s response to my question at this year’s shareholder meeting, they cite that they
aren’t going to do an economic analysis for the Atlantic Coast Pipeline because the Hampton
Roads area needs it. This is a puzzling claim since methane is an accelerant of climate change
and the Hampton Roads area is already experiencing severe repercussions from sea level
rising and the recent increase of extreme storms. According to a June 14, 2020 ​Virginia Pilot
article:
​ ince 1960, Hampton Roads has seen more than a foot of sea level rise, according to tide
“S
gauge data from Norfolk’s Sewell’s Point. The rate of rise has been accelerating in recent years
and is projected to become even steeper in the coming decades, according to a recent report by
the Virginia Institute of Marine Science. The city is also seeing significant storms more often.”

The area that Dominion is claiming they need to serve might literally be underwater or close to it
by the time the project is completed. It also looks like Virginia’s new wind farm reported in this
June 29, 2020 ​Virginia Business article​ might blow away any necessity for the Atlantic Coast
Pipeline. Solar farms also have a bright future in the Tidewater (Hampton Roads) region
according to this November 12, 2019 ​Virginia Gazette article​: “​Pitched as a clean-energy
alternative to fossil fuels, solar farms have been established in the Tidewater area to supply
electricity to users ranging from a state university to Amazon.​”

When Dominion’s CEO Tom Farrell claims gas is needed when the wind isn’t blowing and the
sun isn’t shining, it’s because he is ignoring the storage battery revolution that is bringing energy
at a lower cost to utility customers. This July 11, 2019 Science article ​Giant batteries and cheap
solar power are shoving fossil fuels off the grid​:
“​Goodnight #naturalgas, goodnight #coal, goodnight #nuclear," Mark Jacobson, an atmospheric 
scientist at Stanford University in Palo Alto, California, tweeted after news of the deal surfaced 
late last month. "Because of growing economies of scale, prices for renewables and batteries 
keep coming down," adds Jacobson, who has advised countries around the world on how to shift 
to 100% renewable electricity. As if on cue, last week a major U.S. coal company—West 
Virginia–based Revelation Energy LLC—filed for bankruptcy, the second in as many weeks.” 
 
Since then there have been many articles in financial journals documenting the demise of the 
gas industry before the pandemic including the following: 
November 25, 2019 Oil Price: Why The Latest Shale Bust Is Different 
 
December 11, 2019 New York Times Natural Gas Boom Fizzles as a U.S. Glut Sinks Profits 
 
January 19, 2020 World Oil: America is awash with natural gas, and it’s about to get worse 
 
February 5, 2020 CME Group Natural Gas: The Bust Within the Boom 
 
 
After the pandemic: 
April 30, 2019 CNBC News: Energy demand, hit by coronavirus crisis, is set to see record drop 
this year, IEA says 
 
May 11, 2020 New York Times: Natural Gas Exports Slow as Pandemic Reduces Global 
Demand 
 
May 22, 2020 Financial Times Boom to bust in the US shale heartlands 
 
Considering the pandemic has dramatically slowed the U.S. economy and lowered the demand 
on energy, it would be reasonable to expect Dominion and Duke to conduct an economic 
analysis on whether the Atlantic Coast Pipeline is a viable project. Unfortunately Dominion has 
not acted responsibly in the past and has repeatedly ignored their shareholders and customers 
who have asked for an updated economic analysis for the ACP. In 2018 the Virginia State 
Corporation Commission shocked the energy industry when it rejected Dominion’s Integrated 
Resource Plan for the first time, their decision contained the following footnote: 
“​The record reflects that the Company did not include fuel transportation costs in the modeled
costs of certain natural gas generation facilities. Tr. 610. For purposes of the corrected 2018
IRP, the Company should include a reasonable estimate of fuel transportation costs, including
interruptible transportation, if applicable, associated with all natural gas generation facilities
in addition to the fuel commodity costs.”

As an energy investor, it looks like ACP is on track to be another boondoggle that would
hurt shareholders and customers.
 
It’s imperative for FERC to reject the renewal for the Atlantic Coast Pipeline.​ Too much
has changed in recent years and too much is at stake for a simple renewal process. ​The
Atlantic Coast Pipeline needs to be required to apply to FERC for a new certificate of
necessity.

Below is the documentation that was mentioned in the body of my letter of the shareholders and
customers trying to hold Dominion accountable for the Atlantic Coast Pipeline project.

Thank you for your consideration.

Respectfully submitted,
Freeda Cathcart 
Freeda Cathcart

____________________________________________________________________________________

(Received on May 18 from Dominion in response to Freeda Cathcart’s questions submitted during the
shareholder annual meeting, I added the bolding for emphasis.)

Thank you for being part of the Dominion Energy, Inc. 2020 Annual Meeting of Shareholders.
Due to time limitations, we were unable to respond to all of the questions that were submitted
for the Annual Meeting, including yours. We would like to take this time to follow up with you
regarding your questions.

Q. Recently Berkshire Hathaway abandoned a $9 billion LNG infrastructure project.

Foreign importers have cancelled or delayed shipments of LNG. There's a glut of gas
 in the domestic market especially in the Marcellus shale. Southern Company sold
their stake in the ACP to Dominion. This past December the New York Times article,
Natural Gas Boom Fizzles as a U.S. Glut Sinks Profits, warned against the need for
new gas infrastructure. “Nowhere are the declining fortunes of natural gas more in
evidence than in Appalachia where the Marcellus field centered in central and
western Pennsylvania was once viewed as the most promising in North America."
The sooner Dominion shelves or abandons the Atlantic Coast Pipeline the
sooner our shareholder values will be protected from the growing cost of an
inevitable stranded asset. When was the last time Dominion did an economic
analysis on the marketability for capacity on the ACP? What action is Dominion
taking to protect shareholders from losing share values due to a stranded asset
as large as the ACP?
Q. A new research report by Friends of the Earth and NC WARN shows that the
coronavirus pandemic has only amplified the Atlantic Coast Pipeline's current
problems, which would bring fracked gas through West Virginia, Virginia, and North
Carolina and cost energy customers $30 billion. Have you seen this report and how
do you respond to its advice to recognize the imprudence of pouring billions more
dollars into the ACP, and cancel what many already call a deeply unsound
investment?

Regarding your first question, Dominion Energy does not plan to commission such a
study.​ Regarding your second question, the Company is aware of this report. The Atlantic
Coast Pipeline continues to be a necessary investment for electric reliability, natural gas service
to homes and businesses, and manufacturing. The need is particularly acute in Hampton
Roads, Virginia – the state’s industrial heartland and a vital region for national defense. Efficient,
low-emissions natural gas generation will remain a part of our fleet for the foreseeable future,
given the technology available today. It is needed to ensure reliability and security of electric
service until and unless advances in renewable energy and battery storage allow those
resources to meet our customers’ around-the-clock needs. Chronic gas shortages in Hampton
Roads are driving up costs for electric customers and resulting in curtailment of service to major
industries and critical national security installations. These are current, pressing issues that the
Atlantic Coast Pipeline will help address.
___________________________________________________________________________________

(Diana Smith submitted the following defense of her resolution to Dominion shareholders to the SEC.
The SEC ruled that Dominion could deny including the resolution based on vagueness but it was up to
Dominion to decide if they had already implemented the request. Dominion did not allow the
resolution to be presented at the shareholder’s annual meeting.)

(Dominion shareholder defense for resolution)

Securities and Exchange Commission

Division of Corporation Finance
Office of the Chief Counsel
100 F Street, N. E.
Washington, D.C. 20549
By electronic submission to ​shareholderproposals@sec.gov

Re: Dominion’s Intent to Omit Shareholder Proposal Submitted by Diana Smith

Ladies and Gentlemen:

This is in response to the “no-action” request sent to the SEC by Katherine DeLuca of McGuire Woods on
behalf of Dominion Energy Inc. on December 30, 2019, regarding my proposal.

I submitted a shareholder proposal (hereinafter referred to as the “Proposal”) to Dominion Energy, Inc.
(hereinafter referred to as “Dominion” or the “Company”). This letter is in response to the letter dated
December 30, 2019 (hereinafter called “no-action request”) sent to the Office of Chief Counsel by the
Company, in which Dominion contends that the proposal may be excluded from the Company’s 2020
proxy statement by virtue of Rule 14a-8(i)(3) and Rule 14a-8(i)(10).

I request that the proposal not be excluded from the proxy materials for the 2020 Annual Meeting of
Shareholders, and I request that the SEC take action if Dominion does maintain their intent to exclude it.
I would also like to respond to the statements in the no-action request.

A copy of this letter is being mailed concurrently to Katherine DeLuca of McGuire Woods and
Dominion’s Karen W. Doggett, Assistant Corporate Secretary and Director – Governance

Responses are organized based on the order of the sections in the no-action request:

A. “Impermissibly vague and indefinite”

Dominion contends that this proposal is vague and indefinite. ​The method of response for evaluating
human rights and climate justice was left open to the best judgement of the Company, so as not to be
micro-managing the Company in its daily business. But, asking for an evaluation is not vague, it just
leaves open whether the Company chooses to publish that evaluation in a report, website, or simply a
letter to shareholders. The proposal is specific in that it asks Dominion to evaluate areas ​such as​:

● if and how the board oversees environmental risks and opportunities;

● if and how executive compensation is linked to environmental and social objectives;
 ● if and how Dominion is addressing pollution prevention;
● if and how Dominion is addressing water conservation;
● if and how Dominion is addressing carbon footprint;
● if and how Dominion is addressing gender diversity;
● if and how Dominion is addressing data privacy;
● if and how Dominion is addressing consumer health;
● if and how Dominion is addressing ethical practices;
● if and how Dominion is addressing conflict materials;
● if and how Dominion is addressing forced labor.

The submission of shareholder proposals are the opportunity for shareholders to have concerns
addressed by the company and if they are not sufficiently allayed through communication between the
shareholder who submitted the proposal and the company, then it is presented in the annual report’s
proxy and if the board votes to oppose the proposal then the shareholder can defend the proposal in the
annual shareholder meeting before the vote. Dominion’s objection to the SCC did not include the following
pertinent information from the proposal:

“The US SIF Foundation’s 2018 Report on US Sustainable, Responsible and Impact Investing Trends
reports:

● Sustainable, responsible and impact investing (SRI) assets have expanded to $12.0 trillion in the
United States, up 38 percent from $8.7 trillion in 2016
● Much of this growth is driven by asset managers, who now consider environmental, social or
corporate governance (ESG) criteria across $11.6 trillion in assets, up 44 percent from $8.1
trillion in 2016.
● The top three issues for asset managers and their institutional investor clients are climate
change/carbon, tobacco and conflict risk.
● This demonstrates a high level of interest from investors and the public in corporate social
responsibility.

Shareholders are concerned about the potential risks of the continuing social issues and escalating costs
associated with the Appalachian Coast Pipeline (ACP). The 2018 report ​“Social Cost and​ ​Material Loss:
The Dakota Access Pipeline”​ is a warning for the fiscal risk of the Atlantic Coast Pipeline. The final cost of
DAPL was nearly double the initial project cost. “The banks that financed DAPL incurred an additional
$4.4 billion in costs in the form of account closures, not including costs related to representational
damage.”

B. “Materially false and misleading”

The proposal includes links to reports that substantiate the information in the proposal. Dominion has
submitted no evidence to contradict the information in the proposal. The purpose of including the
financial perils the investors in the Dakota Access Pipeline experienced is to illustrate what befalls a
company that doesn’t proactively address environmental justice, climate justice and human rights. The
Dakota Access Pipeline has the trifecta of each area being involved in their project that resulted in
severe consequences. The shareholders would like the Company to learn from the mistakes of others
and proceed accordingly with best management practices.

C. “Already substantially implemented the Proposal”

Dominion’s record is incongruent from what is posted on their​ website​.

“In 2018, the company adopted the following Environmental Justice Policy to guide our work in this
area:
ENVIRONMENTAL JUSTICE: ONGOING COMMITMENT TO OUR COMMUNITIES
At Dominion Energy, we are committed to providing reliable, affordable, clean energy in accordance
with our values of safety, ethics, excellence, embrace change and team work. This includes
listening to and learning all we can from the communities we are privileged to serve.
Our values also recognize that Environmental justice considerations must be part of our everyday
decisions, community outreach and evaluations as we move forward with projects to modernize
the generation and delivery of energy.”

If this policy was adequately followed, then the Union Hill compressor plan would not have been
actuated. On ​January 8, 2019 Dominion proceeded with their request to have the Union Hill compressor
station air permit approved​. A little over a month later former Vice-President Al Gore and Bishop
William Barber spoke at a rally in Union Hill attended by hundreds of people. Coverage on the rally was
the following from this ​Daily Progress article​:

​ ore, a director of the Climate Reality Project, contended the pipeline would boost greenhouse gas
“G
emissions by 40 percent a year at the expense of monopoly ratepayers of Dominion Energy
Virginia, the state’s largest electric utility. “It is a world-class rip-off of Virginia energy
ratepayers,” he said.”

Since this proposal was submitted the​ 4th Circuit Court of Appeals has vacated the Air Pollution Control
Board permit for Dominion’s Atlantic Coast Pipeline’s compressor station​ due to environmental justice
(hereinafter referred to as EJ) concerns. The following statement was in the ruling:

“The Board’s reliance on air quality standards led it to dismiss EJ concerns. Even if all pollutants within
the county remain below state and national air quality standards, the Board failed to grapple with the
likelihood that those living closest to the Compressor Station -- an overwhelmingly minority population
according to the Friends of Buckingham Survey -- will be affected more than those living in other parts of
the same county. The Board rejected the idea of disproportionate impact on the basis that air quality
standards were met. But environmental justice is not merely a box to be checked, and the Board’s
failure to consider the disproportionate impact on those closest to the Compressor Station resulted in a
flawed analysis....What matters is whether the Board has performed its statutory duty to determine
whether this facility is suitable for this site, in light of EJ and potential health risks for the people of
Union Hill. It has not.”

The Fourth Circuit Court of Appeals vacating of the ACP permit resulted in this negative publicity against
Dominion published in the New York Times ​Environmental Justice Is Not Merely a Box To Be Checked
which included the following:

“At a bare minimum, ensuring environmental justice in this case required Dominion and regulators to
consider how economically disadvantaged or minority communities — like Union Hill — would be
affected. Communities of color and people with fewer financial resources have often borne the
brunt of pollution and other environmental burdens. Dominion and regulators should also have
given serious consideration to an electric compressor that would nearly eliminate air pollution from
the facility. They did neither. Instead of honoring Union Hill’s past and present, the state’s most
powerful forces essentially denied its existence. The courts did​ not.”

Another recent development is the amicus brief Virginia’s Attorney General Mark Herring filed with the
Supreme Court opposing the ACP. His opposition includes climate justice by protesting the pipeline is
not necessary and the escalating costs will be unfairly passed on to Dominion’s customers. From the
January 22, 2020 article ​Virginia AG Files Supreme Court Brief Opposing Atlantic Coast Pipeline:​

“Virginia Attorney General Mark Herring on Wednesday filed a brief in the Atlantic Coast natural gas
pipeline case at the U.S. Supreme Court opposing construction of Dominion Energy Inc's $7.3-$7.8
billion project … Herring, however, questioned whether the project is needed, citing numerous
sources that indicate gas demand is actually decreasing, and that renewable energies are
becoming more cost competitive. "The ever-rising costs of building [the pipeline] will be passed on
to consumers, by the companies that have contracted with Atlantic to carry gas through the
pipeline." When Dominion started work on the 1.5 billion cubic feet per day pipe in the spring of
2018, the company estimated it would cost $6.0-$6.5 billion and be completed in late 2019.”

Dominion Energy has made promises that reports indicate haven’t been fulfilled in funding energy
efficiency to help lower costs for consumers. From this May 2019 article ​Dominion needs to ramp up
efficiency programs to hit mandate, advocates say​:
“Virginia has a voluntary legislative goal to reduce electricity use 10% between 2006 and 2022. The state
is on track to achieve less than one-third of that marker, according to 2018 math by the
Department of Mines, Minerals and Energy. ​ACEEE’s State Energy Efficiency Scorecard shows
Virginia tied for last — in all but one year over the last decade — when measuring spending on
energy efficiency programs as a percentage of electric utility revenue. Dominion ranked 50th
out of 51 utilities in ​ACEEE’s 2017 Utility Energy Efficiency Scorecard.​ ​“Utilities want to sell as
much electricity as possible, so they don’t see the reward in delivering these programs,”
Shoemaker said. ‘That’s where legislation and direction from regulators come in.’”

While the new energy efficiency program Dominion rolled out this past fall looks promising as described
in an article published in The Virginia Energy Efficiency Council by “​Honeywell (the program manager for
Dominion’s newest residential energy efficiency program), the following statement in the article appears
to be incongruent with the bolded statement above:

“All approved programs are part of the $870 million of energy efficiency programs that Dominion Energy
is required to propose over a 10-year period, as ordered by the Grid Transformation & Security
Act of 2018. T​ he landmark legislation will keep Virginia’s traditional advantage of low
electricity prices and reliable service while taking dramatic steps towards the future by
expanding renewable energy an​d broadening the potential for energy efficiency programs in
Virginia.​”

An evaluation by Dominion addressing this incongruency could reassure shareholders that Dominion’s
policies were being acted on as intended and having the results to meet required goals.

After having a conversation about the proposal with Dominion including a follow up email (Exhibit A),
their focus was on sustainability and political transparency. I care about environmental sustainability
and political transparency but those are different categories than EJ, climate justice and human rights.

For instance the United States lags behind Europe regarding data privacy laws. I was very concerned
after reading ​Censible’s ratings for Dominion​ that they didn’t even have a rating for data privacy. From
an article on the European Union​ “c​omprehensive data protection laws are essential for protecting
human rights – most obviously, the right to privacy, but also many related freedoms that depend on our
ability to make choices about how and with whom we share information about ourselves. The European
Union ​General Data Protection Regulation​ (​GDPR​) is one of the strongest and most comprehensive
attempts globally to regulate the collection and use of personal data by both governments and the
private sector.”

Shareholders trust Dominion with our social security numbers which if hacked would make us vulnerable
to victims of fraud and identity theft. If the company has been proactive and has made progress since
the Censible article was published then it is Dominion’s responsibility to report that to reassure the
shareholders. Consider this recent report from ​Government Technology​ November 27, 2019, “​More
than a dozen U.S. utilities were targeted in a wave of cyber attacks within the past year…. The U.S.
government has warned the U.S. electricity grid is an inviting target for overseas hackers. National
security officials have identified Russia and China as having the ability to temporarily disrupt the
operations of electric utilities and gas pipelines.”

Upguard’s January 22, 2020 security report on Dominion​ gave the company a score of 689 and listed the
following failed checks: “domain at risk of being hi-jacked, susceptible to man-in-the-middle attacks,
vulnerable to cross-site scripting, DNS is susceptible to man-in-the-middle attacks.” This news story
Dominion Energy bill phone scam​ c​ laims power to be turned off​ ​is from December 3, 2019. Data security
and privacy are important matters of concern to shareholders and customers.

It’s fine for the Company to put policies on the website and publish articles on them. It’s more important
the Company follows through with the policies to create the results the policies were created to
address. Having a policy on a website is not an indicator that it is being implemented successfully,
especially when financial or industry journals report that the Company has failing scores.

Additional information:
The purpose of Rule 14a-8 “is to provide and regulate a channel of communication among shareholders
and public companies.” Exchange Act Release No. 34-40018 (May 21, 1998). “The SEC continues to
implement Congress' goals by providing shareholders with the right to communicate with other
shareholders and with management through the dissemination of proxy material on matters of broad
social import such as plant closings, tobacco production, cigarette advertising and executive
compensation.” ​Amalgamated Clothing and Textile Workers Union v. Wal-Mart Stores, Inc.​ , 821 F. Supp.
877 (S.D.N.Y. 1993). “In so far as the shareholder has contributed an asset of value to the corporate
venture, in so far as he has handed over his goods and property and money for use and increase, he has
not only the clear right, but more to the point, perhaps, he has the stringent duty to exercise control
over that asset for which he must keep care, guard, guide, and in general be held seriously responsible.
As much as one may surrender the immediate disposition of (his) goods, he can never shirk a
supervisory and secondary duty (not just a right) to make sure these goods are used justly, morally and
beneficially.” ​Medical Committee for Human Rights v. SEC,​ 432 F. 2d. 659, 680-681 (D. C. Cir. 1970),
vacated and dismissed as moot​, 404 U.S. 402 (1972).

As explained in ​Roosevelt v. E.I. DuPont de Nemours & Company​, 958 F. 2d 416, 426 (D. C. Cir. 1992) a
proposal may not be excluded if it has "significant policy, economic or other implications". Interpreting
that standard, the court spoke of actions which are "extraordinary, i.e., one involving 'fundamental
business strategy' or 'long term goals.'" ​Id.​ at 427. Dominion’s argument that the Proposal is vague and
indefinite is irrelevant. All proposals must respect the Company’s management to implement them.
Rather, “the proposal may be excluded only after the proposal is also found to raise no substantial policy
consideration.”

Further clarity is provided by the Exchange Act Release No. 34-40018 (May 21, 1998), which provides
that "Ordinary Business" determinations would hinge on two factors: 1) Subject Matter of the Proposal:
"Certain tasks are so fundamental to management's ability to run a company on a day-to-day basis that
they could not, as a practical matter, be subject to direct shareholder oversight. Examples include the
management of the workforce, such as hiring, promotion, and termination of employees, decisions on
the production quality and quantity, and the retention of suppliers. [2)] However, proposals relating to
such matters but focusing on sufficiently significant social policy issues (e.g., significant discrimination
matters) generally would not be considered to be excludable, because the proposals would transcend
the day-to-day business matters and raise policy issues so significant that it would be appropriate for a
shareholder vote" (bracketed material added).

Conclusion:

As demonstrated above, the Proposal should not be excluded under Rule 14a-8(i)(3) on the grounds that
it is vague and indefinite. ​The method of response for evaluating human rights and climate justice was
left open to the best judgement of the Company, so as not to be micro-managing the Company in its
daily business. But, asking for an evaluation is not vague. The Company may choose to publish that
evaluation in a report, website, or simply a letter to shareholders. The proposal is specific in that it asks
Dominion to evaluate identified areas of concern to shareholders.

The proposal is not excludable under Rule 14a-9 because the proposal is not misleading or false. The
proposal is not excludable under Rule 14a-8(i)(10) because the company has not proven they have
implemented policies to allay the concerns addressed in the proposal. ​The Proposal relates to a
significant policy issues, there is a nexus between the Proposal and the Company, and it seeks the
Company to address shareholders concerns by evaluating specified areas regarding environmental
justice, climate justice and human rights. For these reasons we request the Staff inform the Company
that the SEC proxy rules require denial of the Company’s no-action request.

Sincerely,

(Dominion shareholder)

Exhibit A
On Thu, Jan 16, 2020 at 5:31 PM ​karen.doggett@dominionenergy.com
<​karen.doggett@dominionenergy.com​> wrote:

Dear Diana,

We appreciate the opportunity to speak with you yesterday. We found the dialogue constructive and
helpful in understanding your concerns. As discussed, here is a link to our 2019 and Beyond
Commitments that are included in our Sustainability and Corporate Responsibility Report,
https://sustainability.dominionenergy.com/commitments/​. You can also find our 2018 Commitments
and our performance against those commitments
at​https://sustainability.dominionenergy.com/commitments/commitments-2018/​.

During our conversation, Blake mentioned that Dominion Energy has been recognized as a leader in
political transparency by The Center for Political Accountability (CPA), a non-partisan advocacy
organization that promotes political disclosure and accountability by corporations, and the Zicklin Center
for Business Ethics Research at the University of Pennsylvania. The CPA-Zicklin Index lists Dominion
Energy as a Trendsetter — the highest of six classifications — and ranks the company in the top 10
percent of the nearly 500 companies it analyzed. This is the second year in a row the report has included
Dominion Energy in the Trendsetter category. The 2019 report can be accessed at this link,
https://politicalaccountability.net/hifi/files/2019-CPA-Zicklin-Index-Report.pdf​.

Dominion Energy considers political transparency an essential part of its focus on environmental, social
and governance (ESG) concerns. Some of the practices that earned the company its score include:

· Publicly and voluntarily posting on its website

(​https://www.dominionenergy.com/company/governance/political-contributions​) contributions to
tax-exempt organizations such as the Democratic Governors Association and the Republican Governors
Association;

· Disclosing the share of payments to trade associations that are used for lobbying;

· Providing a publicly available archive of political spending reports dating back to 2009;

· Publishing the company’s detailed policy on political expenditures; and

· Maintaining a committee on the Board of Directors (the Audit Committee) that reviews political
expenditures made with corporate funds.

We hope you find these reports pertinent and informative. We look forward to speaking with you again
and will be in touch with possible dates and times for another call.
With regards,

Karen

Karen W. Doggett

Assistant Corporate Secretary and Director-Governance

Dominion Energy Services, Inc.

600 East Canal Street, Richmond, VA 23219

Office: ​804.819.2123 ​|​ ​Mobile: ​804.337.0826

karen.doggett@dominionenergy.com

Dominion shareholder submitted the following resolution for Dominion’s annual meeting:
Resolution:
Shareholders request Dominion evaluate how cultural shifts towards human rights and climate
justice affect the corporation's governance​.

Supporting statement:

The evaluation could include, at management’s discretion, items such as:

● if and how the board oversees environmental risks and opportunities;
● if and how executive compensation is linked to environmental and social objectives;
● if and how Dominion is addressing pollution prevention;
● if and how Dominion is addressing water conservation;
● if and how Dominion is addressing carbon footprint;
● if and how Dominion is addressing gender diversity;
● if and how Dominion is addressing data privacy;
● if and how Dominion is addressing consumer health;
● if and how Dominion is addressing ethical practices;
● if and how Dominion is addressing conflict materials;
● if and how Dominion is addressing forced labor.

The ​US SIF Foundation’s 2018 Report on US Sustainable, Responsible and Impact Investing
Trends​ reports:

● Sustainable, responsible and impact investing (SRI) assets have expanded to $12.0
trillion in the United States, up 38 percent from $8.7 trillion in 2016
 ● Much of this growth is driven by asset managers, who now consider environmental,
social or corporate governance (ESG) criteria across $11.6 trillion in assets, up 44
percent from $8.1 trillion in 2016.
● The top three issues for asset managers and their institutional investor clients are
climate change/carbon, tobacco and conflict risk.

This demonstrates a high level of interest from investors and the public in corporate social
responsibility.

Shareholders are concerned about the implications in November 2018​ report “Social Cost and
Material Loss: The Dakota Access Pipeline”​ that can be a warning for the fiscal risk of the
Atlantic Coast Pipeline.The final cost of DAPL was nearly double the initial project cost. “The
banks that financed DAPL incurred an additional $4.4 billion in costs in the form of account
closures, not including costs related to representational damage.”

Censible’s ratings for Dominion​ show there’s room for improvement. While Dominion has good
scores for employee satisfaction, workplace safety and governance, the ratings are low for
pollution prevention, water conservation, carbon footprint and gender diversity. Dominion does
not even receive ratings for: data privacy, consumer health, ethical practices, conflict materials
and forced labor.

Improving Dominion’s environmental, social and governance ratings will improve relations with
the community as well as creating a fiscally successful future for the company.
____________________________________________________________________________

(the following letter was hand delivered on Dec. 5, 2018)

Board of Directors
Dominion Energy
Richmond, VA

Freeda Cathcart - SCANA shareholder

December 5, 2018

Dear Chair William Barr, Ms. Helen Dragas, Adm. James Ellis, Mr. Thomas Farrell II,
Mr. John Harris, Mr. Ronald Jibson, Mr. Mark Kington, Mr. Joseph Rigby, Dr. Pamela Royal,
Mr. Robert Spilman Jr., Ms. Susan Story and Mr. Michael Szymanczyk

I respectfully request for you to commission a current analysis to determine if there is an

economic necessity for the Atlantic Coast Pipeline. A current economic analysis would reveal
how the impact of the​ rapid drop in cost of renewable energy​ would affect the demand for
natural gas and if the ACP is needed as an additional transmission line.

The plans to build the ACP were made four years ago and the energy industry has changed
significantly in recent years. SCANA shareholders and customers are still reeling over the
abandoned V.C. Summer plant that left SCANA with $9 billion of stranded assets.​ Dominion
shareholders and customers have valid concerns that the $6.5 billion ACP costs might continue
to rise, especially since not all the necessary permits have been approved.

If the pipeline isn't completed then the shareholders will have the value of their shares decrease
due to stranded assets. Another concern for shareholders is ​last week's report “Social Cost and
Material Loss: The Dakota Access Pipeline,”​ concludes ​the final cost of DAPL was nearly
double the initial project cost. “The banks that financed DAPL incurred an additional $4.4
billion in costs in the form of account closures, not including costs related to
representational damage.”

Dominion Energy Virginia testified in front of the SCC that they have never studied the need for
a new pipeline in Virginia. In 2014 when the ACP was proposed DEV had plans to build 2 large
gas powered electric plants. Since then DEV has canceled their plans to build the plants and
have announced they have no plans to build them in the future. Also four of the proposed six
large gas powered electric plants planned in NC have also been canceled that would have been
served by the ACP.

Dominion Energy has a responsibility to their shareholders to not proceed with incurring
more construction costs for the ACP until they can establish an economic need for the
project, all the necessary permits are in place and all the legal challenges have been
resolved.

Respectfully submitted,

Freeda Cathcart

Board of Directors
Dominion Energy
Richmond
____________________________________________________________________________

(the following letter was signed by Dominion customers and hand delivered on Dec. 5,
2018)
Customers of Dominion Energy
RE: Atlantic Coast Pipeline

Dear Chair William Barr, Ms. Helen Dragas, Adm. James Ellis, Mr. Thomas Farrell II,
Mr. John Harris, Mr. Ronald Jibson, Mr. Mark Kington, Mr. Joseph Rigby, Dr. Pamela Royal,
Mr. Robert Spilman Jr., Ms. Susan Story and Mr. Michael Szymanczyk

The proposal to build the ACP was made four years ago and the energy industry has changed
significantly in recent years. Already the cost of the project has risen to $6.5 billion and the costs
might continue to rise, especially since not all the necessary permits have been approved. The
cost of the pipeline includes a guaranteed 15% rate of return that will be passed along to
ratepayers.

Dominion Energy Virginia testified in front of the SCC that they have never studied the need for
a new pipeline in Virginia. In 2014 when the ACP was proposed DEV had plans to build two
large gas powered electric plants. Since then DEV has canceled their plans to build the plants
and have announced they have no plans to build them in the future. Also four of the proposed
six large gas powered electric plants planned in NC have also been canceled that would have
been served by the ACP.

Dominion Energy has a responsibility to us, the customers, to not proceed with incurring
more construction costs for the ACP until you can establish an economic need for the
project, all the necessary permits are approved and all the legal challenges have been
resolved. We do not want our energy rates to increase for an unneeded capitol project or
due to incompetent implementation.

Thank you for your immediate attention to this important matter.

Sincerely,
Dominion Customers