EQT Production Company v. County of Wise, Virginia

CourtCourt of Appeals of Virginia
DecidedMarch 18, 2025
Docket0155243
StatusUnpublished

This text of EQT Production Company v. County of Wise, Virginia (EQT Production Company v. County of Wise, Virginia) is published on Counsel Stack Legal Research, covering Court of Appeals of Virginia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
EQT Production Company v. County of Wise, Virginia, (Va. Ct. App. 2025).

Opinion

COURT OF APPEALS OF VIRGINIA UNPUBLISHED

Present: Judges Malveaux, Fulton and White Argued at Salem, Virginia

EQT PRODUCTION COMPANY, ET AL. MEMORANDUM OPINION* BY v. Record No. 0155-24-3 JUDGE KIMBERLEY SLAYTON WHITE MARCH 18, 2025 COUNTY OF WISE, VIRGINIA, ET AL.

FROM THE CIRCUIT COURT OF WISE COUNTY David B. Carson, Judge Designate

Stephen M. Hodges (Seth M. Land; Penn, Stuart & Eskridge, on briefs), for appellants.

Paul G. Beers (Harwell M. Darby, Jr.; Glenn, Feldmann, Darby & Goodlatte, on brief), for appellees.

The appellee, Wise County, valued certain natural gas assets in the County owned by the

appellants for purposes of real estate taxation. The County assessed the appellants’ property under

Code § 58.1-3286, valuing the physical structures built to tap into the natural gas but not the gas

reserves themselves. The County used just one valuation approach to determining the property’s

value, which resulted in a higher valuation than the appellants’ preferred approach. The

appellants sought to correct the assessment in the trial court.

The trial court upheld the County’s assessment. It concluded that the County correctly

excluded the reserves from the assessments. It also held that the County’s assessments were

entitled to the statutory presumption of correctness, which the appellants failed to rebut. The

appellants argue that the County violated Code § 58.1-3286 by excluding the reserves, causing a

cascade of errors that resulted in excessively high assessments. We disagree and affirm.

* This opinion is not designated for publication. See Code § 17.1-413(A). BACKGROUND

In 2018, EQT Production Company and EQT Gathering, LLC (collectively “EQT”) sold

its property to Diversified Production LLC (“DGO”) in a bidding process (“2018 Sale”). The

2018 Sale property consisted of land and natural gas assets in 49 counties and three states and

comprised part of the Huron Play, a 2.5-million-acre space of land where EQT has many natural

gas assets.

Of the 2018 Sale property, 578 gas wells, 187.7 miles of pipes, and 14 compressors were

located in Wise County (“Contested Real Estate”). The sale price for the 2018 Sale covered all

the property sold and did not state an amount for the Contested Real Estate specifically.

Additionally, EQT sold the Contested Real Estate after announcing that it would “no longer be

developing the Huron Play gas field” and “voluntarily t[aking] large impairments to the assets in

the amount of $2.3 billion and $118.1 million.” EQT Prod. Co. v. Wise Cnty., 112 Va. Cir. 415,

416 (Wise December 15, 2023). “An impairment is an accounting term for when the market

value of an asset is determined to be lower than the book value.” Id.

In 2018, 2019, and 2020 (“Tax Years”), EQT and DGO (collectively “Taxpayers”) drew

and transported natural gas from the Contested Real Estate. During the Tax Years, Wise County

assessed taxes on the Contested Real Estate according to Code § 58.1-3286 (“Mineral Statute”),

the statute at issue in this case. Taxpayers unsuccessfully sought to correct the assessment under

Code § 58.1-3984 in the trial court.

A. Natural Gas Assets and Valuation Approaches

A natural gas asset has three distinct components: the gas well; the gas reserves, which is

the underground natural gas accessed by the well; and gathering assets, which are pipelines and

compressors used to transport the natural gas out of the well. The gas well and the gathering

-2- assets are collectively termed the “well infrastructure” because they do not generate income on

their own like reserves do or “have any stand-alone value independent of the [gas] reserves.”

There are three approaches to computing the fair market value of a natural gas asset. The

trial court explained these approaches:

In Virginia, mineral land must be taxed at its [fair market value]. There are three primary ways of determining [fair market value]: the cost approach, income approach, and market approach. The cost approach values property at replacement cost new less depreciation, or reduced value from deterioration or obsolescence. The income approach bases [fair market value] on the present worth of monetary benefits anticipated to be derived from future ownership of the property. The market approach [or sales approach] uses analysis and comparison of recent sales of comparable property.

EQT, 112 Va. Cir. at 416; accord McKee Foods Corp. v. Cnty. of Augusta, 297 Va. 482, 496

(2019).

“Each of these approaches utilizes different characteristics of a property to estimate fair

market value, and each analyzes different elements of the property which would likely affect the

price a potential buyer would be willing to pay for the property on the open market.” Keswick

Club, L.P. v. Cnty. of Albemarle, 273 Va. 128, 137 (2007).

The County used the cost approach to determine the fair market value of the Contested

Real Estate during the Tax Years. Taxpayers argue that the County should have used the income

approach. They assert that, because the well infrastructure has no value apart from the reserves,

and vice versa, a natural gas asset’s value is “universally determined by actual market

participants [using the income approach].”

Using the cost approach, the County determined the Contested Real Estate’s value to be

$134.3 million in 2018, $134.3 million in 2019, and $104.6 million in 2020. Under the income

approach, the Contested Real Estate’s value would have been $33 million in 2018, $22 million in

-3- 2019, and $27 million in 2020. Thus, the cost approach resulted in valuations that were “about

4.5 times” greater than the value computed by the income approach.

B. Proceedings

Prior to this case, Taxpayers challenged another tax assessment of their property by the

County in 2011 (“2011 Decision”). In that case, both parties agreed that the cost approach was

the appropriate way to determine the property’s value.

In the present case, the trial court heard testimony and reviewed documentary exhibits.

Based on the evidence, it upheld the County’s cost-based assessment of the Contested Real Estate.

Steve Sprenger, a tax and auditing expert called by Taxpayers, valued the 2018 Sale

property at $363 million. He reached this value by applying the income approach, anticipating

“future cash flows” likely to be derived from selling the natural gas produced by the assets.

Sprenger’s valuation was $100 million more than the price that DGO actually paid for the 2018

Sale. Sprenger also separately valued the Contested Real Estate (the property specific to Wise

County), again using the income approach.

Douglas Mullins, Wise County Commissioner of Revenue, testified regarding how the

County reached its assessment value for the Contested Real Estate. He believed that the 2011

Decision established the cost approach as the “fundamental” way of assessing the value of gas

properties. Unlike Sprenger, he “did not formally research income data” because he only

considered the Contested Real Estate’s well infrastructure (the wells, pipelines, and

compressors), not the income-generating gas reserves. EQT, 112 Va. Cir. at 417. Additionally,

he “disregarded” the 2018 Sale price as not indicative of the property’s value because “the sale

price was significantly below sale value.” Id. Since the well infrastructure did not generate

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EQT Production Company v. County of Wise, Virginia, Counsel Stack Legal Research, https://law.counselstack.com/opinion/eqt-production-company-v-county-of-wise-virginia-vactapp-2025.