Contract analysis

I. Introduction and Purpose of Letter Calderwood & Harkness LLP, on behalf of our client Ridgeline Midstream Services LLC ("Ridgeline" or "RMS"), respectfully submits this letter proposing a procedural schedule for the resumption of the Track II hearing in the above-captioned proceedings. The undersigned, George Trujillo, Responsible Partner, Energy & Infrastructure Practice Group, Calderwood & Harkness LLP, is lead

II. Background and Procedural History A. Initial Filing and Intervention Phase On May 12, 2022, Ridgeline filed its application with the Commission proposing an initial recourse rate of $0.2265 per dekatherm ("Dth") for firm interstate transportation service on the Ridgeline Pipeline System. The proposed recourse rate comprised a reservation charge of $0.2223/Dth and a usage charge of $0.0042/Dth, derived from a rate

III. Status of Tariff Redesign and Anticipated February 21, 2025 Filing Ridgeline, with the assistance of Braswell Energy Consulting Group LLC, has substantially completed the comprehensive redesign of FERC Gas Tariff, Original Volume No. 1. As reported in the three quarterly status reports, the redesigned tariff addresses all fourteen deficiency items identified in the January 19, 2023 Deficiency Letter. Ridgeline p

IV. Description of the Ridgeline Pipeline System For the convenience of the ALJ and the parties, and to provide context for the proposed procedural schedule, Ridgeline provides the following brief summary of the Ridgeline Pipeline System: The Ridgeline Pipeline System is a 187-mile, 24-inch-diameter high-pressure natural gas transmission pipeline located in West Virginia and Pennsylvania. The pipeline has a receipt p

V. Proposed Procedural Schedule A. Scheduling Principles Ridgeline proposes the following procedural schedule for the resumption of the Track II hearing in this consolidated proceeding. The proposed schedule is designed to provide all parties with adequate time to review the redesigned tariff and supplemental testimony, prepare and file responsive testimony, and proceed to an evidentiary hearing in an orderly and eff

VI. Discovery Matters Ridgeline proposes that the parties confer promptly following the prehearing conference to establish a discovery protocol governing the supplemental phase of this proceeding. In light of the comprehensive nature of the redesigned tariff and the volume of supporting workpapers and cost-of-service model data that will accompany the filing, Ridgeline believes that an organized and efficient discove

VII. Settlement Discussions Notwithstanding its proposal for the resumption of the hearing schedule, Ridgeline remains willing to continue settlement discussions in parallel with the hearing track. Settlement Judge Howard Margolis remains appointed in these proceedings, and Ridgeline understands that he remains available to convene additional settlement conferences. Ridgeline respectfully suggests that the filing of

VIII. Coordination with Interconnection Proceeding (Docket No. RP22-847-001) Ridgeline's redesigned tariff filing will include the Interconnection Agreement between Ridgeline and ATPC, filed as a FERC rate schedule. This addresses Deficiency Item 9, which identified the failure to file the interconnection agreement as a rate schedule as a deficiency in the original filing. The interconnection facilities at the Wetzel

IX. Identification of Parties and Counsel For the convenience of the ALJ and the record, Ridgeline identifies the following parties and counsel of record as reflected on the Commission's official service list in these proceedings: Ridgeline Midstream Services LLC (Applicant) Counsel: Calderwood & Harkness LLP George Trujillo, Responsible Partner, Energy & Infrastructure Practice Group Brett Callahan, Lead Associate D

X. Request for Prehearing Conference In light of the foregoing, Ridgeline respectfully requests that Your Honor schedule a prehearing conference for on or about March 7, 2025 — approximately two weeks after the anticipated February 21, 2025 filing — to address the following matters: (1) The proposed procedural schedule set forth in Section V above, including any modifications proposed by the parties or deemed appropr

XI. Consultation with Parties In accordance with customary practice, Calderwood & Harkness has consulted informally with counsel for all parties regarding the proposed procedural schedule. The positions of the parties, to the extent known, are as follows: • ATPC (through William Pratt, Kellner, Royce & Dillard LLP): ATPC has indicated a preference for a longer answering testimony period of seventy-five to ninety (75–

XII. Conclusion and Relief Requested For the foregoing reasons, Ridgeline Midstream Services LLC respectfully requests that the Honorable Judge Whitfield:

1. Acknowledge Ridgeline's confirmed intention to file the redesigned FERC Gas Tariff, Original Volume No. 1, and supplemental direct testimony on or before February 21, 2025, in compliance with the deadline established by Your Honor's March 4, 2024 order;

2. Adopt the proposed procedural schedule set forth in Section V above, or such modifications thereto as the ALJ deems appropriate after consulting with the parties at the prehearing conference;

3. Schedule a prehearing conference for on or about March 7, 2025, approximately two weeks after the anticipated February 21, 2025 filing;

4. Direct the parties to confer regarding the negotiation of a protective order and discovery protocol in advance of the prehearing conference, so that an agreed protective order may be submitted for the ALJ's approval at or before the prehearing conference; and

5. Consider scheduling a fifth settlement conference before Settlement Judge Margolis on or about March 21, 2025, to explore whether the redesigned tariff and supplemental testimony narrow the issues between the parties and create opportunities for a negotiated resolution of some or all of the contested matters. Ridgeline reserves all rights and arguments under the Natural Gas Act, 15 U.S.C. § 717 et seq., the Commis