Contract analysis

I. Purpose of This Filing Calderwood & Harkness LLP, on behalf of Ridgeline Midstream Services LLC ("Ridgeline" or "RMS"), a Delaware limited liability company and wholly owned subsidiary of Dunmore Energy Holdings Ltd. ("DEH"), hereby submits the enclosed Partial Response to the Deficiency Letter issued by the Commission's Office of Energy Market Regulation on January 19, 2023 (the "Deficiency Letter"). The Deficien

II. Background and Procedural History On May 12, 2022, Ridgeline filed its application in the above-captioned dockets seeking: (i) approval of an initial recourse rate of $0.2265 per dekatherm ("Dth") for interstate natural gas transportation service on the Ridgeline Pipeline System, consisting of a reservation charge of $0.2223 per Dth and a usage charge of $0.0042 per Dth; and (ii) authorization for physical interc

1. Mountainside Gas Producers Coalition ("MGPC") filed a timely motion to intervene on July 28, 2022, asserting interests as a coalition of natural gas producers holding firm transportation service agreements on the Ridgeline Pipeline System.

2. Clearwater Municipal Gas Authority ("CMGA") filed a timely motion to intervene on August 1, 2022, asserting interests as a municipal gas distribution authority and prospective shipper on the Ridgeline Pipeline System.

3. Appalachian Trunk Pipeline Company, LLC ("ATPC") filed a motion to intervene and protest on August 15, 2022. ATPC's protest raised objections to, inter alia, (a) the proposed allocation of interconnection facilities costs at the Wetzel County Interconnect, (b) Ridgeline's proposed return on equity, and (c) certain operational provisions in Ridgeline's proposed General Terms and Conditions. By order dated September

III. Summary of the Fourteen Deficiency Items For context and ease of reference, the fourteen (14) deficiency items identified in the Deficiency Letter are summarized below: Item 1: Inadequate cost-of-service support for the proposed 14.00% return on equity ("ROE"), including the absence of an updated proxy group analysis incorporating market data subsequent to 2021. Item 2: Failure to include a fuel-use and lost-and

IV. Description of Deficiency Items Addressed in This Filing A. Item 1 — Return on Equity Support The Deficiency Letter noted that Ridgeline's proposed return on equity of 14.00% was supported by a discounted cash flow ("DCF") proxy group analysis utilizing market data through the end of calendar year 2021 and that no updated analysis had been provided incorporating more recent data. The Office of Energy Market Regul

V. Items Not Addressed — Items 5, 6, 11, 12, 13, and 14 Ridgeline acknowledges that the following six (6) deficiency items are not addressed in this Partial Response and will be addressed in a subsequent supplemental filing: Item 5: Capacity Release Provisions. The Deficiency Letter directed Ridgeline to include capacity release provisions in the General Terms and Conditions of its tariff, consistent with the Commiss

VI. Enclosures and Attachments The following materials are enclosed with this filing: Attachment A: Supplemental ROE Support — Updated DCF Proxy Group Analysis (responsive to Item 1) Attachment B: FL&U Tracker Mechanism Framework (responsive to Item 2) Attachment C: IT Rate Derivation Framework (responsive to Item 3) Attachment D: Load Factor Billing Determinant Support (responsive to Item 4) Attachment E: Proposed E

VII. Service and Filing Information This filing is submitted electronically via the Commission's eFiling system in accordance with the Commission's regulations at 18 C.F.R. § 385.2010. Copies of this filing and all accompanying attachments have been served on all parties on the official service list in Docket Nos. RP22-847-000 and RP22-847-001, including: • Kellner, Royce & Dillard LLP (William Pratt, Esq.), counsel

VIII. Request for Further Proceedings Ridgeline respectfully requests that the Commission accept this Partial Response as responsive to Items 1, 2, 3, 4, 7, 8, 9, and 10 of the Deficiency Letter. Ridgeline further requests that the Commission permit Ridgeline to file supplemental responses addressing the remaining six (6) deficiency items — Items 5, 6, 11, 12, 13, and 14 — on a schedule to be established by ALJ Whitf

IX. Contact Information Any inquiries regarding this filing should be directed to: George Trujillo, Responsible Partner Calderwood & Harkness LLP 1601 K Street NW, Suite 900 Washington, DC 20006 Telephone: (202) 555-7823 Email: gtrujillo@calderwoodharkness.com C&H Matter No. 1016-00005 Brett Callahan, Lead Associate Calderwood & Harkness LLP 1601 K Street NW, Suite 900 Washington, DC 20006 Telephone: (202) 555-7841 E