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Contract analysis / letter-to-ferc-staff-informal-conference.docx
letter-to-ferc-staff-informal-conference.docx
High · 2
Medium · 1
Standard · 0
I. Background and Procedural History
Medium
⚑ Notice / time limit to track
I. Background and Procedural History On May 12, 2022, Ridgeline filed with the Commission an application for an initial tariff rate and interconnection authorization pursuant to Sections 4 and 7 of the Natural Gas Act ("NGA"), 15 U.S.C. §§ 717c and 717f, and the Commission's regulations at 18 C.F.R. Parts 154, 157, and 284 (the "Application"). The Application sought approval of the FERC Gas Tariff, Original Volume No
II. Items Previously Addressed in the Partial Response (March 15, 2023)
High
⚑ Penalty / liquidated damages
II. Items Previously Addressed in the Partial Response (March 15, 2023) For context and to provide Staff with a complete picture of the current posture of Ridgeline's deficiency response, the following is a brief summary of the eight deficiency items that were substantively addressed in the Partial Response filed on March 15, 2023. Ridgeline's responses to each of these items were accompanied by supporting workpapers
III. Remaining Six Deficiency Items Requiring Discussion
High
⚑ Penalty / liquidated damages
III. Remaining Six Deficiency Items Requiring Discussion The following discussion addresses each of the six remaining deficiency items (Items 5, 6, 11, 12, 13, and 14) that were not addressed in the Partial Response and that are the primary focus of the requested informal conference. For each item, Ridgeline provides a summary of the deficiency identified, a description of the work undertaken to date, and specific ar
IV. Proposed Conference Format and Logistics
IV. Proposed Conference Format and Logistics Ridgeline respectfully proposes that the informal conference be held at the Commission's offices at 888 First Street NE, Washington, DC 20426, at a mutually convenient date within thirty (30) days of this letter (i.e., by approximately June 14, 2023). In the alternative, Ridgeline is amenable to conducting the conference by videoconference if that format is preferred by St
V. Coordination with Other Parties
V. Coordination with Other Parties Ridgeline is mindful that these proceedings involve multiple active parties whose interests may be affected by the tariff redesign. Settlement discussions are ongoing before Settlement Judge Howard Margolis, with settlement conferences held on November 30, 2022 and March 8, 2023, and additional settlement conferences anticipated in the coming weeks. Ridgeline has participated active
VI. Conclusion
VI. Conclusion For the reasons set forth above, Ridgeline Midstream Services LLC respectfully requests that Mr. Briggs or his designee contact undersigned counsel at the earliest convenient date to arrange the proposed informal conference. Ridgeline is committed to completing its tariff redesign in a thorough and timely manner and firmly believes that Staff engagement at this critical stage of the proceeding will pro