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Contract analysis / statement-of-nature-of-filing.docx
statement-of-nature-of-filing.docx
1016-00005 · 25 clauses
High · 2 Medium · 0 Standard · 2
I. INTRODUCTION AND NATURE OF FILING
I. INTRODUCTION AND NATURE OF FILING Ridgeline Midstream Services LLC ("Ridgeline" or "Applicant"), a Delaware limited liability company with principal offices located at 700 Kanawha Boulevard East, Suite 1400, Charleston, West Virginia 25301, and having its registered agent, Capitol Filings Inc., located at 1209 Orange Street, Wilmington, Delaware 19801, hereby submits this Statement of Nature of Filing and Tariff S
II. DESCRIPTION OF THE APPLICANT
II. DESCRIPTION OF THE APPLICANT A. Corporate Structure Ridgeline Midstream Services LLC is a limited liability company organized and existing under the laws of the State of Delaware. The Applicant's sole member is Dunmore Energy Holdings Ltd. ("DEH"), which holds a one hundred percent (100%) ownership interest in Ridgeline. Ridgeline was formed on March 17, 2020, for the express purpose of developing, constructing,
III. DESCRIPTION OF THE RIDGELINE PIPELINE SYSTEM Standard
⚑ Commercial term
III. DESCRIPTION OF THE RIDGELINE PIPELINE SYSTEM A. Physical Specifications The Ridgeline Pipeline System consists of approximately one hundred eighty-seven (187) miles of twenty-four inch (24-inch) diameter, high-pressure steel pipeline. The pipeline was designed and constructed in full compliance with the safety requirements of 49 C.F.R. Part 192, which sets forth the minimum federal safety standards for the trans
1. Wetzel Station — Located at the receipt point near the Wetzel County Interconnect in W
1. Wetzel Station — Located at the receipt point near the Wetzel County Interconnect in Wetzel County, West Virginia. This station provides initial compression for natural gas entering the Ridgeline Pipeline System.
2. Mannington Station — Located at approximately the midpoint of the pipeline system in M
2. Mannington Station — Located at approximately the midpoint of the pipeline system in Marion County, West Virginia. This station provides intermediate compression to maintain system pressures along the pipeline route.
3. Waynesburg Station — Located at the delivery point near the Waynesburg Compressor Stat
3. Waynesburg Station — Located at the delivery point near the Waynesburg Compressor Station in Greene County, Pennsylvania. This station provides final compression and pressure regulation for gas volumes being delivered at the downstream terminus of the system. The aggregate installed compression across all three stations is 45,000 horsepower ("HP"). Each station is equipped with natural gas-fired turbine-driven cen
IV. PROPOSED TARIFF — FERC GAS TARIFF, ORIGINAL VOLUME NO. 1 High
⚑ Penalty / liquidated damages
IV. PROPOSED TARIFF — FERC GAS TARIFF, ORIGINAL VOLUME NO. 1 A. Tariff Type and Regulatory Authority Ridgeline hereby submits for Commission acceptance its FERC Gas Tariff, Original Volume No. 1, which sets forth the rates, terms, and conditions under which Ridgeline will provide open-access natural gas transportation service on the Ridgeline Pipeline System. The tariff has been prepared and filed pursuant to Part 28
V. SUMMARY OF PROPOSED RATES
V. SUMMARY OF PROPOSED RATES A. Proposed Recourse Rate — Firm Transportation (Rate Schedule FT-1) Ridgeline proposes the following maximum recourse rate for firm transportation service under Rate Schedule FT-1: The proposed recourse rate has been derived from Ridgeline's cost of service, as detailed in Section VI below, and reflects a rate basis of 100% load factor, levelized over a twenty-five (25) year period. The
VI. COST-OF-SERVICE SUMMARY High
⚑ Penalty / liquidated damages
VI. COST-OF-SERVICE SUMMARY A. Test Year The proposed rates are based on a cost of service developed using a test year ended March 31, 2022. This test year represents the first full twelve-month period following the October 1, 2021, in-service date of the Ridgeline Pipeline System. The selection of this test year is consistent with Commission policy and ensures that the cost of service reflects a representative perio
VII. INTERCONNECTION AUTHORIZATION REQUEST
VII. INTERCONNECTION AUTHORIZATION REQUEST A. Description of Proposed Interconnection In addition to its tariff rate application, Ridgeline hereby seeks authorization from the Commission, pursuant to Section 7 of the NGA, 15 U.S.C. § 717f, for the physical interconnection of the Ridgeline Pipeline System with the existing interstate pipeline network of Appalachian Trunk Pipeline Company, LLC ("ATPC"). ATPC is a limit
VIII. SUPPORTING EXHIBITS AND TESTIMONY
VIII. SUPPORTING EXHIBITS AND TESTIMONY A. Exhibits Filed Exhibits A through P accompany this application and provide the detailed supporting data, schedules, workpapers, and documentation underlying the proposed rates, cost of service, and interconnection request. The exhibits include, without limitation, the following categories of information: • Cost-of-service schedules and rate base calculations, including detai
1. James K. Winfield, Chief Executive Officer and President, Ridgeline Midstream Services
1. James K. Winfield, Chief Executive Officer and President, Ridgeline Midstream Services LLC — Mr. Winfield's testimony addresses the policy considerations underlying the filing, the need for open-access transportation service on the Ridgeline Pipeline System, the commercial rationale for the proposed interconnection with the ATPC system, and the public interest benefits of the proposed rates and service.
2. Angela Moretti, Vice President, Finance and Treasurer, Ridgeline Midstream Services LL
2. Angela Moretti, Vice President, Finance and Treasurer, Ridgeline Midstream Services LLC — Ms. Moretti's testimony addresses the derivation of Ridgeline's cost of service, the components of rate base, the development of operating expense estimates, the capital structure and financing of the Ridgeline Pipeline System, and the financial integrity of the proposed rates.
3. Thomas Greaves, Vice President, Engineering and Operations, Ridgeline Midstream Servic
3. Thomas Greaves, Vice President, Engineering and Operations, Ridgeline Midstream Services LLC — Mr. Greaves' testimony addresses the engineering design and physical specifications of the Ridgeline Pipeline System, the construction history and in-service date of the system, the design and specifications of the proposed Wetzel County Interconnect, and the operational capabilities and reliability of the system.
4. Dr. Natasha Orlov, Director of Rates and Regulatory, Ridgeline Midstream Services LLC
4. Dr. Natasha Orlov, Director of Rates and Regulatory, Ridgeline Midstream Services LLC — Dr. Orlov's testimony addresses the design of the proposed rate schedules, the allocation of cost-of-service components between reservation and usage charges, the derivation of the interruptible transportation rate, the terms and conditions of the tariff, and compliance with the Commission's open-access and rate design policies
5. Dr. Raymond Braswell, Braswell Energy Consulting Group LLC — Dr. Braswell's testimony
5. Dr. Raymond Braswell, Braswell Energy Consulting Group LLC — Dr. Braswell's testimony addresses the appropriate return on equity for the Ridgeline Pipeline System, including the development and analysis of a proxy group of comparable natural gas pipeline companies, the application of the discounted cash flow methodology, and the reasonableness of the proposed 14.00% ROE in light of current capital market condition
6. William C. Easterly, Senior Vice President, Environmental and Permitting, Dunmore Ener
6. William C. Easterly, Senior Vice President, Environmental and Permitting, Dunmore Energy Holdings Ltd. — Mr. Easterly's testimony addresses the environmental review and permitting status of the Ridgeline Pipeline System and the Wetzel County Interconnect, including compliance with applicable federal, state, and local environmental requirements, and the status of all necessary environmental permits and authorizatio
7. Karen L. Fiedler, Director of Market Analysis, Ridgeline Midstream Services LLC — Ms.
7. Karen L. Fiedler, Director of Market Analysis, Ridgeline Midstream Services LLC — Ms. Fiedler's testimony addresses the market demand for transportation service on the Ridgeline Pipeline System, the current and projected supply and demand conditions in the Appalachian Basin, the competitive landscape for natural gas transportation in the region, and the expected utilization of the Ridgeline Pipeline System under t
IX. FILING REQUIREMENTS COMPLIANCE
IX. FILING REQUIREMENTS COMPLIANCE Ridgeline hereby confirms that this filing has been prepared and submitted in compliance with the requirements of 18 C.F.R. § 154.7 and the Commission's Rules of Practice and Procedure. Specifically, this filing includes each of the following elements required by the Commission's regulations: (a) Statement of the nature and reasons for the filing. This Statement of Nature of Filing
X. COMMUNICATIONS AND SERVICE
X. COMMUNICATIONS AND SERVICE All communications, correspondence, and pleadings regarding this filing should be directed to the following persons, who are designated as Ridgeline's representatives for purposes of this proceeding and who should be included on the Commission's official service list: George Trujillo Responsible Partner Calderwood & Harkness LLP 1601 K Street NW, Suite 900 Washington, DC 20006 Telephone:
XI. CONCLUSION AND REQUEST FOR RELIEF
XI. CONCLUSION AND REQUEST FOR RELIEF For the reasons set forth in this Statement of Nature of Filing and Tariff Summary, and in the accompanying exhibits, testimony, and filing materials, Ridgeline Midstream Services LLC respectfully requests that the Federal Energy Regulatory Commission enter an order:
1. Accepting for filing the FERC Gas Tariff, Original Volume No. 1, of Ridgeline Midstrea
1. Accepting for filing the FERC Gas Tariff, Original Volume No. 1, of Ridgeline Midstream Services LLC, including the proposed initial maximum recourse rate of $0.2265/Dth for firm transportation service under Rate Schedule FT-1, the interruptible transportation rate under Rate Schedule IT-1, and the General Terms and Conditions, as described herein;
2. Authorizing the physical interconnection between the Ridgeline Pipeline System and the
2. Authorizing the physical interconnection between the Ridgeline Pipeline System and the interstate pipeline system of Appalachian Trunk Pipeline Company, LLC at the Wetzel County Interconnect in Wetzel County, West Virginia, and approving the draft Interconnection Agreement between Ridgeline and ATPC;
3. Establishing an effective date for the proposed tariff rates no later than sixty (60)
3. Establishing an effective date for the proposed tariff rates no later than sixty (60) days after the date of Commission acceptance of this filing; and
4. Granting such other and further relief as the Commission deems just, reasonable, and a Standard
⚑ Commercial term
4. Granting such other and further relief as the Commission deems just, reasonable, and appropriate in the circumstances. Ridgeline submits that its proposed rates are just and reasonable within the meaning of Section 4 of the NGA, that the proposed interconnection is required by the present and future public convenience and necessity within the meaning of Section 7 of the NGA, and that this filing satisfies all appl