Contract analysis

1. Interconnection Cost Allocation — ATPC's Core Position A. Rejection of Ridgeline's Proposed 34.1% / 65.9% Cost Split ATPC respectfully but firmly rejects Ridgeline's proposed cost allocation as set forth in the Version 2.0 draft, under which Ridgeline would bear only $7.6 million (34.1%) of the total $22.3 million estimated interconnection facilities cost, with the remaining $14.7 million (65.9%) allocated to ATPC

2. Alternative Metering Station Design A. Rejection of Ridgeline's Proposed Ultrasonic Flow Meter Configuration ATPC has carefully reviewed the metering station design proposed by Ridgeline in Mr. Callahan's December 2022 email and the revised schematics accompanying the Version 2.0 draft agreement. Ridgeline proposes the installation of three (3) ultrasonic flow meter runs of 12-inch nominal diameter in a parallel c

3. Pig Launcher/Receiver Specifications A. ATPC's Requirements for Pig Launcher/Receiver Design ATPC requires that the pig launcher and receiver facilities to be installed at the Wetzel County Interconnect be designed as full-opening, barrel-type units capable of accommodating pigs of 30-inch nominal diameter, corresponding to the nominal diameter of the ATPC mainline at Milepost 412.6. ATPC does not accept Ridgeline

4. SCADA Integration and Operational Protocols ATPC requires full integration between the SCADA (Supervisory Control and Data Acquisition) system at the Wetzel County Interconnect metering station and ATPC's existing SCADA system at ATPC's central gas control facility located in Pittsburgh, Pennsylvania. Real-time operational data from the interconnection point is essential for ATPC's dispatchers to manage system flo

5. Operational Flow Requirements at the Interconnect ATPC concurs with the general design premise that the Wetzel County Interconnect shall support bidirectional gas flow between the ATPC and Ridgeline systems. As contemplated by both parties, the initial design capacity of the interconnection shall be 800 MMcf/d, with the facilities designed and constructed to be expandable to 1.2 Bcf/d through the addition of compr

6. Interconnection Agreement as FERC Rate Schedule ATPC acknowledges the Deficiency Letter issued by the Commission's Office of Energy Market Regulation on January 19, 2023, in Docket No. RP22-847-000, which includes, at Item 9, a requirement that the Interconnection Agreement between ATPC and Ridgeline be filed with the Commission as a FERC rate schedule under Section 4 of the Natural Gas Act, 15 U.S.C. § 717c. ATPC

7. Construction and In-Service Timeline ATPC notes that the original target in-service date for the Wetzel County Interconnect was the fourth quarter of 2023, as contemplated in the parties' initial discussions and reflected in the preliminary project schedule exchanged during the September 2022 technical meetings. That target date is no longer achievable due to the pendency of the FERC proceeding in Docket Nos. RP22

8. Insurance and Indemnification ATPC requires that Ridgeline maintain, at its sole cost and expense, the following insurance coverages during the construction and operation of the interconnection facilities at the Wetzel County Interconnect: (a) Comprehensive General Liability Insurance: Coverage in an amount not less than Ten Million Dollars ($10,000,000) per occurrence and Twenty-Five Million Dollars ($25,000,000)

9. Reservation of Rights and Proceeding Positions ATPC expressly reserves all rights, claims, defenses, and positions asserted in its protest and motion to intervene filed on August 15, 2022 in Docket No. RP22-847-000, and in all subsequent filings, pleadings, testimony, and submissions made by ATPC in the above-captioned proceeding. This counterproposal is made solely for the purpose of advancing negotiations toward

1. George Trujillo — Responsible Partner

2. Patricia Dunmore — Billing Partner / DEH Chairperson

3. David Stanton — Working Associate

4. File Summary of Key Issues for Response

1. Cost Allocation ATPC proposes a 50/50 cost allocation: $11.15 million to each party based on the $22.3 million base interconnection facilities cost. Under ATPC's expanded scope (which includes the metering station upgrade and pig launcher upsizing), ATPC proposes $12.9 million to each party on a total of $25.8 million. By contrast, Ridgeline's current position under the Version 2.0 draft is 34.1% Ridgeline ($7.6 m

2. Metering Station Design ATPC proposes four (4) 16-inch ultrasonic flow meter runs in place of Ridgeline's proposed three (3) 12-inch runs. This change increases the meter station cost by $2.6 million (from $9.8 million to $12.4 million). Engineering review is needed — consult Thomas Greaves. Preliminary assessment: 16-inch meter runs are oversized for the 800 MMcf/d initial design capacity and are likely unnecessa

3. Pig Launcher/Receiver ATPC insists on 30-inch pig launcher/receiver facilities to accommodate its own inline inspection tools on the 30-inch ATPC mainline. This increases the pig launcher/receiver cost by $0.9 million (from $4.2 million to $5.1 million). ATPC proposes including this cost in the 50/50 shared allocation. Strong cost-causation argument available: the 30-inch pig specification is attributable solely t

4. Total Cost Impact Under ATPC's full counterproposal (expanded scope + 50/50 allocation), Ridgeline's share of the interconnection cost increases from $7.6 million (Ridgeline's current position) to $12.9 million — a $5.3 million increase representing a 69.7% escalation in Ridgeline's share. This is unacceptable. The response strategy must push back on both vectors: (a) reject the scope expansion (or limit it throug

5. Timeline ATPC's proposed 18-month construction timeline from FERC order to in-service is workable in principle, subject to confirmation from Thomas Greaves regarding current procurement lead times for ultrasonic meters, pig launcher/receiver equipment, and SCADA components. However, the proposed liquidated damages provision of $50,000 per day for construction delays is excessive and non-standard for interconnectio

6. Rate Schedule Filing The FERC Deficiency Letter issued January 19, 2023 includes, at Item 9, a requirement that the Interconnection Agreement be filed as a FERC rate schedule. This is a mandatory requirement and must be incorporated into Version 3.0 of the draft Interconnection Agreement. Coordinate the response to Item 9 with the ongoing tariff redesign work being performed by the Braswell Energy Consulting Group

7. Next Steps (a) Schedule engineering review call with Thomas Greaves (VP Engineering & Operations, Ridgeline) by January 25, 2023 to review ATPC's three enclosures (cost allocation table, metering station schematic, pig launcher/receiver specification); (b) Draft response letter to KRD (William Pratt) by February 15, 2023, targeting transmission to KRD no later than February 16, 2023 (the 30-day deadline requested