Contract analysis

I. Introduction and Purpose This firm represents Ridgeline Midstream Services LLC ("Ridgeline" or "RMS"), a wholly owned subsidiary of Dunmore Energy Holdings Ltd. ("DEH"), in the above-referenced proceedings before the Federal Energy Regulatory Commission ("FERC" or "Commission"), designated as FERC Docket No. RP22-847-000 (Ridgeline's general Section 4 rate case) and FERC Docket No. RP22-847-001 (the contested inte

II. Background on the Proposed Interconnection To place the counterproposal in context, Ridgeline provides the following summary of the relevant pipeline systems and the proposed interconnection point. We recognize that much of this background information is already part of the record in the above-captioned proceedings, but we restate it here for convenience and completeness. A. The Ridgeline Pipeline System Ridgelin

III. Ridgeline's Counterproposal on Metering Station Design A. Overview of Counterproposal Having carefully considered the technical concerns raised by ATPC in its August 15, 2022 protest and the subsequent discussions between the parties' engineering teams, Ridgeline hereby submits its revised counterproposal for the metering station design at the Wetzel County Interconnect. This counterproposal addresses certain of

IV. Interconnection Cost Allocation — Reservation of Position Ridgeline acknowledges that the metering station design counterproposal set forth in Section III above does not resolve the parties' ongoing dispute over the appropriate allocation of interconnection costs. The cost allocation issue is a separate and distinct matter from the metering station design specifications, and Ridgeline believes that the parties ca

V. Proposed Next Steps and Timeline Ridgeline proposes the following next steps and timeline for advancing negotiations on the metering station design:

1. Review of Counterproposal. Ridgeline requests that ATPC and its counsel at Kellner, Royce & Dillard LLP review this counterproposal and the attached revised metering station site plan (Attachment A), ultrasonic flow meter technical specifications (Attachment B), gas chromatograph technical specifications (Attachment C), and SCADA integration protocol summary (Attachment D) at your earliest convenience.

2. Technical Meeting. Ridgeline proposes a technical meeting between Ridgeline's engineering team, led by Thomas Greaves, Vice President of Engineering & Operations, and ATPC's engineering team to discuss the revised metering specifications in detail. Ridgeline requests that this meeting be scheduled within twenty-one (21) days of the date of this letter, with a target date in mid-December 2022. The meeting may be co

3. Direct Testimony Filing. Ridgeline notes that it intends to file its direct testimony on the Track II schedule on December 5, 2022, as required by ALJ Whitfield's procedural order. Ridgeline's direct testimony filing will include, among other things, the pre-filed direct testimony of Thomas Greaves addressing engineering and system design issues, including the metering station design at the Wetzel County Interconn

4. Written Response. Ridgeline respectfully requests that ATPC provide a written response to this counterproposal by no later than December 16, 2022. A timely response will facilitate incorporation of any agreed-upon revisions into Version 2.0 of the Draft Interconnection Agreement, which Ridgeline anticipates circulating in January 2023.

5. Coordination with Track II Schedule. Ridgeline emphasizes the importance of advancing the interconnection negotiations in parallel with the Track II procedural schedule established by the Commission's September 22, 2022 order. The Track II schedule contemplates resolution of the interconnection issues on an expedited basis, and Ridgeline believes that meaningful progress on the technical metering specifications wi

6. Settlement Discussions. Ridgeline notes that the parties remain approximately $0.058/Dth apart on the overall rate in settlement discussions, with Ridgeline's position currently anchored at the proposed recourse rate level and the various intervenor positions reflecting somewhat lower rate levels. While the rate gap remains meaningful, Ridgeline is hopeful that resolution of the technical metering issues — which r

VI. Confidentiality As you are aware, this firm transmitted a letter to your firm dated September 12, 2022, proposing confidentiality and protective order provisions for the exchange of commercially sensitive cost data and technical information in connection with the interconnection negotiations. Those proposed provisions remain under discussion, and we understand that ALJ Whitfield intends to address the entry of a

VII. Attachments The following documents are enclosed with this letter: Attachment A: Revised Metering Station Site Plan — Wetzel County Interconnect (Drawing No. RMS-WCI-SP-2022-03, Rev. 1, prepared by Ridgeline Engineering Department, November 2022). This drawing shows the physical arrangement of the three ultrasonic meter runs, gas chromatograph shelter, pig launcher/receiver, SCADA equipment building, electrical

VIII. Closing Ridgeline looks forward to ATPC's prompt response to this counterproposal and to productive technical discussions on the metering station design for the Wetzel County Interconnect. Ridgeline remains fully committed to reaching a mutually acceptable interconnection agreement that serves the interests of both parties and their respective shippers, and to advancing this proceeding toward a timely and effic