Contract analysis

I. INTRODUCTION AND PURPOSE Ridgeline Midstream Services LLC ("Ridgeline" or "Applicant"), by and through its undersigned counsel, Calderwood & Harkness LLP, hereby submits this First Quarterly Status Report ("Status Report") to the Federal Energy Regulatory Commission ("Commission" or "FERC") pursuant to the Order of Administrative Law Judge Clara Whitfield dated March 4, 2024 (the "March 4 Order"). This Status Repo

II. PROCEDURAL BACKGROUND The following procedural history is provided to place this Status Report in context for the Commission and for any party that may be newly reviewing the record. The procedural history encompasses the initial filing, the interventions and protest, the Deficiency Letter and resulting stay of proceedings, and the three extensions of time that have been granted in this proceeding. A. Initial Fil

III. STATUS OF TARIFF REDESIGN A. Engagement of Braswell Energy Consulting Group LLC Ridgeline, through its parent company DEH, engaged Braswell Energy Consulting Group LLC ("Braswell") on April 15, 2023, under Engagement No. BEC-2023-0041, to serve as the lead tariff redesign consultant for this proceeding. Braswell is a Virginia limited liability company with offices at 8300 Greensboro Drive, Suite 450, McLean, Vir

IV. STATUS OF INTERCONNECTION NEGOTIATIONS Negotiations with ATPC regarding the Interconnection Agreement and cost allocation for the interconnection facilities at the Wetzel County Interconnect remain ongoing. The parties have made progress on certain technical and design issues but continue to differ on the fundamental question of cost allocation. The total cost of the interconnection facilities at the Wetzel Count

V. STATUS OF SETTLEMENT DISCUSSIONS Settlement Judge Howard Margolis has convened four settlement conferences to date in this proceeding: November 30, 2022; March 8, 2023; July 12, 2023; and January 18, 2024. The settlement conferences have provided a constructive forum for the parties to exchange views on the contested issues, but no settlement has been reached to date. As of the most recent settlement conference on

1. Return on Equity. The parties remain significantly apart on the appropriate ROE for the Ridgeline Pipeline System. ATPC proposes an ROE of 10.75%, which Ridgeline believes is unsupported by market data and inadequate to compensate equity investors for the risks associated with the Ridgeline Pipeline System. MGPC proposes a somewhat higher ROE of 11.25%, but this remains well below Ridgeline's proposal of 12.50%. R

2. Interconnection Cost Allocation. As described in Section IV above, ATPC insists on a 50/50 allocation of the $22.3 million interconnection costs ($11.15 million each), while Ridgeline maintains its proposed allocation of 34.1% to Ridgeline ($7.6 million) and 65.9% to ATPC ($14.7 million). This issue is central to the cost of service and rate for both Ridgeline and ATPC, and its resolution will likely be a prerequi

3. Load Factor. All three intervenors — ATPC, MGPC, and CMGA — advocate for a load factor of 85% or higher, which would result in greater billing determinants and, consequently, a lower unit rate. Ridgeline proposes a 75% load factor, which it believes more accurately reflects the expected utilization of the pipeline system and is consistent with Commission precedent for similarly situated systems. Ridgeline remains

VI. RIDGELINE PIPELINE SYSTEM — OPERATIONAL UPDATE Ridgeline provides the following operational update on the Ridgeline Pipeline System for the Commission's information and for the record in this proceeding. The Ridgeline Pipeline System has been in continuous commercial service since October 1, 2021. The system continues to operate safely and reliably, with no material operational disruptions, safety incidents, or f

VII. ANTICIPATED TIMELINE AND MILESTONES Based on the current status of the tariff redesign and the progress described in this Status Report, Ridgeline anticipates the following timeline and milestones for the completion of the redesigned tariff and supplemental testimony: Ridgeline currently anticipates meeting the February 21, 2025 filing deadline established by the March 4 Order. The redesigned tariff filing will

VIII. REQUEST FOR CONTINUED DORMANT STATUS Ridgeline respectfully requests that this proceeding remain on dormant status pending the February 21, 2025 filing deadline. The dormant status was established by ALJ Whitfield's order dated September 8, 2023, in connection with the granting of Ridgeline's second motion for extension of time, and was continued by the March 4 Order. Maintaining the proceeding on dormant statu

IX. SERVICE AND COMMUNICATION A copy of this First Quarterly Status Report is being served on all parties on the Commission's official service list for Docket Nos. RP22-847-000 and RP22-847-001. The parties on the service list, and their respective counsel and representatives, are as follows: FERC Trial Staff: Jonathan Briggs, Lead Trial Attorney Dr. Miriam Okafor, Lead Economic Analyst Office of Energy Market Regula

X. CONCLUSION For the reasons set forth above, Ridgeline respectfully submits this First Quarterly Status Report and requests that the Commission take note of the progress described herein. Ridgeline remains committed to completing the tariff redesign and filing the redesigned FERC Gas Tariff, Original Volume No. 1, and supplemental testimony on or before the February 21, 2025 deadline established by the March 4 Orde