Contract analysis

I. Executive Summary and Purpose A. Purpose The purpose of this memorandum is to benchmark the proposed recourse rate of Ridgeline Midstream Services LLC ("Ridgeline" or the "Company") against comparable FERC-jurisdictional interstate natural gas pipelines operating in the Appalachian Basin. This benchmarking analysis is being performed in direct support of the redesigned tariff filing that Ridgeline anticipates subm

II. Ridgeline Pipeline System — Summary of Key Parameters A. System Description Ridgeline Midstream Services LLC operates a 187-mile, 24-inch-diameter high-pressure natural gas pipeline system located in the Appalachian Basin, traversing portions of West Virginia and southwestern Pennsylvania. The system is designed to provide firm and interruptible transportation service for natural gas produced in the prolific Marc

III. Benchmarking Methodology A. Selection of Comparable Pipelines The identification of comparable pipelines for this benchmarking analysis was guided by a set of six selection criteria designed to ensure that the comparison group is both relevant to Ridgeline's specific characteristics and sufficiently broad to capture the range of rates and operational parameters observed among Appalachian Basin pipelines. The sel

1. FERC Jurisdiction. The pipeline must be a FERC-jurisdictional interstate natural gas pipeline, subject to the Commission's ratemaking authority under the Natural Gas Act ("NGA") and the Natural Gas Policy Act of 1978 ("NGPA").

2. Geographic Location. The pipeline must be located primarily in the Appalachian Basin, defined for purposes of this analysis as the states of Pennsylvania, West Virginia, Ohio, and New York. This geographic filter ensures that the comparable pipelines face similar terrain, construction cost environments, regulatory conditions, and market dynamics as Ridgeline.

3. Open-Access Transportation. The pipeline must be operational and providing open-access transportation service under Part 284, Subpart G of the Commission's regulations, 18 C.F.R. Part 284, Subpart G. This requirement excludes Hinshaw pipelines, local distribution companies, and gathering systems that are not subject to FERC's open-access transportation requirements.

4. Design Capacity. The pipeline must have a design capacity of between 500 MMcf/d and 5.0 Bcf/d. This range is broad enough to capture systems that are meaningfully comparable to Ridgeline's 1.2 Bcf/d design capacity while excluding both very small intrastate systems and very large transcontinental pipeline systems whose cost structures and market dynamics are fundamentally different.

5. Vintage. The pipeline system must have been placed in service or undergone a significant capacity expansion within the past 15 years (i.e., since approximately 2009). This requirement ensures that the comparable group reflects contemporary construction costs, financing terms, and regulatory standards, rather than legacy systems whose rate bases have been substantially depreciated over many decades.

6. Data Availability. Publicly filed tariff data and FERC Form No. 2 annual report data must be available for the pipeline, sufficient to derive the key metrics required for the benchmarking comparison. Applying these criteria, the analysis identified five comparable pipelines, all operating in the Appalachian Basin:

1. Appalachian Trunk Pipeline Company, LLC ("ATPC") — a 640-mile system with a design capacity of 3.8 Bcf/d, operating in Pennsylvania and adjoining states. ATPC is the interconnecting pipeline in this proceeding.

2. Brindoval Gas Transmission LLC ("Brindoval") — a 312-mile, 30-inch system serving Pennsylvania and Ohio markets.

3. Allegany Valley Pipeline Company LP ("Allegany Valley") — a 198-mile, 24-inch system running from northern West Virginia to southwestern New York. Allegany Valley is the most directly comparable system to Ridgeline in terms of diameter, length, and design capacity.

4. Marcellus Gateway Pipeline LLC ("Marcellus Gateway" or "MGPC") — a 245-mile, 36-inch system operating in Pennsylvania and New Jersey, with a design capacity of 2.1 Bcf/d.

5. Northern Ridge Interstate Pipeline Inc. ("Northern Ridge") — a 156-mile, 20-inch system operating in Pennsylvania, with a design capacity of 750 MMcf/d. Data Sources. The data used in this benchmarking analysis was drawn from the following publicly available sources: (i) tariff filings posted on the FERC eLibrary, including initial rate filings, rate case filings, negotiated rate filings, and tariff amendments; (i

IV. Comparable Pipeline Profiles This section provides detailed profiles of each of the five comparable pipelines identified in the benchmarking analysis. Each profile summarizes the pipeline's physical characteristics, financial parameters, regulatory history, and key rate metrics. A. Appalachian Trunk Pipeline Company, LLC (ATPC) FERC Code: 840117 System Overview. ATPC operates a 640-mile interstate natural gas pip

V. Comparative Analysis This section presents a side-by-side comparative analysis of Ridgeline and the five comparable pipelines across each of the key benchmarking metrics. The analysis demonstrates that Ridgeline's revised proposed recourse rate falls within the range of comparable pipeline rates, and that Ridgeline's underlying cost-of-service and rate-design parameters are consistent with industry norms for Appal

I. Depreciation Rate Comparison Range. Depreciation rates range from 2.22% (ATPC, Marcellus Gateway) to 2.86% (Northern Ridge). Analysis. Ridgeline's depreciation rate of 2.50% is within the observed range and is identical to the rates used by Brindoval and Allegany Valley, the two systems that are among the most comparable to Ridgeline. The 2.50% rate implies a useful life of 40 years, which is consistent with FERC'

VI. Implications for Intervenor Positions The benchmarking analysis presented in this memorandum has direct and significant implications for the positions advanced by each of the principal intervenors in this proceeding. This section assesses each intervenor's rate-related arguments in light of the comparable pipeline data. A. ATPC Position Appalachian Trunk Pipeline Company, LLC, represented by Kellner, Royce & Dill

VII. Sensitivity Analyses This section presents a series of sensitivity analyses designed to illustrate the impact of changes in key rate-design assumptions—specifically load factor and ROE—on Ridgeline's proposed recourse rate. The sensitivity analyses provide the Ridgeline team with a quantitative framework for evaluating settlement alternatives and for anticipating the arguments likely to be advanced by intervenor