Contract analysis

I. Executive Summary Calderwood & Harkness LLP has prepared this gap analysis memorandum to compare the provisions of Ridgeline Midstream Services LLC's ("Ridgeline") proposed FERC Gas Tariff, Original Volume No. 1, against the requirements of the North American Energy Standards Board ("NAESB") Wholesale Gas Quadrant ("WGQ") Version 3.2 standards. The purpose of this memorandum is to identify each discrete area in wh

II. Background A. The FERC Proceeding Ridgeline Midstream Services LLC is a Delaware limited liability company organized under the laws of the State of Delaware and a wholly owned subsidiary of Dunmore Energy Holdings Ltd. ("DEH"), a Cayman Islands exempted limited company (Cayman Islands company registration number CR-381204). DEH is a privately held strategic energy company with operations and investments spanning

III. Methodology This gap analysis was performed on a provision-by-provision basis, comparing each relevant provision of Ridgeline's FERC Gas Tariff, Original Volume No. 1 (as originally filed on May 12, 2022, and as revised through successive tariff redesign drafts) against the applicable requirements of NAESB WGQ Version 3.2. The analysis covers the following NAESB WGQ standard areas:

1. Nominations and Scheduling — WGQ Standard 1.3 (including sub-standards 1.3.1 through 1.3.7), governing nomination timelines, nomination cycles, data elements, confirmation protocols, bumping and priority of service, and scheduling procedures.

2. Flowing Gas Provisions — WGQ Standard 1.4 (including sub-standards 1.4.1 through 1.4.5), governing operational flow orders, OFO issuance criteria, tolerance bands, penalty structures, critical period provisions, and planned maintenance scheduling and posting requirements.

3. Invoicing — WGQ Standard 2.3 (including sub-standards 2.3.1 and 2.3.2), governing invoice content, data elements, delivery timelines, and electronic delivery standards.

4. Data Sets and Data Elements — WGQ Standard 3.3 (including sub-standards 3.3.1 and 3.3.2), governing standardized data sets for nominations, confirmations, and scheduling, and standardized location identifiers.

5. Internet Electronic Transport / Electronic Bulletin Board (EBB) — WGQ Standard 4.3 (including sub-standards 4.3.1 through 4.3.4), governing EBB posting obligations, platform design specifications, posting timing requirements, and standards of conduct for non-discriminatory EBB access.

6. Capacity Release — WGQ Standard 5.3 (including sub-standards 5.3.1 through 5.3.4), governing capacity release posting, bidding procedures, prearranged releases, recall/reput rights, creditworthiness, duration and pricing, award notification, and integration with nomination cycles.

7. Imbalance Management — WGQ Standard 6.3 (including sub-standards 6.3.1 and 6.3.2), governing daily and monthly imbalance tracking, netting, cash-out provisions, imbalance trading, penalty structures, and shipper imbalance reporting.

8. Operational Flow Orders and Critical Periods — Included within WGQ Standards 1.3 and 6.3 and addressed as a cross-cutting issue. The analysis covers both the originally filed tariff (May 12, 2022 filing) and the four successive tariff redesign drafts prepared as part of the comprehensive tariff redesign effort: • First Draft — August 2023 • Second Draft — January 2024 • Third Draft — June 2024 • Fourth Draft — Nov

IV. Gap Analysis — Nominations and Scheduling (WGQ Standard 1.3) A. Nomination Timelines and Cycles NAESB WGQ Standard 1.3.2 requires that interstate natural gas pipelines provide four intraday nomination cycles for the scheduling of transportation service. The four required nomination cycles, with their associated deadlines expressed in Central Clock Time ("CCT"), are as follows: (i) Timely Nomination Cycle — Nomina

V. Gap Analysis — Flowing Gas Provisions (WGQ Standard 1.4) A. Operational Flow Orders (OFOs) — Deficiency Item 6 Core Issue NAESB WGQ Standards 1.4.1 through 1.4.3 establish the framework for operational flow orders, which are directives issued by a pipeline to shippers requiring them to adjust their receipts and deliveries to bring their transportation in line with their scheduled quantities or to address system op

VI. Gap Analysis — Electronic Bulletin Board (EBB) Requirements (WGQ Standard 4.3) — Deficiency Item 7 A. EBB Posting Obligations

Section 284.12 of the Commission's regulations, codified at 18 C.F.R. § 284.12, requires each interstate pipeline transporting gas under Subpart B or G of Part 284 to maintain an electronic bulletin board providing specified informational postings to shippers and the public. NAESB WGQ Standard 4.3 supplements this regulatory requirement by establishing detailed specifications for the content, format, and timing of EB

VII. Gap Analysis — Capacity Release (WGQ Standard 5.3) A. Capacity Release Provisions — Deficiency Item 5 We note at the outset that Deficiency Item 5 (absence of capacity release provisions in the GT&Cs) is being separately addressed in the tariff redesign and is the subject of a separate Calderwood & Harkness memorandum. However, because NAESB WGQ Standard 5.3 governs capacity release business practice standards a