Contract analysis

I. Executive Summary This memorandum analyzes the Federal Energy Regulatory Commission's ("FERC" or the "Commission") Order No. 2222 and its potential implications for the tariff applicable to the Ridgeline Pipeline System (the "System"), specifically in the context of the comprehensive tariff redesign being undertaken by Ridgeline Midstream Services LLC ("Ridgeline") to cure all fourteen deficiency items identified

II. Background A. The Ridgeline Pipeline System and Current Proceeding Ridgeline Midstream Services LLC is a Delaware limited liability company and a wholly-owned subsidiary of Dunmore Energy Holdings Ltd., a Cayman Islands exempted company. Ridgeline owns and operates the Ridgeline Pipeline System, a 187-mile, 24-inch-diameter high-pressure natural gas pipeline extending from the Wetzel County Interconnect in Wetzel

III. Overview of FERC Order No. 2222 A. Regulatory History and Purpose FERC Order No. 2222, titled Participation of Distributed Energy Resource Aggregations in Markets Operated by Regional Transmission Organizations and Independent System Operators, was issued on September 17, 2020, and is reported at 172 FERC ¶ 61,247. The order represented a landmark rulemaking in the Commission's ongoing efforts to modernize whole

IV. Analysis of Order No. 2222's Impact on Midstream Pipeline Tariffs A. Gas-Electric Interdependency Considerations The Ridgeline Pipeline System does not directly serve gas-fired electric generators. Rather, Ridgeline delivers gas into the broader Appalachian market via its interconnection with Appalachian Trunk Pipeline Company, LLC ("ATPC") at the Wetzel County Interconnect. ATPC operates a 640-mile, 3.8 Bcf/d tr

V. DEH's 250 MW Wind Portfolio: Tariff Implications A. Nature of the Wind Portfolio As noted in Section II.C above, DEH has a 250 MW wind portfolio currently under development. The wind portfolio represents a strategic diversification of DEH's asset base from its traditional natural gas midstream operations into the renewable energy sector. While the specific location and timeline of the wind portfolio have not been

VI. Survey of Other Pipeline Responses to Order No. 2222 A. Industry Trends Order No. 2222 is a relatively recent rulemaking, and the compliance filing process at the RTO/ISO level has been protracted—several RTOs and ISOs have not yet received full FERC approval of their Order No. 2222 compliance filings as of the date of this memorandum. In this regulatory environment, few interstate natural gas pipelines have yet

VII. Coordination with Other Deficiency Items A. Cross-References to Related Deficiency Items As noted throughout this memorandum, the Order No. 2222 analysis intersects with several other deficiency items identified in the Deficiency Letter. The Redesigned Tariff should be developed holistically, with the Order No. 2222 provisions integrated into the broader tariff structure in a manner that is consistent with the c

VIII. Intervenor and FERC Staff Positions A. ATPC Position Appalachian Trunk Pipeline Company, LLC ("ATPC") is the principal intervenor in this proceeding and is the operator of the downstream pipeline system with which the Ridgeline Pipeline System interconnects at the Wetzel County Interconnect. ATPC is represented by Kellner, Royce & Dillard LLP, with lead counsel William Pratt, of One PPG Place, Suite 2800, Pitts