Contract analysis

I. PRELIMINARY STATEMENT Ridgeline Midstream Services LLC ("Ridgeline" or "Applicant"), a Delaware limited liability company and wholly owned subsidiary of Dunmore Energy Holdings Ltd. ("DEH"), a Cayman Islands exempted limited company, hereby submits this Answer to the Protest filed by Appalachian Trunk Pipeline Company, LLC ("ATPC") on August 15, 2022 (the "Protest"). This Answer is filed pursuant to Rule 213 of th

II. BACKGROUND A. The Ridgeline Pipeline System Ridgeline owns and operates the Ridgeline Pipeline System (the "System"), a 187-mile, 24-inch-diameter high-pressure natural gas pipeline extending from a receipt point at the Wetzel County Interconnect in Wetzel County, West Virginia (approximate coordinates 39.6120° N, 80.7540° W) to a delivery point at the Waynesburg Compressor Station in Greene County, Pennsylvania

III. ARGUMENT A. ATPC's Challenge to the Metering Station Design Is Without Merit ATPC's Protest devotes considerable attention to challenging the engineering design of the proposed Metering Station at the Wetzel County Interconnect. ATPC's argument rests on the premise that the proposed three-run ultrasonic flow meter configuration, combined with the gas chromatograph and SCADA systems specified in the Application,

1. The Proposed Metering Configuration Meets or Exceeds Industry Standards The Metering Station design set forth in the Application is the product of a rigorous engineering analysis conducted under the supervision of Thomas Greaves, Vice President of Engineering & Operations at Ridgeline, and reviewed by qualified third-party engineering consultants. The design was developed in accordance with AGA Report No. 9, Measu

2. Three-Run Ultrasonic Configuration Is Adequate for Bidirectional Flow ATPC's central technical argument is that the three-run ultrasonic flow meter configuration is "inadequate" for bidirectional service at the proposed 800 MMcf/d design capacity. This assertion is factually incorrect and technically unfounded. The three-run configuration specified in the Application provides full redundancy for custody-transfer m

3. Gas Chromatograph and SCADA Integration Are Comprehensive ATPC's Protest raises generalized concerns about gas quality monitoring and SCADA integration at the Wetzel County Interconnect. These concerns are addressed directly by the Metering Station design as specified in the Application. The proposed gas chromatographs will provide continuous compositional analysis at sampling intervals of no more than three minut

1. The Total Interconnection Facilities Cost The total estimated cost of the interconnection facilities at the Wetzel County Interconnect is $22.3 million. This figure encompasses all facilities required to establish a physical interconnection between Ridgeline's 24-inch pipeline system and ATPC's 30-inch mainline at Milepost 412.6 on the ATPC System. The estimate was prepared by Ridgepoint Appraisal & Valuation Inc.

2. Ridgeline's Proposed Allocation: 34.1% / 65.9% Ridgeline proposes to bear $7.6 million (34.08%) of the total interconnection facilities cost and to allocate $14.7 million (65.92%) to ATPC. This allocation is not arbitrary; it is based on a detailed, facility-by-facility cost-causation analysis that identifies which interconnection facilities are required due to the physical characteristics, system configuration, m

3. FERC Precedent Supports Cost-Causation-Based Allocation The Commission has long recognized that interconnection costs should be allocated based on cost causation — the fundamental regulatory principle that the party whose system requirements necessitate particular facilities should bear the cost of those facilities. This principle has been articulated and applied in numerous Commission orders addressing interconne

4. ATPC's 50/50 Proposal Improperly Shifts Costs to Ridgeline ATPC's proposed 50/50 allocation would require Ridgeline to bear $11.15 million — an increase of $3.55 million over the cost-causation-based allocation proposed in the Application — for facilities that Ridgeline will neither own nor operate. This outcome would require Ridgeline to subsidize the cost of modifications to ATPC's own system and facilities that

5. ATPC's Argument That Ridgeline Is the "Primary Beneficiary" Is Misplaced ATPC argues that Ridgeline is the "primary beneficiary" of the proposed interconnection and that this perceived benefit justifies requiring Ridgeline to bear a greater share of the interconnection costs. This argument fundamentally confuses the concept of benefit with the concept of cost causation, and the Commission has repeatedly declined t

IV. RESPONSE TO ATPC'S SPECIFIC ALLEGATIONS In addition to the arguments addressed above, Ridgeline responds below to each specific allegation set forth in ATPC's Protest, providing a point-by-point rebuttal of ATPC's technical and economic claims. A. ATPC Allegation: Metering Station Design Is "Inadequate" ATPC's Protest alleges that the proposed Metering Station design at the Wetzel County Interconnect is "inadequa

V. REQUEST FOR RELIEF WHEREFORE, for the reasons set forth herein, Ridgeline Midstream Services LLC respectfully requests that the Commission:

1. Deny ATPC's Protest in its entirety, including both ATPC's challenge to the Metering Station design and ATPC's challenge to the proposed cost allocation methodology;

2. Affirm the adequacy of the proposed metering station design at the Wetzel County Interconnect, including the three-run ultrasonic flow meter configuration, the dual-redundant gas chromatograph installation, and the SCADA integration design, as meeting or exceeding applicable industry standards and Commission requirements;

3. Affirm the proposed cost allocation of $7.6 million to Ridgeline (34.08%) and $14.7 million to ATPC (65.92%) for the $22.3 million total interconnection facilities cost, as consistent with cost-causation principles and Commission precedent;

4. Proceed with the Track II hearing schedule as established in the Commission's September 22, 2022 order, without delay; and

5. Grant such other and further relief as the Commission deems just, reasonable, and appropriate.

VI. CONCLUSION For the foregoing reasons, ATPC's Protest is without merit on both counts and should be denied. The Metering Station design at the Wetzel County Interconnect meets or exceeds applicable industry standards, including AGA Report No. 9 and GPA Midstream Standard 2261, and is fully adequate for bidirectional flow measurement at the proposed 800 MMcf/d design capacity, with expansion capability to 1.2 Bcf/d