Contract analysis

I. PRELIMINARY STATEMENT Ridgeline Midstream Services LLC ("Ridgeline" or "Applicant"), a Delaware limited liability company and a wholly owned subsidiary of Dunmore Energy Holdings Ltd. ("DEH"), a Cayman Islands exempted limited company, by and through its undersigned counsel, Calderwood & Harkness LLP, respectfully moves the Presiding Administrative Law Judge, the Honorable Clara Whitfield, pursuant to Section 385.

II. BACKGROUND AND PROCEDURAL HISTORY A. The Filing and Initial Proceedings On May 12, 2022, Ridgeline filed its application with the Commission in the above-captioned docket, seeking approval of an initial tariff rate for interstate natural gas transportation service on the Ridgeline Pipeline System and authorization for physical interconnection with ATPC at the Wetzel County Interconnect (Wetzel County, West Virgin

1. Inadequate cost-of-service support for proposed 14.00% ROE (no updated proxy group analysis post-2021);

2. Failure to include a fuel-use and lost-and-unaccounted-for gas ("FL&U") tracker mechanism;

3. Missing interruptible transportation ("IT") rate derivation;

4. Insufficient support for 100% load factor billing determinant assumption;

5. No capacity release provisions in General Terms & Conditions;

6. Incomplete NAESB standards compliance in operational flow order provisions;

7. Missing electronic bulletin board ("EBB") posting requirements;

8. Inadequate shipper-must-have-title provisions;

9. Interconnection agreement not filed as a rate schedule;

10. No penalty revenue crediting mechanism;

11. Inadequate creditworthiness provisions;

12. Missing segmentation and flexible receipt/delivery point provisions;

13. No provisions addressing greenhouse gas emission cost recovery; and

14. Failure to address Order No. 2222 distributed energy resource aggregation implications (renewable energy interconnection). The Deficiency Letter was comprehensive in scope and required Ridgeline to develop substantial new tariff provisions that had not been included in its original filing. The deficiency items ranged from relatively straightforward tariff drafting matters (such as the EBB posting requirements and

III. GROUNDS FOR THE REQUESTED EXTENSION Ridgeline respectfully submits that good cause exists for the requested 180-day extension, from August 28, 2023 to February 23, 2024, based on the following grounds. A. Scope and Complexity of the Remaining Tariff Redesign The six remaining deficiency items — Items 5, 6, 11, 12, 13, and 14 — require the development of substantial new tariff provisions that were not part of Rid

IV. PROPOSED NEW DEADLINE Based on the foregoing, Ridgeline respectfully requests that the deadline for filing the complete response to the Deficiency Letter, including the redesigned FERC Gas Tariff, Original Volume No. 1, and any supplemental testimony, be extended by one hundred eighty (180) days from the current deadline of August 28, 2023 to February 23, 2024. This proposed timeline is consistent with the expect

V. COMMUNICATIONS WITH OTHER PARTIES Pursuant to 18 C.F.R. § 385.2008(a) and the Presiding Judge's standing procedural order, undersigned counsel has communicated with counsel for all active parties in this proceeding regarding the substance of this motion prior to its filing. The positions of the parties are as follows: Appalachian Trunk Pipeline Company, LLC ("ATPC"). Undersigned counsel communicated with William P

VI. REQUEST FOR RELIEF WHEREFORE, Ridgeline Midstream Services LLC respectfully requests that the Presiding Administrative Law Judge, the Honorable Clara Whitfield, enter an order:

1. Granting this Motion for Extension of Time;

2. Extending the deadline for Ridgeline to file its complete response to the January 19, 2023 Deficiency Letter issued by the Office of Energy Market Regulation, including the redesigned FERC Gas Tariff, Original Volume No. 1, and any supplemental testimony, from August 28, 2023 to February 23, 2024;

3. Continuing the stay of the procedural schedule in this proceeding pending Ridgeline's filing of its complete response; and

4. Granting such other and further relief as may be just and appropriate. Respectfully submitted, CALDERWOOD & HARKNESS LLP By: ________ George Trujillo Responsible Partner, Energy & Infrastructure Brett Callahan Lead Associate, Energy & Infrastructure David Stanton Working Associate, Energy & Infrastructure 1601 K Street NW, Suite 900 Washington, DC 20006 Telephone: (202) 555-4200 Facsimile: (202) 555-4201 Counsel f