Contract analysis

I. INTRODUCTION AND SUMMARY OF RELIEF REQUESTED Ridgeline Midstream Services LLC ("Ridgeline" or "Applicant"), by and through its undersigned counsel, Calderwood & Harkness LLP, respectfully moves the presiding Administrative Law Judge, the Honorable Clara Whitfield, pursuant to Rule 212 of the Commission's Rules of Practice and Procedure, 18 C.F.R. § 385.212 (2023), for a third extension of time of twelve (12) month

II. BACKGROUND AND PROCEDURAL HISTORY A. Initiation of the Proceeding On May 12, 2022, Ridgeline filed with the Commission its application for an initial tariff rate for interstate natural gas transportation service on the Ridgeline Pipeline System, together with an application for authorization for physical interconnection with Appalachian Trunk Pipeline Company, LLC ("ATPC") at the Wetzel County Interconnect, Wetze

III. GOOD CAUSE FOR THE REQUESTED EXTENSION Good cause exists for the requested twelve-month extension. Since the granting of the second extension on September 8, 2023, the scope of the tariff redesign has expanded materially beyond what was originally anticipated, rendering the current February 23, 2024 deadline insufficient to complete the comprehensive filing that is now required. The specific bases for this motio

1. Shift from 100% to 75% Load Factor. The original filing used a 100% load factor to derive billing determinants, producing annual billing determinants of 438,000,000 Dth per year (calculated as 1,200,000 Dth/d design-day capacity × 365 days × 100% load factor). Deficiency Item 4 specifically identified this assumption as insufficiently supported, noting the absence of adequate throughput data, historical utilizatio

2. Adoption of Modified Fixed-Variable Rate Design Methodology. The original filing employed a straight cost-of-service rate derivation, under which the total cost of service was divided between reservation and usage components using a simplified allocation methodology. In consultation with Braswell, and in light of the Commission's longstanding preference for rate designs that accurately reflect the cost characteris

3. Updated ROE Based on Revised DCF Proxy Group Analysis. The original filing proposed a 14.00% return on equity based on a DCF proxy group analysis using financial data available prior to 2022. Deficiency Item 1 specifically required an updated proxy group analysis reflecting current market conditions, including changes in interest rates, equity risk premiums, and the financial performance of comparable natural gas

IV. NO PARTY WILL BE PREJUDICED No party to this proceeding will be prejudiced by the requested extension. The proceeding has been in dormant status since September 8, 2023, pursuant to Judge Whitfield's order granting the second extension. No hearing dates, discovery deadlines, rebuttal testimony deadlines, or other procedural milestones are currently pending. The dormant status means that no party faces any time-se

V. PROPOSED CONDITIONS Ridgeline acknowledges that this is the third extension request filed in this proceeding. Ridgeline is reminded of its obligation to demonstrate continued diligence and to provide assurances to the presiding judge and the parties that the extension will be used productively. Ridgeline does not seek this extension for purposes of delay, but rather because the material scope changes to the tariff

VI. REQUESTED RELIEF WHEREFORE, for the foregoing reasons, Ridgeline Midstream Services LLC respectfully requests that the presiding Administrative Law Judge enter an order:

1. Granting a twelve (12)-month extension of the deadline for filing the redesigned FERC Gas Tariff, Original Volume No. 1, and all supplemental pre-filed testimony and exhibits responding to the remaining items identified in the Deficiency Letter, from February 23, 2024 to February 21, 2025;

2. Ordering Ridgeline to file quarterly status reports on the progress of the tariff redesign and settlement discussions on June 15, 2024, September 14, 2024, and December 13, 2024;

3. Maintaining the proceeding in dormant status pending the filing of the redesigned tariff and supplemental testimony; and

4. Granting such other and further relief as the presiding Administrative Law Judge deems just and appropriate.

VII. SERVICE AND COMMUNICATIONS All pleadings, notices, correspondence, and other communications regarding this motion and this proceeding should be directed to the following individuals: George Trujillo Responsible Partner, Energy & Infrastructure Practice Calderwood & Harkness LLP 1601 K Street NW, Suite 900 Washington, DC 20006 Telephone: (202) 555-4100 Email: gtrujillo@calderwoodharkness.com Brett Callahan Lead A

VIII. SIGNATURE Respectfully submitted, CALDERWOOD & HARKNESS LLP By: ________ George Trujillo Responsible Partner, Energy & Infrastructure 1601 K Street NW, Suite 900 Washington, DC 20006 Telephone: (202) 555-4100 Facsimile: (202) 555-4101 Email: gtrujillo@calderwoodharkness.com Brett Callahan Lead Associate, Energy & Infrastructure David Stanton Working Associate, Energy & Infrastructure Counsel for Ridgeline Midst