Contract analysis

I. INTRODUCTION AND PURPOSE Ridgeline Midstream Services LLC ("Ridgeline" or "Applicant") hereby submits this Revised Settlement Proposal, designated Version 2.0, in the above-captioned proceedings before the Federal Energy Regulatory Commission ("FERC" or "Commission"). This Version 2.0 supersedes and replaces in its entirety the Version 1.0 settlement proposal circulated by Ridgeline on November 30, 2022, during th

II. PROCEDURAL BACKGROUND A. Filing History On May 12, 2022, Ridgeline filed with the Commission its application for an initial tariff rate and interconnection authorization pursuant to Sections 4 and 7 of the Natural Gas Act ("NGA"), 15 U.S.C. §§ 717c and 717f, and the Commission's regulations at 18 C.F.R. Parts 154, 157, and 284. The application proposed the establishment of Ridgeline's FERC Gas Tariff, Original Vo

III. SUMMARY OF CONCESSIONS IN VERSION 2.0 A. Overview of Changes from Version 1.0 The following table summarizes the material movements from the Version 1.0 settlement proposal (circulated November 30, 2022) to this Version 2.0 proposal: As the table illustrates, Ridgeline has made concessions on three of the most significant disputed issues in this proceeding. These concessions are discussed in detail below. B. Rat

IV. REVISED SETTLEMENT RATE DERIVATION This section sets forth the derivation of Ridgeline's proposed settlement recourse rate under the revised parameters offered in this Version 2.0 proposal. The calculations presented below are based on the originally filed rate base and test-year operating expenses, adjusted for the revised cost of capital parameters offered herein. Ridgeline notes that these calculations are pre

V. INTERCONNECTION TERMS A. Interconnection Facilities Overview The proposed Ridgeline-ATPC interconnection would be located at the Wetzel County Interconnect, consisting of a new meter station and pig launcher/receiver facility at milepost 0.0 of the Ridgeline Pipeline System. The interconnection would tie into ATPC's existing 30-inch mainline at ATPC Milepost 412.6, providing a direct physical connection between th

VI. TARIFF MODIFICATIONS INCORPORATED IN SETTLEMENT PROPOSAL A. Deficiency Items Already Addressed In its March 15, 2023 partial response to the Deficiency Letter, Ridgeline addressed eight (8) of the fourteen (14) deficiency items identified by OEMR. A summary of the status of each addressed item is provided below: Item 1 — Updated ROE Support. The Deficiency Letter required Ridgeline to provide an updated DCF proxy

VII. CONDITIONS AND RESERVATIONS A. Settlement Rate as "Black box" Ridgeline proposes that the settlement rate agreed upon by the parties be treated as a "black box" settlement rate. Under this approach, which is well-established in Commission settlement practice, the overall rate level is agreed upon by the parties as a compromise without any party conceding its specific position on individual cost-of-service compon

VIII. COMPARISON OF PARTY POSITIONS A. Summary Table of Outstanding Disputes The following table summarizes the outstanding positions of the parties on the principal disputed issues in this proceeding: As the table illustrates, Ridgeline's concessions in this Version 2.0 proposal have substantially narrowed the gap between the parties on every disputed issue. CMGA's position is aligned with ATPC on all material issue

IX. REQUESTED ACTION Based on the foregoing, Ridgeline Midstream Services LLC respectfully requests the following:

1. That all parties to this proceeding — including ATPC, MGPC, CMGA, and FERC Trial Staff — review this Revised Settlement Proposal (Version 2.0) and provide written responses within forty-five (45) days, by approximately December 1, 2023;

2. That Settlement Judge Howard Margolis schedule a fifth settlement conference to discuss the Version 2.0 proposal and explore the parameters of a comprehensive settlement agreement, ideally to be convened before year-end 2023; and

3. That the parties engage in focused, good-faith negotiations on the remaining disputed issues — principally ROE and interconnection cost allocation — with the objective of reaching a comprehensive settlement that resolves all outstanding matters in FERC Docket Nos. RP22-847-000 and RP22-847-001. Ridgeline reaffirms its commitment to a negotiated resolution of this proceeding and its willingness to continue good-fai

X. CONTACT INFORMATION FOR SETTLEMENT COMMUNICATIONS All communications regarding this Version 2.0 settlement proposal, including written responses, counterproposals, and requests for technical or legal discussions, should be directed to the following: Legal Counsel: George Trujillo, Responsible Partner Calderwood & Harkness LLP 1601 K Street NW, Suite 900 Washington, DC 20006 Brett Callahan, Lead Associate Calderwoo

1. Settlement Rate. The settlement recourse rate shall be approximately $0.2509/Dth (total), subject to final calculation and reconciliation. The rate shall be treated as a "black box" settlement rate, meaning that the agreed-upon rate level represents a compromise and is not predicated on the parties' agreement on any specific underlying cost-of-service input or methodology.

2. Return on Equity. The ROE shall not be specified in the settlement agreement. Consistent with the "black box" approach, the