Contract analysis

I. INTRODUCTION AND QUALIFICATIONS A. Witness Identification Q. Please state your full name, title, and business address. A. My name is Dr. Natasha Orlov. I am the Director of Rates & Regulatory at Ridgeline Midstream Services LLC ("Ridgeline" or the "Company"). My business address is 700 Kanawha Boulevard East, Suite 1400, Charleston, West Virginia 25301. Q. Please describe Ridgeline Midstream Services LLC. A. Ridge

1. Inadequate cost-of-service support for the proposed 14.00% return on equity ("ROE");

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

3. Failure to include an interruptible transportation ("IT") rate derivation;

4. Insufficiently supported 100% load factor billing determinant assumption;

5. Absence of capacity release provisions in the General Terms and Conditions ("GT&Cs");

6. Incomplete compliance with NAESB WGQ standards in the operational flow order ("OFO") provisions;

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

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

9. Failure to file the Interconnection Agreement between Ridgeline and Appalachian Trunk Pipeline Company, LLC ("ATPC") as a FERC rate schedule;

10. Absence of a penalty revenue crediting mechanism;

11. Inadequate creditworthiness provisions;

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

13. Absence of greenhouse gas ("GHG") emission cost recovery provisions; and

14. Failure to address FERC Order No. 2222 distributed energy resource ("DER") aggregation implications. Q. Did Ridgeline previously respond to any of the deficiency items? A. Yes. Ridgeline filed a partial response on March 15, 2023, which addressed eight of the fourteen deficiency items — specifically, Items 1 through 4 and Items 7 through 10. However, the partial response did not fully resolve all issues raised by

II. OVERVIEW OF THE REDESIGNED TARIFF A. Tariff Structure — Revised FERC Gas Tariff, Original Volume No. 1 Q. Please describe the structure of the redesigned FERC Gas Tariff, Original Volume No. 1. A. The redesigned FERC Gas Tariff, Original Volume No. 1, is structured as a Part 284, Subpart G open-access transportation tariff, consistent with the Commission's regulations governing open-access transportation by inter

III. DEFICIENCY ITEM 1: RETURN ON EQUITY SUPPORT A. Deficiency Identified Q. What deficiency did OEMR identify with respect to Ridgeline's proposed return on equity? A. In the January 19, 2023 Deficiency Letter, OEMR found that Ridgeline had provided inadequate cost-of-service support for its proposed ROE of 14.00%. Specifically, OEMR noted that the DCF proxy group analysis submitted in support of the original ROE wa

IV. DEFICIENCY ITEM 2: FUEL-USE AND LOST-AND-UNACCOUNTED-FOR GAS (FL&U) TRACKER MECHANISM A. Deficiency Identified Q. What deficiency did OEMR identify regarding fuel use and lost-and-unaccounted-for gas? A. The January 19, 2023 Deficiency Letter noted that Ridgeline's original tariff did not include any mechanism for tracking fuel use and lost-and-unaccounted-for ("FL&U") gas on the Ridgeline Pipeline System. The De

V. DEFICIENCY ITEM 3: INTERRUPTIBLE TRANSPORTATION (IT) RATE DERIVATION A. Deficiency Identified Q. What deficiency did OEMR identify regarding interruptible transportation service? A. The January 19, 2023 Deficiency Letter noted that Ridgeline's original tariff filing failed to include a rate schedule for interruptible transportation service or a derivation of the interruptible transportation rate. OEMR stated that

VI. DEFICIENCY ITEM 4: LOAD FACTOR BILLING DETERMINANT ASSUMPTION A. Deficiency Identified Q. What deficiency did OEMR identify regarding the load factor billing determinant assumption? A. The January 19, 2023 Deficiency Letter found that Ridgeline's original filing assumed a 100% load factor in calculating its billing determinants, and that this assumption was insufficiently supported by the record. OEMR noted that

VII. DEFICIENCY ITEM 5: CAPACITY RELEASE PROVISIONS A. Deficiency Identified Q. What deficiency did OEMR identify regarding capacity release provisions? A. The January 19, 2023 Deficiency Letter identified the absence of capacity release provisions in the General Terms and Conditions of Ridgeline's original tariff as a deficiency. OEMR noted that Commission regulations at 18 C.F.R. § 284.8 require that open-access tr