Contract analysis

I. Introduction and Purpose of Filing Calderwood & Harkness LLP, on behalf of its client Ridgeline Midstream Services LLC ("Ridgeline" or "RMS"), a Delaware limited liability company with its principal office at 700 Kanawha Boulevard East, Suite 1400, Charleston, West Virginia 25301, hereby submits the enclosed redesigned FERC Gas Tariff, Original Volume No. 1, together with supplemental pre-filed testimony and suppo

II. Background and Procedural History On May 12, 2022, Ridgeline filed with the Commission its application seeking approval of an initial tariff rate for interstate transportation service on the Ridgeline Pipeline System and authorization for physical interconnection with the pipeline network of Appalachian Trunk Pipeline Company, LLC ("ATPC") at the Wetzel County Interconnect, located in Wetzel County, West Virginia

III. Description of Enclosed Filing Materials The enclosed filing consists of the following materials, each of which is described in greater detail in the subsections below. A. Redesigned FERC Gas Tariff, Original Volume No. 1 Ridgeline submits herewith its complete Redesigned FERC Gas Tariff, Original Volume No. 1, filed as a Part 284, Subpart G open-access transportation tariff for interstate natural gas pipeline s

IV. Summary of Revised Rate Design and Cost of Service The following is a summary of Ridgeline's revised rate design and cost-of-service analysis, as presented in the supplemental pre-filed testimony of Angela Moretti and Dr. Natasha Orlov and the supporting exhibits. A detailed description of each component and the methodologies employed is set forth in the testimony and exhibits. A. Rate Base Ridgeline's total rate

V. Summary of Responses to Deficiency Items The redesigned FERC Gas Tariff, Original Volume No. 1, and the supplemental pre-filed testimony submitted herewith collectively and comprehensively address each of the fourteen (14) deficiency items identified in the Commission's Deficiency Letter of January 19, 2023. The following is a summary of how each deficiency item has been addressed. Detailed discussion and justific

VI. Interconnection Authorization The filing includes updated interconnection authorization materials for physical interconnection with ATPC at the Wetzel County Interconnect. The Wetzel County Interconnect is located at milepost 0.0 of the Ridgeline Pipeline System, where Ridgeline's 24-inch mainline ties into ATPC's existing 30-inch mainline at ATPC Milepost 412.6 in Wetzel County, West Virginia. The interconnectio

VII. Request to Reactivate Proceeding and Lift Dormant Status Ridgeline respectfully requests that the Commission lift the dormant status designation that was imposed on this proceeding by ALJ Whitfield's order of September 8, 2023 in connection with the grant of the second extension of time. Now that Ridgeline has completed its comprehensive response to all fourteen deficiency items and has filed the redesigned tari

1. A period for answering and responsive testimony by intervenors and Commission Trial Staff to the redesigned tariff and supplemental pre-filed testimony submitted herewith;

2. A period for rebuttal testimony by Ridgeline;

3. A technical conference, if the presiding judge determines that such a conference would be beneficial to narrow the issues for hearing;

4. An evidentiary hearing; and

5. An initial decision by the presiding judge. Ridgeline is prepared to proceed expeditiously and will cooperate with the Commission and all parties in establishing a schedule that provides adequate time for thorough review of the filing while also ensuring that the proceeding moves forward in a timely manner. Ridgeline notes that settlement discussions remain ongoing and reserves the right to continue settlement neg

VIII. Settlement Status As noted in Section II of this letter, four settlement conferences have been held before Settlement Judge Howard Margolis on November 30, 2022; March 8, 2023; July 12, 2023; and January 18, 2024. While the settlement conferences have been productive in narrowing certain areas of dispute among the parties, no settlement has been reached to date. The parties remain approximately $0.058/Dth apart

1. Return on Equity. ATPC has proposed an ROE of 10.75%, MGPC has proposed an ROE of 11.25%, and Ridgeline proposes an ROE of 12.50%. The spread between the parties' positions on ROE represents the single largest component of the rate differential.

2. Interconnection Cost Allocation. ATPC advocates for a 50/50 split of interconnection costs, which would result in each party bearing $11.15 million. Ridgeline maintains its proposed allocation of 34.1% to Ridgeline ($7.6 million) and 65.9% to ATPC ($14.7 million), based on cost-causation principles.

3. Load Factor. The intervenors (ATPC, MGPC, and CMGA) have advocated for a load factor of 85% or higher, which would increase the billing determinants and decrease the recourse rate. Ridgeline proposes a 75% load factor, supported by the analysis in Dr. Orlov's supplemental testimony. Ridgeline remains willing to engage in further settlement discussions and believes that the comprehensive redesign of the tariff and

IX. Service and Filing Details Copies of this filing, including the transmittal letter and all enclosed documents described herein, have been served on all parties listed on the official service list in FERC Docket Nos. RP22-847-000 and RP22-847-001 as of the date of this filing. The following parties have been served: • Appalachian Trunk Pipeline Company, LLC — served through counsel: William Pratt, Esq., Kellner, R

X. Listing of Enclosed Documents The following documents are enclosed with this filing:

1. Redesigned FERC Gas Tariff, Original Volume No. 1, for Ridgeline Midstream Services LLC (clean and redline versions);

2. Supplemental Pre-Filed Testimony of Dr. Natasha Orlov, Director of Rates & Regulatory, Ridgeline Midstream Services LLC (with exhibits);

3. Supplemental Pre-Filed Testimony of Angela Moretti, VP, Finance & Treasurer, Ridgeline Midstream Services LLC (with exhibits);

4. Updated Exhibits A through P, including revised cost-of-service schedules, rate base calculations, rate design workpapers, system map, operating data, depreciation schedules, and capital structure supporting documentation;

5. Interconnection Agreement between Ridgeline Midstream Services LLC and Appalachian Trunk Pipeline Company, LLC (filed as a FERC rate schedule);

6. Statement of Nature of Filing and Tariff Summary per 18 C.F.R. § 154.7;

7. Verification and Certificate of Accuracy, signed by James K. Winfield, Chief Executive Officer & President, Ridgeline Midstream Services LLC; and

XI. Contact Information for Correspondence All correspondence and communications regarding this filing should be directed to the following counsel for Ridgeline: George Trujillo, Partner Calderwood & Harkness LLP 1601 K Street NW, Suite 900 Washington, DC 20006 Telephone: (202) 555-4110 Email: gtrujillo@calderwoodharkness.com Brett Callahan, Lead Associate Calderwood & Harkness LLP 1601 K Street NW, Suite 900 Washing

XII. Closing Ridgeline respectfully requests that the Commission accept the enclosed redesigned FERC Gas Tariff, Original Volume No. 1, and supplemental pre-filed testimony for filing; lift the dormant status designation on this proceeding; and direct the reactivation of the Track II procedural schedule so that this proceeding may proceed to hearing and resolution. Ridgeline stands ready to participate fully in all f