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Contract analysis / revised-tariff-third-draft-redline.docx
revised-tariff-third-draft-redline.docx
High · 6
Medium · 3
Standard · 4
I. Purpose and Scope of This Draft
I. Purpose and Scope of This Draft
II. Deficiency Items Addressed in This Draft
II. Deficiency Items Addressed in This Draft Item 2 (FL&U Tracker Mechanism): Corresponding references have been updated in Rate Schedule FT-1, Section 5 and Rate Schedule IT-1, Section 6. The data reporting template in Appendix E . Item 3 (IT Rate Derivation): Item 5 (Capacity Release Provisions): Item 7 (EBB Posting Requirements): **Item 11 (Creditworthiness Provisions) — ** **III. Deficiency Items ** The following
IV. Cost-of-Service and Rate Design
IV. Cost-of-Service and Rate Design • • • • We have coordinated with Dr. Natasha Orlov (Director of Rates & Regulatory) and Angela Moretti (VP Finance & Treasurer) on the cost-of-service inputs underlying the revised cost-of-service model.
V. Braswell Energy Consulting Group Recommendations
V. Braswell Energy Consulting Group Recommendations Dr. Raymond Braswell, lead consultant on Engagement No. BEC-2023-0041, has .
VI. Next Steps
VI. Next Steps We anticipate delivering the , which will incorporate: • • GHG emission cost recovery provisions ; • Order No. 2222 provisions ; • Interconnection agreement (if ATPC negotiations are resolved); • • Please do not hesitate to contact me with any questions or comments on this draft. I recommend that we schedule an internal working group call for the week of to discuss the draft in detail. Brett Callahan C
Section 1: Name and Description of Pipeline
Standard
⚑ Commercial term
Section 1: Name and Description of Pipeline 1.1 The entity filing this tariff is Ridgeline Midstream Services LLC, a limited liability company duly organized and existing under the laws of the State of Delaware (the "Transporter" or "Ridgeline"). Ridgeline's sole member is Dunmore Energy Holdings Ltd. ("DEH"), an exempted limited company organized under the laws of the Cayman Islands, Cayman Registry No. CR-381204. R
Section 2: FERC Regulatory Authority
Section 2: FERC Regulatory Authority 2.1 The Transporter is a natural gas company within the meaning of Section 1(b) of the Natural Gas Act, 15 U.S.C. § 717a(6) ("NGA"), and is subject to the jurisdiction of the Commission with respect to the transportation of natural gas in interstate commerce and the sale of natural gas for resale in interstate commerce. 2.2 This tariff is filed pursuant to the NGA and the Commissi
Section 3: Nature of Service
Section 3: Nature of Service 3.1 The Transporter offers open-access interstate natural gas transportation service on a non-discriminatory basis pursuant to this tariff. Transportation service is available under the following rate schedules: (a) Rate Schedule FT-1 — Firm Transportation Service. Firm transportation service provides shippers with reserved capacity on the System up to their contracted Maximum Daily Quant
Section 4: Effective Date
Medium
⚑ Forum / governing law
Section 4: Effective Date 4.1 The effective date of this tariff, and of all rate schedules, General Terms and Conditions, and appendices contained herein, shall be as determined and approved by the Commission. The original proposed effective date for this tariff has passed; accordingly, a revised effective date will be specified in the transmittal letter accompanying the filing of this tariff with the Commission. 4.2
Section 1: Availability
Section 1: Availability 1.1 Firm Transportation Service ("FT-1 Service") is available under this Rate Schedule FT-1 to any shipper (the "Shipper") that meets the creditworthiness requirements set forth in Section 11 of the General Terms and Conditions and that has executed a Service Agreement for FT-1 Service with Ridgeline Midstream Services LLC (the "Transporter"). 1.2 FT-1 Service provides the Shipper with reserve
Section 2: Applicability and Character of Service
Section 2: Applicability and Character of Service 2.1 FT-1 Service is open-access transportation service provided under Part 284, Subpart G of the Commission's regulations, 18 C.F.R. § 284.221 et seq., pursuant to the Transporter's blanket certificates for open-access transportation. 2.2 FT-1 Service entitles the Shipper to reserved capacity on the System up to the MDQ stated in the Shipper's executed Service Agreeme
Section 3: Rate
Section 3: Rate 3.1 The maximum recourse rates for FT-1 Service, as revised in this draft based on Braswell Energy Consulting Group LLC's updated cost-of-service model, are as follows: 3.2 The rates set forth in Section 3.1 are derived from the following cost-of-service and billing determinant inputs: (a) Rate Base: $612.40 million (unchanged from original filing); (b) Total Cost of Service: $103.15 million (revised)
Section 4: Reservation Charge Obligation
Section 4: Reservation Charge Obligation 4.1 The Shipper shall be obligated to pay the full reservation charge applicable to the Shipper's contracted MDQ, regardless of whether the Shipper actually schedules or transports any gas on the System during the applicable billing period. The reservation charge is a demand charge reflecting the Shipper's reservation of capacity on the System and is payable in full each month
Section 5: Fuel-Use and Lost-and-Unaccounted-For Gas (FL&U) Retainage
Standard
⚑ Commercial term
Section 5: Fuel-Use and Lost-and-Unaccounted-For Gas (FL&U) Retainage 5.1 In addition to the rates and charges set forth in Section 3 of this Rate Schedule, the Transporter shall retain in-kind a percentage of the natural gas tendered by the Shipper at the receipt point to cover fuel consumed at the Transporter's compressor stations and system lost-and-unaccounted-for gas ("FL&U"). This Section 5 is a new provision i
Section 6: Term of Service
Medium
⚑ Notice / time limit to track
Section 6: Term of Service 6.1 The minimum contract term for FT-1 Service shall be one (1) year from the effective date of the Shipper's Service Agreement. 6.2 An existing firm Shipper shall have a right of first refusal ("ROFR") to continue FT-1 Service at the expiration of the Shipper's Service Agreement, subject to the conditions and procedures set forth in Section 13 (Right of First Refusal) of the General Terms
Section 7: Scheduling and Nominations
High
⚑ Penalty / liquidated damages
Section 7: Scheduling and Nominations 7.1 Nominations for FT-1 Service shall be submitted in accordance with the nomination and scheduling procedures set forth in Section 5 of the General Terms and Conditions, which provisions have been revised to conform to NAESB WGQ Version 3.2 standards as required by Deficiency Item 6 of the FERC OEMR Deficiency Letter dated January 19, 2023. 7.2 The Shipper shall submit nominati
Section 8: Capacity Release
Section 8: Capacity Release 8.1 A Shipper holding FT-1 Service capacity ("Releasing Shipper") may release all or a portion of its contracted capacity to a replacement shipper ("Replacement Shipper") in accordance with the capacity release procedures set forth in Section 29 of the General Terms and Conditions. This Section 8 is a to address Deficiency Item 5 of the FERC OEMR Deficiency Letter dated January 19, 2023. 8
Section 1: Availability
Section 1: Availability 1.1 Interruptible Transportation Service ("IT-1 Service") is available under this Rate Schedule IT-1 to any shipper (the "Shipper") that meets the creditworthiness requirements set forth in Section 11 of the General Terms and Conditions and that has executed a Service Agreement for IT-1 Service with Ridgeline Midstream Services LLC (the "Transporter"). 1.2 IT-1 Service is provided on an interr
Section 2: Applicability and Character of Service
Section 2: Applicability and Character of Service 2.1 IT-1 Service is open-access interruptible transportation service provided under Part 284, Subpart G of the Commission's regulations, 18 C.F.R. § 284.221 et seq., pursuant to the Transporter's blanket certificates for open-access transportation. 2.2 IT-1 Service is interruptible in nature. The Shipper receiving IT-1 Service has no guaranteed right to capacity on th
Section 3: Interruptible Transportation Rate
Section 3: Interruptible Transportation Rate 3.1 The maximum rate for IT-1 Service has been derived in accordance with the Commission's established methodology, as the 100% load factor equivalent of the maximum firm reservation rate under Rate Schedule FT-1, calculated on a per-Dth basis. Specifically: IT Maximum Rate = FT-1 Maximum Reservation Rate + FT-1 Maximum Usage Rate IT Maximum Rate = $0.3102/Dth + $0.0038/Dt
Section 4: IT Revenue Crediting
High
⚑ Penalty / liquidated damages
Section 4: IT Revenue Crediting 4.1 Revenues received by the Transporter from IT-1 Service shall be credited to firm Shippers under Rate Schedule FT-1 in accordance with the methodology set forth in Section 30 of the General Terms and Conditions. 4.2 The IT revenue crediting mechanism addresses the Commission's policy requiring that interruptible transportation revenues be shared with firm Shippers who bear the fixed
Section 5: Scheduling Priority
Medium
⚑ Notice / time limit to track
Section 5: Scheduling Priority 5.1 IT-1 Service nominations shall be scheduled only after all firm nominations under Rate Schedule FT-1 have been confirmed and scheduled for the applicable Day. The Transporter shall schedule IT-1 Service nominations only to the extent that System capacity remains available after the satisfaction of all firm service commitments. 5.2 IT-1 Service is subject to curtailment or interrupti
Section 6: FL&U Retainage for IT Service
Standard
⚑ Commercial term
Section 6: FL&U Retainage for IT Service 6.1 IT-1 Service shall be subject to the same FL&U retainage percentage applicable to FT-1 Service, as established in Section 27 of the General Terms and Conditions and as set forth in Section 5 of Rate Schedule FT-1. The FL&U retainage percentage for IT-1 Service is 2.8%, consisting of a fuel use component of 2.3% and a lost-and-unaccounted-for component of 0.5%. 6.2 The FL&U
Section 7: Term of Service
Section 7: Term of Service 7.1 The term of an IT-1 Service Agreement shall be as specified in the Shipper's Service Agreement, with a minimum term of one (1) day. 7.2 Unless terminated by either party, an IT-1 Service Agreement with a specified term shall remain in effect for the duration of such term. IT-1 Service Agreements may also be entered into on a month-to-month basis, continuing in effect until terminated by
Section 1: Definitions
High
⚑ Penalty / liquidated damages
Section 1: Definitions 1.1 As used in this tariff, including all rate schedules, General Terms and Conditions, forms of service agreements, and appendices, the following terms shall have the meanings ascribed to them below. Capitalized terms not defined in this Section 1 shall have the meanings ascribed to them elsewhere in this tariff or, in the absence of a tariff definition, the meanings customarily attributed to
Section 2: Transportation Service Requests and Contracting
Section 2: Transportation Service Requests and Contracting 2.1 Any person or entity desiring to obtain transportation service on the System shall submit a written request to the Transporter. Requests for FT-1 Service and IT-1 Service shall be submitted in writing (including by electronic means) to the Transporter at the notice address specified in Section 19 of these General Terms and Conditions or through such elect
Section 3: Quality Specifications
High
⚑ Indemnity / guarantee obligation
Section 3: Quality Specifications 3.1 All natural gas tendered by a Shipper at a receipt point for transportation on the System shall meet the following quality specifications at the time of tender: 3.2 Gas tendered at the Wetzel County Interconnect shall be subject to analysis by the gas chromatographs installed at the interconnect metering station. The gas chromatograph analysis shall determine the composition and
Section 4: Measurement
Standard
⚑ Commercial term
Section 4: Measurement 4.1 All natural gas received and delivered by the Transporter shall be measured at the applicable receipt point or delivery point using measurement equipment meeting industry standards and the requirements of this Section 4. 4.2 The metering station at the Wetzel County Interconnect shall consist of three (3) runs of 12-inch ultrasonic flow meters, together with associated gas chromatographs, p
Section 5: Nominations and Scheduling
Section 5: Nominations and Scheduling 5.1 This Section 5 sets forth the nomination and scheduling procedures for transportation service on the System. These procedures have been revised to conform to the standards and timelines established by NAESB WGQ Version 3.2, as required by Deficiency Item 6 of the FERC OEMR Deficiency Letter dated January 19, 2023. 5.2 Nominations for all transportation service (FT-1 and IT-1)
Section 6: Operational Flow Orders (OFOs)
High
⚑ Penalty / liquidated damages
Section 6: Operational Flow Orders (OFOs) 6.1 The Transporter may issue Operational Flow Orders ("OFOs") when the Transporter determines, in its reasonable operational judgment, that an OFO is necessary to maintain the operational integrity of the System, to prevent line pack from exceeding or falling below acceptable levels, to protect the System from potential damage, or to ensure safe and reliable service. This Se
Section 7: Balancing and Imbalance Management
High
⚑ Penalty / liquidated damages
Section 7: Balancing and Imbalance Management 7.1 Each Shipper shall use commercially reasonable efforts to maintain daily balance between the quantity of gas tendered at the receipt point and the quantity of gas taken at the delivery point, adjusted for FL&U retainage. The objective of daily balancing is to minimize the accumulation of imbalances that could adversely affect System operations. 7.2 An imbalance shall