Contract analysis

I. Executive Summary The purpose of this memorandum is to set forth the comprehensive strategy and detailed work plan for the redesign of Ridgeline Midstream Services LLC's ("Ridgeline" or the "Company") FERC Gas Tariff, Original Volume No. 1 (the "Tariff"), as necessitated by the Deficiency Letter issued on January 19, 2023, by the Federal Energy Regulatory Commission's ("FERC" or the "Commission") Office of Energy

II. Background and Current Procedural Posture A. The Ridgeline Pipeline System The Ridgeline Pipeline System (the "System") is a 187-mile, 24-inch-diameter high-pressure natural gas pipeline extending from the Wetzel County Interconnect in Wetzel County, West Virginia (approximate coordinates 39.6120° N, 80.7540° W) to the Waynesburg Compressor Station in Greene County, Pennsylvania (approximate coordinates 39.8965°

III. Analysis of the 14 Deficiency Items This section provides a detailed analysis of each of the fourteen deficiency items identified in the Deficiency Letter. The analysis is organized into two subsections: Section III.A addresses the eight items that were the subject of Ridgeline's partial response filed March 15, 2023, while Section III.B addresses the six outstanding items that remain to be fully resolved throug

IV. Proposed Strategic Approach to the Tariff Redesign A. Overarching Strategy The proposed strategy calls for a complete redesign of FERC Gas Tariff, Original Volume No. 1, addressing all fourteen deficiency items identified in the January 19, 2023 Deficiency Letter. The redesign is not merely an incremental revision of the original tariff but rather a fundamental restructuring of the rate design methodology, accomp

1. Rate Schedule FT-1 (Firm Transportation): Revised reservation and usage charges reflecting the modified fixed-variable rate methodology at 75% load factor and the revised ROE. This is the core rate schedule of the tariff.

2. Rate Schedule IT-1 (Interruptible Transportation): New rate schedule providing a complete derivation of the IT rate and all terms and conditions of IT service. (Deficiency Item 3)

3. General Terms and Conditions: Substantially revised to address Deficiency Items 5, 6, 7, 8, 10, 11, 12, 13, and 14. The GT&C will include, at a minimum: • Capacity Release Provisions (Item 5) • NAESB-compliant Operational Flow Order and Balancing Provisions (Item 6) • EBB Posting Requirements (Item 7) • Shipper-Must-Have-Title Provisions (Item 8) • Penalty Revenue Crediting Mechanism (Item 10) • Creditworthiness P

4. Form of Service Agreement: Updated to conform to the revised rate schedules and GT&C.

5. Interconnection Agreement: To be filed as a FERC rate schedule, incorporating the finalized terms of the Ridgeline-ATPC Interconnection Agreement. (Deficiency Item 9)

6. FL&U Tracker: New mechanism establishing the procedures for tracking and recovering fuel-use and lost-and-unaccounted-for gas costs. (Deficiency Item 2) Each of these components will be drafted by C&H, with economic and rate design input from Braswell and operational input from Ridgeline's engineering and rates teams.

V. Coordination Framework with Braswell Energy Consulting Group LLC A. Engagement Scope and Deliverables The Braswell engagement (engagement number BEC-2023-0041) encompasses the following specific deliverables, each of which corresponds to one or more aspects of the tariff redesign: (1) Updated DCF Proxy Group Analysis: A comprehensive discounted cash flow analysis using an updated proxy group of comparable publicly