1016-00005 · Dunmore Energy Holdings · Interconnection Agreement

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CALDERWOOD & HARKNESS LLP Attorneys at Law

1601 K Street NW, Suite 900 Washington, DC 20006

Telephone: (202) 555-7400 Facsimile: (202) 555-7401 www.calderwoodharkness.com

November 22, 2022

VIA ELECTRONIC MAIL AND FIRST-CLASS MAIL

William Pratt, Esq. Senior Partner Kellner, Royce & Dillard LLP One PPG Place, Suite 2800 Pittsburgh, PA 15222

Re: FERC Docket Nos. RP22-847-000 and RP22-847-001 — Ridgeline Midstream Services LLC / Appalachian Trunk Pipeline Company, LLC Interconnection Agreement Negotiations; Ridgeline's Counterproposal on Metering Station Design at the Wetzel County Interconnect

Dear Mr. Pratt:

I. Introduction and Purpose

This firm represents Ridgeline Midstream Services LLC ("Ridgeline" or "RMS"), a wholly owned subsidiary of Dunmore Energy Holdings Ltd. ("DEH"), in the above-referenced proceedings before the Federal Energy Regulatory Commission ("FERC" or "Commission"), designated as FERC Docket No. RP22-847-000 (Ridgeline's general Section 4 rate case) and FERC Docket No. RP22-847-001 (the contested interconnection proceeding involving Ridgeline and Appalachian Trunk Pipeline Company, LLC ("ATPC")).

As you are aware, ATPC filed its protest and motion to intervene in these proceedings on August 15, 2022, raising objections to, among other things, Ridgeline's proposed metering station design and cost allocation methodology for the proposed physical interconnection at the Wetzel County Interconnect in Wetzel County, West Virginia. Ridgeline filed its answer to ATPC's protest on October 17, 2022, defending both the technical adequacy of its proposed metering station design and the propriety of its cost allocation methodology under applicable Commission precedent. Both filings are incorporated herein by reference.

On September 22, 2022, the Commission issued an order establishing a Track II procedural schedule for the resolution of the interconnection issues, bifurcating those issues from the broader rate case questions to be resolved on the Track I schedule. Consistent with that procedural framework, Administrative Law Judge Clara Whitfield convened a prehearing conference on November 14, 2022, at which the undersigned counsel and your firm appeared on behalf of Ridgeline and ATPC, respectively. During the prehearing conference, ALJ Whitfield encouraged the parties to engage in good-faith negotiations on the technical specifications for the proposed interconnection facilities, with a view toward narrowing the issues in dispute before the direct testimony filing deadline.

The purpose of this letter is to transmit Ridgeline's counterproposal on the metering station design for the proposed physical interconnection at the Wetzel County Interconnect, located at milepost 0.0 of the Ridgeline pipeline system and tying into ATPC's existing 30-inch mainline at ATPC Milepost 412.6 in Wetzel County, West Virginia. This counterproposal is being transmitted in the spirit of advancing the parties' negotiations on the Draft Interconnection Agreement (Version 1.0, initially circulated by Ridgeline in July 2022), and it is Ridgeline's hope that the parties can reach agreement on the technical metering specifications while the broader cost allocation dispute continues to be discussed, both in direct negotiations between counsel and in the settlement conferences before FERC Settlement Judge Howard Margolis.

Ridgeline remains committed to working collaboratively with ATPC and its counsel at Kellner, Royce & Dillard LLP to finalize interconnection terms in an expeditious manner. The direct testimony filing deadline established by ALJ Whitfield is December 5, 2022, and Ridgeline intends to incorporate the metering station design reflected in this counterproposal into the pre-filed direct testimony of Thomas Greaves, Ridgeline's Vice President of Engineering & Operations. Accordingly, we respectfully request ATPC's prompt attention to the counterproposal set forth below and the accompanying technical attachments.

II. Background on the Proposed Interconnection

To place the counterproposal in context, Ridgeline provides the following summary of the relevant pipeline systems and the proposed interconnection point. We recognize that much of this background information is already part of the record in the above-captioned proceedings, but we restate it here for convenience and completeness.

A. The Ridgeline Pipeline System

Ridgeline Midstream Services LLC operates a 187-mile, 24-inch-diameter high-pressure natural gas pipeline system extending from its receipt point at the Wetzel County Interconnect in Wetzel County, West Virginia (approximate coordinates: 39.6120° N, 80.7540° W), to its delivery point at the Waynesburg Compressor Station in Greene County, Pennsylvania (approximate coordinates: 39.8965° N, 80.1810° W). The Ridgeline system has a certificated design capacity of 1.2 Bcf/d (1,200,000 Dth/d) and currently operates at an average throughput of approximately 680 MMcf/d, representing an approximate utilization rate of 56.7%. The system was placed into service on October 1, 2021.

The Ridgeline system includes three compressor stations — the Wetzel Station, the Mannington Station, and the Waynesburg Station — with aggregate installed compression of approximately 45,000 horsepower. The system was constructed at an original cost of approximately $587.2 million, as reflected in the cost-of-service filing in Docket No. RP22-847-000.

Ridgeline Midstream Services LLC is organized as a limited liability company under the laws of the State of Delaware. Its sole member is Dunmore Energy Holdings Ltd. Ridgeline's principal office is located at 700 Kanawha Boulevard East, Suite 1400, Charleston, West Virginia 25301. Its registered agent in Delaware is Capitol Filings Inc., 1209 Orange Street, Wilmington, Delaware 19801. Ridgeline's Employer Identification Number is 87-4231956, and its FERC pipeline code is 960442.

B. ATPC's Existing System

ATPC operates a 640-mile interstate natural gas pipeline system with a current system-wide capacity of approximately 3.8 Bcf/d, serving natural gas markets in Pennsylvania, Ohio, and New York. ATPC's system constitutes one of the primary transmission corridors for Appalachian Basin production and is strategically positioned to receive gas from multiple upstream gathering systems, including the Ridgeline system upon completion of the proposed interconnection.

ATPC is organized as a limited liability company under the laws of the Commonwealth of Pennsylvania. Its principal office is located at 2200 Penn Center West, Suite 300, Pittsburgh, Pennsylvania 15276. ATPC's registered agent in Pennsylvania is Keystone Corporate Services LLC, 600 North Second Street, Harrisburg, Pennsylvania 17101. ATPC's FERC pipeline code is 840117, and its Employer Identification Number is 25-1987643.

ATPC's parent company is Tidewater Infrastructure Partners LP, a Delaware limited partnership controlled by the Alderman family. Harrison J. Alderman serves as Chairman and Marcus R. Alderman serves as President and Chief Executive Officer of Tidewater Infrastructure Partners LP. ATPC's estimated enterprise value, including the Tidewater parent, is approximately $6.1 billion based on publicly available financial information and recent analyst estimates.

C. Proposed Interconnection Point

The proposed interconnection is to be located at the Wetzel County Interconnect, at milepost 0.0 of the Ridgeline pipeline system, where Ridgeline's 24-inch pipeline will tie into ATPC's existing 30-inch mainline at ATPC Milepost 412.6. The interconnection facilities will consist of a new metering station and a pig launcher/receiver, together with associated valving, piping, electrical supply, access road, fencing, and ancillary equipment.

The design capacity at the interconnect point is 800 MMcf/d bidirectional, with the facilities designed to be expandable to 1.2 Bcf/d through the addition of supplemental meter runs at a future date. The original target in-service date for the interconnection facilities was the fourth quarter of 2023; however, as both parties are aware, this target date is now subject to potential delay pending resolution of the contested issues in this proceeding.

The estimated total cost of the interconnection facilities, based on Ridgeline's engineering estimates as submitted in the July 2022 Draft Interconnection Agreement, is approximately $22.3 million. This estimate encompasses all metering equipment, the pig launcher/receiver, site preparation, civil and structural work, electrical and instrumentation, piping, and commissioning costs.

D. ATPC's Protest Concerning the Interconnection

On August 15, 2022, ATPC filed its protest and motion to intervene in this proceeding, raising two principal objections to the proposed interconnection as described in the Draft Interconnection Agreement (Version 1.0). First, ATPC argued that Ridgeline's proposed receipt-point metering station design was technically inadequate, contending that the two-run meter station configuration originally proposed by Ridgeline would be insufficient to accurately measure the full 800 MMcf/d bidirectional design capacity of the interconnection. Second, ATPC contended that the proposed cost allocation methodology, under which ATPC would bear $14.7 million (65.9%) and Ridgeline would bear $7.6 million (34.1%) of the total $22.3 million in interconnection facilities costs, improperly shifted a disproportionate share of costs to ATPC and its shippers.

ATPC, acting through its Vice President of Regulatory Affairs, Sandra K. Fenton, and its outside counsel, William Pratt at Kellner, Royce & Dillard LLP, has advocated for an alternative metering station design and a 50/50 cost allocation framework, under which each party would bear $11.15 million of the total interconnection costs. ATPC's protest also raised certain additional concerns regarding gas quality specifications and custody transfer measurement standards, though those concerns were secondary to the metering design and cost allocation objections.

Ridgeline answered ATPC's protest on October 17, 2022, defending the technical adequacy of its proposed metering station design and the appropriateness of its cost allocation methodology under established Commission precedent, including cost-causation principles and the benefits-received framework articulated in the Commission's interconnection orders. Ridgeline's answer is incorporated herein by reference.

III. Ridgeline's Counterproposal on Metering Station Design

A. Overview of Counterproposal

Having carefully considered the technical concerns raised by ATPC in its August 15, 2022 protest and the subsequent discussions between the parties' engineering teams, Ridgeline hereby submits its revised counterproposal for the metering station design at the Wetzel County Interconnect. This counterproposal addresses certain of ATPC's concerns regarding meter run capacity and measurement redundancy while maintaining Ridgeline's position on the superiority of ultrasonic flow measurement technology and the applicable measurement accuracy requirements.

The counterproposal set forth in this Section III is intended to supplement and, where applicable, replace the metering specifications set forth in Article V ("Measurement") and Exhibit C ("Metering Station Specifications") of the Draft Interconnection Agreement (Version 1.0, circulated by Ridgeline in July 2022). Ridgeline expects that these revised specifications will be incorporated into Version 2.0 of the Draft Interconnection Agreement, which is currently under negotiation between the parties' respective counsel and engineering teams. To the extent that any provision of this counterproposal conflicts with the corresponding provision of the Draft Interconnection Agreement (Version 1.0), this counterproposal shall be deemed to supersede the earlier document for purposes of ongoing negotiations, subject to the parties' mutual agreement on final terms.

B. Ultrasonic Flow Meter Specifications

Ridgeline proposes the installation of ultrasonic flow meters as the primary measurement devices at the Wetzel County Interconnect. Ridgeline has concluded, based on the analysis of its engineering team and consistent with prevailing industry practice for high-volume custody transfer applications, that multipath ultrasonic meters provide superior accuracy, reliability, and long-term operational advantages over alternative measurement technologies, including orifice plate meters.

Configuration. Ridgeline's revised design provides for three (3) meter runs, each equipped with 12-inch ultrasonic flow meters, configured as follows:

• Run No. 1 — Primary measurement run, rated for a throughput range of 0 to 400 MMcf/d. This run will serve as one of two primary measurement paths during normal operations at the interconnect point.

• Run No. 2 — Primary measurement run, rated for a throughput range of 0 to 400 MMcf/d. This run will serve as the second primary measurement path during normal operations, providing combined measurement capacity across Runs No. 1 and No. 2 of up to 800 MMcf/d.

• Run No. 3 — Swing/backup measurement run, rated for a throughput range of 0 to 400 MMcf/d. This run is available for peak flow conditions, scheduled maintenance of either Run No. 1 or Run No. 2, and general redundancy to ensure uninterrupted measurement capability under all operating scenarios.

Capacity. The combined rated capacity across all three meter runs is sufficient to measure the full 800 MMcf/d bidirectional design capacity at the Wetzel County Interconnect. Moreover, the station layout and piping design, as reflected in the revised metering station site plan (Attachment A hereto), accommodate the future addition of two additional meter runs, bringing the total to five runs with a combined measurement capacity sufficient to support the full 1.2 Bcf/d expandable capacity of the interconnection. This expansion capability has been incorporated into the civil and structural design of the metering station from the outset, ensuring that future capacity additions can be achieved without major site modifications.

Accuracy. All ultrasonic meters shall be multipath instruments meeting or exceeding the accuracy requirements set forth in American Gas Association Report No. 9, Measurement of Gas by Multipath Ultrasonic Meters ("AGA Report No. 9"). The minimum accuracy requirement for each meter shall be ±0.5% of reading across the full turndown range of the instrument, under normal operating conditions. This accuracy standard exceeds the requirements typically applied to orifice plate meters under AGA Report No. 3 and provides a superior basis for custody transfer measurement at the interconnect.

Ancillary Equipment. Each meter run shall include the following ancillary equipment and components:

• upstream and downstream flow conditioning elements, designed to ensure a fully developed, symmetrical flow profile at the meter inlet, consistent with the manufacturer's installation requirements and AGA Report No. 9 guidelines;

• Temperature transmitters and pressure transmitters, with accuracy specifications consistent with AGA Report No. 9 requirements for temperature and pressure correction of volumetric flow measurements;

• Inline check valves, positioned to prevent reverse flow through idle meter runs during normal operations and to facilitate isolation of individual runs for maintenance without interrupting flow through the remaining operational runs; and

• Appropriate upstream and downstream straight-run piping lengths, as required by the meter manufacturer and AGA Report No. 9, to minimize flow disturbance effects on measurement accuracy.

Calibration and Verification. All ultrasonic meters shall be factory-calibrated by the meter manufacturer at a recognized, accredited flow calibration facility prior to shipment. Upon installation, each meter shall be field-verified using approved diagnostic procedures, including speed-of-sound comparisons, path velocity profile analysis, and signal quality assessments, to confirm that the meter is operating within specified accuracy parameters. Ridgeline proposes that the Interconnection Agreement include provisions for periodic field verification of meter accuracy, at intervals to be mutually agreed upon by the parties, with a default interval of not less than once per calendar year.

Response to ATPC's Concern Regarding Meter Run Configuration. As noted above, ATPC argued in its August 15, 2022 protest that Ridgeline's originally proposed two-run configuration was inadequate for the 800 MMcf/d design capacity of the interconnect. Ridgeline acknowledges that a two-run configuration, while technically feasible, would have provided limited redundancy in the event that one run was taken out of service for maintenance or calibration. The revised three-run proposal directly addresses ATPC's concern by providing a dedicated swing/backup run (Run No. 3) that ensures full measurement capability is maintained at all times, even with one run offline.

However, Ridgeline does not accept ATPC's suggestion, set forth in the protest, that orifice plate meters should be considered as an alternative to ultrasonic meters. Orifice plate meters, while well-established and widely used in the industry, present significant disadvantages in the context of a high-volume custody transfer application such as the Wetzel County Interconnect. Specifically, orifice plate meters exhibit lower accuracy (typically ±1.0% of reading, compared to ±0.5% for ultrasonic meters), require more frequent maintenance and plate inspections, create a permanent pressure drop across the orifice plate that increases compression costs, and lack the real-time diagnostic capabilities inherent in multipath ultrasonic instruments. Ridgeline's position on this issue remains unchanged, and we respectfully request that ATPC reconsider its advocacy for orifice plate technology in light of the revised three-run ultrasonic configuration now being proposed.

C. Gas Chromatograph Requirements

Ridgeline proposes the installation of online gas chromatographs at the Wetzel County Interconnect to provide continuous compositional analysis of the gas stream for purposes of heating value determination, gas quality monitoring, and custody transfer measurement. The gas chromatograph specifications set forth below are designed to ensure that both Ridgeline and ATPC have access to reliable, real-time gas quality data at the interconnect point.

Number of Units. Ridgeline proposes the installation of two (2) online gas chromatograph units — one primary unit and one redundant/backup unit — housed in a climate-controlled instrument shelter at the metering station. The redundant configuration ensures continuous gas quality monitoring in the event of a primary unit failure, scheduled maintenance, or calibration cycle.

Analytical Capability. Each gas chromatograph shall be capable of analyzing, at minimum, the following components of the natural gas stream:

• Methane (C1)

• Ethane (C2)

• Propane (C3)

• Iso-butane (i-C4)

• Normal-butane (n-C4)

• Iso-pentane (i-C5)

• Normal-pentane (n-C5)

• Hexanes plus (C6+)

• Nitrogen (N2)

• Carbon dioxide (CO2)

• Oxygen (O2)

• Hydrogen sulfide (H2S)

• Water vapor (H2O)

Analysis Cycle Time. Each gas chromatograph shall complete a full analysis cycle in no more than five (5) minutes, providing near-real-time compositional data for heating value calculation and gas quality monitoring purposes. This cycle time is consistent with industry best practices for custody transfer applications and ensures that compositional changes in the gas stream are detected and accounted for promptly.

Accuracy Requirements. Gas chromatograph accuracy shall be consistent with the standards set forth in GPA Standard 2261, Analysis for Natural Gas and Similar Gaseous Mixtures by Gas Chromatography, and GPA Standard 2145, Table of Physical Constants of Paraffin Hydrocarbons and Other Components of Natural Gas. These standards govern the determination of gross heating value, relative density, and compressibility factor for the gas stream, and form the basis for custody transfer calculations at the interconnect.

Heating Value Determination. The heating value of the gas stream, as determined by the gas chromatograph analysis, shall be expressed in British Thermal Units per cubic foot (BTU/cf) at standard conditions (14.73 psia, 60°F). For purposes of the Dth conversion used in Ridgeline's tariff rate calculations, an assumed base heating value of 1,000 BTU/cf shall be applied, with actual measured heating values used for custody transfer settlements between the parties on a daily basis.

Automatic Switchover. The gas chromatograph system shall include automatic switchover functionality, such that in the event of a failure, malfunction, or out-of-tolerance condition on the primary unit, the system will automatically transfer gas quality measurement responsibilities to the backup unit without any interruption in data availability or custody transfer calculations. Notification of any automatic switchover event shall be transmitted to both Ridgeline's and ATPC's SCADA systems in real time.

Data Archival. All gas chromatograph data, including full compositional analyses, heating value calculations, calibration records, and alarm logs, shall be transmitted to the SCADA system (as described in Section III.D below) and archived for a minimum period of three (3) years. This archival period is consistent with FERC's record retention requirements and provides an adequate basis for audit, reconciliation, and dispute resolution purposes.

Response to ATPC's Concerns. Ridgeline notes that ATPC did not raise specific objections to the installation of online gas chromatographs in its August 15, 2022 protest. Nevertheless, Ridgeline is providing enhanced specificity regarding gas chromatograph specifications in this counterproposal to facilitate agreement on measurement quality and custody transfer standards. Ridgeline believes that the detailed specifications set forth above should address any potential concerns ATPC may have regarding the quality and reliability of gas compositional data at the interconnect.

D. SCADA Integration Protocols

Ridgeline proposes that all metering and measurement equipment installed at the Wetzel County Interconnect be fully integrated into both Ridgeline's and ATPC's Supervisory Control and Data Acquisition ("SCADA") systems. Effective SCADA integration is essential to ensuring that both parties have real-time visibility into the operational status and measurement data at the interconnect, and Ridgeline is committed to working cooperatively with ATPC to achieve seamless data exchange.

Data Points. The following data points shall be shared bidirectionally between Ridgeline's and ATPC's SCADA systems in real time:

• Flow rate (expressed in both MMcf/d and Dth/d)

• Pressure (expressed in pounds per square inch gauge, psig)

• Temperature (expressed in degrees Fahrenheit, °F)

• Gas composition (per gas chromatograph analysis, including all components identified in Section III.C above)

• Meter diagnostics (including speed-of-sound data, signal quality metrics, and path performance indicators for each ultrasonic meter run)

• Alarm conditions (including high/low flow alarms, pressure alarms, temperature alarms, gas quality out-of-specification alarms, meter failure alarms, and gas chromatograph switchover notifications)

Communication Protocol. Ridgeline proposes that all SCADA communications between the Wetzel County Interconnect and each party's respective control center be conducted using Distributed Network Protocol 3.0 ("DNP3") over a dedicated fiber optic communication link. DNP3 is the prevailing industry-standard protocol for SCADA communications in the pipeline industry and provides the reliability, security, and data integrity necessary for custody transfer applications. The dedicated fiber optic link shall be installed between the Wetzel County Interconnect and each party's control center, with appropriate redundancy (e.g., a backup communication path via satellite or cellular modem) to ensure continued data availability in the event of a fiber optic link failure.

Control Centers. Ridgeline's SCADA control center is located at Ridgeline's operations center, 700 Kanawha Boulevard East, Suite 1400, Charleston, West Virginia 25301. ATPC's SCADA control center location shall be designated by ATPC; Ridgeline requests that ATPC provide the address and technical contact information for its SCADA control center at its earliest convenience.

Data Polling Frequency. Ridgeline proposes the following minimum data polling frequencies for the SCADA system:

• Flow and pressure data: polling frequency of no less than once every five (5) seconds

• Gas quality data (gas chromatograph output): polling frequency of no less than once every five (5) minutes, consistent with the analysis cycle time specified in Section III.C above

These polling frequencies are designed to ensure that both parties have access to sufficiently granular, near-real-time data for operational decision-making, gas control, and custody transfer purposes.

Cybersecurity Requirements. All SCADA communications associated with the Wetzel County Interconnect shall comply with the North American Electric Reliability Corporation Critical Infrastructure Protection ("NERC CIP") standards to the extent that such standards are applicable to the parties' pipeline operations. In addition, all SCADA communications shall comply with each party's internal cybersecurity policies, including but not limited to access control requirements, encryption standards, intrusion detection and prevention systems, and incident response protocols. Ridgeline's cybersecurity program is maintained in accordance with the Transportation Security Administration's pipeline cybersecurity directives, and Ridgeline expects that ATPC maintains comparable protections for its SCADA infrastructure.

Cost Allocation for SCADA Integration. Each party shall bear its own costs for SCADA integration on its respective side of the interconnect, including the costs of any hardware, software, programming, and testing necessary to integrate the Wetzel County Interconnect metering data into that party's existing SCADA system. Shared communication infrastructure costs — including, without limitation, the cost of the dedicated fiber optic communication link between the interconnect and each party's control center — shall be allocated between the parties in accordance with the overall interconnection cost allocation methodology to be agreed upon in the Interconnection Agreement. Ridgeline acknowledges that the cost allocation for shared SCADA infrastructure is subject to the same unresolved cost allocation dispute discussed in Section IV below, and Ridgeline reserves its position on this issue accordingly.

Primary Technical Contact. Ridgeline proposes that Thomas Greaves, Vice President of Engineering & Operations, serve as Ridgeline's primary technical contact for SCADA integration coordination. Mr. Greaves can be reached at the Ridgeline operations center in Charleston, West Virginia. Ridgeline respectfully requests that ATPC identify its corresponding primary technical contact for SCADA integration matters and provide that individual's contact information in ATPC's response to this counterproposal.

E. Pig Launcher/Receiver Specifications

The revised metering station design includes a pig launcher/receiver installed at milepost 0.0 of the Ridgeline pipeline system, immediately upstream of the meter station. The pig launcher/receiver is an essential component of the interconnection facilities, as it enables both routine pipeline maintenance pigging operations and periodic smart pig inspections of the Ridgeline system from the Wetzel County Interconnect.

The pig launcher/receiver shall be designed and constructed to accommodate standard pipeline inspection gauge ("smart pig") tools compatible with the 24-inch-diameter Ridgeline pipeline, including but not limited to geometry pigs, magnetic flux leakage (MFL) inspection tools, caliper tools, and multi-dataset combination tools. The pig trap shall be of a bidirectional design, capable of accommodating pigging operations initiated from either direction — that is, both launching and receiving pigs to and from the Ridgeline system.

Ridgeline notes that ATPC's 30-inch mainline at Milepost 412.6 requires a compatible pig receiver/launcher on the ATPC side of the interconnect. Ridgeline respectfully requests that ATPC confirm the specifications for its pig trap equipment at Milepost 412.6 to ensure compatibility between the two systems and to facilitate coordinated pigging operations across the interconnect. Coordination of pig trap specifications is particularly important given the difference in pipeline diameter (24-inch Ridgeline vs. 30-inch ATPC), which will require appropriate transition piping and pig sizing considerations.

All pig signaler and indicator devices — including both barrel-mounted and bypass-mounted indicators — shall be integrated into the SCADA system as described in Section III.D above, providing real-time notification to both parties' control centers when a pig passes through the launcher/receiver facility. This integration will enable coordinated scheduling of pigging operations and timely notification to downstream facilities of pig arrival.

F. Physical Layout and Site Plan

Ridgeline has prepared a revised metering station site plan reflecting the three-run ultrasonic meter configuration and associated facilities described in this counterproposal. The revised site plan is included as Attachment A to this letter and shows the physical arrangement of the following components:

• Three (3) ultrasonic meter runs, with associated piping, valving, and flow conditioning elements;

• Gas chromatograph instrument shelter, housing the primary and backup gas chromatograph units;

• Pig launcher/receiver facility, including barrel, closure, and bypass piping;

• SCADA equipment building, housing remote terminal units (RTUs), communication equipment, and uninterruptible power supply (UPS) systems;

• Electrical supply, including transformer and switchgear for station power;

• Access road from the nearest county road to the station site; and

• Perimeter fencing with gated access for security purposes.

The site plan reflects a total facility footprint of approximately 2.5 acres at the Wetzel County Interconnect. The layout has been designed to accommodate future expansion to five (5) meter runs, with pre-graded pad space and piping stubs available for the installation of two additional runs to support the full 1.2 Bcf/d expandable capacity of the interconnection. This forward-looking design approach is intended to minimize future construction costs and operational disruptions when expansion becomes necessary.

Ridgeline requests that ATPC's engineering team review the revised site plan and provide any comments or concerns regarding the proposed layout, particularly as it relates to the interface between Ridgeline's facilities and ATPC's existing 30-inch mainline at Milepost 412.6.

IV. Interconnection Cost Allocation — Reservation of Position

Ridgeline acknowledges that the metering station design counterproposal set forth in Section III above does not resolve the parties' ongoing dispute over the appropriate allocation of interconnection costs. The cost allocation issue is a separate and distinct matter from the metering station design specifications, and Ridgeline believes that the parties can and should reach agreement on technical metering specifications independently of the cost allocation question.

For the avoidance of doubt, Ridgeline maintains its position, as set forth in Article VII of the Draft Interconnection Agreement (Version 1.0, July 2022) and in Ridgeline's October 17, 2022 answer to ATPC's protest, that the appropriate cost allocation for the $22.3 million in total interconnection facilities costs is 34.1% to Ridgeline (approximately $7.6 million) and 65.9% to ATPC (approximately $14.7 million). This allocation is based on well-established cost-causation principles and reflects the relative benefits received by ATPC and its shippers from the interconnection, including the incremental supply diversity, system reliability, and competitive market access that the Ridgeline interconnection will provide to ATPC's system.

Ridgeline is aware that ATPC's position, as stated in its August 15, 2022 protest, advocates for a 50/50 cost allocation, under which each party would bear $11.15 million of the total interconnection costs. Ridgeline respectfully disagrees with this position and does not believe that a 50/50 allocation is supported by the record or by applicable Commission precedent, for the reasons stated in Ridgeline's October 17, 2022 answer.

Ridgeline reserves the right to address the cost allocation issue separately in its direct testimony, in further settlement discussions before FERC Settlement Judge Howard Margolis, and in any other appropriate forum. This firm has prepared a separate, detailed analysis of FERC precedent on interconnection cost allocation under Order No. 2004 and its progeny, and Ridgeline may submit that analysis in connection with its direct testimony filing or in support of its position in the settlement process.

The metering station design counterproposal transmitted herewith is expressly without prejudice to either party's position on the interconnection cost allocation issue. Nothing in this letter or its attachments shall be construed as an acceptance, concession, or waiver of any position taken by either party with respect to cost allocation, and neither party's acceptance or rejection of any aspect of the metering station design counterproposal shall have any bearing on the resolution of the cost allocation dispute.

V. Proposed Next Steps and Timeline

Ridgeline proposes the following next steps and timeline for advancing negotiations on the metering station design:

1. Review of Counterproposal. Ridgeline requests that ATPC and its counsel at Kellner, Royce & Dillard LLP review this counterproposal and the attached revised metering station site plan (Attachment A), ultrasonic flow meter technical specifications (Attachment B), gas chromatograph technical specifications (Attachment C), and SCADA integration protocol summary (Attachment D) at your earliest convenience.

2. Technical Meeting. Ridgeline proposes a technical meeting between Ridgeline's engineering team, led by Thomas Greaves, Vice President of Engineering & Operations, and ATPC's engineering team to discuss the revised metering specifications in detail. Ridgeline requests that this meeting be scheduled within twenty-one (21) days of the date of this letter, with a target date in mid-December 2022. The meeting may be conducted in person at a mutually convenient location or by videoconference, at the parties' discretion. Mr. Greaves is prepared to present the revised metering station design, respond to technical questions, and discuss any modifications that ATPC's engineering team may propose.

3. Direct Testimony Filing. Ridgeline notes that it intends to file its direct testimony on the Track II schedule on December 5, 2022, as required by ALJ Whitfield's procedural order. Ridgeline's direct testimony filing will include, among other things, the pre-filed direct testimony of Thomas Greaves addressing engineering and system design issues, including the metering station design at the Wetzel County Interconnect. The metering station design reflected in Mr. Greaves's testimony will incorporate the counterproposal set forth in this letter. To the extent that the parties are able to reach agreement on metering specifications before the direct testimony filing date, Ridgeline's testimony will reflect that agreement.

4. Written Response. Ridgeline respectfully requests that ATPC provide a written response to this counterproposal by no later than December 16, 2022. A timely response will facilitate incorporation of any agreed-upon revisions into Version 2.0 of the Draft Interconnection Agreement, which Ridgeline anticipates circulating in January 2023.

5. Coordination with Track II Schedule. Ridgeline emphasizes the importance of advancing the interconnection negotiations in parallel with the Track II procedural schedule established by the Commission's September 22, 2022 order. The Track II schedule contemplates resolution of the interconnection issues on an expedited basis, and Ridgeline believes that meaningful progress on the technical metering specifications will assist the parties in narrowing the issues that must ultimately be resolved by ALJ Whitfield and the Commission.

6. Settlement Discussions. Ridgeline notes that the parties remain approximately $0.058/Dth apart on the overall rate in settlement discussions, with Ridgeline's position currently anchored at the proposed recourse rate level and the various intervenor positions reflecting somewhat lower rate levels. While the rate gap remains meaningful, Ridgeline is hopeful that resolution of the technical metering issues — which represent a discrete, tractable subset of the overall dispute — can help build momentum toward a broader settlement of both the rate case and the interconnection issues. Ridgeline remains committed to participating in good faith in the settlement process before Settlement Judge Margolis and encourages ATPC to approach the metering specifications negotiations in that same constructive spirit.

VI. Confidentiality

As you are aware, this firm transmitted a letter to your firm dated September 12, 2022, proposing confidentiality and protective order provisions for the exchange of commercially sensitive cost data and technical information in connection with the interconnection negotiations. Those proposed provisions remain under discussion, and we understand that ALJ Whitfield intends to address the entry of a protective order at the next procedural conference.

Ridgeline notes that certain technical specifications and cost data contained in this letter and its attachments contain confidential commercial information, including detailed engineering specifications, cost estimates, system capacity data, and operational information that is proprietary to Ridgeline and that would not ordinarily be disclosed to the public or to non-parties. Ridgeline designates the attachments to this letter — specifically, Attachment A (Revised Metering Station Site Plan), Attachment B (Ultrasonic Flow Meter Technical Specifications), Attachment C (Gas Chromatograph Technical Specifications), and Attachment D (SCADA Integration Protocol Summary) — as containing confidential commercial information subject to the protective order terms proposed in our September 12, 2022 letter.

Ridgeline respectfully requests that Kellner, Royce & Dillard LLP and ATPC treat the attached site plan and detailed technical specifications as confidential pending the entry of a protective order by ALJ Whitfield. In the interim, Ridgeline requests that access to the attachments be limited to outside counsel and in-house regulatory counsel with a need to know, and that the attachments not be further distributed without Ridgeline's prior written consent. We note that cover copies of this letter are being provided to counsel for certain other parties to the proceeding; however, the attachments are being withheld from those parties pending entry of the protective order.

VII. Attachments

The following documents are enclosed with this letter:

Attachment A: Revised Metering Station Site Plan — Wetzel County Interconnect (Drawing No. RMS-WCI-SP-2022-03, Rev. 1, prepared by Ridgeline Engineering Department, November 2022). This drawing shows the physical arrangement of the three ultrasonic meter runs, gas chromatograph shelter, pig launcher/receiver, SCADA equipment building, electrical supply, access road, and perimeter fencing at the proposed 2.5-acre site, including provisions for future expansion to five meter runs.

Attachment B: Ultrasonic Flow Meter Technical Specifications. This document provides a summary table setting forth manufacturer-neutral performance requirements for the three 12-inch ultrasonic meter runs, including accuracy specifications, turndown ratio, flow conditioning requirements, and calibration and verification procedures, consistent with AGA Report No. 9.

Attachment C: Gas Chromatograph Technical Specifications. This document provides a summary table setting forth performance requirements for the two online gas chromatograph units, including component analysis capabilities, cycle time, accuracy requirements consistent with GPA 2261 and GPA 2145, automatic switchover functionality, and data archival specifications.

Attachment D: SCADA Integration Protocol Summary. This document sets forth the proposed data point listing, communication specifications (DNP3 protocol, fiber optic link), polling frequencies, cybersecurity requirements, and shared infrastructure cost allocation framework for SCADA integration at the Wetzel County Interconnect.

VIII. Closing

Ridgeline looks forward to ATPC's prompt response to this counterproposal and to productive technical discussions on the metering station design for the Wetzel County Interconnect. Ridgeline remains fully committed to reaching a mutually acceptable interconnection agreement that serves the interests of both parties and their respective shippers, and to advancing this proceeding toward a timely and efficient resolution of all contested issues.

Should you wish to discuss any aspect of this counterproposal, the undersigned and George Trujillo, the responsible partner on this matter at Calderwood & Harkness LLP, are available at your convenience. We are also prepared to coordinate with Sandra K. Fenton, ATPC's Vice President of Regulatory Affairs, on scheduling the proposed technical meeting between the parties' engineering teams, and we would welcome your guidance on the appropriate mechanism for arranging that meeting.

We appreciate your attention to this matter and look forward to hearing from you at your earliest opportunity.

Very truly yours,

CALDERWOOD & HARKNESS LLP

By: ________

Brett Callahan Lead Associate, Energy & Infrastructure 1601 K Street NW, Suite 900 Washington, DC 20006 Telephone: (202) 555-7418

Email: bcallahan@calderwoodharkness.com

Enclosures (4)

cc (via electronic mail):

George Trujillo, Esq., Calderwood & Harkness LLP (Responsible Partner)

Patricia Dunmore, Esq., Calderwood & Harkness LLP (Billing Partner) / Chairperson, Dunmore Energy Holdings Ltd.

David Stanton, Esq., Calderwood & Harkness LLP (Working Associate)

James K. Winfield, CEO & President, Ridgeline Midstream Services LLC

Thomas Greaves, VP, Engineering & Operations, Ridgeline Midstream Services LLC

Angela Moretti, VP, Finance & Treasurer, Ridgeline Midstream Services LLC

Dr. Natasha Orlov, Director of Rates & Regulatory, Ridgeline Midstream Services LLC

Sandra K. Fenton, VP, Regulatory Affairs, Appalachian Trunk Pipeline Company, LLC

Rebekah Montague, Esq., Whitmore & Sable LLP (counsel for Mountaineer Gas Pipeline Corporation) (cover letter only; attachments withheld pending entry of protective order)

Stephen Greer, Esq., Fordham Municipal Law Group PC (counsel for the Central Mid-Atlantic Gas Association) (cover letter only; attachments withheld pending entry of protective order)

Jonathan Briggs, Lead Trial Attorney, Office of General Counsel, Federal Energy Regulatory Commission (cover letter only; attachments withheld pending entry of protective order)

CALDERWOOD & HARKNESS LLP Attorneys at Law
1601 K Street NW, Suite 900 Washington, DC 20006
Telephone: (202) 555-7400 Facsimile: (202) 555-7401 www.calderwoodharkness.com
November 22, 2022
VIA ELECTRONIC MAIL AND FIRST-CLASS MAIL
William Pratt, Esq. Senior Partner Kellner, Royce & Dillard LLP One PPG Place, Suite 2800 Pittsburgh, PA 15222
Re: FERC Docket Nos. RP22-847-000 and RP22-847-001 — Ridgeline Midstream Services LLC / Appalachian Trunk Pipeline Company, LLC Interconnection Agreement Negotiations; Ridgeline's Counterproposal on Metering Station Design at the Wetzel County Interconnect
Dear Mr. Pratt:
I. Introduction and Purpose
This firm represents Ridgeline Midstream Services LLC ("Ridgeline" or "RMS"), a wholly owned subsidiary of Dunmore Energy Holdings Ltd. ("DEH"), in the above-referenced proceedings before the Federal Energy Regulatory Commission ("FERC" or "Commission"), designated as FERC Docket No. RP22-847-000 (Ridgeline's general Section 4 rate case) and FERC Docket No. RP22-847-001 (the contested interconnection proceeding involving Ridgeline and Appalachian Trunk Pipeline Company, LLC ("ATPC")).
As you are aware, ATPC filed its protest and motion to intervene in these proceedings on August 15, 2022, raising objections to, among other things, Ridgeline's proposed metering station design and cost allocation methodology for the proposed physical interconnection at the Wetzel County Interconnect in Wetzel County, West Virginia. Ridgeline filed its answer to ATPC's protest on October 17, 2022, defending both the technical adequacy of its proposed metering station design and the propriety of its cost allocation methodology under applicable Commission precedent. Both filings are incorporated herein by reference.
On September 22, 2022, the Commission issued an order establishing a Track II procedural schedule for the resolution of the interconnection issues, bifurcating those issues from the broader rate case questions to be resolved on the Track I schedule. Consistent with that procedural framework, Administrative Law Judge Clara Whitfield convened a prehearing conference on November 14, 2022, at which the undersigned counsel and your firm appeared on behalf of Ridgeline and ATPC, respectively. During the prehearing conference, ALJ Whitfield encouraged the parties to engage in good-faith negotiations on the technical specifications for the proposed interconnection facilities, with a view toward narrowing the issues in dispute before the direct testimony filing deadline.
The purpose of this letter is to transmit Ridgeline's counterproposal on the metering station design for the proposed physical interconnection at the Wetzel County Interconnect, located at milepost 0.0 of the Ridgeline pipeline system and tying into ATPC's existing 30-inch mainline at ATPC Milepost 412.6 in Wetzel County, West Virginia. This counterproposal is being transmitted in the spirit of advancing the parties' negotiations on the Draft Interconnection Agreement (Version 1.0, initially circulated by Ridgeline in July 2022), and it is Ridgeline's hope that the parties can reach agreement on the technical metering specifications while the broader cost allocation dispute continues to be discussed, both in direct negotiations between counsel and in the settlement conferences before FERC Settlement Judge Howard Margolis.
Ridgeline remains committed to working collaboratively with ATPC and its counsel at Kellner, Royce & Dillard LLP to finalize interconnection terms in an expeditious manner. The direct testimony filing deadline established by ALJ Whitfield is December 5, 2022, and Ridgeline intends to incorporate the metering station design reflected in this counterproposal into the pre-filed direct testimony of Thomas Greaves, Ridgeline's Vice President of Engineering & Operations. Accordingly, we respectfully request ATPC's prompt attention to the counterproposal set forth below and the accompanying technical attachments.
II. Background on the Proposed Interconnection
To place the counterproposal in context, Ridgeline provides the following summary of the relevant pipeline systems and the proposed interconnection point. We recognize that much of this background information is already part of the record in the above-captioned proceedings, but we restate it here for convenience and completeness.
A. The Ridgeline Pipeline System
Ridgeline Midstream Services LLC operates a 187-mile, 24-inch-diameter high-pressure natural gas pipeline system extending from its receipt point at the Wetzel County Interconnect in Wetzel County, West Virginia (approximate coordinates: 39.6120° N, 80.7540° W), to its delivery point at the Waynesburg Compressor Station in Greene County, Pennsylvania (approximate coordinates: 39.8965° N, 80.1810° W). The Ridgeline system has a certificated design capacity of 1.2 Bcf/d (1,200,000 Dth/d) and currently operates at an average throughput of approximately 680 MMcf/d, representing an approximate utilization rate of 56.7%. The system was placed into service on October 1, 2021.
The Ridgeline system includes three compressor stations — the Wetzel Station, the Mannington Station, and the Waynesburg Station — with aggregate installed compression of approximately 45,000 horsepower. The system was constructed at an original cost of approximately $587.2 million, as reflected in the cost-of-service filing in Docket No. RP22-847-000.
Ridgeline Midstream Services LLC is organized as a limited liability company under the laws of the State of Delaware. Its sole member is Dunmore Energy Holdings Ltd. Ridgeline's principal office is located at 700 Kanawha Boulevard East, Suite 1400, Charleston, West Virginia 25301. Its registered agent in Delaware is Capitol Filings Inc., 1209 Orange Street, Wilmington, Delaware 19801. Ridgeline's Employer Identification Number is 87-4231956, and its FERC pipeline code is 960442.
B. ATPC's Existing System
ATPC operates a 640-mile interstate natural gas pipeline system with a current system-wide capacity of approximately 3.8 Bcf/d, serving natural gas markets in Pennsylvania, Ohio, and New York. ATPC's system constitutes one of the primary transmission corridors for Appalachian Basin production and is strategically positioned to receive gas from multiple upstream gathering systems, including the Ridgeline system upon completion of the proposed interconnection.
ATPC is organized as a limited liability company under the laws of the Commonwealth of Pennsylvania. Its principal office is located at 2200 Penn Center West, Suite 300, Pittsburgh, Pennsylvania 15276. ATPC's registered agent in Pennsylvania is Keystone Corporate Services LLC, 600 North Second Street, Harrisburg, Pennsylvania 17101. ATPC's FERC pipeline code is 840117, and its Employer Identification Number is 25-1987643.
ATPC's parent company is Tidewater Infrastructure Partners LP, a Delaware limited partnership controlled by the Alderman family. Harrison J. Alderman serves as Chairman and Marcus R. Alderman serves as President and Chief Executive Officer of Tidewater Infrastructure Partners LP. ATPC's estimated enterprise value, including the Tidewater parent, is approximately $6.1 billion based on publicly available financial information and recent analyst estimates.
C. Proposed Interconnection Point
The proposed interconnection is to be located at the Wetzel County Interconnect, at milepost 0.0 of the Ridgeline pipeline system, where Ridgeline's 24-inch pipeline will tie into ATPC's existing 30-inch mainline at ATPC Milepost 412.6. The interconnection facilities will consist of a new metering station and a pig launcher/receiver, together with associated valving, piping, electrical supply, access road, fencing, and ancillary equipment.
The design capacity at the interconnect point is 800 MMcf/d bidirectional, with the facilities designed to be expandable to 1.2 Bcf/d through the addition of supplemental meter runs at a future date. The original target in-service date for the interconnection facilities was the fourth quarter of 2023; however, as both parties are aware, this target date is now subject to potential delay pending resolution of the contested issues in this proceeding.
The estimated total cost of the interconnection facilities, based on Ridgeline's engineering estimates as submitted in the July 2022 Draft Interconnection Agreement, is approximately $22.3 million. This estimate encompasses all metering equipment, the pig launcher/receiver, site preparation, civil and structural work, electrical and instrumentation, piping, and commissioning costs.
D. ATPC's Protest Concerning the Interconnection
On August 15, 2022, ATPC filed its protest and motion to intervene in this proceeding, raising two principal objections to the proposed interconnection as described in the Draft Interconnection Agreement (Version 1.0). First, ATPC argued that Ridgeline's proposed receipt-point metering station design was technically inadequate, contending that the two-run meter station configuration originally proposed by Ridgeline would be insufficient to accurately measure the full 800 MMcf/d bidirectional design capacity of the interconnection. Second, ATPC contended that the proposed cost allocation methodology, under which ATPC would bear $14.7 million (65.9%) and Ridgeline would bear $7.6 million (34.1%) of the total $22.3 million in interconnection facilities costs, improperly shifted a disproportionate share of costs to ATPC and its shippers.
ATPC, acting through its Vice President of Regulatory Affairs, Sandra K. Fenton, and its outside counsel, William Pratt at Kellner, Royce & Dillard LLP, has advocated for an alternative metering station design and a 50/50 cost allocation framework, under which each party would bear $11.15 million of the total interconnection costs. ATPC's protest also raised certain additional concerns regarding gas quality specifications and custody transfer measurement standards, though those concerns were secondary to the metering design and cost allocation objections.
Ridgeline answered ATPC's protest on October 17, 2022, defending the technical adequacy of its proposed metering station design and the appropriateness of its cost allocation methodology under established Commission precedent, including cost-causation principles and the benefits-received framework articulated in the Commission's interconnection orders. Ridgeline's answer is incorporated herein by reference.
III. Ridgeline's Counterproposal on Metering Station Design
A. Overview of Counterproposal
Having carefully considered the technical concerns raised by ATPC in its August 15, 2022 protest and the subsequent discussions between the parties' engineering teams, Ridgeline hereby submits its revised counterproposal for the metering station design at the Wetzel County Interconnect. This counterproposal addresses certain of ATPC's concerns regarding meter run capacity and measurement redundancy while maintaining Ridgeline's position on the superiority of ultrasonic flow measurement technology and the applicable measurement accuracy requirements.
The counterproposal set forth in this Section III is intended to supplement and, where applicable, replace the metering specifications set forth in Article V ("Measurement") and Exhibit C ("Metering Station Specifications") of the Draft Interconnection Agreement (Version 1.0, circulated by Ridgeline in July 2022). Ridgeline expects that these revised specifications will be incorporated into Version 2.0 of the Draft Interconnection Agreement, which is currently under negotiation between the parties' respective counsel and engineering teams. To the extent that any provision of this counterproposal conflicts with the corresponding provision of the Draft Interconnection Agreement (Version 1.0), this counterproposal shall be deemed to supersede the earlier document for purposes of ongoing negotiations, subject to the parties' mutual agreement on final terms.
B. Ultrasonic Flow Meter Specifications
Ridgeline proposes the installation of ultrasonic flow meters as the primary measurement devices at the Wetzel County Interconnect. Ridgeline has concluded, based on the analysis of its engineering team and consistent with prevailing industry practice for high-volume custody transfer applications, that multipath ultrasonic meters provide superior accuracy, reliability, and long-term operational advantages over alternative measurement technologies, including orifice plate meters.
Configuration. Ridgeline's revised design provides for three (3) meter runs, each equipped with 12-inch ultrasonic flow meters, configured as follows:
• Run No. 1 — Primary measurement run, rated for a throughput range of 0 to 400 MMcf/d. This run will serve as one of two primary measurement paths during normal operations at the interconnect point.
• Run No. 2 — Primary measurement run, rated for a throughput range of 0 to 400 MMcf/d. This run will serve as the second primary measurement path during normal operations, providing combined measurement capacity across Runs No. 1 and No. 2 of up to 800 MMcf/d.
• Run No. 3 — Swing/backup measurement run, rated for a throughput range of 0 to 400 MMcf/d. This run is available for peak flow conditions, scheduled maintenance of either Run No. 1 or Run No. 2, and general redundancy to ensure uninterrupted measurement capability under all operating scenarios.
Capacity. The combined rated capacity across all three meter runs is sufficient to measure the full 800 MMcf/d bidirectional design capacity at the Wetzel County Interconnect. Moreover, the station layout and piping design, as reflected in the revised metering station site plan (Attachment A hereto), accommodate the future addition of two additional meter runs, bringing the total to five runs with a combined measurement capacity sufficient to support the full 1.2 Bcf/d expandable capacity of the interconnection. This expansion capability has been incorporated into the civil and structural design of the metering station from the outset, ensuring that future capacity additions can be achieved without major site modifications.
Accuracy. All ultrasonic meters shall be multipath instruments meeting or exceeding the accuracy requirements set forth in American Gas Association Report No. 9, Measurement of Gas by Multipath Ultrasonic Meters ("AGA Report No. 9"). The minimum accuracy requirement for each meter shall be ±0.5% of reading across the full turndown range of the instrument, under normal operating conditions. This accuracy standard exceeds the requirements typically applied to orifice plate meters under AGA Report No. 3 and provides a superior basis for custody transfer measurement at the interconnect.
Ancillary Equipment. Each meter run shall include the following ancillary equipment and components:
• upstream and downstream flow conditioning elements, designed to ensure a fully developed, symmetrical flow profile at the meter inlet, consistent with the manufacturer's installation requirements and AGA Report No. 9 guidelines;
• Temperature transmitters and pressure transmitters, with accuracy specifications consistent with AGA Report No. 9 requirements for temperature and pressure correction of volumetric flow measurements;
• Inline check valves, positioned to prevent reverse flow through idle meter runs during normal operations and to facilitate isolation of individual runs for maintenance without interrupting flow through the remaining operational runs; and
• Appropriate upstream and downstream straight-run piping lengths, as required by the meter manufacturer and AGA Report No. 9, to minimize flow disturbance effects on measurement accuracy.
Calibration and Verification. All ultrasonic meters shall be factory-calibrated by the meter manufacturer at a recognized, accredited flow calibration facility prior to shipment. Upon installation, each meter shall be field-verified using approved diagnostic procedures, including speed-of-sound comparisons, path velocity profile analysis, and signal quality assessments, to confirm that the meter is operating within specified accuracy parameters. Ridgeline proposes that the Interconnection Agreement include provisions for periodic field verification of meter accuracy, at intervals to be mutually agreed upon by the parties, with a default interval of not less than once per calendar year.
Response to ATPC's Concern Regarding Meter Run Configuration. As noted above, ATPC argued in its August 15, 2022 protest that Ridgeline's originally proposed two-run configuration was inadequate for the 800 MMcf/d design capacity of the interconnect. Ridgeline acknowledges that a two-run configuration, while technically feasible, would have provided limited redundancy in the event that one run was taken out of service for maintenance or calibration. The revised three-run proposal directly addresses ATPC's concern by providing a dedicated swing/backup run (Run No. 3) that ensures full measurement capability is maintained at all times, even with one run offline.
However, Ridgeline does not accept ATPC's suggestion, set forth in the protest, that orifice plate meters should be considered as an alternative to ultrasonic meters. Orifice plate meters, while well-established and widely used in the industry, present significant disadvantages in the context of a high-volume custody transfer application such as the Wetzel County Interconnect. Specifically, orifice plate meters exhibit lower accuracy (typically ±1.0% of reading, compared to ±0.5% for ultrasonic meters), require more frequent maintenance and plate inspections, create a permanent pressure drop across the orifice plate that increases compression costs, and lack the real-time diagnostic capabilities inherent in multipath ultrasonic instruments. Ridgeline's position on this issue remains unchanged, and we respectfully request that ATPC reconsider its advocacy for orifice plate technology in light of the revised three-run ultrasonic configuration now being proposed.
C. Gas Chromatograph Requirements
Ridgeline proposes the installation of online gas chromatographs at the Wetzel County Interconnect to provide continuous compositional analysis of the gas stream for purposes of heating value determination, gas quality monitoring, and custody transfer measurement. The gas chromatograph specifications set forth below are designed to ensure that both Ridgeline and ATPC have access to reliable, real-time gas quality data at the interconnect point.
Number of Units. Ridgeline proposes the installation of two (2) online gas chromatograph units — one primary unit and one redundant/backup unit — housed in a climate-controlled instrument shelter at the metering station. The redundant configuration ensures continuous gas quality monitoring in the event of a primary unit failure, scheduled maintenance, or calibration cycle.
Analytical Capability. Each gas chromatograph shall be capable of analyzing, at minimum, the following components of the natural gas stream:
• Methane (C1)
• Ethane (C2)
• Propane (C3)
• Iso-butane (i-C4)
• Normal-butane (n-C4)
• Iso-pentane (i-C5)
• Normal-pentane (n-C5)
• Hexanes plus (C6+)
• Nitrogen (N2)
• Carbon dioxide (CO2)
• Oxygen (O2)
• Hydrogen sulfide (H2S)
• Water vapor (H2O)
Analysis Cycle Time. Each gas chromatograph shall complete a full analysis cycle in no more than five (5) minutes, providing near-real-time compositional data for heating value calculation and gas quality monitoring purposes. This cycle time is consistent with industry best practices for custody transfer applications and ensures that compositional changes in the gas stream are detected and accounted for promptly.
Accuracy Requirements. Gas chromatograph accuracy shall be consistent with the standards set forth in GPA Standard 2261, Analysis for Natural Gas and Similar Gaseous Mixtures by Gas Chromatography, and GPA Standard 2145, Table of Physical Constants of Paraffin Hydrocarbons and Other Components of Natural Gas. These standards govern the determination of gross heating value, relative density, and compressibility factor for the gas stream, and form the basis for custody transfer calculations at the interconnect.
Heating Value Determination. The heating value of the gas stream, as determined by the gas chromatograph analysis, shall be expressed in British Thermal Units per cubic foot (BTU/cf) at standard conditions (14.73 psia, 60°F). For purposes of the Dth conversion used in Ridgeline's tariff rate calculations, an assumed base heating value of 1,000 BTU/cf shall be applied, with actual measured heating values used for custody transfer settlements between the parties on a daily basis.
Automatic Switchover. The gas chromatograph system shall include automatic switchover functionality, such that in the event of a failure, malfunction, or out-of-tolerance condition on the primary unit, the system will automatically transfer gas quality measurement responsibilities to the backup unit without any interruption in data availability or custody transfer calculations. Notification of any automatic switchover event shall be transmitted to both Ridgeline's and ATPC's SCADA systems in real time.
Data Archival. All gas chromatograph data, including full compositional analyses, heating value calculations, calibration records, and alarm logs, shall be transmitted to the SCADA system (as described in Section III.D below) and archived for a minimum period of three (3) years. This archival period is consistent with FERC's record retention requirements and provides an adequate basis for audit, reconciliation, and dispute resolution purposes.
Response to ATPC's Concerns. Ridgeline notes that ATPC did not raise specific objections to the installation of online gas chromatographs in its August 15, 2022 protest. Nevertheless, Ridgeline is providing enhanced specificity regarding gas chromatograph specifications in this counterproposal to facilitate agreement on measurement quality and custody transfer standards. Ridgeline believes that the detailed specifications set forth above should address any potential concerns ATPC may have regarding the quality and reliability of gas compositional data at the interconnect.
D. SCADA Integration Protocols
Ridgeline proposes that all metering and measurement equipment installed at the Wetzel County Interconnect be fully integrated into both Ridgeline's and ATPC's Supervisory Control and Data Acquisition ("SCADA") systems. Effective SCADA integration is essential to ensuring that both parties have real-time visibility into the operational status and measurement data at the interconnect, and Ridgeline is committed to working cooperatively with ATPC to achieve seamless data exchange.
Data Points. The following data points shall be shared bidirectionally between Ridgeline's and ATPC's SCADA systems in real time:
• Flow rate (expressed in both MMcf/d and Dth/d)
• Pressure (expressed in pounds per square inch gauge, psig)
• Temperature (expressed in degrees Fahrenheit, °F)
• Gas composition (per gas chromatograph analysis, including all components identified in Section III.C above)
• Meter diagnostics (including speed-of-sound data, signal quality metrics, and path performance indicators for each ultrasonic meter run)
• Alarm conditions (including high/low flow alarms, pressure alarms, temperature alarms, gas quality out-of-specification alarms, meter failure alarms, and gas chromatograph switchover notifications)
Communication Protocol. Ridgeline proposes that all SCADA communications between the Wetzel County Interconnect and each party's respective control center be conducted using Distributed Network Protocol 3.0 ("DNP3") over a dedicated fiber optic communication link. DNP3 is the prevailing industry-standard protocol for SCADA communications in the pipeline industry and provides the reliability, security, and data integrity necessary for custody transfer applications. The dedicated fiber optic link shall be installed between the Wetzel County Interconnect and each party's control center, with appropriate redundancy (e.g., a backup communication path via satellite or cellular modem) to ensure continued data availability in the event of a fiber optic link failure.
Control Centers. Ridgeline's SCADA control center is located at Ridgeline's operations center, 700 Kanawha Boulevard East, Suite 1400, Charleston, West Virginia 25301. ATPC's SCADA control center location shall be designated by ATPC; Ridgeline requests that ATPC provide the address and technical contact information for its SCADA control center at its earliest convenience.
Data Polling Frequency. Ridgeline proposes the following minimum data polling frequencies for the SCADA system:
• Flow and pressure data: polling frequency of no less than once every five (5) seconds
• Gas quality data (gas chromatograph output): polling frequency of no less than once every five (5) minutes, consistent with the analysis cycle time specified in Section III.C above
These polling frequencies are designed to ensure that both parties have access to sufficiently granular, near-real-time data for operational decision-making, gas control, and custody transfer purposes.
Cybersecurity Requirements. All SCADA communications associated with the Wetzel County Interconnect shall comply with the North American Electric Reliability Corporation Critical Infrastructure Protection ("NERC CIP") standards to the extent that such standards are applicable to the parties' pipeline operations. In addition, all SCADA communications shall comply with each party's internal cybersecurity policies, including but not limited to access control requirements, encryption standards, intrusion detection and prevention systems, and incident response protocols. Ridgeline's cybersecurity program is maintained in accordance with the Transportation Security Administration's pipeline cybersecurity directives, and Ridgeline expects that ATPC maintains comparable protections for its SCADA infrastructure.
Cost Allocation for SCADA Integration. Each party shall bear its own costs for SCADA integration on its respective side of the interconnect, including the costs of any hardware, software, programming, and testing necessary to integrate the Wetzel County Interconnect metering data into that party's existing SCADA system. Shared communication infrastructure costs — including, without limitation, the cost of the dedicated fiber optic communication link between the interconnect and each party's control center — shall be allocated between the parties in accordance with the overall interconnection cost allocation methodology to be agreed upon in the Interconnection Agreement. Ridgeline acknowledges that the cost allocation for shared SCADA infrastructure is subject to the same unresolved cost allocation dispute discussed in Section IV below, and Ridgeline reserves its position on this issue accordingly.
Primary Technical Contact. Ridgeline proposes that Thomas Greaves, Vice President of Engineering & Operations, serve as Ridgeline's primary technical contact for SCADA integration coordination. Mr. Greaves can be reached at the Ridgeline operations center in Charleston, West Virginia. Ridgeline respectfully requests that ATPC identify its corresponding primary technical contact for SCADA integration matters and provide that individual's contact information in ATPC's response to this counterproposal.
E. Pig Launcher/Receiver Specifications
The revised metering station design includes a pig launcher/receiver installed at milepost 0.0 of the Ridgeline pipeline system, immediately upstream of the meter station. The pig launcher/receiver is an essential component of the interconnection facilities, as it enables both routine pipeline maintenance pigging operations and periodic smart pig inspections of the Ridgeline system from the Wetzel County Interconnect.
The pig launcher/receiver shall be designed and constructed to accommodate standard pipeline inspection gauge ("smart pig") tools compatible with the 24-inch-diameter Ridgeline pipeline, including but not limited to geometry pigs, magnetic flux leakage (MFL) inspection tools, caliper tools, and multi-dataset combination tools. The pig trap shall be of a bidirectional design, capable of accommodating pigging operations initiated from either direction — that is, both launching and receiving pigs to and from the Ridgeline system.
Ridgeline notes that ATPC's 30-inch mainline at Milepost 412.6 requires a compatible pig receiver/launcher on the ATPC side of the interconnect. Ridgeline respectfully requests that ATPC confirm the specifications for its pig trap equipment at Milepost 412.6 to ensure compatibility between the two systems and to facilitate coordinated pigging operations across the interconnect. Coordination of pig trap specifications is particularly important given the difference in pipeline diameter (24-inch Ridgeline vs. 30-inch ATPC), which will require appropriate transition piping and pig sizing considerations.
All pig signaler and indicator devices — including both barrel-mounted and bypass-mounted indicators — shall be integrated into the SCADA system as described in Section III.D above, providing real-time notification to both parties' control centers when a pig passes through the launcher/receiver facility. This integration will enable coordinated scheduling of pigging operations and timely notification to downstream facilities of pig arrival.
F. Physical Layout and Site Plan
Ridgeline has prepared a revised metering station site plan reflecting the three-run ultrasonic meter configuration and associated facilities described in this counterproposal. The revised site plan is included as Attachment A to this letter and shows the physical arrangement of the following components:
• Three (3) ultrasonic meter runs, with associated piping, valving, and flow conditioning elements;
• Gas chromatograph instrument shelter, housing the primary and backup gas chromatograph units;
• Pig launcher/receiver facility, including barrel, closure, and bypass piping;
• SCADA equipment building, housing remote terminal units (RTUs), communication equipment, and uninterruptible power supply (UPS) systems;
• Electrical supply, including transformer and switchgear for station power;
• Access road from the nearest county road to the station site; and
• Perimeter fencing with gated access for security purposes.
The site plan reflects a total facility footprint of approximately 2.5 acres at the Wetzel County Interconnect. The layout has been designed to accommodate future expansion to five (5) meter runs, with pre-graded pad space and piping stubs available for the installation of two additional runs to support the full 1.2 Bcf/d expandable capacity of the interconnection. This forward-looking design approach is intended to minimize future construction costs and operational disruptions when expansion becomes necessary.
Ridgeline requests that ATPC's engineering team review the revised site plan and provide any comments or concerns regarding the proposed layout, particularly as it relates to the interface between Ridgeline's facilities and ATPC's existing 30-inch mainline at Milepost 412.6.
IV. Interconnection Cost Allocation — Reservation of Position
Ridgeline acknowledges that the metering station design counterproposal set forth in Section III above does not resolve the parties' ongoing dispute over the appropriate allocation of interconnection costs. The cost allocation issue is a separate and distinct matter from the metering station design specifications, and Ridgeline believes that the parties can and should reach agreement on technical metering specifications independently of the cost allocation question.
For the avoidance of doubt, Ridgeline maintains its position, as set forth in Article VII of the Draft Interconnection Agreement (Version 1.0, July 2022) and in Ridgeline's October 17, 2022 answer to ATPC's protest, that the appropriate cost allocation for the $22.3 million in total interconnection facilities costs is 34.1% to Ridgeline (approximately $7.6 million) and 65.9% to ATPC (approximately $14.7 million). This allocation is based on well-established cost-causation principles and reflects the relative benefits received by ATPC and its shippers from the interconnection, including the incremental supply diversity, system reliability, and competitive market access that the Ridgeline interconnection will provide to ATPC's system.
Ridgeline is aware that ATPC's position, as stated in its August 15, 2022 protest, advocates for a 50/50 cost allocation, under which each party would bear $11.15 million of the total interconnection costs. Ridgeline respectfully disagrees with this position and does not believe that a 50/50 allocation is supported by the record or by applicable Commission precedent, for the reasons stated in Ridgeline's October 17, 2022 answer.
Ridgeline reserves the right to address the cost allocation issue separately in its direct testimony, in further settlement discussions before FERC Settlement Judge Howard Margolis, and in any other appropriate forum. This firm has prepared a separate, detailed analysis of FERC precedent on interconnection cost allocation under Order No. 2004 and its progeny, and Ridgeline may submit that analysis in connection with its direct testimony filing or in support of its position in the settlement process.
The metering station design counterproposal transmitted herewith is expressly without prejudice to either party's position on the interconnection cost allocation issue. Nothing in this letter or its attachments shall be construed as an acceptance, concession, or waiver of any position taken by either party with respect to cost allocation, and neither party's acceptance or rejection of any aspect of the metering station design counterproposal shall have any bearing on the resolution of the cost allocation dispute.
V. Proposed Next Steps and Timeline
Ridgeline proposes the following next steps and timeline for advancing negotiations on the metering station design:
1. Review of Counterproposal. Ridgeline requests that ATPC and its counsel at Kellner, Royce & Dillard LLP review this counterproposal and the attached revised metering station site plan (Attachment A), ultrasonic flow meter technical specifications (Attachment B), gas chromatograph technical specifications (Attachment C), and SCADA integration protocol summary (Attachment D) at your earliest convenience.
2. Technical Meeting. Ridgeline proposes a technical meeting between Ridgeline's engineering team, led by Thomas Greaves, Vice President of Engineering & Operations, and ATPC's engineering team to discuss the revised metering specifications in detail. Ridgeline requests that this meeting be scheduled within twenty-one (21) days of the date of this letter, with a target date in mid-December 2022. The meeting may be conducted in person at a mutually convenient location or by videoconference, at the parties' discretion. Mr. Greaves is prepared to present the revised metering station design, respond to technical questions, and discuss any modifications that ATPC's engineering team may propose.
3. Direct Testimony Filing. Ridgeline notes that it intends to file its direct testimony on the Track II schedule on December 5, 2022, as required by ALJ Whitfield's procedural order. Ridgeline's direct testimony filing will include, among other things, the pre-filed direct testimony of Thomas Greaves addressing engineering and system design issues, including the metering station design at the Wetzel County Interconnect. The metering station design reflected in Mr. Greaves's testimony will incorporate the counterproposal set forth in this letter. To the extent that the parties are able to reach agreement on metering specifications before the direct testimony filing date, Ridgeline's testimony will reflect that agreement.
4. Written Response. Ridgeline respectfully requests that ATPC provide a written response to this counterproposal by no later than December 16, 2022. A timely response will facilitate incorporation of any agreed-upon revisions into Version 2.0 of the Draft Interconnection Agreement, which Ridgeline anticipates circulating in January 2023.
5. Coordination with Track II Schedule. Ridgeline emphasizes the importance of advancing the interconnection negotiations in parallel with the Track II procedural schedule established by the Commission's September 22, 2022 order. The Track II schedule contemplates resolution of the interconnection issues on an expedited basis, and Ridgeline believes that meaningful progress on the technical metering specifications will assist the parties in narrowing the issues that must ultimately be resolved by ALJ Whitfield and the Commission.
6. Settlement Discussions. Ridgeline notes that the parties remain approximately $0.058/Dth apart on the overall rate in settlement discussions, with Ridgeline's position currently anchored at the proposed recourse rate level and the various intervenor positions reflecting somewhat lower rate levels. While the rate gap remains meaningful, Ridgeline is hopeful that resolution of the technical metering issues — which represent a discrete, tractable subset of the overall dispute — can help build momentum toward a broader settlement of both the rate case and the interconnection issues. Ridgeline remains committed to participating in good faith in the settlement process before Settlement Judge Margolis and encourages ATPC to approach the metering specifications negotiations in that same constructive spirit.
VI. Confidentiality
As you are aware, this firm transmitted a letter to your firm dated September 12, 2022, proposing confidentiality and protective order provisions for the exchange of commercially sensitive cost data and technical information in connection with the interconnection negotiations. Those proposed provisions remain under discussion, and we understand that ALJ Whitfield intends to address the entry of a protective order at the next procedural conference.
Ridgeline notes that certain technical specifications and cost data contained in this letter and its attachments contain confidential commercial information, including detailed engineering specifications, cost estimates, system capacity data, and operational information that is proprietary to Ridgeline and that would not ordinarily be disclosed to the public or to non-parties. Ridgeline designates the attachments to this letter — specifically, Attachment A (Revised Metering Station Site Plan), Attachment B (Ultrasonic Flow Meter Technical Specifications), Attachment C (Gas Chromatograph Technical Specifications), and Attachment D (SCADA Integration Protocol Summary) — as containing confidential commercial information subject to the protective order terms proposed in our September 12, 2022 letter.
Ridgeline respectfully requests that Kellner, Royce & Dillard LLP and ATPC treat the attached site plan and detailed technical specifications as confidential pending the entry of a protective order by ALJ Whitfield. In the interim, Ridgeline requests that access to the attachments be limited to outside counsel and in-house regulatory counsel with a need to know, and that the attachments not be further distributed without Ridgeline's prior written consent. We note that cover copies of this letter are being provided to counsel for certain other parties to the proceeding; however, the attachments are being withheld from those parties pending entry of the protective order.
VII. Attachments
The following documents are enclosed with this letter:
Attachment A: Revised Metering Station Site Plan — Wetzel County Interconnect (Drawing No. RMS-WCI-SP-2022-03, Rev. 1, prepared by Ridgeline Engineering Department, November 2022). This drawing shows the physical arrangement of the three ultrasonic meter runs, gas chromatograph shelter, pig launcher/receiver, SCADA equipment building, electrical supply, access road, and perimeter fencing at the proposed 2.5-acre site, including provisions for future expansion to five meter runs.
Attachment B: Ultrasonic Flow Meter Technical Specifications. This document provides a summary table setting forth manufacturer-neutral performance requirements for the three 12-inch ultrasonic meter runs, including accuracy specifications, turndown ratio, flow conditioning requirements, and calibration and verification procedures, consistent with AGA Report No. 9.
Attachment C: Gas Chromatograph Technical Specifications. This document provides a summary table setting forth performance requirements for the two online gas chromatograph units, including component analysis capabilities, cycle time, accuracy requirements consistent with GPA 2261 and GPA 2145, automatic switchover functionality, and data archival specifications.
Attachment D: SCADA Integration Protocol Summary. This document sets forth the proposed data point listing, communication specifications (DNP3 protocol, fiber optic link), polling frequencies, cybersecurity requirements, and shared infrastructure cost allocation framework for SCADA integration at the Wetzel County Interconnect.
VIII. Closing
Ridgeline looks forward to ATPC's prompt response to this counterproposal and to productive technical discussions on the metering station design for the Wetzel County Interconnect. Ridgeline remains fully committed to reaching a mutually acceptable interconnection agreement that serves the interests of both parties and their respective shippers, and to advancing this proceeding toward a timely and efficient resolution of all contested issues.
Should you wish to discuss any aspect of this counterproposal, the undersigned and George Trujillo, the responsible partner on this matter at Calderwood & Harkness LLP, are available at your convenience. We are also prepared to coordinate with Sandra K. Fenton, ATPC's Vice President of Regulatory Affairs, on scheduling the proposed technical meeting between the parties' engineering teams, and we would welcome your guidance on the appropriate mechanism for arranging that meeting.
We appreciate your attention to this matter and look forward to hearing from you at your earliest opportunity.
Very truly yours,
CALDERWOOD & HARKNESS LLP
By: ________
Brett Callahan Lead Associate, Energy & Infrastructure 1601 K Street NW, Suite 900 Washington, DC 20006 Telephone: (202) 555-7418
Email: bcallahan@calderwoodharkness.com
Enclosures (4)
cc (via electronic mail):
George Trujillo, Esq., Calderwood & Harkness LLP (Responsible Partner)
Patricia Dunmore, Esq., Calderwood & Harkness LLP (Billing Partner) / Chairperson, Dunmore Energy Holdings Ltd.
David Stanton, Esq., Calderwood & Harkness LLP (Working Associate)
James K. Winfield, CEO & President, Ridgeline Midstream Services LLC
Thomas Greaves, VP, Engineering & Operations, Ridgeline Midstream Services LLC
Angela Moretti, VP, Finance & Treasurer, Ridgeline Midstream Services LLC
Dr. Natasha Orlov, Director of Rates & Regulatory, Ridgeline Midstream Services LLC
Sandra K. Fenton, VP, Regulatory Affairs, Appalachian Trunk Pipeline Company, LLC
Rebekah Montague, Esq., Whitmore & Sable LLP (counsel for Mountaineer Gas Pipeline Corporation) (cover letter only; attachments withheld pending entry of protective order)
Stephen Greer, Esq., Fordham Municipal Law Group PC (counsel for the Central Mid-Atlantic Gas Association) (cover letter only; attachments withheld pending entry of protective order)
Jonathan Briggs, Lead Trial Attorney, Office of General Counsel, Federal Energy Regulatory Commission (cover letter only; attachments withheld pending entry of protective order)

CALDERWOOD & HARKNESS LLP Attorneys at Law

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