UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION
Ridgeline Midstream Services LLC
Docket No. RP22-847-000 Docket No. RP22-847-001
THIRD QUARTERLY STATUS REPORT OF RIDGELINE MIDSTREAM SERVICES LLC
Filed: December 13, 2024
Calderwood & Harkness LLP 1601 K Street NW, Suite 900 Washington, DC 20006 Counsel for Ridgeline Midstream Services LLC FERC Code: 960442
TABLE OF CONTENTS
I. INTRODUCTION AND PURPOSE
Ridgeline Midstream Services LLC ("Ridgeline" or "Applicant"), a Delaware limited liability company and wholly owned subsidiary of Dunmore Energy Holdings Ltd. ("DEH"), a Cayman Islands exempted limited company (Cayman Registry No. CR-381204), hereby files this Third Quarterly Status Report ("Third Report") in the above-captioned proceedings. This filing is made pursuant to the March 4, 2024 Order of the Honorable Clara Whitfield, Administrative Law Judge ("ALJ"), Federal Energy Regulatory Commission ("FERC" or "Commission"), which granted Ridgeline a third extension of time and established, as a condition of that extension, the requirement that Ridgeline file quarterly status reports on the progress of its tariff redesign in Docket Nos. RP22-847-000 and RP22-847-001.
Specifically, the ALJ's March 4, 2024 Order ("Third Extension Order") granted Ridgeline a twelve-month extension of time, establishing a new filing deadline of February 21, 2025 for the submission of the redesigned FERC Gas Tariff, Original Volume No. 1, and all supplemental pre-filed testimony and supporting exhibits. In granting this extension, the ALJ imposed the condition that Ridgeline file quarterly status reports detailing the progress of the tariff redesign, the status of settlement negotiations among the parties, and any other material developments in the proceeding. The Third Extension Order specified that such reports shall be filed no later than ninety (90) days after the date of the preceding report, with the first report due on or before June 15, 2024.
In compliance with the Third Extension Order, Ridgeline previously filed its First Quarterly Status Report on June 15, 2024, covering the period from March 5, 2024 through June 15, 2024, and its Second Quarterly Status Report on September 14, 2024, covering the period from June 16, 2024 through September 14, 2024. This Third Quarterly Status Report covers the period from September 15, 2024 through December 13, 2024, and constitutes the third of four quarterly reports required under the ALJ's order prior to the February 21, 2025 filing deadline. Ridgeline anticipates that the fourth quarterly report will be mooted by the filing of the redesigned tariff itself.
As set forth in detail below, Ridgeline is pleased to report that substantial progress has been achieved during this reporting period. The tariff redesign is now in near-final form, all fourteen deficiency items identified in the Commission's January 19, 2023 Deficiency Letter have been addressed, and preparation of supplemental pre-filed testimony is well advanced. Ridgeline confirms its intent to meet the February 21, 2025 filing deadline and does not anticipate requesting any further extension of time.
Ridgeline's principal office is located at 700 Kanawha Boulevard East, Suite 1400, Charleston, West Virginia 25301. Ridgeline's registered agent is Capitol Filings Inc., 1209 Orange Street, Wilmington, Delaware 19801. Ridgeline's Employer Identification Number is 87-4231956.
II. PROCEDURAL BACKGROUND
The following procedural summary provides context for this Third Quarterly Status Report and supplements the procedural histories set forth in Ridgeline's prior quarterly reports.
A. Original Filing and Initial Proceedings
On May 12, 2022, Ridgeline filed its original application in these dockets, seeking (i) approval of an initial tariff rate for interstate natural gas transportation service on the Ridgeline Pipeline System under Sections 4 and 7 of the Natural Gas Act ("NGA"), 15 U.S.C. §§ 717c and 717f, and Parts 154, 157, and 284 of the Commission's regulations, 18 C.F.R. Parts 154, 157, and 284 (Docket No. RP22-847-000), and (ii) authorization for physical interconnection with Appalachian Trunk Pipeline Company, LLC ("ATPC") at the Wetzel County Interconnect in Wetzel County, West Virginia (Docket No. RP22-847-001).
B. The Ridgeline Pipeline System
Ridgeline owns and operates the Ridgeline Pipeline System, a 187-mile, 24-inch-diameter high-pressure natural gas transmission pipeline extending from a receipt point at the Wetzel County Interconnect in Wetzel County, West Virginia, to a delivery point at the Waynesburg Compressor Station in Greene County, Pennsylvania. The pipeline has a design capacity of 1.2 billion cubic feet per day ("Bcf/d"), equivalent to 1,200,000 dekatherms per day ("Dth/d"). Current throughput on the system is approximately 680 million cubic feet per day ("MMcf/d"), representing approximately 56.67% utilization of design capacity. The pipeline entered commercial service on October 1, 2021.
The Ridgeline Pipeline System includes three compressor stations: the Wetzel Station, the Mannington Station, and the Waynesburg Station, with aggregate installed compression of 45,000 horsepower ("HP"). These compressor stations provide the necessary pressure to transport natural gas along the full 187-mile pipeline route through the Appalachian terrain of northern West Virginia and southwestern Pennsylvania.
C. Originally Filed Rate
Ridgeline's original filing proposed a recourse rate of $0.2265 per Dth, consisting of a reservation charge component of $0.2223 per Dth and a usage charge component of $0.0042 per Dth. This proposed rate was based on a rate base of $612.40 million, a total cost of service of $97.36 million, a 100% load factor assumption, and billing determinants of 438,000,000 Dth per year. The original filing proposed a return on equity ("ROE") of 14.00%, a capital structure of 55% equity and 45% debt, a cost of debt of 5.25%, resulting in a weighted average cost of capital ("WACC") of 10.0625%.
D. Interventions and Protests
On June 14, 2022, the Commission issued its Notice of Filing in these dockets. Three parties subsequently filed interventions and/or protests:
(a) Mountainside Gas Producers Coalition ("MGPC"). MGPC, an unincorporated association of fourteen independent natural gas producers operating in the Appalachian Basin, under the direction of Calvin Dreyer, Executive Director, filed its motion to intervene on July 28, 2022. MGPC raised concerns regarding Ridgeline's proposed ROE, load factor assumptions, and the adequacy of Ridgeline's tariff provisions governing capacity release and operational flow orders.
(b) Clearwater Municipal Gas Authority ("CMGA"). CMGA, a municipal gas distribution authority serving the Borough of Clearwater and surrounding communities in Greene County, Pennsylvania, under the general management of Dennis Ott, filed its motion to intervene on August 1, 2022. CMGA expressed concern about the potential rate impacts of the proposed interconnection cost allocation on ATPC's existing system rates, which directly affect CMGA's wholesale gas procurement costs.
(c) Appalachian Trunk Pipeline Company, LLC ("ATPC"). ATPC filed its protest and motion to intervene on August 15, 2022. ATPC, which owns and operates a 640-mile, 3.8 Bcf/d interstate natural gas pipeline system serving markets in Pennsylvania, Ohio, and New York, contested Ridgeline's proposed allocation of interconnection costs at the Wetzel County Interconnect and raised certain issues regarding metering station design and NAESB compliance.
E. Commission Orders and Assignment of Presiding Officers
On September 22, 2022, the Commission issued an order granting all three interventions, establishing a Track II procedural schedule for the adjudication of Ridgeline's application, and appointing Settlement Judge Howard Margolis to facilitate settlement discussions among the parties. On November 14, 2022, the Chief Administrative Law Judge designated ALJ Clara Whitfield as the presiding judge in these proceedings. A prehearing conference was held before ALJ Whitfield on November 14, 2022, at which time the parties discussed the procedural schedule and the scope of the issues to be addressed in the Track II hearing.
F. Direct and Answering Testimony
Ridgeline filed its direct pre-filed testimony on December 5, 2022, consisting of the testimony of seven witnesses addressing, among other things, the design and operation of the Ridgeline Pipeline System, the proposed tariff rate, the cost-of-service analysis, the proposed ROE, the interconnection agreement with ATPC, and the general terms and conditions of the proposed tariff. Answering testimony was filed on January 9, 2023, by ATPC (through counsel Kellner, Royce & Dillard LLP, William Pratt, Senior Partner), MGPC (through counsel Whitmore & Sable LLP, Rebekah Montague, Partner), and CMGA (through counsel Fordham Municipal Law Group PC, Stephen Greer, Principal).
G. Deficiency Letter and Stay of Proceedings
On January 19, 2023, the FERC Office of Energy Market Regulation issued a Deficiency Letter identifying fourteen (14) specific deficiencies in Ridgeline's tariff filing. The Deficiency Letter was prepared under the supervision of Dr. Miriam Okafor, Lead Economic Analyst, and Jonathan Briggs, Lead Trial Attorney. The fourteen deficiency items addressed a range of tariff and rate design issues, including the adequacy of Ridgeline's ROE support (Item 1), the absence of a fuel-use and lost-and-unaccounted-for gas tracker mechanism (Item 2), the derivation of the interruptible transportation rate (Item 3), the use of a 100% load factor assumption (Item 4), the absence of capacity release provisions (Item 5), NAESB compliance (Item 6), electronic bulletin board posting requirements (Item 7), shipper-must-have-title policy (Item 8), the treatment of the interconnection agreement as a rate schedule (Item 9), penalty revenue crediting (Item 10), creditworthiness provisions (Item 11), segmentation and flexible receipt/delivery provisions (Item 12), greenhouse gas emission cost recovery (Item 13), and Order No. 2222 distributed energy resource aggregation provisions (Item 14).
On February 6, 2023, ALJ Whitfield issued an order staying the procedural schedule pending Ridgeline's response to the Deficiency Letter. On March 15, 2023, Ridgeline filed a partial response addressing eight of the fourteen deficiency items—specifically, Items 1 through 4 and Items 7 through 10. The remaining six items (Items 5, 6, 11, 12, 13, and 14) required more extensive tariff revisions that could not be completed within the initial response period.
H. Engagement of Braswell Energy Consulting Group
In recognition of the scope and complexity of the required tariff redesign, Ridgeline engaged Braswell Energy Consulting Group LLC ("Braswell") on April 15, 2023 to assist with the comprehensive redesign of the FERC Gas Tariff, Original Volume No. 1. The engagement was designated as Braswell engagement number BEC-2023-0041. Braswell is led by Dr. Raymond Braswell, a former Commission economist with extensive experience in natural gas pipeline rate design and tariff proceedings. Dr. Braswell previously served as Ridgeline's testifying witness on ROE in this proceeding and now serves as the lead redesign consultant through Braswell. The engagement of Braswell was disclosed to all parties and the ALJ in connection with Ridgeline's first request for extension of time.
I. Extensions of Time
The procedural history of this matter has been characterized by a series of extensions of time necessitated by the scope of the required tariff redesign:
First Extension. Ridgeline filed its first request for extension of time on April 28, 2023, seeking an additional 120 days to complete its response to the Deficiency Letter and to advance the tariff redesign process. ALJ Whitfield granted the first extension on May 10, 2023, extending the filing deadline to August 28, 2023.
Second Extension. Ridgeline filed its second request for extension of time on August 25, 2023, seeking an additional 180 days to complete the tariff redesign and prepare supplemental testimony. ALJ Whitfield granted the second extension on September 8, 2023, extending the filing deadline to February 23, 2024. At that time, the ALJ changed the proceeding status to "dormant" in the Commission's case tracking system, reflecting the suspension of active hearing proceedings pending the completion of the tariff redesign.
Third Extension. Ridgeline filed its third request for extension of time on February 20, 2024, seeking an additional twelve (12) months to complete the tariff redesign, finalize the interconnection agreement with ATPC, and prepare comprehensive supplemental testimony. ALJ Whitfield granted the third extension on March 4, 2024, establishing a new filing deadline of February 21, 2025, subject to the condition that Ridgeline file quarterly status reports on the progress of the tariff redesign. It is pursuant to this condition that the instant Third Quarterly Status Report is filed.
III. STATUS OF TARIFF REDESIGN
A. Overall Progress and Near-Final State
Ridgeline is pleased to confirm that the redesign of FERC Gas Tariff, Original Volume No. 1, has reached a near-final state and that Ridgeline fully intends to meet the February 21, 2025 filing deadline established by the ALJ's March 4, 2024 Order. During the reporting period covered by this Third Report (September 15, 2024 through December 13, 2024), Ridgeline, through its counsel at Calderwood & Harkness LLP and its consulting engagement with Braswell Energy Consulting Group LLC, has made significant additional progress in completing and refining the redesigned tariff.
The tariff redesign is now in its fourth draft, dated November 2024. This fourth draft reflects the cumulative work product of Calderwood & Harkness LLP (C&H Matter No. 1016-00005, George Trujillo, Responsible Partner; Brett Callahan, Lead Associate; David Stanton, Working Associate) and Braswell Energy Consulting Group LLC since the commencement of the redesign engagement in April 2023. The fourth draft represents a comprehensive revision of the originally filed tariff and addresses all fourteen deficiency items identified in the Commission's January 19, 2023 Deficiency Letter, as described in detail in Section III.D below.
The redesigned tariff remains a Part 284, Subpart G open-access transportation tariff. The fourth draft incorporates a complete set of general terms and conditions ("GT&Cs"), firm and interruptible transportation rate schedules, a fuel-use and lost-and-unaccounted-for gas tracker mechanism, capacity release provisions, creditworthiness provisions, segmentation and flexible receipt/delivery point provisions, a greenhouse gas cost tracker, and provisions addressing distributed energy resource aggregation under Order No. 2222. The fourth draft also reflects full compliance with NAESB Wholesale Gas Quadrant Version 3.2 standards and incorporates the electronic bulletin board posting requirements mandated by Commission policy.
Ridgeline anticipates that the remaining work required to bring the tariff to final form consists principally of (i) completing conforming changes and cross-references within the tariff document, (ii) finalizing the supplemental pre-filed testimony described in Section III.E below, and (iii) completing final workpaper exhibits in coordination with Braswell. No substantive changes to the tariff design or rate structure are anticipated.
B. Revised Rate Design Parameters
A central element of the tariff redesign has been the revision of certain rate design parameters that were the subject of criticism in the Deficiency Letter and the intervenors' answering testimony. The most significant change in rate design methodology concerns the load factor assumption used to derive billing determinants.
Ridgeline's redesigned tariff adopts a modified fixed-variable rate methodology at a 75% load factor, replacing the original 100% load factor assumption that was the subject of Deficiency Item 4 in the January 19, 2023 Deficiency Letter. The Commission Staff identified the 100% load factor assumption as unreasonable in light of the pipeline's actual throughput history, and all three intervenors similarly challenged this assumption in their answering testimony. After careful analysis, including consideration of the Ridgeline Pipeline System's actual throughput of approximately 680 MMcf/d against a design capacity of 1.2 Bcf/d (representing 56.67% utilization), projected throughput growth, and the load factors approved by the Commission for comparable new-build pipelines in the Appalachian Basin, Ridgeline concluded that a 75% load factor appropriately balances the interests of the pipeline and its shippers.
The revised billing determinants under the 75% load factor assumption are calculated as follows:
Design Capacity: 1,200,000 Dth/d × 365 days/year × 75% load factor = 328,500,000 Dth/yr
This represents a reduction from the original billing determinants of 438,000,000 Dth/yr (which assumed a 100% load factor). As a necessary consequence of the lower billing determinants, the per-unit recourse rate increases to distribute the pipeline's cost of service across a smaller volume of throughput.
Ridgeline's revised proposed recourse rate under the redesigned tariff is $0.3140 per Dth, consisting of:
Reservation Charge: $0.3102/Dth Usage Charge: $0.0038/Dth Total Recourse Rate: $0.3140/Dth
This compares to the originally filed recourse rate of $0.2265 per Dth ($0.2223 reservation + $0.0042 usage). The increase in the per-unit recourse rate from $0.2265/Dth to $0.3140/Dth—an increase of $0.0875/Dth, or approximately 38.6%—is attributable to two principal factors: (i) the reduction in billing determinants resulting from the lower load factor (accounting for approximately 72% of the rate increase), and (ii) a net increase in the total cost of service from $97.36 million to $103.15 million (accounting for approximately 28% of the rate increase), as described in Section III.C below.
C. Revised Cost-of-Service Summary
Ridgeline's redesigned tariff is supported by a revised cost-of-service analysis reflecting both the updated rate design parameters described above and certain revisions to individual cost-of-service components. A summary of the revised cost of service follows.
Rate Base
The rate base remains at $612.40 million as originally filed. No changes to the rate base have been made in the redesigned tariff. The rate base is composed of the following elements:
The pipeline construction cost underlying the net plant in service figure is $587.2 million, reflecting the total capital expenditure for the construction of the 187-mile Ridgeline Pipeline System, including the three compressor stations. Accumulated depreciation as of the test year ended March 31, 2022 is $23.49 million, calculated on a straight-line basis at an annual depreciation rate of 2.5%.
Return on Equity and Weighted Average Cost of Capital
The redesigned tariff proposes a revised ROE of 12.50%, reduced from the originally proposed 14.00%. This reduction reflects the results of an updated discounted cash flow ("DCF") proxy group analysis as of the third quarter of 2024, prepared by Dr. Raymond Braswell of Braswell Energy Consulting Group LLC. The updated DCF analysis addresses Deficiency Item 1, which identified insufficient support for Ridgeline's originally proposed 14.00% ROE. The updated analysis utilizes a proxy group of comparable publicly traded natural gas pipeline companies, applies the Commission's two-step DCF methodology, and incorporates current market data reflecting prevailing capital market conditions as of Q3 2024.
The capital structure remains unchanged at 55% equity and 45% debt, and the cost of debt remains unchanged at 5.25%. The cost of debt represents the weighted average cost of Ridgeline's two outstanding debt instruments:
(i) A $400 million senior secured term loan under Ridgeline's Senior Secured Credit Facility, bearing interest at the Secured Overnight Financing Rate ("SOFR") plus 325 basis points; and
(ii) $150 million in 7.875% Second Lien Senior Secured Notes due 2030.
The resulting revised WACC is calculated as follows:
Equity Component: 0.55 × 12.50% = 6.875% Debt Component: 0.45 × 5.25% = 2.3625% Revised WACC: 6.875% + 2.3625% = 9.2375%
This compares to the original WACC of 10.0625%. The reduction in WACC of 82.5 basis points is attributable entirely to the 150 basis point reduction in the proposed ROE.
Revised Return on Rate Base
$612.40 million × 9.2375% = $56.57 million (compared to original return on rate base of $61.62 million)
Revised Cost-of-Service Components
The following table presents a comparison of the original and revised cost-of-service components:
Ridgeline provides the following explanations for the material changes in individual cost-of-service components:
Return on Rate Base. The reduction of $5.05 million in the return on rate base is directly attributable to the reduction in the proposed ROE from 14.00% to 12.50%, which reduces the WACC from 10.0625% to 9.2375%.
Depreciation Expense. Depreciation expense remains unchanged at $14.68 million, reflecting the continued application of the 2.5% straight-line depreciation rate to the pipeline's depreciable plant in service.
O&M Expense. Operations and maintenance expense has been revised upward from $12.44 million to $13.92 million, an increase of $1.48 million, to reflect updated current-period costs for compressor station maintenance, pipeline integrity management, right-of-way maintenance, and related operational expenditures. These updated costs reflect actual operating experience since the pipeline entered service in October 2021.
A&G Expense. Administrative and general expense has been revised upward from $4.82 million to $5.14 million, an increase of $0.32 million, to reflect updated current-period costs for corporate overhead allocations, insurance, regulatory compliance, and related administrative expenditures.
Taxes Other Than Income. Taxes other than income remain unchanged at $3.80 million, consisting principally of state and local property taxes and payroll taxes.
Income Tax Allowance. The income tax allowance has been revised downward from $16.00 million to $15.04 million, a reduction of $0.96 million, to reflect the lower pre-tax income resulting from the reduced ROE. The income tax allowance is calculated by grossing up the equity return at an approximately 26.13% effective combined federal and state income tax rate, reflecting the 21% federal corporate income tax rate and the 6.5% West Virginia state corporate net income tax rate.
Revenue Credits. Revenue credits have been revised from ($16.10 million) to ($6.00 million), a reduction of $10.10 million. This revision reflects updated projections of interruptible transportation revenue, parking and lending service revenue, and other miscellaneous revenue based on actual operating experience. The original filing's revenue credit projection of $16.10 million was based on pre-service estimates that have proven to be significantly higher than the actual revenue experience since the pipeline entered service.
Rate Derivation
The revised total cost of service of $103.15 million is derived as follows:
$56.57M + $14.68M + $13.92M + $5.14M + $3.80M + $15.04M − $6.00M = $103.15 million
The revised recourse rate is calculated by dividing the total cost of service by the revised billing determinants:
$103.15 million ÷ 328,500,000 Dth/yr = $0.3140/Dth
D. Status of Individual Deficiency Items
Ridgeline provides below the current status of each of the fourteen deficiency items identified in the Commission's January 19, 2023 Deficiency Letter. All fourteen items have been addressed in the fourth draft of the redesigned tariff.
Item 1 — ROE Support: Addressed. Ridgeline has prepared an updated DCF proxy group analysis as of Q3 2024, which supports a revised ROE of 12.50%. This analysis was prepared by Dr. Raymond Braswell of Braswell Energy Consulting Group LLC and utilizes the Commission's established two-step DCF methodology with a proxy group of comparable publicly traded natural gas pipeline companies. Supplemental testimony of Dr. Braswell supporting the revised ROE is being finalized for inclusion with the February 21, 2025 filing.
Item 2 — Fuel-Use and Lost-and-Unaccounted-For Gas (FL&U) Tracker: Addressed. A comprehensive fuel-use and lost-and-unaccounted-for gas tracker mechanism has been designed and incorporated into the revised GT&Cs. The FL&U tracker includes a percentage retention methodology, whereby a stated percentage of volumes tendered for transportation will be retained by Ridgeline to account for compressor fuel usage and unaccounted-for gas losses. The tracker includes annual true-up procedures under which the actual fuel-use and lost-and-unaccounted-for gas percentages will be compared to the stated retention percentage, with any over- or under-recovery reflected in a prospective adjustment to the retention percentage.
Item 3 — Interruptible Transportation (IT) Rate Derivation: Addressed. The interruptible transportation rate schedule (Rate Schedule IT-1) has been fully developed and incorporated into the redesigned tariff. The IT-1 rate is derived from the firm recourse rate with an appropriate relationship that reflects the lower priority and interruptible nature of the service. The redesigned tariff also includes a methodology for crediting interruptible transportation revenues against the cost of service for purposes of the firm rate derivation, consistent with Commission precedent.
Item 4 — Load Factor: Addressed. The redesigned tariff modifies the load factor assumption from 100% to 75%, as described in detail in Section III.B above. The revised load factor is supported by an analysis of the Ridgeline Pipeline System's current throughput of approximately 680 MMcf/d against its design capacity of 1.2 Bcf/d (56.67% utilization), projected throughput growth based on executed and pending precedent agreements, and the load factors approved by the Commission for comparable new-build pipelines in the Appalachian Basin.
Item 5 — Capacity Release Provisions: Addressed. Comprehensive capacity release provisions were incorporated into the redesigned tariff beginning with the third draft (dated June 2024). These provisions include procedures for the release of firm capacity by shippers holding firm transportation agreements, the posting of available capacity on the pipeline's electronic bulletin board, the conduct of capacity release auctions, the establishment of minimum bid requirements, and the rights and obligations of replacement shippers, all in accordance with Commission regulations at 18 C.F.R. § 284.8 and applicable NAESB standards.
Item 6 — NAESB Compliance: Addressed. The operational flow order provisions and other operational provisions of the redesigned tariff have been revised to comply with NAESB Wholesale Gas Quadrant Version 3.2 standards. Ridgeline and Braswell conducted a comprehensive gap analysis comparing the originally filed tariff provisions against applicable NAESB standards and identified several areas requiring revision, including provisions governing nominations and scheduling, capacity allocation, imbalance management, operational flow orders, and electronic communication protocols. All identified gaps have been addressed in the fourth draft.
Item 7 — Electronic Bulletin Board (EBB) Posting Requirements: Addressed. The redesigned tariff incorporates the full suite of electronic bulletin board posting requirements mandated by Commission regulations, including the posting of available capacity, executed transportation agreements, capacity release information, operational notices, and other information required to be posted under 18 C.F.R. § 284.13 and applicable NAESB standards. This item was initially addressed in Ridgeline's partial response of March 15, 2023, and the provisions have been further refined in subsequent drafts.
Item 8 — Shipper-Must-Have-Title Policy: Addressed. The redesigned tariff incorporates the shipper-must-have-title requirement, mandating that shippers tendering gas for transportation on the Ridgeline Pipeline System must hold title to the gas at the time of delivery to the pipeline. This item was initially addressed in Ridgeline's partial response of March 15, 2023, and the provision has been confirmed and carried forward in all subsequent drafts, including the current fourth draft.
Item 9 — Interconnection Agreement as Rate Schedule: Addressed. Consistent with Commission policy requiring that interconnection agreements for new pipeline interconnections be filed as rate schedules, Ridgeline's Interconnection Agreement with ATPC for the physical interconnection at the Wetzel County Interconnect is being finalized for filing as a FERC rate schedule. The current status of the Interconnection Agreement is discussed in detail in Section V below.
Item 10 — Penalty Revenue Crediting: Addressed. The redesigned tariff includes provisions for the crediting of penalty revenues collected under the tariff's operational flow order and imbalance management provisions. Penalty revenues are credited to non-offending shippers on a pro rata basis, consistent with Commission policy. This item was initially addressed in Ridgeline's partial response of March 15, 2023, and the provision has been confirmed in the current fourth draft.
Item 11 — Creditworthiness Provisions: Addressed. The redesigned tariff includes comprehensive creditworthiness provisions governing the establishment of unsecured credit limits for shippers, collateral requirements for shippers that do not satisfy the minimum credit standards, credit rating thresholds, acceptable forms of financial assurance (including letters of credit, surety bonds, cash deposits, and parent guarantees), and procedures for monitoring and adjusting creditworthiness determinations. These provisions have been developed in accordance with Commission creditworthiness policy as articulated in applicable orders and rulings. The creditworthiness provisions were initially addressed in the third draft (June 2024) and have been further refined in the fourth draft.
Item 12 — Segmentation and Flexible Receipt/Delivery Provisions: Addressed. The redesigned tariff now includes provisions permitting shippers to segment their firm transportation capacity and to utilize flexible receipt and delivery points along the Ridgeline Pipeline System. These provisions are designed to enhance the efficiency and flexibility of the transportation service offered on the system and are consistent with Commission policies favoring segmentation and flexible point rights for firm shippers. The segmentation and flexible receipt/delivery provisions were initially addressed in the third draft and have been further refined in the fourth draft.
Item 13 — Greenhouse Gas Emission Cost Recovery: Addressed. The redesigned tariff includes a greenhouse gas ("GHG") cost tracker and passthrough mechanism incorporated into the revised GT&Cs. This mechanism is designed to permit Ridgeline to recover, on a dollar-for-dollar basis, any costs incurred in complying with federal, state, or local greenhouse gas emission regulations, including but not limited to carbon taxes, emission allowance costs, methane emission reduction compliance costs, and reporting and verification costs. The GHG cost tracker includes annual filing and true-up procedures to ensure that recovered amounts reflect actual costs incurred.
Item 14 — Order No. 2222 Distributed Energy Resource Aggregation: Addressed. The redesigned tariff includes provisions addressing the aggregation of distributed energy resources ("DERs") in connection with renewable energy interconnection requests, consistent with the principles of FERC Order No. 2222. These provisions reflect consideration of DEH's broader portfolio, which includes a 250-megawatt ("MW") wind portfolio currently under development, and the potential for future interconnection of renewable energy resources with the Ridgeline Pipeline System and associated midstream infrastructure. The provisions establish a framework for the evaluation and processing of DER aggregation and renewable energy interconnection requests on a non-discriminatory basis.
E. Supplemental Testimony Preparation
In connection with the filing of the redesigned tariff on or before February 21, 2025, Ridgeline is preparing supplemental pre-filed testimony to replace and supersede certain portions of the direct testimony originally filed on December 5, 2022. The supplemental testimony is anticipated to include, at minimum, the following:
Supplemental Testimony of Dr. Natasha Orlov. Dr. Natasha Orlov, Director of Rates & Regulatory for Ridgeline, will provide supplemental testimony addressing all fourteen deficiency items identified in the January 19, 2023 Deficiency Letter and the redesigned tariff provisions adopted in response thereto. Dr. Orlov's supplemental testimony will address, among other things, the modified fixed-variable rate methodology, the 75% load factor assumption and supporting analysis, the FL&U tracker mechanism, the capacity release provisions, the NAESB compliance gap analysis and responsive revisions, the EBB posting requirements, the creditworthiness provisions, the segmentation and flexible receipt/delivery point provisions, the GHG cost tracker and passthrough mechanism, and the implications of Order No. 2222 for the Ridgeline Pipeline System.
Supplemental Testimony of Angela Moretti. Angela Moretti, Vice President, Finance & Treasurer of Ridgeline, will provide supplemental testimony addressing the revised cost-of-service analysis, including the total cost of service of $103.15 million, the rate base of $612.40 million, the revised WACC of 9.2375%, the revised ROE of 12.50%, and the revised billing determinants of 328,500,000 Dth/yr at a 75% load factor, resulting in the revised proposed recourse rate of $0.3140 per Dth ($0.3102/Dth reservation charge + $0.0038/Dth usage charge). Ms. Moretti's testimony will include supporting schedules and workpapers demonstrating the derivation of each cost-of-service component and the calculation of the proposed rates.
Supporting exhibits and workpapers are currently being finalized in coordination with Braswell Energy Consulting Group LLC. The workpapers will include, among other materials, the updated DCF proxy group analysis supporting the revised ROE, the load factor analysis, the FL&U tracker design documentation, the NAESB gap analysis, and the detailed cost-of-service schedules.
IV. STATUS OF SETTLEMENT DISCUSSIONS
A. Fourth Settlement Conference
A fourth settlement conference in these dockets was held on January 18, 2024 before Settlement Judge Howard Margolis. All active parties participated in the conference:
(a) Ridgeline Midstream Services LLC, through counsel Calderwood & Harkness LLP (George Trujillo and Brett Callahan);
(b) Appalachian Trunk Pipeline Company, LLC, through counsel Kellner, Royce & Dillard LLP (William Pratt, Senior Partner);
(c) Mountainside Gas Producers Coalition, through counsel Whitmore & Sable LLP (Rebekah Montague, Partner);
(d) Clearwater Municipal Gas Authority, through counsel Fordham Municipal Law Group PC (Stephen Greer, Principal); and
(e) FERC Trial Staff (Jonathan Briggs, Lead Trial Attorney).
The fourth settlement conference provided an opportunity for the parties to discuss the status of Ridgeline's tariff redesign, the remaining areas of disagreement, and the prospects for a negotiated resolution of the contested issues in these dockets. Despite good-faith discussions among all parties, no settlement was reached at the January 18, 2024 conference.
B. Current Party Positions and Rate Gap
As of the date of this Third Quarterly Status Report, the parties remain approximately $0.058 per Dth apart on the proposed recourse rate. The current positions of the parties are summarized below.
Ridgeline's Position. Ridgeline maintains a recourse rate floor of $0.3140 per Dth, based on the redesigned tariff parameters described in Section III above, including a proposed ROE of 12.50%, a 75% load factor, and a total cost of service of $103.15 million.
ATPC and MGPC Position. ATPC and MGPC advocate a combined rate ceiling of approximately $0.2560 per Dth, reflecting their respective positions on ROE, load factor, and cost-of-service components. While the precise derivation of the intervenors' proposed rate differs between ATPC and MGPC on certain individual components, both parties have converged on an approximate combined rate ceiling that is approximately $0.058/Dth below Ridgeline's proposed rate.
Three principal sticking points remain between the parties:
1. Return on Equity. The parties remain significantly apart on the appropriate ROE for the Ridgeline Pipeline System. ATPC proposes an ROE of 10.75%, which it contends reflects the lower risk profile of the Ridgeline system in light of its favorable geographic position within the Appalachian production basin. MGPC, supported by the testimony of Dr. Eleanor Vasquez, MGPC's rate expert, proposes an ROE of 11.25%, which Dr. Vasquez contends is appropriate based on her own DCF analysis using a narrower proxy group of Appalachian Basin pipeline companies. Ridgeline proposes an ROE of 12.50%, as described in Section III.C above, which it contends is supported by Dr. Braswell's updated DCF proxy group analysis and appropriately reflects the risks associated with a relatively new pipeline system that has not yet achieved its design throughput.
2. Interconnection Cost Allocation. The parties remain unable to agree on the allocation of interconnection facilities costs for the Wetzel County Interconnect. The total estimated cost of the interconnection facilities—including the new meter station, pig launcher/receiver, ultrasonic flow meters, gas chromatographs, SCADA integration, and associated civil and mechanical work—is $22.3 million. ATPC insists on a 50/50 cost allocation, under which each party would bear $11.15 million of the interconnection facilities cost. Ridgeline maintains its proposed allocation of 34.1% to Ridgeline ($7.6 million) and 65.9% to ATPC ($14.7 million), based on cost-causation principles. Ridgeline contends that a disproportionate share of the interconnection facilities cost is attributable to modifications required to ATPC's existing 30-inch mainline at the interconnection point, including meter station configuration requirements driven by ATPC's system operating parameters, and that ATPC should bear a corresponding share of the costs.
3. Load Factor. All three intervenors—ATPC, MGPC, and CMGA—advocate for a load factor of 85% or higher, contending that the Ridgeline Pipeline System's projected throughput growth justifies a higher load factor assumption than the 75% proposed by Ridgeline. Ridgeline maintains that a 75% load factor is appropriate given the system's current utilization of approximately 56.67% and the uncertainty inherent in throughput projections for a pipeline that has been in service for only approximately three years.
C. Prospect for Continued Negotiations
The parties have not scheduled a fifth settlement conference at this time. Following the fourth settlement conference in January 2024, the parties engaged in informal bilateral discussions on certain issues, but these discussions have not resulted in the narrowing of the rate gap or the resolution of any of the three principal sticking points described above.
Ridgeline remains willing to engage in further settlement discussions, including through the auspices of Settlement Judge Margolis, and continues to believe that a negotiated resolution of these proceedings is in the interests of all parties. However, Ridgeline anticipates that the filing of the redesigned tariff and supplemental testimony on February 21, 2025 will provide a more concrete and comprehensive basis for any resumed negotiations, as the parties will have the benefit of Ridgeline's complete tariff filing, including the detailed cost-of-service analysis, the updated DCF analysis, and the comprehensive supporting testimony and workpapers.
Ridgeline notes that CMGA, through its General Manager Dennis Ott, continues to align with ATPC's position on the interconnection cost allocation issue. CMGA has expressed concern about the potential rate impacts of the proposed cost allocation on ATPC's existing 640-mile, 3.8 Bcf/d interstate pipeline system, which serves markets in Pennsylvania, Ohio, and New York. CMGA receives natural gas service through ATPC's system and is concerned that a cost allocation that burdens ATPC with a disproportionate share of the interconnection costs could ultimately result in rate increases on the ATPC system that would be passed through to CMGA and its municipal customers.
V. STATUS OF INTERCONNECTION AGREEMENT
The Interconnection Agreement between Ridgeline and ATPC for the physical interconnection at the Wetzel County Interconnect is currently in its third draft (Version 3.0, dated April 2023). This version was revised following the issuance of the January 19, 2023 Deficiency Letter to reflect the requirement that the interconnection agreement be filed as a FERC rate schedule, thereby addressing Deficiency Item 9.
The key terms of the Interconnection Agreement, as reflected in the current Version 3.0 draft, are summarized below:
Interconnection Point. The interconnection will be located at Milepost 0.0 of the Ridgeline Pipeline System, tying into ATPC's existing 30-inch mainline at ATPC Milepost 412.6, in Wetzel County, West Virginia.
Interconnection Facilities. The interconnection facilities include a new meter station and pig launcher/receiver. The meter station will be equipped with three runs of 12-inch ultrasonic flow meters, gas chromatographs, and SCADA integration to enable real-time flow measurement and data communication between the Ridgeline and ATPC control systems.
Design Capacity. The design capacity at the interconnect is 800 MMcf/d bidirectional, expandable to 1.2 Bcf/d through the addition of supplemental metering and compression facilities.
Estimated Cost and Proposed Allocation. The total estimated cost of the interconnection facilities is $22.3 million. Ridgeline's proposed allocation is: Ridgeline $7.6 million (34.1%) and ATPC $14.7 million (65.9%).
As noted in Section IV.B above, the cost allocation for the interconnection facilities remains a contested issue. ATPC, through its counsel Kellner, Royce & Dillard LLP, continues to advocate for a 50/50 cost allocation under which each party would bear $11.15 million. ATPC also continues to advocate for an alternative metering station design that it contends would reduce the total interconnection facilities cost, though ATPC has not provided a specific cost estimate for its proposed alternative design.
Correspondence between Calderwood & Harkness LLP and Kellner, Royce & Dillard LLP regarding the Interconnection Agreement continued during the reporting period, with the parties exchanging comments on the metering station specifications and the cost allocation methodology. While progress has been made on certain technical provisions of the agreement, the cost allocation and metering station design issues remain unresolved.
Ridgeline expects the Interconnection Agreement to be finalized in connection with the February 21, 2025 tariff filing. However, Ridgeline acknowledges that if the parties are unable to reach agreement on the cost allocation and metering station design issues prior to the filing date, the Interconnection Agreement may be filed with the contested provisions clearly identified, and the cost allocation dispute may need to be resolved through adjudication in the Track II hearing or through further settlement discussions.
Ridgeline notes that the original target in-service date for the interconnection facilities was the fourth quarter of 2023. This timeline has been delayed pending the resolution of the instant proceeding, and a revised in-service date will be established following Commission action on the redesigned tariff filing.
VI. RIDGELINE'S COMMITMENT TO THE FEBRUARY 21, 2025 FILING DEADLINE
Ridgeline hereby confirms its intent to file the redesigned FERC Gas Tariff, Original Volume No. 1, together with all supplemental pre-filed testimony and supporting exhibits, on or before the February 21, 2025 deadline established by the ALJ's March 4, 2024 Order. Ridgeline takes this commitment seriously and recognizes that the ALJ's grant of a third extension of time was conditioned upon Ridgeline's diligent prosecution of the tariff redesign and its compliance with the quarterly reporting requirements.
As described throughout this Third Quarterly Status Report, the tariff redesign is substantially complete. The fourth draft of the redesigned tariff, dated November 2024, addresses all fourteen deficiency items and incorporates all material revisions to the rate design, GT&Cs, and rate schedules. The remaining work required to bring the tariff and supporting testimony to final form consists of the following discrete tasks:
(a) Finalizing the supplemental pre-filed testimony of Dr. Natasha Orlov and Angela Moretti, including incorporation of final data and completion of supporting schedules;
(b) Completing cross-references and conforming changes within the tariff document to ensure internal consistency among the GT&Cs, rate schedules, and exhibits;
(c) Coordinating with Braswell Energy Consulting Group LLC on the completion of final workpaper exhibits, including the updated DCF proxy group analysis, the load factor analysis, and the detailed cost-of-service schedules; and
(d) Finalizing the Interconnection Agreement with ATPC to the extent possible given the status of the cost allocation negotiations, and preparing the agreement for filing as a FERC rate schedule.
Ridgeline does not anticipate requesting any further extension of time. The remaining work is well within the capacity of Ridgeline's internal team and external advisors to complete within the time remaining before the February 21, 2025 deadline.
In connection with the anticipated filing, Ridgeline respectfully requests that the ALJ, upon receipt of the redesigned tariff filing, lift the stay of the procedural schedule that has been in effect since the ALJ's February 6, 2023 Order and establish a revised Track II hearing schedule for the resumption of proceedings. The resumption of the procedural schedule will enable the intervenors to review the redesigned tariff, prepare responsive testimony, and pursue any remaining settlement discussions in the context of the complete tariff filing.
Ridgeline has separately submitted a letter to ALJ Whitfield, dated November 2024, proposing a procedural schedule for the resumption of the Track II hearing following the anticipated February 21, 2025 filing. The proposed schedule includes deadlines for intervenor answering testimony, rebuttal testimony, a technical conference, and an evidentiary hearing, and contemplates a hearing period beginning in approximately the third or fourth quarter of 2025. Ridgeline recognizes that the ALJ retains full discretion to establish the procedural schedule and will comply with whatever schedule the ALJ determines to be appropriate.
VII. ADDITIONAL INFORMATION
A. Ridgeline Operations Update
Ridgeline reports that the Ridgeline Pipeline System continues to operate safely and reliably. Current throughput on the system is approximately 680 MMcf/d, representing approximately 56.67% of the system's 1.2 Bcf/d design capacity. The system entered commercial service on October 1, 2021. The pipeline construction cost was $587.2 million, and the system comprises 187 miles of 24-inch-diameter high-pressure natural gas pipeline equipped with three compressor stations (Wetzel Station, Mannington Station, and Waynesburg Station) with aggregate installed compression of 45,000 HP.
During the reporting period, Ridgeline completed routine maintenance activities at all three compressor stations and conducted pipeline integrity inspections in accordance with its integrity management program and applicable Department of Transportation Pipeline and Hazardous Materials Safety Administration ("PHMSA") regulations. No significant operational incidents, environmental releases, or safety events occurred during the reporting period. The system's safety and reliability record remains strong since its entry into service.
B. DEH Corporate and Financing Information
DEH, registered at 4th Floor, Harbour Place, 103 South Church Street, George Town, Grand Cayman KY1-1002, Cayman Islands, remains the sole member and 100% equity owner of Ridgeline. Patricia Dunmore continues to serve as Founder and Chairperson of DEH, holding a 72% controlling equity interest in the company. The ownership structure and governance of DEH have not changed since Ridgeline's prior quarterly reports.
DEH's estimated enterprise value is approximately $2.8 billion, based on an internal valuation dated December 31, 2023. DEH's 2023 consolidated annual revenue was approximately $485 million. DEH's portfolio of midstream energy assets includes approximately 1,200 miles of midstream gathering and transportation pipelines, two cryogenic gas processing plants (located in northern West Virginia and southwestern Pennsylvania), and a 250 MW wind portfolio currently under development. The 250 MW wind portfolio is in the pre-construction development phase and is expected to reach commercial operation in stages over the next three to five years.
Ridgeline's senior management team continues unchanged:
• James K. Winfield, Chief Executive Officer & President
• Angela Moretti, Vice President, Finance & Treasurer
• Thomas Greaves, Vice President, Engineering & Operations
• Dr. Natasha Orlov, Director of Rates & Regulatory
C. Financing Status
Ridgeline provides the following update on the status of its outstanding debt obligations:
Senior Secured Credit Facility. Ridgeline's Senior Secured Credit Facility, dated September 15, 2021, remains in good standing. The facility is administered by Pinnacle National Bank, N.A. (Richard Calvert, Managing Director), as administrative agent, and is syndicated among three lenders: Pinnacle National Bank, N.A. (40% participation), Granite Trust Company (30% participation), and Lakeshore Capital Bank (30% participation). The facility consists of a $400 million term loan and a $75 million revolving credit facility, maturing on October 1, 2028. The term loan bears interest at SOFR plus 325 basis points. As of December 31, 2024, the outstanding balance on the term loan is $362.8 million, reflecting scheduled amortization payments since the original funding date. The revolving credit facility remains undrawn as of December 31, 2024.
Second Lien Senior Secured Notes. Ridgeline's $150 million in 7.875% Second Lien Senior Secured Notes due 2030 remain outstanding. The notes are held by Harborview Capital Management LLC (Samantha Hu, Portfolio Manager) and Sentinel Ridge Fund LP (Peter Nowicki, Managing Partner). The notes mature in 2030 and bear a fixed interest rate of 7.875% per annum.
DEH Equity Contribution. DEH's equity contribution to the construction of the Ridgeline Pipeline System was $37.2 million, calculated as the difference between the total pipeline construction cost of $587.2 million and the combined debt financing of $550 million ($400 million term loan plus $150 million second lien notes).
Ridgeline continues to comply with all financial covenants and other obligations under its Senior Secured Credit Facility and Second Lien Senior Secured Notes indenture. All scheduled interest and principal payments have been made on time. Status communications with lenders and noteholders are current, and Ridgeline has kept its lender group and noteholders informed of the status of the FERC proceedings.
VIII. SERVICE LIST AND CONTACT INFORMATION
Counsel for Ridgeline Midstream Services LLC:
Calderwood & Harkness LLP George Trujillo, Responsible Partner Brett Callahan, Lead Associate David Stanton, Working Associate 1601 K Street NW, Suite 900 Washington, DC 20006 Telephone: (202) 555-4800 C&H Matter No. 1016-00005 Billing Partner: Patricia Dunmore (dual role as DEH Founder/Chairperson disclosed and waived by client)
Ridgeline Midstream Services LLC:
James K. Winfield, CEO & President 700 Kanawha Boulevard East, Suite 1400 Charleston, WV 25301 Telephone: (304) 555-7200
Copies of this Third Quarterly Status Report have been served upon all parties on the official service list in Docket Nos. RP22-847-000 and RP22-847-001, including:
Appalachian Trunk Pipeline Company, LLC c/o Sandra K. Fenton, VP Regulatory Affairs 2200 Penn Center West, Suite 300 Pittsburgh, PA 15276
Mountainside Gas Producers Coalition c/o Calvin Dreyer, Executive Director 1100 Main Street, Suite 210 Morgantown, WV 26505
Clearwater Municipal Gas Authority c/o Dennis Ott, General Manager 455 Market Street Clearwater, PA 15330
FERC Trial Staff Jonathan Briggs, Lead Trial Attorney Dr. Miriam Okafor, Lead Economic Analyst 888 First Street NE Washington, DC 20426
IX. CONCLUSION AND REQUEST
WHEREFORE, Ridgeline Midstream Services LLC respectfully requests that the Honorable Administrative Law Judge Clara Whitfield accept this Third Quarterly Status Report as satisfying the quarterly reporting condition imposed by the March 4, 2024 Order granting Ridgeline's third extension of time in Docket Nos. RP22-847-000 and RP22-847-001.
Ridgeline confirms its commitment to filing the redesigned FERC Gas Tariff, Original Volume No. 1, together with all supplemental pre-filed testimony and supporting exhibits, on or before February 21, 2025. The tariff redesign is substantially complete, all fourteen deficiency items identified in the Commission's January 19, 2023 Deficiency Letter have been addressed, and the supplemental testimony of Dr. Natasha Orlov and Angela Moretti is being finalized. Ridgeline does not anticipate requesting any further extension of time.
Ridgeline respectfully requests that, promptly following the filing of the redesigned tariff on or before February 21, 2025, the ALJ schedule a status conference or prehearing conference for the purpose of establishing a revised procedural schedule for the resumption of the Track II hearing in these dockets. A prompt resumption of proceedings will enable the parties to review the complete filing, prepare responsive testimony, and pursue settlement discussions—or, if necessary, proceed to an evidentiary hearing—in a timely manner.
Ridgeline appreciates the ALJ's patience and the cooperation of all parties throughout the tariff redesign process and looks forward to the resumption of active proceedings in these dockets.
Respectfully submitted,
CALDERWOOD & HARKNESS LLP
By: ________
George Trujillo Responsible Partner Calderwood & Harkness LLP 1601 K Street NW, Suite 900 Washington, DC 20006 Telephone: (202) 555-4800
Counsel for Ridgeline Midstream Services LLC C&H Matter No. 1016-00005
Date: December 13, 2024
CERTIFICATE OF SERVICE
I, David Stanton, an associate with Calderwood & Harkness LLP, counsel for Ridgeline Midstream Services LLC, hereby certify that on this 13th day of December, 2024, I caused a true and correct copy of the foregoing Third Quarterly Status Report of Ridgeline Midstream Services LLC to be served upon all parties on the official service list in Docket Nos. RP22-847-000 and RP22-847-001, by first-class mail, postage prepaid, and by electronic mail where electronic mail addresses are available, upon the following:
The Honorable Clara Whitfield Administrative Law Judge Federal Energy Regulatory Commission 888 First Street NE Washington, DC 20426
The Honorable Howard Margolis Settlement Judge Federal Energy Regulatory Commission 888 First Street NE Washington, DC 20426
Jonathan Briggs, Lead Trial Attorney Office of Energy Market Regulation Federal Energy Regulatory Commission 888 First Street NE Washington, DC 20426
Dr. Miriam Okafor, Lead Economic Analyst Office of Energy Market Regulation Federal Energy Regulatory Commission 888 First Street NE Washington, DC 20426
William Pratt, Senior Partner Kellner, Royce & Dillard LLP One PPG Place, Suite 2800 Pittsburgh, PA 15222 Counsel for Appalachian Trunk Pipeline Company, LLC
Sandra K. Fenton Vice President, Regulatory Affairs Appalachian Trunk Pipeline Company, LLC 2200 Penn Center West, Suite 300 Pittsburgh, PA 15276
Rebekah Montague, Partner Whitmore & Sable LLP 1200 New Hampshire Avenue NW, Suite 600 Washington, DC 20036 Counsel for Mountainside Gas Producers Coalition
Calvin Dreyer, Executive Director Mountainside Gas Producers Coalition 1100 Main Street, Suite 210 Morgantown, WV 26505
Stephen Greer, Principal Fordham Municipal Law Group PC 312 Adams Avenue, Suite 100 Scranton, PA 18503 Counsel for Clearwater Municipal Gas Authority
Dennis Ott, General Manager Clearwater Municipal Gas Authority 455 Market Street Clearwater, PA 15330