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UNITED STATES OF AMERICA FEDERAL ENERGY REGULATORY COMMISSION

Docket Nos. RP22-847-000 and RP22-847-001

Ridgeline Midstream Services LLC

FERC Gas Tariff, Original Volume No. 1

MOTION OF RIDGELINE MIDSTREAM SERVICES LLC FOR A 120-DAY EXTENSION OF TIME TO COMPLETE RESPONSE TO DEFICIENCY LETTER

Filed: April 28, 2023

Filed by:

Calderwood & Harkness LLP 1601 K Street NW, Suite 900 Washington, DC 20006

George Trujillo, Responsible Partner Brett Callahan, Lead Associate David Stanton, Working Associate

Counsel for Ridgeline Midstream Services LLC

Filed with:

The Honorable Clara Whitfield Administrative Law Judge Federal Energy Regulatory Commission 888 First Street NE Washington, DC 20426

I. INTRODUCTION AND SUMMARY OF RELIEF REQUESTED

Ridgeline Midstream Services LLC ("Ridgeline" or "Applicant"), by and through its undersigned counsel, Calderwood & Harkness LLP, respectfully moves the Presiding Administrative Law Judge, the Honorable Clara Whitfield, pursuant to 18 C.F.R. § 385.2008, for a 120-day extension of time — from the current deadline to August 28, 2023 — to complete its response to the remaining six deficiency items identified in the Deficiency Letter issued by the Commission's Office of Energy Market Regulation ("OEMR") on January 19, 2023, in the above-captioned proceedings.

As detailed herein, Ridgeline filed a partial response to the Deficiency Letter on March 15, 2023, addressing eight of the fourteen identified deficiencies. Specifically, Ridgeline's March 15 partial response resolved Items 1 through 4 and Items 7 through 10 of the Deficiency Letter. Six items remain outstanding: Items 5, 6, 11, 12, 13, and 14. These remaining items involve substantively complex tariff redesign issues that require extensive coordination with recently engaged expert consultants, stakeholder input from multiple intervenors, and careful analysis of evolving Commission policy in areas where established precedent is limited or nonexistent.

Ridgeline represents to the Presiding Judge that no party will be prejudiced by the requested extension. The procedural schedule in these proceedings has been stayed since February 6, 2023, pursuant to the order of Administrative Law Judge Whitfield, and no hearing dates, testimony deadlines, or other scheduling milestones are currently in effect. Counsel for Ridgeline has communicated with counsel for all intervenors and with FERC Trial Staff, and no party has indicated opposition to the requested 120-day extension.

Good cause exists for the requested extension under 18 C.F.R. § 385.2008. The remaining deficiency items collectively require a comprehensive redesign of substantial portions of Ridgeline's FERC Gas Tariff, Original Volume No. 1, including the General Terms and Conditions and potentially the rate schedules themselves. Several of the remaining items involve novel and rapidly evolving areas of Commission policy — including greenhouse gas emission cost recovery and the implications of FERC Order No. 2222 for natural gas pipeline tariffs — for which no established templates or well-settled precedent exist. Moreover, Ridgeline has recently engaged Braswell Energy Consulting Group LLC to provide comprehensive tariff redesign consulting services, and that engagement was finalized only thirteen days before the filing of this Motion. A reasonable period is necessary for the consulting team to complete its analysis, develop recommendations, and coordinate with Ridgeline's operational, financial, and regulatory personnel and with outside counsel.

The Commission's interest in receiving a comprehensive, well-supported, and internally consistent tariff redesign that fully addresses all fourteen deficiency items will be best served by granting this Motion.

II. BACKGROUND

A. The Applicant and the Ridgeline Pipeline System

Ridgeline Midstream Services LLC is a Delaware limited liability company organized and existing under the laws of the State of Delaware. Ridgeline's sole member is Dunmore Energy Holdings Ltd., a Cayman Islands exempted limited company registered with the Cayman Islands Registry under Registration No. CR-381204. Ridgeline's Employer Identification Number is 87-4231956. Ridgeline maintains its principal office at 700 Kanawha Boulevard East, Suite 1400, Charleston, West Virginia 25301. Ridgeline's registered agent for service of process in Delaware is Capitol Filings Inc., located at 1209 Orange Street, Wilmington, Delaware 19801.

Ridgeline owns and operates the Ridgeline Pipeline System (FERC Code: 960442), which consists of a 187-mile, 24-inch-diameter high-pressure natural gas transmission pipeline extending from the Wetzel County Interconnect in Wetzel County, West Virginia, to the Waynesburg Compressor Station in Greene County, Pennsylvania. The Ridgeline Pipeline System 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 an approximate utilization rate of 56.67 percent of design capacity.

The Ridgeline Pipeline System includes three compressor stations: the Wetzel Station, located at the southern terminus of the pipeline in Wetzel County, West Virginia; the Mannington Station, located in Marion County, West Virginia, approximately midway along the pipeline route; and the Waynesburg Station, located at the northern terminus of the pipeline in Greene County, Pennsylvania. These three compressor stations have an aggregate installed compression capacity of 45,000 horsepower ("HP").

The Ridgeline Pipeline System was placed into service on October 1, 2021. The original construction cost of the system, including all pipeline, compressor station, metering, and ancillary facilities, was approximately $587.2 million.

B. The Filing and Procedural History

The procedural history of these proceedings is set forth in detail below because it bears directly on the good cause showing for the requested extension.

The Original Filing. On May 12, 2022, Ridgeline filed an application with the Commission under Sections 4 and 7 of the Natural Gas Act, 15 U.S.C. §§ 717c and 717f, and pursuant to 18 C.F.R. Parts 154, 157, and 284, seeking: (i) approval of an initial tariff rate for interstate transportation service under Ridgeline's FERC Gas Tariff, Original Volume No. 1; and (ii) authorization for physical interconnection with Appalachian Trunk Pipeline Company, LLC ("ATPC") at the Wetzel County Interconnect, tying into ATPC's existing 30-inch mainline at ATPC Milepost 412.6 in Wetzel County, West Virginia. The application was docketed under Docket No. RP22-847-000 (rate case) and Docket No. RP22-847-001 (interconnection).

Ridgeline's proposed initial recourse rate for firm transportation service was $0.2265 per dekatherm ("Dth"), consisting of a reservation charge of $0.2223/Dth and a usage charge of $0.0042/Dth. The proposed rate was derived on the basis of a rate base of $612.40 million, a total cost of service of $97.36 million, a 100 percent load factor, and design capacity billing determinants of 438,000,000 Dth per year. Ridgeline's proposed return on equity was 14.00 percent, based on a capital structure consisting of 55 percent equity and 45 percent debt, a cost of debt of 5.25 percent, and a resulting weighted average cost of capital ("WACC") of 10.0625 percent. Ridgeline's tariff was filed as a Part 284, Subpart G open-access transportation tariff.

Notice, Intervention, and Protests. On June 14, 2022, the Commission issued a Notice of Filing in these proceedings, establishing an intervention and protest deadline of August 15, 2022.

On July 28, 2022, the Mountainside Gas Producers Coalition ("MGPC") filed a timely motion to intervene and comments. MGPC is an unincorporated association of fourteen independent natural gas producers operating in the Appalachian Basin. The lead contact for MGPC is Calvin Dreyer, Executive Director, located at 1100 Main Street, Suite 210, Morgantown, West Virginia 26505. MGPC is represented by counsel Rebekah Montague of Whitmore & Sable LLP, 1200 New Hampshire Avenue NW, Suite 600, Washington, DC 20036. In its comments, MGPC expressed general support for the proposed interconnection between Ridgeline and ATPC, but opposed Ridgeline's proposed recourse rate as excessive. MGPC advocated a rate ceiling of approximately $0.2560/Dth and indicated that it had retained Dr. Eleanor Vasquez as its rate expert.

On August 1, 2022, the Clearwater Municipal Gas Authority ("CMGA") filed a timely motion to intervene. CMGA is a municipal authority organized under the Pennsylvania Municipality Authorities Act, 53 Pa.C.S. §§ 5601–5623. CMGA's General Manager is Dennis Ott, located at 455 Market Street, Clearwater, Pennsylvania 15330. CMGA is represented by counsel Stephen Greer of Fordham Municipal Law Group PC, 312 Adams Avenue, Suite 100, Scranton, Pennsylvania 18503. CMGA expressed concern regarding the potential for rate increases on the ATPC system resulting from the proposed interconnection and indicated that it supports ATPC's position on cost allocation for the interconnection facilities.

On August 15, 2022, ATPC filed a timely protest and motion to intervene. ATPC is a Pennsylvania limited liability company whose parent entity is Tidewater Infrastructure Partners LP, a Delaware limited partnership controlled by the Alderman family. ATPC's Chief Executive Officer is Marcus R. Alderman, and its Vice President of Regulatory Affairs is Sandra K. Fenton, located at 2200 Penn Center West, Suite 300, Pittsburgh, Pennsylvania 15276. ATPC is represented by counsel William Pratt, Senior Partner, Kellner, Royce & Dillard LLP, One PPG Place, Suite 2800, Pittsburgh, Pennsylvania 15222. In its protest, ATPC argued that Ridgeline's proposed receipt-point metering station design at the Wetzel County Interconnect is inadequate to meet ATPC's operational and safety requirements. ATPC further contended that Ridgeline's cost allocation methodology for the interconnection facilities improperly shifts $14.7 million — representing 65.92 percent of the total $22.3 million interconnection facilities cost — to ATPC and its existing shippers.

Procedural Orders, Testimony, and the Deficiency Letter. On September 22, 2022, the Commission issued an order granting all motions to intervene. The Commission established a Track II procedural schedule for the consolidated proceedings and appointed Settlement Judge Howard Margolis to supervise settlement negotiations among the parties.

On October 17, 2022, Ridgeline filed its answer to the ATPC protest, responding in detail to ATPC's arguments regarding metering station design and interconnection cost allocation.

On November 14, 2022, Administrative Law Judge Clara Whitfield was appointed as Presiding Administrative Law Judge in these proceedings. Judge Whitfield held a prehearing conference on November 14, 2022, at which she established the initial procedural schedule for discovery, testimony, and hearing.

On November 30, 2022, the first settlement conference was held before Settlement Judge Margolis. The parties engaged in productive discussions but did not reach agreement on the principal contested issues.

On December 5, 2022, Ridgeline filed the pre-filed direct testimony and supporting exhibits of seven witnesses: James K. Winfield, Chief Executive Officer; Angela Moretti, Vice President of Finance and Treasurer; Thomas Greaves, Vice President of Engineering and Operations; Dr. Natasha Orlov, Director of Rates and Regulatory; Dr. Raymond Braswell (independent rate and economic consultant); and two additional sponsoring witnesses addressing specific aspects of the rate design, cost allocation, and engineering issues in the proceeding.

On January 9, 2023, ATPC, MGPC, and CMGA filed their respective answering testimony and supporting exhibits, responding to Ridgeline's direct case.

On January 19, 2023, the FERC Office of Energy Market Regulation issued a Deficiency Letter identifying fourteen specific deficiencies in Ridgeline's FERC Gas Tariff, Original Volume No. 1 filing. The Deficiency Letter was prepared under the direction of Dr. Miriam Okafor, Lead Economic Analyst, and coordinated with Jonathan Briggs, Lead Trial Attorney in the Office of General Counsel assigned to these proceedings. The Deficiency Letter required Ridgeline to address each identified deficiency and supplement or revise its tariff filing accordingly.

On February 6, 2023, Administrative Law Judge Whitfield issued an order staying the procedural schedule in these proceedings pending Ridgeline's complete response to the Deficiency Letter. Judge Whitfield directed Ridgeline to file a response as expeditiously as practicable and to inform the Presiding Judge of any need for additional time.

On March 8, 2023, the second settlement conference was held before Settlement Judge Margolis. The parties continued settlement discussions but were unable to resolve the outstanding issues. The gap between Ridgeline's position and the position of ATPC and MGPC on the recourse rate remains approximately $0.058/Dth.

Ridgeline's Partial Response. On March 15, 2023, Ridgeline filed a partial response to the Deficiency Letter, addressing eight of the fourteen identified deficiency items. Specifically, the partial response resolved the following items:

• Item 1: Updated return on equity support, including revised discounted cash flow and capital asset pricing model analyses.

• Item 2: Fuel, lost and unaccounted-for gas ("FL&U") tracker overview and proposed tariff provisions.

• Item 3: Interruptible transportation ("IT") rate derivation framework.

• Item 4: Load factor justification, including supporting throughput analysis and shipper survey data.

• Item 7: Electronic Bulletin Board ("EBB") design and requirements, including compliance with 18 C.F.R. § 284.12.

• Item 8: Shipper-must-have-title provisions consistent with Order No. 712.

• Item 9: Interconnection agreement filing as a rate schedule under Section 4 of the Natural Gas Act.

• Item 10: Penalty revenue crediting mechanism, including provisions for distribution of penalty revenues to non-offending shippers.

Six deficiency items remain outstanding: Items 5, 6, 11, 12, 13, and 14. This Motion addresses those remaining items and requests additional time to complete the response.

III. THE REMAINING SIX DEFICIENCY ITEMS AND THE COMPLEXITY OF THE REQUIRED TARIFF REDESIGN

Six deficiency items identified in the January 19, 2023 Deficiency Letter remain unaddressed and require substantial tariff redesign work. The complexity and interrelationship of these items are the principal basis for the requested 120-day extension. Each remaining item is described below, together with an explanation of the work required and the specific reasons that additional time is necessary.

A. Deficiency Item 5 — Capacity Release Provisions

The Deficiency Letter identified the absence of capacity release provisions in the General Terms and Conditions of Ridgeline's FERC Gas Tariff, Original Volume No. 1. Under Commission policy and the requirements of 18 C.F.R. Part 284, pipelines offering firm transportation service under an open-access tariff are required to include comprehensive provisions governing the release of firm capacity by shippers to replacement shippers.

To address this deficiency, Ridgeline must develop a complete set of capacity release provisions that are consistent with Commission policy as set forth in the Part 284 regulations and in relevant Commission orders addressing capacity release mechanics. These provisions must address, at a minimum, the following subjects: (i) the right of firm shippers to release all or a portion of their capacity on a permanent or temporary basis; (ii) pre-arranged deal requirements, including the distinction between pre-arranged and non-pre-arranged releases; (iii) bidding procedures for non-pre-arranged releases, including minimum bid requirements and evaluation criteria; (iv) recall rights and the conditions under which a releasing shipper may recall released capacity; (v) posting requirements on Ridgeline's Electronic Bulletin Board, including the duration and content of postings; and (vi) the relationship between capacity release provisions and the shipper-must-have-title provisions addressed in Ridgeline's partial response (Item 8).

The development of capacity release provisions requires careful coordination with the EBB design addressed in Item 7 of the partial response and with the NAESB compliance issues identified in Item 6 of the Deficiency Letter, which is itself one of the remaining outstanding items. Because capacity release transactions are nominated, confirmed, and scheduled through the pipeline's EBB in accordance with NAESB standards, these three areas of the tariff must be developed in an integrated fashion to ensure internal consistency and operational functionality.

B. Deficiency Item 6 — NAESB Standards Compliance in Operational Flow Order Provisions

The Deficiency Letter found that Ridgeline's tariff provisions governing operational flow orders and related operational procedures are incompletely compliant with the North American Energy Standards Board ("NAESB") Wholesale Gas Quadrant ("WGQ") Version 3.2 standards. The Commission requires interstate natural gas pipelines to incorporate NAESB WGQ standards by reference in their tariffs and to ensure that their operational procedures are consistent with those standards.

To address this deficiency, Ridgeline must undertake a full and detailed gap analysis comparing all existing tariff provisions against the applicable WGQ Version 3.2 standards. This gap analysis encompasses the full range of operational procedures addressed by the NAESB standards, including but not limited to: nominations and scheduling; confirmations; intraday nominations; imbalance management and cashout procedures; operational flow orders, including critical, non-critical, and extraordinary operational flow orders; force majeure provisions; and system-wide and point-specific operational notices.

This is a technically intensive exercise that requires specialized consulting support. The NAESB WGQ Version 3.2 standards are detailed and comprehensive, and ensuring complete compliance requires a line-by-line comparison of the tariff's operational provisions against the applicable standards, followed by redrafting of each non-compliant provision. The engagement of Braswell Energy Consulting Group LLC, discussed in Section IV below, was motivated in significant part by the need for expert support in completing this gap analysis and preparing compliant tariff provisions.

In addition, as noted above, the NAESB compliance analysis for operational flow order provisions must be coordinated with the development of capacity release provisions (Item 5) and segmentation and flexible receipt/delivery point provisions (Item 12), because all of these areas of the tariff interact with the pipeline's nomination, confirmation, and scheduling procedures.

C. Deficiency Item 11 — Creditworthiness Provisions

The Deficiency Letter identified inadequate creditworthiness provisions in Ridgeline's FERC Gas Tariff, Original Volume No. 1. The Commission requires that pipeline tariffs include provisions establishing clear and nondiscriminatory standards for evaluating the creditworthiness of shippers requesting transportation service.

To address this deficiency, Ridgeline must develop comprehensive creditworthiness requirements consistent with Commission policy, including the following elements: (i) unsecured credit limits based on objective financial criteria; (ii) credit rating thresholds tied to investment-grade ratings from nationally recognized statistical rating organizations; (iii) collateral posting requirements for shippers that do not satisfy the pipeline's creditworthiness standards, including acceptable forms of collateral such as irrevocable standby letters of credit, parent company guarantees, and cash deposits; (iv) procedures for ongoing monitoring of shipper creditworthiness and for addressing material adverse changes in a shipper's financial condition; (v) cure periods and dispute resolution procedures for shippers whose creditworthiness is questioned; and (vi) nondiscrimination provisions ensuring that creditworthiness standards are applied on a uniform and transparent basis to all similarly situated shippers.

The development of creditworthiness provisions requires coordination with Ridgeline's existing financing arrangements. Ridgeline's capital structure includes a Senior Secured Credit Facility with Pinnacle National Bank, N.A., as administrative agent, and a lending syndicate that includes Granite Trust Company and Lakeshore Capital Bank. The Senior Secured Credit Facility consists of a $400 million term loan and a $75 million revolving credit facility, bearing interest at SOFR plus 325 basis points, and maturing on October 1, 2028. As of the date of this filing, the outstanding balance under the Senior Secured Credit Facility is approximately $375 million. In addition, Ridgeline has outstanding $150 million in aggregate principal amount of 7.875% Second Lien Senior Secured Notes due 2030, currently held by Harborview Capital Management LLC and Sentinel Ridge Fund LP.

Both the Senior Secured Credit Facility and the Second Lien Senior Secured Notes contain covenants and provisions related to shipper credit exposure, including requirements regarding the pipeline's credit policies and limitations on unsecured credit exposure to individual shippers. The tariff's creditworthiness provisions must be developed with careful attention to these existing contractual obligations to ensure that the tariff provisions are consistent with and do not create conflicts with the pipeline's financing documents. Ridgeline anticipates that coordination with its lenders and noteholders may be required during the development of these provisions, which adds additional time to the process.

D. Deficiency Item 12 — Segmentation and Flexible Receipt/Delivery Point Provisions

The Deficiency Letter required Ridgeline's tariff to include provisions for the segmentation of firm transportation capacity and for flexible receipt and delivery point arrangements. Commission policy favors the inclusion of such provisions in pipeline tariffs because they promote efficient use of pipeline capacity and enhance competition in the transportation marketplace.

Addressing this deficiency involves two related but distinct components. First, Ridgeline must evaluate the engineering feasibility of offering segmented firm transportation service on the Ridgeline Pipeline System. This evaluation requires a detailed analysis of the system's three compressor stations — the Wetzel Station, the Mannington Station, and the Waynesburg Station — and the hydraulic characteristics of each pipeline segment between compression points. The analysis must determine whether the system can accommodate segmented service without adversely affecting the operational integrity of the pipeline or the service provided to existing shippers.

Second, Ridgeline must draft tariff provisions governing the nomination of alternative receipt and delivery points, including provisions specifying the conditions under which a shipper may request a change to its primary receipt or delivery point, the pipeline's obligations to accommodate such requests on a not-unduly-discriminatory basis, and the pricing and operational consequences of alternative receipt and delivery point nominations.

In developing these provisions, particular attention must be given to the characteristics of the Ridgeline Pipeline System's principal receipt and delivery points. The primary receipt point is the Wetzel County Interconnect in Wetzel County, West Virginia, located at Ridgeline milepost 0.0 and connecting with ATPC's 30-inch mainline at ATPC Milepost 412.6. The primary delivery point is the Waynesburg Compressor Station in Greene County, Pennsylvania, located at the northern terminus of the pipeline. The segmentation and flexible point provisions must be consistent with the physical and contractual arrangements at these interconnection and delivery points, and must be coordinated with the capacity release (Item 5) and NAESB compliance (Item 6) provisions.

E. Deficiency Item 13 — Greenhouse Gas Emission Cost Recovery Provisions

The Deficiency Letter required Ridgeline to address provisions for the recovery of greenhouse gas ("GHG") emission costs in its tariff. This is a novel and rapidly evolving area of Commission policy. No established FERC template exists for GHG cost recovery provisions in a natural gas pipeline tariff, and the Commission's expectations regarding the form and content of such provisions continue to develop.

To address this deficiency, Ridgeline must undertake several analytically demanding tasks. First, Ridgeline must analyze the state-level GHG regulations currently applicable to pipeline operations in West Virginia and Pennsylvania, including any existing or proposed requirements for emissions monitoring, reporting, and reduction. Second, Ridgeline must assess potential federal regulatory developments that may affect GHG cost obligations for natural gas pipeline operators in the near and medium term. Third, based on this regulatory analysis, Ridgeline must draft tariff language establishing a GHG cost tracker and passthrough mechanism that would permit Ridgeline to recover prudently incurred GHG compliance costs from its shippers on a fair and equitable basis.

The absence of well-settled Commission precedent in this area means that Ridgeline's response will necessarily involve original policy analysis and creative tariff drafting. Ridgeline is aware that several other pipeline operators have begun to address GHG cost recovery in their tariff filings, but the Commission's orders in those proceedings have not yet established a clear or uniform framework. Ridgeline intends to review available precedent and develop provisions that are both responsive to the Deficiency Letter and consistent with emerging Commission expectations.

F. Deficiency Item 14 — FERC Order No. 2222 and Distributed Energy Resource Aggregation / Renewable Energy Interconnection

The Deficiency Letter required Ridgeline to address the implications of FERC Order No. 2222, which establishes requirements for the participation of distributed energy resource ("DER") aggregations in the organized wholesale electricity markets operated by regional transmission organizations and independent system operators, for Ridgeline's natural gas pipeline tariff.

Although Order No. 2222 was directed primarily at the electric industry, the Commission has signaled increasing interest in how midstream natural gas pipeline operators address renewable energy integration and the potential effects of DER aggregation on natural gas demand and pipeline utilization. This item has particular relevance to Ridgeline because Ridgeline's sole member, Dunmore Energy Holdings Ltd., has a 250-megawatt wind energy portfolio under development. The Commission's interest in the intersection of natural gas pipeline operations and renewable energy development adds a layer of policy complexity to this deficiency item that requires careful and thorough analysis.

Addressing this deficiency requires extensive legal research on the applicability of Order No. 2222 to natural gas pipeline tariffs, an area of Commission policy that is rapidly evolving and for which limited direct precedent exists. Ridgeline must analyze whether and to what extent Order No. 2222's requirements apply to or have implications for the tariff provisions governing transportation service on the Ridgeline Pipeline System, and must develop appropriate tariff provisions that are responsive to the Commission's concerns while remaining operationally feasible and legally sound.

G. Overall Complexity and Need for Comprehensive Redesign

Taken together, the six remaining deficiency items require a comprehensive redesign of substantial portions of Ridgeline's FERC Gas Tariff, Original Volume No. 1, including the General Terms and Conditions and potentially the rate schedules themselves. The scope of the required work is significantly greater than what would be involved in addressing individual, discrete tariff deficiencies.

As described above, Items 5, 6, and 12 are closely interrelated. Capacity release provisions (Item 5), NAESB compliance in operational flow order provisions (Item 6), and segmentation and flexible receipt/delivery point provisions (Item 12) all affect the pipeline's nomination, confirmation, scheduling, and operational flow procedures. These provisions must be developed in an integrated fashion to ensure internal consistency and to avoid creating operational conflicts or ambiguities in the tariff.

Items 13 and 14, addressing GHG cost recovery and Order No. 2222 implications, involve novel regulatory policy areas with limited precedent. The analysis and drafting required for these items cannot be performed on a purely mechanical basis but rather require substantive policy judgments and creative tariff design.

Item 11, addressing creditworthiness provisions, requires coordination with Ridgeline's existing financing arrangements and potentially with Ridgeline's lenders and noteholders, which introduces additional time and complexity.

The interrelationship and collective complexity of these six items is the primary reason that Ridgeline has engaged expert consulting support and requires additional time to complete a comprehensive and well-integrated response.

IV. ENGAGEMENT OF BRASWELL ENERGY CONSULTING GROUP LLC

On April 15, 2023, Dunmore Energy Holdings Ltd., as Ridgeline's sole member, engaged Braswell Energy Consulting Group LLC ("Braswell") to provide comprehensive tariff redesign consulting services in connection with Ridgeline's response to the remaining deficiency items. Braswell is a Virginia limited liability company with offices at 8300 Greensboro Drive, Suite 450, McLean, Virginia 22102. The engagement is identified as Braswell Engagement No. BEC-2023-0041.

Dr. Raymond Braswell, the founder and managing principal of Braswell Energy Consulting Group, is directing the tariff redesign effort. Dr. Braswell is a former FERC economist with more than twenty-five years of experience in natural gas pipeline rate design, tariff development, and regulatory policy. Ridgeline notes that Dr. Braswell previously filed pre-filed direct testimony on Ridgeline's behalf on December 5, 2022, in these proceedings, addressing return on equity and capital structure issues. Dr. Braswell's current engagement as tariff redesign consultant is a separate and subsequent engagement from his earlier role as a testifying expert, and encompasses a broader scope of work directed at the comprehensive redesign of the tariff to address all fourteen deficiency items.

The scope of Braswell's engagement includes a full revision of the FERC Gas Tariff, Original Volume No. 1, to address all fourteen deficiency items identified in the January 19, 2023 Deficiency Letter, with particular focus on the six outstanding items (Items 5, 6, 11, 12, 13, and 14). The engagement contemplates that Braswell will perform detailed technical and policy analysis, develop draft tariff provisions, and coordinate closely with Ridgeline's operational and regulatory staff — including Dr. Natasha Orlov, Director of Rates and Regulatory, and Thomas Greaves, Vice President of Engineering and Operations — as well as with Calderwood & Harkness LLP as outside counsel.

The engagement of Braswell was finalized only thirteen days before the filing of this Motion. Given the breadth and complexity of the remaining deficiency items, Braswell requires a reasonable period to familiarize itself with the full record in these proceedings, perform the required technical and policy analyses, develop recommendations and draft tariff provisions, and coordinate the iterative review and refinement process with Ridgeline's internal teams and outside counsel. Ridgeline respectfully submits that the 120-day extension requested herein is the minimum period reasonably necessary to permit Braswell to complete this work in a thorough and professional manner.

V. PROPOSED TIMELINE

Current Status. The procedural schedule in Docket Nos. RP22-847-000 and RP22-847-001 has been stayed since February 6, 2023, pursuant to the order of Administrative Law Judge Whitfield. No hearing dates, testimony deadlines, discovery cut-off dates, or other scheduling milestones are currently in effect. The stay was entered specifically to permit Ridgeline to complete its response to the Deficiency Letter, and the Presiding Judge directed Ridgeline to inform the bench of any need for additional time.

Requested Extension. Ridgeline respectfully requests a 120-day extension from the date of this Motion, April 28, 2023, establishing a new deadline of August 28, 2023, for the filing of a complete response to all remaining deficiency items (Items 5, 6, 11, 12, 13, and 14).

Proposed Milestones. Ridgeline proposes the following internal milestones during the extension period to ensure that the work progresses in an orderly and timely fashion:

May through June 2023: Braswell Energy Consulting Group will complete its initial gap analysis of the existing tariff provisions and will develop draft tariff provisions addressing Deficiency Items 5 (capacity release), 6 (NAESB standards compliance), 11 (creditworthiness), and 12 (segmentation and flexible receipt/delivery points). This phase will include the detailed NAESB WGQ Version 3.2 gap analysis, engineering analysis of segmentation feasibility across the Ridgeline Pipeline System's three compressor stations, and coordination with Ridgeline's lenders regarding creditworthiness provisions.

June through July 2023: Braswell and Calderwood & Harkness LLP will develop draft tariff provisions addressing Deficiency Items 13 (GHG emission cost recovery) and 14 (Order No. 2222 and DER aggregation / renewable energy interconnection). This phase will involve regulatory policy research, analysis of state-level GHG regulations in West Virginia and Pennsylvania, assessment of emerging federal regulatory developments, and development of novel tariff provisions for which limited precedent exists.

July through August 2023: All draft provisions will be integrated into a revised FERC Gas Tariff, Original Volume No. 1. Ridgeline's internal review process will be conducted, including review by the CEO, VP Finance, VP Engineering & Operations, Director of Rates & Regulatory, and outside counsel. The complete supplemental response will be finalized for filing.

August 28, 2023: Ridgeline will file its complete supplemental response addressing Items 5, 6, 11, 12, 13, and 14 of the Deficiency Letter, together with revised tariff sheets and any necessary supporting testimony or exhibits.

Settlement Conference. Ridgeline notes that a third settlement conference before Settlement Judge Howard Margolis is anticipated for approximately July 12, 2023. The ongoing settlement discussions may inform the tariff redesign, particularly with respect to rate design and cost allocation issues, and the revised tariff provisions under development may in turn facilitate narrowing of the settlement gap between the parties. Ridgeline will keep all parties and the Presiding Judge informed of developments.

VI. GOOD CAUSE FOR THE EXTENSION

The standard for extensions of time under Rule 2008 of the Commission's Rules of Practice and Procedure, 18 C.F.R. § 385.2008, requires a showing of good cause. Good cause exists in this case for several independent and mutually reinforcing reasons.

First, the remaining deficiency items involve technically and legally complex tariff design issues. As described in Section III above, the six outstanding items require Ridgeline to develop comprehensive tariff provisions addressing capacity release mechanics, NAESB WGQ Version 3.2 compliance, creditworthiness standards, segmentation and flexible point service, GHG emission cost recovery, and the implications of FERC Order No. 2222. Several of these areas — particularly GHG cost recovery and Order No. 2222 — involve novel areas of Commission policy for which no established templates or well-settled precedent exist. The analysis and drafting required for these items cannot be completed responsibly in a compressed timeframe.

Second, Ridgeline has recently engaged a consulting expert whose work is essential to the tariff redesign. Braswell Energy Consulting Group LLC was engaged on April 15, 2023 — only thirteen days before the filing of this Motion. The engagement was necessitated by the breadth and complexity of the remaining deficiency items, which collectively require a comprehensive redesign of substantial portions of the FERC Gas Tariff, Original Volume No. 1. It would be unreasonable to expect Braswell to complete this work without a reasonable period for analysis, development of draft provisions, and coordination with Ridgeline's internal staff and outside counsel. The 120-day extension requested herein is the minimum period necessary to permit a thorough and professional effort.

Third, the remaining items are interrelated and must be developed in an integrated fashion. Items 5, 6, and 12 — capacity release, NAESB compliance, and segmentation — all affect the pipeline's nomination, confirmation, scheduling, and operational flow procedures. Developing these provisions in isolation would risk creating internal inconsistencies and operational conflicts within the tariff. A comprehensive, integrated approach is necessary, and that approach requires adequate time.

Fourth, no party will be prejudiced by the requested extension. The procedural schedule in these proceedings has been stayed since February 6, 2023, pursuant to Judge Whitfield's order. No hearing dates, testimony deadlines, or other scheduling milestones are currently set. The extension will not delay any proceedings that are currently underway and will not prejudice any intervenor or FERC Trial Staff. As discussed in Section VII below, counsel for Ridgeline has communicated with counsel for all parties, and no party has indicated opposition to the extension.

Fifth, ongoing settlement efforts may benefit from the additional time. Settlement discussions among the parties continue under the supervision of Settlement Judge Margolis, and a third settlement conference is anticipated for approximately July 2023. The current settlement gap between Ridgeline's position and the ATPC/MGPC position is approximately $0.058/Dth. The tariff redesign now underway may facilitate narrowing of this gap by addressing operational and tariff design issues that have been identified as impediments to settlement. Granting the extension will permit the tariff redesign and settlement discussions to proceed in parallel, potentially promoting a more efficient resolution of these proceedings.

Sixth, the Commission's interest is best served by a complete and well-supported filing. The Commission has a strong interest in receiving tariff filings that are comprehensive, internally consistent, and fully compliant with applicable regulatory requirements. A piecemeal or incomplete response to the Deficiency Letter would not serve that interest and would likely require further deficiency proceedings, resulting in additional delay and inefficiency. Granting the requested 120-day extension will permit Ridgeline to file a complete supplemental response that fully addresses all fourteen deficiency items and presents the Commission with a revised tariff that meets the highest standards of quality and completeness.

For all of these reasons, Ridgeline respectfully submits that good cause exists for the requested 120-day extension under 18 C.F.R. § 385.2008.

VII. NO PARTY HAS INDICATED OPPOSITION

Consistent with its obligations of professional courtesy and its commitment to cooperative engagement with all parties in these proceedings, counsel for Ridgeline, Calderwood & Harkness LLP, has communicated with counsel for each intervenor and with FERC Trial Staff regarding this Motion. Specifically, Ridgeline's counsel has conferred with the following:

• William Pratt, Senior Partner, Kellner, Royce & Dillard LLP, counsel for Appalachian Trunk Pipeline Company, LLC;

• Rebekah Montague, Whitmore & Sable LLP, counsel for Mountainside Gas Producers Coalition;

• Stephen Greer, Fordham Municipal Law Group PC, counsel for Clearwater Municipal Gas Authority; and

• Jonathan Briggs, Lead Trial Attorney, Office of General Counsel, Federal Energy Regulatory Commission, FERC Trial Staff.

No party has indicated opposition to the requested 120-day extension. Ridgeline acknowledges that the absence of opposition does not relieve the Applicant of its burden to demonstrate good cause, and Ridgeline has endeavored to make that showing fully in Section VI above. The absence of opposition does, however, confirm that the extension will not cause prejudice to any party and supports the conclusion that the requested extension is reasonable and appropriate under the circumstances.

Ridgeline will continue to cooperate with all parties throughout the extension period and will provide updates on the progress of the tariff redesign as appropriate. Ridgeline remains committed to completing its response to the Deficiency Letter as expeditiously as practicable and to working constructively with all parties and with the Commission's staff toward a resolution of the outstanding issues in these proceedings.

VIII. CONCLUSION AND PRAYER FOR RELIEF

WHEREFORE, for the reasons set forth above, Ridgeline Midstream Services LLC respectfully requests that Administrative Law Judge Clara Whitfield grant this Motion and enter an order:

1. Extending the deadline for Ridgeline Midstream Services LLC to file a complete response to the remaining deficiency items (Items 5, 6, 11, 12, 13, and 14) identified in the January 19, 2023 Deficiency Letter issued by the Commission's Office of Energy Market Regulation to August 28, 2023 (120 days from the date of this Motion);

2. Continuing the stay of the procedural schedule in Docket Nos. RP22-847-000 and RP22-847-001 pending Ridgeline's filing of its complete response to the Deficiency Letter; and

3. Granting such other and further relief as the Presiding Judge deems just and appropriate.

Respectfully submitted,

CALDERWOOD & HARKNESS LLP

By: ________

George Trujillo, Responsible Partner

Brett Callahan, Lead Associate David Stanton, Working Associate

1601 K Street NW, Suite 900 Washington, DC 20006 Telephone: (202) 555-4200 Facsimile: (202) 555-4201

Counsel for Ridgeline Midstream Services LLC

Dated: April 28, 2023

CERTIFICATE OF SERVICE

I hereby certify that on April 28, 2023, a true and correct copy of the foregoing Motion of Ridgeline Midstream Services LLC for a 120-Day Extension of Time to Complete Response to Deficiency Letter was served upon all parties on the official service list maintained by the Secretary of the Federal Energy Regulatory Commission in Docket Nos. RP22-847-000 and RP22-847-001, by electronic mail and first-class United States mail, postage prepaid, addressed as follows:

Secretary Federal Energy Regulatory Commission 888 First Street NE Washington, DC 20426

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 General Counsel 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

Rebekah Montague Whitmore & Sable LLP 1200 New Hampshire Avenue NW, Suite 600 Washington, DC 20036 Counsel for Mountainside Gas Producers Coalition

Stephen Greer Fordham Municipal Law Group PC 312 Adams Avenue, Suite 100 Scranton, PA 18503 Counsel for Clearwater Municipal Gas Authority

Sandra K. Fenton Vice President, Regulatory Affairs Appalachian Trunk Pipeline Company, LLC 2200 Penn Center West, Suite 300 Pittsburgh, PA 15276

Calvin Dreyer Executive Director Mountainside Gas Producers Coalition 1100 Main Street, Suite 210 Morgantown, WV 26505

Dennis Ott General Manager Clearwater Municipal Gas Authority 455 Market Street Clearwater, PA 15330

________________________________________

David Stanton Calderwood & Harkness LLP 1601 K Street NW, Suite 900 Washington, DC 20006

Dated: April 28, 2023

UNITED STATES OF AMERICA FEDERAL ENERGY REGULATORY COMMISSION
Docket Nos. RP22-847-000 and RP22-847-001
Ridgeline Midstream Services LLC
FERC Gas Tariff, Original Volume No. 1
MOTION OF RIDGELINE MIDSTREAM SERVICES LLC FOR A 120-DAY EXTENSION OF TIME TO COMPLETE RESPONSE TO DEFICIENCY LETTER
Filed: April 28, 2023
Filed by:
Calderwood & Harkness LLP 1601 K Street NW, Suite 900 Washington, DC 20006
George Trujillo, Responsible Partner Brett Callahan, Lead Associate David Stanton, Working Associate
Counsel for Ridgeline Midstream Services LLC
Filed with:
The Honorable Clara Whitfield Administrative Law Judge Federal Energy Regulatory Commission 888 First Street NE Washington, DC 20426
I. INTRODUCTION AND SUMMARY OF RELIEF REQUESTED
Ridgeline Midstream Services LLC ("Ridgeline" or "Applicant"), by and through its undersigned counsel, Calderwood & Harkness LLP, respectfully moves the Presiding Administrative Law Judge, the Honorable Clara Whitfield, pursuant to 18 C.F.R. § 385.2008, for a 120-day extension of time — from the current deadline to August 28, 2023 — to complete its response to the remaining six deficiency items identified in the Deficiency Letter issued by the Commission's Office of Energy Market Regulation ("OEMR") on January 19, 2023, in the above-captioned proceedings.
As detailed herein, Ridgeline filed a partial response to the Deficiency Letter on March 15, 2023, addressing eight of the fourteen identified deficiencies. Specifically, Ridgeline's March 15 partial response resolved Items 1 through 4 and Items 7 through 10 of the Deficiency Letter. Six items remain outstanding: Items 5, 6, 11, 12, 13, and 14. These remaining items involve substantively complex tariff redesign issues that require extensive coordination with recently engaged expert consultants, stakeholder input from multiple intervenors, and careful analysis of evolving Commission policy in areas where established precedent is limited or nonexistent.
Ridgeline represents to the Presiding Judge that no party will be prejudiced by the requested extension. The procedural schedule in these proceedings has been stayed since February 6, 2023, pursuant to the order of Administrative Law Judge Whitfield, and no hearing dates, testimony deadlines, or other scheduling milestones are currently in effect. Counsel for Ridgeline has communicated with counsel for all intervenors and with FERC Trial Staff, and no party has indicated opposition to the requested 120-day extension.
Good cause exists for the requested extension under 18 C.F.R. § 385.2008. The remaining deficiency items collectively require a comprehensive redesign of substantial portions of Ridgeline's FERC Gas Tariff, Original Volume No. 1, including the General Terms and Conditions and potentially the rate schedules themselves. Several of the remaining items involve novel and rapidly evolving areas of Commission policy — including greenhouse gas emission cost recovery and the implications of FERC Order No. 2222 for natural gas pipeline tariffs — for which no established templates or well-settled precedent exist. Moreover, Ridgeline has recently engaged Braswell Energy Consulting Group LLC to provide comprehensive tariff redesign consulting services, and that engagement was finalized only thirteen days before the filing of this Motion. A reasonable period is necessary for the consulting team to complete its analysis, develop recommendations, and coordinate with Ridgeline's operational, financial, and regulatory personnel and with outside counsel.
The Commission's interest in receiving a comprehensive, well-supported, and internally consistent tariff redesign that fully addresses all fourteen deficiency items will be best served by granting this Motion.
II. BACKGROUND
A. The Applicant and the Ridgeline Pipeline System
Ridgeline Midstream Services LLC is a Delaware limited liability company organized and existing under the laws of the State of Delaware. Ridgeline's sole member is Dunmore Energy Holdings Ltd., a Cayman Islands exempted limited company registered with the Cayman Islands Registry under Registration No. CR-381204. Ridgeline's Employer Identification Number is 87-4231956. Ridgeline maintains its principal office at 700 Kanawha Boulevard East, Suite 1400, Charleston, West Virginia 25301. Ridgeline's registered agent for service of process in Delaware is Capitol Filings Inc., located at 1209 Orange Street, Wilmington, Delaware 19801.
Ridgeline owns and operates the Ridgeline Pipeline System (FERC Code: 960442), which consists of a 187-mile, 24-inch-diameter high-pressure natural gas transmission pipeline extending from the Wetzel County Interconnect in Wetzel County, West Virginia, to the Waynesburg Compressor Station in Greene County, Pennsylvania. The Ridgeline Pipeline System 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 an approximate utilization rate of 56.67 percent of design capacity.
The Ridgeline Pipeline System includes three compressor stations: the Wetzel Station, located at the southern terminus of the pipeline in Wetzel County, West Virginia; the Mannington Station, located in Marion County, West Virginia, approximately midway along the pipeline route; and the Waynesburg Station, located at the northern terminus of the pipeline in Greene County, Pennsylvania. These three compressor stations have an aggregate installed compression capacity of 45,000 horsepower ("HP").
The Ridgeline Pipeline System was placed into service on October 1, 2021. The original construction cost of the system, including all pipeline, compressor station, metering, and ancillary facilities, was approximately $587.2 million.
B. The Filing and Procedural History
The procedural history of these proceedings is set forth in detail below because it bears directly on the good cause showing for the requested extension.
The Original Filing. On May 12, 2022, Ridgeline filed an application with the Commission under Sections 4 and 7 of the Natural Gas Act, 15 U.S.C. §§ 717c and 717f, and pursuant to 18 C.F.R. Parts 154, 157, and 284, seeking: (i) approval of an initial tariff rate for interstate transportation service under Ridgeline's FERC Gas Tariff, Original Volume No. 1; and (ii) authorization for physical interconnection with Appalachian Trunk Pipeline Company, LLC ("ATPC") at the Wetzel County Interconnect, tying into ATPC's existing 30-inch mainline at ATPC Milepost 412.6 in Wetzel County, West Virginia. The application was docketed under Docket No. RP22-847-000 (rate case) and Docket No. RP22-847-001 (interconnection).
Ridgeline's proposed initial recourse rate for firm transportation service was $0.2265 per dekatherm ("Dth"), consisting of a reservation charge of $0.2223/Dth and a usage charge of $0.0042/Dth. The proposed rate was derived on the basis of a rate base of $612.40 million, a total cost of service of $97.36 million, a 100 percent load factor, and design capacity billing determinants of 438,000,000 Dth per year. Ridgeline's proposed return on equity was 14.00 percent, based on a capital structure consisting of 55 percent equity and 45 percent debt, a cost of debt of 5.25 percent, and a resulting weighted average cost of capital ("WACC") of 10.0625 percent. Ridgeline's tariff was filed as a Part 284, Subpart G open-access transportation tariff.
Notice, Intervention, and Protests. On June 14, 2022, the Commission issued a Notice of Filing in these proceedings, establishing an intervention and protest deadline of August 15, 2022.
On July 28, 2022, the Mountainside Gas Producers Coalition ("MGPC") filed a timely motion to intervene and comments. MGPC is an unincorporated association of fourteen independent natural gas producers operating in the Appalachian Basin. The lead contact for MGPC is Calvin Dreyer, Executive Director, located at 1100 Main Street, Suite 210, Morgantown, West Virginia 26505. MGPC is represented by counsel Rebekah Montague of Whitmore & Sable LLP, 1200 New Hampshire Avenue NW, Suite 600, Washington, DC 20036. In its comments, MGPC expressed general support for the proposed interconnection between Ridgeline and ATPC, but opposed Ridgeline's proposed recourse rate as excessive. MGPC advocated a rate ceiling of approximately $0.2560/Dth and indicated that it had retained Dr. Eleanor Vasquez as its rate expert.
On August 1, 2022, the Clearwater Municipal Gas Authority ("CMGA") filed a timely motion to intervene. CMGA is a municipal authority organized under the Pennsylvania Municipality Authorities Act, 53 Pa.C.S. §§ 5601–5623. CMGA's General Manager is Dennis Ott, located at 455 Market Street, Clearwater, Pennsylvania 15330. CMGA is represented by counsel Stephen Greer of Fordham Municipal Law Group PC, 312 Adams Avenue, Suite 100, Scranton, Pennsylvania 18503. CMGA expressed concern regarding the potential for rate increases on the ATPC system resulting from the proposed interconnection and indicated that it supports ATPC's position on cost allocation for the interconnection facilities.
On August 15, 2022, ATPC filed a timely protest and motion to intervene. ATPC is a Pennsylvania limited liability company whose parent entity is Tidewater Infrastructure Partners LP, a Delaware limited partnership controlled by the Alderman family. ATPC's Chief Executive Officer is Marcus R. Alderman, and its Vice President of Regulatory Affairs is Sandra K. Fenton, located at 2200 Penn Center West, Suite 300, Pittsburgh, Pennsylvania 15276. ATPC is represented by counsel William Pratt, Senior Partner, Kellner, Royce & Dillard LLP, One PPG Place, Suite 2800, Pittsburgh, Pennsylvania 15222. In its protest, ATPC argued that Ridgeline's proposed receipt-point metering station design at the Wetzel County Interconnect is inadequate to meet ATPC's operational and safety requirements. ATPC further contended that Ridgeline's cost allocation methodology for the interconnection facilities improperly shifts $14.7 million — representing 65.92 percent of the total $22.3 million interconnection facilities cost — to ATPC and its existing shippers.
Procedural Orders, Testimony, and the Deficiency Letter. On September 22, 2022, the Commission issued an order granting all motions to intervene. The Commission established a Track II procedural schedule for the consolidated proceedings and appointed Settlement Judge Howard Margolis to supervise settlement negotiations among the parties.
On October 17, 2022, Ridgeline filed its answer to the ATPC protest, responding in detail to ATPC's arguments regarding metering station design and interconnection cost allocation.
On November 14, 2022, Administrative Law Judge Clara Whitfield was appointed as Presiding Administrative Law Judge in these proceedings. Judge Whitfield held a prehearing conference on November 14, 2022, at which she established the initial procedural schedule for discovery, testimony, and hearing.
On November 30, 2022, the first settlement conference was held before Settlement Judge Margolis. The parties engaged in productive discussions but did not reach agreement on the principal contested issues.
On December 5, 2022, Ridgeline filed the pre-filed direct testimony and supporting exhibits of seven witnesses: James K. Winfield, Chief Executive Officer; Angela Moretti, Vice President of Finance and Treasurer; Thomas Greaves, Vice President of Engineering and Operations; Dr. Natasha Orlov, Director of Rates and Regulatory; Dr. Raymond Braswell (independent rate and economic consultant); and two additional sponsoring witnesses addressing specific aspects of the rate design, cost allocation, and engineering issues in the proceeding.
On January 9, 2023, ATPC, MGPC, and CMGA filed their respective answering testimony and supporting exhibits, responding to Ridgeline's direct case.
On January 19, 2023, the FERC Office of Energy Market Regulation issued a Deficiency Letter identifying fourteen specific deficiencies in Ridgeline's FERC Gas Tariff, Original Volume No. 1 filing. The Deficiency Letter was prepared under the direction of Dr. Miriam Okafor, Lead Economic Analyst, and coordinated with Jonathan Briggs, Lead Trial Attorney in the Office of General Counsel assigned to these proceedings. The Deficiency Letter required Ridgeline to address each identified deficiency and supplement or revise its tariff filing accordingly.
On February 6, 2023, Administrative Law Judge Whitfield issued an order staying the procedural schedule in these proceedings pending Ridgeline's complete response to the Deficiency Letter. Judge Whitfield directed Ridgeline to file a response as expeditiously as practicable and to inform the Presiding Judge of any need for additional time.
On March 8, 2023, the second settlement conference was held before Settlement Judge Margolis. The parties continued settlement discussions but were unable to resolve the outstanding issues. The gap between Ridgeline's position and the position of ATPC and MGPC on the recourse rate remains approximately $0.058/Dth.
Ridgeline's Partial Response. On March 15, 2023, Ridgeline filed a partial response to the Deficiency Letter, addressing eight of the fourteen identified deficiency items. Specifically, the partial response resolved the following items:
• Item 1: Updated return on equity support, including revised discounted cash flow and capital asset pricing model analyses.
• Item 2: Fuel, lost and unaccounted-for gas ("FL&U") tracker overview and proposed tariff provisions.
• Item 3: Interruptible transportation ("IT") rate derivation framework.
• Item 4: Load factor justification, including supporting throughput analysis and shipper survey data.
• Item 7: Electronic Bulletin Board ("EBB") design and requirements, including compliance with 18 C.F.R. § 284.12.
• Item 8: Shipper-must-have-title provisions consistent with Order No. 712.
• Item 9: Interconnection agreement filing as a rate schedule under Section 4 of the Natural Gas Act.
• Item 10: Penalty revenue crediting mechanism, including provisions for distribution of penalty revenues to non-offending shippers.
Six deficiency items remain outstanding: Items 5, 6, 11, 12, 13, and 14. This Motion addresses those remaining items and requests additional time to complete the response.
III. THE REMAINING SIX DEFICIENCY ITEMS AND THE COMPLEXITY OF THE REQUIRED TARIFF REDESIGN
Six deficiency items identified in the January 19, 2023 Deficiency Letter remain unaddressed and require substantial tariff redesign work. The complexity and interrelationship of these items are the principal basis for the requested 120-day extension. Each remaining item is described below, together with an explanation of the work required and the specific reasons that additional time is necessary.
A. Deficiency Item 5 — Capacity Release Provisions
The Deficiency Letter identified the absence of capacity release provisions in the General Terms and Conditions of Ridgeline's FERC Gas Tariff, Original Volume No. 1. Under Commission policy and the requirements of 18 C.F.R. Part 284, pipelines offering firm transportation service under an open-access tariff are required to include comprehensive provisions governing the release of firm capacity by shippers to replacement shippers.
To address this deficiency, Ridgeline must develop a complete set of capacity release provisions that are consistent with Commission policy as set forth in the Part 284 regulations and in relevant Commission orders addressing capacity release mechanics. These provisions must address, at a minimum, the following subjects: (i) the right of firm shippers to release all or a portion of their capacity on a permanent or temporary basis; (ii) pre-arranged deal requirements, including the distinction between pre-arranged and non-pre-arranged releases; (iii) bidding procedures for non-pre-arranged releases, including minimum bid requirements and evaluation criteria; (iv) recall rights and the conditions under which a releasing shipper may recall released capacity; (v) posting requirements on Ridgeline's Electronic Bulletin Board, including the duration and content of postings; and (vi) the relationship between capacity release provisions and the shipper-must-have-title provisions addressed in Ridgeline's partial response (Item 8).
The development of capacity release provisions requires careful coordination with the EBB design addressed in Item 7 of the partial response and with the NAESB compliance issues identified in Item 6 of the Deficiency Letter, which is itself one of the remaining outstanding items. Because capacity release transactions are nominated, confirmed, and scheduled through the pipeline's EBB in accordance with NAESB standards, these three areas of the tariff must be developed in an integrated fashion to ensure internal consistency and operational functionality.
B. Deficiency Item 6 — NAESB Standards Compliance in Operational Flow Order Provisions
The Deficiency Letter found that Ridgeline's tariff provisions governing operational flow orders and related operational procedures are incompletely compliant with the North American Energy Standards Board ("NAESB") Wholesale Gas Quadrant ("WGQ") Version 3.2 standards. The Commission requires interstate natural gas pipelines to incorporate NAESB WGQ standards by reference in their tariffs and to ensure that their operational procedures are consistent with those standards.
To address this deficiency, Ridgeline must undertake a full and detailed gap analysis comparing all existing tariff provisions against the applicable WGQ Version 3.2 standards. This gap analysis encompasses the full range of operational procedures addressed by the NAESB standards, including but not limited to: nominations and scheduling; confirmations; intraday nominations; imbalance management and cashout procedures; operational flow orders, including critical, non-critical, and extraordinary operational flow orders; force majeure provisions; and system-wide and point-specific operational notices.
This is a technically intensive exercise that requires specialized consulting support. The NAESB WGQ Version 3.2 standards are detailed and comprehensive, and ensuring complete compliance requires a line-by-line comparison of the tariff's operational provisions against the applicable standards, followed by redrafting of each non-compliant provision. The engagement of Braswell Energy Consulting Group LLC, discussed in Section IV below, was motivated in significant part by the need for expert support in completing this gap analysis and preparing compliant tariff provisions.
In addition, as noted above, the NAESB compliance analysis for operational flow order provisions must be coordinated with the development of capacity release provisions (Item 5) and segmentation and flexible receipt/delivery point provisions (Item 12), because all of these areas of the tariff interact with the pipeline's nomination, confirmation, and scheduling procedures.
C. Deficiency Item 11 — Creditworthiness Provisions
The Deficiency Letter identified inadequate creditworthiness provisions in Ridgeline's FERC Gas Tariff, Original Volume No. 1. The Commission requires that pipeline tariffs include provisions establishing clear and nondiscriminatory standards for evaluating the creditworthiness of shippers requesting transportation service.
To address this deficiency, Ridgeline must develop comprehensive creditworthiness requirements consistent with Commission policy, including the following elements: (i) unsecured credit limits based on objective financial criteria; (ii) credit rating thresholds tied to investment-grade ratings from nationally recognized statistical rating organizations; (iii) collateral posting requirements for shippers that do not satisfy the pipeline's creditworthiness standards, including acceptable forms of collateral such as irrevocable standby letters of credit, parent company guarantees, and cash deposits; (iv) procedures for ongoing monitoring of shipper creditworthiness and for addressing material adverse changes in a shipper's financial condition; (v) cure periods and dispute resolution procedures for shippers whose creditworthiness is questioned; and (vi) nondiscrimination provisions ensuring that creditworthiness standards are applied on a uniform and transparent basis to all similarly situated shippers.
The development of creditworthiness provisions requires coordination with Ridgeline's existing financing arrangements. Ridgeline's capital structure includes a Senior Secured Credit Facility with Pinnacle National Bank, N.A., as administrative agent, and a lending syndicate that includes Granite Trust Company and Lakeshore Capital Bank. The Senior Secured Credit Facility consists of a $400 million term loan and a $75 million revolving credit facility, bearing interest at SOFR plus 325 basis points, and maturing on October 1, 2028. As of the date of this filing, the outstanding balance under the Senior Secured Credit Facility is approximately $375 million. In addition, Ridgeline has outstanding $150 million in aggregate principal amount of 7.875% Second Lien Senior Secured Notes due 2030, currently held by Harborview Capital Management LLC and Sentinel Ridge Fund LP.
Both the Senior Secured Credit Facility and the Second Lien Senior Secured Notes contain covenants and provisions related to shipper credit exposure, including requirements regarding the pipeline's credit policies and limitations on unsecured credit exposure to individual shippers. The tariff's creditworthiness provisions must be developed with careful attention to these existing contractual obligations to ensure that the tariff provisions are consistent with and do not create conflicts with the pipeline's financing documents. Ridgeline anticipates that coordination with its lenders and noteholders may be required during the development of these provisions, which adds additional time to the process.
D. Deficiency Item 12 — Segmentation and Flexible Receipt/Delivery Point Provisions
The Deficiency Letter required Ridgeline's tariff to include provisions for the segmentation of firm transportation capacity and for flexible receipt and delivery point arrangements. Commission policy favors the inclusion of such provisions in pipeline tariffs because they promote efficient use of pipeline capacity and enhance competition in the transportation marketplace.
Addressing this deficiency involves two related but distinct components. First, Ridgeline must evaluate the engineering feasibility of offering segmented firm transportation service on the Ridgeline Pipeline System. This evaluation requires a detailed analysis of the system's three compressor stations — the Wetzel Station, the Mannington Station, and the Waynesburg Station — and the hydraulic characteristics of each pipeline segment between compression points. The analysis must determine whether the system can accommodate segmented service without adversely affecting the operational integrity of the pipeline or the service provided to existing shippers.
Second, Ridgeline must draft tariff provisions governing the nomination of alternative receipt and delivery points, including provisions specifying the conditions under which a shipper may request a change to its primary receipt or delivery point, the pipeline's obligations to accommodate such requests on a not-unduly-discriminatory basis, and the pricing and operational consequences of alternative receipt and delivery point nominations.
In developing these provisions, particular attention must be given to the characteristics of the Ridgeline Pipeline System's principal receipt and delivery points. The primary receipt point is the Wetzel County Interconnect in Wetzel County, West Virginia, located at Ridgeline milepost 0.0 and connecting with ATPC's 30-inch mainline at ATPC Milepost 412.6. The primary delivery point is the Waynesburg Compressor Station in Greene County, Pennsylvania, located at the northern terminus of the pipeline. The segmentation and flexible point provisions must be consistent with the physical and contractual arrangements at these interconnection and delivery points, and must be coordinated with the capacity release (Item 5) and NAESB compliance (Item 6) provisions.
E. Deficiency Item 13 — Greenhouse Gas Emission Cost Recovery Provisions
The Deficiency Letter required Ridgeline to address provisions for the recovery of greenhouse gas ("GHG") emission costs in its tariff. This is a novel and rapidly evolving area of Commission policy. No established FERC template exists for GHG cost recovery provisions in a natural gas pipeline tariff, and the Commission's expectations regarding the form and content of such provisions continue to develop.
To address this deficiency, Ridgeline must undertake several analytically demanding tasks. First, Ridgeline must analyze the state-level GHG regulations currently applicable to pipeline operations in West Virginia and Pennsylvania, including any existing or proposed requirements for emissions monitoring, reporting, and reduction. Second, Ridgeline must assess potential federal regulatory developments that may affect GHG cost obligations for natural gas pipeline operators in the near and medium term. Third, based on this regulatory analysis, Ridgeline must draft tariff language establishing a GHG cost tracker and passthrough mechanism that would permit Ridgeline to recover prudently incurred GHG compliance costs from its shippers on a fair and equitable basis.
The absence of well-settled Commission precedent in this area means that Ridgeline's response will necessarily involve original policy analysis and creative tariff drafting. Ridgeline is aware that several other pipeline operators have begun to address GHG cost recovery in their tariff filings, but the Commission's orders in those proceedings have not yet established a clear or uniform framework. Ridgeline intends to review available precedent and develop provisions that are both responsive to the Deficiency Letter and consistent with emerging Commission expectations.
F. Deficiency Item 14 — FERC Order No. 2222 and Distributed Energy Resource Aggregation / Renewable Energy Interconnection
The Deficiency Letter required Ridgeline to address the implications of FERC Order No. 2222, which establishes requirements for the participation of distributed energy resource ("DER") aggregations in the organized wholesale electricity markets operated by regional transmission organizations and independent system operators, for Ridgeline's natural gas pipeline tariff.
Although Order No. 2222 was directed primarily at the electric industry, the Commission has signaled increasing interest in how midstream natural gas pipeline operators address renewable energy integration and the potential effects of DER aggregation on natural gas demand and pipeline utilization. This item has particular relevance to Ridgeline because Ridgeline's sole member, Dunmore Energy Holdings Ltd., has a 250-megawatt wind energy portfolio under development. The Commission's interest in the intersection of natural gas pipeline operations and renewable energy development adds a layer of policy complexity to this deficiency item that requires careful and thorough analysis.
Addressing this deficiency requires extensive legal research on the applicability of Order No. 2222 to natural gas pipeline tariffs, an area of Commission policy that is rapidly evolving and for which limited direct precedent exists. Ridgeline must analyze whether and to what extent Order No. 2222's requirements apply to or have implications for the tariff provisions governing transportation service on the Ridgeline Pipeline System, and must develop appropriate tariff provisions that are responsive to the Commission's concerns while remaining operationally feasible and legally sound.
G. Overall Complexity and Need for Comprehensive Redesign
Taken together, the six remaining deficiency items require a comprehensive redesign of substantial portions of Ridgeline's FERC Gas Tariff, Original Volume No. 1, including the General Terms and Conditions and potentially the rate schedules themselves. The scope of the required work is significantly greater than what would be involved in addressing individual, discrete tariff deficiencies.
As described above, Items 5, 6, and 12 are closely interrelated. Capacity release provisions (Item 5), NAESB compliance in operational flow order provisions (Item 6), and segmentation and flexible receipt/delivery point provisions (Item 12) all affect the pipeline's nomination, confirmation, scheduling, and operational flow procedures. These provisions must be developed in an integrated fashion to ensure internal consistency and to avoid creating operational conflicts or ambiguities in the tariff.
Items 13 and 14, addressing GHG cost recovery and Order No. 2222 implications, involve novel regulatory policy areas with limited precedent. The analysis and drafting required for these items cannot be performed on a purely mechanical basis but rather require substantive policy judgments and creative tariff design.
Item 11, addressing creditworthiness provisions, requires coordination with Ridgeline's existing financing arrangements and potentially with Ridgeline's lenders and noteholders, which introduces additional time and complexity.
The interrelationship and collective complexity of these six items is the primary reason that Ridgeline has engaged expert consulting support and requires additional time to complete a comprehensive and well-integrated response.
IV. ENGAGEMENT OF BRASWELL ENERGY CONSULTING GROUP LLC
On April 15, 2023, Dunmore Energy Holdings Ltd., as Ridgeline's sole member, engaged Braswell Energy Consulting Group LLC ("Braswell") to provide comprehensive tariff redesign consulting services in connection with Ridgeline's response to the remaining deficiency items. Braswell is a Virginia limited liability company with offices at 8300 Greensboro Drive, Suite 450, McLean, Virginia 22102. The engagement is identified as Braswell Engagement No. BEC-2023-0041.
Dr. Raymond Braswell, the founder and managing principal of Braswell Energy Consulting Group, is directing the tariff redesign effort. Dr. Braswell is a former FERC economist with more than twenty-five years of experience in natural gas pipeline rate design, tariff development, and regulatory policy. Ridgeline notes that Dr. Braswell previously filed pre-filed direct testimony on Ridgeline's behalf on December 5, 2022, in these proceedings, addressing return on equity and capital structure issues. Dr. Braswell's current engagement as tariff redesign consultant is a separate and subsequent engagement from his earlier role as a testifying expert, and encompasses a broader scope of work directed at the comprehensive redesign of the tariff to address all fourteen deficiency items.
The scope of Braswell's engagement includes a full revision of the FERC Gas Tariff, Original Volume No. 1, to address all fourteen deficiency items identified in the January 19, 2023 Deficiency Letter, with particular focus on the six outstanding items (Items 5, 6, 11, 12, 13, and 14). The engagement contemplates that Braswell will perform detailed technical and policy analysis, develop draft tariff provisions, and coordinate closely with Ridgeline's operational and regulatory staff — including Dr. Natasha Orlov, Director of Rates and Regulatory, and Thomas Greaves, Vice President of Engineering and Operations — as well as with Calderwood & Harkness LLP as outside counsel.
The engagement of Braswell was finalized only thirteen days before the filing of this Motion. Given the breadth and complexity of the remaining deficiency items, Braswell requires a reasonable period to familiarize itself with the full record in these proceedings, perform the required technical and policy analyses, develop recommendations and draft tariff provisions, and coordinate the iterative review and refinement process with Ridgeline's internal teams and outside counsel. Ridgeline respectfully submits that the 120-day extension requested herein is the minimum period reasonably necessary to permit Braswell to complete this work in a thorough and professional manner.
V. PROPOSED TIMELINE
Current Status. The procedural schedule in Docket Nos. RP22-847-000 and RP22-847-001 has been stayed since February 6, 2023, pursuant to the order of Administrative Law Judge Whitfield. No hearing dates, testimony deadlines, discovery cut-off dates, or other scheduling milestones are currently in effect. The stay was entered specifically to permit Ridgeline to complete its response to the Deficiency Letter, and the Presiding Judge directed Ridgeline to inform the bench of any need for additional time.
Requested Extension. Ridgeline respectfully requests a 120-day extension from the date of this Motion, April 28, 2023, establishing a new deadline of August 28, 2023, for the filing of a complete response to all remaining deficiency items (Items 5, 6, 11, 12, 13, and 14).
Proposed Milestones. Ridgeline proposes the following internal milestones during the extension period to ensure that the work progresses in an orderly and timely fashion:
May through June 2023: Braswell Energy Consulting Group will complete its initial gap analysis of the existing tariff provisions and will develop draft tariff provisions addressing Deficiency Items 5 (capacity release), 6 (NAESB standards compliance), 11 (creditworthiness), and 12 (segmentation and flexible receipt/delivery points). This phase will include the detailed NAESB WGQ Version 3.2 gap analysis, engineering analysis of segmentation feasibility across the Ridgeline Pipeline System's three compressor stations, and coordination with Ridgeline's lenders regarding creditworthiness provisions.
June through July 2023: Braswell and Calderwood & Harkness LLP will develop draft tariff provisions addressing Deficiency Items 13 (GHG emission cost recovery) and 14 (Order No. 2222 and DER aggregation / renewable energy interconnection). This phase will involve regulatory policy research, analysis of state-level GHG regulations in West Virginia and Pennsylvania, assessment of emerging federal regulatory developments, and development of novel tariff provisions for which limited precedent exists.
July through August 2023: All draft provisions will be integrated into a revised FERC Gas Tariff, Original Volume No. 1. Ridgeline's internal review process will be conducted, including review by the CEO, VP Finance, VP Engineering & Operations, Director of Rates & Regulatory, and outside counsel. The complete supplemental response will be finalized for filing.
August 28, 2023: Ridgeline will file its complete supplemental response addressing Items 5, 6, 11, 12, 13, and 14 of the Deficiency Letter, together with revised tariff sheets and any necessary supporting testimony or exhibits.
Settlement Conference. Ridgeline notes that a third settlement conference before Settlement Judge Howard Margolis is anticipated for approximately July 12, 2023. The ongoing settlement discussions may inform the tariff redesign, particularly with respect to rate design and cost allocation issues, and the revised tariff provisions under development may in turn facilitate narrowing of the settlement gap between the parties. Ridgeline will keep all parties and the Presiding Judge informed of developments.
VI. GOOD CAUSE FOR THE EXTENSION
The standard for extensions of time under Rule 2008 of the Commission's Rules of Practice and Procedure, 18 C.F.R. § 385.2008, requires a showing of good cause. Good cause exists in this case for several independent and mutually reinforcing reasons.
First, the remaining deficiency items involve technically and legally complex tariff design issues. As described in Section III above, the six outstanding items require Ridgeline to develop comprehensive tariff provisions addressing capacity release mechanics, NAESB WGQ Version 3.2 compliance, creditworthiness standards, segmentation and flexible point service, GHG emission cost recovery, and the implications of FERC Order No. 2222. Several of these areas — particularly GHG cost recovery and Order No. 2222 — involve novel areas of Commission policy for which no established templates or well-settled precedent exist. The analysis and drafting required for these items cannot be completed responsibly in a compressed timeframe.
Second, Ridgeline has recently engaged a consulting expert whose work is essential to the tariff redesign. Braswell Energy Consulting Group LLC was engaged on April 15, 2023 — only thirteen days before the filing of this Motion. The engagement was necessitated by the breadth and complexity of the remaining deficiency items, which collectively require a comprehensive redesign of substantial portions of the FERC Gas Tariff, Original Volume No. 1. It would be unreasonable to expect Braswell to complete this work without a reasonable period for analysis, development of draft provisions, and coordination with Ridgeline's internal staff and outside counsel. The 120-day extension requested herein is the minimum period necessary to permit a thorough and professional effort.
Third, the remaining items are interrelated and must be developed in an integrated fashion. Items 5, 6, and 12 — capacity release, NAESB compliance, and segmentation — all affect the pipeline's nomination, confirmation, scheduling, and operational flow procedures. Developing these provisions in isolation would risk creating internal inconsistencies and operational conflicts within the tariff. A comprehensive, integrated approach is necessary, and that approach requires adequate time.
Fourth, no party will be prejudiced by the requested extension. The procedural schedule in these proceedings has been stayed since February 6, 2023, pursuant to Judge Whitfield's order. No hearing dates, testimony deadlines, or other scheduling milestones are currently set. The extension will not delay any proceedings that are currently underway and will not prejudice any intervenor or FERC Trial Staff. As discussed in Section VII below, counsel for Ridgeline has communicated with counsel for all parties, and no party has indicated opposition to the extension.
Fifth, ongoing settlement efforts may benefit from the additional time. Settlement discussions among the parties continue under the supervision of Settlement Judge Margolis, and a third settlement conference is anticipated for approximately July 2023. The current settlement gap between Ridgeline's position and the ATPC/MGPC position is approximately $0.058/Dth. The tariff redesign now underway may facilitate narrowing of this gap by addressing operational and tariff design issues that have been identified as impediments to settlement. Granting the extension will permit the tariff redesign and settlement discussions to proceed in parallel, potentially promoting a more efficient resolution of these proceedings.
Sixth, the Commission's interest is best served by a complete and well-supported filing. The Commission has a strong interest in receiving tariff filings that are comprehensive, internally consistent, and fully compliant with applicable regulatory requirements. A piecemeal or incomplete response to the Deficiency Letter would not serve that interest and would likely require further deficiency proceedings, resulting in additional delay and inefficiency. Granting the requested 120-day extension will permit Ridgeline to file a complete supplemental response that fully addresses all fourteen deficiency items and presents the Commission with a revised tariff that meets the highest standards of quality and completeness.
For all of these reasons, Ridgeline respectfully submits that good cause exists for the requested 120-day extension under 18 C.F.R. § 385.2008.
VII. NO PARTY HAS INDICATED OPPOSITION
Consistent with its obligations of professional courtesy and its commitment to cooperative engagement with all parties in these proceedings, counsel for Ridgeline, Calderwood & Harkness LLP, has communicated with counsel for each intervenor and with FERC Trial Staff regarding this Motion. Specifically, Ridgeline's counsel has conferred with the following:
• William Pratt, Senior Partner, Kellner, Royce & Dillard LLP, counsel for Appalachian Trunk Pipeline Company, LLC;
• Rebekah Montague, Whitmore & Sable LLP, counsel for Mountainside Gas Producers Coalition;
• Stephen Greer, Fordham Municipal Law Group PC, counsel for Clearwater Municipal Gas Authority; and
• Jonathan Briggs, Lead Trial Attorney, Office of General Counsel, Federal Energy Regulatory Commission, FERC Trial Staff.
No party has indicated opposition to the requested 120-day extension. Ridgeline acknowledges that the absence of opposition does not relieve the Applicant of its burden to demonstrate good cause, and Ridgeline has endeavored to make that showing fully in Section VI above. The absence of opposition does, however, confirm that the extension will not cause prejudice to any party and supports the conclusion that the requested extension is reasonable and appropriate under the circumstances.
Ridgeline will continue to cooperate with all parties throughout the extension period and will provide updates on the progress of the tariff redesign as appropriate. Ridgeline remains committed to completing its response to the Deficiency Letter as expeditiously as practicable and to working constructively with all parties and with the Commission's staff toward a resolution of the outstanding issues in these proceedings.
VIII. CONCLUSION AND PRAYER FOR RELIEF
WHEREFORE, for the reasons set forth above, Ridgeline Midstream Services LLC respectfully requests that Administrative Law Judge Clara Whitfield grant this Motion and enter an order:
1. Extending the deadline for Ridgeline Midstream Services LLC to file a complete response to the remaining deficiency items (Items 5, 6, 11, 12, 13, and 14) identified in the January 19, 2023 Deficiency Letter issued by the Commission's Office of Energy Market Regulation to August 28, 2023 (120 days from the date of this Motion);
2. Continuing the stay of the procedural schedule in Docket Nos. RP22-847-000 and RP22-847-001 pending Ridgeline's filing of its complete response to the Deficiency Letter; and
3. Granting such other and further relief as the Presiding Judge deems just and appropriate.
Respectfully submitted,
CALDERWOOD & HARKNESS LLP
By: ________
George Trujillo, Responsible Partner
Brett Callahan, Lead Associate David Stanton, Working Associate
1601 K Street NW, Suite 900 Washington, DC 20006 Telephone: (202) 555-4200 Facsimile: (202) 555-4201
Counsel for Ridgeline Midstream Services LLC
Dated: April 28, 2023
CERTIFICATE OF SERVICE
I hereby certify that on April 28, 2023, a true and correct copy of the foregoing Motion of Ridgeline Midstream Services LLC for a 120-Day Extension of Time to Complete Response to Deficiency Letter was served upon all parties on the official service list maintained by the Secretary of the Federal Energy Regulatory Commission in Docket Nos. RP22-847-000 and RP22-847-001, by electronic mail and first-class United States mail, postage prepaid, addressed as follows:
Secretary Federal Energy Regulatory Commission 888 First Street NE Washington, DC 20426
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 General Counsel 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
Rebekah Montague Whitmore & Sable LLP 1200 New Hampshire Avenue NW, Suite 600 Washington, DC 20036 Counsel for Mountainside Gas Producers Coalition
Stephen Greer Fordham Municipal Law Group PC 312 Adams Avenue, Suite 100 Scranton, PA 18503 Counsel for Clearwater Municipal Gas Authority
Sandra K. Fenton Vice President, Regulatory Affairs Appalachian Trunk Pipeline Company, LLC 2200 Penn Center West, Suite 300 Pittsburgh, PA 15276
Calvin Dreyer Executive Director Mountainside Gas Producers Coalition 1100 Main Street, Suite 210 Morgantown, WV 26505
Dennis Ott General Manager Clearwater Municipal Gas Authority 455 Market Street Clearwater, PA 15330
________________________________________
David Stanton Calderwood & Harkness LLP 1601 K Street NW, Suite 900 Washington, DC 20006
Dated: April 28, 2023

UNITED STATES OF AMERICA FEDERAL ENERGY REGULATORY COMMISSION

I. INTRODUCTION AND SUMMARY OF RELIEF REQUESTED

II. BACKGROUND

IV. ENGAGEMENT OF BRASWELL ENERGY CONSULTING GROUP LLC

V. PROPOSED TIMELINE

VI. GOOD CAUSE FOR THE EXTENSION

VII. NO PARTY HAS INDICATED OPPOSITION

VIII. CONCLUSION AND PRAYER FOR RELIEF

CALDERWOOD & HARKNESS LLP

CERTIFICATE OF SERVICE

Record

Parties

Dates

Amounts