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UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION

MOTION OF RIDGELINE MIDSTREAM SERVICES LLC FOR EXTENSION OF TIME TO COMPLETE RESPONSE TO DEFICIENCY LETTER

Filed: August 25, 2023 C&H Matter No. 1016-00005

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I. PRELIMINARY STATEMENT

Ridgeline Midstream Services LLC ("Ridgeline" or "Applicant"), a Delaware limited liability company and a wholly owned subsidiary of Dunmore Energy Holdings Ltd. ("DEH"), a Cayman Islands exempted limited company, by and through its undersigned counsel, Calderwood & Harkness LLP, respectfully moves the Presiding Administrative Law Judge, the Honorable Clara Whitfield, pursuant to Section 385.2008 of the Commission's Rules of Practice and Procedure, 18 C.F.R. § 385.2008, for an extension of one hundred eighty (180) days — from the current deadline of August 28, 2023 to February 23, 2024 — to complete its response to the Deficiency Letter issued by the Commission's Office of Energy Market Regulation ("OEMR") on January 19, 2023 (the "Deficiency Letter").

Ridgeline's principal office is located at 700 Kanawha Boulevard East, Suite 1400, Charleston, West Virginia 25301. Ridgeline is the owner and operator of the Ridgeline Pipeline System, a 187-mile high-pressure interstate natural gas pipeline extending from Wetzel County, West Virginia to Greene County, Pennsylvania. The instant application, filed on May 12, 2022, seeks Commission approval of an initial tariff rate for interstate natural gas transportation service on the Ridgeline Pipeline System and authorization for physical interconnection with Appalachian Trunk Pipeline Company, LLC ("ATPC") at the Wetzel County Interconnect.

As set forth more fully below, this is Ridgeline's second motion for extension of time in this proceeding. The first extension, which was granted by Judge Whitfield on May 10, 2023, provided an additional 120 days to respond to the Deficiency Letter, establishing the current August 28, 2023 deadline. Notwithstanding Ridgeline's diligent and good-faith efforts to complete the tariff redesign required by the Deficiency Letter — including the retention of Braswell Energy Consulting Group LLC ("Braswell"), a leading energy regulatory consulting firm led by Dr. Raymond Braswell, a former Commission economist — the scope, complexity, and novelty of the six remaining deficiency items necessitate additional time.

Ridgeline submits that good cause exists for the requested extension. The six remaining deficiency items involve the development of substantial new tariff provisions — including capacity release mechanisms, NAESB standards compliance, creditworthiness provisions, segmentation and flexible receipt/delivery point provisions, greenhouse gas emission cost recovery provisions, and Order No. 2222 distributed energy resource aggregation provisions — that were not part of Ridgeline's original filing and that raise novel regulatory questions for which established Commission precedent is limited or evolving. The requested 180-day extension will afford Ridgeline and its consultants adequate time to develop a comprehensive, internally consistent redesigned tariff that addresses all fourteen deficiency items, while simultaneously permitting the productive continuation of stakeholder negotiations that have the potential to narrow disputed issues and promote the efficient resolution of this proceeding.

No party opposes this motion. As described in Section V below, undersigned counsel has communicated with counsel for all active parties in this proceeding, and no party has interposed an objection to the requested extension.

II. BACKGROUND AND PROCEDURAL HISTORY

A. The Filing and Initial Proceedings

On May 12, 2022, Ridgeline filed its application with the Commission in the above-captioned docket, seeking approval of an initial tariff rate for interstate natural gas transportation service on the Ridgeline Pipeline System and authorization for physical interconnection with ATPC at the Wetzel County Interconnect (Wetzel County, West Virginia). The application was filed pursuant to Sections 4 and 7 of the Natural Gas Act, 15 U.S.C. §§ 717c and 717f, and the Commission's regulations at 18 C.F.R. Parts 154, 157, and 284.

The Ridgeline Pipeline System is a 187-mile, 24-inch-diameter high-pressure natural gas pipeline extending from the Wetzel County Interconnect in Wetzel County, West Virginia, to the Waynesburg Compressor Station in Greene County, Pennsylvania. The system has a design capacity of 1.2 billion cubic feet per day ("Bcf/d") (1,200,000 dekatherms per day ("Dth/d")) and a current throughput of approximately 680 million cubic feet per day ("MMcf/d"), representing approximately 56.67% utilization of design capacity. The system includes three compressor stations with aggregate installed compression of 45,000 horsepower ("HP"). The Ridgeline Pipeline System was placed in service on October 1, 2021.

In its application, Ridgeline proposed a FERC Gas Tariff, Original Volume No. 1, structured as a Part 284, Subpart G open-access transportation tariff. The proposed recourse rate was $0.2265 per Dth, consisting of a reservation charge of $0.2223 per Dth and a usage charge of $0.0042 per Dth. The proposed recourse rate was derived from a total cost of service of $97.36 million and billing determinants of 438,000,000 Dth per year, based on a 100% load factor assumption.

Ridgeline's proposed rate base, as filed, was $612.40 million. The proposed return on equity ("ROE") was 14.00%, based on a capital structure consisting of 55% equity and 45% debt, a cost of debt of 5.25%, and a weighted average cost of capital ("WACC") of 10.0625%. These financial parameters were supported by the pre-filed testimony of Ridgeline's rate and financial witnesses, as discussed further below.

B. Interventions and Protests

On June 14, 2022, the Commission issued a Notice of Filing in this proceeding, which was published in the Federal Register on June 17, 2022, and established an intervention and protest deadline of August 15, 2022. Three entities filed motions to intervene and/or protests during the intervention period, as follows:

Mountainside Gas Producers Coalition ("MGPC"). On July 28, 2022, MGPC, an unincorporated association of fourteen independent natural gas producers operating in the Appalachian Basin, filed a timely motion to intervene and comments. MGPC expressed general support for the proposed interconnection with ATPC, noting that the interconnection would enhance market access for its member producers. However, MGPC opposed Ridgeline's proposed recourse rate as excessive and unjust, advocating that any approved recourse rate should not exceed approximately $0.2560 per Dth. MGPC asserted that Ridgeline's proposed 14.00% ROE was significantly above the zone of reasonableness established by Commission precedent and would impose an undue burden on shippers.

Clearwater Municipal Gas Authority ("CMGA"). On August 1, 2022, CMGA, a municipal gas distribution utility serving approximately 12,000 residential and commercial customers in Clearwater, Pennsylvania and surrounding communities, filed a timely motion to intervene and comments. CMGA expressed concern that the proposed interconnection configuration and cost allocation could result in rate increases on ATPC's system, which would adversely affect CMGA's ratepayers. CMGA requested that the Commission ensure that any approved interconnection and tariff structure would not result in the unjust allocation of costs to ATPC's existing shippers.

Appalachian Trunk Pipeline Company, LLC ("ATPC"). On August 15, 2022, the final day of the intervention period, ATPC filed a protest and motion to intervene. ATPC is the owner and operator of the Appalachian Trunk Pipeline, a 640-mile interstate natural gas pipeline system with a capacity of 3.8 Bcf/d. ATPC opposed the proposed interconnection configuration at the Wetzel County Interconnect, asserting that Ridgeline's proposed design imposed unnecessary operational constraints on ATPC's existing system. ATPC also challenged Ridgeline's proposed cost allocation methodology for the interconnection facilities, arguing that Ridgeline's proposal improperly shifted approximately $14.7 million in interconnection facilities costs to ATPC's shippers. The total cost of interconnection facilities was estimated at $22.3 million, and ATPC asserted that a 50/50 cost split ($11.15 million each) would be more appropriate than Ridgeline's proposed 34.1%/65.9% allocation ($7.6 million Ridgeline / $14.7 million ATPC).

On September 22, 2022, the Commission issued an order granting all three motions to intervene, setting a Track II procedural schedule for the proceeding, and appointing Settlement Judge Howard Margolis to convene settlement conferences and explore the possibility of a negotiated resolution of the disputed issues.

C. Testimony Phase

On November 14, 2022, Administrative Law Judge Clara Whitfield was designated as the Presiding Judge in this proceeding and held a prehearing conference on the same date. The prehearing conference established a schedule for the filing of pre-filed testimony and the conduct of discovery.

On December 5, 2022, Ridgeline filed pre-filed direct testimony of seven witnesses in support of its application. The testimony included, among others, the following witnesses and subject matter areas:

• James K. Winfield, Chief Executive Officer, Ridgeline Midstream Services LLC — policy testimony addressing the need for service on the Ridgeline Pipeline System, the benefits of the proposed interconnection with ATPC, and the overall public interest in approval of the application;

• Angela Moretti, Vice President of Finance and Treasurer, Ridgeline Midstream Services LLC — cost-of-service testimony and rate base support, including detailed schedules of capital costs, operating expenses, depreciation, taxes, and working capital;

• Thomas Greaves, Vice President of Engineering and Operations, Ridgeline Midstream Services LLC — engineering and system design testimony, including pipeline specifications, compressor station configurations, and the design and operational characteristics of the Wetzel County Interconnect;

• Dr. Natasha Orlov, Director of Rates and Regulatory, Ridgeline Midstream Services LLC — rate design and tariff provisions testimony, including the derivation of the proposed reservation and usage charges, the proposed billing determinants, and the terms and conditions of the proposed FERC Gas Tariff, Original Volume No. 1; and

• Dr. Raymond Braswell, independent expert witness — return on equity and capital structure testimony, including a discounted cash flow ("DCF") analysis, a Capital Asset Pricing Model ("CAPM") analysis, a risk premium analysis, and a comparable earnings analysis supporting the proposed 14.00% ROE.

On January 9, 2023, answering testimony was filed by all three intervenors. ATPC filed answering testimony through its counsel, Kellner, Royce & Dillard LLP (lead counsel William Pratt), addressing the interconnection configuration and cost allocation. MGPC filed answering testimony through its counsel, Whitmore & Sable LLP (lead counsel Rebekah Montague), including the testimony of rate expert Dr. Eleanor Vasquez, who challenged Ridgeline's proposed ROE and recommended an ROE of 11.25%. CMGA filed answering testimony through its counsel, Fordham Municipal Law Group PC (lead counsel Stephen Greer), addressing the potential impact of the proceeding on ATPC's existing shippers and CMGA's ratepayers.

D. The Deficiency Letter and Stay of Procedural Schedule

On January 19, 2023, the Commission's Office of Energy Market Regulation, through lead economic analyst Dr. Miriam Okafor and lead trial attorney Jonathan Briggs, issued the Deficiency Letter identifying fourteen (14) separate deficiencies in Ridgeline's tariff filing. The Deficiency Letter required Ridgeline to undertake a comprehensive tariff redesign to address the identified deficiencies. The fourteen deficiency items are as follows:

1. Inadequate cost-of-service support for proposed 14.00% ROE (no updated proxy group analysis post-2021);

2. Failure to include a fuel-use and lost-and-unaccounted-for gas ("FL&U") tracker mechanism;

3. Missing interruptible transportation ("IT") rate derivation;

4. Insufficient support for 100% load factor billing determinant assumption;

5. No capacity release provisions in General Terms & Conditions;

6. Incomplete NAESB standards compliance in operational flow order provisions;

7. Missing electronic bulletin board ("EBB") posting requirements;

8. Inadequate shipper-must-have-title provisions;

9. Interconnection agreement not filed as a rate schedule;

10. No penalty revenue crediting mechanism;

11. Inadequate creditworthiness provisions;

12. Missing segmentation and flexible receipt/delivery point provisions;

13. No provisions addressing greenhouse gas emission cost recovery; and

14. Failure to address Order No. 2222 distributed energy resource aggregation implications (renewable energy interconnection).

The Deficiency Letter was comprehensive in scope and required Ridgeline to develop substantial new tariff provisions that had not been included in its original filing. The deficiency items ranged from relatively straightforward tariff drafting matters (such as the EBB posting requirements and shipper-must-have-title provisions) to complex and novel regulatory questions (such as greenhouse gas emission cost recovery and Order No. 2222 DER aggregation implications).

On February 6, 2023, ALJ Whitfield issued an order staying the procedural schedule in this proceeding pending Ridgeline's response to the Deficiency Letter. The order noted that it would be premature to proceed with the hearing schedule until the deficiencies identified by OEMR had been addressed, and that the stay would remain in effect until further order of the Presiding Judge.

E. Partial Response and First Extension

On March 15, 2023, approximately two months after receiving the Deficiency Letter, Ridgeline filed a partial response addressing eight of the fourteen deficiency items. Specifically, Ridgeline's partial response addressed:

• Item 1 (ROE cost-of-service support) — Ridgeline provided an updated proxy group analysis and supplemental DCF and CAPM analyses reflecting market data through December 31, 2022;

• Item 2 (FL&U tracker mechanism) — Ridgeline proposed a fuel-use and lost-and-unaccounted-for gas tracker consistent with Commission precedent;

• Item 3 (IT rate derivation) — Ridgeline provided a derivation of interruptible transportation rates based on the 100% load factor reservation rate;

• Item 4 (100% load factor support) — Ridgeline provided additional support for its 100% load factor billing determinant assumption, including precedent agreement data and historical throughput information;

• Item 7 (EBB posting requirements) — Ridgeline proposed comprehensive electronic bulletin board posting provisions;

• Item 8 (shipper-must-have-title provisions) — Ridgeline revised its General Terms & Conditions to include appropriate shipper-must-have-title language;

• Item 9 (interconnection agreement as rate schedule) — Ridgeline filed the interconnection agreement with ATPC as a rate schedule under its proposed FERC Gas Tariff; and

• Item 10 (penalty revenue crediting mechanism) — Ridgeline proposed a penalty revenue crediting mechanism consistent with Commission policy.

Six deficiency items remained unaddressed in the partial response: Item 5 (capacity release provisions), Item 6 (NAESB standards compliance), Item 11 (creditworthiness provisions), Item 12 (segmentation and flexible receipt/delivery point provisions), Item 13 (greenhouse gas emission cost recovery), and Item 14 (Order No. 2222/DER aggregation implications). These remaining items are the most complex and novel of the fourteen deficiency items and require the development of substantial new tariff provisions, as discussed further in Section III below.

On April 15, 2023, recognizing the need for specialized expertise to address the remaining deficiency items, Ridgeline engaged Braswell Energy Consulting Group LLC ("Braswell"), a regulatory consulting firm led by Dr. Raymond Braswell, a former Commission economist and the expert witness who had provided Ridgeline's ROE and capital structure testimony in this proceeding. The engagement (engagement number BEC-2023-0041) covers a comprehensive tariff redesign encompassing all six remaining deficiency items, as well as the integration of the redesigned provisions into a coherent and internally consistent FERC Gas Tariff, Original Volume No. 1.

On April 28, 2023, Ridgeline filed its first motion for extension of time, requesting a 120-day extension of the deadline to complete its response to the Deficiency Letter. The motion cited the complexity of the remaining deficiency items and the need for additional time to complete the tariff redesign with the assistance of Braswell. No party opposed the first extension.

On May 10, 2023, ALJ Whitfield granted Ridgeline's first motion for extension of time, extending the deadline for Ridgeline to file its complete response to the Deficiency Letter from the then-current deadline to August 28, 2023. The order noted that Ridgeline had demonstrated good cause for the extension and that the procedural schedule would remain stayed pending the filing.

F. Settlement Activity

Settlement conferences have been held at three points during this proceeding, each convened before Settlement Judge Howard Margolis. The first settlement conference was held on November 30, 2022, shortly after ALJ Whitfield's appointment as Presiding Judge. The second settlement conference was held on March 8, 2023, following Ridgeline's filing of its partial response to the Deficiency Letter. The third and most recent settlement conference was held on July 12, 2023.

Despite the good-faith efforts of all parties, no settlement has been reached. The parties remain significantly apart on several key issues, including the appropriate ROE, the interconnection cost allocation between Ridgeline and ATPC, and the proper load factor assumption for billing determinant purposes. However, the ongoing bilateral negotiations described in Section III.C below continue to hold promise for narrowing the range of disputed issues.

III. GROUNDS FOR THE REQUESTED EXTENSION

Ridgeline respectfully submits that good cause exists for the requested 180-day extension, from August 28, 2023 to February 23, 2024, based on the following grounds.

A. Scope and Complexity of the Remaining Tariff Redesign

The six remaining deficiency items — Items 5, 6, 11, 12, 13, and 14 — require the development of substantial new tariff provisions that were not part of Ridgeline's original filing. Each of these items involves complex regulatory, technical, and policy considerations, and several raise novel questions for which established Commission precedent is limited, evolving, or subject to ongoing industry development. The scope and complexity of each remaining item is summarized below.

Item 5 — Capacity Release Provisions. The Deficiency Letter requires Ridgeline to develop comprehensive capacity release provisions in the General Terms & Conditions of its proposed FERC Gas Tariff. The capacity release program must be consistent with the Commission's open-access policies under 18 C.F.R. Part 284 and applicable Commission orders, including Order Nos. 636, 636-A, and 636-B, as well as more recent guidance. The required provisions include, but are not limited to, shipper rights to release firm transportation capacity, posting requirements for capacity available for release, bidding procedures for released capacity, terms governing prearranged deals, provisions for recall and reput of released capacity, rate caps on released capacity, and the allocation of released capacity among competing bidders. Development of these provisions requires careful analysis of the operational characteristics of the Ridgeline Pipeline System and coordination with NAESB WGQ standards applicable to capacity release transactions.

Item 6 — NAESB Standards Compliance. The Deficiency Letter identified incomplete compliance with the standards promulgated by the North American Energy Standards Board, Wholesale Gas Quadrant ("NAESB WGQ"). Ridgeline is required to conduct a full gap analysis of its proposed tariff against NAESB WGQ Version 3.2 standards, covering operational flow orders, scheduling, nominations, and balancing. This is a highly technical undertaking that requires a detailed comparison of each provision of Ridgeline's proposed tariff with the corresponding NAESB standard, identification of gaps and inconsistencies, and the drafting of revised tariff language to achieve full compliance. The gap analysis must encompass not only the operational flow order provisions specifically identified in the Deficiency Letter but also related provisions governing nominations, scheduling, confirmations, allocations, imbalance management, and operational balancing agreements. Given the interdependencies among these provisions, the NAESB compliance effort requires a holistic review and revision of substantial portions of the General Terms & Conditions.

Item 11 — Creditworthiness Provisions. The Deficiency Letter requires Ridgeline to develop comprehensive creditworthiness provisions that meet Commission standards. The required provisions include criteria for evaluating the creditworthiness of prospective and existing shippers, collateral posting requirements (including the types of acceptable collateral, such as letters of credit, surety bonds, guarantees, and cash deposits), the calculation of unsecured credit limits, credit rating thresholds (including minimum investment-grade rating requirements), procedures for monitoring and reassessing shipper creditworthiness on an ongoing basis, and remedies available to Ridgeline in the event of a shipper's credit deterioration, including the right to demand additional collateral, suspend service, or terminate service agreements. These provisions must be carefully crafted to protect Ridgeline's financial interests while ensuring that the creditworthiness requirements are not unduly restrictive or discriminatory.

Item 12 — Segmentation and Flexible Receipt/Delivery Point Provisions. The Deficiency Letter requires Ridgeline to include provisions in its tariff permitting shippers to segment their firm transportation capacity and to designate alternative receipt and delivery points on the 187-mile Ridgeline Pipeline System. The development of segmentation provisions requires analysis of the system's physical and operational characteristics, including the location and capacity of receipt and delivery points, compressor station configurations, and the hydraulic constraints of the pipeline. Flexible receipt and delivery point provisions must address the conditions under which shippers may designate alternative points, the scheduling priority of primary versus secondary point designations, and any capacity limitations or operational constraints that may apply at particular receipt and delivery points. These provisions have significant implications for the rate design and billing determinants, as the availability of segmentation and flexible points may affect the utilization of the system and the allocation of costs among shippers.

Item 13 — Greenhouse Gas Emission Cost Recovery. The Deficiency Letter requires Ridgeline to address the recovery of greenhouse gas ("GHG") emission costs through its tariff. This is an area of emerging and unsettled regulatory policy at both the federal and state levels. The development of GHG cost recovery provisions requires analysis of potential carbon pricing mechanisms — including federal carbon tax proposals, state-level carbon pricing programs (such as the Regional Greenhouse Gas Initiative, or "RGGI," in which several states in the pipeline's operating region participate or are considering participation), and voluntary carbon offset markets — and the design of a GHG cost tracker or passthrough provision that allows Ridgeline to recover prudently incurred GHG compliance costs without placing undue risk on either the pipeline or its shippers. Given the rapidly evolving nature of federal and state GHG policy, the design of a durable and flexible GHG cost recovery mechanism presents significant analytical and drafting challenges.

Item 14 — Order No. 2222 Distributed Energy Resource Aggregation Implications. The Deficiency Letter requires Ridgeline to address the implications of FERC Order No. 2222, which established rules governing the participation of distributed energy resource ("DER") aggregations in wholesale electricity markets, for the Ridgeline Pipeline System. While Order No. 2222 was directed primarily at regional transmission organizations and independent system operators in the electric sector, the Deficiency Letter requires Ridgeline to consider the implications of DER aggregation for renewable energy interconnection with the Ridgeline Pipeline System. This is a particularly relevant issue given that Ridgeline's parent company, DEH, has a 250-megawatt ("MW") wind portfolio under development in the Appalachian region, which could potentially involve the co-location of renewable energy generation and natural gas pipeline infrastructure. The intersection of DER aggregation with midstream natural gas pipeline tariffs is a novel issue for which there is limited Commission precedent, and the development of appropriate tariff provisions requires careful analysis of the regulatory landscape and emerging industry practices.

The six remaining deficiency items are not independent of one another. Rather, they are deeply interconnected, and the resolution of each item has implications for the others. For example, the capacity release provisions (Item 5) must be consistent with the NAESB standards (Item 6); the segmentation and flexible point provisions (Item 12) affect the billing determinants and rate design, which in turn are affected by the GHG cost recovery provisions (Item 13); and the creditworthiness provisions (Item 11) must account for the credit implications of capacity release transactions (Item 5) and GHG cost obligations (Item 13). Accordingly, the tariff redesign cannot proceed in a piecemeal fashion but must be developed as an integrated, internally consistent whole. This comprehensive approach is essential to producing a tariff filing that will withstand scrutiny and promote the efficient resolution of this proceeding.

B. Braswell Energy Consulting Group Engagement and Work Status

As noted above, Ridgeline engaged Braswell Energy Consulting Group LLC on April 15, 2023, under engagement number BEC-2023-0041, approximately four and a half months ago. Dr. Raymond Braswell, the firm's founder and principal, has assembled a team of regulatory economists, rate design specialists, and tariff drafting professionals to assist Ridgeline with the comprehensive tariff redesign required by the Deficiency Letter.

Since the engagement commenced, Dr. Braswell and his team have been conducting a thorough analysis of the tariff redesign requirements for each of the six remaining deficiency items. This work has included the development of the analytical framework for a modified fixed-variable rate methodology, the recalculation and testing of revised billing determinants under various load factor assumptions, and the preliminary drafting of new tariff provisions addressing capacity release, NAESB compliance, creditworthiness, segmentation and flexible points, GHG cost recovery, and Order No. 2222 implications.

Braswell's work is ongoing and has proven to be more complex and time-consuming than initially anticipated, particularly with respect to Items 13 (GHG cost recovery) and 14 (Order No. 2222/DER aggregation), which involve novel regulatory questions and require analysis of rapidly evolving federal and state policy developments. Dr. Braswell has informed Ridgeline that additional time is needed to develop and test the revised rate design model, to complete the NAESB WGQ Version 3.2 gap analysis, and to ensure consistency across all sections of the redesigned tariff. Braswell has further advised that the integrated nature of the tariff redesign — in which each provision must be consistent with and informed by every other provision — requires a sequential and iterative drafting process that cannot be significantly compressed without sacrificing the quality and coherence of the final product.

Based on Braswell's current work plan and resource allocation, Ridgeline expects that the tariff redesign work will be substantially completed during the fourth quarter of 2023 and the first quarter of 2024, with the final integrated tariff and supplemental testimony ready for filing on or before February 23, 2024.

C. Stakeholder Negotiations

In addition to the tariff redesign work, Ridgeline has been engaged in ongoing bilateral negotiations with the intervenors in this proceeding regarding key elements of the tariff filing. These negotiations have been conducted in parallel with the tariff redesign and have the potential to narrow the range of disputed issues, thereby promoting the efficient resolution of the proceeding.

The principal areas of ongoing negotiation are as follows:

Interconnection Cost Allocation. Ridgeline and ATPC (through its counsel, William Pratt of Kellner, Royce & Dillard LLP) have been engaged in discussions regarding the allocation of the approximately $22.3 million in total interconnection facilities costs at the Wetzel County Interconnect. ATPC has consistently advocated for a 50/50 cost split, which would allocate approximately $11.15 million to each party. Ridgeline's original filing proposed a 34.1%/65.9% cost allocation, under which Ridgeline would bear approximately $7.6 million and ATPC's shippers would bear approximately $14.7 million. The parties have exchanged analyses and counter-proposals but have not yet reached agreement on this issue. Ridgeline believes that continued negotiations, informed by the tariff redesign work, may produce a mutually acceptable cost allocation that could be incorporated into the redesigned tariff.

Return on Equity. The appropriate ROE remains a significant area of dispute. ATPC has proposed an ROE of 10.75%, and MGPC (through its counsel, Rebekah Montague of Whitmore & Sable LLP, and its rate expert, Dr. Eleanor Vasquez) has proposed an ROE of 11.25%. Ridgeline's original filing proposed an ROE of 14.00%, which is acknowledged to be at the upper end of the range. Based on updated market data and the supplemental analyses provided in the March 15, 2023 partial response, Ridgeline is evaluating a potential reduction from the originally proposed 14.00% ROE. A revised ROE position would have direct implications for the cost of service, the rate base, the billing determinants, and the overall recourse rate, and would need to be fully integrated into the redesigned tariff.

Load Factor. The intervenors (ATPC, MGPC, and CMGA) have jointly advocated for a load factor assumption of 85% or higher, as compared to Ridgeline's originally proposed 100% load factor. Ridgeline is considering a modified approach to the load factor assumption, taking into account the system's historical throughput data, the terms of existing precedent agreements, and the expected utilization of the pipeline over the initial rate period. Any modification to the load factor assumption would require a corresponding adjustment to the billing determinants, the reservation and usage charges, and the overall rate design.

These negotiations are proceeding constructively, and Ridgeline is optimistic that continued discussions during the requested extension period may result in agreement or substantial narrowing of the parties' positions on one or more of these issues. Filing a redesigned tariff before these negotiations have had a reasonable opportunity to progress would likely result in an unnecessary proliferation of contested issues and could necessitate additional rounds of testimony and discovery, thereby extending rather than shortening the overall duration of this proceeding. The requested extension serves the interest of administrative efficiency by allowing the tariff redesign to be informed by the results of these negotiations to the greatest extent practicable.

D. No Prejudice to Other Parties

No party to this proceeding will be prejudiced by the requested 180-day extension. The procedural schedule in this proceeding has been stayed since February 6, 2023, pursuant to ALJ Whitfield's order. No testimony deadlines, discovery obligations, or hearing dates are currently pending, and no party faces an imminent regulatory obligation or deadline that would be adversely affected by the extension.

The Ridgeline Pipeline System continues to operate at approximately 680 MMcf/d, representing approximately 56.67% utilization of the system's 1.2 Bcf/d design capacity. Pipeline operations are not contingent on Commission approval of the proposed tariff, and the extension of the tariff filing deadline will not affect the physical operation of the pipeline or the availability of transportation service to existing shippers.

Similarly, ATPC's existing operations on its 640-mile, 3.8 Bcf/d pipeline system are unaffected by the requested extension. The Wetzel County Interconnect is a new interconnection that has not yet been constructed or placed into service, and the delay in finalizing the tariff and interconnection authorization does not impair ATPC's existing system operations or the transportation service available to ATPC's existing shippers.

MGPC's fourteen member producers continue to access natural gas transportation services through existing contractual arrangements on other pipeline systems, and the requested extension does not interfere with their current production, gathering, or transportation activities. CMGA's gas supply is similarly unaffected, as CMGA continues to receive natural gas through its existing service arrangements and is not dependent on the Ridgeline Pipeline System for its current supply.

In sum, the requested extension imposes no operational, financial, or regulatory burden on any party, and the maintenance of the current stay of the procedural schedule during the extension period ensures that no party will be required to incur litigation costs or meet procedural deadlines while the tariff redesign is being completed.

E. Good Cause Shown

Ridgeline respectfully submits that it has demonstrated good cause for the requested extension, as required by 18 C.F.R. § 385.2008. The relevant considerations supporting a finding of good cause include the following:

First, Ridgeline has acted with diligence throughout this proceeding. Upon receiving the Deficiency Letter on January 19, 2023, Ridgeline immediately commenced work on a comprehensive response. Within approximately two months, on March 15, 2023, Ridgeline filed a partial response addressing eight of the fourteen deficiency items — more than half of the identified deficiencies. Ridgeline then promptly retained Braswell Energy Consulting Group, a highly qualified regulatory consulting firm led by a former Commission economist with deep expertise in natural gas pipeline rate design and tariff matters, to assist with the remaining six items.

Second, the six remaining deficiency items are among the most complex and novel items identified in the Deficiency Letter. Items 13 (GHG emission cost recovery) and 14 (Order No. 2222 DER aggregation implications) involve emerging areas of regulatory policy for which established Commission precedent is limited, and which require analysis of rapidly evolving federal and state policy developments. The development of durable and defensible tariff provisions addressing these items requires careful research, analysis, and stakeholder consultation that cannot be completed within the current deadline.

Third, Ridgeline has actively participated in the settlement process and has engaged in good-faith bilateral negotiations with the intervenors. Three settlement conferences have been held (November 30, 2022; March 8, 2023; July 12, 2023), and Ridgeline has maintained ongoing discussions with ATPC, MGPC, and CMGA regarding key tariff provisions. The requested extension will provide additional time for these negotiations to progress, potentially narrowing the scope of contested issues and promoting the efficient resolution of this proceeding.

Fourth, no party opposes the requested extension, and no party will be prejudiced by the grant of additional time.

For all of these reasons, Ridgeline submits that good cause exists for the requested 180-day extension.

IV. PROPOSED NEW DEADLINE

Based on the foregoing, Ridgeline respectfully requests that the deadline for filing the complete response to the Deficiency Letter, including the redesigned FERC Gas Tariff, Original Volume No. 1, and any supplemental testimony, be extended by one hundred eighty (180) days from the current deadline of August 28, 2023 to February 23, 2024.

This proposed timeline is consistent with the expected completion of Braswell's comprehensive tariff redesign work and the anticipated progression of stakeholder negotiations during the extension period. Ridgeline has carefully considered the scope of work remaining and is confident that the proposed deadline of February 23, 2024 provides adequate time to develop and file a comprehensive, internally consistent redesigned tariff that addresses all fourteen deficiency items identified in the Deficiency Letter.

Ridgeline commits to continuing its diligent efforts to complete the tariff redesign as expeditiously as possible and to keeping all parties and the Presiding Judge informed of material developments in the tariff redesign work and the stakeholder negotiation process. In the event that the tariff redesign is completed prior to the proposed February 23, 2024 deadline, Ridgeline will file its complete response at the earliest practicable date. In the event that unforeseen circumstances arise that could affect Ridgeline's ability to meet the proposed deadline, Ridgeline will promptly notify the Presiding Judge and the parties.

A summary of the proposed revised procedural timeline is set forth in Appendix A to this Motion.

V. COMMUNICATIONS WITH OTHER PARTIES

Pursuant to 18 C.F.R. § 385.2008(a) and the Presiding Judge's standing procedural order, undersigned counsel has communicated with counsel for all active parties in this proceeding regarding the substance of this motion prior to its filing. The positions of the parties are as follows:

Appalachian Trunk Pipeline Company, LLC ("ATPC"). Undersigned counsel communicated with William Pratt of Kellner, Royce & Dillard LLP, counsel for ATPC. Mr. Pratt has indicated that ATPC does not oppose the requested 180-day extension. ATPC reserves all rights regarding the substance of Ridgeline's tariff redesign and any positions it may take with respect to the redesigned tariff and supplemental testimony when filed.

Mountainside Gas Producers Coalition ("MGPC"). Undersigned counsel communicated with Rebekah Montague of Whitmore & Sable LLP, counsel for MGPC. Ms. Montague has indicated that MGPC does not oppose the requested 180-day extension.

Clearwater Municipal Gas Authority ("CMGA"). Undersigned counsel communicated with Stephen Greer of Fordham Municipal Law Group PC, counsel for CMGA. Mr. Greer has indicated that CMGA does not oppose the requested 180-day extension.

FERC Trial Staff. Undersigned counsel communicated with Jonathan Briggs, Lead Trial Attorney, Office of General Counsel, Federal Energy Regulatory Commission. Mr. Briggs has been informed of the intended motion and has communicated no objection.

No party has indicated opposition to the requested extension.

VI. REQUEST FOR RELIEF

WHEREFORE, Ridgeline Midstream Services LLC respectfully requests that the Presiding Administrative Law Judge, the Honorable Clara Whitfield, enter an order:

1. Granting this Motion for Extension of Time;

2. Extending the deadline for Ridgeline to file its complete response to the January 19, 2023 Deficiency Letter issued by the Office of Energy Market Regulation, including the redesigned FERC Gas Tariff, Original Volume No. 1, and any supplemental testimony, from August 28, 2023 to February 23, 2024;

3. Continuing the stay of the procedural schedule in this proceeding pending Ridgeline's filing of its complete response; and

4. Granting such other and further relief as may be just and appropriate.

Respectfully submitted,

CALDERWOOD & HARKNESS LLP

By: ________

George Trujillo Responsible Partner, Energy & Infrastructure

Brett Callahan Lead Associate, Energy & Infrastructure

David Stanton Working Associate, Energy & Infrastructure

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

Counsel for Ridgeline Midstream Services LLC

Date: August 25, 2023

CERTIFICATE OF SERVICE

I hereby certify that on August 25, 2023, a copy of the foregoing Motion of Ridgeline Midstream Services LLC for Extension of Time to Complete Response to Deficiency Letter was served upon all parties on the official service list in Docket Nos. RP22-847-000 and RP22-847-001, by electronic filing through the Commission's eFiling system and by first-class United States mail, postage prepaid, addressed to the following:

Kimberly D. Bose, 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, Esq. Kellner, Royce & Dillard LLP One PPG Place, Suite 2800 Pittsburgh, PA 15222 Counsel for Appalachian Trunk Pipeline Company, LLC

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

Stephen Greer, Esq. 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

Date: August 25, 2023

APPENDIX A

PROPOSED REVISED PROCEDURAL TIMELINE (SUMMARY)

This summary is provided for informational purposes and is not intended to bind the Presiding Judge or the parties to any particular schedule for subsequent proceedings. The procedural schedule following Ridgeline's filing of its complete response will be established by the Presiding Judge in consultation with the parties.

Ridgeline Midstream Services LLC	Docket Nos. RP22-847-000
(FERC Code: 960442)	RP22-847-001

Application for Initial Tariff Rate

and Interconnection Authorization

Milestone	Date / Timeframe	Notes
Current Deadline for Response to Deficiency Letter	August 28, 2023	Established by ALJ Whitfield's Order dated May 10, 2023 (granting first extension)
Proposed New Deadline for Complete Response	February 23, 2024	Extension of 180 days from current deadline
Extension Period	180 days	August 28, 2023 through February 23, 2024
Anticipated Milestone: Completion of Braswell Tariff Redesign Work	Q4 2023 / Q1 2024	Includes rate design modeling, NAESB gap analysis, tariff drafting, and internal consistency review
Anticipated Milestone: Filing of Redesigned Tariff and Supplemental Testimony	On or before February 23, 2024	Complete response to all 14 deficiency items, including redesigned FERC Gas Tariff, Original Volume No. 1, and supplemental testimony
Subsequent Steps: Resumption of Procedural Schedule	To be determined by ALJ upon filing	Answering testimony, discovery, and hearing schedule to be set by ALJ Whitfield following Ridgeline's filing of complete response

UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION
MOTION OF RIDGELINE MIDSTREAM SERVICES LLC FOR EXTENSION OF TIME TO COMPLETE RESPONSE TO DEFICIENCY LETTER
Filed: August 25, 2023 C&H Matter No. 1016-00005
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I. PRELIMINARY STATEMENT
Ridgeline Midstream Services LLC ("Ridgeline" or "Applicant"), a Delaware limited liability company and a wholly owned subsidiary of Dunmore Energy Holdings Ltd. ("DEH"), a Cayman Islands exempted limited company, by and through its undersigned counsel, Calderwood & Harkness LLP, respectfully moves the Presiding Administrative Law Judge, the Honorable Clara Whitfield, pursuant to Section 385.2008 of the Commission's Rules of Practice and Procedure, 18 C.F.R. § 385.2008, for an extension of one hundred eighty (180) days — from the current deadline of August 28, 2023 to February 23, 2024 — to complete its response to the Deficiency Letter issued by the Commission's Office of Energy Market Regulation ("OEMR") on January 19, 2023 (the "Deficiency Letter").
Ridgeline's principal office is located at 700 Kanawha Boulevard East, Suite 1400, Charleston, West Virginia 25301. Ridgeline is the owner and operator of the Ridgeline Pipeline System, a 187-mile high-pressure interstate natural gas pipeline extending from Wetzel County, West Virginia to Greene County, Pennsylvania. The instant application, filed on May 12, 2022, seeks Commission approval of an initial tariff rate for interstate natural gas transportation service on the Ridgeline Pipeline System and authorization for physical interconnection with Appalachian Trunk Pipeline Company, LLC ("ATPC") at the Wetzel County Interconnect.
As set forth more fully below, this is Ridgeline's second motion for extension of time in this proceeding. The first extension, which was granted by Judge Whitfield on May 10, 2023, provided an additional 120 days to respond to the Deficiency Letter, establishing the current August 28, 2023 deadline. Notwithstanding Ridgeline's diligent and good-faith efforts to complete the tariff redesign required by the Deficiency Letter — including the retention of Braswell Energy Consulting Group LLC ("Braswell"), a leading energy regulatory consulting firm led by Dr. Raymond Braswell, a former Commission economist — the scope, complexity, and novelty of the six remaining deficiency items necessitate additional time.
Ridgeline submits that good cause exists for the requested extension. The six remaining deficiency items involve the development of substantial new tariff provisions — including capacity release mechanisms, NAESB standards compliance, creditworthiness provisions, segmentation and flexible receipt/delivery point provisions, greenhouse gas emission cost recovery provisions, and Order No. 2222 distributed energy resource aggregation provisions — that were not part of Ridgeline's original filing and that raise novel regulatory questions for which established Commission precedent is limited or evolving. The requested 180-day extension will afford Ridgeline and its consultants adequate time to develop a comprehensive, internally consistent redesigned tariff that addresses all fourteen deficiency items, while simultaneously permitting the productive continuation of stakeholder negotiations that have the potential to narrow disputed issues and promote the efficient resolution of this proceeding.
No party opposes this motion. As described in Section V below, undersigned counsel has communicated with counsel for all active parties in this proceeding, and no party has interposed an objection to the requested extension.
II. BACKGROUND AND PROCEDURAL HISTORY
A. The Filing and Initial Proceedings
On May 12, 2022, Ridgeline filed its application with the Commission in the above-captioned docket, seeking approval of an initial tariff rate for interstate natural gas transportation service on the Ridgeline Pipeline System and authorization for physical interconnection with ATPC at the Wetzel County Interconnect (Wetzel County, West Virginia). The application was filed pursuant to Sections 4 and 7 of the Natural Gas Act, 15 U.S.C. §§ 717c and 717f, and the Commission's regulations at 18 C.F.R. Parts 154, 157, and 284.
The Ridgeline Pipeline System is a 187-mile, 24-inch-diameter high-pressure natural gas pipeline extending from the Wetzel County Interconnect in Wetzel County, West Virginia, to the Waynesburg Compressor Station in Greene County, Pennsylvania. The system has a design capacity of 1.2 billion cubic feet per day ("Bcf/d") (1,200,000 dekatherms per day ("Dth/d")) and a current throughput of approximately 680 million cubic feet per day ("MMcf/d"), representing approximately 56.67% utilization of design capacity. The system includes three compressor stations with aggregate installed compression of 45,000 horsepower ("HP"). The Ridgeline Pipeline System was placed in service on October 1, 2021.
In its application, Ridgeline proposed a FERC Gas Tariff, Original Volume No. 1, structured as a Part 284, Subpart G open-access transportation tariff. The proposed recourse rate was $0.2265 per Dth, consisting of a reservation charge of $0.2223 per Dth and a usage charge of $0.0042 per Dth. The proposed recourse rate was derived from a total cost of service of $97.36 million and billing determinants of 438,000,000 Dth per year, based on a 100% load factor assumption.
Ridgeline's proposed rate base, as filed, was $612.40 million. The proposed return on equity ("ROE") was 14.00%, based on a capital structure consisting of 55% equity and 45% debt, a cost of debt of 5.25%, and a weighted average cost of capital ("WACC") of 10.0625%. These financial parameters were supported by the pre-filed testimony of Ridgeline's rate and financial witnesses, as discussed further below.
B. Interventions and Protests
On June 14, 2022, the Commission issued a Notice of Filing in this proceeding, which was published in the Federal Register on June 17, 2022, and established an intervention and protest deadline of August 15, 2022. Three entities filed motions to intervene and/or protests during the intervention period, as follows:
Mountainside Gas Producers Coalition ("MGPC"). On July 28, 2022, MGPC, an unincorporated association of fourteen independent natural gas producers operating in the Appalachian Basin, filed a timely motion to intervene and comments. MGPC expressed general support for the proposed interconnection with ATPC, noting that the interconnection would enhance market access for its member producers. However, MGPC opposed Ridgeline's proposed recourse rate as excessive and unjust, advocating that any approved recourse rate should not exceed approximately $0.2560 per Dth. MGPC asserted that Ridgeline's proposed 14.00% ROE was significantly above the zone of reasonableness established by Commission precedent and would impose an undue burden on shippers.
Clearwater Municipal Gas Authority ("CMGA"). On August 1, 2022, CMGA, a municipal gas distribution utility serving approximately 12,000 residential and commercial customers in Clearwater, Pennsylvania and surrounding communities, filed a timely motion to intervene and comments. CMGA expressed concern that the proposed interconnection configuration and cost allocation could result in rate increases on ATPC's system, which would adversely affect CMGA's ratepayers. CMGA requested that the Commission ensure that any approved interconnection and tariff structure would not result in the unjust allocation of costs to ATPC's existing shippers.
Appalachian Trunk Pipeline Company, LLC ("ATPC"). On August 15, 2022, the final day of the intervention period, ATPC filed a protest and motion to intervene. ATPC is the owner and operator of the Appalachian Trunk Pipeline, a 640-mile interstate natural gas pipeline system with a capacity of 3.8 Bcf/d. ATPC opposed the proposed interconnection configuration at the Wetzel County Interconnect, asserting that Ridgeline's proposed design imposed unnecessary operational constraints on ATPC's existing system. ATPC also challenged Ridgeline's proposed cost allocation methodology for the interconnection facilities, arguing that Ridgeline's proposal improperly shifted approximately $14.7 million in interconnection facilities costs to ATPC's shippers. The total cost of interconnection facilities was estimated at $22.3 million, and ATPC asserted that a 50/50 cost split ($11.15 million each) would be more appropriate than Ridgeline's proposed 34.1%/65.9% allocation ($7.6 million Ridgeline / $14.7 million ATPC).
On September 22, 2022, the Commission issued an order granting all three motions to intervene, setting a Track II procedural schedule for the proceeding, and appointing Settlement Judge Howard Margolis to convene settlement conferences and explore the possibility of a negotiated resolution of the disputed issues.
C. Testimony Phase
On November 14, 2022, Administrative Law Judge Clara Whitfield was designated as the Presiding Judge in this proceeding and held a prehearing conference on the same date. The prehearing conference established a schedule for the filing of pre-filed testimony and the conduct of discovery.
On December 5, 2022, Ridgeline filed pre-filed direct testimony of seven witnesses in support of its application. The testimony included, among others, the following witnesses and subject matter areas:
•  James K. Winfield, Chief Executive Officer, Ridgeline Midstream Services LLC — policy testimony addressing the need for service on the Ridgeline Pipeline System, the benefits of the proposed interconnection with ATPC, and the overall public interest in approval of the application;
•  Angela Moretti, Vice President of Finance and Treasurer, Ridgeline Midstream Services LLC — cost-of-service testimony and rate base support, including detailed schedules of capital costs, operating expenses, depreciation, taxes, and working capital;
•  Thomas Greaves, Vice President of Engineering and Operations, Ridgeline Midstream Services LLC — engineering and system design testimony, including pipeline specifications, compressor station configurations, and the design and operational characteristics of the Wetzel County Interconnect;
•  Dr. Natasha Orlov, Director of Rates and Regulatory, Ridgeline Midstream Services LLC — rate design and tariff provisions testimony, including the derivation of the proposed reservation and usage charges, the proposed billing determinants, and the terms and conditions of the proposed FERC Gas Tariff, Original Volume No. 1; and
•  Dr. Raymond Braswell, independent expert witness — return on equity and capital structure testimony, including a discounted cash flow ("DCF") analysis, a Capital Asset Pricing Model ("CAPM") analysis, a risk premium analysis, and a comparable earnings analysis supporting the proposed 14.00% ROE.
On January 9, 2023, answering testimony was filed by all three intervenors. ATPC filed answering testimony through its counsel, Kellner, Royce & Dillard LLP (lead counsel William Pratt), addressing the interconnection configuration and cost allocation. MGPC filed answering testimony through its counsel, Whitmore & Sable LLP (lead counsel Rebekah Montague), including the testimony of rate expert Dr. Eleanor Vasquez, who challenged Ridgeline's proposed ROE and recommended an ROE of 11.25%. CMGA filed answering testimony through its counsel, Fordham Municipal Law Group PC (lead counsel Stephen Greer), addressing the potential impact of the proceeding on ATPC's existing shippers and CMGA's ratepayers.
D. The Deficiency Letter and Stay of Procedural Schedule
On January 19, 2023, the Commission's Office of Energy Market Regulation, through lead economic analyst Dr. Miriam Okafor and lead trial attorney Jonathan Briggs, issued the Deficiency Letter identifying fourteen (14) separate deficiencies in Ridgeline's tariff filing. The Deficiency Letter required Ridgeline to undertake a comprehensive tariff redesign to address the identified deficiencies. The fourteen deficiency items are as follows:
1.  Inadequate cost-of-service support for proposed 14.00% ROE (no updated proxy group analysis post-2021);
2.  Failure to include a fuel-use and lost-and-unaccounted-for gas ("FL&U") tracker mechanism;
3.  Missing interruptible transportation ("IT") rate derivation;
4.  Insufficient support for 100% load factor billing determinant assumption;
5.  No capacity release provisions in General Terms & Conditions;
6.  Incomplete NAESB standards compliance in operational flow order provisions;
7.  Missing electronic bulletin board ("EBB") posting requirements;
8.  Inadequate shipper-must-have-title provisions;
9.  Interconnection agreement not filed as a rate schedule;
10.  No penalty revenue crediting mechanism;
11.  Inadequate creditworthiness provisions;
12.  Missing segmentation and flexible receipt/delivery point provisions;
13.  No provisions addressing greenhouse gas emission cost recovery; and
14.  Failure to address Order No. 2222 distributed energy resource aggregation implications (renewable energy interconnection).
The Deficiency Letter was comprehensive in scope and required Ridgeline to develop substantial new tariff provisions that had not been included in its original filing. The deficiency items ranged from relatively straightforward tariff drafting matters (such as the EBB posting requirements and shipper-must-have-title provisions) to complex and novel regulatory questions (such as greenhouse gas emission cost recovery and Order No. 2222 DER aggregation implications).
On February 6, 2023, ALJ Whitfield issued an order staying the procedural schedule in this proceeding pending Ridgeline's response to the Deficiency Letter. The order noted that it would be premature to proceed with the hearing schedule until the deficiencies identified by OEMR had been addressed, and that the stay would remain in effect until further order of the Presiding Judge.
E. Partial Response and First Extension
On March 15, 2023, approximately two months after receiving the Deficiency Letter, Ridgeline filed a partial response addressing eight of the fourteen deficiency items. Specifically, Ridgeline's partial response addressed:
•  Item 1 (ROE cost-of-service support) — Ridgeline provided an updated proxy group analysis and supplemental DCF and CAPM analyses reflecting market data through December 31, 2022;
•  Item 2 (FL&U tracker mechanism) — Ridgeline proposed a fuel-use and lost-and-unaccounted-for gas tracker consistent with Commission precedent;
•  Item 3 (IT rate derivation) — Ridgeline provided a derivation of interruptible transportation rates based on the 100% load factor reservation rate;
•  Item 4 (100% load factor support) — Ridgeline provided additional support for its 100% load factor billing determinant assumption, including precedent agreement data and historical throughput information;
•  Item 7 (EBB posting requirements) — Ridgeline proposed comprehensive electronic bulletin board posting provisions;
•  Item 8 (shipper-must-have-title provisions) — Ridgeline revised its General Terms & Conditions to include appropriate shipper-must-have-title language;
•  Item 9 (interconnection agreement as rate schedule) — Ridgeline filed the interconnection agreement with ATPC as a rate schedule under its proposed FERC Gas Tariff; and
•  Item 10 (penalty revenue crediting mechanism) — Ridgeline proposed a penalty revenue crediting mechanism consistent with Commission policy.
Six deficiency items remained unaddressed in the partial response: Item 5 (capacity release provisions), Item 6 (NAESB standards compliance), Item 11 (creditworthiness provisions), Item 12 (segmentation and flexible receipt/delivery point provisions), Item 13 (greenhouse gas emission cost recovery), and Item 14 (Order No. 2222/DER aggregation implications). These remaining items are the most complex and novel of the fourteen deficiency items and require the development of substantial new tariff provisions, as discussed further in Section III below.
On April 15, 2023, recognizing the need for specialized expertise to address the remaining deficiency items, Ridgeline engaged Braswell Energy Consulting Group LLC ("Braswell"), a regulatory consulting firm led by Dr. Raymond Braswell, a former Commission economist and the expert witness who had provided Ridgeline's ROE and capital structure testimony in this proceeding. The engagement (engagement number BEC-2023-0041) covers a comprehensive tariff redesign encompassing all six remaining deficiency items, as well as the integration of the redesigned provisions into a coherent and internally consistent FERC Gas Tariff, Original Volume No. 1.
On April 28, 2023, Ridgeline filed its first motion for extension of time, requesting a 120-day extension of the deadline to complete its response to the Deficiency Letter. The motion cited the complexity of the remaining deficiency items and the need for additional time to complete the tariff redesign with the assistance of Braswell. No party opposed the first extension.
On May 10, 2023, ALJ Whitfield granted Ridgeline's first motion for extension of time, extending the deadline for Ridgeline to file its complete response to the Deficiency Letter from the then-current deadline to August 28, 2023. The order noted that Ridgeline had demonstrated good cause for the extension and that the procedural schedule would remain stayed pending the filing.
F. Settlement Activity
Settlement conferences have been held at three points during this proceeding, each convened before Settlement Judge Howard Margolis. The first settlement conference was held on November 30, 2022, shortly after ALJ Whitfield's appointment as Presiding Judge. The second settlement conference was held on March 8, 2023, following Ridgeline's filing of its partial response to the Deficiency Letter. The third and most recent settlement conference was held on July 12, 2023.
Despite the good-faith efforts of all parties, no settlement has been reached. The parties remain significantly apart on several key issues, including the appropriate ROE, the interconnection cost allocation between Ridgeline and ATPC, and the proper load factor assumption for billing determinant purposes. However, the ongoing bilateral negotiations described in Section III.C below continue to hold promise for narrowing the range of disputed issues.
III. GROUNDS FOR THE REQUESTED EXTENSION
Ridgeline respectfully submits that good cause exists for the requested 180-day extension, from August 28, 2023 to February 23, 2024, based on the following grounds.
A. Scope and Complexity of the Remaining Tariff Redesign
The six remaining deficiency items — Items 5, 6, 11, 12, 13, and 14 — require the development of substantial new tariff provisions that were not part of Ridgeline's original filing. Each of these items involves complex regulatory, technical, and policy considerations, and several raise novel questions for which established Commission precedent is limited, evolving, or subject to ongoing industry development. The scope and complexity of each remaining item is summarized below.
Item 5 — Capacity Release Provisions. The Deficiency Letter requires Ridgeline to develop comprehensive capacity release provisions in the General Terms & Conditions of its proposed FERC Gas Tariff. The capacity release program must be consistent with the Commission's open-access policies under 18 C.F.R. Part 284 and applicable Commission orders, including Order Nos. 636, 636-A, and 636-B, as well as more recent guidance. The required provisions include, but are not limited to, shipper rights to release firm transportation capacity, posting requirements for capacity available for release, bidding procedures for released capacity, terms governing prearranged deals, provisions for recall and reput of released capacity, rate caps on released capacity, and the allocation of released capacity among competing bidders. Development of these provisions requires careful analysis of the operational characteristics of the Ridgeline Pipeline System and coordination with NAESB WGQ standards applicable to capacity release transactions.
Item 6 — NAESB Standards Compliance. The Deficiency Letter identified incomplete compliance with the standards promulgated by the North American Energy Standards Board, Wholesale Gas Quadrant ("NAESB WGQ"). Ridgeline is required to conduct a full gap analysis of its proposed tariff against NAESB WGQ Version 3.2 standards, covering operational flow orders, scheduling, nominations, and balancing. This is a highly technical undertaking that requires a detailed comparison of each provision of Ridgeline's proposed tariff with the corresponding NAESB standard, identification of gaps and inconsistencies, and the drafting of revised tariff language to achieve full compliance. The gap analysis must encompass not only the operational flow order provisions specifically identified in the Deficiency Letter but also related provisions governing nominations, scheduling, confirmations, allocations, imbalance management, and operational balancing agreements. Given the interdependencies among these provisions, the NAESB compliance effort requires a holistic review and revision of substantial portions of the General Terms & Conditions.
Item 11 — Creditworthiness Provisions. The Deficiency Letter requires Ridgeline to develop comprehensive creditworthiness provisions that meet Commission standards. The required provisions include criteria for evaluating the creditworthiness of prospective and existing shippers, collateral posting requirements (including the types of acceptable collateral, such as letters of credit, surety bonds, guarantees, and cash deposits), the calculation of unsecured credit limits, credit rating thresholds (including minimum investment-grade rating requirements), procedures for monitoring and reassessing shipper creditworthiness on an ongoing basis, and remedies available to Ridgeline in the event of a shipper's credit deterioration, including the right to demand additional collateral, suspend service, or terminate service agreements. These provisions must be carefully crafted to protect Ridgeline's financial interests while ensuring that the creditworthiness requirements are not unduly restrictive or discriminatory.
Item 12 — Segmentation and Flexible Receipt/Delivery Point Provisions. The Deficiency Letter requires Ridgeline to include provisions in its tariff permitting shippers to segment their firm transportation capacity and to designate alternative receipt and delivery points on the 187-mile Ridgeline Pipeline System. The development of segmentation provisions requires analysis of the system's physical and operational characteristics, including the location and capacity of receipt and delivery points, compressor station configurations, and the hydraulic constraints of the pipeline. Flexible receipt and delivery point provisions must address the conditions under which shippers may designate alternative points, the scheduling priority of primary versus secondary point designations, and any capacity limitations or operational constraints that may apply at particular receipt and delivery points. These provisions have significant implications for the rate design and billing determinants, as the availability of segmentation and flexible points may affect the utilization of the system and the allocation of costs among shippers.
Item 13 — Greenhouse Gas Emission Cost Recovery. The Deficiency Letter requires Ridgeline to address the recovery of greenhouse gas ("GHG") emission costs through its tariff. This is an area of emerging and unsettled regulatory policy at both the federal and state levels. The development of GHG cost recovery provisions requires analysis of potential carbon pricing mechanisms — including federal carbon tax proposals, state-level carbon pricing programs (such as the Regional Greenhouse Gas Initiative, or "RGGI," in which several states in the pipeline's operating region participate or are considering participation), and voluntary carbon offset markets — and the design of a GHG cost tracker or passthrough provision that allows Ridgeline to recover prudently incurred GHG compliance costs without placing undue risk on either the pipeline or its shippers. Given the rapidly evolving nature of federal and state GHG policy, the design of a durable and flexible GHG cost recovery mechanism presents significant analytical and drafting challenges.
Item 14 — Order No. 2222 Distributed Energy Resource Aggregation Implications. The Deficiency Letter requires Ridgeline to address the implications of FERC Order No. 2222, which established rules governing the participation of distributed energy resource ("DER") aggregations in wholesale electricity markets, for the Ridgeline Pipeline System. While Order No. 2222 was directed primarily at regional transmission organizations and independent system operators in the electric sector, the Deficiency Letter requires Ridgeline to consider the implications of DER aggregation for renewable energy interconnection with the Ridgeline Pipeline System. This is a particularly relevant issue given that Ridgeline's parent company, DEH, has a 250-megawatt ("MW") wind portfolio under development in the Appalachian region, which could potentially involve the co-location of renewable energy generation and natural gas pipeline infrastructure. The intersection of DER aggregation with midstream natural gas pipeline tariffs is a novel issue for which there is limited Commission precedent, and the development of appropriate tariff provisions requires careful analysis of the regulatory landscape and emerging industry practices.
The six remaining deficiency items are not independent of one another. Rather, they are deeply interconnected, and the resolution of each item has implications for the others. For example, the capacity release provisions (Item 5) must be consistent with the NAESB standards (Item 6); the segmentation and flexible point provisions (Item 12) affect the billing determinants and rate design, which in turn are affected by the GHG cost recovery provisions (Item 13); and the creditworthiness provisions (Item 11) must account for the credit implications of capacity release transactions (Item 5) and GHG cost obligations (Item 13). Accordingly, the tariff redesign cannot proceed in a piecemeal fashion but must be developed as an integrated, internally consistent whole. This comprehensive approach is essential to producing a tariff filing that will withstand scrutiny and promote the efficient resolution of this proceeding.
B. Braswell Energy Consulting Group Engagement and Work Status
As noted above, Ridgeline engaged Braswell Energy Consulting Group LLC on April 15, 2023, under engagement number BEC-2023-0041, approximately four and a half months ago. Dr. Raymond Braswell, the firm's founder and principal, has assembled a team of regulatory economists, rate design specialists, and tariff drafting professionals to assist Ridgeline with the comprehensive tariff redesign required by the Deficiency Letter.
Since the engagement commenced, Dr. Braswell and his team have been conducting a thorough analysis of the tariff redesign requirements for each of the six remaining deficiency items. This work has included the development of the analytical framework for a modified fixed-variable rate methodology, the recalculation and testing of revised billing determinants under various load factor assumptions, and the preliminary drafting of new tariff provisions addressing capacity release, NAESB compliance, creditworthiness, segmentation and flexible points, GHG cost recovery, and Order No. 2222 implications.
Braswell's work is ongoing and has proven to be more complex and time-consuming than initially anticipated, particularly with respect to Items 13 (GHG cost recovery) and 14 (Order No. 2222/DER aggregation), which involve novel regulatory questions and require analysis of rapidly evolving federal and state policy developments. Dr. Braswell has informed Ridgeline that additional time is needed to develop and test the revised rate design model, to complete the NAESB WGQ Version 3.2 gap analysis, and to ensure consistency across all sections of the redesigned tariff. Braswell has further advised that the integrated nature of the tariff redesign — in which each provision must be consistent with and informed by every other provision — requires a sequential and iterative drafting process that cannot be significantly compressed without sacrificing the quality and coherence of the final product.
Based on Braswell's current work plan and resource allocation, Ridgeline expects that the tariff redesign work will be substantially completed during the fourth quarter of 2023 and the first quarter of 2024, with the final integrated tariff and supplemental testimony ready for filing on or before February 23, 2024.
C. Stakeholder Negotiations
In addition to the tariff redesign work, Ridgeline has been engaged in ongoing bilateral negotiations with the intervenors in this proceeding regarding key elements of the tariff filing. These negotiations have been conducted in parallel with the tariff redesign and have the potential to narrow the range of disputed issues, thereby promoting the efficient resolution of the proceeding.
The principal areas of ongoing negotiation are as follows:
Interconnection Cost Allocation. Ridgeline and ATPC (through its counsel, William Pratt of Kellner, Royce & Dillard LLP) have been engaged in discussions regarding the allocation of the approximately $22.3 million in total interconnection facilities costs at the Wetzel County Interconnect. ATPC has consistently advocated for a 50/50 cost split, which would allocate approximately $11.15 million to each party. Ridgeline's original filing proposed a 34.1%/65.9% cost allocation, under which Ridgeline would bear approximately $7.6 million and ATPC's shippers would bear approximately $14.7 million. The parties have exchanged analyses and counter-proposals but have not yet reached agreement on this issue. Ridgeline believes that continued negotiations, informed by the tariff redesign work, may produce a mutually acceptable cost allocation that could be incorporated into the redesigned tariff.
Return on Equity. The appropriate ROE remains a significant area of dispute. ATPC has proposed an ROE of 10.75%, and MGPC (through its counsel, Rebekah Montague of Whitmore & Sable LLP, and its rate expert, Dr. Eleanor Vasquez) has proposed an ROE of 11.25%. Ridgeline's original filing proposed an ROE of 14.00%, which is acknowledged to be at the upper end of the range. Based on updated market data and the supplemental analyses provided in the March 15, 2023 partial response, Ridgeline is evaluating a potential reduction from the originally proposed 14.00% ROE. A revised ROE position would have direct implications for the cost of service, the rate base, the billing determinants, and the overall recourse rate, and would need to be fully integrated into the redesigned tariff.
Load Factor. The intervenors (ATPC, MGPC, and CMGA) have jointly advocated for a load factor assumption of 85% or higher, as compared to Ridgeline's originally proposed 100% load factor. Ridgeline is considering a modified approach to the load factor assumption, taking into account the system's historical throughput data, the terms of existing precedent agreements, and the expected utilization of the pipeline over the initial rate period. Any modification to the load factor assumption would require a corresponding adjustment to the billing determinants, the reservation and usage charges, and the overall rate design.
These negotiations are proceeding constructively, and Ridgeline is optimistic that continued discussions during the requested extension period may result in agreement or substantial narrowing of the parties' positions on one or more of these issues. Filing a redesigned tariff before these negotiations have had a reasonable opportunity to progress would likely result in an unnecessary proliferation of contested issues and could necessitate additional rounds of testimony and discovery, thereby extending rather than shortening the overall duration of this proceeding. The requested extension serves the interest of administrative efficiency by allowing the tariff redesign to be informed by the results of these negotiations to the greatest extent practicable.
D. No Prejudice to Other Parties
No party to this proceeding will be prejudiced by the requested 180-day extension. The procedural schedule in this proceeding has been stayed since February 6, 2023, pursuant to ALJ Whitfield's order. No testimony deadlines, discovery obligations, or hearing dates are currently pending, and no party faces an imminent regulatory obligation or deadline that would be adversely affected by the extension.
The Ridgeline Pipeline System continues to operate at approximately 680 MMcf/d, representing approximately 56.67% utilization of the system's 1.2 Bcf/d design capacity. Pipeline operations are not contingent on Commission approval of the proposed tariff, and the extension of the tariff filing deadline will not affect the physical operation of the pipeline or the availability of transportation service to existing shippers.
Similarly, ATPC's existing operations on its 640-mile, 3.8 Bcf/d pipeline system are unaffected by the requested extension. The Wetzel County Interconnect is a new interconnection that has not yet been constructed or placed into service, and the delay in finalizing the tariff and interconnection authorization does not impair ATPC's existing system operations or the transportation service available to ATPC's existing shippers.
MGPC's fourteen member producers continue to access natural gas transportation services through existing contractual arrangements on other pipeline systems, and the requested extension does not interfere with their current production, gathering, or transportation activities. CMGA's gas supply is similarly unaffected, as CMGA continues to receive natural gas through its existing service arrangements and is not dependent on the Ridgeline Pipeline System for its current supply.
In sum, the requested extension imposes no operational, financial, or regulatory burden on any party, and the maintenance of the current stay of the procedural schedule during the extension period ensures that no party will be required to incur litigation costs or meet procedural deadlines while the tariff redesign is being completed.
E. Good Cause Shown
Ridgeline respectfully submits that it has demonstrated good cause for the requested extension, as required by 18 C.F.R. § 385.2008. The relevant considerations supporting a finding of good cause include the following:
First, Ridgeline has acted with diligence throughout this proceeding. Upon receiving the Deficiency Letter on January 19, 2023, Ridgeline immediately commenced work on a comprehensive response. Within approximately two months, on March 15, 2023, Ridgeline filed a partial response addressing eight of the fourteen deficiency items — more than half of the identified deficiencies. Ridgeline then promptly retained Braswell Energy Consulting Group, a highly qualified regulatory consulting firm led by a former Commission economist with deep expertise in natural gas pipeline rate design and tariff matters, to assist with the remaining six items.
Second, the six remaining deficiency items are among the most complex and novel items identified in the Deficiency Letter. Items 13 (GHG emission cost recovery) and 14 (Order No. 2222 DER aggregation implications) involve emerging areas of regulatory policy for which established Commission precedent is limited, and which require analysis of rapidly evolving federal and state policy developments. The development of durable and defensible tariff provisions addressing these items requires careful research, analysis, and stakeholder consultation that cannot be completed within the current deadline.
Third, Ridgeline has actively participated in the settlement process and has engaged in good-faith bilateral negotiations with the intervenors. Three settlement conferences have been held (November 30, 2022; March 8, 2023; July 12, 2023), and Ridgeline has maintained ongoing discussions with ATPC, MGPC, and CMGA regarding key tariff provisions. The requested extension will provide additional time for these negotiations to progress, potentially narrowing the scope of contested issues and promoting the efficient resolution of this proceeding.
Fourth, no party opposes the requested extension, and no party will be prejudiced by the grant of additional time.
For all of these reasons, Ridgeline submits that good cause exists for the requested 180-day extension.
IV. PROPOSED NEW DEADLINE
Based on the foregoing, Ridgeline respectfully requests that the deadline for filing the complete response to the Deficiency Letter, including the redesigned FERC Gas Tariff, Original Volume No. 1, and any supplemental testimony, be extended by one hundred eighty (180) days from the current deadline of August 28, 2023 to February 23, 2024.
This proposed timeline is consistent with the expected completion of Braswell's comprehensive tariff redesign work and the anticipated progression of stakeholder negotiations during the extension period. Ridgeline has carefully considered the scope of work remaining and is confident that the proposed deadline of February 23, 2024 provides adequate time to develop and file a comprehensive, internally consistent redesigned tariff that addresses all fourteen deficiency items identified in the Deficiency Letter.
Ridgeline commits to continuing its diligent efforts to complete the tariff redesign as expeditiously as possible and to keeping all parties and the Presiding Judge informed of material developments in the tariff redesign work and the stakeholder negotiation process. In the event that the tariff redesign is completed prior to the proposed February 23, 2024 deadline, Ridgeline will file its complete response at the earliest practicable date. In the event that unforeseen circumstances arise that could affect Ridgeline's ability to meet the proposed deadline, Ridgeline will promptly notify the Presiding Judge and the parties.
A summary of the proposed revised procedural timeline is set forth in Appendix A to this Motion.
V. COMMUNICATIONS WITH OTHER PARTIES
Pursuant to 18 C.F.R. § 385.2008(a) and the Presiding Judge's standing procedural order, undersigned counsel has communicated with counsel for all active parties in this proceeding regarding the substance of this motion prior to its filing. The positions of the parties are as follows:
Appalachian Trunk Pipeline Company, LLC ("ATPC"). Undersigned counsel communicated with William Pratt of Kellner, Royce & Dillard LLP, counsel for ATPC. Mr. Pratt has indicated that ATPC does not oppose the requested 180-day extension. ATPC reserves all rights regarding the substance of Ridgeline's tariff redesign and any positions it may take with respect to the redesigned tariff and supplemental testimony when filed.
Mountainside Gas Producers Coalition ("MGPC"). Undersigned counsel communicated with Rebekah Montague of Whitmore & Sable LLP, counsel for MGPC. Ms. Montague has indicated that MGPC does not oppose the requested 180-day extension.
Clearwater Municipal Gas Authority ("CMGA"). Undersigned counsel communicated with Stephen Greer of Fordham Municipal Law Group PC, counsel for CMGA. Mr. Greer has indicated that CMGA does not oppose the requested 180-day extension.
FERC Trial Staff. Undersigned counsel communicated with Jonathan Briggs, Lead Trial Attorney, Office of General Counsel, Federal Energy Regulatory Commission. Mr. Briggs has been informed of the intended motion and has communicated no objection.
No party has indicated opposition to the requested extension.
VI. REQUEST FOR RELIEF
WHEREFORE, Ridgeline Midstream Services LLC respectfully requests that the Presiding Administrative Law Judge, the Honorable Clara Whitfield, enter an order:
1.  Granting this Motion for Extension of Time;
2.  Extending the deadline for Ridgeline to file its complete response to the January 19, 2023 Deficiency Letter issued by the Office of Energy Market Regulation, including the redesigned FERC Gas Tariff, Original Volume No. 1, and any supplemental testimony, from August 28, 2023 to February 23, 2024;
3.  Continuing the stay of the procedural schedule in this proceeding pending Ridgeline's filing of its complete response; and
4.  Granting such other and further relief as may be just and appropriate.
Respectfully submitted,
CALDERWOOD & HARKNESS LLP
By: ________
George Trujillo Responsible Partner, Energy & Infrastructure
Brett Callahan Lead Associate, Energy & Infrastructure
David Stanton Working Associate, Energy & Infrastructure
1601 K Street NW, Suite 900 Washington, DC 20006 Telephone: (202) 555-4200 Facsimile: (202) 555-4201
Counsel for Ridgeline Midstream Services LLC
Date: August 25, 2023
CERTIFICATE OF SERVICE
I hereby certify that on August 25, 2023, a copy of the foregoing Motion of Ridgeline Midstream Services LLC for Extension of Time to Complete Response to Deficiency Letter was served upon all parties on the official service list in Docket Nos. RP22-847-000 and RP22-847-001, by electronic filing through the Commission's eFiling system and by first-class United States mail, postage prepaid, addressed to the following:
Kimberly D. Bose, 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, Esq. Kellner, Royce & Dillard LLP One PPG Place, Suite 2800 Pittsburgh, PA 15222 Counsel for Appalachian Trunk Pipeline Company, LLC
Rebekah Montague, Esq. Whitmore & Sable LLP 1200 New Hampshire Avenue NW, Suite 600 Washington, DC 20036 Counsel for Mountainside Gas Producers Coalition
Stephen Greer, Esq. 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
Date: August 25, 2023
APPENDIX A
PROPOSED REVISED PROCEDURAL TIMELINE (SUMMARY)
This summary is provided for informational purposes and is not intended to bind the Presiding Judge or the parties to any particular schedule for subsequent proceedings. The procedural schedule following Ridgeline's filing of its complete response will be established by the Presiding Judge in consultation with the parties.
Ridgeline Midstream Services LLC | Docket Nos. RP22-847-000
(FERC Code: 960442) | RP22-847-001
Application for Initial Tariff Rate
and Interconnection Authorization
Milestone | Date / Timeframe | Notes
Current Deadline for Response to Deficiency Letter | August 28, 2023 | Established by ALJ Whitfield's Order dated May 10, 2023 (granting first extension)
Proposed New Deadline for Complete Response | February 23, 2024 | Extension of 180 days from current deadline
Extension Period | 180 days | August 28, 2023 through February 23, 2024
Anticipated Milestone: Completion of Braswell Tariff Redesign Work | Q4 2023 / Q1 2024 | Includes rate design modeling, NAESB gap analysis, tariff drafting, and internal consistency review
Anticipated Milestone: Filing of Redesigned Tariff and Supplemental Testimony | On or before February 23, 2024 | Complete response to all 14 deficiency items, including redesigned FERC Gas Tariff, Original Volume No. 1, and supplemental testimony
Subsequent Steps: Resumption of Procedural Schedule | To be determined by ALJ upon filing | Answering testimony, discovery, and hearing schedule to be set by ALJ Whitfield following Ridgeline's filing of complete response