[sheet: Cover & Legend]

[sheet: Cover & Legend]
Field | Value
Document Title | Privileged Settlement Communication Log
Matter | C&H Matter No. 1016-00005
Client | Dunmore Energy Holdings Ltd. / Ridgeline Midstream Services LLC
Docket Nos. | RP22-847-000 (Rate Case) / RP22-847-001 (Interconnection)
Prepared By | Calderwood & Harkness LLP — Energy & Infrastructure Practice
Responsible Partner | George Trujillo
Billing Partner | Patricia Dunmore
Lead Associate | Brett Callahan
Working Associate | David Stanton
Privilege Designation | ATTORNEY-CLIENT PRIVILEGED & CONFIDENTIAL — ATTORNEY WORK PRODUCT — SETTLEMENT PRIVILEGE (FRE 408)
Date Created | November 2022
Last Updated | January 25, 2024
Settlement Judge | Hon. Howard Margolis (FERC)
ALJ | Hon. Clara Whitfield (FERC)
Abbreviation — DEH | Dunmore Energy Holdings Ltd.
Abbreviation — RMS | Ridgeline Midstream Services LLC
Abbreviation — ATPC | Appalachian Trunk Pipeline Company, LLC
Abbreviation — TIP | Tidewater Infrastructure Partners LP
Abbreviation — MGPC | Mountainside Gas Producers Coalition
Abbreviation — CMGA | Clearwater Municipal Gas Authority
Abbreviation — C&H | Calderwood & Harkness LLP
Abbreviation — KRD | Kellner, Royce & Dillard LLP (ATPC counsel)
Abbreviation — W&S | Whitmore & Sable LLP (MGPC counsel)
Abbreviation — FMLG | Fordham Municipal Law Group PC (CMGA counsel)
Abbreviation — Braswell | Braswell Energy Consulting Group LLC
Abbreviation — Res. | Reservation Rate Component ($/Dth)
Abbreviation — Usg. | Usage Rate Component ($/Dth)
Abbreviation — ROE | Return on Equity (%)
Abbreviation — LF | Load Factor (%)
Abbreviation — COS | Cost of Service ($M)
Abbreviation — IC | Interconnection Cost Allocation
[sheet: Conference Summary]
Conference No. | Date | Location | Presiding | Ridgeline / DEH Attendees | Ridgeline Counsel | ATPC Attendees | ATPC Counsel | MGPC Attendees | MGPC Counsel | CMGA Attendees | CMGA Counsel | FERC Trial Staff Attendees | Duration | Outcome / Status | Follow-Up Actions | Notes
1 | 2022-11-30 | FERC Hearing Room 3A, 888 First Street NE, Washington, DC 20426 | Hon. Howard Margolis, Settlement Judge | James K. Winfield (CEO, RMS); Angela Moretti (VP Finance, RMS); Dr. Natasha Orlov (Dir. Rates & Regulatory, RMS); Patricia Dunmore (Chairperson, DEH) | George Trujillo (Partner, C&H); Brett Callahan (Associate, C&H); David Stanton (Associate, C&H) | Sandra K. Fenton (VP Regulatory Affairs, ATPC); Marcus R. Alderman (CEO, ATPC/TIP) | William Pratt (Senior Partner, KRD) | Calvin Dreyer (Exec. Dir., MGPC); Dr. Eleanor Vasquez (Rate Expert) | Rebekah Montague (Partner, W&S) | Dennis Ott (General Manager, CMGA) | Stephen Greer (Principal, FMLG) | Jonathan Briggs (Lead Trial Attorney); Dr. Miriam Okafor (Lead Economic Analyst) | Full day (approx. 7 hours) | No settlement reached; parties identified three core contested issues (ROE, IC cost allocation, load factor); Ridgeline circulated Settlement Offer V1.0 | Ridgeline to provide updated COS workpapers to ATPC under protective order; MGPC to provide Dr. Vasquez analysis; parties to exchange written counterproposals by Jan 15, 2023 | Initial conference; constructive tone but wide gap on all three issues; Settlement Judge Margolis expressed interest in further conferences
2 | 2023-03-08 | FERC Hearing Room 3A, 888 First Street NE, Washington, DC 20426 | Hon. Howard Margolis, Settlement Judge | James K. Winfield; Angela Moretti; Dr. Natasha Orlov | George Trujillo; Brett Callahan | Sandra K. Fenton | William Pratt (KRD) | Calvin Dreyer | Rebekah Montague (W&S) | Dennis Ott | Stephen Greer (FMLG) | Jonathan Briggs; Dr. Miriam Okafor | Half day (approx. 4 hours) | No settlement reached; proceeding complicated by FERC Deficiency Letter (Jan 19, 2023); parties agreed to pause substantive settlement discussions pending Ridgeline's tariff redesign; ATPC reiterated 50/50 IC cost split demand | Ridgeline to complete partial response to Deficiency Letter; reconvene after tariff redesign takes shape | Deficiency Letter significantly altered settlement dynamics; Ridgeline acknowledged need to redesign tariff and update rate proposal
3 | 2023-07-12 | FERC Hearing Room 2B, 888 First Street NE, Washington, DC 20426 | Hon. Howard Margolis, Settlement Judge | James K. Winfield; Angela Moretti; Dr. Raymond Braswell (Braswell Energy Consulting Group) | George Trujillo; Brett Callahan; David Stanton | Sandra K. Fenton | William Pratt (KRD) | Calvin Dreyer; Dr. Eleanor Vasquez | Rebekah Montague (W&S) | Dennis Ott | Stephen Greer (FMLG) | Jonathan Briggs | Full day (approx. 6 hours) | No settlement reached; Ridgeline previewed shift to 75% load factor methodology and reduced ROE; ATPC/MGPC expressed concern that revised rate would be higher on per-unit basis; CMGA aligned with ATPC on IC cost allocation | Ridgeline to circulate Settlement Offer V2.0 by October 2023; ATPC to provide written counterproposal on IC cost allocation; MGPC to update Dr. Vasquez testimony parameters | First conference with Dr. Braswell present; tariff redesign approach discussed in detail; Settlement Judge Margolis noted narrowing on some sub-issues but significant gap remains on headline rate
4 | 2024-01-18 | FERC Hearing Room 3A, 888 First Street NE, Washington, DC 20426 | Hon. Howard Margolis, Settlement Judge | James K. Winfield; Angela Moretti; Dr. Natasha Orlov; Dr. Raymond Braswell | George Trujillo; Brett Callahan | Sandra K. Fenton; Marcus R. Alderman | William Pratt (KRD) | Calvin Dreyer; Dr. Eleanor Vasquez | Rebekah Montague (W&S) | Dennis Ott | Stephen Greer (FMLG) | Jonathan Briggs; Dr. Miriam Okafor | Full day (approx. 8 hours) | No settlement reached; parties remain approximately $0.058/Dth apart (Ridgeline floor: $0.3140/Dth; ATPC/MGPC ceiling: ~$0.2560/Dth); continued disagreement on ROE, IC cost allocation, and load factor; Settlement Judge Margolis recommended parties continue discussions informally | Ridgeline to file third extension request; Ridgeline to circulate Settlement Offer V3.0 by September 2024; parties to continue bilateral discussions on IC agreement terms | Most substantive conference to date; Marcus Alderman attended in person; close to agreement on some GT&C provisions but headline economic terms remain far apart
[sheet: Offers & Counteroffers]
Entry No. | Date | Conference No. or Inter-Conference | Offering Party | Receiving Party/Parties | Communication Type | Document Reference | Proposed Total Recourse Rate ($/Dth) | Reservation Rate Component ($/Dth) | Usage Rate Component ($/Dth) | Proposed ROE (%) | Proposed Capital Structure — Equity / Debt | Proposed Cost of Debt (%) | Proposed WACC (%) | Proposed Load Factor (%) | Proposed Billing Determinants (Dth/yr) | Proposed Total COS ($M) | IC Cost Allocation — Ridgeline Share ($M / %) | IC Cost Allocation — ATPC Share ($M / %) | Total IC Facilities Cost ($M) | Other Key Terms / Conditions | Gap to Ridgeline Position ($/Dth) | Gap to ATPC/MGPC Position ($/Dth) | C&H Internal Notes
1 | 2022-11-30 | Conference 1 | Ridgeline (RMS) | All Parties | Formal Written Settlement Offer | Settlement Offer V1.0 | $0.2265 | $0.2223 | $0.0042 | 14.00% | 55% Equity / 45% Debt | 5.25% | 10.0625% | 100% | 438,000,000 | $97.36 | $7.6M (34.1%) | $14.7M (65.9%) | $22.3 | Based on original filed tariff rate and COS; 25-year levelized; open-access Part 284 Subpart G; proposed effective date Q4 2023 | — | — | Opening position consistent with original filing; establishes baseline for negotiation
2 | 2022-12-20 | Inter-Conference (post-Conf. 1) | ATPC | Ridgeline (via KRD to C&H) | Written Counterproposal | KRD Letter dated 12/20/2022 | $0.1950 | Not specified | Not specified | 10.75% | 50% Equity / 50% Debt | 5.25% | 8.00% | 100% | 438,000,000 | $85.41 | $11.15M (50%) | $11.15M (50%) | $22.3 | ATPC proposes 50/50 IC cost split; lower ROE at 10.75%; demands upgraded metering station design at Ridgeline's sole cost; ATPC opposes any allocation of IC costs to existing ATPC shippers | -$0.0315 | — | ATPC's opening counter is aggressive; 50/50 IC split is their firm demand; ROE at 10.75% is below FERC recent precedent for new pipelines — likely a negotiating position
3 | 2023-01-05 | Inter-Conference (post-Conf. 1) | MGPC | Ridgeline (via W&S to C&H) | Written Position Statement | W&S Letter dated 1/5/2023 | $0.1740 | Not specified | Not specified | 11.25% | 55% Equity / 45% Debt | 5.25% | Not specified | 100% | 438,000,000 | ~$76.2M (est.) | No position on IC | No position on IC | $22.3 | MGPC advocates rate ceiling of $0.1740/Dth per Dr. Vasquez testimony; supports interconnection generally but not at current proposed rate; 14 member producers; Dr. Vasquez proposes 11.25% ROE | -$0.0525 | — | MGPC's position is the most aggressive on rate; Dr. Vasquez's $0.1740 figure uses 100% LF and significantly lower COS assumptions; unlikely to be FERC-supportable at this level
4 | 2023-01-10 | Inter-Conference (post-Conf. 1) | CMGA | All Parties (via FMLG to all counsel) | Written Position Statement | FMLG Letter dated 1/10/2023 | No specific rate proposed | — | — | No position | No position | — | — | No position | — | — | Supports ATPC 50/50 split | Supports ATPC 50/50 split | $22.3 | CMGA (Dennis Ott) concerned about rate increases on ATPC system from IC costs being allocated to existing ATPC shippers; aligns with ATPC on IC cost allocation; no independent rate position | — | — | CMGA is a secondary party; their primary concern is protecting existing ATPC ratepayers from bearing IC costs; not a driver of headline rate negotiations
5 | 2023-03-08 | Conference 2 | Ridgeline (RMS) | All Parties | Oral Presentation at Conference | C&H Talking Points (internal) | Held at $0.2265 (original) | $0.2223 | $0.0042 | 14.00% | 55% / 45% | 5.25% | 10.0625% | 100% | 438,000,000 | $97.36 | $7.6M (34.1%) | $14.7M (65.9%) | $22.3 | Ridgeline maintained original position but signaled willingness to consider tariff redesign implications for rate structure; acknowledged FERC Deficiency Letter requires material changes; proposed pausing settlement talks until redesign scope clarified | — | — | Conference 2 was largely procedural given Deficiency Letter impact; no movement on economic terms
6 | 2023-07-12 | Conference 3 | Ridgeline (RMS) | All Parties | Oral Presentation with Handouts | Braswell Redesign Summary (shared at conference) | Previewed ~$0.31 range | TBD | TBD | 12.50–13.00% (range discussed) | 55% / 45% | 5.25% | ~9.24–9.51% (range) | 75% | 328,500,000 | ~$100–105M range | $7.6M (34.1%) | $14.7M (65.9%) | $22.3 | First presentation of redesigned rate methodology; shift from 100% to 75% load factor increases per-unit rate despite lower ROE; Dr. Braswell explained modified fixed-variable methodology; parties objected to higher per-unit rate | — | — | Significant shift in negotiation dynamics; per-unit rate increase concerns all intervenors; need to demonstrate that lower LF is justified and consistent with FERC policy
7 | 2023-07-25 | Inter-Conference (post-Conf. 3) | ATPC | Ridgeline (via KRD to C&H) | Written Counterproposal | KRD Letter dated 7/25/2023 | $0.2400 | Not specified | Not specified | 10.75% | 50% / 50% | 5.25% | 8.00% | 85% | 372,300,000 | ~$89.3M (est.) | $11.15M (50%) | $11.15M (50%) | $22.3 | ATPC revised rate position upward from $0.1950 to $0.2400 acknowledging redesign parameters; maintains 10.75% ROE; proposes 85% LF as compromise; insists on 50/50 IC cost split; demands pig launcher/receiver specs per ATPC standards | -$0.0740 | — | ATPC moved meaningfully from $0.1950 to $0.2400; 85% LF is a reasonable compromise worth considering; but 10.75% ROE and 50/50 IC split remain firm
8 | 2023-10-15 | Inter-Conference (post-Conf. 3) | Ridgeline (RMS) | All Parties | Formal Written Settlement Offer | Settlement Offer V2.0 | $0.2980 | ~$0.2942 | ~$0.0038 | 13.00% | 55% / 45% | 5.25% | 9.5125% | 75% | 328,500,000 | ~$97.9M | $7.6M (34.1%) | $14.7M (65.9%) | $22.3 | Ridgeline reduced ROE from 14.00% to 13.00% as concession; maintained 75% LF and original IC cost allocation; revised COS reflects lower return but updated O&M/A&G; proposed effective date pushed to Q2 2024 | — | +$0.0420 | Meaningful ROE concession (14.00% → 13.00%); per-unit rate still well above ATPC/MGPC comfort zone; IC allocation unchanged — may need to flex here eventually
9 | 2023-11-08 | Inter-Conference (post-V2.0) | MGPC | Ridgeline (via W&S to C&H) | Written Counterproposal | W&S Letter dated 11/8/2023 | $0.2560 | Not specified | Not specified | 11.25% | 55% / 45% | 5.25% | ~9.55% | 85% | 372,300,000 | ~$95.3M (est.) | No specific IC position | No specific IC position | $22.3 | MGPC moved from $0.1740 to $0.2560; maintained 11.25% ROE per Dr. Vasquez; proposes 85% LF; Dr. Vasquez provided updated analysis; this represents the ATPC/MGPC coalition ceiling | -$0.0420 | — | MGPC's move from $0.1740 to $0.2560 is significant — nearly $0.08/Dth concession; $0.2560 now appears to be the effective ceiling for the intervenor coalition; gap to our V2.0 is $0.042
10 | 2024-01-18 | Conference 4 | Ridgeline (RMS) | All Parties | Oral Presentation with Updated Handouts | Braswell Updated COS Model Summary | $0.3140 | $0.3102 | $0.0038 | 12.50% | 55% / 45% | 5.25% | 9.2375% | 75% | 328,500,000 | $103.15 | $7.6M (34.1%) | $14.7M (65.9%) | $22.3 | Ridgeline presented final redesigned tariff parameters; ROE reduced to 12.50% (from 13.00% in V2.0 and 14.00% original); COS increased to $103.15M due to updated O&M ($13.92M), A&G ($5.14M), and reduced revenue credits ($6.00M vs. $16.10M original); rate floor set at $0.3140/Dth | — | +$0.0580 | Rate paradox: lower ROE but higher per-unit rate due to 75% LF and higher operating costs; Settlement Judge Margolis noted this disconnect is hard for intervenors to accept; need to provide clear narrative on why 75% LF is appropriate
11 | 2024-01-18 | Conference 4 | ATPC | Ridgeline (oral at conference) | Oral Counterproposal | KRD oral statements (C&H notes) | $0.2560 | Not specified | Not specified | 10.75% | 50% / 50% | 5.25% | 8.00% | 85% | 372,300,000 | ~$95.3M (est.) | $11.15M (50%) | $11.15M (50%) | $22.3 | ATPC aligned with MGPC's $0.2560 ceiling; maintained 10.75% ROE and 50/50 IC cost split; ATPC expressed willingness to discuss metering station design compromise but not cost allocation; Marcus Alderman stated IC cost allocation is 'non-negotiable' at 50/50 | -$0.0580 | — | ATPC and MGPC now aligned at $0.2560 ceiling; Marcus Alderman's personal attendance and 'non-negotiable' statement on IC suggests limited flexibility on this point; $0.058/Dth gap is current state of play
12 | 2024-09-15 | Inter-Conference (post-Conf. 4) | Ridgeline (RMS) | All Parties | Formal Written Settlement Offer | Settlement Offer V3.0 | $0.3140 | $0.3102 | $0.0038 | 12.50% | 55% / 45% | 5.25% | 9.2375% | 75% | 328,500,000 | $103.15 | $7.6M (34.1%) | $14.7M (65.9%) | $22.3 | Ridgeline formalized Conference 4 oral proposal as V3.0; maintained $0.3140/Dth floor; revised WACC of 9.2375%; revised COS of $103.15M; maintained IC cost allocation at 34.1/65.9; proposed including FL&U tracker, capacity release provisions, GHG cost recovery mechanism, and Order No. 2222 provisions as part of any settlement package | — | +$0.0580 | V3.0 is the current operative offer; no movement from Conference 4 position; emphasis shifted to demonstrating comprehensive tariff redesign addresses all 14 deficiency items; gap remains $0.058/Dth
[sheet: ROE Positions]
Date | Conference / Communication | Ridgeline Proposed ROE (%) | ATPC Proposed ROE (%) | MGPC Proposed ROE (%) | CMGA Position | FERC Staff Comments | Ridgeline–ATPC ROE Gap (bps) | Ridgeline–MGPC ROE Gap (bps) | Notes
2022-11-30 | Conference 1 / Settlement Offer V1.0 | 14.00% | 10.75% | 11.25% | No position | Trial Staff reserved position | 325 | 275 | Original filing ROE; proxy group DCF analysis pre-2021 data
2022-12-20 | ATPC Counterproposal (KRD Letter) | 14.00% | 10.75% | 11.25% | Aligned with ATPC | — | 325 | 275 | ATPC formal counter maintains 10.75%
2023-01-05 | MGPC Position (W&S Letter) | 14.00% | 10.75% | 11.25% | No position | — | 325 | 275 | Dr. Vasquez testimony supports 11.25%
2023-03-08 | Conference 2 (no movement) | 14.00% | 10.75% | 11.25% | Aligned with ATPC | — | 325 | 275 | No ROE discussion; conference focused on Deficiency Letter impact
2023-07-12 | Conference 3 (Braswell preview) | 12.50–13.00% (range) | 10.75% | 11.25% | Aligned with ATPC | — | 175–225 | 125–175 | First signal of ROE reduction as part of tariff redesign
2023-10-15 | Settlement Offer V2.0 | 13.00% | 10.75% | 11.25% | Aligned with ATPC | — | 225 | 175 | Ridgeline reduced from 14.00% to 13.00%
2023-11-08 | MGPC Counterproposal (W&S Letter) | 13.00% | 10.75% | 11.25% | Aligned with ATPC | — | 225 | 175 | MGPC maintained 11.25% per Dr. Vasquez updated analysis
2024-01-18 | Conference 4 / Settlement Offer V3.0 | 12.50% | 10.75% | 11.25% | Aligned with ATPC | Dr. Okafor noted recent FERC ROE range of 10.5%–13.0% for new pipelines | 175 | 125 | Ridgeline reduced further to 12.50% per updated Q3 2024 DCF proxy group analysis; gap narrowing but still 175 bps from ATPC
[sheet: IC Cost Allocation]
Date | Conference / Communication | Total IC Facilities Cost ($M) | Ridgeline Proposed Split — RMS Share ($M) | Ridgeline Proposed Split — RMS % | Ridgeline Proposed Split — ATPC Share ($M) | Ridgeline Proposed Split — ATPC % | ATPC Proposed Split — RMS Share ($M) | ATPC Proposed Split — RMS % | ATPC Proposed Split — ATPC Share ($M) | ATPC Proposed Split — ATPC % | CMGA Position | Dollar Difference Between Positions — ATPC ($M) | Metering Station Design Status | Notes
2022-11-30 | Conference 1 / Settlement Offer V1.0 | $22.30 | $7.60 | 34.1% | $14.70 | 65.9% | $11.15 | 50.0% | $11.15 | 50.0% | Supports ATPC 50/50 | $3.55 | Ridgeline proposed ultrasonic flow meters (3 runs, 12-inch); ATPC objected to design adequacy | Original positions established; $3.55M gap on ATPC share ($14.7M vs. $11.15M)
2022-12-20 | ATPC Counterproposal | $22.30 | $7.60 | 34.1% | $14.70 | 65.9% | $11.15 | 50.0% | $11.15 | 50.0% | Supports ATPC 50/50 | $3.55 | ATPC demands alternative metering design per ATPC engineering standards; pig launcher/receiver specs at issue | ATPC position unchanged; $14.7M allocation to ATPC shippers is core objection in ATPC protest
2023-03-08 | Conference 2 | $22.30 | $7.60 | 34.1% | $14.70 | 65.9% | $11.15 | 50.0% | $11.15 | 50.0% | Supports ATPC 50/50 | $3.55 | Paused pending tariff redesign | No movement; IC agreement to be filed as FERC rate schedule per Deficiency Item 9
2023-07-12 | Conference 3 | $22.30 | $7.60 | 34.1% | $14.70 | 65.9% | $11.15 | 50.0% | $11.15 | 50.0% | Supports ATPC 50/50 | $3.55 | Draft IC Agreement V3.0 incorporating rate schedule filing requirement circulated April 2023 | No movement on cost allocation; IC Agreement V3.0 addresses Deficiency Item 9
2024-01-18 | Conference 4 | $22.30 | $7.60 | 34.1% | $14.70 | 65.9% | $11.15 | 50.0% | $11.15 | 50.0% | Supports ATPC 50/50 | $3.55 | Marcus Alderman stated IC cost allocation is 'non-negotiable' at 50/50; metering design discussions ongoing via Callahan-Pratt technical channel | Marcus Alderman's personal statement; most inflexible position of all three contested issues; may require ALJ determination
2024-09-15 | Settlement Offer V3.0 | $22.30 | $7.60 | 34.1% | $14.70 | 65.9% | $11.15 | 50.0% | $11.15 | 50.0% | Supports ATPC 50/50 | $3.55 | Metering design discussions continuing; pig launcher/receiver compromise under review by Callahan and Pratt | No movement on allocation; V3.0 maintains 34.1/65.9 split; gap remains at $3.55M
[sheet: Load Factor Positions]
Date | Conference / Communication | Ridgeline Proposed LF (%) | ATPC Proposed LF (%) | MGPC Proposed LF (%) | CMGA Position | Design Capacity (Dth/d) | Ridgeline Billing Determinants (Dth/yr) | Intervenor Billing Determinants (Dth/yr) | Billing Determinant Gap (Dth/yr) | Impact on Rate | Current Actual Throughput (MMcf/d) | Actual Utilization (%) | Notes
2022-11-30 | Conference 1 / V1.0 | 100% | 100% (accepted for initial discussion) | 100% (accepted for initial discussion) | No position | 1,200,000 | 438,000,000 | 438,000,000 | 0 | At 100% LF all parties used same determinants | 680 | 56.67% | Original filing assumed 100% LF; FERC Deficiency Item 4 challenged this assumption
2023-03-08 | Conference 2 | 100% (held pending redesign) | 100% (no change yet) | 100% (no change yet) | No position | 1,200,000 | 438,000,000 | 438,000,000 | 0 | LF not yet contested; redesign implications pending | 680 | 56.67% | Deficiency Item 4 flagged 100% LF as unsupported; Ridgeline began considering alternatives
2023-07-12 | Conference 3 (redesign preview) | 75% | 85% | 85% | Aligned with ATPC | 1,200,000 | 328,500,000 | 372,300,000 | 43,800,000 | 75% LF produces $0.3140/Dth vs. 85% LF producing ~$0.2773/Dth (using Ridgeline COS) | 680 | 56.67% | Load factor is now a key contested issue; 75% vs. 85% represents ~$0.037/Dth difference
2023-10-15 | Settlement Offer V2.0 | 75% | 85% | 85% | Aligned with ATPC | 1,200,000 | 328,500,000 | 372,300,000 | 43,800,000 | Gap persists at 10 percentage points on LF | 680 | 56.67% | Intervenors argue actual utilization (56.67%) supports higher LF assumption for rate design purposes
2024-01-18 | Conference 4 / V3.0 | 75% | 85% | 85% | Aligned with ATPC | 1,200,000 | 328,500,000 | 372,300,000 | 43,800,000 | If Ridgeline's $103.15M COS used with 85% LF: $103.15M ÷ 372,300,000 = ~$0.2771/Dth | 680 | 56.67% | LF dispute accounts for approximately $0.037 of the $0.058 total gap; this is the single largest driver of the rate difference