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CALDERWOOD & HARKNESS LLP Attorneys at Law

1601 K Street NW, Suite 900 Washington, DC 20006

Telephone: (202) 555-4100 Facsimile: (202) 555-4101 www.calderwoodharkness.com

February 21, 2025

VIA ELECTRONIC FILING (eFiling) AND FIRST-CLASS MAIL

Kimberly D. Bose, Secretary Federal Energy Regulatory Commission 888 First Street NE Washington, DC 20426

Re: Ridgeline Midstream Services LLC FERC Docket Nos. RP22-847-000 (Rate Case) and RP22-847-001 (Interconnection) Filing of Redesigned FERC Gas Tariff, Original Volume No. 1, and Supplemental Testimony Ridgeline FERC Code: 960442

Dear Secretary Bose:

I. Introduction and Purpose of Filing

Calderwood & Harkness LLP, on behalf of its client Ridgeline Midstream Services LLC ("Ridgeline" or "RMS"), a Delaware limited liability company with its principal office at 700 Kanawha Boulevard East, Suite 1400, Charleston, West Virginia 25301, hereby submits the enclosed redesigned FERC Gas Tariff, Original Volume No. 1, together with supplemental pre-filed testimony and supporting exhibits, for filing with the Federal Energy Regulatory Commission (the "Commission" or "FERC") in the above-captioned dockets.

This filing is made pursuant to Sections 4 and 7 of the Natural Gas Act ("NGA"), 15 U.S.C. §§ 717c and 717f, and the Commission's implementing regulations at 18 C.F.R. Parts 154, 157, and 284. The filing constitutes Ridgeline's comprehensive response to the Deficiency Letter issued by the Commission's Office of Energy Market Regulation ("OEMR") on January 19, 2023, which identified fourteen (14) specific deficiency items requiring correction or supplementation in Ridgeline's original tariff filing of May 12, 2022. Each of the fourteen deficiency items is addressed in full through the redesigned tariff provisions and the supplemental pre-filed testimony submitted herewith, as described in detail in Section V of this transmittal letter.

This filing is made in compliance with the deadline established by Administrative Law Judge Clara Whitfield in her order of March 4, 2024 (the "Third Extension Order"), which granted Ridgeline's third motion for extension of time and set February 21, 2025 as the final deadline for filing the redesigned tariff and supplemental testimony. Ridgeline has complied with all conditions imposed in the Third Extension Order, including the filing of quarterly status reports on June 15, 2024; September 14, 2024; and December 13, 2024.

In connection with this filing, Ridgeline respectfully requests that the Commission lift the dormant status designation currently applicable to this proceeding and direct that the Track II procedural schedule be reactivated so that the proceeding may move forward to hearing and resolution. As set forth more fully below, Ridgeline believes the redesigned tariff and supplemental testimony fully cure all identified deficiencies and provide a sound basis for the Commission to evaluate Ridgeline's proposed rates and terms of service.

II. Background and Procedural History

On May 12, 2022, Ridgeline filed with the Commission its application seeking approval of an initial tariff rate for interstate transportation service on the Ridgeline Pipeline System and authorization for physical interconnection with the pipeline network of Appalachian Trunk Pipeline Company, LLC ("ATPC") at the Wetzel County Interconnect, located in Wetzel County, West Virginia. The filing was docketed by the Commission as Docket No. RP22-847-000 (rate case) and Docket No. RP22-847-001 (interconnection).

Ridgeline is a wholly owned subsidiary of Dunmore Energy Holdings Ltd. ("DEH"), a Cayman Islands exempted limited company (Cayman Registry No. CR-381204). DEH is the ultimate parent entity of Ridgeline and provides certain administrative and financial support services to Ridgeline pursuant to a Management Services Agreement. The Ridgeline Pipeline System is Ridgeline's sole jurisdictional asset and consists of 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"), equivalent to 1,200,000 dekatherms per day ("Dth/d"), and is supported by three compressor stations with an aggregate installed compression capacity of 45,000 horsepower ("HP"). The Ridgeline Pipeline System was placed in service on October 1, 2021.

On June 14, 2022, the Commission issued a Notice of Filing and Instituting Proceeding in this docket, establishing a deadline of August 15, 2022 for motions to intervene and protests. During the intervention period, three parties filed timely motions to intervene:

• Mountainside Gas Producers Coalition ("MGPC") filed its motion to intervene on July 28, 2022. MGPC is an unincorporated association of natural gas producers operating in the Appalachian Basin that ship or seek to ship gas on the Ridgeline Pipeline System.

• Clearwater Municipal Gas Authority ("CMGA") filed its motion to intervene on August 1, 2022. CMGA is a municipal gas distribution authority serving residential and commercial customers in portions of southwestern Pennsylvania and northern West Virginia.

• Appalachian Trunk Pipeline Company, LLC ("ATPC") filed its motion to intervene and protest on August 15, 2022. ATPC is the owner and operator of the ATPC mainline system, with which Ridgeline seeks to interconnect at the Wetzel County Interconnect. ATPC's protest raised objections to, among other things, Ridgeline's proposed return on equity, load factor assumptions, and the proposed allocation of interconnection costs.

On September 22, 2022, the Commission issued an order granting all three motions to intervene, establishing a Track II procedural schedule for the hearing of Ridgeline's rate case application, and appointing Settlement Judge Howard Margolis to facilitate settlement discussions among the parties. Administrative Law Judge Clara Whitfield was subsequently appointed as the presiding judge for the hearing proceeding on November 14, 2022, and a prehearing conference was held on the same date at which the initial hearing schedule was established.

On December 5, 2022, Ridgeline filed its pre-filed direct testimony of seven witnesses, covering all aspects of the proposed tariff rate, cost of service, rate design, system operations, and interconnection facilities. On January 9, 2023, ATPC, MGPC, and CMGA each filed answering testimony through their respective expert witnesses, raising a number of challenges to Ridgeline's proposed rate design, cost of service, and tariff provisions.

On January 19, 2023, the Commission's Office of Energy Market Regulation issued a Deficiency Letter identifying fourteen (14) deficiencies in Ridgeline's tariff filing (the "Deficiency Letter"). The deficiencies ranged from inadequate support for Ridgeline's proposed return on equity and load factor assumptions to the absence of key tariff provisions required under FERC policy and applicable regulations, including fuel-use and lost-and-unaccounted-for gas tracker mechanisms, interruptible transportation rate derivation, capacity release provisions, NAESB Wholesale Gas Quadrant ("WGQ") Version 3.2 compliance, electronic bulletin board ("EBB") posting requirements, shipper-must-have-title provisions, creditworthiness provisions, and the treatment of the interconnection agreement as a FERC rate schedule.

On February 6, 2023, ALJ Whitfield issued a procedural order staying the Track II hearing schedule pending Ridgeline's response to the Deficiency Letter. On March 15, 2023, Ridgeline filed a partial response to the Deficiency Letter, addressing eight of the fourteen deficiency items (specifically, Items 1 through 4 and Items 7 through 10). The instant filing completes Ridgeline's response to all remaining deficiency items and supersedes the March 15, 2023 partial response in its entirety.

Following the issuance of the Deficiency Letter and the stay of the procedural schedule, Ridgeline obtained three successive extensions of time to prepare its comprehensive response:

• First Extension: Granted by ALJ Whitfield on May 10, 2023, providing an additional 120 days and setting a deadline of August 28, 2023.

• Second Extension: Granted by ALJ Whitfield on September 8, 2023, providing an additional 180 days and setting a deadline of February 23, 2024. In connection with this extension, ALJ Whitfield classified the proceeding as dormant pursuant to 18 C.F.R. § 385.710.

• Third Extension: Granted by ALJ Whitfield on March 4, 2024, providing an additional twelve (12) months and setting a final deadline of February 21, 2025. The Third Extension Order imposed conditions requiring Ridgeline to file quarterly status reports with the Commission and serve copies on all parties, which Ridgeline has done on each required date.

In compliance with the conditions of the Third Extension Order, Ridgeline filed three quarterly status reports with the Commission on June 15, 2024; September 14, 2024; and December 13, 2024. Each report described the progress of Ridgeline's tariff redesign effort and confirmed Ridgeline's intention to meet the February 21, 2025 filing deadline.

In connection with the tariff redesign effort, Ridgeline engaged Braswell Energy Consulting Group LLC ("Braswell" or "BEC") on April 15, 2023 (Engagement No. BEC-2023-0041) to assist with the comprehensive redesign of Ridgeline's FERC Gas Tariff and preparation of supporting cost-of-service and rate design analyses. Braswell was engaged under the direction of Dr. Raymond Braswell, a former senior economist with the Commission's Office of Energy Market Regulation, whose experience includes participation in more than forty FERC rate proceedings. Dr. Braswell's team provided substantial analytical and drafting support for the redesigned tariff and the supplemental testimony submitted herewith.

Throughout the course of this proceeding, the parties have participated in four settlement conferences before Settlement Judge Margolis, held on November 30, 2022; March 8, 2023; July 12, 2023; and January 18, 2024. While those conferences have narrowed certain areas of disagreement among the parties, no settlement has been reached to date. The parties remain approximately $0.058/Dth apart on the recourse rate. The settlement status is described in more detail in Section VIII of this letter.

III. Description of Enclosed Filing Materials

The enclosed filing consists of the following materials, each of which is described in greater detail in the subsections below.

A. Redesigned FERC Gas Tariff, Original Volume No. 1

Ridgeline submits herewith its complete Redesigned FERC Gas Tariff, Original Volume No. 1, filed as a Part 284, Subpart G open-access transportation tariff for interstate natural gas pipeline service. The redesigned tariff has been comprehensively revised and reorganized to address all fourteen deficiency items identified in the Deficiency Letter, to incorporate current FERC policy requirements, and to conform to the Commission's applicable regulations and orders. The redesigned tariff includes the following components:

• Rate Schedule FT-1 (Firm Transportation Service): Sets forth the terms, conditions, and rates applicable to firm transportation service on the Ridgeline Pipeline System, including the revised reservation rate and usage rate, maximum daily quantity provisions, scheduling priorities, and force majeure provisions.

• Rate Schedule IT-1 (Interruptible Transportation Service): A new rate schedule providing for interruptible transportation service on the Ridgeline Pipeline System, with a derived interruptible transportation rate, IT revenue crediting methodology, and rate floor consistent with FERC policy, addressing Deficiency Item 3.

• Revised General Terms and Conditions ("GT&C"): Extensively revised General Terms and Conditions addressing, among other things, fuel-use and lost-and-unaccounted-for gas ("FL&U") tracker mechanisms, capacity release provisions, NAESB WGQ Version 3.2 compliance, electronic bulletin board posting requirements, shipper-must-have-title provisions, creditworthiness provisions, segmentation and flexible receipt/delivery point provisions, penalty revenue crediting, greenhouse gas emission cost recovery provisions, and provisions addressing FERC Order No. 2222 distributed energy resource aggregation implications.

• Form of Service Agreement: A revised pro forma service agreement for firm and interruptible transportation service on the Ridgeline Pipeline System.

• Interconnection Agreement between Ridgeline and ATPC: The Interconnection Agreement between Ridgeline and Appalachian Trunk Pipeline Company, LLC for physical interconnection at the Wetzel County Interconnect is now filed as a FERC rate schedule within the tariff, in compliance with Deficiency Item 9.

Both clean and redline versions of the redesigned tariff are submitted. All tariff sheets in the redline version are marked to show changes from the original filing of May 12, 2022, enabling the Commission and parties to readily identify all modifications.

B. Supplemental Pre-Filed Testimony

Ridgeline submits the supplemental pre-filed testimony of two witnesses in support of the redesigned tariff:

• Supplemental Pre-Filed Testimony of Dr. Natasha Orlov, Director of Rates & Regulatory, Ridgeline Midstream Services LLC. Dr. Orlov's testimony addresses all fourteen deficiency items identified in the Deficiency Letter and provides a comprehensive description and justification of the redesigned tariff provisions. Specifically, Dr. Orlov's testimony covers the modified fixed-variable rate methodology; the revised 75% load factor billing determinants; the new FL&U tracker mechanism, including the percentage retention methodology and annual true-up procedures; the capacity release provisions; the NAESB WGQ Version 3.2 compliance revisions; the EBB posting requirements; the shipper-must-have-title provisions; the creditworthiness provisions, including collateral requirements, unsecured credit limits, and credit rating thresholds; the segmentation and flexible receipt/delivery point provisions; the greenhouse gas emission cost recovery provisions, including the proposed GHG cost tracker and passthrough mechanism addressing emerging FERC and state-level requirements; and the provisions addressing FERC Order No. 2222 distributed energy resource aggregation implications, including renewable energy interconnection considerations relevant to DEH's 250 MW wind portfolio currently under development.

• Supplemental Pre-Filed Testimony of Angela Moretti, VP, Finance & Treasurer, Ridgeline Midstream Services LLC. Ms. Moretti's testimony presents the revised cost-of-service model and updated rate base for the Ridgeline Pipeline System, including the revised capital structure, return on equity, cost of debt, depreciation analysis, operating expenses, tax allowance, and revenue credits. Ms. Moretti's testimony also provides updated financial data and supporting calculations for each component of the revised total cost of service.

Both witnesses' testimony is accompanied by supporting exhibits, which are referenced and described within the testimony.

C. Supporting Exhibits

Ridgeline submits updated Exhibits A through P in support of the redesigned tariff and supplemental testimony. The updated exhibits include, without limitation, revised cost-of-service schedules, rate base calculations, rate design workpapers, depreciation schedules, capital structure supporting documentation, operating statistics, system maps, and related financial and operational data. Each exhibit has been updated to reflect current information and to support the revised rate design described in Section IV of this letter and in the supplemental testimony.

IV. Summary of Revised Rate Design and Cost of Service

The following is a summary of Ridgeline's revised rate design and cost-of-service analysis, as presented in the supplemental pre-filed testimony of Angela Moretti and Dr. Natasha Orlov and the supporting exhibits. A detailed description of each component and the methodologies employed is set forth in the testimony and exhibits.

A. Rate Base

Ridgeline's total rate base remains unchanged from the original filing at $612.40 million. The components of the rate base are as follows:

Net plant in service of $563.71 million reflects the original construction cost of the Ridgeline Pipeline System of $587.20 million, less accumulated depreciation of $23.49 million calculated on the basis of a 2.5% annual straight-line depreciation rate applied from the system's in-service date of October 1, 2021 through the test year. The working capital allowance of $18.64 million is calculated using the Commission's standard formula of one-eighth (1/8) of annual operations and maintenance ("O&M") expense plus administrative and general ("A&G") expense. Accumulated deferred income taxes of $12.45 million reduce the rate base in accordance with the Commission's normalization requirements. Other rate base items of $42.50 million include gas stored underground, prepayments, and materials and supplies.

B. Capital Structure and Return

Ridgeline's proposed capital structure remains unchanged from the original filing at 55% equity and 45% debt. However, Ridgeline has revised its proposed return on equity ("ROE") downward from 14.00% to 12.50%, based on an updated discounted cash flow ("DCF") proxy group analysis as of the third quarter of 2024. The updated DCF analysis is presented in the supplemental testimony of Angela Moretti and the supporting exhibits, and reflects current market conditions and the Commission's established DCF methodology.

Ridgeline's cost of debt is 5.25%, representing the weighted average cost of two tranches of outstanding indebtedness:

• A $400 million term loan facility priced at SOFR plus 325 basis points; and

• $150 million in aggregate principal amount of 7.875% Second Lien Senior Secured Notes due 2030.

The resulting revised weighted average cost of capital ("WACC") is 9.2375%, calculated as follows:

(0.55 × 12.50%) + (0.45 × 5.25%) = 6.875% + 2.3625% = 9.2375%

Applying the revised WACC to the total rate base of $612.40 million yields a revised return on rate base of $56.57 million ($612.40 million × 9.2375%).

C. Operating Expenses and Taxes

The following table summarizes Ridgeline's revised operating expenses and taxes:

The depreciation expense of $14.68 million reflects the annual straight-line depreciation rate of 2.5% applied to the original construction cost of $587.20 million. Revised O&M expense of $13.92 million and revised A&G expense of $5.14 million have been updated from the original filing to reflect current cost levels, as described in Ms. Moretti's testimony. Taxes other than income of $3.80 million consist principally of property taxes and franchise taxes assessed in the states of West Virginia and Pennsylvania. The revised income tax allowance of $15.04 million has been grossed up using an effective combined federal and state income tax rate of approximately 26.13%, reflecting the federal statutory rate of 21% and the West Virginia state corporate net income tax rate of 6.5%. Revenue credits of $6.00 million are applied as an offset to the cost of service.

D. Total Cost of Service

Ridgeline's revised total cost of service is $103.15 million, derived as follows:

E. Billing Determinants and Recourse Rate

The Ridgeline Pipeline System has a design capacity of 1,200,000 Dth/d (1.2 Bcf/d). In the original filing, Ridgeline utilized a 100% load factor to derive its billing determinants and proposed recourse rate. In response to Deficiency Item 4, Ridgeline has revised its load factor assumption to 75%, which Ridgeline submits is reasonable and well-supported based on the analysis presented in the supplemental testimony of Dr. Orlov.

The revised billing determinants are calculated as follows:

1,200,000 Dth/d × 365 days × 75% = 328,500,000 Dth/yr

Dividing the revised total cost of service of $103.15 million by the revised billing determinants of 328,500,000 Dth/yr yields a revised proposed recourse rate of $0.3140/Dth (total), comprising a reservation rate of $0.3102/Dth and a usage rate of $0.0038/Dth.

As of the date of this filing, the Ridgeline Pipeline System has a current average system throughput of approximately 680 million cubic feet per day ("MMcf/d"), representing approximately 56.67% utilization of the system's design capacity. Ridgeline expects throughput to increase as additional shippers contract for service on the system and as upstream production activity in the Appalachian Basin continues to expand.

V. Summary of Responses to Deficiency Items

The redesigned FERC Gas Tariff, Original Volume No. 1, and the supplemental pre-filed testimony submitted herewith collectively and comprehensively address each of the fourteen (14) deficiency items identified in the Commission's Deficiency Letter of January 19, 2023. The following is a summary of how each deficiency item has been addressed. Detailed discussion and justification of each response is provided in the supplemental testimony of Dr. Natasha Orlov and, where applicable, Angela Moretti.

Item 1 — ROE Support. The Deficiency Letter required Ridgeline to provide adequate support for its proposed return on equity. In response, Ridgeline has reduced its proposed ROE from 14.00% to 12.50% and has submitted an updated DCF proxy group analysis as of the third quarter of 2024, prepared in accordance with the Commission's established two-step DCF methodology. The updated analysis identifies a proxy group of comparable pipeline companies, calculates the median and mean zone of reasonableness, and demonstrates that Ridgeline's proposed 12.50% ROE falls within the upper half of the zone of reasonableness, as is appropriate given Ridgeline's status as a new entrant pipeline with unique business and financial risk characteristics. The updated DCF analysis is presented in detail in the supplemental testimony of Angela Moretti and the supporting exhibits.

Item 2 — FL&U Tracker Mechanism. The Deficiency Letter identified the absence of a fuel-use and lost-and-unaccounted-for gas ("FL&U") tracker mechanism as a deficiency. In response, Ridgeline has incorporated a new FL&U tracker mechanism into the General Terms and Conditions of the redesigned tariff. The mechanism provides for a percentage retention of gas-in-kind at each receipt point to compensate for compressor fuel usage and system losses. The tariff establishes an initial FL&U percentage based on the system's actual operating experience and provides for annual true-up procedures to adjust the percentage based on actual fuel usage and losses, with shipper refunds or surcharges as appropriate. The FL&U tracker provisions are described in detail in Dr. Orlov's supplemental testimony.

Item 3 — IT Rate Derivation. The Deficiency Letter required Ridgeline to include a properly derived interruptible transportation rate. In response, Ridgeline has added a new Rate Schedule IT-1 to the redesigned tariff, providing for interruptible transportation service on the Ridgeline Pipeline System. The IT rate has been derived in accordance with Commission policy, and the tariff includes an IT revenue crediting methodology whereby revenues from interruptible transportation service are credited to firm transportation shippers. A rate floor consistent with FERC precedent has been established to prevent subsidization of interruptible service. The IT rate derivation is described in detail in Dr. Orlov's supplemental testimony.

Item 4 — Load Factor Justification. The Deficiency Letter required Ridgeline to provide adequate justification for its proposed load factor assumption or to revise the load factor. In response, Ridgeline has modified its load factor assumption from 100% to 75%, which Ridgeline submits is reasonable in light of the system's actual operating experience, projected throughput levels, and the characteristics of firm transportation contracts on the system. The revised 75% load factor yields revised billing determinants of 328,500,000 Dth/yr. Supporting analysis of the load factor assumption, including comparisons to load factors approved by the Commission for other similarly situated pipeline systems, is provided in Dr. Orlov's supplemental testimony.

Item 5 — Capacity Release Provisions. The Deficiency Letter identified the absence of capacity release provisions as a deficiency. In response, Ridgeline has added comprehensive capacity release provisions to the General Terms and Conditions of the redesigned tariff, fully addressing Commission requirements for capacity release posting, bidding, and prearranged deal procedures. The capacity release provisions are consistent with the Commission's regulations at 18 C.F.R. § 284.8 and Commission precedent. The provisions are described in detail in Dr. Orlov's supplemental testimony.

Item 6 — NAESB Standards Compliance. The Deficiency Letter required Ridgeline to revise its tariff for full compliance with NAESB Wholesale Gas Quadrant Version 3.2 standards. In response, Ridgeline has revised its operational flow order provisions and related tariff sections to conform to NAESB WGQ Version 3.2 requirements, including but not limited to nomination cycles, confirmation procedures, scheduling, allocation, balancing, and operational flow order priority structures. Compliance with NAESB standards is described in Dr. Orlov's supplemental testimony.

Item 7 — EBB Posting Requirements. The Deficiency Letter required Ridgeline to incorporate electronic bulletin board posting requirements into its tariff. In response, Ridgeline has added comprehensive EBB posting provisions to the General Terms and Conditions, covering capacity availability, transactional data, index of customers, operationally available capacity, and operational notices. The EBB provisions comply with the Commission's regulations at 18 C.F.R. § 284.13(d) and applicable Commission orders. The EBB provisions are described in Dr. Orlov's supplemental testimony.

Item 8 — Shipper-Must-Have-Title Provisions. The Deficiency Letter required Ridgeline to include adequate shipper-must-have-title provisions in its tariff. In response, Ridgeline has incorporated shipper-must-have-title provisions into the General Terms and Conditions, requiring shippers to hold title to the gas at the time of nomination and to maintain title through the point of delivery, consistent with Commission policy. The provisions are described in Dr. Orlov's supplemental testimony.

Item 9 — Interconnection Agreement as Rate Schedule. The Deficiency Letter required Ridgeline to file the Interconnection Agreement between Ridgeline and ATPC as a FERC rate schedule. In response, the Interconnection Agreement is now included as a rate schedule within the redesigned tariff, as described in Section VI of this letter and in Dr. Orlov's supplemental testimony.

Item 10 — Penalty Revenue Crediting. The Deficiency Letter required Ridgeline to include a penalty revenue crediting mechanism. In response, Ridgeline has added penalty revenue crediting provisions to the General Terms and Conditions, providing that revenues collected from penalties assessed for scheduling violations, unauthorized overruns, and other tariff infractions will be credited to non-offending shippers in accordance with Commission policy. The provisions are described in Dr. Orlov's supplemental testimony.

Item 11 — Creditworthiness Provisions. The Deficiency Letter required Ridgeline to include comprehensive creditworthiness provisions in its tariff. In response, Ridgeline has added detailed creditworthiness provisions to the General Terms and Conditions, including requirements for collateral (letters of credit, guarantees, and cash deposits), unsecured credit limits based on the shipper's tangible net worth and financial condition, and credit rating thresholds tied to investment-grade ratings from nationally recognized statistical rating organizations. The provisions also address procedures for requesting and evaluating creditworthiness, adequate assurance provisions, and dispute resolution procedures related to creditworthiness determinations. The creditworthiness provisions are described in detail in Dr. Orlov's supplemental testimony.

Item 12 — Segmentation and Flexible Points. The Deficiency Letter required Ridgeline to include segmentation and flexible receipt/delivery point provisions. In response, Ridgeline has added provisions to the General Terms and Conditions permitting firm transportation shippers to segment their capacity and to designate flexible receipt and delivery points, subject to operational feasibility and scheduling priority provisions. The segmentation and flexible point provisions are described in Dr. Orlov's supplemental testimony.

Item 13 — GHG Emission Cost Recovery. The Deficiency Letter identified the need for Ridgeline to address the recovery of greenhouse gas ("GHG") emission costs that may be imposed on the pipeline system by federal or state regulatory requirements. In response, Ridgeline has incorporated greenhouse gas emission cost recovery provisions into the General Terms and Conditions, including a GHG cost tracker and passthrough mechanism. The provisions address the recovery of costs arising from emerging FERC and state-level requirements related to methane emissions reporting, carbon pricing, and environmental compliance, and are designed to provide transparency and predictability for shippers while allowing Ridgeline to recover prudently incurred GHG compliance costs. The GHG emission cost recovery provisions are described in detail in Dr. Orlov's supplemental testimony.

Item 14 — Order No. 2222 DER Aggregation. The Deficiency Letter required Ridgeline to address the implications of FERC Order No. 2222 regarding distributed energy resource ("DER") aggregation for the Ridgeline Pipeline System. In response, Ridgeline has incorporated provisions into the General Terms and Conditions addressing Order No. 2222 DER aggregation implications, including renewable energy interconnection considerations relevant to DEH's 250 MW wind portfolio currently under development adjacent to the Ridgeline Pipeline System in West Virginia and Pennsylvania. The provisions address coordination between the pipeline system and DER aggregation participants and the potential impact of DER integration on pipeline scheduling and operational planning. The provisions are described in Dr. Orlov's supplemental testimony.

As noted above, the instant filing completes Ridgeline's response to all fourteen deficiency items. The partial response filed on March 15, 2023, which addressed Deficiency Items 1 through 4 and Items 7 through 10, is hereby superseded in its entirety by the redesigned tariff and supplemental testimony submitted herewith.

VI. Interconnection Authorization

The filing includes updated interconnection authorization materials for physical interconnection with ATPC at the Wetzel County Interconnect. The Wetzel County Interconnect is located at milepost 0.0 of the Ridgeline Pipeline System, where Ridgeline's 24-inch mainline ties into ATPC's existing 30-inch mainline at ATPC Milepost 412.6 in Wetzel County, West Virginia.

The interconnection facilities consist of the following principal components:

• A new meter station equipped with ultrasonic flow meters configured in three parallel runs of 12-inch metering pipes, gas chromatographs for gas quality measurement, and full integration with Ridgeline's and ATPC's respective SCADA systems;

• A pig launcher/receiver for pipeline inspection and maintenance purposes; and

• Associated valving, piping, and control infrastructure necessary for safe and reliable operation of the interconnection.

The estimated total cost of the interconnection facilities is $22.3 million. Ridgeline proposes the following allocation of interconnection costs between the parties:

Ridgeline's proposed cost allocation is based on cost-causation principles, taking into account the relative usage and benefit that each party derives from the interconnection facilities, the relative capacity of each party's pipeline system at the point of interconnection, and the fact that the interconnection provides ATPC with access to Ridgeline's system capacity and the upstream production areas it serves.

The design capacity at the Wetzel County Interconnect is 800 MMcf/d bidirectional, with the potential for expansion to 1.2 Bcf/d through the addition of supplemental compression and metering capacity.

In compliance with Deficiency Item 9, the Interconnection Agreement between Ridgeline and ATPC is now filed as a FERC rate schedule within the redesigned tariff. The Interconnection Agreement sets forth the rights and obligations of each party with respect to the design, construction, ownership, operation, and maintenance of the interconnection facilities, as well as the allocation of costs, indemnification provisions, and dispute resolution procedures.

Ridgeline notes that ATPC's position regarding cost allocation remains contested. ATPC has advocated for a 50/50 cost allocation split, which would result in each party bearing $11.15 million of the total interconnection facilities cost. Ridgeline disagrees with ATPC's proposed allocation and maintains that its proposed 34.1%/65.9% allocation is consistent with cost-causation principles and Commission precedent. This issue remains a contested matter for resolution in the Track II hearing proceedings.

VII. Request to Reactivate Proceeding and Lift Dormant Status

Ridgeline respectfully requests that the Commission lift the dormant status designation that was imposed on this proceeding by ALJ Whitfield's order of September 8, 2023 in connection with the grant of the second extension of time. Now that Ridgeline has completed its comprehensive response to all fourteen deficiency items and has filed the redesigned tariff and supplemental testimony, the basis for the dormant classification no longer exists. The proceeding is ripe for the resumption of the Track II hearing schedule.

Ridgeline further requests that ALJ Whitfield convene a status and scheduling conference at the earliest practicable date to establish a revised Track II procedural schedule for the resumption of hearings. Ridgeline proposes that the following procedural milestones be discussed at the scheduling conference and incorporated into the revised procedural schedule:

1. A period for answering and responsive testimony by intervenors and Commission Trial Staff to the redesigned tariff and supplemental pre-filed testimony submitted herewith;

2. A period for rebuttal testimony by Ridgeline;

3. A technical conference, if the presiding judge determines that such a conference would be beneficial to narrow the issues for hearing;

4. An evidentiary hearing; and

5. An initial decision by the presiding judge.

Ridgeline is prepared to proceed expeditiously and will cooperate with the Commission and all parties in establishing a schedule that provides adequate time for thorough review of the filing while also ensuring that the proceeding moves forward in a timely manner.

Ridgeline notes that settlement discussions remain ongoing and reserves the right to continue settlement negotiations in parallel with the resumed hearing proceedings, as described in Section VIII below.

VIII. Settlement Status

As noted in Section II of this letter, four settlement conferences have been held before Settlement Judge Howard Margolis on November 30, 2022; March 8, 2023; July 12, 2023; and January 18, 2024. While the settlement conferences have been productive in narrowing certain areas of dispute among the parties, no settlement has been reached to date.

The parties remain approximately $0.058/Dth apart on the recourse rate. Specifically, Ridgeline's current position reflects a floor recourse rate of $0.3140/Dth, while ATPC and MGPC have indicated a ceiling of approximately $0.2560/Dth. CMGA has generally aligned its position with that of ATPC and MGPC on rate-level issues.

The key unresolved issues that have prevented a settlement to date are as follows:

1. Return on Equity. ATPC has proposed an ROE of 10.75%, MGPC has proposed an ROE of 11.25%, and Ridgeline proposes an ROE of 12.50%. The spread between the parties' positions on ROE represents the single largest component of the rate differential.

2. Interconnection Cost Allocation. ATPC advocates for a 50/50 split of interconnection costs, which would result in each party bearing $11.15 million. Ridgeline maintains its proposed allocation of 34.1% to Ridgeline ($7.6 million) and 65.9% to ATPC ($14.7 million), based on cost-causation principles.

3. Load Factor. The intervenors (ATPC, MGPC, and CMGA) have advocated for a load factor of 85% or higher, which would increase the billing determinants and decrease the recourse rate. Ridgeline proposes a 75% load factor, supported by the analysis in Dr. Orlov's supplemental testimony.

Ridgeline remains willing to engage in further settlement discussions and believes that the comprehensive redesign of the tariff and the revised rate design submitted herewith may provide a basis for renewed settlement negotiations. Ridgeline respectfully requests that Settlement Judge Margolis remain available to facilitate further settlement discussions as the Track II hearing schedule is reactivated.

IX. Service and Filing Details

Copies of this filing, including the transmittal letter and all enclosed documents described herein, have been served on all parties listed on the official service list in FERC Docket Nos. RP22-847-000 and RP22-847-001 as of the date of this filing. The following parties have been served:

• Appalachian Trunk Pipeline Company, LLC — served through counsel: William Pratt, Esq., Kellner, Royce & Dillard LLP, One PPG Place, Suite 2800, Pittsburgh, Pennsylvania 15222.

• Mountainside Gas Producers Coalition — served through counsel: Rebekah Montague, Esq., Whitmore & Sable LLP, 1200 New Hampshire Avenue NW, Suite 600, Washington, DC 20036.

• Clearwater Municipal Gas Authority — served through counsel: Stephen Greer, Esq., Fordham Municipal Law Group PC, 312 Adams Avenue, Suite 100, Scranton, Pennsylvania 18503.

• FERC Trial Staff — served upon Jonathan Briggs, Esq. and Dr. Miriam Okafor, Office of the General Counsel / Office of Energy Market Regulation, Federal Energy Regulatory Commission, 888 First Street NE, Washington, DC 20426.

This filing has been made electronically via the Commission's eFiling system in accordance with the Commission's regulations and applicable orders. Where required, copies have also been served by first-class United States mail, postage prepaid, on the date hereof.

Ridgeline certifies that this filing complies with 18 C.F.R. § 154.7 (statement of nature of filing) and 18 C.F.R. § 385.2010 (service requirements). A Statement of Nature of Filing and Tariff Summary prepared in accordance with 18 C.F.R. § 154.7 is included among the enclosed documents. A Certificate of Service is attached hereto.

X. Listing of Enclosed Documents

The following documents are enclosed with this filing:

1. Redesigned FERC Gas Tariff, Original Volume No. 1, for Ridgeline Midstream Services LLC (clean and redline versions);

2. Supplemental Pre-Filed Testimony of Dr. Natasha Orlov, Director of Rates & Regulatory, Ridgeline Midstream Services LLC (with exhibits);

3. Supplemental Pre-Filed Testimony of Angela Moretti, VP, Finance & Treasurer, Ridgeline Midstream Services LLC (with exhibits);

4. Updated Exhibits A through P, including revised cost-of-service schedules, rate base calculations, rate design workpapers, system map, operating data, depreciation schedules, and capital structure supporting documentation;

5. Interconnection Agreement between Ridgeline Midstream Services LLC and Appalachian Trunk Pipeline Company, LLC (filed as a FERC rate schedule);

6. Statement of Nature of Filing and Tariff Summary per 18 C.F.R. § 154.7;

7. Verification and Certificate of Accuracy, signed by James K. Winfield, Chief Executive Officer & President, Ridgeline Midstream Services LLC; and

8. Certificate of Service.

XI. Contact Information for Correspondence

All correspondence and communications regarding this filing should be directed to the following counsel for Ridgeline:

George Trujillo, Partner Calderwood & Harkness LLP 1601 K Street NW, Suite 900 Washington, DC 20006 Telephone: (202) 555-4110

Email: gtrujillo@calderwoodharkness.com

Brett Callahan, Lead Associate Calderwood & Harkness LLP 1601 K Street NW, Suite 900 Washington, DC 20006 Telephone: (202) 555-4123

Email: bcallahan@calderwoodharkness.com

David Stanton, Associate Calderwood & Harkness LLP 1601 K Street NW, Suite 900 Washington, DC 20006 Telephone: (202) 555-4137

Email: dstanton@calderwoodharkness.com

C&H Matter No. 1016-00005

Communications may also be directed to the following representatives of Ridgeline:

James K. Winfield, Chief Executive Officer & President Ridgeline Midstream Services LLC 700 Kanawha Boulevard East, Suite 1400 Charleston, West Virginia 25301 Telephone: (304) 555-7200

Email: jwinfield@ridgelinemidstream.com

Dr. Natasha Orlov, Director of Rates & Regulatory Ridgeline Midstream Services LLC 700 Kanawha Boulevard East, Suite 1400 Charleston, West Virginia 25301 Telephone: (304) 555-7245

Email: norlov@ridgelinemidstream.com

XII. Closing

Ridgeline respectfully requests that the Commission accept the enclosed redesigned FERC Gas Tariff, Original Volume No. 1, and supplemental pre-filed testimony for filing; lift the dormant status designation on this proceeding; and direct the reactivation of the Track II procedural schedule so that this proceeding may proceed to hearing and resolution. Ridgeline stands ready to participate fully in all further proceedings and to work constructively with the Commission, Trial Staff, and all parties toward a just and reasonable resolution of the matters pending in this docket.

Should the Commission or its Staff have any questions regarding this filing, please do not hesitate to contact undersigned counsel.

Respectfully submitted,

CALDERWOOD & HARKNESS LLP

By: ________

George Trujillo, Partner Calderwood & Harkness LLP 1601 K Street NW, Suite 900 Washington, DC 20006 Telephone: (202) 555-4110

Email: gtrujillo@calderwoodharkness.com

Counsel for Ridgeline Midstream Services LLC

CERTIFICATE OF SERVICE

I, David Stanton, an associate with the law firm of Calderwood & Harkness LLP, hereby certify that on this 21st day of February, 2025, a true and correct copy of the foregoing Transmittal Letter and all enclosed documents filed on behalf of Ridgeline Midstream Services LLC in FERC Docket Nos. RP22-847-000 and RP22-847-001 was served upon all parties listed on the official service list maintained by the Secretary of the Federal Energy Regulatory Commission in the above-captioned dockets by the following methods:

(1) Electronic Filing — via the Commission's eFiling system, in accordance with the Commission's regulations at 18 C.F.R. § 385.2010 and applicable Commission orders; and

(2) First-Class United States Mail — postage prepaid, to the following parties and their counsel of record:

Appalachian Trunk Pipeline Company, LLC c/o William Pratt, Esq. Kellner, Royce & Dillard LLP One PPG Place, Suite 2800 Pittsburgh, Pennsylvania 15222

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

Clearwater Municipal Gas Authority c/o Stephen Greer, Esq. Fordham Municipal Law Group PC 312 Adams Avenue, Suite 100 Scranton, Pennsylvania 18503

FERC Trial Staff c/o Jonathan Briggs, Esq. Office of the General Counsel Federal Energy Regulatory Commission 888 First Street NE Washington, DC 20426

________________________________________

David Stanton Associate, Calderwood & Harkness LLP 1601 K Street NW, Suite 900 Washington, DC 20006 Telephone: (202) 555-4137

Email: dstanton@calderwoodharkness.com

Date: February 21, 2025

Rate Base Component	Amount ($ millions)
Net Plant in Service	$563.71
Working Capital Allowance	$18.64
Accumulated Deferred Income Taxes (ADIT)	($12.45)
Other Rate Base Items (Gas Stored, Prepayments, Materials & Supplies)	$42.50
Total Rate Base	$612.40
Expense Component	Amount ($ millions)
Depreciation Expense (2.5% straight-line)	$14.68
Operations & Maintenance Expense	$13.92
Administrative & General Expense	$5.14
Taxes Other Than Income (Property & Franchise)	$3.80
Income Tax Allowance	$15.04
Revenue Credits	($6.00)
Component	Amount ($ millions)
Return on Rate Base	$56.57
Depreciation Expense	$14.68
Operations & Maintenance Expense	$13.92
Administrative & General Expense	$5.14
Taxes Other Than Income	$3.80
Income Tax Allowance	$15.04
Revenue Credits	($6.00)
Total Cost of Service	$103.15
Party	Proposed Share	Amount ($ millions)
Ridgeline Midstream Services LLC	34.1%	$7.6
Appalachian Trunk Pipeline Company, LLC	65.9%	$14.7

Total

CALDERWOOD & HARKNESS LLP Attorneys at Law
1601 K Street NW, Suite 900 Washington, DC 20006
Telephone: (202) 555-4100 Facsimile: (202) 555-4101 www.calderwoodharkness.com
February 21, 2025
VIA ELECTRONIC FILING (eFiling) AND FIRST-CLASS MAIL
Kimberly D. Bose, Secretary Federal Energy Regulatory Commission 888 First Street NE Washington, DC 20426
Re: Ridgeline Midstream Services LLC FERC Docket Nos. RP22-847-000 (Rate Case) and RP22-847-001 (Interconnection) Filing of Redesigned FERC Gas Tariff, Original Volume No. 1, and Supplemental Testimony Ridgeline FERC Code: 960442
Dear Secretary Bose:
I. Introduction and Purpose of Filing
Calderwood & Harkness LLP, on behalf of its client Ridgeline Midstream Services LLC ("Ridgeline" or "RMS"), a Delaware limited liability company with its principal office at 700 Kanawha Boulevard East, Suite 1400, Charleston, West Virginia 25301, hereby submits the enclosed redesigned FERC Gas Tariff, Original Volume No. 1, together with supplemental pre-filed testimony and supporting exhibits, for filing with the Federal Energy Regulatory Commission (the "Commission" or "FERC") in the above-captioned dockets.
This filing is made pursuant to Sections 4 and 7 of the Natural Gas Act ("NGA"), 15 U.S.C. §§ 717c and 717f, and the Commission's implementing regulations at 18 C.F.R. Parts 154, 157, and 284. The filing constitutes Ridgeline's comprehensive response to the Deficiency Letter issued by the Commission's Office of Energy Market Regulation ("OEMR") on January 19, 2023, which identified fourteen (14) specific deficiency items requiring correction or supplementation in Ridgeline's original tariff filing of May 12, 2022. Each of the fourteen deficiency items is addressed in full through the redesigned tariff provisions and the supplemental pre-filed testimony submitted herewith, as described in detail in Section V of this transmittal letter.
This filing is made in compliance with the deadline established by Administrative Law Judge Clara Whitfield in her order of March 4, 2024 (the "Third Extension Order"), which granted Ridgeline's third motion for extension of time and set February 21, 2025 as the final deadline for filing the redesigned tariff and supplemental testimony. Ridgeline has complied with all conditions imposed in the Third Extension Order, including the filing of quarterly status reports on June 15, 2024; September 14, 2024; and December 13, 2024.
In connection with this filing, Ridgeline respectfully requests that the Commission lift the dormant status designation currently applicable to this proceeding and direct that the Track II procedural schedule be reactivated so that the proceeding may move forward to hearing and resolution. As set forth more fully below, Ridgeline believes the redesigned tariff and supplemental testimony fully cure all identified deficiencies and provide a sound basis for the Commission to evaluate Ridgeline's proposed rates and terms of service.
II. Background and Procedural History
On May 12, 2022, Ridgeline filed with the Commission its application seeking approval of an initial tariff rate for interstate transportation service on the Ridgeline Pipeline System and authorization for physical interconnection with the pipeline network of Appalachian Trunk Pipeline Company, LLC ("ATPC") at the Wetzel County Interconnect, located in Wetzel County, West Virginia. The filing was docketed by the Commission as Docket No. RP22-847-000 (rate case) and Docket No. RP22-847-001 (interconnection).
Ridgeline is a wholly owned subsidiary of Dunmore Energy Holdings Ltd. ("DEH"), a Cayman Islands exempted limited company (Cayman Registry No. CR-381204). DEH is the ultimate parent entity of Ridgeline and provides certain administrative and financial support services to Ridgeline pursuant to a Management Services Agreement. The Ridgeline Pipeline System is Ridgeline's sole jurisdictional asset and consists of 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"), equivalent to 1,200,000 dekatherms per day ("Dth/d"), and is supported by three compressor stations with an aggregate installed compression capacity of 45,000 horsepower ("HP"). The Ridgeline Pipeline System was placed in service on October 1, 2021.
On June 14, 2022, the Commission issued a Notice of Filing and Instituting Proceeding in this docket, establishing a deadline of August 15, 2022 for motions to intervene and protests. During the intervention period, three parties filed timely motions to intervene:
•  Mountainside Gas Producers Coalition ("MGPC") filed its motion to intervene on July 28, 2022. MGPC is an unincorporated association of natural gas producers operating in the Appalachian Basin that ship or seek to ship gas on the Ridgeline Pipeline System.
•  Clearwater Municipal Gas Authority ("CMGA") filed its motion to intervene on August 1, 2022. CMGA is a municipal gas distribution authority serving residential and commercial customers in portions of southwestern Pennsylvania and northern West Virginia.
•  Appalachian Trunk Pipeline Company, LLC ("ATPC") filed its motion to intervene and protest on August 15, 2022. ATPC is the owner and operator of the ATPC mainline system, with which Ridgeline seeks to interconnect at the Wetzel County Interconnect. ATPC's protest raised objections to, among other things, Ridgeline's proposed return on equity, load factor assumptions, and the proposed allocation of interconnection costs.
On September 22, 2022, the Commission issued an order granting all three motions to intervene, establishing a Track II procedural schedule for the hearing of Ridgeline's rate case application, and appointing Settlement Judge Howard Margolis to facilitate settlement discussions among the parties. Administrative Law Judge Clara Whitfield was subsequently appointed as the presiding judge for the hearing proceeding on November 14, 2022, and a prehearing conference was held on the same date at which the initial hearing schedule was established.
On December 5, 2022, Ridgeline filed its pre-filed direct testimony of seven witnesses, covering all aspects of the proposed tariff rate, cost of service, rate design, system operations, and interconnection facilities. On January 9, 2023, ATPC, MGPC, and CMGA each filed answering testimony through their respective expert witnesses, raising a number of challenges to Ridgeline's proposed rate design, cost of service, and tariff provisions.
On January 19, 2023, the Commission's Office of Energy Market Regulation issued a Deficiency Letter identifying fourteen (14) deficiencies in Ridgeline's tariff filing (the "Deficiency Letter"). The deficiencies ranged from inadequate support for Ridgeline's proposed return on equity and load factor assumptions to the absence of key tariff provisions required under FERC policy and applicable regulations, including fuel-use and lost-and-unaccounted-for gas tracker mechanisms, interruptible transportation rate derivation, capacity release provisions, NAESB Wholesale Gas Quadrant ("WGQ") Version 3.2 compliance, electronic bulletin board ("EBB") posting requirements, shipper-must-have-title provisions, creditworthiness provisions, and the treatment of the interconnection agreement as a FERC rate schedule.
On February 6, 2023, ALJ Whitfield issued a procedural order staying the Track II hearing schedule pending Ridgeline's response to the Deficiency Letter. On March 15, 2023, Ridgeline filed a partial response to the Deficiency Letter, addressing eight of the fourteen deficiency items (specifically, Items 1 through 4 and Items 7 through 10). The instant filing completes Ridgeline's response to all remaining deficiency items and supersedes the March 15, 2023 partial response in its entirety.
Following the issuance of the Deficiency Letter and the stay of the procedural schedule, Ridgeline obtained three successive extensions of time to prepare its comprehensive response:
•  First Extension: Granted by ALJ Whitfield on May 10, 2023, providing an additional 120 days and setting a deadline of August 28, 2023.
•  Second Extension: Granted by ALJ Whitfield on September 8, 2023, providing an additional 180 days and setting a deadline of February 23, 2024. In connection with this extension, ALJ Whitfield classified the proceeding as dormant pursuant to 18 C.F.R. § 385.710.
•  Third Extension: Granted by ALJ Whitfield on March 4, 2024, providing an additional twelve (12) months and setting a final deadline of February 21, 2025. The Third Extension Order imposed conditions requiring Ridgeline to file quarterly status reports with the Commission and serve copies on all parties, which Ridgeline has done on each required date.
In compliance with the conditions of the Third Extension Order, Ridgeline filed three quarterly status reports with the Commission on June 15, 2024; September 14, 2024; and December 13, 2024. Each report described the progress of Ridgeline's tariff redesign effort and confirmed Ridgeline's intention to meet the February 21, 2025 filing deadline.
In connection with the tariff redesign effort, Ridgeline engaged Braswell Energy Consulting Group LLC ("Braswell" or "BEC") on April 15, 2023 (Engagement No. BEC-2023-0041) to assist with the comprehensive redesign of Ridgeline's FERC Gas Tariff and preparation of supporting cost-of-service and rate design analyses. Braswell was engaged under the direction of Dr. Raymond Braswell, a former senior economist with the Commission's Office of Energy Market Regulation, whose experience includes participation in more than forty FERC rate proceedings. Dr. Braswell's team provided substantial analytical and drafting support for the redesigned tariff and the supplemental testimony submitted herewith.
Throughout the course of this proceeding, the parties have participated in four settlement conferences before Settlement Judge Margolis, held on November 30, 2022; March 8, 2023; July 12, 2023; and January 18, 2024. While those conferences have narrowed certain areas of disagreement among the parties, no settlement has been reached to date. The parties remain approximately $0.058/Dth apart on the recourse rate. The settlement status is described in more detail in Section VIII of this letter.
III. Description of Enclosed Filing Materials
The enclosed filing consists of the following materials, each of which is described in greater detail in the subsections below.
A. Redesigned FERC Gas Tariff, Original Volume No. 1
Ridgeline submits herewith its complete Redesigned FERC Gas Tariff, Original Volume No. 1, filed as a Part 284, Subpart G open-access transportation tariff for interstate natural gas pipeline service. The redesigned tariff has been comprehensively revised and reorganized to address all fourteen deficiency items identified in the Deficiency Letter, to incorporate current FERC policy requirements, and to conform to the Commission's applicable regulations and orders. The redesigned tariff includes the following components:
•  Rate Schedule FT-1 (Firm Transportation Service): Sets forth the terms, conditions, and rates applicable to firm transportation service on the Ridgeline Pipeline System, including the revised reservation rate and usage rate, maximum daily quantity provisions, scheduling priorities, and force majeure provisions.
•  Rate Schedule IT-1 (Interruptible Transportation Service): A new rate schedule providing for interruptible transportation service on the Ridgeline Pipeline System, with a derived interruptible transportation rate, IT revenue crediting methodology, and rate floor consistent with FERC policy, addressing Deficiency Item 3.
•  Revised General Terms and Conditions ("GT&C"): Extensively revised General Terms and Conditions addressing, among other things, fuel-use and lost-and-unaccounted-for gas ("FL&U") tracker mechanisms, capacity release provisions, NAESB WGQ Version 3.2 compliance, electronic bulletin board posting requirements, shipper-must-have-title provisions, creditworthiness provisions, segmentation and flexible receipt/delivery point provisions, penalty revenue crediting, greenhouse gas emission cost recovery provisions, and provisions addressing FERC Order No. 2222 distributed energy resource aggregation implications.
•  Form of Service Agreement: A revised pro forma service agreement for firm and interruptible transportation service on the Ridgeline Pipeline System.
•  Interconnection Agreement between Ridgeline and ATPC: The Interconnection Agreement between Ridgeline and Appalachian Trunk Pipeline Company, LLC for physical interconnection at the Wetzel County Interconnect is now filed as a FERC rate schedule within the tariff, in compliance with Deficiency Item 9.
Both clean and redline versions of the redesigned tariff are submitted. All tariff sheets in the redline version are marked to show changes from the original filing of May 12, 2022, enabling the Commission and parties to readily identify all modifications.
B. Supplemental Pre-Filed Testimony
Ridgeline submits the supplemental pre-filed testimony of two witnesses in support of the redesigned tariff:
•  Supplemental Pre-Filed Testimony of Dr. Natasha Orlov, Director of Rates & Regulatory, Ridgeline Midstream Services LLC. Dr. Orlov's testimony addresses all fourteen deficiency items identified in the Deficiency Letter and provides a comprehensive description and justification of the redesigned tariff provisions. Specifically, Dr. Orlov's testimony covers the modified fixed-variable rate methodology; the revised 75% load factor billing determinants; the new FL&U tracker mechanism, including the percentage retention methodology and annual true-up procedures; the capacity release provisions; the NAESB WGQ Version 3.2 compliance revisions; the EBB posting requirements; the shipper-must-have-title provisions; the creditworthiness provisions, including collateral requirements, unsecured credit limits, and credit rating thresholds; the segmentation and flexible receipt/delivery point provisions; the greenhouse gas emission cost recovery provisions, including the proposed GHG cost tracker and passthrough mechanism addressing emerging FERC and state-level requirements; and the provisions addressing FERC Order No. 2222 distributed energy resource aggregation implications, including renewable energy interconnection considerations relevant to DEH's 250 MW wind portfolio currently under development.
•  Supplemental Pre-Filed Testimony of Angela Moretti, VP, Finance & Treasurer, Ridgeline Midstream Services LLC. Ms. Moretti's testimony presents the revised cost-of-service model and updated rate base for the Ridgeline Pipeline System, including the revised capital structure, return on equity, cost of debt, depreciation analysis, operating expenses, tax allowance, and revenue credits. Ms. Moretti's testimony also provides updated financial data and supporting calculations for each component of the revised total cost of service.
Both witnesses' testimony is accompanied by supporting exhibits, which are referenced and described within the testimony.
C. Supporting Exhibits
Ridgeline submits updated Exhibits A through P in support of the redesigned tariff and supplemental testimony. The updated exhibits include, without limitation, revised cost-of-service schedules, rate base calculations, rate design workpapers, depreciation schedules, capital structure supporting documentation, operating statistics, system maps, and related financial and operational data. Each exhibit has been updated to reflect current information and to support the revised rate design described in Section IV of this letter and in the supplemental testimony.
IV. Summary of Revised Rate Design and Cost of Service
The following is a summary of Ridgeline's revised rate design and cost-of-service analysis, as presented in the supplemental pre-filed testimony of Angela Moretti and Dr. Natasha Orlov and the supporting exhibits. A detailed description of each component and the methodologies employed is set forth in the testimony and exhibits.
A. Rate Base
Ridgeline's total rate base remains unchanged from the original filing at $612.40 million. The components of the rate base are as follows:
Net plant in service of $563.71 million reflects the original construction cost of the Ridgeline Pipeline System of $587.20 million, less accumulated depreciation of $23.49 million calculated on the basis of a 2.5% annual straight-line depreciation rate applied from the system's in-service date of October 1, 2021 through the test year. The working capital allowance of $18.64 million is calculated using the Commission's standard formula of one-eighth (1/8) of annual operations and maintenance ("O&M") expense plus administrative and general ("A&G") expense. Accumulated deferred income taxes of $12.45 million reduce the rate base in accordance with the Commission's normalization requirements. Other rate base items of $42.50 million include gas stored underground, prepayments, and materials and supplies.
B. Capital Structure and Return
Ridgeline's proposed capital structure remains unchanged from the original filing at 55% equity and 45% debt. However, Ridgeline has revised its proposed return on equity ("ROE") downward from 14.00% to 12.50%, based on an updated discounted cash flow ("DCF") proxy group analysis as of the third quarter of 2024. The updated DCF analysis is presented in the supplemental testimony of Angela Moretti and the supporting exhibits, and reflects current market conditions and the Commission's established DCF methodology.
Ridgeline's cost of debt is 5.25%, representing the weighted average cost of two tranches of outstanding indebtedness:
•  A $400 million term loan facility priced at SOFR plus 325 basis points; and
•  $150 million in aggregate principal amount of 7.875% Second Lien Senior Secured Notes due 2030.
The resulting revised weighted average cost of capital ("WACC") is 9.2375%, calculated as follows:
(0.55 × 12.50%) + (0.45 × 5.25%) = 6.875% + 2.3625% = 9.2375%
Applying the revised WACC to the total rate base of $612.40 million yields a revised return on rate base of $56.57 million ($612.40 million × 9.2375%).
C. Operating Expenses and Taxes
The following table summarizes Ridgeline's revised operating expenses and taxes:
The depreciation expense of $14.68 million reflects the annual straight-line depreciation rate of 2.5% applied to the original construction cost of $587.20 million. Revised O&M expense of $13.92 million and revised A&G expense of $5.14 million have been updated from the original filing to reflect current cost levels, as described in Ms. Moretti's testimony. Taxes other than income of $3.80 million consist principally of property taxes and franchise taxes assessed in the states of West Virginia and Pennsylvania. The revised income tax allowance of $15.04 million has been grossed up using an effective combined federal and state income tax rate of approximately 26.13%, reflecting the federal statutory rate of 21% and the West Virginia state corporate net income tax rate of 6.5%. Revenue credits of $6.00 million are applied as an offset to the cost of service.
D. Total Cost of Service
Ridgeline's revised total cost of service is $103.15 million, derived as follows:
E. Billing Determinants and Recourse Rate
The Ridgeline Pipeline System has a design capacity of 1,200,000 Dth/d (1.2 Bcf/d). In the original filing, Ridgeline utilized a 100% load factor to derive its billing determinants and proposed recourse rate. In response to Deficiency Item 4, Ridgeline has revised its load factor assumption to 75%, which Ridgeline submits is reasonable and well-supported based on the analysis presented in the supplemental testimony of Dr. Orlov.
The revised billing determinants are calculated as follows:
1,200,000 Dth/d × 365 days × 75% = 328,500,000 Dth/yr
Dividing the revised total cost of service of $103.15 million by the revised billing determinants of 328,500,000 Dth/yr yields a revised proposed recourse rate of $0.3140/Dth (total), comprising a reservation rate of $0.3102/Dth and a usage rate of $0.0038/Dth.
As of the date of this filing, the Ridgeline Pipeline System has a current average system throughput of approximately 680 million cubic feet per day ("MMcf/d"), representing approximately 56.67% utilization of the system's design capacity. Ridgeline expects throughput to increase as additional shippers contract for service on the system and as upstream production activity in the Appalachian Basin continues to expand.
V. Summary of Responses to Deficiency Items
The redesigned FERC Gas Tariff, Original Volume No. 1, and the supplemental pre-filed testimony submitted herewith collectively and comprehensively address each of the fourteen (14) deficiency items identified in the Commission's Deficiency Letter of January 19, 2023. The following is a summary of how each deficiency item has been addressed. Detailed discussion and justification of each response is provided in the supplemental testimony of Dr. Natasha Orlov and, where applicable, Angela Moretti.
Item 1 — ROE Support. The Deficiency Letter required Ridgeline to provide adequate support for its proposed return on equity. In response, Ridgeline has reduced its proposed ROE from 14.00% to 12.50% and has submitted an updated DCF proxy group analysis as of the third quarter of 2024, prepared in accordance with the Commission's established two-step DCF methodology. The updated analysis identifies a proxy group of comparable pipeline companies, calculates the median and mean zone of reasonableness, and demonstrates that Ridgeline's proposed 12.50% ROE falls within the upper half of the zone of reasonableness, as is appropriate given Ridgeline's status as a new entrant pipeline with unique business and financial risk characteristics. The updated DCF analysis is presented in detail in the supplemental testimony of Angela Moretti and the supporting exhibits.
Item 2 — FL&U Tracker Mechanism. The Deficiency Letter identified the absence of a fuel-use and lost-and-unaccounted-for gas ("FL&U") tracker mechanism as a deficiency. In response, Ridgeline has incorporated a new FL&U tracker mechanism into the General Terms and Conditions of the redesigned tariff. The mechanism provides for a percentage retention of gas-in-kind at each receipt point to compensate for compressor fuel usage and system losses. The tariff establishes an initial FL&U percentage based on the system's actual operating experience and provides for annual true-up procedures to adjust the percentage based on actual fuel usage and losses, with shipper refunds or surcharges as appropriate. The FL&U tracker provisions are described in detail in Dr. Orlov's supplemental testimony.
Item 3 — IT Rate Derivation. The Deficiency Letter required Ridgeline to include a properly derived interruptible transportation rate. In response, Ridgeline has added a new Rate Schedule IT-1 to the redesigned tariff, providing for interruptible transportation service on the Ridgeline Pipeline System. The IT rate has been derived in accordance with Commission policy, and the tariff includes an IT revenue crediting methodology whereby revenues from interruptible transportation service are credited to firm transportation shippers. A rate floor consistent with FERC precedent has been established to prevent subsidization of interruptible service. The IT rate derivation is described in detail in Dr. Orlov's supplemental testimony.
Item 4 — Load Factor Justification. The Deficiency Letter required Ridgeline to provide adequate justification for its proposed load factor assumption or to revise the load factor. In response, Ridgeline has modified its load factor assumption from 100% to 75%, which Ridgeline submits is reasonable in light of the system's actual operating experience, projected throughput levels, and the characteristics of firm transportation contracts on the system. The revised 75% load factor yields revised billing determinants of 328,500,000 Dth/yr. Supporting analysis of the load factor assumption, including comparisons to load factors approved by the Commission for other similarly situated pipeline systems, is provided in Dr. Orlov's supplemental testimony.
Item 5 — Capacity Release Provisions. The Deficiency Letter identified the absence of capacity release provisions as a deficiency. In response, Ridgeline has added comprehensive capacity release provisions to the General Terms and Conditions of the redesigned tariff, fully addressing Commission requirements for capacity release posting, bidding, and prearranged deal procedures. The capacity release provisions are consistent with the Commission's regulations at 18 C.F.R. § 284.8 and Commission precedent. The provisions are described in detail in Dr. Orlov's supplemental testimony.
Item 6 — NAESB Standards Compliance. The Deficiency Letter required Ridgeline to revise its tariff for full compliance with NAESB Wholesale Gas Quadrant Version 3.2 standards. In response, Ridgeline has revised its operational flow order provisions and related tariff sections to conform to NAESB WGQ Version 3.2 requirements, including but not limited to nomination cycles, confirmation procedures, scheduling, allocation, balancing, and operational flow order priority structures. Compliance with NAESB standards is described in Dr. Orlov's supplemental testimony.
Item 7 — EBB Posting Requirements. The Deficiency Letter required Ridgeline to incorporate electronic bulletin board posting requirements into its tariff. In response, Ridgeline has added comprehensive EBB posting provisions to the General Terms and Conditions, covering capacity availability, transactional data, index of customers, operationally available capacity, and operational notices. The EBB provisions comply with the Commission's regulations at 18 C.F.R. § 284.13(d) and applicable Commission orders. The EBB provisions are described in Dr. Orlov's supplemental testimony.
Item 8 — Shipper-Must-Have-Title Provisions. The Deficiency Letter required Ridgeline to include adequate shipper-must-have-title provisions in its tariff. In response, Ridgeline has incorporated shipper-must-have-title provisions into the General Terms and Conditions, requiring shippers to hold title to the gas at the time of nomination and to maintain title through the point of delivery, consistent with Commission policy. The provisions are described in Dr. Orlov's supplemental testimony.
Item 9 — Interconnection Agreement as Rate Schedule. The Deficiency Letter required Ridgeline to file the Interconnection Agreement between Ridgeline and ATPC as a FERC rate schedule. In response, the Interconnection Agreement is now included as a rate schedule within the redesigned tariff, as described in Section VI of this letter and in Dr. Orlov's supplemental testimony.
Item 10 — Penalty Revenue Crediting. The Deficiency Letter required Ridgeline to include a penalty revenue crediting mechanism. In response, Ridgeline has added penalty revenue crediting provisions to the General Terms and Conditions, providing that revenues collected from penalties assessed for scheduling violations, unauthorized overruns, and other tariff infractions will be credited to non-offending shippers in accordance with Commission policy. The provisions are described in Dr. Orlov's supplemental testimony.
Item 11 — Creditworthiness Provisions. The Deficiency Letter required Ridgeline to include comprehensive creditworthiness provisions in its tariff. In response, Ridgeline has added detailed creditworthiness provisions to the General Terms and Conditions, including requirements for collateral (letters of credit, guarantees, and cash deposits), unsecured credit limits based on the shipper's tangible net worth and financial condition, and credit rating thresholds tied to investment-grade ratings from nationally recognized statistical rating organizations. The provisions also address procedures for requesting and evaluating creditworthiness, adequate assurance provisions, and dispute resolution procedures related to creditworthiness determinations. The creditworthiness provisions are described in detail in Dr. Orlov's supplemental testimony.
Item 12 — Segmentation and Flexible Points. The Deficiency Letter required Ridgeline to include segmentation and flexible receipt/delivery point provisions. In response, Ridgeline has added provisions to the General Terms and Conditions permitting firm transportation shippers to segment their capacity and to designate flexible receipt and delivery points, subject to operational feasibility and scheduling priority provisions. The segmentation and flexible point provisions are described in Dr. Orlov's supplemental testimony.
Item 13 — GHG Emission Cost Recovery. The Deficiency Letter identified the need for Ridgeline to address the recovery of greenhouse gas ("GHG") emission costs that may be imposed on the pipeline system by federal or state regulatory requirements. In response, Ridgeline has incorporated greenhouse gas emission cost recovery provisions into the General Terms and Conditions, including a GHG cost tracker and passthrough mechanism. The provisions address the recovery of costs arising from emerging FERC and state-level requirements related to methane emissions reporting, carbon pricing, and environmental compliance, and are designed to provide transparency and predictability for shippers while allowing Ridgeline to recover prudently incurred GHG compliance costs. The GHG emission cost recovery provisions are described in detail in Dr. Orlov's supplemental testimony.
Item 14 — Order No. 2222 DER Aggregation. The Deficiency Letter required Ridgeline to address the implications of FERC Order No. 2222 regarding distributed energy resource ("DER") aggregation for the Ridgeline Pipeline System. In response, Ridgeline has incorporated provisions into the General Terms and Conditions addressing Order No. 2222 DER aggregation implications, including renewable energy interconnection considerations relevant to DEH's 250 MW wind portfolio currently under development adjacent to the Ridgeline Pipeline System in West Virginia and Pennsylvania. The provisions address coordination between the pipeline system and DER aggregation participants and the potential impact of DER integration on pipeline scheduling and operational planning. The provisions are described in Dr. Orlov's supplemental testimony.
As noted above, the instant filing completes Ridgeline's response to all fourteen deficiency items. The partial response filed on March 15, 2023, which addressed Deficiency Items 1 through 4 and Items 7 through 10, is hereby superseded in its entirety by the redesigned tariff and supplemental testimony submitted herewith.
VI. Interconnection Authorization
The filing includes updated interconnection authorization materials for physical interconnection with ATPC at the Wetzel County Interconnect. The Wetzel County Interconnect is located at milepost 0.0 of the Ridgeline Pipeline System, where Ridgeline's 24-inch mainline ties into ATPC's existing 30-inch mainline at ATPC Milepost 412.6 in Wetzel County, West Virginia.
The interconnection facilities consist of the following principal components:
•  A new meter station equipped with ultrasonic flow meters configured in three parallel runs of 12-inch metering pipes, gas chromatographs for gas quality measurement, and full integration with Ridgeline's and ATPC's respective SCADA systems;
•  A pig launcher/receiver for pipeline inspection and maintenance purposes; and
•  Associated valving, piping, and control infrastructure necessary for safe and reliable operation of the interconnection.
The estimated total cost of the interconnection facilities is $22.3 million. Ridgeline proposes the following allocation of interconnection costs between the parties:
Ridgeline's proposed cost allocation is based on cost-causation principles, taking into account the relative usage and benefit that each party derives from the interconnection facilities, the relative capacity of each party's pipeline system at the point of interconnection, and the fact that the interconnection provides ATPC with access to Ridgeline's system capacity and the upstream production areas it serves.
The design capacity at the Wetzel County Interconnect is 800 MMcf/d bidirectional, with the potential for expansion to 1.2 Bcf/d through the addition of supplemental compression and metering capacity.
In compliance with Deficiency Item 9, the Interconnection Agreement between Ridgeline and ATPC is now filed as a FERC rate schedule within the redesigned tariff. The Interconnection Agreement sets forth the rights and obligations of each party with respect to the design, construction, ownership, operation, and maintenance of the interconnection facilities, as well as the allocation of costs, indemnification provisions, and dispute resolution procedures.
Ridgeline notes that ATPC's position regarding cost allocation remains contested. ATPC has advocated for a 50/50 cost allocation split, which would result in each party bearing $11.15 million of the total interconnection facilities cost. Ridgeline disagrees with ATPC's proposed allocation and maintains that its proposed 34.1%/65.9% allocation is consistent with cost-causation principles and Commission precedent. This issue remains a contested matter for resolution in the Track II hearing proceedings.
VII. Request to Reactivate Proceeding and Lift Dormant Status
Ridgeline respectfully requests that the Commission lift the dormant status designation that was imposed on this proceeding by ALJ Whitfield's order of September 8, 2023 in connection with the grant of the second extension of time. Now that Ridgeline has completed its comprehensive response to all fourteen deficiency items and has filed the redesigned tariff and supplemental testimony, the basis for the dormant classification no longer exists. The proceeding is ripe for the resumption of the Track II hearing schedule.
Ridgeline further requests that ALJ Whitfield convene a status and scheduling conference at the earliest practicable date to establish a revised Track II procedural schedule for the resumption of hearings. Ridgeline proposes that the following procedural milestones be discussed at the scheduling conference and incorporated into the revised procedural schedule:
1.  A period for answering and responsive testimony by intervenors and Commission Trial Staff to the redesigned tariff and supplemental pre-filed testimony submitted herewith;
2.  A period for rebuttal testimony by Ridgeline;
3.  A technical conference, if the presiding judge determines that such a conference would be beneficial to narrow the issues for hearing;
4.  An evidentiary hearing; and
5.  An initial decision by the presiding judge.
Ridgeline is prepared to proceed expeditiously and will cooperate with the Commission and all parties in establishing a schedule that provides adequate time for thorough review of the filing while also ensuring that the proceeding moves forward in a timely manner.
Ridgeline notes that settlement discussions remain ongoing and reserves the right to continue settlement negotiations in parallel with the resumed hearing proceedings, as described in Section VIII below.
VIII. Settlement Status
As noted in Section II of this letter, four settlement conferences have been held before Settlement Judge Howard Margolis on November 30, 2022; March 8, 2023; July 12, 2023; and January 18, 2024. While the settlement conferences have been productive in narrowing certain areas of dispute among the parties, no settlement has been reached to date.
The parties remain approximately $0.058/Dth apart on the recourse rate. Specifically, Ridgeline's current position reflects a floor recourse rate of $0.3140/Dth, while ATPC and MGPC have indicated a ceiling of approximately $0.2560/Dth. CMGA has generally aligned its position with that of ATPC and MGPC on rate-level issues.
The key unresolved issues that have prevented a settlement to date are as follows:
1.  Return on Equity. ATPC has proposed an ROE of 10.75%, MGPC has proposed an ROE of 11.25%, and Ridgeline proposes an ROE of 12.50%. The spread between the parties' positions on ROE represents the single largest component of the rate differential.
2.  Interconnection Cost Allocation. ATPC advocates for a 50/50 split of interconnection costs, which would result in each party bearing $11.15 million. Ridgeline maintains its proposed allocation of 34.1% to Ridgeline ($7.6 million) and 65.9% to ATPC ($14.7 million), based on cost-causation principles.
3.  Load Factor. The intervenors (ATPC, MGPC, and CMGA) have advocated for a load factor of 85% or higher, which would increase the billing determinants and decrease the recourse rate. Ridgeline proposes a 75% load factor, supported by the analysis in Dr. Orlov's supplemental testimony.
Ridgeline remains willing to engage in further settlement discussions and believes that the comprehensive redesign of the tariff and the revised rate design submitted herewith may provide a basis for renewed settlement negotiations. Ridgeline respectfully requests that Settlement Judge Margolis remain available to facilitate further settlement discussions as the Track II hearing schedule is reactivated.
IX. Service and Filing Details
Copies of this filing, including the transmittal letter and all enclosed documents described herein, have been served on all parties listed on the official service list in FERC Docket Nos. RP22-847-000 and RP22-847-001 as of the date of this filing. The following parties have been served:
•  Appalachian Trunk Pipeline Company, LLC — served through counsel: William Pratt, Esq., Kellner, Royce & Dillard LLP, One PPG Place, Suite 2800, Pittsburgh, Pennsylvania 15222.
•  Mountainside Gas Producers Coalition — served through counsel: Rebekah Montague, Esq., Whitmore & Sable LLP, 1200 New Hampshire Avenue NW, Suite 600, Washington, DC 20036.
•  Clearwater Municipal Gas Authority — served through counsel: Stephen Greer, Esq., Fordham Municipal Law Group PC, 312 Adams Avenue, Suite 100, Scranton, Pennsylvania 18503.
•  FERC Trial Staff — served upon Jonathan Briggs, Esq. and Dr. Miriam Okafor, Office of the General Counsel / Office of Energy Market Regulation, Federal Energy Regulatory Commission, 888 First Street NE, Washington, DC 20426.
This filing has been made electronically via the Commission's eFiling system in accordance with the Commission's regulations and applicable orders. Where required, copies have also been served by first-class United States mail, postage prepaid, on the date hereof.
Ridgeline certifies that this filing complies with 18 C.F.R. § 154.7 (statement of nature of filing) and 18 C.F.R. § 385.2010 (service requirements). A Statement of Nature of Filing and Tariff Summary prepared in accordance with 18 C.F.R. § 154.7 is included among the enclosed documents. A Certificate of Service is attached hereto.
X. Listing of Enclosed Documents
The following documents are enclosed with this filing:
1.  Redesigned FERC Gas Tariff, Original Volume No. 1, for Ridgeline Midstream Services LLC (clean and redline versions);
2.  Supplemental Pre-Filed Testimony of Dr. Natasha Orlov, Director of Rates & Regulatory, Ridgeline Midstream Services LLC (with exhibits);
3.  Supplemental Pre-Filed Testimony of Angela Moretti, VP, Finance & Treasurer, Ridgeline Midstream Services LLC (with exhibits);
4.  Updated Exhibits A through P, including revised cost-of-service schedules, rate base calculations, rate design workpapers, system map, operating data, depreciation schedules, and capital structure supporting documentation;
5.  Interconnection Agreement between Ridgeline Midstream Services LLC and Appalachian Trunk Pipeline Company, LLC (filed as a FERC rate schedule);
6.  Statement of Nature of Filing and Tariff Summary per 18 C.F.R. § 154.7;
7.  Verification and Certificate of Accuracy, signed by James K. Winfield, Chief Executive Officer & President, Ridgeline Midstream Services LLC; and
8.  Certificate of Service.
XI. Contact Information for Correspondence
All correspondence and communications regarding this filing should be directed to the following counsel for Ridgeline:
George Trujillo, Partner Calderwood & Harkness LLP 1601 K Street NW, Suite 900 Washington, DC 20006 Telephone: (202) 555-4110
Email: gtrujillo@calderwoodharkness.com
Brett Callahan, Lead Associate Calderwood & Harkness LLP 1601 K Street NW, Suite 900 Washington, DC 20006 Telephone: (202) 555-4123
Email: bcallahan@calderwoodharkness.com
David Stanton, Associate Calderwood & Harkness LLP 1601 K Street NW, Suite 900 Washington, DC 20006 Telephone: (202) 555-4137
Email: dstanton@calderwoodharkness.com
C&H Matter No. 1016-00005
Communications may also be directed to the following representatives of Ridgeline:
James K. Winfield, Chief Executive Officer & President Ridgeline Midstream Services LLC 700 Kanawha Boulevard East, Suite 1400 Charleston, West Virginia 25301 Telephone: (304) 555-7200
Email: jwinfield@ridgelinemidstream.com
Dr. Natasha Orlov, Director of Rates & Regulatory Ridgeline Midstream Services LLC 700 Kanawha Boulevard East, Suite 1400 Charleston, West Virginia 25301 Telephone: (304) 555-7245
Email: norlov@ridgelinemidstream.com
XII. Closing
Ridgeline respectfully requests that the Commission accept the enclosed redesigned FERC Gas Tariff, Original Volume No. 1, and supplemental pre-filed testimony for filing; lift the dormant status designation on this proceeding; and direct the reactivation of the Track II procedural schedule so that this proceeding may proceed to hearing and resolution. Ridgeline stands ready to participate fully in all further proceedings and to work constructively with the Commission, Trial Staff, and all parties toward a just and reasonable resolution of the matters pending in this docket.
Should the Commission or its Staff have any questions regarding this filing, please do not hesitate to contact undersigned counsel.
Respectfully submitted,
CALDERWOOD & HARKNESS LLP
By: ________
George Trujillo, Partner Calderwood & Harkness LLP 1601 K Street NW, Suite 900 Washington, DC 20006 Telephone: (202) 555-4110
Email: gtrujillo@calderwoodharkness.com
Counsel for Ridgeline Midstream Services LLC
CERTIFICATE OF SERVICE
I, David Stanton, an associate with the law firm of Calderwood & Harkness LLP, hereby certify that on this 21st day of February, 2025, a true and correct copy of the foregoing Transmittal Letter and all enclosed documents filed on behalf of Ridgeline Midstream Services LLC in FERC Docket Nos. RP22-847-000 and RP22-847-001 was served upon all parties listed on the official service list maintained by the Secretary of the Federal Energy Regulatory Commission in the above-captioned dockets by the following methods:
(1) Electronic Filing — via the Commission's eFiling system, in accordance with the Commission's regulations at 18 C.F.R. § 385.2010 and applicable Commission orders; and
(2) First-Class United States Mail — postage prepaid, to the following parties and their counsel of record:
Appalachian Trunk Pipeline Company, LLC c/o William Pratt, Esq. Kellner, Royce & Dillard LLP One PPG Place, Suite 2800 Pittsburgh, Pennsylvania 15222
Mountainside Gas Producers Coalition c/o Rebekah Montague, Esq. Whitmore & Sable LLP 1200 New Hampshire Avenue NW, Suite 600 Washington, DC 20036
Clearwater Municipal Gas Authority c/o Stephen Greer, Esq. Fordham Municipal Law Group PC 312 Adams Avenue, Suite 100 Scranton, Pennsylvania 18503
FERC Trial Staff c/o Jonathan Briggs, Esq. Office of the General Counsel Federal Energy Regulatory Commission 888 First Street NE Washington, DC 20426
________________________________________
David Stanton Associate, Calderwood & Harkness LLP 1601 K Street NW, Suite 900 Washington, DC 20006 Telephone: (202) 555-4137
Email: dstanton@calderwoodharkness.com
Date: February 21, 2025
Rate Base Component | Amount ($ millions)
Net Plant in Service | $563.71
Working Capital Allowance | $18.64
Accumulated Deferred Income Taxes (ADIT) | ($12.45)
Other Rate Base Items (Gas Stored, Prepayments, Materials & Supplies) | $42.50
Total Rate Base | $612.40
Expense Component | Amount ($ millions)
Depreciation Expense (2.5% straight-line) | $14.68
Operations & Maintenance Expense | $13.92
Administrative & General Expense | $5.14
Taxes Other Than Income (Property & Franchise) | $3.80
Income Tax Allowance | $15.04
Revenue Credits | ($6.00)
Component | Amount ($ millions)
Return on Rate Base | $56.57
Depreciation Expense | $14.68
Operations & Maintenance Expense | $13.92
Administrative & General Expense | $5.14
Taxes Other Than Income | $3.80
Income Tax Allowance | $15.04
Revenue Credits | ($6.00)
Total Cost of Service | $103.15
Party | Proposed Share | Amount ($ millions)
Ridgeline Midstream Services LLC | 34.1% | $7.6
Appalachian Trunk Pipeline Company, LLC | 65.9% | $14.7
Total | 100.0% | $22.3

CALDERWOOD & HARKNESS LLP Attorneys at Law

CALDERWOOD & HARKNESS LLP

CERTIFICATE OF SERVICE

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