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Extract to table / memo-interconnection-cost-allocation.docx
memo-interconnection-cost-allocation.docx
Parties
Harkness LLP
Ridgeline Midstream Services LLC
Dunmore Energy Holdings Ltd
Tidewater Infrastructure Partners LP
Dillard LLP
System Ridgeline Midstream Services LLC
Capitol Filings Inc
Tidewater GP Inc
Dates
October 28, 2022
August 15, 2022
May 12, 2022
October 17, 2022
November 14, 2022
November 30, 2022
October 1, 2021
August 1, 2022
July 28, 2022
June 14, 2022
Amounts
$22.3
$11.15
$14.7
$587.2
$6.1
$7.6
$8.2
$4.9
$3.3
$2.7
Obligations
shall be just and reasonable
The Commission's rejection of 50/50 splits is not categorical — an equal split may be appropriate where the evidence shows that both parties' systems impose roughly equal requirements on the interconnection facilities — but the Commission has made clear that the allocation must be driven by the evidence, not by a presumption of equality
However, a protesting party advocating an alternative allocation — in this case, ATPC's proposed 50/50 split — must present affirmative evidence supporting its position
It is not sufficient for the protestor to merely criticize the applicant's proposal; the protestor must demonstrate that its alternative allocation is consistent with cost-causation principles and would produce a just and reasonable result