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Extract to table / memo-interconnection-cost-precedent.docx
memo-interconnection-cost-precedent.docx
Parties
Harkness LLP
Dunmore Energy Holdings Ltd
Ridgeline Midstream Services LLC
Dillard LLP
System Ridgeline Midstream Services LLC
Tidewater Infrastructure Partners LP
In Ashgrove Corp
America LLC
Dates
May 12, 2022
August 15, 2022
October 1, 2021
September 22, 2022
October 17, 2022
November 14, 2022
January 19, 2023
February 21, 2025
Amounts
$22.3
$7.6
$14.7
$11.15
$587.2
$18
$4.2
$1.1
$2.3
$5.8
Obligations
Circuit has stated in clear terms that cost-causation is the "touchstone" of just and reasonable rate design, and that FERC is required to ensure that costs are allocated in a manner "at least roughly commensurate" with the benefits derived by each paying party
(iv) The extent to which each party's existing system facilities must be modified or upgraded to accommodate the interconnection is a critical factor
Circuit endorsed cost-causation as the "lodestar" of just and reasonable rate design, holding that FERC must ensure that costs are allocated to those who cause them or benefit from them