Extract to table
Pull the structured facts out of a document: parties, dates, amounts, obligations.
Extract to table / memo-ghg-cost-recovery.docx
memo-ghg-cost-recovery.docx
Parties
Harkness LLP
Dunmore Energy Holdings Ltd
Ridgeline Midstream Services LLC
Braswell Energy Consulting Group LLC
Dillard LLP
Tidewater Infrastructure Partners LP
Sable LLP
Harborview Capital Management LLC
Dates
March 22, 2024
January 19, 2023
April 15, 2023
May 12, 2022
November 14, 2022
September 22, 2022
March 15, 2023
February 6, 2023
February 21, 2025
November 15, 2023
Amounts
$0.005
$103.15
$3.5
$0.0107
$0.3247
$0.3140
$0.2265
$0.2223
$0.0042
$97.36
Obligations
" This language is significant because it demonstrates that FERC staff has affirmatively identified GHG cost recovery as an issue that must be addressed in the Tariff — not merely as an optional enhancement, but as a necessary component of a complete tariff filing
The GHG cost recovery mechanism must be designed to accommodate both current and anticipated future emission profiles
Facilities exceeding the 25,000 metric ton CO₂-equivalent ("CO₂e") annual reporting threshold must file annual reports with the EPA through the electronic Greenhouse Gas Reporting Tool ("e-GGRT") by March 31 of the year following the reporting year
However, achieving and maintaining compliance will itself generate significant costs — including the LDAR program costs, pneumatic controller replacement costs, and enhanced monitoring costs described above — which must be recovered through the tariff
Multi-State Compliance Coordination The fact that Ridgeline's System spans the West Virginia–Pennsylvania border creates coordination challenges that the GHG Cost Tracker mechanism must address
Ridgeline must comply with the distinct GHG regulatory frameworks of both states simultaneously