19. In the event that Enbridge Gas should seek recovery of any revenue requirement shortfall after the end of the initial 10-year RSP, it will be supported by an updated PI calculation that uses actual capital costs and actual customer attachments (revenues). The OEB stated in Union's Community Expansion Application8, "The OEB agrees with this approach and will require Union to provide a revised DCF calculation based on actuals after the 10-year forecast risk period is over in the event that Union seeks to recover any revenue requirement shortfall."

20. Enbridge Gas is requesting that the Board approve a 10-year RSP for all Expansion Projects. The RSP will address the Board's finding in the Generic Proceeding, EB2016-0004 that "a utility would bear the risk for that 10-year period if the customers they forecast did not attach to the system."9 The RSP will commence on the inservice date of the Project. A 10-year period is also consistent with what the Board approved in EGD's application for an SES applicable to all future Expansion Projects in EB-2017-0147.

21. The RSP is proposed to function as follows: If leave of the Board is granted to construct an Expansion Project, Enbridge Gas will include the forecasted capital costs of a project in rate base as of the in-service date. Capital costs included in rate base would be those costs outlined in the economic feasibility assessment of the project net of any third-party funding (such as government administered grants pursuant to O.Reg. 24/19, municipal contributions and any contribution in aid of construction from customers).