SES terms which has been approved in EB-2017-0147 as well for several other projects as noted earlier in the application.

34. The 20-year maximum may not make all projects economically viable, in which case Enbridge Gas expects that a CIAC will be required in addition to the TCS.

35. Enbridge Gas proposes that projects where a TCS rate rider is applied should be included in the Company's Rolling Project Portfolio and Investment Portfolios alongside other system expansion projects. This will provide an ongoing method of determining the financial feasibility and rate impact of expansion projects as prescribed in E.B.O. 188. As such, separate tracking and reporting on these projects will not be warranted.

Hourly Allocation Factor (HAF)

36. The HAF is a method of allocating the upfront capital investment of a Development Project designed to provide incremental firm capacity to multiple customers forecasted to require additional firm service within an identified Area of Benefit10. Unlike the SES and TCS, the HAF is not a rate, but rather an element of the Company's respective economic feasibility policies that addresses the method by which capital costs of a project are allocated.

37. The concept of the HAF is consistent with the Board's E.B.O. 188 Guidelines which states: "The Board agrees with the parties that the common criteria for contributions in aid of construction should apply to all customer classes. If there is a reasonable

10 The Area of Benefit is defined as the geographic area, drawn as a polygon on a map, that includes all customers who will be served by, and benefit from, the infrastructure build or pressure increase from the Development Project.