proposing that the threshold of applicability be set by Enbridge Gas on a case by case basis. The HAF will typically be applied in situations where gas service is being made available to large volume customers, however it can also be used for projects involving small volume customers where one or more of them may be placing a larger peak demand on the system relative to others that are served by that project.

43. Consistent with previous LTC projects, once the HAF is determined and set, it remains constant for all customers meeting the threshold of applicability for that particular Development Project requesting incremental capacity within the Area of Benefit. Enbridge Gas will cease to allocate and apply the HAF to the economic feasibility analysis of new customers requesting service in the Area of Benefit once the total incremental capacity has been fully allocated11. This approach will help reduce the situations where a single customer underpins a large project with a longterm contract or CIAC and then a neighbouring customer gains access to the incremental capacity without being allocated a fair share of the capital costs that generated that capacity. It also allows the Company to factor in anticipated growth to optimize the design of the facilities up front.

44. For the purposes of the economic feasibility analysis for customers allocated costs using the HAF, Enbridge Gas would continue to apply the E.B.O.188 Guidelines. Large volume customers would have flexibility through longer term contracts and/or a CIAC payment to achieve a PI of 1.0. Small volume customers would have the option of a CIAC payment and/or the TCS, as applicable over a defined term to achieve a PI of 1.0.

11 EB-2018-0188, CK Rural Expansion Project; EB-2019-0218, Sarnia Expansion Project