appropriate once additional details are announced. For the purposes of this Application, Enbridge Gas has assumed it will be subject to the OBPS in 2021. Any cost impacts to the Facility Carbon Charge due to a change in the estimated OBPS compliance obligation will be included in Enbridge Gas’s future FCPP applications for disposition of FCPP-related deferral and variance account balances.
- 13.Enbridge Gas’s Application is being submitted at this time to be able to comply with the GGPPA and begin charging customers the 2021 Federal Carbon Charge Rate for natural gas, in accordance with the FCPP, beginning April 1, 2021.
2. ENBRIDGE GAS'S OBLIGATIONS UNDER THE GGPPA
- 14.As a natural gas utility in Ontario, a “listed province” in the GGPPA, Enbridge Gas is required to register under Part 1 of the GGPPA with the CRA as a “distributor” for volumes of natural gas delivered to its customers.15 Further, Enbridge Gas is required to register under the GGPPA as an “emitter” since its transmission and storage compressor stations are “covered facilities” under Part 2 of the GGPPA.16
- 15.As a “distributor” Enbridge Gas is required to remit Federal Carbon Charges related to the GGPPA to the Government of Canada. As an “emitter” Enbridge Gas is required to remit payment for any excess emissions under the OBPS. Enbridge Gas has estimated its 2021 cost of compliance with the GGPPA to be approximately $1.42 billion: $863.66 million for the EGD rate zone (see Exhibit B, Tab 1 for additional detail) and $556.37 million for the Union rate zones (see Exhibit B, Tab 2 for additional detail). In addition, Enbridge Gas estimates that it will incur 2021 administrative costs of approximately $4.41 million associated with the
15 The GGPPA, s.55 (1); The GGPPA requires registration of distributors of marketable or non-marketable natural gas. The GGPPA defines “marketable natural gas” as natural gas that consists of at least 90% methane and that meets the specifications for pipeline transport and sale for general distribution to the public. The GGPPA defines “non-marketable natural gas” as natural gas other than marketable natural gas.
16 The GGPPA, s.57(1).