• attributes to determine if they present a viable means of reducing OBPS compliance costs. If Enbridge Gas procures Credits or Offset Credits at a lower price than the excess emissions charge, the difference between these two costs will be recorded in the Federal Carbon Charge – Facility Variance Accounts and, as discussed in the responses to interrogatories and Enbridge Gas’s Reply Argument dealing with its 2020 Application, Enbridge Gas will seek to dispose of that variance through a future FCPP application.30

• 31.Additional administrative costs may be incurred, such as increased staffing and consulting costs, in order to pursue and acquire Credits and Offset Credits. All actual administrative costs incurred will be recorded in the Greenhouse Gas Emissions Administration Deferral Accounts and Enbridge Gas will seek to dispose of those amounts in a future FCPP application.

3. REQUESTED APPROVALS

• 32.As the costs to comply with the GGPPA in 2021 form part of Enbridge Gas’s ongoing operating costs as a utility, and consistent with Enbridge Gas’s 2020 Application, Enbridge Gas proposes to continue to treat all prudently incurred costs of compliance with the GGPPA as a pass-through to customers (Y Factor).

• 33.Through this Application and by February 11, 2021, Enbridge Gas is seeking final

• OEB approval of rates, with the exception of First Nations on-reserve customers for which Enbridge Gas requests that rate increases be approved on an interim basis, subject to the OEB’s determinations regarding the Deferred Issues, to be applied to customer bills beginning April 1, 2021, as set out at Exhibit D. Enbridge Gas will file a draft rate order for final rates following the issuance of the OEB’s Decision and Order for this Application. Subject to the OEB’s approval of that draft rate order

30 EB-2019-0247, Exhibit I.STAFF.8 b) and c), June 18, 2020; EB-2019-0247, Enbridge Gas Reply Argument, July 16, 2020, p. 12.