for the Union rate zones) revenue requirement associated with Cap and Trade-related billing system functionality re-purposed for GGPPA-related charges and the revenue requirement of $0.06 million associated with the additional billing system modifications required in 2020 for the Union rate zones.10 The 2021 revenue requirement for these costs has not been previously collected from customers.

STAFFING RESOURCES

• 10. For 2021, staffing costs are currently estimated to be approximately $1.10 million.
  
  These fully allocated costs are for the five FTEs that comprise the Carbon Strategy team in 2020 plus one additional FTE. This level of staffing reflects the incremental level of effort Enbridge Gas has experienced to-date and expects to require across the organization to comply with the GGPPA in 2021 including the incremental effort to evaluate and procure Offset Credits and begin preparations to comply with the federal Clean Fuel Standard (“CFS”).11 With the establishment of other carbon emission-related programming and initiatives in the future, including the increasing level of effort required to implement the CFS, Enbridge Gas may require incremental staffing resources. Enbridge Gas will seek OEB approval to recover prudently incurred actual 2021 staffing costs that reflect the incremental effort required to comply with the GGPPA and other GHG or carbon pricing regulations, together with its overall 2021 administration costs, in a future proceeding.

• 11.The GGPPA impacts a wide variety of groups across the organization and wherever reasonable to do so Enbridge Gas has leveraged existing resources outside of the Carbon Strategy team and will continue to do so going forward. This demonstrates Enbridge Gas’s commitment to cost-effectiveness, productivity gains and continuous

10 As set out in Enbridge Gas’s 2020 Application (EB-2019-0247), Exhibit C, p. 7, included in the calculation of 2021 revenue requirement for the Union rate zones are capital costs related to additional billing system modifications previously expected to be incurred in 2019 and actually incurred in 2020. 11 https://www.canada.ca/en/environment-climate-change/services/managing-pollution/energy- production/fuel-regulations/clean-fuel-standard.html