improvement. These ancillary resources and related costs will not be recorded in the GGEADA in 2021.

CONSULTING AND EXTERNAL LEGAL SUPPORT

• 12.Enbridge Gas anticipates that it will incur $0.30 million in consulting and external legal costs in 2021 for work supporting the development and sustainment of Enbridge Gas’s carbon strategy and related analyses, the review and interpretation of any new or updated regulations associated with the GGPPA or other GHG or carbon pricing programs and for work supporting the development of Enbridge Gas’s Application and associated OEB proceedings.
  
  
• 13.These expenditures are required to ensure that Enbridge Gas remains well-informed of, and in compliance with, current and new regulatory requirements. Enbridge Gas also notes that it may incur additional consulting and external legal costs associated with other GHG or carbon pricing programs, such as the CFS. These costs will also be recorded in the GGEADA.

GHG REPORTING AND VERIFICATION

• 14.In accordance with OBPS regulations, Enbridge Gas is required to have it’s annual OBPS report verified by a third-party auditor. The verification includes both the GHG emissions and the production from each specified industrial activity during the compliance period that was used in calculation of the emissions limit.12 The emission report and verification report must be submitted by June 1 of the year following a respective compliance period. For the 2020 compliance period, verification will be completed and submitted by June 1, 2021. Enbridge Gas anticipates the fees associated with 2020 emissions verification to be $0.05 million.

12 Output-Based Pricing System Regulations, Schedule 5; https://laws- lois.justice.gc.ca/eng/regulations/SOR-2019-266/index.html