Enbridge staff outline infrastructure-rate tracker, reporting requirements and why pre-1970 pipe is prioritized

Enbridge Gas staff used a technical conference to summarize the company's Infrastructure Rate Adjustment tracker, the way replacement projects are selected, and the reporting the tariff requires. "I'm Jess Gibson. I work in the regulatory department over at Enbridge," said Gibson, who opened the session and framed the day's agenda.

Gibson said the feeder-line replacement program pre-dates 2010 and that the 2010 general rate case incorporated that program into an Infrastructure Rate Adjustment, or IRA, a cost-recovery mechanism that creates a surcharge collected from customers. The IRA, she said, is described in tariff 2.07 and requires at least annual filing (the tariff allows up to twice per year). "What the surcharge is meant to do is ... track costs to then recover those rates into the surcharge," Gibson said.

Staff described the master list that supports IRA reporting: each feeder or belt-line is denoted by a numbered identifier, broken out by pipe diameter and vintage year, and rolled up to annual footage totals. Quinn Evans, who the group identified as the feed-line tracker manager, said the master list is updated annually and that a new exhibit added in 2022 (Exhibit 6 in the annual plan) requires a description and timeline of anticipated filings due in November.

The presenters walked participants through the program's regulatory history. The 2013 rate case created the master list of eligible projects; a 2019 proceeding established a spending cap indexed to the GDP deflator; and the IRA mechanism is intended to reduce the need for annual rate-case filings by allowing interim cost recovery subject to reporting and cap rules. Gibson emphasized that when base rates are reset in a general rate case, the IRA tracker is reset to zero because previously tracked amounts roll into base distribution rates.

On safety and prioritization, staff said the program focuses on replacing riskier assets first. Several speakers explained why pre-1970 pipe is treated differently: federal regulations and prescriptive construction/recordkeeping standards matured in the early 1970s, so pipe installed before those standards often lacks the documentation that provides confidence in original construction and testing. As one participant summarized, the November 1971 publication of 49 CFR 192 established step-by-step construction and recordkeeping rules that many earlier installations do not clearly document.

Staff framed the IRA as a balance between urgency, budget discipline and the practical limits of crews, permitting and contractor availability. Gibson said the company continues normal maintenance and other replacement outside of the tracker where appropriate, and that the tracker does not remove the company's obligation to provide safe, reliable service.

The company said it would submit an updated master list and schedule to regulatory staff soon and that parties had an upcoming July meeting to define requested detail for the November annual plan and budget filing. The presentation closed with guidance on how variances above the cap are handled and a reminder that project-level documentation (agreements, executed crossings and material legal costs) can be produced when a matter is material and a data request is made.