Review of Muskrat Falls Development — Submission to Consumer Advocate

Here are proposed interrogatories I submitted February 23rd to the Consumer Advocate, Mr. Thomas Johnson LLB of the firm O’Dea Earle designated by the Newfoundland and Labrador Board of Commissioners of Public Utilities. The PUB is conducting a review of the proposal from the Crown energy corporation Nalcor to develop a hydro-electric facility in Labrador.


Dear Mr. Johnson,

I have a series of related questions regarding Nalcor’s energy production estimates, production management plans, and operating reserve plans related to Muskrat Falls development. I would very much appreciate your consideration of these questions for possible inclusion in the ongoing review. I am not completely conversant in all of the evidence adduced, so it is possible that some of my questions are duplicative. These draft questions would therefore benefit from your review and editing.
Thank you for your consideration,
Tom Adams, Toronto
Part 1
Exhibit CE-28 is a study called “Churchill River Complex: Power and Energy Modeling Study” conducted by Acres International and dated 1998. In that study, there was no AC/DC converter (and therefore no converter losses) and no transmission congestion, and the average energy reported for Muskrat was 4.4 TWh/yr at the generator (Table S-1) and 4.26 TWhyr at Quebec border (Table S-2). Firm energy at the generator was reported by Acres at 4.08 TWh (Table S-1). Now Nalcor is claiming average energy of 4.9 TWh/yr and firm energy of 4.4 TWh/yr.
1.1 What is the basis for Nalcor’s 4.9 TWh/yr average energy estimate? In replying, please explain all differences between the current estimate and the estimate in CE-28. In addition, include a detailed discussion of any spillage of water at both Muskrat Falls and all other interconnected hydro-electric facilities in order to accommodate production from Muskrat Fall? If full integrated spillage analysis is not available, please indicate when it will be available and provide the terms of reference for that work.
1.2 Please quantify the forecasted annual spill of water that is expected at Muskrat Falls by year over the period 2017-2067. Provide the spillage estimate at Muskrat Falls by month assuming a normal water year in 2018, 2028, 2038, and 2048.
1.3 Please quantify the forecasted annual spill of water that is expected at on-island generation by year over the period 2010-2067 under both the isolated island and integrated system scenarios.
Part 2
In the exhibit “Labrador-Island HVDC Link and Island Interconnected System Reliability” (Nalcor exhibit  # 106) we see at page 9 that the peak losses incurred delivering Muskrat Power to Soldier’s Pond are approximately 10%.

What are Nalcor’s estimates for the peak and average losses incurred delivering Muskrat Power to Soldier’s Pond, Cape Bretton downstream of the AC/DC converter, the New Brunswick/Nova Scotia border, the New Brunswick/Maine border, and the Maine/New Hampshire border? (Precise estimates are not necessary.)
Part 3

The 2009 water management agreement governs the use of provincial water resources.


3.1 Does Nalcor acknowledge that the water management agreement gives priority to any contracts CFLCo has with Hydro-Quebec? If not, why not?

3.2 Does Nalcor’s plan for Muskrat Falls involve Nalcor drawing on more winter generation from the Upper Churchill than the 300 megawatts of Churchill Falls power that it currently has rights to? If so, what is the basis, including the contractual basis, for Nalcor’s plan?

3.3 How much of Nalcor’s entitlement to winter generation from the Upper Churchill is used to supply local Labrador needs today and over the planning horizon out until 2041?3.4 Does Nalcor assume that all or substantially all generation at Muskrat Falls available at times when south-bound transmission facilities are congested will be stored in the reservoir above Churchill Falls? If yes, please explain the timing of return of that generation and the contractual basis for that return of generation. Explain any impacts Nalcor’s plans for the use of upper Churchill storage and generation facilities will have on Hydro Quebec.

Part 4
Reliance on a 900 MW link from Labrador to Newfoundland could substantially increase the operating reserve requirements on the island.
4.1 Please explain how operating reserves are managed on the island today and how this will change under the interconnection scenario.
4.2 How do Nalcor’s plans with respect to operating reserve in an interconnected scenario compare with NPCC requirements?

One Comment

  1. Hello Tom. Thank you for forwarding these questions. We heard in the last day of the hearings that the PUB has given Nalcor until March 9th to answer all IRs…. Please let us know once you receive answers to your questions.


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