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An Estimate of Electricity Prices in Newfoundland

Post Muskrat Falls

A Discussion Paper on Muskrat Falls

Volume XI

July 2014

This is one of those cases in which imagination is baffled by the facts
Adam Smith
The Father of Modern Economics

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A Muskrat Falls Discussion Paper Volume XI Page 1
Executive Summary
The final impact the Muskrat Falls project will have on the island electricity rate structure is
uncertain. During the project sanction decision (DG3) Nalcor refused to provide a detailed
summary of the stand alone cost of Muskrat Falls power, and the resultant impact on the
blended residential rates. Instead an online rate calculator was presented which estimated
what the light bill would be in 2017, considering your currently monthly payment. There was
no transparency as to the underlying algorithm used in this calculator.
On June 26, 2014 Nalcor released the long awaited updated cost estimate for the Muskrat Falls
Project. In the 18 months following the project sanction, the capital cost had increased by $800
million for a total estimated cost of 7 Billion dollars, not including interest during construction,
or the $400 million of additional equity required maintain the prescribed debt service ratio for
the project. It was advised that this overrun would result in a 7% increase in the rates to the
island consumer
This increase is not negligible in itself. However, since the sanctioning of Muskrat Falls there
have been other large capital projects initiated by Nalcor, which will be recovered within the
rate base of Island consumers. These include the following:
1. Third Line to Labrador West (Estimated Cost of 300 Million)
2. Third Line to Avalon (Estimated Cost of 290 Million)
3. 100 MW thermal generator
To the knowledge of the author these items were not included in the recent power rates
forecasted by Nalcor following Muskrat Falls commissioning. This paper attempts to estimate
the final rates to the rate payer in 2018 considering these additional inputs, and other
sensitivities, including:
1. Recommendation of the Independent Engineer to increase the annual operating and
maintenance cost for the Muskrat Falls Project by an additional 8.5 Million dollars.
2. An additional cost increase of 5% on Muskrat Falls capital costs beyond the June 26

3. Increased peak loads, and requirements to burn additional thermal generation in
4. If Hydro Quebec win their declaratory action on the interpretation of the 1969 Power
5. The 700 GWhr of annual energy from Muskrat Falls designated for the Vale facility being
sold at industrial rates of 8 cents/kwhr, in lieu of the average island rate.
6. Lower than expected demand for electricity due to rate shock.

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7. Export revenue from Muskrat Falls is used to lower the rates to the consumer.
Detailed financial information was not provided by Nalcor at DG3. Therefore, this analysis is
based on DG2 data submitted by Nalcor to the Public Utilities Board. Although the project cost
increased by 1.2 Billion dollars between DG2 and DG3, the benefit of the Federal Loan
Guarantee offset the subsequent increase. The DG2 data is therefore indicative only, but the
dramatic increase in rates from the other factors is apparent from the final analysis presented

Forecast Electricity Cost (Cents/kwhr) in 2018
With their decision to proceed with Muskrat Falls, Nalcor has committed the people of the
province to 50 years of power bills which are increasing in a manner out width the rest of North
America. Furthermore the total increase in the rates, from all factors, will likely result in a
blended rate 35% higher than quoted by Nalcor at project sanction (i.e.; online calculator).
In the opinion of the Author it is imperative that the PUB include as part of it current
investigation a full integrated view of the island rates for the period of 2017 to 2027. This
should include both Muskrat Falls and any further reliability enhancements required resulting
from the 2014 power outages. The PUB should complete an analysis similar to that included
within this paper, with the full participation of the planning departments of both Newfoundland
and Labrador Hydro, and Newfoundland Power.
The shroud of secrecy concerning what consumers will pay once this project comes online
should be lifted by the PUB. It is their duty and obligation.
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Muskrat Falls has dominated the political discussion in the Province of Newfoundland and
Labrador since the term sheet was executed in November 2010. Yet despite the volumes of
technical and commercial information submitted to the Public Utilities Board, Joint Review
Panel, or other public venues there remains an alarming lack of awareness of the impact the
Muskrat Falls development will have on electricity rates once the project is commissioned.
Nalcor has not provided a single, detailed source of commercial information which outlines the
components of the Power Purchase Agreement, and how that will combine with the existing
island system to arrive at an estimated blended rate.
Instead of providing detailed calculations to the public, Nalcor has elected to simplify the
argument by limiting the discussion to the blended rate, informing consumers what their
electricity bill will be in 2017 compared to current values. During the DG3 debate, interested
consumers could use an online rate calculator to determine the impact on the rates. The
following is a snapshot of the rate calculator found on the Power in Our Hands website

Figure 1: Rate Calculator Power in Our Hands
According to this calculator if the average retail rate in 2011 was 11.21 Cents/kwhr, then in
2018 the island consumer would be paying 15 cents per kwhr. There was no further
information provided by Nalcor during the DG3 debate to describe how these rates were
determined including what was included from these rate estimates.

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In his May 12 column Russell Wangersky
gave a compelling argument why Nalcor need to
disclose the detailed calculations in how the blended rate is calculated. Wangersky also argued
that Nalcor need to provide transparency as to how the two new transmission lines, and new
thermal generator, and cost over-runs on Muskrat Falls will have on the final rate to the
consumer. For example, was the impact of the long planned third line to the Avalon Peninsula
included in the rate calculator used by Nalcor to convince the Public as to the benefits of
Muskrat Falls?
This paper will attempt examine the information provided by Nalcor during the PUB hearings,
and estimate the rate that will be charged to Newfoundland and Labrador ratepayers in 2018.
DG2 Pricing Data Provided During PUB Hearings
Nalcors submission to the PUB lacked a single, coherent, and detailed economic analysis of the
Muskrat Falls incremental cost basis, and the impact that will have on the blended residential
rate. However there were several responses to Requests for Information, RFIs, which provided
a piecemeal submission of the required commercial analysis.
RFI-KPL-Nalcor-27 Rev. 1
Provided a summary of the incremental cost of Muskrat Falls
power delivered to Soldiers Pond. A summary of the nominal unit
rate is provided in Figure 2.

Figure 2: Nominal Incremental Unit Rate of Muskrat Falls Power


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This RFI was raised by the PUB to provide a detailed summary of
the Island average domestic rate projection from the July 18, 2011
presentation, shown in Figure 3. It provided the annual revenue
requirement for Newfoundland Hydro, and how that translated
into a retail rate by Newfoundland Power. It is the blended rate,
which includes the Muskrat Falls cost, in addition to all other cost
incurred to supply energy to the Ratepayers. For relevance in
upcoming discussions, PUB-Nalcor-5 defined the 2010 island
interconnected revenue requirement as $377 million. This was
for 6045 GWhr of energy delivered by Hydro at the transmission

Figure 3: Island Average Domestic Rate Projections

Exhibit 99
Nalcor provided a printout of the Strategist incremental analysis
for both the Isolated and Infeed options as part of Exhibit 99.
For the Infeed scenario the costs were sub-divided as follows:
1) Total Fixed Charges comprising of
a. New Thermal Generation
b. Small Hydro
c. Infeed Costs (The LIL transmission annual costs)

Exhibit 99 -
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2) Fuel Expenses
3) Other PPAs
4) Muskrat Falls Power Purchase Agreement
5) Operating Costs
The total of items 1 thru 5 were the costs required to meet the
additional annual energy included in the lowest cost analysis, and
did not include some cost common both alternatives associated
with the existing generation base.
From these three separate sources of information the reader is able to determine what the
annual revenue requirement for Newfoundland Hydro is comprised. This is provided in Figure
4. Muskrat Falls will clearly drive the regulated revenue requirements for Newfoundland and
Labrador Hydro over the next 50 year period.

Figure 4: Composition of Annual Revenue Requirement for NLH (In Thousands)
Figure 5 is the annual revenue requirement for Newfoundland Hydro expressed in constant
2011 dollars (ie; inflation accounted for). In real dollars the annual revenue requirement for
Newfoundland and Labrador Hydro will nearly double from the period of 2010 to 2018.
Perhaps more interesting is that the annual revenue required to maintain the existing island
system will actually decrease from 2015 onwards in real dollars. Within the Muskrat Falls
debate the annual cost to maintain and replace the existing Hydro base services (transmission
and generation) was not relevant to determine the lowest cost option, as it was common to
both. But when estimating future rates to the island rate payer it is critical that this information
be correct. Considering all the recent discussion about the need to invest in an aging
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infrastructure the PUB should challenge Nalcor as to why the amount of investment in the
existing assets is decreasing in real terms when they forecast rates into the future.

Figure 5: Annual Revenue Requirements in Real (2011) Dollars
2014 Capital Expenditure (CAPEX) Program
Following the 2014 power outages, Newfoundland and Labrador Hydro commenced a series of
capital expenditures to restore consumer confidence in the island electrical system, and to
meet future growth plans. These included the following:
1) Third Line from Bay D Espoir to the Avalon Peninsula. Budgeted expenditure for this is
$291 Million. From the application to the PUB this would result in an increase of 3% at
the wholesale level, and 2.5% at the retail level.
2) Third Line from Western Labrador to Churchill Falls. Estimated cost of $300 million but
it is unclear what percentage will be recovered within the island rate structure, and
what portion would be borne by Labrador customers, including Alderon. For the
purposes of this analysis the Author has assumed that $200 million is recovered through
the island rate base.
3) Supply and installation of the 100 MW Combustion Turbine Generator. The notice to
the PUB indicated that this would contribute 2.5% to the rate structure. However,
within the Muskrat Falls debate, there was a 50 MW generator planned for 2015. This
was included in the rates for the isolated and interconnected options, as shown in
Figure 3 under the heading Expansion Costs Non Muskrat. From Exhibit 99, the DG2
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analysis included a price tag of $65 million (2010 dollars) for CT units. The current
estimate for the 100 MW supply is about 50 million more than this budget
. Therefore
there is about $50 million in additional expenditure which must be recovered in the
In total if these three items must be recovered from the island consumer, and are not included
in the numbers presented in PUB-Nalcor-5, there will be some $541 million in additional CAPEX
to be included in the rates. Appendix A provides a summary the impact on the annual cost
based on a 30 year depreciation period, and a weighted average cost of capital (WACC)
equaling 4%. This calculation is provided within Columns 27-32 of Appendix A and is consistent
with the methods used by Nalcor within Exhibit 99.
Findings of the Independent Engineers Report
Within the November 29, 2013 Independent Engineers Report there were several findings
which will potentially affect rates borne by the island consumer. The most alarming was on the
discussion within Section 5.1.9 concerning renewals and replacements. Nalcor advised that the
financial planning of the project does not specifically include costs for renewals and
replacements within the annual costs estimates. The IE was of the opinion that this was not
correct, and that there should be allowances for minor and major replacements. There has
been no effort to quantify what this would be.
Furthermore within Section 6.2.2 the IE recommended that the annual O and M cost should be
8.5 million more than derived by Nalcor. Assuming this is correct it will have to be recovered
within the rate base. It is included within Column 34 of Appendix A.
Muskrat Falls Cost Increases
On June 26
Nalcor confirmed that after only 1 year of construction that Muskrat Falls is
already 13% over the DG3 budget. This will result in an estimated 50-60 million a year in
additional revenue requirement for Newfoundland and Labrador Hydro (Column 35 Appendix
The project is far from completed. Any further schedule delays, or labor shortages could have a
further impact on the cost estimate. This is expected and should be planned for. Although in
the opinion of the Author this could be in excess of 10%, for the purposes of this analysis the
future cost growth is assumed to be 5%. This is included within Column 36 of Appendix A.

Notice of Application to the PUB for New Transmission Line Bay D Expor to Western Avalon -
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#DarkNL - Meeting Peak Loads
As has been discussed in Volume 10 of this discussion paper series
, there is very high likelihood
that there will be continued reliance on thermal generation to meet peak loads on the island
during the cold winter days. This is due to potential underestimation of peak loads by Nalcors
econometric modelling, requirement to provide Emera 167 MW of energy during the peak
periods, and generation/transmission issues on the island.
Exhibit 99
indicates Nalcor are planning to spend only 500 k on fuel in 2017, escalating to 1.2
million per year in 2028. This was based on the strategist runs, which apparently excluded the
167 MW delivery to Emera, and assumed there was 900 MW of capacity coming over the Strait
of Belle Isle link.
Assuming the Water Management Agreement works as intended, and Nalcor can take more
than 300 MW of production from the existing Upper Churchill facility, there will be a much
lower dependence upon thermal. However, this amount of oil consumption seems very low
and Nalcor should be challenged to substantiate it. In the opinion of the Author an annual
allowance of 5 million per year for fuel would be more realistic assumption even if Nalcor win
the current declaratory action. As this is opinion only, and would have a small impact on rates,
it has been excluded from the analysis predicting rate increases.
Hydro Quebec Declaratory Action
In 2013 Hydro Quebec filed a Declaratory Judgment with respect to the interpretation of the
1969 Power Contract for the Upper Churchill. This is explained by Nalcor within their 2014
Strategic Document as:

The outcome of this court case will have a substantial impact on the rates borne by NL
ratepayers. If Hydro Quebec is successful on one, or both, of these issues then the intent of the
Water Management Agreement is severely undermined.

Page 54 of 72 of Exhibit 99
On page 23 of the strategic document Nalcor discuss the ongoing court challenges. Please see the following link:
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The Water Management Agreement would still be legal, but the WMA has always respected the
primacy of the existing 1969 Power Contract. If the Quebec courts once again uphold that HQ
are entitled to all but 300 MW of production from the Upper Churchill, then the primary intent
of the Water Management Agreement, and how it relates to the run of the river facility at
Muskrat Falls, would be very much invalidated.
Under the Water Management Agreement Nalcor were planning in periods of low domestic
demand to divert power from Muskrat Falls to meet their delivery obligations to Hydro Quebec
under the 1969 Power Contract. This would result in less production from the UC plant, and
would allow water to be stored in the reservoir. In periods of high demand in Newfoundland
and Labrador, Nalcor could then supplement production from Muskrat with additional
production from the Upper Churchill utilizing the stored water. This Water Management
Agreement would guarantee the full 824 MW from the combined system, irrespective of the
water flow, or storage at the Muskrat Falls plant.
In periods of low water flow on the Churchill River, this could result in several hundred MWs of
power being diverted from the Upper Churchill plant, to the Nalcor transmission system. This
would exceed the 300 MW total allowable RECALL allocation from the Upper Churchill facility.
If Hydro Quebec win their current declaratory action on the 1969 Power Contract, and CFLCo
cant sell more than the 300 MW of capacity at any additional time, Nalcor cannot divert more
than 80 MW (Remaining RECALL) to meet peak requirements in winter when the natural water
flow at Muskrat Falls is limited.
Nalcor are being disingenuous in stating that the declaratory action has nothing to do with
Water Management, or the Muskrat Falls business case.
From a reliability perspective,
without being able to take above 300 MW from the Upper Churchill (which must serve an
existing customer base) then the firm output from the Muskrat Falls plant is about 170 MW

when the storage of the reservoir is consumed (after about 7 hours of production). The PUB
will likely review this as part of its ongoing investigation into system reliability. However the
likely outcome is for additional thermal generation to be maintained on the Avalon, to meet
reliability requirements during peak periods.
Costs associated with additional capacity, or oil generation when there is insufficient generation
will have an impact on the rates. Although within their DG2/DG3 assessments Nalcor planned
for additional thermal capacity, it was well into the future and after the Muskrat Falls rate
shock. If HQ win this new generation will likely have to be accelerated, or Holyrood be

13 David Cochranes Tweets of interviews with Nalcor on July
26, 2013.
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For the purposes of this analysis the Author has assumed that Holyrood must be maintained.
Included within the sensitivity analysis is the required upgrades to Holyrood which was included
by Nalcor within the isolated island option (Exhibit 99). Furthermore the Author has included
20 million in annual fuel charges to meet peak island demands when the required capacity is
not available from the LIL. This is an estimate only but considered a reasonable estimate.
The calculations are included within Columns 37-39 of Appendix A.
Considering all these impacts the total annual revenue requirement for Newfoundland and
Labrador Hydro is provided within Figure 6.

Figure 6: Annual Revenue Requirement with Additional Costs
Selling to Vale at Industrial Rates
Figure 6 provides a summary of the total annual revenue required by Newfoundland and
Labrador Hydro. This must be recovered through the selling of energy to Newfoundland Power,
industrial customers, and to residential users within the NLH grid. Request for information
Nalcor-PUB-5 had a detailed calculation of how the annual revenue requirement for NLH was
translated into an average retail rate to island consumers. This is summarized for 2010 to 2020
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From 2011 to 2014 there is a large increase in demand originating from the Vale plant in Long
Harbour. Being an industrial customer they will not pay the same rate as home owners. If the
industrial customers are provided a rate of 8 cents per kwhr
then the remainder of the
revenue must come from higher rates from residential customers. Considering that Vale will
use 700 GWhr of the original 1800 GWhr of energy brought from Muskrat Falls then the
residential user will pay a higher rate for the 1100 GWhr used by residential customers.
It appears that Nalcor have provided the average rate, and have not included the impact of Vale
within their rate projections for domestic users. If Industrial Customers will maintain lower
rates, then the allocation to Vale will have a substantial impact on rates to domestic users. The
calculations for this are provided within Columns 45 to 54 within Appendix A.
The impact of the Vale allocation at Industrial Rates is provided within Figure 7. It results in an
estimated increase in residential rates of 5%. The rates charges to industrial customers will
have to be the subject of a government policy into the future.
Lower (Elastic) Energy Demand
It is clear that electricity prices in the Province of Newfoundland and Labrador are about to
increase substantially. Yet the demand growth forecasted by Nalcor is consistent in its growth?
Despite a stable population, Nalcor have predicted a 0.8% annual growth in island consumption
in the 50 year period following Muskrat Falls coming online

new-hydro-rates-approved/1 The rates for industrial customers will be 8 cents in 2015.
Slide 10
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This makes no sense on many fronts. The most basic of these is that a 60-80% increase in
electricity costs will have an impact on consumption. People will convert to more efficient heat
pumps, convert to other energy sources (Wood) or simply turn down the heat.
One of the greatest risks associated with the Muskrat Falls project is the issue of low demand.
Unlike oil generation Muskrat Falls is a sunk cost, and the annual revenue shown in Figure 6
must be recovered from the customers, irrespective of how much energy is used. Less energy
being sold by Newfoundland and Labrador Hydro will just result in a higher unit rate.
For the purposes of this sensitivity assessment the Author has assumed that the massive rate
shock will result in 300 GWhr of less energy being used each year. This will result in a cost
increase of about 6% to the overall retail rate. The calculations are provided within Columns
55-60 of Appendix A. It is also summarized within Figure 7.
Export Revenues Used to Offset Rates
During the media scrum following the announcement of the revised cost estimates for Muskrat
Falls Tom Marshall indicated that a PC government would use revenue from electricity exports
to offset rates borne by the island consumer. This will have an impact on lowering the rates.
Assuming that there is 40% of Muskrat production (1960 GWhr) available for export, there will
be sales of 1764 GWhr of energy available for sales once line losses are accounted for. The EIA
predict that energy prices in 2017 will be about 65 $MWhr in 2018 for generation
. In 2018
the annual revenue from exports will therefore be $115 million.
If the entire export revenue is used to reduce residential rates it would result in a savings of
about 3 cents per kwhr. This is provided in Columns 61 to 69 of Appendix A. The impact on the
rates is shown in Figure 7.
However, the reader should be reminded that the government of Newfoundland will be
borrowing 1 Billion dollars to finance the equity contributions into the project. Assuming a 5%
annual interest rate on the borrowed equity there would be an annual interest payment of 50
million dollars. What Nalcor put in one pocket, they take from the other.

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Figure 7: Estimated Unit Rates (cents per kwhr) for Sensitivity Cases

In this paper the Author has attempted to demonstrate the dramatic impact on the domestic
electricity price caused by Muskrat Falls and other capital works projects undertaken by Nalcor.
They are substantial and may lead to 85% increase in electricity rates from 2011 to 2018. These
calculations are based on data provided by Nalcor during the PUB hearings on the Muskrat Falls
However, the rate projections presented in this paper are dramatically higher (~40%) than
those presented by Nalcor as part of their online rate calculator, or recent commentary.
However, Nalcor has not been transparent as to how these rates have been determined.
Therefore in the Opinion of the Author the PUB has to present to the public a full set of
calculations, which considers all factors (real and potential) to provide some visibility as to
where power rates will be in the next 10-15 years.
The people of the province deserve this transparency. This should be completed on an urgent
basis, and prior to the next provincial election. I truly wish that the calculations presented in
this paper are wrong.

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Appendix A

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