The decision of Nova Scotia’s Utility and Rate Review Board (UARB),  on Muskrat Falls, was a good example to Newfoundlanders
and Labradorians of how a full independent review can play a key role in giving
protection to the public.

The UARB’s
job was to ferret out whether there was a justification for the Maritime Link
(ML) proposal, and whether the project made sense in terms of the cost per KWh,
to NS ratepayers.

In every sense, the UARB’s narrative is inextricably
linked to the entire Muskrat Falls Project.  
Nalcor and the Provincial Government have had a hard time, from the very
beginning, justifying the investment.  The
independent UARB analysis has cut a trail to certain fundamental reasons (untruths)
which made their job so difficult.       

Whether one
agrees with the conclusions of the UARB or not, it has provided a far more
independent glimpse of how essential facts have been altered to obtain Newfoundland’s
approval than is likely to emerge from any other source.  

Where are
the conflicts in Emera’s and Nalcor’s story?

I recognize
four significant issues. There may be others.

chief assumption, on which the $7.6 billion Muskrat Falls Project is based, is
that the price of a barrel of oil, in 2013, was expected to be $122.50 and forecasted
to “have a compound growth rate of 3.5% to 4.5%…for the period to 2025” or
$162.80/barrel in that year (page 46, NL PUB Report on Muskrat Falls Project).  Beyond 2025, the PUB Report continues to
state Nalcor’s assumption regarding oil prices, as increasing “2% annually in
line with general inflation to 2067.”

In such a high price world, MF was said to be cheaper than the
Holyrood plus a bit of wind and hydro option. I should note that an oil price
of $150 implies an energy equivalent natural gas price of $25 per thousand
cubic feet.

In contrast, the UARB is
forecasting New England “market-priced” electricity, over the next 35 years, in
the 5-7 cent range per KWh a low rate determined by projected low shale gas
prices which, on that basis, would see the price of natural gas, in North America,
around  $5 (or less) per thousand cubic
feet long term. 

                  One of these two scenarios
must be wrong.

So how did Nalcor come to
choose such a high oil price forecast ? 

How could Emera’s energy
price forecast (as adopted by the UARB) be so different?

UARB states (para 216, page 70) that the Maritime Link (ML) Project is $706
million to $1.422 billion more expensive than the alternative lowest cost
option without the addition of twice as much extra power as originally
contracted for i.e. the new , and very cheap, “Market-priced Energy”.

 Nalcor had to have run
those numbers, just as Emera did.  Neither
company could have expected to get such a proposal past the Interveners,
Consultants and Members of the UARB. They both must have known that the
original deal would have to be changed. 

We need to know, when
Nalcor was aware that the ML Proposal was deficient and for how long it has it known
that the other 40% of Muskrat power might have to be given up as the price for
getting the UARB’s approval. 

What false and misleading
information has Nalcor allowed the Premier and other Ministers to provide the
House of Assembly?  Or, is the Premier
and her Ministers in on the secret, too?  The Opposition Parties should be in the Media
asking those questions!

the availability of power when the Upper Churchill Contract expires, in 2041,
you may recall the following direct quote from Nalcor’s Submission, to the PUB.  It was made in defense of its Muskrat Falls
strategy and its refusal to construct a Plan that recognized the availability
of cheap power from the Upper Churchill, at that time.  Nalcor said:

“There is inherent uncertainty around
guaranteeing the availability of supply from Churchill Falls in 2041 because it
is difficult to determine the environmental and policy frameworks that will be
in place 30+ years out. There are other issues surrounding the CF asset with
respect to HQ, as Nalcor is not the sole shareholder of the Churchill Falls

You will
also recall that the then Minister of Natural Resources, Jerome Kennedy,
released a document, entitled “UPPER CHURCHILL: Can We Wait Until 2041?

in response to critics who said the Ministers’ and Nalcor’s statements, regarding
the “certainty” issue, were pure bafflegab. (See More Bafflegab on the Upper Churchill).

What did the
UARB say?

First, the
UARB quoted Emera’s Subsidiary which testified, before the Board (para 189,
page 62), as “to other sources of available energy from Nalcor”.  Among those sources, the UARB noted, as

“In 2041, the Upper Churchill reverts
to ownership of Newfoundland and Labrador”.

Later, the
UARB concluded:

Para 200
(page 65) QUOTE: “….the evidence clearly
shows that there should be no shortage of Market-priced Energy when the
Churchill Falls arrangement with Hydro Quebec comes to a conclusion in 2041.”

Para 201
(page 66) QUOTE: “However, until 2041
, there is, as Morrison Park described it “substantial uncertainty”
about the availability of a supply
…..” Underline added.

For the UARB,
but not for Nalcor, there is complete certainty about the availability of additional
power from the Upper Churchill in 2041. 

4.         On the matter of the availability
of Market-priced Energy (again, that’s the cheap 40% surplus power Nalcor has successively
committed to Labrador mining, to domestic power needs and for the US export
market, the UARB says, (para 226 page 73) that “(t)he Board will impose a condition relative to the availability of
Market-priced Energy over the 35 year term.”

In para 227,
it goes on to say “…such a condition
should not create any practical difficulty because it would codify what NSPML (Emera)
asserts is the effect of the arrangement in any case”.

The UARB confirms,
based upon the evidence it received, that Nalcor and Emera had an “arrangement”;
its report details numerous Nalcor/Emera meetings on that subject.

phrasing is formal and deliberate. 

The UARB, by
implication, is suggesting that the parties have not provided full disclosure.

Indeed, it is convinced that the evidence is sufficient to
conclude that Emera’s and Nalcor’s “arrangement” was strong enough to entitle
it to make very precise demands of Nalcor. 
Emera’s claims were such that repeatedly, throughout the Decision, it demanded
the savings offered through the “certainty” of a contract for 40% of Muskrat
Falls power (or 200% more) at a ‘levelized’ rate of 10 cent per kwh flat over
the long term.  Only with those savings
from “surplus” Market-priced Energy, the UARB repeated over and over, could the
ML become the lowest cost option for Nova Scotia.

All that is
needed, it said, is for Nalcor to “codify” its existing bargain with Nalcor by
putting it in writing.


Nalcor had
one story for Newfoundland and Labrador. 

It allowed Emera
to tell a very different story in Nova Scotia. 

The UARB is
having none of it.  It’s basically saying
that the Nalcor / Emera tango must stop.

It wants
Nalcor’s promises to Emera “codified”.

must pay 80 % of the cost of a project that sees 60% of its output dedicated
and delivered to NS.

And NS must get
that Muskrat Falls power at prices way below that which Newfoundland will pay
for its “minority” share.

Does this
sound familiar?

inconsistencies and contradictions, noted by the UARB, alone, are enough to
bring a halt to the Muskrat Falls Project.

How many other
untruths were required to hustle through the Muskrat Falls sanction,
I wonder?

Nothing less
than a completely independent review, of this Project, should be acceptable to
the people of this Province.  
Des Sullivan
Des Sullivan
St. John's, Newfoundland and Labrador, Canada Uncle Gnarley is hosted by Des Sullivan, of St. John's. He is a businessman engaged over three decades in real estate management and development companies and in retail. He is currently a Director of Dorset Investments Limited and Donovan Holdings Limited. During his early career he served as Executive Assistant to Premier's Frank D. Moores (1975-1979) and Brian Peckford (1979-1985). He also served as a Part-Time Board Member on the Canada-Newfoundland Labrador Offshore Petroleum Board (C-NLOPB). Uncle Gnarley appears on the masthead representing serious and unambiguous positions on NL politics and public policy. Uncle Gnarley is a fiscal conservative possessing distinctly liberal values and a non-partisan persusasion. Those values and opinions underlie this writer's views on NL's politics, economy and society. Uncle Gnarley publishes Monday mornings and more often when events warrant.


If a Big Mac costs McDonalds $10 to produce and it is sold for $1.50, McDonalds will go out of business. They would not declare a profit!


Bill left public life shortly after the signing of the Atlantic Accord and became a member of the Court of Appeal until his retirement in 2003. During his time on the court he was involved in a number of successful appeals which overturned wrongful convictions, for which he was recognized by Innocence Canada. Bill had a special place in his heart for the underdog.

Churchill Falls Explainer (Coles Notes version)

If CFLCo is required to maximize its profit, then CFLCo should sell its electricity to the highest bidder(s) on the most advantageous terms available.


  1. $25 per thousand feet of natural gas to = Nalcor's $162.80 2025 oil forecast? 2% inflation for FIFTY years – both of these scenarios sound insane.

    Natural gas needs to be around $18 delivered to match MF starting price of 16.4 cents kWh. 4X the Henry Hub current price by 2041.

    Cost of delivery of natural gas has been overstated for MF proponents – Nalcor could buy their own LNG 30 million gallon tanker and lease it out for the majority of days not used for domestic supply. 6 LNG shipments a year should meet NLs natural gas demand (on the Avalon) – NE USA to Avalon would only take days travel time.

    Des how does 8 cent kWh industrial power by 2015, 16.4 (+2% annually thereafter)cent residential power affect Nalcors generous demand forecast? 12000 GHW by 2067 from our current 7854 GWH. Yet 20,000 GWH of UC power will be available once the contract expires in 2041.

    MF = < 5000 GWH at 100% capacity or 25% of NLs UC share in 41'.

    To me it appears demand forecasts and cost of energy have been manipulated so MF comes out on top.

    Nalcor needs to stop trying to be cute and update all of the numbers to reflect reality.

    Put out EoI tenders on 505MW natural gas generation station to replace Holyrood AND a NG supply contract for aprox 400 billion cubic feet by 2041.

    $6.2B for MF dam + power infrastructure (more like $10B) – $1.0B (cost of new NG plant) / 50 years = $104M – $180M annually for natural gas fuel costs.

    Residential rates are set to increase at least FIFTY % by 2017 and industrial rates ONE HUNDRED % by 2015. Nalcor will be unable to match current demand with such sharp increases – let alone project 54 years into the future!

    Bill 29, Ministers whom seem to have little grasp on MF, media NLPC sycophants and Nalcors poor explanation, UARB, HQ court case, faulty demand forecasts – NO WORRIES HERE!

  2. Des.

    The Emera application (http://nsuarb.novascotia.ca/sites/default/files/documents/muskratfalls/m-2.pdf) was issued on January 28, 2013. As soon as the carrot of Figure 4-4 was put in front of the UARB, Nalcor should have realised they were going to grab it, and refuse to give the carrot back. The process was de-railed as soon as this Figure 4-4 was shown to the people of Nova Scotia.

    Newfoundlanders should read through the UARB hearings. There was a great deal of dialogue between Nalcor and Emera about surplus power availability. Yet during the June 2013 AGM, Ed Martin responded to questioning from Jim Morgan that he was not approached by Emera about surplus power. Something does not correlate. Something does not add up?

    But if you want to see what benefits an open and transparent process brings, then read the economics that were presented to the UARB (excel file at bottom of following link http://nsuarb.novascotia.ca/content/maritime-link-application-muskrat-falls) A clear summary of the costs, the returns, and when the equity will be repaid. This is a level of detail and clarity that Newfoundlanders are yet to see, on a project which we will pay for.

    Here in Newfoundland we have a premier who is now saying that the link does not require UARB approval. But if the cost are not recovered in the rate base (15 cents/kwhr) how will it be paid for on the open Market (5 cents)? Who pays?

    Our premier should also understand that in accordance with the National Energy Board, before any power is sold in the US it must first be offered to Canadian utlitlies at commercially competitive terms. So if they build a link with the intent to sell it to New England at 4 cents, then the terms of their NEB eport license dictate that Nalcor will first must offer it to Nova Scotians at 4 cents.

    Premier Dunderdale may get Premier Dexter re-elected yet.

  3. there are 2 others which should be added to your list.

    1) Nalcor presented to our PUB a demand profile for newfoundland that will initially require 40 percent from muskrat falls. This will grow to 100% by 2052. Even in the base plan, Nalcor was depending upon using upper churchill power to meet the base nova scotia block after 2041. Even before labrador mining or emera surplus there was not enough power to meet all their committments. Nalcor have dodged this question.

    2) When determining the lowestcost option for our PUB nalcor modelled the LIL in strategist as a 900 mw thermal unit. basically like any ct unit, there was 900 MW available when u needed it. this is despite that the unit is only rated for 824 mw? Nalcor assumed there was recall available in winter. this 80 MW of recall has now been committed to Alderon.

  4. Des… after 2 rum and coke I thought of a top 10 of issues which Nalcor missed, overlooked, ignored, or seem to be wrong in their view. 1 and 2 are given in the previous comment.

    3) Nalcor promoted the gated project management process during our PUB process. DG2 was meant to be a review of the alternatives. Yet the DG2 reports provided by Nalcor to the PUB had no mention of alternatives. The DG2 review documents also did not include any review of the economics. The DG2 assessment was a readiness review of the Lower Churchill Project. When the mandate changed from developing the lower churchill to providing the lowest cost power for Newfoundland, Nalcor should have not have let the project pass DG2. The work was not done. At least it was not provided in the DG2 documentation provided to the PUB.

    4) When they did review the various options (in support of the DG3 decision) there was only 1 interconnected alternative. They did not consider wind, with the cable to Labrador. They did not consider power imports (Upper Churchill). Both of these were potentially lower cost, and lower risk than the current alternative.

    5) In their economic assessment Nalcor only considered 1 demand profile. Although the department of finance determine High, Medium and Low housing starts each year, Nalcor did not take a similar approach in calculating the lowest cost option. Best practice would have been to use a Monte Carlo assessment for the demand, and the construction cost. A probability plot could have been produced, with a target cost with a standard deviation. This would have been best practice. 600 million in engineering fees demand best practice.

  5. 6) During the PUB process Nalcor presented the incremental cost of Muskrat Falls Power delivered to soldiers pond (http://www.pub.nl.ca/applications/MuskratFalls2011/files/rfi/CA-KPL-Nalcor-27-Rev1.pdf). This is the source of the 23 cents per kwhr for Muskrat Power delivered in 2017. But Nalcor also presented the blended cost of energy (http://www.pub.nl.ca/applications/MuskratFalls2011/files/rfi/PUB-Nalcor-5.pdf). Yet 700 GWhr of Muskrat Falls power will be provided to Vale at 5.9 cents per kwhr, much less than residential customers will pay. With this into consideration the incremental cost for residential users will be closer to 30 cents. The blended rate for residential users will be closer to 18. Nalcor should be challenged on this, as the rates they have provided to the PUB appear to be incorrect. The rates are lower than what they actually will be.

    7) With the DG2 assessment Nalcor had Portland Creek included in the expansion plan. In addition to ruining an excellent salmon river, it would provide firm energy into the interconnected option, even with Muskrat Falls. I believe this was provided only for the Emera obligation, such that there would be enough firm energy to meet the NS block until 2041 until Churchill Falls was available. If this was true island consumers were paying real money to meet the NS Block obligation. This was identified in one of JM's discussion papers. Nalcor did not use Portland Creek in their DG3 decision. They provided a cheaper CT unit instead.

    8) Within various presentations Nalcor have presented an overview of the dividends coming from Muskrat Falls. This is where the oft refereced 400 million a year back to the provincial government has come from. Go to page 35 of the following link http://www.nalcorenergy.com/uploads/file/agm%202011%20muskrat%20falls%20presentation%20ed%20martin%20june%2022.pdf

    The majority of the politicians, and observers believe that this is what Nalcor will make. But this is incorrect, and could almost be viewed as deception. This dividend does not include the repayment of the equity the provincial government has put into the project. Furthermore, in the most recent AGM Ed Martin indicated that this money will NEVER go back to the government, as Nalcor will use these dividend to pay for Gull Island and other expansion plans. This is new information, and totally contrary to what was referenced in the PUB hearings, and the House of Assembly debates. This is the biggest single piece of inconsistent messaging coming from the Muskrat Falls project. The reality is that for 30 years Muskrat Falls will generate less revenue (once you consider equity repayment) than the Upper Churchill. Nalcor have forgotten that they have to pay their investor back. A great business model if you can do it.

  6. 9) After the pressure imposed by Cabot Martin during the PUB hearings Nalcor finally did commit to looking at Natural Gas. Ed Martin (in his interview with Dave Vardy for the Action Canada Paper) indicated that Nalcor did not consider Grand Banks gas feasible as it is all used for production. This is not correct, as Whiterose (which Nalcor are a partner in) re-inject vast amounts of gas for future use. When Nalcor finally did look at Natural Gas they considered a full development ONLY to provide us enough gas for electricity, and nothing for export etc. This is despite the fact that their own energy plan indicate that there will be gas production in Newfoundland within the next 10 years. This is also despite the fact that there are several LNG export terminals being considered on the eastern seaboard destined for European market.

    I can't help that we have missed the real opportunity here. A 2-3 Billion dollar investment by Nalcor would have kick started a Gas industry in Newfoundland and Labrador. This is an opportunity lost because of tunnel vision.

    10) Holyrood Closing….. I still can not understand how Holyrood will be permitted to close, without being replaced. If energy is provided to Emera and Labrador Mining, how will we meet the peak demands in winter. This will only be made worse if HQ win their court challenge. I can not see how Holyrood will ever close… Only time will tell.

    It is easy to pick out issues when you look at 5 years of work. I still think this may be the right time, but I would have preferred if it was delayed 3 years to get over the current resource boom. I believe I will be proven correct in this regard. However, I also do believe that Nalcor had tunnel vision on the project (which can also be expected). The biggest issues are they abandoned their gated management process which was meant to stop tunnel vision. They, with the government also castrated the PUB process. This was the greatest mistake. A open and unrestricted PUB process would have never allowed a Sanction without the UARB approval.

    But hindsight is 20-20.

  7. Why stop at 10.

    11) Are Nalcor being 100% truthful when they indicate that even if HQ win their court challenge on the 1969 Power Contract that it will have no impact on Muskrat Falls. Sure it will not impact the total amount of production (4900 GEhr per year), but will the energy be there when we need it? The WMA clearly requires that power and energy from the Upper Churchill will be used to suppliment production from Muskrat Falls when flows are low. However if this is precluded because of the 1969 Contract then it is a major issue, as the energy may not be there when we need it. This is a very complex issue, and Nalcor's cocksure simplistic explainations do not provide assurances to me.

    12) Nalcor have been stating that financing of the project will not be an issue. Yet they are completing all work to date with Equity? They have also not yet secured any financing. Follow the money….

    13) Nalcor have said that they are on budget. Yet they are complaining in private about the cost of doing business in the current environment. Are Nalcor on budget for what they have spent to date? What about their forecast to complete, is this still on budget? What percentage of their contingency have they already used? What is their earned value on the work performed to date? The cost reports on the website (https://muskratfalls.nalcorenergy.com/wp-content/uploads/2013/03/Benefits-Report_May2013.pdf) only show money spent. It does not provide the forecast to complete, nor what the orginal budget was. This information certainly exists. Why not show the public everything, and not piecemeal info. Furthermore why is Nalcor only showing the total cost since sanction, and not including the 440 million spent prior to sanction?

    14) Why do Nalcor still talk about exporting power into the US markets, when the Provincial Government have aknowledged that Bill 61 will potentially block this very sale. Bill 61 clearly does not meet the reciprocity requirements of FERC. Which means if we dont open up our markets, we can't sell into theirs. This is a very real risk, which Nalcor have yet to formally respond to. Is this another NAFTA challenge? Was this discussed during their DG2 decision gate. If they properly assessed the economics, and determined they needed a monopoly to make it feasible, this issue would have been identified.

    15) What are Nalcor doing with their transmission capacity through Quebec. They currently pay 15 million a year for 300 MW of transmission capacity. We are transmitting power through Quebec now. What is Nalcor's plan with this after the maritime link is built. Will they maintain it?

    16) What is the capacity of the LIL. Nalcor say it is 900 MW. Yet Emera in their application to the UARB indicated that it is 1200 MW. What is the capacity. If it is 1200 MW, will this allow Emera to buy market priced electricity from Hydro Quebec to wheel accross the LIL and ML into Nova Scotia. If so will there be a OAT tariff applied. Will this be used to lower the rates to Newfoundlanders.

    17) Why can government not provide a clear answer on whether export sales will be used to lower our rates? Can government explain why they are using our electricity rates as a form of taxation. Very legitimate question which has not been properly answered. Muskrat Falls has the potential to be the largest tax in our history. But it is not a sales tax, or income tax. It is a tax on our electricity.

  8. 18) There are 4 parts of the transmission for MF. There is a large line between MF and the UC. There is the LIL and the ML. But there is also an upgrade of the island system (AC) between the ML and the LIL. Who is paying for this upgrade? Will this be included in the rates applied to Newfoundlanders? Is it only required for the export of energy to Nova Scotia?

    19) The North Spur…. Much has been asked… very little has been answered. Nalcor should just release all the engineering reports. They should issue a letter from their engineering consultant that all is well, and this is the remedial plan. Why is this such an issue? Maybe it is not that simple?

    20) Nalcor's future growth plans. There is alot of talk about Gull Island, wind, etc. etc. There is also alot of recent talk from using the Muskrat Falls earnings to pay for this future growth. All in the best interest of Newfoundland. This may be true, but lets see the numbers, and the returns. Lets have a proper debate.

    There is my top 20 questions or issues which I wish our own PUB were permitted to look at.

    A public and transparent process is what should be expected when the taxpayers take on a 7 Billion dollar committment.

  9. The strategy of reducing the need for oil-fired generation until 2041 strikes me as a smart, low risk approach. The answer to "Can we wait until 2041?" seems to me to be pretty obviously yes. By 2041, Labrador power might be very valuable. On the other hand, it might not be. For example, if many households in NA have replaced their gas furnaces with a cogenerating gas-fired fuel cell by 2041, NLers might find themselves not wanting more generation in Labrador than is there today.

  10. The ONE most expensive and uneconomic scenario for extra power to meet Island demand was Muskrat Falls. It is so far off the grid, pun intended, in economic terms, that it simply blows my mind. Why this option was "chosen" to meet Island needs is ludicrous, and either sheer stupidity or gross negligence.

    The other aspect….that it is simply a money grab by high rollers within the province…is almost impossible for me to comprehend, since it would enrich a few at the expense of the province's long term fiscal outlook.

    I used to think our leaders had integrity but these events really make me wonder if these are simply hooligans and crooks in high-powered suits.

  11. You guys realize there is little desire on the part of the offshore to invest in gas short term… and if it were to be developed.. it'd go to Europe right? Where the price is much better? It's an arbitrage position that would see any LNG carrier pointed this way bypassing us for the bigger payout.

    The gas will get developed when it's worth it. Husky seems to believe that's 2025. It will probably go to Europe as well.

  12. i believe you miss the point. A 2-3 billion investment by nalcor may have kickstarted a gas industry. a full gas ti wire study was a committment in the 2007 energy plan.

    i am also confident in saying that a gas development in 2025 is a hell of alot more likely than gull island.

  13. On reliability issues… the question of 50 or 150 year design for transmission towers has been somewhat addressed and discussed, and the extra cost for such design.
    But the following, reliability questions I have not seen addressed
    1. the northern peninsula is notorious for outages due to salt contamination on the lines during wind storms. Unlike a very extreme ice load which mau happen once in a 100 years, salt contamination can knock off this line for hours or days a dozen times a year, seriously impacting reliability. Nalcor compared the reliability of the new line there to our existing 230kv line, but we have no 230 kv lines in that area, so the comparison is useless. And they stated that salt is not a contaminant to be considered,…. which blows the mind to suggest that.
    2. GICs( solar induced current) knocked out Churchill falls transmission and triggered the large outage into the united States in 1979. Thereafter, HQ spent one billion dollars on measures to reduce the affects of SICs.
    I have seen no plans by Nalcor to address this for MF. The major risks contributors to SICs is very long transmission lines, and east west directions, and terminations in a coastal area. Add to that that parts of Nfld has measured some of the highest GICs of anywhere in the world. WHile the North Spur is a question of poor engineering investigation, is a GIC fix another billion dollar oversight? GICs cause trouble for several years on a 11 year repeat pattern. If it was serious enough for HQ to address for reliability, can we ignore it?
    3. We seem to be achieving only half the forecast for power demand increases…. and this is fundamental to using this high cost block of power for the island. the forecast was based on our winter heating needs.
    The latest trend for housing is to build 'NET ZERO' houses. There are perhaps 50 0f these in Canada and a thousand progressing in the USA. They use very little energy, and have some solar panels, and both take a little power from the grid and put some back, so effectively on average need no power from the grid. We can perhaps forgive our power companies for assessing this for our area for the next decade. But Nalcor said we are approaching saturation for efficiency gains when they did their forecasts, and came up with a robust forecast for future energy needs for winter heating.
    Now already, in 2013 we have adopted new efficienvy standards for new houses. The average reduction in energy use? 27 percent. This type of construction has been around since about 1985 and just now has been formally adopted as a minimum standard, which was expected.
    And cost effective efficient heating is reliable and getting more uptake. The winter month reduction in electricity use? Up to 60 percent. This technology has been around for decades.
    How can a world class company overlook such things to say we are approaching saturation for efficieny improvements?

    Winston Adams