Written by “JM”
Edited by Des Sullivan 

DARK-NL investigation being undertaken by the Public Utilities Board is playing an important
role and not just by getting to the root cause of the Province-wide power
outages last January. 
Robbed of the protection
a narrow reference afforded Nalcor, during the 2011 PUB review of Muskrat Falls,
the Crown owned corporation must now answer new questions posed both by the PUB,
interveners, and others relating to security of supply after Muskrat is commissioned.

new information illuminates the deficiencies in Nalcor’s filings with the PUB,
in 2011, and exposes key aspects of a plan which ought to have been released at
that time.
Public may now finally understand Nalcor’s true intent for the Province’s
electrical system when the interconnections with both Labrador and Nova Scotia
are completed. 

begin by asking: what has been identified as substantially different from the plan
first proposed by Nalcor, in 2010, and what are the implications?   

of the major issues with the original Muskrat Falls PUB review was that it was intentionally
restricted, by the Government, to the island supply case only.  It did not consider the Maritime Link
interconnection and delivery of 167 MW to Nova Scotia including during “peak”
periods. Nor did it acknowledge the potential additional revenue from the
export of surplus energy.

original PUB Inquiry was useful for its analysis of the project as well as for
the transparency it provided. But the process, without inclusion of the
Maritime Link, was seriously undermined because the plan the PUB was asked to evaluate
was not the one Nalcor had in mind. 

addressed to Nalcor, in relation to the Maritime Link, were not answered; they
were deemed by that Corporation outside the scope of the reference
question.  As a result, concerns
regarding the ability of Muskrat Falls to meet peak winter demand on the Island,
and supply 167 MW of power to Nova Scotia, failed to get the notice such a
fundamental issue warranted.

implications of this issue for higher costs to consumers and unplanned thermal
(oil) generation, in order to meet our “peak” power requirements, are
significant. As a priority, Nalcor should answer immediately the impact this
commitment to Nova Scotia will have on Island electricity rates.

Exhibit, below, is proof that Nalcor did not want to expose a major weakness in
its case when it argued Muskrat was the best alternative. The revelation would
have skewered the project as the lowest cost option.

Consider this question posed to Nalcor and its

Nalcor refused to acknowledge then that the Nova Scotia Block was a key issue
to in the Island’s winter demand forecast, one also central to the issue of the
project’s viability,  it was assumed by the Author that Nalcor had, at
least, included the commitment in its analysis of the project

assumption, taken to its logical conclusion, suggests the LOLH reliability calculations  (a resource planning model used by Nalcor) presented to Manitoba Hydro International (MHI) and the PUB included delivery
of the 167 MWs to Nova Scotia; it was also assumed that the timing of those obligations were
accounted for.   

issues are critical because, if Nalcor is forced to burn additional oil in
order to meet ‘peak’ demand in winter, the earlier requirement for new generation could materially add great cost to the equation
used by Nalcor’s accountants (Cumulative Present Worth Analysis (CPW)) in order to conclude Muskrat Falls is the lowest cost option.   

another way, although the Maritime Link was excluded from the PUB review, the
Author assumed that the Nova Scotia Block was accounted for by Nalcor, Manitoba
Hydro, Navigant and the PUB to determine that Muskrat Falls was the lowest cost

assumption was wrong.

recently posted on its web site answers to questions raised by Mr. David Vardy¹ and others,
including this one, which bears on the subject under discussion: 

months January-May represent the period of ‘peak’ demand.  The acknowledgement, by Nalcor, that only
673MW, not the 830 MW capacity will be available, confirms a serious
omission in its representations not just to the PUB, but to its own

reply to Vardy’s question verifies that the work completed by Nalcor and
validated by MHI and Navigant, as third party expert verification of Nalcor’s
analysis, was not reflective of the true plan the Agency had in mind.  The revelation undermines three years of
public debate, in which the arguments presented for the project were grounded
in analysis based upon the wrong information

wonder that the PUB stated in its Report To Government that “(t)he information provided by Nalcor in
the review is not detailed, complete or current enough to allow the Board to
determine whether the Interconnected Option represents the least-cost option….”


longer protected by a limited reference question of its own design, Nalcor must
now answer the PUB’s concerns regarding the adequacy of power to meet the
Province’s needs after the commissioning of Muskrat Falls.  Nalcor cannot answer questions selectively
this time; its information must be based upon the entire project, including
those commitments made to Emera of Nova Scotia, which have been confirmed by
the UARB in that Province. 

Exhibit below was issued by Nalcor in response to a question from the Consumer
Advocate.  It provides a glimpse of the post-Muskrat

Table demonstrates that we will be dependent upon Nova Scotia to provide up to
300 MW of capacity to meet the required contingency levels at “peak” demand.  While the Table contains a lot of data, I
would refer you  specifically to the column titled “Maritime Link” in which a 300 MW capacity
from the Link is indicated commencing 2021-22.

has not verified if firm contracts have been executed which permit this supply;
nor has it confirmed if any additional costs for this power will have to be
borne by the NL rate payer.  If
additional costs apply to its procurement, we need to know if they are already
included in Nalcor’s rate projections. 
Note 4 of the Exhibit, attributed to this power allocation, is hardly

Within the original Muskrat Falls Review, the amount of oil consumed for thermal generation post-Muskrat
was limited. 
  Nalcor must now also disclose how much oil
will be burnt each year in order to meet our demand requirements.

In summary, Nalcor must clarify:

1)       If, post-Muskrat, we
will be burning oil, in Holyrood, to meet our obligations to Nova Scotia. 
2)      If the Island
ratepayer is responsible for the additional oil generation. 

3)      When the additional
fuel is added, is Muskrat Falls still the lowest option…was it ever?

4)      If 675 MW is still coming
from the LIL.  The number seems to
neglect any allocation of Muskrat Falls’ capacity to Labrador Mining.  The 75 MW allocation to Alderon will exacerbate
the power shortfall on the island.   

Finally, we must challenge the Government and Nalcor for spending resources
on MHI, Navigant and the PUB to review a scenario that was meaningless for any
purpose, except possibly to permit them to ‘sell’ the project to the

The people of Newfoundland and Labrador have been exposed, perhaps, to the
greatest ‘Snow Job’ in our history.  If
the consumers of the province are expected to pay additional rates to meet the delivery
of 167 MW to Nova Scotia, the proposition is worse than a deception; it is a
corruption of governance.  

The PUB should be mandated to investigate the matter. 

The full truth needs to come out.  

[1] Dave Vardy should be commended for his personal effort in raising
questions to Nalcor regarding the Muskrat Falls.  He has done a
yoeman service to the Province in raising awareness of issues such as
the one discussed in this piece.

Editors Note:
“JM” is the
anonymous researcher and writer who presented a major Paper to the PUB Review during
the Muskrat Falls Review.  He has since written a series of twelve Papers on various aspects of the project, links to which are found on The Sir Robert Bond Papers Blog. 

JM has also posted on Uncle Gnarley Blog, including, most recently, Gnarley’s Theory of Political DevolutionThe Great Revolutionary From The Shore
and The Right Side of History. 

To recent readers unfamiliar with “JM”, I would say that, while circumstances require
his anonymity, his credentials are his professional expertise,  his technical knowledge of the Muskrat Falls project and the high level of analysis he brings to the subject.  

– Des Sullivan


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.


This is the most important set of negotiations we have engaged in since the Atlantic Accord and Hibernia. Despite being a small jurisdiction we proved to be smart and nimble enough to negotiate good deals on both. They have stood the test of time and have resulted in billions of dollars in royalties and created an industry which represents over a quarter of our economy. Will we prove to be smart and nimble enough to do the same with the Upper Churchill?


  1. I think we need an Anti-Corruption Squad set up to monitor the Muskrat Falls Contract from the beginning to the end. I and many others are perturb on a daily basis over hearing how this project is run. It all sounds Very Corrupt to me! Let us prove that it isn't by doing an investigation through a vehicle like an Anti-Coruption Squad.

  2. With new revelations gathering steam, it is incumbent upon the PUB to act in the best interests of the people and the province….and call for an immediate halt to ALL work on this project. The evidence is clear that we are still very much in the dark on many unanswered questions and the final outcome could be even worse than us naysayers feared.

    I am not certain of the PUB's capacity to make such an order but, at the very least, they ought to come put publicly with very strong censure and very strong and specific recommendations to government that this project must be put on hold, pending further evaluation and analysis of the facts….not the fanciful slight of hand we have endured so far.

    Corruption is indeed a very strong word but the mounting evidence strongly suggests that there are significant truths that have been covered up and glossed over by both government and NALCOR. It is time, for those in a position to do so, to stand and be counted or the vile stench of this fiasco will permeate our collective psyche for generations.