From: Maurice E. Adams
Sent: May-03-14 12:44 PM
To: Cheryl Blundon
Subject: The Board's Investigation and Hearing into Supply Issues and Power Outages on the Island Interconnected System

- Request for Comments (2nd CORRECTED COPY)



My apologies again,  Ms. Blundon.

I appears that my earlier (and corrected) Written Comments on the above-noted subject contained a significant error with respect

to the total Island Interconnected System peak demand (CORRECTED VERSION BELOW).

Accordingly, I have made a final correction to issue #2 and included a 4th info-graphic to help clarify the issue.

Thank you, once again, for your consideration of this important matter.

Best regards,

Maurice E. Adams




Good day Ms. Blundon.

With respect to the above-noted matter.

Summary Comments

Key Issues

1.          Liberty Consulting appears to be well qualified in the areas of power generation, transmission/distribution/

2.          maintenance management systems, load forecasting, etc.


          I would, however, submit that

  • there is no clear evidence that Liberty Consulting has the requisite expertise in the areas of conservation
    and efficiency
  • conservation and efficiency are key issues identified by the Board, and I would suggest that when
    integrated with other options, conservation and efficiency may be the most reliable and lowest possible
    cost option for addressing short, medium and long term requirements
  • conservation and efficiency programs in other jurisdictions appear not only to be able to reduce energy use,
     but may help even keep rates stable or reduce them
  • other than a brief commentary in Liberty's interim report concerning NL Hydro and NL Power
    'communicating' their requests for consumers to conserve energy, the absence on any substantial
    information and/or recommendations in Liberty's report related to the issue of conservation and
    efficiency is (I would suggest) evidence to suggest that Liberty Consulting may not have the
    requisite expertise to properly consider, assess, and where appropriate, integrate these issues into the
    island's future electricity load, reliability and cost configurations
  • the Board should obtain independent consulting expertise in the area of conservation and efficiency
    (the level of such expertise should be similar to that demonstrated by Liberty Consulting in the areas
    of power generation, transmission/distribution/maintenance management systems, load forecasting,
    industry best practices, etc.)

2.        It seems clear (from Liberty's interim report) that the root causes of the electricity supply and outage
issues of 2013 and early 2014 were grounded, first and foremost, not in the failure of the island's
generation capacity as such, but in NL Hydro's maintenance, upgrading, and parts supply failure of
its transmission/distribution systems
(such as breakers and transformers), and it is these that in turn
caused the generators at Holyrood to shut down.

            I would submit therefore that

  • NL Hydro's emphasis on adding "new generation" is misplaced, and not supported by the facts or
    even by the evidence in Liberty's report
  • the facts show that while NL Hydro reports the existing total Island Interconnected System capacity
     at 1,946 MW and firm capacity at 1,813 MW, NL Hydro's data shows that the total Island
    Interconnected System peak demand for 2013 was in the vicinity of only 1,630 MW. Accordingly,
     the existing Island Interconnected System's total "available" capacity for 2013 should therefore
    have been more than 300 MW above peak demand and the existing Island Interconnected
    System's "available" firm capacity should have been almost 200 MW ABOVE the total Island
    Interconnected System peak demand (see 4th info-graphic below, copied from ) --- and Liberty Consulting Interim Report confirms that
    it is the Island Interconnected System capacity and requirements (not just the NL Hyrdo System
    capacity and requirements) that is most significant (Liberty's Recommendation No. 7 refers)
  • accordingly, the existing total and firm generation capacity should both have been more than
    --- if NL Hydro had done the proper upgrades, parts supply and maintenance on its
    transmission/distribution and generation systems
  • Liberty's interim report (page ES-2) states, in part, that "Addressing the continuing risks of
    imbalances requires either or both of adding resources and making sure
    that existing resources are available at peak times
    (during winters in the case of
    Newfoundland and Labrador)
    " -- emphasis added
  • clearly, Liberty's interim report identifies the problem --- not as being "inadequate" existing
    resources, but clearly a supply/demand
    "imbalance" --- an imbalance that can be addressed
     by EITHER adding new generation OR by "making sure that existing resources are available
    at peak times" --
    emphasis added
  • the Board should consider NL Hydro's planned, improved maintenance management system
    (which I understand was recommended by Liberty and is to be submitted by June 15, 2014)
    before it makes a decision on the most reliable (and lowest possible cost) immediate and short
     term option.
  • the evidence (and past events) confirm and demonstrate clearly that even when NL Hydro
     has had a firm capacity that is already in excess of peak demand, excess capacity has not
    been sufficient to ensure that NL Hydro has been able to provide island ratepayers with
    reliable service. Increasing that already existing "excess" capacity is clearly not addressing
    the fundamental problem --- NL Hydro's failure with respect to the maintenance management
    of its existing resources
  • accordingly, I would suggest that adding new generation to address what is fundamentally
    a maintenance problem is not in the best interest of ratepayers, not the lowest cost, provides
    no confidence that such new generation will indeed be 'available', is not necessary and does
    not address the root problem


 3.        It is clear from the info-graphics (below) that the island's already existing generation capacity
is already underutilized (copied from




Notwithstanding the above-noted information, it should be noted that Holyrood rarely operates at capacity (1.6 percent of the time), or
 less than 6 days per year (and not at all in year 2011).

Surely, ratepayers should not have to pay even more because NL Hydro has not properly maintained its transmission and distribution
systems and is under-utilizing its already existing excess generation capacity.


Maurice E. Adams