Ameren buries hopes for buried power lines, puts efforts into tree trimming

AP1000 Refueling Outage Record showcases Westinghouse nuclear power excellence as Sanmen Unit 2 completes its first reactor refueling in 28.14 days, highlighting safety, reliability, outage optimization, and economic efficiency in China.

Key Points

It is the 28.14-day initial refueling at Sanmen Unit 2, a global benchmark achieved with Westinghouse AP1000 technology.

✅ 28.14-day first refueling at Sanmen Unit 2 sets global benchmark

✅ AP1000 design simplifies systems, improves safety and reliability

✅ Outage optimization by Westinghouse and CNNC accelerates schedules

Westinghouse Electric Company China operations today announced that Sanmen Unit 2, one of the world's first AP1000® nuclear power plants, has set a new refueling outage record in the global nuclear power industry, completing its initial outage in 28.14 days.

"Our innovative AP1000 technology allows for simplified systems and significantly reduces the amount of equipment, while improving the safety, reliability and economic efficiency of this nuclear power plant, reflecting global nuclear milestones reached recently," said Gavin Liu, president of the Westinghouse Asia Operating Plant Services Business. "We are delighted to see the first refueling outage for Sanmen Unit 2 was completed in less than 30 days. This is a great achievement for Sanmen Nuclear Power Company and further demonstrates the outstanding performance of AP1000 design."

All four units of the AP1000 nuclear power plants in China have completed their first refueling outages in the past 18 months, aligning with China's nuclear energy development momentum across the sector.  The duration of each subsequent outage has fallen significantly - from 46.66 days on the first outage to 28.14 days on Sanmen Unit 2.

"During the first AP1000 refueling outage at the Sanmen site in December 2019, a Westinghouse team of experts worked side-by-side with the Sanmen outage team to partner on outage optimization, and immediately set a new standard for a first-of-a-kind outage, while major refurbishments like the Bruce refurbishment moved forward elsewhere," said Miao Yamin, chairman of CNNC Sanmen Nuclear Power Company Limited. "Lessons learned were openly exchanged between our teams on each subsequent outage, which has built to this impressive achievement."

Westinghouse provided urgent technical support on critical issues during the outage, as international programs such as Barakah Unit 1 achieved key milestones, to help ensure that work was carried out on schedule with no impact to critical path.

In addition to the four AP1000 units in China, two units are under construction at the Vogtle expansion near Waynesboro, Georgia, USA.

Separately, in the United States, a new reactor startup underscored renewed momentum in nuclear generation this year.

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EU Winter Energy Mix 2022-2023 shows renewables, wind, solar, and hydro overtaking coal and gas, as demand fell amid high prices; Ember and IEA confirm lower emissions across Europe during the energy crisis.

Key Points

It describes Europe's winter power mix: reduced coal and gas, and record wind, solar, and hydro output.

✅ Coal generation fell 11% YoY; gas output declined even more.

✅ Renewables supplied 40%: wind, solar, and hydro outpaced fossil fuels.

✅ Ember and IEA confirm trends; mild winter tempered demand.

The EU burned less coal this winter during the energy crisis than in previous years, according to an analysis, quashing fears that consumption of the most polluting fossil fuel would soar as countries scrambled to find substitutes for lost supplies of Russian gas.

The study from energy think-tank Ember shows that between October 2022 and March 2023 coal generation fell 27 terawatt hours, or almost 11 per cent year on year, while gas generation fell 38 terawatt hours, as renewables crowded out gas and consumers cut electricity consumption in response to soaring prices.

Renewable energy supplies also rose, with combined wind and solar power and hydroelectric output outstripping fossil fuel generation for the first time, providing 40 per cent of all electricity supplies. The Financial Times checked Ember’s findings with the International Energy Agency, which said they broadly matched its own preliminary analysis of Europe’s electricity generation over the winter.

The study demonstrates that fears of a steep rebound in coal usage in Europe’s power mix were overstated, despite the continent’s worst energy crisis in 40 years following Russia’s full-scale invasion of Ukraine, even as stunted hydro and nuclear output in parts of Europe posed challenges.

While Russia slashed gas supplies to Europe and succeeded in boosting energy prices for consumers to record levels, the push by governments to rejuvenate old coal plants, including Germany's coal generation, to ensure the lights stayed on ultimately did not lead to increased consumption.

“With Europe successfully on the other side of this winter and major supply disruptions avoided, it is clear the threatened coal comeback did not materialise,” analysts at Ember said in the report.

“With fossil fuel generation down, EU power sector emissions during winter were the lowest they have ever been.”

Ember cautioned, however, that Europe had been assisted by a mild winter that helped cut electricity demand for heating and there was no guarantee of such weather next winter. Companies and households had also endured a lot of pain as a result of the higher prices that had led them to cut consumption, even though in some periods, such as the latest lockdown, power demand held firm in parts of Europe.

Total electricity consumption between October and March declined 94 terawatt hours, or 7 per cent, compared with the same period in winter 2021/22, continuing post-Covid transition dynamics across Europe.

“For a lot of people this winter was really hard with electricity prices that were extraordinarily high and we shouldn’t lose sight of that,” said Ember analyst Harriet Fox.

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Ontario Electricity Capacity Gap threatens reliability as IESO forecasts shortfalls from the Pickering shutdown and rapid electrification, requiring new low-emission nuclear generation to meet net-zero targets, maintain baseload, and stabilize the grid.

Key Points

Expected 2030 shortfalls from Pickering closure and electrification, requiring new low-emission nuclear to meet net-zero.

✅ IESO projects a 3.6-9.5 GW capacity gap by 2030

✅ Pickering shutdown removes baseload, stressing reliability

✅ New low-emission nuclear needed to meet net-zero targets

Ontario faces an electricity supply shortage and reliability risks in the next four to eight years and will not meet net-zero objectives without building new low-emission, nuclear generation starting as soon as possible, according to a report released yesterday by the Power Workers' Union (PWU). The capacity needed to fill the expected supply gap will be equivalent to doubling the province's planned nuclear fleet in eight years.

The planned closure of the Pickering nuclear power plant in 2025 and the increase in demand from electrification of the economy are the drivers behind a capacity gap in 2030 of at least 3.6 GW which could widen to as much as 9.5 GW, Electrification Pathways for Ontario to Reduce Emissions, finds. Ontario's Independent Electricity System Operator (IESO) has since 2013 been forecasting a significant gap in the province's electricity supply due the closure of Pickering, but has been underestimating the impact of electrification, the report says.

In addition, the electrification of buildings, transport and industry sectors that will be needed to achieve goals of net-zero emissions by 2050 that being set by the federal government and civil society will see the province's electricity demand increase by at least 130% over current planning forecasts, and potentially by over 190%. Leveraging electricity, natural gas and hydrogen synergies can reduce supply needs, but 55 GW of new electricity capacity, including new large-scale nuclear plants, will still be needed by 2050 - four times Ontario's current nuclear and hydro assets - the report finds.

These findings underscore the urgent need for a paradigm shift in Ontario's electricity planning and procurement process, the authors say, adding that immediate action is needed both to mitigate the system reliability risks and enable the significant societal benefits needed to pursue net-zero objectives. Planning for procurement to replace Pickering's capacity, or to pursue life extension options, must begin as soon as possible.

"Policymakers around the world realise climate change can't be tackled without nuclear. Ontario's nuclear fleet has delivered emissions reductions for over 50 years," PWU President Jeff Parnell said. "In fact, without building new nuclear units, Ontario will miss its emission reduction targets and carbon emissions from electricity generation will rise dramatically, as explored in why Ontario's power could get dirtier today."

"This report clearly shows that Ontario cannot sustain the low-carbon status of its hydro and nuclear-based electricity system, decarbonise its economy and meet its carbon reduction targets without new nuclear or continued operation at Pickering in the near term. Most disturbing is the fact that we are already well behind and needed to start planning for this capacity yesterday," he said.

The six operating Candu reactors at Ontario Power Generation's Pickering plant have been kept in operation to provide baseload electricity during the refurbishment of units at the Darlington and Bruce plants. Currently, the company plans to shut down Pickering units 1 and 4 in 2024 and units 5 to 8 in 2025, even as Ontario moves to refurbish Pickering B to extend life.

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BC-Alberta Transmission Intertie enables clean hydro to balance wind and solar, expanding transmission capacity so Site C hydro can dispatch power, cut emissions, lower costs, and accelerate electrification across provincial grids under federal climate policy.

Key Points

A cross-provincial grid link using BC hydro to firm Alberta wind and solar, cutting emissions and costs.

✅ Balances variable renewables with dispatchable hydro from Site C.

✅ Enables power trade: peak exports, low-cost wind imports.

✅ Lowers decarbonization costs and supports electrification goals.

By Mark Jaccard

Lost in the news and noise of the federal government's newly announced $170-per-tonne carbon tax was a single, critical sentence in Canada's updated climate plan, one that signals a strategy that could serve as the cornerstone for a future free of greenhouse gas emissions.

"The government will work with provinces and territories to connect parts of Canada that have abundant clean hydroelectricity with parts that are currently more dependent on fossil fuels for electricity generation — including by advancing strategic intertie projects."

Why do we think this one sentence is so important? And what has it got to do with the controversial Site C project Site C electricity debate under construction in British Columbia?

The answer lies in the huge amount of electricity we'll need to generate in Canada to achieve our climate goals for 2030 and 2050. Even while we aggressively pursue energy efficiency, our electric cars, buses and perhaps trucks in Canada's net-zero race will need a huge amount of new electricity, as will our buildings and industries. 

Luckily, Canada is blessed with an electricity system that is the envy of the world — already over 80 per cent zero emission, the bulk being from flexible hydro-electricity, with a backbone of nuclear power largely in Ontario, a national electricity success and rapidly growing shares of cheap wind and solar. 

Provincial differences
Yet the story differs significantly from one province to another. While B.C.'s electricity is nearly emissions free, the opposite is true of its neighbour, Alberta, where more than 80 per cent still comes from fossil fuels. This, despite an impressive shift away from coal power in recent years.

Now imagine if B.C. and Alberta were one province.

This might sound like the start of a bad joke, or a horror movie to some, but it's the crux of new research by a trio of energy economists who put a fine point on the value of such co-operation.

The study, by Brett Dolter, Kent Fellows and Nic Rivers, takes a detailed look at the economic case for completing Site C, BC Hydro's controversial large hydro project under construction, and makes three key conclusions.

First, they argue Site C should likely not have been started in the first place. Only a narrow set of assumptions can now justify its total cost. But what's done is done, and absent a time machine, the decision to complete the dam rests on go-forward costs.

On that note, their second conclusion is no more optimistic. Considering the cost to complete the project, even accounting for avoiding termination costs should it be cancelled, they find the economics of completing Site C over-budget status to be weak. If the New York Times had a Site C needle in the style of the newspaper's election visual, it would be "leaning cancel" at this point.

In Alberta, more than 80 per cent of the electricity still comes from fossil fuels, despite an impressive shift away from coal power in recent years. (CBC)
But it is their third conclusion that stands out as worthy of attention. They argue there is a case for completing Site C if the following conditions are met:

B.C. and Alberta reduce their electricity sector emissions by more than 75 per cent (this really means Alberta, given B.C.'s already clean position); and

B.C. and Alberta expand their ability to move electricity between their respective provinces by building new transmission lines.

Let's deal with each of these in turn.

On Condition 1, we give an emphatic: YES! Reducing electricity emissions is an absolute must to meet climate pledges if Canada is to come even close to achieving its net-zero goals. As noted above, a clean electricity grid will be the cornerstone of a decarbonized economy as we generate a great deal more power to electrify everything from industrial processes to heating to transportation and more. 

Condition 2 is more challenging. Talk of increasing transmission connections across Canada, including Hydro-Québec's U.S. strategy has been ongoing for over 50 years, with little success to speak of. But this time might well be different. And the implications for a completed Site C, should the government go that route, are profound.

Wind and solar costs rapidly declining
Somewhat ironically, the case for Site C is made stronger by the rapidly declining costs of two of its apparent renewable competitors: wind and solar.

The cost of wind and solar generation has fallen by 70 per cent and 90 per cent, respectively, a dramatic decline in the past 10 years. No longer can these variable sources of power be derided as high cost; they are unequivocally the cheapest sources of raw energy in electricity systems today.

However, electricity system operators must deal with their "non-dispatchability," a seemingly complicated term that simply means they produce electricity only when the sun shines and the wind blows, which is not necessarily when electricity customers want their electricity delivered (dispatched) to them. And because of this characteristic, the value of dispatchable electricity sources, like a completed Site C, will grow as a complement to wind and solar. 

Thus, as Alberta's generation of cheap wind and solar grows, so too does the value of connecting it with the firm, dispatchable resources available in B.C.

Rather than displacing wind and solar, large hydro facilities with the ability to increase or decrease output on short notice can actually enable more investment in these renewable sources. Expanding the transmission connection, with Site C on one side of that line, becomes even more valuable.

Many in B.C. might read this and rightly ask themselves, why should we foot the bill for this costly project to help out Albertans? The answer is that it won't be charity — B.C. will get paid handsomely for the power it delivers in peak periods and will be able to import wind power at low prices from Alberta in other times. B.C. will benefit greatly from these gains of trade.

Turning to Alberta, why should Albertans support B.C. reaping these gains? The answer is two-fold.

First, Site C will actually enable more low-cost wind and solar to be built in Alberta due to hydro's ability to balance these non-dispatchable renewables. Jobs and economic opportunity will occur in Alberta from this renewable energy growth.

Second, while B.C. imports won't come cheap, they will be less costly than the decarbonization alternatives Alberta would need without B.C.'s flexible hydro, as the economists' study shows. This means lower overall costs to Alberta's power consumers.

A clear role for Ottawa
To be sure, there are challenges to increasing the connectedness of B.C. and Alberta's power systems, not least of which is BC Hydro being a regulated, government-owned monopoly while Alberta is a competitive market amongst private generators. Some significant accommodations in climate policy and grids will be needed to ensure both sides can compete and benefit from trade on an equal footing.

There is also the pesky matter of permitting and constructing thousands of kilometres of power lines. Getting linear energy infrastructure built in Canada has not exactly been our forte of late.

We are not naive to the significant challenges in such an approach, but it's not often that we see such a clear narrative for beneficial climate action that, when considered at the provincial level, is likely to be thwarted, but when considered more broadly can produce a big win.

It's the clearest example yet of a role for the federal government to bridge the gap, to facilitate the needed regulatory conversations, and, let's be frank, to bring money to the table to make the line happen. Neither provincial side is likely to do it on their own, nor, as history has shown, are they likely to do it together. 

For a government committed to reducing emissions, and with a justified emphasis on the electricity sector, the opportunity to expand the Alberta-B.C. transmission intertie, leveraging the flexibility of B.C.'s hydro with the abundance of wind and solar potential on the Prairies, offers a potential massive decarbonization win for Western Canada that is too good to ignore.

Mark Jaccard, a professor at Simon Fraser University, and Blake Shaffer, a professor at the University of Calgary

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Alberta Energy-Only Electricity Market faces capacity market debate, AESO price cap review, and coal-to-gas shifts by TransAlta and Capital Power, balancing reliability with volatility as investment signals evolve across Alberta's grid.

Key Points

An energy market paying generators only for electricity sold, with AESO oversight and a price cap guiding new capacity.

✅ AESO reviewing $999 per MW-h wholesale price cap.

✅ UCP retained energy-only; capacity market plan cancelled.

✅ TransAlta and Capital Power shift to coal-to-gas.

The Kenney government’s decision to cancel the redesign of Alberta’s electricity system to a capacity market won’t side-track two of the province’s largest power generators from converting coal-fired facilities to burn natural gas as part of Alberta’s shift from coal to cleaner energy overall.

But other changes could be coming to the province’s existing energy-only electricity market — including the alteration of the $999 per megawatt-hour (MW-h) wholesale price cap in Alberta.

The heads of TransAlta Corp. and Capital Power Corp. are proceeding with strategies to convert existing coal-fired power generating facilities to use natural gas in the coming years.

Calgary-based TransAlta first announced in 2017 that it would make the switch, as the NDP government was in the midst of overhauling the electricity sector and wind generation began to outpace coal in the province.

At the time, the Notley government planned to phase out coal-fired power by 2030, even as Alberta moved to retire coal by 2023 in practice, and shift Alberta into an electricity capacity market in 2021.

Such a move, made on the recommendation of the Alberta Electric System Operator (AESO), was intended to reduce price volatility and ensure system reliability.

Under the energy-only market, generators receive payments for electricity produced and sold into the grid. In a capacity market, generators are also paid for having power available on demand, regardless of how often they sell energy into the provincial grid.

The UCP government decided last month to ditch plans for a capacity market after consulting with the sector, saying it would be better for consumers.

On a conference call, TransAlta CEO Dawn Farrell said the company will convert coal-fired generating plants to burn gas, although it may alter the mix between simple conversions and switching to so-called “hybrid” plants.

(A hybrid conversion is a larger and more-expensive switch, as it includes installing a new gas turbine and heat-recovery steam generator, but it creates a highly efficient combined cycle unit.)

“Our view is fundamentally that carbon will be priced over the next 20 years no matter what,” she said Friday.

“We cannot get off coal fast enough in this company, and gas right now in Alberta is extremely inexpensive…

“So our coal-to-gas strategy is completely predicated on our belief that it’s not smart to be in carbon-intensive fuels for the future.”

Elsewhere in Canada, the Stop the Shock campaign has advocated for reviving coal power, underscoring ongoing policy debates.

The company said it’s planning the coal-to-gas conversion and re-powering of some or all of the units at its Keephills and Sundance facilities to gas-fired generation sometime between 2020 and 2023.

Similarly, Capital Power CEO Brian Vaasjo said the Edmonton-based company is moving ahead with a project that will allow it to burn both coal and natural gas at its Genesee generating station, even as Ontario’s energy minister sought to explore a halt to natural gas generation elsewhere.

In June, the company announced it would spend an estimated $50 million between 2019 and 2021 to allow it to use gas at the facility.

“What we’re doing is going to be dual fuel, so we will be able to operate 100 per cent natural gas or 100 per cent coal and everything in between,” Vaasjo said in an interview.

“You can expect to see we will be burning coal in the winter when natural gas prices are high, and we will be burning natural gas in summer when gas prices are real low.”

The transition comes as the government’s decision to stick with the energy-only market has been welcomed by players in the industry, and as Alberta's electricity future increasingly leans on wind resources.

A study by electricity consultancy EDC Associates found the capacity market would result in consumers paying an extra $1.4 billion in direct costs in 2021-22, as it required more generation to come online earlier than expected.

These additional costs would have accumulated to $10 billion by 2030, said EDC chief executive Duane-Reid Carlson.

For Capital Power, the decision to stick with the current system makes the province more investable in the future. Vaasjo said there was great uncertainty about the transition to a capacity market, and the possibility of rules shifting further.

Officials with Enmax Corp. said the city-owned utility would not have invested in future generation under the proposed capacity market.

“There is no short-term need (today) for new generation, so we’re just looking at the market and saying, ‘OK, as it evolves, we will see what happens,’” said Enmax vice-president Tim Boston.

Sticking with the energy-only market doesn’t mean Alberta will keep the existing rules.

In a July 25 letter, Alberta Energy Minister Sonya Savage directed AESO chair Will Bridge to examine if changes to the existing market are needed and report back by July 2020.

AESO, which manages the power grid, has been asked to investigate whether the current price cap of $999 per megawatt-hour (MW-h) should be changed.

The price ceiling hasn’t been altered since the energy-only market was implemented by the Klein government about two decades ago.

While allowing prices to go higher would increase volatility, reflecting lessons from Europe’s power crisis about scarcity pricing, during periods of rising demand and limited supply, it would send a signal to generators when investment in new generation is required, said Kent Fellows, a research associate at the University of Calgary’s School of Public Policy.

“Keeping the price (cap) too low could end up costing us more in the long run,” he said.

In a 2016 report, AESO said the province examined raising the price cap to $5,000 per MW-h, but “determined that it was unlikely to be successful in attracting investment due to increased price volatility.”

However, the amount of future generation that will be required in Alberta has been scaled back by the province.

In the United States, the Electricity Reliability Council of Texas (ERCOT) allows wholesale power prices in the state to climb to a cap of $9,000 per megawatt hours as demand rises — as it did Tuesday in the midst of a heat wave, according to Bloomberg.

Jim Wachowich, legal counsel for the Consumers’ Coalition of Alberta, said while few players are exposed to spot electricity prices, he has yet to be convinced raising the cap would be good for Albertans.

“Someone has to show me the evidence, and I suspect that’s what the minister has asked the AESO to do,” he said.

Generators say they believe some tinkering is needed to the energy-only market to ensure new generation is built when it’s required.

“The No. 1 change that the government has to … think about is in pricing,” added Farrell.

“If you don’t have enough of a price signal in an energy-only market to attract new capital, you won’t get new capital — and you’ll run up against the wall.”

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Muskrat Falls rate mitigation offsets Newfoundland Power's rate stabilization decrease as NL Hydro begins cost recovery; Public Utilities Board approval enables collections while Labrador-Island Link nears commissioning, stabilizing electricity rates despite megaproject delays, overruns.

Key Points

Muskrat Falls rate mitigation is NL Hydro's cost recovery via power rates to stabilize bills as commissioning nears.

✅ Offsets 6.4% decrease with a 6.1% rate increase

✅ About 6% now funds NL Hydro's rate mitigation

✅ Collections begin as Labrador-Island Link nears commissioning

With their July electricity bill, Newfoundland Power customers have begun paying for Muskrat Falls, though a lump-sum credit was also announced to offset costs and bills haven't significantly increased — yet.

In a July newsletter, Newfoundland Power said electricity bills were set to decrease by 6.4 per cent as part of the annual rate stabilization adjustment, which reflects the cost of electricity generation.

Instead, that decrease has been offset by a 6.1 increase in electricity rates so Newfoundland and Labrador Hydro can begin recovering the cost of Muskrat Falls, with a $5.2-billion federal package also underpinning the project, the $13-billion hydroelectric megaproject that is billions over budget and years behind schedule.

That means for residential customers, electricity rates will decrease to 12.346 cents per kilowatt, though the basic customer charge will go up slightly from $15.81 to $15.83. According to an N.L. Hydro spokesperson, about six per cent of electricity bills will now go toward what it calls a "rate mitigation fund." 

N.L. Hydro claims victory in Muskrat Falls arbitration dispute with Astaldi
Software troubles blamed for $260M Muskrat Falls cost increase, with N.L. power rates stable for now
The spokesperson said N.L. Hydro is expecting the rate increase to result in $43 million this year, according to a recent financial update from the energy corporation — a tiny fraction of the project's cost. 

N.L. Hydro asked the Public Utilities Board to approve the rate increase, a process similar to Nova Scotia's recent 14% approval by its regulator, in May. In a letter, Energy, Industry and Technology Minister Andrew Parsons supported the increase, though he asked N.L. Hydro to keep electricity rates "as close to current levels as possible. 

Province modifies order in council
Muskrat Falls is not yet fully online — largely due to software problems with the Labrador-Island Link transmission line — and an order in council dictated that ratepayers on the island of Newfoundland would not begin paying for the project until the project was fully commissioned. 

The provincial government modified that order in council so N.L. Hydro can begin collecting costs associated with Muskrat Falls once the project is "nearing" commissioning.

In June, N.L. Hydro said the project was expected to finally be completed by the end of the year.

In an interview with CBC News, Progressive Conservative interim leader David Brazil said the decision to begin recovering the cost of Muskrat Falls from consumers should have been delayed.

"There was an opportunity here for people to get some reprieve when it came to their electricity bills and this administration chose not to do that, not to help the people while they're struggling," he said.

In a statement, Parsons said reducing the rate was not an option, and would have resulted in increased borrowing costs for Muskrat Falls.

"Reducing the rate for one year to have it increase significantly the following year is not consistent with rate mitigation and also places an increased financial burden on taxpayers one year from now," Parsons said.

Decision 'reasonable': Consumer advocate
Brazil said his party didn't know the payments from Muskrat Falls would start in July, and criticized the government for not being more transparent.

A person wearing a blue shirt and black blazer stands outside on a lawn.
N.L. consumer advocate Dennis Browne says it makes sense to begin recouping the cost of Muskrat Falls. (Garrett Barry/CBC)
Newfoundland and Labrador consumer advocate Dennis Browne said the decision to begin collecting costs from consumers was "reasonable."

"We're into a financial hole due to Muskrat Falls, and what has happened is in order to stabilize rates, we have gone into rate stabilization efforts," he said.

In February, the provincial and federal governments signed a complex agreement to shield ratepayers aimed at softening the worst of the financial impact from Muskrat Falls. Browne noted even with the agreement, the provincial government will have to pay hundreds of millions in order to stabilize electricity rates.

"Muskrat Falls would cost us $0.23 a kilowatt, and that is out of the range of affordability for most people, and that's why we're into rate mitigation," he said. "This was part of a rate mitigation effort, and I accepted it as part of that."

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