A New Era for Churchill Falls: Newfoundland and Labrador Secures Billions in Landmark Deal with Quebec

BC Hydro drought operations address climate change impacts with hydropower scheduling, reservoir management, water conservation, inflow forecasting, and fish habitat protection across the Lower Mainland and Vancouver Island while maintaining electricity generation from storage facilities.

Key Points

BC Hydro drought operations conserve water, protect fish, and sustain hydropower during extended heat and low inflows.

✅ Proactive reservoir releases protect downstream salmon spawning.

✅ Reduced flows at Puntledge, Coquitlam, and Ruskin/Stave facilities.

✅ System relies on northern storage to maintain electricity supply.

BC Hydro is adjusting its operating plans around power generation as extended heat and little forecast rain continue to impact the province, a report says.

“Unpredictable weather patterns related to climate change are expected to continue in the years ahead and BC Hydro is constantly adapting to these evolving conditions, especially after events such as record demand in 2021 that tested the grid,” said the report, titled “Casting drought: How climate change is contributing to uncertain weather and how BC Hydro’s generation system is adapting.”

The study said there is no concern with BC Hydro being able to continue to deliver power through the drought because there is enough water at its larger facilities, even as issues like crypto mining electricity use draw scrutiny from observers.

Still, it said, with no meaningful precipitation in the forecast, its smaller facilities in the Lower Mainland and on Vancouver Island will continue to see record low or near record low inflows for this time of the year.

“In the Lower Mainland, inflows since the beginning of September are ranked in the bottom three compared to historical records,” the report said.

The report said the hydroelectric system is directly impacted by variations in weather and the record-setting, unseasonably dry and warm weather this fall highlights the impacts of climate change, while demand patterns can be counterintuitive, as electricity use even increased during Earth Hour 2018 in some areas, hinting at challenges to come.

It noted symptoms of climate change include increased frequency of extreme events like drought and intense storms, and rapid glacial melt.

“With the extremely hot and dry conditions, BC Hydro has been taking proactive steps at many of our South Coast facilities for months to conserve water to protect the downstream fish habit,” spokesperson Mora Scott said. “We began holding back water in July and August at some facilities anticipating the dry conditions to help ensure we would have water storage for the later summer and early fall salmon spawning.”

Scott said BC Hydro’s reservoirs play an important role in managing these difficult conditions by using storage and planning releases to provide protection to downstream river flows. The reservoirs are, in effect, a battery waiting to be used for power.

While the dry conditions have had an impact on BC Hydro’s watersheds, several unregulated natural river systems — not related to BC Hydro — have fared worse, with rivers drying up and thousands of fish killed, the report said.

BC Hydro is currently seeing the most significant impacts on operations at Puntledge and Campbell River on Vancouver Island as well as Coquitlam and Ruskin/Stave in the Lower Mainland.

To help manage water levels on Vancouver Island, BC Hydro reduced Puntledge River flows by one-third last week and on the Lower Mainland reduced flows at Coquitlam by one-third and Ruskin/Stave by one quarter.

However, the utility company said, there are no concerns about continued power delivery.

“British Columbians benefit from BC Hydro’s integrated, provincial electricity system, which helps send power across the province, including to Vancouver Island, and programs like the winter payment plan support customers during colder months,” staff said.

Most of the electricity generated and used in B.C. is produced by larger facilities in the north and southeast of the province — and while water levels in those areas are below normal levels, there is enough water to meet the province’s power needs, even as additions like Site C's electricity remain a subject of debate among observers.

The Glacier Media investigation found a quarter of BC Hydro's power comes from the Mica, Revelstoke and Hugh Keenleyside dams on the Columbia River. Some 29% comes from dams in the Peace region, including the under-construction Site C project that has faced cost overruns. At certain points of the year, those reservoirs are reliant on glacier water.

Still, BC Hydro remains optimistic.

Forecasts are currently showing little rain in the near-term; however, historically, precipitation and inflows show up by the end of October. If that does not happen, BC Hydro said it would continue to closely track weather and inflow forecasts to adapt its operations to protect fish, while regional cooperation such as bridging with Alberta remains part of broader policy discussions.

Among things BC Hydro said it is doing to adapt are:

Continuously working to improve its weather and inflow forecasting;
Expanding its hydroclimate monitoring technology, including custom-made solutions that have been designed in-house, as well as upgrading snow survey stations to automated, real-time snow and climate stations, and;
Investing in capital projects — like spillway gate replacements — that will increase resiliency of the system to climate change.

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Quebec Energy Bill Tariff Delay disrupts Canada-U.S. trade, renewable energy investment, hydroelectric expansion, and clean technology projects, as Trump tariffs on aluminum and steel raise costs, threatening climate targets and green infrastructure timelines.

Key Points

A policy pause in Quebec from U.S. tariff threats, disrupting clean investment, hydro expansion, and climate targets.

✅ Tariff risk inflates aluminum and steel project costs.

✅ Quebec delays clean energy legislation amid trade uncertainty.

✅ Hydroelectric reliance complicates emissions reduction timelines.

The Trump administration's tariff threat has had a significant impact on Quebec's energy sector, with tariff threats boosting support for projects even as the uncertainty resulted in the delay of a critical energy bill. Originally introduced to streamline energy development and tackle climate change, the bill was meant to help transition Quebec towards greener alternatives while fostering economic growth. However, the U.S. threat to impose tariffs on Canadian goods, including energy products, introduced a wave of uncertainty that led to a pause in the bill's legislative process.

Quebec’s energy bill had ambitious goals of transitioning to renewable sources like wind, solar, and hydroelectric power. It sought to support investments in clean technologies and the expansion of the province's clean energy infrastructure, as the U.S. demand for Canadian green power continues to grow across the border. Moreover, it emphasized the reduction of carbon emissions, an important step towards meeting Quebec's climate targets. At its core, the bill aimed to position the province as a leader in green energy development in Canada and globally.

The interruption caused by President Donald Trump's tariff rhetoric has, however, cast a shadow over the legislation. Tariffs, if enacted, would disproportionately affect Canada's energy exports, with electricity exports at risk under growing tensions, particularly in sectors like aluminum and steel, which are integral to energy infrastructure development. These tariffs could increase the cost of energy-related projects, thereby hindering Quebec's ability to achieve its renewable energy goals and reduce carbon emissions in a timely manner.

The tariff threat was seen as a part of the broader trade tensions between the U.S. and Canada, a continuation of the trade war that had escalated under Trump’s presidency. In this context, the Quebec government was forced to reconsider its legislative priorities, with policymakers citing concerns over the potential long-term consequences on the energy industry, as leaders elsewhere threatened to cut U.S.-bound electricity to exert leverage. With the uncertainty around tariffs and trade relations, the government opted to delay the bill until the geopolitical situation stabilized.

This delay underscores the vulnerability of Quebec’s energy agenda to external pressures. While the provincial government had set its sights on an ambitious green energy future, it now faces significant challenges in ensuring that its projects remain economically viable under the cloud of potential tariffs, even as experts warn against curbing Quebec's exports during the dispute. The delay in the energy bill also reflects broader challenges faced by the Canadian energy sector, which is highly integrated with the U.S. market.

The situation is further complicated by the province's reliance on hydroelectric power, a cornerstone of its energy strategy that supplies markets like New York, where tariffs could spike New York energy prices if cross-border flows are disrupted. While hydroelectric power is a clean and renewable source of energy, there are concerns about the environmental impact of large-scale dams, and these concerns have been growing in recent years. The tariff threat may prompt a reevaluation of Quebec’s energy mix and force the government to balance its environmental goals with economic realities.

The potential imposition of tariffs also raises questions about the future of North American energy cooperation. Historically, Canada and the U.S. have enjoyed a symbiotic energy relationship, with significant energy trade flowing across the border. The energy bill in Quebec was designed with the understanding that cross-border energy trade would continue to thrive. The Trump administration's tariff threat, however, casts doubt on this stability, forcing Quebec lawmakers to reconsider how they proceed with energy policy in a more uncertain trade environment.

Looking forward, Quebec's energy sector will likely need to adjust its strategies to account for the possibility of tariffs, while still pushing for a sustainable energy future, especially if Biden outlook for Canada's energy proves more favorable for the sector in the medium term. It may also open the door for deeper discussions about diversification, both in terms of energy sources and trade partnerships, as Quebec seeks to mitigate the impact of external threats. The delay in the energy bill, though unfortunate, may serve as a wake-up call for Canadian lawmakers to rethink how they balance environmental goals with global trade realities.

Ultimately, the Trump tariff threat highlights the delicate balance between regional energy ambitions and international trade dynamics. For Quebec, the delay in the energy bill could prove to be a pivotal moment in shaping the future of its energy policy.

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Wall Street Fossil Fuel Pivot signals banks reassessing ESG, net-zero, and decarbonization goals, reviving oil, gas, and coal financing while recalibrating clean energy exposure amid policy shifts, regulatory rollbacks, and investment risk realignment.

Key Points

A shift as major U.S. banks ease ESG limits to fund oil, gas, coal while rebalancing alongside renewables.

✅ Banks revisit lending to oil, gas, and coal after policy shifts.

✅ ESG and net-zero commitments face reassessment amid returns.

✅ Renewables compete for capital as risk models are updated.

The global energy finance sector, worth a staggering $1.4 trillion, is undergoing a significant transformation, largely due to former President Donald Trump's renewed support for the oil, gas, and coal industries. Wall Street, which had previously aligned itself with global climate initiatives and the energy transition and net-zero goals, is now reassessing its strategy and pivoting toward a more fossil-fuel-friendly stance.

This shift represents a major change from the earlier stance, where many of the largest U.S. banks and financial institutions took a firm stance on decarbonization push, including limiting their exposure to fossil-fuel projects. Just a few years ago, these institutions were vocal supporters of the global push for a sustainable future, with many committing to support clean energy solutions and abandon investments in high-carbon energy sources.

However, with the change in administration and the resurgence of support for traditional energy sectors under Trump’s policies, these same banks are now rethinking their strategies. Financial institutions are increasingly discussing the possibility of lifting long-standing restrictions that limited their investments in controversial fossil-fuel projects, including coal mining, where emissions drop as coal declines, and offshore drilling. The change reflects a broader realignment within the energy finance sector, with Wall Street reexamining its role in shaping the future of energy.

One of the most significant developments is the Biden administration’s policy reversal, which emphasized reducing the U.S. carbon footprint in favor of carbon-free electricity strategies. Under Trump, however, there has been a renewed focus on supporting the traditional energy sectors. His administration has pushed to reduce regulatory burdens on fossil-fuel companies, particularly oil and gas, while simultaneously reintroducing favorable tax incentives for the coal and gas industries. This is a stark contrast to the Biden administration's efforts to incentivize the transition toward renewable energy and zero-emissions goals.

Trump's policies have, in effect, sent a strong signal to financial markets that the fossil-fuel industry could see a resurgence. U.S. banks, which had previously distanced themselves from financing oil and gas ventures due to the pressure from environmental activists and ESG (Environmental, Social, and Governance) investors, as seen in investor pressure on Duke Energy, are now reconsidering their positions. Major players like JPMorgan Chase and Goldman Sachs are reportedly having internal discussions about revisiting financing for energy projects that involve high carbon emissions, including controversial oil extraction and gas drilling initiatives.

The implications of this shift are far-reaching. In the past, a growing number of institutional investors had embraced ESG principles, with the goal of supporting the transition to renewable energy sources. However, Trump’s pro-fossil fuel stance appears to be emboldening Wall Street’s biggest players to rethink their commitment to green investing. Some are now advocating for a “balanced approach” that would allow for continued investment in traditional energy sectors, while also acknowledging the growing importance of renewable energy investments, a trend echoed by European oil majors going electric in recent years.

This reversal has led to confusion among investors and analysts, who are now grappling with how to navigate a rapidly changing landscape. Wall Street's newfound support for the fossil-fuel industry comes amid a backdrop of global concerns about climate change. Many investors, who had previously embraced policies aimed at curbing the effects of global warming, are now finding it harder to reconcile their environmental commitments with the shift toward fossil-fuel-heavy portfolios. The reemergence of fossil-fuel-friendly policies is forcing institutional investors to rethink their long-term strategies.

The consequences of this policy shift are also being felt by renewable energy companies, which now face increased competition for investment dollars from traditional energy sectors. The shift towards oil and gas projects has made it more challenging for renewable energy companies to attract the same level of financial backing, even as demand for clean energy continues to rise and as doubling electricity investment becomes a key policy call. This could result in a deceleration of renewable energy projects, potentially delaying the progress needed to meet the world’s climate targets.

Despite this, some analysts remain optimistic that the long-term shift toward green energy is inevitable, even if fossil-fuel investments gain a temporary boost. As the world continues to grapple with the effects of climate change, and as technological advancements in clean energy continue to reduce costs, the transition to renewables is likely to persist, regardless of the political climate.

The shift in Wall Street’s approach to energy investments, spurred by Trump’s pro-fossil fuel policies, is reshaping the $1.4 trillion global energy finance market. While the pivot towards fossil fuels may offer short-term gains, the long-term trajectory for energy markets remains firmly in the direction of renewables. The next few years will be crucial in determining whether financial institutions can balance the demand for short-term profitability with their long-term environmental responsibilities.

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Manitoba Hydro Court Ruling affirms the Public Utilities Board exceeded its jurisdiction by ordering a First Nations rate class, overturning an electricity rates appeal tied to geography, poverty, and regulatory authority in Manitoba.

Key Points

A decision holding the PUB lacked authority to create a First Nations rate class, restoring uniform electricity pricing.

✅ Court says PUB exceeded jurisdiction creating on-reserve rate

✅ Equalized electricity pricing reaffirmed across Manitoba

✅ Geography, not poverty, found decisive in unlawful rate class

Manitoba Hydro was wrongly forced to create a new rate class for electricity customers living on First Nations, the Manitoba Court of Appeal has ruled. 

The court decided the Public Utilities Board "exceeded its jurisdiction" by mandating Indigenous customers on First Nations could have a different electricity rate from other Manitobans. 

The board made the order in 2018, which exempted those customers from the general rate increase that year of 3.6 per cent.

"The directive constituted the creation and implementation of general social policy, an area outside of the PUB's jurisdiction and encroaching into areas that are better suited to the federal and provincial government," says the decision, which was released Tuesday.

Hydro's appeal of the PUB's decision went to court earlier this year.

At the time, the Crown corporation acknowledged many Indigenous people on First Nations live in poverty, but it argued the Public Utilities Board was overstepping its authority in trying to address the issue by creating a new rate class.

It also argued it was against provincial law to charge different rates in different areas of the province.

The PUB, however, insisted that legislation gives it the right to decide which factors are relevant when considering electricity prices, such as social issues. 

Special Manitoba Hydro rate class needed to offset challenges of living on First Nations, appeal court hears
Manitoba Hydro can appeal order to create special First Nation rate
The board had heard evidence that some customers were making "unacceptable" sacrifices to keep the lights on each month.

Decision 'heavy-handed': AMC
The Assembly of Manitoba Chiefs, an intervener in the appeal, had backed the utility board's position. It said on-reserve customers are disproportionately vulnerable to rate hikes over time.

Grand Chief Arlen Dumas said Wednesday he was surprised by the court's ruling. 

He argued Indigenous people are unduly excluded in the setting of electricity rates in Manitoba.

"I will be speaking with my federal and provincial counterparts on how we deal with this issue, because I think it's the wrong [decision]. It's heavy-handed and we need to address it."

The appeal court judges said there is past precedent for setting equal electricity rates, regardless of where customers live. Legislation to that effect was made in the early 2000s and a few years ago, the PUB recognized that geographical limitations should not be imposed on a class of customers.

Since the board's new order didn't extend the same savings to First Nations members who don't live on reserve but face similar financial circumstances, it is clear the deciding factor was geography, rather than poverty or treaty status, the judges said.

Manitoba Hydro temporarily cutting 200 jobs, many of them front-line workers
"In my view, the PUB erred in law when it created an on-reserve class based solely on a geographic region of the province in which customers are located," the decision read.

While Manitoba Hydro objected to the PUB's order in 2018, it still devoted money to create the new customer class.

Spokesperson Bruce Owen said the utility is still studying the impact of the court's decision, but it appreciates the ruling.  

"We all recognize that many people on First Nations have challenges, but our argument was solely on whether or not the PUB had the authority to create a special rate class based on where people live."

Owen added that Hydro recognizes electricity rates can be a hardship on individuals facing poverty. He said those considerations are part of the discussions the corporation has with the utilities board.

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TotalEnergies VSB Acquisition accelerates renewable energy growth, expanding wind and solar portfolios across Germany and Europe, advancing decarbonization, net-zero targets, and the energy transition through a US$1.65 billion strategic clean power investment.

Key Points

A US$1.65B deal: TotalEnergies acquires VSB to scale wind and solar in Europe and advance net-zero goals.

✅ US$1.65B purchase expands wind and solar pipeline

✅ Strengthens presence in Germany and wider Europe

✅ Advances net-zero, energy transition objectives

In a major move to expand its renewable energy portfolio, French energy giant TotalEnergies has announced its decision to acquire German renewable energy developer VSB for US$1.65 billion. This acquisition represents a significant step in TotalEnergies' strategy to accelerate its transition from fossil fuels to greener energy sources, aligning with the global push towards sustainability and carbon reduction, as reflected in Europe's green surge across key markets.

Strengthening TotalEnergies’ Renewable Energy Portfolio

TotalEnergies has long been one of the largest players in the global energy market, historically known for its oil and gas operations. However, in recent years, the company has made a concerted effort to diversify its portfolio and shift its focus toward renewable energy. The purchase of VSB, a leading developer of wind and solar energy projects, occurs amid rising European wind investment trends and is a clear reflection of TotalEnergies' commitment to this green energy transition.

VSB, based in Dresden, Germany, specializes in the development, construction, and operation of renewable energy projects, particularly wind and solar power. The company has a significant presence in Europe, with a growing portfolio of projects in countries like Germany, where clean energy accounts for 50% of electricity today, Poland, and the Czech Republic. The acquisition will allow TotalEnergies to bolster its renewable energy capacity, particularly in the wind and solar sectors, which are key components of its long-term sustainability goals.

By acquiring VSB, TotalEnergies is not only increasing its renewable energy output but also gaining access to a highly experienced team with a proven track record in energy project development. This move is expected to expedite TotalEnergies’ renewable energy ambitions, enabling the company to build on VSB’s strong market presence and established partnerships across Europe.

VSB’s Strategic Role in the Energy Transition

VSB’s expertise in the renewable energy sector makes it a valuable addition to TotalEnergies' green energy strategy. The company has been at the forefront of the energy transition in Europe, particularly in wind energy development, as offshore wind is set to become a $1 trillion business over the coming decades. Over the years, VSB has completed numerous large-scale wind projects, including both onshore and offshore installations.

The acquisition also positions TotalEnergies to better compete in the rapidly growing European renewable energy market, including the UK, where offshore wind is powering up alongside strong demand due to increased governmental focus on achieving net-zero emissions by 2050. Germany, in particular, has set ambitious renewable energy targets as part of its Energiewende initiative, which aims to reduce the country’s carbon emissions and increase the share of renewables in its energy mix. By acquiring VSB, TotalEnergies is not only enhancing its capabilities in Germany but also gaining a foothold in other European markets where VSB has operations.

With Europe increasingly shifting toward wind and solar power as part of its decarbonization efforts, including emerging solutions like offshore green hydrogen that complement wind buildouts, VSB’s track record of developing large-scale, sustainable energy projects provides TotalEnergies with a strong competitive edge. The acquisition will further TotalEnergies' position as a leader in the renewable energy space, especially in wind and solar power generation.

Financial and Market Implications

The US$1.65 billion deal marks TotalEnergies' largest renewable energy acquisition in recent years and underscores the growing importance of green energy investments within the company’s broader business strategy. TotalEnergies plans to use this acquisition to scale up its renewable energy assets and move closer to its target of achieving net-zero emissions by 2050. The deal also positions TotalEnergies to capitalize on the expected growth of renewable energy across Europe, particularly in countries with aggressive renewable energy targets and incentives.

The transaction is also expected to boost TotalEnergies’ presence in the global renewable energy market. As the world increasingly turns to wind, solar, and other sustainable energy sources, TotalEnergies is positioning itself to be a major player in the global energy transition. The acquisition of VSB complements TotalEnergies' previous investments in renewable energy and further aligns its portfolio with international sustainability trends.

From a financial standpoint, TotalEnergies’ purchase of VSB reflects the growing trend of large energy companies investing heavily in renewable energy. With wind and solar power becoming more economically competitive with fossil fuels, this investment is seen as a prudent long-term strategy, one that is likely to yield strong returns as demand for clean energy continues to rise.

Looking Ahead: TotalEnergies' Green Transition

TotalEnergies' acquisition of VSB is part of the company’s broader strategy to diversify its energy offerings and shift away from its traditional reliance on oil and gas. The company has already made significant strides in renewable energy, with investments in solar, wind, and battery storage projects across the globe, as developments like France's largest battery storage platform underline this momentum. The VSB acquisition will only accelerate these efforts, positioning TotalEnergies as one of the foremost leaders in the clean energy revolution.

By 2030, TotalEnergies plans to allocate more than 25% of its total capital expenditure to renewable energies and electricity. The company has already set ambitious goals to reduce its carbon footprint and shift its business model to align with the global drive toward sustainability. The integration of VSB into TotalEnergies’ portfolio signals a firm commitment to these goals, ensuring the company remains at the forefront of the energy transition.

In conclusion, TotalEnergies’ purchase of VSB for US$1.65 billion marks a significant milestone in the company’s renewable energy journey. By acquiring a company with deep expertise in wind and solar power development, TotalEnergies is taking decisive steps to strengthen its position in the renewable energy market and further its ambitions of achieving net-zero emissions by 2050. This acquisition will not only enhance the company’s growth prospects but also contribute to the ongoing global shift toward clean, sustainable energy sources.

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Muskrat Falls financial impact highlights a hydro megaproject's cost overruns, rate mitigation challenges, and inquiry findings in Newfoundland and Labrador, with power exports, Churchill River generation, and subsea cables shaping long-term viability.

Key Points

It refers to the project's burden on provincial finances, driven by cost overruns, rate hikes, and debt risks.

✅ Costs rose to $12.7B from $6.2B; inquiry cites suppressed risks.

✅ Rate mitigation needed to offset power bill shocks.

✅ Exports via subsea cables may improve long-term viability.

Newfoundland and Labrador's premier says the Muskrat Falls hydro megaproject is currently too much of a massive financial burden for him to be optimistic about its long-term potential.

"I am probably one of the most optimistic people in this room," Liberal Premier Dwight Ball told the inquiry into the project's runaway cost and scheduling issues, echoing challenges at Manitoba Hydro that have raised similar concerns.

"I believe the future is optimistic for Newfoundland Labrador, of course I do. But I'm not going to sit here today and say we have an optimistic future because of the Muskrat Falls project."

Ball, who was re-elected on May 16, has been critical of the project since he was opposition leader around the time it was sanctioned by the former Tory government.

He said Friday that despite his criticism of the Labrador dam, which has seen costs essentially double to more than $12.7 billion, he didn't set out to celebrate a failed project.

He said he still wants to see Muskrat Falls succeed someday through power sales outside the province, but there are immediate challenges -- including mitigating power-rate hikes once the dam starts providing full power and addressing winter reliability risks for households.

"We were told the project would be $6.2 billion, we're at $12.7 (billion). We were never told this project would be nearly 30 per cent of the net debt of this province just six, seven years later," the premier said.

"I wanted this to be successful, and in the long term I still want it to be successful. But we have to deal with the next 10 years."

The nearly complete dam will harness Labrador's lower Churchill River to provide electricity to the province as well as Nova Scotia and potentially beyond through subsea cables, while the legacy of Churchill Falls continues to shape regional power arrangements.

Ball's testimony wraps up a crucial phase of hearings in the extensive public inquiry.

The inquiry has heard from dozens of witnesses, with current and former politicians, bureaucrats, executives and consultants, amid debates over Quebec's electricity ambitions in the region, shedding long-demanded light on what went on behind closed doors that made the project go sideways.

Some witnesses have suggested that estimates were intentionally suppressed, and many high-ranking officials, including former premiers, have denied seeing key information about risk.

On Thursday, Ball testified to his shock when he began to understand the true financial state of the project after he was elected premier in 2015.

On Friday, Ball said he has more faith in future of the offshore oil and gas industry, and emerging options like small nuclear reactors, for example, than a mismanaged project that has put immense pressure on residents already struggling to make ends meet.

After his testimony, Ball said he takes some responsibility for a missed opportunity to mitigate methylmercury risks downstream from the dam through capping the reservoir, in parallel with debates over biomass power in electricity generation, something he had committed to doing before it is fully flooded this summer.

Still to come is a third phase of hearings on future best practices for issues like managing large-scale projects and independent electricity planning, two public feedback sessions and closing submissions from lawyers.

The final report from the inquiry is due before Dec. 31.

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