# Prescription method memo: basin two (the St. Lawrence River Basin, Québec) **Date:** 2026-07-29. **Seat:** Fable (wave builder seat). **Status: PROPOSED, NOT RATIFIED.** No value reaches the registry until the operator ratifies this memo (wave contract gate, unchanged). Method authority: the wave contract as amended, and the basin one memo (`PRESCRIPTION_METHOD_MEMO_2026-07-29.md`), whose ratified parameterization (X=12, K=5, N=3, cadence 8y, the waterless-exclusion rule, the S table) this memo REUSES rather than re-argues. Instrument list: confirmed by the operator 2026-07-29 (`docs/AQUADRIO_BASIN_TWO_INSTRUMENT_BRIEF_2026-07-29.md`), plus the operator-instructed rating-methodology item (§3.6). **The one-sentence result.** Québec's regime, like Michigan's, ratifies triggers, prohibitions, and prices, never a numeric consumptive-use ceiling, so the TRANSLATED operand is honestly absent; the DIAL operand is proposed at **0.30 L/kWh (strict-under)** via the ratified method with the climate-band translation documented; and the basin's boundary translates the regime's OWN statutory map rather than any line of ours. **Evidentiary posture, per leg.** Translated leg: absent; the instruments are documented in §3 from the official consolidated text (legisquebec.gouv.qc.ca, "Ce document a valeur officielle", current to 2026-04-01), read directly this session. Dial leg: documented to the five factors in the basin one memo §5; the additional exposure here is the climate-band translation (§2), stated as its own step. **The US evidentiary frame does not travel:** Québec is a civil-law jurisdiction; the Daubert/judicial-notice analysis has no automatic analog and the Québec expert-evidence posture is counsel's question [OPEN], flagged once and blocking nothing (operator, 2026-07-29). Basin-two surface copy follows the hydro-water defense memo's §7 say/never-say discipline (SOW, WP-5 row). --- ## 1. The map: the regime's own ratified boundary EQA §31.89 (verbatim, official text): "'St. Lawrence River Basin' or 'Basin' means the part of Québec in which all waters flow towards the St. Lawrence River upstream from Trois-Rivières, excluding the Saint-Maurice river watershed and the Bécancour river, and which is described on the map shown in Schedule 0.A and any other paper or electronic map the Minister may prepare to determine its boundaries more precisely." Ministerial maps publish in the Gazette officielle; the electronic layer is the open-data "Territory of the Agreement" dataset. **Proposal: basin two IS the statutory Basin**, boundaries translated from Schedule 0.A and the ministerial maps, never drawn by us. This is the posture applied to cartography, and it is stronger here than in basin one: Michigan's HUC8s are a federal survey convention; Québec's Basin is a line the regime itself ratified in statute. - **Identifier: the registry's `BasinId` is HUC-shaped (digits) and cannot carry this.** Proposed accommodation, one line at WP-3: a jurisdictional basin id form (proposal: `QC-SLRB` at a declared level `statute`), refused by the current schema until the operator ratifies the form. Flagged in the instrument brief; now concrete. - The statutory Basin is narrower than "everything draining the St. Lawrence" (it stops upstream of Trois-Rivières and excludes two named watersheds). We inherit that scope exactly; a facility below Trois-Rivières is simply outside basin two, by the regime's own line. ## 2. The descriptive layer: adjacent-band translation, documented Neither anchor dataset reaches Québec: LBNL simulates 965 US TMY stations; the Ren dataset carries no Canadian city, so under the named-lineage rule Ren contributes nothing here (it was corroboration-only in basin one anyway). The contract's small-N clause covers exactly this: **widen to the adjacent climate band with the translation documented.** - The adjacent band is basin one's (Detroit; the nearest LBNL-modeled band to the St. Lawrence corridor). The demonstrated-configuration set and the best demonstrated water-using configuration (airside economizer + adiabatic cooling, operator-reported 0.1 to 0.3 L/kWh, LBNL 2024 p. 47) carry over. - **The translation's direction is stated:** the St. Lawrence corridor is colder than Detroit (more free-cooling hours, more economizer coverage), so a configuration that demonstrates 0.1 to 0.3 in Detroit's band demonstrates at or below that range here. Holding P at the band's top (0.30) is therefore conservative in the achievability direction: the ceiling is easier to beat in this climate, never harder. A ceiling that is too loose fails no honest facility; a ceiling set below demonstrated achievability would be the indefensible direction, and this translation cannot produce it. - C(b) unchanged: at 3 metered facilities in this band, measurement replaces the model and the translation retires. ## 3. The normative layer, from the official text ### 3.1 The Agreement, implemented in statute EQA §31.88 (verbatim): the subdivision "ensure[s] the implementation in Québec of the Great Lakes-St. Lawrence River Basin Sustainable Water Resources Agreement" (2005-12-13; Québec, Ontario, and the eight US states), construed consistently with the Agreement. §31.89 defines consumptive use identically to the Compact frame: "that portion of water withdrawn or impounded from the St. Lawrence River Basin that is lost or otherwise not returned to the Basin due to evaporation, incorporation into a product, or other processes." ### 3.2 The authorization trigger EQA §31.75(1): withdrawals below "a maximum flow rate of less than 75,000 litres per day" are exempt from prior ministerial authorization (s. 22 scheme); at or above it, authorization is required. RPEP (Q-2, r. 35.2) §3 sets the averaging convention (90 consecutive days constituting the maximum withdrawal period) and §11 places the same 75,000 L/day line for facility standards. **A trigger, not a ceiling**: lawful operation above it proceeds under authorization. ### 3.3 The transfer-out prohibition and the review threshold EQA §31.90 (verbatim): "No water withdrawn from the St. Lawrence River Basin may be transferred out of the Basin," with grandfathering (pre-2011-09-01) and four exceptions (water packaged in the Basin in containers of 20 litres or less; water used within the Basin in manufacture, preservation or processing; vehicle supply; humanitarian and emergency). §31.91 permits straddling- municipality waterworks transfers with return-to-Basin. §31.92: transfers of **379,000 litres or more per day average** (the Agreement's 100,000 GPD, metricized) face regional-body review and strict conditions (avoidance through conservation first). **A prohibition and a review trigger; still not an intensity ceiling on consumptive use inside the Basin.** Also noted from §31.74: works for impounding and hydroelectric production are excluded from the statutory definition of "withdrawal" (with limited carve-ins). The regime itself declines to treat hydro reservoir operation as a withdrawal, which is context for the hydro-water discussion but changes nothing here: our indirect-water factor table is our own instrument, uniform on every grid, and this memo's prescription concerns facility site water only. ### 3.4 The royalty: a price, documented, never translated The water royalty regulation (rates effective 2024-01-01, first increase since 2010): base rate $35 per million litres (from $2.50); **$150 per million litres where water is incorporated into a product** (from $70); an additional $350 per million litres for bottled water; 3% annual escalation; and the liability threshold moving to a 50,000 L/day maximum-daily basis effective 2026-01-01. Source: Gazette officielle 2023 (publicationsduquebec, encrypted Gazette PDF; rates corroborated by multiple secondary reports) [PRIMARY-CITE PENDING: page-cite from the Gazette text at ratification]. The tiered rate is the regime's own consumptive-use distinction, stated in price. **Aquadrio counts, never prices**: the royalty enters as documented evidence that Québec's regime differentiates consumptive incorporation from pass-through use, and translates to no ceiling. ### 3.5 The finding: no ratified numeric consumptive-use ceiling Every ratified number in §3.1-3.4 is a trigger (75,000 L/day authorization; 379,000 L/day transfer review; 50,000 L/day royalty liability), a prohibition (transfer-out), or a price ($35/$150/$350 per ML). None is a ceiling on a facility's consumptive use inside the Basin. **Translated operand: ABSENT. No allocation basis needed.** Same structure as basin one, reached on a different sovereign's instruments. ### 3.6 The rating-methodology instrument (operator instruction, 2026-07-29) The Canadian analog of S&P's "Data Center Securitizations: Global Methodology And Assumptions" exists: **Morningstar DBRS, "Rating and Monitoring Data Center Transactions"** (updated November 2025; DBRS is the Canadian ratings seat). Role here: external methodology evidence that the capital-markets layer rates data center assets under published, versioned criteria, the same layer /who-its-for described pricing risk. It enters as documented context for general acceptance, never as a limit to translate and never as pricing by us. [OPEN]: the document body sits behind DBRS's portal; full-text read and any water/utility-risk criteria extraction pending access. ### 3.7 Stress: S = 1.00 No Québec statutory or Agreement-based water-quantity stress designation for the Basin was found; the Canada-Québec St. Lawrence Action Plan is ecosystem programming, not a quantity classification. Same refusal as basin one: no cross-domain mapping, S = 1.00, documented context only. WRI Aqueduct remains the named fallback screen, unneeded where no classification question is posed. ## 4. The first derivation, worked > Aquadrio prescribes a direct water ceiling of **0.30 L/kWh (strict-under)** > [PROPOSED] for **the St. Lawrence River Basin as defined by EQA §31.89 and > Schedule 0.A (Québec's statutory Basin map)**, effective **on ratification**, > version **1**, because: (1) efficient facilities in the adjacent demonstrated > climate band run **0.1 to 0.3 L/kWh** (LBNL 2024 p. 47, operator-reported, > best demonstrated water-using configuration), and the colder St. Lawrence > corridor can only improve on that band (§2, the translation's direction); > (2) the basin's quantity-stress posture is **unclassified**, so S = 1.00; > (3) the ratified derivation rule maps (1) and (2) to 0.30 x 1.00 = **0.30**. > > The basin's governing regime ratifies **no numeric consumptive-use ceiling** > (§3.5): it gates by authorization at 75,000 L/day, prohibits transfer out of > the Basin, reviews transfers at 379,000 L/day, and prices consumptive > incorporation at a premium royalty rate. The record states this in place of > a translated operand. Registry entry shape: as basin one's, dial-only, `derivation_ref` this memo, `basin` pending the identifier-form ratification (§1). ## 5. Inputs (the C(a) watch list) | Input | Vintage | Supersession consequence | |---|---|---| | EQA Q-2 §§31.74-31.93 (official consolidated) | current to 2026-04-01, read 2026-07-29 | amendment re-derives §3 | | RPEP Q-2, r. 35.2 | current to 2026-04-01 | amendment re-derives §3.2 | | Royalty regulation (2023 amendment) | rates in force 2024-01-01; threshold change 2026-01-01 | **a numeric cap would add the translated operand (armed)** | | Schedule 0.A + ministerial Basin maps | statutory; electronic layer on open.canada.ca | boundary revision re-maps the basin | | LBNL-2001637 | Dec 2024 | new water figures re-derive P (shared with basin one) | | Morningstar DBRS data center methodology | Nov 2025 update | full-text read closes §3.6's [OPEN] | ## 6. [OPEN], honestly listed 1. Ratify: the statutory-Basin boundary proposal and the `BasinId` accommodation form (§1); the adjacent-band translation (§2); dial 0.30; S = 1.00. 2. Québec evidentiary frame: counsel's question, outstanding, blocking nothing (operator, 2026-07-29). 3. Gazette page-cite for the royalty rates (primary text is an encrypted Gazette PDF; cite-at-ratification). 4. DBRS methodology full-text read (§3.6). 5. Hydro-Québec lease/flow instruments: context inventory not attempted this pass; add before any HQ-facility grading, not before ratification. 6. Basin-two surfaces: buildable on ratification; copy follows the hydro-water defense memo's §7 discipline (structural, in the SOW). ## 7. Sources - EQA (chapter Q-2), official consolidated English text, legisquebec.gouv.qc.ca, read in-browser 2026-07-29: §§31.74, 31.75, 31.88-31.92 quoted verbatim. - RPEP (chapter Q-2, r. 35.2), same source, current to 2026-04-01: §§1, 3, 11. - SQ 2009, c. 21 (the implementing act; section history lines in the EQA text). - Gazette officielle du Québec 2023, royalty amendment (publicationsduquebec PDF 106209); secondary corroboration: CBC, Global News, esemag (2023-2024). - Morningstar DBRS, "Rating and Monitoring Data Center Transactions" (dbrs.morningstar.com research/470694; update press release research/466909). - Open Government Canada, "Territory of the Agreement on Sustainable Water Resources in the Great Lakes and St. Lawrence River Basin in Quebec" (the Basin's electronic map layer). - LBNL-2001637 (shared descriptive anchor; basin one memo §2.1).