Alcoa said the decision to close out the contracts does not affect Alcoa's ... ability to operate the smelter or secure electricity supply to the smelter.

Alcoa's Portland smelter is losing money and risks closure.

In 2014, Alcoa closed the Point Henry smelter which led to the closure last year of the Anglesea power plant.

And there could be additional knock on effects since the smelter consumes around 10 per cent of Victoria's entire electricity output.

AGL expects the Portland facility to continue to operate, meaning physical demand for electricity from the smelter will continue, it said.

Trail Smelter Arbitration. United States v. Canada, Reports of International Arbitral Awards, vol. 3 (1941), p. 1911 et seq., at p. 1920.

Analysts have been wary of the possible closure of both of the Portland smelter in Victoria and also the Tomago plant near Newcastle due to the poor economics of the industry.

AGL, which supplies the big aluminium smelter with electricity from its Loy Yang A power plant in the Latrobe Valley, said it expects the other three owners will also move to terminate their agreements.

The future of the Portland aluminium smelter in Victoria and the jobs of hundreds of workers is in doubt with the power company which supplies the plant disclosing one of the plant's owners is to terminate a supply contract, with all supply contracts expected to be axed.

In the first place, although the commentary referred to the general pronouncements on future damage in the Trail Smelter case, it did not mention that the arbitral tribunal had awarded compensation with regard to cleared land and uncleared land without taking such a threshold into account.

The first of the three projects is being developed by Société Le Nickel (the New Caledonian affiliate of the French State owned company Eramet), which is investing between 140 million and 190 million in its Doniambo smelter to boost production from 60,000 to 75,000 tons per year.

As the Tribunal in the Trail Smelter Arbitration stated in its interim award Where the wrongful act itself is of such a nature as to preclude the ascertainment of the amount of damages with certainty, it would be a perversion of fundamental principles of justice to deny all relief to the injured person, and thereby relieve the wrongdoer from making any amend for his acts.