Cleaner plant emissions could up demand for high sulfur coal

By Charleston Daily Mail


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A Marshall County power plant is producing cleaner emissions, and that could mean good things for the Ohio Valley coal industry.

American Electric Power announced the complete installation of two so-called scrubbers at its Kammer-Mitchell plant. With the scrubbers installed, the plant is reducing its sulfur dioxide emissions by 98 percent.

The cleaner process could have other effects beyond reducing air pollution. High sulfur coal of the kind mined in the Ohio Valley is the best to use with the new scrubber, so AEP officials expect they'll need more coal from local mines. The plant uses about four million tons of coal every year.

Kammer-Mitchell has entered into an agreement with Consol Energy to provide more high sulfur coal for the plant.

"As plants add scrubbers, they create a new market for Ohio Valley coal mines,'' said Consol spokesman Tom Hoffman. "The scrubbers are a key part of increasing demand for coal.''

The plant also added about 55 new full-time employees to its payroll because of the scrubbers and a system for reducing emissions known as "selective catalytic reduction.''

Work on the scrubbers, technically called flue gas desulfurizarions, led to the death of a contract employee in March 2006.

Gerald Talbert, 27, died in March 2006 when the 1,000-foot tall scrubber stack caught fire while he and other workers were inside. Talbert was an employee of Pullman Power LLC, a Kansas City company working on the plant's upgrade, which was designed to bring it in line with federal emissions standards.

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Nova Scotia Power delays start of controversial new charge for solar customers

Nova Scotia Power solar charge proposes an $8/kW monthly system access fee on net metering customers, citing grid costs. UARB review, carbon credits, rate hikes, and solar industry impacts fuel political and consumer backlash.

 

Key Points

A proposed $8/kW monthly grid access fee on net metered solar customers, delayed to Feb 1, 2023, pending UARB review.

✅ $8/kW monthly system access fee on net metering

✅ Delay to Feb 1, 2023 after industry and political pushback

✅ UARB review; debate over grid costs and carbon credits

 

Nova Scotia Power has pushed back by a year the start date of a proposed new charge for customers who generate electricity and sell it back to the grid, following days of concern from the solar industry and politicians worried that it will damage the sector.

The company applied to the Nova Scotia Utility and Review Board (UARB) last week for various changes, including a "system access charge" of $8 per kilowatt monthly on net metered installations, and the province cannot order the utility to lower rates under current law. The vast majority of the province's 4,100 net metering customers are residential customers with solar power, according to the application. 

The proposed charge would have come into effect Tuesday if approved, but Nova Scotia Power said in a news release Tuesday it will change the date in its filing from Feb. 1, 2022, to Feb. 1, 2023.

"We understand that the solar industry was taken off guard," utility CEO Peter Gregg said in an interview.

"There could have been an opportunity to have more conversations in advance."

Gregg said the utility will meet with members of the solar industry over the next year to work on finding solutions that support the sector's growth, while addressing what NSP sees as an inequity in the net metering system.

NSP recognized that customers who choose solar invest a significant amount and pay for the electricity they use, but they don't pay for costs associated with accessing the electrical grid when they need energy, such as on cold winter evenings when the sun is not shining.

"I know that's hit a nerve, but it doesn't take away the fact that it is an issue," Gregg said.

He said this is an issue utilities are navigating around North America, where seasonal rate designs have sparked consumer backlash in New Brunswick, and NSP is open to hearing ideas for other models of charges or fees.

The utility's suggested system access charge closely resembles one proposed in California, which has also raised major concerns from the solar industry and been criticized by the likes of Elon Musk, and has parallels to Massachusetts solar demand charges as well.

Although the "solar profile" of Nova Scotia and California is very different, with far more solar customers in that state, and in other provinces such as Saskatchewan, NDP criticism of 8% hikes has intensified affordability debates, Gregg said the fundamental issues are the same.

For those with a typical 10-kilowatt solar system, which generates around $1,800 of electricity a year, the new charge would mean those customers would be required to pay $960 back to NSP. That would roughly double the length of time it takes for those customers to pay off their investment for the panels.

David Brushett, chair of Solar Nova Scotia, said he relayed concerns from solar installers and others in the industry to Gregg on Monday. 

Brushett said the year delay is a positive first step, but he is still calling on the province to take a strong stance against the application, which has led to customers cancelling their panel installations and companies considering layoffs.

"There's still an urgency to this situation that hasn't been addressed, and we need to kind of protect the industry," he said Tuesday.

NSP's original application proposed exempting net metering customers who enrolled before Feb. 1, 2022, from the charge for 25 years after they sign up. But any benefit would be lost if those customers sold their home, and the exemption wouldn't extend to the new buyers, said Brushett.


Carbon offsets missing from equation: industry
Brushett said NSP "completely ignored" the fact that it's getting free carbon offset credits from homeowners who use solar energy under the provincial cap and trade program.

If the net metering system continues as is, NSP has said non-solar customers would pay about $55 million between now and 2030. That number assumes about 2,000 people sign up for net metering each year over the next nine years.

When asked whether those carbon emission credits were factored into the calculations for the proposed charge, Gregg said, "I don't believe in the current structure it is, but it's something that certainly we'd be open to hearing about."

Brushett said his group is finalizing a legal response to NSP's proposal and has already filed an official complaint against the company with the UARB.


Base charge on actual electrical output: customer
At least one shareholder in NSP parent company Emera is considering selling his shares in response to the application.

Joe Hood, a shareholder from Middle Sackville, said the proposed charge won't apply to his existing 11.16-kilowatt solar system, but if it did, it would cost him $1,071 a year.

"I am offended that a company I would invest in would do this to the solar industry in Nova Scotia," he said.

According to his meter, Hood said he pushed 9,600 kilowatt hours of solar electricity to the grid last year— some only for a brief period, and all of which was used by his home by the end of the year.

Under the proposed charge, someone with one solar panel who goes away on vacation in the summer would push all their electricity to the grid, and be charged far less than someone with 10 panels who has used all their own power and hasn't pushed anything.

"Nova Scotia Power's argument is that it's an issue with the grid. Well, then it should be based on what touches the grid," Hood said.

Far from actually making the system fair for everyone, Hood said this charge places solar only in the hands of the super-rich or NSP, with projects like its community solar gardens in Amherst, N.S.


Green Party suggests legislation update
Nova Scotia's Green Party also said Tuesday that Gregg's arguments of fairness are misleading, echoing earlier premier opposition to a 14% hike on rates.

The party is calling for an update to the Electricity Act that would "prevent penalizing any activity that helps Nova Scotia reach its emissions target," aligning with calls to make the electricity system more accountable to residents.

In its application, NSP has also asked to increase electricity rates for residential customers by at least 10 per cent over the next three years, amid debate that culminated in a 14% rate hike approval by regulators. 

The company wants to maintain its nine per cent rate of return.

NSP expects to earn $153 million this year, $192 million in 2023, and $213 million in 2024 from its rate of return. 

 

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Energy Vault Secures $28M for California Green Hydrogen Microgrid

Calistoga Resiliency Centre Microgrid delivers grid resilience via green hydrogen and BESS, providing island-mode backup during PSPS events, wildfire risk, and outages, with black-start and grid-forming capabilities for reliable community power.

 

Key Points

A hybrid green hydrogen and BESS facility ensuring resilient, islanded power for Calistoga during PSPS and outages.

✅ 293 MWh capacity with 8.5 MW peak for critical backup

✅ Hybrid lithium-ion BESS plus green hydrogen fuel cells

✅ Island mode with black-start and grid-forming support

 

Energy Vault, a prominent energy storage and technology company known for its gravity storage, recently secured US$28 million in project financing for its innovative Calistoga Resiliency Centre (CRC) in California. This funding will enable the development of a microgrid powered by a unique combination of green hydrogen and battery energy storage systems (BESS), marking a significant step forward in enhancing grid resilience in the face of natural disasters such as wildfires.

Located in California's fire-prone regions, the CRC is designed to provide critical backup power during Public Safety Power Shutoff (PSPS) events—periods when utility companies proactively cut power to prevent wildfires. These events can leave communities without electricity for extended periods, making the need for reliable, independent power sources more urgent as many utilities see benefits in energy storage today. The CRC, with a capacity of 293 MWh and a peak output of 8.5 MW, will ensure that the Calistoga community maintains power even when the grid is disconnected.

The CRC features an integrated hybrid system that combines lithium-ion batteries and green hydrogen fuel cells, even as some grid-scale projects adopt vanadium flow batteries for long-duration needs. During a PSPS event or other grid outages, the system will operate in "island mode," using hydrogen to generate electricity. This setup not only guarantees power supply but also contributes to grid stability by supporting black-start and grid-forming functions. Energy Vault's proprietary B-VAULT DC battery technology complements the hydrogen fuel cells, enhancing the overall performance and resilience of the microgrid.

One of the key aspects of the CRC project is the utilization of green hydrogen. Unlike traditional hydrogen, which is often produced using fossil fuels, green hydrogen is generated through renewable energy sources like solar or wind power, with large-scale initiatives such as British Columbia hydrogen project accelerating supply, making it a cleaner and more sustainable alternative. This aligns with California’s ambitious clean energy goals and is expected to reduce the carbon footprint of the region’s energy infrastructure.

The CRC project also sets a precedent for future hybrid microgrid deployments across California and other wildfire-prone areas, with utilities like SDG&E Emerald Storage highlighting growing adoption. Energy Vault has positioned the CRC as a model for scalable, utility-scale microgrids that can be adapted to various locations facing similar challenges. Following the success of this project, Energy Vault is expanding its portfolio with additional projects in Texas, where it anticipates securing up to US$25 million in financing.

The funding for the CRC also includes the sale of an investment tax credit (ITC), a key component of the financing structure that helps make such ambitious projects financially viable. This structure is crucial as it allows companies to leverage government incentives to offset development costs, including CEC long-duration storage funding, thus encouraging further investment in green energy infrastructure.

Despite some skepticism regarding the transportation of hydrogen rather than producing it onsite, the project has garnered strong support. California’s Public Utilities Commission (CPUC) acknowledged the potential risks of transporting green hydrogen but emphasized that it is still preferable to using more harmful fuel sources. This recognition is important as it validates Energy Vault’s approach to using hydrogen as part of a broader strategy to transition to clean, reliable energy solutions.

Energy Vault's shift from its traditional gravity-based energy storage systems to battery energy storage systems, such as BESS in New York, reflects the company's adaptation to the growing demand for versatile, efficient energy solutions. The hybrid approach of combining BESS with green hydrogen represents an innovative way to address the challenges of energy storage, especially in regions vulnerable to natural disasters and power outages.

As the CRC nears mechanical completion and aims for full commercial operations by Q2 2025, it is poised to become a critical part of California’s grid resilience strategy. The microgrid's ability to function autonomously during emergencies will provide invaluable benefits not only to Calistoga but also to other communities that may face similar grid disruptions in the future.

Energy Vault’s US$28 million financing for the Calistoga Resiliency Centre marks a significant milestone in the development of hybrid microgrids that combine the power of green hydrogen and battery energy storage. This project exemplifies the future of energy resilience, showcasing a forward-thinking approach to mitigating the impact of natural disasters and ensuring a reliable, sustainable energy future for communities at risk. With its innovative use of renewable energy sources and cutting-edge technology, the CRC sets a strong example for future energy storage projects worldwide.

 

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European Power Hits Records as Plants Start to Buckle in Heat

European Power Crisis intensifies as record electricity prices, nuclear output cuts, gas supply strain, heatwave drought, and Rhine shipping bottlenecks hit Germany, France, and Switzerland, tightening winter storage and driving long-term contracts higher.

 

Key Points

A surge in European power prices from heatwaves, nuclear curbs, Rhine coal limits, and reduced Russian gas supply.

✅ Record year-ahead prices in Germany and France

✅ Nuclear output curbed by warm river cooling limits

✅ Rhine low water disrupts coal logistics and generation

 

Benchmark power prices in Europe hit fresh records Friday as utilities are increasingly reducing electricity output in western Europe because of the hot weather. 

Next-year contracts in Germany and France, Europe’s biggest economies rose to new highs after Switzerland’s Axpo Holding AG announced curbs at one of its nuclear plants. Electricite de France SA is also reducing nuclear output because of high river temperatures and cooling water restrictions, while Uniper SE in Germany is struggling to get enough coal up the river Rhine. 

Europe is suffering its worst energy crunch in decades, and losing nuclear power is compounding the strain as gas cuts made by Russia in retaliation for sanctions drive a surge in prices. The extreme heat led to the driest July on record in France and is underscoring the impact that a warming climate is having on vital infrastructure.

Water levels on Germany’s Rhine have fallen so low that the river may effectively close soon, impacting supplies of coal to the plants next to it. The Rhone and Garonne in France and the Aare in Switzerland are all too warm to be used to cool nuclear plants effectively, forcing operators to limit energy output under environmental constraints. 

Northwest European weather forecast for the next two weeks:
relates to European Power Hits Records as Plants Start to Buckle in Heat
  
The German year-ahead contract gained as much as 2% to 413 euros a megawatt-hour on the European Energy Exchange AG. The French equivalent rose 1.9% to a record 535 euros. Long-term prices are coming under pressure because producing less power from nuclear and coal will increase the demand for natural gas, which is badly needed to fill storage sites ahead of the winter.  


France to Curb Nuclear Output as Europe’s Energy Crisis Worsens
Uniper SE said on Thursday that two of its coal-fired stations along the Rhine may need to curb output during the next few weeks as transporting coal along the Rhine becomes impossible. 

Plants on the river near Mannheim and Karlsruhe, operated by Grosskraftwerk Mannheim AG and EnBW AG, have previously struggled to source coal because of the shallow water, even as German renewables deliver more electricity than coal and nuclear at times. Both companies said generation hasn’t been affected yet. 

“The low tide is not currently affecting our generation of energy because our plants do not have the need for continuous fresh water,” a Steag GmbH spokesman said on Friday. “But the low tide level can make running plants and transporting coal more complicated than usual.”

The spokesman said though that there is slight reduction in output of about 10 to 15 megawatts, which would equate to a few percent, because of the hot temperatures. “This has been happening over some time now and is a problem for everyone because the plant system is not designed to withstand such hot temperatures,” he said.

 

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N.L., Ottawa agree to shield ratepayers from Muskrat Falls cost overruns

Muskrat Falls Financing Restructuring redirects megadam benefits to ratepayers, stabilizes electricity rates, and overhauls federal provincial loan guarantees for the hydro project, addressing cost overruns flagged by the Public Utilities Board in Newfoundland and Labrador.

 

Key Points

A revised funding model shifting benefits to ratepayers to curb rate hikes linked to Muskrat Falls cost overruns.

✅ Shields ratepayers from megadam cost overruns

✅ Revises federal provincial loan guarantees

✅ Targets stable electricity rates by 2021 and beyond

 

Ottawa and Newfoundland and Labrador say they will rewrite the financial structure of the Muskrat Falls hydro project to shield ratepayers from paying for the megadam's cost overruns.

Federal Natural Resources Minister Seamus O'Regan and Premier Dwight Ball announced Monday that their two governments would scrap the financial structure agreed upon in past federal-provincial loan agreements, moving to a model that redirects benefits, such as a lump sum credit, to ratepayers.

Both politicians called the announcement, which was light on dollar figures, a major milestone in easing residents' fears that electricity rates will spike sharply, as seen with Nova Scotia's debated 14% hike, when the over-budget dam comes fully online next year.
"We are in a far better place today thanks to this comprehensive plan," Ball said.

Ball has said the issue of electricity rates is a top priority for his government, and he has pledged to keep rates near existing levels, but rate mitigation talks with Ottawa have dragged on since April.

A report by the province's Public Utilities Board released Friday forecast an "unprecedented" 75 per cent increase in average domestic rates for island residents in 2021, while Nova Scotia's regulator approved a 14% hike, and reported concerns from industrial customers about their ability to remain competitive.

Costs of the Muskrat Falls megadam on Labrador's Lower Churchill River have ballooned to more than $12.7 billion since the project was approved in 2012, according to the latest estimate of Crown corporation Nalcor Energy.

The dam is set to produce more power than the province can sell. Its existing financial structure would have left electricity ratepayers paying for Muskrat Falls to make up the difference starting in 2021, an issue both governments said Monday has been resolved with the relaunch of financing talks.

"Essentially, you won't pay this on your monthly light bills," Ball said.

But details of how the project will meet financing requirements in coming decades to make up the gap in funds are still to be worked out.

Both Ball and O'Regan criticized previous governments for sanctioning the poorly planned development and again pledged their commitment to easing the burden on residents.

"We promised we would be there to help, and we will be," O'Regan said before announcing a "relaunch" of negotiations around the project's financial structure.

He did not say how much the new setup might cost the federal government, despite earlier federal funding commitments, stressing that the new focus will be on the project's long-term sustainability. "There's no single piece of policy ... that can resolve such a large and complicated mess," O'Regan said.

The two governments also said they will work towards electrifying federal buildings to reduce an anticipated power surplus in the province.

In the short term, the federal government said it would allow for "flexibility" in upcoming cash requirements related to debt servicing, allowing deferral of payments if necessary.

Ball said that flexibility was built in to ensure the plan would still be applicable if costs continue to rise before Muskrat Falls is commissioned.

Political opponents criticized Monday's plan as lacking detail.

"What I heard talked about was an agreement that in the future, there's going to be an agreement," said Progressive Conservative Leader Ches Crosbie. "This was an occasion to reassure people that there's a plan in place to make life here affordable, and I didn't see that happen today."

Others addressed the lingering questions about the project's final cost.

Nalcor's latest financial update has remained unchanged since 2017, though the Muskrat Falls project has seen additional delays related to staffing and software issues.

Dennis Browne, the province's consumer advocate, said the switch to a cost of service model is a significant move that will benefit ratepayers, but he said it's impossible to truly restructure the project while it's a work in progress. "We need to know what the figures are, and we don't have them," he said.

 

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Seattle City Light's Initiative Helps Over 93,000 Customers Reduce Electricity Bills

Seattle City Light Energy Efficiency Programs help 93,000 residents cut bills with rebates, home energy audits, weatherization, conservation workshops, and sustainability tools, reducing electricity use and greenhouse gas emissions across Seattle communities.

 

Key Points

They are utility programs that lower electricity use and bills via rebates, energy audits, and weatherization services.

✅ Rebates for ENERGY STAR appliances and efficient HVAC upgrades

✅ Free audits with tailored recommendations and savings roadmaps

✅ Weatherization aid for low-income households and renters

 

In a noteworthy achievement for both residents and the environment, Seattle City Light has successfully helped more than 93,000 customers reduce their electricity bills through various energy efficiency programs. This initiative not only alleviates financial burdens for many households, amid concerns about pandemic-era shut-offs that heightened energy insecurity, but also aligns with the city’s commitment to sustainability and responsible energy use.

The Drive for Energy Efficiency

Seattle City Light, the city’s publicly owned electric utility, has been at the forefront of promoting energy efficiency among its customers. Recognizing that energy costs can strain household budgets, the utility has developed a range of programs and tracks emerging utility rate designs to help residents lower their energy consumption and, consequently, their bills.

One of the main aspects of this initiative is the emphasis on education and awareness. By providing customers with tools and resources to understand their energy usage, City Light empowers residents to make informed choices that can lead to substantial savings and prepare for power outage events as well.

Key Programs and Services

Seattle City Light offers a variety of programs aimed at reducing energy consumption. Among the most popular are:

  1. Energy Efficiency Rebates: Customers can receive rebates for purchasing energy-efficient appliances, such as refrigerators, washing machines, and HVAC systems. These appliances are designed to consume less electricity than traditional models, resulting in lower energy bills over time.

  2. Home Energy Audits: Free energy audits are available for residential customers. During these audits, trained professionals assess homes for energy efficiency and provide recommendations on improvements. This personalized service allows homeowners to understand specific changes that can lead to savings.

  3. Weatherization Assistance: This program is particularly beneficial for low-income households. By improving insulation, sealing air leaks, and enhancing overall energy efficiency, residents can maintain comfortable indoor temperatures without over-relying on heating and cooling systems.

  4. Community Workshops: Seattle City Light conducts workshops that educate residents about energy conservation strategies. These sessions cover topics such as smart energy use, seasonal tips for reducing consumption, and the benefits of renewable energy sources, highlighting examples of clean energy engagement in other cities.

The Impact on Households

The impact of these initiatives is profound. By assisting over 93,000 customers in lowering their electricity bills, Seattle City Light not only provides immediate financial relief but also encourages a long-term commitment to energy conservation. This collective effort has resulted in significant reductions in overall energy consumption, contributing to a decrease in greenhouse gas emissions—a critical step in the fight against climate change.

Additionally, the programs have been particularly beneficial for low-income households. By targeting these communities, Seattle City Light ensures that the benefits of energy efficiency reach those who need them the most, promoting equity-focused regulation and access to essential resources.

Looking Ahead: Challenges and Opportunities

While the success of these initiatives is commendable, challenges remain. Fluctuating energy prices can still pose difficulties for many households, especially those on fixed incomes, as some utilities explore minimum charges for low-usage customers in their rate structures. Seattle City Light recognizes the need for ongoing support and resources to help residents navigate these financial challenges.

The utility is committed to expanding its programs to reach even more customers in the future. This includes enhancing outreach efforts to ensure that residents are aware of the available resources, even as debates like utility revenue in a free-electricity future shape planning, and potentially forming partnerships with local organizations to broaden the impact of its initiatives.

 

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Portsmouth residents voice concerns over noise, flicker generated by turbine

Portsmouth Wind Turbine Complaints highlight noise, shadow flicker, resident impacts, Town Council hearings, and Green Development mitigation plans near Portsmouth High School, covering renewable energy output, PPAs, and community compliance.

 

Key Points

Resident reports of noise and shadow flicker near Portsmouth High School, prompting review and mitigation efforts.

✅ Noise exceeds ambient levels seasonally, residents report fatigue.

✅ Shadow flicker lasts up to 90 minutes on affected homes.

✅ Town tasks developer to meet neighbors and propose mitigation.

 

The combination of the noise and shadows generated by the town’s wind turbine has rankled some neighbors who voiced their frustration to the Town Council during its meeting Monday.

Mark DePasquale, the founder and chairman of the company that owns the turbine, tried to reassure them with promises to address the bothersome conditions.

David Souza, a lifelong town resident who lives on Lowell Drive, showed videos of the repeated, flashing shadows cast on his home by the three blades spinning.

“I am a firefighter. I need to get my sleep,” he said. “And now it’s starting to affect my job. I’m tired.”

Town Council President Keith Hamilton tasked DePasquale with meeting with the neighbors and returning with an update in a month. “What I do need you to do, Mr. DePasquale, is to follow through with all these people.”

DePasquale said he was unaware of the flurry of complaints lodged by the residents Monday. His company had only heard of one complaint. “If I knew there was an issue before tonight, we would have responded,” he said.

His company, Green Development LLC, formerly Wind Energy Development LLC, installed the 279-foot-tall turbine near Portsmouth High School that started running in August 2016, as offshore developers like Deepwater Wind in Massachusetts plan major construction nearby. It replaced another turbine installed by a separate company that broke down in 2012.

In November 2014, the town signed an agreement with Wind Energy Development to take down the existing turbine, pay off the remaining $1.45 million of the bond the town took out to install it and put up a new turbine, amid broader legal debates like the Cornwall wind farm ruling that can affect project timelines.

In exchange, Wind Energy Development sells a portion of the energy generated by the turbine to the town at a rate of 15.5 cents per kilowatt hour for 25 years. Some of the energy generated is sold to the town of Coventry.

“We took down (the old turbine) and paid off the debt,” DePasquale said, noting that cancellations can carry high costs as seen in Ontario wind project penalties for scrapping projects. “I have no problem doing whatever the council wants … There was an economic decision made to pay off the bond and build something better.”

The turbine was on pace to produce 4 million-plus kilowatt hours per year, Michelle Carpenter, the chief operating officer of Wind Energy Development, said last April. It generates enough energy to power all municipal and school buildings in town, she said, while places like Summerside’s wind power show similarly strong output.

The constant stream of shadows cast on certain homes in the area can last for as long as an hour-and-a-half, according to Souza. “We shouldn’t have to put up with this,” he said.

Sprague Street resident John Vegas said the turbine’s noise, especially in late August, is louder than the neighborhood’s ambient noise.

“Throughout the summer, there’s almost no flicker, but this time of year it’s very prominent,” Vegas added. “It can be every day.”

He mentioned neighbors needed to be better organized to get results.

“When the residents purchased our properties we did not have this wind turbine in our backyard,” Souza said in a memo. “Due to the wind turbine … our quality of life has suffered.”

After the discussion, the council unanimously voted to allow Green Development to sublease excess energy to the Rhode Island Convention Center Authority, a similar agreement to the one the company struck with Coventry, as regional New England solar growth adds pressure on grid upgrade planning.

“This has to be a sustainable solution,” DePasquale said. “We will work together with the town on a solution.”

 

 

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