Malcolm Watson Named Chair of NAED'S 2008 Centennial Celebration Committee

Coal-to-Clean Energy Hubs leverage Bipartisan Infrastructure Law and Inflation Reduction Act funding to repurpose mine lands with microgrids, advanced nuclear, carbon capture, and rare earth processing, boosting energy security, jobs, and grid modernization.

Key Points

They are federal projects converting coal communities and mine lands into clean energy hubs, repurposing infrastructure.

✅ DOE demos on mine lands: microgrids, nuclear, carbon capture.

✅ Funding from BIL, CHIPS and IRA targets energy communities.

✅ Rare earths from coal waste bolster EV supply chains.

The Biden administration is channeling hundreds of millions of dollars in clean energy funding from recent legislation into its efforts to turn coal communities into clean energy hubs, the White House said.

The administration gave an update on its push across agencies to kick-start projects nationwide with funding Congress approved during Biden’s first two years in office. The effort includes $450 million from the Bipartisan Infrastructure Law that the Department of Energy will allocate to an array of new clean energy demonstration projects on former mine lands.

“These projects could focus on a range of technologies from microgrids to advanced nuclear to power plans with carbon capture,” Energy Secretary Jennifer Granholm said on a call with reporters Monday. “They’ll prove out the potential to reactivate or repurpose existing infrastructure like transmission lines and substations across an aging U.S. power grid, and these projects could spur new economic development in these communities.”

Among the projects the White House highlighted, it said $16 million from the infrastructure law will go to the University of North Dakota and West Virginia University to create design studies for the first-ever full-scale refinery facility in the U.S. that could extract and separate rare earth elements and minerals from coal mine waste streams. The materials are critical for electric vehicle-battery components that are currently heavily sourced from outside the U.S.

“Those efforts will pave the way toward building a first of its kind facility that produces essential materials for solar panels, wind turbines, EVs and more while cleaning up polluted land and water and creating good-paying jobs for local workers,” Granholm said.

Biden created an interagency working group focused on revitalizing coal-power communities through federal investments when he took office. In 2021, the group selected 25 priority areas ranging from West Virginia to Wyoming to focus on development, as high natural gas prices strengthened the case for clean electricity. There are nearly 18,000 identified mine sites across 1.5 million acres in the United States, according to the White House.

The massive effort fits into a broader Biden administration push to both fight climate change and support communities that have lost economic activity during a transition away from fossil fuel sources such as coal. While Biden’s most ambitious clean energy plans fell flat in Congress in the face of opposition from Republicans and some Democrats after the previous administration’s power plant overhaul, three major laws still unlocked funding for his administration to deploy.

Many of the initiatives are made possible through the Bipartisan Infrastructure Law, Chips and Science Act and the Inflation Reduction Act, even without a clean electricity standard on the books. The task force aims to make sure communities most affected by the changing energy landscape are taking maximum advantage of the federal benefits.

“Those new and expanded operations are coming to energy communities and creating good paying jobs,” Biden’s senior advisor for clean energy innovation and implementation John Podesta said on the call. “These laws can provide substantial federal support to energy communities like capping abandoned oil and gas wells, extracting critical minerals, building battery factories and launching demonstration projects in carbon capture or green hydrogen.”

The administration touted the potential benefits of the Inflation Reduction Act, a bill passed by Democrats to spur clean energy investments last year, even as early assessments show mixed results to date. At the time, U.S. consumers were dealing with decades-high inflation fueled in part by an energy crisis and high gas prices that drove debate — a point Republicans emphasized as the plan moved through Congress.

Deputy Treasury Secretary Wally Adeyemo said the Inflation Reduction Act aims to both “lower the deficit, as well as promote our energy security, lowering energy costs for consumers and combatting climate change.”

“As the Treasury works to implement the law, we’re focused on ensuring that all Americans benefit from the growth of the clean energy economy, particularly those who live in communities that have been dependent on the energy sector for job for a long time,” Adeyemo told reporters. “Economic growth and productivity are higher when all communities are able to reach their full potential.”

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BC Hydro Electricity Imports shape CleanBC claims as Powerex trades cross-border electricity, blending hydro with coal and gas supplies, affecting emissions, grid carbon intensity, and how electric vehicles and households assess "clean" power.

Key Points

Powerex buys power for BC Hydro, mixing hydro with coal and gas, shifting emissions and affecting CleanBC targets.

✅ Powerex trades optimize price, not carbon intensity

✅ Imports can include coal- and gas-fired generation

✅ Emissions affect EV and CleanBC decarbonization claims

British Columbians naturally assume they’re using clean power when they fire up holiday lights, juice up a cell phone or plug in a shiny new electric car. 

That’s the message conveyed in advertisements for the CleanBC initiative launched by the NDP government, amid indications that residents are split on going nuclear according to a survey, which has spent $3.17 million on a CleanBC “information campaign,” including almost $570,000 for focus group testing and telephone town halls, according to the B.C. finance ministry.

“We’ll reduce air pollution by shifting to clean B.C. energy,” say the CleanBC ads, which feature scenic photos of hydro reservoirs. “CleanBC: Our Nature. Our Power. Our Future.” 

Yet despite all the bumph, British Columbians have no way of knowing if the electricity they use comes from a coal-fired plant in Alberta or Wyoming, a nuclear plant in Washington, a gas-fired plant in California or a hydro dam in B.C. 

Here’s why. 

BC Hydro’s wholly-owned corporate subsidiary, Powerex Corp., exports B.C. power when prices are high and imports power from other jurisdictions when prices are low. 

In 2018, for instance, B.C. imported more electricity than it exported — not because B.C. has a power shortage (it has a growing surplus due to the recent spate of mill closures and the commissioning of two new generating stations in B.C.) but because Powerex reaps bigger profits when BC Hydro slows down generators to import cheaper power, especially at night.

“B.C. buys its power from outside B.C., which we would argue is not clean,” says Martin Mullany, interim executive director for Clean Energy BC. 

“A good chunk of the electricity we use is imported,” Mullany says. “In reality we are trading for brown power” — meaning power generated from conventional ‘dirty’ sources such as coal and gas. 

Wyoming, which generates almost 90 per cent of its power from coal, was among the 12 U.S. states that exported power to B.C. last year. (Notably, B.C. did not export any electricity to Wyoming in 2018.)

Utah, where coal-fired power plants produce 70 per cent of the state’s energy amid debate over the costs of scrapping coal-fired electricity, and Montana, which derives about 55 per cent of its power from coal, also exported power to B.C. last year. 

So did Nebraska, which gets 63 per cent of its power from coal, 15 per cent from nuclear plants, 14 per cent from wind and three per cent from natural gas.   

Coal is responsible for about 23 per cent of the power generated in Arizona, another exporter to B.C., while gas produces about 44 per cent of the electricity in that state.  

In 2017, the latest year for which statistics are available, electricity imports to B.C. totalled just over 1.2 million tonnes of carbon dioxide emissions, according to the B.C. environment ministry — roughly the equivalent of putting 255,000 new cars on the road, using the U.S. Environmental Protection Agency’s calculation of 4.71 tonnes of annual carbon emissions for a standard passenger vehicle. 

These figures far outstrip the estimated local and upstream emissions from the contested Woodfibre LNG plant in Squamish that is expected to release annual emissions equivalent to 170,000 new cars on the road.

Import emissions cast a new light on B.C.’s latest “milestone” announcement that 30,000 electric cars are now among 3.7 million registered vehicles in the province.

BC Electric Vehicles Announcement Horgan Heyman Mungall Weaver
In November of 2018 the province announced a new target to have all new light-duty cars and trucks sold to be zero-emission vehicles by the year 2040. Photo: Province of B.C. / Flickr

“Making sure more of the vehicles driven in the province are powered by BC Hydro’s clean electricity is one of the most important steps to reduce [carbon] pollution,” said the November 28 release from the energy ministry, noting that electrification has prompted a first call for power in 15 years from BC Hydro.

Mullany points out that Powerex’s priority is to make money for the province and not to reduce emissions.

“It’s not there for the cleanest outcome,” he said. “At some time we have to step up to say it’s either the money or the clean power, which is more important to us?”

Electricity bought and sold by little-known, unregulated Powerex
These transactions are money-makers for Powerex, an opaque entity that is exempt from B.C.’s freedom of information laws. 

Little detailed information is available to the public about the dealings of Powerex, which is overseen by a board of directors comprised of BC Hydro board members and BC Hydro CEO and president Chris O’Reilly. 

According to BC Hydro’s annual service plan, Powerex’s net income ranged from $59 million to $436 million from 2014 to 2018. 

“We will never know the true picture. It’s a black box.” 

Powerex’s CEO Tom Bechard — the highest paid public servant in the province — took home $939,000 in pay and benefits last year, earning $430,000 of his executive compensation through a bonus and holdback based on his individual and company performance.  

“The problem is that all of the trade goes on at Powerex and Powerex is an unregulated entity,” Mullany says. 

“We will never know the true picture. It’s a black box.” 

In 2018, Powerex exported 8.7 million megawatt hours of electricity to the U.S. for a total value of almost $570 million, according to data from the Canada Energy Regulator. That same year, Powerex imported 9.6 million megawatt hours of electricity from the U.S. for almost $360 million. 

Powerex sold B.C.’s publicly subsidized power for an average of $87 per megawatt hour in 2018, according to the Canada Energy Regulator. It imported electricity for an average of $58 per megawatt hour that year. 

In an emailed statement in response to questions from The Narwhal, BC Hydro said “there can be a need to import some power to meet our electricity needs” due to dam reservoir fluctuations during the year and from year to year.

‘Impossible’ to determine if electricity is from coal or wind power
Emissions associated with electricity imports are on average “significantly lower than the emissions of a natural gas generating plant because we mostly import electricity from hydro generation and, increasingly, power produced from wind and solar,” BC Hydro claimed in its statement. 

But U.S. energy economist Robert McCullough says there’s no way to distinguish gas and coal-fired U.S. power exports to B.C. from wind or hydro power, noting that “electrons lack labels.” 

Similarly, when B.C. imports power from Alberta, where generators are shifting to gas and 48.5 per cent of electricity production is coal-fired and 38 per cent comes from natural gas, there’s no way to tell if the electricity is from coal, wind or gas, McCullough says.

“It really is impossible to make that determination.” 

Wyoming Gilette coal pits NASA
The Gillette coal pits in Wyoming, one of the largest coal-producers in the U.S. Photo: NASA Earth Observatory

Neither the Canada Energy Regulator nor Statistics Canada could provide annual data on electricity imports and exports between B.C. and Alberta. 

But you can watch imports and exports in real time on this handy Alberta website, which also lists Alberta’s power sources. 

In 2018, California, Washington and Oregon supplied considerably more power to B.C. than other states, according to data from Canada Energy Regulator. 

Washington, where about one-quarter of generated power comes from fossil fuels, led the pack, with more than $339 million in electricity exports to B.C. 

California, which still gets more than half of its power from gas-fired plants even though it leads the U.S. in renewable energy with substantial investments in wind, solar and geothermal, was in second place, selling about $18.4 million worth of power to B.C. 

And Oregon, which produces about 43 per cent of its power from natural gas and six per cent from coal, exported about $6.2 million worth of electricity to B.C. last year. 

By comparison, Nebraska’s power exports to B.C. totalled about $1.6 million, Montana’s added up to $1.3 million,  Nevada’s were about $706,000 and Wyoming’s were about $346,000.

Clean electrons or dirty electrons?
Dan Woynillowicz, deputy director of Clean Energy Canada, which co-chaired the B.C. government’s Climate Solutions and Clean Growth Advisory Council, says B.C. typically exports power to other jurisdictions during peak demand. 

Gas-fired plants and hydro power can generate electricity quickly, while coal-fired power plants take longer to ramp up and wind power is variable, Woynillowicz notes. 

“When you need power fast and there aren’t many sources that can supply it you’re willing to pay more for it.”

Woynillowicz says “the odds are high” that B.C. power exports are displacing dirty power.

Elsewhere in Canada, analysts warn that Ontario's electricity could get dirtier as policies change, raising similar concerns.

“As a consumer you never know whether you’re getting a clean electron or a dirty electron. You’re just getting an electron.” 

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Natrium small modular reactor pairs a sodium-cooled fast reactor with molten salt storage to deliver load-following, dispatchable nuclear power, enhancing grid flexibility and peaking capacity as TerraPower and GE Hitachi pursue factory-built, affordable deployment.

Key Points

A TerraPower-GE Hitachi SMR joining a sodium-cooled reactor with molten salt storage for flexible, dispatchable power.

✅ 345 MW base; 500 MW for 5.5 hours via thermal storage

✅ Sodium-cooled coolant and molten salt storage enable load-following

✅ Backed by major utilities; factory-built modules aim lower costs

Nuclear power is the Immovable Object of generation sources. It can take days just to bring a nuclear plant completely online, rendering it useless as a tool to manage the fluctuations in the supply and demand on a modern energy grid.  

Now a firm launched by Bill Gates in 2006, TerraPower, in partnership with GE Hitachi Nuclear Energy, believes it has found a way to make the infamously unwieldy energy source a great deal nimbler, drawing on next-gen nuclear ideas — and for an affordable price. 

The new design, announced by TerraPower on August 27th, is a combination of a "sodium-cooled fast reactor" — a type of small reactor in which liquid sodium is used as a coolant — and an energy storage system. While the reactor could pump out 345 megawatts of electrical power indefinitely, the attached storage system would retain heat in the form of molten salt and could discharge the heat when needed, increasing the plant’s overall power output to 500 megawatts for more than 5.5 hours. 

“This allows for a nuclear design that follows daily electric load changes and helps customers capitalize on peaking opportunities driven by renewable energy fluctuations,” TerraPower said. 

Dubbed Natrium after the Latin name for sodium ('natrium'), the new design will be available in the late 2020s, said Chris Levesque, TerraPower's president and CEO.

TerraPower said it has the support of a handful of top U.S. utilities, including Berkshire Hathaway Energy subsidiary Pacificorp, Energy Northwest, and Duke Energy. 

The reactor's molten salt storage add-on would essentially reprise the role currently played by coal- or gas-fired power stations or grid-scale batteries: each is a dispatchable form of power generation that can quickly ratchet up or down in response to changes in grid demand or supply. As the power demands of modern grids become ever more variable with additions of wind and solar power — which only provide energy when the wind is blowing or the sun shining — low-carbon sources of dispatchable power are needed more and more, and Europe is losing nuclear power at a difficult moment for energy security. California’s rolling blackouts are one example of what can happen when not enough power is available to be dispatched to meet peak demand. 

The use of molten salt, which retains heat at extremely high temperatures, as a storage technology is not new. Concentrated solar power plants also collect energy in the form of molten salt, although such plants have largely been abandoned in the U.S. The technology could enjoy new life alongside nuclear plants: TerraPower and GE Hitachi Nuclear are only two of several private firms working to develop reactor designs that incorporate molten salt storage units, including U.K.- and Canada-based developer Moltex Energy.

The Gates-backed venture and its partner touted the "significant cost savings" that would be achieved by building major portions of their Natrium plants through not a custom but an industrial process — a defining feature of the newest generation of advanced reactors is that their parts can be made in factories and assembled on-site — although more details on cost weren't available. Reuters reported earlier that each plant would cost around $1 billion.

NuScale Power

A day after TerraPower and GE Hitachi's unveiled their new design, another nuclear firm — Portland, Oregon-based NuScale Power — announced that the U.S. Nuclear Regulatory Commission (NRC) had completed its final safety evaluation of NuScale’s new small modular reactor design.

It was the first small modular reactor design ever to receive design approval from the NRC, NuScale said. 

The approval means customers can now pursue plans to develop its reactor design confident that the NRC has signed off on its safety aspects. NuScale said it has signed agreements with interested parties in the U.S., Canada, Romania, the Czech Republic, and Jordan, and is in the process of negotiating more. 

NuScale previously said that construction on one of its plants could begin in Utah in 2023, with the aim of completing the first Power Module in 2026 and the remaining 11 modules in 2027.

NuScale
An artist’s rendering of NuScale Power’s small modular nuclear reactor plant. NUSCALE POWER
NuScale’s reactor is smaller than TerraPower’s. Entirely factory-built, each of its Power Modules would generate 60 megawatts of power. The design, typical of advanced reactors, uses pressurized water reactor technology, with one power plant able to house up to 12 individual Power Modules. 

In a sign of the huge amounts of time and resources it takes to get new nuclear technology to the market’s doorstep, NuScale said it first completed its Design Certification Application in December 2016. NRC officials then spent as many as 115,000 hours reviewing it, NuScale said, in what was only the first of several phases in the review process. 

In January 2019, President Donald Trump signed into law the Nuclear Energy Innovation and Modernization Act (NEIMA), designed to speed the licensing process for advanced nuclear reactors, and the DOE under Secretary Rick Perry moved to advance nuclear development through parallel initiatives. The law had widespread bipartisan support, underscoring Democrats' recent tentative embrace of nuclear power.

An industry eager to turn the page

After a boom in the construction of massive nuclear power plants in the 1960s and 70s, the world's aging fleet of nuclear plants suffers from rising costs and flagging public support. Nuclear advocates have for years heralded so-called small modular reactors or SMRs as the cheaper and more agile successors to the first generation of plants, and policy moves such as the UK's green industrial revolution lay out pathways for successive waves of reactors. But so far a breakthrough on cost has proved elusive, and delays in development timelines have been abundant. 

Edwin Lyman, the director of nuclear power safety at the Union of Concerned Scientists, suggested on Twitter that the nuclear designs used by TerraPower and GE Hitachi had fallen short of a major innovation. “Oh brother. The last thing the world needs is a fleet of sodium-cooled fast reactors,” he wrote.  

Still, climate scientists view nuclear energy as a crucial source of zero-carbon energy, with analyses arguing that net-zero emissions may be impossible without nuclear in many scenarios, if the world stands a chance at limiting global temperature increases to well below 2 degrees Celsius above pre-industrial levels. Nearly all mainstream projections of the world’s path to keeping the temperature increase below those levels feature nuclear energy in a prominent role, including those by the United Nations and the International Energy Agency (IEA). 

According to the IEA: “Achieving the clean energy transition with less nuclear power is possible but would require an extraordinary effort.”

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Australia Electricity Supply Shortfall highlights AEMO's warning of reduced reserves as coal retirements outpace capacity, risking load shedding. Calls for 1GW strategic reserves and investment in renewables, storage, and dispatchable power in Victoria.

Key Points

It is AEMO's forecast of reduced reserves, higher outage risk, and a need for 1GW strategic backup capacity.

✅ Coal retirements outpacing firm, dispatchable capacity

✅ AEMO urges 1GW strategic reserves in Victoria and South Australia

✅ Investment needed: renewables, storage, grid and reliability services

Australia’s electricity operator has warned of threats to electricity supply including a shortfall in generation and reduced power reserves on the horizon.

The Australian Energy Market Operator (AEMO) has called for further investment in the country’s energy portfolio as retiring coal plants are replaced by intermittent renewables poised to eclipse coal, leaving the grid with less back-up capacity.

AEMO has said this increases the chances of supply interruption and load shedding.

It added the federal government should target 1GW of strategic reserves in the states most at risk – Victoria and South Australia, even as the Prime Minister has ruled out taxpayer-funded power plants in the current energy battle.

CEO of the Clean Energy Council, Kane Thornton, said the shortfall in generation, reflected in a short supply of electricity, was due a decade of indecisiveness and debate leading to a “policy vacuum”.

He added: “The AEMO report revealed that the new projects added to the system under the renewable energy target will help to improve reliability over the next few years.

“We need to accept that the energy system is in transition, with lessons from dispatchable power shortages in Europe, and long term policy is now essential to ensure private investment in the most efficient new energy technology and solutions.”

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Developing Countries Clean Energy investment fell as renewable energy financing slowed in China; solar and wind growth lagged while coal power hit new highs, raising emissions risks for emerging markets and complicating climate change goals.

Key Points

Renewables investment and power trends in emerging nations: solar, wind, coal shifts, and steps toward decarbonization.

✅ Investment fell to $133b; China dropped to $86b

✅ Coal power rose to 6,900 TWh; 47% generation share

✅ New coal builds declined to 39 GW, decade low

New clean energy investment slid by more than a fifth in developing countries last year due to a slowdown in China, while the amount of coal-fired power generation jumped to a new high, reflecting global power demand trends, a recent annual survey showed.

Bloomberg New Energy Finance (BNEF) surveyed 104 emerging markets and found that developing nations were moving towards cleaner, low-emissions sources in many regions, but not fast enough to limit carbon dioxide emissions or the effects of climate change.

New investment in wind, solar and other clean energy projects dropped to $133 billion last year from $169 billion a year earlier, mainly due to a slump in Chinese investment, even as electricity investment globally surpasses oil and gas for the first time, the research showed.

China’s clean energy investment fell to $86 billion from $122 billion a year earlier, with dynamics in China's electricity sector also in focus. Investment by India and Brazil also declined, mainly due to lower costs for solar and wind.

However, the volume of coal-fired power generation produced and consumed in developing countries increased to a new high of 6,900 terrawatt hours (TWh) last year, even as renewables are poised to eclipse coal globally, from 6,400 TWh in 2017.

The increase of 500 TWh is equivalent to the power consumed in the U.S. state of Texas in one year, underscoring how surging electricity demand is putting power systems under strain. Coal accounted for 47% of all power generation across the 104 countries.

“The transition from coal toward cleaner sources in developing nations is underway,” said Ethan Zindler, head of Americas at BNEF. “But like trying to turn a massive oil tanker, it takes time.”

Despite the spike in coal-fired generation, the amount of new coal capacity which was added to the grid in developing countries declined, with Europe's renewables crowding out gas offering a contrasting pathway. New construction of coal plants fell to its lowest level in a decade last year of 39 gigawatts (GW).

The report comes a week ahead of United Nations climate talks in Madrid, Spain, where more than 190 countries will flesh out the details of an accord to limit global warming.

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Sycamore Energy Manitoba Hydro Lawsuit centers on alleged mismanagement of the solar rebate incentive program, project delays, inspection backlogs, and alleged customer interference, impacting renewable energy installations, contractors, and clean power investment across Manitoba.

Key Points

Claim alleging mismanagement of Manitoba's solar rebate, delays, and inducing customers to switch installers.

✅ Lawsuit alleges mismanaged solar rebate incentive program

✅ Delays in inspections left hundreds of projects incomplete

✅ Claims Hydro urged customers to switch installers for rebates

Sycamore Energy filed a statement of claim Monday in Manitoba Court of Queens Bench against Manitoba Hydro saying it badly mismanaged its Solar Energy Program, a dispute that comes as Canada's solar progress faces criticism nationwide.

The claim also noted the crown corporation caused significant financial and reputational damage to Sycamore Energy, echoing disputes like Ontario wind cancellation costs seen elsewhere.

The statement of claim says Manitoba Hydro was telling customers to find other companies to complete solar panel installations, even as Nova Scotia's solar charge debate has unfolded.

'I'm still waiting': dozens of Manitoba solar system installations in the queue under expired incentive program
This all comes after a pilot project was launched in the province in April 2016, which would allow people to apply for a rebate under the incentive program, while Saskatchewan adjusted solar credits in parallel, and the project would cover about 25 per cent of the installation costs.

The project ended in April 2018, but hundreds of approved projects had yet to be finished.

According to Manitoba Hydro, in November there were 252 approved projects awaiting completion by more than one contractor, and Sycamore Energy said it had about 100 of those projects, a dynamic seen as New England's solar growth strains grid upgrades in other regions.

At the time Sycamore Energy COO, Alex Stuart, blamed Manitoba Hydro for the delays, stating it took too long to get inspections after solar systems were installed.

Scott Powell, Manitoba Hydro’s director of corporate communications, said in November he disagreed with Sycamore Energy’s comments, even as Ontario moves to reintroduce renewables elsewhere.

In a news release, the company said it sold more installations under Manitoba Hydro’s Solar Energy Program compared to other companies and it was instrumental in helping set up standards for the program.

“Manitoba Hydro mismanaged the solar rebate program from the beginning. In the end, they targeted our company unfairly and unlawfully by inducing our customers to break their contracts with us. Manitoba Hydro told our customers they could get an extension to their rebate but only if they switched to different installers,” said Justin Phillips, CEO of Sycamore Energy in a news release.

“We would much rather be installing clean, effective solar power projects for our customers right now. The last thing we want to do is to be suing Manitoba Hydro, but we feel we have no choice. Their actions have cost us millions in lost business. They’ve also cost the province jobs, millions in private investment and a positive way forward to help combat climate change.”

Manitoba Hydro now has 20 days to respond to the action, and a recent Cornwall wind-farm ruling underscores the stakes.

When asked for a response from CTV News, a spokesperson for the Crown corporation said it hadn’t yet been made aware of the suit.

“If a statement of claim is filed and served, we’ll file a statement of defence in due course. As this matter is now apparently before the courts, we have no further comment,” the spokesperson said.

None of these allegations have been proven in court.

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