| House Research Department Updated: October 2017 
<br />Xcel Energy’s Community Solar Garden Program Page 6 
<br />Second, Xcel said that these larger projects are not consistent with the legislature’s intent in 
<br />creating the community solar garden program, which it characterized as expanding “access to the 
<br />benefits of solar to customers who are traditionally unsuited to rooftop solar . . . , [including] 
<br />customers who lack access to an appropriate roof location, are unable to afford the upfront costs 
<br />of an installation, or are discouraged by system maintenance or other considerations.”14  
<br />Third, the company expressed concern that large solar gardens would focus on selling to large 
<br />customers, creating “the potential for entire service classes [i.e., residential and small business] 
<br />to be largely excluded from participation….”15 
<br />Fourth, Xcel noted that the bill credit rate under the community solar garden program was 
<br />significantly higher than the price paid at the time by Xcel for solar electricity produced by 
<br />utility-scale projects acquired under a power purchase agreement resulting from the company’s 
<br />most recent resource bidding process ($0.0732 per kWh).16 
<br />As these issues were being raised in the first half of 2015, community solar garden applications 
<br />continued to accumulate, rising to a total capacity of more than 500 MW by April 2, 646 MW by 
<br />May 18, and 912 MW by June 23.17 On June 22, 2015, Xcel reached agreement with several 
<br />stakeholders on the co-location issue. 
<br />The agreement, approved by the commission with some modifications, contained the following 
<br />provisions:18 
<br />•Projects exceeding 5 MW for which applications had been received by Xcel as of the date
<br />of the agreement would be scaled back to 5 MW.
<br />•Applications received after the date of the agreement but before September 25, 2015,
<br />would be limited to 5 MW.
<br />•Applications received between September 25, 2015, and September 15, 2016, would be
<br />limited to 1 MW.
<br />•The commission will determine whether and what co-location limits will apply to solar
<br />garden applications submitted after September 15, 2016.
<br />14 Ibid., p. 4. 
<br />15 Ibid.  The Office of the Attorney General noted that such a strategy greatly reduces the marketing costs of 
<br />solar garden developers, who would avoid dealing with a large number of small customers.  In the Matter of the 
<br />Petition of Northern States Power Company for Approval of its Proposed Community Solar Gardens Program, 
<br />Minnesota Public Utilities Commission Docket No. E002/M-867, Comments of the Office of the Attorney General – 
<br />Residential Utilities and Antitrust Division, March 4, 2015, pp. 3-4.  The same principle would hold true for a 
<br />developer’s administrative costs. 
<br />16 Letter from Aakash Chandarana, Regional Vice President, Rates and Regulatory Affairs, Xcel Energy, to 
<br />Daniel P. Wolf, Executive Secretary, Minnesota Public Utilities Commission, Docket No. E-002/M-13-867, Re: 
<br />Reply Comments, March 4, 2015, p. 10. 
<br />17 Minnesota Public Utilities Commission, In the Matter of the Petition of Northern States Power Company, 
<br />dba Xcel Energy, for Approval of Its Proposed Solar Garden Program, Docket No. E-002/M-13-867, Order 
<br />Adopting Partial Settlement as Modified, August 6, 2015, pp. 3, 5. 
<br />18 Ibid., p. 5. |