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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.