MNIPL Comments to PUC on Community Solar

In the Matter of Xcel Energy’s Plan for a Community Solar Garden Program

Pursuant to Minn. Stat. 216B.1641; Docket No. E002/M-13-867

December 2, 2013

Comments of Minnesota Interfaith Power and Light

Minnesota Interfaith Power & Light believes the active care of creation is integral to spiritual life and social justice. Through leadership and guidance to Minnesota’s faith communities, we respond to climate change by bringing faith communities together and providing opportunities for congregations to join the growing climate justice movement.

We represent nearly 2000 individuals from over 200 faith communities, most of which reside in Xcel’s service territory.    Our members were active advocates for the community solar gardens legislation through their participation in the Clean Energy and Jobs campaign comprised of over sixty diverse citizen groups.

Our faith community members are inquiring frequently about how they can help promote the rapid deployment of Community Solar Gardens within their congregations.   Community solar installers tell us that faith congregation buildings might make good host sites, which might often be under 100kW.

General Concerns with the Xcel Petition

We support an interim “applicable retail rate” that allows the community solar gardens industry to respond to clear public demand for solar energy, and this requires fairly priced solar energy.    We support the interim rate proposal 3 made by Minnesota Solar Energy Industry Association (MNSEIA) on this docket.  We support even higher interim rates which are justified by using the median cost of CO2 emissions ($36/T), as suggested by the Minnesota Center for Environmental Advocacy in its recent Motion to Re-open Externalities Docket.    

If the Public Utilities Commission cannot support the MNSEIA rate proposal that we favor, we hope that the Commission will use all available discretion to arrive at an interim rate that is at least as high as the lower bounds of an expected future Value of Solar Tariff.   Defaulting to a low interim rate in the absence of a VOST can cause the nascent Community Solar industry to miss the shrinking window of the expiring 30% Investment tax credit.    We are struck by MNSEIA’s comment that “delaying development until after the expiration of the 30% ITC will eliminate most, if not all, solar financing opportunities”. 

We do not support Xcel’s proposal to impose quarterly megawatt limits on project applications .   This goes against legislative intent and it sets limits on the desires of its own customers.   In a free market economy, Xcel should be flexible enough respond to whatever level of demand their customers present.   Xcel’s Colorado experience with community solar should be sufficient to mitigate their learning curve concerns.   Rather than limiting applications to assure service quality, we would prefer to see Xcel perform to service level standards that are acceptable to community solar companies and their customers.  

In general, we want Xcel to work aggressively and flexibly in responding to unconstrained free market demands coming from its customers and the legislative intent to create financially viable solar gardens.   Therefore, we support the important additional points made in public comments by Fresh Energy, the Interstate Renewable Energy Council, and the Minnesota Solar Energy Industry Association.

Based on the interest expressed by our congregations, MN Interfaith Power and Light is exploring ways to help congregations conduct subscription drives.     Quarterly caps on capacity and underpriced electricity reimbursements will dampen consumer demand and discourage these potential drives from ever starting. 

Respectfully Submitted,

Minnesota Interfaith Power & Light

Julia Frost Nerbonne, Executive Director

Joy Throm, Board Chair

Jack Chandler

Richard Condon

Tara Daun

Charles Dayton

Rev. Donna Martinson

Julie Nester

Rev. Gwin Pratt




2104 Stevens Ave. S

Minneapolis, MN 55404