MnSEIA engages on a variety of regulatory proceedings at the Minnesota Public Utilities Commission to ensure solar and storage policies are correctly implemented and upheld. Our year-round regulatory work ensures a strong solar and storage market in the state and collaboration between our members and state agencies.

MnSEIA staff appreciates member input on our regulatory comments. If you’d like to participate in any regulatory matter, please email info@mnseia.org.

To learn more about MnSEIA's policy work, check out our webpage here. To see the working groups we're involved in, click here.

This page is a living resource and will be updated regularly. Search the full e-dockets here.

Active Dockets:

Capacity Definition: Docket 24-200 (From 16-521/18-711)

Summary: After MnSEIA's successful challenge to the Dakota Electric TSM (Docket Nos. 16-521/18-711), the PUC opened a new docket to understand how the proper understanding of capacity may affect reliability. The request for comment also included discussion of net metering. Discussions concluded between MnSEIA and MREA on the application of this definition to reliability issues on Tuesday, 8/13 - parties will be filing separate comments.

Update from 11.7.2024: On November 7, 2024, the Commission held a hearing on Docket 24-200, in regards to the definition of “capacity” under Minnesota law, and possible impacts that might be caused to grid reliability. Despite the fact that no reliability concerns were raised in the comment period, the Commission adopted a decision option that defined “capacity” as being measured at either the inverter or a power control system (PCS) before customer load, while referring the matter to a rulemaking proceeding. MnSEIA advocated in the hearing as in our comments that capacity is clearly defined, under statute, as being at the ‘point of common coupling’ and consequently the bidirectional meter. MnSEIA made additional note of the fact that no serious reliability issues had been brought up in comments, despite it being the focus of the notice of comment period. The Commission decided upon the above-discussed resolution as a compromise option between the Dept. of Commerce and the utilities, as well as the referral to further rulemaking process.

What sectors does this impact? Installers of behind-the-meter PV and storage

How this impacts the industry: This affects how cooperative utilities classify the DER arrangements MnSEIA members install - ensuring that they are properly counting capacity at the point of interconnection, and not improperly classifying behind-the-meter capacity that cannot affect export. Restrictions imposed here could negatively impact net metering down the line, including limiting the ability of DER owners to export excess energy as allowed under statute. This represents an opportunity to challenge (and stop) the utility practice of studying and regulating behind the meter PV systems at nameplate capacity, rather than capacity at the inverter.

Challenge to the TPL: Docket 23-424/MN Court of Appeals A24-0845

Summary: MnSEIA filed our reply brief to Court of Appeals case A24-0845, discussing our argument that the TPL requires review by the Minnesota Public Utilities Commission in order to be implemented. In short, this artifical cap was imposed by Xcel without review by the PUC, violating the Commission's duty to regulate utilities in Minnesota. The existence of the TPL chokes the deployment of distributed solar, storage, and generation of all kinds, putting a severe cap on Minnesota's renewable energy goals.

How this impacts the industry: The TPL caps Minnesota solar deployment - if the PUC were to properly review the TPL, and if it were removed, it would free up over 2 GW of available capacity on feeders and transformers in Xcel Energy territory.

Distributed Solar Energy Standard (DSES): Docket 23-403

What sectors does this impact? Solar installers, developers, and commercial & industrial (C&I) customers

Hosting Capacity Analysis: Docket 22-574/Docket 23-466

What sectors does this impact? All behind the meter and front of meter DG installers and developers

Interconnection Ombudsperson Surcharge: Docket E002/24-248

Summary: On November 21, 2024, the PUC held a hearing to decide how to apply the Interconnection Ombudsperson surcharge. MnSEIA's proposed language was adopted, putting the fee in the MN DIP in a proceeding 2025 docket, and denying Xcel's petition to add American Association of Arbitrator requirements to the Ombudsperson. MnSEIA's proposal for enhanced data collection to ensure that the fee can be adjusted was not adopted. MnSEIA will file proposed alterations in a years' time, when the ombudsperson's time spent and fee adjustments are filed with the Commission.

What sectors does this impact? All installers, developers - anyone looking to interconnect DG in Minnesota

How this impacts the industry: The fee is applied to all interconnection applications. The ombudsperson a potential resource for all MnSEIA members dealing with interconnection topics in Minnesota.

Retroactive Change to Applicable Retail Rate Proposal: Docket 13-867

MnSEIA, CCSA, US Solar, Cooperative Energy Futures, Institute for Local Self-Reliance, Vote Solar, and Novel Energy Solutions filed Reply Comments opposing Xcel’s proposal to retroactively change the way that the applicable retail rate (“ARR”) is determined. This would reduce the amount paid to ARR Community Solar Garden subscribers because of legal and factual issues with the proposal.

Small DER Capacity Reservation System for Xcel Energy: Docket E002/24-176

Summary: Xcel Energy has proposed a capacity reservation on small DER systems - this is the third time they have done so since 2021. Xcel then proposed, and Commerce agreed, the suspension of this docket ahead of the September 1st PUC docket on Minnesota Law 2024 (SF 4942). Ch. 126, Art. 6, Sec. 53, and the broader impacts of 23-542 - Xcel's Integrated Distribution System Plan. DOC believes a small DER capacity reservation is redundant, given the cost-causer-pays principle that Section 53 addresses. After the September docket, the obligation will be on Xcel to again propose a capacity reservation if it believes it to be necessary.

What sectors does this impact? Installers, CSG operators

How this impacts the industry: A capacity reservation would put a cap on small DER systems. This docket has been suspended due to redundancy, and the IDP docket.

Xcel Energy Residential Time-of-Use Rates Proposal: Docket 23-524

On 12.22.2023, Xcel Energy filed a proposal for time-of-use rates (TOU) in its Minnesota territory. They did so based on their Flex Pricing pilot program, from November 2020 to October 2022, and the current implementation of a TOU rate in Colorado with their Operating Company (PSCo). The TOU rollout in Colorado is ongoing, as Xcel has only partially rolled out smart meter infrastructure. MnSEIA's comments focused on net metering - the TOU proposal insufficiently addressed the effect these rates would have on net metered customers, law and MN policy states that it does.

What sectors does this impact? All residential installers, net metered customers

How this impacts the industry: All residential customers have the possibility to be affected by this proposal. Depending upon its execution, Xcel's TOU proposal can be a great boon or issue for distributed generation and net metered customers in Minnesota. At its current point, it would undercut net metering compensation, so MnSEIA continues to advocate for DG customers.

Closed Dockets:

Community Solar Garden Program Creation: Docket 13-867

MnSEIA was instrumental in creating Minnesota's nation-leading community solar garden program in 2013, and has continued to protect and bolster the industry since. The dockets below created Xcel Energy's CSG program, and enhance it each year. Learn more here.

COVID-19 Relief: Docket 20-492

During the beginnings of the COVID-19 pandemic, PUC Commissioner Sullivan requested that Minnesota's rate regulated utilities offer ideas for COVID economic relief and recovery. Many utilities, including Xcel Energy and Minnesota Power, stepped up and offered to expedite the installation of planned utility-scale solar investments. MnSEIA supported these commitments for the many jobs, economic development, and solar that would be created across the state. Read MnSEIA's full press release on these announcements here.

DG Tariff: Docket 16-521

Distributed Generation (DG) solar projects subject to the DG Tariff are classified as projects in the 1-10 MW size range. This is a promising market for Minnesota that would boost resiliency of the electrical grid and open up more opportunities for solar. MnSEIA has made it a goal to improve the current regulatory framework to spur this promising market. Learn more about the DG tariff here.

Interconnection Standards: Docket 16-521

MnSEIA has advocated for the solar industry at the PUC to develop the Minnesota Distributed Energy Resources Interconnection Process (MN DIP.) Interconnection standards are a "living document' and need to be revised over time, and MnSEIA will continue to advocate for our members. Learn more about MnSEIA's work here.

MN Power Expedited Projects: Docket 20-828

In 2020, the PUC asked Minnesota's rate regulated utilities to offer ideas for COVID economic recovery. Many utilities, including Xcel Energy and Minnesota Power, stepped up and offered to expedite the installation of planned utility-scale solar investments. Minnesota Power's economic recovery project for roughly 20 MWs of solar was filed in Docket 20-828, which MnSEIA supported. Read MnSEIA's full press release on the economic recovery efforts here.

Planned Outages: Docket 13-867

Few things are as frustrating to a Community Solar Garden owner or operator as a garden going offline with little notice. MnSEIA has worked to mitigate the impacts of planned outages on a case-by-case basis but is also working on a regulatory level towards a systemic fix to prevent outage crises in the future. Learn more about our planned outages work here.

Residential Adder: Docket 13-867

The Residential Adder is a measure that implements an "adder" to the credit on residential solar customers' utility bills from their subscriptions. This program has helped significantly grow the residential community solar industry in Minnesota, and MnSEIA helps recalculate or reaffirm the rate with the Minnesota Public Utilities Commission every few years.

PV Demand Credit Rider/Solar Capacity Credit: Dockets 15-115/13-115

MnSEIA has negotiated with Xcel Energy, the Department of Commerce, and other stakeholders to develop and continuously improve a "Capacity Credit" that later became the "PV Demand Credit Rider." The PV Demand Credit offers Commercial and Industrial solar developers a special rate if they undergo demand-response curtailment during peak demand periods. This credit has created many megawatts of C&I solar projects in Minnesota—a market that MnSEIA is always looking to help grow. Learn more here.

SolarSense: Docket 16-485/20-607

Minnesota Power's SolarSense program has helped spur a burgeoning solar industry in Northern Minnesota. It includes incentives for residential solar installations, a Low Income Solar Grant program, and an education program. MnSEIA has supported extending and expanding the program so more Minnesota Power customers can access clean energy.

Third-Party Aggregators of Retail Customers: Docket 22-600

MnSEIA supports allowing third-party aggregators of retail customers (ARCs) to bid demand response into organized markets. Fast-acting, flexible resources will become increasingly important to ensure a reliable and resilient grid. MnSEIA opposes continuing to allow electric utility monopolies to control demand response because they are not incentivized to maximize its potential. A competitive marketplace would likely promote innovation and lower energy costs to ratepayers.

Third Party Billing Changes: Docket 13-867/21-695

MnSEIA and The Coalition for Community Solar Access (CCSA) filed joint comments in 2021 for a proposed change to Xcel Energy's Solar*Rewards Community program. The modification would have made it more difficult for renters to subscribe to community solar gardens that their apartment building purchased or participated in. 

Value of Solar: Docket 13-867

In 2013, MnSEIA played an instrumental role in the passage of the “Value of Solar,” (VOS) a first-of-its-kind rate designed to be equivalent to the direct benefit that a solar facility provides the utility, its ratepayers, and society generally. The Minnesota PUC calculates the VOS each year based on eight different components, and MnSEIA represents the solar industry to ensure the VOS is accurately calculated. Learn more about the Value of Solar here.

Xcel Energy Grid Security Report re: HCR Docket: 20-800

MnSEIA has been involved, with our partners, at the PUC to ask utilities to provide data to developers in a more timely and efficient manner. Solar developers need access to current and accurate data about the distribution system to ensure that they are able to interconnect projects to the grid. MnSEIA worked collaboratively with Xcel Energy to find solutions that work better for all parties.

Xcel Energy's Interconnection Cost Sharing Proposal: Docket 18-714

Necessary upgrade costs to facilitate interconnection can be prohibitively expensive for many developers and homeowners. MnSEIA has helped create a permanent fund for those expenses in Xcel Energy territory to improve the interconnection process so more Minnesotans can go solar.

Xcel Energy's Resiliency Service Program: Docket 22-170

Xcel Energy proposed a new Resiliency Service Program to enter the behind-the-meter energy storage market. MnSEIA filed comments to advocate for a competitive marketplace for our members. 

Xcel Energy's Solar*Rewards for Schools: Docket 21-718

After four years of lobbying at the State Capitol, MnSEIA and our partners successfully passed legislation to create a Solar for Schools program in Minnesota. MnSEIA has since been very involved in the implementation of this program at the regulatory level. The energy costs for public school campuses is the second-highest cost for districts, after payroll. This program will help create jobs, clean energy, and STEM learning opportunities across the state. Learn more about the program here.

Xcel Energy's Solar*Rewards Program: Docket 13-1015

Solar*Rewards is an important part of the rooftop solar landscape in Minnesota. MnSEIA keeps regular tabs on the success of the program, and has consistently advocated for it at the legislature. On occasion, major programmatic changes require MnSEIA regulatory input on behalf of the sector.

Xcel Energy's Quality of Service Plan (QSP): Docket 12-383

The Quality of Service Plan (QSP) tariff for Xcel Energy created a one million dollar penalty for the utility's underperformance in customer service. Compliance with this tariff is overseen by Minnesota's Public Utility Commission, and MnSEIA acts on behalf of our members to see that this tariff is enforced.

This page is a living resource and will be updated regularly. Search the full e-dockets here.

Thank you to our members who support MnSEIA's year-round regulatory work. To learn more about our policy work, check out our webpage here. To see the working groups we're involved in, click here.

Curtis Zaun, MnSEIA

 

 

Questions? Email MnSEIA's Director of Policy & Regulatory Affairs, Curtis Zaun at czaun@mnseia.org.

Solar on Schools in Minnesota, Winona State University, McKinstry - MnSEIA
Image Courtesy of McKinstry