Within days of its open on December 12, 2014, Xcel Energy’s Minnesota Community Solar Garden (CSG) Program had well over 300 MW worth of CSG applications submitted and by this writing nearly 430 MW. The rush of significant application creates a question of “who’s in line first?” That was the question before the Minnesota Public Utilities Commission (Commission) today.
As noted in our prior coverage, the Commission instructed the program to be “first-ready, first-served” and laid out specific instructions on the steps developers would need to take to complete applications and develop a garden in compliance with the program. These instructions were the result of substantial deliberation with interested parties and reflected in Xcel’s shiny new Tariff Section 9 governing the CSG Program. The problem, however, is that any CSG needs to interconnect to Xcel’s distribution system, and that process is governed by Xcel’s existing Tariff Section 10. The interplay of these two tariff sections complicates the “who’s in line first?” issue by adding the question “which line?” Importantly, over 100 MW of applications destined for the CSG program were in line in the Section 10 interconnection queue before the CSG program opened last month. A developer sought resolution of the two-queue issue from the Commission.
After considerable discussion, the Commission essentially decided the interconnection queue should follow the CSG program queue and directed as follows:
- CSG applications will enter the appropriate Section 10 interconnection queue and be placed or reordered in this queue based on the date and time that Xcel determines the application to be complete under Section 9.
- For any interconnection applications already studied that require additional engineering study due to changes in the interconnection queue positions, Xcel was directed to track the additional cost incurred by re-performing parts of the engineering study and bill applicants for the parts of the study that were required to be redone due to distribution system changes.
Although it was understandably difficult for the Commission to decide at what point an application should receive a spot in line, today’s decision vests more weight in Xcel’s completeness determination – previously a ministerial task. Furthermore, the Commission left open how CSG developers that have invested money in furtherance of Section 10 interconnection applications will receive value for that investment if they move backwards in the Section 10 interconnection queue.
During deliberations the Commission also acknowledged that other issues are bound to percolate. Stay tuned . . .