An article appeared in the Fargo Forum newspaper with words to the effect that utilities in Minnesota wish to assess more fees for home solar energy systems and to decrease the rates at which UTILITIES must pay to buy back electricity from solar producers such as myself. I am against such a decrease in the rates paid back to solar providers from coops and power companies.

Of further concern is the fact that during the summer months my Coop raises electric rates by 13.5% from 10.75% to 12.2% without increasing our compensation. I am locked in at 10.75%. Is this within statue?

My wife and I are retired and chose to 'go green' by installing a solar array on our rooftop. We purchased a 2017 Chevrolet Volt electric vehicle with every indication of saving money on our monthly power bills. WE ARE STERNLY OPPOSED TO ANY CAPITULATION TO THE POWER COMPANIES AND COOPS OF MINNESOTA IN THEIR EFFORTS TO RAISE RATES. FURTHER, WE REQUEST THAT THE MINNESOTA PUC SEEK TO REWARD CONSUMERS WHO HAVE DONE WHAT WE HAVE DONE BY LOWERING RATES OR PROVIDING TAX BENEFITS IN 2017 AND BEYOND!

Since installation of our solar project in March of 2017 we were able to take advantage of a 30% tax credit from the federal government. WHERE IS ANY HELP FROM THE STATE OF MINNESOTA?

SURELY OUR PUC WILL TRY AND EXTEND SUCH A GENEROUS TAX REBATE OF AT LEAST 30% IN THE NEXT LEGISLATIVE SESSION! AND....WE WOULD EXPECT THAT IT BE RETROACTIVE.

Utilities are asking for fees on qualifying facilities because they say there is a cost shift that exists because of net metering, and those customers aren't paying their fair share for grid maintenance. The problem is they haven't proven that a cost shift actually exists. They cite one study done in Louisiana paid for by fossil fuel interests that says there's a cost shift. Here's 34 studies not paid for by fossil fuel interests that show the opposite: http://www.seia.org/policy/distributed-solar/solar-cost-benefit-studies

Even if there was a cost shift, one has to ask if there are other cost shifts going on. A 2011 Minnesota Department of Health study found that 10% of newborns near the North Shore had risky levels of mercury because diets close to Lake Superior tend to have more fish in them. Mercury is linked to birth defects and learning disabilities in children. According to the MN Pollution Control Agency, 99% of mercury found in MN lakes and streams comes from the air, and the majority of that comes from coal power plants. The fact that the utilities that built these plants don't have to pay for the mercury related birth defects is the biggest cost shift in the industry (though climate change, asthma rates, and heart attacks may all argue with that). If someone is willing to spend their own money to put a clean power source on the grid, we should encourage them, not penalize them.

All we ask is that the fees are fair and reasonable, and can be supported by actual data as opposed to a randomly selected amount, and that customers aren't forced to pay for fees or services they don't need (we have one customer who is paying $300 / year for the option to get a rebate check each month, when he only wants it at the end of the year. The utility doesn't care that the service they are forcing him to buy is a service he doesn't want or need).

Additionally, the fees should incorporate the benefits solar provides to the grid, so if the benefit is greater than the cost, our customers should be paid similar to a peaking plant, if the benefits don't outweigh the costs then there should be a fee.

Lost profit should not be included as a factor in fee cost, our customers should have the freedom to choose what is best for them, not to be forced to choose options that aren't in their own economic interests. I'm unclear why energy efficiency gets a rebate, but solar gets penalized. Both have the same impact of reducing kwhs needed from the grid, yet they are treated differently.

Finally, the fees should be set at the time of installation for 25 years, uncertainty only created problems in the business world.

The addition of a solar or wind surcharge has been demonstrated to be unsupported in all but cases where the market penetration is significant. Clearly such is not the case in any minnesota utility? Since the proposed fees are being removed from regulatory control and subject to an, alledged, mediation process, it is clearly a political power play by COOPs, and municipal utilities, to avoid any scientific or fact based review! Even if one were to accept an argument that these charges Impact only those who have demonstrated by their construction of a solar or wind generation facility that they would be able to afford them they still would not be equiptable or reasonable. Additionaly this arguement ignores the fact that such installations are maintained by persons beyond the previous group who are making sacrifices in the support of the environment. These fees of course ignore the fact that in some global manner any consumer who uses less than some hypathical typical user would be placing the same burden on other users as the solar or wind generator. Actually the opposite would be true also, that is the user of more than average amounts would place a burden on others. The fairest method of rate setting is to treat energy as a commodity and price it accordingly. The argument that no other seller charges a facility fee is discounted by advocates of fees but it is really true, I don't pay the hospital a fee for being there.

While I agree all customers should help pay the costs for maintaining power lines a fair way to do this would be to make it a separate line item on the bill. My current power bill lists numerous adjustments and fees as separate line items. Itemizing the costs to maintain the lines as a separate line item would make it fair to all customers. Then if you are a net user or net generator everyone pays their fair share.

One thing that could come out of this plan is that people like myself who are considering becoming off grid rather than grid tied will find it cheaper to be off grid. Where I live there are 5 customers on 1 mile of line, so if I go off grid now there is one less customer to cover the costs of this line.
I have two friends in the Zumbrota area who are currently living off the electric grid. They built new homes and it was cheaper to be off grid than to pay the connection fees. is this the way of the future?

I strongly encourage the PUC to set aside … nay, to “throw out” considerations that allow the utility companies to “change the deal after the fact.” Investors have already made commitments and spent money based on an agreement and an existing set of circumstances that they could not have anticipated changing. The utilities made a deal based on these circumstances. Now, they wish to change it?

Instead, I encourage the PUC to limit any decisions to “change the deal” (i.e., to increase fees charged to individual renewable energy sources) such that the changes apply ONLY to future deals, not to deals made in the past. This would be fair, in that these decisions could be made with all the facts on the table. It is unfair to allow a change in a deal that has already been struck, thereby allowing “the rules” to be changed after the decision to invest has been made and committed.

The US Gov't and many utilities strongly encouraged individuals to install renewable power generation capability. The reasons are well-known and carefully documented. In short, to help save the environment and the economy, and to allow the utility to comply with governmental regulations and requirements for certain percentages of their output to be provided by renewable energy. Many concerned citizens (myself included) responded and invested in renewable power resources in various ways, including individual investment in a renewable resource for their own home, because we care about the issues that need to be addressed and because the incentives offered made it less financially “painful” to help in some way.

It is important to consider, especially in the case of individuals who installed renewable energy resources, that the up-front costs are significant – in my case, a net investment of over $21,000 ($38,560 less $17,433 in rebates and tax credits). Original projections suggested a 21-22 year break-even point for this investment. Based on 4 years of operational experience, the break-even point will be 21.8 years.

Let's be sure that we understand, particularly as the facts apply to the smaller installations, that the energy companies suffer no huge cost exposures. There are no additional distribution costs – the energy is produced and used locally. There are no additional cost-of-production, billing, collection, management of facility, personnel, or equipment purchase, maintenance, or replacement concerns – these are all borne by the local, individual investor, as are all “start-up” costs. So, in the case of the individual homeowner/investor situation: Why do the utility companies need to increase fees for these?

Additionally, individual investors have no way to recover these increased costs by passing them on to customers (like the big utilities do) because our “customers” are ourselves (trying to recover the cost of our original investment) and the utility company, who simply pays us the same price for our energy as they charge for theirs.

Morally, how do we justify allowing someone to “change the deal” after a deal has been struck? I can understand that our legislators might allow a “different deal” for folks who have not yet made a decision – for folks who have not yet invested in something that now they cannot change. If the changes were allowed only for future investments, at least that would allow the opportunity for the prospective investor to choose to invest/spend their money elsewhere; but those of us who have already made the decision, based on what we believed to be “the deal,” did not expect these additional charges and fees that are being proposed and we should not have to bear them.

The coop fees should be disallowed and a more equitable arrangement hammered out. I do understand that Coops have a harder time recouping their grid costs due to inefficient spacing of customers as contrasted with municipal power companies who service many more customers per mile of line than coops can. But we (the coop customers) pay for that disparity through higher basic service and power costs than those the municipals charge.

As others have noted, the Coops have not been able to prove that legitimate (appropriately sized) independent renewable power owners are “not paying their fair share” of grid costs. Solar owners most certainly do pay their fair share of the costs – we use solar at night, during bad weather, cloudy days and other times when the panels do not provide enough power for our needs. During those times we buy our power the same as anyone else. People’s Coop has claimed that some owners have installed way more solar power than they can use just to make money off it. I cannot verify or refute that claim, but given the costs of purchase and installation of the panels, and the long payback time, that claim seems far-fetched at best. If it is true, that can be easily remedied by limiting the amount of the reimbursement to cover only the homeowner’s proven power needs as shown on their power bill.

Because I installed my panels before July 2016, it does not affect me personally at this time, but without PUC oversight, they will likely “renegotiate” my contract at any time, and assess any fee they like with no outside entity to question the validity of their charges.

There is an obvious alternative that I do not hear discussed. It could be argued that to require the coops to pay retail for the excess power generated by distributed generation users is unfair. It would be more fair from their standpoint to pay only wholesale – the same rate they pay their regular suppliers. This is a strong argument, and while I personally benefit from the current arrangement, I would have no real moral basis for insisting on continuing to receive retail vs. wholesale compensation for the excess power my panels generate. However, it would be unfair for the coops to claim that they shouldn’t have to pay for that power at all since it is just as useful as the power they get from any other supplier. The use of our excess power allows them to avoid the massive cost of building new power plants. Please note that despite all their whining they have no problem at all with solar and wind power as long as they are the ones controlling it!

I would like to add my voice to those above opposed to allowing utilities to charge individual solar producers an "infrastructure fee". There are no distribution costs for the solar power I generate locally. I generate the most power during the peak demand times of hot summer days, reducing the need for the utility to purchase power to meet that peak. I have had solar panels on my roof for 6 years and have 2 electric cars and have already suffered the injustice of an extra fee to drive electric and do my part to reduce the outrageous societal costs of fossil fuel use. It is sad that the early adopters who have been encouraged by their government and their conscience to do the right thing for the common good, now can be freely trampled upon by the powers that be because of our small numbers and lack of political clout. I am encouraged that the PUC is still there to hear our voice and do the right thing.

I am concerned as a new solar energy provider my upfront costs will not pay back like I had planned. Can my utility just change the rules on a whim? We need the PUC to continue to monitor the need and fairness of any proposed changes. It seems like the utilities would like to sell solar power from their own solar gardens to "green" consumers at a premium rather than encourage rooftop production. Why gotbble up green space for solar arrays when we have under utilized rooftop?

I can see no reason for the PUC not to have control of whether or not electric customers are assessed fees for producing their own electricity. I really don't think such fees are necessary but I am even more certain that the utility companies should determine what they are.

Why are these fees being charged ? If there is no operational basis for the fee, then the fee should be dropped. I do not have solar panels, but this type of surprise cost is not good for the solar industry and green energy in general.

I argue that in the area of distributed electrical generation--an area in which our state should have great interest in promoting sustainable integration of distributed generation into the existing electrical grid--there should be statewide public oversight. We need the proper checks and balances to make certain that no particular utility, investor owned or co-op owned, takes unjustified negative action toward producers that may 1) upset a producer's investment in their equipment, 2) inhibit growth of renewable energy sources in MN, or 3) treats producers unjustly as compared to other non-producers. In a perfect world, state oversight is unnecessary. Local decisions made by utilities would be 100% justifiable. We all recognize, however, that individual actors or companies do not always "get it right." Those co-ops and utilities that are communicating with their constituents and making decisions supported by the evidence and their constituents should not fear state oversight. Removing all state oversight simply leaves opportunity for some folks to take advantage, whether intentional or unintentional. So, yes, the MPUC should scrutinize any fees being assessed by utilities on distributed generator producers because there exists a strong public interest in making certain development of renewable energy is done in a fair and sustainable manner throughout the state. Utilities do not need a blank check when it comes to assessment of fees, and instead there needs to be some mechanism for accountability to prevent or remedy abuse.

I recommend that the PUC should investigate the methods used to calculate solar fees in cases where utilities want to impose them, and in addition I believe fees on distributed solar producers should not be allowed at all.

We just commissioned our solar array yesterday, and MiEnergy at this time is supportive of our choice, without charging fees. i would be very upset if in the future they start charging us a fee, because we made our investment decisions taking that into account. Recognizing the imperative to increase solar generation, the federal tax credit was designed to encourage distributed generation. What possible rationale could utilities have to essentially charge fees to diminish that government policy and incentives to generate more solar?

I agree with the argument that we already do pay for our fair share of grid costs to the co-op, because we pay the co-op for the power we do use when the sun isn't shining. Then they pay us for the excess power we generate, and turn around and send it back out to their grid. No additional grid or administrative costs are involved at all.

Furthermore, our contribution to the co-op is that we provide them power at average prices at the peak usage times, for which they would otherwise be forced to go out and buy peaking power at very high prices. We provide a clearly defined benefit to them, which is demonstrated by other initiatives the co-op pursues. For example, they promote and pay for financial incentives for interruptible water heaters and furnaces to reduce peak usage. Their strong public outreach for voluntarily shifting usage away from the peak times proves that what we sell to them is valuable. Those programs save everyone one money, and our solar contribution does too. Any attempt to impose fees should take full account of the benefits we provide.

In addition, I believe our solar production now counts toward their renewable production requirements. Utilities are going gung ho for solar because it is now the cheapest source, and I sure hope they see us as partners, not competitors.

The PUC should stay involved in investigating the models and rationales used by any utilities trying impose solar fees. I believe you will find they are unjustified by facts.

I think that the PUC should review the method by which fees are determined. I don’t understand any rational for the argument that the utilities are harmed by net-metering of distributed solar producers.

We continue to purchase power from the utility as in the past. The only difference is that we are also producing power to sell to the utility. Due to the nature of photovoltaics, most of that power is produced at peak demand times – the same times that utilities complain about having to purchase peak energy at high cost. Their extensive promotion of conservation, especially during peak demand times, is answered in part by distributed solar producers. Seems like a win-win.

I share the concerns stated by others regarding their installation of arrays depending on the economics understood at the time. Changing the rules of the game after the fact is unfair – in addition to being unjustified.

Texas, Florida, Puerto Rico, the US Virgin Islands and all taxpayers are bearing the cost of ongoing investment in coal fired or natural gas electric plants due to intensification of hurricanes due to global warming and climate change . I took responsibility for my contribution to global warming by purchasing solar power for my home through a community solar garden with Rochester PU. Other people who led the way by purchasing panels for their homes should not be penalized unfairly for doing so. Yes, we need to maintain our electric grid and I agree with appropriate fees to do so, but we need a fair and transparent investigation to ensure that any charges are not in place to discourage people from pursuing the clean power we need if we are to save our planet for our children and grandchildren. I agree with the point made above by Mr. Nethercut that power produced by photovoltaics complements the power produced by utilities at times of greatest demand and that it is of benefit to utilities to have these distributed producers.

I believe that a modest grid connect fee is acceptable. However, some of the fees that coops are charging are excessive. In my humble opinion, we should be working to encourage RE. I understand that coops are having stress about their funding partly related to the increase of RE, but charging crazy fees is not good public policy.

Secondly, legislative attempts to quash PUC investigations into excessive fees is very bad policy. The PUC is supposed to represent rate-payers of the state, not producers.

What does Germany do? Do we want big energy poles in the skyline. No fees for solar and wind!

We Believe and Feel that all of the cooperative fees are “unreasonable” and are “inappropriate;” We have A Solar Array . We Believe that when we are feeding our energy back to the grid we are actually relieving stresses in sport on the grid and transformers ( The Transformers do not have to work as hard ) ,Less Load for that section of line .

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The fees should be eliminated Completely and ( PUC ) Should ALWAYS have the ability to to investigate the utility fees places on renewable energy both Wind and Solar and any other source of energy the future holds for Humanity .

Eric

The Minnesota PUC should continue to investigate any fees and their methods for arriving at and applying such fees placed on renewable energy and its producers as an essential role in keeping utility companies accountable to the public.

This oversight is particularly important when it applies to fees imposed (negotiated) on small producers, including those with residential solar panels. As stated by many of those making comments; the arguments by utility companies that residential solar power production creates additional costs, when many customers continue to pay fees and purchase power from the utilities and do not require additional infrastructure, need examination.

The recently added solar panels on my home generate the most power when the electrical demand is highest - sunny days mid-summer - reducing the demand on the utility to increase its power production. The utility company, as a result, may not need to build additional costly plants.

Our investement in solar panels was based on laws, regulations and incentives in place. Incentives have been created in recognition of the need to decrease the demand on energy generated by non-renewable sources. These include other incentives supported by utilities, such as off-peak power and cycling. To retroactively change the conditions on which renewable energy investments were made is a disincentive for those of us who have invested and others who may in the future.

Please continue your important role of oversight and investigation. Take all facts and factors into consideration when assessing requests to include, change or add fees. Consider continuing to incentivize these investments to encourage us all to invest in long-term solutions that are environmentally sound. Thank you.

We think that all of the cooperative fees are “unreasonable” and are “inappropriate;” The fees should be eliminated or substantially decreased in amount; and The fees should only apply to energy sold back to the grid. The rise and use of renewable energy should not be discouraged or priced out of only those who can afford it. In Florida people were without power for days however if many were to have solar, one those people would be greatly less impacted by the power outages and two power companies may be able to better coordinate their resources to places that have no power as those with solar would be self sufficient. People should not be punished or discouraged financially because of this and because a power company wants to hold onto an out of date business model.

all business transaction in these United States should negotiated between the buyer and the seller. in those cases where a monopoly is allowed, the business must be regulated. as consumers we have no protection without PUC oversight. even with PUC oversight I should not be required to subsidize a private enterprise even if they think they are operating for the public good in some fashion. i should only be charged a fair price for the commodity i am purchasing and if i choose to purchase less i should not be charged more. the power provider should reflect all their costs in there price per unit of energy i purchase. if the price goes beyond what i am willing to pay i should be allowed to disconnect. let's face it. technology is going to change. i seriously doubt that 100 years from now we will purchase power from a grid. everything will be fully distributed. just like turn of the century and into the early 1900's, we must let the buggy wip manufactures die a natural death. it is not the job of government to prop up these businesses. in the long run it is not in Minnesota's best interests to do so if we wish to remain competitive Please act in Minnesota 's best interest and do not cave into the self interest of the power companies. you are a consumer also. when new technology becomes your best interest you do not want regulators telling you that you must continue to buy the old. thank you

I believe that the cooperative fees are inappropriate. I installed solar panels at a significant cost and still have to pay the standard access fees, which is of course reasonable. In addition I pay $2.65 per month 'cost pf basic service - net metering' and and a variable charge -- $1.43 recently - for 'net metering grid access'. While the charges are currently not high, there is no guaranty that they would not be raised significantly if more users adopt solar. Frankly I cannot see why there should be any charge for solar beyond the basic service charge, since current flows equally well in either direction, and basic charges cover that cost. In any case case, I would certainly advocate for a role for the PUC in the setting of such charges.

This May we put in a solar array on our private residential property mainly because we want to support all endeavors for a clean renewable energy source. The results so far are so encouraging that we want our business and local municipality to work together on a re-development project that hopefully would encourage the use of clean energy for our building and community. How discouraging it is to hear that some municipatilities are putting surcharges on customers who choose to support clean renewable resources. We think these surcharges are unreasonable and inappropriate in light of all the postitives that are coming from the solar industry; at one time we had 6 personnell WORKING on this project. Multiply the short term benefits with the long term and we all benefit. Please eliminate all or any fees that would be imposed upon those who are willing to invest in our long term health and all the other benefits associated with Solar (Wind) energy production. Thank-you.

I also recommend that the PUC should investigate the methods used to calculate solar fees in cases where utilities want to impose them. Common sense tells us the we need to invest in renewable energy. . . . . what is the best way to promote renewable energy? It's bye making it more affordable and fair to people like me. Do the "right" thing ! I invested a lot of money in solar energy, I have no issues spending a little more to be able to self store my energy . . . . I have no problem cutting the cord completely from the grid !

The Public Utilities Commission has protected the electric consuming public for many years, and for that we are grateful. It is imperative that the PUC continue to investigate fees. More importantly, I would implore the PUC to eschew fees that "punish" distributed producers, such as those with solar or wind generation. These producers are helping to bring us a greener, sustainable future. In fact, I would advocate that these fees be reduced or eliminated, or at the most, applied to energy sold back to the utility. Higher fees will hinder increases in our carbon-free electric production, and applied retroactively on existing installations, greatly change the economics. This is unreasonable. Thank you for your consideration.

Last summer we installed a solar array on our residence and had an agreeable fee for selling back to our local Coop, but then the rules changed in early 2017 which put us in a battle with our Coop only to lose to the Omnibus bill passed earlier this year. Our Coop implemented a monthly flat fee AND a net metering fee based on the size of our array. These fees make spending more money ton install battery backups more and more appealing. At $50 a month just for solar (which is less then the $65 our Coop originally was going to do but they backed down a bit with our fight) it's still not making sense compared to the Flat Fees, Net Metering Fees and BuyBack fees charged by our neighboring Coops. I appreciate what the Minnesota Public Utility Commission's role was prior to this summers changes and I feel STRONGLY that the PUC needs to retain their power and oversight over the Electric Coops utilities. IF the Coops can't run a business like Xcel Energy does and reward behavior that is better for all of our futures then they shouldn't exist and we should have more Xcel customers and less Coop customers. Their fees are unreasonable and unjustifiable. After multiple attempts to gain justification we failed. They won't share their fee justification because they don't have to (quote directly from our Coop's Manager). Fees should only be charged to sales back to the grid and even those should be reasonable and justifiable. I am providing power to my neighbor who works from home during the day and is retired and home during the day when I'm producing energy. Supporting greener, sustainable options is something I will continue to advocate for. Thank you for pushing forward with what is RIGHT.

the solar fee is not to "allow renewable energy at a fair price", rather it is an attempt to "keep the monopoly alive; and slow the adoption of new technology". The utilities are a regulated monopoly; and although REAs have an elected board, that board has a defined conflict of interest fagainst supporting efficiency. The boards and REAs have said they see LED light bulbs and renewable energy as competition, rather than a means as their mission statement says " to get electrical service to the individual customer as efficiency as possible".

REAs have imposed monthly fees as high as $72/mo on solar array owners, monthly cell service phone fees of $25/month, and have recently been adding "unique hook up requirements and fees" since they now feel they have complete oversight. They have signed 30 year+ coal purchase contracts as recently as 2015, and some even have rules preventing customers with renewable enrgy (solar or wind) to be board members.

The PUC needs to get copies of the recent rules and fees adopted by the REAs, compile them, and then review the impact and intent of the rules. This list will make the intent of the REAs to dissuade member ownership and adoption of modern technology visible. it will also reinforce the need to have a complete study to justify the costs and benefits of renewable energy to the individual members.

Without oversight, history will repaet itself -- monopolies become fat and greedy and care for the monopoly...rather than the individual when they are not regulated - whether it is a government, meat packing indusrty or an electric coop.

The issue here is that electric utilities are trying to monopolize the electric power distribution system, and suppress individuals if they wish to become more self sufficient and produce their own power. It is also suppressing alternative energy. in essence since power companies haven't updated their power distribution systems, and with an ageing infrastructure and asking for people to limit power use and cycle A/C systems because of the demand on their resources. and when power goes down there is no repercussion to the electric company when peoples food goes bad or when someone needs that power for medical issues in their home. THe whole issue here is that the power company does not control individuals solar production so they cant profit off it as much so they penalize people for producing their own power when instead they should be buying it from the people at the same price they by from their corporate producers because they have issues generating enough power them selves

I am against any fees or lower than selling rate discounts being assessed to anyone who has solar or wind power being put back onto the grid! The power companies should never be able to decide these issues. That would be like the fox watching over the chicken coupe. There should always be an unbiased Public Utilities Commission overseeing these issues and listening to the general public's opinion. The electric companies just want to make money, not look ahead to what is best for the future advancement of our society. Luckily these type of decisions were not left up to the horse raiser's years ago, or we would all be still riding horses today instead of driving cars. There is no downside to solar. Our government's should do everything they can to promote solar power and not allow the electric companies to ever do anything to penalize and discourage the adoption of it.

I believe the electric companies are taking advantage of people. I have paid many years for my electricity. Now I want to invest in my retirement by putting money into solar instead of Money going out the door. It will be a big investment at first but should payout in the future. I don't feel it's fair for electric companies to charge you a fee to not use their service. I will still be paying for off peak and very cold winter days when solar is not so productive the electric company will be getting money from me again. I feel that they want to double dip. It's not ok. On another note. Why should I be penalized for wanting clean energy!!! This should be rewarded not discouraged. Thanks for listening Denise Esler A Concerned consumer

Electrical Cooperatives should not be allowed to charge customers for generating power on their property. What justification do Electrical Cooperatives cite for charging this fee? Any and all fees should be transparent and justified. The goal is and should always be to protect the consumer. I expect our governing bodies should be encouraging innovative and environmentally responsible solutions to the energy needs of our state. Solar and wind power (on the small and large scale) is increasing and it is shortsighted to think that they will not be an increasingly significant part of our energy portfolio.

I installed a solar large ground mount system this year at my property. I did this for a variety of reasons but it scares me to think that my utility company could charge me inappropriate fees without any oversight. After spending as much time, energy and money into a system that is green and is helping to curb peak demand over sunny hot summer days why should I be further penalized? I believe all cooperative fees should be eliminated or at minimum decreased with oversight to assure advantage isn't being taken by utilities to penalize homeowners.

While not a solar provider, but rather as a father, and for my children’s survival, I am seriously considering such a move. I believe we need to move off of fossil fuels immediately, and with every method possible.

Based upon the well documented, but not officially recognized, rapid loss of Arctic albedo, I believe we are operating with a much shorter time horizon than the establishment pundits would have us believe. Therefore we need every possible solution available right now, and cannot afford to wait for cooperatives to depreciate their prior investments.

I think fees charged to small solar providers are unreasonable and inappropriate, as such fees from an economic perspective act as disincentives to move toward a carbon free energy. Such fees currently used and proposed are exorbitant and regressive in nature, and seem not designed to recoup costs, but to make clean energy solutions non-affordable to small solar providers. These fees are in essence a reverse carbon tax.

If fees are required for the preservation continued maintenance of the energy grid, they should be specifically justified with exact producible data, and those maintenance costs be should first be born by sources that are detrimental to our society's longevity, ie fossil fuels, not toward those that can offer possible hope.

In summary, it is short sighted and counterproductive to disincentive solutions that provide a possible escape from our children's precarious future.

These utility companies are thieves!

Our government wants to reduce our carbon footprint and so are promoting solar. The utility companies are worried about their bottom line and only their bottom line, they could care less of the consumer or our foot print. They know they have a monopoly and they are not going to give it up. They have paid a lobbyist to get their way and our week politicians who want to reduce our carbon foot print listen to them. Do the right thing and kill these fees.

Keep in mind the utility companies will come up with another way to increase profits from people who have no choice or voice.

I'm amazed this issue has gotten this far... our so called leaders at the capital should have stop this madness in its tracks...and now we have to send letters to explain what common sence can't ...unbelievable !

Thank you.

I think that all of the cooperative fees are “unreasonable”. The fees should be eliminated or substantially decreased in amount. The fees should only apply to energy sold back to the grid. We are considering a solar system for our home and these fees may detour us.

I do not generate my own energy, but if I did it would be a travesty to have someone else (a company) arbitrarily charge fees without a fair and reasonable audit!

I think that all of the cooperative fees are unreasonable,and are inappropriate. The fees should be eliminated. or substantially decreased in the amount.

I am a customer of Goodhue Electric Coop and have a 7.1 kWh solar array installed in December 2016. When considering the purchase of the solar system the interconnectivity fee was $125 by the time the contract was signed it was raised to over $900. The coop couldn't or wouldn't explain the basis for this ridiculously huge fee increase. Since I don't pay a monthly fee for solar I think the coop wanted their money upfront to discourage solar installations and avoid issues with the PUC like this where the monthly fee might be changed or eliminated.

Upfront or monthly fees just to connect a solar installation to the grid are designed to discourage alternate energy and are not appropriate as we try to reduce our dependence on fossil fuels as energy sources. I want the PUC to require coops to justify the fees assessed to connect to the grid so customers know someone has deemed the fees appropriate and reasonable.

There is a reason the legislative majority in Minnesota tried to eliminate the PUC's oversight on connectivity fees in 2017 - to allow coops to charge whatever amount they wanted to customers with solar to connect to the grid. Thank goodness this bill did not pass. Coop customers need the independent oversight of the PUC to advocate for us against the abuse and greed of the coops.

I am planning to install a solar ground mount system at my property. Unreasonable fees levied would greatly discourage investments in this type of going green efforts. The fees should be appropriately assessed only on energy sold back to the grid.

The fees being imposed, or the option to impose these fee on Solar by some of the utilities, are simply an attempt to discourage and eliminate solar. The utilities are not putting the members first. The comments that solar negatively impacts those not on solar is inaccurate, as those with solar still pay fixed costs.

This mindset is both short sighted and will actually negatively impact the utilities as a whole. Members who install solar are become increasingly frustrated with the coops' anti-solar fees. As battery storage becomes more financially available, these same members will go off grid. Many are already doing this. The result will be: fewer members to share fixed costs.

I encourage that fair and unbiased oversight occurs, and we do not have the fox watching the hen house. We want to look to the future, not sustain the status quo.

Thank you for the opportunity to weigh in on this vital issue.

This bill would allow utilities to charge customers for additional "costs" of solar without considering the benefits--which utilities would be incentivized to discount. This will only lead to higher costs and encourage a valuation of costs without benefits, of which there are many benefits.

Solar needs to be treated the same as other conservation, such as energy efficiency, which gets rebates, not penalties. This distorts the market and unfairly marks out solar against competition. Any policy should have a clear value of the benefits, fairness to all technologies, and allow competition and freedom of choice for customers. Let the providers compete to win business.

I think that all of the cooperative fees are unreasonable and inappropriate. These fees should be eliminated or substantially decreased in amount. And, most importantly, fees should only apply to energy sold back to the grid.

I've arranged my comment into 7 sections with my references listed at the bottom.

1 - Utilities, Monopolies, Fees, and Regulation: Utilities supply basic needs and often are a monopoly for the area they serve. This can, and often is, done responsibly. However, while it is human nature to do what is "right" it is often challenged when what is right differs based on point of view. Utilities are like any other companies, and thus report to their shareholders or owners. while usually utilities are able to balance this well, it could be a conflict. When there is competition, it works as a forcing function to ensure customer's needs match those of the shareholders/owners. However, if there is a monopoly, in the case of a utility, regulation must be used to ensure that customer's interests are represented. Without regulation, a utility could charge fees for arbitrary reasons and without any justification. Many fees may be justified, but regulation is needed to ensure that they are and that they are presented in a transparent, justifiable, and accessible manner.

2 – Contracts and stability: Rooftop solar is a way to introduce stability and long term financial benefit. With the installation of rooftop solar, it largely frees or greatly lessens the impact of changing energy costs. In addition, rooftop solar is usually looked at in terms of how long it will pay for itself. This is usually not a short period of time. However, it is a finite time and usually well under 20 years. However, if new fees are introduced after an installation is put in, or if the terms of the contract are changed, this long term equation could be changed significantly. Making such changes after such a long term investment is made undermines the stability and long term benefit it was intended to bring. In general, a contract is a binding agreement, intended to provide assurance for such a long term investment. In many cases, this is much like changing retirement benefits after a person retires. While this sometimes must be done, the justification must be sound and regulation should ensure this.

3 - Cost of solar to utilities: Some utilities have instituted fees aimed at covering the added cost of infrastructure to enable adding distributed power generation such as solar. However, other utilities have not. A study by IEEE spectrum (1) stated that while most utility power grids are not designed for two-way power flow, most power grids required little or no additional cost to support up to at least 15.5% of the median daytime peak load. However, rooftop does lead to lower utility revenue, however, this does not seem like a justifiable reason for application of a fee. Finally, solar power generation, should help reduce peak power demand as solar peak generation is usually only a few hours before average Midwest peak demand (2)(3).

4 - Cost of carbon: The cost of carbon is beginning to be assessed and accounted for more often lately. This commission has established the cost of carbon to be between $9.05 and $43.06 per ton (4). The EPA established the cost as between $11 and $56 per ton, growing to $26 to $95 by 2050. A study by Stanford University placed the cost at $220 per ton (5). For this comment, I will use the “central” estimate from the EPA study of $37 per ton (6). According to the US Energy Information Administration (EIA), the electric power industry in Minnesota released 33.4 million tons of CO2 in 2015(7). Also according to the EIA, 1846 Gwh were produced from coal which supplied 39% of Minnesota's total energy(8): 4.7Twh. At $37 per ton, this is $1.2B or divided by Minnesota's total energy output: $263 per Mwh. So, for every Mwh generated by rooftop solar, our society saves $263. Further, as rooftop solar production increases, it will likely displace production from sources like coal instead of sources like wind, nuclear, or other less “dirty” sources. If there is a fee added, it should account for the cost of carbon. If not at $37 per ton, somewhere between $9 and $43 seems like a good start.

5 - Cost of pollution: 55 thousand premature deaths in the United States are attributed to air pollution each year (9). The primary cause of air pollutants is from coal (9). Minnesota derives 39% of our energy from coal (8). According to a report by the Minnesota Pollution Control Agency in 2002, over 85% of the sulfur dioxide and 31% of the nitrogen oxides released in Minnesota are from coal and gas combustion (10). This commission established the lower end cost of NOx at $2467 per ton and SO2 at $4543 per ton (4). The EIA listed Minnesota emissions from the electric power industry at 29.7 thousand tons of SO2, and 30.9 thousand tons of NOx(7). Assuming the lower bounds of the cost of these pollutants, this is a total cost of $221M. This comes out to $45 per Mwh and at the high end of the cost estimates, it is $120 per Mwh.

6 – My utility company: I am fortunate that my utility company is Rochester Public Utilities. They do a terrific job on public education and outreach around energy conservation and encourage rooftop solar as well as other renewable power sources. Not only have they not implemented any fees targeting rooftop solar, but they encourage it through rebates and education. With my 10KW solar installation, I generate about 12Mwh per year. From what I listed above, this saves society about $3696 each year. Because I am fortunate to have a utility company which values this, it saves me around $1200 each year as well. I do not wish to impose more regulatory burden on any utilities, however, we all collectively pay in climate change and pollution for non-renewable derived energy. So, any fees which target this huge societal savings should see some extra scrutiny. If they are justified, so be it. Stories like the now infamous Amendment 1 in Florida sadly highlight that not every utility has pure intentions. Thus oversight and regulation are the only assurance that the public can count on.

7 – Summary: I support investigation of fees which target solar. I think that there are likely cases where the fees or portions of the fees are justified. I also suspect that there are cases where the fees are not justified. Any fees should be transparent and justifiable. Any fee should also account for the benefits provided by solar, both directly (efficiency, peak load, etc) and socially. Ideally, investigations of these fees will be as non-invasive as possible. However, where they require changes, customers and the public count on the government to ensure that things are fair and right for everyone involved.

References: 1 - https://spectrum.ieee.org/energywise/energy/policy/calculating-the-full-cost-of-electricity-rooftop-solar-pv 2 - https://netdensity.net/tag/solar/ 3 - https://www.eia.gov/beta/realtime_grid/#/summary/demand?end=20160802&start=20160702&regions=04 4 - http://www.lawofrenewableenergy.com/2017/07/articles/energy-policy/mn-puc-establishes-new-environmental-costs-for-use-in-all-proceedings/ 5 - https://msande.stanford.edu/news/estimated-social-cost-climate-change-not-accurate-stanford-experts-say 6 - http://costofcarbon.org/faq 7 - https://www.eia.gov/state/data.php?sid=MN#Environment 8 - https://www.eia.gov/state/?sid=MN#tabs-4 9 - https://www.citylab.com/environment/2015/09/the-enormous-social-cost-of-cheap-coal/405730/ 10 - https://www.pca.state.mn.us/sites/default/files/airwater.pdf

I think the PUC has to monitor this closely. I have heard of too many examples where the fees charged by a utility just don't make sense. If they can be justified--fine. Personally, I don't understand why there should be any fees. The solar industry is providing jobs, helping the environment ,etc.-- all good things. Why do anything that would distract from that--no fees.

My family installed a solar array in 2014 with the intention that we would generate enough electricity to power nearly all of our needs. We did this because of our concerns over air pollution and climate change that are impacted in no small part by fossil fuel-derived power. We feel that we have made a significant financial investment that benefits not only our own family, but our community at large given that we all breathe the same air and deal with the same impacts of climate change. Yet, we feel that there is a concerted effort on the part of the electric cooperatives to maintain the fossil fuel status quo and penalize those of us who have chosen to install solar facilities.

As Mr. Johnson stated in a comment submitted earlier with which we fully agree: “utilities are asking for fees on qualifying facilities because they say there is a cost shift that exists because of net metering, and those customers aren't paying their fair share for grid maintenance. The problem is they haven't proven that a cost shift actually exists.”

We understand that we need to share in the cost of maintaining power lines, cooperative staff salaries, etc. but we don’t want fees to be set without PUC oversight that should ensure they be reasonable and not arbitrarily determined. Furthermore, we should not have to pay for fees or services that we don’t need or use. We are already considerably frustrated that we no longer have the option of taking any complaints to the PUC for resolution, but rather have to go through our cooperative’s board (surely this is a conflict of interest!).

We fully support the PUC’s ability to investigate how utilities are calculating the fees they charge to solar array owners. We feel confident that this is the only way to ensure that any fees are fair, consistent, and reflect the actual costs incurred by the cooperatives and utilities to have arrays like ours connected to their grid. While we think that it would be nice if we were actually rewarded by the electric industry from time to time for investing our own money (thus saving them some of the trouble) in electricity production that causes less harm to the environment and to people, we’re not asking here for special consideration or recompense. We’re starting to feel as if we should just throw our hands in the air and go off the grid entirely. Why are we having to fight so hard and so often for doing a good thing?!

I do not agree with the fee, nor the fee method for the DG producers.

The fee is the same for the entire cooperative network, thus they have sidestepped the review process to see if there is justification for any fee, by implementing a boiler plate option. The boiler plate option also does not accurately depict if an individual user will have issue with the utility due to the method of how it is calculated. Taking only the face plate of the panels is a very arbitrary way to show the "harm" done by a DG facility to the cooperative.

Numerous studies have touted benefits for DG, but those factors have been left out of the method of fee calculation. Why should a school or dairy farmer pay a fee if they are not contributing to the grid with their small solar facility.

The fee has been a way to discourage DG resources by cooperative members and encourage them to utilize the cooperative facilities that are connected to the grid in the same manner.

As a solar installer, this has caused a reduction in rural DG projects due to the fact that a cooperative member has no certainty with how the utility will treat them. The rules say that the utility has full discretion to change their fee at any time. There is no recourse for a DG facility if their are future change, thus causing people to not put in their own facilities.

Also the small percentage of DG in general almost makes this a none issue, and adding fees in that case is just a preventative method to future DG growth.

The current solar fees being imposed by Coops are grossly high. There is no uncertainty about the fact that they are a big wet blanket for customer-owned (DG) solar. We see this first hand every day in our solar business. When Coop members find out the magnitude of this fee, they very often walk away from the idea of solar. They are baffled that their Coop is charging this high fee.
What is really at stake is the question of whether the State of Minnesota has an interest in allowing and fostering solar DG. If we think the status quo of central power plants is just fine, then we should allow these fees and anything else the utility companies want to impose. If, on the other hand, we want to encourage solar DG, and all the positive things that come from on-site, renewable energy, we need to find a different model. We need to eliminate or dramatically reduces these fees.
Studies have shown that almost ½ of our nation’s energy could theoretically be supplied by solar DG. If we continue to move in this direction, we would gradually transform our state into a model of grid-stabilizing, simple, long lasting, home grown, clean energy. This direction leads to job growth, long term money savings, and countless other advantages. We have the choice to go in this direction or put the brakes on. What would our children and grandchildren want us to do?
There have been a significant number of studies done across the United States that ask the question of whether increased solar DG has a negative impact on Utilities. These studies consider all positive and negative impacts. Examples of positive impacts include 1) adding capacity to the grid, at no cost to the utility, 2) reducing transmission cost, 3) offsetting some peak daytime demand, and 4) environmental compliance considerations. In nearly every study, the calculated value of solar energy is at or above current retail value, and shown to be of no detriment to the utility company bottom line. The current solar fees assume absolutely no positive contribution from solar energy. Is this really a fairly designed fee? How much thought and calculation really went into these fees? There may be a need for some give and take between utilities and would-be DG owners, but the current, punishing fees are definitely not part of any give and take discussion.