4.c) D Hebert Comments on SolarSherri,
In general, there appears to be no size break for the solar gardens. Solar farms will be much larger in size
(>10MW) due to the efficiencies needed to make them cash flow. Solar gardens can be much smaller.
Many Ordinances have a size break around 100kW with fewer restrictions for solar gardens under
100kW (40kW is a size allowed under one of the Minnesota solar incentive programs).
Section 2 - Amends Section 2.5 related to Agriculture Preserves District for accessory uses to agriculture.
Depending on the interpretation of “accessory” it’s not clear how that work. A solar farm is for
wholesale and may not be interpreted as “accessory” to the agriculture. The same interpretation could
also be used for solar gardens unless the subscribers to the solar gardens are all agriculture operations.
Section 3(2) – This section may benefit from a size requirement. A solar garden <100kW takes up much
less space than a typical 500kW or 1MW solar garden and would benefit from less intensive permit
application process.
Section 3(D) – In many instances the local permit and the interconnection agreement process are
running concurrently. Requiring the interconnection agreement prior to applying for the CUP could
cause problems due to time delays. Language could be amended to note the CUP is contingent upon
interconnection agreement with the local utility.
Section 3(E) –Is a Natural Resources Assessment something specific to the city’s current Ordinance? If
not, the use of environmental assessment worksheet (EAW) may be more consistent with state rules.
Section 3(3)(A) – You are probably aware the Minnesota Public Utilities Commission will be making a
determination on the interpretation of MN Statutes 216B.164 on June 25th. It was wise to just reference
the Statute rather than taking on that issue.
Section 3(3)(B) – A 40 kW solar garden only needs about ½ an acre. Requiring 5 acres of land for all solar
gardens could be considered restrictive. One option is to identify the land needed based on the size of
the proposed system.
Section 3(3)(G) – Screening exceptions could be considered if the required screening impacts the
operations of the solar system.
Section 3(3)(J) – interconnection can occur at other than a substation. I would suggest language “or the
distance to a substation or other point of interconnection…”
Section 3(3)(L) – Depending on the surface area coverage requirements in the Ordinance this could be
very restrictive.
Please contact me if you have any questions. Thank you for providing an opportunity for comment.
Duane
507-961-3350