Interconnection Agreement Requirement

Based on subdivision 5(b)(1), Commerce requires a signed interconnection agreement but does not require that a project enter through a particular interconnection portal. Xcel Energy handles the technical review required to secure an Interconnection Agreement as described in MNDIP. To become a solar garden, a Subscriber Organization then applies with a project, that meets all programmatic requirements, to Commerce. If approved, a Subscriber Organization then works with Xcel to continue the process toward project construction and setting up subscribers at the appropriate bill compensation rates.

Eligible LMI Households

LMI-Accessible Community Solar Gardens must reserve at least 30% of capacity for LMI Residential Subscribers. Subscriber Organizations may qualify households as income-eligible using one of the three pathways below. All LMI Residential Subscribers must complete the Attestation of Income-Based Eligibility and submit it to their Subscriber Organization, along with supporting documentation.

• Pathway A: Verify that the household participates in an approved categorical program, as listed in Commerce's ECO program guidance.
• Pathway B: Verify that the household’s total annual income is at or below 150% of the area median income, as reported in the household’s most recently filed IRS Form 1040.
• Pathway C: If the household is unable to provide a Form 1040, verify that the household meets income eligibility requirements through alternative documentation of the household's income sources, as specified in program guidance materials. 

Key Documents

• Subscriber Attestation of Income-Based Eligibility for LMI-Accessible CSG Program
• Subscriber Organization Instructions for Income Verification Procedures
• Energy Conservation and Optimization (ECO) Program Guidance providing the list of programs approved for categorical eligibility, updated December 2023 
• 2025 Minnesota Area Median Income Look-Up Table referencing HUD income levels by county and household size, updated April 2025
• Program Definitions
• Initial Subscriber Mix Report Template
• Annual Subscriber Report
• Subscriber Organization Report – Year 1
• Subscriber Organization Report – Years 2-25

Reporting

Subscriber Organizations must submit the following reports (templates are in the Key Documents section above):

• Initial Subscriber Mix Report: Due within 30 days of the project beginning to generate bill credits for its subscribers.
• CSG Subscriber Report:  Due annually on June 1st for the previous calendar year, including the first partial year of operation. (Must be signed and notarized.)
• CSG Subscriber Organization Report:
  o Year 1: Due on June 1st for the previous calendar year for the first partial year of
     operation. (Must be signed.)
  o Years 2-25: Due on June 1st for the previous calendar year for full years 2-25.
     (Must be signed and notarized).

Consumer Protections

The new LMI-Accessible CSG Program includes consumer protections that prohibit community solar garden developers or their marketing representatives from:

• checking the credit score or credit history of a new or existing residential subscriber
• charging an exit fee to a residential subscriber
• enrolling a subscriber without the subscriber's prior, voluntary consent
• engaging in misleading or deceptive conduct, and
• making false or misleading representations.

Additional Key Features

Key features include:

• At least 30% of each project’s energy capacity must be subscribed to by low- and moderate-income households.
• At least 55% of each project’s energy capacity must be subscribed to low- and moderate-income households, affordable housing providers, and public interest subscribers (including schools, faith communities, and non-profits).
• Subscribers can be from anywhere in Xcel Energy’s Minnesota service territory. The LMI-Accessible CSG Program does not require that subscribers be in the same or an adjacent county to the project.
• Individual gardens may be sized up to 5 MW.
• The total annual capacity of new gardens is capped. In 2024, Commerce can approve no more than 100 MW.
• The bill credit rates for subscribers will be calculated by customer class based on a percentage of the annually updated average retail electric rates (A50 rates). The final approved rates approved by the Minnesota Public Utilities Commission will be published in the new CSG docket: 23-335.

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