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Determining best practices in program design <br />• Solar ownership models. More research is needed to enumerate the possible models for solar <br />development, considering land ownership, solar system ownership, Renewable Energy Credit <br />(REC) ownership, and financing arrangements. Research is needed to understand the risks and <br />benefits of each, and how these can be structured to align with Minnesota's economic, <br />environmental, and equity goals. <br />• Environmental and social considerations. The MPCA could consider incorporating aspects that <br />contribute to the environment and communities, particularly environmental justice <br />communities and climate -vulnerable populations. For example: <br />o Equity and environmental justice considerations. Program design must take into <br />account who benefits from solar development at CLP sites and who bears the costs and <br />risks. Use of an equity policy review tool could help the MPCA and partner agencies <br />develop a program that considers equity and environmental justice in its processes and <br />results and incorporates ways to address environmental, social, and public health needs. <br />o Pollinator habitat and solar development. Executive Order 19-28 aimed at restoring <br />pollinator health in Minnesota directs the MPCA to "manage closed landfills under its <br />supervision to create, protect, and enhance pollinator habitat." Pollinator habitat is <br />commonly implemented in conjunction with solar projects in Minnesota. The Board of <br />Soil and Water Resources (BWSR) has a Habitat Friendly Solar program that offers <br />guidance and encourages those implementing solar to meet program standards. <br />Pollinator habitat has been implemented in brightfield projects in other states, including <br />Massachusetts. The MPCA could seek guidance from BWSR and other states on <br />specifications and implementation. More study is needed to understand how pollinator <br />habitat could lower or increase costs associated with a solar project. <br />Understanding economics of solar development on landfills <br />Preliminary interconnection study for top sites. The interconnection to a local <br />transmission/distribution system is a large cost component to solar development and <br />uncertainty around what would be required on a site -by -site basis makes it difficult to <br />determine the viability of solar development. <br />• Hard -to -develop sites and policies and incentives that would make these developable. State <br />policy and incentive programs have proven very valuable in Minnesota, in other states, and at <br />the federal level in encouraging renewable energy development. Some landfill sites may require <br />additional incentives and policies to facilitate development. Many ideas were raised during the <br />study, however, these need to be vetted. For example: <br />o Virtual net metering. Virtual net metering or a similar policy for grid -tied projects could <br />assist in overcoming financial barriers related to developing solar on landfills. Virtual net <br />metering is a mechanism allowing energy customers to credit kilowatt-hours from one <br />meter to another. Many CLP sites are large enough to support solar systems that can <br />produce many megawatts of electricity. Most of those sites, however, do not have need <br />for the power onsite. These sites will be connected to the grid and can provide power to <br />nearby communities or to other grid connected users. <br />o Brownfield adder. In Minnesota, there is one policy that most closely approximates net <br />metering, the Community Solar Gardens program (CSG). These projects, however, are <br />limited to one MW, and at this threshold are not cost effective for a developer. Projects <br />with one MW cap would not make use of many potential acres of available land. A <br />solution could be to include a "brownfield adder" to the CSG rules allowing for <br />development of projects greater than one MW. <br />13 <br />