Community Solar Garden (CSG) program update; StadlerMerl�ora�durr� public V�orks Departmen�
To: Honorab(e Mayor and Members of fhe City Coun i(
From: St��en J. Stadler, Public Works Director `� � -
Copy: Mike Marnson, City Manager
Date: June �, 2015
Subject: Community Solar Garden (CSG} program update
We curr�ntly have CSG proposals #rom SolarCi�y, SunShare and SunEdisan. Also, the
MetropoEitan Counc�! is partn�ring with N�nnepin County -� others in iss�ing a Requesfi for
Proposals {RFP) for CSG Subscription Agreements. Accordingly, fihere is the opportunity ta
work coflaboratively with them by participating ir� subscriptions that become available �ia that
process. They are in�ending to publish the RFP onlabou� July 7, 2�15. They ha�e as�Ced that
cities provide letters of intent by July 24 if they'd like to participate.
There is some uncertainty regar�ing fihe CSG program as the Public Utilities Commissior� (PUC)
is scheduled ta deli�erate an June 25 on a challenge by Xce! Energy regarding the coupling and
co-locating af salar gardens {PUC DocKet #'[ 3�867}. The ariginal iegislafian r�stricted a solar
garden to 1 MW in size/capacity. Haweuer, th� PUC subsequently ruied that "common coupfing"
should be allowed. Thus, several deve[opers are proposing coupling of many 1 MW garder�s
that are co-located resulting in �ery large arrays of solar panels of 10+ MW capacities. Many
developers have already spent miflio�s posifianing themseEves to enter the CSG pragram with
these large array solar gardens based on tne PUC guidance to-dafe.
Staff will preser�t a summary of our in-hand proposals and would like to discuss our optians for
selecting a developer on our own vs. su�scribing to CSG energy �ia the Met Council's RFP
initiati�e.
A�tached are: 'i ) some general CSG infarmational sheets; 2) an informational sheet on the Met
Council-led effort to a[low local go��rnm�n�s to procure energy subscriptions from fihe single
RFP; 3) a description of fihe lottery process that wifl be used to obfiain subscripfiions ti�rough the
collaborative RFP, and: 4) a sample letter of infient fio par�icipate in the collaborafive RFP
subscriptions.
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Commun�ty So�ar Gardens are centra�ty-located solar
photo�olfiaic (PV) systems �hafi pro�ide electricity to
par�kitipating subscribers, Could it work #or you?
Are you interested in going solar but unable to do so on your own? Perhaps yau li�e in an
apartment, har►e a shaded roof at home, or don`t have spa�e at your organization. Naw you can jain a
community solar garden installed near you!
Community solar gardens are a simple way to go solar You purcha5e an up-front subscription,
then soak �n the rays (much of Minnesofia is as sunny as places lifce Housfion, TX and Talia�assee, FL).
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The amount of electricity you use each year helps you decide how much sotar to get.
Your sotar garden subscription can couer up to 120% of your usage. A typica! Minnesota home uses
80� kilowatt-�ours (kV11h) a manth, �temember: a more efficient home means more cost-effecti�e solar!
Eleetricity Use
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So�ar Subscript�on
Utility B���
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A typical MN horne � 4 kW of solar could Solar power procluc#ion
uses SOD kWh each monfih, � pro�ide half the electricity is shown and credited on
or 9,600 kWh each year � used by the typical MN home � the subscriber's utifity bill
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As a st�bscriber, you don'� have to worry about e�ery detaiL See below far key players.
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5IIBSCRIB�RS: individual
en�ities who get solar power
UT[LITY: electricity pro�ider °`�
where solar garden is installed
D�'V�LOPER: primary group
organizing the solar garden
SITE ASSES50R: expert that
studies solar garden location
H05T SITE: location where
solar garden is instal[ed
INSTALLER: expert that
installs the solar garden
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�� See more details about utility programs and rul�s for community solar gardens
on our website at SolarGardens.MnCERTs.or #c�Wh_O.
FINANCE: sources of
financing forthe project
OUTREACH PARTNERS:
groups that find subscribers
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continues wi�h ques�ic�ns
u can ask operators as
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Comrnunity Solar Gardens (also �alled Community Solar and Community-Shared Solar) ar� cenfiraliy-
located solar p�otovoltaic {PV} systems that produce electricity for parkicipating su�scribers. They are a
way for people in Minnesofia fio bene�Fifi from solar PV systems without i�sfialling their owr� stand,alone
project. Programs vary by �atility in Minnesota. Many cooperative utility customers can subscribe to a
projec�t owr�ed by their local utiiity. C�stomers served by Xc�l Er�ergy can participate in projects affered
by pri�ate Community Solar G'arden Operators. ` �
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To help prospecti�e subscriber5 decide which project might be right, CERTs, Minnesofa Department of
Commerce, Minnesota S�lar Energy Indus�ry Associatior�, and Mir�nesota Renewabie Energy Society have
develo�aed a do�ument outlining what any Subscriber Agreernent should address and highlighting fihe
ques�ion5 t�ai can be asfced up �Front �ta ensure a clear undersfianding of fihe subscription ar�d its terms.
Before subscribing to any particular project, all subscribers
should ask for and re�iew th� operafior's suiascriber agreement.
A�I subscriber agreements sho�ld address elements included in
the Community Solar Garder� Subscriber �isc�osure Checklist
(see link at left). Additional questions that subscribers can ask
are on the pages to came.
• How long haue yo� been in business? How mar�y installatians ha�e yau dane? �o you ha�� reference5 I can
cantact?
� Will I be able to �isit the system? How can I show I'm participafiing?
• Wifl I be able to see online how much my subscription is producing �or the life ofi my subscription
agreerr�ent?
• How will 1 receive updates abaut the project? Haw will I b� notified i# something goes wrong?
• Who handles my s�abscription o�er tirr�e? Who do I tall if E ha�e questions?
• When do I need to sign a subscriber agreement? What kinci of paperwork will i need to fill out?
• What types af PV module5 will be us�d in the project? Fiow do they differ �From other panels on the market,
and why did you choose them?
• What will you do to ensure that the panels won't become shaded by another structure in the future?
Subscribers will be compensated for their share of the Community Solar Garden system's output �ia a credit on
their utility bill. The credit wilE be made on a dollar per [ci[owatt hour produced ($/kWh) basis for most utilities.
Subscribers in Xce! Energy's s�r�ice te.�ritory will �e compensated at the Applicable Re��ail Ra��i(ARR) for the
durafiion of their subscription; which .rnay last up to �5 years. i'he ARR is calcuiated by Xcel �nQrgy by diviciing the
previous year's re�en�es by sales for �ach customer class, th� ARR wilf be updated e�ery year. 5u€�scribers shau[d
verify their 5er�ice cfass (i.e., residenti�l ser�ice, small general ser�ice, or general ser�ice�) prio'� to suf�scribing. The
current ARRs plus renewable energy credit (REC) paymen�s by Community Solar Garden size are listed below.
Most operators make
assumptions that the ARR will
chang� o�er time when fihey
estimate a subscriber's potential
ret�rn on in�estm�nt. 7he retail
rate trends over the past 2Q ta
25 years are a good rule of
thumb to ground truth these
numbers. An assessment by Xce�
Energy indicafies thafi �he ARRs
across all customer classes ha�e increased an a�erage af 2.b to 2.9 percen� per year 5ince 199Z.
2015 Xcel Energy Applicable Retail Rates + REC Payments {$IkWh)
T�e Minnesota Public Utilities Comm�ssion has jurisdiction aver Commur�ity 5olar Garden rates for Xcel Energy and
o�her in��stor-owned utiliti�s. The Comrriission may change the community solar garden subscription rates for
future projects, but community solar gardens forming under the current ARR struct�re will recei�e t�e ARRs in
place at fhe time the solar energy i5 generated �or the life of the comrnunity solar garden.
RECs stand5 for Renewabfe �nergy Credits, which re�resent the renewable attributes of solar and other renewab[e
energy generatian. �peratars in Xcel �nergy's Community Solar Garden program may elect to sel! the R�Cs to the
utility.ln the case o# Xcel Energy customer5, the compensation will b� paid dirertly ta the subscriber based on the
5ize of th� garden as described in the table above. lf the RECs are sold, suf�sct-ibers cannot market themselves a5
"solar powered," as the green attributes for subscrip�ion are assigned to the owner of the RECs. This is consistent
with Green-E best practices to avoid double counting {see link in More Resources section).
�' The General S�rvic� cus�omer class is also referred to as the Demand-Met�red rustomer tlass.
To partici�ate in a project, a potential subscriber must purchase a subscription. There are two primary subscription
models: pay upfront and pay�as-you-go. I� a pay upfrant madel a subsCriber purchases a sui�scription �or a
onetime fee that co�ers the Iife of the agreement, Th� subscriber re�aps th� subscription benefits (utility bill credits
for energy produced) for the length of their sub5cription. In a pay-as-you�go model a subscriber pays in
installments, which are often I�ased on the Cammunity Solar Garden's produc#ion attributed to their subxriptian.
Whiche�er route you choase, you will not ac�ually own soiar panels, you wiff own a subscription for the solar
energy sysfem`s production. Xcel fnergy customers can sutascribe to as little as �0� watts of solar capacity or up ta
120% of their a�erage annual energy use.
Subscr[pfiion Size and Prite Questions
� To parfiicipate, do i pay an upfront subscrip�tiort fe�, a monthly subscription fee, ar a combination thereof?
o What is the subscripfiion price? Is it an up-front price or a monthly charge? Is the subscri�tion price all
indusl�e, or are there additlonal administra�ive ar maintenance fees that may be charged?
• Appraximately how much energy will the system praduce, and what partion o# my energy use might !
expect my subscription ta offse# annually? 6ased on your subscrip�ion rates, w�at would it cost me to cover
ali af my electri�ity use?
• What happens if my subscriptian`s energy produ�tion exceeds my energy bill during the year? What happens
if it exceeds 1 z0% af my energy us�� Who benefits from my subscription's excess production?
Additional Subscription Terms Questions
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• What is the term of my svbscription (i.e., how long does it lasfi; under w�at condifiions is there an exit
per�alty}?` , _
• What happens if'I move,-vvant to cancel, or die? How will my share�s be transferred? Is it my responsibility to
sell it to someone else? - -�
• How muc� wilf ! be paid for rny subscriptlon at th� tlme ofi trans#er or cancella�ion?
• What are the tax implications of my subscription?
• What happer�s �o my su6scription if the operator goes out of business ar sells tMe garden?
• Describe fihe production and maintenance warrantie5 induded in th� 5ubscription agreement.
• What happens i�the operator is unable to maintain artd a�erate the garden? What are my remedies as a
subscr�ber?
• W�at happens if the garden is perpetually under-producing? 1Nhat are my remedies as a subscriber?
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Comnnunity Solar Gardens (also called Community Solar and Community-
Shared Solar) are centrally-located solar PV systems that provide
electricity to participating suhscriber�. They are a new and exciting way
for p�ople in Minnesota ta benefit from solar photovoltaic (PV} systems
wEth�uf harr'rng ta install #heir own stand-a[one project.
This document features [cey ques�E'rons comrnr�nity graups, aften working
on behalf of multiple subscribers, could ask to learn �nore about
Community Solar Garden de►reiopers and operators.
COMPANY & APPROACH
COMMUNITY
S�LAR
CARDENS
• Haw long have you been in I�usiness? How many installations have you done? bo you have references we
can contact?
• Vllha� do you see as your strategic ad�aniage in this new Minnesoia market?
� Are you in camp[iance with lacal, state, ancf federal laws and regulations, including �ax, ownership, and
securi�ies laws and regulations?
• Who will develop, own, finance, ins�alf, operate, and rr�aintain the sys�em? Do you ha�e a set of
contractiors you work with for these tasks? po you plan to do them yourself?
• Will your process be o�en to an RFP with the oppartunity for IacaE contraetors to be involved?
• Is the installer who wili be performing the work NABCEP certified?
YOUft MOD�L ,
� Is your model a pre-paid plan or a pay-as-you-go plan �or a combination)?
e If pay-as-you-go, is there a Iong-term subscription? Penalty for early termination?
• If pre-paid, are ihere times when a subscriber might be asked to pay additicanal charges?
• Wha� risl<s and �enefits do you see with your model? �
e Da you ha�e a plan for how �o engage lower income customers in your projects?
� What does your model [oal< like for less than 1� subscribers?
� What ro[es do subscribers have in the garden's financial health and future? Will there be an ar�n�aal
meeting of subscri�ers to discuss �inancial reports and activities? Voting righ�s of th� subscribers?
e Will the operator issue annual reports to subscribers and/or the comrr�unity? If sa, what wil! be includeef in
the reports?
e What is the form of the guarantee that the prajecf will be intact far the duration vf the subscription?
• Will I get my maney back if any�hing happens to yo€�r company?
EQUIPMENT & MAIN7ENANCE
• What types of modules are being specified? Are they high qualiiy frorn a reputable company?
• bescribe your production and maintenance warranties.
• What is the Eifetime of the equipment?
� What levels ar�d types of insurance do you carry?
� Who will be the entity to conduct the maintenance on the sys�em? How have you budgeted for those costs
in your business model?
� Do you carry ser�ice interruption insurance? What do I get back frorr� a service irtterruption?
� ls afl maintenance included in the initial subscription price?
PARTNERS & SITE SELECTION
+ Are you open to working with hosC sites and community partners to tailor your projects?
• Can community groups participate in site selectian?
• What are yaur expectations of roles and responsibi[ities of the community part�ers?
• Describe costs, both community partner costs and capital costs for the project.
• Wha will handle the majority of the mari<eting—yau, community partners, ar a combo?
• Do you have a�reference for host sites in terms af the type af entity and/or location?
�, Do you have a prefer�nce for ground-mounted �s. rooftop installations?
FOR SUBSCRIBERS
• Checklist of items that should be included in a Community Salar Garden subscriber agreemer��:
http://mncerts.or�/cs�-disclosu re
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• Questions that prospecti�e subscribers can ask o�F operators about their Corr�munity Solar Garden prajects:
http://m ncerts.or�/cs�-su bscribers
l.earn more from the C[ean Energy Resource Teams (CERTs} in our Guide to Community Solar Gardens, which
includes a list of available programs; frequently aslced questions, and other resources at
h ttp://rr� ncerts. o r�/s af a r�a rd ens.
SOURCES:
+ Questions for Hiring a Contractor by Minnesota Department af Commerce
htt : mn. av commerce ener ima es Nirin -Renewable-Ener -lnstaller. df
• Michigan Community Solar Gardens Guidebook by Great La[ces Renewable Energy Association
www.michi�an.�a�/documents/�dcd/Michi�an Communitv Solar Guideboak 437888 7.pdf
• Camrr�unity Sofar �arden Guide by National Renewa�le Energy Laboratory
www. n rel.�a�/docs/fyllosti/49930.pdf
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Community Solar Subscriber Collaborative:
An Oppor�unity for IVletro Area Locat Governments
Description: Community Solar Gardens create a new apporkunity for local gouernment entities ta
support c(ean energy, sa�e on energy bills for public buildings and plants, and hedge against the
future price �olatility of electricity.
The Community 5olar Subscriber Col[aborati�e is a jaint effart for Metro area local governments to
procure sofar garden subscriptions from a single RFP process. By working together, go�ernment
�ntities gain an econorny of scale in the solicitation process (red�cing the adminisfirative burden to
�et de�elopers} and in attracti�en�ss to developers, resulting in bett�r pricing and subscription
terms.
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The pracess below describes how the RFP will be issued and how loca! governments are able to
procure solar garden subscriptions through this initiati�e.
Process:
1. Letter of Intent: Interested lacal governmerits sign a non-binding letter of intent declaring
their intent ta subscri�e, and attach to the letter a list of the premises and loads they are
interested in subscribing. Interested entities must be willing to subscribe ta at least 200kW
of solar praduction {equivalent to 48 , Q kWh annual consumption). ��{�����
2. Joint Powers Agreement (Optionat): Local go�ernments rec�uiring a Joint Powers
Agreement (JPA) to be s�gned according to their pracurement policies may sign a
community solar garden subscriptionTspecific JPA.
3. Request for Proposals; The Metropolitan Council wil! publish an RFP for d�velopers to
prauicte community solar garden subscriptions ta the local ga�ernments that signed a Letter
of Intent. Developers' proposals will include a list of the counties they can pro�ide
subscriptions to and how rr�uch capacity they ha�e available for each county.
4. Derreloper Selection: A#eam af governmental participants from the core steering group
and major subscribers, selected by the Council, will evaluate proposals recei�ed, ranking
#hem according ta qualifications, experience, and price.
5. Lot#ery Process: Lacal governments that signed a Let#er of Intent will be entered into a
Iotiery for avai[able gardens. Local go�ernments drawn in the lattery will have the first right
of refusal to subscribe fo the garden(s) for which #hey are drawn.
6. Execute Subscription Agreement(s): In order to secure its subscription(s), each local
ga�ernment entity will need to execute its vwn Subscription Agreement(s} wiih the
de�eloper it is purchasing a subscription frorn.
7. Garden Appro�al Process: There is currently a long queue for community solar gardens
to he appro�ed by Xcel energy before they can be built. This process is expected to take
15-21 weeks after the initial application is submitted and may be longer as this is a new
program in Minnesota and the number af garden applications has been much higher than
expected.
8. Garden Construction: Canstruction af each garden can take from 1 to 6 months or ionger
depending on the permitting and process at the host site.
9. Energy Produced; Bill Credits Assigned: Once the garden is approved and buil�, it will
begin producing solar energy, deli�ered to Xcel and credited ta subscribing entities in the
farm af $I�CWh bill credits.
Timeline:
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RFP Published by Met Cnuncil Expected July 7th, 2015
Letters of Intent due to Mei Council Due July 24th, 2015
Joint Pawers Agreemen#s signed (if deemed r�ecessary by th
participating entities) Due July 24 , 2015
PrOpOS�IS DU� AuguSt 3rd, 2015
Selection and Ranking of Pr�posals August 2415
Lottery Process August-September 2015
�x�cute Subscription Agreements October 2015
Contacfi for Questions:
Trevar Drake
Project Coordinator
Great Plains Institute
612-767-7291
tdrak�C���isd. ��t.
Download documents, read frequent questions, and find rnore informafian online at
www.mncerts.orglsolargardenslcollaborative
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Lo�tery Process
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Prvicess I- The Se)ec�"ron Tr�am: , , ; _
Siep 1: Reviews and rejects any proposafs where they ha�e concerns about the work getting
done in a quality and timefy manner.
St�p 2: Ranks Solar Garden proposals per RFP seiection criteria (this says that price is at
least equal #a the qualitative factors). However, thase praposals ihat includ� a request for
material de�iation in subscription legal terms will be ranked afteral! those requesting r�o
changes and fhose w�ere the changes are deemed immateriai to the selection team.
Step 1: Determine and assign a number of "#icke�s" per entity for all the load in the entity's
Letker of Intent in a cour�ty eligible based on the location of the propased garden, wi�ere each
ticket represenfs a u�scription load of 20% of one garden (approximately 200kW solar
-- ca�aci� or 4, Q kWh annual consumption). Each enfity may also have 1 ticket equivalent
��`" � to a subscripfion load less than 20%, but greater than 10°10 of one garden (Approximately 100-
��¢�� ���� 200kW or 24fl,000-480,040 kWh).
Step 2: Randomly pull the first ticket and;
a) Check that the entity repr�sented on the ticket has laad that is eligible for the garden
by location. if e(igibfe, proceed to step "b." If not eligible, return ticket to the pot.
b) Offer this entify subscription to the garden at up to 20% participation.
a. Note that each entity may reject within 15 business days if price is toa high or
contracf terms changes are not acceptable; rejecting participation will be
treated for this allocation assignment as if fulfiilled, that is, this ticket wili not
be put back in the pot for the next garden's allocation but would be able to b�
alfocated after all o#her tickets have been pulled {see Process lII, Step 3).
Step 3: Cantinue pulling tickets in this random manner until 1 DO% of the subscriptions are
allocated, considering:
a) If some selected entities are at less than 20% par�icipation, the other sefected
entities, in the order drawn, will gst the option to increase fheir par#icipation.
Step 4: I#, after all selected entifies have had the opportunity to increase #heir participation and
100°/a participation is not met, GPI wifl pufl addifional tickets ta include additiona! entiiies. Each
new enti#y pu!(ed will be allowed up to the lessor of 40% or the amount needed to fil! up the
garden.
Step 5: If no additional entities wan# to complete the one garden's subscriptians, the deueloper
will be allowed to: a) withdraw the proposaf ar b) honor those subscriptions accepted by our
entities, and take responsibility for and solicii other subscribers to fill ouf the subscriptians.
Step 6: Take all tickets that have been set aside {that is not assigned) and put them back into
the communai pot
Step i: Return to step 1 of this �rocess with the next best ranked proposal (and do this until a[I
solar garden propvsals are allotted, if entity commitments allaw that).
Step 1: Determine all rejections of affers �y entities. A contingent response or no respanse
after 15 business days will be .cor�sidered a rejection±
5tep 2; Offer reassignment to thnse entities in the last ranked proposal(s) as needed to fill any
ha6es in subscriptions created by the rejections in higher ranked proposals, in the same order
as the ticket pulls that were assigned. For instance, if rejections make 8 subscriptions availabie
at higher levels, tF�e last 8 tickets assigned will be offered to mo�e up (in the orcEer they were in)
to t�e 8 holes, but if #hey accept the reassignment they must be able and willing to f�t the hole
(that is, if it's a 50kw hole, #hen that's the only amount allawed, and if they were at 200kw then
the ather 150kw stays assigned where it was originally).
Step 3: Per Step 2b, entities that rejected initial offers will be abie to subscribe to any
remaining gardens in the arder they were initially drawn.
Ste� 4: If there are disputes or adjustments needecf, GPI is allowed ta make reassignments as
necessary to mast fu61y fill up the gardens, taking accnunt of the best interests of the
governmental subscribers at its reasonable discretion.
Date
Mr.lason Willett
Metropalitan Councif
En�ironmental Ser�ices
390 Narth Robert Street
St, Paul, MN 55101
jason.willett@metc.state.mn.us
RE: Go�ernmental 5olar Subscriber Callaborati�e
Dear Mr. Willett:
We understand the Metropolitan Cour�c
business(es? and get proposal(s) to dev�e
other interested government entities ca
ntends to issue a Request for,;Proposals to find
�',cammunity solar gardens to which #he Council and
,ubscribe.
[ENiITY NAME] belie�es the sacietal, financial and �nvironmental value of Community Solar
Gardens (CSGsj warrants our''pul'suin� th,is opportunity in conjunction wiih other local
government entities. Our staff ha�'�'evi�wed �ariaus rr�aterials and resaurces regarding CSGs,
and has re�iewed the electrical load� ofi;,our facilities. !n order to participate in a
collaborati�e and expeditious mann�r, we,agree to abicfe by the Me#ropolitan Council's
procur�rt��T����processes, to the a�llntment prac�ss between go�ernments, ta the evaluation
,.
panel rn��ke-up, and understand that we wifl not be able to negotiate {but just accept or
declin�j �I�ese oppor�unities. We agree ta not hold the Metropqlitan Councii, the other
par#�cipatir�g gi�vernments or the Great Plains Institute liable for their good faith efforts in
this program.
Overalf, we have co����cled that there is �alue in this program and therefore, we intend #o
participate in subscriptions that become a�ailable as part of the Metropolitan Counci!'s
Request for Pr'aposals for CSG Subscription Agreements slated to occur in July, 2015.
Attached �o this letter is a list of facifities we intend to invof�e in the purchase of Community
Salar Garden subscriptions - if the price and terrr�s of the subscriptian agreements meet our
gaals and objecti�es. In total, this is a commitment not to exceed [SIJM OF Al.L.
SUBSCRIPTION �OADSJ kWh.
ihis letter does not bind [�N7k7Y NAME] to sign any specific subscription agreements or
o�therwise commit financial resources ta a community salar garden projeet. Nar does
submitting this letter to the Metropolitar� Cour�cil pre�ent [ENTITY NAME] fram soliciting for
C5G subscriptions alone ar with other entities. The in�tent of this letter is to clearly state
[EN71TY NAME]'s desire ta subscribe to one or rnore community solar gardens depenclent on
the terms and cor�ditions of the praposals received as a r�sult of the Request for Propasals for
Community Safar Garden Subscrrptron Agreements being issued by the M�tropolitan Council in
June or July, 2015.
We encourage the Metropolitan Council to continue to take a feadership role on CSG projects
so that [ENTITY NAME] along with other local go�ernment entit�es can partici'pate in the
financially responsible and en�ironmentally preferable=attributes o# sal�r energy and share
thase benefi#s with its residents and businesses.
Together, by leveraging the strength o�' lacal go�err�ment ent�ti��.�,nd the
Metropolitan Council, we can reduce carbon emissions and improu:� the;�
for metra area residents and busines
Sincerely,
[FULL NAME OF HIGH RANKING STA��.OR
[FULL TITLE]
3 I
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OFFICIAL]
�rtise of the
ll quality af life