After a four-year process, the Minnesota Department of Commerce’s Energy Environmental Review and Analysis (EERA) unit is set to publish new requirements for decommissioning plans on solar and wind facilities in the coming months. With efforts driven by the Minnesota Public Utilities Commission, the guidelines will define what constitutes an acceptable decommissioning plan for Minnesota wind and solar sites.
While a decommissioning plan is already required on applications for Minnesota wind and solar facility permits, the agencies have better articulated the required content and level of detail. We recommend that facility operators revisit their decommissioning plans to confirm they meet the new guidelines and to better understand and plan for total potential decommissioning costs.
Impact to new and existing Minnesota wind and solar facilities
Existing wind and solar facilities will need to have adequate decommissioning plans as defined by the guidance and subject to EERA review on a five-year rolling review schedule. Potential necessary updates to existing plans may involve updating the description of decommissioning tasks and timing, cost estimate, financial surety, and more. Additionally, the plans will need to address regulatory requirements that may apply during decommissioning activities and waste disposal. New facilities will be required to include a draft decommissioning plan following the same guidance and subject to public review during the state permitting process.
Barr has been following the development of the draft guidance and helping existing facilities preemptively update their decommissioning plans to a level of detail that EERA confirmed was satisfactory. We are confident that we can continue to assist clients in developing or updating plans that will comply with the new guidelines with limited or no agency comments. Barr’s experts can also help facilities understand the technical components needed for these plans and how to navigate potential permitting requirements.
To learn more about how Barr can help you prepare an adequate decommissioning plan for a new facility or update your existing plans to meet the new requirements, contact Carl Gustafson or Sarah Johnson.