Studies and Reports > 2025 Biennial Report >Transmission Planning Zones

8.0 Renewable Energy Standards

8.1  Introduction

Minn. Stat. § 216B.2425, subd. 7, states that in the Biennial Report the utilities shall address necessary transmission upgrades to support development of renewable energy resources required to meet the objectives set forth under Minn. Stat. § 216B.1691 (formerly the Renewable Energy Standards). In its May 30, 2008, Order approving the 2007 Biennial Report and Renewable Energy Standards Report, the Commission said, “Future biennial transmission projects reports shall incorporate, and address transmission issues related to meeting the standards and milestones of the new renewable energy standards enacted at Minn. Laws 2007, ch. 3.” By 2020, the utilities had largely met the current Renewable Energy Standards, and many had additionally announced voluntary renewable or clean energy standards that exceeded the statutory objectives. As a result, in its 2020 Order approving the 2019 Report, the Commission said the 2021 Report should include content similar to the 2019 Report, along with new information regarding additional clean-energy goals and related transmission needs. The 2021 Biennial Report included this information in Chapter 9 of that report.

In 2023, the Minnesota Legislature amended the objectives set forth in Minn. Stat. § 216B.1691 to include additional milestones for renewable energy as well as creating new carbon-free energy standards (CFS) (see 2023 Minn. Laws Ch. 7). The statutory objectives now include:

*See Minn. Stat. § 216B.1691, subd. 2f for additional detail relevant to the solar energy standards. For example, the 10% solar energy target by 2030 is established as a goal, rather than a requirement, and the legislation includes several other targets for smaller-scale solar energy.

In this Report, similar to prior reports, the utilities are reporting on their best estimates for the amounts of renewable generation required in future years and the efforts under way to ensure adequate transmission will be available to transmit that energy to the necessary market areas. A Gap Analysis is provided to illustrate the amount of renewable generation already available and the amounts required in the future to meet the standard. The narrative in this chapter is similar in many respects to the narrative and explanations provided in the 2023 Report, but all figures and charts and tables have been updated to reflect current legislation. As discussed more fully below, a gap analysis has not been provided for the carbon-free energy standards, as the Commission is continuing to evaluate and provide guidance on how this new standard will be implemented.

8.2  Reporting Utilities

It should be pointed out, as was done in previous reports, the utilities required to submit the Biennial Transmission Projects Report are not identical to those required to meet the Renewable Energy Standards. The information in this chapter reflects the work of all the utilities required to meet RES milestones, regardless of whether they own transmission lines and are required to participate in the Biennial Report. A list of those utilities participating in the Biennial Transmission Projects Report can be found in Chapter 2.0. The utilities participating in this part of the 2025 Biennial Report on renewable energy are the following.

Investor-owned Utilities

Minnesota Power
Northern States Power Company d/b/a Xcel Energy

Otter Tail Power Company

Generation and Transmission Cooperative Electric Associations

Basin Electric Power Cooperative Dairyland Power Cooperative
East River Electric Power Cooperative Great River Energy
L&O Power Cooperative Minnkota Power Cooperative

Municipal Power Agencies

Central Minnesota Municipal Power Agency

Minnesota Municipal Power Agency
Southern Minnesota Municipal Power Agency

Rochester Public Utilities
Western Minnesota Municipal Power Agency/Missouri River Energy Services

Power District

Heartland Consumers Power District

8.4  Compliance Summary

Minnesota utilities continue to increase the size and expand the diversity of their renewable portfolios. The table provided in the introduction details the RES and SES obligations Minnesota utilities are working to achieve. Overall, Minnesota utilities have a 2025 collective obligation of 24.5% RES and 1.5% SES, as a percentage of applicable retail sales. The most recent reporting is summarized by the Minnesota Department of Commerce in Docket No. E999/PR-24-12, dated January 15, 2025. All utilities have satisfied their respective compliance requirements and expect to continue to achieve and maintain all compliance requirements in the future. All utilities continue to plan for the addition of increased renewable generation. The utilities have provided a Gap Analysis regarding compliance with the upcoming 2025 Solar Energy Standard in Section 8.6 as well.

8.4  Gap Analysis

A Gap Analysis is an estimate of how many more megawatts of renewable generating capacity a utility expects it will require beyond that which is presently available to obtain the required amount of renewable energy. A Gap Analysis is not an exercise intended to verify the validity of forecasted energy sales and associated capacity needs. It is done for transmission planning purposes only. This is the tenth time the utilities have prepared a Gap Analysis; a Gap Analysis was also prepared for the 2007, 2009, 2011, 2013, 2015, 2017, 2019, 2021, and 2023 Biennial Reports.

8.5  Base Capacity and RES Forecast

The chart below presents a system-wide overview of existing capacity in 2025 (used as a base figure throughout the various milestone periods) and forecasted renewable capacity requirements to meet Minnesota RES as well as non-Minnesota renewable energy standards (RES). Each utility provided its own forecast of Minnesota RES and non-Minnesota RES renewable energy standards and converted such estimates into capacity based on their own mix of renewable resources (e.g., wind, biomass, hydropower, solar) using the most appropriate capacity factors unique to their specific generating resources. It is important to note that the data presented in this Report represents MTO members’ efforts to report on metrics that are part of a regulatory construct that is evolving because of the 2023 legislation. The Commission is currently in the process of issuing guidance to electric utilities on implementation of the RES, SES and CFS requirements in Docket Nos. E999/CI-23-151²¹ and E999/CI-24-352²². Accordingly, MTO utilities remain in the planning stages related to compliance with the Minnesota Legislature’s 2023 amendments.²³ To the extent that there are relevant updates informing implementation of these standards, MTO utilities are committed to coordinating with stakeholders if additional information is requested.

The following Table 1 shows a more specific breakdown of each utility’s Minnesota RES and non- Minnesota RES needed capacity forecast.

Note:
1. Majority of the non-MN RES is from voluntary renewable energy objectives in North and South Dakota.
2-1. Generation (MW) forecasts are from the 2024-2040 IRP approved by the Commission in April 2025.
2-2. MW values for the entire NSP System are multiplied by NSPM (MN) I/A allocation factor for MN RES and non-MN RES values (73% for MN and 27% for non-MN).
2-3. 2025 Biennial Report capacity and resource production (energy) forecasts were based on the 2020-2034 IRP Alternate Preferred Plan (filed 6/2021, approved 4/2022).

8.5.1  RES Capacity Acquired and Net RES Need

The following chart represents the total renewable capacity system-wide that will be acquired and lost between 2027 and 2035, as well as the total Minnesota RES and non-Minnesota RES needs between 2027 and 2035. Capacity losses are attributable to the expiration of various power purchase agreements for renewable energy generation, and these losses are implicitly incorporated into the datasets provided.

As can be seen, the Minnesota RES utilities have sufficient capacity acquired to meet the Minnesota RES needs through 2035. When considering the RES needs, including other jurisdictions outside of Minnesota, the Minnesota RES utilities have enough capacity to meet RES needs beyond 2027. In addition, some utilities with less than sufficient capacity to meet the Minnesota RES need may use renewable energy credits to fulfill their requirement.

Focusing back on just Minnesota RES needs, Table 2 below provides a more specific breakdown of each utility’s forecast.

Note:
1. Capacity acquired includes resources active as of 2025 and planned resources.
2. Acquired MW are non-generic resources and Legislated CSG (both 2016-2024 and 2024+) from the 2024-2040 IRP Settlement “Resource Annual” tab of the EnCompass Output (EO) file (DG Solar MW is NOT included for SES).

Note that the “Needed MW MN RES” bar in the bar chart in this section represents the total level of RES megawatts required (or need) in Minnesota. Conversely, the column in Table 2 labeled “MN RES Net” represents the additional RES capacity presently identified to meet RES megawatts required. To the extent there is a shortfall, or “gap,” between MN RES megawatts required and the additional RES capacity identified points to the likelihood that some utilities will seek additional renewable capacity. Alternatively, some utilities may use renewable energy credits to fulfill their RES requirements.

8.6  Solar Energy Standard

In 2013, the Minnesota Legislature established a separate solar standard for public utilities, effective by the end of 2020.²⁴ That statute requires public utilities subject to the SES to report to the Commission on July 1, 2014, and each July thereafter, on progress towards achieving the 1.5 percent solar energy standard.

Chapter 8 of the Biennial Report discusses utilities’ compliance with Minnesota Renewable Energy Standards. Additionally, a brief summary regarding the status of compliance with the 2027 Solar Energy Standard (SES) is included below. Utilities file annual reports to demonstrate compliance with the SES on June 1 of each year as required by the statute and directed by the Commission.

Table 3 shows a more specific breakdown of each utility’s Minnesota SES and non-Minnesota SES megawatts required capacity forecast.

Note:
1-1. Generation (MW) forecasts are from the 2024-2040 IRP approved by MN PUC in April 2025
1-2. SES and CFS MW values are considered to be 100% of the NSP System total for MN because there is no SES or CFS requirement in WI, SD or ND (MI does have a CFS but it accounts for less than 1% of the NSP System total retail MWh)
1-3. 2023 Biennial Report capacity and resource production (energy) forecasts were based on the 2020-2034 IRP Alternate Preferred Plan (filed 6/2021, approved 4/2022).
Note: SES is the MN Solar Energy Standard which will require additional solar beyond the MN RES.

Additionally, Table 4 below provides SES Utilities’ planned level of solar capacity additions.

Note:
* Acquired MW are non-generic resources and Legislated CSG (both 2016-2024 and 2024+) from the 2024-2040 IRP Settlement “Resource Annual” tab of the EnCompass Output (EO) file (DG Solar MW is NOT included for SES)

8.7  Carbon-Free Standard

Note:
1. No other states in BEPC’s territory have a Carbon Free Standard
2-1. Generation (MW) forecasts are from the 2024-2040 IRP approved by MN PUC in April 2025 2-2. CFS forecast includes nuclear as the Monticello and Prairie Island extensions were approved as part of the 2024-2040 IRP
2-3. SES and CFS MW values are considered to be 100% of the NSP System total for MN because there is no SES or CFS requirement in WI, SD or ND (MI does have a CFS but it accounts for less than 1% of the NSP System total retail MWh)

Note:
1. Capacity acquired includes resources active as of 2025 and planned resources.
2. Acquired MW are non-generic resources and Legislated CSG (both 2016-2024 and 2024+) from the 2024-2040 IRP Settlement “Resource Annual” tab of the EnCompass Output (EO) file (DG Solar MW is NOT included for SES)

8.8  Gap Analysis Summary

21 The Commission has issued orders on implementing the changes to Minn. Stat. § 216B.1691 on December 6, 2023, April 12, 2024, November 7, 2024, August 7, 2025, and September 16, 2025.

22 See November 7, 2024 Order Initiating New Docket and Clarifying “Environmental Justice Area”.

23 Because MTO utilities have either just received or are waiting for additional guidance for how to implement the CFS, this metric is not captured in this Report. MTO utilities will provide this information in the next Biennial report and will work with stakeholders if additional information in required in this proceeding.

24 Minn. Laws 2013, Ch. 85, § 3, codified at Minn. Stat. § 216B.1691, subd. 2f (Solar Energy Standard or SES).