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In any event, successive regulatory tightening and tax increases have already created a “reasonably effective deterrent” to market entry.

There is a second complication. The relentless flow of Commission statements may eventually make enforcement less damaging rather than more.

“The regulatory failures are unhelpful but perhaps the sheer number and regularity of them has made them less remarkable, such that they become ‘wallpaper’,” Waugh says.

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Minnesota Valley, a small cooperative utility serving parts of western Minnesota, claimed the 2.5-megawatt array vastly exceeded the 40-kilowatt limit it sets for members. The utility threatened to cut off electricity to the casino if the tribal nation turned the system on.

The ruling means the array—which has sat unused for a year and a half despite being fully built—can finally be switched on once an independent engineer completes a safety review and the tribe resolves any resulting technical recommendations.

The PUC ordered the utility to continue supplying electricity to the casino provided the solar system remains behind the meter—meaning it does not export power onto the wider grid.