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Published on August 26th, 2013 | by Zachary Shahan

6

Why Sunrun Is For Net Metering, Not Feed-in Tariffs Or Value Of Solar Tariffs

August 26th, 2013 by Zachary Shahan
 

[Important Update] Also see: Tax Threat To Solar Homeowners With Feed-in Tariffs or Value Of Solar Tariffs

It’s well known that feed-in tariffs have supported most solar power growth across the world. It’s also well known that very few places in the US offer a solar feed-in tariff (FiT). I was recently contacted by someone who had started a petition pushing for a solar feed-in tariff in California. I went ahead and published a quick article on the petition over on CleanTechnica.

Quite frankly, aside from any commentary on the details of the proposed policy, I am a firm believer in the need for more citizen action supporting the growth of solar power. We need more people to email, call, and talk in person with their political representatives to push for more solar power. We need more people to get motivated about this topic, as citizens were about civil rights, women’s rights, and the need to ban harmful pesticides. But, yes, the details of the policies we push for are of course important, and we should focus our efforts on the strongest solar policies. In California (and other places in the US), is a FiT really the best way to go?

Interestingly, following the above-mentioned article, the folks at Sunrun, “the nation’s #1 home solar company,” reached out to me to have a discussion about why they aren’t a fan of the petition, nor a push for feed-in tariffs in the US in general. Rather, they’d like to see a continued focus on net metering.

Of course, hearing Sunrun’s take on this was appreciated. And I was intrigued that it was so opposed to a FiT push that it would reach out about that. Is there really any chance a California-wide FiT could be passed? (I didn’t think so.) How would a FiT policy threaten Sunrun’s business? I got to speak with Sunrun’s Director of Government Affairs, Walker Wright, and Sunrun’s Manager of Public Policy, Susan Wise, about these matters.

The main opposition to feed-in tariffs was expressed in the initial email from Susan: “There are a few things about them — mainly that they put a ceiling on solar deployment and allow monopoly utilities to maintain control over how consumers get electricity.”

Of course, with every policy, there is room for manipulation. The devil is in the details, as they say. In the case of the US, and even the state of California, the concern seemed to be that the management of such details is so distributed that it’s impractical, and that FiTs are so open to highjacking and manipulation by the utility industry and its allies that they seem like more of a risk than another helpful solar incentive.

Susan and Walter see net metering as the best and most fair policy for both homeowners and the utility. Net metering policies are in place almost all across the US and were set up in a decent way. Regarding the petition we shared, the main concern was that “it distracts from what’s really needed and what works, which is the net metering policy that is in place and successful today, and should remain in place,” as Susan wrote. “It’s the cornerstone policy for solar growth and provides a critical framework that gives consumers fair compensation (full retail credit) for the solar they put back on the grid. NEM is what will allow solar adoption and the solar economy to continue to expand.”

The claim that it gives fair compensation is actually debatable. Utilities debate it, trying to reduce the amount they pay to solar homeowners, but much more realistically, it has been shown to be too low by researchers who have calculated the myriad social, environmental, and grid costs and benefits that solar provides. I brought up the potential growth of Value of Solar Tariffs (VOSTs), which are supposed to more intricately calculate “fair compensation.” Sunrun’s concern, as with feed-in tariffs, is that the assumptions used to determine VOSTs would largely be set by anti-solar utilities, and the value would be less than what simple net metering policies offer. Indeed, I did note that the VOST used in Austin is considerably less comprehensive in its inclusion of solar benefits than the one that came out of a report for the Mid-Atlantic Solar Energy Industries Association (MSEIA) and the Pennsylvania Solar Energy Industries Association (PASEIA).

So, as with FiTs, the concern was that they would stifle solar growth. Here’s a full response from Sunrun:

  • Net metering is the only path forward if the objective is to give solar deployment a chance to meet is technical potential.

  • The VOST concept fundamentally moves rooftop solar from a behind the meter policy (BTM) to an in front of the meter policy (FTM) - an incredibly important distinction.

  • Moving rooftop solar in front of the meter gives the utility the ability to control/throttle future market development.  They will use this to limit the market because, at the end of the day, rooftop resources will compete with their central station resources.  They could either say “we don’t need any more generation resources – we’ve got plenty because our coal plants have years of life left on them….so we are only going to allow X MW of VOST to interconnect this year,” or they could drastically reduce the value of the tariff to undermine future deployment and maximize the financial performance of their generation portfolio.

  • In contrast, NEM is a BTM (behind the meter) policy.  The only two throttles on solar deployment in a BTM policy context are 1) consumer choice/demand (we know this to be incredibly strong for solar) and 2) technical integration in terms of interconnecting with the grid, and we are far away from even having that discussion at this point.

To further support the home solar company’s perspective on these important policy issues, Susan connected me with the Managing Director from Renewable Analytics, Dirk Morbitzer, who is a solar industry veteran and a native of Germany (where the country’s world-leading solar FiT basically grew solar power into the fast-growing, disruptive powerhouse that it is today).

Dirk offered up this extensive comment:

I think that Feed-in-Tariffs make sense for markets that have relatively low system output (in kWh per kW) and where utility electricity prices are low.

In markets that have high electricity prices (such as California) and a high kWh system output (as almost all of the US has compared to Germany) than Net Metering has significant advantages.

As regions in the US with high PV system output also have a high usage of Air Conditioning systems, there is a strong correlation between peak power usage (air condition) and peak solar production. This correlation provides a significant benefit to the utility companies that would otherwise have to contract (expensive) peak power generation.

Distributed Power Generation allows to dimension the grid infrastructure differently — depending on the power usage profiles of different customer groups.

Net Energy Metering also avoids the issue of overbuilding system sizes — something Germany has experienced over the last years.

With a FIT every system owner maximizes profits — e.g. build the maximum system size.

With annualized NEM, the system size is limited to the maximum energy use of that building — e.g. there is no incentive to build a system with maximum output, but size the system to the actual energy need.

The argument that NEM customers are not paying their share of the grid is a very interesting one — as NEM customers in most cases still buy some electricity from the grid — just a (significantly) reduced volume. They behave as if they conserve a large part of the previously used electricity.

The argument that anyone with a PV system should pay a grid connection or grid usage fee is the same as claiming that anyone who conserves water should pay a water system connection fee (base fee) as a penalty for conserving water.

Some very interesting comments. One in particular stands out for its similarity to a criticism of FiTs and VOSTs put forward by Susan above. This quote I’m referring to: “With annualized NEM, the system size is limited to the maximum energy use of that building.” In other words, just like a cap could be set on FiTs and VOSTs, a cap has already been set on NEM. People who go solar who might very well want to maximize the use of their roof and put as many solar panels on it as possible, can’t do so if that would exceed the maximum energy use of that building.

Yes, there are drawbacks to that maximization of rooftop space, but given the urgency and speed with which we must deploy solar power to help deal with the global warming crisis we face, I think the need far outweighs any downsides. That extra solar power from people who have already decided to go solar might be considerable. And, to reiterate, this is yet again an instance of the details being set up in a way as to limit rooftop solar power growth.

All in all, what’s my take on all of this?

1- I don’t think a statewide FiT really has a chance of being passed, and certainly not a nationwide one. But I’m still supportive of anyone who wants to push for FiTs. As I said above, we need people to get more heavily involved in pushing for strong solar policies. If FiTs get some people excited and active, that’s a great step forward. Perhaps from there they will also adopt or switch to a focus on other policies, like net metering. Also, as much as it is indeed true that the details of a FiT policy could make it worse than net metering, the details could also make it stronger.

Taking a US example, LA’s feed-in tariff stimulated a flood of solar power applications. The incentives were clearly attractive. Unfortunately, a low cap will result in a much smaller number of projects being built than were submitted. Will many of the solar projects that don’t get awarded a FiT contract end up getting built anyway? Will the disappointment or the hope for program expansion kill the projects or put them in permanent limbo? Would the LA solar market be better off without this policy? It’s hard to know, but this does give some backing to Sunrun’s FiT concerns.

2- Since Sunrun is more involved in the solar legislation arena in California, I’d probably defer to its expertise on the desire for net metering over a FiT. Though, I also wonder if perhaps a FiT would threaten the solar leasing model that brings Sunrun most of its customers. The current policies are a great support to the solar leasing model. A statewide FiT? Maybe not…

3- As a bit of an idealist, I’d love to see VOST policies adopted that really pay solar owners for the net value of the electricity they produce. As a bit of a realist, I know that will never happen in the majority of locations, that getting enough support and involvement from US citizens and nonprofits to make that happen is highly unlikely in the majority of cities, counties, and states. So, while a great policy model in theory, perhaps VOSTs are best left on the research table.

4- Net metering definitely warrants continued support, expansion, and strengthening. I am happy to see Sunrun so involved in that side of things… of course, it’s more than logical for the company to be so involved — net metering is a huge, non-subsidy support to the solar industry.

If you’ve made it through this entire article, I assume you are an informed and thoughtful solar power lover. What are your thoughts on the topics above?

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About the Author

is the director of CleanTechnica, the most popular cleantech-focused website in the world, and Planetsave, a world-leading green and science news site. He has been covering green news of various sorts since 2008, and he has been especially focused on solar energy, electric vehicles, and wind energy since 2009. Aside from his work on CleanTechnica and Planetsave, he's the founder and director of Solar Love, EV Obsession, and Bikocity. To connect with Zach on some of your favorite social networks, go to ZacharyShahan.com and click on the relevant buttons.



  • Paul Zubrinich

    Hey Zach,
    What a great article! One issue that I was surprised wasn’t explored was how FITs played out in the southern European markets, most notably Italy and Spain. They produced very pronounced boom and bust cycles, which shattered investor confidence. This was also followed up by retroactive reductions (i.e. a punishment for those who made good investment decisions), which in turn has made investors fearful of government promises that are too good to be true. I think Germany’s monthly regressions based on growth target “corridors” and France’s quarterly reductions are safer because they can readjust the prices as the market shifts. However, Italy’s Conto Energia was dangerous because it was not regularly adjusted, and as the price of solar plummeted there were huge unforeseen rushes of installations. The same thing happened in Victoria, Australia where I’m from. The FIT there dropped from AU$0.60 to AU$0.25 in one staggering step. Clearly they should have planned for more regular and gradual reductions, rather than an approach akin to shock therapy. Some analysts predict a similar impending bust cycle for the Japanese market. We will see.
    In the pre-grid parity era, FITs proved to be the most effective mechanism to drive massive capacities, although the next decade will surely see solar penetrate the market purely on cost. If this is coupled with more realistic taxes on GHG emissions, uptake will surely skyrocket and FITs will become a thing of the past, hopefully along with fossil-fuelled electricity.
    Cheers, Paul Zubrinich

    • http://zacharyshahan.com/ Zachary Shahan

      Thanks for the extensive comment! I know you are a policy buff. :D I guess we just figured this was known well enough… but maybe not actually a safe assumption. Thanks for continuing the conversation! FiTs definitely get idealized a bit here, without discussion of specifics.

  • azaredaniel

    Why cant a Voting, Tax paying Homeowner, be allowed to participate in the Ca. State mandate of 33% Renewable Energy by 2020, with out third party leasing ? or using our Desert Eco-Systems ?

    In California alone, third-party solar installations account for two-thirds of the residential PV market, which exceeded non-residential for the first time.

    “Examples of how they have been “slowing the process” are:

    (1) Renewable portfolio standards (RPS) which create de facto caps on the deployment of renewable energies. (The Germans don’t have any RPSs. Their FIT program is open ended, the more capacity, the merrier!)

    (2) Net-metering caps. Most states only allow a small percentage of one to two percent of peak load to be net-metered. There are exceptions however. Colorado, for example, has no aggregate capacity limit. However, most states do. Net-metering, therefore, will certainly “hold back the clean energy tide.”.

    (3) The third party leasing rent-to-own outfits like Sungevity, but more importantly, Solarcity, which just went public with an IPO, fight tooth and nail to protect scarce capacity carveouts (from the state RPSs) so as to bolster their chosen business models as the expense of all others. The same goes for the utility-scale folks. The in-fighting, due in part to the small de facto caps of the RPSs, have significantly slowed the deployment of renewables in the U.S.

    (4) Most importantly is how we connect distributed renewable energies to the grid in the U.S., the most salient difference between the American net-metering program and the German feed-in tariff is that net-metering is *retail* energy whereas the FIT is *wholesale* energy. Thus, net-metering does little more than offset onsite loads and in the process it shifts the rate burdens of lost customers onto other ratepayers. Those rate burdens also include all of the utility’s overhead as well since compensation is at the retail rate. A FIT, on the other hand, as wholesale energy feeds the energy directly into the electric grid, and because it is must take wholesale energy it must be used first, and in many cases it will off set more expensive energies found on the grid, such as peaker plant power, spinning reserves and so forth saving rate payers money.” Bob Tregilus.

    Third party leasing is fine on the surface and is making a contribution in reducing our fossil fuel consumption, but third party leasers, the Big Boy solar companies that build in the Fragile Desert Eco-Systems, and the Utilities all fight over Renewable Portfolio Standards Pie allowance.

    All Three leagues have a piece of the pie, but there is 4 to 6 teams in each league that want a piece of that carve out money pie, causing huge infighting, and as of right now the homeowner is left out of the ballgame, with no chance of eating the all american pie, why? because we are not represented at the Renewable Portfolio Standard dining hall, with a chair at the pie eating table.

    “The benefits of owning a renewable energy system far outweigh the benefits of a lease or a power purchase agreement (PPA). Under the American Recovery and Reinvestment Act of 2009, homeowners are eligible for a federal personal income tax credit up to 30% of the purchase cost of their renewable energy system, without a maximum limit.** Homeowners can utilize the incentive money in any way they choose. But homeowners that choose to lease their systems turn over their rebates and incentives to the third party lease or PPA companies associated with the solar systems installed on their homes.”

    “The owner of a renewable energy system is also sheltered from rising electricity costs, which have historically increased on average of 3-5% each year. This presents homeowners with opportunities to save money each month on energy and also reduces their reliance on third-party utility companies. By purchasing a renewable energy system with cash or through a loan, a homeowner can completely pay off his or her system and then independently produce clean energy. By choosing a lease or a PPA option homeowners are essentially substituting their utility companies with third-party leasing companies. Additionally, homeowners will likely be required to purchase their systems, renew their leases, or have the systems removed from their roof and revert to paying utility rates once their leases have ended.” Charlie Angione.

    “There’s absolutely no such thing as a $0 down solar lease or PPA and here’s why. A requirement of both of these financing programs is that you agree upfront to give the leasing or PPA company your 30% federal tax credit which is worth thousands of dollars as well as any other financial incentives.

    At $5.57 per Watt. a 6 kW solar system would yield a federal tax credit of $10,026!

    With a $0 down loan instead of a lease, you’ll get to keep the 30% federal tax credit as well as all other applicable financial incentives for yourself and you’ll own your solar system instead of renting it, for a much greater return on investment.

    And if you do decide to lease instead of own, good luck ever selling your home with a lease attached to it. What homebuyer will want to purchase your home and assume your remaining lease payments on a used solar system on your roof, when they can buy and own a brand new system for thousands less.” Ray Boggs

    The Feed in Tariff is a policy mechanism designed to accelerate investment in Renewable Energy, the California FiT allows eligible customers generators to enter into 10- 15- 20- year contracts with their utility company to sell the electricity produced by renewable energy, and guarantees that anyone who generates electricity from R E source, whether homeowner, small business, or large utility, is able to sell that electricity. It is mandated by the State to produce 33% R E by 2020.

    FIT policies can be implemented to support all renewable technologies including:
    Wind
    Photovoltaics (PV)
    Solar thermal
    Geothermal
    Biogas
    Biomass
    Fuel cells
    Tidal and wave power.

    California law does not allow Homeowners to oversize their Renewable Energy systems.

    Allowing homeowners to oversize their Renewable Energy systems, is a true capitalistic tool, that will give us the potential democratize our energy generation and transform millions of homes and small business into energy generators, during Sandy, Solar homes where not utilized to their full potential, because there was no disconnect and or transfer switch, to turn off incoming grid and start in home Solar power. how comforting it would be, to have mandatory transfer switches on all residential and small business renewable energy installations.

    The state currently produces about 71% of the electricity it consumes, while it imports 8% from the Pacific Northwest and 21% from the Southwest.

    Natural gas was burned to make 45.3% of California’s power generated in-state in 2011. Nuclear power from Diablo Canyon in San Luis Obispo County accounted for 9.15%, large hydropower 18.3%, renewable 16.6% and coal 1.6%.

    We need a National Feed in Tariff, for Renewable Energy, with laws that level the playing field, this petition starts with homeowners in California.

    Japan, Germany, and our state of Hawaii, will pay residents between 13 – 37 cents per kilowatt hour, here in California they will pay a commercial FiT in a few counties at 17 cents per kilowatt hour, No Residential FiT and they wont let us oversize our Residential Renewable Energy systems.

    Want to change our Feed in Tariff? Campaign to allow Californian residents to sell electricity obtained by renewable energy for a fair pro-business market price. Will you read, sign, and share this petition?

    http://signon.org/sign/let-california-home-owners

  • azaredaniel

    “Wind and Solar are available everywhere so Renewable Energy can be economically harnessed at small scale across the Cities, Counties, States and our Nation, This nature of Renewable Energy, coupled with an exponential increase of Renewable Energy generation here and abroad promises to Transform the structure and scale of the Grid.

    But the greater Transformation is the democratization of the electric Grid, abandoning a 20th century grid dominated by large, centralized utilities, For a 21st century Grid, a democratized network of Independently owned and widely dispersed Renewable Energy generators, with economic benefits of electricity generation as widely dispersed as its ownership.” John Farrell.

    “Clean local energy provides the most efficient pathway to the smart energy future and the new energy economy. Democratizing the Electricity System does a brilliant job illustrating the unparalleled benefits of small and midsize Renewable Energy and the urgent need for new policies that make the economic and political opportunities accessible.” Craig Lewis

    The Feed in Tariff is a policy mechanism designed to accelerate investment in Renewable Energy, Solar, Wind, Biomass, Hydro, and Geo-thermal, the FIT allows eligible customer generators to enter into long term contracts ( 20 years – 30 years ) with the utility company to sell the electricity produced by Renewable Energy, and guarantees that anyone who generates electricity from Renewable Energy source, weather Homeowner, Small business, or Industry.

    How the FIT maximizes the benefits of Renewable Energy, Renewable Energy holds the promise of addressing Global Warming, Air Pollution, and creating Jobs and diversifying the Market while providing a long term, secure, local energy supply to fuel the economy. Governments that are serious about encouraging Renewable Energy development increasingly understand that the FIT are among the most effective policy instruments at their disposal.

    FIT price is set so that a modest profit is ensured, thereby unleashing the collective capital resources of the entire City, County, State, and Nation. FIT are the most common policy for encouraging Renewable Energy systems globally, in part because Feed in mechanism achieve larger deployment at a lower cost, than other policy mechanisms such as Quotas, Direct Incentives, or Voluntary Goals.

    The FITs give us the potential to work with the utility monopolies, and democratize energy generation and transform millions of homes and small business into energy generators, during Sandy, Solar homes where not utilized to their full potential, because there was no disconnect and or transfer switch, to turn off incoming grid and start in home Solar power. how comforting it would be, to have mandatory transfer switches on all residential and small business renewable energy installations.

    “Essential components of successful Feed In Tariffs
    1. The right to connect easily to the Grid for anyone who wants to produce Renewable Energy, and allow homeowners to oversize their Solar Systems.

    2. A fair price (Tariff ) paid to producers to ensure a modest return on investment that is tailored to each Renewable Technology and the location where it is installed.

    3. Long-Term contracts to create stability in the market, they send a strong signal to manufacturers and installers to make long-term investments, which help keep cost down.

    4. A regular review of the program to ensure that the Tariffs are set appropriately and that they are lowered regularly as cost decrease and allocation are meet, but no lower than than 2 – 3 cents below the first tier retail rate.

    5. No Cap, or limit, on the amount of Renewable power that can be developed.” Canadian Renewable Energy Alliance

    Design Criteria of Good Feed In Tariff:
    Eligible Technologies

    Eligible Homes or Commercial properties

    Tariff Calculation Methodology

    Technology Specific Tariffs

    Duration of Tariff Payments

    Financing Mechanism

    Purchase Obligation

    Priority Grid Access

    Cost sharing Methodology to Grid Connection

    Effective Administration Procedures

    Setting Targets

    Progress Reports
    By Future Policy.org

    “The benefits of owning a renewable energy system far outweigh the benefits of a lease or a power purchase agreement (PPA). Under the American Recovery and Reinvestment Act of 2009, homeowners are eligible for a federal personal income tax credit up to 30% of the purchase cost of their renewable energy system, without a maximum limit.** Homeowners can utilize the incentive money in any way they choose. But homeowners that choose to lease their systems turn over their rebates and incentives to the third party lease or PPA companies associated with the solar systems installed on their homes.”
    “The owner of a renewable energy system is also sheltered from rising electricity costs, which have historically increased on average of 3-5% each year. This presents homeowners with opportunities to save money each month on energy and also reduces their reliance on third-party utility companies. By purchasing a renewable energy system with cash or through a loan, a homeowner can completely pay off his or her system and then independently produce clean energy.

    By choosing a lease or a PPA option homeowners are essentially substituting their utility companies with third-party leasing companies. Additionally, homeowners will likely be required to purchase their systems, renew their leases, or have the systems removed from their roof and revert to paying utility rates once their leases have ended.” Charlie Angione.

    “There’s absolutely no such thing as a $0 down solar lease or PPA and here’s why. A requirement of both of these financing programs is that you agree upfront to give the leasing or PPA company your 30% federal tax credit which is worth thousands of dollars as well as any other financial incentives.

    At $5.57 per Watt. a 6 kW solar system would yield a federal tax credit of $10,026!

    With a $0 down loan instead of a lease, you’ll get to keep the 30% federal tax credit as well as all other applicable financial incentives for yourself and you’ll own your solar system instead of renting it, for a much greater return on investment.

    And if you do decide to lease instead of own, good luck ever selling your home with a lease attached to it. What homebuyer will want to purchase your home and assume your remaining lease payments on a used solar system on your roof, when they can buy and own a brand new system for thousands less.” Ray Boggs

    The Feed in Tariff will, combat Global Warming, Create local Jobs an effect Industry an Innovation, Foster local Technical Skills, Reduce cost of Renewable Energy sources, Minimize Grid Loss by encouraging local power supply, Replacing Aging Power Plants ( Dirty Kilowatt vs Clean Kilowatt ), Gives Communities the power to be part of the Solution.

    Hawaii has the largest Renewable portfolio ( RPS ) in the United States, requiring 40% of its energy be derived from renewable Energy by 2030, additionally it has a three tiered Feed in Tariff, Solar, Wind, and Hydro. Hawaii is leading the way with cutting-edge Solar Energy Policy, this proactive approach, in essence aims to move beyond arbitrary limits, toward a Grid that is planned to fully incorporate Residential Homeowner Solar and other green Energies.

    Renewable Energy will create a Clean Kilowatt revenue stream for the Nation and its citizens a politician dream come true.

    • Gerry

      A really great comment. I live in Australia and we have similar issues. However, the solar industry over here is in a mess. While States differ on the amount and approach taken nobody, and in the particular the various governments, can agree on a fair system. Where people adopted home solar some time ago most new users receive less rebate and now we have energy companies and the media adopting a divisive approach to the public by blaming current solar users in part for price increases. The typical stories coming out from the media is that those without solar are subsidising those with and actually providing figures. As usual most of the gutless politicians are supporting whatever is popular as opposed what is right and fair.

  • Comment from Berlin

    “The main opposition to feed-in tariffs was expressed in the initial email from Susan: ‘There are a few things about them — mainly that they put a ceiling on solar deployment and allow monopoly utilities to maintain control over how consumers get electricity.’”

    Hunh? Not sure what evidence SunRun has for these claims. In Germany’s FiT, for example, there has been an “atmende Deckel,” or “flexible ceiling,” but that does not mean that they stop PV installation at some point, as the phrasing above may disingenuously suggest. Instead, the idea is that as deployment grows, costs should be driven down as a part of economies of scale and the learning curve, and hence the guaranteed reimbursements to people who install PV can be gradually lowered. That’s supposed to minimize the costs for reimbursements that are distributed to other citizens. When the govt offers tax credits instead, they are also reducing revenue and in effect distributing costs elsewhere in the system, too.

    Also not really sure in what sense FiT’s allow monopoly utilities to control how consumers get electricity. Again in Germany, utilities become the point at which information is gathered about how much inputs and outputs of electricity happen at a given home. If you want net metering, someone has to collect information. As microgrids develop, as utilities change, who gathers the info may change, but for now, it is convenient to assign that task to utilities because they have traditionally been monopolies, although they are not really any more in Germany.

    Finally, FiT’s require net metering.

    I think it might be worth asking what’s really behind SunRun’s claims. I like the business they’re in, but I found these arguments odd.

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