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NRECA Comments for FTC Workshop Examining Competition and Consumer Protection Issues in the Rooftop Solar Business

Policy Positions   
Retail rates should be designed to treat all consumers equitably and designed to minimize cost shifting among consumers. In order to achieve these goals, rates and cost-drivers should be aligned as much as possible. NRECA is concerned that net metering policies lead to cost shifting among consumers. Cost shifting occurs because net metering customers underpay the fixed-costs they impose on the system and because utilities are required to pay significantly more than avoided cost for a resource that cannot be dispatched reliably.