Sunnova Energy Corporation

20 Greenway Plaza,
Suite 475
Houston, TX 77046
sunnova.com

Ms. Lisa R. Barton

Secretary
U.S. International Trade Commission
500 E Street, S.W.
Suite 112
Washington, D.C. 20436

Dear Ms. Barton,

It has come to our attention that Suniva Inc. has filed a petition with the U.S. International Trade Commiss io n
(ITC) seeking the imposition of trade tariffs of 40 cents per watt on all foreign- made solar cells. These cells are
integral to the production of solar panels because they are the mechanism by which sunlight is converted to
electricity. The petition also requests that the government require foreign manufacturers to charge a minimum
price of 78 cents per watt for panels. Recently, solar panels have sold for as little as 37 cents per watt.

Sunnova encourages the ITC to reject this request for three primary reasons. First, the imposition of tariffs on
solar cells and panels will significantly harm the U.S. economy by destroying jobs. The solar industry currently
employs more than 260,000 U.S. citizens, and untold thousands, if not the vast majority of these jobs, would be
lost. In 2016, the solar industry created one out of every 50 U.S. jobs. According to some estimates, the solar
industry had a $154 billion impact on the U.S. economy in 2016. Sunnova has appreciated the administratio ns
commitment to job creation, and we encourage you not to halt the dynamic growth we have seen in the sector
over the past five years.

Second, imposing such tariffs and price floors on cells and panels will hurt American middle class families.
According to GTM and PowerScout, the average solar service end user earns $75,000 per year per family. The
savings from distributed or rooftop solar energy systems help families pay mortgages, college tuition bills, and
pay other necessary bills in life.

Finally, Sunnova has always advocated for an energy industry that allows consumers to choose their power
providers and that is free of subsidies and government intervention. This proposed action by a small investme nt
firm that made a poor investment decision should not be allowed to hurt American jobs and consumers. The last
time import tariffs were imposed on solar panels, in 2012 and 2013, the World Trade Organization (WTO)
declared that they were in violation of international trade rules. The WTO asked the U.S. to adapt the measures
that were taken to bring them in line with agreements that had been signed regarding subsidies and countervailing
measures.

For the reasons listed above, we encourage the ITC not to impose tariffs, price floors, or any other market-
distorting measures on solar cells or panels. We believe that doing so will harm U.S. jobs, the economy, and
millions of hard working American families.
Sincerely,

William J. Berger
Chief Executive Officer
Sunnova Energy Corporation

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