TechSurveillance

Solar Leasing and Solar PPA Programs: The Increase in Residential Photovoltaic Solar Deployment

NOVEMBER 2013

This article explores the basic business model and solar leasing program offered by SolarCity*—the largest, vertically-integrated, and only publicly traded solar leasing company at this time. It will compare leasing programs to the traditional method of purchasing a solar system outright, describe how SolarCity makes money, and break down the elements driving profits, such as high retail power rates, declining costs, tax credits, and rules. Finally, this article will make a few suggestions to electric cooperatives on how to deal with the threat of loss of kWh sales and possible advantages of third-party partnerships.

INTRODUCTION The solar industry has benefited for years from state and utility incentives, federal investment tax credit (ITC), accelerated depreciation, and generous net metering laws. In the latest quarterly report published by GTM Research and the Solar Energy Industries Association (www.seia.org/research-resources/us-solar-market-insight-q1-2013), PV solar installations totaled 723 MW in Q1 2013, up 33 percent over Q1 2012, giving the U.S. a PV solar operating capacity of 7,962 MW—a 60 percent increase from two years ago. Despite the likelihood that these incentives will be less valuable over the coming years, GTM/SEIA forecast a strong 30 percent annual growth rate in solar installations through 2016 (see Figure 1).

* There are a number of companies offering solar leasing across the , including , BrightGrid, Sun Run, Vivint, SunEdison, and SunPower. Each company’s offerings vary based on geographic operations, target consumers, length of lease, and business model. NRECA does not have a position on any particular solar leasing company. This article was written to provide NRECA member co-ops with the best information available at this time to support technology business decisions.

nreca members only Solar Leasing and Solar PPA Programs: The Increase in Residential Photovoltaic Solar Deployment | 2

10,000 9,186 9,000

8,000 7,045 7,000

6,000 5,306 5,000 4,375 4,000 3,328 3,000 Installed Capacity (MW dc) (MW Capacity Installed 2,000 1,890

1,000 848

0 2010 2011 2012 2013E 2014E 2015E 2016E

Source: GTM Research and the Solar Energy Industries Association (U.S. Solar Market Insight: Q1 2013)

FIGURE 1: U.S. PV Installation Forecast, 2010–2016E

The government incentives are not the whole Although customers can buy a SolarCity solar story for why solar is booming. One recent project outright, more than 90 percent choose development that accompanies the basic to finance the system in one of two ways. Cus- economic drivers of reduced system costs tomers can lease a system, paying SolarCity a and maturing distribution and sales networks fee for use of the system and benefiting from is the new leasing programs that allow residen- the economics of the system’s power produc- tial customers to build a solar array on their tion. Alternatively, the most popular option is homes at zero upfront cost, with only monthly for the customer to sign a power purchase payments. agreement (PPA) with SolarCity that specifies the initial price per kWh, annual price escalator, SOLARCITY’S BUSINESS MODEL FOR and terms of the agreement. The company also RESIDENTIAL PV SOLAR has small energy efficiency and electric vehicle SolarCity was founded in 2006 and has grown (EV) charging station businesses providing up- quickly to 3,000 employees operating in 14 sale revenues. states (AZ, CA, CO, CT, DE, HI, MD, MA, NJ, NY, OR, PA, TX, WA, DC). In December 2012, SolarCity As an example, a standard PPA would charge went public with an IPO offering price of $8.00 the homeowner around 13¢/kWh when they per share (ticker: SCTY, recent high $65.30). As had been paying 15¢/kWh to their utility. The they describe it, their primary business is to rate would escalate two or three percent per “sell energy.” They do this by offering a fully- year for a term of 20 years. Because the panels integrated service of solar system design, proj- have a usable life of approximately 30 years, ect permitting and management, installation, SolarCity could capture additional “renewal billing, performance monitoring, and most value” from years 21-30, depending on what importantly, project finance. the consumer chooses to do with the array.

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SolarCity focuses on The consumers options are to upgrade to a investors, with investors seeking to own solar areas where utility new system, purchase the current system, ex- assets and capture returns through upfront rates are 15¢/kWh tend the current contract, or have the panels monetization of the tax credit. The ITC drops to removed. SolarCity sends a monthly statement 10 percent at the end of 2016. The other fed- or higher, but as similar to a utility bill to their customers, allows eral support is allowing accelerated deprecia- solar installation transfer of the PPA if the customer moves, and tion over six years rather than the actual useful costs decline, this covers all insurance and maintenance. life of 30 years, reducing tax exposure. threshold could likewise drop. It is believed that SolarCity currently focuses on There are many state policies that support solar; utility customers who pay an average of 15¢/kWh the most important are those that impact the or more for power, which is about 7.6 percent size of the addressable market for companies of the U.S. market in 2012, and anticipated to like SolarCity. These include renewable portfo- grow to 10 percent in 2016. State and federal lio standards (RPS), certifi- incentives can drive down that cost threshold. cates, net energy metering, and third-party For example, SolarCity has a strong presence in ownership regulations. Washington, DC where retail rates are around 13¢/kWh and has a number of municipal PV The Renewable Portfolio Standard (RPS) is a incentives. If the cost of installing a solar sys- state-level regulation that mandates a certain State and federal tem declines, the generic threshold of 15¢/kWh level of energy production from renewable incentives and will also decline, increasing SolarCity’s address- energy sources. Nationally, 30 states (including Washington, DC) have RPS mandates in place. policies have able market. In October of 2013, SolarCity pur- ’s 33 percent RPS target for 2020 a significant chased ZEP Solar, a provider of solar mounting systems, for $158 million to address this issue. stands out, given the aggressiveness of the tar- impact on the Overall, SolarCity economics improve from get and the size of California’s economy. A solar attractiveness of lower system-installed cost per watt and lower renewable energy certificate (SREC) is created solar projects. cost of capital. when a unit of is produced, and can either be sold together with the power or The Role of Government Incentives sold separately. Seven states plus Washington, and Policies DC have SREC markets, with The economics for SolarCity projects, or indeed having recently displaced as the any PV solar projects, would not be as attractive most robust. SolarCity owns any SREC credit without various state and federal incentives as part of its PPA with the customer. and policies. There are two primary forms of federal support, both of which are purely finan- The issue of third-party ownership rules hinges cial. The first is the investment tax credit (ITC), on the definition of an electric utility, and in which allows owners of a solar power genera- some states only utilities are allowed to sell tion system to reduce their federal tax liability power generation. This means that, in some by an amount equal to 30 percent of the pur- states, a company like SolarCity would have to chase cost of the system. The ITC is available to register as a utility for each solar project it owned, individuals, commercial buyers, and institutional making it difficult or impossible to operate in Solar Leasing and Solar PPA Programs: The Increase in Residential Photovoltaic Solar Deployment | 4

that state. There are six states, mostly in the Southeast, that explicitly don’t allow third-party ownership. Twenty states explicitly allow third- RI: May be limited to certain sectors party ownership, and the rules are unclear for DC UT: Limited to the remaining states. SolarCity only operates in VA: See notes certain sectors states that allow third-party ownership. States

AZ: Limited to that don’t allow third-party ownership do so certain sectors because of state retail restructuring and the associated complications. (See Figure 2.)

Puerto Rico Authorized by state or otherwise currently in use, For more information, please see Appendix A. at least in certain jurisdictions within the state At Least 22 states Apparently disallowed by state or otherwise and Washington, DC and Net energy metering, often referred to as “net restricted by legal barriers Puerto Rico Authorize Status unclear or unknown or Allow Third-Party metering,” allows owners of small solar energy Note: This map is intended to serve as an unofficial guide; it does not constitute Solar PV Purchase facilities that sit “behind-the-meter” to receive legal advice. Seek qualified legal expertise before making binding financial Power Agreements decisions related to a third-party PPA. credit at the retail electricity rate for excess solar power production. Effectively, the cus- FIGURE 2: Third-Party Solar PV Power Purchase Agreements (PPAs), tomer’s meter flows in the normal way when February 2013. Source: DSIRE www.dsireusa.org/summarymaps/ the customer uses more power than their solar index.cfm?ee=0&RE=0 energy facility produces, but flows backwards when the solar power facility produces more IOWA COURT SIDES WITH THIRD-PARTY SOLAR power than the customer uses. There are often limits on net metering, such as “true-ups” at In March of 2013, an Iowa district court ruling allowed Eagle monthly or annual intervals. In a “true-up,” any Point Solar to sell electricity directly to the Dubuque city govern- energy created in excess of the customer load ment to power the municipal building where the panels are is either purchased at avoided cost or simply located. This ruling came after the local utility, Alliant Energy, zeroed out. Many states and utilities also have contended that the project violated state territory laws. net The Polk County District Court found that Eagle Point would metering caps on size of systems and/or total not be acting as a utility, so the company can sign what is capacity of net metering systems. SolarCity known as a third-party power purchase agreement (PPA) with owns the revenues from net metering sales to Dubuque to sell the city electricity from the panels, which are the utility—which are separate from the PPA owned by an investor and managed by Eagle Point. with the consumer. (See Table 1.)

Excerpt from: Court sides with Iowa solar installer in dispute with utility. Posted on 04/12/2013 by Kari Lydersen www.midwestenergynews.com/2013/04/12/court-sides- with-iowa-solar-installer-in-dispute-with-utility Solar Leasing and Solar PPA Programs: The Increase in Residential Photovoltaic Solar Deployment | 5

Within the electrical systems, substations GETTING BETWEEN THE CO-OP AND THE OWNER-MEMBER tend to be the thieves’ There are several business models for co-ops to get involved in solar where a third-party owns target the generation because they can monetize the tax benefits or have expertise and efficiencies the co-op can’t match. There are also several business models being used by third-parties to cut of choice. the co-op out of the circle and sell at retail directly to co-op members. Below is an excerpt from the SolarCity website:

• SolarCity will handle all details • SolarCity will work with you to determine which utility rate plan makes the most financial sense based on your system production and your electrical usage patterns. We will install your new net meter and coordinate with your utility company to switch you to a new rate plan.

Source: www..com/learn/understanding-netmetering.aspx

TABLE 1: Business Models of Major Solar Companies Solar Company Business Model

Clean Power Finance CPF is a financial services and software company for the residential solar industry, connecting buyers, sellers, and financiers on web-based platform to design, finance and install systems.

Renewable Energy Corp. REC produces wafers, cells, and solar panels for the solar industry. REC also engages in project development in selected solar segments.

SolarCity Full service offering from customer acquisition to financing, installation, and operations and maintenance.

SunEdison SunEdison is a global leader in the manufacture and sale of solar wafers with R&D and manufacturing facilities in the U.S., Europe, and Asia. Offers lease or PPA programs for residential and commercial customers.

Sungevity Residential lease or sale programs. Customer acquisition is through online financing and project management platform.

SunPower SunPower manufactures high efficiency solar panels, and sells or leases to residential, commercial and utility customers. It is majority-owned by French oil company, Total, providing unequalled financial strength.

SunRun SunRun buys residential solar systems, has them installed by third-party installers, leases (or PPA) the systems, and provides monitoring and maintenance.

The solar leasing business is immature and dominated by startup companies. SolarCity is notable within that group because it is fully-integrated. SunRun and finance systems, acquire customers and service them, but outsource installation. Clean Power Finance is essentially a financing platform that matches up installers, customers, and investors.

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Within the electrical SOLARCITY’S FINANCIAL MODEL After six years, when the tax benefits have been systems, substations SolarCity builds solar systems for residential exhausted, the structure would “flip” to 95 tend to be the thieves’ customers. They pay for the system upfront in percent for SolarCity and 5 percent for the target exchange for a lease or PPA that pays SolarCity tax equity investor. The tax equity investor of choice. a small but low-risk cash stream over 20 years. would then sell his residual 5 percent share This structure creates a cash flow mismatch in to SolarCity and exit completely. which SolarCity is likely cash flow negative for The complexity of SolarCity’s financial model, The economics of the first five to eight years of the arrangement. and the fact that actual contracts with tax solar are challenging This sort of business can only be financed with a lot of equity, and the cost of that equity will equity investors are not available to the public, for businesses such be high until solar leasing companies prove makes it difficult to know if SolarCity makes as SolarCity, as they their business models. money on their investment funds. It is believed face significant that, over time, SolarCity should earn positive upfront costs in A significant amount of the economic value of returns even after the investment funds have exchange for low- solar projects is held in the investment tax generated returns for their investors and the credit and accelerated depreciation. SolarCity customer’s contract has been honored. This is risk, long-term cannot use the ITC or accelerated depreciation financially inefficient, but it is a necessary fea- revenue streams. because they lose money—they have no tax ture of living with the investment tax credit. They make it work exposure. This is a big problem that can only through financing be solved by bringing investors with tax appe - Wall Street analysts estimate that SolarCity will structures such as tite. Most likely, SolarCity creates investment lose money until at least 2018. SolarCity will partnership flips and funds to finance the solar installations using also be cash flow negative for the next several years. It is cash hungry, and will remain so as leasing pass- primarily two financing structures: partnership flips and lease pass-throughs. These structures long as it is growing, because it must pay for throughs. are explained further in CRN’s related Tech - the solar systems upfront in return for a 20-year Surveillance article: The Changing Cost of cash stream. As the growth rate slows, and cash Solar Power—Financing Options for Electric becomes available from investment funds that Cooperatives. They are both focused on achiev- have already paid off their tax equity investors, ing the same objective: allow SolarCity to raise cash flow will improve. enough capital to pay for installing solar power systems for its clients, while allowing investors THE NAME OF THE GAME: COST OF CAPITAL to earn returns and tax credits from ownership SolarCity’s growth prospects appear strong, as of the systems. a leader in a rapidly growing industry. It has made major investments in its installation net- Partnership flips are used for about two-thirds work and brand name, which may prove to be of system investments. In this structure, Solar - its most valuable assets. However, SolarCity’s City and an outside investor (the tax equity in- greatest challenge is reducing its cost of capi- vestor) would create a taxable special purpose tal. Financing renewable energy projects can entity to develop, build, operate and maintain be challenging and inefficient. Companies like the solar facility. For example, the equity own- SolarCity are currently dependent on making ership could initially be 95 percent for the tax agreements with dozens of tax equity investors. equity investor and 5 percent for SolarCity. For This can be a cumbersome and potentially un- the first six years, the tax benefits and profits reliable source of equity capital, but worst of would flow according to this 95/5 percent split. all, this is expensive money. Solar Leasing and Solar PPA Programs: The Increase in Residential Photovoltaic Solar Deployment | 7

Within the electrical Issues around net SolarCity is asking: how cheap can it get money be addressed. As distributed generation has systems,metering substations are in order to help its customers finance their grown, a number of utilities have sought to re- tendreceiving to be the attention thieves’ systems? The size of the addressable market vise, cap, or remove net metering. This issue from varioustarget depends on the answer. The financing of solar will play out differently depending on location, leasing will commoditize during the next few but will have major implications everywhere. utilities,of choice. as years, and success will go to the companies distributed able to access capital at the lowest price. The second concern for electric cooperatives is: generation what type of company is installing all that continues to grow. There are a lot of new ideas and proposals to solar? Co-ops could probably learn to live with lower the cost of capital for SolarCity and others. some third-party PV sales in their territories, Recently proposed federal legislation would but what if the local Investor-Owned Utility expand Master Limited Partnership (MLP) and (IOU) buys the solar company? There is a real Real Estate Investment Trusts (REIT) treatment possibility that a solar leasing company, espe- to renewable energy sources, putting renew- cially one not as well financed as SolarCity, able projects on an equal footing with oil, gas, could be sold to a major IOU. This could be fol- and coal infrastructure projects. This would lowed by an aggressive campaign to sell more make the financing process more reliable with PV on co-op member rooftops, lowering rev- a significantly lower cost of capital. Securitiza- enue and hurting the cooperative-consumer re- tion of solar projects is also getting a lot of lationship. attention. Wall Street is working on turning portfolios of solar systems into asset-backed Every co-op has a unique mix of costs, regula- securities. All of these efforts are aimed at tions, directorship and contracts. Presented bringing down the cost of capital. here are several possible ways for co-ops to deal with this situation. It is incumbent up on COMPETITIVE THREAT OR POTENTIAL each co-op to determine for itself the best PARTNERS FOR ELECTRIC COOPERATIVES? course of action. With several The growth of solar leasing and PPA companies approaches to co-op creates two concerns for electric cooperatives. Option 1: Competing in the PV Market First, a co-op can go into competition with the involvement and The first is the prospect of lost kWh sales when co-op members install residential or commer- third-party vendors by offering its own PV serv- response to the cial solar arrays that produce some or all power ices. One way would be through community growing solar for their needs, on an annual net-metered solar farms and local green power purchasing market, it is up to basis. These customers would keep their con- options. In a community solar program, the each to determine nection to the co-op’s lines for non-daylight co-op owns and operates a centrally-located their own best hours and as a backup. Going completely off PV system, and sells shares to its membership course of action. the grid isn’t feasible until battery technology who would get a credit on their bill. NRECA is comes down considerably in cost. Net metering currently working on ways to reduce the cost rules would allow them to use the grid without and greatly simplify the purchase, installation, paying for it. On a small scale, the harm of lost and commissioning of utility-scale PV systems kWh sales is small. But, as the economics con- through a U.S. Department of Energy (DOE) tinue to improve, and solar residential installa- Sunshot research project. For more info see the tions continue to proliferate, the impact must Sunshot sidebar. Solar Leasing and Solar PPA Programs: The Increase in Residential Photovoltaic Solar Deployment | 8

Within the electrical DOE SUNSHOT INITIATIVE—SUNDA: systems, substations STANDARDIZING UTILITY-SCALE SOLAR FOR COOPERATIVES tend to be the thieves’ The U.S. Department of Energy (DOE) and the National Rural Electric Cooperative Association target (NRECA) signed a cooperative agreement for a multi-state 23MW solar installation research proj- of choice. ect that seeks to identify and address barriers to photovoltaic (PV) deployment at cooperatives. The DOE is providing $3.6 million, matched by a $1.2 million cost share from NRECA, the National Rural Utility Cooperative Finance Corporation (CFC), Federated Rural Electric Insurance Exchange, PowerSecure International, Inc. (NYSE: POWR) and fifteen participating cooperatives.

For this project, co-ops will explore how standardization can help bring down the “soft” costs— labor, procurement, supply chain and other costs—of PV installations and also reduce uncertainty about the effects of these installations on a system.

Working with 15 co-ops that are planning from 250 kW to 5 MW of solar PV, NRECA will analyze the business-side of these deployments and develop “PV system packages” consisting of stan- dardized, optimized and scalable technical designs for 250 kW, 500 kW, and 1 MW systems.

Demand for solar Option 2: Launch a Residential PV Program ops could own the new solar installations and will continue to Another way would be for a co-op to launch its could continue to charge their members for increase as own residential PV program, install, own and the power. They could hire a local contractor to operate the panels themselves. The co-op install and service the systems. This is just one installation costs could contract any part of this process. A option. There are a number of possible owner- decline and method gaining popularity is by offering bulk ship and revenue sharing models that can environmental purchasing programs. Currently known as maximize the co-op’s access to low cost capi- concerns increase. “Solarize” programs, the idea is to select one tal, the co-op’s relationship with its member- Co-ops can leverage or more reputable local installers, and commit owners, the third-party’s ability to monetize the their strengths to one large bulk purchase and installation for tax benefits, or the third-party’s expertise and in response and distributed PV that the co-op can sell to its efficiencies. Each co-op has unique contracts, members or entire communities (such as an customer demands, and regulations that must secure benefits in entire subdivision or business complex). The be considered. the long-term. larger the capacity committed, the cheaper the prices of the residential PV. More information Electric cooperatives need to be actively can be found in the Solarize sidebar at the end engaged and aware of the changes taking of the article. Interested co-ops should consider place on the grid. As long as the price of solar contacting the Cooperative Finance Council declines and consumer concerns about the (CFC) or the National Renewable Cooperative environment increase, there will be a high (NRCO) for more information. demand for more solar power. Finding constructive ways to leverage cooperative Option 3: Partnering with Third-Party Solar strengths—including extensive experience in Leasing Companies energy distribution management, reliable grid A third option would be to go into partner- infrastructure, and the ability to provide back- ship with third-party solar leasing companies. up power—in order to respond to the changing Co-ops have access to low cost financing that economic environment—will benefit coopera- makes them very attractive partners. The co- tives in the long-term. n

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Within the electrical systems, substations SOLARIZE BULK PURCHASING tend to be the thieves’ Bulk purchasing programs, also known more specifically as “Solarize” programs, have target recently gained in popularity within some communities. The unique benefit of this type of choice. of program is that it helps consumers receive better pricing for small, distributed proj- ects by aggregating the individual small systems into a larger procurement process. These initiatives are most often led by nonprofit or local government administrators within a city or county jurisdiction, as a way to encourage greater solar adoption within the community, although electric cooperatives also could implement this pathway.

In the initiative, the cooperative identifies one or a few reputable, local installers (possi- bly through an RFP process) and then pre-negotiates installation rates on behalf of local residents and businesses. The selected installer(s) commit to several set rates based on level of participation, so that as the amount of capacity installed within the community increases, costs decline. The administrator then initiates a participation campaign with a deadline for committing. During the campaign period, local residents and businesses sign up to participate by committing to purchase an onsite system at the negotiated rate. It is transparent in that as more capacity is committed, installed prices have the potential to fall to lower tiers. In most cases, participants have been able to secure measurable percentage discounts for installing several small-scale projects throughout the community.

Excerpt from the report: Electric Cooperative Pathways to Solar Engagement: A Framework for Considering Solar Power Options Within the Cooperative Business Model produced by the National Rural Utilities Cooperative Finance Corporation and the Solar Electric Power Association.

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Within the electrical systems, substations APPENDIX A: SOURCES FOR DSIRE THIRD-PARTY SOLAR MAP tend to be the thieves’ target • : ACC Decision 71795, Docket E-20690A-09-0346 of choice. • California: Cal. Pub. Util. Code § 218, § 2868 • : S.B. 09-051; PUC Decision C09-0990 (2009) • : Connecticut Clean Energy Fund • D.C.: PSC Order 15837 • Delaware: S.B. 266 and S.B. 267 (2010) • Florida: PUC Decision: Docket 860725-EU; Order 17009 (1987) • Georgia: GA Territorial Act: O.C.G.A. § 46-3-1 • : S.B. 704 (2011) • Illinois: 220 ILCS 5/16-102; 83 Ill. Adm. Code, Part 465 • Iowa: IUB Declaratory Ruling-Order: Docket DRU-2012-0001 (2012) • : KRS 278.010 (3) • Massachusetts: 220 CMR 18.00 • : H.B. 1057 (2009) • Michigan: 2008 Public Act 286; PSC Order Docket U-15787 • New Jersey: N.J. Stat. 48:3-51; N.J.A.C. §14:8-4.1 et seq. • New Mexico: H.B. 181 and S.B. 190 (2010) (effective 1/1/2011) • Nevada: NRS 704.021 (AB 186, 2009); PUC Orders 07-06024 and 07-06027 • : NY CLS Public Service § 2.13 • New Hampshire: PUC 902.02 and PUC Docket DE 10-212 (letter 1/31/12) • North Carolina: General Statutes § 623(23) • Ohio: PUC Order 06-653-EL-ORD • Oklahoma: 17 Okl. St. § 151; O.A.C. § 165:40 • Oregon: PUC Order, Docket 08-388 • Pen nsylvania: PUC Order, Docket M-00051865 • Puerto Rico: No policy reference available; based on news reports and articles • Rhode Island: R.I. Gen. Laws § 39-26.4 (2011); Third-party-owned municipal financing arrangements may net meter. • Texas: S.B. 981 (2011) (effective 9/1/2011) • Utah: H.B. 0145 (2010) (effective 3/31/2010, and limited to installations at public buildings, schools or 501(c)(3) non-profits) • Vermont: No policy reference available, based on news reports and communications • Virginia: DSIRE had previously identified VA as a state where third-party PPAs were authorized or otherwise currently in use, at least in certain jurisdictions within in the state, but has re-categorized VA to unknown status as of Oct 2011. See reference VA Code § 56-232 and 20VAC5-315-20 • Washington DC: REIP Program; PSC Order 15837

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Questions or Comments CRN Contact: Andrew Cotter, CRN Program Manager: [email protected]

Legal Notice This work contains findings that are general in nature. Readers are reminded to perform due diligence in applying these findings to their specific needs, as it is not possible for NRECA to have sufficient understanding of any specific situation to ensure applicability of the findings in all cases. Neither the authors nor NRECA assume liability for how readers may use, interpret, or apply the information, analysis, templates, and guidance herein or with respect to the use of, or damages resulting from the use of, any information, apparatus, method, or process contained herein. In addition, the authors and NRECA make no warranty or representation that the use of these contents does not infringe on privately held rights. This work product constitutes the intellectual property of NRECA and its suppliers, as the case may be, and contains Confidential Information. As such, this work product must be handled in accordance with the CRN Policy Statement on Confidential Information. Copyright © 2013 by the National Rural Electric Cooperative Association.