Commenting on the first draft of the framework, the wind turbine owners association, Danmarks Vindmølleforening (DV), suggests that a provision be added for net metering to allow electricity users to generate their own power and run the metre backwards if their output is greater than consumption at any given moment. Such a policy is already in place for solar generators in Denmark. DV says net metering would allow smaller, "household" turbines to be profitable in the new market -- unlike the statute's suggested tariff of DKK 0.60/kWh for 12 years.
In addition, DV has called for an exact specification of who should pay for all grid connection and expansion costs -- the wind plant developer or the owner of the grid. DV is also doubtful over the logistics of the statutory instrument's incentive to encourage the owners of old turbines up to 150 kW in size to scrap these machines and reinvest in new technology. Owners can invest in two times an old machine's capacity and receive a secured DKK 0.60/kWh for 12,000 full load hours -- but only if the new turbine is erected "less than 2.5 kilometres from an already-replaced turbine under 100 kW" before 2003. DV says it will be nearly impossible to reach this deadline, which should be moved to 2006. Owners replacing turbines of up to 100 kW can invest in three times the old machine's capacity and get the old rate for output of DKK 0.60/kWh.