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                               October 14, 2021

       Robert Lane
       Chief Financial Officer
       Sunnova Energy International Inc.
       20 East Greenway Plaza, Suite 540
       Houston, Texas 77046

                                                        Re: Sunnova Energy
International Inc.
                                                            Form 10-K for the
Fiscal Year ended December 31, 2020
                                                            Filed February 25,
2021
                                                            File No. 001-38995

       Dear Mr. Lane:

              We have reviewed your October 5, 2021 response to our comment
letter and have the
       following comments. In some of our comments, we may ask you to provide
us with information
       so we may better understand your disclosure.

              Please respond to these comments within ten business days by
providing the requested
       information or advise us as soon as possible when you will respond. If
you do not believe our
       comments apply to your facts and circumstances, please tell us why in
your response.

             After reviewing your response to these comments, we may have
additional
       comments. Unless we note otherwise, our references to prior comments are
to comments in our
       September 22, 2021 letter.

       Form 10-K for the Fiscal Year ended December 31, 2020

       Note 2 Significant Accounting Policies
       Dealer Commitments, page 103

   1.                                                   We understand from your
response to prior comment two that in exchange for incentive
                                                        payments made under
your agreements with Trinity Solar, Inc. and other dealers, the
                                                        dealers must obtain
specified numbers of new customer contracts and agree to originate
                                                        the majority of their
business through your platform. You explain that payments made to
                                                        dealers represent costs
of obtaining an anticipated contract, that you are entitled to refunds
                                                        if the dealers do not
achieve target sales, and that such costs "...would not have been
                                                        incurred if the
contract with the customer had not been obtained."
 Robert Lane
Sunnova Energy International Inc.
October 14, 2021
Page 2
         Please tell us how the "provisions for refunds" and "netting
mechanisms" are structured in
         establishing correlation between the payments to dealers and the
specified numbers of
         new customer contracts. For example, clarify whether the entire
payment is subject to
         proportional return or netting based on the specified targets and if
this is not the case,
         further explain how you determined that all of the payments to dealers
are appropriately
         accounted for as incremental costs to obtain a contract.

         Please identify the corresponding provisions in the current agreement
with Trinity Solar,
         Inc., submit that agreement as supplemental information for our
review, and if such
         provisions are not fully representation of the refund and netting
provisions in the other
         dealer agreements, describe the nature and extent of variations.
      You may contact John Cannarella, Staff Accountant, at (202) 551-3337 or
Karl Hiller,
Branch Chief, at (202) 551-3686 with any questions.



FirstName LastNameRobert Lane                                 Sincerely,
Comapany NameSunnova Energy International Inc.
                                                              Division of
Corporation Finance
October 14, 2021 Page 2                                       Office of Energy
& Transportation
FirstName LastName