This doesn't have to be the case. Plants don't use all the sunlight that hits them, because available light isn't generally the bottleneck in plant growth. Note how most plants are green, which is to say they're content with reflecting the most energy-dense range of the visible spectrum. Solar panels can in theory (and possibly in practice, I'm unsure of the current state of the art) yield more efficient utilization of solar energy than plants do. (Of course we also need to consider efficiency losses from reconverting the energy back into light, but I recall the reading that the overall system efficiency can still beat direct sunlight in theory (consider that the grow lights can be precisely tuned to only emit energy in the frequencies that plants crave).)