Rate change public comments

Comments on the proposed rates for 2022-2023 can be submitted by emailing ContactUs@smud.org or by mailing written comments to:
SMUD
P.O. Box 15830, MS A451
Sacramento, CA 95852-0830

All personally identifiable information, including last names, addresses, phone numbers and email addresses are removed prior to posting.

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Comments 


September 15 - Sean F.

Hi, 

I intend to make verbal comment for agenda item 10, as follows (if for some reason I cannot be at the meeting, I would like this read for me, though I plan on attending):

Good evening. My name is Sean F., and I am a SMUD ratepayer and constituent in Ward 3.

I am calling in to discuss your change in Net Energy Metering payments for rooftop solar. As someone who recently moved to Sacramento to care for an elderly member of our family, and as someone who has installed rooftop solar on a previous home, I had been considering installing rooftop solar on this home. However, if the Net Energy Metering payments are reduced by an average of 40%, as they are in this proposal, it would simply not pencil out, and we would not be able to take the risk. And if we can’t take the risk, I have to wonder how many other people will simply stop considering rooftop solar for their homes and businesses.

And here’s the sad part--as the father of two sons I KNOW that rooftop solar is one important part of combatting the climate crisis and leaving an inhabitable environment for my children and their children. It’s just that, as a middle class union worker, changing the payback on the energy I’d generate for me, my family, and my neighbors, would simply make it take too long to pay back.

When you add in the fact that you are willing to sunset the agreed upon rate structure on your existing solar customers BEFORE the useful lifetime of these systems has expired (as part of this rate change) I am forced to believe that I cannot trust my public utility, YOU, SMUD, to honor the deals you make with us. And keep in mind, we aren’t just ratepayers, we’re your constituents, and we are watching. Many people showed up outside your offices today because we want you to know this isn’t right, and we won’t stand for it.

So I ask you, urge you, to follow your own goals that are laid out in your Carbon Free 2030 plan and vote to table this change to the net energy metering rates. Go back to the drawing board and consider how to create a rate structure that won’t prevent people of all income levels from choosing rooftop solar for themselves and their neighbors. Do the right thing for us, for our climate, and for future generations.

Thanks,
Sean F., Constituent and Ratepayer, Ward 3


September 14 - James S.

Honorable Board Members,

I believe that you are making a mistake in abandoning the current reimbursement rates for home solar, and adopting the wholesale reimbursement cost model. I read the report that said that the home solar users are being subsidized by the rest of the SMUD ratepayers. This is a half truth. SMUD chooses to set rates according to its priorities. Every time SMUD gives an incentive, be it for getting an efficient refrigerator, or the incentives for electric cars (installation incentives and discount on electric rates at certain hours), or the users that use power at peak times paying more than those at non peak times, SMUD makes a decision to essentially tax some of its ratepayers in favor of essentially a credit for others. The time shifting of credits that the current system uses allows families to be part of the solution to our energy needs by producing electricity for all. It also shifts costs from SMUD from the capital expenditure for solar panels and their accouterments away from SMUD to the producers. This is no small expense avoidance.

The recapture of solar system homeowner expenses and capital expenditures is very long as you are all aware. Adopting the new rate rules will dissuade many from getting new systems. It is also unfair to those  customers, like myself, who used your solar calculator and saw a payback of 20 years who will instead never break even.

I posit that the new rate schedule will also put the brakes on solar installations except in new homes where state law mandates it. It is SMUDs choice of how to view their incentives, as unfair costs to those who don’t take advantage of them, or as tools to better society and our environment. The new solar rate structure should be rejected.

Sincerely,
James S.
(a SMUD customer)


September 11 - Nick E.

Dear Mr. Lau and SMUD Board of Directors,

I urge you to not approve the proposed changes to residential solar credits.  Now is not the time to reduce the incentives for rooftop solar.  I have a rooftop system myself and feel that is unfair to change the rate structure for these systems.  I realize there was no guarantee that the rates would remain unchanged, nonetheless, in choosing to buy a system I did not expect the rates to be changed this dramatically.   Please continue SMUD’s commitment to reducing our contribution to climate change by voting against these changes.

Sincerely,

Nick E.
Sacramento, CA 95864


September 11 - Nancee M.

Dear SMUD Board:

Hello. I am a SMUD customer in the City of Sacramento. I own a small home and I have installed 12 solar panels on the roof. 12 are all the panels that can fit on my roof. It cost $12,000 to install the panels in 2012 and it will be many years before that investment is returned. I did not install solar panels to make a profit. I installed solar panels because I believe it is the right thing to do. Install panels on already disturbed landscapes rather than putting panels on wildlife habitat. Generate cleaner energy.

Your Chief Executive Officer and General manager Report on Rates and Serves dated June 17, 2021 (Report) says several incongruous things.  It says that SMUD’s goal is to add 3,000 MW of new renewable energy and storage by 2030. (Report, p. 32). That is unlikely to happen in neighborhoods with smaller homes, many of which might be in disadvantaged areas. The proposal incentives storage. (Report, p. 32). A battery wall would have cost an amount equal to the cost of the installation of the panels themselves. It is even less likely that smaller homes, that cannot fit a large number of panels, and families that cannot afford the cost of panels and an expensive battery, will now be able to afford to install solar panels at all, because it makes less economic sense without the battery wall. So, this proposal makes it even LESS likely that SMUD will reach its goal to add 3,000 MW of new renewable energy and storage by 2030. The changes to solar power compensation is going in the wrong direction by taking away incentives to install solar panels in the first place.

I encourage you not to adopt the changes to the NEM rate schedule as proposed in the Report. There are very few houses in my neighborhood with solar panels now. That number will not grow if the NEM proposal in the Report is adopted.

Sincerely,
Nancee M.
Sacramento, CA 95818


September 10 - Mark G.

Part of my public comments. 
Please acknowledge receipt. 

Mark G.

Sent from my hard wired computer 

Attachments:
SMUD rate action 2021.docx
SMUD hearing June 4 2019 by MG rev June 4.pptx
attachment.pdf
SMUD Public Hearing Transcript 19117 2019-06-04.pdf


September 10 - David G.

As a Smud customer that purchased solar panels back in 2013, I have to agree with many customers' well researched and substantive comments that emphatically state there is NO INCENTIVE TO PURCHASE SOLAR & BATTERY within your predetermined paidcontractors/consultants reports to make a crucial reduction in CO2 emissions and energy efficiency. 

The proposal should be allowed a VOTE BY THE PEOPLE who are SMUD customers.  I fear that the Board is short-sighted and is making another blunder ridden decision such as previous Boards did with the ill-conceived RANCHO SECO NUCLEAR POWER PLANT. 

This Solar-Battery rate proposal should be POSTPONED AT LEAST 3 YEARS when NEW SOLID STATE BATTERY TECHNOLOGIES come into the market and State Government comes up with an ENERGY INFRASTRUCTURE proposal that's uses the best minds from Science, Technology,Social and Ecological University communities.  

I purchased with my own cash Solar Panels for around $20,000 -- Today with old technology batteries the systems you want will price out most SMUD customers even more so than changing HVAC, STOVES and HOT WATER to all-electric. 

Is it true that your proposal has no built-in REVIEW, REVISE and IMPROVEMENT timelines? If it doesn't, then how can you justify being GOOD Stewards of our Publicly Owned Utility?

Sincerely,

David G.

ElK Grove & City Of Sacramento customer

 

September 6 - Jered S.

Hello SMUD Board,

I’m a civil engineer employed in the utility-scale solar industry.  I am against the solar rate change because I see it directly contradicting your 2030 goal.  

I watched a replay of the recent meeting, and I was surprised that nobody brought up the possibility that SMUD might someday lose customers to off-grid battery storage systems or micro-grids, driving up rates for the rest of us.  

NEM in its current form create solar partners, who often switch to electric vehicles, who will then go to the next level of grid-tied battery storage or someday V2G.  Consider continuing to invest in partnerships with these types of forward-thinking people — your best customers who will help finance your VPP.  Don’t alienate them while subsidizing the poor soul with the $400 monthly bill!

I’ve copied a link to a good, timely debate that may add a new perspective.  It’s balanced, but the pro-NEM guy has some good arguments.

Suncast episode 395:  Should Net Metering Still Exist?

https://podcasts.apple.com/us/podcast/suncast/id1045871373?i=1000532994197  

Jered S.
Sacramento CA 95811


September 2 - John W.

Hello Paul.    Thank you for taking the time to respond to my letter of concern about SMUD's position on future roof top solar energy production.  

From your reply and the apparent position of most board members, I expect SMUD will take the advice of your contracted consultant and reduce the amount paid to customers with rooftop panels who contribute power to the grid.  This action will result in less clean energy entering the grid from this source than would be the case if current rates were maintained.  The community cannot afford to reduce the amount of clean energy produced regardless of the source, as the fires and flooding of recent days should tell us.

Since SMUD seems to believe the assertions of the contractor's study, and will probably adopt it, there needs to be a mechanism included in your plan to verify the assumptions made by the study's authors based on actual experience after a reasonable period, like two years.  Such verification should be a formal side-by-side comparison of  parameters forecast by the study and those experienced by SMUD in terms of the amount of clean energy coming in from the various sources.  If the assumptions made by the study are borne out by experience, all well and good.  If not, adjustments can be made, such as the amount paid to rooftop contributors to increase their contributions, or incorporating advances in technology. This verification should be a hard requirement included in the plan up front, so it does not get overtaken by events.  

Clean power is a new, but existential matter for future generations, so there is no room for error.  Very careful management of a matter as important as this requires evaluation of methods based on facts and data, not on unproven theory.  Please do all you can to assure there is evaluation based on actual facts and data to verify the steps you take.

John W.


August 31 - Jean W.

Comments to the SMUD BOD 8-31-2021

Dear SMUD Board of Directors, 

In response to the SMUD NEM 2.0 proposaI I cite two articles by Severin Borenstein and James Bushnell, "Headwinds and Tailwinds: Implication of Inefficient Retail Energy Pricing for Energy Substitution" ( Energy Institute WP 319R)  and "Do Two Electricity Pricing Wrongs Make a Right? Cost Recovery Externalities, and Efficiency",  NBER Working 24756 (http://www.nber.org.papers/w24756). The analysis is for older data (2014-2016), and does not include true costs of the externalities of fossil fuels or carbon. There is a recent paper, "A review of the value of solar methodology with a case study of the U.S. VOS" by Koami Soulemane Hayibo and Joshua M. Pearce, 2021, that looks at the true value of solar quite differently. I have attached that paper to this email. There are serious flaws in the E3 study which have been cited by others. The only way to reach a net-zero status is to increase solar plus battery systems, and utility scale system.
 
It seems on first reading that the issue of infrastructure and transmission can be covered by a fixed monthly fee, similar to what PGE added to electricity bills over the last few years.
 
One troubling fact is that some 25% of PGE customers are on the care plan, reducing their bills by 25% and requiring huge subsidies from the rest of us.  I would argue that low income "care plan" subsidy not be added to electricity and gas bills, and come out of the state's general fund, now per Gov. Newsom, $72 million dollars in excess of the state's budget.  That would help reduce the excessive increases in our utility bills, I am sure.
 
With regard to your issue of the solar customers costing non-solar customers, in fact rooftop solar customers supply excess power to their neighbors at a small fraction of the cost ( 3 cents/kwh or less ) which then the utility ( for us it's PGE) then charges 23 cents per kwh for the exact same electrons, which they in fact did not generate.  The utility actually makes money on the transaction but has never calculated the value so it is not reported in any obvious way.  So the argument that there is a cost to non-solar customers is incorrect.  As a solar + battery owner, we not only support our neighbors by providing excess power during the day, we also can provide power to neighbors for recharging cell phones and even EVs, during a PSPS or wildfire event.  No one is quantifying or monetizing this aspect of solar+battery power, but for resiliency this is a valuable resource for neighborhoods that is not being monetized at all in your computations.  Looking forward, solar + battery on homes and government offices is a long-term resiliency investment that needs to be factored in. 
 
Making solar and battery storage more difficult will make it harder for people to put solar and battery power into their homes.  It reduces resiliency going forward and makes the costs for each PSPS event or heat event higher for the utilities. Having resilient neighborhoods will help all of the residents, reduce costs for the utilities, and help control bill costs for those with solar + battery systems, residential and commercial.  What is needed is an incentive program to put on the solar and add sufficient batteries for a 4 hour "ride-through" minimum, with an on-bill repayment system so those without up-front funding (not available from any bank I know of) can use the rebate plus on-bill system to cover the cost while reaping the benefits.  Owners of rentals should also be able to participate in the on-bill repayment system and rebate program.  I would guess that the units with a solar+battery system could even rent for more than those without.
 
With respect to the overbuilding, I would argue for 50% over-building especially if going to get a EV, heat pump, heat pump water heater, electric dryer, induction stove, i.e. going all electric.
In other words, consider all the things one would need to replace ( gas furnace, gas dryer, AC, gas stove, anything using propane, gas water heater) to go all-electric. We have an obligation to all of our next generations to cut GHG emissions as quickly as possible, so oversizing and granting the first step -(1) solar + battery systems, and the important second step, (2) on-bill financing, are key.
 
With regard to the issue of the cost of utility scale versus local distributed solar and battery systems, I would like to point out:
(1)  Long transmission lines lead to greater risk from weather events, fire, and cyberattack, whereas in-the-neighborhood locations for solar + battery will lead to greater resiliency and less risk from weather events and cyberattack. Also
(2)  Distributed energy resources, i.e. solar and battery storage, reduces the cost of upkeep for the transmission lines and the risk of wildfires  
 
The reduced maintenance and operations costs could alone be worth putting more resources in neighborhoods and on rooftops, as PGE has discovered. Increased costs for the results of fires or utility shut-off events could be quite a bit higher over the next 10-20 years, as properties become more valuable, and homeowners and commercial and small businesses discover that they have to sue to be made whole. 
 
On balance, maintaining and strengthening NEM and a strong incentive system for solar + battery systems is the best long-term plan for the future. Increased incentives for all multi-family housing and use of VNEM should be a central core of this incentive system.  A minimum of 20 years for contracts for payback is necessary to provide the basis for those contemplating installation of solar and battery systems in homes, multi-family and commercial systems.
 
In response to EV charging, if you have an EV you should add at least 2 kW of solar.  If you have solar plus battery, you should charge your EV during peak solar periods - 11 - 3 pm.  That way you use more of the sun's power and soak up the excess solar power during the day.  And many people do not charge EV's daily - smaller amounts more frequently may be the better charging plan.
 
Thank you for the opportunity to comment on your proposal.
 
Hayibo_2021-s2.0-S1364032120308832-main.pdf

Jean W. MD MPH MBA


August 31 - Osha M.

Dear Mr. Lau,
Thanks for your response.  I did attempt to listen to the meeting for a while and I heard many comments with which I agreed, and that further explained the folly of the proposal before SMUD.  I was at one time proud to be a SMUD customer because of its leadership in implementing the solar and renewable energy revolution.  David Freeman and many others worked tirelessly to create the reputation SMUD enjoys in renewable energy circles.  There must be another way to address the need to update SMUD’s programs without gutting the very thing that will help stop climate change and make the grid more reliable - distributed generation.

I was also appalled at the accessibility of the hearing tonight.  I have attended many meetings around the state both pre and during COVID.  I have never seen a meeting that did not at least make an effort to show the decision makers and key staff in real time during the meeting.  The meeting did not meet minimum standards for public accessibility in my opinion.

I ask that you please take a look at these issues and take steps to address them.

Thanks,
Osha M.
Orangevale 
Customer for 23 years 


August 31 - Lola P.

Good Morning, 

Our state is on fire and we need to do everything we can to combat climate change and reduce our use of fossil fuels. 

There are Issues with the study SMUD is using to justify this proposal and therefore the new NEM rate -

Most importantly: SMUD’s solar study incorrectly claimed that SMUD “pays” solar users for simply using their own solar energy at home. 

The study is also contradicted by mounting evidence and an analysis by national grid modeling experts Vibrant Clean Energy showing that rooftop solar reduces the cost of the electricity grid, can cut Californians’ energy bills by $120 billion over the next thirty years, and reduce global warming pollution by an additional 4 million metric tons.

Residential Solar Battery costs approximately $8,500 (Tesla powerwall) the incentive is an average of $850 which is nowhere close to making up for the gutted solar credit to make it economical to purchase a battery in addition to the cost of solar panels. This would make investing in roof-top solar uneconomical for the average working and middle class family and would make it impossible for low income families to have solar.

We know from Texas, Louisiana and locally PG&E that long distance power lines are becoming more and more dangerous - power outages, fires, etc.

This proposal will not help SMUD reach their climate goals as it will end solar-rooftop. It will kill the solar industry in California.

Also, I just want to say how disappointed I was with SMUD's frontloading the public comments with their community partners that seemed to be there only to boost SMUDs ego.

California and SMUD should lead and make solar energy possible for ALL SMUD customers not discourage the expansion of solar.

Thank you,

Lola P.


August 31 - Patrick S.

SunPower Comments to SMUD Board re NEM 2.0_8.31.21.pdf


August 31 - Robin D.

I oppose the rate hike and support Mark G's argument. The rates must be based on SMUD’s reasonable costs, not on its budget wishes, according to the CA Court of Appeal. We should have voter approval of rate hikes.

The rates were just raised in 2019. Is this a public utility or are you trying to make a profit for investors? You’re more concerned with the Stock Market than your customers. We are in the middle of a pandemic and a depression. Inflation is rising every day. We have many low-income people that cannot afford a rate increase.

In response to your argument for wildfire mitigation, how many customers live in a forested location? I don’t think many.

Regarding solar rates, if you want to have more people install solar, you must provide an incentive. This increases the amount of energy SMUD can provide. Otherwise, new customers will not install solar.
Also, if rates are raised, customers will have no incentive to install all electric homes.

Robin D.


August 31 - Ed S.

Greetings SMUD Board Members,

The SMUD staff proposal has five key elements.  The multi-prong program should be designed to work together to create a transformative policy for distributed energy at SMUD.

Some of the new elements SMUD has articulated require further elaboration.  Vote Solar strongly supports the development of an optional Critical Peak Price Rate.  The details of that rate still need to be developed and should be done quickly and transparently. Likewise, SMUD is proposing a Virtual Net Energy Metering (VNEM) program for multi-family dwellings in under-resourced communities.  Again, the details of this program need further elaboration.  We urge SMUD to quickly complete the VNEM program design so that the program can begin in early 2022.

Importantly, SMUD is proposing an innovative Virtual Power Plant Program.  This program has a lot of potential to address the need to meet the evening net peak energy requirements.  It is worth noting that the Hawaii Electric Company is already implementing the equivalent of SMUD’s battery incentive program to meet critical needs.      The Hawaii program provides an incentive of $4350 for customers who install storage paired with solar and commit to making 5 kilowatts available daily for serving peak system requirements.

SMUD is setting a goal of 30,000 customers that will have paired systems by 2030.   While Vote Solar appreciates SMUD setting a target for customer engagement by 2030.  However, we believe that the 30,000 customer participation in the VPP is not ambitious enough given the climate emergency and customer interest in energy resiliency.  We encourage SMUD to adopt a stretch goal of enabling at least 90,000 customers to install storage with solar over the next decade.  If SMUD were to achieve such an ambitious target it will clearly transform the way energy is generated and delivered for Sacramento and set an example for the rest of California and beyond.


August 31 - Laura H.

I would like the call in number to this meeting. 

The proposed interconnection fees are too high.
I am against the charge on solar & reduced export pay rate. These undervalue the health benefits of solar and will cause a loss of clean solar jobs.


August 31 - David S.

Hello, 
My name is David S. I am with the SD350 organization and I do not think that the Sacramento Municipal Utility District should go forward with some of its proposed policies for rooftop solar. For starters, the cuts that the district is making to it’s net energy metering rates will contract the market for rooftop solar. If homeowners are to be potentially paid less for the solar energy they produce, it will take them much longer to pay off the overhead fees of installing solar in the first place. This will cause less and less people to want to use rooftop solar, since they would be forced to make a much longer long term investment that is less beneficial to them. Additionally, the district should not force all of its customers to switch to a new net energy metering plan in 2030, as customers on its net energy metering 1.0 plan should be able to stay on their initial plan for 20 years after they sign on to it, which is a state standard. This is what customers have come to expect, and it allows them to follow through on paying back their overhead investments. When it comes to changes in a market like rooftop solar, which greatly emphasizes the collaboration between customer and service provider, it’s crucial to make well reasoned changes to policy. This is why I think that the Sacramento Municipal Utility District should revise its proposed rooftop solar policy changes -- specifically it’s cuts to current net energy metering plans -- in order to prevent the rooftop solar market from contracting. 
Thank you,
David S.


August 31 - Jane L.

RE: Public Comment to be read aloud, Special SMUD Board Meeting 8/31/21, topic NEM 2.0 
 
Dear SMUD Board of Directors and General Manager Paul Lau,

As a homeowner with rooftop solar, I have seen the benefits and savings available with solar-powered systems.  And, as a resident of California, I have seen the devastation and damage caused by drought, fires and floods that have been exacerbated by climate change.  Using solar power to reduce our reliance on fossil fuels is critical to mitigating this harm.  
 
SMUD’s commitment to reducing greenhouse gas emissions, as expressed in advertisements and statements on its webpage, reads well but it is contradicted by the pending proposals to reduce the credit that solar users receive for sharing their extra energy, and to force existing solar users onto the lower solar credit tier if they add a battery to their system.  Just when SMUD should be working to expand the use of solar power and make it more available to more people, it is proposing to make it more expensive for anyone who adds a battery or more solar panels or who is a new homeowner. 
 
What SMUD should be proposing is to make solar energy available to more people, such as residents of multi-tenant buildings, and to provide subsidies for low-income customers.  This would help these customers reduce their energy bills and help protect them from rising energy costs and power outages that could occur.   
 
Rolling back the successful net metering program makes energy more expensive for everyone and takes us away from the goal of reducing GHG emissions. Making solar power available to more homeowners and businesses will take us forward to a more equitable, energy-efficient system and this should be where SMUD wants to go. 
 
Thank you, 
 
Jane L.
Wilton, CA - Ward 2


August 31 - Tom W.

As part of the proposal, SMUD is stating that the new rate would apply to excess energy created.

Would SMUD please define the term “excess energy” under new proposal.
Can we assume that this refers to energy produced in excess of actual consumption, and not the solar generated for consumption.


August 31 - Megan S.

 Honorable Directors;

I think SMUD is generally, moving in the right direction, but there are areas of deep concern to me. I turn to you to express our opinions to the SMUD CEO. Primarily, it is clear SMUD has not taken the shortcomings of the E3 report seriously. In addition, they have not modified their view of rooftop solar owners as rich people foisting off paying their fair share of electric infrastructure on to the poor. This attitude offends me deeply! Short of sharing my SMUD bill and income tax return, which is not anyone's business, I will assure you I am not rich and can not afford large donations of my funds to any cause, including to SMUD to fund any energy project. 

 Let’s be clear: SMUD charges me a $22.25 “System Infrastructure fixed charge” along with County tax and State surcharge every month. And SMUD charges me for any kilowatt I get from SMUD and even breaks it down into time-of-day. SMUD knows how much energy I produce with my solar system that is saving SMUDS kilowatts for use elsewhere, just like anyone else who conserves energy. Now there is a proposal to increase the Net Energy Metering that would make it even less likely people will want to invest in Rooftop Solar or even buy home with Rooftop Solar (by State law new homes must have solar or SMUDs Solar Shares, which is less economical for the homeowner.)  SMUD apparently wants to ensure they are the only economical energy produces by snuffing individual consumer's ability to utilize the sun that hits their rooftop to provide their energy needs. This is a self-serving, policy that is not taking into consideration the consequences of their action. We need solar on every Rooftop that can support it if we a to get off our addiction to fossil Fuel

If a recent survey is any indication of participation in the Emergency battery use/ Virtual Power plant, I am severely disappointed. First of all, SMUD asked a question without giving adequate information to answer the question: if I would participate? No information about if this was behind my meter calculations if I was in control of the battery discharge and would it apply to a one-time or possibly multiple times I would be required to share my storage. In addition, they seemed to want to charge ME a large fee for my peak hours and in return give me a tiny discount (for how long or how often is not clear) on my off-peak hours as compensation, which in no way comes even close to making up for the charge, for the privilege of sharing my power in an emergency situation. Of course, this was for Emergency use, which SMUD says I would be notified in advance, most likely 24hrs in advance, but possibly only a few hours in advance. It would probably be only once a year but it could be multiple times. If this notice is by email, I could miss it entirely if it was after I checked my email, which is once a day if that! 

Let me be clear, I would graciously share my stored power for a reduced fee to SMUD, say what SMUD would normally pay for my excess energy. Considering they would be paying premium fees for kilowatts elsewhere during a heatwave this would be a great deal. Heck, I might give SMUD the energy for free if they gave me a credit for the same amount on my bill which seems to be a fair market offer. 

I have to question SMUD’s motives when they try to invent programs designed to fleece rooftop solar owners. Perhaps there are rich people with sufficient guilt complexes who would go for these schemes and willingly pay to play. But you average middle class or poor person you may have aided in getting rooftop solar should not have to pay any more than anyone else for kilowatts. They have already made a long-term investment in energy production. It is time SMUD gave rooftop solar the respect it deserves. Start treating rooftop solar-like any other energy producer. Energy Production needs to change if we are ever going to save ourselves from the worst of what climate change has in store for us. Developing micro-grids is not just another way to make corporate size profits, it is to build a resilient grid and our salvation. I recommend diverting funds from long-distance power lines into developing micro-grids that connect and share evenly & fairly, throughout the SMUD territory.

The Survey left me confused and convinced SMUD is still operating on incomplete and poor data from the E3 report that doesn't take into account the damage Carbon is doing to our habitat and the price of its effects on our lives (warming-drought-wild fires-loss of homes-infrastructure loss-and loss of human and animal lives-decreased food production-burned watershed -lack of potable drinking water-potential eco refugees) This is the only reason I support a price on carbon. Additionally, E3 does not address the economics of long-distance power line construction, maintenance, and their risk of causing fires and blackouts if they fail or are turned off during red flag warnings. Then that leads to refrigeration failures that cost thousands in food waste, medication waste, and loss of productivity and revenue to small businesses and taxes that would have been paid to the state.

Take a lesson from PG&E Long-distance lines have risks.

My short-term hope is SMUD makes an attitude adjustment towards Rooftop Solar that is needed if we are to succeed in my long-term hope, that we prevail in the fight of our lives for a stable, safe livable climate.

--Sincerely,
Megan S. B.S.N.


August 31 - Frank L.

SMUD Board - Statement of Frank L 08-31-21.pdf


August 29 - Sean F.

I am writing to address your proposed changes to Solar and Storage rates and the terms of those rates. I relocated to Sacramento from Placerville about a year ago. At my old residence, I installed solar panels in an array that was about the right size for my residence and needs. I did so with an understanding of the rough payback time, based upon the rates and the way my utility, PG&E, would compensate me for generating excess electricity. 

When I moved to Sacramento, installing solar at my residence was at the top of my list of items to do at my home. In doing my research, I discovered immediately that SMUD was proposing new rates of compensation, and that the sizing of my system would be limited to the past usage at my residence. Both of these factors immediately gave me pause. Should I invest my money in a system when the payback time might change? Does it make sense to purchase a system that is too small because my residence has been occupied by my 90 year old monther-in-law (who used much LESS electricity than a family of 4 with children doing distance learning and adults working from home)? Just the uncertainty was enough for me to reconsider installing solar.

Now that I see what you are proposing, I have to say that solar would no longer make sense for me and my family. I say that as someone who is keenly aware of how climate change is threatening the future of our species and as the parent of two sons who will inherit this deadly mess if we don't start fixing it now. I WANT to do the right thing, and I WANT a public utility that helps me do it. Instead of discouraging rooftop solar, I would like to see it expanded to include more people in multi-unit housing and incentives for low income ratepayers and renters. I know that rooftop solar alone cannot solve the climate crisis, but it MUST be a viable part of the mix. 

Let's just be clear--the changes you are proposing will kill rooftop solar. They will certainly cause more GHGs to be released (in direct opposition to your "Carbon Free 2030" initiative.) They will incent people to purchase dirty GHG releasing gas and diesel generators to protect against outages. They are NOT in keeping with your mission as a PUBLIC utility tasked with acting in the public interest and necessity.

You must reverse course and return to providing the incentives to grow rooftop solar and storage in our region. Your ratepayers and the young people of this region are watching. Do the right thing.

Sincerely, 
Sean F.


August 28 - Lee M.

The SMUD Board members have expressed a desire for NEM 2.0 to grow the solar market in Sacramento, but the executive staff has shown once again that they don’t have the same desire. As the basis for the proposal, SMUD executive staff used the water carrier for the California Utilities and the CPUC consulting company E3 report as the basis for SMUD’s NEM 2.0 proposal. The SMUD website is full of public comments regarding the flaws in the E3 study. During a SMUD board meeting over 80 people were waiting to make their public comments on this flawed study, but many had to drop off the line because the meeting was running long and the SMUD board decided not to be flexible to let people make their comments when a panel participant offered to give up their time on the agenda. But the executive chose to use the bad data anyway.
When bad data is used, well, as the old saying goes, Garbage in and Garbage out.
SMUD staff claims that the large reduction in export credits will not impact the market, a puzzling and insincere claim. Staff is projecting that their proposed NEM 2.0 plan will lead to 39,000 additional solar-only customers by 2030, equivalent to 4,300 projects per year, which is nearly the current installation rate. SMUD’s NEM 2.0 proposal will bring the number of PV-only projects closer to zero according to the industry initial estimates. 

An export rate of 7.4 ¢/kWh would also jeopardize the new solar homes mandate as the Energy Commission can only enforce requirements if they are cost-effective. Further, last year, SMUD pushed through a special allowance under the state building code to build utility-scale power plants in place of rooftop solar incorporated into the building. 
 
SMUD’s NEM 2.0 proposal includes incentives for energy storage systems. Great news, but customers enrolled in critical peak pricing, or the virtual power plant program will receive additional benefits, but SMUD has yet to release the details. The board has promised transparency, but as usual, the executive staff does not unless they are pressured by customers, someone raises an issue to their board member or someone asks for a public record request.
 
Other proposals presented by SMUD staff related to solar will further impede the market. SMUD would like residential interconnection fees to increase to $475 for systems <10 kW and $900 for systems >10 kW. Commercial interconnection fees would range from $2,500 to $5,000.
  
Utilities should be able to recoup the costs of interconnecting systems, but SMUD proposed fees are significantly higher than the fees in other utilities. Interconnection fees in LADWP, which has a highly resource-intensive interconnection process, the charge is only $130 to recuperate their costs for systems <30 kW. So why the large discrepancy? Where are the numbers to back the need for these high interconnect fees? Another example of Executives Staff lack of transparency.
  
The current NEM 2.0 proposal does not include a fixed charge nor charges on the solar energy consumed on-site, and that is a very good thing. The $25 million battery incentive program could help grow the battery market. The virtual power plant program, if done right, could increase the PV + storage projects, but the information released does not have the details needed to make any real estimates as to how much and how effectively these programs and how it will lead to the closing of local fossil fuel power plants. Again, lack of transparency on the part of the Executive Staff.

SMUD's proposal ignores a longstanding California principle that ensures solar users can stay on the same net metering credit for the lifetime of their solar system which is 20 years. SMUD executive staff is proposing 10 years. Solar users make a significant investment that has important community and societal benefits, a request that was ignored by Executive Staff as a requirement for the E3 report. Solar users are owed the consideration of a likely return on their investment. SMUD's proposal destroys that likelihood.

SMUD Board and executive staff have shown time and again, that they do not think the energy produced by a customer’s solar panels is valuable. They do not see rooftop solar as an important way to reduce air pollution and help SMUD achieve its zero-carbon goals.

SMUD’s Zero Carbon by 2030 plan which was created as a result of the climate emergency declaration calls for an additional 250,000-500,000 kW of rooftop solar by 2030. If SMUD kills the cost-effectiveness of solar, SMUD will not meet its goal and encounter great difficulty in closing its fossil fuel power plants, three of which are in low-income neighborhoods. Has executive staff not noticed that California has been in a 10-year drought? The drought is lowering water levels in dams and reservoirs which will impact, the hydroelectric power plants. So where will this gap in energy come from?  SMUD might need even more rooftop solar than originally thought to meet its zero-carbon goal. Perhaps executives staff behind-the-scenes plan is to keep the fossil fuel plants open longer, blaming the drought instead of the short-sightedness of the executive staff NEM 2.0 plan as the excuse.

The board sets the policies, and the executive staff carries out that policy. It seems that the executive staff has fallen very short of achieving the board's expressed goal. The board needs to send this proposal back to executive staff and have them come up with a better plan with more transparency and customer participation

Sincerely
Lee M.
Ward 3


August 31 - Steve U.

Director Rose,

Perhaps SMUD staff are not aware I am attending the meeting, just can call using the phone number provided by SMUD 1-669-524-5252

Please confirm the SSR requirement the renewable generation facility has to be eligible for certification as a renewable energy source as defined by the CEC.

In my written comment I have submitted the CEC's RPS Eligibility Guidebook, where on pdf page 11 the CEC clarifies the WREGIS approval requirement for certification approval.

CEC requires the facility to be registered and approved in WREGIS. This WREGIS registration has a fee of $50.00 per year.

The registration will also mean the excess energy SMUD receives will be considered null power that SMUD will have to match with REC of RPS compliance.

This will increase the costs for the PV owner $50 per year.

Other customers are burdened with the REC costs for RPS compliance for the null power SMUD receives from the PV owner excess generation.

Thanks for relating my comments at the hearing,

Steve U.


August 31 - Rick U.

Dear Mr. Lau,

I am writing on behalf of the Solar Energy Industries Association (SEIA) to express concern regarding the proposed revisions to SMUD’s net metering (NEM) tariff for distributed solar and storage.1 While SEIA recognizes that compensation structures should evolve to reflect changing technology costs and grid needs, we are significantly concerned about the changes proposed by SMUD. To be clear, SEIA supports a transition to solar plus storage driven by rates and incentives that enable customers to electrify their homes and businesses and use their onsite resources in a manner that is most beneficial to the grid. To this end, we are supportive of net billing as a successor to net metering and dynamic rate design. However, we are concerned by the pace and magnitude of the changes proposed by SMUD for its NEM successor tariff. Our concerns are put forward in more detail below:

1 SEIA is the national association of the solar industry, representing over 1,000 member companies across all market segments.
• Fair Treatment for Existing Net Metering Customers: As customers make investments in clean energy resources, it is imperative that they feel confident those investments are stable and will pay off over the long term. SEIA urges SMUD to ensure fair treatment for existing solar customers. Specifically, SEIA urges SMUD to allow existing NEM customers to remain on their current NEM tariff for 20 years from interconnection. This is industry standard in California and throughout much of the country and is a policy that SMUD should adopt as well.

• Export Rate: SEIA is concerned with the significant reduction in the export rate proposed by SMUD. As proposed, the export rate would be reduced from 11-18 c/kWh to 7.4 c/kWh. A reduction of this magnitude would have a major impact on customer economics and, if implemented without a transition, would result in significant disruption to the local solar industry. In keeping with the fundamental rate design principle of gradualism, and SMUD’s role as a community institution, SEIA urges SMUD to adopt a glidepath to allow the local solar industry to adapt to changes in the export rate.

• Energy Storage Incentive: SEIA is supportive of up-front incentives to help customers buy down the cost of battery energy storage. However, SEIA is concerned that the storage incentive proposed by SMUD is inadequate to enable robust customer adoption. Given the acute need for clean backup power in the face of extreme weather events and increasing dependence on reliable power, it is imperative that customers have access to energy storage. Further, as SMUD recognizes, solar customers who pair their systems with storage can provide greater grid and environmental benefits to their neighbors and community. Therefore, SEIA encourages SMUD to increase the proposed storage incentive to enable more customers to adopt battery energy storage.

• Virtual Net Metering: As we electrify and decarbonize our grid, we must do so equitably to ensure all residents benefit from clean local power. One of the best ways to do this is to expand virtual net metering (VNEM) to allow more customers to go solar. To this end, SEIA urges SMUD to expand VNEM to all multitenant properties including commercial properties.

SEIA appreciates the opportunity to comment on SMUD’s NEM successor tariff and urges SMUD to consider these recommendations.

Regards,

Rick U.
Senior Director and Counsel, California
Solar Energy Industries Association (SEIA)


August 31 - Fatima M.

Thank you for your email Paul.  

I understand that this is what SMUD wants, but this does not reflect what the community wants. As a "community" owned non-profit, SMUD should also listen to the wants and desires of the community. Surely you don't think that SMUD is the only one that cares and is concerned about climate change, I certainly do and I'm sure that many SMUD customers are also concerned. 

Communities are still struggling due to COVID, climate-change induced heatwaves and wildfires. In quoting a community member "if you want to lower my blood pressure, help me pay my electricity bill"

My neighbor's electricity bill was over $400 a month last summer and she was suffering from economic inequity because she was drowning in utility bill debt from her children being home more and using more energy. She installed solar and is now able to afford her bill which is around $100/month. Why don't you all ask SMUD customers to provide their feedback and input on this proposal via a survey or poll or vote to see how they feel about this proposal? Should the customers have a say and input in these decisions that will affect their lives. 

My relatives live on the second floor of an apartment and called me last week and asked why is her SMUD bill so high? It's over $400. I think you all need to go back to the drawing board and work with people in this space that are focusing on developing evidence-driven policies that will provide the public with information on the outcomes of utility programs.

I appreciate what you all are seeking to achieve, however, the methods and means to get to that end should not cause harm in the way you're proposal has laid out for the financial health and well-being for many SMUD customers. 

I encourage you all to learn about and even consider working with the Center for Race, Energy, and Climate Justice (Pecan Street). 

https://www.pecanstreet.org/work/justice/

The entire country is engaged in a broad and long-overdue examination of the roles that race and racism play in our society – our legal system, workforce, communities, politics, schools, and more.
Race also plays a role in energy – who has access to it, how much they pay for it, who works in the energy industry, who lives near our power plants, and who has a seat at the table to determine energy choices that our towns, cities, states and countries make on our behalf.
We also know that communities of color will bear a disproportionate share of the impacts of climate change, and that if climate solutions are not implemented with equity in mind, they, too, could further widen the equity gap.
Pecan Street’s Center for Race, Energy & Climate Justice was developed to bring our organization’s unique data and research capabilities to this critical and complicated issue.
We will not solve this issue alone. But with our partners, we aim to leverage our decade of energy and water data collection and analysis to highlight areas of concern and opportunity that will be key in achieving fairness and equity in an area that plays such a central role in our lives.
I trust that you want to do the right thing and do it in a fair and just way that this current proposal does not do. 

Respectfully,
Fatima 


August 30 - Mark G.

August 30, 2021 

Directors of SMUD, 

I will welcome any questions you have, either for me or for staff, about the constitutionality of the current and proposed rates.  In this email I propose five (5) questions that the Board can ask staff to get to the bottom of the issue, whether the proposed rates for 2022 and 2023 are taxes as defined in Article XIII C of the California Constitution.  If they are then they must be approved by the electorate. 

My slides reply to some of staff's responses to when I made a similar argument in the 2019 rate hearing.  Nobody on the Board questioned staff on staff's obviously irrelevant responses at the time.  I am hoping that this time around the Board members will question staff on those responses, if staff makes them again.  Such as saying that other states allow the use of a scalar in setting rates or that the CPUC allows it.  Both statements may be true but they are 100% irrelevant, because utilities in other states and utilities regulated by CPUC (investor owned utilities) are not subject to Proposition 26 and Article XIII C of the California Constitution, but SMUD is.  

Staff's claim in the 2019 rate hearing that the rates were really based on "embedded cost" is obviously false, both because the CEO and GM Reports (for 2017, 2019 and 2021) explicitly say that the rates are based on SMUD's marginal cost, and because when I made a Public Records Act request shortly after that meeting for SMUD records that described or quantified SMUD's "embedded cost" SMUD told me that it had no responsive records.  None.  If SMUD's rates approved in 2019 had really been based on embedded cost there would be many records about that cost. 

You are more than capable of framing your own questions for staff but I will propose 5 questions in case staff uses these false excuses again. 

1.  It may be true that utilities in other states are allowed to use a scalar in setting their rates, but those utilities are not subject to Proposition 26 and the California Constitution, Article XIII C, so that is irrelevant.  Is that true? 

2.  It may be true that California's investor owned utilities, which are regulated by the CPUC, are allowed to use a scalar in setting their rates, but SMUD is not an IOU and not regulated by the CPUC, so that is irrelevant.  Is that true? 

3.  At least four SMUD documents state unequivocally that SMUD rates are based on its marginal cost of providing electricity.  As the 2018 RT02 rate design study shows, SMUD's rates are 9.2% higher than its marginal cost.  Why did staff claim in the 2019 rate hearing that SMUD rates are based on "embedded cost"?  Staff's claim at the 2019 rate hearing that its rates were NOT based on marginal cost appears to be both a blatant falsehood and irrelevant, an attempt to divert attention away from the issue.  Please explain.  

4.  Is there any rate design study for the rates approved in 2019 other than the 2018 Residential Time-of-Use Rate (RT02) Design Study?  Did that analysis show that SMUD's rates do not exceed SMUD's reasonable cost of providing electricity?  Please elaborate.  If the current rates are taxes then the proposed rates are taxes too, so yes the current rates are relevant to this rate action.  

5.  How would it make any difference whether SMUD rates are based on this phantom "embedded cost" versus marginal cost?  The requirement in Article XIII C is that SMUD's rates must either be approved by the electorate or must be no more than SMUD's reasonable cost of providing the service.  Whether you claim your rates are based on marginal or embedded cost, you still must comply with Article XIII C.  Please respond in detail. 

Supporting evidence for questions 3, 4 and 5: 

The CEO and GM Report for 2021 says, "SMUD uses marginal cost to set rates."  (page 98).  
The CEO and GM Report for 2019 says, "SMUD follows the marginal cost approach from NERA and industry best practice rate principles to determine how much it costs to provide service to customers."  (page 28) 
The CEO and GM Report for 2017 says, "The proposed prices by time period for the Time of Day (5-8 p.m. Peak) Rate are based on SMUD's most recent marginal cost study."  (page 27)
SMUD's 2018 Residential Time-of-Use Rate (RT02) Design Study is all about marginal cost and says, "SMUD’s proposed rate structure as defined by the Chief Executive Officer & General Manager’s Report and Recommendation on Rates and Services is based on by SMUD’s Marginal Cost of service. Marginal costs are the additional costs SMUD incurs to provide electric service to a new customer, a new load or the savings expected from not serving that customer or load."(page 2)   
None of these four documents mentions the term "embedded cost."  
SMUD never made any written analysis of its "embedded cost" of providing electricity.  Mr. Graham found this out through his Public Record Act request in 2019.

Clearly SMUD sets is rates based on marginal cost.  

Directors, these questions will enable the Board to really understand the issue and get relevant information from staff.  Please ask staff these questions tomorrow night.  

Sincerely, 

Mark G.

Sent from my hard wired computer 


August 30 - Debbie S.

Your communist rate increases for solar and over next two years to support solar which is killing our planet shows how stupid and political you are. You make me sick!!


August 30 - Al R.

Hi Paul:
 
Thank you for your very considered response to my Email, it is appreciated.
 
I too am disappointed that CALSSA did not engage in the Collaborative meetings and I did my best to fill in. The team was wonderful to work with and positive things did come out of it like the VPP and CPP program, with storage incentives.
 
Of greatest concern to me is your statement: "While I acknowledge that you’d prefer a later implementation date, SMUD’s proposal is holistic, data-based and fair to continue to support the growth of solar and storage in our service territory."
 
Please understand that it is not that I prefer a later implementation date, but that my agreement to support the final rate design was predicated upon the start date being January 1, 2023 as a compromise to not having a much needed glide path. 
 
I have in my 3/10/21 notes that January 1, 2023 was going to be the start date. "Financial successor Rate Modeling - Jan 2023." I sincerely believe the extra time is vital to not do serious damage to the solar industry in Sacramento.  
 
I do find it very hard to believe that starting 1/1/2023 would cost SMUD $10,000,000. On the contrary, it will help keep the solar industry healthy, give time for transitional training for selling batteries and serve SMUD's 2030 goals well. 
 
I don't know if you know this but there currently is a severe battery supply shortage that we hope will be over next year and we also hope battery prices will be lower so the payback period, even with SMUD incentives is not so long, generally over 14 years.  
 
The supply shortages, increasing material costs, COVID problems etc. have put a strain on many including solar installation companies.  Staying in business this year has been a big challenge and we will probably show a loss this year. By the way, the collaborative modeling placed the cost to install a battery at $10,000 before incentives, which is about our cost or less, in reality to be an actual surviving business, we must install at between $12,000 and $14,000. And now the CSLB is taking away solar C-46 contractors ability to install batteries, something C-46 contractors have been doing for 40 years. The cost of having a C-10 electrical contractor install batteries will be much higher. We are being hit hard from all directions.
 
And now we have to contend with a $475 fee and the likelihood of not selling much solar in SMUD next year (we sold one system in Roseville over the past 4 years).  We need that extra year to adapt as was agreed to in the Collaborative meetings.  We really do want to sell batteries in SMUD but need to be around to do so, we want to be a good partner with SMUD.
 
Paul, please understand that this is a matter of survival for us and many other companies and employee jobs.
 
One thing I pushed back hard on was a very faulty comment made in a collaborative meeting by a SMUD member stated "I don't think middle income should pay for wealthier (peoples solar systems)."  This is so very untrue and shows a great misunderstanding and insensitivity to reality.  Most  SMUD solar sales are to middle income homes and even lower income because the financing works, barely, but it works.  At 7.4 cents, financing will have a definite negative cash flow which will greatly effect middle and lower income peoples ability to go solar.  This will push SMUD sales to upper income people, the exact opposite of what it should be. 
 
Anyway, sorry to go on, I greatly admire SMUD and do appreciate SMUD's effort here but we do need that January 1, 2023 start date, we need time to adjust and recover from this very bad period of time, it will ultimately truly be to SMUD and its customers benefit. 
 
Kind regards,
 
A R


August 31 - Steve B.

Dear Paul,
Thank you for the response. I have now corresponded with a number of SMUD Board Members and the common theme of this proposed action as explained to me is ratepayer equality. It seems to me the decision has already been made and the meeting will just be a public rubber stamp. HOWEVER, let me note this:
When this great nation was founded, only the very wealthy paid federal taxes. The Founding Fathers set this country up so those better off helped support the have-nots. Our entire nation was founded on the idea that we are one community, that we stand together, and that those who are able will help those who need it for the common benefit of us all. Frankly, that IS the American Way.
One example of this, of course, is the property taxes we pay to support our schools. I have no children in public schools. I have not had kids in the schools for decades. Yet the wife and I still happily pay our taxes to support the schools. It helps us all. We are part of the community and are happy to do our part.
The SMUD proposal on the table does NOT help our community. It only helps those who have not invested in solar. The proposal on the table only helps the wealthy at the expense of the poor. Ratepayer equity is all well and good, but I must point out that is a socialist idea, not an American idea. If America adopted your “equity” idea on a broad basis, we would witness the end of America. 
As always, I urge SMUD to do the right thing. Not the cheap thing. Not the things that help the rich over the poor. Not socialist ideas. 
I urge SMUD to: (1) not cut the solar support, (2) give solar to the poor in our community as it helps us all, (3) do more weatherization and insulation and make it free to the poor; and (4) don’t be afraid to ask the well-to-do to do their part for our communal benefit. United we stand, and prosper. Divided we fall. Please be part of the solution.
Steve B.
SMUD customer


August 30 - Jennifer B.

Dear Paul, as a concerned citizen who believes in the value of solar and that our rights and benefits to the use of solar should be protected, I beg you to reconsider SMUDS proposal to decrease the net metering credit applied to solar owners under all circumstances.  A reduction of the credit is a bad decision for customers and for SMUD.  Obviously, it would decrease the benefit of solar use to current solar customers but it would also reduce the likelihood that people would go to solar in the future Additionally, it would mean that SMUD cannot be trusted because you don't stick to your promises and you don't ultimately have your customers best interest in mind.  Shame on you for even considering this!

Thank you, Jennifer B.

Sacramento CA 95820


August 30 - Erik R.

Dear Member Tamayo and General Manager Lau:

I am writing to oppose the proposed modifications to SMUD’s residential solar programs. I personally made an investment in solar last year. I felt that it was important to reduce my own footprint and increase local energy resiliency. Also, I wanted to reduce the environmental impacts, and the social and economic costs of centralized solar.
 
The changes in energy buy-back pricing, limitation on use of batteries, and limits on sizing of solar will deter other SMUD customers from making the investments needed to achieve a more sustainable and resilient electrical grid. 

SMUD should be promoting small-scale rooftop investments while at the same time pursuing larger scale solar projects.  Both are needed and the current proposals go too far in slashing incentives for residents to make these investments.

Specifically, while the costs that SMUD pays for its infrastructure and risk management are indeed going up, they are going up because of the reliance on non-solar elements of the energy portfolio. Wildfire risk is mitigated through residential and rooftop sources; home batteries should be a critical part of regional shifting to renewables; additional transformers and other fixed infrastructure needs can be reduced through localization.
 
Please reject this ill-conceived proposal and instead sustain the historic commitment to-support small-scale solar and all of the local businesses that help make these investments possible.
 
Thank you for your attention,

Erik R.


August 30 - Alan E.

Dear General Manager and SMUD Directors, 

I live in Natomas Sacramento and I own a small roof top solar system. I oppose the proposed reduction in net metering compensation for SMUDs solar customer partners. The reduction from retail rate to approximately the wholesale rate is too low, making new rooftop solar infeasible. The proposal includes a grandfather status that expires in only eight years, ( in 2030) which does not cover the typical payback period and is to be implemented immediately in January 2022, without a transition period. Finally, If an existing solar customer wants to add a solar battery then that customer loses their grandfather status!  This is a HUGE disincentive in adding solar batteries to existing systems. SMUDs Solar battery incentive program is insufficient  to overcome the removal of one's grandfathers status. SMUDs current proposal is an improvement over their ill conceived March 2019 proposal, but I cannot support it as currently proposed. Thus I am recommending five changes to SMUDs rate proposal which I will summarize in my conclusion. 

If SMUD Directors approve the proposed NEM rate reduction I believe it will decimate the local solar industry making roof top residential and commercial systems economically infeasible. I can make this statement with confidence because it has been done before.  Nevada in 2015 reduced the NEM retail rates to wholesale rates, which prompted a legislative reversal two years later as described in the next paragraph.. 

Net metering subsidy has been in place in Nevada since 1997.   Before 2016, Nevada utilities paid people with solar panels the “retail” rate for electricity.  In 2015, the Nevada legislature passed a law that required the commission to examine the electric rate structure and to look at cost shifting.  On December 22, 2015, regulators in Nevada created major controversy following their decision to reduce rooftop solar incentives in addition to creating new fees for solar owners.  The new rates and conditions apply to both new and existing customers and changed the NEM rate to the "wholesale" rate. The reduced rate was to be transitioned over four years. This decimated the Nevada solar industry and they lobbied hard to reverse this new rate structure. The decision prompted Nevada solar groups and the Nevada Attorney General's Bureau of Consumer Protection to intervene in 2016. They challenged the commission's decision based on the fact "it violated the contract clause of the Constitution because many rooftop solar contracts were predicated on retail rate net metering.  In response, a twenty year grandfather clause to cover the systems life expectancy for existing solar systems was added.  After two years the public demanded that the solar industry be restored, so In 2017 Nevada legislators passed a  bill to restore favorable reimbursement rates for net metering customers.  Under the new system, new rooftop solar customers will receive a reimbursement equal to a percentage of the retail price of electricity whenever they send their own energy back to the electric grid. That percentage rates are known as "tiers" and while not full retail they are much more than whole sale rates. 

The proposed NEM rate reduction can certainly pose the same risk to our local solar companies as it did in Nevada.  This could result in a significant reduction in new residential and commercial rooftop solar systems installations and associated increase in green house gas emissions causing significant  adverse environmental impacts,. If that risk is real and likely, then SMUD should be required to conduct a CEQA review.  SMUD's analysis says that it will not have a reduction in new rooftop solar systems after the new NEM rate is implemented, indeed they expect an increase in solar energy from 215 MW generated to 445 MW by 2030. This is an very important prediction and SMUD should document in detail the assumptions that went into this astonishing claim. 

To lessen the shock to the solar industry and to local solar customers (residential and commercial) any significant reduction in NEM rate should occur over a transition period not less than four years in order to adequately cover family and business financial and budget planning. 
And the grandfather status for existing systems should be lengthened to either the systems 20 year life expectancy, or at a minimum, to the systems payback period  of 12-15 years as determined previously by Nevada's Attorney General Bureau of Consumer Protection. 

I, like many others, want to add solar panels and batteries to convert my house from PG&E gas to all electric and also accommodate the future purchase of at least one EV, if not two. I understand under the current proposal I would lose my NEM 2.0 grandfather status if I did so before 2030. The $500 to $1500 storage incentive also proposed by SMUD does not come close to make my system upgrades financially viable (or new systems)especially under the proposed NEM rate reduction. I firmly believe SMUD customers are willing to subsidize greater incentives for solar+battery storage as this is a huge step forward in combating climate change!  SMUD needs to remove this grandfather death clause disincentive from their NEM proposal. SMUD's $25 million solar battery incentive program is too low.  I believe the funding runs from January 2022 through December 2030? So on average the program allows for approximately $3m annually? I contend that the incentive should start at $1500 and go to $5000 in order to properly incentivize new solar battery storage. 

I also wanted the batteries to mitigate future increases in power outages anticipated due to climate change. The alternative to solar/storage is to purchase a generator that runs on natural gas. (or diesel) Whole house generators are a much better option financially if the NEM proposal passes with the included grandfather death clause.  Residential, businesses and critical public safety facilities especially, should not have this disincentive to adding batteries to their current rooftop solar systems. The potential negative impact of solar battery reductions and increases in whole house diesel and natural gas generators should be included in the CEQA analysis if the grandfather death clause is included in the NEM proposal.  

My little 3.8kw system saves over 4300 lbs of coal burned or 440 gallons equivalent of gas guzzled per year. This directly relates to a reduction in local GHG emissions, but in the Value of Solar analysis it appears this is a societal benefit and is not included as a monetary benefit? I could be wrong about that as it was kind of confusing to me. It  just seems all the money I spent up front (at the urging of my Government and SMUD I might add) on a system that provides benefits to not just me, but also to my community is discounted and revenue loss to SMUD is the driving force behind the value of solar calculations. 

In summary, 

1) I agree that SMUD should be compensated for appropriate justifiable connection fees. I believe that there should be a reduction in NEM 2.0 compensation, just not to the amount proposed of 7.4 cents per kw. That is too low and will kill the local solar industry and reduce the number of rooftop solar built (adverse regional impacts) significantly affecting an increase in GHG emissions. (adverse local, regional and global impacts) If that is a likely outcome of the NEM proposal- then I believe SMUD is required to prepare a CEQA review. 

2)  Any significant NEM rate change should be implemented over a period of no less than four years and grandfather status for existing systems should extend to 20 years or, at a minimum, the calculated payback period 

3)  If an existing solar customer wants to add a solar battery it should not affect their grandfather status. SMUD needs to add incentives to solar batteries, not disincentives! 

4) SMUD proposed solar battery program needs to raise its incentive contribution starting at $1,500 up to $5,000. I think SMUD can afford this as their rates are at least 38% lower than PG&E. I believe the community would support this too. SMUD should send out a survey to see how much the community is willing to support solar and solar storage , after all many, including me, contribute extra dollars to be supplied with  green energy at extra cost…and we did vote to decommission nuclear power in the past. 

5) If SMUD makes substantial NEM changes it should conduct a annual survey to  determine if the rate change caused a significant reduction in new roof top solar installs on previously built homes as compared to the rate of installation in the pre-covid year 2019.  

Thank you for the opportunity to share my views.  As a community owned, not for profit utility,  I hope the primary focus is not on revenue loss in regards to roof top solar benefits calculations. I do not think that approach fits our community and SMUD's mission and values. 

PS: I first attached the word document, then decided I should just copy the word document text in this email... so you do not have to open the attachment unless for some reason you want to save this email. Thanks for all you do in volunteering your time to the community. 
Sincerely, 

Alan E. 
Sacramento Ca. 95835 


August 30 - Don H.

Why should the general public add batteries when SMUD gives with one hand and takes with another?  Furthermore, is SMUD going to quickly build another utility-scale plant of any type during an emergency need?


August 30 - Jon S.

SMUDs plan to reduce the credit for solar customers to 7.4 cents/kwhr is the wrong move.  SMUD has been one of the leading utilities in the market supporting solar, but this cut does not accurately reflect the value that distributed solar adds to the grid.   

This will keep solar in the Sacramento region out of the hands of many of the low-income customers that would benefit the most from adding solar to their house.  

I want to see SMUD continue to be a leader in utility-owned solar, but this proposal undercuts and undervalues distributed generation and harms your customers.

Thank you,
Jon S.


Jon S.
Managing Partner
Peak Demand 


August 31 - Steve U.

Please include this statement and the attached PDF, as part of Steve U's PUC 14403.5(b) report for SMUD board's consideration at the 8/31/2021 rate hearing.

Please post on the SMUD board meeting web site so I may reference this and my full report at the rate hearing.

SMUD Rates staff have said "No" to my question:

"Do customers that wish to be on the SSR rate, have to register and in WREGIS and RPS Online System before SMUD will allow enrollment in the SSR rate schedule?"

TN217317_20170427T142045_RPS_Eligibility_Guidebook_Ninth_Edition_Revised.pdf PDF page 11 says:

"Clarifies that a facility shall be registered and approved in WREGIS before an application will be approved for RPS certification in Chapter 3.A.1."

For the SMUD Rates staff reply of "No" to my above question to be correct, please remove "eligible for certification as" from SSR I. Applicability statement of:

"A renewable electrical generation facility is a facility that is eligible for certification as a renewable energy resource as defined by the California Energy Resources Conservation and Development Commission (CEC).1 These facilities include, but may not be 
limited to, generators fueled by:"

Steve U.


August 30 - Martha O.

Dear Mr. Lau and concerned board members,

I trust that the board will lead with their hearts and weigh the facts before making any significant changes to the current net metering credit agreement.

As a lifelong resident of Sacramento and advocate of solar use, I appreciate all that SMUD has done to provide the grid infrastructure and electrical system to myself and other residents of the Sacramento and surrounding areas. However, I am concerned about SMUD’s current proposal.

As a resident who recently installed a rooftop solar and battery system to my home, I’m concerned how SMUD’S proposal will likely reduce the sales value of my home or decrease my investment or benefits to the community at large. I’m also concerned how such a change will likely negatively impact the solar industry in California.

Like other sunny states, I’d like to continue seeing California as a leader in providing affordable and renewable sources of energy to everyone.

Thank you for your consideration, efforts, and making this very difficult decision for all concerned citizens.

-Best regards

Martha O.
Rancho Cordova, CA 95742


August 30 - Todd P.

Hi Paul, 

Do you have any idea what a TESLA battery costs? It's around $12,000 for a single unit. Not affordable at all. I financed my panels and I'm still mad that I could have installed more solar but was limited by SMUD to being net zero because SMUD is just a bunch of greedy bastards who want to use more expensive energy sources than the inexpensively (for SMUD)  produced energy because hey, solar doesn't work. 

Solar does work and will work if SMUD would stop their greed and fear of becoming irrelevant.  As  long as SMUD is limiting the number and amount of homeowner produced electricity you have no right to a "price reduction" to float more expensive energy sources. 

You people suck! 

Todd P. 
Carmichael, CA 


August 30 - Stacy and Phil K.

Paul Lau 
General Manager
Sacramento Municipal Utility District

Dear Mr. Lau:

We have just been informed that SMUD is considering slashing the rate that is paid to solar users for the extra energy we produce that then is shared with the community.  This proposed action is untenable and is a slap in the face to those of us who have purchased solar systems with the notion that we are helping, not hindering, SMUD in meeting their energy needs.

We have been solar users since 1999.  We were, in fact, one of the first homes outfitted with panels with the assistance of a SMUD Solar Program.  We received a low interest loan to help pay for the system, and were given guidance from SMUD employees.  It was a great program; one that caused us to truly believe we were part of the solution to the global warming/climate change disaster that is now upon us in full force.  We have since updated our system, on our own, but believe that alternative energy sources are necessary to allow our children, and our children's children, to live in a habitable world.

This rate slash that you are considering will not help our efforts to overcome climate change.  To the contrary, discouraging the addition of rooftop solar systems will put SMUD among those organizations who don't give a damn about solving the climate crisis by subjugating true climate solutions to a greedy bottom line.   

SMUD needs to reject this proposal.  To not do so negates any indication that SMUD is interested in encouraging alternative sources of energy.  Many working- and middle-class individuals who are weighing the decision to purchase a solar system are much less likely to do so when the economic benefit is reduced to the extent that SMUD is proposing.

SMUD's proposal violates a longstanding California principle that ensures solar users can stay on the same net metering credit for the lifetime of their solar system - twenty years.  What you are proposing is unconscionable; to approve this rate slash makes a folly of any claim of community concern that SMUD may possess.

You know better.  Do the right thing and reject this proposal.

Sincerely,

Stacy K. and Phil K.

cc:  SMUD Board of Directors


August 30 - Clay N.

Mr Paul Lau: 
SMUD has had a great history of being a forward thinking utility. 
I have always loved you guys, don't change course and screw things up.
We need more solar, keep doing your part to make it happen,
                   Don't Slack Off Now !
    
      Together for an all electric future,    
--Clay N.


August 30 - Paul S. M.Ed., CPhT, FCSHP

Dear SMUD Board of Directors,

Please do not slash the credit for solar users’ extra energy to a flat 7.4 cents per kWh.

We do not want to be forced onto this new rate if we choose to add a battery or additional panels that increase my solar generation by more than 1kW or 10 percent (whichever is greater). If one day I decided to sell my home, the new owner will be forced onto SMUD’s reduced credit. This will likely reduce the sales value of my home. 

This SMUD proposal violates a longstanding California principle of guaranteeing that solar users receive the same net metering credit for the lifetime of their solar system – twenty years. We rooftop solar users make a significant investment that has important community and societal benefits. We are owed the courtesy of a predictable return on investment to where, SMUD’s proposal ruins that predictability.

Kind Regards,

Paul S., M.Ed., CPhT, FCSHP


August 30 - Shishpal R.

SMUD instead of accepting and promoting use of small scale solar powered energy production is trying very hard to make it very difficult for the average user to install and recoup its investments in solar panels. While SMUD should be trying to get energy from every rooftop, it limits the production a homeowner can have off its rooftop.  SMUD needs a new business model by which it offers to buy excess capacity from ALL available rooftops and switch to renewable energy as soon as practical.  SMUD needs to change its financial model to be more efficient in the new age and not work on simply making SMUD's existence (in its current form) its primary goal.

Please hire an external consultant from the New and Renewable energy sector rather than your traditional energy consultant to engage SMUD in a new and sustainable financial model and one that does not repeatedly target small businesses or homeowners.

WHATEVER YOUR PROPOSAL/FINANCIAL MODEL - IT MUST ENCOURAGE AVERAGE HOME OWNER TO INSTALL ROOFTOP SOLAR.  If it doesn't it's simply UNACCEPTABLE.

Thank you.
Shishpal R.


August 30 - Osha M.

Dear General Manager and Board:
I am writing to oppose the proposed modifications to SMUD’s solar programs.

The changes in energy buy-back pricing, limitation on use of batteries, and limits on sizing of solar will deter residents from making the investments needed to achieve a more sustainable electrical grid.  SMUD should be promoting small scale rooftop investments while at the same time pursuing larger scale solar projects.  Both are needed and the current proposals go too far in slashing incentives for residents to make these investments.

I also support more initiatives to get multifamily and commercial structures into solar.  We have a great climate for these investments and SMUD should not be fighting actions that will reduce pollution and provide more grid resilience in our region.

Please support small scale solar and all of the local businesses that help make these investments possible and do not adopt the changes as proposed.

Thanks,
Osha 

Osha R. M.
Orangevale, CA 95662


August 30 - Melanie L.

Dear SMUD Directors,
In consideration of SMUD's mission of increasing energy accessibility and decreasing the carbon footprint of human activities, I ask you to please reconsider your proposed fees and incentives for homeowners installing solar panels and tying into your grid.  

First, the fee for homeowners tying into the grid should be lowered nearer to the fee charged by PG and E.  Second, the credit for home solar collectors contributing to the grid should not be decreased so drastically.  I have heard the argument that the availability of energy from solar farms makes the homeowners' contribution less valuable.  However, as droughts lessen the availability of hydroelectricity, residence-sourced solar electricity should be more valuable.  Third, rebates to support homeowners' installation of batteries to store electricity should be more robust, to encourage battery acquisition.  Your fee and incentive policies should be aimed at allowing more people of different income levels to contribute to providing more renewable energy sources.

Thank you for your consideration.
Melanie L.


August 30 - Bruce M.

Dear Board Members, 

I am quite concerned about SMUD's proposed changes to how you credit solar users for the extra power they produce. Crediting your new solar customers just 7.4 cents per kilowatt for extra power they produce and requiring the purchase  of a backup battery, adding thousands of dollars to the cost, will kill any incentive for purchasing and installing solar panels. It will, in effect, put the cost of solar out of the reach of your middle class customers and kill the solar industry in the Sacramento area.

I also feel betrayed by your plan to give your current solar customers only 10 years, at the most, before forcing us to the new rates. I am quite sure we have helped SMUD avoid brownouts and rolling blackouts because of the extra power we have generated and which then became available to SMUD and their non solar customers. In return, we get this terrible, proposed, job killing plan.

I am, therefore, asking you to reject this plan, which will not help your customers, and most likely cost many of your customers, who work in the rooftop solar industry, their jobs. 

Thank you,

Bruce M. (SMUD customer for over 60 years)


August 30 - Dave G.

Paul, 
The proposal to go down to 7.4 cents is not acceptable.

SMUD's proposal violates a longstanding California principle that ensures solar users can stay on the same net metering credit for the lifetime of their solar system - twenty years. Solar users make a significant investment that has important community and societal benefits, and are owed the courtesy of a predictable return on investment. SMUD's proposal ruins that predictability.

Thanks
Dave G.


August 30 - Eric S.

Hello Paul, 

As a parent of three children and a SMUD customer I am writing you to hopefully connect with your humanity.  Smoke fills the air.  Science know well that human induced climate change is causing our planet to possibly become a waist land for human human beings.  SMUD should be doing everything possible to fully transition our energy grid to renewable energy over the next five years.  Photo voltaic solar panels is an obvious means to help solve the problem.  If you work to lower the incentives for residence to place solar panels on their homes than far less homes will be able to finance solar.  

These issues are becoming obvious to all.  Renewable energies should be further incentivized not disincentivized.

Please do what’s best for humanity as a whole and stop the  disincentivizing  of solar or else you and SMUD will go down as evil entities that will need to be fully exposed.

Sincerely,

Eric S.
Folsom. California


August 30 - Fatima M.

Dear Paul and SMUD Board Members, 

As a solar customer of SMUD since 2016, I urge you to change your proposal and to protect solar customers. You should be promoting more solar for all instead of less. Your proposal will negatively impact the already high inequity in utility debt burden which is the highest among Black, Latino, and economically vulnerable neighborhoods. I urge you to implement more equitable policies overall regarding your rates, and especially regarding solar energy. 

Please do not make this enormous mistake of devaluing the solar energy produced by SMUD customers. Instead you should be valuing the solar energy produced by your customers and allowing more options and energy freedom and independence. 

Thank you and please do the right thing,

-- 
Fatima M. 


August 30 - Lola P.

Good Morning, 

Our state is on fire and we need to do everything we can to combat climate change and reduce our use of fossil fuels. 

There are Issues with the study SMUD is using to justify this proposal and therefore the new NEM rate -

Most importantly: SMUD’s solar study incorrectly claimed that SMUD “pays” solar users for simply using their own solar energy at home. 

The study is also contradicted by mounting evidence and an analysis by national grid modeling experts Vibrant Clean Energy showing that rooftop solar reduces the cost of the electricity grid, can cut Californians’ energy bills by $120 billion over the next thirty years, and reduce global warming pollution by an additional 4 million metric tons.

Residential Solar Battery costs approximately $8,500 (Tesla powerwall) the incentive is an average of $850 which is nowhere close to making up for the gutted solar credit to make it economical to purchase a battery in addition to the cost of solar panels. This would make investing in roof-top solar uneconomical for the average working and middle class family and would make it impossible for low income families to have solar.

We know from Texas, Louisiana and locally PG&E that long distance power lines are becoming more and more dangerous - power outages, fires, etc.

This proposal will not help SMUD reach their climate goals as it will end solar-rooftop. It will kill the solar industry in California.

Also, I just want to say how disappointed I was with SMUD's frontloading the public comments with their community partners that seemed to be there only to boost SMUDs ego.

California and SMUD should lead and make solar energy possible for ALL SMUD customers not discourage the expansion of solar.

Thank you,

Lola P.


August 30 - Rick C.

Comments on SMUD’s Proposed Critical Peak Pricing 
Rick C. August 31, 2021

I strongly support the intent of the Critical Peak Pricing (CPP) program to encourage the installation of battery storage and other future resources in SMUD’s planned Virtual Power Plant. My comments here apply to CPP as a condition of SMUD’s battery incentive program. 

The current GM Report on Rates and Regulations does not provide actual CPP rates and otherwise offers only scant information. Yet, batteries are such a big investment that SMUD should post more details on this new tariff to allow prospective customers to evaluate the financial benefits for investing in storage and committing to the CPP program.  The tariff becomes effective next June, but the pricing and conditions should be published well in advance – by the end of this year, for example.   Here are some questions that the CPP should be answering:

What Is the Discounted Non-Peak Pricing?  What are the discount prices for mid-peak and off-peak time periods?  Do they apply to all non-peak hours during the summer season, including weekend and holidays?  For solar customers, the details are particularly important since discounted off-peak prices will effectively lower savings during solar self-consumption hours.

What Is the Critical Peak Pricing Rate?  The original SmartSacramento pilot in 2011 balanced the off-peak discounts with a very high CPP rate of 75 cents/kWh as an incentive to voluntarily curtail loads when activated.  The current proposal is for a price adder during CPP called events on top of current TOD prices.  Will this be a fixed adder set annually, or a per event price?  Will the rate change each year?

When the CPP extends beyond the peak period, will the adder be applied to baseline TOD or to the discounted TOD mid and off-peak pricing? Does this also apply to export power to the grid during called CPP events, or is the adder on the current export compensation rate? 

What Are the Terms for Participation?  Will the battery discharge be controlled by SMUD as a condition of participation?  How long will the commitment be to the CPP program?  The Report says a minimum of one year but implies a longer period may be required.

Can SMUD Share Cost-Benefit Analysis?  The Report notes that the CPP program will be financially neutral for SMUD ratepayers.  But can staff provide details on the estimated potential savings and payback for program participants?  If SMUD expects 30,000 battery participants to help meet its Carbon Zero goals, it should demonstrate the cost benefits for their relatively large investment in batteries. This is particularly true for existing solar customers contemplating upgrading to solar + storage since participation in the CPP program will entail losing their grandfathered pricing status for the sale of export generation.

Will SMUD Support CPP for New Construction?  A good portion of the projected new solar installations will be in new construction where Title 24 requires it.  However, SMUD’s Neighborhood SolarShares program offers builders to opt out in favor of participation in a SMUD solar farm.  This option jeopardizes local solar + storage distributed generation.  As an alternative, SMUD can extend Virtual Net Metering program, currently proposed only for affordable housing projects, to new and existing multi-family complexes, allowing more of these units to participate in CPP and battery installations.

Rick C.


August 30 - John B.

My name is John B.  I was a non-NEM representative on the Technical Working Group -- Value of Solar and Storage.  I have remained engaged in the process for the adoption of NEM 2.0 and submit this email as my comments concerning the adoption of the proposed changes to the NEM program. 

There are common systemic issues all utilities in California are facing from the impact of NEM 1.0 on utility rates:  (i) There is a significant and growing cross-subsidy paid by non-NEM customers to NEM customers which has a disproportionate impact on the low to moderate income population and (ii) NEM customers do not pay a fair share of the costs of the fixed assets needed to deliver on demand power shifting these costs to non-NEM customers. 

Indeed, those who can participate in roof top solar and storage and electrification, such as electric cars, are more affluent.  NEM 1.0 effectively imposes a regressive tax on those least able to absorb it-- a reverse Robin Hood situation.  It is only fair that a rate structure be adopted which avoids a windfall to better off NEM customers.  

It is also important to remember that NEM 1.0 was designed to provide a generous financial incentive to promote the nascent solar industry.  Needless to say, the solar industry has matured and is vigorous.  The goal has been reached.  Simply stated, there is no need to continue to make grossly inflated energy purchases to spur the solar industry.  A fair value for NEM energy deliveries was developed through a painstaking and thorough analysis starting with the Working Group and ending with the E3 report after robust public participation.  That effort should form the bedrock for NEM 2.0 because it reflects a considered analysis taking into consideration the relevant factors identified by the stakeholders. 

In my travels I have also read a criticism of NEM 2.0 as "penalizing" NEM customers for generating their own power. This argument ignores a two basic facts:   

First, NEM customers are not "off the grid".  When the sun goes down or does not shine on overcast days, they flip the switch and the lights turn on because of power supplied through the grid.  Conversely, the grid takes delivery of their excess power.  The importance of basic grid infrastructure, including reliable and dispatch-able generation, has been recently demonstrated by the shortage of capacity during hot days. 

Second, tested by market standards, the rate at which NEM customers are reimbursed for delivered power is not competitive.  Solar farms deliver power at 3-4 cents/kwh versus about 12 cents for NEM customers.  If anyone is getting penalized, it is non-NEM customers who are paying dearly for NEM generated electrons.  

At bottom, the consideration of NEM 2.0 should be driven by fundamental fairness.  E3's valuation of solar and solar plus storage is a solidly derived value. While it is more than the wholesale rate of scaled up solar, it takes into consideration the unique aspects of roof top solar, particularly when storage is considered.  Moreover, the disparate impact on low to moderate income customers must be addressed:  How can the reverse Robin Hood condition be perpetuated?  I believe that as a public entity SMUD has a higher duty to make sure energy is delivered at a fair and sustainable price to all customers, without shifting costs from the have nots to the haves.  At the same time existing NEM customers should be protected for a reasonable period by continuing NEM 1.0 in recognition of their reliance on cost/pay back calculations which likely influenced the decision to install solar.  Furthermore, incentives from SMUD for the addition of battery storage should be adopted because the data demonstrates it is a cost effective technology in the long run.   

Thank you for considering my comments.   


August 30 - Sean F.

Thanks for your reply. This all sounds great—until you realize the end result will be no new rooftop solar and storage being installed.

I, for one, will not make the investment because I will not be able to get it installed before 1/1/22. And, even if I could, your policies would not allow it to be sized appropriately for our current and future needs; When we add panels in the future, they would be at the lower rate. You also fail to take into account the MUCH higher connection fees you charge solar customers—mine was $9.86/month with PG&E in Placerville—just to give a specific example of HOW MUCH higher yours are. 

If you take this approach, you are NOT acting in the public interest, and the net effect will be in direct opposition to your carbon free 2030 goals.

We, the ratepayers, are watching and will take appropriate action if your mandate to operate in the public interest is ignored. 

-Sean


August 30 - Johan v R.

Dear Paul,

Solar Rights Alliance just made me aware of a possible reduction in SMUD NEM rates. Such lower rates make it much harder for me as a homeowner (who would like to get solar in the near future) and small landlord (currently in the process of possibly installing solar on two houses) to invest in solar for my tenant’s single-family homes, so I kindly request you to keep the current rates. We understand SMUD has overhead costs as well, but for our use case, a lowered NEM rate would make solar investment financially very unattractive.

Best regards,

Johan v R.


August 30 - Sean F.

I am writing to address your proposed changes to Solar and Storage rates and the terms of those rates. I relocated to Sacramento from Placerville about a year ago. At my old residence, I installed solar panels in an array that was about the right size for my residence and needs. I did so with an understanding of the rough payback time, based upon the rates and the way my utility, PG&E, would compensate me for generating excess electricity. 

When I moved to Sacramento, installing solar at my residence was at the top of my list of items to do at my home. In doing my research, I discovered immediately that SMUD was proposing new rates of compensation, and that the sizing of my system would be limited to the past usage at my residence. Both of these factors immediately gave me pause. Should I invest my money in a system when the payback time might change? Does it make sense to purchase a system that is too small because my residence has been occupied by my 90 year old monther-in-law (who used much LESS electricity than a family of 4 with children doing distance learning and adults working from home)? Just the uncertainty was enough for me to reconsider installing solar.

Now that I see what you are proposing, I have to say that solar would no longer make sense for me and my family. I say that as someone who is keenly aware of how climate change is threatening the future of our species and as the parent of two sons whowill inherit this deadly mess if we don't start fixing it now. I WANT to do the right thing, and I WANT a public utility that helps me do it. Instead of discouraging rooftop solar, I would like to see it expanded to include more people in multi-unit housing and incentives for low income ratepayers and renters. I know that rooftop solar alone cannot solve the climate crisis, but it MUST be a viable part of the mix. 

Let's just be clear--the changes you are proposing will kill rooftop solar. They will certainly cause more GHGs to be released (in direct opposition to your "Carbon Free 2030" initiative.) They will incent people to purchase dirty GHG releasing gas anddiesel generators to protect against outages. They are NOT in keeping with your mission as a PUBLIC utility tasked with acting in the public interest and necessity.

You must reverse course and return to providing the incentives to grow rooftop solar and storage in our region. Your ratepayers and the young people of this region are watching. Do the right thing.


Sincerely, 

Sean F.


August 29 - Manual A.

I just learned that SMUD or staff has proposed to significantly cut the credit solar users receive for sharing their extra energy with the community. I'd like to state my opposition to this proposal.  

Net metering lets solar users share their extra solar energy with the community for a bill credit. SMUD currently credits solar users at the retail rate. This means SMUD buys that extra solar energy for the same price it sells it to the community. This makes sense, since SMUD didn’t have to pay to make that energy, and pays very little to transport it. SMUD should maintain this option as a community utility.  If SMUD is truly interested in middle and lower-income members of the community it should develop programs for solar on rental property.  

It's time for SMUD to take a leadership role in the expansion of customer-centric energy systems and how a community-based utility can continue under this business model. Continuing to use monopoly utility arguments will only do a disservice to SMUD as a community-based utility. 

I will be happy to meet if you would like to discuss further. Let me know if you have any questions. 


August 29 - Jim S.

As a loyal SMUD customer for 44 years and a rooftop solar owner for 6 years, I am very disappointed in the direction SMUD is going with its Net Energy Metering (NEM) policy.  As a Professional Engineer thoroughly familiar with California utility policies and procedures, I concur with the desire to accurately price residential solar credits, but the proposal does not do that, and goes too far.  It makes existing rooftop solar completely uneconomical for existing systems installed under the "Million Solar Roofs" policy.  Only new construction, with mandated solar, will contribute to renewable generation.  Is that SMUD's intent - to kill the economics of rooftop solar? 

Personally, I am absolutely opposed to the current proposal.

Please see the attached comments on the E3 study.

-- 
Jim S.

SMUD NEM


August 29 - Al R.

Hi Paul:
 
I trust you are having a good weekend and are staying out of the smoke. Thank you for all the hard work you and your wonderful staff are doing for the community and the environment.
 
I also appreciate all the hard work that has gone into SMUD’s NEM 2.0. Unfortunately, the program that Staff came up with differed in critical ways from what I understood it would be. I do have to correct some errors about my thoughts in the Collaborative meetings.
 
1. That I “am comfortable” with a 7.4 cent NEM 2.0 rate.  I never was as can be seen from my attached October 21, 2020 Feedback response sent to all members of the Collaborative meeting which stated:
 
“CALSSA has an awesome team that is looking forward to working on the true VOS and making NEM 2 work for a win, win for everyone.”
 
This statement meant I wanted to see the true value of solar accounted for and that I didn’t agree that it was as low at 7.4 cents. (I stated that many times in the Collaborative meetings) I did agree that it is easier for customers to understand one kWh price, but I was obviously hoping it would be higher than 7.4 cents as a true value of solar. 
 
With the price at only 7.4 cents, it also makes sense that a higher price be paid to Battery owners when they supply power during super peak periods.
 
As the Collaborative meetings went on it became clear that 7.4 cents was what SMUD was stuck on so I emphasized that a glide path was vital to not damage the solar industry in Sacramento as seen in my statement:
 
2. “Because selling Solar in SMUD is already a delicate balance of cost to benefit for the customer, it is very important that there be a “glide path” to any reduction to export rates until a robust battery program is established, and strong critical peak (real time) pricing can be established to incentivize customers.  This is so important for resiliency and meeting the wonderful and extremely important 2030 Climate Emergency Resolution.”   
 
As the Prop 26 issue entered the room a compromise to have NEM 2.0 start on January 1, 2023 was reached. 
 
I thought this was fully agreed to and I was very disappointed to find Staff had moved it to January 1, 2021 which is to soon for us to adjust to and will hurt the solar industry as I and many others have pointed out many times.
 
Please find my original Letter attached in full and please call me with any questions.
 
Thank you,
 
Al R.

Collaborative Meeting - 1 - Reply


August 29 - Tom W.

Dear Mr. Lau,

Of course you are intimately familiar with the above image and message from the SMUD homepage.
However, when I heard about your plans to cut the solar credit to a flat 7.4c / kWh, I was seriously wondering how these two messages fit together.

I, too, want to live where they take care of the planet… and I am writing to you today, on a day when the outside air quality is so bad that it is considered hazardous to spend time outside.
Wildfires are a big problem in California; many of us remember the devastating Campfire that originated from an electrical transmission line.  Global warming is real and we see the results of decades of denial right here and right now.

Yet, despite those significant challenges and despite SMUD’s own vision of achieving a zero carbon economy, you continue to do everything in your power to make roof top solar unattractive.  

Not only would the proposed changes make solar prohibitively expensive for anybody installing a system from 2022 onwards, but even current solar system owners, who had their systems approved and installed before then, get slapped in the face by forcing them into the new rates by 2030.  It is incomprehensible that those who made a significant investment and relied on rate stability are now being undermined by your proposal.  

We need more roof top solar, not less!  
There are plenty of studies, and I am sure you are familiar with them, that show that decentralized power generation provides significant economic benefits to everybody, not just to the owner of the roof top solar system.  The SMUD rate proposal ignores that and its justification is based on a flawed study, conducted by a consulting firm with an agenda, that 
incorrectly claims that solar users get paid by SMUD 
No, they are just not being charged for the energy produced and consumed by themselves or within the local community.
completely ignores positive externalities from solar, such as a reduction of global warming pollution 
These externalities benefit everybody, whether solar owner or not.  Again, looking out the window, seeing nothing but smoke, it should be easy to see that these positive externalities have a clear financial and social benefit to the community.
was conducted based on outdated climate change goals, with SMUD operating fossil power plants past 2040 
I applaud the SMUD Board of Directors for recently adopting a much stronger goal of zero carbon emissions by 2030.  The overwhelming impacts from global warming worldwide require a radical change in energy policy and roof top solar is an important aspect of that.

I have been following SMUD’s various attempts to undermine roof top solar installations for quite some time now and I can only hope that the recent, and devastating impacts from global warming (more intense and frequent wildfires, floods, unexpected winter storms, etc.) and the many voices from the local community and others make you reevaluate whether this aspect of SMUD’s strategy is truly in line with SMUD’s own goals and what the community / public is asking for.  To me, it is not.

I am also hoping that SMUD’s publicly elected Board of Directors sees the clear conflict between the proposed solar rate change and what the local community and the State of California needs.

Please reconsider your proposal and make a forward-looking decision to take care of our planet: support and encourage solar, don’t fight it!

Thank you,
Tom W.


August 28 - Roberta F.

I have always been proud of and happy to have SMUD services. However, I am deeply upset with and offended by your continued efforts to backtrack on promises made and the basic premises of your support of solar. I have installed three soar slystems - two on rental properties (a single family hoem and a triplex) and one at my residence. How many property owners have installed solar at rental properties? I did so to do my part for the enirvonment and to assist tenants who have difficulty affording their utility bills. The investment does not cost out but I was committed to doing the right thing to help our world at home.

I am adamantly opposed to each of your proposals including:

1. reducing credit if a home is sold and violating the longstanding California principle of ensuring the benefit of the same net metering credit for 20 years - th lifetime of a solar system;

2. the proposed changes would make it extremely difficult for the average middle class faniliies who have the least ability to absorb increasing energy costs for their homes;

3. the study by E3,a  bought and paid for expert, lacks credibility;

4. the approach  to multi-fmaily propeties lacks fairness - my properties are not officially designatated as low income properties but they are rented by young people who have to struggle to make ends meet - they need the benefit of solar power;

5. the arbitrary limits on the number of panels installed is unfair; at the time the evaluation was made for my residence both of the children were off at college thus making my needs appear unreasonably low; my home is large with 4 bedrooms and the usage during the time evaluated was not reflective of what it would be for a family of more than one parent; my future plans included added a garage with an apartment above so it was recommended that I install additoinal panels when that propject was completed; our next car purchases (mine and two for my adult children) will be electric so adding EV access is appropriate and a good thing; people who had the forethought and willingness to suopport solar SHOULD NOT BE PUNISHED - homes should be evaluated more accurately rather than makeng efforts to reduce access to solar;

6. the proposed new connection fees seem unreasonable given the actual cost of connecting solar systems.

I believe you do not appreciate the anger and discontent you are cultivating  for SMUD which historically has been a much valued and appreciated company.


August 27 - Cindie F.

You are not listening.   I am an all electric house with solar panels and a battery.   As soon as I can I will be completely self sufficient.    I do not need SMUD.   I will be encouraging my neighbors to do the same.

Sent from my iPhone


August 27 - Bernard S.

Paul,
I have rooftop solar from TESLA.  I feel that SMUD is betraying me  by reducing the payments I get for sharing my electricity.  I try to be a good citizen, and SMUD stabs me.

Bernard


Bernard E. S.

Sacramento, 
Mission Statement:
I enjoy myself. I pursue health, wealth, organization, and happiness. I improve things. I honestly communicate.


August 27 - Mark G.

Hello SMUD,

Please acknowledge your receipt of this message and the attached file of slides. 

I have sent you information about the proposed rate increases and my first alternative recommendation to it a long time ago, starting on June 18, 2021, which was the day after SMUD began the current rate process, and then on August 15.  Among the files I sent you on June 18, 2021 was my power point from the SMUD rate action hearing on June 4, 2019.  

In this message I am sending you some of that information about the current rate action in a slide format I have used before, a power point.  Please make this power point, the attached file, available to each member of the Board and staff and to the public through the SMUD website.  Please have it ready to go prior to the start of the hearing on August 31.  

I also asked you for your cooperation in allowing me to present my slides, my power point, during my 5 minute presentation to the Board during the rate hearing.  You have failed to acknowledge that request and respond to it.  I am asking you again.  

What I would like to be able to do is simply say, "Next slide" when it is time to advance to the next slide, and for somebody at SMUD to advance to my next slide.  Will you do this?  Yes or no.  Please reply in the affirmative ASAP. 

Sincerely,

Mark G.

SMUD rate hearing August 31, 2021 presentation

Sent from my hard wired computer


August 27 - Cindie F.

Why would you want to punish those of us with solar panels?   Is your profit more important than saving the earth for your children?  You should be more encouraging of homeowners who have or want solar power.  I don’t think SMUD is trying to protect the earth.  It won’t matter how wealthy the shareholders become if there is no earth.  Not thinking we all will move to another planet.
 
Sent from my iPhone


August 27 - Ed M.

Hi Paul,
Please find attached a sincere letter from the solar industry.
Kind regards,
Ed


August 27 - Charles A.

I understand the issues surrounding solar on home owner’s rooftops. The most important one I believe is that SMUD has a dilemma, specifically that they do not have enough storage capacity for after dark operations without having costly, and polluting, generation plants that would not be utilitzed during the day. I am aware that SMUD has the ability to use battery storage capacity that homeowners can provide. I have been considering adding batteries to our solar system. This proposal would prevent me from doing so due to your proposed cost adjustments. This is not only a disservice to me but to all of your customers because I would allow SMUD to utitlize excess capacity from batteries that I owned thus assisting SMUD in reducing their costs and those of their customers. I strongly urge you to consider this and that every solar owner contemplating installing batteries will likely have the same issues. 

SMUD is NOT a for profit company and should start acting like what they are a “Municipal” utility owned and operated on behalf of the people of this area. 

Please do NOT approve this proposal.

Charles L. A. III


August 27 - Denise A.

Good afternoon Paul and SMUD board. I am hearing terrible news about SMUD wanting to cut solar incentives and effectively hard the future of solar installation. 

California is fighting annual massive wildfires and our annual snow pack is disappearing. Climate change is catastrophic to us. We need to promote more, not less green energy. Please do not increase the cost of solar hook-ups, reduce the buy-back program, or institute high fees on each user. This puts us backwards to fight for our planet. Thank you. 

Denise A.


August 27 - Elia B.

Hi! I have two properties that I'm in the process of doing solar in Ward 6. 


I support the new rates, I think 7.4 cents is actually a very good deal for solar owners at todays solar cost. But, 

I think it is so fair I propose no house cap on solar size. or a larger cap like double annual usage or 20kh/hr or something.


Proposal:
State Net Metering Requirements
net to 110% approved at 7.4 cents
+110%-220% at the cost of utility scale, say 3 cents/kw. 

Take a step back, I'm not a property owner, you're not in charge of SMUD. Just problem solving energy solutions objectively. If a house is installing $20,000 solar project. Economically, is it most efficient to add one more kw to that existing system or build a new system? I think the proposed rates are Very fair, but I propose we piggy back as much solar as possible to each development at the cheapest construction cost and save SMUD rate payers too. 

PS, I am part of the solar rights alliance due to the proposals for flat solar fees, I was adamantly against that, but I fully support the SMUD rates and almost even think 7.4 is too good of a deal for solar owners. I want the rate to be low enough SMUD thinks it's a good deal and will not cap project size. 

I am afraid of the research on heat island effects of utility scale solar. 

Thank you for all your time and work!
Elia B. (Ward 6)

August 27 - David W.

Dear President Bui-Thompson and the Board [Ms. Lofton, thank you for forwarding to the entire Board],

Please see the attached comments from 350 Sacramento regarding SMUD's pending rate proposal, which is to be discussed at a SMUD public hearing Tuesday August 31.

Thank you.

David W.

Sent with ProtonMail Secure Email.

350Sac-SMUD Bd Ltr on Rate Proposal 8-27-21


August 27 - Don H.

Please do not slash the credit that solar users receive for sharing their extra energy with the community.

-- 
Don H.


August 27 - Cinda J.

I would appreciate you and others would stop the threats of  extra charges to rooftop solar customers. I got solar to make my imprint on our climate less and save a few $$ in my bill.  I know SMUDs goal of getting all their power from renewable sources so these long running threats are puzzling. Please leave us alone and be thankful some of your customers care about clean air and water.
Sent from my iPhone


August 27 - John W.

Please consider this: Any action you take to reduce or prevent clean energy production, regardless of how it is produced, will result in making the global climate situation worse. The only solution to the climate crisis is the production of more clean energy. Therefore, as the leader of a utility, you must not take action to stop or slow down the production of clean energy. To do so would be to contribute to the crisis. You must find a way to meet SMUD's needs without making the crisis worse. 


John W.


August 27 - Franco V.

To all, 

I am writing because I have just been apprised of a possible decision by Mr. Lau and the SMUD Board of Directors. I cannot think of any justification the board would have in making a negative ruling on homeowner solar power at a time such as this.

At a time in the world when Climate Change is no longer a question of "if and when", but is devastating significant portions of the world now, our leaders should be addressing how to fight back by encouraging new technologies. This is a primary effort that can determine the way mankind will survive now, and in the future, by reducing our carbon footprint.

Solar power is the way going forward. There should be a concerted effort to encourage homeowners to install solar, currently, an expensive investment but one that will pay dividends over the life of the system. 

Instead of reducing the "net metering credit", SMUD should be substantially increasing the credit as a means of expanding the grid to handle the summer electrical use demands that will surely come, and will grow each year. I do not understand why you want to throttle growth of solar power at a time when we need it most. Will there still be enough power when our reservoirs no longer have enough water to supply our needs?

We already know what happens when a power company (read, PG&E) puts profit ahead of its clients and responsible management. Is SMUD planning to start down such a path?

Respectfully,
Franco V.
SMUD Customer


August 27 - Steve B.

Dear Paul Lau
SMUD General Manager,

I am writing to express my deep disappointment at SMUD’s persistent anti-solar actions. While giving lip-service to being pro-solar, our community-owned utility - that purports to be community-responsive – is working quietly to discourage rooftop solar with battery backup.

SMUD’s latest attack is something I would expect from the despised PG&E, not my community-owned utility. SMUD has proposed to slash the credit that solar users receive for sharing their extra energy with the community, from an average of 13.5 cents per kilowatt hour to just 7.4 cents per kilowatt hour. If this proposal goes through, solar will become unaffordable for most middle and working class people in the Sacramento area. 

If SMUD truly had the best interests of the community at heart, it would RAISE the credit amount given to rooftop solar providers. This would, in turn, incentivize homeowners to invest in solar, providing more power into SMUD’s grid, enabling the utility to sell power as Sacramento is blessed with abundant sunlight. 

But this is not the road SMUD has chosen. Instead, SMUD wants to kill rooftop solar in favor of large solar plants hundreds of miles away, with power moved over transmission lines – lines that have started wildfire, lines that have caused Californian’s to die, lines that cause regular power blackouts, lines that PG&E says it now has to charge ratepayers BILLIONS to move underground.

This is not the way forward. This is keeping us stuck in a system that worked well over the last 100 years but will not work going forward. We need to plan now for a better future, and that future is rooftop solar with battery backup.

I urge SMUD to immediately fire the staff who thought up this harebrained scheme and instruct a new, better staff to incentivize rooftop solar. SMUD commissionaires who want to keep Sacramento locked into an antiquated power system should immediately resign or face recall.

DO THE RIGHT THING for us all. Be part of the solution – do not perpetuate the problems of the past.

Steve B.


August 27 - Nihad H.

Dear Mr. Lau,

I've just learned that SMUD has proposed that effective January 1, 2022 to reduce the credit received by roof top solar users presently receive for sharing their extra energy with SMUD to a flat rate of 7.4 Cent per kWh. I would like to point out that this proposal will discourage most people from installing  solar panels because it makes it economically not advantageous. Given the State of California leadership in combating climate warming and its efforts to ultimately eliminate the use of fossil fuels in electrical power generation, I find this proposal contradicts this State's goal. Therefore, I respectfully urge you not to support this proposal.

Thank you ,


Sincerely,

Nihad A. H., PhD


August 27 - Colleen J.

Mr. Lau, 

As a single parent who passionately cares about the disturbing rate of acceleration of global warming, I am begging you to please not make it financially more difficult for families to obtain and keep solar energy. SMUD should be going “green” as you keep claiming instead of secretly and hypocritically punishing solar owners who put so much less strain on the power grid by giving that power back. 

I struggle financially already so much, and because SMUD would not allow me to put up more panels, my true up settlement is very high. It has actually cost me more to use solar and this is wrong. You should be moving forward and taking steps to assist environmentally- sound energy instead of dragging us backward into an age of climate disaster. I beg you to find some conscience and think about your children’s future living environment. Please help solar, not punish this invaluable resource, for the greater good of all. 

Sincerely, 
Colleen J. RN, single mother , SMUD client and proud solar consumer 


August 23 - Severin B.

I would like to weigh in in favor of the SMUD 2021-22 Rate Proposal.  I think it is an important first step in moving policy on Distributed Energy Resources to focus on compensating the value these resources bring to the grid.  As we battle the climate crisis, there is quite a lot of uncertainty about the value of different low-carbon resources in different locations on the grid. This proposal improves the alignment of financial incentives with the best available knowledge today about the value of DERs.  In my view, it probably is still overly optimistic in valuing the contribution of DERs, and in the vision for the size of the DER role in the grid. However, I do believe that DERs have an important role to play, and our knowledge of the most cost-effective low-carbon grid architecture continues to evolve.  At this point in that evolution, the proposed changes are a prudent step in the right direction.

I would also like to commend the expanded use of Critical Peak Pricing in the proposal.  SMUD has been a leader in this important area, which will be crucial to grid balancing as evening net peak demands grow due to a warming climate and increased solar adoption.  CPP is the most proven-effective tool in eliciting demand-side adjustment to help balance the grid when it is under stress.

Sincerely,

Severin B.


August 20 - Steve U.

Report and recommendations

Re: comment on GM rate report


August 16 - Ben D.

PDF Presentation


August 15 - Mark G.

August 15, 2021

Board of Directors and staff,

Please place this in the record of this meeting. Public comments on items not on the agenda.

This is my first alternative recommendation for SMUD's 2022 and 2023 rates and charges, annotated.

SMUD should back out the 9.2% scalar that SMUD built into the original time of day (TOD) rates in 2017, plus all of the across the board rate increases that have increased that scalar up to about 10.7%, before applying the proposed 1.5% and 2.0% rate increases. This applies to the rates per kWh and the system infrastructure fixed charge (SIFC) for the rates and charges of all customer classes and categories to which the 9.2% scalar was added.

When I say back out I mean to multiply the current rates by a number that is less than 1 such that you will arrive at rates that you would have had if SMUD had never added in the 9.2% scalar in the first place. Such a calculation will reduce the current rates by something in the neighborhood of 9.2%, but not exactly that amount due to the mathematics of it. The 9.2% scalar plus all the subsequent across the board rate increases is currently "baked into" SMUD's rate and charges. It should not be.

The reason is that the current and proposed rates are taxes as defined in the California Constitution, Article XIII C, and SMUD never presented these rates and charges to the electorate nor received the approval of the electorate. General taxes cannot be imposed, extended or increased unless approved by a majority of the electorate. Special taxes may not be imposed, extended or increased unless approved by a 2/3 majority of the electorate. SMUD imposed these taxes in 2017 and extended and increased them in 2019. The proposed rates for 2022 and 2023 would extend and increase these taxes again.

My June 18, 2021 email, with all four (4) attachments, explain the issue in depth. I incorporate that email and those attachments into this alternative recommendation by this reference. One of those was the original rate design study referred to by NERA economic consulting in their letter in the CEO and GM Report and Recommendation on Rates and Services, which was Appendix I. That rate design study showed the line by line marginal cost components, and the sum of them, and then showed the addition of the 9.2% scalar which was intended to align the rates with SMUD's predetermined budget. The scalar is not one of your costs! And for that reason it should not be built into your rates. SMUD fails to understand the relationship between its costs and its rates.

As my analysis shows, the original time of day rates exceed SMUD's reasonable cost of providing electricity by slightly more than 9.2%. The definition of a tax is very broad, but a charge or rate is not a tax if it qualifies for any of the seven exceptions. The only exception that could even possibly apply to SMUD rates and charges is e2, which is that the rates do not exceed SMUD's reasonable cost of providing electricity. But my analysis shows that they do exceed it by 9.2% at the time. The "scalar" that SMUD built in is not authorized by any statute or case law or any other legal authority. I even provided authority in terms of case law saying that, essentially, the government may not base its rates on predetermined budgets. That appears to be exactly what SMUD has done.

SMUD has failed to provide the following:

1. A law or court opinion that supports SMUD adding a 9.2% scalar into its rates, as it did in the original TOD rates approved in June, 2017;

2. A law or court opinion that supports SMUD setting rates based on "embedded cost" AND SMUD's analysis of its embedded cost, if there is one AND an explanation with a legal basis of how adding a scalar transforms the marginal cost into a so called embedded cost.

I ask SMUD to provide these items to the public (all of SMUD’s customers, via the SMUD website with a special notice of this new information) as soon as possible, and no later than a few days prior to the rate hearing, scheduled for August 31, 2021, so that members of the public may have time to review and prepare comments on what you provide. One form in which SMUD can provide them is an errata to the 2021 CEO and General Manager’s Report. I recommend that.

Please note that the 2020 Rate Costing Study, Planning, Pricing and Enterprise Performance, March 31, 2020 failed to provide justification for SMUD's proposed rates. Have you read it? Has any Board member actually read this rate costing study cover to cover? It is not included in the CEO and General Manager's Report, nor is it available on the SMUD website. You should make this available as an errata to the CEO and GM Report.

There are only a few sections of this study.

There is 1, Introduction and 2, Marginal cost components with Table 2.1 – Classification of Marginal Cost Components.

The Introduction says, "The Sacramento Municipal Utility District’s (SMUD) proposed rate structure as defined by the Chief Executive Officer & General Manager’s Report and Recommendation on Rates and Services is influenced by SMUD’s Marginal Cost. Marginal costs are the additional costs SMUD incurs to provide electric service to a new customer or a new load, or the savings expected from not serving that customer or load. These costs vary by the voltage at which electricity is delivered to the customer." The key here is that the rate study is all about marginal costs.

There is 3, Marginal Costs for Energy and Table 3.1.

There is 4, Demand-related Marginal Costs and Table 4.1 – Marginal T&D Capacity Costs (2020$).

There is 5, Customer related marginal costs and Figure 5.1 – Residential Customer-related Costs by Component.

There is 6, Other Cost Adders, in narrative form only with no table.

The units of measurement are not consistent. Some are $/kWh, others are $/kWyear or $/customer-year. These are never combined into a table showing the sum total of all the marginal costs in any units. The units should be $/kWh because those are the units in the proposed rate resolution.

My questions and Rates' answers further reveal that this rate costing study fails to justify the proposed rates, as described next.

In response to one of my questions on June 29, your Rates people (Rates@SMUD.org) gave incomplete and evasive answers on July 6 to some of my questions about the 2020 rate costing study.

I will present my questions and SMUD’s answers in line and indented.

MG #3 The 2020 Rate Study says, “The Sacramento Municipal Utility District’s (SMUD) proposed rate structure as defined by the Chief Executive Officer & General Manager’s Report and Recommendation on Rates and Services is influenced by SMUD’s Marginal Cost.” What else, besides SMUD’s Marginal Cost, influences the proposed rate structure?

SMUD: Question #3 - Please see SMUD Chief Executive Officer and General Manager’s Report Volume 1 for other factors such as the Strategic Direction 2 (SD-2) and the 2030 Zero Carbon Plan.

MG #4 How or in what ways do the other factors besides SMUD’s Marginal Cost influence the proposed rate structure? Please elaborate and quantify.

SMUD Question #4 - See response to question #3. For example, the SD-2 objectives adopted by the Board provides direction to staff for rate design. In addition, SMUD’s rate recommendation helps meets SMUD’s financial targets and other strategic directions.

MG #5 The previous rate design study, called the “2018 Residential Time-of-Use Rate (RT02) Design Study”, contained a series of tables (Tables L, M, N and O) on pages 14 and 15 that presented the marginal cost of each of the components of SMUD’s cost of service and how SMUD got from those numbers to the proposed rates for 2018 and 2019. The 2020 Rate Study does not contain such tables. Is this omission intentional?

SMUD Question #5 - The tables referenced were not produced as we are not proposing to restructure residential rates in this recommendation.

MG #6 Will SMUD show its marginal cost and other data for the proposed rates in tables that are similar to Tables L, M, N and O from the 2018 Residential Time-of-Use Rate (RT02) Design Study?

SMUD Question #6 - No. See response to question#5.

MG #12 The 2018 Residential Time-of-Use Rate (RT02) Design Study used a “scalar” of 9.2%, which SMUD added to the total energy marginal cost to reach the 2017 energy charges. (Table M, page 14) SMUD’s explanation at the time was, “The proposed time-of-use energy rate is completed by setting proposed rate revenues equal to rate revenues for the budget year. The reconciliation of marginal costs to rate revenues is accomplished through increasing final marginal cost energy charges by a scalar of 9.2%.” Table N added in another scalar of 0.35%. It has been said that the use of the 9.2% scalar is not allowed by the California Constitution, Article XIII C, because such use causes the then proposed rates to exceed SMUD’s reasonable cost of providing electricity service. The question is has SMUD backed this 9.2% scalar out of the proposed rates?

SMUD Question #12 - SMUD disagrees that use of the 9.2% scalar causes SMUD’s proposed rates to exceed its reasonable cost of service. SMUD has not backed the 9.2% scalar out of the proposed rates.

My comments:

SMUD’s answers to questions 3 and 4 reveal that these other items that “influence” SMUD’s marginal cost are not quantified in the 2020 rate costing study. They are alluded to, generally. The marginal costs shown in Table 3.1, which is the only table with units of $/kWh, are much lower than the proposed rates. Therefore the rate costing study does not really justify the proposed rates.

SMUD’s responses to questions 5 and 6 about restructuring the rates is not relevant. The point of these 2 questions and of the “2018 Residential Time-of-Use Rate (RT02) Design Study” is that the way SMUD can justify its rates is by identifying, as the 2018 rate design study did, each of the components of its marginal cost and adding them up. Because the 2020 study failed to do that it failed to justify the proposed rates.

How much higher than its marginal cost does SMUD think it can set its rates and still be considered not reasonably exceeding its cost of providing electricity service? Do you think you can go 50% over? 200% over? 30% over? Where is your bright dividing line and what is the legal and policy basis for it? The California Constitution, Article XIII C, does not give a number. My opinion is that 9.2% over the marginal costs is not the reasonable marginal cost.

I may provide further details and analysis of this alternative recommendation later, but consider this alternative recommendation #1 to be complete.

For now please acknowledge your receipt of this and place it on the agenda and in the rate resolution for the Board to consider, as the Public Utilities Code requires you to do.

Sincerely,

Mark G.

Sent from my hard wired computer

Note: This comment was sent to SMUD 3 separate times.


August 13 - Mark G.

August 13, 2021

Ms. L.,

Please forward this to the Board of Directors and staff. Thank you!

Hello SMUD Board of Directors and staff,

This is a very rough first draft of my first alternative recommendation for SMUD's 2022 and 2023 rates and charges.

SMUD should back out the 9.2% scalar that SMUD built into the original time of day (TOD) rates in 2017, plus all of the across the board rate increases that have increased that scalar up to about 10.7%, before applying the proposed 1.5% and 2.0% rate increases. This applies to the rates per kWh and the system infrastructure fixed charge (SIFC) for the rates and charges of all customer classes and categories to which the 9.2% scalar was added.

When I say back out I mean to multiply the current rates by a number that is less than 1 such that you will arrive at rates that you would have had if SMUD had never added in the 9.2% scalar in the first place. Such a calculation will reduce the current rates by something in the neighborhood of 9.2%, but not exactly that amount due to the mathematics of it. The 9.2% scalar plus all the subsequent across the board rate increases is currently "baked into" SMUD's rate and charges. It should not be.

The reason is that the current and proposed rates are taxes as defined in the California Constitution, Article XIII C, and SMUD never presented these rates and charges to the electorate nor received the approval of the electorate. General taxes cannot be imposed, extended or increased unless approved by a majority of the electorate. Special taxes may not be imposed, extended or increased unless approved by a 2/3 majority of the electorate.

My June 18, 2021 email, with all four (4) attachments, explain the issue in depth. I incorporate that email and those attachments into this alternative recommendation by this reference. One of those was the original rate design study referred to by NERA economic consulting in their letter in the CEO and GM Report and Recommendation on Rates and Services, which was Appendix I. That rate design study showed the line by line marginal cost components, and the sum of them, and then showed the addition of the 9.2% scalar which was intended to align the rates with SMUD's predetermined budget.

As my analysis shows, the original time of day rates exceed SMUD's reasonable cost of providing electricity by slightly more than 9.2%. The definition of a tax is very broad, but a charge or rate is not a tax if it qualifies for any of the seven exceptions. The only exception that could even possibly apply to SMUD rates and charges is 2e, which is that the rates do not exceed SMUD's reasonable cost of providing electricity. But my analysis shows that they do exceed it by 9.2% at the time. The "scalar" that SMUD built in is not authorized by any statute or case law or any other legal authority. I even provided authority in terms of case law saying that, essentially, the government may not base its rates on predetermined budgets. That appears to be exactly what SMUD has done.

I will provide further details and analysis of this alternative recommendation later.

For now please acknowledge your receipt of this and place it on the agenda and in the rate resolution for the Board to consider, as the Public Utilities Code requires you to do.

Sincerely,

Mark G.

Sent from my hard wired computer


August 8 - Nicholas B.

Strongly opposed

Let's be honest here smud, we all know the increase will happen with or with out opposition. 

Unless a person gets off the grid completely they get screwed. 

Your reasons are non legitimate. 

Wild fire mitigation lol. You failed every year. 

Reliable. Uh still not. 

Clean energy. You will never get there, but keep juicing your costumers. Never ending money grab. 

Increase operations costs. Join the club.

Talk to your governments lunatic in chief, shutdowns don't help the economy. Printing funny money and funding a tital wave of illegals doesn't make an effective bandaid.

Like I said opposition or not we the consumer get the shaft everytime. 


August 2 - Catherine K.

Hello: 

Our family has serious concerns with the proposed rate increases.  The initial rate increases that were phased in during the time-of-day (peak hours starting from 5-9 pm) heavily punished working families with 8-5 schedules.  Our family and many workingfamilies need electricity to do homework, feed the kids, throw in an occasional laundry load.  As a budget-conscious mum, I started sleeping later to start the laundry, which would sometimes disturb the family's sleep. 

Summer Hours

public comments 1

The bright spot with the COVID pandemic, I resumed our regular activities using our electronic appliances during non-peak. Don't forget this time, my family has experienced a pay decrease but we have increased child care costs, higher internet speeds to accommodatethe higher device use, increased food, toiletries cost due to the inflated prices during the pandemic. At the same time, SMUD came up with a brilliant idea to change the Time of Day rates. This again forced our family to change our habits in an effort to savemoney. Please see the changes in off-peak and start of mid-peak hours. Please be reminded that morning hours are dedicated to online school, and any disruptions cause undue stress.



Below you will find a new excerpt providing commentary on the time of day impact to families.

public comments 3

Below you will find our family bills and the impact of the various rate increases to our budget.

2019

public comments 4

Image edited to protect personal information.

2021 bill

public comments 4

Image edited to protect personal information.

As you can see, with climate change, pandemic habit changes, our usage has dramatically increased.   What you do not see is the increased cost due to the pandemic - food, childcare, gas, and decreased income from our respective employers.  The proposedrate increases are just too high and will further put us, middle-income families, further and further away from our financial goals of saving for retirement and college. Our family opposes the rate changes but we do have some solutions for your consideration:

Increase the EAPR income guidelines to increase the number of families that could qualify for rate increases.

public comments 6

Change the electric vehicle rates times from midnight -6am to match the Mid-peak summer hours and off-peak hours.  Not only do you incentivize your customers to adopt more green habits but it also helps meet your sustainability goals indicated in the2030 Zero Carbon Plan or 2030 Clean Energy Vision.  If implemented you could greatly assist middle-income households' budgets.

public comments 6

Thank you for the opportunity to provide comments.

Sincerely,

Catherine K.


July 30 - Michael and Colleen L.

Hello, 

My wife and I are new homeowners here with SMUD service.  We recently added a rooftop solar system to our home and experienced what many were saying - resistance to a right-sized system to our needs.  Even despite NEM1.0 time of day rates, weare still owing some for our solar-only setup each month.  For NEM2.0 to take the rate down so low really makes it difficult for folks to recoup the costs of solar and help defray the costs of their substantially lower electricity usage.  And if fewer folksinstall solar, the net effect on the environment will not be as positive.

I also do not feel it is fair to charge solar customers the rates you do if you do not pay solar customers for their electricity generation in equal amounts.  It is a significant disincentive and it doesn't help in a world where micro-gridswill likely help us sustain in the midst of so much hot weather and climate change.  

Please please do NOT ruin solar for everyone.

Signed,

Michael and Colleen L.


July 29 - Max H.

My comments on the proposed rates for 2022-2023:

Dear SMUD Board,

I recently purchased 15 solar panels about a year ago and one of the selling pointswas the ability to recoup the costs with clean energy. It is unfair for someone tomake a large investment into clean solar power with the intent of saving money monthly and then SMUD changes their rates to pay them pennies on the dollar for excess power. Theproposal of us sending our excess power now and only getting your wholesale rate doesn't help. Itseems SMUD is now trying to make up for those who invested in solar panels to provide SMUD their excess power at pennies on the dollar since they aren't billing them as much electricity as non-solar customers.

It makes no sense to invest in solar if you don't save money to make up for the investment!! I think you would need to providethe battery system for free if you want to put this burden onto your customers instead of letting the "excess net energy" flow to our neighbors. This decision does NOT sound like the “community owned not for profit electric company” i’ve been a resident offor many years. 

As a SMUD customer, I certainly disapprove of these changes as it is nowhere near the best interests of the customers. 

Thank you,

Max

(all my SMUD serviced properties, feedback is for all properties)


July 27 - Alan E.

Hello, 

I live in Natomas and I installed a small rooftop solar system in 2017. I am opposed to the proposed reduction in net metering compensation as currently proposed, although it is an improvement over theMarch 2019 proposal. 

I worked out of town approximately 25 days a month, but I retired four years ago and moved back to my home here in Sacramento. I then installed a small roof top system for environmental and economic reasonsto my home in Natomas under the encouragement of State and Federal Government incentives. However, I was not allowed to properly size the system by SMUD because it was based on my last years usage... when I lived primarily in another county and not on my reasonablecurrent power requirements when I would be living full time at my home. Despite being denied to design my system based on reasonable assumptions I proceeded and hired a local solar company to install my undersized rooftop solar system. 

I want to add panels and batteries in the future to properly size my system to my current power needs and to accommodate the future purchase of at least one EV, if not two. I understand under the currentsolar/storage proposal I would lose my NEM 1.0 status if I did so before 2030. The $500 to $1500 storage incentive proposed by smud does not come close to make my system upgrades financially viable.  I also wanted the batteries to mitigate future increasesin power outages anticipated due to climate change. The alternative to solar/storage is to purchase a generator that runs on natural gas. (or diesel) Whole house generators are a much better option financially if the solar/storage rate changes passes but willincrease local GHG emissions.. Was the potential increase in local home generators taken into account in your analysis if this solar/storage proposal is adopted? 

My little 3.6KW system saves over 4300 lbs of coal burned or 440 gallons equivalent of gas guzzled per year. This directly relates to a reduction in GHG emissions. I believe a CEQA analysis must be preparedIf this solar /storage rate proposal is passed, as there will be a significant adverse reduction in the number of future rooftop and commercial solar systems built, along with an associated cumulative  increase in GHG emissions.  This assumption is based onsimilar increases in solar fees in Nevada 6 years ago that killed the local solar industry, so much so that the rate increases were later rolled back..  The solar industry returned after the solar fees were rolled back, albeit not with the same  momentum beforethe fee increase. 

In summary,

I agree that smud should be compensated for connection fees. I believe that there should be a reduction in NEM 2.0 compensation, just not to the amount proposed of 7.4 cents per kw. That is too low andwill kill the local solar industry and reduce the number of rooftop solar (adverse regional impacts) significantly adversely affecting an increase in GHG emissions.(adverse local, regional and global impacts) I do not believe the value of my solar system insaving the release of GHG emissions (4400 lbs of coal or 440 gallons of gas) were taken into account in the calculation of the value of solar, which violates numerous smud policies. The future is solar plus storage and smuds $25m incentive program is to low. I believe the funding runs from Jan 2022 thru Dec 2030? So on average the program allows for approximately $3m annually? I contend that the incentive should start at $1500 and go to $5000 in order to properly incentivize new storage. In addition, SMUD shouldallow existing solar owners to add panels and batteries to their existing systems without impacting their NEM 1.0 status.SMUD can afford this as their existing rates are up to 38% lower than PG&E. Finally, the assumptions predictive models you used to estimatecustomer behavior due to the proposed solar/storage changes need to be prominently highlighted and easily accessed  so we customers can understand your reasoning behind your proposals. 
  
Sincerely, 

Alan E.


July 27 - Alan E.

Hi,

I've spent over 30 minutes on your website trying to find information about value of solar/storage public comment workshop number 2 to be held on July 27 at 10 am. This should have been very easy to find on smud.org, or am I missing something?

I was following the NEM 2.0 value of solar process the last two years since I own a small rooftop system and I am very concerned about the proposed changes being considered to reduce my net metering compensation. I was signed up to get notifications and I received a couple, but the notifications have stopped since the pandemic/virtual meetings started over a year ago. Right now I am very frustrated as I cannot seem to get any information on how to attend this virtual public workshop from your website.

I would appreciate a response and some direction on how to participate in the public workshop.

Thank you in advance,

Alan E.


July 22 - Hugh and Kay G.

We have had solar for 10 years (12 panels) and recently added 12 more panels. We took out loans to install these panels and did a calculation about how many years it would be to recoup our costs (we are in our 80'sso the addition of 12 panels did not make economic sense but made environmental sense). The past two months are the first time our cost of electricity and the cost of electricity used were almost equal. We believe your proposal to drastically reduce the reimbursement for excess solar sold to SMUD is a giant step backward and will discourage home owners to install solar. We find the proposed policy unbelievable in light of your TV commercials “congratulating" SMUD for “guaranteeing” a carbon free city in 2030. We hope you will reconsider this proposal and consider your advertisement and your environmental responsibility for our future generations in your decision.


July 14 - Kevin M.

Hello,

It is unfair for someone to make a large investment into clean solar power with the intent of saving money monthly and then SMUD changes their rates to pay them pennies on the dollar for excess power. It makes no sense to invest in solar in the first place if you don't save money to make up for the investment. I think you would need to basically provide the battery system if you want to put this burden onto your customers instead of letting the "excess net energy" flow to your local neighbors. Even then, is it "clean" for the environment if everyone is now buying these batteries and replacing them every so often? Why not just keep the rate structure (and infrastructure without using batteries) in place as it is? 

I recently purchased a home about a year ago and one of the selling points was that it had solar panels installed. We would be able to get by, providing that SMUD would use net metering and allow us to "store" our kWh's for later when we would need them. The proposal of us sending our excess power now and only getting your wholesale rate doesn't help. As part of the home purchase, we paid for the entire solar system (without any tax breaks). It seems SMUD is now trying to make up for those who invested in solar panels to provide SMUD their excess power at pennies on the dollar since they aren't billing them as much electricity as non-solar customers.

Thanks for your time 


July 10 - Steve U.

Questions for the Proposed 2022-2023 rate changes in the rate proposal in the 2021 GM Report

Question on Renewable energy credits (RECs) ownership.

Who has title to the certificates for NEM1 and SSR renewable generation issued for a generating units registered with WREGIS?

WREGIS is not intended to establish legal title to Certificates but instead to accurately track who is registered as possessing Certificates. Persons must address any issues regarding ownership or security interests in the Certificates outside of WREGIS. See https://urldefense.proofpoint.com/v2/url?u=https-3A__www.wecc.org_Administrative_WREGIS&d=DwICaQ&c=Ko5vnWWlemq1VcwTIpbf0g&r=zlBlDs7W0TQsFjIvtOFbMTEYl0JaLagCasWjK-9meZU&m=65QFjN07XjazbKyb4L4yIU7y88Ex08MgsP3pDSAVrhc&s=ovR_bE2t4EnJwpjN8ZDTYaimcJQAZJrwd7-MUtz2AC4&e=  Terms of Use.pdf item 7.

Does SMUD intend to strip off the RECs from NEM1 and SSR customer generation and sell the RECs or use the RECs in calculating procurement requirements for the California Renewables Portfolio Standard (RPS)?

SMUD recommended back in 2007, that the utility be required to purchase the RECs associated with the renewable generating unit. See https://urldefense.proofpoint.com/v2/url?u=https-3A__docs.cpuc.ca.gov_word-5Fpdf_FINAL-5FDECISION_64072.pdf&d=DwICaQ&c=Ko5vnWWlemq1VcwTIpbf0g&r=zlBlDs7W0TQsFjIvtOFbMTEYl0JaLagCasWjK-9meZU&m=65QFjN07XjazbKyb4L4yIU7y88Ex08MgsP3pDSAVrhc&s=Go05Uczkah5L6UY1PK9Ni99lCY1yJxZ3ZTyYrwP0F7k&e=  foot note 186.

Does the SSR Export Compensation Rate effective January 1, 2022 of $0.0740 per kWh include the value of the RECs?

Steve U.


July 8 - Rick C.

These comments summarize the main points we made on behalf of 350 Sacramento and Vote Solar during the May preview of the proposed Solar and Solar + Storage rates.

We are gratified that SMUD has abandoned its original plan to charge rooftop solar customers a set Grid Access Fee (GAF) based on the size of the photovoltaic (PV) panels.  Instead, the proposed rate  allows solar owners to retain generation credits for on-site use at the currently available rate.  It then offers a lower buyback price for excess generation sold into SMUD’s grid.  This is an excellent compromise solution. It eliminates the highly regressive GAF which placed a fixed cost on total output. And it acknowledges that a customer’s home use of solar should be off-limits to SMUD revenue capture – a huge concession.

On balance, we believe the 7.4 cents/kWh fixed price for purchase of excess generation appears reasonable, crediting back savings from carbon reduction from SMUD’s thermal plants and the avoided costs of storage batteries.  And because SMUD leaves solar use within the home untouched, the blended savings comes to more than 10 cent/kWh.  The bifurcation of savings between home use and export creates strong arbitrage opportunities to downsize solar installations to optimize output for on-site use and to further encourage appliance electrification, electric vehicle charging and battery storage.

Solar + Storage

We agree with SMUD’s emphasis on the added value of storage to existing and future solar rooftop installations.  And we applaud the introduction of the Critical Peak Pricing rate as an important component of SMUD’s Virtual Power Plant for battery, electric vehicle, and appliance discharge.   However, we feel that SMUD’s goal for battery installs is too limiting and that SMUD should aim for a 50% capture rate or 50,000 battery installations by 2030.

Virtual Net Metering (VNEM)

For the first time, the SMUD Rate Report proposed VNEM for affordable multi-family housing projects.  This is a long overdue program that is already in place at other California utilities. We see no reason why VNEM cannot be extended to all new multi-family construction including condominiums and apartment houses. It should also be available for true Community Solar projects where non-profits can allocate PV production to low-income renters.  Having this option will encourage solar and battery storage at these new distributive power plants. Because VNEM is a program and not a rate, the GM Report provides no details.  We encourage SMUD Board to direct staff to expand VNEM as noted, and to release public details of this program by this Fall.

Rick C.


June 30 - Mike C.

thank u for ur consideration. however, as u may be proud of your industry 'standing' of rates, u might want to ALSO be concerned about the rate for poorer customers, ESPECIALLY SENIORS. ur programs have to go much deeper for us. 
then u say: "The need for the modest rate increases is due to several factors..." WHAT IS MODEST ABOUT A 34% RAISE IN 2 YEARS? what a joke. again it may be modest for the industry, which i cannot accept. and i have showed u what our increases are for Social Security. NOW THAT'S MODEST!
try to have a little compassion instead of parroting the same old press points. i don't buy the fake news on TV nor do buy your explanation of y u cannot help poorer people. no wonder there r so many homeless. 
try again eh T and team?
mikeC


June 30 - Anonymous

I am strongly opposed to this proposal of rate increases for 2022-2023. These increases would be a hardship on my family.


June 29 - Debi & Gary N

We just got word that rates are going to be increased so I'm writing to you with hopes that rates won't be increased. EVERYTHING else is going up except wages and adding another increase will cause hardships beyond what we can afford. Please reconsider raising the rates at this time allowing us to catch up with our finances after the last 18 months dealing with Covid!!

Thank you,
Debi & Gary N.


June 29 - Anonymous

Please DO NOT increase our rates again. We are struggling as is to keep up with the price increases everywhere. This is not ok and we don’t qualify for any low income help. We can’t afford an increase from this company too. Where is the sensitivity for all during these times.


June 29 - Mark G.

June 29, 2021

Hello SMUD,

This message contains my first set of comments and questions on the 2021 rate action.  I will appreciate your response at your earliest convenience. 

Mark G.

#1 The CEO and GM Report says, "The cost-of-service analysis that demonstrates cost-justification for the proposed rates is the SMUD Rate Costing Study ('2020 Rate Study') which is incorporated herein by this reference."  (Volume 1, page 92)

That study is dated March 31, 2020, which is less than one month after the start of the pandemic. The pandemic turned the California economy, the Sacramento economy, the U.S. economy and the world economy upside down. It introduced many changes.

SMUD’s financial results for 2020 were tens of millions of dollars ahead of its projections, which called for significant increases in net position. Apparently SMUD benefitted from the changes that the pandemic brought. For example at one point in 2020 SMUD announced that it had saved $40 million due to its employees working from home.
The question is, does EE plan to produce a new Rate Study?

#2 Will the new rate study, if any, state SMUD’s assumptions about the pandemic for 2022 and 2023 and its effect on the Sacramento economy and its expectations for its financial performance for 2022 and 2023?

#3 The 2020 Rate Study says, “The Sacramento Municipal Utility District’s (SMUD) proposed rate structure as defined by the Chief Executive Officer & General Manager’s Report and Recommendation on Rates and Services is influenced by SMUD’s Marginal Cost.”

What else, besides SMUD’s Marginal Cost, influences the proposed rate structure?

#4 How or in what ways do the other factors besides SMUD’s Marginal Cost influence the proposed rate structure? Please elaborate and quantify.

#5 The previous rate design study, called the “2018 Residential Time-of-Use Rate (RT02) Design Study”, contained a series of tables (Tables L, M, N and O) on pages 14 and 15 that presented the marginal cost of each of the components of SMUD’s cost of service and how SMUD got from those numbers to the proposed rates for 2018 and 2019. The 2020 Rate Study does not contain such tables. Is this omission intentional?

#6 Will SMUD show its marginal cost and other data for the proposed rates in tables that are similar to Tables L, M, N and O from the 2018 Residential Time-of-Use Rate (RT02) Design Study?

#7 Assuming the Board approves the proposed rate increases what will be SMUD’s projected increase in net position in 2022 and 2023?

#8 The CEO and GM Report says, “Increased operating costs, including materials and labor - due to the COVID-19 pandemic, and
the impacts it has had to global supply chains, we are starting to see higher material costs for
many materials we use every day. While we believe some of the more drastic price increases are
temporary, there is general inflationary pressure on goods and services that will likely be
sustained.” Yet in 2020 SMUD said that it had saved $40 million in labor costs due to many of its employees working from home. How can you explain this? How can you reconcile these two statements? How can you explain this statement in the CEO and GM Report in light of the $40 million savings in 2020 on labor costs?

#9 Assuming the Board approves the proposed rate increases what will be SMUD’s total revenue from sale of electricity in 2022 and 2023?

#10 The table in the CEO and GM Report, page 64, presents the “Detail of Rate Changes, Years 2022 and 2023 include proposed rate increases.”

Are the proposed rates in this table simply the result of adding 1.5% and then 2.0% for the years 2022 and 2023, respectively, to the current rates?

#11 Are the proposed rates based on SMUD’s predetermined budgets for 2022 and 2023?

#12 The 2018 Residential Time-of-Use Rate (RT02) Design Study used a “scalar” of 9.2%, which SMUD added to the total energy marginal cost to reach the 2017 energy charges. (Table M, page 14) SMUD’s explanation at the time was, “The proposed time-of-use energy rate is completed by setting proposed rate revenues equal to rate revenues for the budget year. The reconciliation of marginal costs to rate revenues is accomplished through increasing final marginal cost energy charges by a scalar of 9.2%.”

Table N added in another scalar of 0.35%. It has been said that the use of the 9.2% scalar is not allowed by the California Constitution, Article XIII C, because such use causes the then proposed rates to exceed SMUD’s reasonable cost of providing electricity service. The question is has SMUD backed this 9.2% scalar out of the proposed rates?

#13 Is the 9.2% scalar that SMUD added to its rates in the 2018 Residential Time-of-Use Rate (RT02) Design Study baked into or still included in the current rates?

#14 SMUD has apparently made a mistake in its calculation of the off peak summer rate for 2023. Assuming SMUD intends to raise rates as of January 1, 2023 by 2.0%, which is what the CEO and GM Report says on page 38, the rate should be $0.1349. SMUD shows $0.1350. Although the difference is a fraction of a penny it will add up to millions of dollars because SMUD has so many residential customers and this is 8 months out of the year. $0.1350 is not the correct figure because if you add 2% to the 2022 rate of $0.1323, proposed for March 1, 2022, and carry it out to six decimal points you get $0.134900. So SMUD cannot round up from there to $0.1350. SMUD needs to either change the proposed rate for this time period to the correct figure, $0.1349, or write a new paragraph into the rate resolution saying that for the off peak summer rate for 2023 SMUD is raising its rates slightly more than 2% but for all other time periods for 2023 it is raising them 2%, and mention this in all the customer meetings and the two workshops and the rate hearing. Please reply to this. If you believe your calculation is correct and I have made an error in my calculation please clarify and show your calculation.

#15 SMUD has made a similar mathematical error in the SIFC proposed for March 1, 2022. The current SIFC is $22.25 per month. It will be $22.70 as of October 1, 2021. Adding 1.5% to that gives $23.0405. SMUD shows $23.05 in the table on page 64 of the CEO and GM Report. SMUD cannot round up from $23.0405 to $23.05. Mathematical practice is to round up to the nearest decimal point only when the decimal point after that is 5 or greater, and to not round up when that number is 0 to 4, inclusive. Here the decimal point is 0 (the 2nd 0 in $23.0405) and so you cannot round up. It’s literally one penny per customer per month. SMUD has approximately 600,000 residential customers (see question #16) and that equates to an unnecessarily high SIFC of $6,000 per month.

Again the solution is to either change the proposed rate for this time period to the correct figure, $23.04, or write a new paragraph into the rate resolution saying that for the SIFC for 2022 SMUD is raising its rates slightly more than 2% but for all of the rates per kWh for 2022 it is raising them 2%, and mention this in all the customer meetings and the two workshops and the rate hearing. Please reply to this. If you believe your calculation is correct and I have made an error in my calculation please clarify and show your calculation.

Sent from my hard wired computer 


June 29 - Mike C.

dear mr j,

u may remember... or not, but we had some emails pass last year about rate hikes. well here's the actual "rate hikes" we seniors get (see attached). now compare that with what u (SMUD) did. and think about this also along the same lines, gasoline has gone up 50% in the last few years, food, clothing, etc. and now that the pandemic is over, everyone is talking about INFLATION.

can't smud do something more for seniors?

Please?

mikeC


June 26 - Ada

Hello.
I have reviewed your proposal for rate increases and the reasons.
Our bills are outrages as it is and as a customer, i feel that we are being taken advantage of.
Isn’t cleaner energy, etc a job for our govenor to address?
Why not send him the concerns and ask that this be a priority instead of reparations, etc.
Thanks.
Ada


June 26 - John

The structure of the "Key details" bullets on https://www.smud.org/en/Rate-Information/2022-2023-proposed-rate-changes/Solar-and-Storage-Rate-details is unclear, and the FAQ section mirrors this.
Bullet 1 deals with NEM 1.0 rate customers, fine.
Bullet 2 deals with solar + storage, fine.
Bullet 3 deals with SMUD excess buyback fine.
Bullet 4 deals with SMUD buyback of "this" excess electricity, which I can easily read in either of 2 completely different ways, even after assuming that "this" refers to " solar customers [with] excess power they do not use or store in their battery."The intended reading changes the interpretation drastically, based on, for example, whether bullet 3 refers to all solar customers, only solar + storage, and/or whether or not the customer is on the NEM 1.0 rate.
Reading 1: bullets 3 + 4 apply to all customers, one implication of which is that it would change the NEM 1.0 buyback rate from time of day to a flat rate lower than the lowest current ToD rate.
Reading 2: bullets 3 + 4 apply only to all customers not on the NEM 1.0 rate (i.e. new connections approved after the Proposal's effective date), so the proposal is only changing the economic assumptions of systems not yet approved for connection,solar with or without storage.
In principle there might be additional substantively different readings, but hopefully the example above demonstrates the ambiguity sufficiently. 

Best Regards, John


June 25 - Michael B.

Solar + storage looks interesting but ...

Traditional behind-the-meter storage (I've recently looked) more than doubles the cost of a solar energy system. That renders it uneconomic under current conditions. What kind of incentive is SMUD planning to address that? Without a substantial incentive, the storage is financially not feasible for existing small solar system owners; it's essentially the cost of installing a whole new solar system.

(Example: 3.8kw nameplate (real peak output is more like 3.5-3.6) solar producing, during early-mid summer, produces (gross) about 25-28 kwh/day. It cost about $13K a year ago. It produces 70-80% of my annual consumption (less with the EV, now), but the details are what's important. During summer, the mid-day peak output is usually surplus; so a traditional battery would be sized to capture all of that and deliver it during peak and evening mid-peak times - essentially, energy price arbitrage. A battery suitable for that (10-15 kwh) been quoted at more than $15K. IOW more than what the panels cost.)

Bottom line, absent some program that substantially reduces the cost of the batteries, both initial and continuing (panels last 20-25 years; batteries likely need expensive replacement about every 10) cost to individuals by mandating solar+storage means only 1) very rich people who are contributing to cleaning up the environment and don't care (much) about the cost, or 2) PPA companies that are maximizing solar output as commercial generators using rooftops, will be able to afford solar. Is that what you really want - to leave most rooftops clear of solar (where rooftops are already-built-on land that would have little environmental impact to develop for solar), while building more greenfield (or buying from commercial greenfield) solar projects that DO have significant environmental impacts? Ultimately, we need both, but distributing solar within the existing service area, where new transmission lines should not be required, seems like something to be encouraged, rather than being discouraged by making it cost-prohibitive.

Some thoughts about (partially) mitigating the problem:

Substantial incentives for traditional behind-the-meter batteries would reduce the amount of locally-produced solar you must accept at mid-day, as well as power you must deliver during peak times. That may have grid operational advantages - smoothing out the duck curve. Basic battery incentives should at least represent the value of improving grid operations.

Will SMUD offer extra incentives for batteries that can provide grid stabilization services - i.e. connected to the grid in such a way that you can use a portion of the battery capacity for grid operating purposes? What kind of numbers are we talking about in terms of 1) extra cost for purchase and installation compared to a traditional behind-the-meter battery; 2) how much of the battery capacity might be used - IOW how much bigger does the battery have to be; and 3) pricing - how much would SMUD pay for the services?

I now have an EV, and have considered adding on to my existing solar system. Haven't done it yet, and the car so far hasn't hit my bill badly; and in most cases adding even a row of panels would cost as much as a whole new system (so saving that for a battery might be more cost-effective). Would that automatically trigger inclusion in the new rate?

Is the new feed-in rate in fact just for surplus power (in excess of what's used on-site), or are you still proposing to charge retail for all usage on the property and pay the wholesale rate for all solar produced (IOW eliminate net metering entirely)? It does sound like the latter is still where you are going, unless storage is added.

How does your proposal compare with what the PUC is considering for NEM 3? That needs to be disclosed.

As I noted in comments in previous years, an example of a place that actually encourages rooftop solar (with storage), and incentivizes it heavily, is South Australia. They frequently come close to (if not exceed, selling surplus power to neighboring grids) 100% renewable energy. Would be worth looking at their operation as a specific example in the analysis materials.

Michael B.
Folsom, CA


June 25 - Jamie

To Whom it May Concern:

I am writing in to strongly oppose the 2022 & 2023 rate increases from SMUD. Every year us customers are suffering from the ever increasing costs from SMUD and the rate increases that are also imposed every fiscal year. After the reeling effects that the COVID-19 pandemic has left on many families I personally feel that a rate increase in a time of when families are trying to get back ahead or caught up on back bills is in extremely poor judgment on SMUD's part. SMUD has already initiated the time of day rate which charges us customers the most during the Summer months to even just cook our dinner meals. Unless we eat before 5pm or after 8pm of course. Ever year SMUD "proposes" a rate increase it is always for the same reasons. Enough is enough! Stop passing these excuses onto the already suffering customer. Some that qualify for aid with other Utility companies but can't with SMUD because the qualifications are not the same/standard. I hope that the SMUD Board will finally listen to their customers pleas for NO rate increases! 


June 21 - Rick C.

Hi J,

Now that the GM Report on Rates is out, I couldn’t find a reference to Virtual Net Energy Metering in the NEM2 write-up.  My supposition is that VNEM is more likely a program than a separate rate, though I expect some administrative fees would have to be documented.  Can you let us know what the status of VNEM development is at SMUD right now?

Thanks,

Rick C.


June 18 - Mark G.

June 18, 2021
Ms. L,

Will you forward this message with its attached files to the Directors and key staff? 
Thank you.

Directors and key staff,
This message is about the current rate action, your proposed rates for 2022 and 2023, the current CEO and GM Report and Recommendation on Rates and Services that you voted on (agenda item 9) at the Board meeting last night, the hearing date that you voted on, and the key question, which is whether the proposed rates violate the limitation on local government taxes in Article XIII C of the California Constitution.  Such rates must be approved by the electorate, whether they are taxes or special taxes.  Your proposed rates and charges are special taxes as defined.  
SMUD imposed the special tax in June, 2017 when you first created the time of day rates.  You extended and increased them in 2019 and are planning to do that again this year. 

There is only one document, to date, that presents and quantifies SMUD’s reasonable costs of providing electricity service and the components thereof.  That document is “2018 Residential Time-of-Use Rate (RT02) Design Study,” a 16 page document, that provided the factual / evidentiary basis for the original time of day rates adopted in June, 2017.  This is the key document because it introduced the “scalar” of 9.2%.  (Tables L and M, page 14).  
The problem is that after carefully accounting for each Marginal Cost Component SMUD unconstitutionally added a “scalar” of 9.2% to set rate revenues equal to budget revenues.  In other words SMUD had a target for how much money it wanted to take in via residential
TOD rates and to reach that target it added 9.2% to its marginal cost.
You extended and increased the special tax in 2019 when you raised rates.  According to your CEO and GM Report and Exhibit to Agenda Item #9 you are planning to extend and increase them again this year.  This is unconstitutional. 

According to my calculations the 2020 rates approved in Resolution 19-06-13 are about 9.55% too high as of January 1, 2020, 9.83% too high as of October 1, 2020, 10.08% too high as of January 1, 2021, and 10.28% too high as of October 1, 2021. These figures are the result of applying the actual rate increases approved by the Board in Resolution 19-06-13 to the 2019 rates, assuming that the 2019 rates were 9.2% too high because of the “scalar” of 9.2% that SMUD added to its rates in the rate design study. 

I encourage you to become thoroughly familiar with this issue as soon as you can.  Ask me questions.  Please be genuinely interested in the truth of the issue.  Don't just look for a fast and easy way to disregard what I am saying.  It's a key issue and if your rates are unconstitutional they could be reversed.  That's what is at stake.  If there were ever an issue deserving of your attention and interest and curiosity and study this is it. 

Thank you in advance for reading this material, making a genuine effort to understand it, approaching it with an open mind and asking me and your staff specific questions including follow up questions when it doesn't appear they have really answered your question. 

Mark G.
Enclosures