Value of Solar Study public comments


August 25 - Anonymous

Thanks for the opportunity to comment on the study, and to provide feedback. I think a lot of the concerns in the comments I have read so far is a fear by solar customers that this study will be weaponized to impose additional costs. I also think this concern could have been mitigated by incorporating customers, solar companies, and experts in the field as the study was developed. Funding a study by an external consultant and then publishing it with no input by your customers is a hard pill to swallow here.

I am a customer with solar installed on my roof. I am also motivated to work with SMUD to find the best options for creating resilience in the power grid and to address climate change. I thought, as I think many customers did, that installing solar panels was one of the best methods to achieve both those goals while reducing our personal utility costs over time. Uncertainty creates an unstable situation for everyone.

I think a plan for what the ideal situation, from SMUD’s perspective, would be helpful here. I also think that any changes to net metering, or other costs imposed, should either be implemented slowly over time or preferably to new rooftop solar installations who know what they would be getting into ahead of time. The unknown options here have me thinking I might need to take more drastic actions: add more solar + batteries and completely disconnect from the grid, or have the solar company take the system off my roof and resell it to a PG&E customer!

Part of the energy rate pays for SMUD infrastructure and to have uninterrupted power when it’s cloudy or during the night - I get that. However, we also have infrastructure costs as power providers to SMUD. We bear the cost of the land, the roof structure, property taxes, and the solar installation + equipment. The power we provide the the grid also has to travel the least distance of any other source of power generation.

Finally SMUD has existing solar farms and is planning to invest $1.5B in more solar. How can that power be worth a different rate than rooftop solar when it is the same kW produced at the same time with no additional infrastructure cost to SMUD.

Let’s find a way to work together to find the solution, whatever it is, but I think you have received feedback twice now from your rooftop solar customers that the current approach is not working. I also see zero comments from non-solar customers, which makes me think this is not a primary concern for them... while in the middle of a pandemic, raging wildfires, and whatever is going on in Washington DC.

Stay safe, stay healthy, and please wear a mask! Thanks for listening. 


August 23 - Kirby S. 
My solar adds surplus energy to the grid, I love my solar, i enjoy knowing my home is powered by clean energy. SMUD pays me pennies for the excess I produce and then You are trying to Add more Fees to my bill! I support the Rooftop solar system Owner in Saying STOP trying to Discourage Roof Top Solar!!! Support it instead and leave it just as it is!!!!! Thank You "


August 23 - Sunrun Inc. 

Dear SMUD Board of Directors,

Sunrun Inc. (“Sunrun”) submits the following comments on the Sacramento Municipal Utility District (“SMUD”) Value of Solar and Solar + Storage Study Draft (“Draft Study”) prepared by Energy + Environmental Economics, Inc. (“E3”).

I. Executive Summary

SMUD engaged E3 to conduct an independent analysis of the value of solar and storage, with a focus on behind the meter (“BTM”) solar and storage. The Draft Study concludes that the direct value of customer solar and solar + storage systems in 2020 is $0.03 - $0.07 per kWh; and that under SMUD’s current net metering (“NEM”) program, this results in a net cost to SMUD of $0.05 - 0.09 per kWh. The Draft Study estimates that “[w]hen considering all systems operating in 2020, the total payment to customers with BTM solar and solar + storage resources exceeds the value to SMUD ratepayers by $25 - 41 million. These estimates equate to annual bill increases of $26 - 45 for the average residential customer.”

The Draft Study significantly undervalues BTM solar and storage resources and Sunrun urges the Board to reject the Draft Study as contrary to the public interest. The Draft Study’s flawed conclusions perpetuate the unsubstantiated narrative advanced by NEM critics that customer-sited solar and storage create a “cost shift” that burdens non-solar customers. This narrative is unsupported in other jurisdictions and the Draft Study does not support it in the SMUD territory. The Draft Study’s results are the product of flawed methodologies and unsupported assumptions, including:

• Failure to take into account the timeline for meeting the Climate Emergency Declaration goals of net zero carbon emissions by 2030.
• Incorrectly categorizing savings from customer energy conservation and demand management as a cost to SMUD.
• Failure to consider a realistic demand curve aligned with the Climate Emergency Declaration.
• Failure to consider transmission and distribution constraints that limit the amount of utility scale solar available to meet demand under SMUD’s electrification goals.
• Failure to account for the transmission access charge savings that BTM solar and storage provide to SMUD ratepayers by reducing power import needs.
• Applying an inappropriately high 15% derate to estimate BTM solar and storage potential to provide transmission system deferrals.
• Failure to appropriately consider distribution system planning needs, including opportunities to leverage customer-sited solar and storage resources for infrastructure deferral or avoidance.
• Failure to consider customer choice, energy efficiency benefits of self consumption, and reasonable economic considerations as to how a customer would operate their battery absent any grid service programs or economic price signal to support the grid.
• A fundamental and unsupported bias toward meeting resource needs with utility scale solar over BTM solar and solar + storage.
• Assessing the value of BTM solar and storage on “scenarios” that do not provide an accurate framework from which to assess the value of these resources.
• Underprojecting the amount of customer-sited energy storage likely to be deployed over the next 10 years.
• Failure to appropriately assess the resilience value of BTM solar and storage.
• Failure to conduct any quantitative analysis of the jobs and local economic impact benefits of BTM solar and storage, despite this being a value component specifically identified for evaluation by the Technical Working Group (“TWG”).

When the value of customer-sited solar and storage is not properly acknowledged and accounted for, and DER customers are not allowed to deliver that value to the grid on a level playing field, these resources will be sidelined and achievement of SMUD’s climate and energy goals will be more costly and less responsive to consumer needs and preferences. Understanding the generation and distribution system needs to achieve the Board’s climate and energy goals - and how customer-sited solar and energy storage can contribute to meeting these goals while maintaining affordable rates and reliable electric service - requires an objective analysis of the value of BTM solar and energy storage. The Draft Study fails to accomplish this.

Instead of continuing down a flawed path that will undercut timely climate and clean energy goals, Sunrun urges the Board to reject the current study and direct Staff to begin an advanced system planning process. This will align SMUD’s system needs with demand forecasts and public policy goals - including those judiciously articulated in the Climate Emergency Declaration. This process will provide the appropriate context from which to understand the capabilities and limitations of different resources and allow the Board to evaluate BTM solar and storage from a holistic system planning perspective.

Achieving the climate and energy goals adopted by the Board requires a comprehensive approach to integrating demand and supply side resources, including utility scale and behind-the-meter clean energy resources, in order to maximize the benefits of each type of resource. Sunrun commends the Board for its leadership in adopting the Climate Emergency Declaration to more rapidly advance deep decarbonization strategies and achieve climate and clean energy goals. To evaluate the most cost-effective means to achieve these goals, it is essential that the Board is guided by objective analyses that take into account the policy priorities of the Board and the generation and transmission and distribution system resources needed to meet those policy priorities.

It is no secret that advances in solar, storage and other DER technologies provide increasingly important flexibility to more cost-effectively achieve deep decarbonization goals. Indeed, numerous states recognizing the value of customer-sited DERs to meet these and other goals have instituted market and regulatory reforms to provide these resources the market participation pathways necessary to unlock that value of the resources for the benefit of all ratepayers.

Unlike the current Draft Study, an objective study informed by the resource needs to meet the Climate Emergency Declaration goals will reveal opportunities to develop customer programs that encourage greater energy conservation and leverage customer-sited solar and storage to provide greenhouse gas (“GHG”) emissions reductions, peak demand reduction, distribution system upgrade deferral and avoidance, enhanced reliability and resilience of the grid, and other benefits that lower costs for all SMUD customers. In other words, when customer-sited solar and storage are evaluated objectively and in the context of how these resources can contribute to achieving the climate and clean energy goals of the Board, it will be clear that these resources do not burden non-solar customers with a “cost-shift,” but instead provide substantial net benefits to SMUD ratepayers as a whole.

The Draft Study is a seriously flawed document lacking the analytical rigor and objective analysis that Board policy should be based upon. We urge the Board to continue its strong leadership on climate and clean energy and abstain from making any changes to rates that would impact BTM solar and energy storage without first conducting a thorough advanced distribution system planning process. This process will clarify the value these resources provide in advancing SMUD’s energy and climate goals, and the attendant benefits they provide to all SMUD ratepayers.

II. Discussion

A. The Draft Study’s Analysis of the TWG Value Components Is Fraught with Technical Flaws and Unsupported Assumptions that Result in Significant Undervaluation of Customer-Sited Solar and Storage.

1. The “Helps Meet Clean Energy Goals” and “Incremental Clean Energy” Scenarios Are Flawed Analytical Frameworks that Drive Heavily Skewed Results Undervaluing BTM Solar and Storage

The Draft Study assesses the value components for BTM solar and storage under two scenarios: “Helps Meet Clean Energy Goals” and “Incremental Clean Energy.” The “Helps Meet Clean Energy Goals” scenario assumes that SMUD’s clean energy goals will be met with utility scale solar resources. The value of BTM solar (and storage) under this scenario is analyzed based on the assumption that utility scale solar is a preferred resource that will be procured ahead of all other resources available to SMUD and therefore BTM solar consumed by the customer or injected to the grid will displace energy otherwise provided by utility scale solar. Under the “Incremental Clean Energy” scenario, the Draft Study assumes that BTM solar resources can provide “incremental” clean energy value beyond SMUD’s clean energy goals. Under this scenario, BTM solar is assumed to displace natural gas generation at the margins.

Neither of these scenarios are appropriate for assessing the value of BTM solar and storage resources. As described further in the sections below, utility scale solar (or storage) is not an “apples to apples” comparison with BTM solar and storage. In other words, utility scale solar does not necessarily provide the same service (or “benefit”) as BTM solar for any particular value component. Under the “Helps Meet Clean Energy Goals” scenario it is inaccurate to assume that the value of BTM solar is limited to displacing the wholesale energy cost of purchasing utility scale solar and transmission and distribution line losses saved from delivering that utility scale solar to SMUD customers. Moreover, deriving BTM solar and storage valuations based on the assumption that the same value component benefits can be provided by utility scale solar presents a highly simplistic and inaccurate picture of the dynamics of the bulk power system - from the generation to the transmission and distribution system. The August 19, 2020 letter from the CPUC, CAISO, and the California Energy Commission to Governor Newsom regarding the power outages on August 14th and 15th triggered due to insufficient resources highlights this point.

The letter states power outages that occurred on August 14th and 15th were the result of a confluence of factors, including “severe constraints on imports because of a developing, historic west-wide heat wave.” The letter further described the import constraints factor:

Another factor that appears to have contributed to resource shortages is California’s heavy reliance on import resources to meet increasing energy needs in the late afternoon and evening hours during summer. Some of these import resources bid into the CAISO energy markets but are not secured by long-term contracts. This poses a risk if import resources become unavailable when there are West-wide shortages due to an extreme heat event, such as the one we are currently experiencing. The CAISO has observed that during the current heat wave, energy supporting imports from other Western utilities have been significantly constrained during the late afternoon and evening hours, as those other utilities must plan to meet their own demand and have limited ability to export supplies to California. This hampers the CAISO’s ability to secure net import energy sufficient to meet evening ramping requirements.

The Draft Study’s simplistic assumption that SMUD can meet its climate and clean energy goals through imported utility scale solar stands in stark contrast to the realities of the bulk power system. The prospect of more frequent extreme heat wave events such as that described in the letter as contributing to the unavailability of imported power will only become more frequent as the impacts of climate change compound.

Moreover, the “Helps Meet Clean Energy” scenario also fails to account for GHG emissions reduction, generation capacity, the value of energy from generation resources displaced other than utility scale solar, the locational marginal price value of customer-sited solar, and multiple other values that should be accounted for when assessing the value of BTM solar and storage. The inclusion of the “Incremental Clean Energy” scenario is a meaningless comparative scenario given the multiple design flaws in the “Helps Meet Clean Energy Goals” scenario.

More fundamentally, neither scenario takes into account the transmission, distribution and electric generation and supporting resources needed to meet SMUD’s climate and energy goals. The Board’s recent adoption of the Climate Emergency Declaration and the rolling blackouts in response to the recent heatwave highlight the inadequacies of the Draft Study’s scenarios and underlying assumptions.

The Board unanimously approved the Climate Emergency Declaration in July directing Staff to report within 180 days on clear, actionable and measurable strategies and plans to meet SMUD’s climate emergency goals, which include achieving carbon neutrality by 2030. The Climate Emergency Declaration affirms SMUD’s commitment to the greenhouse gas (“GHG”) emission reduction strategies previously adopted in the 2040 Energy Plan.

The 2040 Energy Plan states “in order for California to reach its goal of 80% GHG emission reductions and for the Sacramento region to achieve the same level of reductions, it may be necessary to dramatically scale up the pace of electrification of buildings and transportation while also maximizing improvements in energy efficiency, demand response, and renewable energy. This would have to be done at all points in the grid, from large scale grid-connected renewables and storage to small scale behind-the-meter resources.”

The Emergency Climate Declaration requires SMUD to meet net-zero carbon emissions by the year 2030. Many of the deep decarbonization strategies identified in the 2040 Energy Plan - including a dramatic shift to electrification, must be implemented 10 years ahead of the originally planned schedule in order to meet the 2030 goals, and will require greater integration of customer-sited solar and storage. The assumption that the SMUD territory will meet electrification goals by 2030 and that the increase in demand resulting from that electrification will be - and should be - met by utility scale solar resources is a foundational assumption of the Draft Study that (a) does not pass basic scrutiny; and (b) is inconsistent with the Board’s goals and stated objectives.

Customer-sited solar and storage resources offer myriad benefits that will “Help Meet Clean Energy Goals” that go well beyond marginal T&D line loss savings and displacing utility scale solar wholesale energy costs. To understand how various types of resources, including BTM solar and storage can and should contribute to SMUD’s climate, clean energy and other goals, advanced distribution system planning should be initiated.

For instance, in Hawaii - a state on the leading edge of BTM solar and storage adoption - the Hawaii Public Utilities Commission (“Hawaii PUC”) initiated an advanced distribution system planning processes in 2018 to investigate how to better integrate customer-sited solar, storage and other DERs to accelerate the State’s progress towards a clean energy future. The Hawaii PUC describes the process as investigating ways to “connect critical grid-planning processes and priorities in innovative ways that could respond to the State’s needs and reduce costs to customers.”

The Draft Study’s evaluation of BTM solar and storage fails to provide this critical context and therefore falls well short of providing any probative value in assessing the value that BTM solar and storage resources provide to ratepayers in the SMUD territory. As it currently stands, the Draft Study essentially provides an extremely narrow assessment of BTM solar compared to utility scale solar based on wholesale energy values in an apparent attempt to demonstrate that BTM solar resources are currently being overcompensated under NEM rates.

The Draft Study does not apply the analytical rigor necessary to provide the Board an objective assessment of the value of BTM solar and storage or any useful basis upon which to make informed policy decisions. The Draft Study is fraught with the shortcomings and ill-conceived “scenario” comparisons that regrettably appear to be designed to skew the results in favor of policy outcomes preferred by NEM critics. We urge the Board to reject these transparent attempts to undermine the benefits of BTM solar and storage and adopt our recommendation to initiate an advanced distribution system planning process and consider BTM solar and storage in this broader context in order to align SMUD’s system needs, investments, and program development with public policy goals.

2. TWG Avoided Cost Value Components 1a & 9

TWG Avoided Cost Value Components 1a & 9 attempt to capture the avoided purchase of energy that would otherwise be needed, including SMUD’s obligations to comply with California’s RPS and carbon emissions cap-and-trade system (value component 1a); and decreased thermal power plant operations resulting in decreased variable operating costs (i.e., water, waste, etc.) (value component 9).

The avoided energy and displaced thermal power plant values must be substantially modified to account for transmission and distribution (“T&D”) needs to achieve the electrification and other clean energy goals identified in the Climate Emergency Declaration. Critically, the analysis of value components 1a and 9 is based in part on the assumption that SMUD will meet a substantial portion of its electricity demand from utility scale solar imports. The analysis for these value components does not appear to: (1) consider T&D system network upgrades required to actually deliver the energy from these out-of-state solar facilities to SMUD customers; (2) assess the cost burden of these upgrades and the associated transmission access charges (“TAC”) that would be assessed for wheeling power from these utility scale solar resources to serve SMUD load; or (3) consider the locational marginal price (“LMP”) at various points along the T&D system serving the SMUD territory.

As such, the wholesale energy value of utility scale solar in the Western Interconnection is an inappropriate proxy from which to value the incremental value of BTM solar and storage. At minimum, detailed T&D network upgrade and TAC analyses would be needed to derive a more accurate understanding of the value that customer-sited solar and storage resources can provide under these value components.

As noted above, advanced distribution system planning is a cornerstone to ensuring that ratepayer dollars are effectively and efficiently spent to align system operational capabilities with energy, climate and other public policy objectives. To accurately evaluate these (and the other) value components, the analysis must take into account load forecasting and the results of T&D system planning studies for meeting those forecasts and achieving public policy goals - including the Emergency Climate Declaration’s emphasis on electrification as a key strategy for meeting net-zero carbon emissions by 2030. These studies will identify T&D infrastructure needs and inform myriad value components of BTM solar and storage.

For instance, at its most fundamental level, BTM solar is a load reducer that displaces the need for SMUD to provide energy to meet a particular customer’s energy demand. The value of that displaced energy is not; however - as the Draft Study assumes - simply reflected by the wholesale value of a utility scale solar facility. The value of that energy is instead informed by the time of day in which the customer’s generation displaces energy delivered by SMUD, the location of the customer on the electric grid, the electricity demand of other customers served on the same circuit or substation, and other factors that the Draft Study ignores. Because the Draft Study evaluates value components 1a and 9 from a framework that compares BTM resources with utility scale resources (i.e., through the lens of the “Helps Meet Clean Energy Goals” scenario), it does not capture these additional values, nor does it acknowledge these additional values.

In addition to load reduction benefits, solar and storage can provide other valuable T&D system benefits. These include dynamic load management, peak demand reduction, infrastructure deferral and avoidance, hosting capacity expansion, and others. The need for these services and the value to ratepayers when these services are provided by BTM solar and storage can be identified in advanced distribution system planning processes. These processes will provide the framework for evaluating the availability and market participation pathways for BTM solar and storage to meet demand and other distribution system needs. As such, an advanced distribution system planning process should be a prerequisite to a value of solar and storage study.

3. TWG Avoided Cost Value Component 1b

TWG Value Component 1b attempts to capture the avoided purchase of energy that would otherwise be needed, including SMUD’s obligations to comply with California’s RPS and carbon emissions cap-and-trade system.

The Draft Study states “the marginal cost of greenhouse gas emissions is calculated as the cap and trade allowance price multiplied by the marginal emission rate (the emissions from the last plant to dispatch in each hour).” The Draft Study concludes that the “Incremental Clean Energy” scenario results in a GHG emission reduction value of between $0.072 kWh and $0.163/kWh. Despite the substantial GHG emission reduction value provided by BTM solar, the Draft Study appears to assume that because that value could theoretically be provided by utility scale solar or other non-fossil energy sources, that it should be disregarded or heavily discounted for BTM solar. The Draft Study states:

Simply adding these societal values to the total ratepayer values derived from customer solar installations incorrectly assumes that customer solar is the only means to achieve these benefits. In reality, SMUD has a variety of means at its disposal to meet the clean energy targets set out by its Board of Directors. If achieving these benefits is a goal for the utility, the cost of achieving these benefits through customer solar must be weighed against the cost of achieving them through alternate means. This type of analysis is beyond the scope of this report and is best conducted as part of a comprehensive utility planning process such as an Integrated Resource Plan.

The fact that other resources can also provide GHG emission reduction benefits is not a basis to exclude that value from BTM solar resources. Moreover, the Draft Study suggests that the Board has left open the question of “whether” it would like to advance climate and clean energy goals and the conclusion that if so the cost of achieving these goals with BTm solar “must” be compared with alternate means. This (a) completely ignores the Climate Emergency Declaration through which the Board has made climate and energy goals a priority ; and (b) incorrectly assumes that GHG emission reduction value should be assessed based on the relative cost of the energy from any particular resource that can also provide GHG emission reductions. By the Draft Study’s logic, when assessing the value of any other resource, the GHG emission reduction value should also be discounted if utility scale solar could provide the same amount of “energy” (and therefore attendant GHG emissions reductions) as a lower wholesale energy price. In other words, the Draft Study removes the GHG reduction value that BTM solar and storage provide - despite that these resources are in fact providing that benefit.

As discussed in the section above, this assumption is inappropriate and based on the fundamentally flawed “scenarios” through which the Draft Study evaluates BTM solar and storage. Comparing the wholesale price of the energy component of utility scale solar to BTM solar and then excluding the GHG emission reduction value of BTM solar is a critical methodological flaw in the Draft Study. BTM solar has multiple benefits; one of which is the ability to reduce GHG emissions. GHG emission reduction value should therefore be a part of the value stack when assessing the value of BTM solar regardless of whether other resources can also provide that value.

4. TWG Avoided Cost Value Component 4

TWG avoided cost value component 4 attempts to capture generation capacity resource adequacy value.

Sunrun agrees with the Draft Study’s use of the net cost of new entry (Net-CONE) of a capacity resource to calculate resource adequacy value but we question the assumptions this analysis is based upon. For instance, utilizing a loss-of-load probability method to identify planning needs may be warranted as part of the analysis but it does not provide insight into the level of reserves needed as conventional generations sources retire within the planning horizon.

Sunrun notes again the Draft Study’s failure to take into account the electrification and other clean energy goals set forth in the Board’s Climate Emergency Declaration. The generation capacity needs for SMUD must be assessed based on the best possible understanding of the SMUD territory’s distribution and generation resource needs to meet these goals. The recent rolling blackouts impacting hundreds of thousands of customers also highlights the importance of “local” (i.e. BTM) resources to provide capacity value at load. Periods of high electricity demand underscore the value of BTM solar and storage. These resources’ dynamic load management capabilities allow them to operate both as a dispatchable load reducer through demand response and other dynamic load management programs and as a dispatchable local generation resource to reduce the need for imported power for other customers on constrained circuits. These capacity values are not accounted for in the Draft Study, cannot be provided by utility scale solar and storage, and are an important value component that BTM solar and storage will provide in meeting the goals articulated in the Climate Emergency Declaration.

5. TWG Avoided Cost Value Component 21

TWG avoided cost value component 21 for sub-transmission and distribution capacity attempts to capture daytime demand reduction and traditional distribution upgrade reductions.

The forecasts utilized in SMUD’s five-year plan and the Draft Study’s marginal cost method do not accurately reflect the future needs of SMUD to achieve the policy objectives adopted in the Climate Emergency Declaration. SMUD’s sub-transmission and distribution capacity must be reassessed to understand the potential system upgrade and other resource needs to timely achieve the Climate Emergency Declaration’s goals. As discussed above, advanced distribution system planning is a cornerstone to ensuring that ratepayer dollars are effectively and efficiently spent to align system operational capabilities with energy and climate policy objectives identified in the Climate Emergency Declaration and Sunrun urges the Board to adopt such a process.

Sunrun also notes that the Draft Study appears to focus solely on specified deferral value for the 2020 - 2025 forecast period and dismisses potential unspecified deferral value of BTM solar and storage. With respect to specified deferral value, the Draft Study states “[f]or 2020-2025 E3 and GridSME identified which planned sub-transmission and distribution capacity investments were potentially deferrable by customer solar systems, based on the type of project and information provided by SMUD on the need driving each scheduled investment.” Regarding unspecified deferral value, the Draft Study states “[a]n alternate approach would have involved the remodeling of the entire SMUD system based on theoretical system loadings if there were no BTM solar installations in the SMUD territory. Such an analysis, however, would have required the SMUD engineers to conduct an extensive re-engineering of the sub-transmission and distribution systems, and was determined to be beyond the scope of work that could be done for this analysis.”

The California Public Utilities Commission (“CPUC”) recently adopted revisions to its avoided cost calculator to account for the unspecified deferral value provided by DERs. The calculator now includes a “No New DER Scenario” sensitivity analysis to determine the value of capacity that will not be built, fuel that will not be purchased or burned, and electricity that will not be used as a result of DERs on the system. The CPUC summarized the revision as “[t]he outputs of the modeling tells us what it would cost to operate the grid replacing the DERs with supply-side resources.” This avoided cost modeling is the standard in California. It provides a straightforward metric for determining the reduced system costs that DERs provide from unspecified deferral value that should be accounted for when assessing the value of BTM solar and storage.

Sunrun also notes that with respect to specified deferral, whether a DER solution is capable of providing specified deferral value will in many cases depend upon the location specific circumstances of the identified grid need. More fundamentally; however, the avoided distribution costs for specific planned distribution upgrades avoided by DERs can only be monetized where those specified values are actually pursued, such as through the distribution investment deferral framework (“DIDF”) process. SMUD does not have such a process and specified deferral value becomes much harder to accomplish when a “stable” of DERs are not already on the system that can be operationalized for deferral opportunities when they arise.

The investments needed to meet the Climate Emergency Declaration goals identified in an advanced distribution system planning process will reveal opportunities to leverage BTM solar and storage resources to defer or avoid system wide and location specific capital investments through dynamic load management, peak demand reduction, infrastructure deferral and avoidance, hosting capacity expansion, and others to reduce costs to SMUD ratepayers. To maximize these ratepayer benefits; however, BTM resources must have a level playing field upon which to compete with other generation and distribution system resources. SMUD can begin to level the playing field with advanced distribution system planning to identify grid needs and instituting programs that provide market participation pathways for customer-sited resources to help meet identified grid needs; and in turn provide greater insight into the value these resources provide to all SMUD ratepayers.

6. TWG Avoided Cost Value Component 18

TWG avoided cost value component 18 for transmission capacity attempts to capture reductions in daytime demand and traditional upgrades.

The Draft Study states “[a]s shown in [Table 7], there is no forecast[ed] need for transmission capacity projects after 2020. A direct use of the marginal transmission capacity cost from the SMUD study would therefore overestimate the value of peak load reductions provided over this time period.” The Draft Study continues that “[l]ong-lived assets that provide load reductions past 2028 could provide capacity value, but crediting of such value should only occur for the years of operation past 2028 wherein there is a need for transmission peak load reductions. Accordingly, E3 used a value of $0/kW-yr for the period 2020 – 2028.”

As mentioned throughout these comments, the Climate Emergency Declaration adopted by the Board requires an accelerated transition to electrification to meet clean energy and climate goals. The Draft Study does not take into account the substantial increase in electric load that will occur as a result of the transition to greater electrification - including the electric demand of the equivalent of 900,000 additional electric vehicles and 400,000 all electric homes - nor the impact of such load increases on the transmission system. As such, the Draft Study did not consider the transmission capacity and demand reduction value that BTM solar and storage can provide in this critical context. SMUD’s transmission capacity needs must be reassessed to understand what is needed to achieve the Climate Emergency Declaration’s goals and to discern how BTM solar and storage can provide value to all SMUD ratepayers under this component.

With regard to the post 2028 period, the Draft Study states “[b]eginning with 2029 E3 used a de-rated portion of SMUD’s marginal transmission capacity cost reported in the rate costing, reflecting 15 percent of this annual value.” Sunrun observes that the 15 percent derate derives from assumptions made in the context of distribution deferrals, reflecting that some un-targeted BTM is simply not located in the right place, or is otherwise not the right fit, to cause distribution deferrals. While the same concept can apply to transmission, it is highly questionable whether an actual study would produce a similar result. One of the primary reasons that hypothetical, un-targeted BTM generation might not be able to defer a distribution investment is that distribution needs can be highly localized. On the other hand, the load “sinks” associated with bulk transmission systems are much larger. Therefore, locational dependence is less pronounced, and more BTM would fall within a load sink that defines a potential transmission need than with the distribution system. In other words, the Draft Study’s use of the 15 percent derate used for the distribution system is not an apples to apples comparison for use on the transmission system. The derate for the transmission system should be much smaller.

With regard to the Draft Study’s assumption that BTM solar provides $0 in transmission capacity benefits, this assumption also fails to account for SMUD’s ability to sell transmission as a source of revenue. To the extent that BTM solar and storage contribute to increased transmission capacity that SMUD is able to make available and generate revenue from, this value should be accounted for and attributed to BTM solar and storage resources.

SMUD also pays some CAISO transmission-related charges even though it operates separately from CAISO. When BTM solar and storage reduce the need for SMUD to import power and incur CAISO TACs (i.e., lower the SMUD allocation of CAISO costs), these resources are providing a benefit to SMUD ratepayers. This value should also be accounted for and attributed to BTM solar and storage resources.

7. TWG Societal and Solar Customer Value Component 15

TWG societal and solar customer value component 15 for resilience attempts to capture the value of a customer’s ability to meet critical needs during an outage if the system is configured to function during grid outages.

The Draft Study states “[g]iven that SMUD’s reliability data indicates an average outage duration of 1.33 hours, E3 used the one-hour duration values in the figure above as the base case for assessing resilience value to customer solar system owners.” The Draft Study’s conclusion that the annual resilience value to an average residential customer is $23 significantly underestimates the resilience value of BTM solar and storage.

Contrary to the Draft Study’s assumption that resiliency confers benefits only to the solar and storage customer, BTM solar and storage customers, SMUD, and society as a whole benefit from the resilience value added by these resources. For example, during a power outage, BTM solar and storage systems can enable businesses to stay open, employees to stay on the job, residents to stay (and work and learn) in their homes, and hospitals to continue to operate and save lives. This confers direct benefits to the individual customers through, for instance, avoided loss of perishable materials and goods including avoided food and medicine spoilage that could cause a more significant burden to families and individual health, avoided loss of customers and revenue, avoided equipment damage, and avoided data losses. It confers benefits more broadly to society as a whole through, for instance, enabling customers to work from home, businesses to stay open and provide services to customers, and helps hospitals and essential public service entities to continue to operate during grid outages.

The need for these resilience measures is highlighted by the rolling blackouts caused by wildfires and bulk power system issues noted above. Electrical outages resulting from wildfires have increasingly become a “norm” in California and are currently impacting communities across the state. SMUD solar and storage customers aligning their resource needs with time of use price signals from SMUD are providing a resilience service to the grid by reducing energy imports, reducing the need for load shedding and avoiding interruption of power. Recognizing the need for greater resilience in the face of wildfires, earlier this year the CPUC finalized rules to allocate SGIP resources to direct more than $500 million in incentives for BTM energy storage over the next four years to customers most at risk from wildfires and the grid outages instituted to prevent those fires. While the risk of wildfire is lower in the SMUD territory than in some other parts of the state, wildfire mitigation is only one aspect of resilience and the impacts of climate change are altering what is considered “normal” in a utility service territory.

As discussed above, the Draft Study assesses the value components for BTM solar and storage from the standpoint that BTM resources will displace imported utility scale solar (under the “Helps Meet Clean Energy Goals” scenario) or imported natural gas (under the “Incremental Clean Energy” scenario). The recent rolling blackouts that were the subject of the above referenced letter to Governor Newsom highlight the fundamental flaws in relying on the clean energy “import” assumption to justify the Draft Study’s undervaluation of BTM solar.

Sunrun acknowledges that some resilience and other “non-energy” benefits may be more difficult to quantify than energy system benefits, and in some instances may require new and different measurement tools. However, to leave these critical benefits unmeasured - as the Draft Study does - is equivalent to assuming that they have no value. The Draft Study’s narrow assumptions regarding resilience are unsupported and undervalue the resilience benefits of BTM solar and storage.

8. TWG Societal and Solar Customer Value Component 14

TWG societal and solar customer value component 14 for equity attempts to capture the value of reduced energy burden for low-income customers who have solar/storage.

The Draft Study finds that while “customer solar and solar + storage systems may contribute to equity by reducing the bills of low-income customers that adopt solar”; “E3 finds that SMUD’s current NEM leads to bill increases for non-solar customers due to the compensation solar customers receive through NEM, raising retail rates for all customers. This increases the energy burden that non-solar lower income customers who already spend disproportionately on electricity and other utilities must bear.”

The Draft Study’s dismissal of the equity benefits of BTM solar and storage to low-income customers (1) ignores one of the primary goals of the Board’s Climate Emergency Declaration; and (2) is based on the flawed assumption that NEM causes a cost-shift to non-participating customers. In the Climate Emergency Declaration, the Board emphasized SMUD’s Sustainable Communities Initiative and the need to leverage GHG emission reduction investments through community partnerships and to target and maximize benefits in underserved neighborhoods.

Expanding access to BTM solar and storage to customers in underserved communities provides these customers additional tools to manage their energy bills, adds local clean generation and storage capacity in the deployed location that can be dispatched individually and through aggregations to deliver locational and system wide benefits to all ratepayers; and enhances grid resilience and reliability. Aggregated BTM resources may also ultimately lead to the retirement of polluting natural gas plants, particularly higher heat rate peaker plants, which are often disproportionately impacting the communities who live closest to these plants.

The Draft Study’s dismissal of the equity benefits of BTM solar and storage fails to acknowledge that expanded access to BTM resources empowers low-income and other underserved customers to be part of the climate solution and thereby misses the mark on this important Board policy priority.

9. TWG Societal and Solar Customer Value Component 18

TWG societal and solar customer value component 18 for the local economy discusses the jobs and local economic growth resulting from rooftop solar.

The Draft Study acknowledges that customer-sited solar and storage installations leads to increased economic activity and jobs, but then provides the following unsupported assertion to justify the unreasonable conclusion that an assessment of the economic impact of BTM solar and storage should not be included in the study:

E3 finds that the installation of customer solar and solar + storage systems leads to bill increases for non-solar customers due to the compensation solar customers receive through NEM, which raises retail rates for all customers. These increased bills have a negative effect on the local economy, as non-solar customers have less income to spend on non-energy goods and services. Local businesses’ costs increase due to these increases in electricity rates, reducing their ability to hire staff and create further economic growth.

The Draft Study then concludes that “[t]he net effect of these two contrasting forces cannot be known without a comprehensive macroeconomic analysis, which falls outside of the scope of this study.” The TWG identified local economic impacts as a value component to be assessed in the study. To simply not conduct that analysis is unacceptable. Where BTM solar and storage create economic benefits, those values must be accounted for on the “benefit” side of the equation. The Draft Study’s assertion that a macroeconomic impact analysis is necessary to determine the “net effect” between the local economic impact “benefits” and “costs” is illogical. If a macroeconomic impact analysis is needed to evaluate the local economic impacts of BTM solar and storage, then such an analysis is not outside the scope because the TWG identified economic impacts as a value component.

As a starting point for evaluating the economic benefits of BTM solar and storage, Sunrun recommends review of the study conducted by Crossborder Energy. That study used NREL data and estimated that rooftop solar systems provide 17% of added local economic benefits compared to utility-scale solar. Sunrun also recommends the value of solar study conducted for the Maryland Public Service Commission (“Maryland PSC”). The Maryland PSC study showed that BTM solar provided approximately $0.13 to $0.17/kWh of additional macroeconomic benefits beyond those of what utility scale would provide.

10. Section 3.5 - Customer Solar System Operation and Value

The Draft Study modeled the different costs and benefits associated with SMUD’s customer solar systems under the three different configurations: 1) solar only; 2) solar + storage responding to SMUD’s retail rates; and 3) solar + storage responding to SMUD dispatch signals in order to maximize value for all customers.

The assumptions and methodologies employed in the modeling exacerbate the flawed value component analyses described above. The Draft Study states that it evaluated representative customers and rate combination for all years between 2020 and 2049 “in order to produce lifetime estimates of the value of solar and storage over twenty years (i.e., as the last systems in the study period would be installed in 2030, their 20th year of operation would be 2049).” The rationale behind stopping the analysis of BTM solar and storage installation in 2030 is not clear. Customers in the real world would not behave in this way and as additional systems are added beyond 2030, the potential for pre- and post-2030 resources to provide higher aggregate system value increases. A more accurate analysis would include customer installations through 2040 coupled with updated information from advanced distribution system planning to take into account the grid needs identified as necessary to achieve the Climate Emergency Declaration goals by 2030.

Additionally, within Figure 18, the assumed storage dispatch profile is questionable and it is not clear which use case this represents. Based on the energy value represented within this table, the customer would simply self consume and not inject to the grid as modeled. Customers will not operate their battery in this manner unless there are price signals to justify providing additional support through power injections to the grid.

11. Section 4 - Results

The Draft Study presents its results under three categories: (1) “Solar Only”; (2) “Solar + Storage (Customer Dispatch)”; and (3) “Solar + Storage (Utility Partnership).” Each category is assessed for “2020” and “2030” under the “Helps Meet Clean Energy” and “Incremental Clean Energy” scenarios.

As discussed above, neither of the “scenarios” employed are appropriate for assessing the value of BTM solar and storage, and flawed methodologies and assumptions used to derive the conclusions presented in Section 4 of the Draft Study skew the results to significantly undervalue BTM solar and storage. Further, the Draft Study takes an overly simplistic and flawed approach to analyzing many of the value components. The Draft Study’s shortcomings include considering energy consumed by a customer from their on-site solar as a “cost” to SMUD, failing to assess economic impact benefits from BTM solar and storage installations, failing to accurately consider how customers will respond to increased utility rates that result from billions of dollars in SMUD investments through investment in energy management technologies - including BTM solar and storage; and failing to account for the system changes and resource needs that must come to bear in order to achieve the Board’s Climate Emergency Declaration.

As discussed throughout these comments, BTM solar and storage valuations should be informed by advanced system distribution planning processes. SMUD has an acute need for an advanced distribution planning process and Sunrun urges the Board to adopt such a process to better understand the resource needs to meet the Climate Emergency Declaration goals and the role that BTM solar and storage can play in meeting those needs.

III. Conclusion

The Draft Study significantly undervalues BTM solar and storage due to serious methodological flaws and assumptions that are inconsistent with public policy goals, transmission and distribution system planning and operational needs, customer preferences, and DER adoption forecasts. As a result, the Draft Study fails to properly account for the role that customer-sited solar and storage must play in meeting the Board’s climate, energy and related public policy goals - and in particular the goals adopted in the Climate Emergency Declaration.

Instead of continuing down the flawed path that has emerged in this value of solar and storage study, Sunrun urges the Board to reject this study and direct Staff to begin an advanced system planning process to align SMUD’s system needs with demand forecasts and public policy goals - including those judiciously articulated by the Board in the Climate Emergency Declaration. This process will provide the appropriate context from which to understand the capabilities and limitations of different resources and allow the Board to evaluate BTM solar and storage from a holistic system planning perspective.

Unlike the current Draft Study, an objective study informed by the resource needs to meet the Climate Emergency Declaration goals will reveal opportunities to develop customer programs that encourage greater energy conservation and leverage customer-sited solar and storage resources to provide GHG emissions reductions, peak demand reduction, distribution system upgrade deferral and avoidance, enhanced reliability and resilience of the grid, and other benefits that lower costs for all SMUD customers. When customer-sited solar and storage are evaluated objectively and in the context of how these resources can contribute to achieving the climate, clean energy, and other public policy goals adopted by the Board, it will be clear that these resources do not burden non-solar customers with a “cost-shift”; but instead provide significant net benefits to SMUD ratepayers as a whole.

Respectfully submitted,

/s/ Lauren R.
Lauren R.
Director of Policy & Market Development
Sunrun Inc.
############
San Francisco, CA #####

/s/ Steven R. 
Steven R.
Director Grid Solutions, Public Policy
Sunrun Inc.
############
Dated: August 23, 2020 San Francisco, CA #####


August 23 - John W. 
In no way should any type of solar be discouraged, because it produces energy without pollution. Dealing with the climate crisis requires all the pollution-free power we can get. Customers without rooftop solar (RTS) need to be incentivized to install solar. One way to do that is to show them that customers with RTS get a financial break for having RTS. Perhaps adjustments can be made to the amount of the financial break, but it should not be eliminated. Costs to non-RTS users should be higher because they are not contributing to pollution reduction. Everyone should be contributing to pollution reduction. Even some low-income customers could acquire RTS utilizing the incentives available today. Climate change is an existential issue that must be addressed before it is too late. Please do all you can to promote more RTS, not reduce it.


August 23 - Elia B. 
I spent a few hours trying to go through all of the report. I have the follow 4 or 5 comments. 

1. Over production, no where could I find why SMUD fights so hard to not let residential solar over produce. There is no current cash payment for over production. I see a few months of the year SMUD can have excessive noon production, but they could easily tell people like me to increase usage at that time and we could account for that. Even now I purpose fully run time my water heater to run at that time and sometimes charge my car. If I had a report of SMUD over production I would happy comply to help SMUD use overproduction. It is a fact, SMUD just built, is currently building many acres at rancho seco, if SMUD thinks they need to build solar there then why can't a resident over produce. This mismatch that I can't explain makes me very upset. 

2. storage, I see the report saying residential storage is not cost effective. But in my reading I couldn't really tell for who. What if i'm happy to lose $1,000 to help SMUD meet peak energy, I don't care if it's less cost effective. I want to spend my money to greatly reduce out emissions whatever that is I can do. 

alerts to use: I want a text every time SMUD has excess Solar. I'm happy to pay for smart timers that turn on when SMUD issues alerts and my car will start charging and etc. I heard these ideas a generation ago, why isn't this available?

lease my roof: I am passionate about building out roofs before taking away Swanson Hawk and Burrowing owl and general contribution to endless urban, solar and vineyard sprawl. I will lease my roof to your for $1 a year. I'm sure many people would. That must be cheaper and at the same time far more ethical than meeting your demand through green fill. 

I want to use energy when you need me to, I want to give you free solar if i'm installing solar anyways the additional cost to give you extra for no return to me is not that much and want to give you me rooftops to produce more solar for free. Make this happen, before we all burn and flood to death.


August 23 - California Solar & Storage Association and Solar Energy Industries Association 
SMUD Board of Directors,
CALSSA and SEIA appreciate the opportunity to submit comments on E3’s draft Value of Solar and Storage Study done under the direction of SMUD’s General Manager and staff. We are disappointed in SMUD’s denial of our request for a modest amount of time to review and provide comments after our meeting with E3, instead of having only three working days. We have provided comments on numerous studies done under contract with utilities and other government agencies and rarely is public comment and participation so truncated. 

Timelines aside, we believe this study contains several crucial flaws that should be addressed before SMUD proceeds with important public policy decisions related to the future growth of distributed energy resources. Here, we provide our key takeaway of the draft study as well as an overview of our critiques of the draft. Our detailed analysis follows after the overview of the critiques. 

Key Takeaway 

Commendably, the study is among the first attempts to quantify the value of adding a smart energy storage system to behind the meter solar. As utilities should be actively and aggressively encouraging smart energy storage systems, which remotely communicate with the utility to charge and discharge at optimal times, this aspect of the study is an important element. While we believe E3 undervalues how tens of thousands of smart solar-charged batteries could help SMUD reach its new 2030 zero-carbon goal (see our detailed comments for more information), we appreciate the cutting-edge analysis to include smart storage. Unfortunately, instead of highlighting the findings in the executive summary, E3 buried this information in the body of the report. We think this is a mistake that should be corrected. 

Beyond the study’s valuation of smart storage, overall the draft falls short on providing the board an accurate and forward-thinking assessment of customer-sited solar and storage. We are disappointed to see that instead of leading, SMUD is following the footsteps of California’s investor-owned utilities by undervaluing the benefits and exaggerating the alleged cost shift of solar systems installed by SMUD customers to save money and do right by the community and the planet. Whether intentional or not, the draft study and the accompanying FairSolar webpage repeat the well-worn tropes peddled by fossil fuel interests, namely that homes and businesses that consume less energy from the grid are a burden to society and that the environmental and community benefits of rooftop solar are of little value. 

We believe SMUD can and should do better. We offer these comments as a starting point to revising and publishing a study that is deserving of the truly remarkable utility that SMUD is for the Sacramento community.

Overview of our critiques to E3

Our critiques to the E3 study are focused on the assumptions used in evaluating the costs and benefits of distributed solar and storage systems, as well as how E3 presented their findings. We have summarized our critiques below.

1) E3’s main findings ignore environmental benefits and the value of storage

The main finding in the draft’s executive summary is that the value of solar in 2020 is between 3 cents/kWh and 7 cents/kWh. (Although Table 1 states that it includes solar + storage results from the “Customer Dispatch” scenario, the table only shows values from the “Solar Only” analysis.) These figures ignore both the environmental benefits of rooftop solar, which E3 calculated would add between 3.1 cents/kWh and 17.6 cents/kWh to the value, and the benefits of adding storage, which increases the value by another 2 cents/kWh to 5.5 cents/kWh. In light of the Board’s recent climate emergency declaration and the importance of solar and energy storage to reduce peak demand, these benefits should not be excluded from the main findings of the report. While E3 discusses the environmental benefits of solar and value of storage in the body of the report, the main findings are what is shared most with the general public, as epitomized by the FairSolar webpage and Arlen Orchard’s op-ed in Utility Dive. Excluding the values of storage and the environmental benefits of solar from the main findings gives the appearance that solar has less value than it actually does.

2) The cost calculations include electricity consumed on-site, penalizing solar consumers for using less energy than their neighbors 

E3 calculated the costs of solar based on the total solar energy produced by a customer’s solar panels instead of the energy exported to the grid and credited at the NEM rate. Energy that customers generate and consume onsite simply reduces the electricity purchased from SMUD, similar to energy efficient appliances and building features. SMUD should not regard the energy generated and consumed onsite as a cost to the utility. By extension, SMUD would also regard new ultra-efficient homes as costs to the utility. This is especially true given SMUD has one of the highest monthly fixed charges in state that all customers, including solar customers, pay. 

3) The draft does not take into account SMUD’s climate emergency declaration

E3 calculated the value of solar using SMUD’s old climate change goals, which kept SMUD’s natural gas plants open past 2040. When the SMUD Board adopted its new goal of 0 carbon by 2030 on July 16, despite the fact that the new goal would likely change many aspects of the value of solar, E3 did not revise the study accordingly. For example, we suspect that the new goal could increase demands on transmission and distribution infrastructure, giving more value to solar that can alleviate those demands. Given this significant change in the direction of SMUD policy, we suggest E3 be directed to revise their study to take the Board’s climate emergency into account. 

4) The draft ignores the environmental benefits from reduced methane emissions

When calculating the environmental benefits of solar, E3 did not include reductions in methane emissions. Customers who generate their own solar energy reduce the need for generation from gas-fired power plants. Because methane leaks throughout the production, transmission, and distribution processes of delivering natural gas to power plants, reducing reliance on gas-fired power avoids some of the fugitive methane that would otherwise escape into the atmosphere.

Since methane is a powerful greenhouse gas that, ton for ton, exacerbates climate change 34 times more than carbon dioxide, the environmental benefit realized from solar’s ability to reduce methane emissions is substantial. E3 has acknowledged that the exclusion of methane emission reductions was an oversight.

5) The draft does not incorporate how solar helps SMUD comply with its climate change goals

E3 did not calculate the value of solar to help SMUD comply with its climate change goals. The draft study only includes the cap and trade value of avoided GHG emissions, but that is only a small part of the total value to SMUD of reducing GHG emissions. When customers reduce their consumption of grid-supplied electricity, they reduce the utility’s need to make other investments to reach GHG emission targets that oversight bodies, such as the Board, set for them apart from the statewide cap and trade limits. The state has devoted significant resources to modeling the costs to achieve this goal, and modeling work performed by E3 has found these compliance costs will rise sharply in the future. The CPUC adopted E3’s proposal to include the avoidance of these direct compliance costs as a value in the tool E3 developed for the CPUC to quantify the value of distributed energy resources. E3’s analysis for SMUD should similarly incorporate this value as a direct ratepayer benefit. 

6) Other critiques

In total, E3 calculated or attempted to calculate 24 values of solar. Based on similar calculations E3 has performed for the CPUC and our own analysis, some of the actual values are higher than those reported by E3 in the draft study. This appears to be the case for E3’s calculations on the long-term hedging value, as solar allows SMUD to procure less energy well into the future. and the resiliency value enabled by rooftop solar + storage. 

Below are our detailed comments on the draft study.
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Comments of the California Solar & Storage Association and the Solar Energy Industries Association on the draft Value of Solar + Storage Study

Introduction

The California Solar & Storage Association (CALSSA) and the Solar Energy Industries Association (SEIA) appreciate the opportunity to submit these comments on the draft Value of Solar and Storage Study prepared for SMUD by E3, in collaboration with GridSME. While the draft study is a good start to evaluating the numerous benefits that customer-sited solar and storage provide, some aspects of the analysis that should be revised because they undervalue those benefits. We offer several detailed suggestions that would improve the draft report’s conclusions and align the underlying methodology more closely with other studies recently completed by E3. We also recommend several modifications in the presentation of the results that would make the full range of solar and storage values, particularly E3’s findings regarding the value of “smart” solar + storage, more salient and easily comprehensible for readers. 

The Study Should Be Based on an Export-Only Analysis of Costs

The draft study examines the costs and benefits of every kilowatt-hour (kWh) of energy produced by customer-sited solar (or solar and storage) systems, an approach commonly referred to as the “All Generation'' approach. Under this approach, every kWh produced by customer-sited energy systems, whether exported to the grid or consumed on-site, is treated as a cost to the utility. This manner of accounting for costs and benefits does not treat customer-sited solar equitably compared to other measures that reduce customers’ consumption of grid-delivered electricity. 

SMUD actively promotes several energy efficiency programs including rebates of up to $3,000 per residence and the provision of low-interest loans to finance energy efficiency upgrades. Studies have found that energy savings of up to 50 percent are achievable in the residential sector. SMUD would also experience significant revenue losses from customers achieving deep efficiency savings of this magnitude, yet these savings are never characterized as “payments” from other customers. 

In 2013, E3 completed a study on the ratepayer impacts of net energy metering (NEM) for the California Public Utilities Commission (CPUC) that looked at the cost and benefits of customer sited solar through two lenses: the “All Generation” approach and an “Export Only” approach that only quantified the cost impact to the utility from the NEM credits produced by electricity exported to the grid. The latter approach permits policy-makers to consider the costs to other ratepayers from NEM per se, that is the compensation structure for exports. Even in the absence of NEM (with no credit for exports at all), customers could install solar to offset only their on-site usage, which would yield bill savings much like any other energy efficiency investment. To the extent solar systems offset on-site usage, they operate in an “efficiency mode” similar to other energy saving measures. 

We realize that the draft study is a cost benefit analysis of solar and storage systems and not NEM per se, but the results will inform the deliberations of SMUD’s staff and Board concerning what, if any, changes to make to the NEM compensation structure. Although we believe that the “Export Only” approach is the appropriate lens for evaluating the costs of customer-sited solar and storage, at minimum policy-makers should have the analysis presented both ways so they may to choose whether to include the financial implications of all generation or to treat on-site consumption comparably to other efficiency measures and focus on the financial implications of the bill credits for exports to the grid.

Because Solar Is a Long-Term Asset, Results Should Be Shown in Levelized Terms

Solar panels are a long-lived asset, and panels built to today’s standards can easily last 25 years or more with relatively little performance degradation. While not as long-lived as solar, energy storage system manufacturers typically offer a ten-year warranty, and the technology is quickly improving. Solar and storage devices installed today provide benefits far into the future, but the draft study relies on a “snapshot” approach that rests solely on the costs and benefits that accrue in a given year. The snapshot approach undercounts the value of these technologies, particularly when the value of one or more of the benefits is anticipated to rise in the future. In contrast to snapshot approaches, levelization is a standard technique for presenting the average discounted costs and benefits of an investment across time. E3 should modify the draft study to present long-term levelized values, which will capture the benefit of substantially higher avoided GHG compliance costs in the future as we discuss in more detail below. 

Avoided GHG Compliance Costs Are a Ratepayer Benefit 

There are two types of concrete, financial benefits that accrue to ratepayers related to avoided greenhouse gas (GHG) emissions: the cost for gas-fired generators to comply with the state’s cap and trade program and the cost a utility must bear to meet utility-specific GHG emissions targets. (We discuss the societal benefits of avoided GHGs in a subsequent section.) For the draft SMUD study, E3 includes the cap and trade cost among the ratepayer benefits, which is appropriate since cap and trade compliance costs are undeniably passed on to utility customers by gas-fired generators. However, the draft study diverges from the work E3 has recently completed for the CPUC in its treatment of avoided utility compliance costs. 

When customers reduce their consumption of grid-supplied electricity, they reduce the utility’s need to make other investments to reach GHG emission targets that oversight bodies set for them apart from the statewide cap and trade limits. California has ambitious goals to reduce its GHG emissions, including Senate Bill (SB) 100’s goal of 100% clean energy by 2045. The state has devoted significant resources to modeling the costs to achieve this goal. Earlier this year, the CPUC adopted a new Reference System Plan (RSP) in its Integrated Resource Planning (IRP) process that is based on modeling the optimum resource portfolio to reach the state’s GHG goals, including an interim 2030 goal of 46 million tons (MT) of GHG emissions and the 2045 SB 100 goal. This modeling used E3’s RESOLVE model plus associated production cost modeling, and calculated the marginal costs to reduce GHG emissions from 2020 through 2045. This analysis included all of the utilities in California – including SMUD – although the adopted RSP covers only the CPUC-jurisdictional entities. 

The CPUC uses the Avoided Cost Calculator (ACC), produced by E3, to evaluate the benefits of customer-sited energy resources. For the ACC, E3 recommended, and the CPUC approved, including the avoided compliance cost calculated in the IRP process as a direct (i.e., non-societal) benefit of customer-sited resources. Since SMUD has its own ambitious GHG targets, SMUD ratepayers will likewise benefit from the avoided compliance costs provided by customer-sited solar + storage. While the draft report discusses this value on pages 33 and 34, E3 did not include it in the results shown in the ratepayer perspective charts and tables. Consistent with the analysis that E3 performed for the CPUC, E3 should include the avoided compliance cost as a ratepayer benefit in its analysis for SMUD.

Marginal Cost of GHG Compliance Value Is Very Low

In addition to our critique that the draft report excludes the avoided GHG compliance cost from the ratepayer benefits, we question why the compliance value E3 estimates, as shown in the chart on page 34, is far below the value E3 incorporated into the ACC. 

After reviewing this work, in Decision 20-04-010 the CPUC adopted a “smoothed” trajectory for marginal GHG emissions to be applied in its ACC. This trajectory is intended to prevent the undervaluing of long-lived DER assets over the next decade (2020-2030), given the steep rise in marginal GHG costs thereafter. If the DER industry contracts due to low valuation over the next decade, it may be difficult to rebuild the industry if it is needed to respond to sharply rising GHG values after 2030.

The key point is that this recent modeling of marginal GHG compliance values for California produces far higher values than the minimum “floor” prices in the short-term GHG cap and trade market used in the draft study. Most of the costs to achieve the state’s GHG goals will come from programs outside of the cap and trade market, which is what is captured for the electric sector in the marginal GHG values in the RSP modeling. Even the state’s forecast of cap and trade prices is well above the cap and trade floor prices. The draft study, at page 33, includes the marginal GHG results from RESOLVE modeling in the last SMUD IRP, but this IRP appears to predate SB 100. Finally, if SMUD expects to accelerate achievement of the state’s climate goals to a date earlier than 2045, perhaps as early as 2030 as envisioned in the Board’s recent “climate emergency” declaration, it seems highly unlikely that SMUD can achieve that goal at a cost far below what most of the rest of the state has modeled for achieving the SB 100 goal by 2045.

We have applied the much higher marginal GHG compliance values from the statewide modeling in the CPUC’s ACC to representative solar and solar + storage profiles in Sacramento. We find that, when the latest statewide modeling is used, the GHG compliance value of local solar resources is much higher than estimated in the draft SMUD study. For example, the draft study finds a GHG compliance value for solar of approximately 0.7 cents/kWh in 2020, compared to 2 cents/kWh in the ACC. The gap in values becomes much larger in 2030 at 0.9 cents/kWh vs 5.3 cents per kWh. 

These differences are due both to the much higher future compliance costs projected in the ACC and the levelization of those costs. E3 should explain why its analysis apparently indicates that SMUD can achieve its ambitious GHG reduction goals at a cost far below what is indicated in the CPUC’s IRP modeling and 2020 ACC. Finally, it is important to note that the CPUC IRP modeling assumes that distributed resources are replaced entirely with utility-scale renewable and storage resources, not with gas-fired resources. 

The SMUD Study May Understate Avoided Energy Costs

SMUD today is part of the Balancing Area of Northern California (BANC), not the California Independent System Operator (CAISO). However, because BANC is a small balancing area located entirely within the much larger CAISO footprint, we would expect that SMUD’s avoided costs for energy would track CAISO market prices in northern California. Even if SMUD’s marginal gas-fired resources have lower costs than other gas plants in the area, the utility’s opportunity costs will be to sell into, or to buy from, the CAISO market as economics dictate. In this regard, SMUD’s modeling of its avoided energy costs appears to be substantially lower than the more recent modeling of CAISO market prices that is included in the 2020 ACC. The costs in the ACC zone around Sacramento (PG&E Climate Zone 12) exceed the draft study values by 2.5 cents/kWh to 4.5 cents/kWh depending on the hour of day.

In addition, SEIA and CALSSA observe that even the avoided energy cost forecast in the ACC may be too low, as it assumes that the natural gas transportation rates for gas-fired power plants in California will escalate only with general inflation. The growth in natural gas transportation rates in California – including the PG&E backbone rates that impact the benchmark for SMUD and the northern California gas market in general – have been far above inflation since the San Bruno pipeline explosion in 2010. CPUC Resolution E-5077 which approved the 2020 ACC, indicated at page 24 that “this issue deserves more scrutiny.” In that vein, the CPUC recently initiated a rulemaking (R. 20-02-007) on long-term planning for the natural gas system. This rulemaking recognizes that the state’s GHG reduction goals will reduce future gas use and will raise issues about whether reasonable gas transportation rates can be maintained as throughput declines. Finally, E3 itself authored or supported several 2019 studies which concluded that future gas transportation rates will continue to escalate at well above inflation in the coming era of declining throughput as California reduces natural gas use to meet GHG reduction goals.

The Board’s Climate Emergency Declaration Necessitates a Supplemental Analysis of the Transmission and Distribution Value of Customer-Sited Resources

We recognize that E3’s analysis was well underway at the time the Board passed the climate emergency declaration on July 16, 2020 and that there is insufficient time to conduct a rigorous analysis of its implications before E3 is scheduled to present the study to the Board next month. However, the study should acknowledge the impact of the declaration and give the Board a range of the likely effect it will have on the value of customer-sited resources. 

In the draft study, E3 concludes, based on SMUD’s most recent transmission and distribution investment plans, that customer-sited energy resources will yield miniscule savings through avoided transmission and distribution expenditures. These findings may change as SMUD staff begins to analyze the actions required to meet the 2030 goals in the declaration. For example, we suspect that if SMUD were to rely exclusively on investments in utility-scale renewables and storage to decarbonize its energy supply, additional transmission capacity will be needed to deliver that electricity to SMUD’s distribution substations. Similarly, we suspect that more aggressive electrification of transportation and buildings will trigger the need to upgrade SMUD’s distribution infrastructure, expenditures that could be mitigated through strategic deployment and use of customer-sited energy resources. As SMUD staff begins to complete its analysis of the actions needed to achieve the goals described in the declaration, E3 should conduct a supplemental analysis of avoidable transmission and distribution so that staff and the Board have a more complete and up to date analysis at its disposal as they contemplate revisions to NEM. 

The Study Should Include a Value of Avoided Fugitive Methane Emissions in the Societal Benefits 

Methane is a powerful greenhouse gas that, ton for ton, exacerbates climate change far more than carbon dioxide (CO2). The Intergovernmental Panel on Climate Change’s (IPCC’s) most recent findings estimate methane has a global warming potential (GWP) of 34, meaning that a ton of methane released into the atmosphere warms the planet as much as 34 tons of CO2. Because methane contributes much more to climate change on a per-unit basis than CO2, the societal benefit of methane mitigation measures is substantial
 
When customers generate their own electricity (or use less of it), they reduce the need for generation from gas-fired power plants. Because methane leaks throughout the production, transmission, and distribution processes of delivering natural gas to power plants, reducing reliance on gas-fired power avoids some of the fugitive methane that would otherwise escape into the atmosphere during production and delivery of gas to those plants. 
The draft study contains no discussion of this benefit provided by clean, customer-sited energy resources. In work it recently performed for the CPUC, E3 included the value of reduced fugitive methane in the updated ACC. The CPUC adopted a “leakage adder” of 6.4 percent following E3’s recommendation, meaning every ton of CO2 emitted from gas-fired sources that is mitigated by on-site generation or energy efficiency measures is credited with an additional 6.4 percent of avoided GHG reductions due to the associated reduction in fugitive methane. 

We strongly urge E3 to include a fugitive methane leakage adder in the analysis it is conducting for SMUD, just as it did for the CPUC. We believe, though, that the leakage adder should be higher than the value E3 derived for the ACC for two reasons. First, in trying to align the ACC calculations with the GHG inventory maintained by CARB, E3 excluded fugitive methane that occurs out of state. Since California imports approximately 90 percent of the natural gas it consumes, the decision to limit the analysis to in-state sources of fugitive methane substantially reduces the benefit from 2.3 percent leakage for every unit of natural gas consumed to only 0.7 percent. We believe that SMUD also obtains all or almost all of its natural gas supplies from out of state producing basins. Because SMUD’s electric system is interconnected with the entire Western grid, the sources of gas-fired power reduced by energy efficiency and renewable energy in SMUD’s territory may occur anywhere in the Western US and Canada. E3 does not ignore the societal benefit of CO2 reductions that occur out of state in its calculations; likewise, E3 should not limit the calculation of the societal benefit of avoided methane exclusively to California sources. E3 should use the full 2.3 percent value for the SMUD study.

Second, SMUD used older GWP figures from the IPCC’s Fourth Assessment Report, which assigns methane a GWP of 25. While this is consistent with the values used by CARB in the state’s GHG inventory, E3 should use the 34 GWP value based on the more recent science endorsed in the Fifth Assessment Report. In combination, these two changes roughly quadruple the leakage adder, from 6.4 percent to 28.6 percent. 

The Draft Study Uses a Low Value for the Hedging Benefits of Renewable Energy

Solar displaces natural gas use, and thus hedges against the volatility in natural gas prices. The draft assumes that the avoided cost of hedging is 5% of avoided energy costs, based on a paper that looked at the risk premium in short-term forward contracts for power in the Pacific Northwest. However, solar provides a hedge for its full 20- to 30-year life, and avoids the very expensive cost of fixing the price of natural gas for this long-term period, not just for a few years. Other analyses have quantified the long-term hedge value of solar, based on the significant financial cost of committing the money required to fix the cost of natural gas for a 20- to 30-year period equal to the life of this resource. These values are much higher, in the range of 2 cents/kWh to 3 cents/kWh, considerably more than 5% of avoided energy costs. 

Executive Summary Should Include Figures 20 and 21

The draft study marks a significant contribution to quantifying the benefits of customer-sited energy storage, especially “smart” solar + storage where the storage system is dispatched in a highly granular fashion to meet grid needs (which E3 refers to as the “Utility Partnership” scenario). However, the Executive Summary only includes the chart of “Solar Only” results. The findings regarding the value of storage deserve more emphasis since the results in the Executive Summary are usually the only results garner much attention. Simply including Figures 20 and 21 in the Executive Summary will facilitate more casual readers’ understanding of the sizable grid benefits that storage can provide. 

Values Shown in Table 1 Are Incorrect

The values listed in Table 1 (and Table 15) do not correspond to the values shown in Figures 19, 20, 22, and 23. Whereas the table purports to include results from the “Customer Dispatch” storage configuration, the range of values shown under 2020 (3.2 to 7.0 cents/kWh) only reflects the values shown in Figure 19, the figure that depicts the “Solar Only” results. If the “Customer Dispatch” findings were included, the range should be 3.1 to 9.1 cents/kWh (from Figure 20). For 2030, neither the value nor the revenue reduction numbers match the values depicted in Figures 22 and 23. 

Table 1 Should Include the Utility Partnership Values

Aside from failing to accurately capture the Customer Dispatch results in Table 1, the table ignores, without explanation, the much larger value that storage provides in the Utility Partnership scenario. Dispatching storage in a more precise, granular manner to offset demand for electricity at times of highest value substantially increases E3’s estimated value of solar and storage. Compared to the “Solar Only” scenario, smart dispatch increases the average value of kWh produced by customer-sited solar from 7 cents/kWh to 12.5 cents/kWh. The incremental value of Utility Partnership remains large even compared to solar + storage in the “Customer Dispatch” scenario (9.1 cents/kWh vs 12.5 cents/kWh), in which the storage systems discharge only in response to static time-of-use price signals. According to E3’s calculations, Utility Partnership solar and storage systems produce a net benefit for SMUD’s non-solar customers, before adding any societal benefits. Yet, the results are not presented until page 46 of the report. These encouraging results should not be buried two-thirds of the way into the report, especially in light of SMUD’s efforts to realize these benefits through its Smart Energy Optimizer incentive program. 

E3 Should Add Societal Benefits to the Summary Results

Societal benefits more than double the value of generation from customer-sited solar in some of the scenarios E3 evaluates. E3 includes its societal value estimates in the Executive Summary, but because the draft report only lists them in the text on page 3, a reader cannot readily understand how the inclusion of those benefits affects the results shown in Figure 1 and Table 1. E3 should either include societal benefits in Figure 1 and Table 1 or produce alternate versions showing their impact on the results. Readers should not have to manually perform those calculations to grasp their implications. Even using the middle of the range of values shown for GHG reductions (excluding the outlier value of 16.3 cents/kWh, the average is 4.5 cents/kWh), the total societal benefit of 5.8 cents/kWh profoundly affects the results.


August 22 - David W
To: E3 and the SMUD Board of Directors
From: David W.
Re: Comments on E3 Report on SMUD Value of Solar+Storage

While there are other flaws of the report that will likely receive comment, in my view the largest single problem with the report is its failure to fully incorporate the societal benefits of rooftop solar. Properly accounting for this flaw would mean that SMUD should be paying net-energy metering (NEM) customers more for the solar power they export, not less (see item 3 below).

Another grave issue regarding the report is that it was commissioned and framed before the Board’s recent Climate Emergency Resolution. As a result the goals and projections underlying the report are outdated and inadequate to the climate emergency 2030 goals. I submit to the Board that this problem is so serious that this report should be shelved in its draft form and a revised report created once SMUD has outlined its conceptual path to the 2030 goals.

Overall the report does not live up to the SMUD Board’s innovative vision or SMUD’s customers’ urgent needs for rapid transition to a clean energy future. 

Below I offer some more detailed comments.

1. Regarding report organization: SMUD has acknowledged that it views the incremental scenario as the appropriate scenario (Jennifer Davidson, Aug 3, 2020 VoSS TWG meeting), and in my opinion the “helps meet goals” scenario is not realistic. The “helps meet goals” scenario is therefore clutter, complication, and not useful. It also lowballs the value of rooftop solar and therefore biases perception of the value of rooftop solar. I request it be deleted throughout the document.

2. I understand that E3 has provided an Avoided Cost Calculator model to the California Public Utilities Commission (CPUC) that yields a much higher value of solar than E3 presents in their study for SMUD - nearly double, even without the added societal benefits that have been discounted in both products. This inconsistency between the low value developed for SMUD and the more typical value for the CPUC must be explored and reconciled.

3. It is unconscionable in the time of historic heat waves and droughts, melting Arctic, dying jet stream, and rising seas set to displace 400 million people that E3 and SMUD have omitted from serious consideration the social cost of carbon emissions (SCC) from the value of solar arrived at in this report. Even the middling SCC figure E3 estimates, of about 7 cents per kWh, would double the report’s estimated 2020 value of NEM solar, placing it above SMUD’s current NEM reimbursement rate. The societal costs are real, and are what the climate emergency is about. It is past time to take action and to work on building acknowledgement of SCC into SMUD’s planning, deliberations, and operations. A real value of rooftop solar, incorporating social costs of fossil fuel burning, is a necessary step in that direction. I previously expressed this view strongly in the Value of Solar+Storage Technical Working Group meetings - but SMUD staff indicated they had no intent to give this direction to the VoSS consultant. The Board must give direction to our unwilling staff. I also object to SMUD’s characterization in its “Getting Solar Right” webpage that environmentalists were consulted and included in the report development process when my and others’ input was baldly disregarded.

4. It is difficult if not impossible to determine what values E3 is using in their discussion of the social cost of carbon (SCC). Table 13 on p. 32 cites SCC values from $15 to $875 per metric ton (or tonne [t]). Nowhere is it stated what value of SCC E3 has plucked from the huge range in this table, and no explanation is given for what value or values were used or why. This must be clarified. A clearer way to present this would be to select and justify an SCC value - or a narrower range than given in Table 13, calculate gross societal cost, and then subtract the cost of California carbon emissions compliance from the gross SCC to arrive at full societal benefits of rooftop solar.

5. According to analysis by the Solar Energy Industries Association which I believe will be addressed in comments by the California Solar and Storage Association, E3 used marginal cost data for greenhouse gas emissions that are outdated (pre-SB 100) and lowball the cost. By 2030, the assumed cost is too low by a factor of 2 to a factor of 6 or more. This serious error must be addressed.

6. E3 should include the benefits of reducing emissions from methane leaks in the benefits of solar and solar plus storage. Methane is a potent greenhouse gas, most recently estimated by the United Nations Intergovernmental Panel on Climate Change as 34 times more powerful than CO2. Reduced fossil fuel use brings reductions in methane emitted in the natural gas extraction, storage, and transport processes attributable to SMUD’s consumption of natural gas. The analysis should include effects due to natural gas brought in from outside California.

7. E3 and SMUD should double-check and clarify their values used in the analysis for power generation and carbon emissions. E3's Table 17 implies rates of 2451-3676 kWh generated per tonne of CO2 emitted. However, even SMUD’s most efficient gas-fired plant, Cosumnes, has a rate of only about 2420 kWh/t CO2 according to 2018 data, and for generation over all SMUD plants during 2018, this rate was yet lower: 2284 kWh/t CO2 (psehealthyenergy.org). E3's Footnote 37 implies that E3 applied a rate of 2558 kWh generated per tonne of carbon emitted. Assuming an exaggerated rate of generation versus carbon emitted incorrectly reduces the apparent impacts of carbon emissions.

8. As a “bookend” to the societal cost of greenhouse gas emissions, E3 should calculate the cost of removing (sequestering) a quantity equal to all residual SMUD-attributable greenhouse gases from the atmosphere. It is foreseeable that in the not-too-distant future SMUD may be required to pursue such a measure.

8. Value of Solar plus Utility Partnership-dispatched storage should be highlighted. This alternative consistently delivered a substantial bump in the value of solar-plus-storage estimates in the various scenarios, yet this is barely noted in the executive summary and is underemphasized throughout. SMUD is going to need a lot more storage, and fast, for zero-carbon energy to be feasible. Seeing the value of partnership-dispatched storage capacity provides SMUD incentive to leverage customer willingness to add storage as well as to cooperate with SMUD in the timely dispatch of stored solar energy.


August 22 - James H. 

Residential Rooftop Solar
SMUDs idea to provide large commercial solar farms seems like a grand idea but, most of those farms will end up far from the customers they serve, or will be planted on top of what could be farmland or residential housing land. The farther away from the customers being served the more transmission lines will be needed. With solar panels spread out over a large area when cloud cover enters the area many panels will not be affected unlike very large arrays which would cease producing all at once.

It seems the residential customers are subsidizing commercial businesses. When I look at the Off-Peak, Peak and Summer Super Peak rates and times, I find it difficult to understand why rates during the week are so much higher than the weekends. Could it be residential customers are funding the discounted rates for factories and large business building complexes?

How about making the solar generation on residential roofs simple by looking at just the number of watts generated minus the number consumed. Take the complicated dollars and cents out of the equation. Something SMUD has failed to consider is most residential customers either have a lease they are paying to the solar panel providers or they invested thousands of dollars to outright buy their panels. If SMUD hadn’t fought installation of solar in the beginning and instead embraced it by providing a vehicle as the solar businesses did, none of this would have been an issue. SMUD would be the lease-holder and the residents would pay SMUD for the use of the solar panels. 

It seems SMUD has spent Thousands of Dollars to build a study why residents shouldn’t have solar instead of embracing it. You SMUD are still fighting the wishes of residents to have a say in the way OUR utility is being run. You have taken on the air of a BIG business that is going to have their way no matter what. Your report is very lacking and as everyone knows you can manipulate any report or spreadsheet to reflect the outcome you desire.

The SMUD Board is out of control and lost sight of who you serve.

Please reconsider your treatment of the SMUD customers and owners.

Sincerely,
James H.


August 21 - Anonymous
There is obvious discrepancies in the solar Report, attacking solar customers, and suggesting solar offers no climate change benefits. The report needs to be rewritten for the following reasons: 
Problem #1: SMUD's solar study asserts that SMUD "pays" solar users even when they are simply making and consuming their own solar energy at home.
SMUD's study incorrectly purports that SMUD “pays” solar users a total of $25-$41 million a year even when they are simply making and consuming their own solar energy on-site.
This is clearly absurd. SMUD doesn't "pay" anyone when customers reduce their energy use. If this were true, it would also mean that SMUD is paying people if, for example, they:
Shut off lights or install energy efficient appliances.
Use an air conditioner with a built-in solar array and battery such that the unit is never plugged into the wall socket.
Here's what actually happens. SMUD credits customers for the extra energy they send back to the grid, not for the energy customers use on-site. The credit for this extra energy is the only “payment” at issue here.
Reducing electricity use from the grid is desirable behavior. It reduces the burden on the grid and makes it easier for SMUD to reach its goal of a 100% clean energy mix by 2030. No class of customers should ever be penalized or considered problematic for doing so -- whether because of solar, energy efficiency or reduced business operations due to COVID.[1]
Remedy: Re-focus the study only on the solar energy that is sent back to the grid. Remove from the study the solar energy that people consume at home or at their business.
Problem #2: SMUD's solar study implies that rooftop solar's climate change benefits should not be valued
SMUD's solar study and their accompanying website give the overwhelming impression that the value of solar is only $.03-$.07/kWh. This is misleading because it only captures a limited number of rooftop solar's benefits (namely the ways that rooftop solar allows the utility to avoid generating or purchasing electricity).
There is another critical benefit, however: the impact rooftop solar has on reducing global warming pollution.[2] The report quantifies this benefit as well. But it buries it in fine print and excludes it from all the topline charts and graphs.
That is unfortunate and misleading. The fine print states that rooftop solar's impact on reducing global warming pollution (along with several other social benefits) increases solar's value by between $.02 and $.16/kWh.
Combining the value of solar headlined in the report with the value of solar from reducing global warming pollution is likely to yield a solar value of at least $.12/kWh -- considerably higher than the report's headline.
Putting critiques one and two together strongly suggests that rooftop solar actually provides a net benefit to SMUD, in contrast to the study's topline conclusions.
Remedy: Redo the study to include all of rooftop solar's social benefits, especially climate change benefits, in the topline calculations of solar's value.
Problem #3: SMUD's solar study is not based on SMUD's new climate change goal
In addition to burying rooftop solar's global warming benefits in the fine print, SMUD's study also is premised on SMUD's old, outdated climate change goal that assumed SMUD would still operate its five fossil fuel power plants past 2040.
Things have changed: the SMUD Board of Directors recently adopted a stronger goal to reduce SMUD's global warming pollution to zero by 2030.
In fairness, the study was launched before the SMUD Board adopted its new goal. But the study has to be revised to reflect the new goal. To reach zero carbon emissions by 2030, SMUD must increase both large-scale renewable investments and local rooftop solar and storage beyond what SMUD currently plans for in its clean energy plan created in 2018 (called the Integrated Resource Plan), and on a faster timeline. SMUD will also likely increase its efforts to encourage customers to switch to electric cars and appliances.
SMUD will need to increasingly partner with customers who want to install their own solar system to help the community meet these new goals, and that should get reflected in solar's value.
Remedy: Redo the study’s calculations to reflect SMUD's new climate change goal of zero carbon pollution by 2030.
Detailed Background
More and more compelling evidence shows that rooftop solar and battery storage provide significant benefits not only to the individuals with solar, but also to the larger community. Rooftop solar reduces the cost of maintaining and expanding the grid and also reduces pollution, especially climate change pollution. These benefits increase with solar-powered batteries that store the extra solar energy to use when the sun isn't shining.
SMUD and the state of California need more rooftop solar and battery storage to fight global warming, help people keep the lights on during power outages, and give consumers more ways to manage their energy choices.
This is especially the case with SMUD now that they have committed to reducing their global warming pollution to zero by 2030, which means they will need to cease burning natural gas at their five power plants.
In contrast, SMUD has claimed for some time that rooftop solar has more costs than benefits, and that customers who have rooftop solar are not paying their fair share of the electrical grid, are overly subsidized, and are responsible for causing rates to increase for non-solar users. Last spring, We are using the energy created, and adding to the grid, while reducing the carbon imprint. SMUD's report concludes that solar's costs are greater than their benefits and suggests that solar should be discouraged going forward. However, the report contains several obvious flaws that suggest that the opposite is true -- that solar's benefits outweigh their cost and should be encouraged. "


August 21 - Rick C. 
Thank you for the opportunity to review and comment on this important Study on the Value of Rooftop Solar.  I believe the Study, by the reputable consulting group E3, can provide significant guidance to SMUD in its transitional approach to solar production from its customer owners. Particularly useful is its findings that SMUD managed battery storage - in collaboration with its customer solar owners – would be the most cost/beneficial option. 
 Here are the areas where I think the Study does a good job:
• The separate analysis of three scenarios:  solar only, solar + battery storage and solar + utility managed battery storage,
• The inclusion of all cost/benefit attributes identified by the Technical Working Group,
• Analysis from several perspectives: ratepayers, solar participant and societal.
The Study should provide valuable information for subsequent NEM-2 rate making. But,  I believe it suffers in several areas to provide the needed clarity and background data that would inform future rate design. Here are my general recommendations in that regard:
Drop the RPS Replacement Scenario from the Study.  
The Study includes two scenarios: Incremental to SMUD’s Renewable Goals and Helps Meet SMUD’s Renewable Goals. In my view, the latter is irrelevant.  Rooftop solar does not contribute directly to Renewable Portfolio Standard (RPS) requirements for state utilities.  It is considered a load reduction, like energy conservation, by SMUD and CAISO grid operators; and is filed with the Energy Commission as an adjustment to SMUD’s Managed Load Study.  Even in the SolarShares and Greenergy programs, the customer participants retain the renewable energy credits for the power generation.  
Clarify whether SMUD generating plant costs are in fact the first marginal unit to be displaced by rooftop solar when applicable.
The Study discusses many of its assumptions without distinguishing how they might apply differently to each Scenario.  For example, the Study defines energy costing as the marginal price from production simulation modelling which optimizes resource dispatch .  Presumably, this approach is used for both the Incremental and Helps Meet RPS Scenario. I would argue that the Incremental Scenario’s energy pricing should be approached differently.
Figure 4 in the Study, illustrated below, shows that daytime prices on average never rise above 2.5 cents/kWh in 2020 and fall much lower by 2030.  This appears to assume that solar is primarily on the market margin and will become more plentiful and less valuable in the coming years. This may be the case where rooftop solar is displacing RPS in the irrelevant Helps Meet SMUD Goals scenario. 
Study Projection of Marginal Energy Pricing 2020 - 2040

VOS comment graphic
But it is not the case with rooftop solar which actually decrements SMUD load.  In this instance, the reverse loading order should apply, and the marginal unit being displaced will be SMUD’s thermal generating plants when applicable.  Currently these gas plants make up more than half the total electricity SMUD produces, while solar power remains below 5% (see Endnote 2).  So, in the near term, there is plenty of capacity for rooftop solar to displace SMUD’s natural gas generation and to shift more hydropower to peak periods.  
This is even more relevant under SMUD’s Climate Emergency Declaration, where these power plants must ramp down to lower the greenhouse gas emissions to a carbon-neutral by 2030 and a carbon zero status by 2045. This can only be done by lowering grid energy use and by adding carbon-free power – both of which rooftop solar provides.
Provide more detail on how specific SMUD generating data is used to determine the hourly energy costs.
 Figure 4’s illustration of hourly marginal energy raises the question of whether or how specific SMUD generation data was used in the analysis.  For example, the Study employs the following gas pricing forecasts from Northern California trading hubs which range between $1.79 - $2.73 per MMBtu in 2020.  
Yet SMUD’s 2020 fuel pricing for Cosumnes and the cogeneration units is $3.09 per MMBtu while its biogas gas is more than $11/MMBtu).  Did the Study even consider SMUD’s long term gas contracts, including pipeline transmission and hedging costs?

VOS comment graphic

VOS comment graphic

Moreover, the fuel costs for SMUD gas-powered power plants averages 3.78 cents/kWh(shown below), in contrast to the 2.5 cent/kWh costs illustrated in the Study graph.

VOS comment graphic

Clarify whether the reduction of RPS requirements by rooftop solar are given value in the Study.
Because rooftop solar reduces SMUD’s energy baseline, it lowers the required RPS targets which are a function of the utility’s retail loads.  For example, SMUD must provide renewable energy equal to 60% of SMUD’s customer usage in 2030 and 100% by 2045. It is unclear that the Study accounts for that savings in avoided RPS power costs because of rooftop’s solar’s contribution to lowered energy use.
Provide a representational table differentiating expected revenue loss by customer type and by consumed and export power.
It sounds like E3 did a great job utilizing a dataset of load-shapes from a range of residential and commercial SMUD customers.  For future rate making it would be very useful to present the results of this data analysis in a constructive, differentiated format, particularly for calculated revenue loss. Similarly, for future ratemaking and policy discussion, it will be important to distinguish how much of the rooftop solar production is consumed by the customer and how much exported to the grid.

Endnote 1.  Description of hourly energy pricing in Study

VOS comment graphic

Endnote 2.  2018 CEC Power Content Filing Summary

VOS comment graphic


August 21 - Deborah H. 
It is very sad to see the way California is not thinking of future energy and just raising taxes in every direction. Solar just MAKES SENSE !! in this state. I hope SMUD encourages growth with solar energy by NOT putting a penalty on those of us who have it. Encourage it -


August 21 - Tim R. 
I am currently a "non-solar" customer with SMUD. I support the production and use of clean energy. But I agree the current NEM rate system is flawed. There are 3 components to a business transaction. Supply, Demand, and the Logistics that put the other 2 together. Before solar technology, energy companies were responsible for both supply & logistics. Solar technology has increased the sources of supply to homeowners & businesses throughout the community. Legislation (& SMUD) have promoted the production of clean energy through the NEM rating system for the last 24 years; until the expense of that promotion reached the threshold of essentially becoming a hidden consumer tax on economic activity at the point of sale. Electricity is a vital component for an economy's "commerce infrastructure". The objective of that infrastructure is to INCREASE economic activity. But taxing economic activity at the point of sale REDUCES economic activity. Because over 70% of economic activity is CONSUMER SPENDING. At this point in time, the NEM rating system is stressing economic activity for the entire community.
I appreciate homeowners and businesses with the ability & desire to invest in the production of clean energy. And I would stand with them if an energy company ever tried to eliminate them from the energy production market completely. But the cost (& liability) of transporting and delivering that energy is significant. That cost is the difference between wholesale & retail pricing. A NEM rating system that guarantees a wholesale price for the production of clean energy... is not only fair; is is vital for environment AND economy.
Thanks for your consideration.


August 20 - Donald O. 

First off - this website is reprehensible, it purports to present so-called cost shifts given in a DRAFT report as if these were reviewed and correct. It pits customer against customer and greatly damages our trust in SMUD, its staff and the Board!
Next the DRAFT report is fundamentally flawed. It takes the solar that the customer generates and uses directly, never even touching the grid, as somehow getting a "payment" from SMUD and therefore causing an "unfair cost shift" to other customers. This is just another form of energy efficiency. You do not make these wild claims against customers who live in energy efficient homes, buy LEDs, or teach their kids to close the window when the AC is on!
Also, the evaluation of exported generation, which is ALL SMUD should concern itself with, neglects or buries many key values of solar. 
When a report like this is so at odds with so many other such studies, including E3's own work for the State, one must conclude that the fix was in. The fact that SMUD staff jumped in so quickly to push out the "results" of such a flawed study, even before stakeholder review, shows this to be a disingenuous process.
Pull the study and get it right. For all of our futures! 


August 20 - WILLIAM S. 
SMUD should not be dragging its feet on wider adoption of rooftop solar. We have climate change. We need to discourage fossil fuel use and encourage renewable energy sources such as solar and wind. New housing should be required to have rooftop solar. The cost can be amortized over the life of the loan. It will go a long way in helping to save our planet for future generations. 


August 20 - Patricia K. 
As a SMUD customer who put in rooftop Solar panels as an attempt to decrease our electricity bills I am concerned that you may decrease the rate you credit (NOT PAY) us for the small amount of electricity we use on some days. Our large home uses quite a bit of electricity and while we know that it would be 20 year or longer before our system pays for itself, we have at least decreased our SMUD bills and feel that we can actually run our air conditioning on hot days, rather than trying to conserve so that we aren't paying $300 a month during the summer. 
We still pay for electricity each month and we still pay for the fixed costs every month. We took money from savings to pay for our solar, so we aren't still paying for it, but we took some of our security for the future to bring down costs. Please don't make it even less worthwhile for us to have our solar. 


August 20 - Rick C. 
Comments on SMUD’s Value of Solar Study
Thank you for the opportunity to review and comment on this important Study on the Value of Rooftop Solar. I believe the Study, by the reputable consulting group E3, can provide significant guidance to SMUD in its transitional approach to solar production from its customer owners. Particularly useful is its findings that SMUD managed battery storage - in collaboration with its customer solar owners – would be the most cost/beneficial option. 
Here are the areas where I think the Study does a good job:
• The separate analysis of three scenarios: solar only, solar + battery storage and solar + utility managed battery storage,
• The inclusion of all cost/benefit attributes identified by the Technical Working Group,
• Analysis from several perspectives: ratepayers, solar participant and societal.

My main concern is that while the Study should provide valuable information for subsequent NEM-2 rate making, I believe it suffers in several areas to provide the needed clarity and background data that would inform future rate design. Here are my general recommendations in that regard:

Drop the RPS Replacement Scenario from the Study. 

The Study includes two scenarios: Incremental to SMUD’s Renewable Goals and Helps Meet SMUD’s Renewable Goals. In my view, the latter is irrelevant. Rooftop solar does not contribute directly to Renewable Portfolio Standard (RPS) requirements for state utilities. It is considered a load reduction, like energy conservation, by SMUD and CAISO grid operators; and is filed with the Energy Commission as an adjustment to SMUD’s Managed Load Study. Even in the SolarShares and Greenergy programs, the customer participants retain the renewable energy credits for the power generation.

Clarify whether SMUD generating plant costs are in fact the first marginal unit to be displaced by rooftop solar when applicable.

The Study discusses many of its assumptions without distinguishing how they might apply differently to each Scenario. For example, the Study defines energy costing as the marginal price from production simulation modelling which optimizes resource dispatch . Presumably, this approach is used for both the Incremental and Helps Meet RPS Scenario. I would argue that the Incremental Scenario’s energy pricing should be approached differently.
Figure 4 in the Study, illustrated below, shows that daytime prices on average never rise above 2.5 cents/kWh in 2020 and fall much lower by 2030. This appears to assume that solar is primarily on the market margin and will become more plentiful and less valuable in the coming years. This may be the case where rooftop solar is displacing RPS in the irrelevant Helps Meet SMUD Goals scenario. 
Study Projection of Marginal Energy Pricing 2020 - 2040

But it is not the case with rooftop solar which actually decrements SMUD load. In this instance, the reverse loading order should apply, and the marginal unit being displaced will be SMUD’s thermal generating plants when applicable. Currently these gas plants make up more than half the total electricity SMUD produces, while solar power remains below 5% (see Endnote 2). So, in the near term, there is plenty of capacity for rooftop solar to displace SMUD’s natural gas generation and to shift more hydropower to peak periods. 
This is even more relevant under SMUD’s Climate Emergency Declaration, where these power plants must ramp down to lower the greenhouse gas emissions to a carbon-neutral by 2030 and a carbon zero status by 2045. This can only be done by lowering grid energy use and by adding carbon-free power – both of which rooftop solar provides.

Provide more detail on how specific SMUD generating data is used to determine the hourly energy costs.

Figure 4’s illustration of hourly marginal energy raises the question of whether or how specific SMUD generation data was used in the analysis. For example, the Study employs the following gas pricing forecasts from Northern California trading hubs which range between $1.79 - $2.73 per MMBtu in 2020. 
Yet SMUD’s 2020 fuel pricing for Cosumnes and the cogeneration units is $3.09 per MMBtu while its biogas gas is more than $11/MMBtu). Did the Study even consider SMUD’s long term gas contracts, including pipeline transmission and hedging costs? 

Moreover, the fuel costs for SMUD gas-powered power plants averages 3.78 cents/kWh(shown below), in contrast to the 2.5 cent/kWh costs illustrated in the Study graph.

Clarify whether the reduction of RPS requirements by rooftop solar are given value in the Study.

Because rooftop solar reduces SMUD’s energy baseline, it lowers the required RPS targets which are a function of the utility’s retail loads. For example, SMUD must provide renewable energy equal to 60% of SMUD’s customer usage in 2030 and 100% by 2045. It is unclear that the Study accounts for that savings in avoided RPS power costs because of rooftop’s solar’s contribution to lowered energy use.
?
Provide a representational table differentiating expected revenue loss by customer type and by consumed and export power.

It sounds like E3 did a great job utilizing a dataset of load-shapes from a range of residential and commercial SMUD customers. For future rate making it would be very useful to present the results of this data analysis in a constructive, differentiated format, particularly for calculated revenue loss. Similarly, for future ratemaking and policy discussion, it will be important to distinguish how much of the rooftop solar production is consumed by the customer and how much exported to the grid.

Endnote 1. Description of hourly energy pricing in Study


August 19 - Anonymous
I bought solar for my home in 2016. It is the best thing i could have done for my household and the world. We all, including SMUD, need to consciously cut our carbon emissions. I read you have pland to cut to 0 emissions by 2030. If that is the case, you need to make those changes now! Invest in solar fields to supply to those who don't or can't buy the panels for themselves. All new construction (residential & commercial) should be outfitted with solar. Make it beneficial for an individual to invest for themselves. You are making a move in the wrong direction if you penalize the people who are consciously making an effort to keep our world livable!


August 19 - Troy L. 
Your attack on solar owners in Sacramento needs to end. Those of us that have installed install solar on our rooftops have chosen to help SMUD meet their goal of 100% renewable energy by 2030 at our own expense. Please do not choose to penalize us for this investment that helps your grid maintain its reliability and integrity in times of peak use. My choice to reduce my usage during times of afternoon and peak load should be rewarded by SMUD, not penalized. To reach your 2030 goal of zero carbon emissions, you need my solar array on my rooftop. Treat rooftop solar owners as partners, not adversaries. 


August 19 - Anonymous
The whole point of going solar is to conserve energy and our resources and of course, to save money. On one hand everybody says to go solar but then PGE and SMUD wants to increase electric rates and/or charge extra fees or tariffs on folks who have solar panels. So now, one has to pay for solar panels, pay monthly to the installer or maintenance charges and then pay an extra charge to the electric company.! To common folks that is a lot of money to pay every month. I might as well get rid of my solar panels.


August 19 - Candice and Alan
Dear SMUD,
We have been a customer of SMUD for over 40 years. We chose our current home because it had solar on the roof. It is important to us to improve the environment and leave things better for the next generation. Solar is just one way we chose to do this. We also drive an electric car. Overall, we do research and make decisions on facts. During this week of record temperatures, it is alarming to see that California had to implement rolling blackouts. Now that we are on a fixed income, it would be nearly impossible for us to pay more for our electricity use. We have seen fees added to our SMUD monthly bills each year, and they are ever increasing. Consumers who make conscious choices to improve the environment for all, should not be penalized for doing so. Sacramento is our home and we feel compelled to speak out against penalizing homeowners who have solar on their roofs. It is unfair to raise rates only on people who have solar and it is sending a message that SMUD will penalize you if you try to make a positive difference in our community.


August 19 - David D. 
SMUD's study incorrectly purports that SMUD “pays” solar users a total of $25-$41 million a year even when they are simply making and consuming their own solar energy on-site. 

This is clearly absurd. SMUD doesn't "pay" anyone when customers reduce their energy use. If this were true, it would also mean that SMUD is paying people if, for example, they:
Shut off lights or install energy efficient appliances.
Use an air conditioner with a built-in solar array and battery such that the unit is never plugged into the wall socket.

Here's what actually happens. SMUD credits customers for the extra energy they send back to the grid, not for the energy customers use on-site. The credit for this extra energy is the only “payment” at issue here.

Reducing electricity use from the grid is desirable behavior. It reduces the burden on the grid and makes it easier for SMUD to reach its goal of a 100% clean energy mix by 2030. No class of customers should ever be penalized or considered problematic for doing so -- whether because of solar, energy efficiency or reduced business operations due to COVID.
SMUD's solar study and their accompanying website give the overwhelming impression that the value of solar is only $.03-$.07/kWh. This is misleading because it only captures a limited number of rooftop solar's benefits (namely the ways that rooftop solar allows the utility to avoid generating or purchasing electricity). 

There is another critical benefit, however: the impact rooftop solar has on reducing global warming pollution. The report quantifies this benefit as well. But it buries it in fine print and excludes it from all the topline charts and graphs. 

That is unfortunate and misleading. The fine print states that rooftop solar's impact on reducing global warming pollution (along with several other social benefits) increases solar's value by between $.02 and $.16/kWh. 

Combining the value of solar headlined in the report with the value of solar from reducing global warming pollution is likely to yield a solar value of at least $.12/kWh - considerably higher than the report's headline.

Putting critiques one and two together strongly suggests that rooftop solar actually provides a net benefit to SMUD, in contrast to the study's topline conclusions. 

In addition to burying rooftop solar's global warming benefits in the fine print, SMUD's study also is premised on SMUD's old, outdated climate change goal that assumed SMUD would still operate its five fossil fuel power plants past 2040. 

Things have changed: the SMUD Board of Directors recently adopted a stronger goal to reduce SMUD's global warming pollution to zero by 2030. 

In fairness, the study was launched before the SMUD Board adopted its new goal. But the study has to be revised to reflect the new goal. To reach zero carbon emissions by 2030, SMUD must increase both large-scale renewable investments and local rooftop solar and storage beyond what SMUD currently plans for in its clean energy plan created in 2018 (called the Integrated Resource Plan), and on a faster timeline. SMUD will also likely increase its efforts to encourage customers to switch to electric cars and appliances. 

SMUD will need to increasingly partner with customers who want to install their own solar system to help the community meet these new goals, and that should get reflected in solar's value.


August 19 - Gisla D. 
I am outraged about SMUDs study/statistics. SMUD claimes that they are transparent and truthful.... Here are the facts: 1)SMUD does not pay solar producers for energy, they credit their accounts. Does SMUD pay for customers turning off lights or purchasing energy efficient appliances?
2) Solar benefits should not be valued. SMUD only cites the savings. Global warming (see increased fires) and pollution are additional factors. This changes the value of solar from $.03 - $.07 to $.12 Question to customers: convenient not to count environmental impact?
3) What about SMUDS board of directors to reduce carbon emission to zero by 2030? The study and findings does not match the goal. 
Not including roof top solar is short sighted, actually ignorant. We have homeowners who are willing to share energy clean energy) rather than burning gas or coal, with a cost for production, polluting and affecting the health of the families that are living around the power plants, frankly all of us directly or indirectly. SMUD must be honest and do the right thing. It is our life, our health and that of our children and grand chhildren.


August 19 - Jon A. 
To the Board of Directors of SMUD

Nearly four years have passed since I have installed solar panels onto the roof of my house. I am reflecting on that decision now as I read that you as a group are considering the results of a new study that is asserting some very questionable ideas. These ideas, if adopted will most likely entirely change the rules that were agreed upon when I purchased the system.

Idea #1 – SMUD pays solar users $25 to $41 million a year.
If so, I did not receive my check. In fact, last year I lost $85 worth of solar credits because I did not use them fast enough. When I deposit money into a bank, do I need to spend it within 2 years? SMUD in fact profits off of excess energy produced by solar that is credited and not consumed in 2 years. That was $85 of free energy that you not only did not have to pay for; you did not have the cost nor did you lose any of its effectiveness due to transportation. That was simply gone to my neighbors via the grid and you charged them for it. 

Maybe $85 is not a significant amount of money to you but it is to me. By myself, it is not significant but I ask you “How many customers do you have like me?” How much extra money do you make from that little discrepancy? Pennies can turn into Millions if there are enough people involved. 

This discrepancy does not go the other way. This year due to the pandemic and the need to work from home has dramatically increased our energy consumption. So much so that at the end of my year, I owe nearly $500. Now that it is owed, are you going to give me two years to pay it. Also, if I don’t pay it in 2 years, is it no longer owed? I do not think that is the case.

So, the scenario that exists today is that If you owe me, you don’t have to pay me, but if I owe you, I must pay you. I as a Solar customer, have produced more energy than I consume, I do not tax the grid when power is in high demand, I contribute energy that is clean and does not pollute, it is readily available, and at no cost to you. How does that translate into you “Paying Solar Users $25 to $41 million”? How does that work? The manner in which the study answers that question is a much worse travesty of justice. 

As long as I remember, we have been told that it is better to save energy. It has even been mandated that many devices use less and less energy. We are supposed to use less energy and increase the life span of the electrical system in place. This is not how the study views this action. When someone purchases equipment that uses less electricity, or follows guidelines and uses less electricity, or even worse, produces their own electricity; the study views this as SMUD paying the customer for electricity that they did not use. 

In other words, the majority of the money that is included in the $25 to $40 million is in the form of conservation and solar produced electricity not being charged. Somehow by me investing in a solar generation system, using the system to create my own electricity, and then that electricity is somehow a payment made by SMUD to me. This twisted logic is somehow claiming that because we did not buy something is in fact a payment to us is inconceivable. 
The amount of mental gymnastics done to twist reality into a predetermined result is mind boggling. 

My main concern in this idea is that SMUD was designed to be a not for profit entity that is suppose to serve the community. It is this type of prejudice thinking that entirely contradicts the spirt of that intention. In fact, it treats the community as though we are to perform at the expected levels that SMUD dictates and if we do not consume what we are supposed to, then we are supposed to pay the difference anyway. That sounds dangerously like a dictatorship.

Idea # 2 Rooftop Solar’s contribution to Reduction in Climate Change should NOT be Valued.

The assertion implies that the only benefit is that they do not have to purchase that power from another source. There are many other costs that are saved that are not included. 

When you purchase energy, you have to transport it from where it was generated from to where it will be used. There is a significant loss of money associate with transportation. First it requires enormous lengths of powerlines. These powerlines cost a tremendous amount of money to install. Also, a significant amount of that energy is lost in the form of heat generated while it is moving through the line. Since not all of the energy produced will arrive to its final destination of the power meter, this is a loss of money due to transportation.

The more energy that travels through these enormous lengths of powerlines, the more wear and tear occurs on the lines. It costs enormous amounts of money to repair and replace these lines. It costs even more in terms of property and human lives if you don’t, as demonstrated by PG&E.
Solar power is produced and consumed locally. I don’t mean Sacramento proper; I mean within my very own neighborhood. There is no transportation and the amount of energy lost is virtually zero. So how does that not get included into the value?

Now what about the benefit to society? Air quality in California is serious issue. Solar power and Geohydrothermal power are the cleanest forms of power and the former only exists in few places. Solar power exists everywhere. We can drastically reduce the need for carbon-based fuel sources with solar and will have a remarkable affect on the atmosphere’s ability to heal itself. The pandemic showed us in the beginning how much cleaner the air is when we don’t drive as much. Power companies need to follow the same example and encourage people to build rooftop solar. We the consumers make the capital investment to build the generation system, so there is no capital expense to you, there is no loss from transportation, there is less wear on the grid, and you get to begin to reverse the damage of climate change. 

All of these benefits help save the system and make the world a better place. They need to be included into the study.

Idea #3 SMUD no longer has the goal of zero carbon emissions by 2030.

The premise of this study is based on the old commitment that SMUD is committed to running all five carbon-based fuel plants past 2040. This idea suggests that SMUD will still be producing power at that cost until beyond 2040. 

The study began before the commitment was made by the board of directors to reduce carbon emissions to zero by 2030. That said, the study was not revised to reflect this decision. 

The cost structure to produce electricity will change dramatically if that decision is to accomplished. It is a great decision, and in order to accomplish it, rooftop solar will be needed more than ever to accomplish it. The amount of capital needed to build entire new clean energy generation systems is not possible without more private citizens purchasing rooftop solar generators taking on some of the cost of those systems. The board must know this.

This fact that this study does not reflect the effects of that decision, puts into question the board’s commitment to that very decision. Does the board really want to reach that goal or was it just a statement for the public with no real intent to accomplish the goal of that decision? Given the results of that study, I am afraid of the answer to that question.

August 19 - Jennifer
Anything we do to reduce the use of grid energy is a win for all. 

Rooftop solar panels significantly reduce the use of grid energy and should be encouraged not discouraged. 

SMUD customers should not be punished for reducing grid energy use.

KEEP ROOFTOP SOLAR GOING penalty free!


August 19 - Anonymous
I had solar installed in 2016. It cost me about $22.5K. I used to spend an average of $150/mo. for my SMUD bill. I originally figured the $22.5K would be paid off in 12.5 years (However, I paid it off in 2 years.) My solar is guaranteed, in total, for 25 years from the installer. When I true everything up at the end of the year I sometimes have a surplus and some years I have had to pay. I figure that averages to about $200/yr. to true up my annual bill.

All figured, I should SAVE $17,000+ over 25 years, and that doesn't account for the 2.5% average annual increases SMUD is expected to charge during that time.

Please PROMOTE rooftop solar for the benefit of the community. As long as there are federal subsidies, it is a big advantage to any customer using over 1200 kw/mo. And for the customers using only 1000 kw/mo. it is still something to consider.

Also note: SMUD should promote the higher efficiency panels, NOT the ones from China! 


August 18 - Chris M. 
Rolling blackouts in the State of California could be completely eradicated with the further installation of rooftop solar and battery back-up.
We have found that by collecting solar energy and storing it on our battery back-up for use during peak energy times, we are ‘off-grid’ from 8:00 am.to 9:00 pm most days.
This helps SMUD and our neighbors by Generating, Storing and Using our own energy..... especially critical during rolling blackouts.
We pay a monthly surcharge of $20. on top of our regular monthly SMUD bill.
What with the initial expense of installing rooftop solar, and battery back-up, it sounds disingenuous to say we are not paying our fair share.
That is like saying people who grow their own tomatoes should pay more at the grocery store.
Please consider the full ramifications of asking those who have already paid their fair share to pay more for the same electricity as their neighbors.


August 18 - Shaan
Smud you guys are messed up
Why are solar customers getting ripped off
We want to be green and you as a corporation is now trying to rip solar customers 


August 18 - Madeline 
We need to invest in solar power now more than ever. I urge SMUD to expand their programs to help people install rooftop solar systems. Solar not only makes power for the grid but is a solution to fighting climate change; it's a win-win. This country needs to transform our energy systems and I encourage SMUD to lead the way. 


August 18 - Cinda J. 
It continues to disturb me when SMUD keeps trying to come up with ways to keep trying to disenfranchise their customers who have or want to have solar energy. WHY?!?! It’s ridiculous in this time and in our state to take the path of fossil fuel companies. You should be happy that people want solar. Let’s try to look ahead instead of forcing people to go backwards. 


August 18 - Anonymous
I have rooftop solar panels. I drive a electric car. I do everything to be greener. I think you should be doing everything to promote more rooftop solar. Instead you do everything to punish those of us who are doing or part to save our planet. 


August 18 - Jacqueline F. 
i am so disappointed that SMUD would attempt to change the rate or any other aspect of the original expectation of when I invested $30,000 into my rooftop Solar, Especially now when we have this unexpected several days of triple digit temperture. You are receiving the excess power that I produce so why would this be a bad thing, You attempt seem to make it as I as a solar company pay you nothing for the power I use over the power I create. If more people were invested in solar power you would not be experiencing rolling brown outs during these triple digits weather. With global warming there will be many more of these triple digit days and all of the power being produce maybe able to support many more households. I believe the solar study is slanted toward SMUD benefit or the benefit of the solar company which lease there solar panels and keep all rebates charging clients for profit. If you change the original expectation I had when I invested in Solar I will be forced to invest in Solar batteries so I am taken completely off the grid and you will no longer benefit from my solar


August 18 - Vickshna 
Below are the top three problems with SMUD’s solar study, followed by more in-depth background. Please submit a public comment to SMUD about the study by the August 23rd deadline on SMUD’s website (scroll to the bottom of their site for submission instructions). Contact Dave R. at Solar Rights Alliance with questions: ####@#####.org. Thank you!!

Problem #1: SMUD’s solar study asserts that SMUD “pays” solar users even when they are simply making and consuming their own solar energy at home.

SMUD’s study incorrectly purports that SMUD “pays” solar users a total of $25-$41 million a year even when they are simply making and consuming their own solar energy on-site.

This is clearly absurd. SMUD doesn’t “pay” anyone when customers reduce their energy use. If this were true, it would also mean that SMUD is paying people if, for example, they:

Shut off lights or install energy efficient appliances.Use an air conditioner with a built-in solar array and battery such that the unit is never plugged into the wall socket.

Here’s what actually happens. SMUD credits customers for the extra energy they send back to the grid, not for the energy customers use on-site. The credit for this extra energy is the only “payment” at issue here.

Reducing electricity use from the grid is desirable behavior. It reduces the burden on the grid and makes it easier for SMUD to reach its goal of a 100% clean energy mix by 2030. No class of customers should ever be penalized or considered problematic for doing so — whether because of solar, energy efficiency or reduced business operations due to COVID. [1]

Remedy: Re-focus the study only on the solar energy that is sent back to the grid. Remove from the study the solar energy that people consume at home or at their business.

Problem #2: SMUD’s solar study implies that rooftop solar’s climate change benefits should not be valued

SMUD’s solar study and their accompanying website give the overwhelming impression that the value of solar is only $.03-$.07/kWh. This is misleading because it only captures a limited number of rooftop solar’s benefits (namely the ways that rooftop solar allows the utility to avoid generating or purchasing electricity).

There is another critical benefit, however: the impact rooftop solar has on reducing global warming pollution.[2] The report quantifies this benefit as well. But it buries it in fine print and excludes it from all the topline charts and graphs.

That is unfortunate and misleading. The fine print states that rooftop solar’s impact on reducing global warming pollution (along with several other social benefits) increases solar’s value by between $.02 and $.16/kWh.

Combining the value of solar headlined in the report with the value of solar from reducing global warming pollution is likely to yield a solar value of at least $.12/kWh — considerably higher than the report’s headline.

Putting critiques one and two together strongly suggests that rooftop solar actually provides a net benefit to SMUD, in contrast to the study’s topline conclusions.

Remedy: Redo the study to include all of rooftop solar’s social benefits, especially climate change benefits, in the topline calculations of solar’s value.

Problem #3: SMUD’s solar study is not based on SMUD’s new climate change goal

In addition to burying rooftop solar’s global warming benefits in the fine print, SMUD’s study also is premised on SMUD’s old, outdated climate change goal that assumed SMUD would still operate its five fossil fuel power plants past 2040.

Things have changed: the SMUD Board of Directors recently adopted a stronger goal to reduce SMUD’s global warming pollution to zero by 2030.

In fairness, the study was launched before the SMUD Board adopted its new goal. But the study has to be revised to reflect the new goal. To reach zero carbon emissions by 2030, SMUD must increase both large-scale renewable investments and local rooftop solar and storage beyond what SMUD currently plans for in its clean energy plan created in 2018 (called the Integrated Resource Plan), and on a faster timeline. SMUD will also likely increase its efforts to encourage customers to switch to electric cars and appliances.

SMUD will need to increasingly partner with customers who want to install their own solar system to help the community meet these new goals, and that should get reflected in solar’s value.

Remedy: Redo the study’s calculations to reflect SMUD’s new climate change goal of zero carbon pollution by 2030.

Detailed Background

More and more compelling evidence shows that rooftop solar and battery storage provide significant benefits not only to the individuals with solar, but also to the larger community. Rooftop solar reduces the cost of maintaining and expanding the grid and also reduces pollution, especially climate change pollution. These benefits increase with solar-powered batteries that store the extra solar energy to use when the sun isn’t shining.

SMUD and the state of California need more rooftop solar and battery storage to fight global warming, help people keep the lights on during power outages, and give consumers more ways to manage their energy choices.

This is especially the case with SMUD now that they have committed to reducing their global warming pollution to zero by 2030, which means they will need to cease burning natural gas at their five power plants.

In contrast, SMUD has claimed for some time that rooftop solar has more costs than benefits, and that customers who have rooftop solar are not paying their fair share of the electrical grid, are overly subsidized, and are responsible for causing rates to increase for non-solar users. Last spring, SMUD attempted to charge all solar users a new monthly fee that averaged $40-$60, claiming this would force solar users to pay their “fair share.” SMUD withdrew their proposal after a community outcry.

After withdrawing the solar fee proposal, SMUD decided to take a step back, perform a detailed study to quantify solar’s benefits and costs, and then decide what their solar policies should be. Theoretically that’s fine, but the devil is in the details. We have worried that SMUD staff are fundamentally opposed to rooftop solar and would use their influence to steer the study towards the conclusions unfavorable to solar.

Our analysis of the study confirms this fear. SMUD’s report concludes that solar’s costs are greater than their benefits and suggests that solar should be discouraged going forward. However, the report contains several obvious flaws that suggest that the opposite is true — that solar’s benefits outweigh their cost and should be encouraged.


August 18 - Shaan
Below are the top three problems with SMUD’s solar study, followed by more in-depth background. Please submit a public comment to SMUD about the study by the August 23rd deadline on SMUD’s website (scroll to the bottom of their site for submission instructions). Contact Dave R. at Solar Rights Alliance with questions: ####@####.org. Thank you!!
Problem #1: SMUD’s solar study asserts that SMUD “pays” solar users even when they are simply making and consuming their own solar energy at home.
SMUD’s study incorrectly purports that SMUD “pays” solar users a total of $25-$41 million a year even when they are simply making and consuming their own solar energy on-site.
This is clearly absurd. SMUD doesn’t “pay” anyone when customers reduce their energy use. If this were true, it would also mean that SMUD is paying people if, for example, they:
Shut off lights or install energy efficient appliances.Use an air conditioner with a built-in solar array and battery such that the unit is never plugged into the wall socket.
Here’s what actually happens. SMUD credits customers for the extra energy they send back to the grid, not for the energy customers use on-site. The credit for this extra energy is the only “payment” at issue here.
Reducing electricity use from the grid is desirable behavior. It reduces the burden on the grid and makes it easier for SMUD to reach its goal of a 100% clean energy mix by 2030. No class of customers should ever be penalized or considered problematic for doing so — whether because of solar, energy efficiency or reduced business operations due to COVID. [1]
Remedy: Re-focus the study only on the solar energy that is sent back to the grid. Remove from the study the solar energy that people consume at home or at their business.
Problem #2: SMUD’s solar study implies that rooftop solar’s climate change benefits should not be valued
SMUD’s solar study and their accompanying website give the overwhelming impression that the value of solar is only $.03-$.07/kWh. This is misleading because it only captures a limited number of rooftop solar’s benefits (namely the ways that rooftop solar allows the utility to avoid generating or purchasing electricity).
There is another critical benefit, however: the impact rooftop solar has on reducing global warming pollution.[2] The report quantifies this benefit as well. But it buries it in fine print and excludes it from all the topline charts and graphs.
That is unfortunate and misleading. The fine print states that rooftop solar’s impact on reducing global warming pollution (along with several other social benefits) increases solar’s value by between $.02 and $.16/kWh.
Combining the value of solar headlined in the report with the value of solar from reducing global warming pollution is likely to yield a solar value of at least $.12/kWh — considerably higher than the report’s headline.
Putting critiques one and two together strongly suggests that rooftop solar actually provides a net benefit to SMUD, in contrast to the study’s topline conclusions.
Remedy: Redo the study to include all of rooftop solar’s social benefits, especially climate change benefits, in the topline calculations of solar’s value.
Problem #3: SMUD’s solar study is not based on SMUD’s new climate change goal
In addition to burying rooftop solar’s global warming benefits in the fine print, SMUD’s study also is premised on SMUD’s old, outdated climate change goal that assumed SMUD would still operate its five fossil fuel power plants past 2040.
Things have changed: the SMUD Board of Directors recently adopted a stronger goal to reduce SMUD’s global warming pollution to zero by 2030.
In fairness, the study was launched before the SMUD Board adopted its new goal. But the study has to be revised to reflect the new goal. To reach zero carbon emissions by 2030, SMUD must increase both large-scale renewable investments and local rooftop solar and storage beyond what SMUD currently plans for in its clean energy plan created in 2018 (called the Integrated Resource Plan), and on a faster timeline. SMUD will also likely increase its efforts to encourage customers to switch to electric cars and appliances.
SMUD will need to increasingly partner with customers who want to install their own solar system to help the community meet these new goals, and that should get reflected in solar’s value.
Remedy: Redo the study’s calculations to reflect SMUD’s new climate change goal of zero carbon pollution by 2030.
Detailed Background
More and more compelling evidence shows that rooftop solar and battery storage provide significant benefits not only to the individuals with solar, but also to the larger community. Rooftop solar reduces the cost of maintaining and expanding the grid and also reduces pollution, especially climate change pollution. These benefits increase with solar-powered batteries that store the extra solar energy to use when the sun isn’t shining.
SMUD and the state of California need more rooftop solar and battery storage to fight global warming, help people keep the lights on during power outages, and give consumers more ways to manage their energy choices.
This is especially the case with SMUD now that they have committed to reducing their global warming pollution to zero by 2030, which means they will need to cease burning natural gas at their five power plants.
In contrast, SMUD has claimed for some time that rooftop solar has more costs than benefits, and that customers who have rooftop solar are not paying their fair share of the electrical grid, are overly subsidized, and are responsible for causing rates to increase for non-solar users. Last spring, SMUD attempted to charge all solar users a new monthly fee that averaged $40-$60, claiming this would force solar users to pay their “fair share.” SMUD withdrew their proposal after a community outcry.
After withdrawing the solar fee proposal, SMUD decided to take a step back, perform a detailed study to quantify solar’s benefits and costs, and then decide what their solar policies should be. Theoretically that’s fine, but the devil is in the details. We have worried that SMUD staff are fundamentally opposed to rooftop solar and would use their influence to steer the study towards the conclusions unfavorable to solar.
Our analysis of the study confirms this fear. SMUD’s report concludes that solar’s costs are greater than their benefits and suggests that solar should be discouraged going forward. However, the report contains several obvious flaws that suggest that the opposite is true — that solar’s benefits outweigh their cost and should be encouraged.


August 18 - Vishal T.
Below are the top three problems with SMUD’s solar study, followed by more in-depth background. Please submit a public comment to SMUD about the study by the August 23rd deadline on SMUD’s website (scroll to the bottom of their site for submission instructions). Contact Dave R. at Solar Rights Alliance with questions: ####@####.org. Thank you!!

Problem #1: SMUD’s solar study asserts that SMUD “pays” solar users even when they are simply making and consuming their own solar energy at home.

SMUD’s study incorrectly purports that SMUD “pays” solar users a total of $25-$41 million a year even when they are simply making and consuming their own solar energy on-site.

This is clearly absurd. SMUD doesn’t “pay” anyone when customers reduce their energy use. If this were true, it would also mean that SMUD is paying people if, for example, they:

Shut off lights or install energy efficient appliances.Use an air conditioner with a built-in solar array and battery such that the unit is never plugged into the wall socket.

Here’s what actually happens. SMUD credits customers for the extra energy they send back to the grid, not for the energy customers use on-site. The credit for this extra energy is the only “payment” at issue here.

Reducing electricity use from the grid is desirable behavior. It reduces the burden on the grid and makes it easier for SMUD to reach its goal of a 100% clean energy mix by 2030. No class of customers should ever be penalized or considered problematic for doing so — whether because of solar, energy efficiency or reduced business operations due to COVID. [1]

Remedy: Re-focus the study only on the solar energy that is sent back to the grid. Remove from the study the solar energy that people consume at home or at their business.

Problem #2: SMUD’s solar study implies that rooftop solar’s climate change benefits should not be valued

SMUD’s solar study and their accompanying website give the overwhelming impression that the value of solar is only $.03-$.07/kWh. This is misleading because it only captures a limited number of rooftop solar’s benefits (namely the ways that rooftop solar allows the utility to avoid generating or purchasing electricity).

There is another critical benefit, however: the impact rooftop solar has on reducing global warming pollution.[2] The report quantifies this benefit as well. But it buries it in fine print and excludes it from all the topline charts and graphs.

That is unfortunate and misleading. The fine print states that rooftop solar’s impact on reducing global warming pollution (along with several other social benefits) increases solar’s value by between $.02 and $.16/kWh.

Combining the value of solar headlined in the report with the value of solar from reducing global warming pollution is likely to yield a solar value of at least $.12/kWh — considerably higher than the report’s headline.

Putting critiques one and two together strongly suggests that rooftop solar actually provides a net benefit to SMUD, in contrast to the study’s topline conclusions.

Remedy: Redo the study to include all of rooftop solar’s social benefits, especially climate change benefits, in the topline calculations of solar’s value.

Problem #3: SMUD’s solar study is not based on SMUD’s new climate change goal

In addition to burying rooftop solar’s global warming benefits in the fine print, SMUD’s study also is premised on SMUD’s old, outdated climate change goal that assumed SMUD would still operate its five fossil fuel power plants past 2040.

Things have changed: the SMUD Board of Directors recently adopted a stronger goal to reduce SMUD’s global warming pollution to zero by 2030.

In fairness, the study was launched before the SMUD Board adopted its new goal. But the study has to be revised to reflect the new goal. To reach zero carbon emissions by 2030, SMUD must increase both large-scale renewable investments and local rooftop solar and storage beyond what SMUD currently plans for in its clean energy plan created in 2018 (called the Integrated Resource Plan), and on a faster timeline. SMUD will also likely increase its efforts to encourage customers to switch to electric cars and appliances.

SMUD will need to increasingly partner with customers who want to install their own solar system to help the community meet these new goals, and that should get reflected in solar’s value.

Remedy: Redo the study’s calculations to reflect SMUD’s new climate change goal of zero carbon pollution by 2030.

Detailed Background

More and more compelling evidence shows that rooftop solar and battery storage provide significant benefits not only to the individuals with solar, but also to the larger community. Rooftop solar reduces the cost of maintaining and expanding the grid and also reduces pollution, especially climate change pollution. These benefits increase with solar-powered batteries that store the extra solar energy to use when the sun isn’t shining.

SMUD and the state of California need more rooftop solar and battery storage to fight global warming, help people keep the lights on during power outages, and give consumers more ways to manage their energy choices.

This is especially the case with SMUD now that they have committed to reducing their global warming pollution to zero by 2030, which means they will need to cease burning natural gas at their five power plants.

In contrast, SMUD has claimed for some time that rooftop solar has more costs than benefits, and that customers who have rooftop solar are not paying their fair share of the electrical grid, are overly subsidized, and are responsible for causing rates to increase for non-solar users. Last spring, SMUD attempted to charge all solar users a new monthly fee that averaged $40-$60, claiming this would force solar users to pay their “fair share.” SMUD withdrew their proposal after a community outcry.

After withdrawing the solar fee proposal, SMUD decided to take a step back, perform a detailed study to quantify solar’s benefits and costs, and then decide what their solar policies should be. Theoretically that’s fine, but the devil is in the details. We have worried that SMUD staff are fundamentally opposed to rooftop solar and would use their influence to steer the study towards the conclusions unfavorable to solar.

Our analysis of the study confirms this fear. SMUD’s report concludes that solar’s costs are greater than their benefits and suggests that solar should be discouraged going forward. However, the report contains several obvious flaws that suggest that the opposite is true — that solar’s benefits outweigh their cost and should be encouraged.


August 18 - Vikash T.
Below are the top three problems with SMUD’s solar study, followed by more in-depth background. Please submit a public comment to SMUD about the study by the August 23rd deadline on SMUD’s website (scroll to the bottom of their site for submission instructions). Contact Dave R. at Solar Rights Alliance with questions: ####@####.org. Thank you!!

Problem #1: SMUD’s solar study asserts that SMUD “pays” solar users even when they are simply making and consuming their own solar energy at home.

SMUD’s study incorrectly purports that SMUD “pays” solar users a total of $25-$41 million a year even when they are simply making and consuming their own solar energy on-site.

This is clearly absurd. SMUD doesn’t “pay” anyone when customers reduce their energy use. If this were true, it would also mean that SMUD is paying people if, for example, they:

Shut off lights or install energy efficient appliances.Use an air conditioner with a built-in solar array and battery such that the unit is never plugged into the wall socket.

Here’s what actually happens. SMUD credits customers for the extra energy they send back to the grid, not for the energy customers use on-site. The credit for this extra energy is the only “payment” at issue here.

Reducing electricity use from the grid is desirable behavior. It reduces the burden on the grid and makes it easier for SMUD to reach its goal of a 100% clean energy mix by 2030. No class of customers should ever be penalized or considered problematic for doing so — whether because of solar, energy efficiency or reduced business operations due to COVID. [1]

Remedy: Re-focus the study only on the solar energy that is sent back to the grid. Remove from the study the solar energy that people consume at home or at their business.

Problem #2: SMUD’s solar study implies that rooftop solar’s climate change benefits should not be valued

SMUD’s solar study and their accompanying website give the overwhelming impression that the value of solar is only $.03-$.07/kWh. This is misleading because it only captures a limited number of rooftop solar’s benefits (namely the ways that rooftop solar allows the utility to avoid generating or purchasing electricity).

There is another critical benefit, however: the impact rooftop solar has on reducing global warming pollution.[2] The report quantifies this benefit as well. But it buries it in fine print and excludes it from all the topline charts and graphs.

That is unfortunate and misleading. The fine print states that rooftop solar’s impact on reducing global warming pollution (along with several other social benefits) increases solar’s value by between $.02 and $.16/kWh.

Combining the value of solar headlined in the report with the value of solar from reducing global warming pollution is likely to yield a solar value of at least $.12/kWh — considerably higher than the report’s headline.

Putting critiques one and two together strongly suggests that rooftop solar actually provides a net benefit to SMUD, in contrast to the study’s topline conclusions.

Remedy: Redo the study to include all of rooftop solar’s social benefits, especially climate change benefits, in the topline calculations of solar’s value.

Problem #3: SMUD’s solar study is not based on SMUD’s new climate change goal

In addition to burying rooftop solar’s global warming benefits in the fine print, SMUD’s study also is premised on SMUD’s old, outdated climate change goal that assumed SMUD would still operate its five fossil fuel power plants past 2040.

Things have changed: the SMUD Board of Directors recently adopted a stronger goal to reduce SMUD’s global warming pollution to zero by 2030.

In fairness, the study was launched before the SMUD Board adopted its new goal. But the study has to be revised to reflect the new goal. To reach zero carbon emissions by 2030, SMUD must increase both large-scale renewable investments and local rooftop solar and storage beyond what SMUD currently plans for in its clean energy plan created in 2018 (called the Integrated Resource Plan), and on a faster timeline. SMUD will also likely increase its efforts to encourage customers to switch to electric cars and appliances.

SMUD will need to increasingly partner with customers who want to install their own solar system to help the community meet these new goals, and that should get reflected in solar’s value.

Remedy: Redo the study’s calculations to reflect SMUD’s new climate change goal of zero carbon pollution by 2030.

Detailed Background

More and more compelling evidence shows that rooftop solar and battery storage provide significant benefits not only to the individuals with solar, but also to the larger community. Rooftop solar reduces the cost of maintaining and expanding the grid and also reduces pollution, especially climate change pollution. These benefits increase with solar-powered batteries that store the extra solar energy to use when the sun isn’t shining.

SMUD and the state of California need more rooftop solar and battery storage to fight global warming, help people keep the lights on during power outages, and give consumers more ways to manage their energy choices.

This is especially the case with SMUD now that they have committed to reducing their global warming pollution to zero by 2030, which means they will need to cease burning natural gas at their five power plants.

In contrast, SMUD has claimed for some time that rooftop solar has more costs than benefits, and that customers who have rooftop solar are not paying their fair share of the electrical grid, are overly subsidized, and are responsible for causing rates to increase for non-solar users. Last spring, SMUD attempted to charge all solar users a new monthly fee that averaged $40-$60, claiming this would force solar users to pay their “fair share.” SMUD withdrew their proposal after a community outcry.

After withdrawing the solar fee proposal, SMUD decided to take a step back, perform a detailed study to quantify solar’s benefits and costs, and then decide what their solar policies should be. Theoretically that’s fine, but the devil is in the details. We have worried that SMUD staff are fundamentally opposed to rooftop solar and would use their influence to steer the study towards the conclusions unfavorable to solar.

Our analysis of the study confirms this fear. SMUD’s report concludes that solar’s costs are greater than their benefits and suggests that solar should be discouraged going forward. However, the report contains several obvious flaws that suggest that the opposite is true — that solar’s benefits outweigh their cost and should be encouraged.


August 18 - Vijendra A.
Below are the top three problems with SMUD’s solar study, followed by more in-depth background. Please submit a public comment to SMUD about the study by the August 23rd deadline on SMUD’s website (scroll to the bottom of their site for submission instructions). Contact Dave R. at Solar Rights Alliance with questions: ####@####.org. Thank you!!

Problem #1: SMUD’s solar study asserts that SMUD “pays” solar users even when they are simply making and consuming their own solar energy at home.

SMUD’s study incorrectly purports that SMUD “pays” solar users a total of $25-$41 million a year even when they are simply making and consuming their own solar energy on-site.

This is clearly absurd. SMUD doesn’t “pay” anyone when customers reduce their energy use. If this were true, it would also mean that SMUD is paying people if, for example, they:

Shut off lights or install energy efficient appliances.Use an air conditioner with a built-in solar array and battery such that the unit is never plugged into the wall socket.

Here’s what actually happens. SMUD credits customers for the extra energy they send back to the grid, not for the energy customers use on-site. The credit for this extra energy is the only “payment” at issue here.

Reducing electricity use from the grid is desirable behavior. It reduces the burden on the grid and makes it easier for SMUD to reach its goal of a 100% clean energy mix by 2030. No class of customers should ever be penalized or considered problematic for doing so — whether because of solar, energy efficiency or reduced business operations due to COVID. [1]

Remedy: Re-focus the study only on the solar energy that is sent back to the grid. Remove from the study the solar energy that people consume at home or at their business.

Problem #2: SMUD’s solar study implies that rooftop solar’s climate change benefits should not be valued

SMUD’s solar study and their accompanying website give the overwhelming impression that the value of solar is only $.03-$.07/kWh. This is misleading because it only captures a limited number of rooftop solar’s benefits (namely the ways that rooftop solar allows the utility to avoid generating or purchasing electricity).

There is another critical benefit, however: the impact rooftop solar has on reducing global warming pollution.[2] The report quantifies this benefit as well. But it buries it in fine print and excludes it from all the topline charts and graphs.

That is unfortunate and misleading. The fine print states that rooftop solar’s impact on reducing global warming pollution (along with several other social benefits) increases solar’s value by between $.02 and $.16/kWh.

Combining the value of solar headlined in the report with the value of solar from reducing global warming pollution is likely to yield a solar value of at least $.12/kWh — considerably higher than the report’s headline.

Putting critiques one and two together strongly suggests that rooftop solar actually provides a net benefit to SMUD, in contrast to the study’s topline conclusions.

Remedy: Redo the study to include all of rooftop solar’s social benefits, especially climate change benefits, in the topline calculations of solar’s value.

Problem #3: SMUD’s solar study is not based on SMUD’s new climate change goal

In addition to burying rooftop solar’s global warming benefits in the fine print, SMUD’s study also is premised on SMUD’s old, outdated climate change goal that assumed SMUD would still operate its five fossil fuel power plants past 2040.

Things have changed: the SMUD Board of Directors recently adopted a stronger goal to reduce SMUD’s global warming pollution to zero by 2030.

In fairness, the study was launched before the SMUD Board adopted its new goal. But the study has to be revised to reflect the new goal. To reach zero carbon emissions by 2030, SMUD must increase both large-scale renewable investments and local rooftop solar and storage beyond what SMUD currently plans for in its clean energy plan created in 2018 (called the Integrated Resource Plan), and on a faster timeline. SMUD will also likely increase its efforts to encourage customers to switch to electric cars and appliances.

SMUD will need to increasingly partner with customers who want to install their own solar system to help the community meet these new goals, and that should get reflected in solar’s value.

Remedy: Redo the study’s calculations to reflect SMUD’s new climate change goal of zero carbon pollution by 2030.

Detailed Background

More and more compelling evidence shows that rooftop solar and battery storage provide significant benefits not only to the individuals with solar, but also to the larger community. Rooftop solar reduces the cost of maintaining and expanding the grid and also reduces pollution, especially climate change pollution. These benefits increase with solar-powered batteries that store the extra solar energy to use when the sun isn’t shining.

SMUD and the state of California need more rooftop solar and battery storage to fight global warming, help people keep the lights on during power outages, and give consumers more ways to manage their energy choices.

This is especially the case with SMUD now that they have committed to reducing their global warming pollution to zero by 2030, which means they will need to cease burning natural gas at their five power plants.

In contrast, SMUD has claimed for some time that rooftop solar has more costs than benefits, and that customers who have rooftop solar are not paying their fair share of the electrical grid, are overly subsidized, and are responsible for causing rates to increase for non-solar users. Last spring, SMUD attempted to charge all solar users a new monthly fee that averaged $40-$60, claiming this would force solar users to pay their “fair share.” SMUD withdrew their proposal after a community outcry.

After withdrawing the solar fee proposal, SMUD decided to take a step back, perform a detailed study to quantify solar’s benefits and costs, and then decide what their solar policies should be. Theoretically that’s fine, but the devil is in the details. We have worried that SMUD staff are fundamentally opposed to rooftop solar and would use their influence to steer the study towards the conclusions unfavorable to solar.

Our analysis of the study confirms this fear. SMUD’s report concludes that solar’s costs are greater than their benefits and suggests that solar should be discouraged going forward. However, the report contains several obvious flaws that suggest that the opposite is true — that solar’s benefits outweigh their cost and should be encouraged.

August 18 - Ashu P.
Below are the top three problems with SMUD’s solar study, followed by more in-depth background. Please submit a public comment to SMUD about the study by the August 23rd deadline on SMUD’s website (scroll to the bottom of their site for submission instructions). Contact Dave R. at Solar Rights Alliance with questions: ####@####.org. Thank you!!

Problem #1: SMUD’s solar study asserts that SMUD “pays” solar users even when they are simply making and consuming their own solar energy at home.

SMUD’s study incorrectly purports that SMUD “pays” solar users a total of $25-$41 million a year even when they are simply making and consuming their own solar energy on-site.

This is clearly absurd. SMUD doesn’t “pay” anyone when customers reduce their energy use. If this were true, it would also mean that SMUD is paying people if, for example, they:

Shut off lights or install energy efficient appliances.Use an air conditioner with a built-in solar array and battery such that the unit is never plugged into the wall socket.

Here’s what actually happens. SMUD credits customers for the extra energy they send back to the grid, not for the energy customers use on-site. The credit for this extra energy is the only “payment” at issue here.

Reducing electricity use from the grid is desirable behavior. It reduces the burden on the grid and makes it easier for SMUD to reach its goal of a 100% clean energy mix by 2030. No class of customers should ever be penalized or considered problematic for doing so — whether because of solar, energy efficiency or reduced business operations due to COVID. [1]

Remedy: Re-focus the study only on the solar energy that is sent back to the grid. Remove from the study the solar energy that people consume at home or at their business.

Problem #2: SMUD’s solar study implies that rooftop solar’s climate change benefits should not be valued

SMUD’s solar study and their accompanying website give the overwhelming impression that the value of solar is only $.03-$.07/kWh. This is misleading because it only captures a limited number of rooftop solar’s benefits (namely the ways that rooftop solar allows the utility to avoid generating or purchasing electricity).

There is another critical benefit, however: the impact rooftop solar has on reducing global warming pollution.[2] The report quantifies this benefit as well. But it buries it in fine print and excludes it from all the topline charts and graphs.

That is unfortunate and misleading. The fine print states that rooftop solar’s impact on reducing global warming pollution (along with several other social benefits) increases solar’s value by between $.02 and $.16/kWh.

Combining the value of solar headlined in the report with the value of solar from reducing global warming pollution is likely to yield a solar value of at least $.12/kWh — considerably higher than the report’s headline.

Putting critiques one and two together strongly suggests that rooftop solar actually provides a net benefit to SMUD, in contrast to the study’s topline conclusions.

Remedy: Redo the study to include all of rooftop solar’s social benefits, especially climate change benefits, in the topline calculations of solar’s value.

Problem #3: SMUD’s solar study is not based on SMUD’s new climate change goal

In addition to burying rooftop solar’s global warming benefits in the fine print, SMUD’s study also is premised on SMUD’s old, outdated climate change goal that assumed SMUD would still operate its five fossil fuel power plants past 2040.

Things have changed: the SMUD Board of Directors recently adopted a stronger goal to reduce SMUD’s global warming pollution to zero by 2030.

In fairness, the study was launched before the SMUD Board adopted its new goal. But the study has to be revised to reflect the new goal. To reach zero carbon emissions by 2030, SMUD must increase both large-scale renewable investments and local rooftop solar and storage beyond what SMUD currently plans for in its clean energy plan created in 2018 (called the Integrated Resource Plan), and on a faster timeline. SMUD will also likely increase its efforts to encourage customers to switch to electric cars and appliances.

SMUD will need to increasingly partner with customers who want to install their own solar system to help the community meet these new goals, and that should get reflected in solar’s value.

Remedy: Redo the study’s calculations to reflect SMUD’s new climate change goal of zero carbon pollution by 2030.

Detailed Background

More and more compelling evidence shows that rooftop solar and battery storage provide significant benefits not only to the individuals with solar, but also to the larger community. Rooftop solar reduces the cost of maintaining and expanding the grid and also reduces pollution, especially climate change pollution. These benefits increase with solar-powered batteries that store the extra solar energy to use when the sun isn’t shining.

SMUD and the state of California need more rooftop solar and battery storage to fight global warming, help people keep the lights on during power outages, and give consumers more ways to manage their energy choices.

This is especially the case with SMUD now that they have committed to reducing their global warming pollution to zero by 2030, which means they will need to cease burning natural gas at their five power plants.

In contrast, SMUD has claimed for some time that rooftop solar has more costs than benefits, and that customers who have rooftop solar are not paying their fair share of the electrical grid, are overly subsidized, and are responsible for causing rates to increase for non-solar users. Last spring, SMUD attempted to charge all solar users a new monthly fee that averaged $40-$60, claiming this would force solar users to pay their “fair share.” SMUD withdrew their proposal after a community outcry.

After withdrawing the solar fee proposal, SMUD decided to take a step back, perform a detailed study to quantify solar’s benefits and costs, and then decide what their solar policies should be. Theoretically that’s fine, but the devil is in the details. We have worried that SMUD staff are fundamentally opposed to rooftop solar and would use their influence to steer the study towards the conclusions unfavorable to solar.

Our analysis of the study confirms this fear. SMUD’s report concludes that solar’s costs are greater than their benefits and suggests that solar should be discouraged going forward. However, the report contains several obvious flaws that suggest that the opposite is true — that solar’s benefits outweigh their cost and should be encouraged.


August 18 - Anonymous
Solar panels belong on roof tops, especially commercial roof tops but also residential ones. Solar farms waste land and habitat. Conservation is also key to any energy efforts.


August 18 - CG
A more equitable solution would be to:
1. Raise the fixed infrastructure charge (even if the amount is different for a solar customer vs a non-solar customer).
2. Take into account all of the rooftop solar INSTEAD of building your own solar farms or buying dirty energy.

Alternatively, change the rules only for NEW solar installs so people know what they're getting into rather than screwing over people you led into believing solar was a sound investment for them under NEM 1.0. 


August 18 - Terry W. 
As a rooftop solar user / producer I think the numbers in this study have been manipulated. SMUD’s buyback rate is not .16. Per kWh. In fact I have never seen any money. We didn’t get into solar to just save money, we wanted to be part of a community that cares about the environment. We wanted to produce clean energy. We wanted to do something that is good for everyone. I think it would be shortsighted to charge rooftop solar customers more. We are not part of the problem we are part of the solution. I understand SMUD needs to turn a profit to reinvest in clean energy. Keep the buyback @ .03 - .05 but don’t punish us for doing the right thing. 


August 18 - Roy M. 
I have a solar system installed on my roof which was purchased with particular expectations about future energy needs and cost. So, on the one hand, I appreciate efforts to be fair to all customers, and a public review process will be essential. Go for it! On the other hand, people like myself acted in accord to a economic situation, including a reasonable expectation about the future, and fairness includes not "going back" on a deal made. The deal we made includes a $20 (+-) monthly service (connection?) charge. Doesn't this pay for something?


August 18 - Anonymous
The more people that have solar, the less chance of a rolling blackout. The more homes being built, the more electricity you have to provide. We are a big help in that area by having solar. You won't even let us put in more solar than we use because you are afraid of a small rebate. What crazy thinking. Now you want to chrg us fees for having solar. How unreasonable is that! You can't be for the customer with thinking like that.


August 18 - Matthew E. 
While subsidies were useful for getting solar off the ground, I'm all for determining a fair way to share the cost of supporting the infrastructure across solar and non-solar customers more evenly. 


August 18 - Heather
I am writing in to reject this flawed study that undervalues the benefits of rooftop solar. One of the main reasons I decided to purchase in the 95829 area is because the home had solar panels. I saw first hand at my parents house how it was saving the Earth through climate change and our bill was reduced with the solar panel. By instilling a new fee structure, you are basically saying SMUD doens't believe in climate change. I believe SMUD should be providing more incentives for people to get solar panels. We need more homes in California to encourage rooftop solar panels and not discourage people. Thank you for your time. 


August 18 - Anonymous
Please do not take our God given solar away. It’s much nicer and cleaner for our environment! So do NOT discourage people to use Solar. I already have Solar on one house and plan to do the other house also. Thanks for considering my input. 
SMUD customer sinds 2000


August 18 - Carlene E. 
SMUD's solar study asserts that SMUD "pays" solar users even when they are simply making and consuming their own solar energy at home.
SMUD's study incorrectly purports that SMUD “pays” solar users a total of $25-$41 million a year even when they are simply making and consuming their own solar energy on-site.
This is clearly absurd. SMUD doesn't "pay" anyone when customers reduce their energy use. If this were true, it would also mean that SMUD is paying people if, for example, they:
Shut off lights or install energy efficient appliances.
Use an air conditioner with a built-in solar array and battery such that the unit is never plugged into the wall socket.
Here's what actually happens. SMUD credits customers for the extra energy they send back to the grid, not for the energy customers use on-site. The credit for this extra energy is the only “payment” at issue here.
Reducing electricity use from the grid is desirable behavior. It reduces the burden on the grid and makes it easier for SMUD to reach its goal of a 100% clean energy mix by 2030. No class of customers should ever be penalized or considered problematic for doing so - whether because of solar, energy efficiency or reduced business operations due to COVID.[1]
Remedy: Re-focus the study only on the solar energy that is sent back to the grid. Remove from the study the solar energy that people consume at home or at their business.
Problem #2: SMUD's solar study implies that rooftop solar's climate change benefits should not be valued
SMUD's solar study and their accompanying website give the overwhelming impression that the value of solar is only $.03-$.07/kWh. This is misleading because it only captures a limited number of rooftop solar's benefits (namely the ways that rooftop solar allows the utility to avoid generating or purchasing electricity).
There is another critical benefit, however: the impact rooftop solar has on reducing global warming pollution.[2] The report quantifies this benefit as well. But it buries it in fine print and excludes it from all the topline charts and graphs.
That is unfortunate and misleading. The fine print states that rooftop solar's impact on reducing global warming pollution (along with several other social benefits) increases solar's value by between $.02 and $.16/kWh.
Combining the value of solar headlined in the report with the value of solar from reducing global warming pollution is likely to yield a solar value of at least $.12/kWh -- considerably higher than the report's headline.
Putting critiques one and two together strongly suggests that rooftop solar actually provides a net benefit to SMUD, in contrast to the study's topline conclusions.
Remedy: Redo the study to include all of rooftop solar's social benefits, especially climate change benefits, in the topline calculations of solar's value.
Problem #3: SMUD's solar study is not based on SMUD's new climate change goal
In addition to burying rooftop solar's global warming benefits in the fine print, SMUD's study also is premised on SMUD's old, outdated climate change goal that assumed SMUD would still operate its five fossil fuel power plants past 2040.
Things have changed: the SMUD Board of Directors recently adopted a stronger goal to reduce SMUD's global warming pollution to zero by 2030.
In fairness, the study was launched before the SMUD Board adopted its new goal. But the study has to be revised to reflect the new goal. To reach zero carbon emissions by 2030, SMUD must increase both large-scale renewable investments and local rooftop solar and storage beyond what SMUD currently plans for in its clean energy plan created in 2018 (called the Integrated Resource Plan), and on a faster timeline. SMUD will also likely increase its efforts to encourage customers to switch to electric cars and appliances.
SMUD will need to increasingly partner with customers who want to install their own solar system to help the community meet these new goals, and that should get reflected in solar's value.
Remedy: Redo the study’s calculations to reflect SMUD's new climate change goal of zero carbon pollution by 2030. 


August 18 - Manuel A. 
I want to express my concern with the draft study. I don’t believe it captures the true value of roof top solar. SMUD should look at customers with solar as partners and value solar at it’s retail rate. The use of solar is no different than other energy efficiency efforts. As a customer based electrical system solar can support the entire SMUD system, you just need to get out the central until it mode. 


August 18 - SANDEEP R. 
Please do not increase the net metering fee. 


August 18 - Toby W. 
The idea that SMUD is "paying solar customers more than its value, and the extra costs being passed along to non-solar customers will continue to grow" is so disingenuous as is the information in the draft study. I'm not sure where the study came up with the glorious .12/kWh, but that's simply not true. We are offered the wholesale rate which is more like .03/kWh.

Penalizing current rooftop solar owners and/or discouraging rooftop solar going forward is not the answer! SMUD should be pushing for more rooftop solar while investing in batteries to store the extra energy for use on less sunny days. This approach benefits SMUD's commitment to reduce global warming pollution to zero by 2030 without penalizing rooftop solar owners. SMUD has NOT provided an honest evaluation of the cost to benefit ratio for rooftop solar. Residential solar IS the answer to reducing global warming and thus to reducing the cost of pollution!  Just this week, we see again just how fragile the electrical grid is. SMUD needs to embrace solar and battery storage as a solution!


August 18 - Armand G. 
I disagree with the “findings” of the “independent” report SMUD is relying on to promote their predetermined conclusions. The report was prepared by an organization that works for the utility industry. The conclusions should be construed as biased regardless of claims to the contrary. An independent analysis would be more credible if peer-reviewed and published for public and scientific scrutiny rather than a paid for report that presents the conclusions SMUD was advancing even before the analysis was complete. The conclusions are wrong and are not supported by any credible scientific analysis (see IPCC 2020). The analysis was narrowed by omitting and ignoring obvious benefits of rooftop solar Including the benefit of reducing transmission that involves not just the potential to reduce the direct costs of infrastructure construction and maintenance but also the environmental impacts resulting from the loss of habitats and the direct and cumulative impacts to native species, many of which are threatened or endangered now faced with the possibility of extinction. Avoiding these impacts while benefiting from the investments of private citizens effectively helping the state and SMUD meet its renewable goals for 2030 and beyond should be embraced. For most rooftop solar customers, if polled, would likely identify the environmental benefits as motivation for incurring the substantial expense of installing solar. It is unconscionable that SMUD would dishonor the financial sacrifices and environmental commitments made by rooftop solar owners trying to do their part for the greater good, Sacramento, California, the USA and the planet. It seems SMUD is unfortunately on the wrong side of this issue. SMUD should be encouraging rooftop solar just as the State of California is doing through forward thinking environmental awareness and climate conscious legislation. I encourage SMUD to reconsider whatever is motivating them to pursue such a wrong-headed policy. It is not a credible argument to say rooftop solar is not cost or environmental beneficial. Even if the cost is more, it’s worth it. That is why I participate in SMUD’s green renewable program, paying more for my energy because it’s not about the money, it’s about the planet. It’s about doing what is right for humanity. Whatever the reason to claim as true, what is practically universally known to anyone paying attention and having any environmental awareness, as not being true, is a bad decision on the part of SMUD and should be reversed. 


August 18 - Mark R. 
Solar power works. We put solar on our rooftop to help add power to the grid an lower our cost of electricity. Along with my neighbors who did the same, we lowered the need for new, expensive power plants (in particular gas), saving SMUD money. In a very recent SacBee article, we saw that Solar power covers around 25% of all energy needs during the day. Without it, the rolling blackouts would have happened much earlier during this most recent heatwave. What we need are incentives to put in battery backup so that during the peak hours of 530pm to 830pm, we have power, generated by the sun. Giving us a fraction of the cost you charge us per kilowatt hour will discourage the growth of clean solar along with battery backup.


August 18 - Lee K. 
We purchased and installed solar panels approximately 3 years ago. We are so happy we installed them when we did. Before dial panels our electricity bill during the summer were between $275 to $300/month and thus was using our HVAC only during hot summer days, during a time when we should not have used our HVAC. Our monthly SMUD electric bills are now less than $20/month and we use our HVAC when we needed. We feel great about our contribution to lowering our demand on our environment and our ability to give back Excess electricity generated by our panels. We should be installing more solar panels. This is apparent by SMUD’s installation of solar panels on their own administrative building.


August 18 - Donna C. 
I feel rooftop solar with or without battery storage provide significant benefits not only to the individuals with solar, but also to the larger community. Rooftop solar reduces the cost of maintaining and expanding the grid and also reduces pollution, especially climate change pollution. Rooftop solar needs to be encouraged, not discouraged if SMUD want to meet its zero pollution goal by 2030. I strongly feel we must all contribute and rooftop solar can get individuals committed to this cause 


August 18 - Anonymous
I have solar. I would have preferred more panels but was informed that SMUD would not allow me to have more. If I were able to have sufficient panels I would be saving even more. As it is my costs to SMUD are nearly just the required $22 a monthly. A few more panels will be added when I am able as my goal is to supply my neighbor as well. As we all should have panels to power each other. My panels are extremely efficient. Not sure where the data for the guesstimate is obtained as no one from SMUD has asked me. 


August 18 - Amanda Z 
As with every business in Capitalism there is always a need to increase profit year over year. 

Solar generation at a local level makes the most sense and solar owners have the same right to sell the energy they produce at the same rate that they pay for that same energy they receive from the grid. 

The time for energy providers are changing - for the better. Local solar eliminates the need to continue to expand the grid, but is held up by local solar owners. 
Solar saves everyone money. Solar reduces the cost of running the grid and reduces the need to invest in centralized power generation. With an increase in rooftop solar there is a shift in how companies should operate and should not be at the expense of solar owners. Solar makes sense - anything in contrary to it is just a way of keeping customers hostage to rely on centralized energy generation, period. 

Solar users pay the same fees as non solar consumers for consuming less energy off the grid. Solar users also provide energy back to the grid to support customer without solar energy. 

Solar energy is not subsidized, the same cost for energy consumed from the grid should also be the same cost that is paid to consumers to send energy to the grid for others to consume. Energy companies want to be the big guy handing out energy but Solar users have the right to invest in solar energy and provide excess to others. The cost is not passed on to the energy company or non solar consumers. 

Asking to eliminate or reduce solar rooftop systems is backwards thinking when the energy generated is clean and local. 
The study is still being conducted and is not final but to see that conclusions are being made without ANY evidence of how solar energy is a benefit makes absolutely no sense. Value of solar is at the eye of the beholder. I, for one, find it saves our environment and improves the quality of energy for all.
Its like pie once rooftop solar users starting eating at the table and getting a sliver of pie, the big bullies started to complain. 

This is not acceptable and as a consumer I will fight to keep my rooftop solar valuable and receives he benefits I deserve for generating energy in a clean and efficient matter that supports not only my home but also my community!
Don’t be greedy like PGE!


August 18 - Judy
Utilities should not be for profit. It is in the best interests of everyone to have heat, air conditioning and power. If you operate as a money grubbing for-profit, you will never help this planet to become sustainable. Our world is growing, we all need solar and the clean energy it generates. Roof top solar should be an asset to your utility and not competition. Have a little foresight and support sustainable roof top solar. Keep our costs down! 


August 18 - Emily B.

My family is signing up for a PPA with a solar company and this information leaves me feeling confused and concerned about whether or not solar is a good idea. I feel like I’m doing the right thing by generating energy through solar. I was trying to have a predictable bill and help contribute to a greener future. Now I’m fearful that having solar will become more costly. These PPAs are 25 year agreements please take this into consideration when you are making this decision. I look forward to being a part of this process. Thank you for the option to receive updates on this topic.


August 18 - Vito
I’m a believer of the long term benefits of solar power. I would think that it would re-enforce our efforts to curtail global warming and climate change. I encourage SMUD to support solar power power. 

August 18 - Eric S.
As a customer I am very disappointed in SMUD for attempting to discourage rooftop solar. I hope I do not need to let my neighbors know what your company is attempting. 
SMUD is pushing a flawed study that grossly undervalues the benefits of rooftop solar, and hands SMUD the excuse they need to discourage rooftop solar in Sacramento with new fees and deep cuts to the net metering credit.
Below are the top three problems with SMUD's solar study, followed by more in-depth background. Please submit a public comment to SMUD about the study by the August 23rd deadline on their website (scroll to the bottom of their site for submission instructions). Contact Dave Rosenfeld at Solar Rights Alliance with questions: dave@solarrights.org. Thank you!!
Problem #1: SMUD's solar study asserts that SMUD "pays" solar users even when they are simply making and consuming their own solar energy at home.
SMUD's study incorrectly purports that SMUD “pays” solar users a total of $25-$41 million a year even when they are simply making and consuming their own solar energy on-site.
This is clearly absurd. SMUD doesn't "pay" anyone when customers reduce their energy use. If this were true, it would also mean that SMUD is paying people if, for example, they:
Shut off lights or install energy efficient appliances.
Use an air conditioner with a built-in solar array and battery such that the unit is never plugged into the wall socket.
Here's what actually happens. SMUD credits customers for the extra energy they send back to the grid, not for the energy customers use on-site. The credit for this extra energy is the only “payment” at issue here.
Reducing electricity use from the grid is desirable behavior. It reduces the burden on the grid and makes it easier for SMUD to reach its goal of a 100% clean energy mix by 2030. No class of customers should ever be penalized or considered problematic for doing so - whether because of solar, energy efficiency or reduced business operations due to COVID.[1]
Remedy: Re-focus the study only on the solar energy that is sent back to the grid. Remove from the study the solar energy that people consume at home or at their business.
Problem #2: SMUD's solar study implies that rooftop solar's climate change benefits should not be valued
SMUD's solar study and their accompanying website give the overwhelming impression that the value of solar is only $.03-$.07/kWh. This is misleading because it only captures a limited number of rooftop solar's benefits (namely the ways that rooftop solar allows the utility to avoid generating or purchasing electricity).
There is another critical benefit, however: the impact rooftop solar has on reducing global warming pollution.[2] The report quantifies this benefit as well. But it buries it in fine print and excludes it from all the topline charts and graphs.
That is unfortunate and misleading. The fine print states that rooftop solar's impact on reducing global warming pollution (along with several other social benefits) increases solar's value by between $.02 and $.16/kWh.
Combining the value of solar headlined in the report with the value of solar from reducing global warming pollution is likely to yield a solar value of at least $.12/kWh - considerably higher than the report's headline.
Putting critiques one and two together strongly suggests that rooftop solar actually provides a net benefit to SMUD, in contrast to the study's topline conclusions.
Remedy: Redo the study to include all of rooftop solar's social benefits, especially climate change benefits, in the topline calculations of solar's value.
Problem #3: SMUD's solar study is not based on SMUD's new climate change goal
In addition to burying rooftop solar's global warming benefits in the fine print, SMUD's study also is premised on SMUD's old, outdated climate change goal that assumed SMUD would still operate its five fossil fuel power plants past 2040.
Things have changed: the SMUD Board of Directors recently adopted a stronger goal to reduce SMUD's global warming pollution to zero by 2030.
In fairness, the study was launched before the SMUD Board adopted its new goal. But the study has to be revised to reflect the new goal. To reach zero carbon emissions by 2030, SMUD must increase both large-scale renewable investments and local rooftop solar and storage beyond what SMUD currently plans for in its clean energy plan created in 2018 (called the Integrated Resource Plan), and on a faster timeline. SMUD will also likely increase its efforts to encourage customers to switch to electric cars and appliances.
SMUD will need to increasingly partner with customers who want to install their own solar system to help the community meet these new goals, and that should get reflected in solar's value.
Remedy: Redo the study’s calculations to reflect SMUD's new climate change goal of zero carbon pollution by 2030.
Detailed Background
More and more compelling evidence shows that rooftop solar and battery storage provide significant benefits not only to the individuals with solar, but also to the larger community. Rooftop solar reduces the cost of maintaining and expanding the grid and also reduces pollution, especially climate change pollution. These benefits increase with solar-powered batteries that store the extra solar energy to use when the sun isn't shining.
SMUD and the state of California need more rooftop solar and battery storage to fight global warming, help people keep the lights on during power outages, and give consumers more ways to manage their energy choices.
This is especially the case with SMUD now that they have committed to reducing their global warming pollution to zero by 2030, which means they will need to cease burning natural gas at their five power plants.
In contrast, SMUD has claimed for some time that rooftop solar has more costs than benefits, and that customers who have rooftop solar are not paying their fair share of the electrical grid, are overly subsidized, and are responsible for causing rates to increase for non-solar users. Last spring, SMUD attempted to charge all solar users a new monthly fee that averaged $40-$60, claiming this would force solar users to pay their "fair share." SMUD withdrew their proposal after a community outcry.
After withdrawing the solar fee proposal, SMUD decided to take a step back, perform a detailed study to quantify solar's benefits and costs, and then decide what their solar policies should be. Theoretically that's fine, but the devil is in the details. We have worried that SMUD staff are fundamentally opposed to rooftop solar and would use their influence to steer the study towards the conclusions unfavorable to solar.
Our analysis of the study confirms this fear. SMUD's report concludes that solar's costs are greater than their benefits and suggests that solar should be discouraged going forward. However, the report contains several obvious flaws that suggest that the opposite is true -- that solar's benefits outweigh their cost and should be encouraged.

August 18 - Nicole R. 

The report you're using is just wrong / skewed. It uses fine print and accounting tricks to create an excuse to discourage rooftop solar with new fees and deep cuts to the net metering credit.

I have solar panels on my rental house, covering 98% of the power, and solar panels on my new home that covers 35% of the power. I believe in the many benefits of solar.

With Sacramento County about to get a LOT of new homes build in the near future, and the fact that there's already supply and demand issues during this heatwave, why wouldn't you want all new houses to have solar panels to help offset their power requirements from your grid? Seems like you could support more houses with the same amount of power if you'd just allow each of them to offset the power requirements with solar. 


August 18 - Anonymous 

UNBELIEVABLE! As a citizen who has 18 solar panels on my roof, I can absolutely tell you that SMUD’s claim of paying me, not making any money off of me, is CLEARLY ABSURD!!! I pay a SMUD bill every month. The bill might be a little less than a non-solar user, but I am paying you nonetheless. SMUD credits me VERY LITTLE for the EXTRA ENERGY I send back to the grid. Just because someone drives a hybrid car, doesn’t mean they get a monthly $50 check for saving gas. That’s ludicrous. SMUD’s so-called study is just another way to cover citizen’s eyes from the truth. They want more money, period. To accomplish that, they must find sneaky ways to increase profits, including doing their own funded studies to assert falsehoods. DO NOT BUY INTO IT!


August 18 - Paul S.

Dear SMUD Board of Directors,

My name is Paul S. I am a solar rooftop owner and a member of the Solar Rights Alliance.

You really need to get on the ball with encouraging rooftop solar in the Sacramento and surrounding counties in order to help save our environment. There are serious gaps and problems in your recent study pertaining to rooftop solar energy values, which in turn, warrant further review and study on your end to help further identify specific benchmarks with assessing consumer value.

For example:

Problem #1: SMUD's solar study asserts that SMUD "pays" solar users even when they are simply making and consuming their own solar energy at home. The SMUD's study incorrectly purports that SMUD “pays” solar users a total of $25-$41 million a year even when they are simply making and consuming their own solar energy on-site.

This is clearly absurd. SMUD doesn't "pay" anyone when customers reduce their energy use. If this were true, it would also mean that SMUD is paying people if, for example, they: 

• Shut off lights or install energy efficient appliances. 
• Use an air conditioner with a built-in solar array and battery such that the unit is never plugged into the wall socket.

Here's what actually happens. SMUD credits customers for the extra energy they send back to the grid, not for the energy customers use on-site. The credit for this extra energy is the only “payment” at issue here.

Reducing electricity use from the grid is desirable behavior. It reduces the burden on the grid and makes it easier for SMUD to reach its goal of a 100% clean energy mix by 2030. No class of customers should ever be penalized or considered problematic for doing so -- whether because of solar, energy efficiency or reduced business operations due to COVID.

Problem #2: SMUD's solar study implies that rooftop solar's climate change benefits should not be valued SMUD's solar study and their accompanying website give the overwhelming impression that the value of solar is only $.03-$.07/kWh. This is misleading because it only captures a limited number of rooftop solar's benefits (namely the ways that rooftop solar allows the utility to avoid generating or purchasing electricity). 

There is another critical benefit, however: the impact rooftop solar has on reducing global warming pollution. The report quantifies this benefit as well. But it buries it in fine print and excludes it from all the topline charts and graphs. 

That is unfortunate and misleading. The fine print states that rooftop solar's impact on reducing global warming pollution (along with several other social benefits) increases solar's value by between $.02 and $.16/kWh. Combining the value of solar headlined in the report with the value of solar from reducing global warming pollution is likely to yield a solar value of at least $.12/kWh - considerably higher than the report's headline.

Putting critiques one and two together strongly suggests that rooftop solar actually provides a net benefit to SMUD, in contrast to the study's topline conclusions.

Remedy: Redo the study to include all of rooftop solar's social benefits, especially climate change benefits, in the topline calculations of solar's value. 

Problem #3: SMUD's solar study is not based on SMUD's new climate change goal In addition to burying rooftop solar's global warming benefits in the fine print, SMUD's study also is premised on SMUD's old, outdated climate change goal that assumed SMUD would still operate its five fossil fuel power plants past 2040.

Things have changed: the SMUD Board of Directors recently adopted a stronger goal to reduce SMUD's global warming pollution to zero by 2030. 

In fairness, the study was launched before the SMUD Board adopted its new goal. But the study has to be revised to reflect the new goal. To reach zero carbon emissions by 2030, SMUD must increase both large-scale renewable investments and local rooftop solar and storage beyond what SMUD currently plans for in its clean energy plan created in 2018 (called the Integrated Resource Plan), and on a faster timeline. SMUD will also likely increase its efforts to encourage customers to switch to electric cars and appliances. 
SMUD will need to increasingly partner with customers who want to install their own solar system to help the community meet these new goals, and that should get reflected in solar's value.

I hope that you take our concerns and comments as future considerations to help your constituents to feel confident with what you are trying to achieve. I signed up for solar rooftop many years ago in order to help ensure that future generations of the planet do not have to pay for our generation’s environmental mishaps and mistakes. 
Sincerely, 
Paul S.


August 18 - Lola P. 
I purchased my rooftop solar system about three years ago. In addition in to wanting to reduce my energy bills, a large part of deciding to go solar was putting my money where my mouth is. Climate change is destroying our planet and making it unlivable in certain areas, those areas will only expand. 
SMUD has committed to reducing their global warming pollution to zero by 2030, which means they will need to cease burning natural gas at their five power plants. They will need to expand their clean energy production and/or purchasing. Rooftop solar provides clean energy, it also reduces the cost of maintaining and expanding the grid. And it reduces pollution, especially climate change pollution. The only “cost” to SMUD from rooftop solar is the credit on the consumers’ bill when their system produces more energy than they use. SMUD and the state of California need more rooftop solar and battery storage to fight global warming and to help people keep the lights on during power outages. This is a way for SMUD to increase the amount of solar energy without having to purchase, install and maintain equipment. 
SMUD encourages their customers to reduce electricity usage by turning off light, purchasing energy efficient appliances and devices, setting their thermostats higher, and to not use unnecessary electricity during peak hours. Customers are not penalized for using these energy reduction practices, but SMUD wants to penalize rooftop solar owner who are also reducing their energy usage from the grid. Including the energy that consumers generate and use themselves is misleading, as no other customers are penalized for reducing electricity usage. The study should focus on what is sent to SMUD, not total generated energy. 
Your calculations and graphs for the benefits of rooftop solar leave out an important detail, namely impact rooftop solar has on reducing global warming pollution (only mentioned in the fine print). If you include the reduction of energy usage during peak times, the reduction in pollution, and the environmental benefits because rooftop solar energy is 100% clean and local, then this should be a win-win. Not something customers are punished for and should be factored into your report. 
SMUD's report concludes that solar's costs are greater than their benefits and suggests that rooftop solar should be discouraged going forward. However, the report contains several flaws as mentioned above that when included suggest that solar's benefits outweigh their cost and should be encouraged. Also SMUD’s report does not reflect zero carbon pollution by 2030. All of these factors should be included in the decision on the benefits of rooftop solar. 
Thank you, 
Lola P.


August 18 - Valerie Y 
How can this study possibly be correct? For my rooftop solar, I fronted the cost to instal it, I own it outright, and I sell back to you at the same rate you sell to me. In addition to the fact that at this time I buy more electricity from you than I sell to you, you also charge me connection fees and I volunteered for the your Green Energy program to help fund your investments in solar and wind power production. It is absolutely insulting and harmful that you are continuing to claim that somehow residential rooftop solar is so expensive to you. Especially in this time of heat waves and rolling black/brown outs when residents with rooftop solar are helping to lessen the needs of the grid as a whole. 
Please stop attacking your customers. There is more to the “value” of solar. It’s about each of us trying to do our part to lessen the impacts of our lives on the climate of this earth. It’s about doing our part to ensure emergency services can be prioritized during heat waves. And it’s about independence from carbon based energy production. 


August 18 - Gregory G 
Please see solar system as a resource and not a liability


August 18 - Jemahl A. 
Please support more consistent means of ensuring solar panel access for home owners and businesses. The current provision under review does not meet Californian’s needs in this regard.


August 18 - Sumeet B. 
I think this is a flawed study. I think it is unconscionable that a publicly-owned utility would be trying to discourage rooftop solar. We need to transition to renewables ASAP and rooftop solar with home based energy solar is hugely beneficial, especially with the grid issues California is having. I am a new SMUD customer and I want rooftop solar and vehicle-to-grid charging and I don't think it is right that SMUD is standing in the way.


August 18 - Anonymous 
With the rolling blackouts going on I am certain whoever does not have solar panels regrets it.
If we want to have a cleaner world we need them. 
Solar is a win for everyone except the sellers of obsolete technologies 


August 18 - Anonymous 
This study fails to take into account the value rooftop solar provides during those times like our current extreme heat wave when SMUD cannot meet the excess power demand on the grid. 
My family has rooftop soar in Woodland and a Tesla PowerWall battery that allows us to disconnect from the grid during power outages and rely solely on the energy we produce. 
The microgrid backup plan that rooftop solar customers can provide add stability to the greater power grid as excessive heat events become the norm, rather than the exception. 
As we approach the tipping point for guaranteeing the early demise of human and animal habitation on Earth, due to our ongoing filthy energy choices, pulling in any direction but towards clean, sustainable energy is choosing no future at all. 
Do the right thing now. Stop promoting armageddon in a bid to line your own pockets now. 


August 18 - Anonymous 
Solar on every home is very beneficial to everyone, and there should be fair net billing, better credit for net producers from solar, and no additional fees for having solar.


August 18 - Kweku S. 
Solar is the best energy saver for me and my family.


August 18 - Theodore M. 
SMUD costumers that have already made a commitment to solar by installing systems in their home made that decision based on the rates at that time. A change in rates or a fee would change that unfairly to the costumers with solar and reduce the adoption of further adoption of solar as well as batteries and micro grids, that could only help SMUD and the community.


August 18 - Anonymous 
We lease our Solar System and already pay over 12cents/ kWh. We are sure that there are a lot of customers who are doing the same thing. How will you make this NEM equitable for the customers who lease? We seem to only get ahead during the summer months & that's because we bought a new Heat Pump that we are paying a SMUD Loan for. If we are already paying over SMUD's Rate & we get hit with a higher NEM cost, what good did it do us to get a Solar System in the first place. We will be paying more per kWh each year than customers without Solar. The whole reason for Solar was to help save the environment. Now your telling us(Solar Leasers) we have to pay more than customers who do not have Solar. It seems you need to separate the customers who bought their Solar outright & got the rebates from the Solar Leasers who couldn't afford to buy System & are paying as much or more per kWh than customers without Solar. You must have records of the Solar Leasers as we had to get SMUD's approval to have the company put the System in. I know it is different paperwork for Leasing than buying. SMUD should not include Solar Leasers in the new NEM costs as we already pay the going kWh rate. 
Please let us(Solar Leasers) know what you are going to consider for us. We have given you our extra kWh at your same rate so we should be compensated accordingly. 
Thank you for reading this & please be equitable for all your customers.


August 18 - Anonymous 
I am a solar customer I do not generate more than I use. I just expect watt for watt trade that is why I got solar. This study is unfair to the solar customer. It says nothing about the investment we made in the solar systems. 
If this is about the cutomer who generates more kwhs than the they use at the end of the year. Than I agree that they should be paid the supply rate. 
But to buy a kwh from a customer at a lower rate and sell it back to the same customer at a higher rate is completely unfair. 
The non-solar customer did not shell out the 20,000 to 50,000 or more dollars to get the solar systems. It takes ten or more years to pay for itself. So for the non-solar customer they are not paying an out of pocket expense more than the solar customer. 


August 18 - Lee M. 
The E3 report is not based on SMUD's new climate change goal which was voted on by the board in July. This was a landmark move by the board and the study does not take the SMUD Climate Emergency Declaration. 
The Declaration has adopted a stronger goal to reduce SMUD's global warming pollution to zero by 2030. Therefore the data in the report is old and useless. 
The E3 study was launched before the Declaration was adopted, but with the new goals which are to reach zero carbon emissions by 2030 which is a very short timeline, SMUD must increase both large-scale renewable investments and local rooftop solar and storage beyond what SMUD currently plans for in its clean energy plan created in the 2018 IRP. 
SMUD will also likely increase its efforts to encourage customers to switch to electric cars and appliances. 
There are other social benefits as well that Rooftop Solar brings to the table, but climate change benefits are huge. 


August 18 - Jeff T. 
First, I would like to commend SMUD board of directors on the recent decision to reach carbon zero by 2030. The climate emergency is real and it requires leaders like SMUD to take drastic action to make a substantial difference. 
However, I am a SMUD customer with rooftop solar and I have been VERY disappointed to see SMUD's constant attacks and castigation of its own "valued" costumers with rooftop solar. It is clear that SMUD is facing difficulties balancing their infrastructure demands in a changing climate (environmental & economic). 
Instead of blaming solar costumers for their proactive efforts to fight climate change, SMUD should be doing more to promote and incentivize the use of solar + battery storage. This will help reduce back-and-forth demand on the grid, reduce peak grid power demand and improve solar-to-home and home-to-grid efficiency. Residential battery storage would greatly benefit the costumer and ease demand on the grid yet SMUD barely even mentions it! SMUD should be using their resources and efforts to solve this NET metering problem by significantly encouraging its solar costumers to add battery storage (instead of accusing them of stealing hard earned money from their neighbors). SMUD can use this opportunity to actually solve many of the problems that are being blamed on solar costumers. 
According to the 2018 Power Content Label published on SMUD's website, the primary source of electricity produced by SMUD is from natural gas (54% natural gas vs 2% solar). SMUD cannot meet their 2030 zero carbon goal by demonizing its residential solar costumers and blaming them for abusing the non-solar costumers. Is it really SMUD's plan to discourage residential solar and require their costumers to rely even more heavily on natural gas in order to make it easy to manage the grid? 
SMUD is being disingenuous and harmful in their marketing and I demand that the board of directors hold them accountable. The climate emergency requires drastic and difficult changes to our energy production and use. I ask that the SMUD board of directors use their decision making authority to embrace long-term change instead of short-term protection.


August 18 - Dominique 
Rooftop solar should be implemented in every facet of the world and not doing so is a crime against humanity.


August 18 - Dennis M. 
SMUD was suppossed to be a good actor when compared to PGE. But your attacks on individual solar installations are proof that you value your power over the little guy. 
Enough with your fudged numbers and twisted rationale. You should be embracing a smaller SMUD with more distributed rooftop energy. Instead, you are clinging to your bureaucratic power. Get over yourselves and give people the right to be energy independent. Instead you limit the number of panels, reduce credits, try to impose fees, etc. You are attacking solar rights while the world heats up from greenhouse gasses. You should be embarassed. 
You need a change of course and leadership. 
Leave my solar credits alone. I paid a lot of money for that system and I have no intention of subsidising SMUD. Look inward and see how you can reduce YOUR footprint and ENCOURAGE distributed solar usage in this climate crisis. 
Dennis M.


August 18 - Larry M. 
I urge you to read and put into practice what Greta Thunberg wrote in her book "No one is too small to make a .difference".
I have solar on my rental house in Sacramento and my primary residence elsewhere. I drive an electric car to cut down on my CO2 emissions. 
We need to go to 100% solar, not restrict it. Yes, that means you will go out of business unless you find a way to also generate solar power instead of CO2 emitting power.


August 18 - Colleen D. 
Dear SMUD 
We have found extreme value in having a Solar system added to our home, We have helped with going green, lowered our electric cost and this cost helps us stay in California! It adds great value for resale when we do decide to sell. The Solar system has been flawless in its performance. Tax breaks and low-interest financing have worked great too! 
We need rooftop solar in this state with the great solar power we have. All homes, and commercial buildings should be capturing the suns power and SMUD should continue to support all its solar customers. 
Sincerely, Colleen and Randy D.


August 18 - Daniel D. 
I've had Solar power for over three years now and am enjoying the low rates and almost no electrical outages. With NEM, it makes it even less costly. 
However, if SMUC reduces the NEM or increases user fees, then the homeowners suffer for problems that likely will never come up with SMUD. 
It seems as if SMUD is doing its best to discourage or even eliminate the use of Solar power. Renewable energy is eventually be a necessity of life - oil and gas sources are not infinite. SMUD needs understand that most homeowners need electricity at low cost, what with the now rampan Covid-19 eliminating jobs and impacting the economy.


August 18 - Don A. 
I find that some of the points made in the study are inaccurate and misleading. In my case, I installed solar in 2015 and was only allowed to install solar with an output less than 80% of my average use of electricity. A couple of years later I installed a swimming pool which drove up my power consumption significantly. SMUD credits me a small amount of money for the occasional occurrence of generating more electricity than I consume. My annual net metering bill is when the dollars are paid for the substantial amount of electricity that I consume annually. 
When I was sold solar, I believed that my investment allowed me to be helping the environment, helping the grid by offsetting some of the load when hot weather makes the grid heavily loaded and credited some money back when my small solar plant gives SMUD more than I can consume. I still feel that my choice to go solar was the right choice. I feel that SMUD should have allowed me to install more than I was able to install at the time as my system would be even more productive. 
I am told by fellow solar users that the devil is in the details of the report that is being reviewed. Please review the details and don't be swayed by inaccurate and misleading representations that solar customers are bad for SMUD and that SMUD's costs are excessive because of solar customers. 
What would I do differently today? Wait until I installed my pool to install solar? No, I believe that any amount of solar that helps to offset monthly utility expenses is good for the customers and good for the SMUD user community.


August 18 - Brian L. 
It seems that you are still trying to penalize solar customers for doing their part to reduce the impact on the environment. Petroleum is not going to last forever. Instead of fighting against the inevitable you should be investing in more renewable energy yourselves and not discourage consumers from purchasing renewable energy systems by increasing the charges for solar users.


August 18 - Nancy C. 
Hello, I am a long time SMUD customer and I am concerned about your lack of support for rooftop solar. We need more alternative energy sources, not less. SMUD says they pay solar users even when they are making/using their own solar energy on site. Please do not misrepresent the facts. In reality I own a credit when I am not using energy. After all I am reducing use on the grid. We all know that using rooftop solar reduces global warming pollution. Please state this clearly not undermine or ignore the reality of this. Your so called “study” is flawed and your study was done before you adopted a stronger goal to reduce the global warming pollution to zero by 2030. Your study needs to be revised and reflect the reality of the goal. It is extremely discouraging to customers when you talk about “lost revenue” and you have to make this up somehow. Yes, you should be able to recover fixed costs but not by penalizing customers who reduce their energy use. You need to change your rate plan to help with the fluctuations in energy use. Plan ahead so that you can move forward addressing climate change. Don’t show us you are “stuck” but instead show customers you are innovative and pioneering as we face these significant and ongoing energy challenges.


August 18 - Anonymous 
I would like to express my opinion on Rooftop Solar. 
1. Solar produces the clean energy and it is more helpful to the environment on the long run.
2. Currently, there is a heat wave going on in Sacramento and it causes a lot of burden on the grid to produce electricity for all of its customers without any power outages and having the rooftop solar is very helpful to keep up with the demand. These heat waves etc are not just one off scenarios and might be occurring time to time every year. 
3. Not every solar customer is producing enormous energy using the rooftop solar. There are customers who are paying 70-80$ a month as the electricity bill during this summer despite having a roof top solar. 
4. I always believed, having a rooftop Solar is a benefit/advantage for any home and companies like SMUD and discouraging this will negatively impact the customer’s and the global environment. 
I hope everyone will still have the right to produce their own clean energy using rooftop solar! Thank you!


August 18 - Corina P. 
Please stop messing with solar! Solar is good for us and good for the world. Hands off!


August 18 - Patrick D. 
Repeatedly we have seen in recent years that SMUD is attacking the value of solar. Most conspicuous in it's absence has been any allowance for home battery storage. It's almost as if SMUD is actively discouraging those who want to pursue this, or even refuse to acknowledge it in their studies. But why would that be? 
No sooner do we read that SMUD is trying to tell us that this is ineffective or cost prohibitive, we read that SMUD is doing a study on how THEY can be the ones to supply the battery storage. For a price of course. And also that they would be in control of the batteries. 
Twelve Wing Productions has done a year long study of how a solar and battery equipped home would perform in the real world called "The Energy Sovereignty Project". The result of this project (10.2kw PV + 82kwh battery storage) was that for over 9 months out of the year we used nearly no power at all from the grid in a home that averaged 36kwh daily over that same period.
Because we were using large capacity at home battery storage, we reduced the overall in and out load over solar alone by over 95%. 
This never gets mentioned by SMUD because that aspect of this is inconvenient for them. Not only do we severely limit our need for net metering, we supply power at SMUD's most critical time... summer peak. 
In addition to the home use, we were able to drive just over 10,000 miles on SPARE sunlight. That is to say that by controlling our storage and utilization of power at the home itself, we were able to do nearly all our driving from March through late October on locally stored energy. 
So where is SMUD in support of batteries? Why aren't there exemptions for these fees for battery powered customers? 
The reason we are seeing SMUD silent on this is because they, themselves, are looking to capitalize on this. The last thing they want is for all of you to do what The Energy Sovereignty Project home did and reduce your total usage of power by 98% while at the same time reducing the load on the grid as a whole by 80%. 
SMUD desires to keep your dependence on them at 100%. That much is clear here. 
Stop ignoring the batteries. The technological advances in battery storage that have occurred in the last 5 years and that are ongoing will mean that cost effective home batteries will be available to all consumers at affordable costs. 
Honor your solar and battery customers. Truly look to the future of power management. 
Thank you for your time and attention, 
Patrick D.


August 18 - Stacy K. 
Hello SMUD Board: I have read the Value of Solar study and I am shocked once again by this short sided study. We are original Solar Pioneers and have loved the system that we had for over 20 years (we recently replaced it due to an addition to our house). SMUD has been a rooftop solar leader for over 20 years and now seems bound and determined to lead us back into the dark ages. Instead of celebrating rooftop solar you are doing everything you can to disincentivise more rooftop solar, which frankly should be on every rooftop in the Central Valley. 
SMUD claims they pay customers when they reduce their energy, no they don't and that argument doesn't hold water as then it would mean you are also paying people who reduce their energy by using LED lights or installing energy efficient appliances. SMUD does not pay me to make my own energy it just credits me when I send excess energy back to the grid which seems like a win win to me. Reducing electricity from the grid is something we should be happy about and strive for. It reduces the burden on the grid and makes it easier for SMUD to reach it's new stated goal of 100% clean energy by 2030. 
The impact of rooftop solar has on reducing global warming is so very important. Your study does not include all of rooftop solar's benefits. 
The solar study does not include information about SMUD's new climate change goal. We were so delighted when the Board decided to adopt the new goal of 100% clean energy by 2030, to do this you need rooftop solar. 
In conclusion, we became Solar Pioneers to become part of the solution to a huge global problem. SMUD gave us that opportunity and we have touted the great leadership at SMUD ever since. We have encouraged our friends and neighbors to get on board. One of the benefits now, is the solar credit to our tax bill. This is huge and needs to be continued. 
PLEASE redo your study and stop seeing rooftop solar as a problem and get back in the mindset of it being part of the solution to the very real climate change. 
Sincerely, Stacy & Phil K.


August 18 - Geoffrey E.
There are 3 major problem with SMUD's "Value of Solar" study.
First, this study asserts that SMU pays solar users for power that they are generating and using at home. The study incorrectly claims that SMUD pats Solar users "$25 - $41 million per year. However, this is power that is produced and consumed in situ, reducing demand for power from SMUD at no cost to SMUD. Energy conservation costs SMUD nothing. Only extra energy sent to the grid is given a credit. This credit is the sole form of "payment."
The study should be repeated, excluding all home solar generated power that is consumed in the home. It should be completed using only that power that is sent to the grid unused by the home that generated it. 

The second problem is that SMUD's solar study implies that rooftop solar's climate change benefits should not be valued more than 3 to 7 cents per kWh. The study only includes a few of rooftop solar's benefits. One key benefit is hidden in the fine print and does not appear on any graph. If the value of reducing global warming pollution is included, the calculated benefit should be closer to 12 cents per kWh. 
The study should be redone to include all of rooftop solar's benefits including the reduction of global warming pollution.
The third major problem with SMUD's study is that it is not based upon SMUD's own climate change goal. The study is predicated upon SMUD's obsolete goal of running fossil fuel generation past the year 2040. SMUD's Board of Directors has adopted a more ambitious goal of reducing Global Warming pollution to zero by 2030. The study should be redone to reflect SMUD's climate change goal. 


August 18 - Brett 
Seems to me that instead of encouraging solar SMUD is determined to discourage new solar customers which is not in keeping with their pro-environmental stance. It is a thinly veiled attempt to cast solar customers as the bad guy,as not paying their fair share. This is an attack not only on solar customers but on the environment itself. Please STOP! 


August 17 - Lee M. 
Dear Board Members. 
The following is a contributed article by Arlen Orchard, CEO and General Manager at the Sacramento Municipal Utility District. https://www.utilitydive.com/news/study-shows-value-of-california-solar-with-statewide-implications/583185/ 
Wonder if you all saw the article in Utility Drive today. Sure makes it look as though the cahoots with Arlen and Sr. Staff. Does this violate SMUD's Code of Conduct SD-12, specifically points to the "honesty policy,"
Looks as though your CEO/GM and Executive staff are doing their best to destroy Rooftop Solar with the E3 report which we know has flaws. Why is this study being touted as being a done deal? Why is the board continuing to let the outgoing CEO/GM and Executive Staff act this unprofessionally? And once again Arlen and executive staff make it "us vs them" making the board look very bad. 
I would like to know what the next steps are to get the CEO and staff to follow the procedure that was agreed on instead of spending time figuring out how to go around the agreed-upon procedure. I would also like to know, how the board is going to fix the damage done by the CEO and staff. Will, you put the process on hold until the new GM is in place and Arlen is gone? I am skeptical that if an internal candidate is chosen, that things will be any different. Changes in culture need to be made at SMUD and made ASAP. We don't need another Arlen Orchard in charge, who will continue to act in this sneaky, dishonest manner. 
At this point, Rooftop Solar, Rooftop Solar + Storage will never be perceived as being valuable since SMUD has widespread influence in the industry. It is not only in Sacramento but throughout the USA and even the world. 
Thank you Board and I hope to hear from you soon. 
Lee M. Ward 3


August 17 - Anonymous 
State policy is still, last I heard, to do net metering and encourage rooftop solar. Yes, I understand that you don't like that, and would rather buy solar only from utility-scale facilities (preferably that you own). Your little fight with the Energy Commission over selling utility-scale PV power to builders instead of accepting the state-mandated rooftop power shows that clearly. 
If the issue is fixed charges, you could adjust the amount of that on the bill - yes, there's a connection charge on all bills that has to be paid monthly, including by solar customers, though your comments conveniently ignore that. 
If the issue is reduced power purchase, well, any form of demand reduction will do that including improved building and appliance efficiency (which I note you have also largely discontinued support of). If your pricing structure doesn't reflect that, you have a problem that rendering distributed renewable power unaffordable for owners both prospective and existing won't fix. Thanks for stranding my asset, purchased in good faith based on your program at the time I got it. 
I have solar. At the time I bought it (less than a year ago) the expected payback based on TOU rates was 9-10 years (up from 7-8 for the prior fixed rate). That was acceptable. With the change you're proposing, the payback period approaches infinite - beyond the useful life of the system. 
Look beyond the end of your nose. This is not just a rate-setting issue. This is also a system management issue. Yes, it's inconvenient to deal with a lot of little generators distributed through your system. But it also has benefits, reducing the need for high-capacity transmission lines. One management point might be that you need more storage to deal with variable power inputs scattered around your system. Forcing that on individual system owners by eliminating useful payback periods won't help your grid usage much - in fact, it could end up costing you if a bunch of homeowners band together and start selling "grid stabilization" using their batteries. You could do that, along with rate arbitrage, yourself as a system service that solar users could pay a fee for. 
You do mandatory TOU now. Most solar is "bought" by you at off-peak or mid-peak rates and "sold" at mid- or top-peak rates. Those who don't have solar are getting the benefit of your not needing to purchase spot power during the day. There is a value to that. 
And finally, this program places you in a leadership competition with San Diego Gas & Electric, among California power systems, for discouraging rooftop solar through rate evil. Not good company.


August 17 - Andrey K.
There are so many problems with the independent study. 
1. If the "actual value of solar on the market" is $0.07/kWh rather than $0.12, I am committed to be selling my electricity at that price, but then in turn I would expect to be able to purchase kilowatts at the same price. This would apply the market forces on me and SMUD to invest into battery/pumped storage, and that's the only way to reduce carbon footprint. I dismiss the notion that my solar system's output is worth only $0.07/kWh in summer afternoon when it retails at over $0.20/kWh 
2. The drawing with "back and forth interactions" on the grid requires an elaboration. If (hypothetically) my solar system produces exactly the same amount of kilowatts as my household uses, the total net flow would be exactly the same. How come the electrons moving in opposite direction in the wires create "more usage of the grid"? 
3. The claim from the info page that "A large part of our fixed costs to serve customers are collected through energy use charges" is totally valid. Let's adjust it then. Are the fixed costs for infrastructure more than $21? Let's adjust that, but not just for solar owners! SMUD is all about transparency? There's is no better way to improve transparency then clearly stating where the expenses are. This would also greatly improve our community's ability to see where the costs are and where to look for efficiency bottlenecks 
4. The word "fair" is repeated multiple times on the study presentation page. Fairness and social justice are important things, but it's wrong to use them in the context of "Getting solar right" study. Those are completely independent issues. Current state of solar industry tells us that it's not rich people invest in solar, it's the ordinary people who think ahead. 


August 17 - Anonymous 
The report seems to take ratepayer benefits and clean energy benefits separately, but surely these benefits are accrued at the same time and the benefits can be added together.


August 17 - Anonymous 
Many solar systems are being installed as a requirement from the State of California in new homes. Homeowners have no choice on this purchase. SMUD should have rates that allow the homeowner to recoup the cost of the system (embedded in the home purchase price). If that is less than the benefits to SMUD, SMUD should look to the state for reimbursement for this state requirement.


August 17 - Anonymous 
We purchased our rooftop solar with the commitment of a guaranteed purchase amount of our production of energy from SMUD. This was a huge factor in our decision and important to continue as we pay for our solar equipment purchase. We want to help with energy production and feel we shouldn’t be penalized by a lower rate for our energy contributions. Thank you.


August 17 - Megan S. 
I think your study has serious flaws. 
First, you should not use the behind the meter/or lack of use of SMUD electricity as any part of the evaluation of the value of Rooftop Solar. If I just turned off my lights and appliances, insulated my house, bought LED light bulbs, and conserve energy, you would not be out there with your propaganda telling the public I was costing them money! I am highly offended and think your position on this is despicable! 
Second, I have to wonder why this report is so different than the one given to the Public Utility Commission by this same group. The only reason I can think of is they had metrics and directives given to them by the SMUD Administration. 
Third, Any value of energy bought from any other producer is known to vary over time. SMUD has not made a clear case of the value of energy, now, in the past or in the future. Make that case, then we can discuss what SMUD should pay for energy. 
Considering the recent record-breaking heatwave, it is clear that unhealthy air days are part of the way we currently produce energy. Also, Rooftop Solar and Battery back up would only reduce strain on the GRID, even if not one watt of electric power was sold to SMUD. And yet Rooftop Solar is producing power for the rest for California to use. I venture to say if people who feel their roof is too shaded for solar panels were to install a backup battery, they could save energy to use at a higher rate time of day or in a rolling blackout situation. You must feel your consumers are ignorant if you expect them to swallow your propaganda. Maybe some are, but many are not and will be just as outraged as I am about the page from which I am sending this comment. 
I demand you take down this false and misleading page that slanders rooftop solar users and misleads the public on energy matters. I am NOT proud of the way SMUD is doing business at this time. 
Signed by a proud and lower-income Rooftop Solar Owner. 


August 17 - Anonymous 
Your premise and your so called “independent firm” fail to take into account the premium the self generating household provides SMUD. The excess power generated helps offset the load that SMUD needs to generate during the peak periods. Their is a premium value during that time that would average out to your so called premium and offset what you called unfair share that non-self generating customers are burdened with. Every customer pays a connection charge which is their share of the burden of the connection to SMUD’s grid. Any other fee or cost charge or under payment to the self generating household is essentially a double charge or an unjustifiable fee.


August 16 - Tina L. 
I would like to know how you calculate “excess generation” and decide you are paying “more than it is worth” given what you are charging during peak and super-peak. I would also like to know if the costs for the homeowner (installation, panel life, inverter replacement, etc.) is included in your calculations. Solar early adopters have incurred costs and risks because they thought it was the right thing to do for their community and the planet. How is this, or is this, factored in? Please provide a detailed explanation of the assumptions that went in to the study.


August 16 - Dale P. 
The E3 study has a major drawback and a few less critical issues. 
1. Customer solar generation is analogous to energy conservation with the caveat that its benefit is only semi-predictable, which increases the cost of overall system resilience and reliability. 
E3 assumes that SMUD should be compensated at the retail rate for the energy demand it does not experience due to customer solar generation behind the meter. This assumption skews the analysis to cast customer solar in a less favorable light. The utility seeks to encourage energy conservation from its customers through several programs and initiatives. Solar generation actually falls into the category of a type of demand/energy reduction measure 
The cost to the utility should be calculated as the payments to the solar customer for their net exports of energy to SMUD, minus the value of deferred energy/capacity generation and transmission costs saved by all customers for non-exported customer solar generation, plus an increased resilience and reliability charge to adjust for the fact that customer solar generation is only semi-predictable. 
Without correcting this misstatement SMUD’s claim that customer solar is radically unfair to the general customer is susceptible to skepticism. 
2. E3 does not recognize the distinct possibility that low market prices may be corrected by technological and market changes; for example, new types of energy storage and uses like “green hydrogen”. 
3. E3 seems to undervalue the social cost of fossil fuel pollution and greenhouse gas emissions by using a value of >= $.01 per kW for 2020. I have seen values > $.02 and up to $.08. 
The study provides some guidance about what a fairer solar compensation rate may look like. 
• Solar customers should be paid something between the market value and retail value of generation at the time they export energy to SMUD. This will place the customer motivation on energy and environmental conservation rather than system cost recovery. However, the life-cycle cost of the system will likely be approximately zero when energy/demand and reliability concerns are carefully considered. 
• SMUD rates should more effectively partition fixed and variable costs. The solar customer should pay the fixed costs they engender outside of the solar export remuneration, be rewarded by the variable costs deferred and charged for the variable costs such as semi-predicable resource resiliency. 
• The SMUD restrictions on allowable solar capacity should be relaxed to recognize that customer demand may be quite different in the future due to electrification and new uses like EV’s. A focus on energy/demand and environmental conservation in the NEM.2 rates will make sure that systems are sized properly by the customer who will be assuming the risk of over optimism. 


August 15 - Steve 
As others have already stated, you don't seem to be taking into account the $20+ monthly fee solar users pay for the privilege of being connected to the grid in addition to our usage - this fee is already greater than your largest "unfair" amount to non-solar users of $90/year in 2030. 
Any change that you do make should only impact new solar users, and should be fully disclosed to them so that they have the information necessary to make an informed decision (as we did when we purchased our solar). Current solar customers need to be grandfathered into the structure that was in place when we made the financial decision to make such a large investment. 


August 15 - Jill B. 
When you refer to "retail value", is this the price SMUD pays for energy on the open market or is it the price SMUD charges the consumer for buying power from SMUD...equating a simple pass through of cost? If the retail value is open market & that market is a lower cost to SMUD then it does not make sense for SMUD to pay the consumer more...


August 15 - Daniel E. 
Shame on you SMUD for demonizing your customers, and shame on you E3 for your industry pandering and selective analysis. David Freeman must be rolling in his grave at the way SMUD is so quickly destroying his legacy and attempting to dethrone yourselves as forward-thinkers and innovators in the utility industry. And even a cursory review of this study by Sachu Constantine of Vote Solar suggests that E3 is selectively devaluing/disregarding stats depending on who is paying for the study. Perhaps if solar customers got together and paid E3 for a study the result would be a glowing analysis of the net-benefit of solar for the power grid? SMUD, the commoditization of distributed energy generation and storage could be positive for SMUD’s future, yet customer-hostile approaches, like those captured in this website, and selective analysis, reveal a narrow corporate viewpoint that is stuck in the past. You can do better.


August 15 - Austin A. 
Pay Solar users 7 Cents per KWH, but Charge more than double that to sell the same power to the neighbor on the grid? Curtailment is a failure of operators to cut old pollution sources of power when its not needed by base load contracts, cut those nasty contracts. 
We all pay a fixed grid fee already, so It confuses me how if this is implemented will my fixed grid fee go down if I dont have solar? You cant charge for grid access twice. 
This makes no sense, keep the incentives for solar SMUD. 


August 15 - Gurprit R. 
The report is very one sided and should also take into account for the rate smud is charging. Smuds rate is higher when compared to other places. Roseville Electric rates are much lower then our rate. Step up Smud.


August 14 - Anonymous 
This is a grossly one-sided presentation on the SMUD website. The benefit of solar to society are essentially not mentioned whereas the "costs" are bizarrely presented so as to somehow argue that energy received should not cost the same as energy generated. Even if this presentation was accurate, which is hard to accept given its one sidedness, solar SHOULD be subsidized even more than it is currently until every dwelling has their own power generation and storage. This includes everything from low income multifamily dwellings to large single family estates.It is grossly inappropriate to try to split solar versus non-solar customers as the goal should be getting to 100% solar. I am gravely concerned that this presentation represents an attempt by SMUD to maintain a monopolistic control with centralized power generation and that should never be the goal of a "community owned" utility. SMUD's desire for control should not outweigh environmental concerns and consumers' ability to maintain independence from that control. 


August 14 - Cory C.

The methodology of this study is outright ridiculous because it counts lost revenue and not just comparing the price of energy sold to the utility to the price they sell energy to customers. By this logic, people with efficient houses should have to pay larger energy bill else they unfairly contribute to the cost for other customers. Removing incentives to invest in clean energy because they're working at reducing demand for dirty energy and therefore making dirty energy alternatives less competitive isn't a problem it's the entire point of the program.


August 14 - Anonymous

As a recent purchaser of rooftop solar, I resent this characterization of those who are giving you power (on the margin) as essentially stealing power. Your own "true-up" rate shows how little you actually value the produced power - less than a nickel/kwh. And your Time of Use system for net-metering based on value vs. kwh is essentially a "buy low, sell high" system with almost all of the power produced at off-peak or mid-peak rates.

You further show your colors (hello, SDG&E & friends - when are you planning to quadruple your CEO's salary to keep up with the private utilities?) by only using solar+storage in your comparison graphics; because of their excessive cost, the generally high reliability of power in SMUD, and SMUD's reasonable rates, those systems don't have an actual payback period in SMUD - but they *do* generally take the owners "off the grid" entirely. Most current solar installations don't do that, but cutting the rate offset significantly will push more of us in that direction if we can afford it (I can't; many probably can) because ordinary grid-tied solar will be priced off the market.

On-site solar normally is a load-reduction measure if sized to meet your current interconnection standards. That REDUCES your system cost. Yes, I'm offended not only by you coming out with this, but the way it's presented. Unfortunately, I also understand that there's nothing the solar owners can do about it, since SMUD is unregulated. Thanks for rendering my solar installation valueless.


August 13 - Anonymous

Thank you for confiscating over $10000 of my money by rendering rooftop solar valueless. The purpose of it was to control my escalating (as you raise your - unregulated - standard rates annually in an attempt to become PG&E-lite) summer electric bills. This eliminates that, takes my power, and still gives me $200/month bills in the summer (and that's with high efficiency a/c and other improvements. SMUD just lost any credibility they might have had as a community-centric organization.


August 10 - David S.

The study is only of value if SMUD accepts the bigger picture reality instead of trying to protect its existing business model. The current SMUD policies artificially restrict rooftop solar growth and therefore are actually slowing solar growth in CA and causing more damage to the environment, as well as costing money to those consumers who want larger arrays and are using more electricity due to having electric cars. I was absolutely shocked to see that SMUD is MUCH more restrictive on solar permitting than PGE. It's ridiculous and so again, the study is worthless unless SMUD changes its position on artificially restricing rooftop growth. 


August 7 - Jay

It feels pretty disingenuous to take a draft study, spin it as propaganda, and post misleading conclusions on a public site. 


August 7 - Casey

You statments are not correct. Solar customers do not get paid the rate indicated. The rate is much lower. The rate vary by time of day, just like the rates charges to non solar customers. If solar customers do not produce enough power at peak and summer peak peak, they get charged the the same peak and summer peak rates as all customers on a time of use plan. SMUD requires all solar customers to be on a time of use plan. Non solar customers can choose different plans that are not available for solar customers. Also solar customers are charged a connection fee every month, even if they don't consume power from SMUD.

The current rates are fair to all customers. The customers that paid for solar installations help save cost to SMUD by reducing power consumption at peak power demands. This saves SMUD and non solar customers. If solar customers did not install solar, then SMUD would need to increase power production or purchase power from another power company at peak demands at higher rates.

Please revise your false statements and show all customers what solar customers get paid and pay SMUD.

Casey


August 6 - Chad E.

I am a homeowner who bought a home that was completed in early 2020 at a time when solar was required as part of the home purchase due to state laws that took effect in January. For those of us in that situation, and even those that made a choice when it wasn’t required in the years between the closing of NEM 1.0 and now, I believe there is a case for grandfathering us on a basis either close to the NEM 1.0 or somewhere reasonably close to it. Significant adjustments to the rate structure should be forward looking, once options are available such as purchasing 100% solar through SMUD are considered to meet the state requirements.

The foundation of this comment is one that appeals to the economics that apply to those of us who have had to install solar after the expiration of NEM 1.0. My experience with solar just from January to today and estimated through the end of the year suggests that I will realize about $750 of total savings (based on valuing both the solar I generate and use myself, and that which I sell back to the grid, at the TOD rates in effect at the time of the generation). I have been tracking it carefully. Given the money invested in the system, I will have about a 21 year pay back on the system, which is longer than the expected life of the panels. I wish I had other options that were more efficient at the time of buying a house, but these were not available. If the compensation were to drop by nearly half, many of us would never come close to recovering the investment in the panels we were required to install.

Please consider some transitional approach that includes providing good options to those who in the future may decide to meet state requirements by purchasing a product from SMUD that fulfills that requirement, while also allowing for full knowledge of the approach SMUD will take with them if they pursue their own rooftop solar instead. A fair comparison can be made at that time, and tradeoffs considered. For those of us caught in the gap, the cost of your decision to raise rates dramatically would be quite harmful.

Chad E.


August 6 - Rick B.

The “study” has not been vetted by anyone but SMUD staff…this is the worst example of misleading and poor public process I have ever seen. And to pit solar customers against others is the kind of divisive politics associated with our current “President”. Shame on you.

Best regards,

Rick B.
San Francisco


August 5 - David W.

Very inappropriate for you to pit customer against customer. You are building a tower of bad faith examples.

I could and will be citing examples of how this page’s analysis is skewed. Just for starters, it’s not solar customers’ “fault”, any more than it is energy efficiency customers’ fault, that they buy less energy from SMUD. It is not solar customers’ fault that SMUD fails to correctly account for grid costs in its fixed charges. Yes, those charges might be a burden to low income customers – so create a cost structure that gives them a break, don’t demonize solar customers to your own ends of convenience.

I urge you to take this page down immediately and consider your words more judiciously. If not, I will consider it more in a growing list of examples of bad faith, and you will be hearing a very great deal more from me and others.

David W.


August 5 - Lee M.

To Whom it may concern

I just saw your webpage https://www.smud.org/FairSolar

How is it fair to pit customers against customers? It is not only inappropriate but also shows bad faith. The SMUD marketing machine once again shows a lack of faith. Attacking Rooftop Solar when there has been no response from those on the SMUD Valuation Technical Workgroup on the numbers. I was on that team and we were told that the process would be transparent. We were never told that this customer-facing webpage as part of the deal. So dishonest and sneaky.

So how will people wanting to be on the Community Group give their input when it looks like the E3 report is a done deal. Insulting

Please take down the webpage ASAP

Sincerely

Lee M.
Ward 3
Rooftop Solar Owner


August 5 - David O.

You can’t be serious. We invested $35-40,000 on solar based on all the talk about “reducing our carbon foot-print” and helping with the increasing energy needs that SMUD would encounter in the future. We did so to” save our planet” and now that seems to have been a lie! We spent this money knowing that it would be a 25-30+ year payback but did it for the above reasons. The non-solar people did not put out that amount of money! Now they are complaining because they pay more on a monthly basis? The proposed rate changes should not be implemented or you will turn your backs on people who did the "right thing" only to be burned!

David O.


August 4 - Peter G.

Hi, we have had solar on our rooftop here in Elk Grove since 2012. We are one of the few households in SMUD's service area that consistently produces more electricity than we consume (we have 33 roof panels). When we receive our annual settlement statement in August or September, we are compensated for excess production at WHOLESALE (your cost of production) rates, not RETAIL (as your email claims). There is a huge difference; we are compensated at less than 6 cents per kilowatt hour in the form of a credit, versus the retail cost of the electricity we avoided using from SMUD which is mostly in the peak hours, closer to 15 center per kilowatt hour.

Am I missing something here? It seems that your statement is inaccurate. You do not credit retail charges for excess solar production; in fact, you credit your wholesale, which is what is would cost you to provide the same electricity per kilowatt hour.

Please contact me because I do not understand your reasoning here. Our land line is ***-***-**** and our email is ********@*****.***. Thank you! - Peter G.


August 4 - Candice B.

My concern is that I bought my solar system in 2018 with the impression that my savings would be enhanced by selling my excess energy back to SMUD at the same prices that I am paying. If you reduce that by 50-80% to make rates "equitable" you have just made my system less cost effective. I am not sure any decrease in the rate I am paid is necessary--the electric access fee that SMUD charges are there to cover infrastructure costs.

Solar generators (BTM) are not paid .12 per KW for all their energy production -- it varies by time of day, just like energy charges for electricity I receive from SMUD.

I feel greatly deceived: SMUD and the government urges home owners to install solar to save money and the environment and then SMUD is undercutting us by building their own solar grid and claiming our energy isn't worth much any more.

Please analyze how much BTM solar customers save SMUD per KW when they have to buy from outside sources during heavy demand periods. This is a critical consideration and should earn us more during those times due to solar customers reducing the strain on the grid.

Sincerely,

Candice B.
North Highlands CA


August 4 - Walter B.

Dear SMUD, After reading your proposal for Net metering I find it inaccurate!

You state that " Rooftop solar customers avoid paying costs associated with keeping the lights on for the SMUD system." yet fail to mention that you charge solar customers a fee of over $20 a month no matter what the bill is. We are told this is to pay for the infrastructure we are using. So which is it? We are paying for it or we are not, or are you just ripping off solar users for $20 a month?

Also you say you're paying us 12 cents KwH. I find that comical as when you reconcile the bill at the end of the year you pay us wholesale rates for the overage. So either you are lying or your math stinks!

Sincerely,

Walter B.
Elk Grove


August 4 - Nancee M.

SMUD Board of Directors:

Hello. I have rooftop solar on my small, urban house. I installed the rooftop solar in 2011 in large part, because I want to model responsible behavior for my two children and because it is what SMUD and California has committed to. Increasing renewable energy (other than hydroelectric) sources rather than non-renewable energy sources. It was in small part an economic solution. The economics just barely penciled out. Barely. If you change the rate and decrease it as dramatically as the current proposal outlines, rooftop solar will not pencil out for anyone but the wealthiest home owners, in the wealthiest neighborhoods, with the largest roofs. I have a relatively small house (1800 square feet) in an urban neighborhood. Few neighbors have chosen to put in rooftop solar to date. Many fewer will under your proposal.

Rooftop solar is a much better land use and environmental decision than creating large solar farms in the county that would destroy habitat for endangered and other species. Rooftop solar makes sense environmentally. It barely makes sense economically. And, under your current proposal, it will make even less economic sense to those in middle and lower income neighborhoods. The only ones left to be able to afford rooftop solar, something we should be encouraging, not discouraging, would be wealthy Californians. In the suburbs.

Please reject his proposal. It is not color blind and will result in much less rooftop solar in urban and low income neighborhoods. Much less.

Sincerely,

Nancee M.


August 4 - Mike E.

There are 2 areas where you will render home solar a losing proposition.

You limit the size of your solar systems to the previous 12 months usage. This penalizes solar owners when their systems only produce power for about 7-9 hours a day. We have to limit the size of the system while you triple the price you charge us back for the time of day period when most solar systems have stopped producing energy. The only way around this for solar owners is to purchase a $10,000 + battery to store electricity for later use.

Now, you tell us the power we produce in excess of our usage is basically worthless. We basically can produce 100% of our needs and still owe you money due to your time of day price gouge. That’s not very “solar friendly”.

If you drop the price you pay us for excess power solar becomes a losing proposition unless we spend the money for a battery which at current prices, is extremely prohibitive. I have no problem paying an increased fee for my connection to the grid. But as you raise the cost per KWH charged to us, and pay us less for our excess, solar becomes a losing proposition. So much for solar friendly.


August 4 - Anonymous

We leased our Solar System as we could not afford to buy one & it wouldn't have saved us any money if we took out another loan to pay for one. We pay over 12cents/ kWh right now & we have had our system for 4 years. How will it be equitable for us to pay an extra NEM cost? We should pay more than customers without Solar. We went along with SMUD's philosophy back then that we would be helping the environment. Now after leasing a Solar System for 20 years SMUD wants us to pay more than customers who either can not or will not put their own Solar System up. You will be punishing us for doing the right thing for the environment. SMUD should go through it's records and check how many customers leased their Solar Systems and separate them from those that bought their Solar outright. Then work out an equitable NEM that doesn't penalize customers for leasing instead of buying. We still feel that anyone who is helping the environment shouldn't be penalized for it.

Thank you for reading this & we hope you will find an equitable solution for customers who are trying to save our environment.


August 4 - Lynne F.

I am a single Mom that rents. I have no say in if I can or can not install "rooftop solar". I found that whole disclosure quite disturbing. You advertise, "Customer owned electric Co". Did I have a say in this "payback for solar" amount?? Who set up the payback amount to rooftop solar customers with such a high rate. An incentive to install solar?? Why was there not a time limit on such a payback difference in the per kWh amount? Who is running things?? This is SAD!!!