2019 rate proposal public comments

Comments on the 2019 rate proposal may be submitted by emailing contactus@smud.org or by mailing written comments to:
SMUD
P.O. Box 15830, MS A451
Sacramento, CA 95852-0830.

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

If you do not wish for your comments to be publicly available on this page, please indicate that at the time of submission. 

Comments

April 17 - Jay H.

To Whom It May Concern,

I am writing to give input on the proposed charges for residential solar customers. As someone who is in the process of having solar installed I have an interest in how these changes will impact me.

I would like to start by saying that I understand basic infrastructure needs to exist in order for my solar system to operate and provide electricity for my home. I appreciate that SMUD has this infrastructure in place so that the solar system on my home can generate the electricity that I need to power my home.

I feel that thought needs to be given to how fees are structured. Charging an infrastructure fee (the current practice) seems reasonable as all utility users pay the cost. If changes need to be made in order for SMUD to stay solvent then changes should be adopted in a manner that makes sense.

Implementing a charge simply based on the size of a solar system unfairly burdens solar customers with fees. Leaving solar customers to pay significantly higher fees than other electricity customers. If the current infrastructure charges aren’t set at a rate that meets costs then the most logical manner to meet costs would be to look at setting new infrastructure charges that keep up with needs.

SMUD should consider charging customers evenly for their access to the electrical grid. Keeping electricity costs reasonable is understandable, but everyone should share equally in the charges that guarantee access to the grid. Solar customers reduce overall demand for electricity on the grid, so profits for electrical use are likely to be less over time. I would suggest that a structure be explored that will more evenly distribute the costs, rather than implementing an ever increasing charge for solar customers who are making a significant monetary investment in order to provide for our own electrical needs.

Forcing solar customers to pay the infrastructure fee as well as an additional fee based on system size does not make sense, especially since SMUD will likely see a significant drop in the number of systems installed after the federal tax credit expires at the end of this year. Only new homes built will be a significant impact when it comes to solar and the majority of existing homes will most likely continue using regular electricity purchased from SMUD.

Thanks so much.

Sincerely – Jay


April 15 - SMUD customer

Good morning As a public ally owners utility I feel that you are constantly trying to find new ways to tax your owners I have solar on my house and generate power to the system which generates a credit and thus at peak times Smud and its non generating users benefit from my solar power in that you receive the power but to not have to pay for installation and maintenance of the generation facility You also refused to provide any relief for the second meter on my property stating that a Smud rule requires any meters over 1 residential get charges at a commercials power rate so I pay 20 a month for a meter that uses less that 30 kw a month do the math Smud that is criminal As far as this fee I think you should drop it Do customers to have to pay for smart meters anyway is a travesty You cut people from meter reading and went smart which was money in your pocket You charge me for commercial meter because my barn was 200 from my residential panel and then charge me commercial rates for the power I think you should simply raise the rate everyone pays and not single out someone who helps you meets your emissions controls for power production in Sacramento I hope you reconsider your stances and drop all these add on fees otherwise the next steps for solar customers will be off grid which means you loose customers and volume to bill As a customer opened utility I say you let the customer choose the billing scheme not the greedy executives 


April 15 - Jeremy J. Z.

RE: Opposition to Proposed Changes to SMUD’s NEM Program (“NEMv2”)

Dear Directors Rose, Bui-Thompson, Fishman, Herber, Kerth, Tamayo, and Sanborn:

Geocon Consultants, Inc. (Geocon), writes today in opposition to the Staff Proposal presented to the Sacramento Municipal Utility District (SMUD) Board of Directors to restructure its net energy metering (NEM) program and adopt the “NEMv2” program (“Exhibit to Agenda Item #1: Board Strategic Development Committee and Special SMUD Board of Directors Meeting, Tuesday, March 5, 2019.” Available at: https://www.smud.org/-/media/Documents/Corporate/About-Us/Board-Meetings-and-Agendas/2019/Mar/1---Jennifer-Davidson-Pricing-Roadmap-2019-03-05.ashx). Geocon is a proud SMUD customer. Our office at 3160 Gold Valley Drive in Rancho Cordova has over 40 employees and an in-house testing laboratory. We are an engineering consulting firm specializing in geotechnical engineering and environmental consulting. Solar is an important part of our work. We have helped design hundreds of small- to large-scale solar systems for customers in the Sacramento area.

We are deeply disappointed in SMUD’s apparent anti-solar, anti-consumer proposal. We respectfully request that the SMUD Board of Directors rescind the proposal and initiate a thoughtful stakeholder process to consider a path forward that does not undermine Sacramento’s thriving solar market including our business and the nearly 3,000 solar jobs in Sacramento County (The Solar Foundation. “Solar Jobs Census 2018.” https://www.solarstates.org/#state/california/county/064067/solar-jobs/2018).

In considering changes to the NEM program, we respectfully request that SMUD adhere to two foundational principles:

  1. Provide predictable grandfathering terms.
    SMUD proposes to backdate grandfathering eligibility for its existing NEM program to January 1, 2018, exposing customers who have chosen to adopt solar in the last year and a quarter to economic uncertainty (SMUD “2019 Proposed Rate Changes: Business.” Accessed 25 Mar. 2019. https://www.smud.org/-/media/Documents/Rate-Information/2019-Rate-Action/GM-Report-Volume-1.ashx). SMUD’s proposal will have a chilling effect on the market. If customers can’t be sure that their utility won’t change the rules of the road after the fact, they will stop investing in solar. This in turn will hurt Sacramento’s solar industry and related businesses like ours.
  2. Avoid punitive measures like fixed fees.
    The proposed monthly fixed charge basically a tax on solar. We are disappointed that a publicly-owned, consumer-oriented utility like SMUD would choose a policy design that cannot be managed by customers or their solar providers, but rather just deters solar adoption.

We respectfully ask you to rescind the NEMv2 proposal and conduct a transparent stakeholder process to consider potential changes to SMUD’s customer solar program. Thank you for your consideration.

Sincerely,

GEOCON CONSULTANTS, INC.

Jeremy J. Z.
Vice President / Senior Engineer


April 15 - Keven N.

Hi Heidi,

Thank you for your response.  I do have some more to share.

This is my personal story below.

The grandfathering does not apply to me, the home I'm purchasing has a solar system on the roof.  It is not a purchased nor lease system, but we have to pay for the power generated.

The Undesirable Consequences of SMUD’s Grid Access Charge

We recently found out about the SMUD Grid Access Charge through my work manager and we just can't believe what we have heard.  I'm sure you know about this cover-up agenda that SMUD is attempting and keeping away from the public.

SMUD Grid Access Charge fee!  It's just ridiculous! 

If you’re a SMUD customer with new or taking over an existing residential solar system, you must pay a Grid Access Charge of $8/kW per month?!  And increasing to $11/kW per month by 2025?!  The larger or higher capacity of your system, the higher the Grid Access Charge fee.  Isn’t the point of installing solar so that you can reduce or eliminate your electricity bill?  But this is just the opposite.

We were in contract to purchase a home that has a leased solar system and we've cancelled our home purchase agreement because this.  Here’s the math, even if the solar system can generate and cover 100% of our usage, our total cost is: we’ll be paying $60 on the solar lease, $20 SMUD Infrastructure Fee, and $32 Grid Access Fee for a 4kW system.  We would be paying double for our electricity.

What SMUD is trying to do has already affected people's lives.  Due to this Grid Access Charge fee, we've cancelled our home purchase agreement, during escrow and had created a big ripple effect:

  • First, we have wasted our time taking off work early (loss of financial earning), dragged our kids with us to see the house, and wasted our time going thru the purchase process.
  • Second, the seller had wasted their time (loss of financial earning) to make the viewing possible.
  • Third, agents on both sides spent their gas, time, negotiated and drafted contracts, performed all the work but not compensated because the sale did not go thru.  Also, loss of potential earning on other sales.
  • Fourth, the loan officers have devoted their time and efforts to process our loan, performed their work, but will not be compensated.  Also, loss of potential earning on other sales.
  • Fifth, the appraiser was booked but then cancelled.  The appraiser had lost out on other earnings due to blocking their time for this appointment.
  • Six, the home inspector was also in the same boat, lost other potential earnings due to our cancellation.
  • Furthermore, the seller will continue to have a hard time of selling their property.
  • All the solar homes will continue to sit on the market, causing an oversupply condition which will result to a declining home value and real estate market.
  • There still are much more to this ripple effect…

This is what truly had happened.  So many people's lives and earnings had already been affected by this "non-sense proposal".  The worst has yet to come until this Grid Access fee is implemented.

Please abandon this unreasonable and ridiculous idea of charging a Grid Access fee.  It will affect all our lives, including yours.

I've also spoken to solar business such as SunRun and they have stopped installing solar to all homes because they know it will not be beneficial to their customers.  They have great ethical value, to take a loss, rather than keep on installing and making money unethically.  Many other solar businesses have laid off their employees and closing, even solar courses at Cosumnes River College is shutting down.  The economy for Sacramento will be greatly affected.

Keven


April 14 - Terry F.

Hi,

Your proposed Solar charge will wipe out the Solar business in SMUD areas.

I can no longer do business in your area as now there will be no savings for the customer. It is a luxury in your area. A customer can get a 0 down, 20yr loan, and finance a system for every $10000 for just $44/mo. Your rate increase is the cost of a system.

You will have effectively killed Solar in Sacramento.

I live here in Sacramento and my businesses is based here. I cannot do business in my own back yard and may consider moving out of the area.

Please reconsider.

Concerned Solar installer.

Terry F.  


April 13 - L.K.

I’ve a south-facing roof ideal for solar. Been reading everything I could to make an informed decision. We all believe it is the responsible thing to do. Conservation will only go so far. Now, you come up with THE game changer. Been mulling over this thing since a friend in the business notified me. People are not going to be able to go solar if this sort of thing is approved. We are pinching pennies why shouldn’t you?? But we have options: battery system (the $20+$66 will help). Utilities could/might become Federalized, some communities have co-ops. SMUD could stop building show places and be a little responsible. Take a pay-cut. These POTENTIAL charges are certainly like hitting us with our own pay cut! The battery issue will be broken, might have already been by the MIT people. What will you come up with then?? SMUD is supposed to provide a service. Suspect you are afraid of losing power, personal control. Are you non-profit—or “notforprofit”? Is that it? Because most of the current population is NOT going solar and, in this city of trees, will not be going solar. It is our fondest hope that who ever came up with this grab will come to his/her senses and pull back—say to Catalina. . .

Respectfully,

L.K.  


April 13 - Keith L.

This proposal goes directly against any person trying to reduce greenhouse gases and be environmentally responsible. You want to charge me more money while you provide less product. This is criminal. What happened to the not for profit part of SMUD. You should be doing the exact opposite and encouraging people who are doing the right thing for the environment rather than punishing us. Shame on you.  


April 11 - Roy M. 

Dear director Rose,

I intend to install a solar system on my roof this year (last year for federal tax credit?), but heard that linking such a system to the SMUD grid just got way more expensive. Is this true?

I read your bio. Awesome! Can I count on you to encourage private money (like mine) to buy into solar power any way SMUD can, including favorable fee structures and even rebates?

I retired from an Air Pollution Specialist position in 2000. If you can spare the time, I'd love to join you for lunch near your office sometime. 

Roy M.


April 11 - Gabor L. 

Please do not approve the proposed Grid Access Fee  -- it is a move in the wrong direction

Dear Director Sanborn,

I have been a SMUD customer for the past 19 years and have appreciated the consistent service of electricity.  Your team does an amazing job delivering power to the areas you service and does so at a great price point.

As a SMUD customer I have been pleasantly surprised at the level of effort SMUD has made to make the transition to solar power easy for the homeowner.  

The website is fantastic, the integration with a solar site assessment tool and my usage data sharing makes system sizing a breeze.  It was so easy to plan and execute going solar.  Even the interconnect agreement is completely online and within a few days I had my approval letter.   

But this past week I received news that was quite shocking.  

https://www.smud.org/en/Rate-Information/Rate-Action/2019-rate-change-proposal/Residential

As of March 31, 2019 any new interconnect agreement may be subject to a Grid Access Fee $8.00 per month per kW of capacity if the fee proposal is adopted. 

This means that for the system I am installing I would have to pay SMUD $56 - 64.00 per month.  

This seems outrageous since the grid connect fee plus the regular connect fee will be higher than my bill used to be during the low months.

California is on a path to clean sustainable energy and SB 100 is an aggressive goal of 100% renewable energy by 2045.  The proposed Grid Access Fee doesn’t advance that goal.  I don’t know any one on SMUD that would invest in going solar with the proposed fee.  

The underlying problem with SMUD’s Grid Access Fee is that is doesn’t factor in the value that roof top solar provides.   In recent years California ISO cancelled 2.5 billion in infrastructure projects because the solar contribution to the grid mitigated the demand.

https://pv-magazine-usa.com/2018/03/27/distributed-solar-and-efficiency-saves-california-2-6-billion-on-power-lines/

I beg you to continue to educate yourself and the other directors on the value of rooftop solar and to provide the leadership we need to recognize we are in a transition from centralized power generation to distributed generation.  We need new ideas, not road blocks.  We need incentives to install solar battery storage not discriminatory fees.

SMUD has been a solar champion, an your leadership has allowed this.  Don’t stop now.  We need more rooftop solar, we need to be investing in large battery storage facilities like the 100 megawatt plant recently installed in southwest Australia.  

Here are a series of independent studies from a Brookings Institute article that support the value of rooftop solar and net metering:

  • In 2013 Vermont’s Public Service Department conducted a study (http://www.leg.state.vt.us/reports/2013ExternalReports/285580.pdf) that concluded that “net-metered systems do not impose a significant net cost to ratepayers who are not net-metering participants.” The legislatively mandated analysis deemed the policy a successful component of the state’s overall energy strategy that is cost effectively advancing Vermont’s renewable energy goals.
  • In 2014 a study commissioned by the Nevada Public Utility Commission (http://puc.nv.gov/uploadedFiles/pucnvgov/Content/About/Media_Outreach/Announcements/Announcements/E3 PUCN NEM Report 2014.pdf?pdf=Net-Metering-Study) itself concluded that net metering provided $36 million in benefits to all NV Energy customers, confirming that solar energy can provide cost savings for both solar and non-solar customers alike. What’s more, solar installations will make fewer costly grid upgrades necessary, leading to additional savings. The study estimated a net benefit of $166 million over the lifetime of solar systems installed through 2016. Furthermore, due to changes to utility incentives and net-metering policies in Nevada starting in 2014, solar customers would not be significantly shifting costs to other ratepayers.
  • A 2014 study commissioned by the Mississippi Public Services Commission (http://www.synapse-energy.com/sites/default/files/Net Metering in Mississippi.pdf) concluded that the benefits of implementing net metering for solar PV in Mississippi outweigh the costs in all but one scenario. The study found that distributed solar can help avoid significant infrastructure investments, take pressure off the state’s oil and gas generation at peak demand times, and lower rates. (However, the study also warned that increased penetrations of distributed solar could lead to lower revenues for utilities and suggested that the state investigate Value of Solar Tariffs, or VOST, and other alternative valuations to calculate the true cost of solar.)
  • In 2014 Minnesota’s Public Utility Commission approved a first-ever statewide “value of solar” (https://ilsr.org/wp-content/uploads/2014/04/MN-Value-of-Solar-from-ILSR.pdf) methodology which affirmed that distributed solar generation is worth more than its retail price and concluded that net metering undervalues rooftop solar. The “value of solar” methodology is designed to capture the societal value of PV-generated electricity. The PUC found that the value of solar was at 14.5 cents per kilowatt hour (kWh)—which was 3 to 3.5 cents more per kilowatt than Xcel’s retail rates—when other metrics such as the social cost of carbon, the avoided construction of new power stations, and the displacement of more expensive power sources were factored in.
  • Another study commissioned by the Maine Public Utility Commission in 2015 (https://www.nrcm.org/wp-content/uploads/2015/03/MPUCValueofSolarReport.pdf) put a value of $0.33 per kWh on energy generated by distributed solar, compared to the average retail price of $0.13 per kWh — the rate at which electricity is sold to residential customers as well as the rate at which distributed solar is compensated. The study concludes that solar power provides a substantial public benefit because it reduces electricity prices due to the displacement of more expensive power sources, reduces air and climate pollution, reduces costs for the electric grid system, reduces the need to build more power plants to meet peak demand, stabilizes prices, and promotes energy security. These avoided costs represent a net benefit for non-solar ratepayers.

https://www.brookings.edu/research/rooftop-solar-net-metering-is-a-net-benefit/

Contrary to why SMUD is telling us about Solar power produces not paying their fair share, Solar energy is being undervalued

  • For instance, a review of 11 net metering studies (https://environmentamerica.org/sites/environment/files/reports/EA_shiningrewards_print.pdf) by Environment America Research and Policy Center has found that distributed solar offers net benefits to the entire electric grid through reduced capital investment costs, avoided energy costs, and reduced environmental compliance costs. Eight of the 11 studies found the value of solar energy to be higher than the average local residential retail electricity rate: The median value of solar power across all 11 studies was nearly 17 cents per unit, compared to the nation’s average retail electricity rate of about 12 cents per unit.
  • A 2015 cost-benefit study (http://www.oregonrenewables.com/Publications/Reports/Missouri_Net_MeteringEval_2015.pdf) of net metering in Missouri by the Missouri Energy Initiative found that even accounting for increased utility administrative costs and the shifting of some fixed expenses, net metering is a net benefit for all customers regardless of whether they have rooftop solar. The study used values for two kinds of costs and two benefits and concluded that net metering’s “net effect” is positive. The typical solar owner pays only 20 percent less in fixed grid costs and costs the utility an estimated $187 per interconnection. Meanwhile, solar owners benefit the system through reduced emissions and energy costs.
  • Likewise, a study by Acadia Center (https://acadiacenter.org/document/value-of-solar-massachusetts/) found the value of solar to exceed 22 cents per kWh of value for Massachusetts ratepayers through reduced energy and infrastructure costs, lower fuel prices, and lowering the cost of compliance with the Commonwealth’s greenhouse gas requirements. This value was estimated to exceed the retail rate provided through net metering.
  • In yet another study, researchers at the University at Albany, George Washington University, and Clean Power Research (http://www.asrc.cestm.albany.edu/perez/2011/solval.pdf) have found that solar installations in New York deliver between 15 and 40 cents per kWh to ratepayers. The study noted that these numbers provide economic justification for the existence of incentives that transfer value from those who benefit from solar electric generation to those who invest in solar electric generation.

Bottom line, we are in a transition.  We are moving to a new model of power generation and there will be some pains.  What we need to look for is a way to make the transition, share the costs but also share the benefits as we build out the future 100% clean energy California that SB 100 (2018) has targeted.

Thank you.

Gabor L.
SMUD Customer and new Solar producer


April 11 - David T.

Your proposal to charge customers $10/kilowatt for home power generation is misguided and wrong. 

Home power generation is saving SMUD a ton of money by negating the need to source more expensive power or build new power generation facilities.  The payback on solar investment is already on the order 11 years with the 30% federal subsidy.  That subsidy drops to 26% next year, 22% in 2021 and ceases for residential customers in 2022. This, combined with your proposed rate increase will kill the residential solar power program.

For example, based on the last four years of data, my 10.7KW solar power system will generate about 17MW of AC power per year.  That works out to $3400 per year at an average cost of $0.18 per kilowatt hour, or $283 per month.  Your proposed rate charge would, on my system, soak up $88/month.  Given my investment of close to $53,000 ($37,100 after the 30% federal subsidy) in the system, the payback would increase from 11 years to 15.8 years.  Once the federal subsidy goes away, the payback for a similar system will be 22.6 years.

These figures assume there is no cost of capital, i.e., a loan wasn’t needed to purchase and install the system.  Interest charges, or even a modest capitalization rate will further erode any benefits.

This also assumes the rate stayed at $8.00/KWh which by your own schedule is not true.  The rate goes steadily up, topping out (probably temporarily) at $13/KWh.  This will further increase the payback period for the system.

In addition, you propose to grandfather only those who still live in their homes were the system was installed.  Not extending the grandfather clause to new owners of the property effectively decreases the value of the system when the property is sold.  This takes away money we expected to recover in the value of our homes.

I strongly encourage the SMUD board to reject any attempt to enact this rate change.  I have talked to a number of people who feel strongly that after doing the right thing by investing in solar energy, we are now being railroaded by the utilities serving our areas.  PG&E tried to enact the same rate penalty and it was turned back.  I am sure you will see a similar level of outrage when this plan is better understood by the people who are served by SMUD.

David T.


April 11 - SMUD customer

I am concerned that your company has no information regarding the solar Grid Access Charge in the billing portion of your web page. Had I known of this proposal, I never would have installed Solar. This information should be in BOLD on your pages that include anything to do with billing or solar power. What you are doing is dishonest, deceptive and the list goes on. You need to make it clear to your customer of what it is costing them for solar connection. MAKE THE CHANGE TO YOUR WEB SITE AND DO NOT PASS THE PROPOSAL. 


April 11 - Keven N.

We recently found out about the SMUD Grid Access Charge through a coworker and we just can't believe what have we heard.  I'm sure you know about this covered up agenda that SMUD is attempting and keeping away from the public. 

SMUD Grid Access Charge.  It's just ridiculous!  Solar home owners must pay for a Grid Access Charge of $8 per kW per month?!?!?!  So the larger your system, supposedly to save you from the cost of electricity, but will result in a larger SMUD bill.

We've cancelled our home purchase agreement because this.  The property being purchased has a solar lease.  What's the point of having solar?  Even if the solar system can generate and cover 100% of the usage, we’ll be paying $50 on the solar lease, $20 SMUD Infrastructure Fee, and $32 Grid Access Fee for a 4kW system.  We would be paying twice for our electricity.

What SMUD is trying to do is already affecting people's lives.  We've cancelled our home purchase agreement, right after it went into escrow, and created a domino effects:

  • First, we have wasted our time taking off work early (loss of financial earning), dragged our kids with us to see the house, and wasted our time going thru the purchase process.
  • Second, the seller had wasted their time (loss of financial earning) to make the viewing possible.
  • Third, agents on both sides spent their gas, time, negotiated and drafted contracts, performed the work but will not be compensated because the sales did not go through.  Also, loss of potential earning on other sales.
  • Fourth, the loan officers have devoted their time to process our loan, performed their work, but will not be compensated.  Also, loss of potential earning on other sales.
  • Fifth, the appraiser was booked but cancelled.  The appraiser had lost out on other earnings due to blocking their time for this appointment.
  • Six, the home inspector was also in the same boat, lost out other potential earnings due to our cancellation.
  • The seller will continue to have a hard time of selling their property.
  • There will be an overall decline in real estate market value as more home sits on the market, over supplying condition.
  • There may still be more others affected…

This is what truly had happened.  So many people's lives and earnings had already been affected by this "non-sense proposal".  Imagine the worst when it is actually in effect.

Please abandon this unreasonable and ridiculous idea of charging a Grid Access fee.  It will affect all our lives including yours.

Sincerely,

Keven N.


April 11 - Anonymous

Procurement'''/ You have good lawyers to twist , usage, to Procurement................... I pay for solar and get penalized because , of SMUD Procurement


April 11 - Susannah C.

Hello and thanks for your note. When utilities and agencies assess the impacts of DG solar generation, they should look not just at last revenue but at the full range of costs and benefits of that generation, which extends far beyond the avoided commodity cost. Many such studies have already been conducted across the nation. Did you consider going down that more comprehensive and accurate path?

Thanks,

Susannah


April 9 - Kellen C.

To the SMUD Executive Committee,

I'll try my best to control my anger and disbelief as I write this email, but I couldn't believe when I was made aware of this proposed changed for people who have purchased solar, who will purchases solar, and for those moving into solar homes are being punished for helping the environment. The proposed rate for 8 kw/hr has all be scraped my future plans for upgrading my new home that I recently purchased in 2018. In the article explaining the proposal it almost a written as sort of a punishment for people who have purchased solar. Saying that people who have solar "do not pay of fair share". Not paying our fair share? Isn't it a good thing that people are taking it upon themselves to use renewable energy? Isn't it a good thing for whatever power a solar home doesn't use its sold back to the electric company at a very minimal cost so that it can be used to power another home without damaging the environment? I suppose it not good for SMUD, since the solar panels are owned by private owners instead of solar panels produced by the city. 

In the article you listed several reason why the rates are needed. 1st  you mentioned its due to fire mitigation. Please explain what fires does SMUD have to worry about in the Sacramento area? Is the Delta area a fire threat waiting to happen? Is the Folsom grasslands a fire hazard danger? The Delta area is pretty much a giant wetland which is far from a fire hazard. The Folsom area is a well-known affluent area and is well funded by the city of Folsom/ El Dorado Hills area. Also the area around the Sacramento Airport is all private farmlands owned by people who are responsible for their lands. So what fire mitigation is there to managed? 

2nd you mentioned its to help "to meet carbon reduction goals through transportation and building electrification and investments in renewable energy and increase energy efficiency" It's kind of hypocritical to significantly charge your customers who invest in solar upgrades, just so you can do it yourself and reap the benefits. This rate increase will have the opposite effect. It will discourage citizen and businesses in the Sacramento area in investing privately in renewable energy. Unless that your intent...

Reading several comments on your public comment section over the proposed change to the Grid Access several owners have already commented and voiced their displeasure and have already expressed closing down their business. Not sure if you realized this, but this proposal may set a precedence towards other electrical companies to push for similar changes for their "Grid Access" which would effectively kill any future solar projects in California. 

This proposal is bad for business, and its bad for Sacramento and its citizens. As a born and raised Sacramento resident I hope you will understand the ramifications of this proposal and vote No.

Thank You

Kellen C.


April 9 - Richard S.

Unfortunately, I will be in Marin County, helping my wife babysit Grandsons that day.  I would ask and would appreciate your help by asking that you provide copies of my email statements to the SMUD Board members.

I am greatly concerned that the proposed fees SMUD staff are asking their Board of Directors to adopt would make solar and battery storage an almost unattainable solution for the many vulnerable seniors and people with disabilities that must depend on consistant electricity to operate both their mobility and medical equipment.  At the same time, utilities across California have been approved by the CPUC to de-energize their service areas. And many continue to have their electricity interrupted due to utility system failure.

Solar systems with battery storage could make the difference for many in my community when their electricity is unavailable.  Without solar/battery energy storage, at best, they may experience a lack of function for many hours or even a few days.  At worst, medically necessary life-support equipment that must have consistant electricity to operate may also not be available for hours or many days.  And during some power outages, if back-up power is unavailable, cell towers may not function, creating a situation where there those most negatively affected by the power outage have no no way to contact emergency personnel.

Instead, I ask that SMUD look to those utilities that are supplying residential battery energy storage systems to their customers.  SMUD must learn why those utilities are able to take such pro-active steps for their electricity customers, especially the most vulnerable populations within their service areas, and find a way to help SMUD customers (especially those most vulnerable seniors and persons with disailities) become beneficiaries of these new, clean energy systems.

Thank you.

Richard S.


April 9 - Richard S.

Dear Director Heidi Sanborn,

As the Executive Director of Designing Accessible Communities, a California non-profit organization, I am writing to ask that you not vote in favor of the solar/battery storage fees that will have an extremely damaging affect on many low income seniors and persons with disabilities.  Instead, the Board should be encouraging residents to install solar and battery storage, like Green Mountain Utility on the East Coast.

Please reject the proposed new solar-only fee. It is an attack on solar, and will punish people simply for reducing their electricity use. The only result will be to discourage people from becoming more energy efficient and independent. To be clear, solar users should pay their share of the grid. The SMUD proposal, however, is a poorly-conceived overreach that simply punishes people for making the responsible choice.

Sincerely,
Richard S.


April 6 - G.L.

Hello,

SB 100 heralded a clarion call for a future void of fossil fuels powering the grid by 2045. Your action is in direct opposition to this target as it halts solar installation in SMUD service areas. I am a homeowner who is in the process of installing 8kW of rooftop solar. I would have NEVER pulled the trigger on the project if I had know about this fee. Instead of retarding the growth of solar due to peak oversupply, let’s look at ways to absorb the oversupply and continue to move forward to clean energy. 1) Acknowledge that monolithic centralized power distribution systems are a thing of the past. 2) Embrace distributed power systems and the new democratization of power generation. 3) Incentivize every PV installation to install enough battery storage so the excess power is not burdensome to you, SMUD, and the “grid” is not used as a solar PV systems virtual battery. 4) Build multiple massive battery storage facilities in preparation for the future mandated move to clean energy. The proposed Grid Access Fee is a step in the wrong direction and only deals with the immediate oversupply of solar energy during a very small period of the day. Let’s work together to move to a sustainable future. Let’s continue to encourage solar production like you have been, and come up with innovative ways to move into the fossil fuel free future.

Thank you!

GL Galt CA 


April 2 - John T.

To the SMUD Executive Committee,

My wife and I installed a 4.8kw residential rooftop solar system which went live on April 1, 2019. While we will be exempt from your Grid Access Charge for 10 years, I am compelled to tell you that I would not have installed this system if these charges applied to me now:

My average bill is approximately $100 per month (non-solar). Your proposed Grid Access Charge would be $38.40 per month for 2020, and rise to $52.80 per month in 2025. My installation cost over $14,000 and was to require an 11 year pay-back. If these proposed changes affected my situation, the payback period would be 17 years. These charges represent an additional 6 years of payoff on a system that is rated to last 25 years. Additionally, I will have to replace my roof during that time and that will cost much more to remove and reinstall the solar panels. And this doesn't include any other maintenance costs which surely arise over 25 years. Adding solar to my rooftop would not be worth the risk -- there would be very little financial incentive. 

Making the math work on the solar investment was a challenge to begin with. Now with these proposed changes, it is easy to say that I wouldn't have done it. If we, as Californians, want to support clean energy, this will be a step backward because it will stifle the solar industry in this region.

Sincerely,

John T.


April 2 - Al R.

My name is Al R. and I am the president and founder of ACR Solar International, a solar Manufacturing and Installer in Carmichael.  This is my 40th Year in Solar, I hold 5 solar patents, have been a solar consultant on the Federal and State levels, moved my manufacturing and family from Virginia in 1992 because of an invitation to do so by SMUD. I am active with the Carmichael Chamber of Commerce and installed Solar on Heidi Sanborn’s home.   

ACR Solar is a highly ethical company as can be seen by our online reputation and our Motto, Quality, Value, and Integrity Since 1979. As an ethical company, ACR Solar had to suddenly shut down our business of selling and installing solar electric in SMUD territory when we surprised last week when we became aware that SMUD may institute a “grandfathering” policy as of March 31 that may result in large monthly fees being charged to new solar customers after that date. It is the “may” that created uncertainty and is the cause of the shutdown of SMUD solar sales. 

As of March 26, we painfully had to tell our sales team to stop selling solar electric in SMUD and to tell all current potential customers of the uncertainty and potential of large fees to our customers.

I, and the entire solar, storage and environmental community are very proud of, and have great appreciation for the wonderful work SMUD and its staff have done to become the National leader in Environmental stewardship that SMUD is today. The country looks to SMUD to continue this vital role as an environmental steward, in other words, the Nations eyes are on SMUD for continued solar, storage, and environmental leadership.

This fixed fee proposal with it’s March 31 proposal came as an unexpected, disruptive, and painful shock to the solar installation community and is completely contrary to SMUD’s wonderful stated policy “to be the trusted partner with our customers and community,” because this sudden SMUD proposal is directly causing economic damage to the community and potentially to SMUD's reputation as an environmental champion.

SMUD needs to initiate a transparent and fact-based stakeholder process assessing the full range of costs and benefits of customer-generated clean energy exported to the grid and future SMUD policy related to self-generation by its customers.

The truth that they will find is that solar electric in SMUD is usually barely break even or negative and that the picture presented on page 41 of its Board presentation is incorrect in that solar electric in SMUD territory is nowhere near as profitable to customers as presented. SMUD area solar customers buy solar because they want it and see the future value but few or none will buy solar if it means a $400 to $800 yearly negative thus killing solar sales in SMUD territory.  It is vital to include solar’s environmental and other benefits to the community and the Nation.

The solar community requests that the SMUD immediately rescind the proposal and initiate the vital fact-based stakeholder process with the clean energy community, including the California Solar and Storage Association, to map out a pathway forward that does not harm the growth of solar in the Sacramento Valley region or SMUD's reputation as the Nation's environmental Utility leader.

Thank you


March 28 - William J.

The summary of the new proposed rate increase states, “Rate increases to meet our IRP goals are expected to result in an annual rate increase of approximately 1.75% for the next decade just to fund achievement of the IRP’s aggressive carbon reduction goals. This will be in addition to rate increases driven by other business requirements.”

This is 37% of the rate increase in 2020 and 39% in 2021.  This is outrageous!  I am a retiree and I voted for you believing you would protect both our economic and environmental interests.  Have mercy on us, and be a little less “aggressive”.   Certainly environmental protection can be achieved with a far lower economic impact residential customers.  Please get this pared back to a more reasonable amount.  

Thank you,

William J.


March 28 - Seth D.

To Smud,

I run a local business in the heart of the Sacramento area and in the heart of SMUD territory. I also live in SMUD territory. We have seen the changes for solar that SMUD is proposing to make after March 31st and they are disturbing to say the least. 

I run a roofing and solar company. This change will dramatically affect my business and the lives of my 50 employees. The proposed cost of $8 per 1kw of solar system size is so high it will deter those that would like to get renewable energy for their home from going green. The proposed cost to not grandfather in homes that currently have solar after they move doesn't make sense either. These homes were set up with solar long before this idea was proposed. 

I would like to know when I could meet with someone to discuss these changes and how damaging they will be to the community and to renewable energy. I look forward to a response. Thanks.


March 28 - Lorraine S.

I find it troubling that those who participate in combatting Climate Change by investing in “Green Energy products” at great expense, such as Solar energy, are now being proposed to pay a fee Access charge to the SMUD Grid.  Seems to me this is punishment for investing in Green Technology that is supposed to be combatting the over-use of valuable energy resources generated by your Grid.  Punishment:  Much like the State of California fee placed on the Registration/License Fee for hybrid vehicles that don’t use enough gas (fossil fuel) & pay enough “tax” at the pump to fund roadway infrastructure.  Punishment for using less fossil fuel & reducing the carbon footprint is definitely the wrong direction if the goal is to combat Climate Change.

Then, I read articles in the newspaper about how California generates too much solar energy & is paying other states/grids to take it. ??  Meanwhile, the Robo calls trying to sell solar equipment and installation plague our phone lines almost daily.

It seems to me that the Solar Industry Sale—at least in CA---appears to be a bait & switch operation:  Buy our solar system; which by the way, may require the consumer to put on a New Roof & gutter system prior to install.  The amount could easily double the amount of the what the solar system cost.  Not small change.  Then the News has it, CA generates too much solar &  then SMUD comes along and says the on-site solar system needs to also pay an Access Fee to the SMUD grid.

As with everything in Government(s) now, a real lack of communication & transparency.  We the people do not have fathomless funds to buy everything productive (or useless) & then pay more fees as punishment when our Goal is to invest in & create a better world.

Thank you for hearing me out & I look forward to at least, a Press Release Communication about the facts and the math of charges.


March 28 - Chris M.

To Whom it May Concern:  I am one of your customers in Wilton considering a rooftop solar system.  After seeing your proposed rate increase for such customers on your website, I am reconsidering.  I think this will serve as a great deterrent to people considering adding solar.  It would seem to me with SB 100 requiring California to be 60% renewable-powered by 2030, and 100% by 2045, utilities would be trying to incentivize solar. People with solar are helping provide additional energy to the grid at peak use times, helping everyone.  I also don't think it's fair to put this proposal up on your site with a deadline for new solar applications on 3/31 before the proposal has even been passed (not to mention that's a Sunday, so I assume the effective deadline is 3/29)--that's not much advance notice for people currently considering solar.  I would request that you reconsider the additional surcharge, and at least move the deadline for the surcharge affecting new applications to give people a little more time to make a decision about whether adding solar will still be cost-effective, given the proposed rate increase.  

Thank you for your consideration,

Chris M.


March 26 - Matthew A.

Dear SMUD Executive Committee,

My name is Matthew A. and I am a lifetime Sacramento area resident and business owner. I have been made aware of and researched the proposed “Grid Access Charge” changes going in effect beginning March 31, 2019. 

This year, I am installing solar on my commercial building and also on some rental properties. I am extremely concerned because these proposed charges would eliminate the financial savings that I would achieve by installing solar. These savings are necessary to offset the cost of installing solar. This will also essentially kill the solar industry in the Sacramento area, which is absolutely not ideal for the environment or SMUD’s goals for more renewable energy.

I understand that there are costs associated with solar customer’s being connected to the SMUD energy grid. These costs should be captured in the monthly connection fees being charged to me and your other customers. The KWh charges would dissuade most consumers from installing solar.

Other energy utilities have made similar solar policies and it has had a profound negative effect on the solar industry. For example, SRP in Arizona implemented a similar program, and the solar industry is virtually extinct from that district. Modesto and Turlock have seen a similar demise of the solar industry after implementing such policies.

Will you please consider removing the Grid Access Charge as currently proposed and continue to be a leading utility in California for clean energy and solar production? The alternative will be catastrophic for so many business that rely on solar sales and installation. It will also affect businesses like mine from making the solar investment.

Thank you for your consideration and I look forward to your response.

Respectfully,

Matthew A.


March 26 - Ryan K.

The proposed grid solar access surcharge is monopolistic and unethical. The UN has announced catastrophic repercussions if we humanity do not reverse our global greenhouse gas emissions and solar is a major factor here.

https://www.forbes.com/sites/davekeating/2018/10/08/as-the-un-warns-of-climate-catastrophe-by-2030-the-eu-is-pulling-back-climate-ambition/#1e9e6a7b11ef

Solar can drastically reduce all forms of electrical use and combustion engines in many ways. There's also substantial case law that deems this monopolistic. What good is a non-profit when you're hindering the economy and the future of our children? I urge you to reconsider this. Please don't contribute to the problem when you have an opportunity to be a leader. Make a stand for the right choice and be an example for all other utility companies. 

On a closing note, please let me remind you of your mission statement:

With our eyes on the future, we’re taking steps to reduce our reliance on carbon-based fuels and meet ambitious goals set by your elected Board of Directors and state lawmakers to dramatically reduce greenhouse gas emissions. We're on track to provide 33% of our energy from renewable sources by 2020. Investments in wind, solar and biogas will help us get there.

Ryan K.


March 26 - Disgruntled SMUD customer

So now my decision to go solar this june will actually cost me more money than not going solar is what you are telling me. Now that i have gotten my finances in order and credit score high enough to purchase a system you are going to penalize me for doing something positive for my family  (creating more disposable income).  I do not know anyone in my neighborhood who has that small a system.  In fact, as I look around only the new homes forced to buy the solar on their roofs have systems your average size estimate.  I am sorry, but this does not look positive for the smud community.  It looks like a money grab by smud and you are forcing smud customers to buy our power from smud and smud alone.  Sounding like pg and e more and more.  you are going to have a fight on your hands.  You are taking the decision making process away from us and making it for us.  Next I suppose you'll tell us you are now producing your own green energy and we can buy it from you.  I do not believe one word it this letter.  Telling us how much our bill will go up is BS and you know it is.  Shameful marketing tool and please do not try to legitimize this by having someone show more of your graphs.  They are way off and will be further off this year. 

 

Disgruntled smud customer. 


March 21 - Thomas M.

Hello SMUD Directors; I have attended two rate meetings and have some comments on the issue of the fixed charge. The fixed charge has some ramifications that I did not hear discussed but that I think are significant.

California state energy policy seeks to encourage conservation, solar (batteries) and equitable treatment of customers. The fixed charge to me seems detrimental to those goals.  And the assumption that "all users share the infrastructure equally" is not necessarily the only way to allocate infrastructure costs according to NRDC.

3/4 of California is served by pge, sce, sdge and they have no fixed charge per CPUC.

I understand that developing rates these days are challenging but I think understanding the side effects of fixed charges are worth the effort.

Sincerely, Thomas,  *******@yahoo.com

A few discussion points:

1) My editorial on fixed charge

https://www.newsreview.com/sacramento/smud-isnt-as-green-as/content?oid=27623584

2) video (2 minutes) on fixed charge - this model is used by dominion energy Virginia in my sisters area - $6.70 / customer charge

https://medium.com/getting-it-right-on-electricity-rate-design/new-explainer-video-on-utility-fixed-charges-and-donuts-b97095d0b71e

3) NRDC explains that SMUDs assumption that "all users share the infrastructure equally" is not necessarily the only way to allocate  -

https://www.nrdc.org/experts/samantha-williams/there-war-attrition-electricity-fixed-charges

"To push monthly fixed charges higher, utilities need a justification. Many, including Xcel Energy in Minnesota last year, assert that a portion of their electricity distribution system — poles, wires and transformers — are another “fixed cost” to recover via the monthly customer charge.

But they aren’t.

As the Regulatory Assistance Project has pointed out, the costs of power plants, transmission lines, and distribution facilities end up varying with energy use when viewed over the long run. In other words, more energy usage over time — and not the mere fact of a household being connected to the grid — is what drives needs for investments in generation and delivery system infrastructure.

The Minnesota Commission understood these dynamics and rejected Xcel’s proposed fixed fee hike last year.

Unfortunately, some utilities have made this arena unnecessarily complicated by advancing a range of different economic theories aimed at supporting higher mandatory fees for utility customers. The theory used by Xcel in Minnesota is but one. However, a simple and very straightforward approach continues to be best: to leave the customer charge low by basing it on the actual and projected costs of meters, meter reading, and billing in a given utility territory. All costs that vary over the long-term — including distribution system-related costs — are then recovered volumetrically.  This is the basic recipe that gets the customer charge right. "

4) synapse energy video on fixed charge - first 15 min are good. The customer fact sheet illustrates how the fixed charge negatively affects low use consumers. Maybe SMUD can hire synapse to consult on the current rate issues to help develop a state of the art rate structure that sends the right incentives.   

Fixed Charges: Impacts and Alternatives | Synapse Energy

http://www.synapse-energy.com/project/fixed-charges-impacts-and-alternatives

5) utility dive on fixed charge history

https://www.utilitydive.com/news/are-regulators-starting-to-rethink-fixed-charges/530417/

"After the financial crisis, U.S. electricity sales flattened, due primarily to reduced demand and accelerated by the impacts of EE and DER. In response, utilities requested higher fixed charges that provide revenue independent of usage.

6) fixed charge increases energy use, energy Alabama

https://alcse.org/are-fixed-charges-bad-for-customers/

"In a report conducted by the Kansas Corporation Commission, they concluded that increased fixed charges in Kansas would increase electricity use by 1.1 to 6.8%, varying by utility and season. This means the projected increase would be greater than all the energy savings from all the energy efficiency programs in the state. The same report found that such a change in rate structure and consumption would offset the financial benefits of decades of energy efficiency efforts and penalize customers who have already invested in or installed energy efficiency measures under the previous rate structure. The increase in fixed charges would weaken the incentive for future investors in energy efficiency, which could have negative impacts on the local economy and environment."

7)   fixed rate New York

https://lowerfixedcharges.org/

8) solar united neighbors

https://www.solarunitedneighbors.org/learn-the-issues/fixed-charges/