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

June 24 - J.D.

Sad Day, that we, the monopolized OWNERS are burdened to PAY unjustifiable and possibly illegal TAXES !     I.E. 9%+  Scaler increase to meet 'our' goals..

What happened to  Customer prices tied to the 'Cost of Providing Service', even though sMUD likes to compare themselves to the Criminal PG&E. (Erin Brockovich knows PG&E all too well.)

sMUD is/was OUR Community Owned ELECTRIC service; and is NOT authorized to ADD TAXES to pay for SHINE neighborhood beautification programs, Over-Advertising, ETC. "to meet 'our' goals". 

Too much of OUR  payment for service  dollars and cents are wasted. You even pay an outside source to try to compare y/our company as a good value, and also to figure out how to tap us for more money without squealing.

Your team did get back to me on your budget for Weather Modification / Cloud Seeding, $300,000. 

You/We spent about $1,000,000 on it last year, increasing your spray area to 444 square miles, from the 192 square miles you used to spray for 49 years in just El Dorado County.

 Plus the planes that have to go back and forth to monitor progress.

The response was $300,000 for next year.  I can't imagine you would  Scale back operations now.

A Fire Science Response Budget should also be set aside, as I believe there will be a causal link discovered in your portion of the Weather Modification/ Cloud Seeding efforts, those that you are so proud of for 50 years, 

P.S. Those Dumb meters are invasive in many ways, and I wonder when you will get caught for denying any adverse research on the safety of that mess. 

I hope the courts are true to the people.

Sincerely Hurting my head, 
J.D.


June 23 - Thomas M.

Hello SMUD Directors; I have attended four rate meetings and have some comments on the issue of the fixed charge. The fixed charge has some ramifications that I have  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 best 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.

Sincerely, Thomas M.

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 (http://www.raponline.org/wp-content/uploads/2016/05/rap-lazar-pricingdosanddonts-2011-04.pdf), 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 (https://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 (https://www.eia.gov/todayinenergy/detail.php?id=35612), 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/


June 21 - Mark G.

Ms. Lesch,

Please forward this to the Board and staff as soon as possible.

Also, this is my 4th set of comments on the proposed rates for 2020 and 2021.  Please post on the SMUD website with all the other comments on this matter. 

Thank you,

Members of the Board and staff,

This is what I will say in my public comments at the Board meeting on June 24, 2019. 

You have about 1 1/2 business days to prepare a response.

I would appreciate a response from the Board and / or staff during the meeting on Monday night.

For your convenience please refer to the section called "Bottom line" at the end of this message.

Thank you,

Mark G.

P.S.  Comments and questions on the proposed rates

#1  At the rate hearing on June 4 I showed that the current rates are based on SMUD's marginal cost according to the 2018 Rate Design Study (RT02).  The CEO and GM Report for 2017 contained Appendix I, a letter from NERA Economic Consulting, that mentioned this. 

#2  I also showed that SMUD had added 9.2% to its marginal cost in creating the current rates.  SMUD called this a "scalar".  This was in Table M, page 14, of the RT02 Rate Design Study and the explanation was right above Table M.

#3  The California Constitution, Article XIII C, says that a local government may not "impose, extend, or increase any special tax unless and until that tax is submitted to the electorate and approved by a two-thirds vote."  "The local government bears the burden of proving by a preponderance of the evidence that a levy, charge, or other exaction is not a tax, . . . ."  A levy, charge or other exaction is not a tax if it "does not exceed the reasonable costs to the local government of providing the service or product."

#4  The 9.2% scalar in the current rates is a tax.  The current rates are taxes because of the scalar.  They exceed SMUD's reasonable cost by 9.2%.

#5  Board President Tamayo asked General Counsel Lewis during the rate hearing to respond to this argument.  Ms. Lewis asked Jennifer Davidson to respond. 

#6  Ms. Davidson's response was that the scalar "is used by IOUs, and it is also used by regulatory bodies across the country," and that the

22 marginal cost in rate making is the cost of adding one
23 more customer. And you'll recall we talked about
24 there's the marginal costs and there's the embedded
25 cost, and at no time are they ever equal. Sometimes

1 embedded costs is greater than marginal and sometimes
2 it's lesser, and so you needed to have a factor to
3 equate the two.
4 So it is true that right now the marginal cost
5 is less than the embedded cost, so we needed to figure
6 out what is the right way to correctly allocate costs
7 in the cost study from the marginal cost to the
8 embedded cost, and we also want to make sure that we
9 allocate those costs accurately and equitably, and so
10 we do apply a math formula or a percentage to all the
11 components to appropriately scale, hence the name
12 "scalar," between the cost of adding one more customer
13 and all actual total costs of our system.

 
Transcipt of rate hearing, pages 41-42

#7  IOUs are not subject to the California Constitution, Article XIII C (Propositions 218 and 26).  SMUD is.

#8  Regulatory bodies across the country are not subject to and do not implement or enforce Article XIII C.

#9  The terms "embed" and "embedded" do not appear anywhere in the 2017 CEO and GM Report, Volumes 1 and 2.  Nor in the Rate Design Study RT02.  Nor in the marginal cost study mentioned in the NERA Economic Consulting letter.  Nor in Resolution 17-06-09 or Attachment B thereto.  Nor in any other document I have seen connected with the current rates.

#10  Ms. Davidson may have intended to give an honest and truthful response about the components and origins of SMUD's current rates but obviously her claim about "embedded cost" is not supported by ANY of the documents related to the current rates.

#11  On June 13 I sent SMUD a Public Records Act request for:

electronic copies of records that describe, analyze or quantify SMUD's "embedded cost":

a)  for the current time of day residential rates; and
b)  for the proposed rates for 2020 and 2021


#12  Nicole Looney in the Office of the General Counsel responded to my PRA request yesterday by showing me a link to the page with the SMUD Budget Letters and Budget Summaries for the last few years and claiming that "Ms. Davidson used the term “embedded” in reference to SMUD’s budget." 

https://www.smud.org/en/Corporate/About-us/Company-Information/Reports-and-Statements/Budget-Reports

#13  Ms. Looney obviously did not look at any of those records before sending me her response.  She would have noticed that the terms "embed" and "embedded" do not appear in any of them.  SMUD has failed to properly respond to my PRA request.

#14  SMUD has prepared and posted on its website an Exhibit to Agenda Item #12.

https://www.smud.org/-/media/Documents/Corporate/About-Us/Board-Meetings-and-Agendas/2019/Jun/ExhibittoItem12BODMtg06242019.ashx

#15  Slide 14 of that Exhibit addresses Alternative Recommendation #4, which is my recommendation:

Recommendation: Reduce the current residential 2019
rates by the “9.2% scalar” and then increase rates by
4.75% in 2020 and 4.50% in 2021

 

#16  The first item in the "Staff Assessment" is "This rate action does include restructuring the current residential rates adopted by the Board in 2017." 

#17  That first item is not responsive to the recommendation.  Please explain it!!

#18  The second item is, "The scalar was used to reconcile marginal cost to achieve a revenue neutral rate design."  Reconcile marginal cost to what?  Please explain that!!

#19  SMUD raised its rates in June, 2017 when it authorized the Time of Day rates which are currently in effect.  This is shown in my comments #7 through #11 in my 3rd set of comments on the proposed rates, which are dated June 18, 2019.

#20  The third item is irrelevant as explained earlier because neither IOS nor electric utilities nor regulatory commissions in other states are subject to or implement or enforce Article XIII C.

Bottom line:

#A  SMUD has failed to cost justify its current rates.

#B  SMUD is about to extend and increase a tax without voter approval in violation of Article XIII C.

#C  Based on my PRA request and SMUD's response to it there are NO RECORDS that describe, analyze or quantify SMUD's "embedded cost".

#D  I am going to sue SMUD for this violation among others.  (Fixed charges will be another one.)  Your hired attorney is going to have a hard time explaining to the Superior Court for Sacramento County how and why the current rates are allegedly based on "embedded cost" when there are NO RECORDS that describe, analyze or quantify SMUD's "embedded cost" and that term does not appear either in the resolution for the current rates, 17-06-09, or the 2017 CEO and GM Report or any record that NERA Economic Consulting reviewed.

#E  June 24 will be your last chance to fix this.  Once you vote on the resolution you will have given up all your opportunity and right to authorize 2020 and 2021 rates in a way that complies with Article XIII C.

#F  SMUD has failed to explain or demonstrate why it should NOT adopt alternative #4.  Please do so by or at the June 24, 2019 Board meeting.

June 20 - Dan B.

Ryan, 

Wow, two increases each of the coming two years, and a pretty big increase the first year. Thanks for the update.

Dan


June 20 - Joachim R.

Good afternoon Damien,

I just had a follow up question about the rate hikes upcoming.

Am I reading this right?  Looks like SMUD went from a 9.25% two step rate hike to an 11.25% four step rate hike.  Why the 2% increase for the same overall time allotment.

Regards,
Joachim R.


June 20 - Nancy J.

Yes, you’re right......sorry, I should have done the math instead of making you do it for me!

That’s a very substantial increase….was there something that changed in SMUD’s analyses between the first proposal and now?

Nancy J.


June 20 - Nancy J.

Thanks for the heads up, Ryan.  So, the rate increase is the same but just in 4 increments, instead of 2 – correct?

Second question, has there been any resolution on the fixed charges for solar customers?

Nancy J.


June 19 - Beverly P.

Dear Board Members,
 
I am very concerned about the the rising utility cost which began with the addition of a monthly "System Infrastructure Fixed Charge". Icontacted my Ward 1Representative, Brandon Rose, via email, about this issue approximately 6 months ago and received a very polite, not very helpful response.
 
Analysis of my electricity bills for 2018, indicated that 54% of the bill was for actual KWH usage; 46% for the surcharge. For consumers of much more power than I use, the surcharge decreases to a much smaller percentage of the bill. This is a bit outrageous. I pay for food, clothing,etc.  (goods) without an additional service charge/surcharge to the purveyor. Why should electricity be different? I am a very conservative customer. I do not use my electric clothes dryer for 6 months of the year, all lght bulbs are energy efficient, minimal use of TV and air conditioning, etc. I am a fixed income senior who does not meet the requirements for a reduced rate program offered by SMUD.
 
The new rates effective June 1-September 30th, places a further financial strain and discomfort during the summer on electricity consumption. I am quite skeptical about SMUD's assertion that it it more  costly to produce power from the hours of 5-8 PM Mondays through Fridays. Many people are jamming our freeways and public transportation to return home from work during that window; the large buildings in downtown Sacramento which house County, State and Federal offices are usually powered down by 5 PM. I would be very interested in seeing the data which were used to calculate the new rates.
 
The most disconcerting cost is the 2 year propsed rate increases for residential customers, with a rate increase for commercial users as well. I was unable to locate the exact percentage rate increase for the latter. This means that we, the residential consumers, will indirectly pay even more for electricity than the proposed increases because the commercial users will "pass on or pass through" their rate increase for goods and services to us, i.e. we will absorb their increase. It's almost a double whammy.
 
SMUD's proposed projects which will be funded by the rate increases are commendable but at what realistic, quality of life cost to consumers? Cost of living in California is already astronomical; our water and power are life necessities and their costs cannot become prohibitive and burdensome in the extreme. I have not seen any efforts by SMUD to reduce costs where feasible. Thank you for your attention and I do appreciate the reliable electricity which I receive.
 
Sincerely,
Beverly P.

June 19 - Harrison K.

Hi Marie,

Just reading the below… is there a typo? It looks like the 4.75% 2020 increase is now about 6.75% while the 2021 total is still 4.5%.

Thank you,
Harrison K.


June 19 - Ross T.

Board Members

I was in attendance at the June 4, 2019 SMUD Board Meeting when the SMUD staff presented the ridiculously high new rate proposal.  I was appalled that one of the SMUD Board Members said that she had not read the General Manager’s Report before coming to the meeting. 

I would like to suggest one way SMUD could save on costs.  We have seen and heard countless TV and radio commercials from SMUD telling us about the 5-8 peak Summer rates.  Unless these commercials are run for free they should be stopped immediately.  This is a GROSS WASTE of our SMUD rate money.  We already receive a newsletter and other mailings from SMUD about the Summer rates.  Unless you live in a cave you already know about the SMUD rates.  I’m guessing that this unnecessary “advertising” by SMUD is costing MILLIONS of DOLLARS.

Stop this ridiculous waste of ratepayer’s money and reduce the proposed rates accordingly.

On another subject.  Why is it that SMUD cannot provide the beginning and ending meter readings on our SMUD bill or on the SMUD website graph display.  Each month I have to calculate the ending meter reading.  There is no way for me to verify if what SMUD is telling me about the kWh’s I have used is accurate. 

Ross T.


June 18 - Paul S.

Hi Brittany,

Please run the calculations on how this increase will impact our total billing. I would like a further breakdown between our commercial accounts and traction power accounts.

Please let me know if you have questions.

Paul S.


June 18 - Steve P.

Marie,

Thank you for sharing this information, however it extremely concerning and will impact our business greatly as we were planning on expanding our footprint at this location in the near future. I think we will need to discuss in further detail at your earliest convenience but no later then Friday. I will be available tomorrow afternoon after 1pm and all day on Thursday.

Steve P.


June 18 - Mark G.

Hello SMUD,

Here are my comments as described in the subject line.  Please share with the Members of the Board and your staff and make available on the SMUD website. 

Thank you,
Mark G.

Comments:

#1  During the rate hearing on June 4, 2019 SMUD implicitly acknowledged that it is extending and increasing the current rates and the scalar that is "baked into" or incorporated into the current rates as a result of the 2017 rate action by not disagreeing with my statement that SMUD is doing so.

#2   Jennifer Davidson's answer to the question of the scalar, that begins at 1:01:33 on the June 4, 2019 rate hearing meeting video, revolved around SMUD's "embedded cost" of providing electricity service and the difference between embedded cost and its marginal cost.

#3  Neither the 2017 nor the 2019 CEO and General Manager's Report and Recommendation on Rates and Services mentions the term "embedded cost" or the term "embedded" except once in connection with fixed costs (page 36 of the 2019 Report).  

#4  SMUD has failed to cost justify its current rates or its proposed rates for 2020 and 2021 as required by Article XIII C of the California Constitution.  SMUD failed to cost justify the 9.2% scalar that SMUD has proposed to extend and increase for 2020 and 2021.

#5  NERA Economic Consulting's letter, which was Appendix I on pages 109-112 of the CEO and GM Report for 2017, refers to several documents including the 2018 Residential Time-of-Use Rate (RT02) Design Study.  That was the only document that provided cost justification for the then proposed rates.  That study was all about SMUD's marginal cost, as I explained during the rate hearing.  There was no mention of SMUD's "embedded cost". 

#6  Regarding the 3rd comment in the Staff Assessment, slide #14, Alternative Recommendation #4, "Adjusting marginal cost based rates by a scalar is an accepted practice by the industry (also referred to as equal percent of marginal costs or EPMC)" the electric utility industry is NOT subject to Article XIII C of the California Constitution with the exception of municipal utilities and municipal utility districts in the State of California.  Therefore it is irrelevant whether this "is an accepted practice by the industry."  That does not satisfy Article XIII C.

#7  Page 35 of the 2018 SMUD Annual Report shows a big increase of $209 million in the Total net position, from $1,512 (million) to $1,721 (millio) at the end of 2017 and 2018, respectively on operating revenues of $1.595 billion.  As a percentage of operating revenues this is 13.10%.  That is probably higher as a percentage than PG&E's net income.

#8  According to SMUD's 5 YEAR SUMMARY (Unaudited) on page 26 of the 2018 SMUD Annual Report Average revenue per residential kWh sold (cents) went up to 14.43 in 2018 from 14.05 in 2017.  This is a 2.7% increase.

#9  Page 11 of the CEO and GM Report for 2017 says in part, "The proposed rate increases for 2018 and 2019 represent an average revenue increase of 1% per year.  These increases will generate an additional $40 million over two years to fund technology and grid modernization investments."  It is clear that your current rates are an increase over the rates previously in place.
 
#10  Page 21 of the CEO and GM Report for 2017.  “Table 3 shows the effect of the recommended 1.5% rate increase in 2018 for the residential class and the recommended 1.0% rate increase in 2018 followed by a 1.0% rate increase in 2019 for non-residential classes.”  For residential the 2018 Revenue Forecast is $627.43 million and with the Proposed Increase it is $636.95 million.  Again it is clear that your current rates are an increase over the rates previously in place.

#11  Page 40 of the 2018 SMUD Annual Report shows operating income of $242 million in 2018 on operating revenues of $1.595 billion, up from $216 million in 2017.  As a percentage of operating revenues this is 15.17%.  That is probably higher as a percentage than PG&E's net income.  SMUD's rates are way higher than they need to be.

That is all.  What are your comments and responses to my comments?


June 17 - Stephen F.

Mark,

The new structure appears to me to raise the rates by a total of 11.25% over the next thirty (30) months.  That is a full two % points higher.  What changed?

The District is working to lower the energy use impact by considering changing out bulbs to LEDs, replacing fixtures with efficient LED’s and installing solar lighting on new opportunities.

We manage our thermostats and lighting in the best way possible but to provide a safe environment for park users after the sun goes down.  I try to do the same with my energy use at home.

I know rate increases are a necessary evil to pay for infrastructure upgrades, but I do not like the impact on the District’s budget.

I hope that my comments are heard, but I am not certain if they will have an effect on the outcome.

Thank you,

Stephen F.


June 17 - Jennifer W.

To whom this may or may not concern:

I am sure that my opinion will not matter on this deal as to why as a Sacramento resident our SMUD is costing more to be delivered to us between certian hours of the day!

It has not cost more with the exception of summer months in comparison to winter months.

Why all of a sudden the price hike?

If whoever gets this letter will kindly pass it on to someone who might value my opinion I would appreciate it.

Thank you.

Jennifer W.


June 17 - Kathy R.

Hello SMUD Directors,

As a SMUD ratepayer and Sacramento County resident, I am writing today to express my complete opposition to SMUD's current rate proposal to increase rates by 3.75% on Jan 1, 2020, 3% on Oct 1, 2020, 2.5% on Jan 1, 2021 and 2% on Oct 1, 2021. A cumulative rate increase of 11.25% in a two year period is egregious. It is also a slap in the face to ratepayers to move a revised proposal that has a 2% additional increase in rates after ratepayers expressed concern with the previous rate increase that was cumulatively 9.25% over two years, and seems punitive. I urge you to reject this rate increase at the June 24th Board Meeting.

-- Kathy R.


June 16 - Joel T.

Hello SMUD Directors,

As a SMUD ratepayer and Sacramento County resident, I am writing today to express my complete opposition to SMUD's current rate proposal to increase rates by 3.75% on Jan 1, 2020, 3% on Oct 1, 2020, 2.5% on Jan 1, 2021 and 2% on Oct 1, 2021. A cumulative rate increase of 11.25% in a two year period is egregious. It is also a slap in the face to ratepayers to move a revised proposal that has a 2% additional increase in rates after ratepayers expressed concern with the previous rate increase that was cumulatively 9.25% over two years, and seems punitive. I urge you to reject this rate increase at the June 24th Board Meeting.

-- Joel T.


June 15 - Don L.

Hello SMUD Directors,

As a SMUD ratepayer and Sacramento County resident, I am writing today to express my complete opposition to SMUD's current rate proposal to increase rates by 3.75% on Jan 1, 2020, 3% on Oct 1, 2020, 2.5% on Jan 1, 2021 and 2% on Oct 1, 2021. A cumulative rate increase of 11.25% in a two year period is egregious. It is also a slap in the face to ratepayers to move a revised proposal that has a 2% additional increase in rates after ratepayers expressed concern with the previous rate increase that was cumulatively 9.25% over two years, and seems punitive. I urge you to reject this rate increase at the June 24th Board Meeting.

-- Don L.


June 14 - Nicolas G.

Hello SMUD Directors,

As a SMUD ratepayer and Sacramento County resident, I am writing today to express my complete opposition to SMUD's current rate proposal to increase rates by 3.75% on Jan 1, 2020, 3% on Oct 1, 2020, 2.5% on Jan 1, 2021 and 2% on Oct 1, 2021. A cumulative rate increase of 11.25% in a two year period is egregious. It is also a slap in the face to ratepayers to move a revised proposal that has a 2% additional increase in rates after ratepayers expressed concern with the previous rate increase that was cumulatively 9.25% over two years, and seems punitive. I urge you to reject this rate increase at the June 24th Board Meeting.

-- Nicolas G.


June 13 - Amador R.

Thank you for allowing me to comment. I have read the well written, properly documented comments, opposing the proposed rate increases. I too am opposed to such increases. I am writing as a common consumer, one who pays the bill every month. Your proposed increases and the argument for it are so typical of the way this state operates. California is known for having the lowest IQ when it comes to finding solutions ...”just charge more.” Politicians do it, excluding themselves from it, utilities do it to cover their mistakes or faults. For all the talk about California being the leader of a cleaner, purer, fairer...blah...blah...blah, more compassionate world, all we see is higher prices. If, as a consumer, I dare to save more, I will eventually pay more because...”our revenue has come down...” It happened when we saved water and it happens when we use less electricity or gas. My suggestion is that SMUD ( or any other public entity ), if indeed must increase the rates, limits the increases to no more than the actual inflation rate. Thank you

Amador R.


June 13 - Shaun D.

Hello SMUD Directors,

As a SMUD ratepayer and Sacramento County resident, I am writing today to express my complete opposition to SMUD's current rate proposal to increase rates by 3.75% on Jan 1, 2020, 3% on Oct 1, 2020, 2.5% on Jan 1, 2021 and 2% on Oct 1, 2021. A cumulative rate increase of 11.25% in a two year period is egregious. It is also a slap in the face to ratepayers to move a revised proposal that has a 2% additional increase in rates after ratepayers expressed concern with the previous rate increase that was cumulatively 9.25% over two years, and seems punitive. I urge you to reject this rate increase at the June 24th Board Meeting.

-- Shaun D.


June 7 - Cynthia L.

Re: Proposed Rate Change in 2020 and 2021

Dear SMUD:

Have mercy on us seniors!
I am 78 years old, and no longer have earning power. I live on a fixed income, and the annual increases on that income equal approximately 2% per year, if there is an increase at all. (We went three years with $0 increase in Social Security).

First you charge more for time-of-day usage, and now you want to charge 4+% on top of that. So that means financially I am going backwards -- it is not even a break even.

Please consider seniors. For every time there is a price increase, we slide backwards. It adds even more to the stress of being elderly.

Sincerely,
Cynthia L.


June 5 - Colleen O.

Re:   proposed rate change

Yes, I want to comment.  It seems like every time a few months go by, you're once again asking to raise your rates.  You ask for more increases, more often, and of a greater percentage than any other utility I have.   

Your last and  rather recent change was the Time of Day increases.  That's been a real challenge to deal with  and  still trying to keep my bill down to where I can afford it.  

Now you're talking about another almost 10% increase over the next two years!!   Isn't that a bit much to ask for?  If you're going to ask for that, then I suggest you do something to give back to your customers who are trying so hard to keep their electricity usage low. . . .  like how about  getting rid of the "time of day" increase.  That would be more fair and acceptable to your customers, I'm sure.  

Seems like the more I (we) try to accommodate you by using less electricity, the more you ask for MORE $$$$$.  I'm really beginning to doubt the sincerity of SMUD in always insisting that they're working hard to keep our rates down.  Doesn't look that way to me anymore.

Sincerely,

colleen o. 


May 31 - Jennifer V.

Hi Dan and Roshini –

Last week we had a good discussion with Kelvin to understand SMUD’s proposed 2019 business rate changes. For 2020, it’s a proposed 4.75% rate increase, and 4.5% increase in 2021. The Board is scheduled to consider these rates next week, June 6. SMUD expects at least 4% rate increases every year for at least the next 8 years.

In addition to the rate increase, there’s also rate restructuring that will especially impact accounts with lower or intermittent energy use. SMUD is upping fixed charges and dropping the energy rates, so things like sumps and pumps will experience greater impact.

Kelvin is collecting some additional data on account impacts. For now, I am sending you the link to the fact sheet and general info

The rate restructuring will diminish the SolarShares benefit, but we still expect to realize savings through the program.

I think it would be a good idea for Kelvin to meet with you directly to share additional context. We are still assessing the information as well. I’m also preparing an internal write-up for fiscal considerations.

Best,
Jennifer V


May 30 - Mel S.

Subject: 2020 & 2021 Rate Increases

SMUD

Here are my comments re: the rate increases proposed for the next couple years. Though the purposes of how the rate increases will be spent are OK with me, the increases themselves I OPPOSE. 

     My reasons are due to the RATE INCREASES with the TIME-OF-DAY-RATE that went into effect this year. The 12 hours of the day most of us are awake have increased from June through September by around 20 to over 100%!!!

That DOES NOT balance the decreases of about 15-18%. during off peak times.

     Overall that means 3 years in a row of increases that total over 10-12% at least. It seems with the 2019 increase you should be able to cover some or most of the costs proposed for the 20/21 increases. 

Thanks for listening,

Mel S.


May 30 - Mark G.

Comments on SMUD rate action June 2019 set 2 May 30, 2019

Hello SMUD,

Here are some, but not all, of my comments on the rate action for June, 2019. Please forward these to the Board of Directors and staff. Also please post these on the SMUD website.

Thank you.

Mark G.

Comments:

#0-4. The proposed new rates shown on page 89 of the CEO and GM Report for 2019, volume 1, are the result of adding 4.75% and then 4.5%, respectively, to the 2019 rates for residential to get the proposed 2020 and 2021 rates. The 2019 rates, described in the CEO and GM Report for 2017 in Appendix I, pages 109 - 112, are based on the draft report titled "2017 (sic) Residential Time-of-Use Rate (RT02) Design Study," dated November 30, 2016.

 

Table M of that RT02 study shows, on page 14, that SMUD has introduced an addition to the proposed rates called a "scalar" a mounting to 9.2%. SMUD's explanation is, "The proposed time-of-use energy rate is completed by setting proposed rate revenues equal to rate revenues for the budget year. The reconciliation of marginal costs to rate revenues is accomplished through increasing final marginal cost energy charges by a scalar of 9.2%"

("2017 (sic) Residential Time-of-Use Rate (RT02) Design Study," dated November 30, 2016, page 14)

It is readily apparent that the proposed 2020 and 2021 rates incorporate the RT02 Design Study. That is the RT02 Design Study is built into the proposed 2020 and 2021 rates.

#0-C1. SMUD has made a mistake in the Summer off peak rate for 2020, showing "Summer Off-Peak per kWh $0.1222." It should be $0.1221.

#0-C2. Thank you for making the CEO and GM Report for 2019 copyable. You never did this for the 2017 CEO and GM Report despite my repeated requests and despite the public convenience that a copyable version provides.

Correction to comment #1-16:

#1-16 Article XIII C of the California Constitution provides several exceptions to the definition of a “tax”, one of which is charges “imposed for a specific government service or product provided directly to the payor that is not provided to those not charged, and which does not exceed the reasonable costs to the local government of providing the service or product.” (Art. XIII C, § 1, subd. (e)(2)).

 

ARTICLE XIII C [VOTER APPROVAL FOR LOCAL TAX LEVIES] [SECTION 1 - SEC. 3]

( Article 13C added Nov. 5, 1996, by Prop. 218. Initiative measure. )

 


 

SECTION 1.

 

Definitions. As used in this article:

 

  1. “General tax” means any tax imposed for general governmental purposes.
  2. “Local government” means any county, city, city and county, including a charter city or county, any special district, or any other local or regional governmental entity.
  3. “Special district” means an agency of the State, formed pursuant to general law or a special act, for the local performance of governmental or proprietary functions with limited geographic boundaries including, but not limited to, school districts and redevelopment agencies.
  4. “Special tax” means any tax imposed for specific purposes, including a tax imposed for specific purposes, which is placed into a general fund.
  5. As used in this article, “tax” means any levy, charge, or exaction of any kind imposed by a local government, except the following:
    1. A charge imposed for a specific benefit conferred or privilege granted directly to the payor that is not provided to those not charged, and which does not exceed the reasonable costs to the local government of conferring the benefit or granting the privilege.
    2. A charge imposed for a specific government service or product provided directly to the payor that is not provided to those not charged, and which does not exceed the reasonable costs to the local government of providing the service or product.
    3. A charge imposed for the reasonable regulatory costs to a local government for issuing licenses and permits, performing investigations, inspections, and audits, enforcing agricultural marketing orders, and the administrative enforcement and adjudication thereof.
    4. A charge imposed for entrance to or use of local government property, or the purchase, rental, or lease of local government property.
    5. A fine, penalty, or other monetary charge imposed by the judicial branch of government or a local government, as a result of a violation of law.
    6. A charge imposed as a condition of property development.
    7. Assessments and property-related fees imposed in accordance with the provisions of Article XIII D.

 

The local government bears the burden of proving by a preponderance of the evidence that a levy, charge, or other exaction is not a tax, that the amount is no more than necessary to cover the reasonable costs of the governmental activity, and that the manner in which those costs are allocated to a payor bear a fair or reasonable relationship to the payor’s burdens on, or benefits received from, the governmental activity.

(Sec. 1 amended Nov. 2, 2010, by Prop. 26. Initiative measure.)

Article XIII C, section 2(d) says:

(d) No local government may impose, extend, or increase any special tax unless and until that tax is submitted to the electorate and approved by a two-thirds vote. A special tax shall not be deemed to have been increased if it is imposed at a rate not higher than the maximum rate so approved.

 


 

(Sec. 2 added Nov. 5, 1996, by Prop. 218. Initiative measure.)

Comment: The 9.2% scalar is NOT part of SMUD’s reasonable cost of providing the electricity service. Therefore the current time of day (TOD) rates (2019) adopted in the June 2017 rate action are taxes. We have seen that the proposed rates for 2020 and 2021 are simply the current rates plus 4.75% and then 4.50%, respectively. SMUD has not backed out the 9.2% scalar from the current rates before adding the 4.75% and then 4.50%. Therefore the proposed rates are unconstitutional, in violation of Article XIII C, section 2(d).

 

My next few comments are related to the proposed rate increases for 2020 and 2021 and the following recent California court case:

CERTIFIED FOR PUBLICATION

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA

FOURTH APPELLATE DISTRICT

DIVISION THREE

 

CAPISTRANO TAXPAYERS ASSOCIATION, INC.,

Plaintiff and Respondent, v.

CITY OF SAN JUAN CAPISTRANO,

Defendant and Appellant.

G048969

(Super. Ct. No. 30-2012-00594579)

 

In Capistrano the Court wrote:

“The way Proposition 218 operates, water rates that exceed the cost of service operate as a tax, similar to the way a ‘carbon tax’ might be imposed on use of energy. But, we should emphasize: Just because such above-cost rates are a tax does not mean they cannot be imposed – they just have to be submitted to the relevant electorate and approved by the people in a vote. There is no reason, for example, why a water district or local government cannot, consistent with Proposition 218, seek the approval of the voters to impose a tax on water over a given level of usage – as we indicated earlier, that might be a good idea. However, if a local government body chooses to impose tiered rates unilaterally without a vote, those tiers must be based on cost of service for the incremental level of usage, not pre-determined budgets.”

 

(Order modifying opinion; no change in judgment, dated May 19, 2015.)

 

#1-17 Regarding the scalar of 9.2% in Table M, SMUD should consider and incorporate into its proposed rates for 2020 and 2021 the above quotation from this Capistrano case because it is directly applicable to the proposed rates. Even though it is about Proposition 218, which does not apply to electricity rates, it is analogous to Proposition 26 which does.

 

#1-18 This Capistrano case set a precedent applicable to the SMUD proposed residential rates for 2020 and 2021. As such it is legally binding on SMUD. SMUD must comply with Proposition 26 as the Court explained in the context of Proposition 218.

 


 

 

#1-19 The above cited quotation from Capistrano is directly applicable and relevant to SMUD’s 9.2% scalar in Table M. In particular SMUD’s explanation for adding in the 9.2% scalar in the current rates, found between Tables L and M on page 14 of the Rate Design Study RT02 for 2018, which is shown next, is just the same as a “pre-determined budget” from the above cited Capistrano case.

 

The proposed time-of-use energy rate is completed by setting proposed rate revenues equal to rate revenues for the budget year. The reconciliation of marginal costs to rate revenues is accomplished through increasing final marginal cost energy charges by a scalar of 9.2%.

 

The Capistrano case says that SMUD cannot do what it said in the above indented quotation. SMUD’s “reconciliation of marginal costs to rate revenues” is just the same as basing rates on “pre-determined budgets.”

 

#1-429-1

 

SMUD’s response and failure to answer most of my questions is not conducive to transparency in government or to Ordinance 15-1 or to the California Government Code section 54950, which says:

 

In enacting this chapter, the Legislature finds and declares that the public commissions, boards and councils and the other public agencies in this State exist to aid in the conduct of the people’s business. It is the intent of the law that their actions be taken openly and that their deliberations be conducted openly.

The people of this State do not yield their sovereignty to the agencies which serve them. The people, in delegating authority, do not give their public servants the right to decide what is good for the people to know and what is not good for them to know. The people insist on remaining informed so that they may retain control over the instruments they have created.

(Added by Stats. 1953, Ch. 1588.)

 

 

http://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=GOV&division=2.&tit le=5.&part=1.&chapter=9.&article=

 

#1-429-2 All SMUD customers, not just me, have a right to know SMUD's answers to the questions I asked about the law as it pertains to SMUD and the proposed rate increases for 2020 and 2021. The proposed rate increases for 2020 and 2021 and the CEO and GM Report 2019 is FULL of statements about the law and "legal conclusions" which you claim to be so afraid of, in particular about the applicability of Proposition 26 to the proposed rates. Since your Report is full of legal statements you (or some other department in SMUD, possibly the Legal Department) should be willing to and capable of answering questions about the same.

 


 

https://www.smud.org/en/Corporate/About-us/Company-Information/Reports-and- Statements/GM-Reports-on-Rates-and-Services

 

#1-429-3 Ordinance 15-1 by SMUD is the ordinance currently in effect that governs this current rate process. Section 2(h) of that ordinance says in full:

 

(h) Members of the public may submit questions related to the Report in writing at any time after release of the Report up until five (5) business days prior to the public hearing. To the extent practicable, SMUD staff shall respond to such questions in writing within five (5) business days of receipt. Questions received after 5:00 p.m. shall be deemed to have been received on the next business day. SMUD staff will provide notice in the event that complex questions require additional time.

 

There is no distinction made between questions about the law as it pertains to the SMUD proposed rate increases and questions about anything else. SMUD is supposed to answer all questions submitted, related to the Report, in writing any time up until 5 business days (that is five) prior to the public hearing.  You are supposed to respond to such questions in writing within 5 business days of receipt. Therefore according to Ordinance 15-1 SMUD should answer, and should have already answered, all legal questions it received about the Report and the proposed rates for 2020 and 2021. SMUD has failed to do that.

#1-429-4

SMUD’s answers (actually failure to answer and excuse for such failure) to my questions 1-3, Set 1, are false. SMUD wrote that those questions are, “Not related to the 2019 GM Report.”

My questions are directly related to the Chief Executive Officer and General Manager’s Report and Recommendation on Rates and Services, March 21, 2019 • Volume 1, in particular to the quotation from that Report that I cited in my questions. SMUD has failed to answer questions related to the 2019 GM Report.

#1-429-11

SMUD’s answer to my question #11, Set 1, is false. My question was, "#11 When was the last time SMUD prepared a new rate design study prior to the one it prepared in connection with the CEO and GM Report 2017?" Your answer, in full, was, "Question # 11 –The 2014 SmartPricing Options Final Evaluation Study" That study was not a rate design study. SMUD has given a false answer to a question related to the 2019 GM Report.

#1-429-12

SMUD’s answer to my question #12, about the 9.2% scalar included in the 2019 rates and, by extension, in the proposed 2020 and 2021 rates, is obviously false. My question was, “The question here is, are the proposed rate increases for 2020 and 2021 based, in part, on the scalar of 9.2%?”

SMUD’s answer was, “The scalar is not related to the 2019 GM Report. The 9.2% scalar was part of the rate proposal the Board adopted in 2017. The proposed rates for 2020 and 2021 are based on the current rates.” Of the three sentences of SMUD’s answer the first one is false and the second and third are true. Overall SMUD’s answer is false.

 


 

SMUD has made no effort to remove the scalar from the proposed 2020 and 2021 rates. Insofar as the 9.2% scalar from the current rates AND the current rates are taxes as defined in Article XIII C of the California Constitution, and because SMUD may not “impose, extend, or increase any special tax unless and until that tax is submitted to the electorate and approved by a two- thirds vote” the proposed rates are unconstitutional.

 

The current rates include the scalar. For proof please see my Set 1 of questions and also the RT02 rate design study. The CEO and GM Report and Recommendation on Rates and Services, Volume 1, Appendix I, is a letter from NERA Economic Consulting to SMUD on NERA's review and assessment of the proposed rates. NERA says they reviewed a few documents including that RT02 rate design study. That study includes and incorporates the 9.2% scalar that I asked about. When you say that, "The proposed rates for 2020 and 2021 are based on the current rates" that is true, and that is why SMUD should admit that the proposed rate increases for 2020 and 2021 based, in part, on the scalar of 9.2%.

 

The scalar is in the current rates and the proposed rates for 2020 and 2021 are based on the current rates. Therefore the scalar is also in the proposed rates for 2020 and 2021.

#3-1 through #3-4

SMUD dodged and failed to answer any of my questions, Set 3, about the proposed rates. This is a pattern at SMUD. SMUD also failed to answer the vast majority of my 19 questions in Set 1. This is gutless and irresponsible. It is contrary to the Government Code section 54950, contrary to SMUD’s purpose as a PUBLIC utility, and it reflects SMUD’s attitude of secrecy, laziness and deception when it comes to letting its customers know what it proposes to do. This attitude surely starts at the top with CEO and GM Arlen Orchard, and trickles down to all staff. Orchard ought to be directed by the Board to change his attitude regarding answering customer questions. Same with General Counsel Laura Lewis. The SMUD customers deserve much better.

#3-2    SMUD has failed to cost justify the proposed 2020 and 2021 rates. SMUD should postpone the vote on the proposed rates for 2020 and 2021 until it cost justifies the rates.

 

SMUD has published a Chief Executive Officer and General Manager’s Report and Recommendation on Rates and Services, March 21, 2019 • Volume 1 and 2, (the “Report”) and addenda 1 and 2. I also have the 2019 rate costing study. There is no cost justification in the Report.

 

That Report says on page 113, in a section called "Compliance":

 

The proposed rate adjustments are based upon cost of service principles, because these adjustments bring charges closer to recovering the cost of service, and the extent to which they exceed cost is the result of grandfathered rate-making legislative choices that predate Proposition 26, which the measure does not disturb.

The cost-of-service analysis that demonstrates cost-justification for the proposed rates is the SMUD Rate Costing Study (March 2019) (“2019 Rate Study”) which is incorporated herein by this reference.

 


 

That is a theoretical statement, a claim that may or may not be true (supported) depending on the facts and figures that SMUD presents or might present to support it. The 2019 Rate Study does not appear to support that theoretical statement.

 

The only table in the SMUD Rate Costing Study that shows costs per kWh in each time of day period is

 

Table 3.1 Generation Marginal Costs by Time-of-Use Period* (2019$) on page 8.

 

But that is obviously incomplete; there must be more marginal costs that are not shown there. The other tables in that study are:

 

Table 4.1 Marginal T&D Capacity Costs ($/kW-year)* on page 9 and Table 5.1 Customer-related Marginal Cost ($/customer-year) on page 12.

Notice the units in Tables 4.1 and 5.1. SMUD has failed to translate the figures in Tables 4.1 and 5.1 into units of ($/kWh). Therefore it is not possible to add the marginal costs shown in those tables to the Generation marginal costs shown in Table 3.1 Therefore SMUD has failed to show that the proposed rates for 2020 and 2021 are cost justified. SMUD should publish on its website all of that data now in an addendum to the Report.

 

As you know the proposed rates, shown in detail on page 89 of the Report, include for 2020

$0.2970 for Summer Peak, $0.1688 for Summer Mid Peak and $0.1222 for Summer Off Peak. The unnumbered table on page 89 of the Report shows the detail of rate changes.

The current rates are $0.2835, $0.1611 and $0.1166 respectively for each of those time of day periods.

 

Here are the data from Table 3.1.

 

This is an image I have placed in the body of these comments. If you do not see it please refer to Table 3.1 on page 8 of the Rate Costing Study for 2019.

 

Time-of-Day period information

Here are the proposed rates for TOD 5-8 p.m. for 2020.

This is an image I have placed in the body of these comments. If you do not see it please refer to page 89 of the CEO and GM Report for 2019.

 

Residential Time-of-Day RT02 table

Obviously something is missing. SMUD has failed to cost justify the proposed 2020 and 2021 rates.

For example for the Summer Peak you propose a rate of $0.2970 for 2020 but you have only justified $0.1768. And so on across the table. SMUD has only cost justified 50-60% of its proposed rates for 2020 and 2021.

SMUD should publish on its website all the missing data in terms of marginal costs (or whatever other costs you are using) to bridge the gap between the data in Table 3.1 and the proposed rates for TOD for 2020. There is a similar gap between the data in Table 3.1 and the proposed rates for TOD for 2021; SMUD should publish that data too.

#530-1

SMUD should publish on its website and in an Addendum to the current CEO and GM Report, and in all future rate reports, a complete glossary including definitions of all terminology

 

including, but not limited to, terminology from economics, energy, and anything that might be unfamiliar to the layman. Unfortunately despite my comments last year and SMUD’s statement that it would do so, SMUD has failed to do so. This leaves SMUD’s report, its rate design studies, its consultant letters including letters from NERA Economic Consulting, and its rates and rate resolutions and attachments incomprehensible to most people. This is not conducive to transparency or good government.


May 30 - Mark G.

Comments on SMUD rate action June 2019 May 30, 2019

Hello SMUD,

Here are some, but not all, of my comments on the rate action for June, 2019. Please forward these to the Board of Directors and staff. Also please post these on the SMUD website.

Thank you. Mark

Comments:

SMUD has published a document titled Chief Executive Officer and General Manager’s Report and

Recommendation on Rates and Services, March 21, 2019 • Volume 1. I will call this the “CEO and GM Report 2019”. In this document SMUD claims:

 

ComplianceIntroduction

California voters approved Proposition 26 in November 2010, and that measure provides that every “levy, charge, or exaction of any kind imposed by a local government” is treated as a tax subject to voter approval, with exceptions discussed below. (Cal. Const., art. XIII C, § 1, subd. (e).) Proposition 26 therefore applies only to charges that are “imposed” by local government.

SMUD rates are not “imposed” on customers for purposes of Proposition 26, because that language requires some exercise of government force or authority, which is not involved when a public agency such as SMUD provides services to customers in a competitive market. SMUD customers pay only for the voluntary use of service, and they have meaningful alternatives to that service, such as self-generation with solar, hydro, fuel cell, wind and geothermal power.

 

(page 113)

 

#1-1 As long as SMUD is using the preceding analysis as its excuse for its failure to comply with Proposition 26 SMUD should state and publish on its website approximately many customers in the SMUD service area (or persons who might otherwise be SMUD customers if they really needed SMUD for electricity) currently receive electricity via self-generation with solar, hydro, fuel cell, wind and geothermal power.

 

#1-2 As long as SMUD is using the preceding analysis as its excuse for its failure to comply with Proposition 26 SMUD should state and publish on its website identify the sources from which a person


living in the SMUD service area might be able to obtain electricity service such as self-generation with solar, hydro, fuel cell, wind and geothermal power. By source I mean a commercially available source such as a company that sells to individuals.

 

#1-3 As long as SMUD is using the preceding analysis as its excuse for its failure to comply with Proposition 26 SMUD should state and publish on its website approximately how much money would a person living in the SMUD service area have to invest in equipment in order to be able to obtain electricity service from sources such as self-generation with solar, hydro, fuel cell, wind and geothermal power. (Publish data for each source if you can.)

 

#1-4 SMUD should consider the following case in regards to SMUD’s argument quoted above that its rates are not imposed and therefore not subject to Proposition 26.

CITIZENS FOR FAIR REU RATES et al. v. CITY OF REDDING et al., California Supreme Court case S224779, (Ct.App. 3 C071906, Shasta County Super. Ct. Nos. 171377, 172960).

 

The decision of the Court of Appeal was reversed; however the following statement by the Court of Appeal was not reversed. In other words the decision was reversed on other grounds. The Court of Appeal addressed this exact argument that SMUD has made about its electric rates not being

“imposed”.

 

Redding argues Proposition 26 does not apply because the Utility’s rates (including the PILOT component) are not “imposed.” Redding reasons that “[e]ven if the PILOT were funded by [electric] rates, no force or authority is involved here -- those who wish to buy energy from [the Utility] pay the PILOT (and other costs argued to be funded by [the Utility’s] service rates) only to the extent they use its service. Those who obtain energy in other ways do not. [There are] other alternatives to electric utility service (such as solar, water, wind and geothermal power)   ” The trial court rejected the argument,

pointing out that while “legally [the Utility] has no monopoly as an electric utility, the reality is that for many people there are no economically viable alternatives. The Court used the example of a tenant who is renting a house or apartment that is served by [the Utility]. While theoretically possible that a tenant who does not wish to use [the Utility] could install an alternate power source, that is simply not a realistic option.” We agree. A tax does not lose its revenue-generating character because there is a theoretical but


unrealistic way to escape from the tax’s purview. The PILOT was imposed under Redding’s authority to generate revenue for its general fund.

 

We also reject Redding’s argument that the PILOT was never “imposed” by “force

or authority” because the one percent levy was collected in customer bills for electric service. For guidance, we turn to the instructive case of Howard Jarvis Taxpayers Assn

v. City of La Habra (2001) 25 Cal.4th 809, 823 (La Habra). In La Habra, the California Supreme Court considered the question of when a tax on utility rates is “imposed.” (Id. at p. 818.) The city argued the tax was not imposed until the voters approved the levy. (Id. at pp. 817-818.) The Supreme Court rejected the proposition that “when a city

disregards the approval requirement in imposing a tax, the imposition has never happened and thus may not be challenged.” (Id. at p. 818.) The La Habra court held Proposition

62, which added voter-approval requirements for local taxes, “prohibited the imposition of a general tax ‘unless and until such general tax is submitted to the electorate.’ (Gov. Code, § 53723.) That command is allegedly violated each time the City collects its utility tax through the service providers.” (La Habra, at p. 823, italics added.) The same reasoning applies here. That the PILOT in this case may be collected through electric service bills does not by itself render Proposition 26 inapplicable.

(pages 13-14)

 

SMUD should have considered the Redding case in regards to SMUD’s argument that, “SMUD rates are not ‘imposed’ on customers for purposes of Proposition 26”.

#1-5

Redding (the above discussed case) set a precedent applicable to SMUD’s new Time of Day and Fixed Rate electricity rates. Remember that although the decision was reversed on appeal the quoted analysis and disposition from the Court of Appeal of the City of Redding’s argument that its rates were not

“imposed” was not reversed. In other words the decision was reversed on other grounds.


#1-6 As long as SMUD is failing to comply with Proposition 26 SMUD should state and publish on its website Its legal response to the argument in Redding. You should state how and why in SMUD’s opinion the Court of Appeal’s analysis and disposition of the City of Redding’s argument does not apply to SMUD’s new Time of Day and Fixed Rate electricity rates.

 

#1-7 As long as SMUD is failing to comply with Proposition 26 SMUD should state and publish on its website Its legal basis for its argument, quoted above, that its rates are not imposed. SMUD should state whether it has or is aware of any case law or other legal authority to that effect and identify such case law or other legal authority if so. Identify the court, if any, that has agreed with the argument that SMUD makes about its rates not being “imposed” and therefore not subject to Proposition 26.

 

#1-10 If SMUD has done a new rate design study and has not made it available to the public, please do so immediately as part of this rate process. Although this should not be necessary you may consider this to be my Public Records Act request for said rate design study.

 

The next several questions are about the CEO and GM Report 2019 and the following documents.

 

The CEO and GM Report 2017 contained, as Appendix I, a letter dated December 6, 2016 a letter from NERA Economic Consulting addressed to SMUD’s Resource Planning and Pricing Department (RP&P). The subject of the letter was NERA’s independent review of SMUD’s 2016 Marginal Cost of Service (MCS) Study and its proposed residential Time of Use (TOU) rates for the period 2017 – 2019. That letter was pages 109 – 112.

 

Among the documents that NERA reviewed was SMUD’s “2017 (sic) Residential Time-of-Use Rate (RT02) Design Study”. I will call that the “RT02 Design Study”.

 

Table M of that study, on page 14, shows that SMUD took the “Total Energy Marginal Cost”, which was the final column in Table L (also on page 14) and added what SMUD calls a “scalar” of 9.2% to reach the “2017 Energy Charges” (final column of Table M).

 

SMUD’s explanation of this scalar, right in between Tables L and M, is:

 

The proposed time-of-use energy rate is completed by setting proposed rate revenues equal to rate revenues for the budget year. The reconciliation of marginal costs to rate revenues is accomplished through increasing final marginal cost energy charges by a scalar of 9.2%.


Tables L and M and the explanation in between them are copied and pasted here.

 

Table L: Time-of-Use Energy Marginal Cost

 

 

#12 In the CEO and GM Report 2019 SMUD presents its “Detail of Rate Changes, Years 2020 and 2021 include proposed rate increases, Residential Rates” on page 89. That table for Residential Rates, not otherwise identified, is reproduced here.

 

The CEO and GM Report 2019 says, “SMUD staff recommends a rate increase of 4.75% in 2020 and 4.50% in 2021 for residential and nonresidential customers.” (page 10) The proposed rates in the table on page 89 are 4.75% higher than 2019 rates for 2020 and 4.5% higher than 2020 rates for 2021.

SMUD has not made any effort to eliminate the 9.2% scalar, introduced into the 2019 rates from the proposed 2020 and 2021 rates. Therefore the answer to the following question appears obvious but I will ask it anyway. The question here is, are the proposed rate increases for 2020 and 2021 based, in part, on the scalar of 9.2%?

 

#1-13 SMUD must eliminate the 9.2% scalar from the proposed rates for 2020 and 2021 to comply with Proposition 26.

 

#1-14 Related to the previous item, the proposed rates for 2020 and 2021 are based on the current (2019) rates.

 

#1-15 The scalar of 9.2% identified earlier built into the proposed rates for 2020 and 2021.

#1-16 Article XIII C of the California Constitution provides several exceptions to the definition of a “tax”, one of which is charges “imposed for a specific government service or product provided directly to the payor that is not provided to those not charged, and which does not exceed the reasonable costs to the local government of providing the service or product.” (Art. XIII C, § 1, subd. (e)(2)).

The 9.2% scalar, in SMUD’s opinion, is NOT part of SMUD’s reasonable cost of providing the electricity service.

 

To be continued.

Thank you,

Mark G.


May 29 - Don G.

Read this customer's letter to SMUD


May 23 – Maxine S.

 

Re: Proposed Rate Increases

 

Dear SMUD,

 

Please, raise your rates! The only thing this customer wishes you would do is to structure your billing progressively. Target customers actually causing increased costs and consuming excess energy when you raise those rates. Please do not apply the typical regressive billing schemes you tend to favor. It hurts customers who do not live in fire-prone areas or make an enormous carbon foot-print with their excesses. Raise your rates SMUD! Just do it in a smarter, fairer, progressive way. Just do it so minimalist customers do not have to subsidize those who chose to live in paradise or squander resources with abandon.

 

Thank you,

Maxine S.


May 23 - Anonymous

The recent time-of-day rate increase has drastically changed my way of life. On fixed incomes. Need to cook, wash, dry, cool, heat as little as possible 5-8 to KEEP total bill somewhat low like it used to be. Now 2 new rate increases are needed??? PLEASE do not make our needs unaffordable!!! Budget and economize better and HOLD costs. 


May 22 - Ahmad F.

Re: SMUD Commercial Rate Restructure

 

I have reviewed SMUD’s proposal to restructure its commercial retail rates as presented in the Chief Executive Officer and General Manager’s Report and Recommendation on Rates and Services, March 21, 2019 – Volume 1 (Report). The rationale for restructuring commercial rates and the specifics of the rate changes are summarized in pages 55-74 of the Report.

 

SMUD has identified three major problems with the current rate designs:

 

First, the time periods are no longer aligned with the market costing periods due to the Duck Curve phenomenon created by the rising share of renewable energy resources in the energy supply mix. As shown in Figure 21 in the Report, in 2018, prices rise later in the day, which is quite different from the situation that existed in 2010. Higher prices are now occurring late in the evening as opposed to around 5 pm. By changing the definition of the pricing periods, customers will be able to save money by shifting more energy use to when it is less expensive for SMUD to provide it. This will ultimately help lower customer bills.

 

Second, fixed monthly charges are under-recovering fixed costs. The unrecovered amount is recovered in the volumetric charge. Such a volumetrically focused rate design is ill-suited to current business conditions where changes in technology and public policy mandates have changed how customers use energy.

 

Third, the current rate designs are not consistent across customer classes. Some rate classes include demand charges and some don’t. Some include a super peak demand charge while others don’t. However, the cost structure of generating and delivering electricity does not support this disparity across rate classes.

 

Similar rate design challenges are universally present in the electric utility industry across the country and are being addressed by several utilities.

 

SMUD proposes to make several changes in its rate designs for commercial customers that will address these challenges. The details are presented in Figures 24-25 and Tables 15-18. They can be summarized as follows:

  • The timing of the pricing periods will be changed to better reflect the time period of costs
  • Fixed charges will be raised for all classes
  • Energy charges will be lowered for all customer classes
  • Summer Peak Demand charges will be added or raised for all customer classes except the GSN_T class which does not have them, which creates a single price which varies only by voltage.
  • The Site Infrastructure Demand charge will be raised for five classes, lowered for two classes and left unchanged for three; thereby reducing the disparity of this charge across voltage levels.

These changes are designed to make commercial rate designs closer to cost causation, which is by far the most important rate design principle.

The changes will be revenue neutral. Within each class, some customers will see higher bills and some will see lower bills but the magnitude of bill changes for 95% of customers will be smaller than 5% per year (except for the GSN_T in which 95% of customer will sees less than an average of $5 per month per year bill change).

I support these changes because they will yield rate designs that better reflect the cost causation principle. They will improve economic efficiency and equity while also encouraging electrification through lower energy charges.

Sincerely,

Ahmad F., Ph.D. Principal


May 16 - Elaine N.

Customer Services,

Upon speaking with SMUD customer service representative, Cole, this afternoon,  he offered the opportunity to submit the following suggestion to your office.

I discussed with Cole that the cost for my total electricity usage plus Sacramento City Tax and State Surcharge  was less than the System Infrastructure Fixed Charge.  I really try to keep an eye on my energy usage.  While I do not need financial assistance to pay my energy bill, a little bit of encouragement to continue my low usage or even try to get it lower, would be challenging and a good goal.  I think this could be a good plan for others to do the same.

I suggest that SMUD offer a small "reward" or "bonus" or "discount" to those customers whose energy usage is decreased from the previous month.  A small compensation would go a long way in encouraging people to be more aware of their energy usage and be motivated to reduce it.  As an example only, if a customer reduced their energy usage more than 5%, perhaps they could get a $5.00 reduction on their bill.  Just a small amount to remind the customer that their efforts are paying off and they could possibly do even better.

Thank you for the opportunity to comment and offer my suggestion. 

Elaine N.


May 16 - Christine F.

Dear SMUD, 

I will be unable to attend the public hearings, so this is my comment. 

I do not oppose rates changes. 

What I would like to propose is that part of the rate increases go toward removing above ground lines and installing the lines underground. 

A benefit of the change from above to below ground lines is that then, lines could be upgraded as needed. 

Thank you, 
Christine F.


May 15 - William D.B.

 

Hello,

Please consider this a protest by myself, wife, and two children of your rate hike proposal. Also, I have applied for a discount from you, but because I am self-employed, you only consider a certain percentage of business expenses deductible. This is unfair to me and many other self-employed persons who have business with a high percentage of expenses to run their businesses.

William D.B.


May 13 - William M.

Hello,

I just received the latest notice of rate increases for 2020 and 2021 with my current bill.

Your proposed increases are directed at a number of items: reliability during peak demand, technology to support cyber security, customer experience, and support of the Integrated Resource Plan.

First we should review the increases that have already been put in place. The flat fee ratepayers are charged every billing cycle should provide resources to pay for some of the items mentioned in paragraph two. Then there is the time-of-use increase, which should also cover some of the enumerated expenses in paragraph two.

Finally the increases proposed are out of line with the general inflation predicted of 2+%.

In short I think the increases are not justified and should be revisited to make them reflect the economic climate in place and predicted.

--

William M.


May 10 - Rich K.

I am against the proposed rate hike. SMUD has just increased our rates with the Time-of-Day increase, and now they want another increase. $5 a month here, another $5 a month there. All utilities are increasing prices for their customers. It adds up. Heck, my social security benefits can’t keep up. I’m a senior living on my small social security and smaller pension benefits. And I don’t qualify for rate assistance. I can’t afford all these rate increases, even if SMUD promotes low competitive rates. I’m against this latest proposed rate hike. Rich K.


May 8 - Mark G.

Hello Rates person,

You answered my question #14 even though you apparently did not intend to.

Regarding question #12 in Set 1, you wrote:

Question # 12 –The scalar is not related to the 2019 GM Report. The 9.2% scalar was part of the rate proposal the Board adopted in 2017. The proposed rates for 2020 and 2021 are based on the current rates.

The current rates include the scalar.  For proof please see my Set 1 of questions and also the RT02 rate design study.  The CEO and GM Report and Recommendation on Rates and Services, Volume 1, Appendix I, is a letter from NERA Economic Consulting to SMUD on NERA's review and assessment of the proposed rates.  NERA says they reviewed a few documents including that RT02 rate design study.  That study includes and incorporates the 9.2% scalar that I asked about.  When you say that, "The proposed rates for 2020 and 2021 are based on the current rates" that is true, and that is why you should answer my question #12 and all the other questions I asked about that scalar, which are 13, 15, 16, 17 and 19.  The scalar is in the current rates and the proposed rates for 2020 and 2021 are based on the current rates.  Therefore the scalar is also in the proposed rates for 2020 and 2021. 

Please answer questions 12, 13, 15, 16, 17 and 19.  You have admitted that they are relevant to the proposed rates for 2020 and 2021.

Mark G.


May 2 - Joyce Z.

I have been a SMUD customer for a very long time. My biggest complaint is the "set rate" for equipment, which was instigated at around $5 per month and has been steadily going up to $20 + at this point. Except for summer when I run my air conditioner, this set rate is often higher that my actual bill. This strikes me as unfair. Do large electricity users pay this same rate? Why is this rate not a percentage on actual electricity use? In the years I've lived at my present residence, the only "equipment upgrade" (and I use that loosely) was a number of years ago some contractors were sent in to add a support to a large electric pole at the front edge of my property. They put up an ugly metal brace, did not bother to paint it to even remotely match the pole and left dug up clay dirt around the work area, stepping all over my landscaping ruining it for several years. If you are pulling an extra $20 a month from every SMUD customer, it looks like all that extra money could have bought a more professional job on this work. Last, you have set this Draconian summer rate system (who can keep up with all those "better rate" times) and now you probably want to raise all your rates. To say the least, I'm not a happy customer. I don't feel like I'm part of a "community-owned" service since all I seem to be doing is paying higher and higher rates.

Sincerely,
Joyce Z. 


April 29 - Vamshi C.

Hello, Please do not increase any rates as the utility bills keep increasing day by day and affecting our stay in this state. Please consider is going green with affordable prices. Thank you, Regards Vamshi C.


 April 25 - Edd A.

I hope that you have conceded retired people on a fixed income. 

Please add an addendum that over 65 on fixed income will not be subject to the rate increases. 

We don't get rate increases on our 

Fixed income so we  deserve a break.

Taxes and rate increases will  cause us to consider moving. If 1/4 of the over 65 people move out you will be responsible for us taking our money to another county or another state.  

Thanks for hearing my comments. Hope to see this action taken. 

Edd A.


April 25 - Steve H.

Hi,

I was at your meeting solar this week. I heard the mentioning of "climate change" and "CO2" many times. So it seems, dealing with those two COSTS you and then costs me.

Just how much of an increase is it to deal with them?

Do you just accept them as true? Have you ever seen proof? Seen the DATA to support it?

Many say that CO2 causes warming, which causes polar ice to melt, which causes the oceans to have higher tides. If so, why in the following SF Bay tide table are the tides higher in  1885 than the 50s, 60s, or 70s? If you can't answer that, then you are accepting what others are saying without proof and paying for a RUMOR:

Most sincerely,
Steve H.

customer who doesn't like throwing money at costly rumors

https://www.psmsl.org/data/obtaining/rlr.annual.plots/10_high.png


April 23 - Jim P.

Dear SMUD Public Comment Email,

 

Thank you for listening to the public, withdrawing the proposed solar fee, and committing to involve solar customers in your plans going forward. I work for a Sacramento based, family owned Solar Company, and this will likely save my job! I'm 67 years old, and depend on this job for my livelihood. In your future plans, please consider ways you can encourage and incentivize even more SMUD customers to choose solar and energy storage. It would be amazing to have a utility like SMUD taking such steps.

 

Thanks again.
/Jim P.


April 23 - Suzi H.

 

Dear SMUD Public Comment Email,

 

Thank you for listening to the public, withdrawing the proposed solar fee, and committing to involve solar customers in your plans going forward. In your future plans, please consider ways you can encourage and incentivize even more SMUD customers to choose solar and energy storage. It would be amazing to have a utility like SMUD taking such steps.

 

Sincerely,

Suzi H. 


April 23 - Hollynn D.

 

Dear SMUD Public Comment Email,

 

Thank you for listening to the public, withdrawing the proposed solar fee, and committing to involve solar customers in your plans going forward. In your future plans, please consider ways you can encourage and incentivize even more SMUD customers to choose solar and energy storage. It would be amazing to have a utility like SMUD taking such steps.

 

Sincerely,

Hollynn D. 


April 23 - Julie G.

 

Friends at SMUD,

 

Thank you for withdrawing the proposed solar fee from consideration this week.

 

SMUD is known not only nationally, but also internationally, for embracing forward-thinking, large-scale renewable energy and energy efficiency. This recent decision to cancel fees that would disincentivize residential solar is evidence of that.

 

Thank you for considering the input that many customers provided. I, like many others, look forward to working with SMUD to keep the Sacramento region a model for the upcoming energy transition.

 

With deep appreciation,

Julie G.

Proud SMUD customer since 1986 


April 22 - Denise A.

 

Good morning!  As a solar customer, I beg you to meet somewhere in the middle.  The proposed increases pretty much negate the fiscal benefits to going solar.  Since California and the planet depend on our green initiatives, this seems like a backwards move.  Thank you! 


April 22 - Benjamin Z.

 

SMUD

 

A simple request: Please plan to make access to solar power better rather than even more complicated.

 

Sincerely

Benjamin Z. 


April 22 – Anonymous

 

I want to log my opposition to the proposed additional charges for on site energy generation by customers. You claim this is because we use the system more and in different ways which is being subsidized by other non generating consumers but I would point out that I have no choice in the matter because I do not have the option to have my system only supply my needs. When I bought solar I was forced to hook it up to the grid so if SMUD has an outage, I do as well. Therefore, it is unfair to add this additional charge when I have no choice where MY power generation goes. Additionally, SMUD benefits from my production during the day when I am at work by reducing the overall load on the system. If you need to raise funds for wildfire mitigation, maintenance, etc... this should be borne by all consumers. Lastly, you devalue my resale value of my home with this proposal as a sale would trigger the proposed fees immediately for the new owner. I am wholeheartedly opposed to a rate hike in this fashion unless/until SMUD stops forcing power generators to sell their power into the grid. 


April 22 - Julie G.

 

Dear Sir or Madam:

 

Because my letter concerns a proposed policy decision, please forward this letter to SMUD's President and Directors.

 

Thank you.

____________________________________________

To the President and Directors at SMUD:

 

Please reject the proposed solar fee.

 

As current SMUD solar customers, we pay a monthly System Infrastructure Fixed Charge to be connected to the grid. As proposed, this fee would increase five-fold in ten years.

 

This is a contradictory strategy for SMUD, moving us away from energy sustainability, rather than toward it. It penalizes, rather than rewards, customers who are pulling less energy from the grid. This is an about-face for SMUD's previous leadership in the energy field.

 

SMUD invited me to participate voluntarily in Greenergy: I did. SMUD experimented with dairy digesters: I applauded. When a SMUD rep tabling a public event encouraged us to 'install the biggest solar system possible' on our rooftop, with SMUD's support, we did.

 

To our shock and dismay, the new proposed solar fee means that in 2028, our monthly base charge with no actual usage would be more than our full electric bill before we even installed PV.

 

At a time when we need serious options for a sustainable energy transition, the SMUD proposed solar fee is bad for customers like us, businesses like you, and most importantly, bad for the needed move from carbon to renewable energy.

 

Please reject this option.

Julie G.

Proud SMUD customer since 1986 


April 22 - Suzi H.

 

The proposed new fees would punish SMUD customers for going solar and threatens to halt the growth of these local energy resources in SMUD.  These fees could add hundreds of dollars a year to the electricity bills for solar households resulting in no savings and add monthly costs to individual homeowners and thousands of dollars a year for solar churches, businesses and schools.

 

Please do not impose these fees, reevaluate.  Solar homeowners and businesses are willing to pay their far share but the proposals are way too high and will result in many homeowners with solar to remove their panels, resulting in more power usage and probably many solar companies going out of business.

 

Sincerely,

Suzi H. 


April 22 - Suzi H.

 

Dear SMUD Public Comment Email, 

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,

Suzi H. 


April 22 - Erika S.

 

Dear SMUD Public Comments,

 

As a SMUD ratepayer and a solar supporter, I strongly oppose the new solar-only fixed charges recently proposed by your staff. These new solar fees would undermine SMUD customers’ basic right to reduce their purchase of utility-generated power, would increase global warming emissions and air pollution and would put solar out of reach for most SMUD customers. They are the wrong path forward for a utility that has long been a clean energy leader. Please reject this discriminatory solar fee proposal immediately. Solar users should pay for their fair share of the grid, but solar fixed charges are the wrong way to go.

 

Sincerely,

ERIKA S. 


April 22 - Greg & Kathleen M.

 

Now we see that the roll-out of solar was ill-conceived if the rules now have to be changed.  We are tired of policy makers not thinking through the ramifications of this kind of incentive.  We end up covering the costs for poor policies.

 

We are outraged as citizens and consumers.  Please do no vote to implement this new fee.

 

Greg & Kathleen M.

Citrus Heights 


April 22 - Peter B.

 

Good evening,

I just learned about the proposed SMUD solar access fee and, as a SMUD customer, wanted to write and voice my disagreement with this plan. 

 

First off, the name alone is very misleading.  "Access fee" gives the impression that the fee is to offset a cost that SMUD has been absorbing by their customers going to solar.  This bit of trickery is more in line with what I would expect from PG&E.  If a customer has enough generation capability to offset their grid usage completely, aren't they already paying a $20+ monthly infrastructure charge, just for being connected to your grid?  What additional benefit would SMUD be providing for this "access fee"? 

Also, since SMUD is a customer owned utility, I find it ridiculous that you would penalize your customers for spending their money on a product that benefits our whole community.

 

I realize that some in your organization may see customer owned solar as a threat to SMUD's business.  SMUD has often reminded us that electricity demand is starting to outpace supply, perhaps you should be thanking your "green-minded" neighbors.

 

Thank you for your time.

 

Sincerely,

Peter B. 


April 22 - Lateef

It’s particularly cruel to punish us who are trying to do the right thing.  Adding fees to solar defeats the purpose of having a fixed rate.  Solar costs enough as it is.  What am I going to do now that I’m on a fixed income?

Lateef 


April 22 - Lee M. & Craig V.

My name is Lee M. My husband and I live in a new community in the Vineyard Point area of South Sacramento, Ward 3. My husband was born and raised in Sacramento. I moved to South Sacramento in 1980. We are longtime SMUD Customers.

 

First of all, I would like to thank SMUD for listening to their customers and their feedback on the Proposed Customer Renewal Self Generation Grid Access Charge, grandfathering deadline and NET 2.0. And also, for rescinding the proposal rather than moving forward.

 

I hope that by working together that a more equitable plan will be created. One that does not punish people who have solar for being socially responsible. With the now rescinded proposed plan, SMUD's math was literally based on the amount of power solar users were NOT buying from SMUD because they have solar. The electricity generated by solar is added to SMUD’s supply chain and thus adds value. That fact should not be ignored.

 

This is NOT a unique "burden". It is the same as someone turning down their AC or installing LED lightbulbs OR running electrical devices during non-peak hours. In fact, it is a socially desirable behavior that should be encouraged, not taxed and discouraged.

 

There was a push 10 years ago by SMUD and other utilities to have residential & commercial customers install solar in order for the utility to meet their required renewable generation goals and we helped SMUD meet that goal. SMUD offered incentives to buy solar panels. SMUD was a leader by encouraging people to switch to solar and also influenced the county of Sacramento to change building codes so that all new houses in the county are required to at least offer solar on new homes. We chose solar in our new home because it’s the right thing to do.

 

I want to see SMUD show leadership once again by coming up with a plan where more people are using solar and SMUD adopts a plan to store the energy created by solar users. Let’s not have a repeat of the 2000/2001 energy crisis. California had a shortage of electricity supply caused by market manipulations and capped retail electricity prices. If solar energy is stored, then SMUD and their customers would be protected if this reoccurred. Solar is the right thing for SMUD, it’s customers and Sacramento.

 

Thank you for your time

 

Sincerely

Lee M./Craig V. 


April 22 – Anonymous

 

Why is your new rate schedule going to increase my access fee from $20.30 to over $68? You're not trying to make it more cost effective for people to invest in Solar to try to help reduce the stress on your system at peak hours! You're going to make it MORE costly to have solar and it's NOT a luxury because it still has to be paid for and $14,000 is NOT cheap and it's not cost effective for YOUR organization to continue to contract for fossil fuels to run the power plants! Another thing, this house has been here since 1956 and the connection fee has been paid for every month so you figure it out and you'll see that I've paid over $2,400 in the last 10 years I've owned this house and now you want to more than triple it 


April 22 – Anonymous

 

Dear SMUD Board of Directors:

 

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. I am a homeowner with solar panels installed on my rooftop in 2013 and am also a Tesla owner in 2018. We are working towards being more energy efficient but these kinds of fees, almost like a penalty, is a disincentive. Thank you! 


April 22 - Marianne B.

 

Dear Sirs,

 

I am very disappointed that SMUD is considering a grid access fee for Solar users and would urge you all strongly to VOTE NO for this fee increase. I was not allowed to get as much solar as I wished when it was installed at my home, because of regulations limiting my solar installation, when I acquired it years ago.  I pay for my solar installation, and my SMUD fees, and am charged extra fees at the end of each year, in spite of having my electrical use reduced by my solar panels.  I feel my overall power fees are not significantly reduced after all the fees already in place.  Adding the grid access fee will cause further loss of incentive to use solar power, which is not a good strategy to reduce energy production impact on global warming and help people afford energy for their home.

 

Please vote NO to any grid access fees.

 

Thank you for your consideration of this important matter.

 

Sincerely,

Marianne B. 


April 22 - Alan E.

Read this customer's letter to the Board of Directors.


April 21 - Winnie N.

 

I disapprove of Smud raising solar user for an extra $40-55 a month for using clean energy of solar!! We are trying to protect our earth and has taken an extra step to ensure our earth is being protected, yet you are punishing us for this very act.

 

Winnie N. 


April 21 - Heidi B.

 

Dear SMUD Board

 

I am writing to express my complete opposition to charging solar homes with a monthly fee. These fees are unfair and not justified. The whole point of buying a home with solar is to reduce charges. This fee proposal would create a bill that is ridiculosly overpriced compated to what i currently pay with my solar. I already paid a great deal to have solar home!

 

Please vote NO to this fee increase.

 

Heidi B. 


April 21 – Terrence

 

NO on Proposed SMUD increase fee on solar panels.

 

Terrence 


April 21 - Margie D.

 

I want to state my opposition to the proposal on solar. This is an attack on customers who have installed solar in their homes. If this proposal passes, there’s no reason for me to have solar and pay extra. This proposal is in the best interest of SMUD, not customers and not the environment.

 

A.         

Margie D. 


April 21 - Ben and Gloria W.

 

As renewable energy becomes a requirement in California, your purposed solar fee makes no sense.  Please reconsider this misguided idea.

 

Ben and Gloria W. 


April 21 - Micah B.

 

I have been a SMUD customer for over 20 years. I appreciate that I have rarely had my service interrupted. I understand the value of the grid infrastructure. I am writing to oppose the addition of a monthly grid access fee.  One of the things that I’ve always appreciated about Smud is there open support of renewable energy and energy efficiency. The addition of this fee would completely negate the economic viability of a small solar array on a single-family home. Please consider my request when the board votes.

 

Micah B. 


April 21 - Logan J.

 

Hello, as a SMUD customer who regularly sings SMUD's praises for their green policies and customer service, I am dismayed to learn about the potential "grid-access" fee. That fee would eliminate the savings we currently see after having spent $20k installing solar panels last year. This is a huge step in the wrong direction for a company that has long had a reputation for being civic minded and environmentally conscious. Please reconsider these fees. I'm especially frustrated as the mention of such fees back when we decided to spend that 20k would have potentially kept us from doing so. Instead, we could be on the hook for that investment PLUS an additional $600/year+ as a retroactive tax. This is very frustrating.

 

Logan J. 


April 21 - Ken and Nancy H.

 

We are solar customers and are totally opposed to the proposed rate hike for solar customers as it would discourage people from converting to solar power by decreasing their savings. If we are ever going to convert to “green” energy on a large scale, we must provide more, not less, financial incentives. 


April 21 – Anonymous

 

I'm writing to communicate my concerns with SMUD's 2019 proposed rate changes.  I'm particularly concerned with the proposed Grid Access Charge.  Charging solar customers an additional fee based on the size of the their system is wrong and inconsistent with SMUDs carbon neutral goals. The Grid Access Charge disportionately impacts existing SMUD customers with solar and provides a significant disincentive for other SMUD customers that may be considering solar.

 

SMUD charges every customer $20.30 for a "System Infrastructure Fixed Charge".  This charge "helps cover SMUD costs for infrastructure, including poles, lines, transformers, metering equipment and customer service expenses such as the contact center."  Given that there is $30 million per year shortfall, the "System Infrastructure Fixed Charge" has not kept pace with rising costs.  Instead of creating a new Grid Access Charge, SMUD should consider increasing the "System Infrastructure Fixed Charge".  All SMUD customers should bare the responsibility of paying for the shortfall, not just SMUD's solar customers.

 

In short, the proposed Grid Access Charge is wrong and is inconsistent

with SMUD's carbon neutral goals.  I urge the SMUD Board of Directors to reject this proposed rate change and direct staff to evaluate other options that are more equitable and consistent with SMUDs carbon neutral goals.  In lieu of the proposed Grid Access Charge, staff should consider other means to addressing the $30 million per year shortfall that doesn't disportionately impact solar customers. 

The Board should have the staff consider the following options: 1) increase the "System Infrastructure Fixed Charge" for all SMUD customers, and 2) assess lowering the kWh rate for surplus power sold to SMUD from residential customers.  The combination of these two changes, among others, can fully fund wildfire mitigation and other ongoing costs 


April 20 - Jeff C.

 

Dear SMUD,

 

I am writing to urge you not to enact the proposed new “grid access” fee. My neighbor and I were frankly shocked that SMUD, a champion of green energy and community involvement, would consider such a deterrent to solar development. This honestly seems like something PG&E would do. I have always been very proud of SMUD and even have “Powered by SMUD” stickers on our electric car. Please reconsider this action as it will jeopardize future solar expansion. Over the 30 year life of a solar loan this could result in 20,000$ of additional cost, making solar a very poor option. Why deter movement towards cleaner air and less fossil fuel consumption? I urge you to please reconsider this proposal

 

Sincerely,

Jeff Caspar 


April 20 - Catherine E.

 

I am writing in regards to the proposed solar connection fee and how it is greatly discouraging me from installing solar panels as I had planned for next month!  I have a contract in place to do so, but am considering cancelling based on this news!

 

I have a small home and my average electric cost is pretty low anyway. Arguably not even worth getting the solar installed. Yet I plan to do so because I am concerned with the rising cost of electricity due to rate increases tied to increased demand as well as the issue of wild fire costs impacting the industry. I am trying to be proactive, but this fee is almost the amount I already pay you (average) a month! Why spend $12,000 installing a system and then still have to pay you like I already do? Why bother?!?!?

New installations need exemptions for at least 20 years to offset the amounts we are already investing.

 

Catherine E. 


April 20 – Renea N.

Hi,

In the last 2 years, my electric bill has doubled.  I pay more to Smud now than before I had Solar Panels, plus I also pay Solar Company.

Thanks,

Renea N.


April 19 – Randy M.

So from what I read you want to charge customers who bought solar an extra 20 to 35 dollars a month for being hooked up to the SMUD power grid.  My question at this point is why did your company even bother to promote green energy and the cost savings from it just to later implement a obvious cash grab that takes away from the point of having solar in the first place.  Also wouldn't that violate some EEO law or something due to the fact that every SMUD customer is hooked up to the grid yet you are only overcharging solar customers?  So shouldn't everybody have to pay the increase regardless of the fact that they have solar or not?  SMUD also promotes energy credits for solar customers who are low use energy users, so?  With this increase you are contradicting what your company promotes and promises.  So I ask you, do not implement this new solar fee.


April 19 – SMUD Customer

The utility companies used to charge more because of a shortage of electricity, now that there are many solar installations you want to charge more because you're not making enough money. I thought you existed for the public good of Sacramento? 


April 19 – SMUD Customer

You should be reducing the rates not increasing them you losers.


April 19 – SMUD Customer

You should be reducing the rates not increasing them you losers.


April 19 – SMUD Customer

Enough is enough.  Tired of fees and taxes I don't want to stay in CA any more. Retirement soon and I'm leaving. Customer went energy efficient for a reason.


April 19 – Lu S.

I am against the proposed solar grid access charge. At a minimum, the Board of Directors need to slow down and examine the following:

  • How the proposed rates were calculated and justify the fee structure
  • Did SMUD consider the project growth in solar households and how the growth (or lack of growth if this proposal is adopted) in the fee-payer population will impact revenues and expected cost to maintain the grid.
  • Is maintaining grid access a fixed cost or not? It's difficult to tell based on the information presented so far.
  • Why is the fee based on the size of a customer's system? I currently have a 6.3 kWh system, but I never generate more than 5 kWh at a time because my panels are spread out along my roof.

The proposed rates are excessive for people who want to do the right thing and go green. Under the proposed access fees, for my 6.3 kwh system, my monthly fees would be $50.4 per month in 2020 and grow to $69.3 per month by 2025. The $50-70 access fee in combination with the monthly $20 system infrastructure fixed cost would exceed my energy usage cost in all but 3 months out of the year.

Let that sink in for a moment: the fees and taxes on my bill will be greater than my electricity charge for 9 out of 12 months of the year. I am all for paying my fair share to maintain and enhance the grid, but this proposal does so on the backs of solar customers. This proposal is at odds with SMUD's vision and goes against many of its core and keys values. This proposal will kill solar adoption in SMUD's service areas.

-Lu S.


April 19 – SMUD Customer

I think you people are thinking too far out of the box. Get real


April 19 – Ben M.

Please explain why you are looking to penalize customers with solar, who are making it easier for you to provide renewable energy. Yes, you maintain the grid but i am responsible for maintaining the localized solar plant, not a trivial expense on my part.

Ben M.


April 19 – Howard L.

Hello,

I just read the Grid Access Charge in the 2019 Proposed Rate Changes, and looking for some clarification regarding the proposal.  This looks like an entirely new rate increase, on top of the System Infrastructure Fixed Charge.

I bought my house in 2012 which already had a PV system installed. Does that mean I'm eligible for the grandfather provisions?  Or, is my service considered move or transfer, since I'm not the original owner who put in the PV system?

And, how would I know how many kW is my PV system?

I'm very concerned that the Grid Access Charge will have a negative financial burden for consumers.  Assuming I have a standard 4 kW PV system which generates 200 kWh of electricity in peak months, the Grid Access Charge of $32 per would exceed what cost savings produced by my PV system (200 kWh x $0.15 hypothetical off-peak rate when power is generally generated) of $30.  That's based on production in peak months.  In winter months, the financial burden would be even greater.

This proposal is not going help customers move toward greener energy and protecting the environment if the financial impact severely burdens the consumer.

Regards,
Howard L.


April 19 – Valerie M.

I had Tesla install solar panels last year which now cost me $53/mo. I was told SMUD would buy back any extra that I do not use. After using them for several months I checked with SMUD and was told that I might get "something" back but call back in May. So now SMUD wants to add further insult to injury by adding ANOTHER $50 charge? Why would ANYONE add solar panels? I'm seriously considering having Tesla take them off (if I can.)
Can you clarify what's going on?
Valerie M.


April 19 - Cristy E.

 

Dear SMUD Public Comment Email,

 

I was recently made aware of your plans for a solar increase of $40-$55/month. We had our solar panels installed less than a year ago. My understanding is that this would impact our monthly bill significantly. I find this very unfair as we were not made aware of this change while signing our contracts both with smud and tesla. We may not have made the decision to add the solar panels. This will cause us to pay more on average a year than we had pre-solar. I find this a disgusting breech of trust. Furthermore, you just increased rates by the charging the "time of day" rates. This all seems like a money grab in my opinion. While I understand there are significant operating costs involved with energy, continuing to pile on those costs to homeowners is appalling. 


April 19 - Deon R.

 

Dear SMUD Public Comment Email,

 

Hello, I urge you to reject the proposed new solar-only fee being proposed by SMUD. I've only had solar for 2 years now and I planned on selling my house in a couple of years, this new fee would severely hurt the value of my home and may make potential buyers look elsewhere. We should not be penalized for trying to do the right thing by using green energy sources like Solar. 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 and I'm ok with the $20/month I'm paying SMUD right now, I mean I'm not but I understand it so it's fine. But them jacking up the cost considerably is just crazy. The SMUD proposal, however, is a poorly-conceived overreach that simply punishes people for making the responsible choice and it will hurt homeowners. Please stop / vote against the SMUD proposal.

 

Sincerely,

Deon R. 


April 19 - Jeff M.

 

Dear SMUD Public Comment Email,

 

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,

Jeff M. 


April 19 - Ron F.

 

Dear SMUD Public Comment Email,

 

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,

Ron F. 


April 19 - Robert M.

 

Dear SMUD Public Comment Email,

 

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,

Robert M.

 

April 19 - Owen A. 

Dear SMUD Public Comment Email,

 

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,

Owen A. 


April 19 - Rhonda R.

 

Dear SMUD Public Comment Email,

 

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,

Rhonda R. 


April 19 - Donald G.

 

Dear SMUD Public Comment Email,

 

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. Our children have just installed solar at their home to save energy and money. This is a direct slam against honest and hard-working families attempting to save money and become energy conscious!

 

Sincerely,

Donald G. 


April 19 - John T.

 

Dear SMUD Public Comment Email,

 

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,

John T. 


April 19 - James N.

 

Dear SMUD Public Comment Email,

 

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,  

James N. 


April 19 - Merril N.

 

Dear SMUD Public Comment Email,

 

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,

Merrill N. 


April 19 - Michael H.

 

Dear SMUD Public Comment Email,

 

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,

Michael H. 


April 19 - Shaan M.

 

Dear SMUD Public Comment Email,

 

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,

Shaan M. 


April 19 - Melinda B.

 

Dear SMUD Public Comment Email,

 

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,

Melinda B. 


April 19 - Jerry R.

 

Dear SMUD Public Comment Email,

 

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,

Jerry R. 


April 19 - Ivan K.

 

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.

 

Ivan K. 


April 19 - Larry M.

 

Dear SMUD Public Comment Email,

 

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,

Larry M. 


April 19 - Ronald A.

 

To:

Nancy Bui-Thompson Director, Sacramento Municipal Utility District

Gregg Fishman Director, Sacramento Municipal Utility District

Rosanna Herber Director, Sacramento Municipal Utility District

 

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.

 

V/R

 

Ronald A. 


April 19 - Linda R.

 

Dear SMUD Public Comment Email,

 

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,

Linda R. 


April 19 - Rene R.

 

Dear SMUD Public Comment Email,

 

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,

Rene R. 


April 19 – Anonymous

 

Why the hell would I install solar to help the energy problem and now get charged a fee for it. This seems like an excuse to collect money. The fee would counter the positive enticements for Americans to install solar. I vote no. Hell NO. 


April 19 – Anonymous

 

Please reject this avenue of taxation. We chose solar as a means to help the environment and our natural resources in Addition to saving us money We believe this action will negate all those measures and continue our free fall into destroying our planets environment. Essentially solar users are penalized for being responsible environmentally concerned citizens. SMUD has built numerous solar farms are these now at risk and ALSO subject to a SOLAR FEE . Consider the hypocrisy in that action. SMUD was founded as an alternative to the demonized PG&E LETS NOT LOOSE THE VISION BY THIS MONEY GRAB! REJECT THIS FEE ON SOLAR PROPOSAL 


April 19 - Greg R.

 

Please do not adopt a grid access fee to solar customers. This is wrong and a punishment for attempting to help the environment. Until now I loved being part of a local energy company that gives me the feeling that me as a customer matters. Now with this proposal I fell that you are turning into PG&E who can care less about their customers. 

 

Please consider not implementing this access fee.

 

Thank you from a 30 year customer,

Greg R. 


April 19 - David H.

 

I'd like to add my thoughts on the proposed SMUD grid connection fee for solar owners.

The rationale behind this is reasonable, but the proposed application could be improved.  Instead of applying the grid connection fee to just on site generators, it should be applied to all customers who are connected to the grid! Then the electric usage rates could be based just upon kwh from SMUD without rolling the connection fee into the rates - a system that has created the present imbalance.

 

By separating the grid connection fee from electric usage for all users and billing it accordingly, SMUD would become much more transparent, and alternative energy sources would not have the perception that they are being discriminated against.  Of course by doing so, rates per kwh from SMUD would decrease by the amount of the increase in grid connection fee.

 

David H. 


April 19 - Aaron H.

 

You are out of your minds!! 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.

 

-Aaron H. 


April 19 - George J.D. IV

 

Good Morning,

 

I'm a SMUD customer and I'm writing to voice my opposition to the proposed "Grid Access" fee levied against those who want to install solar roofs.

 

Given the threat posed by climate change, no additional barriers or impediments should be imposed on those who try to generate power in a clean and renewable way.

 

Regards,

George J.D. IV 


April 19 - Ken B. and Angela L.

 

Dear SMUD board,

 

We wanted to express our dismay and disappointment at the proposed rate surcharge for solar customers. We have praised SMUD to friends and family since we moved here, and in fact just recently encouraged family members to move to Sac County due in part to SMUD (they had solar on their current home, and were planning on having it on their new home here). If this rate change is enacted, it will undo the decades of good feelings we’ve had towards SMUD.

 

In our specific instance, based on past usage and size of our solar system, it seems it would add about SIXTEEN CENTS per kilowatt hour to the cost of the electricity we purchase from SMUD (or more, since our grandfather period would not end until beyond 2025). The cost advantage that SMUD cites over other providers such as PG&E would likely be entirely negated by this huge surcharge.

 

We urge the SMUD board to please consider alternatives to generating revenue, especially ones that are applied more equally to all customers, rather than targeting those uses who are trying to help save the planet!

 

Longtime SMUD customers,

Ken B.

Angela L. 


April 19 - H.C. Jr.

 

As a Smud customer adopting solar in 2018. I object to rate increases for grid connectivity.

 

H.C. Jr. 


April 19 - Will M., Esq.

 

Hello,

 

I am writing to oppose solar grid access fees. These fees would punish existing solar customers (like myself) who signed agreements based on a fee structure that existed at the time they signed up. This pulls the rug out from underneath them. This is not fair.

 

It also disincentivizes new solar customers. I do not think it is wise climate policy, long-term financial policy, or fair and equitable to impose high fees for solar customers.

 

Solar is the future, fossil fuels are the past. Invest in the future, be on the right side of history.

 

Best regards,

Will M., Esq.

Energy/Utility Professional 


April 19 – Charley

 

Director Herber and SMUD—

 

I'm deeply alarmed to learn of the proposed Grid Access Charge for SMUD customers generating their own electricity. I've been a SMUD customer since 1995, and I've long felt the organization is a refreshingly progressive entity in the world of power utilities. This proposal risks casting that good will asunder. And it's just plain bad for the world.

 

With the heat of climate change breathing down our necks, we need to be doing all we can to reduce our dependence on carbon-based fuels. Your punitive new fees create a powerful disincentive for people to commit to green energy sources. On your website, you state a typical residential PV system is 4 kWp. The monthly charge for such a system would range from $32 to $44 through 2025. One assumes the charge will continue to increase beyond 2025, though you don't list those numbers. That's $528 per year! This makes return-on-investment calculations much less attractive, and will doubtless discourage some people from making the decision to commit to solar or wind. That's bad for all of us.

 

If SMUD were a typical for-profit utility, this would look like an unfortunately typical move to defend profits in the status-quo, carbon-based way of generating electricity. That is, it'd be a dirty maneuver to head off what looks like a threat to the traditional dirty way of generating power. But from SMUD, it's just mystifying. This is a community-based municipal utility proposing a move that is sharply contrary to the community's best interests. I am genuinely stunned to see this from SMUD. This is not the SMUD I thought I knew.

 

I confess I also have a personal interest in this proposal. My situation may be similar to that of many others. We have a PV system that went live about a year ago--in 2018. It's 7.92 kWp--let's call that 8 for simplicity. The grandfathering rules say we wouldn't be charged the new penalty until 2028. Extrapolating the table on your website, the charge would probably be about  $13/kW/month by then, or $104/month for a system of our size. We already pay $21/month to be connected to SMUD. Assuming that remained flat, our monthly bill would be about $125 for not even using any electricity! Our average bill before installing PV was less than $100. Do you see the disconnect? By installing solar, our SMUD bill would be larger than if we had not done so. That's nonsensical.

 

Also look at it this way. That new $104/month penalty is $1248/year. We'll be retired next year, living on fixed retirement income. Suddenly in 2028 our utility costs will spike by $1248. That's a cruel thing to do to anyone, but especially retired folks on fixed incomes.

 

You're basing the charge on the capacity of the system. This is further unfair in that PV systems almost never operate at full capacity. It's a theoretical maximum based on the sum of the power ratings of the installed panels. In reality, weather, shade, and sun angles decrease this. Why hit a customer for the full charge in, say, December, when the days are short, the sun is low in the sky, and there's a lot of weather limiting production?

 

You state that your solar customers aren't paying their fair share of the fixed costs of operating the grid. Yet we already pay the "System Infrastructure Fixed Charge." So this argument appears disingenuous. And even if there is in fact some degree of subsidization going on, that is socially and environmentally appropriate. As a community, a nation, and a planet, we need to be moving away from carbon-based power systems. Having revenue from carbon help pay for renewable development, investment, and use moves us in the right direction.

 

Punishing those who commit to renewables sets us all back and impedes our efforts to save this planet we call home.

 

Please reject this proposal.

 

I'd be happy to continue this conversation, and look forward to hearing your thoughts.

 

Charley 


April 19 - Renee K.

 

SMUD 

 

We as responsible consumers have been looking at installing solar for years, only to be turned away due to our roof justification.

 

Currently, this past January, the company SunRun was able to make it not only affordable, cost effective and easy, we feel we are doing our part to save energy by using our own footprint and rooftop to help create the energy we use.

 

We take pride in the fact that we are  creating energy and thought SMUD was a proponent of this.

With new fees and rising costs, if I had known this, I probably would not have put solar on our home.

If SMUD places an additional fee, I fear this will turn more people away than you think.

I thought SMUD wanted regular folks to save energy??????

 

Creating an additional cost will drive a lot of people from making the right choice. I DONT REALLY THINK SMUD WANTS THIS!!!!!!!

 

THANK YOU

RENEE K. 


April 19 – Anonymous

 

Access fee hike

 

We do not want a rate increase. We are planning to sell our home and an additional fee will impact the buyers decision to purchase. 


April 19 - Elizabeth M.

 

I am a lifelong Sacramento resident and SMUD customer.  I am writing to ask that the Board disapprove the new proposed grid access charge on new solar customers. 

 

I am a legislative policy consultant and have worked on renewable energy issues for 20 years.  Solar is already an expensive investment and, beginning next year, will be mandatory for all new homes.  I understand there may be a need to charge something to manage the load; however, imposing a fee that is high enough to offset a significant portion of a customer's energy savings associated with installing solar both undermines the intent of the new building standard and discourages consumers from installing solar on their existing homes. 

 

Moreover, as an electric car owner, I believe discouraging residents from installing solar to power their cars is simply bad policy for our region's air quality. 

 

Please do not approve the fee at the current level. 

 

Sincerely,

Elizabeth M. 


April 19 - Amran D.

 

Dear SMUD Board of Directors:

 

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.

 

Thank you,

Amran D. 


April 19 - Kevin N.

 

Dear SMUD Public Comments,

 

As a SMUD ratepayer and a solar supporter, I strongly oppose the new solar-only fixed charges recently proposed by your staff. These new solar fees would undermine SMUD customers’ basic right to reduce their purchase of utility-generated power, would increase global warming emissions and air pollution and would put solar out of reach for most SMUD customers. They are the wrong path forward for a utility that has long been a clean energy leader. Please reject this discriminatory solar fee proposal immediately. Solar users should pay for their fair share of the grid, but solar fixed charges are the wrong way to go.

 

Sincerely,

Kevin N. 


April 19 – Anonymous

 

You already charge over $21.for services on my bill now you want to raise it to (between) $40-$55. plus I still pay over $125. per month for the electricity my solar doesn't produce.  I'm in a all electric house on a fixed income and struggle with the bills I currently have. 


April 19 - Anonymous

 

To SMUD

       

        Why are you planning to increase rates for solar customers.  I thought the idea was to promote solar installations, not to charge extra for going "GREEN"....THIS IS AN OUTRAGEOUS PROPOSAL" 


April 19 - Sidney W.

 

SMUD should be busy designing a sustainable future whereby customers benefit by alternate, sustainable energy sources, and not contriving a way of extracting revenue from energy contributors. I have no problem paying balanced rates for retirees who achieve such a goal.

 

-Sidney W. 


April 19 - Brendan M.

 

To whom it may concern,

 

Adding a grid access fee will remove any incentive for future homeowners to invest in solar energy.  This is a huge step backwards towards a sustainable future.

 

Please do not implement this fee which would unfairly target those of us trying to do our part to curb carbon emissions.

 

I understand you need to raise additional funds, however this is absolutely not the way to do it.  Raise rate across the board and continue to incentivize more people to add solar. 

 

Future earthlings thank you for your consideration.

 

Brendan M. 


April 19 - Julie G.

 

To the SMUD Board of Directors,

 

I've been an enthusiastic SMUD customer and supporter since 1986. SMUD was a true leader in community energy, experimenting with different solutions to keep the Sacramento region future-focused and sustainable. I applaud those efforts to this date.

 

My husband and I saved for years to put a solar system on our roof, planning for the purchase of an electric car. Our average monthly energy bill before installing solar was $77/month. We were motivated to purchase an expensive solar system to do our part to reduce global emissions.

 

The proposed new solar-only fee is a step backward for SMUD. And it would punish people like us, who partnered with SMUD and invested thousands of dollars to contribute to renewable energy solutions for our region.  However, SMUD's proposed solar fee means we would pay increased penalties for pitching in to help our region meet sustainable, renewable energy goals. As proposed, the System Infrastructure Fixed Charge would increase five-fold in ten years. This is an apparent contradictory strategy for SMUD, moving us away from energy sustainability, rather than toward it.

 

This mystifies me, coming from the utility that invited me to enroll in its Greenergy program - which I voluntarily did - to support renewable energy solutions for our region. Now, it seems SMUD has switched tacks and wants to penalize me and others like me who support renewable energy solutions. This is a stunning about-face by SMUD. 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. To this end, we already pay a monthly System Infrastructure Fixed Charge.

 

The SMUD proposal is poorly-conceived and appears to that punishes people for making responsible choices that will benefit all of us.  As governing and grass roots bodies in the Sacramento region continue net zero discussions, SMUD's proposed solar fee is leading us in the wrong direction.

 

I'll be glad to discuss this with you in further detail. Thank you in advance for your engagement.

 

Julie G.

SMUD customer 


April 19 - Michael C.

 

Dear SMUD Public Comment Email,

 

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,

Michael C. 


April 19 – Mary Ann B.

 

Dear SMUD Public Comment Email, 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,

Mary Ann B. 


April 19 - Donna T.

 

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.

 

Donna Tielsch

Tango by the River 


April 19 - Ronna R.

 

To whom it may concern,

 

Stop the proposed solar power grid fee. This unfairly punishes solar customers who installed solar to reduce our footprint and will hinder future solar customers. Do the right thing and drop this money grabbing farce.

 

Sincerely,

Ronna R. 


April 19 - Anonymous

 

Why start picking on solar customers, we have made an investment that will take 15-20 years to pay off and during that time we are paying more for electricity than everyone else because we have to make payments for the solar ( which in most cases is Hundreds of dollars per month) plus pay for whatever electricity our solar doesn't create.  in my case it't close to $600. per month in the winter and $750 per month in the summer.  That's compared to before solar of $200.00 in the winter and $400.  in the summer. After the solar was installed it's been between $1600-$1800 per year and that doesn't include the monthly service charges.The loan is about $400. per month for 15 years.  I was hoping that after 15 years to start getting a return on my investment instead it looks like Smud is going punish solar users instead of those who don't want to bother with the investment and maybe their right if this is the way we're going to be treated.  I could suggest you put a surcharge on those who don't want to invest in solar but, that would be as unfair as it would be putting one on Solar users.  If your going to make a bill to one group without the other it's unfair so if your going to raise rates it should be across the board not picking one group over another. 


April 19 - Ann S.

 

Dear SMUD,

 

As a SMUD customer, I was very alarmed to hear of the proposed new solar-only fee rate hike. It would present a hardship and burden to the community, particularly to those trying to decrease their costs and promote cleaner energy practices. Such a rate hike will devalue properties that currently have solar and deter others from going solar. Solar customers already pay their fair share in grid access fees. Please do not go forward with this rate increase.

 

Thank you,

Ann S. 


April 19 - Diane N.

 

Hi, I’m writing today to protest the proposed grid access charges. My family and I have been considering solar for sometime but to date it has not been cost effective for us. We participate in SMUD's Greenergy plan for now. For us, the additional fees SMUD is proposing would make solar cost-prohibitive. If SMUD truly wants to support a transition to solar and other green technologies, SMUD should find ways to encourage the switch to these technologies. The proposed fees would certain have the opposite effect.

 

Thank you. -Diane N.


April 19 - Jones Family

Dear SMUD,

 

My name is M. Jones; my family of 5 have solar panels through Solar City/Tesla and it’s not a huge financial benefit to us —which we knew going in. If we had money to buy our own solar panels outright then, yes, we would have a true monetary gain but we don’t. We pay our SMUD bill and we pay Solar City/Tesla for solar energy created; even energy not used! So, we didn’t add these panels to save money; we did it to be “good stewards and offset our overall carbon footprint”! Yes, Solar City and their investors are making a killing but instead of going after the average ‘solar citizen’ who is trying to offset their carbon - please just invest in more solar and make it more available to the average person. I don’t think it’s fair to charge us extravagant fees for our making ethical choice to try and offset carbon and teach our children the same. We are not rich, we couldn’t afford to buy panels outright or even take a loan to do so, so the deal we made with Solar City/Tesla doesn’t give us huge benefits - we’ve maybe saved 10$ in almost 5 years- so that’s crazy to charge us like 50$ a month for trying to do good. It’s not reasonable or fair!

 

Jones Family 


April 19 – Anonymous

 

Smud has no right to charge us for electricity that our homes are generating we have paid a large sum of money to purchase the solar units and unless they wants to buy the unit from us they have no right to charge us for us helping to create electricity for ourselves. 


April 19 - Mike W.

 

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. I feel, as a solar user, we are trying to be responsible individuals who are in support of your efforts to curb the use of electricity during peak hours of the day, to help avoid “Brown outs”. As well as, helping those who cannot afford the natural use of the sun to have more access to the grid. Again please reject the fees that punish the use of solar energy.

 

Mike W. 


April 19 - Scott S.

 

I am writing to strongly oppose any increases of grid access fees for solar customers. Regardless of any sort of grandfathering, this policy is inappropriate. Solar should always be encouraged even to the point if subsidization. Nothing else is likely to reduce carbon emissions. That SMUD would consider this while the federal tax subsidy is starting to phase out and so many horrible environmental policies are being put in place is a very bad idea. Please do not increase or otherwise add to already high grid connect fees.

 

-Scott S. 


April 19 – Anonymous

 

 

I oppose the proposed new grid access fee. I think it is the wrong approach for the planet and for people who have already made significant financial sacrifices trying to do the right thing for the planet. 


April 19 – Ted

 

Dear SMUD Board of Directors:

 

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.

 

Thank you,

 

Ted 


April 19 – Charley

 

Director Herber and SMUD—

 

I'm deeply alarmed to learn of the proposed Grid Access Charge for SMUD customers generating their own electricity. I've been a SMUD customer since 1995, and I've long felt the organization is a refreshingly progressive entity in the world of power utilities. This proposal risks casting that good will asunder. And it's just plain bad for the world.

 

With the heat of climate change breathing down our necks, we need to be doing all we can to reduce our dependence on carbon-based fuels. Your punitive new fees create a powerful disincentive for people to commit to green energy sources. On your website, you state a typical residential PV system is 4 kWp. The monthly charge for such a system would range from $32 to $44 through 2025. One assumes the charge will continue to increase beyond 2025, though you don't list those numbers. That's $528 per year! This makes return-on-investment calculations much less attractive, and will doubtless discourage some people from making the decision to commit to solar or wind. That's bad for all of us.

 

If SMUD were a typical for-profit utility, this would look like an unfortunately typical move to defend profits in the status-quo, carbon-based way of generating electricity. That is, it'd be a dirty maneuver to head off what looks like a threat to the traditional dirty way of generating power. But from SMUD, it's just mystifying. This is a community-based municipal utility proposing a move that is sharply contrary to the community's best interests. I am genuinely stunned to see this from SMUD. This is not the SMUD I thought I knew.

 

I confess I also have a personal interest in this proposal. My situation may be similar to that of many others. We have a PV system that went live about a year ago--in 2018. It's 7.92 kWp--let's call that 8 for simplicity. The grandfathering rules say we wouldn't be charged the new penalty until 2028.

 

Extrapolating the table on your website, the charge would probably be about  $13/kW/month by then, or $104/month for a system of our size. We already pay $21/month to be connected to SMUD. Assuming that remained flat, our monthly bill would be about $125 for not even using any electricity! Our average bill before installing PV was less than $100. Do you see the disconnect? By installing solar, our SMUD bill would be larger than if we had not done so. That's nonsensical.

 

Also look at it this way. That new $104/month penalty is $1248/year. We'll be retired next year, living on fixed retirement income. Suddenly in 2028 our utility costs will spike by $1248. That's a cruel thing to do to anyone, but especially retired folks on fixed incomes.

 

You're basing the charge on the capacity of the system. This is further unfair in that PV systems almost never operate at full capacity. It's a theoretical maximum based on the sum of the power ratings of the installed panels. In reality, weather, shade, and sun angles decrease this. Why hit a customer for the full charge in, say, December, when the days are short, the sun is low in the sky, and there's a lot of weather limiting production?

 

You state that your solar customers aren't paying their fair share of the fixed costs of operating the grid. Yet we already pay the "System Infrastructure Fixed Charge." So this argument appears disingenuous. And even if there is in fact some degree of subsidization going on, that is socially and environmentally appropriate. As a community, a nation, and a planet, we need to be moving away from carbon-based power systems. Having revenue from carbon help pay for renewable development, investment, and use moves us in the right direction.

 

Punishing those who commit to renewables sets us all back and impedes our efforts to save this planet we call home.

 

Please reject this proposal.

 

I'd be happy to continue this conversation, and look forward to hearing your thoughts.

 

Charley 


April 19 – Anonymous

 

In July 2013 we had solar panels installed by Paramount...since then Paramount became Solar City and now Telsa..  Our contract with Paramount is still binding all concerned, and our contract has very specific agreements regarding how the contract can end and what happens when the home is sold.  

 

I seriously object to someone unilaterally changing the terms of our contract

 

I submit it cannot be done, and would be subject to a court challenge if Telsa/Smud follows through on proposals of 4/19/19. 


April 19 - Laith Y.

 

Hi, I’m a resident of sacramento and a customer of SMUD and want to complain about the proposed grid access fee for solar users. I understand the problem that SMUD is trying to address but the fee is not a good answer. This along with the ramp down of the federal incentive for solar will reduce adoption for existing home. This means that less will be done to reduce emissions. Sacramento as a whole needs to reduce emissions according to the mayors commission on climate change of Sacramento. SMUD’s CEO is on that commission so it isn’t a surprise. If we approach the problem from an emissions point of view, we should be incentivizing solar, not bogging it down with fees. This is like charging more for veggies because you are eating healthy, or giving more homework because you are doing good. That doesn’t make sense and neither does this. The old infrastructure can’t handle the new end user setup which the entire world is heading toward. SMUD should embrace solar, and motivate people to move away from power made from natural gas. My proposal is the following: Charge the fee to those not on solar, accelerate the shutdown of your natural gas power plant, move to storage of that green power. If you don’t do any of that and still plan on the fee, Let people disconnect from the grid, so they can do solar and storage at home. I thought Smud was a green thinker, but this move ruined my day. I have posted your intent to all social media platforms and will be voicing my concern at your board meetings.

 

Laith Y. 


April 19 - Brent A.

 

Greetings SMUD,

 

My name is Brent Anderson at 1434 Oregon Dr, Sacramento. Thank you for representing us on the SMUD board!

 

I've been so pleased with the ways that SMUD has been advocating for its customers to adopt solar energy. Given its track record, I was shocked to learn of the proposed $20 grid access fee that it is considering to levee on people who are installing solar panels.

 

There are much better ways of raising revenue, increasing price per kWh, etc. We still have many many Sacramento roofs that are primed to harness the energy of the sun, but have not done so yet. Let's think about ways to INCENTIVIZE them to do it; not DISENSENTIVIZE them.

 

Thank you for your thoughtful consideration.

~~~Brent A. 


April 19 - Laura H.

 

SMUD should not go backward by charging more for solar. I am not on solar, but I do pay into the greenergy program in hopes that alternate energy demand will encourage a better tomorrow. Please find another way to make up added costs.

 

Your concerned customer,

Laura H.

Sent from my iPhone- please excuse typos 


April 19 - Anonymous

 

Vote no on new Solar fees. 


April 19 - Lola P.

 

Hello,

 

The proposed solar access fee is a terrible idea, while some fee on solar is understandable the current version is a deterrent to people considering solar and harms those who have already made the investment in good faith, and in many cases it will negate the savings from solar.

 

It is a  penalty to those investing in the future and the planet's future. Individuals who have or who will invest in solar are helping the environment in addition to lowering their monthly utility costs. Also much of the solar generation happens during peak usage times, reducing the load on SMUDs grid and helping to prevent outages from too much demand on the system.

 

SMUD touts being part of the community, but California values our environment. The wildfires that are devastating California are linked to climate change and therefore fossil fuels. Individuals who invest in solar our doing our part to lower our fossil fuel usage.

 

Also this fee will make it harder to sell homes with solar systems, rather than being an investment you are making it an detriment.

 

Thank you,

Lola P. 


April 19 - Jeff J.

 

I am upset at the recent news of your increasing fees or ending exemption for solar homeowners.

PLEASE DO NOTHING TO DISCOURAGE THE USE OF SOLAR ENERGY!!!

 

Jeff J. 


April 19 - Lee M. & Craig V.

 

Dear SMUD Directors

 

The proposed new solar-only fee is an attack on solar and will punish solar users 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 but this is a solution that is not only absurd but ill-conceived. Why would anyone want to have solar panels if it will cost them more than benefit? SMUD uses the energy we produce, we are contributing to your supply chain and yet SMUD wants to make having solar panels and generating energy cost prohibitive? This makes NO SENSE.

We would expect this type of bizarre and punitive plan from PG&E, who have a reputation for bleeding their customers dry but I hold SMUD higher standard. Whoever came up with this plan or group of people, need to come up with some other way to create more revenue but not on the backs of those that have solar panels.

 

Sincerely

Lee M. & Craig V. 


April 19 - Jorge I.

 

Please do not implement the solar tax/fees. This will put technology adoption backwards.

 

Regards,

Jorge I. 


April 19 - Barinder S.

 

Dear SMUD Board Members,

 

I humbly request you to reject the Grid Access Fee proposal for solar systems for following reasons:

1.           It will discourage community from investing in environment friendly Solar energy solution.

2.           It will discourage industry from coming out with innovating Solar energy solutions.

3.           It is not fair to levy such a fee on the community when in last decade SMUD has promoted solar energy and exhorted the community to invest in Solar solutions.

4.           The existing solar systems will become liability for new home buyers.

 

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,

Barinder S. 


April 19 - Larry C.

 

If SMUD is serious about being an energy conservatory leader, it should not put a usurious fee on solar customers. Stop it!

 

Larry C. 


April 19 – Ravi

 

Dear SMUD,

 

The intent of this comment is to inform that imposing of these charges is discouraging solar and I oppose these interconnection charges. Thank you.

 

Thanks,

Ravi 


April 19 - Anna Marie C. P.

 

I am writing to inform SMUD of my disapproval of the proposed Grid Access Charge that would penalize residential customers who have solar panels by charging an average of $8 x 4kW, or $32 a month, to access the grid. Solar panel owners spend a high amount of money upfront to help contribute to a greener planet. In addition, it helps reduce the need for SMUD to build infrastructure for the growing population's electricity needs. In many ways, a solar panel owner who feeds energy back to the grid is helping the community and saving SMUD money on infrastructure. Remember, brown-outs used to be the norm. Even still SMUD asks customers to not use high energy appliances during peek periods. I imagine the excess energy produced by solar panels helps relieve a burden to the grid.

 

I understand that this fee is proposed for new solar panel owners, but shouldn't SMUD be proactive in supporting greener ways of producing energy? When a person elects to purchase solar panels, they are shouldering the cost of the panels and the cost of maintenance and repairs to those panels. And the excess energy is available for SMUD to use and distribute to their customers in the grid. To me, it doesn't make sense that SMUD would discourage residents from purchasing solar panels by penalizing them $32 x 12months, or $384+ dollars a year, just to be connected to the grid. Imagine if all solar panel users convert to battery storage in retaliation. This would mean SMUD would have to build more infrastructure to keep up with energy needs for every house that cuts themselves off the grid.

 

All SMUD customers pay a base fee for connection to the grid (by way of the system infrastructure fixed charge). Do not penalize a solar panel resident who continues to provide energy to the grid. That is just plain wrong!

 

Additionally, this proposal was not mentioned in the highlights of the proposed rate changes on the website. So, to me, it seems suspicious that this proposed Grid Access Charge is not fully disclosed or transparent.

 

I used to respect SMUD, but this tactic is a low blow and has changed my perception about SMUD being a green, community-driven district. All I see here is pure greed and a lack of appreciation for how solar panel residents help contribute to SMUD's "supposed" purpose of providing green, renewable energy to their customers.

 

Sincerely,

Anna Marie C. P.

Solar Panel Owner 


April 19 - Lynn M.

 

Dear SMUD Public Comment Email,

 

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,

Lynn M.


April 19 – Anonymous

 

Please stop the proposed solar fee. It goes totally against SMUD’s assertion of being an energy conservation


April 19 - Matthew O.

 

I urged you to please reject the proposed new solar-only fee. Smud incentives solar and is now punishing the ones who chose to make the switch. My bill is about even to what it would have been Had I not gotten solar. I did it to help the planet. If you increase this fee I will be essentially fined for helping the earth. It is an attack on solar, and will punish people simply for reducing their electricity useable helping Smud reach their goals. The only result will be to discourage people from becoming more energy efficient and independent. If I can’t sell my house because of the change affecting buyers it is the same thing. The SMUD proposal, however, is a poorly-conceived overreach that simply punishes people for making the responsible choice.

 

Matthew O.


 

April 19 - Steve B.

 

Dear SMUD,

 

I have been informed that now SMUD hates solar and wants to add a new tax to those of us who were progressive and spent their own money to be part of the solution. ARE YOU INSANE? Did SMUD learn nothing from the debacle that was Ranch Seco? How much of our money did SMUD waste on that? And now SMUD wants to add a new tax on solar?

 

I say HELL NO! SMUD needs to support solar. SMUD needs to promote solar, not cripple it with new taxes.

 

Maybe it’s time for a ratepayer revolt. Maybe we need to vote in all new, pro-solar board members so we can get rid of the anti-solar staff.

 

GET IT TOGETHER SMUD OR WE WILL ACT.

 

Steve B.


 

April 19 - Nolan J.

 

The solar fees program that SMUD is going to implement is entirely unfair to potential solar customers. SMUD pretends to care about green energy, but this legislation will made solar power completely cost prohibitive in the Sacramento area. Especially because SMUD plans to charge solar customers the fee regardless of whether they have their own battery backup or not. The stated purpose of the legislation is entirely false if people who don’t even use the grid (battery customers) are charged the same as people who do. Regardless, solar power should be incentivized, not punished.

 

-Nolan J.


 

April 19 - Roberta J.

 

SMUD's program of fees for solar power users is the reason why I have not installed solar power for my home. why do it if SMUD is going to bill me *more* than I currently pay for power, when the power I am using is free?

 

This policy is directly in conflict with SMUDs own stated support of renewable energy.

 

I appreciate that someone has to pay for the grid. I get that. But people who live in the SMUD district certainly should not pay the exorbitant fees being proposed.


 

April 19 - Judith J.

 

I am a 71 year old widow that is living on a small fixed income.  I cannot afford to increase my monthly expenses.  I barely have enough income to make it through the month.  Many months I do not make it on my income.  Please do not adopt this rate increase as most retired people cannot afford an increase.

Thank you for your consideration in this matter

 

Judith J.


 

April 19 - Catherine K.

 

Hello Board,

 

As a mother of five year old son, the increased rate changes will not only pose a barrier for my family considering to purchase an electric car. We currently live in a smart home, we have forgone sprawl for higher density energy efficient home. Our next step was to buy an electric car as gas is increasing this summer to $4 a gallon. The new rate increases will not only increase our costs to purchase an electric car but will put us out of reach. We have not seen our wages increase but our discretionary income is getting eaten away by the impending gas increases and rising childcare costs. If you are considering an increase, please only consider a 2% increase rather 25% plus increase to the fees. Our wages never see such an increase. Thank you for the opportunity to comment


 

April 19 - Joseph M.

 

First off, yes some Tesla bot just alerted me to this.  I don't follow Tesla bots per se, but I do have a few cents on the issue:

 

I get it, the grid is infrastructure, which is a big stranded investment.  Current recovery model is build that into the rates.  That means solar customers are not necessarily paying true cost of the infrastructure.  However, I think taking on more than a few dollars to customers with panels will just feel outrageous.  Let me be clear, I don't have panels and pay the extra for SMUD to go 100% renewable for my power, so I don't share the interests of customers with panels.  But I do think it sends the wrong message to soak them with more than a few bucks per month. 

 

A better approach:

+Create a flat component for infrastructure cost recovery that everyone pays.

+Lower rates for kWhrs

 

In the long run (think fullness of time) the changes precipitated by residential solar will help transform the system into something more modern and capable and we'll look back at a healthier more resilient grid.  I know it does not always look that way when viewing the present and having to deal with these new flows on a network not totally built for that.

 

or...

 

What's next, exit fees for energy efficiency?  What's the difference?


 

April 19 - Lill J. and Colleen M.

 

I was just informed that SMUD is proposing to more than double the grid access fee. Solar is a positive approach to reducing our carbon footprint and should be encouraged by all especially energy companies. This proposal does just the opposite. When we decided to invest in our solar system it was to eliminate our electricity bill. I concede that we have to pay a minimal fee to be on the grid so you can monitor how much energy we produce, but it should not be used as a way to balance your budget. We look forward to the day when technology allows us to store our own energy onsite and we can be completely off your grid. We do not support the increase in fees proposed.

 

Sincerely,

Lill J. and Colleen M.


 

April 19 – Evan

 

Hello,

 

The introduction of a fee for solar homeowners will have a negative impact on the industry. And most importantly we feel that California, a state that champions itself as being one of the leading environmental legislative powerhouses would be ok with hurting the states transition to solar energy. It is always money that ruins everything. FIND A WAY TO ADAPT TO THE TRANSITION. This is the easy way out not the right way.

 

Evan


 

April 19 - Dan and Karen D.

 

Reduction of fossil fuel usage is one of the main reasons Solar Panel use has become so popular, along with reduction of the cost of monthly fees.

 

To raise fees is tantamount to the breaking a contractual agreement between the homeowners and SMUD.

 

If monies is a problem, maybe administration staff could be reduced, replacing high salaried individuals for workers and/or improved technological equipment designed to reduce the work load as well as improve the delivery of electricity to customers.

 

A trust to be broken can never be repaired. Do NOT raise fees simply for additional money/power.

 

Dan and Karen D.

USATF Master Certified (Emeritus)

About Timing Association


 

April 19 - Jessica D.

 

Hello,

 

I’m disappointed to hear that SMUD is considering a large surcharge on solar panels. I recently purchased solar for my home as a way to help the environment and save my family some money. This large price increase would take up any savings I might have realized from my solar panels. While I appreciate that SMUD needs to meet their bottom line, I encourage you to look in other places for additional income, rather than those that are trying to “go green.”

 

Regards,

Jessica D.


 

April 19 - Mike B.

 

SMUD-

 

I am very disappointed to learn about this policy, as it seems to be in conflict with the long term goals for our community. The economics of a distributed grid is clearly unfavorable to SMUD in the long term, and I can appreciate the effort to protect lower-income customers from rate increases. 

 

As you attempt to reconcile these issues, I sincerely hope that you reconsider the pricing tiers based on consumption instead of "grid access". Adding more tiers and forcing those with the highest consumption to pay the most could hopefully meet your profit goals and encourage both conservation, efficiency, and investment in renewable distributed energy where it will have the greatest impact. In the long term, the grid access model probably makes sense but implementing it over this time frame is laughable since most homeowners will not stay in the same home for that duration, the practical timeline is much sooner. I do not have solar on my home and would consider this measure an additional obstacle to installing panels in the future.

 

Thank you in advance for your thoughtful consideration and ongoing efforts to provide clean, affordable energy to the community.

 

Regards,

Mike B.


 

April 19 – Anonymous

 

8$/kW is INSANE!! You are completely punishing those of us who want to create clean energy at our homes. Worst thing is that you know it, you even added the grandfather in clause to appease all of us who’ve had solar for a while. I don’t know who came up with this idea, but it was definitely not a solar friendly person. Please reconsider!!


 

April 19 – Anonymous

 

I am voicing my issue with the new grid fee. This is just observed and just like the politics in this state. Ripping off the people of CA is getting ridiculous by the day. How are people supposed to live with high new tax,  new ways the Democrats find to take more cash. It's hard as it is and now this new fee will be coming out. We dont even save anything at all with the panels as it is. I do not want the new fee to take place please understand.


 

April 19 - Ted F.

 

Dear Sirs,

 

I understand that SMUD is  proposing to charge customers who have solar panels and who contribute energy to the grid, an access fee in the range of $40-55 monthly.

 

That number seems rather high. Remember, California is trying to promote green energy and customers with solar panels are helping achieve that goal.

 

I understand that SMUD needs to maintain their grid structure. It would seem that a fee 1/2 of that proposed ($20 to 30) might be more acceptable.

 

Ted F.


 

April 19 – Anonymous

 

I am disappointed that smud is even considering such fees. I don't have solar panels yet.  But this action is very discouraging.  For years I have considered smud a reasonable and consumer oriented utility.  But this and time of day pricing are tarnishing that image.


 

April 19 – Al

 

Hello Sir/Madam,

 

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. Thank you, 

 

Best regards,

Al


 

April 19 – Pierce

 

Hi SMUD team, 

 

I was told there is a consideration for a rate charge that would impact solar customers.

 

Please consider there's already a $20 infrastructure fee and an additional charge for grid access by KWh adds an argument against SMUD's initiative of environment sustainability and commitments.

 

Thank you,

Pierce


 

April 19 - Deon R.

 

Hi,

 

I'm Deon R. and I'm a SMUD customer.  How exactly do I vote against this proposal from SMUD to increase the charges against people who have solar panels?  I know existing users will be grandfathered in but I plan on selling my house in a year or two and these new fee's will severely hurt the value of my home. It could cause potential buyers to look elsewhere, to a home without solar or a solar home not on SMUD's network. I'm against these proposed changes whole-heartedly. 

 

How can I make my voice heard? Who do I let know that I'm against these changes?

 

Thanks,

Deon R.


 

April 19 - Rick and Kim T.

 

We leased a solar system for our home in 2016 for 20 years with a fixed rate energy purchase from Solar City, now Tesla, and that if we sold our house prior to 20 years, the same benefits will be transferred to the new owner.  Currently, I believe, if we produce more than we use, SMUD purchases back from us the excess and we pay roughly $15 on  for grid fee.  I do not understand why the grid fee is imposed, just because we live in Sacramento?  SMUD should be paying the customers for providing the energy, which in turn SMUD sells and charges to customers in higher rates.  It seems like SMUD is double dipping the profit.  Regardless, we have continued to pay for the grid fee for over three years.  However, recently I was informed by Tesla that the SMUD is planning to impose an additional grid fee of $40 to $50 per month.  That’s over 300% increase.  The purpose of having solar is to reduce monthly energy charges by utilizing natural resources.  So, anything that would discourage customers, like raising additional grid fee to $40 to $50 per month, defeats the purpose.  More importantly, it is detriment to those who are living on a fixed income. 

 

What is the purpose of raising the fee?  We strongly oppose the additional increased grid fee of $40 to $50 per month.  Please let us know what else we can do to oppose this additional fee imposition. 

 

Sincerely,

Rick and Kim T.


 

April 19 - Jaro S.

 

Reading through the proposed changes I have a big issue with the grid charge being selective to those that generate there own power.  Currently, I have no solar or other power generation and would not be effected, but to have different rates based on how people use the utility doesn’t make sense.  If there is a grid charge because being hooked up to power regardless of use costs SMUD money, then everyone should have this charge.  I would expect the cost of electricity could be then reduced and balance out to about even for the  median household.  Then SMUD doesn’t have to manage or be concerned with how much people use electricity because the grid costs are covered.  

 

By charging only of solar is hooked up you encourage people to implement solar on their own without informing SMUD.  Sure, they wouldn’t be able to sell it back in that case, but with battery packs and small systems that’s really not an issue for those looking to get around the system.

 

I rather see a system that doesn’t specifically encourage or discourage certain behaviors by default.  If then you want to encourage behavior the subsidized offerings I have seen from SMUD make more sense as they can be quickly offered and retracted as times change without adjusting base rates and how people are charged. 

 

It also prevents SMUD from trying to track things like if someone has solar.  What if they have solar, but it breaks or is removed.  Now as a homeowner I would have to call in and have my plan adjusted otherwise I would be unfairly charged.  Please don’t create a system that complicates things more than necessary.

 

Regards,

Jaro S.


 

April 19 - Mats J.

 

I guess there is a vote on grid access fees for solar residents. Increases of hundreds of % proposed???  That is outrageous, and must be stopped.  I don't mind paying for access to the grid, but what is being proposed makes no sense, especially when we are trying to save this planet.  It's also unfair because access fees were taken into account when deciding whether or not to make the investment in solar.  You must re-think this.  Thank you for the consideration.

 

Rgds,

Mats J.


 

April 19 - Judy S.

 

We decided to have solar installed for a couple of reasons. To lower our electric bill and to become more energy efficient. Raising our smud rates seems to me like a punishment for solar customers who are trying to become more energy aware. The rate increase will also discourage new solar customers, which I think is counterproductive to your whole purpose of encouraging alternative energy sources.

 

Thank you,

Judy


 

April 19 - Jagjeet K.

 

This fee is an unnecessary burden on solar customers and undoes the benefit of having solar. I will soon be on fixed income as I am forced to retire due to my health. What are you doing to me and so many disabled like me or seniors???? This makes no sense and is cruel.

 

Jagjeet K.


 

April 19 - Mary W.

 

As a SMUD Customer, I was dumbfounded to read of this proposal. I installed solar panels to promote the responsible use of our planets resources moving into the future. I am astounded at the huge fee for putting energy into the grid which will hobble the future of solar and make it impossible to sell my house unless I remove my solar panels. Why isn't SMUD investing in the future???

 

Sincerely,

Mary W.


 

April 19 - Linda R.

 

To Whom It May Concern:

 

I am writing you, requesting that you reject the proposed fees charging the public simply because they chose to put up solar panels.  Those of us that have done this have chosen to act responsibly about choosing alternative and energy efficient resources.  Your proposal to charge us additional fees, is an act to punish us for trying to act responsibly and to discourage others who seek to do so.  In California, we have been a leader in the nation seeking alternative energy and you are acting in direct opposition to that.  Represent us as you would your own family seeking to act responsibly.  Many of us are earning a fixed income and imposing additional fees will be a hardship.

 

Sincerely,

Linda R.


 

April 19 - John D.L.

 

Hi,

 

I just wanted to express my opinion on the solar grid fee proposal. This would more than wipe out my solar generation amount and I would be paying more for electricity than if I didn't have solar at all. Not to mention the loss of the investment to install in the first place.

 

I know that there is a a proposed grandfather clause, but even this would reduce the value of the system should I choose to move at some point and cause a major financial disincentive for installing solar on any existing home that doesn't have it already.

 

Regards,

John D.L.

SMUD customer for 36 years


 

April 19 - Antonio and Kori S.

 

I would like to voice my concern that you are going to increase your fees for people who have Solar. We are leasing from Solar City, we are paying about $25 a month to SMUD now. Our system produces quite well, we rarely need electricity from you, although you usually benefit from our overage. I was under the impression SMUD wanted us to have Solar. It is posted on your website. Is this a punishment fee? I will stop encouraging my friends from now on to go to Solar.

 

Antonio and Kori S.


 

April 19 - Michael L.

 

We do not want a rate increase. We are planning to sell our home and an additional fee will impact the buyers decision to purchase.


 

April 19 - Louis M. Jr.

 

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.

 

Louis M. Jr.


 

April 19 – Anonymous

 

Wrong answer. I understand the need for upgrading, maintaining, and replacing/recovering equipment from the recent fires. However,  what may be considered a modest increase in cost for services will have a negative impact on retired and low income portions of the people you serve.  Since retirees are living on fixed incomes a rise in cost could mean the difference between purchasing medications. Lower income families are already stressed and this increase will simply result in exacerbating an already bad situation.

 

This increase violates the primary purpose of moving to solar to begin with, if that purpose was to protect the environment and reduce cost.

 

I contend that the end result will ultimately slow the move towards solar energy, have a negative economic impact on vulnerable portions of the population, and reduce public confidence by signaling the arbitrary increases in the future.


 

April 19 – Anonymous

 

In response to your consideration of a "Grid Fee" for solar customers, is completely inconsistent with my understanding of my solar service. SMUD, in addition to many solar companies have pitched a program that would lower electric bills while using clean energy sources. Now we are told that there will be a new charge for that. That is a dramatic charge that is proposed to offset other expenses SMUD has. To say it's unfair is an understatment. California with its "Green Energy" push seems like it's just another avenue to charge more to its customers. Typical action from disconnected board members looking for more revenue. I will be leaving this State because of these types of Extra Charges to its citizens!


 

April 19 - Reza T.

 

I purchased solar panels because I thought I was helping to alleviate my burden on the grid by contributing to the grid. I thought I was being a thoughtful, responsible citizen and that was worth the price I was paying for these solar panels. 

 

What was the purpose of buying solar panels if the utility company I thought I was helping is angry they aren't making enough money off of me?

 

Why have solar panels at all if purchasing power from you is ALL that matters?

 

Why bother with all these "Green" initiatives guilting us into taking on more responsibility if we are nothing more than consumers to you?

 

- Reza T.


 

April 19 - Melanie H.

 

SMUD,

 

I purchased solar in direct response to your new time rate change where I'm charged more for my electricity during the 'peak hours' which happen to coincide with the hours I'm actually at home, awake and using electricity.

 

I think it's taking extreme advantage of your monopoly on our electricity that you are now proposing this fee just to keep your bottom line solvent. We are being asked repeatedly by the state to 'go green' - and then you want to charge us for doing that and for being conscious about the environment and wanting to lessen our footprint.

 

Do NOT adopt the new solar fees.

--

Melanie H.


 

April 19 – Anonymous

 

To whom it may concern: You guys are a bunch of thieves. The timing of this is in line with required solar installation on new homes in CA in 2020. So in addition to a higher home price you will charge an extra $600 a year!! Unbelievable! I am strongly opposed!


 

April 19 - Liz A.

 

Dear SMUD,

 

I do not understand how your proposed Grid Access Surcharge is in sync with our State of California Alternative Energy Goals as proposed by our Legislature, and being implemented across our State -- How does this incredible dis-incentive help?

 

As a residential homeowner in Sacramento, we installed solar panels last year to 1) take advantage of the Federal Tax Credits, 2) reduce our carbon footprint, 3) decrease our overall energy needs from SMUD, and 4) allow for a future electric vehicle purchase.

 

Why are you trying to penalize us for taking these pro-active steps that benefit our State, our community and our State's Alternative Energy Goals?

 

Making the investment in solar panels was part of our personal investment to be part of the California Green Energy Future, and we are willing to pay our fair share of the grid that is part of that system.  But this is far from an equitable solution, and amounts to not only a penalty for pro-active citizens, but also a huge disincentive to increasing residential solar, as well as an economic hit to the solar industry and installation vendors in the Sacramento area.

 

Please reconsider this proposal, and come back to your rate-payers and progressive solar panel owners with a more balanced approach to our shared green energy future.

 

--

Liz A.


 

April 19 – Lucas

 

To Whom it May Concern,

 

I would like to add my voice to what I can only assume is a choir of dissent about the proposed rate change.  When I purchased my house 6 years ago, one of the things that attracted me to the house was that it had a solar system on it.  I knew that I would be helping the environment, that I would be reducing my energy bills, and that when I eventually sold my house that I would be able to benefit by advertising my solar panels to potential buyers.

 

With the proposed rate change, I can only assume that this will drastically reduce solar panel adoption in the area which I think is shameful that a power company would be pushing for.  The reduced rates I have previously enjoyed are now going to be drastically reduced by the over $300 a year I would pay (if I weren't grandfathered in).  I am looking to sell my house sometime this year though, and that means that instead of a benefit to advertise to potential buyers, I will need to disclose that our publicly owned utility company is going to be charging whoever buys my house much higher rates.

 

This proposal seems absurd to me, I couldn't believe what I heard when I found out about it, and I rarely reach out to organizations like this but this is beyond acceptable and I want to make sure SMUD knows that.  SMUD should be doing everything in their power to encourage and reward renewable energy adoption, and this proposal is the exact opposite.

 

Please do not punish your customers who invest in renewable energy.

 

Sincerely,

Lucas


 

April 19 - Jeffrey L.

 

I am against your retroactive solar rate change and surcharge. I recently installed solar on my residence. A lot of thought went into decision. It was based on applicable cost, return, smud rates and regulations. Retroactively changing your exemption from 20 years to 10 years appears to be a legal violation. How will customers be able to have confidence in SMUD commitment to customers?

 

Regards,

Jeffrey L.


 

April 19 - Edward J.

 

I'm an unhappy customer.  I am against your proposed solar grid access fee. I purchased solar to help the ecology and save money.  I don't believe your proposed fee helps solar panel owners.  It only helps SMUD and your investors. I will actively fight your proposed rate.

 

Edward J.

SMUD Customer


 

April 19 - Iqbal S.

 

I have solar at my home and I would like SMUD to not add additional fees as being proposed.

If there are additional fees added people will be discouraged to install solar as well as buying electric car. Why would a company do that if it is encouraging clean energy.

 

I would strongly oppose this proposal in fee for solar.

 

Iqbal S.


 

April 19 - Cheryl N.

 

Your proposed solar fee is counter-productive. As you search for “green” alternatives, the solar power generation transmitted to SMUD should be a treasured resource. To effectively tax people for supporting your green initiative is to confound your declared intent.

 

Cheryl N.


 

April 19 - Tim A.

 

Dear SMUD Public Comment Email,

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,

Tim A.


 

April 19 - Travis B.

 

Dear SMUD Public Comment Email,

 

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,

Travis B.


 

April 19 - Patty K.

 

Dear SMUD Public Comment Email,

 

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,

Patty K.


 

April 19 - Jason D.

 

Dear SMUD Public Comments,

 

As a SMUD ratepayer and a solar supporter, I strongly oppose the new solar-only fixed charges recently proposed by your staff. These new solar fees would undermine SMUD customers’ basic right to reduce their purchase of utility-generated power, would increase global warming emissions and air pollution and would put solar out of reach for most SMUD customers. They are the wrong path forward for a utility that has long been a clean energy leader. Please reject this discriminatory solar fee proposal immediately. Solar users should pay for their fair share of the grid, but solar fixed charges are the wrong way to go.

 

Sincerely,

Jason D.


 

April 19 - Ruben O.

 

Dear SMUD Public Comment Email,

 

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,

Ruben O.


 

April 19 - Dennis P.

 

Dear SMUD Public Comment Email,

 

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,

Dennis P.


 

April 19 - Courtney H.

 

Dear SMUD Public Comment Email,

 

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,

Courtney H.


 

April 19 - Mary W.

 

Dear SMUD Public Comment Email,

 

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,

Mary W.


 

April 19 - Devin H.

 

Dear SMUD Public Comment Email,

 

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,

Devin H.


 

April 19 - Raj P.

 

Dear SMUD Public Comment Email,

 

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,

Raj P.


 

April 19 - Devon R.

 

Dear SMUD Public Comment Email,

 

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,

Devon R.


 

April 19 - Marissa P.

 

Dear SMUD Public Comment Email,

 

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,

Marissa P.


 

April 19 - Keith A.

 

Dear SMUD Public Comment Email,

 

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, Keith A.


 

April 19 - Nihad H.

Dear SMUD Public Comment Email, 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,

Nihad H.


 

April 19 - Marc M.

 

Dear SMUD Public Comment Email,

 

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,

Marc M.


 

April 19 - Lou S.

 

Dear SMUD Public Comment Email,

 

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,

lou s.


 

April 19 - Theodore M.

 

Dear SMUD Public Comment Email,

 

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,

Theodore M.


 

April 19 - Ronald A.

 

Dear SMUD Public Comment Email,

 

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,

Ronald A.


 

April 19 - Steven B.

 

Dear SMUD Public Comment Email,

 

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,

Steven B.


 

April 19 - Judy S.

 

Dear SMUD Public Comment Email,

 

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,

Judy S.


 

April 19 - Ping Y.

 

Dear SMUD Public Comment Email,

 

Please reject the proposed new solar-only fee. Solar users are already paying the same monthly service fee and being responsible for maintaining their own equipment and helping the grid out on peak hours. This new fee is an attack on solar and will punish people simply for being forward thinking and 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,

Ping Y.


 

April 19 - Nick S.

 

Dear SMUD Public Comment Email,

 

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.


 

April 18 - SMUD customer

 

Customers who have installed Solar or are considering installing Solar should not be punished for trying to be environmentally conscious.  This sends the wrong signal for the future of our local area of California as well as the State.  I agree that we should have some responsiblity in upgrading our whole electrical system, but this puts an unreasonable financial burden on Solar customers.  Please look at a more equitable solution that will not have customers think Solar is not worth the cost or effort to install.  The Proposal would be a step backward in all of our efforts to reduce greenhouse emissions. Thank you for your time to read this. 


April 18 - Jeff K.

 

Dear SMUD Directors - 

Thank you for some of your individual replies to my earlier email.  I look forward to participating in a few of the upcoming public forum on the rate proposals.

I had a bit more time to look closely at the impact of the proposed Grid Access Charge on a typical residential PV system.  I was able to add a variable for a recurring monthly charge to our standard PV financial calculator (which I’ve attached in case anyone is interested in modifying the system variables). Here is a summary of the results:

Sample - numbers for the impact of Grid Access Charge on PV system

While a residential system in the current SMUD rate environment has a moderate financial return, we believe the financial drivers for capacity growth are low. Once the first phase of Grid Access Charge is introduced, you can see the project immediately becomes economically irrational.  This should all but eliminate the expansion of behind-the-meter PV generation.  While we have no interest in seeing self-generation grow any more rapidly than today’s rate, we do believe that PV and PV coupled storage will play an important role in grid management.  We expect SMUD’s aggressive promotion of beneficial electrification and EV adoption to pay dividends in demand growth, the results of which can be managed by strategic deployment of generation within the distribution feeder.  It will be important not to render PV solar financially unviable.  

Some other paths that could be considered:

1.) a greatly reduced Access Charge that maintains positive NPV for the average residential system.
2.) an exemption for the combination of PV, storage and DSM.
3.) a strategic annual behind-the-meter PV capacity target that would trigger an Access Charge once exceeded.
4.) additional subsidy or interest rate buy-down for EAPR customers that install rooftop solar.

Most sincerely,

Jeff K., CEM
Brighton Energy 


April 18 - Ross K.

This is BS

 

This is one sided Tax on a  select group that uses less energy.

 

Instead of a fixed rate you should be looking at a fee structure that migrates me to battery and not giving my power back. Then I am just like any other user just using less power.

 

If I installed 4kw system and generated 4100Kwh of energy of which I did not purchase from you and in your eyes did not pay my fair share of fixed costs.

 

How is that any different than me taking advantage of New A/C unit, Insulation, Gas Water Heater from Electrical, Gas Dryer from Electric, Gas Heater from Electric. Now I have reduced my consumption by 4000+ kWh the same as a solar user but I don’t have a Saving Energy Surcharge.

 

Hard to feel like I need to pay more of the 30M when I see over 200 Positions making 200-400K a year to run a electric utility.

 

Easy solution is for all solar users to just scuttle their old systems and and not replace, Use will skyrocket and then we will have issues with billions in New lines and power stations to support the extra power needs.

 

You created the issue with Rebates and Incintives when it suited you, now that we are locked in you screw us with a Tax

 

But you are Grandfathered in, That doesn’t apply to new owners so it’s a 3-10K reduction in home value


April 18 - Lynn M.

 

Dear SMUD Public Comment Email,

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,

Lynn M. 


April 17 - Ross K.

 

I am against the Rate Charged

I would really like to try and understand how SMUD is not screwing Solar Customers with new Fee proposal and how this wont reduce resale values of homes with Solar.

You already Charge me $20 for the ability to use power

My normal use during day nest me about 11,000 kwh per year of usage, and 4,800 kwh of Solar, So I still buy about $450 in power per year from Smud. 

Now you want to add a flat fee based on my System size because I somehow cause more stress to the electrical system even though most of my power back goes to other homes in my neighborhood or the battery storage you have here to be feed back out.

$8-$11 per Kw

For my 4kw system that $32 per month or another $384 on top of my current $450 I pay you.

I only generated 4800kwh last year, $384 / 4800 = .075 per kwh surcharge, almost the cost of the power if I just scrapped my Solar Units

Why am I paying you for all the power I generate, Not just what I give back.

Yes I am grandfathered but you were sneeky in that also 20yrs for me starting on connect date (10 yrs ago) so I only get 10yrs.

And if somebody buys my house they get fee day one, making the solar system a boat anchor.

And what if I go to Battery storage and give none back to SMUD, still hit with fee

And I get nothing for the fee, I still have to pay for the Lease on System $40 or Maintance if I own.

This fee will kill solar in Sacramento

Explain to me why I should pay for more of the infrastructure than any other user 


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 10 - Jeff K.

Dear Director Fishman - 

I hope this note finds you well.  It was great seeing you at several of the events late last year.  So encouraged to see the continued energy from the Board as it's come together since November.

I’m typically not one to weigh in on specific policy topics as I’m humbled by the staff brainpower that I see applied to policy formation, and remiss to put the narrow interests of a particular constituency above the complexity of SMUD’s task of service delivery.  However, from the perspective of a growing energy consultancy based in Sacramento with an extensive view of the Western Region market, I feel compelled to provide our viewpoint on the most recent staff recommendation to enact Grid Access Charges on ratepayers with behind-the-meter generation.  

Brighton Energy is not a pure-play solar company that bemoans any obstacle to solar growth.  While we do develop commercial solar projects in the CA IOU territories, as a holistic energy consultancy, our primary focus in SMUD territory is commercial energy efficiency (as SEED implementor on CES) and home performance.  While the approval of the Grid Access Charge would have little-to-no direct impact on our business, we still believe this would be the wrong path for SMUD and our community.  

1.) SMUD is already doing a great job managing growth of behind-the-meter solar.  We work with hundreds of commercial rate-payers across California and in many cases, premise-based solar is an important element of implementing their energy strategy.  In IOU territory, usage rates and demand charges are high enough and growing fast enough to make this extremely viable.  We frequently encounter clients that simply want to be rid of the IOU provider.  We have not developed even one solar project in the SMUD region as the low rate structure and remarkably high customer satisfaction aren’t providing the financial or emotional incentive to self-generate.  I looked quickly at the most recent staff reports (2017 full year numbers) which validates our anecdotal experience - residential and C&I penetration (MWh solar capacity / MWh sold) is 2.06% and 1.09% respectively [2017 Annual Report p. 48; CEO/GM Report on Rates & Services, 6/21/18, p. 18].

2.) Solar + Storage are an important element of the DER management mix.  SMUD has had an incredibly successful run of energy efficiency program effects; and while certainly not saturated, will have declining impact in years to come.  SMUD staff is already adding important elements of beneficial electrification and other DER management aspects to programs that will provide continuity for the non-wire demand management.  We believe that solar coupled with storage is an important DER lever that could be taken off the table by the current Grid Access Charge proposal.  

3.) SMUD is viewed as a leader in carbon reduction.  We have yet to see a capacity based self-generation tax proposed within California.  Should SMUD implement the proposed charge, it would join Nevada (where solar capacity growth all but stopped) on the forefront of extracting cost recovery from customers that self-generate.   The image of SMUD leading the charge on punitive taxation of customers who generate clean energy could do irreparable damage to the hard-earned reputation of SMUD as a leader in carbon reduction initiative.  While the risk is debatable, we believe that SMUD is already effectively managing the capacity growth so the exposure is unnecessary.  The $30M “subsidy" indicated by staff fails to account for reduced distribution and transmission costs, and for the financial and good-will value of the environmental benefits.  

I know all of the Board members are looking closely at the proposed rate structure changes and will - as always - do what is in the best interest of our community.  We are confident that the removal of the Grid Access Charge from the package of approved rate adjustments will best serve SMUD and our community over the long-term.  Feel free to contact me directly if you’d like to discuss further. 

Most Sincerely,

Jeff K., Managing Director
Brighton Energy


April 9 - Corienne S.

Dear Director Brandon Rose,

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,
Corienne S


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 7 – Randy L.

Hi, 

Not sure who sent the email. When I first was contacting SMUD about solar I told your rep. that we wanted to add more panels for our electric car we were going to buy in the furture. They told us we had wait till we purchase the car and then we could ad more panels. They told me I had to have the system installed by a certain date to get grandfathered in, but they did not tell me I would lose my grandfathered status when I added panels for the electric car I told them that I was going to buy. Your reps. should have been up front and give me the full story when you are trying to get as many people to sign up for your program and not leave out important detail like this buried in the CEO report. SMUD acts more like a company that is trying to break the original agreement at any opportunity you can find rather than Municipal Utilitiy that is really trying to help your customers. I hope you will do the right thing and let the customers that SMUD grandfathered in add panels without looking for any reason to kick me off grandfathered status. Would have been nice to be in the paperwork.

Thank you,

Randy


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 – Randy L.

Hi,

I installed solar back in 2017 so I was grandfathered in your grid access. We want to increase our number if panels due to greater electrical usage. I called into SMUD today and was told if I added panels to my system my grandfather status would be taken away. Can you please call me or give me more info on the new program and let me know if I install more panels before your June 24th vote I will be safe from the new charges per our original agreement.

Thank you, 

Randy L.


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 25 - Rachel B.

Hi Obadiah,

It was a pleasure meeting you at the Gridworks (formerly More Than Smart) "Future of NEM" meetings in 2017-2018. I appreciated your perspective on the discussion. To refresh your memory, I work with Ilan G. on Borrego Solar's policy team. We do commercial solar and energy storage development and EPC.

I wanted to reach out to discuss SMUD's "NEMv2" proposal for C&I customers. Might you have some time to connect about this, either by phone this week or on Tuesday 4/2 at your office in Sac?

We have two concerns I'd love to chat through with you--

  1. Customers in limbo. We have two large customers caught in the 1/1/2018-3/31/2019 limbo period. Borrego and our customers were all surprised to learn that their interconnection applications would not receive grandfathering protection. 
  2. Fixed charges don't send a price signal. The fixed charge, which will wipe out solar savings, is not a price signal that our customers can respond to. Unlike demand charges, TOU periods, or other rate design features, the fixed charge cannot be managed. The only price signal it sends is for the customer to decline to install solar or solar+storage. 

Might you have some time to discuss? We are surprised that SMUD would consider a policy that does not drive distributed generation towards some larger goal (load-shifting, for example, or self-consumption), but rather disincentivizes it entirely.

I'd welcome the opportunity to connect with you or one of your colleagues about this. 

Many thanks!
Rachel 
 


 

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/