Zero Carbon Plan public comments

Between December 2020 and April 2021, we took steps to collect feedback and approve the 2030 Zero Carbon Plan. Below are the public comments received during public comment period.

April 17 - Ronnie Jeanne A.

SMUD is the best and most responsible electric company for addressing the climate emergency. I want to purchase an electric car but feel I can't purchase one until I have solar electricity. Since my electric bill is so low, I won't benefit from solar financially and since my income is so low, I won't benefit from the tax break. However, SMUD has a program to assess all of this and provide some guidance on purchasing and installing and I think even financing. They assist their customers in acquiring solar electricity and purchase it reasonably and fairly to all. Very lucky they are my electric company.

April 16 - Laurie L.

I want to commend SMUD for attempting to achieve this “moonshot” to cut emissions to zero by 2030. You are creating a model that I hope utilities everywhere will follow.

At the same time you must realize that we are truly out of time. That means that no matter how much you accomplish, you still need to do more and do it faster. So although I applaud your efforts, it is imperative that you do all in your power to speed up this transition and do more than your current plans. Our children and grandchildren need a livable planet to grow up on and we have not yet turned the corner to ensure their future.

So I’m hoping that you will recognize that we’re very late for solutions to the climate crisis and will approach this transition using every possible tool you have—behavioral changes, incentives, disincentives, stretch goals, rooftop and community solar, etc. It’s past time to play it safe; we need your specialized knowledge and extreme creativity to show the rest of the state, country, and world that it is feasible to transition to zero carbon quickly. And then go beyond the timelines and goals you set at every opportunity. Some specific suggestions: center equity in all decisions, speed up the timeline for building electrification, support VNEM for community solar, increase rooftop solar in low-income areas, investigate new technologies, explore how distributed energy can work in our community, continue to engage and listen to the public, avoid carbon accounting tricks that don’t result in true emission reductions, engage the State in passing legislation to cut emissions faster...

This is an exciting project and I am proud to be in SMUD’s area. We are counting on you approaching the effort to achieve zero carbon with authenticity, creativity, and speed. Thank you.

April 16 - Karen J.

I am very grateful for SMUD’s commitment to be fossil fuel free by 2030. It is a big step for our region and a model for other utilities nationally. I am also grateful for the electrification incentives SMUD provides. They are critical in helping the SMUD region reach its electrification goals. Overall, I am really pleased with the 2030 Plan. I do, however, want to comment on two specific issues that I hope SMUD will address.

As someone who is in the process of retrofitting the buildings I own to make them electrification ready, I encourage SMUD to identify any portions of its own system that could make that problematic due to undersized transformers or feeder lines. I hope SMUD will do this sooner rather than later. I have already encountered a problem trying to retrofit a two unit residential building in the Central City where the feeder line is inadequate for the additional current required to make my building all electric. The cost of either installing an additional power pole on my property or trenching the length of my backyard and across the alley to the existing power pole is prohibitive and is in addition to the cost of new electrical boxes and the need to do some rewiring with heavier gage wire. The feeder line inadequacy has left me unable to retrofit my building and I'm sure I won’t be the only one with this problem. It is an issue SMUD must address because it's so expensive and problematic that property owners simply can’t.

SMUD’s plan to get to the last ten percent of non-fossil fuel energy needed includes the use of various biofuels, including some biofuel from California’s dairy industry. I find dairy industry biofuels problematic because it is my understanding that the digesters used to convert manure into biogas only make economic sense for large dairies (3,000 or more cows crowded together in feed lots). My concern is that, in addition to releasing methane, dairies of this size cause other significant air and water pollution problems as well as bad odors, all of which negatively impact adjacent communities, most of which are poor communities of color. Because of this, large dairies are the kind of agricultural operations that need to be phased out, not encouraged. I’m concerned that buying biofuel from them will not only keep them going but cause them to expand. I have also read articles where epidemiologists identify factory farms that crowd huge numbers of animals together as having the potential to cause pandemics. I do not want to see the already serious problems of poor rural communities made still worse and hope that SMUD can find ways to avoid using this particularly problematic source of biofuel.

Thank-you for this opportunity to comment.

April 16 - Sacramento Climate Coalition Climate Emergency Team

First, we hope this does not set a precedent for short public comment periods, sixteen days was simply insufficient to engage with our Coalition members adequately. Since the scale of changes necessary is so vast and there are repeated commitments to partnerships, we trust you will include adequate time for public comment in future steps toward Carbon Zero.

The Sacramento Climate Coalition, a group representing 34 organizations in the Greater Sacramento area, would like to applaud, once again, SMUD’s commitment to preserving the planet as we know it for our children and grandchildren. Your leadership in this area is outstanding. Thank you.

We found much to like in your Zero Carbon Plan. Specifically, we applaud and stand firmly behind the following points:

A commitment to achieving a status of zero carbon by 2030. You have correctly concluded that 2045 (advocated by the State of California) is too late to achieve Carbon Zero in view of the rapid accretion of GHG in the atmosphere.
The decision to take McClellan and Campbell’s Soup plants out of operation.
Reliance on proven clean technologies and expanded investment in wind, solar and geothermal.
A focus on both affordability and reliability.
The Government Affairs Section is an important part of the plan and a welcome sight, since SMUD accurately acknowledges that ultimate success in decarbonization of the economy requires the assistance of multiple levels of and overlapping jurisdictions.
The “Action plan and risk mitigation strategy” section sets out a chart of near-term action items to be completed by March 31, 2022, and a chart of medium-term action items to be completed by March 31, 2024. These charts do a good job of listing the initial actions that must be taken in working on the 2030 Zero Carbon goal.

We have a few suggestions that we believe will make the document stronger. The recommendations are listed below. You will find more detailed explanations after this section.

Suggestions for Section: Thermal Energy

Overall this section addresses many issues. The information could be better presented. As it reads now it’s difficult to see how all the points link together.
The timeline for the Thermal Plants shutdown is unclear and lacks specifics.
Provide more detail for the actual costs of RNG (biomass), and the potential environmental impacts when producing it..
Be more specific about when the Cosumnes Plant will be off natural gas.
Be more specific about what criteria SMUD will apply to the resource options (cost, thermal losses from transmission, reliability, etc.). These criteria are needed to determine what types of energy SMUD will need to import.
We need to produce more Solar Power locally, and purchase less from abroad.
While the report says hydro is a critical resource, a more thorough analysis showing how or if this resource will be exploited beyond current levels is needed.

Suggestions for Section: Proven Clean Technologies

Make use of the federal investment tax credit to help rates by investing in combined solar and battery storage projects.
Provide aggressive support for local rooftop solar and battery storage.
Make a solid commitment and plan to partner with the City and County of Sacramento to take advantage of Federal and State funding.
Expand your program for rewarding customers for their willingness to give up power when the grid reaches a critical demand state.
SMUD should couple the planned procurement of 250 MW of solar power by 2024 with more battery storage than the proposed (5MW) to build solar power plus battery storage units. Hybrid solar projects coupled with battery storage can take advantage of federal investment tax credits and help keep SMUD rates down, while becoming operational before the natural gas plants are retooled to become peaking units.

Suggestions for Section: New Technology and Business Models Strategy

Commit to transparency in decision-making and data sharing with the public.
Accelerate the adoption and scale up of new VPP and DER programs especially where pilots already exist and customer base can be expanded more rapidly due to the existing investment in infrastructure.

Suggestions for Section: Financial Strategy and Options

Metrics that take into consideration the impacts that climate change has on the health of our citizens (especially low income) need to be used every time SMUD makes a decision.
Leverage Partnerships: partner with the City and County of Sacramento who have CED’s of their own with a 2030 timeline. Partner with technology leaders. Partner with your customers (rooftop solar). Viable partnerships produce financial wins.
Another partnership opportunity is within the residential rooftop solar space. SMUD should partner with the City and County to advocate that the State’s $14.3 billion surplus to support rooftop solar for low-to-moderate income residents, as recently identified by the Sacramento Bee.

Suggestion for Section: Government Affairs Strategy

SMUD has correctly recognized that the year 2045, as seen in both State and City documents, is too late for the planet. The advocacy strategy that you articulate in this section needs to focus on updating these targets to 2030.

Suggestion for Section: Action plan and risk mitigation strategy

No actions for the years 2025 to 2030 are listed and intermediate goals for these years are not identified. A more robust analysis needs to be completed on the actions required in these years and their probability of success.

Suggestion for Section: Conclusion portion of the Draft Plan

The Conclusion of SMUD’s Draft 2030 Zero Carbon Plan lacks the spark and excitement that can be seen in the plan itself. The Executive Summary offers a better outline of SMUD’s commitments and proposed programs for 2030 Zero Carbon. Incorporate more of the Executive Summary into the Conclusion.

DETAILED RECOMMENDATIONS FOR EACH SECTION FOLLOWS:

Thermal Energy/Natural Gas Generation Repurposing Strategy

The Natural Gas Generation Repurposing Strategy chapter addresses many issues, information, and possible solutions. However, the information is scattered all over the chapter, and it is difficult to see how the recommendations get applied to comparative scenarios (retire all thermal units vs. retiring two units). It requires several reads to make sense of this chapter.
The timeline for Thermal Plants is vague, and lacks detail.
a. This chapter does not state when work is to begin on each of the five projects, so it is impossible to clearly understand why two of the retooling projects, Carson and P&G, are scheduled for completion in 2027 and 2029, respectively. Starting to work now on multiple projects will save money in the long run and provide for more opportunities to reduce GHG emission sooner than later (and provide for “shovel ready” grant proposals as discussed in the Finance chapter).
b. However, in the Action Plan on page 118, it states under near-term action items that “Feasibility Study of the reliability, economics and impacts, focusing on solutions for McClellan and Campbell will be completed by March 31, 2022.”
c. Under Medium Term Action Items to be completed by March 31, 2024: The document states, “Update and implement Natural Gas Generator Repurposing Strategy, including:
∙ Finalize solution for McClellan and Campbell replacement.
∙ Conduct comprehensive reliability analysis and retooling (or retirement) plan for each thermal generator location [Carson, P&G, and Cosumnes] and update retooling plan annually as necessary.
∙ Update our research and development plan for new large-scale technologies. Seek expertise and opportunities to partner, research and fund projects.”
d. The reader must conclude that the two dates mentioned are completion dates, but no indication of a start date other than 2021. And, the work for the medium-term projects takes longer than the near-term projects. Are there near term milestones you can list as near-term for the Carson, P&G, and Cosumnes? And, please show a start date so the readers know for sure when the work is to begin.
e. The Carson Power Plant, as described in the report [pg.67], lists a number of studies that need to be done to deal with growth in the area over the next “5-years and beyond” and mitigation measures. If this could begin now, this could also improve the scheduled completion date. A study that looks at impacts in five years should already be under way.
f. We support the decision to take McClellan and Campbell’s Soup plants out of operation. Proctor & Gamble should also be considered for conversion to zero emissions technologies rather than RNG.
The Plan is unclear as to the actual costs of RNG (biomass), and the potential environmental impacts when creating RNG. SMUD may want to see biomass as a bridge solution, and it may be necessary until better fuel solutions are found. Currently, biomass can produce electricity on demand, help the grid meet predictable changes in load and complement variable sources of power, like wind and solar. But there are likely impacts that need to be studied by SMUD.
When will Cosumnes be off natural gas? The report isn’t clear, but it hints it may extend beyond 2030 and rely on carbon sequestration options. The Cosumnes options, including benefits and impacts, should be clearly spelled out with individual timelines for each fuel option, including, but not limited to:
a. RNG options from landfills and waste treatment plants
b. Hydrogen options listed
c. Renewable diesel
d. Options with battery usage, especially flow batteries and batteries with durations of 12 hours or longer
e. Add carbon sequestration to alternatives to ensure net zero carbon
Figure 8, page 71: What is meant by, “Coordinate plan with Clean tech, new tech/distributed resources”? This Figure suggests that Cosumnes may not be operational as a biofuel operated plant in 2030 if the “Pursue biofuels…” and “Coordinate plan…” banners are accurate.
SMUD plans to procure 250 MW of solar power by 2024. This provides an opportunity to act early and increase battery storage beyond 5MW, as proposed. Solar power tied to batteries (and possibly other types of storage in the near future) will be essential for base load operations and should be in operation before Carson, P&G, and Cosumnes convert to peaking power plants. Plus, hybrid solar projects coupled with battery storage can take advantage of federal investment tax credits and help keep SMUD rates down.
Imported Power: The report shows that if all thermal plants were retired, SMUD would need to create/purchase 3,200 MW of power from outside SMUD’s service area. How much will need to be imported if three of the five plants stay operational? Can we just reduce the total by the amounts shown in Table 9. SMUD thermal power plant overview in 2030? Is It accurate to state SMUD will need to find 3,200 – (100+150+621)= 2,329 MW of outside power? Table 10, Summary of Proven Clean Technology resource potential ranges (MW), [pg. 84] in the Proven Clean Technology Chapter, shows ranges of available power, but doesn’t really answer the question of what criteria would SMUD apply to the resource options (cost, thermal losses from transmission, reliability, etc.). These criteria are needed to determine what types of energy SMUD will want to import. Last, do we need to import solar power in Sacramento County when we have so much more “capacity” to grow solar at home? We support increasing the support for rooftop solar and the various DER solutions that are listed in Section on New Technology and Business Models Strategy.
Hydro in the UARP. While the report says hydro is one of four key bullet points, SMUD really doesn’t plan any analysis. SMUD must look at reoperation of the UARP as configured (with no new facilities) but using three thermal plants and other scenarios as they are developed. The emphasis should be on improved operation of the UARP and not just plugging in hydro’s existing operations into the operation plans of the thermal units.

SMUD may find new ways to operate the UARP that can save water and increase efficiency of operation while still meeting regulatory release patterns. This is important especially now that the thermal plants are peaking units and climate change may create long drought periods where every drop of water will be needed. This type of study will not conflict with SMUD’s concerns regarding, “the cost, permitting challenges and environmental concerns. We also see a broader trend to reduce the number of existing dams.” [pg. 84]

Proven Clean Technology

We support SMUD’s reliance on proven clean technologies and expanded investment in wind, solar and geothermal. Although these strategies are beneficial since they are available at different times, battery storage is key to expanding their use. Battery storage technology is improving at such a rapid rate, it is important to invest earlier than proposed and to investigate and test long duration storage technologies. We hope SMUD will investigate and utilize the federal investment tax credit to help rates by investing in combined solar and battery storage projects.
SMUD should aggressively support local rooftop solar and battery storage, as well as panels on commercial buildings, parking lots and highways. These local efforts will not require the costs of long distance power lines, loss of power during transmission, costs of joining a larger power distribution network and will preserve California and other State’s open space and habitat and avoid environmental harm.
Furthermore, we support the Sacramento Bee’s opinion that solar must be made more attractive if California is to have any chance to meet its climate-change goals.
Finally, we agree that affordability and reliability are important; however, we don’t believe one size fits all. Let’s ensure affordability for low and moderate income residents, but more affluent residents may want to invest in something like renewable green hydrogen production. Also, let's expand the reliability options. Expand your program for paying customers for their willingness to give up power when SMUD’s customer base reaches a critical demand state.

New Technology and Business Models Strategy

To be successful with this element, SMUD will need to maintain a commitment to a high degree of transparency and sharing data with the public.
In the timeline on page 100 the schedules appear longer than necessary. While contracted capacity VPP might take a little longer than the BYOD space VPP, both seem to be taking quite a bit of time especially with the scale up and expansion times included. In reality these programs aren't at 100% until 2026, while the Plan acknowledges that research has already been done on some of the elements. In view of the urgency of the climate emergency and the consequences of not reducing GHG as quickly as possible, this delay in implementation appears irresponsible. Any acceleration would be a benefit, but it's hard to quantify how much potential for the schedules’ acceleration with the level of detail in this document.

Financial Strategy and Options

The goals and objectives are as clearly stated as can be expected at this time, and it is now an appropriate time to begin to form partnerships as described in this report.
The SMUD “balance sheet” doesn’t account for the current impacts of climate change that have already ravaged our state. Nor does it include the impacts on the health of our neighbors (especially low income neighbors). These metrics need to be measured each time SMUD makes any decision. Your 2030 strategy is bold as it is, but this is no time to delay progress and place money over our climate and our health.
As described on page 104, “It’ll be important to continue meeting or exceeding our financial metric targets to ensure we have access to the capital needed to implement our 2030 Zero Carbon Plan, and protect against larger rate increases in the future.” GHG emissions should become a new target that is recognized as a way to avoid greater costs to SMUD in the future if climate change targets are not met.

Create Partnerships Starting with a City, County, and SMUD Regional Partnership
Working with the City and County through a partnership agreement (e.g., an MOU or a JPA ) SMUD will develop stronger relationships as the three agencies work towards a similar 2030 Zero Carbon goal. The City, County and SMUD, as the three jurisdictions in this county which have already adopted a Climate Emergency Declaration, are the core team members that can tackle topics and issues like, but certainly not limited to:
a. Environmental Justice financing, because all have a role and responsibility in this area.
b. New developments that should be designed as all electric (technical recommendations, building code revisions, permitting, and financial incentives)
c. Work in under-represented areas on green projects like accelerated tree planting. All have funds for this and funding can be shared to address areas with high SCI Sensitivity Scores [per Figure 6].

This partnership recommended fits well into the Sacramento Regional Partnership discussed on page 106. “Sacramento Regional Partnership: Collaboration with government, environmental agencies and private organizations will expand ideas, tackle common barriers to accelerate timelines and co-invest in solutions to lower total decarbonization costs in a coordinated and efficient way.” The Partnership should collaborate with the Technology partners and the One Sacramento group discussed below.
Technology partners in manufacturing, other energy providers, and financial institutions and foundations are also important and should also collaborate with the Regional Partnership and the One Sacramento group discussed below.
The “One Sacramento” initiative isn’t explained, but is called a key example bringing together local governments, academia, regional organizations, industry, under- resourced communities, healthcare organizations and investors. The report further states, “By creating a forum to discuss our shared goals, we can expand the array of potential partnerships, streamline planning processes and maximize the regional impact of expected new funding from stimulus and recovery packages and possible Green New Deal funding.”. This partnership appears to be a Partnership with other community partners, as described on page 106, and should also collaborate with the Regional Partnership and the Technology partners.

Grants and “Shovel Ready” Projects
Regional partnerships for economic mobility are a great idea, and will improve chances for grant awards with partners in our area that support grant proposals. Having “shovel ready” projects defined, sub-recipients or other partners identified and vetted, and teams with the capability and capacity to build a winning proposal.”[page 109]
Being “shovel ready” will take time so that planning and engineering is advanced enough that with sufficient funding, construction can begin within a very short time. This is another reason to try to expedite critical GHG emission elimination projects as soon as possible.
We also recommend SMUD partner with the City and County of Sacramento to support the Sacramento Bee’s proposal to advocate that the Legislature and Governor Newsom utilize the $14.3 billion surplus to support the rooftop solar program and take some of that unexpected money to create a fund to help low-to-moderate income residents to get their own solar systems installed.
The last paragraph of the chapter says, “Building on this momentum, we can capture grant funding by implementing a grant capture team focused on our 2030 Zero Carbon Plan goals. This team will leverage our current capture process to do three things:
a. Leverage industry partnerships to help define and align agency funding with SMUD projects.
b. Leverage our Government Affairs team and external partners to advocate for zero carbon grant funding.

What is number three?

Government Affairs Strategy

This is an important part of the plan and a welcome sight, since SMUD accurately acknowledges that ultimate success in decarbonization of the economy requires the assistance of multiple levels of and overlapping jurisdictions.
a. Looking for collaboration and funding from State and federal levels of government will be a valuable tool in achieving the goals of the Plan.
b. The commitments to challenge outdated policy, promote beneficial regulation, and educate policymakers are all crucial to the success of the Plan.
c. Similarly the commitment to engage the public in advancing the Plan is exciting and we gladly commit to engage with you to make sure this happens.
The Plan calls out Governor Brown’s executive order and statements by the Mayors of Sacramento and West Sacramento to focus on 2045, which SMUD has correctly concluded is too late to achieve Carbon Zero in view of the rapid accretion of GHG in the atmosphere. The advocacy strategy that SMUD articulates in this section also needs to be directed towards updating these targets to 2030.
We also encourage a specific focus on teaming with the City and County of Sacramento to develop a partnership to co-commit to public education, ordinance and other rulemaking strategies that can optimize the different powers of local governments to promote SMUD’s energy efficiency, VPP, solar and transportation strategies including retrofit of existing buildings.

Action plan and risk mitigation strategy

The “Action plan and risk mitigation strategy” section of the 2030 Zero Carbon Action Plan sets out a chart of near-term action items to be completed by March 31, 2022, and a chart of medium-term action items to be completed by March 31, 2024. (pp. 118-120.) These charts do a good job of listing the initial actions that must be taken in working on the 2030 Zero Carbon goal. However, no actions for the years 2025 to 2030 are listed and intermediate goals for these years are not identified. The Action Plan is not a timeline that sets out milestone goals that need to be met if the 2030 goal is to be achieved, but rather a plan for the first four years, 2021 – 2024.
This omission of identified actions to be taken after 2024 is explained by the approach taken with long-term planning in this Plan, which uses risks and mitigation strategy. Using this strategy, a plan for future action must identify key 9risks that need to be taken into account (i.e., negative technology impacts, climate change, regulatory changes, etc.) and a flexible strategy should be used for future planning. The flexible strategy advocated for use in this Plan is that of adaptive planning, using a “least regrets” decision analysis to determine which decision will minimize cost across various versions of future developments. This least regrets decision is the one that should be adopted for risk mitigation.
There are two very significant flaws with this approach. The first flaw lies in the definition of cost. The second lies in the failure to maximize achieving the ultimate goal of the plan.
In deciding which actions should be taken, the flexible strategy compares the costs of different decisions, and chooses the one with the least cost. But, this Action Plan does not define “cost” or identify what factors should be considered in determining the cost of a decision. Certainly, financial costs matter and must be considered. But, there are other costs, too, that are difficult to quantify. With air pollution, there is a cost in dollars to eliminate or remediate it, but there is also a cost for people with asthma, for children who can’t play outdoors, and for businesses that can’t provide outside activities. You can quantify lost wages and health care costs, but how do you compute the “cost” of human suffering and loss of outside activities? The answer must be, obviously, that much value is given to human suffering and the effect on community activities, and this value must be taken into consideration when computing the “cost” of an action. How you define “cost” is key, and this Plan does not explicitly set out the more inclusive definition of cost.
The second flaw in this approach is that it does not make meeting the 2030 Zero Carbon Goal the overriding, ultimate result that must be met. If one action is cheaper than a second one, but the second one will advance our progress to zero carbon ten times more than the first one, the second one should be given more weight. If choosing this second one has a negative impact on finances, or land use, or transportation, then ways to mitigate those resulting negative effects should be considered and adopted if possible. A flexible plan should stay focused on the ultimate goal – 2030 Zero Carbon – and should make necessary adjustments to the intermediate actions and goals to maximize the possibility that we will meet this goal. A strict “least regrets” decision analysis to determine which decision will minimize cost does not appear to do this.
The bottom line in the 2030 Zero Carbon Goal is getting to zero carbon emissions by 2030 and protecting our community, businesses, land, agriculture, and habitat, as best we can. This Action Plan needs to stay focused on that ultimate goal and be a plan to get that done.

Conclusion

It is clear from the state of the world’s climate and increasing climate disasters that as a nation, we should have begun collective action way before the present time. 10SMUD has been a leader for decades, often before their fellow utilities, in implementing green energy programs and energy options for its customers and therefore helped in the effort toward a more carbon free planet. The Conclusion of SMUD’s Draft 2030 Zero Carbon Plan however, lacks the spark and excitement that can be seen in the plan itself. The Executive Summary offers a better synopsis of SMUD’s commitments and proposed programs for 2030 Zero Carbon.
The Conclusion states: “ One of the defining features of our 2030 Carbon Zero Plan is to reduce emissions associated with all our electricity generation”. It continues with the “all-encompassing goal will be removing natural gas from our portfolio”. It outlines the need for flexibility in engaging in renewable technologies and as each new element is implemented that SMUD “will need to reassess the system , the technology landscape and customer preferences.” The illustration of the”Flexible Pathway” in the conclusion is disconcerting to look at. It is tipped to the far right in terms of action and leaves major action to the last few years. For example 2027 is the year for implementation of the new tech and business models. New technology must be explored and studied before proceeding, and SMUD clearly wants to implement the best scenario for its customers and its budget, but much of this technology is already proven with industries that are already established, and the cost of much of the technology has dropped in recent years. SMUD has outlined it is very concerned with raising rates and of being able to maintain a reliable source of energy once it shifts to renewable energy. It appears that remaining “flexible” means being very cautious. While doing a good job of researching new energy sources does need to be done, boldness is what will save our planet. This Plan’s Conclusion and the slow proposed inclusion of New Technologies suggest that too much study, reassessing and caution, might delay critical action needed to address this crisis in a timely way.
The renewable resource mix is exciting, as is the repurposing of the natural gas plants, and solar as seen in the graph on page 115 is the biggest portion of renewable options. The figures in the conclusion on the megawatt goals for solar, however, do not match those in the Executive Summary for the same resource.
Your Executive Summary paints a brighter picture. It includes what the Conclusion is missing: excitement about the 2030 decarbonization plan, a major acknowledgement of the need for equity and working with disadvantaged communities to elicit their feedback, and supporting them in obtaining green technology in their homes and as well as developing “a comprehensive regional communications, marketing, outreach and education effort” (p. 18 - table with the year 1 priorities). In addition, the table on page 18 includes identification of “workforce skills needed to support zero carbon technologies,” also an essential task. On page 7 SMUD states that “...widespread adoption of customer-owned distributed energy resources like electric vehicles and rooftop solar will be key to achieving zero carbon.” This is very important for the public to hear. Historically, SMUD has not been seen by many in the public as supportive of rooftop solar. 11
Envisioning this venture as a partnership with your customers and the community, as well as the Cities of the Sacramento area, the County, and community and business organizations, is a wise approach. These partnerships are vital to be successful in this fight. Joint efforts can clearly offer cost savings as well.
It would be preferable to read an overview of the Executive Summary for your Conclusion, as it would leave the reader feeling like SMUD is less tentative and more fully engaged in this process.

Chris B.
Coordinator
Sacramento Climate Coalition Climate Emergency Team

April 16 - David W.

Kudos for setting and pursuing an advanced zero-carbon goal. Unfortunately, to get there SMUD exec staff are proposing a plan that looks like corporate energy - make more, sell more, increase revenue, get bigger. Instead, the Board must continually redirect SMUD executives to focus on customer (= co-owner) benefits. Even if this makes SMUD smaller, reduces gross revenue -- if it helps the customers-SMUD ecosystem, it should be in SMUD's plan: Load reduction by conservation and initiatives like solar thermal hot water. VNEM. NEM that supports customer solar+storage. Daytime EV charging infrastructure at attractive rates or with a day/evening exchange agreement with EV owners to support demand/supply balance using V2G. Many more objectives like this need expanding and all need explicit targets in the 2030 Plan. This will require continuous work and continuous improvement - thank you for your commitment.

April 16 - Luis A. & Barbara L.

2030 Zero Carbon Team
Sacramento Municipal Utility District

RE: Sierra Club’s Supplemental Comments on 2030 Zero Carbon Plan

This letter is to supplement Sierra Club’s comments submitted to the Sacramento Municipal Utility District (“SMUD”) on April 13, 2021. To clarify, our letter at that time was focused on providing feedback, and we want to emphasize that the Sierra Club is very supportive of SMUD’s efforts; we are especially pleased with the SMUD goal of zero carbon as opposed to net zero carbon.

Sierra Club is also encouraged by the willingness of SMUD to work with us to address any areas of concern with the plan - we want SMUD to succeed. One area we would like to see be refined in the plan is the elimination of SMUD’s gas fleet, and the replacement of language around retooling power plants with biofuels to clean fuels, which would be consistent with the Resource Plan policy changes the Board recently made. However, before we consider retooling certain gas units, we would like to see SMUD commit to retiring its entire gas fleet in the future, pending a reliability assessment that would include looking at the public health, climate, and economic benefits of replacing the gas fleet with clean resources.

As such, we recommend that SMUD revise the gas generation repurposing strategy as follows: (1) Commit to retiring all of the gas units no later than 2035; (2) Study and prioritize the retirement of McClellan in 2024 and Campbell in 2025; (3) Study the retirement of Carson, Procter & Gamble, and Cosumnes shortly after 2025 but no later than 2035; (4) In conjunction, research and scale alternatives to gas should be considered in the plan. Should some type of combustion be needed pending a reliability assessment note that it will be done with clean fuels, such as hydrogen.

To reiterate, we want SMUD to succeed, and we also want it to set an example for other utilities to follow. We look forward to working with you in implementing an aggressive zero-carbon plan that meets the moment this climate crisis demands, and maintains affordability and reliability.

Sincerely,

Luis A.
Senior Campaign Representative
My Generation Campaign

Barbara L.
Chair, Sacramento Group
Motherlode Chapter

cc: General Manager, Sacramento Municipal Utility District

April 16 - Daniel K.

As a SMUD ratepayer and a small business owner in Sacramento I believe that in order for SMUD to achieve the zero-carbon goal as laid out in the plan the utility must develop a balanced portfolio of utility scale solar projects that are grid connected and are developed on lands that are degraded or environmentally contaminated. The amount of local renewable energy SMUD is forecasting to need by 2030 may likely have to be increased due to higher load growth, deeper electrification efforts, and earlier retirement of remaining natural gas generation beyond what is in the plan. It is prudent for SMUD to begin planning for where these additional renewable resources should be coming from beyond a 10-year planning horizon since the ultimate objective will be zero carbon emissions and 100 percent clean energy. Getting to the goal of 100 percent clean energy seems aspirational right now but the technologies that are being reviewed in SMUD’s Zero Carbon Plan lay the groundwork for the investments in renewable fuels to power next generation carbon free powerplants but to achieve this goal will require new electric infrastructure investments to create grid resiliency and build more capacity to bring power in from outside of the Sacramento region. I support the goals and vision that SMUD has laid out the Zero Carbon Plan and want the utility to exceed not just meet them since the impacts of climate change and our need for adaptation in a zero carbon world will require us to move the needle further and faster beyond 2030.

April 16 - National Fuel Cell Research Center (NFCRC)

Dear Sacramento Municipal Utility District,

The National Fuel Cell Research Center (NFCRC) respectfully submits comments to the Sacramento Municipal Utility District (SMUD) on the proposed 2030 Zero Carbon Plan.

I. INTRODUCTION

The NFCRC facilitates and accelerates the development and deployment of fuel cell technology and systems; promotes strategic alliances to address the market challenges associated with the installation and integration of fuel cell systems; and educates and develops resources for the power and energy storage sectors. The NFCRC was established in 1998 at the University of California, Irvine by the U.S. Department of Energy and the California Energy Commission in order to develop advanced sources of power generation, transportation and fuels and has overseen and reviewed thousands of commercial fuel cell applications.

The NFCRC greatly appreciates the bold vision laid out by SMUD to reach zero carbon emissions in our power supply by 2030. We applaud the consideration and inclusion of hydrogen, and further request that SMUD:

Include fuel cell systems and microgrids in the near-term plan to achieve zero carbon, resiliency, climate, air quality, equity, and infrastructure goals.
Outline actions in the near-term that will allow for large-scale use of hydrogen production and storage by 2030.

II. COMMENTS The use of fuel cell systems, hydrogen and renewable gas has a significant impact on the reduction of criteria air pollutants and air toxics as well as greenhouse gas (GHG) emissions, making these technologies important solutions to advance the goals of SMUD and the Sacramento region while also addressing air quality and environmental justice issues.

A. Fuel Cell Systems

Fuel cells are uniquely qualified to serve 24-7-365 power generation as well as backup generation requirements. Due to high operating efficiency and continuous operation, non-combustion fuel cell systems generate electricity that is cleaner than the utility grid network—resulting in reduced GHG and criteria pollutant emissions.

The fuel cell industry provides significant benefits to its customers in the form of very high fuel efficiency, low and zero emissions, resilience, and the ability to island from the grid. Many fuel cell installations operate as behind-the-meter projects, at commercial, industrial or critical facility sites, meaning that they are configured to provide onsite power with little or no export to the distribution system. As such, it is a primary concern of NFCRC that distributed energy resources (DER) be valued appropriately for the benefits that they provide to the grid. For example, an electron generated by a zero emitting or low emitting technology makes the SMUD energy system cleaner regardless of whether it is consumed behind the customer meter or exported onto the distribution system. Similarly, a project can provide load relief with both exported generation and generation consumed behind-the-meter. Both configurations of projects should be compensated for the values that they provide to the grid. As an example, ISO New England recognizes this fact and allows behind-the-meter generation and other load reductions, such as energy efficiency and demand response, to participate in its Forward Capacity Market.

Emission Reduction and Local Air Quality

Clean distributed generation, such as that produced by fuel cell systems, has unique features and capabilities to address the need for air quality in geographically diverse communities and serve as alternative power and heat generation sources.

The reductions of carbon and criteria air pollutants from stationary fuel cells can also make a direct positive impact on local communities. Stationary fuel cells can create additional positive local air quality impacts, provide non-intermittent renewable power (when using renewable gas), and support SMUD’s significant energy and environmental goals.

Fuel cell systems also displace traditional emergency backup generators (almost exclusively diesel combustion generators) that emit criteria air pollutants and GHG. This feature is especially critical given that poor air quality can be a major issue in disadvantaged communities that are often disproportionately burdened by air pollution and risks of COVID-19. By providing always-on zero criteria pollutant emission power, fuel cells can increase adoption of intermittent renewable wind and solar resources throughout California while significantly increasing the generation of decarbonized and pollutant-free electricity.

Load Management, Reliability and Resilience

Both front-of-the-meter and behind-the-meter fuel cell resources are well-suited to resolve transmission and distribution constraints. Not only do fuel cell power plants reduce GHG and criteria air pollutants, they are also efficient, compact, quiet and easy-to-site, and are ideal DER solutions where resilient power is needed near a load. Fuel cell DER facilities serve loads and can provide benefits to the utility system at the distribution level, whether literally on the customer premises (behind-the-meter), or in any number of front-of-the-meter applications including:

a) at substation interface points acting as load reducers and providing capacity to the regional transmission and distribution system;

b) on utility circuits leading to key customers;

c) as a primary generation resource enabling operation of a multi-load, multi-customer utility microgrids;

d) under a combination where a normal front-of-the-meter resource can serve a dedicated circuit providing a behind-the-meter service to a critical customer (e.g., a wastewater treatment plant);

e) under a combination where a normal behind-the-meter facility can also provide local load reduction as a front-of-the-meter resource under a Net Energy Metering, Demand Side Management (DSM) or desired export situation.

Fuel cell systems generate 24/7, clean, load-following power at close to 100% capacity factors. The hydrogen fuel cell electric generation profile fits prime power, continuous power and backup power requirements. Compared to other front-of-the-meter non-wires alternative solutions, the combination of fuel cell high efficiency and extremely high capacity factor results in the displacement of more GHG emissions than equivalent-sized intermittent resources, such as solar and wind power. This high capacity factor corresponds to the production of clean, renewable electric energy (MWh) per unit of power capacity (MW) that is on the order of four (4) times that of solar power systems (assuming a 25% capacity factor for solar) and on the order of three (3) times that of wind power systems (assuming a capacity factor of 30% for wind). Thus, investments in fuel cell non-wire solutions produce vastly more energy than wind or solar power systems per unit of capacity installed. When this electric energy is produced at times of low solar and wind energy availability, the fuel cell systems produce much lower GHG emissions per MWh. This translates into substantially more GHG reductions per MW installed.

The integration of combined heat and power (“CHP”) can enhance the air quality and GHG benefits of fuel cells by providing an effective and highly efficient mechanism (up to ~90% system efficiency) to reduce emissions from traditional thermal generation methods (e.g., industrial boilers and process heat, commercial space and water heating).

Installations of fuel cell systems can be used by SMUD to (1) support local capacity and spinning reserve requirements that are used for grid reliability, (2) serve as an alternative to costly transmission and distribution upgrades to the system, and (3) with appropriate rate structures allow dynamic dispatch of the fuel cell systems to enable the grid to integrate more intermittent renewable generation.

Fuel cell systems support the utility grid network and can also provide ancillary services such as:

Peak demand reduction;
Power quality improvements;
Grid frequency and voltage support; and
Fast ramping and load-following.

B. Renewable Hydrogen

Renewable wind and solar power generation, fuel cells operating on natural gas, biogas, and renewable hydrogen, and energy storage technologies can all reduce CO2 and other GHG emissions. Through the fuel flexibility of fuel cells and the ability to operate continuously and follow fluctuating electrical (and thermal) loads, fuel cell systems can also provide a critical role in enabling increased market penetration of renewable solar and wind resources on the grid. These features of fuel cell systems allow them to reduce pollutant emissions and improve air quality over and above the improvements that can be made with solar, wind, and energy storage systems alone.

Renewable hydrogen, including hydrogen as a blend stock or secondary component with methane can be produced from many renewable sources including biogas, other renewable gas derivatives, and by renewable solar or wind powering of water electrolysis in power-to-gas applications. Hydrogen is critically needed today to address both the stationary power and the transportation air quality and GHG reduction goals of SMUD, for many reasons. First, hydrogen offers one of the only economic, modular, and geographically flexible means for zero emission long-duration (e.g., seasonal) storage of renewable power. Second, hydrogen can be produced in much larger quantities than all other renewable gases to meet a much larger fraction of the otherwise difficult to electrify end-uses (such as long-haul freight, aviation, marine transport, and industrial heating). Third, hydrogen offers zero GHG and zero criteria pollutant conversion options in both its production and end-use. Fourth, there are fuel cell systems available today that can use these renewable fuels and are only constrained by the availability of these fuels, which limits both the market and the significant GHG, criteria air pollutant and toxic air contaminant emission reductions that can be uniquely achieved using continuous power fuel cell systems. Organic feedstocks are more limited than solar and wind resources, which are technically able to produce large amounts of renewable hydrogen via a power-to-gas electrolysis process.

Every jurisdiction that has objectively analyzed how all sectors of the economy can reliably become zero emissions has identified hydrogen as an essential element of their strategic plans. These jurisdictions include Germany, France, Portugal, United Kingdom, Japan, Australia, South Korea and China amongst others. Most of these jurisdictions have complete decarbonization goals that are not as ambitious as those that SMUD plans; that is, SMUD is committing to net-zero emissions by 2030 while most of these jurisdictions plan to be net-zero emissions by 2040 or later. Since hydrogen infrastructure is nearly non-existent today (except for a very small number of hydrogen production facilities, small sections of pipeline, and small numbers of delivery trucks and fueling stations) immediate investment in hydrogen infrastructure is required if it is to become available to support SMUD goals for 2030.

In particular, the NFCRC recommends investment in infrastructure to engender large scale use of hydrogen and the immediate introduction of pilot projects that produce renewable hydrogen, store renewable hydrogen, transmit and distribute renewable hydrogen in both new and dedicated hydrogen pipelines, and as a blend-stock that can eventually transform the current natural gas system into a renewable energy transmission, storage and distribution system. Unless these investments are made immediately, the infrastructure will be insufficient to allow hydrogen to enable zero emissions economy-wide. As a comparison case, Germany alone has committed to spend at least nine billion euros on hydrogen beginning in 2021.¹ And hydrogen is the only known zero emissions solution for many attributes that SMUD’s zero emissions future needs, such as the following (details of each feature are elucidated in Saeedmanesh et al., 2018²):

Massive energy storage potential
Rapid vehicle fueling
Long vehicle range
Heavy vehicle/ship/train payload
Seasonal (long duration) storage potential
Sufficient raw materials on earth
Water naturally recycled in short time on earth
Feedstock for industry heat
Feedstock for industry chemicals (e.g., ammonia)
Pre-cursor for high energy density renewable liquid fuels
Re-use of existing gas infrastructure (for lower cost)

C. Renewable Gas

The NFCRC would like to emphasize the importance of adopting renewable gas policies and projects that have the greatest positive environmental impacts, enabled by the development of the renewable gas market. Fuel cell systems used in commercial, industrial and multi-unit residential buildings today can use these renewable fuels and are only constrained by the availability of the fuels, limiting both the market and the significant GHG, criteria air pollutant and toxic air contaminant emission reductions that can be uniquely achieved by the use of these continuous power fuel cell systems.

The NFCRC fully supports SMUD’s recognition of the significant reductions in upstream short-lived climate pollutants (SLCP) that can result from the capture and use of biogas and biomass. Hydrogen production from biogas (e.g., dairy digester gas) can further reduce SLCP because methane that would otherwise be released into the atmosphere is captured and utilized. This pathway leads to very significant emission reductions, especially in agricultural communities. If solar, wind, or other zero SLCP emitting power generation is used to produce hydrogen for power generation in a fuel cell, then upstream SLCP that would otherwise have been associated with the gas and electric power systems used to produce that same power are eliminated. If the same renewable hydrogen is used as vehicle fuel in fuel cell electric vehicles, then upstream SLCP emissions are reduced that would otherwise have been associated with the petroleum extraction, transport, refining, and end-uses that it displaced. Other pathways by which hydrogen could be used to reduce SLCP emissions are available as well.

D. Microgrids

A modern grid and utility infrastructure incorporates resiliency and microgrids into energy planning and the NFCRC advises SMUD to more strongly include microgrids in the Zero Carbon Plan. When paired with storage, wind, solar, demand response, and other technologies, fuel cell systems can serve as the backbone for microgrids that integrate numerous distributed energy resources and controls. Microgrids that use fuel cell systems as baseload power can immediately disconnect from the grid and island (operate autonomously) from the larger grid when circumstances demand (e.g., grid outage). The fuel cell installation innately operates as an energy management system, with critical loads for backup power already identified and immediately followed in the event of an outage. A fuel cell system can smoothly transition from the grid to fully power the load during a grid outage, without interruption to the end user, and to seamlessly re-connect to the grid when its power is restored. Fuel cells can be, but do not need to be, connected to a storage device to provide these and other resiliency benefits.

Many fuel cell systems are currently powering microgrids, and all these installations are providing clean and resilient power that is increasingly important as climate-caused and planned electric grid disruptions and natural disasters intensify. Alternative community generation microgrids are comprised of non-combustion resources that do not emit criteria pollutants and air toxics like solar, fuel cells, and battery energy storage devices. The increased use of these technologies will allow SMUD to protect ratepayers against extreme weather events and other electric grid outages and reduce the use of diesel generators across the region.

As an example from another jurisdiction, Mass General Brigham (formerly Partners Healthcare) is using fuel cell systems at multiple locations to provide clean, resilient power that provides uninterrupted service for their critical operations. 4.1 MW of fuel cell systems have been installed with the support of the Massachusetts Alternative Portfolio Standard.³

A fuel cell-powered microgrid in the Parkville neighborhood of Hartford, Connecticut provides 100% of electricity for a senior center, elementary school and library; facilities that each can serve as a refuge for residents during emergencies or bad weather. In the event of a major grid outage, the microgrid provides emergency power to the senior center, elementary school and library, as well as to an adjacent supermarket and gas station. Another microgrid with a fuel cell providing baseload and resilient power in Woodbridge, Connecticut supplies power to the grid during regular operation and maintains power during outages for six critical town buildings, including a town hall, a senior center, a public works department, a police department, a fire department, and a library.

Fuel cell systems have additionally been installed as part of the Brooklyn Queens Demand Management Demand Response Program that allows ConEdison to plan for and maintain their infrastructure, while supplying reliable energy during peak periods of high demand in densely populated areas.⁴ The program ultimately avoided nearly $1 billion in ratepayer costs through use of targeted DER installations. One project in Brooklyn, New York uses solar, storage, and fuel cell technologies together in a microgrid of a low-income housing development to optimize the efficiency, reliability, and affordability of the project.

E. Data Centers

Most backup power demands can be met with stationary fuel cell systems because of the small footprint required for the energy conversion equipment and no need for fuel delivery (when fueled by natural gas). Hydrogen fuel that could be supplied via underground former natural gas pipelines is significantly more reliable than the above-ground electric grid. It may be possible, as a result, that pipeline gas delivery could meet the reliability demands of data centers, hospitals, and other end-uses that require high reliability. If the underground delivery of fuel could be proven sufficiently reliable, then on-site fuel storage could also be eliminated for backup power applications, which would require less space (land) compared to diesel generators and diesel fuel storage. In addition, on-site stored diesel fuel has the potential to leak and contaminate soils and groundwater. If the fuel cell systems are built into the site, then they both offset the grid power (and related GHG and criteria air pollutant emissions) and achieve a seamless transition to backup power during grid outages.

Forty (40) data centers in the U.S. are using Bloom Energy fuel cell systems, including at eBay, AT&T, Equinix, Apple, and JP Morgan.⁵ Each component in the Bloom Energy Server architecture is built with native redundancy of the component, which assures 99% uptime.⁶ eBay installed six (6) MW of Bloom Energy fuel cell systems to provide primary, onsite, reliable power matched to the operational requirements of the data center and to meet their sustainability requirements. The system provides 100% of electricity demand while drastically reducing carbon footprint with a redundant, modular architecture. This system architecture replaces large and expensive backup diesel generators and UPS components. During a 2015 grid outage, eBay reported that a utility fault dropped the 138,000V utility grid connection while the fuel cell systems worked flawlessly with no impact to their power supply.⁷

Additionally, Microsoft has been a forerunner in testing and developing plans for renewable hydrogen system replacing diesel generators at data centers.⁸

III. Conclusion

The NFCRC emphasizes the importance of hydrogen, fuel cell systems, and renewable fuels in addressing - first and foremost - short-term and long-term air quality impacts in disproportionately impacted communities. The NFCRC thus encourages SMUD to:

Include fuel cell systems and microgrids in the near-term plan to achieve zero carbon, resiliency, climate, air quality, equity, and infrastructure goals.
Outline actions in the near-term that will allow for large-scale use of hydrogen production and storage by 2030.

Sincerely,
/s/ Jack B.

Dr. Jack B.
Director National Fuel Cell Research Center
University of California, Irvine Irvine, CA 92697-3550

_____________________

¹ DW.com, “Germany and hydrogen — €9 billion to spend as strategy is revealed,” available on-line at: https://www.dw.com/en/germany-and-hydrogen-9-billion-to-spend-as-strategy-is-revealed/a-53719746
² Saeedmanesh, A., Mac Kinnon, M.A., and Brouwer, J., Hydrogen is essential for sustainability, Current Opinion in Electrochemistry, Volume 12, Pages 166-181, December 2018.
³ Burger, Andrew, Partners HealthCare Turns to Fuel Cells to Improve Electric Reliability at its Massachusetts Hospitals, Microgrid Knowledge, March 5, 2019. Available at: https://microgridknowledge.com/fuel-cellshealthcare-bloom-energy/
⁴ Brooklyn Queens Demand Management Demand Response Program Overview, available at: https://www.coned.com/en/business-partners/business-opportunities/brooklyn-queens-demand-managementdemand-response-program
⁵Available at: https://resources.bloomenergy.com/data-centers
⁶ Id.
⁷ Available at: http://casfcc.org/PDF/Fuel_Cells_For_Resilience_And_Decarbonization_In_California_050120.pdf
⁸ Roach, John, “Microsoft tests hydrogen fuel cells for backup power at datacenters”, Microsoft Blog available at: https://blogs.microsoft.com/latino/2020/07/29/microsoft-tests-hydrogen-fuel-cells-for-backup-power-at-datacenters/

April 16 - Grid Alternative North Valley

Thank you to the SMUD team for all the thoughtful work and time that has gone into the 2030 Carbon Zero Plan. We commend SMUD’s goal to eliminate carbon emissions from our power supply by 2030, taking an active lead in the region to transition to a clean energy economy.

GRID Alternatives’ mission is to make the benefits and opportunities of renewable energy accessible to communities on the front lines of economic and environmental injustice. We support the clean energy vision described in the Plan, including solar plus storage, EV access, proven clean technologies, and distributed energy resources. GRID remains ready to partner with SMUD and the community to ensure the clean energy transition is a just transition, one that centers benefits on those in our community most vulnerable to the impacts of climate change.

We applaud SMUD’s demonstrated commitment to community members living with low incomes and the nonprofit service community. We are pleased to have partnered with SMUD to combine the benefits of deep energy efficiency retrofits with no-cost solar technology for income-qualified customers and nonprofit organizations. The partnership not only provides long-term energy burden relief but provides a training opportunity for job seekers in the growing clean energy field. With new technologies being one of SMUD's main four focus areas, GRID is looking forward to supporting the implementation of community-based DER projects expanding the reach of solar and battery storage technologies.

GRID is also looking forward to working with SMUD to increase the adoption of EV incentive programs. From our experience as case managers for the Sacramento Clean Cars 4 All program, we are aware of the interest in EV and familiar with the barriers and concerns for those living with low-incomes in the community. As transportation costs are usually one of the highest household expenses, EV offering would reduce the burden to low-income residents while also cutting local tailpipe emissions.

Equity investments in clean technology adoption have both carbon reduction and localized benefits, as well as far-reaching economic benefits for communities that are traditionally been left out of discussions and decisions about carbon emissions. We are excited to continue working with SMUD to meet these significant 2030 goals. Through an equitable approach to spreading energy access, we can meet the dire need to address climate change while also improving quality of life in the Sacramento region!

April 16 - City of Sacramento

Dear Directors,

We applaud SMUD’s leadership to accelerate the elimination of greenhouse gas emissions from your power portfolio. This leadership is exactly the type of bold accountability and direction that we need to achieve our goal for carbon neutrality.

We also believe it’ is an urgent and necessary step to protect the most vulnerable in our communities, helping us to act comprehensively on climate in a manner that’s equitable and brings benefits to those who need them most. We strongly urge that you approve staff’s recommendation, reaffirming your commitment to mitigate the climate emergency that faces us. The well-being of our community depends on it.

Only by working together can we achieve our goals of carbon neutrality and a resilient, equitable, and livable community. While we at the City can regulate land use and buildings, or lead by example and partnership, like SMUD, we face our own regulatory realities. The City cannot mandate the cleaning up of the grid. The City can’t shift the power sources of the grid, we can only shift how that power gets used in our built environment. Energy use in the built environment comprises 38% of our community emissions in the City of Sacramento. Without SMUD’s clear direction in the 2030 Plan to eliminate fossil fuels from your power mix, the City will be challenged to accelerate the reduction of greenhouse gas emissions we know we need.

This action tonight sets the important platform we need to succeed: by passing this plan, you equip the City to maximize our efforts to decarbonize our built environment.

We wish to prioritize two issues for our collaboration in implementation of this plan:

Firstly, we strongly urge the SMUD Board to revisit its current rules and standards to ensure they provide the flexibility needed for going all-electric in a range of design scenarios. We believe SMUD can provide safety and reliability while reconsidering how its rules apply in our all-electric future. For example, transformer siting and clearance plays a significant role in the viability of dense infill development that City policies incentivize. SMUD rules must support the more efficient use of space, especially for our infill projects. We urge you to take a holistic approach reconsidering current service standards. We look forward to collaborating to ensure SMUD rules amplify City policies and standards, so that new development is equipped to best access the grid.
Secondly, we wish to emphasize the importance of a virtual net energy metering (VNEM) option for our affordable multi-family housing developers, especially as we go all electric. We find it unacceptablethat here in SMUD territory region we do not yet have a zero-net energy affordable housing development, but it is largely attributable to the absence of this basic rate tool. Funding for affordable multi-family projects is limited, despite significant funding commitments by our City Council. The absence of VNEM shaves thin margins from projects and precludes options for going fully electric with available funding. The absence of VNEM further challenges our developers to access highly competitive funding, precluding ongoing cash flow that helps with upfront financing. This puts projects at a disadvantage and can preclude them from ever securing the grants or financing to even getting built. The Board must take swift action to ensure VNEM is available as a resource for our affordable housing developers, equipping them to participate as partners in a renewable, electrified system.

Tonight’s plan is an important step. Not only does the 2030 plan respond to the Climate Emergency Declaration you adopted in July 2020, but it advances the great work initiated by the Mayors’ Commission on Climate Change. As an outcome of nearly two years of the Commission’s work, the City has now established the clear direction to electrify our buildings and vehicle fleet. But only SMUD can ensure that those electric emissions are as clean as possible, as quickly as possible.

We commend the leadership of your Board and staff, including the important leadership of your former CEO, Arlen Orchard, and all the SMUD staff that supported in the Climate Commission process. SMUD has been a key partner, assisting the City in our efforts to advance regulations that ensure new buildings are safe, clean, and free of natural gas. We will continue to work with your team to ensure that we electrify in a manner that is equitable and leaves no community behind. We look forward to continued collaboration and leadership, which is critical for our mutual success.

Tonight, we urge you to continue your important work and amplify SMUD’s commitment to our shared visions. This action will accelerate our ability to achieve the City’s adopted policies including our own Climate Emergency Declaration and our commitment to carbon neutrality by 2045. For more information, please go to cityofsacramento.org/climateaction, or contact the City’s interim lead for our climate action strategies, Jennifer Venema, at 916-808-1859, or jvenema@cityofsacramento.org.

Only by working together can we rise to the challenge we face.

Sincerely, Darrell S., Mayor
City of Sacramento

Jay S., Vice Mayor
City of Sacramento

April 16 - Kevin W.

Golden State Natural Gas Systems supports SMUD's 2030 Carbon Zero Plan. GSNGS represents/consults a consortium of companies for technologies/services as they relate to Climate/Energy/Water mitigation. We believe your vision is attainable.

April 16 - Ted J.

How will modern software help enable this transition? Can SMUD achieve its goals with piecemeal solutions or is a holistic platform needed?

April 16 - Jeanine B.

Thank you SMUD for this comprehensive 2030 Zero Carbon plan. As a SMUD customer I want to extend my support and challenge SMUD to accelerated its timeline for going completely carbon neutral. Please consider developing a plan to close all gas-fired plants in Sacramento Valley by 2026.

April 16 - ECOS

ECOS' Comments on SMUD’s Proposed 2030 Carbon Zero Plan

The Environmental Council of Sacramento (ECOS) supports SMUD’s 2030 Carbon Zero Plan. We note that it depends upon the expansion of new renewables, storage capacity, distributive resources, and emerging technologies. It should serve as a national model for electric utilities. We recognize that the Plan makes optimistic assumptions regarding the development of technologies and carries a level of risk to achieve.

The Plan assumes that 90% of the GHG emission reductions will be possible by 2030 with proven, cost-effective technologies. However, the remaining 10% reduction is unproven, requiring further evaluation in advanced long-duration storage technologies, renewable natural gas and possibly hydrogen as a substitute fuel for peak power generation. We encourage SMUD staff to vigorously pursue alternatives for this critical gap that would yield the least environmental impact.

The Plan also indicates SMUD will be about 90% carbon free with the aggressive adoption of renewables and storage. This greenhouse gas (GHG) emission reduction requires major cost reductions in enabling emerging technologies like storage. The addition of significant utility-scale solar resources must be carefully planned to eliminate negative land use impacts. ECOS is ready to partner to identify both creative and appropriate resource locations. We also support the goal for a vibrant rooftop solar industry and the ability to avoid land-use impacts.

The remaining 10% of GHG reductions will remain in the form of continued thermal gas plant generation to support intermittency, power reserves and peaking requirements; and the Plans calls on fuel switching to eliminate thermal emissions. SMUD will need to consider the use of biofuels to ensure none or only very short-term biogenic emissions are released. CARB’s Low Carbon Fuel Standard (LCFS) modeling tool can be a helpful resource. The use of zero-carbon hydrogen would eliminate this concern. As the Plan progresses, SMUD should consider the need for the remaining gas plants.

The Plan also outlines the need for new demand response and distributed generation resource technologies to get to zero. Partnering and incentivizing individual action will be critical to meeting the goals and should be done with an equity lens. Because this is a high-level plan, it understandably lacks details that will need to be documented in future reports.

We note that Sacramento County’s draft Climate Action Plan (CAP) leans heavily on SMUD’s 2030 goal for emission reductions, anticipating .853 million MTCO2e from SMUD’s transition to clean energy, instead of commitments through the County’s ordinance authority. The County should seize the opportunity to partner with SMUD, who offers generous incentives, to enhance transportation and building electrification requirements. However, Sacramento County should not be so reliant upon the actions of SMUD to meet regional goals - especially since SMUD lacks representation on key local decision-making bodies like the Sacramento Metropolitan Air Quality Management District or Sacramento Area Council of Governments.

Because SMUD’s carbon target relies on optimistic projections for technology development, and associated unpredictable financial factors, we suggest that SMUD management inform County staff that SMUD’s Plan cannot be counted on to provide the GHG emission reduction assumed in the draft CAP and that strong county action can enhance this plan as well as lower overall energy bills for customers, when factoring in fuel switching.

April 15 -Vincent V.

Solar credits on existing and new solar projects are a vital boost to homeowners and a excellent way to make us into energy producers. I would like to see SMUD 's continued support of these credits and make solar possible for the majority of homes in the Sacramento region. Please do not reduce and cancel these energy credits and the rebates for installing solar. EV charging stations should be at every gas station and soon. I see the commercials saying its to much to do but if we are moving to EV we need to support it with EV charging stations like gas stations

April 15 -Vincent V.

April 15 - Dinah W.

Thank you, SMUD, for your leadership in helping get the Sacramento region to carbon zero ASAP through your net-zero plan for 2030. I am a renter, and my landlord, who owns dozens of older, single family homes in Sacramento, needs incentives to electrify her properties. Please consider this scenario in your plan. Thank you for ensuring that low-income homeowners have access to electrification, and please consider all renters and middle class homeowners, too. Incentives for appliances and solar are key.

April 15 - Coalition for Clean Air

SMUD Board Members and Staff:

The Coalition for Clean Air appreciates your commitment to reaching zero carbon by 2030. This is a thoughtful plan, combining a strong commitment to decarbonization with the practical necessity of keeping costs low for customers.

From an air quality and environmental justice perspective, the key commitment in the Plan is the shutdown of two gas-fired power plants and major cutbacks in use of two others, so we urge you to fulfill that commitment on time. These major reductions in burning of natural gas will benefit disadvantaged communities that are burdened with health-damaging smog and soot.

We agree that procuring a diverse portfolio of renewable resources, including solar, wind and geothermal is a smart way to build SMUD’s clean-energy toolbox.

We urge you to proceed cautiously on biofuels, as they vary widely in feedstocks and impacts. SMUD should use life-cycle assessments of the impacts of any proposed biofuels, as the California Air Resources Board does with its pioneering Low Carbon Fuel Standard.

We strongly support you goals for tripling energy efficiency and using demand response, as these will reduce the need for power and will save money.

We agree with your emphasis on transportation electrification, which will reduce the biggest cause of air pollution in the region. We urge you to assure that the benefits of clean mobility reach all Sacramentans, especially those in under-served communities.

We suggest adding a commitment to electrification of lawn and garden equipment; gas-powered engines in leaf-blowers, lawn-mowers, etc., are highly polluting and can now be replaced by zero-emission alternatives, which are also much quieter.

Respectfully,
Bill M.
Policy Director

April 15 - Wesley L.

This is a comprehensive plan to achieve Zero Carbon by 2030! I'm impressed and glad I'm a customer (40+) years. I believe your plan incorporates advance state of the art and practice while looking to technology and policy advances. I especially like the focus on the following: disadvantage communities and customers, education (especially to school age future users and policy makers), and governments as well as private sector. I hope the education program is verbose and age appropriate to help future generations understand how Critical our Climate is to our future quality of life on the planet. Congratulations on your continued leadership.

April 15 - David M.

SMUD was once a leader on rooftop solar but now lags way behind. It's absolutely needed for 100 reasons, even if it costs more now. Please institute a significant subsidy program for generation and batteries for low- and moderate-income homeowners and landlords, perhaps penalties for large landowners who don't do it. And don't penalize folks for installing it!

April 15 - Dan S.

I’m writing in support of the draft 2030 Carbon Zero Plan. SMUD is showing true leadership with this effort and addressing the health and safety needs of the public. I would like to see the final plan include details on phasing out and closing gas-powered plants including earlier retirement for the Campbell plant. Also include details on co-generation conversion. Please provide more detail on the future role of renewable natural gas. More research is needed on the use of alternative tech for storage requirements. Annual reports on GHG production and reduction need to be detailed and comprehensive. Document avoided costs and savings too. Include support for more electrification programs and pilots. Community solar is important and needs to be supported and included in the final plan. This includes rooftop solar. As a longtime resident of Sacramento County and a SMUD customer I strongly support the direction shown in the 2030 Carbon Zero plan. My family, including children and grandchildren, also live here and this plan will help protect their future.

April 15 - Rick C., Rosie Y. and Oscar B. 350 Sacramento

Comments on SMUD’s Proposed 2030 Carbon Zero Plan, April 2021

We at 350 Sacramento and the undersigned signatories are excited to support SMUD’s 2030 Carbon Zero Plan’s expansion of new renewables, storage capacity, distributive resources, and emerging technologies. The Plan represents a monumental effort for SMUD and an inspiring example for the electric utility industry nationally. It is also particularly well-timed with the expected availability of new funds for energy and climate projects under the new Biden administration.

We are especially pleased that the Plan is truly carbon zero, unlike the Integrated Resource Plan (IRP) – approved only two years ago -- which subtracts SMUD-supported community electrification from actual power plant emissions to achieve “net zero” by 2040. This Plan in fact resembles the IRP scenario supported by 350 that reduced emissions by 90% leaving the remaining 10% as continued gas plant generation to support intermittency, power reserves and peak requirements. In this case, the Carbon Zero Plan meets 90% of emission reduction with existing technologies and assumes that the last 10% will be met with technologies that will emerge as proven and cost effective by the end of the decade. We wholeheartedly applaud this laudably optimistic approach.

Staff has done an impressive job assembling the Plan with the aid of its consultants. It provides a comprehensive though still high-level guide which lacks many details that should be documented in future more in-depth reports. We see opportunities for further research and future reporting in the following areas:

1. The ramping down and retirement of SMUD’s thermal plants,

2. The role of future biogas and digester fuels and their carbon accounting,

3. Study of alternative storage technologies,

4. More detailed better greenhouse gas (GHG) reporting,

5-6. Support for electrification and thermal storage projects,

7. Explicit support for Virtual Net Metering and community solar.

1. Develop a detailed plan to wind down and close the gas-fired power plants.

The proposed SMUD Plan provides a timeline for retiring two of its plants in 2024-25 (Campbell and McClellan), converting the remaining cogeneration plants to low-use simple cycle operation and repurposing them and Cosumnes to renewable natural gas (RNG) in ten years. This will require a major review of its current operational budget projections to assure that upgrade funds are not invested in plants that will cease or greatly curtail operation over the decade.

The issue is not trivial: as indicated in the table below, currently SMUD intends to spend more than $87 million over the next five years in major equipment and capital costs on these plants.

chart

SMUD must ensure that these projected costs will not become stranded assets. For example, SMUD plans major overhauls after 50,000 hours of operations which will occur in 2021 for Procter & Gamble, 2022 at Campbell and 2025 at Carson Ice (as noted in the table’s shaded boxes). These power plants currently have capacity factors of between 40% - 60% capacity, but even these hours of operation will drop significantly on their way to zero in 2040. This means investments in the near term, if amortized over the next 50,000 hours of operation, will not be paid off until 2040 or later – ten years after the plants could be shuttered. Clearly, SMUD should be seriously considering deferring or foregoing some or all those costs which can be directed to renewable investments.

Detail cogeneration conversion plan. Staff should prepare detailed reports on the retiring and conversion of the cogeneration plants including how the Procter and Gamble and Carson Ice contracts can be unwound and potentially converted to peaking plants earlier than projected.

Study earlier retirement for Campbell. The report should also consider the earlier retirement of the Campbell plant than the proposed Plan’s 2025 date. This plant has no steam host, produces N0x and other pollutants in an impacted low-income community and costs SMUD more than $800,000 in operational maintenance and an expected $7.8 million in scheduled overhaul costs in 2022. Closing this plant earlier will send an important signal of SMUD’s commitment.

2. Explain more fully the future role of Renewable Natural Gas

The Plan relies on the continued operation of Cosumnes as a combined cycle plant to provide flexible support for back-up and regulation. This choice makes sense for several reasons. The plant is among the most efficient in the state and unlike the cogeneration plants, which have retired their underlying bonds, Cosumnes retains bonded indebtedness through 2030. However, Cosumnes contributes 65% - 70% of total power generation and GHG emissions, making its transformation to zero carbon in this Plan incredibly important.

Detail all new sources for RNG. To avoid greenhouse gas (GHG) emissions, the Plan will convert Cosumnes and the remaining cogeneration peaking plants to renewable natural gas (RNG). SMUD currently relies on biogas from landfill, dairy, and wastewater treatment as well as from biomass contracts. But, as indicated in the following table, SMUD expects these sources will contract in the coming years. Also threatened is SMUD’s supply of digester gas from the Regional County Sanitation District (Regional San), which is seeking to install its own cogeneration plant before SMUD’s contract expires in 2025.

chart

Develop a comprehensive carbon accounting for RNG. The Plan explores options on how to supplement these sources in the coming critical decade including biogas derived from the wood waste harvested from fire mitigation in the forest lands surrounding UARP’s hydroelectric plants. The Plan also introduces the exciting prospect of hydrogen and the potential for RNG local storage to provide flexible fuel availability. Burning hydrogen does not create carbon dioxide but the biogenic fuels do, a point that is countered by otherwise avoided GHG. SMUD should provide a complete carbon accounting of these fuel sources.

3. Produce Studies on Alternative Technologies to Meet Peak Storage

The Plan relies heavily on 4-hour and other short duration batteries to provide backup support during peak and overcast periods when renewable output is unavailable or diminished. However, the Plan dismisses two other promising technologies that could augment this needed storage:

Pumped storage at existing SMUD hydroelectric facilities, and
Concentrating solar collectors with molten salt storage capability.

While these options do not meet the sought-after gold standard criteria for multi-day day storage, they could provide a valuable alternative to sole reliance on batteries for intra-day (6-24 hour) daily storage and should be studied more extensively. Though more costly than renewables on their own, these alternatives may prove to be cost competitive with solar + storage. They may also be good candidates for federal funding.

4. Prepare More Detailed Annual Reports on Greenhouse Gas (GHG)

Detail GHG reporting by source. Currently SMUD publishes an annual Sustainability Report which does record SMUD’s estimate of its current GHG total, but otherwise is inadequate for fully measuring future progress of the Zero Carbon Plan going forward. For one, the emissions should be documented for each power source, including purchases, as indicated in the following graph.

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Determine more useful GHG metric. Secondly, the report should include pounds per unit of electric use as a comparative metric for GHG. The Climate Registry uses pounds per MWH for wholesale and retail sales to compare across utilities. More useful locally would be reported pounds per kWh, which can be used by customers to help determine their household carbon impact, as well as to determine savings from electrification and electric vehicle use. The following table provides an example of the calculation of this metric.

chart

Sources: SMUD Sustainability and Annual Reports

Detail GHG reporting assumptions. Thirdly, the report should document its calculation and adjustments and how SMUD emissions may vary from those reported by other agencies such as the Air Resources Board and the Climate Registry. It should present which components are included, which are not and the rationale for the omissions. The report should also clarify the following emission components:

How it normalizes hydroelectric and wind power generation,
What the net GHG emission savings are from combusting its biogenic fuels – digester gas and biogas – after subtracting out the potential emissions from direct methane release,
Estimates of the emission savings from providing cogeneration-powered steam to replace natural gas boiler use at the Carson Ice and Procter & Gamble plants,
How much GHG is associated with sale of power to agencies outside SMUD.

5. Support Electrification Projects and Pilots

SMUD’s 2019 IRP launched a $1.7 billion campaign to assist financially in building and vehicle electrification through 2040. This commitment has led to the most generous targeted electrification incentives in the country. We have also been pleased with the pro-active involvement of key SMUD staff in the development of electrification ordinances and other actions with the city, county, and air quality management district.

Address grid barriers. These efforts should be accompanied by SMUD analysis at the distribution system level to identify and address any capacity bottlenecks to vehicle or building electrification due to undersized transformers or feeder lines. Our fear is that expenses associated with replacing poles on private lots and connecting to buried electrical line would be passed on directly to building owners. This creates a severe disincentive to electrification and may create areas of stranded customers paying higher gas rates on an attenuated gas system.

Document GHG savings. SMUD is also in the best position to document and report on the expected greenhouse gas savings within its territory for the transition from gasoline and diesel to electric vehicles and from natural gas to electric end-uses such as space and water heating and cooking.

6. What About Thermal Storage?

In the 1980’s, at the height of SMUD’s customer demand programs, it invested in large-scale thermal storage cooling projects in commercial buildings and in unique storage equipment in residential homes (the short-lived Phoenix systems). It even dedicated time-based special rates for thermal storage in an era before universal Time-of-Day. We believe it is again time to focus on the potential for customer-sited thermal storage.

Significantly, the Plan’s Virtual Power Plant does include dispatchable thermal storage from new heat pump water heaters, but it does not specifically discuss large-scale new and retrofit heat pump-based thermal storage commercial projects, such as the one serving the SMUD campus. These projects, which can be launched as pilots, will provide dual benefits by removing natural gas and related emissions, while providing control of peak power. A bold move would be to invest in thermal storage projects in the upcoming Railyard developments, including such intensively used buildings as the planned Kaiser hospital and the new Courthouse.

7. Support True Community Solar

In conjunction with the current Title 24 building code cycle, SMUD received CEC approval in early 2020 for its Neighborhood Solar Shares option for new building construction. This allows contractual replacement of on-site photovoltaic placement with remote solar generation by SMUD to meet the new code requirements. This program involves integrating resident meter usage data with apportioned solar output to apply a monthly credit.

VNEM supports low-income housing. This accounting and crediting approach to solar generation allocation is the basis for Virtual Net Energy Metering or VNEM, which is used throughout the state and elsewhere, though not yet at SMUD. VNEM allows builders of multi-family buildings to locate solar panels at a central location on-site and have the resulting credits allocated fairly among the residents. It is particularly useful for low-income multi-family housing developments.

VNEM for community solar. The Plan supports Virtual Power Plants (VPP) with a focus on low-income community. This should include VNEM as a useful tool to facilitate distributed neighborhood solar production including stand-alone community solar project by non-profit developers. In this case, the solar credits can be assigned to neighboring low-income renters.

Highlight the Advantages of Rooftop Solar. The Plan expects that rooftop solar will contribute 250 – 500 MW of generation by 2030. It also proposes to partner with those customers who install both solar and battery storage as Virtual Power Plants, presumably under new NEM-2 successor rate arrangements. However, the Plan fails to properly acknowledge the value of rooftop solar to SMUD including the following points:

The customer financial contribution, aided by tax credits,
Rooftop PV provides local real estate availability that will become more highly prized as suitable sites become scarcer for utility-scale solar farms, and
Finally, customer solar provides a positive distributive effect on the grid.

This point is well- illustrated in Figure 11 of the Technical Report, where the geographically distributed Feed-In Tariff PV installations, cumulatively provide better intermittency grid coverage on cloudy days compared to a centralized PV plant such as at Rancho Seco. Similarly, the totality of rooftop solar provides useful output diversity to SMUD not only by its scattered distribution throughout the District, but also its variable orientations.

April 15 - Molly R.

Accelerate carbon zero faster! We need to be leaders as the capital of California, and others will follow. Let's not fall behind in making the right decisions.

April 15 - Laurie L.

Pushing for your team to leverage the grant opporunities, local community on your decisions forward and to prioritize decommissioning old infrastructure. Thank you!

April 15 - Dale S.

April 15 - Ezra R.

I would like to extend my support for SMUD's 2030 Carbon Zero Plan, and encourage an accelerated timeline for going completely carbon neutral. Please continue to invest and expand your renewable energy sources. As a SMUD customer, I am impressed with your work so far and ask that you please continue to improve your 2030 plan. Please consider these recommendations:

- Develop a detailed plan to close all gas-fired power plants throughout the Sacramento Valley in the next 5 years.
- Continue to support electrification through grants and incentives to move away from natural gas use in buildings and homes. Increase incentives for Electric Vehicle (EV) charging networks and home chargers. Incentivize retrofits to all-electric homes to make it affordable for low-income residents.
-Limit or slowly phase-out Renewable Natural Gas (RNG). Develop comprehensive carbon accounting for RNG, and only use it sparingly.
- Use alternative technologies, such as batteries, to meet Peak Demand with power storage.
- Prepare detailed Annual Reports on Greenhouse Gas (GHG) usage. Report each GHG by source, and decrease % of use each year.
- Support and incentivize Virtual Net Energy Metering (VNEM) to encourage use at low-income or workforce homes. Increase rebates and incentives for installation of rooftop solar and grid-tied systems

April 15 - Austin A.

I know SMUD has said it needs to up the cost to users with rooftop solar since they are displacing their use, and causing those without rooftop to pay more (According to SMUD). Can this be addressed in this plan. How will SMUD incentivize rooftop solar and home battery storage (fixed and EV)? I want to get solar on my roof, but with all the news that SMUD will cut its net metering rates even lower yet, having rooftop solar does not make sense. Can SMUD separate solar and battery? Can smud offer a program where users who have a battery on the grid can get better rates for adding power into the grid at peak times and then pulling power back in at low demand times? SMUD needs to be less hostile to those who are going to get solar on their rooftops. If the fixed grid infrastructure is too low, then raise it. Don't raise the per KWH fee.

Also, I applaud SMUDS efforts to have homes go all-electric to reduce greenhouse gasses, but will SMUD be bringing more new clean power online at a fast enough rate to still decommission old plants, and take on the new load of all electric homes? It makes sense for SMUD to encourage electrification of appliances that can Load shape, or run at off hours (Heat Pump/Pre Cool, Water Heater, Cloths Dryer(heat pump) (with auto timer) etc. Encouraging users to get electric induction ranges makes less sense, because those have huge peak loads at peak hours of the day. Thanks

April 14 -Harold T.

The proposed 2030 Goal of reaching zero carbon is significant and important in our efforts to slow global warming.

The SMUD staff and Board are to be encouraged in working to manage the existential threat of climate change due to excessive emissions of GHG’s. My comments beyond those in this document, adopt by reference the consistent observations and detailed comments of Rick Codina, a utility expert who has commented on the 2030 Plan

Generally- This plan is a vast improvement from the 2018 IRP which I and others commented upon is several open meetings. However, it is clear that SMUD staff continues to see roof top and community owned solar as a threat to the rate base. Thus, the report seeks to enlarge economic contributions from “utility scale” solar electric and storage and lessen the fiscal and policy incentives for customer owned electric power. While one can agree that utility owned storage has both safety and efficiency benefits leading to such major public works as battery farms and pumped storage, roof top customer owned and community developed solar is the lowest environmental cost in both direct and indirect costs. Cost that must include capital, operational, and carbon footprint. Why should SMUD finance its improvements in the national capital markets when its own citizens are willing to pay the tariff for clean electric power on their roofs.

Specific Comments

Biomass RNG and Biogas- P 81-- 290-900 MW of power supply

While RNG and Biogas are appropriate fuels to collect and burn for electric power, biomass combustion is highly limited due to poor quality and contaminated wood fuels found fueling existing Central Valley biomass generators. Forest wood is increasing used for agricultural compost and landscaping purposes leaving limited clean fuel forest resources. The plan needs to specifically project how much power is to be derived from Biomass compared to bio-gas and RNG.

As one of the lead litigators in a five county District Attorney investigation team reviewing the Covanta Corporation burning and disposal of contaminated fuels, we learned many facts not acknowledged by regulatory authorities. First, municipal wood waste, a major biomass fuel source, was consistently contaminated with various metals and plastics. Second, dioxin was a frequent waste combustion by-product and found in power plant ash sent to compost and dairy facilities. SMUD runs the risk of superfund exposure as a user of power from contaminated fuels.

New Hydro Resources- p 84 --Pumped storage from existing reservoirs

While the plan dismisses this option, (In our experience, new hydro resources, including pumped hydro, are not likely to be built in California due to the cost, permitting challenges and environmental concerns.), SMUD should revisit this option in light of a revised cost benefit analysis. Specifically, the competing costs of nominally less directly expensive power, is a false accounting when SMUD includes external environmental costs (both carbon footprint and external costs) of alternative power supplies.

In fact, wind from Wyoming and Nevada requires new or expanded right of ways over or through the Sierras. Solar electric purchased from “other balancing authority areas” (22,800 MW in the plan) does not include the external environmental costs to desert tortoise and San Joaquin Kit fox endangered habitats. To fairly compare power supply from pump storage, including its local environmental cost, to Southern California vendors, one must include both the carbon footprint and the externalized environmental cost of the Southern California “other balancing authorities” power.

Roof-Top and Community Solar -p 85

While the plan states roof top and community solar is economically infeasible (Rooftop solar was also considered as a proven clean technology. Capital costs to build or install these resources exceed three times the price of utility solar), this analysis fails to calculate the capital contribution of the roof top panel owner. The 2030 plan should be revised to show an accurate cost per watt given customer capital contributions. Second, the cost analysis should be revised to reflect the lower carbon footprint of installing panels on an existing roof or parking lot. When an honest comprehensive accounting of costs is made, the conversion of agricultural lands and loss of wildlife habitat while not immediately borne by the utility are costs pushed on the public fisc and add significantly to the carbon footprint of the “utility scale” options. The plan needs to have a revised, more complete, and more honest cost and carbon foot print accounting prior to making decisions lest the final policy decisions are based on false cost comparisons.

April 14 - Rosie Y.

Really glad to see SMUD going out on a limb to get to carbon zero by 2030, and I am very supportive of this measure. This feels like real leadership in our community for the world. But having SMUD fossil free is not the same as having all of its customers fossil free without electrification. In working on retrofits SMUD should, and is, prioritizing disadvantaged communities. SMUD’s goal currently is to have 100% of the EAPR customers electrified by 2040 and the rest of the market by 2045. However, this does not cover the many renters and middle income people for whom electrification will be a daunting task. SMUD needs to commit resources, search for partnerships, federal support, and any other mechanisms to support conversion of these buildings in ways that keep rents stable. In terms of infrastructure upgrades, it is not just the big infrastructure that needs attention but also some of the other barriers to people being able to install EV chargers, solar, heat pump technology—things like buried lines, undersized transformers, and aging power poles on private lots. Some of these upgrades historically have fallen on the parcel owners, but in order to effect the larger goals of including microgrids and electrification, that cannot continue--SMUD needs to invest in infrastructure at all levels. Also, SMUD should be looking very soon at ensuring that people can train and get jobs in building energy evaluation, panel upgrades, heat pump installation, battery and EV charger installation. Consider forming partnerships to extend existing programs at community colleges to include classes to learn the skills that will be needed in the community to get this work done; and consider how to get low income ratepayers aware of opportunities to get training.

April 14 - Sierra D.

I love this. So cool. Maybe you could partner with local businesses/government to put solar panels out on their property to help reach that goal. Love SMUD, the best thing about Sacramento county- you guys rock.

April 14 - Debra L.

Please vote for zero carbon plan 2030 and encourage residential solar in our SMUD district.

April 14 - Jeffrey

SMUD's analysis shows that EV charging load will grow by 55x between 2021 and 2030 (from 16 GWh to nearly 900 GWh). It is critical that EV charging -- which will likely be the single largest (and perhaps most flexible) load in a household -- be dynamically grid-responsive and integrated in such a way that maximizes use of renewable energy. SMUD should support interoperable and standardized charging technologies to ensure that EV charging is automatically aligned with the lowest rates or cleanest times of day, and that EV charging can be automatically and flexibly managed to respond to grid emergencies, such as what we witnessed late last summer.

Partnerships with individual automakers may be useful, but a truly brand-agnostic and standardized solution is needed to ensure that all customers -- regardless of the EV model they drive -- can enjoy the benefits of vehicle electrification and ensure that they are integrating charging load in a grid friendly manner. Smart chargers, such as those supporting networking and ISO 15118 to communicate energy needs with vehicles, offer rich opportunities to help integrate EV charging.

April 13 - Luis A. & Barbara L.

President Bui-Thompson and Board of Directors
Sacramento Municipal Utility District
6301 S Street Sacramento, California 95817

Submitted via electronic mail

RE: Sierra Club’s Comments on 2030 Zero Carbon Plan

The Sierra Club appreciates the opportunity to comment on the draft 2030 Zero Carbon Plan, and for being able to participate in the stakeholder meetings facilitated by the Sacramento Municipal Utility District (“SMUD”) and the Smart Electric Power Alliance (“SEPA”).

We support SMUD’s adoption of a Climate Emergency Declaration and the efforts being undertaken to address this pressing situation resulting in the development of this plan. However, we find that the zero-carbon plan as currently prepared does not achieve what its name suggests. Below, we provide the following comments outlining our various concerns with the plan.

I. ELECTRIFICATION

The Sierra Club agrees that electrification is a win-win that will “improve air quality and community health with greatest impacts felt in communities disproportionately impacted by poor air quality”. We also support the deployment of clean energy technology in under-resourced communities and to prioritize community engagement and education on these matters.

The SMUD plan also states that electrification would “help maintain affordable rates and lower overall household energy bills”, a statement supported by a recent California Public Utilities Commission white paper concluding that electrification can save customers over $100 per month in overall energy bills in 2030, countering rising electricity rates. However, SMUD fails to acknowledge that electrification would unlock additional revenue streams for the utility that would help maintain affordable rates as it seeks to make major investments in its power system to achieve a zero-carbon future.

Moreover, SMUD claims that, through its plan, it would accelerate its goals of 100% electrification in transportation and buildings by 2045 to comply with SB 100. Achieving a policy outcome by the most distant date under California law is not acceleration. Additionally, the Climate Emergency Declaration by SMUD reiterates it’s 2018 goal which sets a date of 2040 for net-zero emissions: “SMUD’s Board of Directors adopted SMUD’s 2040 Energy Plan, which serves as an ambitious roadmap for how SMUD will achieve net-zero GHG emissions by 2040.”

II. DEMAND-SIDE RESOURCES

We support SMUD’s prioritization on a Flex Alert, which would be similar to California’s Flex Alert in which conservation is urged to ensure reliability. Last year when the state experienced rolling blackouts, energy conservation played a significant role in avoiding rolling blackouts on specific days and times during the extreme heat wave. Similarly, demand response programs played a key role in maintaining reliability, particularly when Governor Newsom worked with state agencies to reduce the demand of large energy users, such as industrial and commercial customers.

However, the plan only envisions a low potential of 230 megawatts (“MW”) of demand response by 2030, and gives low priority to behind-the-meter (“BTM”) resources. SMUD’s plan then focuses on assessing pilot programs and completing more studies on these resources. SMUD must do more - demand-side resources are not new. The best way to educate customers is to have fully fleshed out programs that make the case to customers that participating in technologies like smart thermostats, electric vehicles, and heat pumps will lower their electricity bills.

Furthermore, demand-side resources, which includes energy efficiency, can play a key role not only in keeping the lights on, but also enhancing local resiliency, reducing energy bills, and avoiding the over procurement of utility-scale generation that is difficult to site while protecting critical natural resources. SMUD must prioritize the deployment of demand-side resources, and clean technologies that are placed in the built environment, such as BTM resources.

III. REPURPOSING OF NATURAL GAS GENERATION

We applaud SMUD for moving toward retiring the McClellan and Campbell’s sites, yet we question SMUD’s move to retain the majority of its gas-fired power plants and reconfiguring them to burn biofuels. By retaining some amount of gas or even using biofuels, a limited and expensive resource, SMUD’s plan is not zero-carbon.

SMUD has failed to show how it is maximizing its use of renewable energy, grid upgrades, and load shifting technologies before coming to the conclusion that it needs some type of resource that could serve as peaking capacity. In Los Angeles, Sierra Club has found that the need to retain some type of flexible and combustible resource is necessary in the last mile of the renewable energy transition (from 90% to 100%), and the city is utilizing renewable hydrogen, which is a zero-carbon resource unlike biofuels.

Therefore, we recommend SMUD go back to the drawing board and conduct a reliability assessment with the end goal is the retirement of all of its power plants. Should SMUD need to reconfigure any of its power plants in order to utilize them as a peaking resource in the last 10%, it should do so with renewable hydrogen. Sierra Club would like to see the details of SMUDs transition from where it is now to 90% clean energy, maximizing its investments in clean resources before resorting to reconfiguring its power plants.

IV. EMERGING TECHNOLOGIES

Finally, Sierra Club recommends the inclusion of other emerging technologies; for example, one that is currently being utilized by Portland General Electric is being used in Portland, Oregon, or similar systems as used in Hawaii, Nova Scotia, and Utah. These cities installed electricity-generating turbines in water pipes, and the one in Oregon is currently generating an average of 1,100 megawatt-hours of electricity annually. While the amount is minimal, it would serve as a critical local resource that utilizes existing infrastructure.

We would also like to state our strong opposition to carbon capture technologies and again biofuels. Studies and practical experiences show that we can achieve a 90% renewable grid with a combination of solar, wind, and storage. To get from 90% to 100%, as previously noted, we would rather see the use of renewable hydrogen. We do not want to see wasted time and resources on technologies that keep us hooked on fossil fuels like carbon capture and biofuels when there are clean alternatives that are proven to work.

V. CONCLUSION

At this time, we do not fully support the currently drafted version of SMUD’s plan. Without substantial changes, this cannot be called a zero-carbon plan.

Thank you again for the opportunity to comment, and we look forward to working with you on making improvements to the plan as described above.

Sincerely,

Luis A.
Senior Campaign Representative
My Generation Campaign

Barbara L.
Chair, Sacramento Group
Motherlode Chapter

cc: General Manager, Sacramento Municipal Utility District

April 13 - Brian K.

Please invest in energy that is reliable even when sunlight and wind are not plentiful. I resent being manipulated with time of day rates to reduce usage due to inefficient energy production, and blackouts. Carbon is necessary. Isn't it good for vegetation!? Regardless, nuclear and hydro are the only carbon-free energy sources proven to have potential to meet demand at a bearable price. Please take us forward instead of backward in energy production. Otherwise, we must use highly dependable gasoline-powered generators during blackouts because you prefer arcane energy sources. Your plan sounds fine on paper but it is simplistic and misleading. The resources required to build and maintain solar and wind production shows they are extremely expensive relative to capacity, carry high environmental costs, and are the least productive methods available. You already ask us to reduce usage to meet your production, rather than strengthening your production to meet demand. This plan will complete your betrayal of customers for political kudos. It will result in substantially higher tiered rates and growing production shortfalls. Please do change production methods when an alternative is more reliable and less expensive, i.e. objectively better. Current solar and wind technology make them the econcomically worst choices. As a monopoly, you owe the community the most dependable energy at the best possible price. We deserve a competent provider with these priorities.

April 13 - Ronnie Jeanne A.

I'm very impressed with SMUD making bold plans and offering help to those of us who want to do something about climate change and save life on the planet. I came to Sacramento in 1970 and bought some windows to have dual pane windows and wanted to set up grey water for the grass. I wanted to buy an electric car since they have been on the market but have been waiting to get solar electricity first. I don't qualify on tax reduction, but hoping to do this for my grandchildren. You are making it closer to a possibility for me.

April 13 - Ramona L.

Will there be incentives to encourage investing in communities of low wealth. These communities, have been historically limited by economic barriers, will this bring jobs and lower energy costs to consumers in those areas?

April 12 - Alan S.

ENHANCING SMUD's NETZERO CARBON PLAN:
Three Major Benefits via One Technology Solution

What is the value to SMUD and all of its stakeholders if the NetZero Carbon Plan can cost-effectively include up to three additional Greenhouse Gas Emissions reduction-support initiatives...thereby accelerating program success?
a) Perennial, Inherent Intra-grid Energy Loss Reduction (lessening energy
inefficiencies)
b) Safe Electric Vehicle Adoption; Avoid Otherwise-imminent Reliability Risk
and Associated Cost Increases
c) Reduced Fire/Wildfire Greenhouse Gas Emissions and Related
Costs/Damage/Liabilities

1. Per the US Energy Information Administration, SMUD experienced approximately 431.01 Million kilowatt hours (kWh) of Unmetered “intra-grid” Energy Loss in 2019 alone. That represents both technical and non-technical Loss occurring (annually) in front of the meter.

If the average SMUD customer uses 1000 kWh/month, this ongoing recorded annual Loss represents enough energy to service approximately 36,000 SMUD customer homes - per year.

Realizing that Energy Efficiency is huge to the success of the NetZero Carbon Plan, cost-effective technology now exists to proactively identify this recurring Intra-grid Energy Loss (e.g., over-energized circuit feeders, antiquated asset sizing, power theft, improper tap settings, etc).

If only 50% of SMUD’s annual Intra-grid Energy Loss is identified/remediated, upwards of 18,000 customer homes can be powered annually via these energy savings; MERELY by creating Intra-grid Energy Efficiency. This type of Intra-grid Energy Efficiency will decrease generation burden concerning the NetZero Carbon Plan (i.e., savings achieved via efficiency results in less generation demand to otherwise offset the perennial Energy Inefficiency Loss).

Assuming a 50% reduction of SMUD’s annual intra-grid Energy Loss, an estimated ROI from the use of such technology would be approximately 5-6 years. Thus creating savings of an estimated 215.5 Million kWh PER YEAR for SMUD customers, or 2.6+ Trillion kWh of energy savings throughout the anticipated technology lifespan (aka, powering 18,000 homes annually for 12+ years of service, simply via achieving improved Intra-grid Energy Efficiency). As mentioned above, this will aid to lessen the NetZero Carbon Plan generation demands, and facilitate faster NetZero Carbon goals achievement.

2. Reduction of Greenhouse Gas emissions is paramount. Adoption of Electric Vehicles (EV) is important to the NetZero Carbon Plan, but the unplanned grid-edge load/overload created by increased EV adoption will be problematic to SMUD’s historically excellent Reliability performance. Each residential EV charging station will add unplanned load equivalency of 1 to 2.5 homes onto each respective transformer. Two EV owners using the same upstream transformer for EV charging will create 2 to 5 homes of unplanned load/overload on the respective transformer. Therefore, SMUD’s undeniably aging transformer fleet (deployed decades ago) will be directly burdened and at risk of asset failure given this forthcoming increased or excessive load/overload due to expanded EV adoption.

Because EVs are commonly charged in the evening/night hours, necessary transformer cool-down periods will be lessened. The unplanned load/overload burden caused by expanded EV adoption will accelerate End-Of-Life (EOL) for SMUD’s transformer assets; creating outages, possible asset fires, and possible wildfires. While EVs will help to offset GHG emissions, they will present a genuine load/overload/Reliability challenge. Without proactive intra-grid visibility, SMUD will not know where, when, or how much unplanned EV load impact is striking its aged distribution transformer fleet until a trouble-call is reported, and/or a power outage (or worse) occurs. This otherwise imminent Reliability and Liability risk is no longer necessary given technology gains.

By applying today’s time-proven/field-proven Intra-grid Sensor technology, SMUD can now achieve empirical data visibility into its transformer fleet; which is not reliably achievable via Advanced Meter Infrastructure. Using Automated Alert features, this technology will enable SMUD to proactively monitor its transformer fleet; noting where, when and how much unplanned EV charging station demand is creating load/overload which will otherwise be posturing the respective transformer assets to experience accelerated EOL resulting in outages, plus associated cost and risk impacts.

Proactive monitoring of transformer assets will enable the Prevention of outages/fires/wildfires. Empirical data will facilitate necessary awareness, and strategic planned intervention by SMUD; avoiding undesirable Reliability and Liability outcomes and costs for its customers, and all stakeholders.

3. Greenhouse Gas (GHG) Emissions are not solely associated with Energy Generation, and fossil fuel powered vehicles. As has been documented by wildfire instances in California, massive GHG emissions are an unwelcomed byproduct of these now-perennial disasters. The November 2018 Paradise California fire spewed an estimated 1.3 Million Metric Tons of GHG into the atmosphere. The California wildfires of 2020 spewed an estimated 112+ Metric Tons of GHG (e.g., approximately 1.6X the total GHG emitted by California’s 15+ Million auto fleet). Wildfires alone could reduce or even offset the intended gains of the ambitious NetZero Carbon initiative.

Preventing, and Early Detecting of fires/wildfires is imperative with regard to reducing harmful GHG emissions. Auto Alerts and Situational Awareness are imperative to facilitating public safety, reduced environmental damage, reduced local economic damage, and reduced utility liability risk; in addition to lessening wildfire GHG impact. Existing and Emerging Technology can leverage SMUD’s existing overhead transformer fleets to simultaneously achieve fire/wildfire Prevention, Early Detection, Auto Alerts, and Situational Awareness.

If the NetZero Carbon Plan aims to rid SMUD of its serious air quality problems, then we cannot allow fire/wildfire GHG emissions to offset much (or all) of our valiant efforts to be implemented via this worthwhile NetZero Carbon program. Yet, just one bad fire/wildfire season has the ability to create approximately 1.6X as much GHG emissions as the entire fleet of autos that we aspire to convert to EVs, as noted above for California in 2020.

Fire/wildfire mitigation is mandatory to truly achieve NetZero Carbon benefits within SMUD’s service area, while also improving public safety, environmental protections, local economy preservation, reduced liability risk, etc.

All three of the aforementioned value propositions are simultaneously achievable via the implementation of One, Cost-Effective, Multi-Beneficial Technology.

Today’s foresight by SMUD’s leadership to embrace game-changing technology will deliver critical improvements, advancements, protections, and financial gains for ALL stakeholders.

Why not embrace cost-effective Intra-grid Sensor technology now to further enhance the value and intended success of the NetZero Carbon Plan?

April 11 - Anonymous

As a customer, while I care about environmental benefits, rates and reliability are definitely more important factors. I hope SMUD can keep the rates low and maintain reliability while promoting cleaner energy. Too aggressive is not will more harm than good. SMUD should also carefully scrutinize those postive comments and the feedback to see if they are truly from customers rather than vendors or people who have business interests in this initiative.

April 9 - Laurie H.

I look forward to your community outreach and education. We all have a lot to learn. I hope you scale workshops to different levels of understanding and target specific communities (including youth!) to be sure you reach representatives from the entire population.

April 7 - John W.

Read the plan, makes one feel good, but will do nothing to reduce global CO2 emissions to reduce global warming. SMUD's renewable energy mix is already low CO2 emission and renewable, anything SMUD does will just clean up around the edges. The gross polluters are not changed, their emissions will continue to rise in the foreseeable years. Point is fact, using less natural gas will just encourage LNG export to: China, India, Japan, South and North Korea, Taiwan, Singapore, resulting in small CO2 reduction, high prices and lower reliability for your PRIMARY customers: us. I will remember who approves this plan.

April 7 - Brenda D.

I am SO excited for this plan and 100% support it. I believe it is time for the general public to open their eyes to how much we are affecting the environment. If other companies follow SMUD's lead and begin to adopt clean forms of energy we will set the right path for generations to come. YES SMUD!! CLEAN ENERGY 2030!!

April 7 - Eric P.

Go SMUD Go! Whatever it takes… This reminds me of voting to close Rancho Seco.

April 3 - Mika J.

Go talk to Professor Ian Plimer. Zero Carbon is not good. We actually need Carbon. Does anyone actually understand this?

April 2 - Andy F.

We appreciate SMUD's reaching out to the community throughout this process. Very impressed SMUD once again 'walks their talk.' Closing high-emissions plants in near future to really make a clean and climate-friendly future is visionary / amazing. Working for a nonprofit supporting people with developmental disabilities, I thank you for keeping in mind lower income families and neighborhoods, and for supporting plans to assist people with disabilities to afford often-higher-energy use due to health device needs.

March 31 - Rick C.

Thank you for extending the comment period for the Zero Carbon Plan to April 16th, providing many of us more time to offer more detailed remarks. My initial reaction is acknowledgement of this impressive effort, very thoughtful, thorough and reliant on good research from staff and your consultants. I am reminded of the zero carbon scenario put forth by the 2019 IRP consultant E3 which was rejected by the Board only two years ago as impossibly costly and infeasible. The new plan is a leap of faith that relies on new cost considerations and makes a strong commitment to finding carbon-free technology and community-based DER solutions for the last 10% of power requirements to meet reliability constraints. SMUD has faced many challenges in the past and I am convinced this too will be successfully met.

March 31 - James G.

How much is this plan going to cost the tax payers? Because great plans hit the low income and the poor the hardest.

March 29 - Robert B.

The SMUD 2030 Zero Carbon Plan (Plan) should received the full support of the Board. In enacting the Plan, SMUD to continue to be a leader in community based electricity by transitioning to a zero carbon model of operations which is vital given the present threat of climate change and the need to reduce carbon consumption. As a SMUD customer, I fully support the Plan and hope that it is given approval, support, and continued support by the Board.

March 27 - David L.

I am impressed by the breadth of SMUD’s plans to move to Zero Carbon.

I note that customer rooftop solar is included in your calculations, with expected growth over the next decade.

I hope that the SMUD Board will use common sense in the contentious issue of increasing homeowner rooftop array grid connect fees. To raise them to the level previously proposed would severely restrict any growth in homeowner rooftop solar. Please investigate the study recently completed by the Michigan Technological University. https://lnkd.in/gpKKNCb

March 26 - Michael E.

First, consider direct or joint sharing on pumped storage where practical. Its clean like hydro, is effective backup (peak) power and is probably cheaper than batteries.

Second, make sure reliability studies are thorough and address unlikely events to be sure conditions here do not result in impacts to customers like what happened in Texas: where solar and wind were inoperable due to cloud cover and frost.