January 21, 2025
Oregon Public Utility Commission
201 High Street SE, Suite 100
Salem, OR 97301-3398
Delivered via email to: [email protected]
RE: UM 1696 – Comments supporting Staff’s recommendation to approve major cost-effectiveness exceptions for multiple heat pump measures, as requested by Energy Trust of Oregon.
The Green Energy Institute at Lewis & Clark Law School (GEI), Community Energy Project (CEP), Oregon Environmental Council (OEC), Earthjustice, Mobilizing Climate Action Together (MCAT), NW Energy Coalition (NWEC), Oregon Citizens’ Utility Board (CUB), and Verde appreciate the opportunity to submit this comment in support of Staff’s recommendation to approve major cost-effectiveness exceptions for multiple heat pump measures, as requested by Energy Trust of Oregon (ETO or Energy Trust).1 Energy Trust has requested the Commission exempt two heat pump measures from ETO’s cost effective requirements to better support Oregon households and state goals to combat climate change and energy burden. These measures supporting heat pump adoption, particularly for low- and moderate-income households and will provide economic and health benefits to individual households while also supporting Oregon climate and energy goals. 1 In the Matter of Energy Trust of Oregon, Cost Effectiveness Exception Request for Electric Measures, Docket No. UM 1696, Staff Report (Dec. 30, 2024) [hereinafter Staff Report on ETO Request].
2. We urge the Commission to approve these measures to support a just energy transition, particularly for energy burdened households and environmental justice communities; traditional cost effectiveness tests fail to adequately capture the benefits provided by heat pumps, especially for those households experiencing low and moderate incomes prioritized by ETO’s present request. In this comment, we identify five key reasons ETO’s request will support Oregon goals and households, thus justifying cost-effectiveness exceptions. We focus on state heat pump goals, cost savings, extreme weather events, healthier homes, and meeting climate goals while also supporting environmental justice communities.
First, in 2023, state legislators established a goal to install half-a-million heat pumps statewide by 2030.2 Over the next five years, agencies like the Commission are tasked with supporting this goal, including removing both financial and nonfinancial barriers to heat pump adoption….
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