This letter was published on behalf of Sierra Club, MCAT, CUB, and OSSIA in response to PacifiCorp’s WattSmart Program.

Sierra Club, Mobilizing Climate Action Together (MCAT), the Oregon Citizens’ Utility Board (CUB), and the Oregon Solar + Storage Industries Association (OSSIA) (collectively, “Joint Organizations’) write to express support for PacifiCorp’s plans to bring its WattSmart battery demand response program to Oregon customers. Home energy storage, particularly when paired with rooftop solar, can provide significant customer and community benefits, ranging from improved resiliency to lower system costs. We understand that PacifiCorp initially intends to

manage the batteries for strictly demand response—off-setting customers’ load—but that the Company will eventually add other capacities, including exporting the batteries’ energy back to the grid to maximize benefits. This would allow WattSmart batteries to be used as a virtual power plant, particularly if paired with other distributed energy resources like rooftop solar, smart thermostats and EV chargers, which can be a critical resource as PacifiCorp decarbonizes

its system and provides clean energy 24/7 to Oregon customers. Indeed, the U.S. Department of Energy estimates that tripling the scale of virtual power plants across the country by 2030 could address 10-20% of peak demand and avoid $10 billion in annual grid costs.

As the Company finalizes its WattSmart proposal for Oregon customers, we suggest that PacifiCorp consider the following modifications to broaden customer participation.

1.Provide increased, up-front incentives for low- and moderate-income customers

The Joint Organizations support PacifiCorp’s proposal to provide an upfront incentive payment to customers willing to invest in home battery systems. Upfront costs are often cited as the

biggest obstacle to purchasing a home battery, and PacifiCorp’s proposed incentive ($150/kW x annual commitment term) will likely help many Oregon households purchase home storage, particularly when those households can access additional incentives from the Energy Trust of Oregon (ETO) and the federal 30% investment tax credit (ITC). However, this incentive level,

which works out to $3,000 for a 5kW battery, may not be significant enough to support low- and moderate-income customers. These customers may not be able to finance the remaining cost of a battery, especially if they cannot take advantage of the ITC, which is true for many low- and moderate-income customers who do not have tax liabilities. To ensure that WattSmart is

financially in-reach for all of PacifiCorp’s customers, the Company should provide enhanced incentives for low- and moderate-income customers. For instance, in PGE’s “SmartBattery” pilot, PGE included a $5,000 upfront rebate for the first 25 income-qualified customers, all of which were fully claimed within the first year of the program. PGE had also offered lower

upfront incentives for customers located in specific geographic areas, but found that “if PGE wants to encourage customers who otherwise are not planning on installing a battery to do so, more than $3,000 is needed.”2 PacifiCorp could also mimic ETO’s battery incentives, which

provide higher incentives for lower income customers. For PacifiCorp customers, ETO’s battery storage incentives increase from up to $6,000 to up to $10,000 for income qualified customers.

Scaling the upfront incentive to provide additional support for low- and moderate-income customers will help to ensure that these communities are not left behind.

2.Consider a battery leasing program, like the one offered by Vermont’s Green

Mountain Power

While an upfront incentive payment is helpful for households interested in installing energy storage, Green Mountain Power’s experience demonstrates that a battery leasing program can be even more effective. Under Green Mountain Power’s program, home batteries, which can be

accessed by the utility during times of high grid need, can be leased from the utility for $55/month over 10 years.3 While the Vermont utility also offers generous upfront incentives for customers to purchase their own batteries (up to $10,500), its customer-owned program has

enrolled just 2.5 MW compared to 30 MW through the leasing program.4 Indeed, the leasing program, which was initially offered with a 500-customer cap on participation, had long waitlists

until the cap was lifted by the Vermont Public Utilities Commission in August 2023,

further indicating the popularity of a leasing model over a customer ownership model.

Under a leasing program, PacifiCorp would own the batteries placed in customers’ homes, which would make PacifiCorp’s proposal to have access to the batteries 24/7 more appropriate.

Notably, most other battery incentive programs do not grant the utility 24/7 access to the battery, but rather only during relatively few high-demand periods throughout the year. The Joint Organizations are not currently taking a position on whether it is appropriate for PacifiCorp to have 24/7 access to customers’ batteries under WattSmart, particularly if the Company does not own the battery, and may provide additional comment at a later date.

3.Ensure full battery capacity is available to battery owners prior to an anticipated storm or outage event

PacifiCorp is proposing that it will not drain batteries below 10 percent capacity and that dispatch events will be managed to minimize use of the battery system during or prior to an expected outage. The Joint Organizations are concerned that this minimal level of guaranteed battery capacity will not provide battery owners with meaningfully access to energy in the event of an outage. In other words, the customer’s battery may not meaningfully increase reliability

during an outage event, which could result in customer dissatisfaction. Considering the increasing need to rely on public safety power shut offs to avoid wildfires, providing assurance

to customers that if they invest in storage, that storage will be available during an outage is especially important. It’s also notable that other utilities, such as PGE, guarantee higher battery capacity levels and ensure that customers have full battery capacity prior to outages. For

instance, PGE’s SmartBattery pilot allows customers to share up to 80% of their battery’s capacity, meaning that 20% is always reserved for the battery owner and, perhaps more importantly, the customer’s battery is only controlled by PGE during high demand periods, estimated to be 15 times a year.

PacifiCorp should revise WattSmart to ensure that customers have full capacity prior to an anticipated outage event. This will better incentivize customers to both purchase a home battery

and then share its capacity with PacifiCorp, as the customer will be confident in the battery’s ability to meet his or her own needs during an outage

Thank you for your consideration of these comments. The Joint Organizations support expanding WattSmart to Oregon customers and believe that the above recommendations can help make WattSmart a success. We are happy to discuss these comments further or answer any questions that the Company may have.

Sincerely,

DOWNLOAD THE PDF VERSION

From: Dr. John Perona, on behalf of Mobilizing Climate Action Together

Mobilizing Climate Action Together (MCAT) is a group of experienced volunteer healthy climate advocates affiliated with the Oregon League of Conservation Voters.

We write to urge that the Oregon Department of Environmental Quality approve the 401 Water Quality Certification permit for NEXT Renewable Fuels (USACE Permit application #2020-383; DSL # 63077-RF).

MCAT does not possess in-depth expertise in the area of water quality regulation. However, we are encouraged that the DEQ has indicated, in its Public Notice, that subject to conditions it is reasonably assured that the implementation of the project will be consistent with applicable provisions of the federal Clean Water Act, state water quality standards, and other appropriate requirements of state law. Given the ecological fragility of the area, we call on DEQ to work with heightened sensitivity to enforce the off-site mitigation plan for enhancing nearby wetlands, the conditions for maintaining the integrity of state waters during construction, and the post-construction stormwater management plan for minimizing impacts on the natural environment in Clatskanie and surrounding areas.

MCAT recognizes that chemical fuels are necessary and will still play an important role in the post-fossil fuel economy that we are ultimately working for. Having said that, we also wish to emphasize that chemical fuels such as renewable diesel impose considerable risks, especially when a refinery is placed in a sensitive ecological area not far upstream from the Columbia River estuary. We ask that DEQ work with the vigilance appropriate to such a sensitive area, especially to ensure strict compliance with spill prevention and reporting requirements set out in the certification letter. Although not directly DEQ’s responsibility, we also ask that DEQ help promote collaboration between state and county governing authorities to ensure that project construction strictly complies with seismic safety standards.

We support NEXT permitting because of the very substantial healthy climate benefits of renewable diesel (RD). Carbon intensities for many of the approved RD pathways in Oregon’s Clean Fuels Program (CFP) are in the range of 20-40 g CO2e/MJ, far lower than the equivalent value of about 100 g CO2e/MJ for petroleum diesel. According to ODOE’s most recent Clean Fuels Forecast, RD is projected to account for 10% of the total diesel volume used in Oregon for 2024, compared to just over 1% in 2021. Our in-state demand for the fuel is evidently very high, demonstrating the importance and need for the NEXT facility to begin production soon. In-state refinement capacity will surely lower fuel costs for Oregon residents and businesses who make use of RD, spurring increased demand and thereby maximizing climate benefits in accord with the CFP’s goals.

At full capacity, NEXT will be able to meet all of Oregon’s needs for diesel fuel.

Our support is also grounded in the design of Oregon’s CFP. Some present uses of RD, such as transit buses, reflect an interim role for the fuel – as electrification is possible for these applications. Because renewably generated electricity earns the most credit under the CFP, there will be a clear incentive to eventually phase out RD for such uses. Thus, the well-designed structure of the CFP prevents undesirable lock-in of RD in circumstances where an even more beneficial fuel becomes available. On the other hand, there are other important uses for RD, such as long-haul trucking, where electrification is not yet practical or cost-effective. In these cases the savings in carbon pollution by swapping RD for petroleum diesel will be longer-lasting.

More broadly, we wish to note that RD also carries social equity benefits. Every gallon of RD produced at the NEXT facility directly replaces a gallon of petroleum diesel, and it is well known that drilling for this fuel by fracking has differentially greater impact on frontline and low- income communities. Further, combustion of RD generates much lower levels of black particulate matter compared with petroleum diesel. This will lessen the deposition of black particles on Pacific Northwest glaciers and high mountain snowpack, slowing warming-induced melting and reducing the potential for meltwater floods that particularly impact farming communities.

We know that not every impact from the NEXT facility can be fully mitigated. However, our best scientific projections, including those made by the Oregon Climate Change Research Institute, are that the impacts of climate change will be devastating. Decreasing snowpack that is altering river flows, rising water temperatures and increases in extreme weather events are already taking a toll on the Columbia River ecosystem. These impacts from global warming make it all the more important that everything possible be done so that the local impacts from the construction and operation of NEXT do not worsen the already ongoing degradation of that ecosystem.

We also wish to note that the choice of biomass feedstocks for RD production has a significant influence on the overall environmental impact of this approach to greenhouse gas emissions mitigation. We applaud the exclusion of palm oil from allowed feedstocks, given the catastrophic human and environmental impacts that palm plantations supplying biofuels markets have had in East Asia. However feedstocks such as US Midwestern corn and soybeans

are allowed under Oregon’s CFP, even though the dual use of these commodities for food and fuel has potential to drive up food prices. As the NEXT facility will likely expand RD usage in Washington and Oregon, we ask that DEQ monitor this potential impact and consider reducing or excluding impacted crop RD feedstocks as may be appropriate in the future.

Oregon is in the leading group of US states with respect to its vision for limiting climate pollution. Moving forward, we are confident that the NEXT facility will further strengthen Oregon’s commitment to limiting the damages of climate change. This will allow Oregon to serve increasingly as a model for other states to follow. We urge DEQ to issue the 401 Water Quality Certification permit without delay.

Thank you very much for considering our comments. Questions should be directed to Dr. John Perona at johnjperona@gmail.com

Sincerely,

John Perona
On behalf of: Mobilizing Climate Action Together (MCAT)

You can view the PDF version of our letter here.

Dear Co-Chairs Gorsek and McLain and members of the Committee,

Our transportation system planning should focus on maintenance and operation of current facilities, on safety improvements to reduce injuries and fatalities, and on modernizing seismic resilience.  As the funding streams on which we have depended are no longer keeping up, we need innovative solutions. We can reduce congestion by shifting a lot of travel from roads and streets to transit and active transportation. This infrastructure has been underfunded and is consequently underutilized. Such investment is cost-effective and promotes public health by reducing air pollution.  

Since current funding for ODOT and for local jurisdictions depends largely on the dwindling income from the tax on gasoline sales, we must develop other funding streams. System planners must continue to actively educate and involve the public in this process, as you have done with this summer’s Listening Sessions. 

Indexing the gasoline tax to inflation is a common-sense action. Also, this tax rate should be increased now to compensate for lower revenue due to rising vehicle fuel efficiency. (Oregon’s gas tax ($0.40/gal) is currently lower than Washington’s ($0.494/gal) or California’s ($0.60/gal).)  In addition, the payroll-tax-funded STIF could be increased to bolster monies for transit. 

The funding option with the best potential for solving the fiscal gap is the Road User Charge (RUC, also referred to as a Vehicle Miles Traveled (VMT) charge). Oregon has this funding mechanism in place in the OReGO program, though there has been little enrollment. A vehicle’s annual mileage can be captured by a variety of mechanisms (via small tracking devices or accessing manufacturers’ existing data streams). To ease privacy concerns, such mechanisms should report mileage but not location. 

Oregon should fully fund the Electric Vehicle Rebate Program to meet the demand. As we electrify Oregon’s vehicle fleet, we must resist even higher DMV fees for electric vehicles over gasoline vehicles, since this would discourage the transition away from internal-combustion vehicles. 

Until we have adequate funding for O&M, transit and micromobility, we cannot afford huge expenditures on large highway projects. We need to require that such projects have secured full funding before construction begins and must not create obligations to the General Fund. We should require emissions reductions with any costly project, following the lead of states like Colorado (Greenhouse Gas Standard for Transportation Planning).

Tolling of large projects will be necessary but needs to be designed as congestion pricing, i.e. structured to reduce driving at peak times and to reduce driving overall, encouraging mode-shifting to public transit and active transportation, in order to meet goals of speeding travel and reducing tailpipe emissions. 

Other potential funding options include: 

1. increasing DMV fees for all cars and trucks, 
2. increasing sales taxes on all cars and trucks (and fees for registering vehicles purchased out of state), 
3. imposing fees on retail delivery services or on transportation network companies (TNCs)
4. imposing sales taxes on tires, graded according to tire weight and higher for studded tires 

Following these principles will help us meet fiscal, safety, congestion and climate goals. Thank you for conducting these listening sessions and for considering our input,

The Transportation Committee

MCAT (Mobilizing Climate Action Together)

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How the Gifford Pinchot National Forest got its name. And lost its soul