Is UM 1622 Already Decided? An End Of Weatherization In Oregon?

Is UM 1622 Already Decided?

Oregon's Public Utility Commission "Staff", whoever that means, has issued what appears to be the full breadth of an expected OPUC ruling:

Description:  Staff Report for September 30, 2014 Public Meeting (Item No. 1); Filed by Juliet Johnson.

Docket Name:  ENERGY TRUST OF OREGON EXCEPTIONS

Utility Company: 

Type of Activity:  STAFF REPORT, filed on 9/25/2014.

To view this document, please click on the below link:

        http://edocs.puc.state.or.us/efdocs/HAU/um1622hau162141.pdf

Here at document page 22, is the entirety of the staff recognition of my comments and the full breadth of my internet sharing, evident through all hyperlinks:

In response to this docket Phillip Norman provided excerpts from a blog that he writes.
In the blog excerpts he asserts gas prices will go up due to future unforeseen tracking
regulations.

Yes, that's a typo of fracking. Does Staff know anything about this evil? You will correct this typo, and nothing else in the issued ruling, in your evil misconception about cheap energy-to-be-wasted. Each deeply-felt comment got similar snooty dismissal. There is no excuse that you have not applied fifty year cost of energy in the math. And, you have not even questioned Energy Trust's undocumented queer math, so out of touch with the reality known to most home owners, who are not going to Cabo for the Winter. Is there more to it than wrong energy cost and the huge overhead in low-volume delivery?

Here at document page 74 is the recommendation of OPUC Staff in matters of single family residential weatherization:

Here at document page 74 is the recommendation of OPUC Staff in matters of multifamily residential weatherization:

If enacted, this means Energy Trust may spend Public Purpose funds, give small incentives as their queer means, for attic insulation only.  This ignores the fact that Energy Trust overhead is about $25,000 per home served, and rebate amounts are meaningless in the big picture.

At 10/3/2014, the deed is done:

Description:  Errata Order No. 14-343, signed by Commissioners John Savage and Stephen M. Bloom; DISPOSITION:  ORDER NO. 14-332 CORRECTED.  Copies electronically served 10/3/14.

Docket Name:  ENERGY TRUST OF OREGON EXCEPTIONS

Utility Company: 

Type of Activity:  ORDER, signed on 10/3/2014.

To view this document, please click on the below link:

        http://apps.puc.state.or.us/edockets/orders.asp?ordernumber=14-343

The public shall judge that only attic insulation matters; all other measures are not cost effective. This is mean. It is wrong. It ignores all facts I have presented for OPUC consideration. The idiotic air sealing pilot program I have criticized , though called Final, and should-be-dead, is continued somehow.

And, here let us call a distinction in single family programs between existing homes and new homes. Public Purpose funds should never be spent on new homes. Their quality of construction is a matter of code enforcement and commercial, not society, quality control. Perhaps new means are needed to ensure quality with spec homes, as with an assigned and paid outside party. Quality increments in costs are borne without issue in new mortgages. It is only in the matter of somehow-defective existing homes, that  interest is due for an unwary public. Energy Trust and OPUC shall have no fiduciary relationship with new-home builders. Especially, Energy Trust shall cease offering bribes to new-home builders to apply meaningless Energy Performance Score labels, EPS,  a commercial product sold to Cake Systems and taking about $1000 per label from Public Purpose funds, just in payouts to builders; perhaps double that counting assorted overhead. The illegality in not being subject to any test of benefit. Acquiring a rating is a commercial decision, and many rating systems are recognized by Oregon Department of Energy . It is wrong to use public funds to favor the ETO/ Cake Systems product. This aside, where is there a need for public incentives in new home construction? OPUC is doing nothing about misadventures with EPS, while acting to wreck existing-home weatherization.

An End Of Weatherization In Oregon?

Of course not. If residential weatherization becomes fully detached from Energy Trust and the OPUC, the public will demand new management, and some workable use of the taxes in a still-mandated Public Purpose Fund. Programs not engaged in residential weatherization will not be tolerated.

Comments Upon the 9/30/2014 OPUC Public Meeting
I did get to speak at the hearing, but no one at this "public meeting" had any influence. Action had already been firmly decided without need or any real consideration of public comment. Were those who spoke recorded, even? The process has been a sham, and I accuse the American Legislative Exchange Council has played a very silent but big role in the crime. We get badly installed attic insulation where our Public Purpose Fund and Energy Trust have anything to do with it, nothing more. Outside the Portland area, agencies other than Energy Trust perhaps still have good resort to Public Purpose funds, and may not be shut down by hammer-wielding OPUC. Commissioners accept that in five months, most Portland-area weatherization workers will lose their jobs, and good riddance to us. A six month delay was asked; five were granted in compromise from first-offered four, unilaterally by godlike Commissioner John Savage. Dispirited, many will seek other work with a future, immediately. This is stupid, really, really stupid.  I think this is deliberate elimination of public support of weatherization, eliminating the involved taxes upon natural gas and electricity bills. I hope we say good riddance to OPUC and Energy Trust, after re-creating a Public Purpose Fund as a draw upon state income taxes, say 1%, whatever is a similar amount. Weatherization should be for everyone, even those heating with wood, and strong association with fracked natural gas, even for electricity, has been troublesome. I hope the utility tax, while still in the law, will be impounded for issue in up-front loans through an Oregon State Bank. Where for all these years half of the tax contribution has been from home owners and only 15% has come back to them, we have some catching up to do, for fairness. And hereafter it shall not be that any favored person is given anything. All action shall be in the form of fair loans to anyone, for qualifying highest-integrity work, as it should always have been. If nothing were being "given away", there could have been no basis for the lynching.

Wishes Of OPUC Hearing UM 1622

I will attend the 9/30/2014 9:30 AM hearing of Oregon's Public Utilities Commission, in the matter of Docket UM1622 . If I am allowed to speak, I will offer my wishes for a good future of residential energy conservation in my state. I will be speaking with the unique voice of one who does the work with highest diligence, honesty and creativity. I do the work by means of my own invention, not as a rube dragged into scams by national scandal of the US Department Of Energy, dumb-dumb Home Performance With Energy Star, HPwES. HPwES teaches that infiltration is what makes us cold. Tighten up a home with the magic of a blower door. Measure the results and the savings with a blower door. Not so! Fresh air within our reasonable control against excess, is nearly free . The US Department of Energy never did the math. They know nothing of math . Where we find foolish programs lacking return on investment, we have been dragged in by DOE , EPA, and their propagandist ICF International.

I want Oregon to lead the nation in a better way, anticipating the hard times ahead, where, within ten years , our queer bubble of cheap energy expires. If responsible people act wisely, they may avoid being cursed in those days ahead, for cruel inaction. Work done today not only has payback over a life of fifty years; it avoids the inflation in labor and materials, amplifying benefits in energy cost savings. When economy is most needed, it may be out of reach.

My contributions for the hearing are  naive PDF printings of four blog posts found here. What a wonderful thing, Google's Blogger, where my writing may be read and PDF-printed in any language. I think these printings are blessed with sincerity lacking in the simple trash of some contributors, such as far-right-fracking-lover Cascade Policy Institute , cheering the end of inconvenient energy conservation our grandchildren-be-damned.

So, what shall I say at the hearing? (I hope others will help me to edit this list.)

1. Don't take a path where we become honor-bound to eliminate Oregon's Public Purpose Fund, no longer engaged in residential weatherization, which is its justification. Weatherization with government sponsorship must not have as its only goal the reduced cost to Utilities supplying energy. If because of bad choices and mismanagement of programs, OPUC and Energy Trust take a direction contrary to consumer interest in saving energy by known means of insulation, tight construction, better HVAC systems and better lighting, then the government sponsorship becomes disgraced and obscene. We must not take that path. Let us instead consider measures only by their public good. Any measure with fifty-year annual return to utility customers greater than 6%, shall be within bounds for Fund sponsorship. The rate of return shall include expected inflation in cost of accepted measures. Measures without proven durability shall be excluded. A full palate of qualifying measures shall be managed for each customer, by a customer-managed checklist.

2. Delivery of residential weatherization pursuant to Oregon's Public Purpose Fund must be increased on a grand scale . This will be difficult while retail cost of energy remains low. The State Of Oregon shall require policy based on fifty year cost of energy and fifty year durability of weatherization measures. Then, encourage increase of action by up-front financing in a loan fund that shall grow to at least one billion dollars. Immediately impound all Public Purpose Fund revenue as a true fund, none to be disbursed except as in loans.

3. Reinstate attic floor sealing and duct sealing as sponsored measures. These have been removed happily by Energy Trust, only because they are an obstacle to blow and go cheap and dishonest weatherization, the mainstay of Energy Trust's reportable accomplishments. Done right, they are inexpensive, and customers find investments repaid in about two years. Proper HVAC ducting should have no leakage.

4. Abolish Clean Energy Works Oregon. This organization is illegally outside the regulation of the Public Purpose Fund, and should never have been formed.

5. Reform or replace Energy Trust Of Oregon as principal implementor of weatherization. Where all sponsored action is through loans, the absurd weatherization measure of the month, in rebates, is gone as a driver. We will find better drivers. All weatherization measures will be tracked and quality-controlled, regardless of payback priorities. Eligible measures for loans will be tightly controlled and no home may receive a first-round total of more than, say, $5000.

6. Bring all homes into management, especially rental homes. Know that parallel programs will be in place immediately for business properties. Priority in business property weatherization loans shall serve renters of business properties.

A Real Insulation Job, In Detail

Here examine one point in the scatter chart of the previous post:

Do you wonder what someone should expect for a measly $2600 of insulation work?
How about this? A dangerous, broken, leaky attic ladder was intelligently replaced. The floor insulation is boosted from questionable R13, to a durable R40. A large portion of living space wall area had freely communicated with the attic, and that is now sealed fireproof and airtight.

To see before and after, and a lot more, please consult these Google Documents:

Laurelhurst Paid Invoice Here note $319 per year predicted savings. The $2600 investment with wonderful safety and usability consequences, is repaid in a very-acceptable eight years. Weatherization measures alone are repaid in about two years. I earned only $15.90 per hour here, and must charge more. At fair invoice of $4000, I would have earned $30 per hour, and payback would have lengthened to about thirteen years, still a very good investment.

A $168 rebate on the $400 installed cost of insulation is rather irrelevant. A rebate of any amount on the so-important sealing work would have been very relevant. The attic floor sealing cost of $200 is repaid in nine months of savings, the usual story. It hurts to know weatherization sponsor Energy Trust saw no value in my sealing work, offering cruel insult of the competence and diligence, of one repelled by foolishness and abhorring the scandal of HPwES blower door liars. No one is guided in floor sealing, by a blower door.

Fair compensation of my superior work is threatened by counterfeit weatherization under HPwES. 

Laurelhurst Floor Sealing

As is common, I needed lighted work conditions to make intricate wood support blocks for seals of GP Densarmor drywall.

I use GP Densarmor drywall and flexible grout to seal a chimney chase. This is just one of the many sealing challenges in this job, chosen to illustrate need of in-attic carpentry to make support blocks. Lights, a good work surface for a chop saw, and a vacuum cleaner are essential. Do not accept flimsy fire-unsafe foamed-in plastic. 

Choose Densarmor drywall for plugs that may be refined with a Sureform shaver. The two such plugs in this job each needed lowering into place with a lanyard, and several chopsaw refinements of the scrap 2x4 plug retainer.










Laurelhurst Ladder, Insulation, Decking

Laurelhurst Attic Ventilation Here note foolish cut-in by roofers of roof high vents, only promoting the infiltration losses of house heat. The attic has no soffit vents, but has opportunity of excellent attic ventilation if attic windows are replaced with something modern and motorized, not yet on offer.