Oregon Residential Rebate Comments

November 28, 2012

Oregon Department of Energy
625 Marion Street N.E.
Salem, OR 97301-3737                                                           Re: Rulemaking for RETC Program

Submitted to: kathy.d.stuttaford@odoe.state.or.us.

The following comments are submitted in response to a notice of a public rulemaking hearing by the Oregon Department of Energy for its Residential Energy Tax Credit (RETC) Program in Salem, OR, on December 4, 2012.

GEO – the Geothermal Exchange Organization – is the primary trade group for the U.S. geothermal (ground source) heat pump industry. We represent major manufacturers, distributors and installers of ground source heat pumps (GSHPs), as well as architects, engineers, drillers and all other trade associates who bring these systems to the public.

We thank the State of Oregon and the Department for their longstanding support energy efficiency and for GSHPs through the financial incentives offered by your RETC Program.

GEO believes that existing Section 330-070-0070 standards for ground source heat pump installations are comprehensive and fair, and that existing rules for pre-qualification of installers authorized to prepare Oregon tax credit applications is sufficient.

We appreciate the possibility of an additional credit when such systems are coupled with an approved duct system.

GEO also finds the Department’s proposed minimum standards for ground source heat pump compressor upgrades are reasonable.

Monetary incentives for ground source heat pump system installations as currently offered are appreciated, but given the energy efficiency of GSHPs, we believe that financial assistance and support could be higher to help counter first cost, especially in retrofit applications.

This is especially true for new models of various manufacturers’ ground source units, which can now achieve EER ratings of 40. In any event, the rebate available for ground source heat pumps should be on a par with, and at least equal to, air source heat pumps and ductless heat pump (mini-split) systems. The superior efficiency of GSHP systems is reflected by current U.S. EPA Energy Star minimum qualifications of EER = 17.1 and COP 3.6, while the minimum requirement for air-source heat pump split systems is only EER=12.

GEO suggests that the Department consider technical support for staff on current trends in ground source heat pumps. This could be accomplished through industry contacts who could help staff in certain areas of technical change. GEO could serve as the Department’s point of contact for such expertise.

 To summarize, GEO appreciates Oregon’s Energy Efficiency Rebate Program, especially as it pertains to geothermal, or ground source heat pump systems. The state has obviously applied a great amount of time in crafting a program that not only reflects the legislative intent of the law, but seeks to maximize participation and effectiveness of the program.

We hope the Department will look into the strides in efficiency that our products have recently experienced, and will seriously consider increasing current rebates to a par with ductless heat pumps.

GEO urges the Department to maintain contact with our industry on any questions it may have regarding efficiencies and of ground source heat pumps and other technical matters. And we urge increased communications and outreach for ground source heat pumps across the state.

Thank you for the opportunity to comment on your proposed rulemakings to improve your RETC Program.


Douglas A. Dougherty
President and CEO
GEO – The Geothermal Exchange Organization