Docket Number	Docket Name	Company
UM 2234	PORTLAND GENERAL ELECTRIC APPLICATION FOR DEFERRAL RELATED TO FLEX LOAD PLAN	PORTLAND GENERAL ELECTRIC

Created Date	Comment Type	First Name	Last Name	Comment
1/26/2026 12:32:44 AM	General Comment			To the PGE Program Management Team and the Oregon Public Utility Commission, Public Comment: Technical Deficiencies of Residential Smart Thermostat Program (Docket UM 2234 / Schedule 5) To: thermostats@pgn.com CC: PUC.PublicComments@puc.oregon.gov, kathy.zarate@puc.oregon.gov, peter.kernan@puc.oregon.gov To the PGE Program Management Team and the Oregon Public Utility Commission, I am submitting this formal feedback regarding the PGE Residential Smart Thermostat Program (operating under Schedule 5 and currently referenced in Docket UM 2234). While I support the utility's decarbonization and load-shifting goals, I am writing to highlight significant technical deficiencies in the current winter program logic as it applies to customers with electric heat pumps. The "one-size-fits-all" approach to event triggers currently creates an efficiency penalty that is counterproductive to both grid stability and consumer energy conservation. Specifically, I request the Commission and PGE management address the following: 1. Inefficient Prep Cycle and Auxiliary Heat Spikes The current 1-hour "prep cycle" (typically beginning at 6:00 AM) frequently occurs during the lowest daily temperatures when heat pump COP (Coefficient of Performance) is at its minimum. This aggressive setpoint increase often triggers Auxiliary/Emergency resistive heat strips. This creates a high-demand, high-cost energy spike—the exact scenario the program is designed to mitigate. 2. The Recovery Period Penalty Heat pumps are designed for gradual, steady-state operation. The thermal loss incurred during a 3-hour winter event necessitates an extended "recovery" period after 10:00 AM. In my experience, the total kWh consumed for the morning "prep" and "recovery" periods often exceeds the energy "saved" during the event, resulting in a net increase in total daily consumption. 3. Conflict with Thermostat Optimization Logic Most smart thermostats (e.g., Google Nest, ecobee) use proprietary algorithms to reach setpoints efficiently through gradual ramping. The PGE "Rush Hour" signal overrides these efficiency-focused algorithms with a fixed-time binary signal, forcing the HVAC system into its least efficient mode of operation. Formal Request: As this program moves through its design transition in 2026, I recommend that PGE implement a Heat Pump Specific Logic that: Disables the mandatory automated prep cycle for heat pump users. Allows for more gradual thermal ramping that respects the technical limitations of air-source heat pumps in sub-freezing temperatures. I have a degree of technical knowledge about how an electric heat pump functions. I am open to providing more detail or data if requested to help you better understand how the Smart Thermostat program is counter productive to electrical energy savings during the winter season program. Furthermore, I believe that the program does not take into account the initial set temperature. Consumers who are already taking steps to reduce energy consumption experience set back temperatures that fall below 68 degrees on mornings when the outside temperatures are in the low twenties. I look forward to seeing the technical adjustments I have mentioned reflected in future program updates. Sincerely, Dale Johnsen 4952 Shadow Hills Dr SE Turner OR 97392