August 20, 2025
Via electronic filing
Oregon Public Utility Commission
Attn: Filing Center
puc.filingcenter@puc.oregon.gov
Re: Comments on Proposed IRP/CEP and RFP Rules
OPUC Docket AR 669 – Rulemaking to Amend Integrated Resource Plan Guidelines and Competitive Bidding Rules
Thank you for the opportunity to add a few additional thoughts to the already robust
record in revising the IRP/CEP and RFP rules in AR 669. The undersigned write to offer just a
few small recommendations.
(1) We encourage specific language directing multi-state utilities to evaluate
resources on a system-wide basis.
(2) We underscore the importance of utility transparency and accessibility to ensure
robust stakeholder participation in IRP advisory groups.
(1) The rules should require multi-state utility evaluation of resources on a system-wide basis
Guideline 10 currently provides:
Multi-state utilities should plan their generation and transmission systems, or gas supply
and delivery, on an integrated-system basis that achieves a best cost/risk portfolio for all
their retail customers.
To ensure that multi-state utilities adequately implement Guideline 10, we recommend that OAR
860-090-0060(7) specifically identifies the need for a multi-state utility to model its generation
and transmission system in an optimized manner for the multi-state system as a single whole.
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(2) The rules should include procedural requirements for the IRP and CEP that explicitly call
for open and accessible processes to gather public input
Open public participation is key to robust IRPs and CEPs that are informed by public input and
responsive to community concerns. The IRP Guidelines have long recognized that prerogative in
Guideline 2a:
The public, which includes other utilities, should be allowed significant
involvement in the preparation of the IRP. Involvement includes opportunities to
contribute information and ideas, as well as to receive information. Parties must
have an opportunity to make relevant inquiries of the utility formulating the plan.
Disputes about whether information requests are relevant or unreasonably
burdensome, or whether a utility is being properly responsive, may be submitted
to the Commission for resolution.1
Recognizing the importance Oregon’s clean energy policies place on stakeholder engagement
and consideration of community impacts and benefits of utility decision making, we emphasize
the need for the rules to preclude any utility gatekeeping in the development of an IRP and/or
CEP. OAR 860-090-0060(4) properly requires the utility to document public input. We
recommend that subsection (a) be revised as follows (emphasized language is the suggested
addition):
OAR 860-090-0060(4)–The utility must include in the IRP an appendix that:
(a) Describes the opportunities the utility created for public input, which must
include meetings that are open to everyone, including the timeframes over
which the utility accepted input from the public on each draft element of the IRP
enumerated in OAR 860-090-0070.
However, we worry that OAR 860-090 alone, even as revised, is not enough as it focuses on
requiring the utility to describe its process for public input versus having more robust
requirements for how the utility should collect that input. In our experience, the rules need to be
specific about what minimum standards the Commission has for utility engagement, and should
clearly communicate the expectation that utilities must hold an open process to gather public
input in preparation of the IRP. Additionally, the rules should specify the need for accessible
forums that discuss IRP and CEP related topics so that stakeholders without the resources of
traditional IRP participants can offer input.
The rules should specify these minimum standards for public participation as procedural
requirements; without that specificity the forums for public input in utility planning could be at
1 Docket No. UM 1056, Order No. 07-002 at 8, https://apps.puc.state.or.us/orders/2007ords/07-002.pdf
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the mercy of arbitrary decisions. Despite Guideline 2a, NW Natural recently explored closing its
public input process to a Technical Working Group (via application) that could provide feedback
and ask questions live during IRP meetings, while non-TWG participants would only be able to
participate via forms or questions after the fact. Similarly, PGE had an engagement forum known
as the Learning Labs, that we understand were intended to be a more accessible forum for
discussion of clean energy planning and other matters relevant to stakeholders without the
resources to participate in IRP meetings, and PGE suddenly decided to close that forum. NW
Natural ended up not forming the TWG and PGE has since engaged with multiple stakeholders
to revamp its accessible public forums. However, we view those two experiences as an example
of why the PUC should establish minimum requirements of stakeholder engagement.
For that reason, we also suggest the following additions:
● For inclusion in draft OAR 860-090-0030, 0040, or on its own, a “Pre-filing Procedural
Requirements for IRPs” section:
○ In preparing the IRP, the utility must allow significant and open involvement by
the public, including opportunities to contribute information and ideas, receive
information, and ask reasonable requests from the utility (e.g. portfolios, futures,
scenarios, etc.). The utility must also seek input and engagement in forums more
accessible to stakeholders without the resources to attend traditional IRP forums.
● For inclusion in draft OAR 860-090-0080, or on its own, a “Pre-filing Procedural
Requirements for CEPs” section:
○ In preparing the CEP, the utility must allow significant and open involvement by
the public, including opportunities to contribute information and ideas, receive
information, and ask reasonable requests from the utility (e.g. portfolios, futures,
scenarios, etc.). The utility must also seek input and engagement in forums more
accessible to stakeholders without the resources to attend traditional IRP forums.
We sincerely appreciate your consideration of this additional input, and we welcome discussion
about our recommended additions.
Sincerely,
Carra Sahler
Director and Staff Attorney
Green Energy Institute at Lewis & Clark Law School
Pat DeLaquil
Steering Committee
Mobilizing Climate Action Together
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Rose Monahan
Staff Attorney
Sierra Club
Jennifer Hill-Hart
Policy & Program Director
Oregon Citizens’ Utility Board
Cherice Bock
Climate Policy Director
350PDX
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