Oregon Court of Appeals Dismisses Utility Appeal regarding PURPA Fixed Price Payments

In December 2020, the Oregon Court of Appeals dismissed Portland General Electric Company’s (PGE’s) appeal of the Oregon Public Utility Commission’s (Oregon Commission’s) decision in Docket No. UM 1805 regarding contract term requirements under the Public Utility Regulatory Policies Act (PURPA). The Court’s decision capped a series of decisions affirming a long-standing Oregon Commission policy where qualifying facilities (QFs) eligible for standard contracts receive 15 years of fixed price payments.   

PacifiCorp Utah and Oregon GRC Orders

In late December 2020, the Utah Public Service Commission (Utah Commission) and the Oregon Public Utility Commission (Oregon Commission) issued separate orders on PacifiCorp’s Utah and Oregon general rate cases. On December 30, the Utah Commission granted an increase to PacifiCorp, dba Rocky Mountain Power’s (PacifiCorp) annual revenue requirement of $31.41 million. In its initial Utah filing, PacifiCorp sought to increase its retail rates by $95.78 million, or 4.8%. On December 18, 2020, the Oregon Commission ordered a decrease to PacifiCorp’s revenue requirement of approximately $20.9 million, representing a 1.6% decrease from the its previous rates. PacifiCorp’s initial Oregon filing sought an increase of $78 million, or approximately 6%. 

Oregon PUC and PGE Allow Projects to Participate in Community Solar Program

On May 19, 2020, the Oregon Public Utility Commission (Oregon Commission) approved, in principle, a proposed tariff for allocating community solar program (CSP) costs across Portland General Electric Company’s (PGE’s) customer classes. In a public settlement agreement, with the Oregon Commission’s approval of its tariff, PGE agreed to allow solar projects that were parties to the settlement agreement to terminate each project’s pre-existing power purchase agreement (PPA) if so requested within 90 days of the Commission order and to sell their power in the CSP. 

Oregon Court of Appeals Reverses OPUC on PacifiCorp’s Direct Access Charge

On June 19, 2019, the Oregon Court of Appeals issued an opinion in Calpine Energy Solutions, LLC v. Oregon Public Utility Commission (Oregon Commission or OPUC), reversing the OPUC’s approval of PacifiCorp’s Transition Adjustment Mechanism (TAM). The core decision by the Court is that a state regulatory agency, like the Oregon Commission, must make its decision based on the evidence brought before it and not information or decisions from prior cases. 

PGE Direct Access Status Quo Retained

On December 18, 2018, the Oregon Public Utility Commission (Oregon Commission) issued its final order resolving Portland General Electric Company’s (PGE’s) most recent general rate case. The Oregon Commission resolved numerous issues related to PGE’s overall customer rates, and adopted several different stipulations that the rate case parties had reached on various topics, allowing PGE a rate increase of 1.8 percent, rather than the 4.8 percent PGE originally requested. Importantly, the Oregon Commission maintained the status quo for PGE’s modestly successful direct access program.  

Oregon Commission Determines It Lacks Authority to Allow Utilities to Defer Costs Associated With Capital Projects

On October 29, 2018, the Oregon Public Utility Commission (Oregon Commission or OPUC) issued an order finding that it lacks the legal authority to allow utilities to defer, for later ratemaking consideration, the costs associated with their capital projects. The Oregon Commission’s decision represents a departure from its past practice, and also marked an instance of the Oregon Commission reaching a conclusion that was not advanced by any party to the proceeding.  

Oregon Public Utility Commission Codifies PURPA Policies

On October 29, 2018, the Oregon Public Utility Commission (Oregon Commission) issued modifications to its rules governing a utility’s purchase of power from qualifying facilities (QFs) under Oregon’s implementation of the Public Utility Regulatory Policies Act of 1978 (PURPA).  These rules were codified in the Oregon Commission’s rules after they were published by the Oregon Secretary of State on November 2, 2018.  The final rules are the culmination of a three-year old Petition for Rulemaking filed by Obsidian Renewables, LLC in November 2015.   

Oregon PUC Approves PGE Storage Pilot

On August 13, 2018, the Oregon Public Utility Commission (Oregon Commission) adopted a stipulation outlining an agreed approach to the development of five energy storage projects by Portland General Electric Company (PGE). The Oregon Commission concluded that PGE’s proposed structure for PGE’s Coffee Creek Request for Proposal (RFP) is reasonable; however, the Commission stated that it would require PGE to review ownership issues as part of future filings on the Coffee Creek project.