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Good morning, everyone. Today is October 28, 2025, and this is a regular public meeting of the Public Utility Commission of Oregon, and all commissioners are present. We take time at the beginning of each meeting to provide the opportunity, the public, the opportunity to comment on issues that are not on the agenda this morning. And so if anyone wishes to comment, you can use the

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raise your hand feature or press star nine if you're dialed in to give a public comment on issues

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not on our agenda. So I will give a minute to see if any hands come up.

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I don't see any

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public comment this morning on items not on our agenda. So let's move on to the consent agenda.

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Do I have a motion to approve the consent agenda?

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I will move to, excuse me, I will move to

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approve the consent agenda. Oh, second. I concur. The consent agenda is adopted. Great. This morning,

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we have an item on our rulemaking agenda, RM1, docket number AR674, rulemaking to amend

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OAR 86091, the Small Scale Renewable Energy Project Standard. And I think Gene Falconer is going to

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I present that for staff this morning.

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Jean?

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Good

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morning.

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Good morning.

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So, good morning, Chair Tonny, Commissioner Perkins,

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and Commissioner Power.

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For the record, my name is Jean Faulkiner,

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and I'm representing PUC staff.

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I'm joined by staff council, Joanna Reiman Schneider.

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Today I'm presenting staff's recommendation

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to move AR-674, which considers changes

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to the administrative rules

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that implement Oregon's small-scale,

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renewable energy project standards

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to the formal rulemaking phase.

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As a reminder, the state's goal

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for community-based renewable energy projects law

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requires large electric IOUs

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to have 10% of their aggregate electrical capacity

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composed of small-scale resources

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under 20 megawatts by 2030.

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This past May, a Pacific War filed a petition

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requesting a declaratory ruling

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to clarify several SSR-compliant scenarios

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as we get closer to the standards 2030 effective date.

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The Commission declined to take up a declaratory ruling at that time, and instead opened this rulemaking who scope it limited to addressing clarifications regarding first, how to calculate the SSR compliance obligation and second, which resources will count toward the SSR requirement.

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We heard the Commission ask for something expedited and narrowly focused, and staff tried to carry that through in our process, leading to these draft rules.

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Before I give an overview of staff's proposal, staff would like to thank all of the stakeholders

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who participated in this process for their timely, thoughtful, and constructive feedback

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provided through meetings of workshop and written comments.

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Stakeholders productive engagement with this process enabled us to complete a thorough review

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of the current rules on a relatively short time frame as envisioned by the commission.

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Because the rulemaking began with a request for greater clarity, staff aired on the side

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being explicit. We understand that the commission made a strategically nuanced decision when the

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rules were created in 2021, but we expect this to be the most efficient approach so close to

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the 2030 requirement. Staff's proposal was guided by some key principles. First, we wanted to

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continue to treat the SSR standard as a generating capacity standard. This principle influenced a

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a number of staffs proposed rules,

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such as those stating that storage

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and behind the beta resources are not eligible SSRs,

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as well as to not involve energy-based instruments

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and compliance.

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Second, we wanted to preserve the value proposition

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of resources with system and community value.

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Staffs proposals that community solar projects

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and front-of-meter resources incorporated

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into microgrids are SSR eligible,

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aligned with this principle,

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as the staff's proposal to exclude storage resources from aggregate electrical capacity.

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Lastly, we wanted to create clear criteria for calculating compliance that can be planned for

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by utilities and project developers and that align with the intent of the laws and state policy.

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This principle underlined staff's proposal that aggregate electrical capacity be calculated one

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year prior to a given compliance date, among other things. Although we are moving forward to the

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formal rulemaking with a good amount of alignment on staff's proposal, there are areas

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where there are still differing.

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First, some stakeholders are concerned about proposed rule language that explicitly excludes storage and SSR capacity when calculating aggregate electrical capacity. In our view, this aligns with a generating capacity standard and eliminates the feedback loop caused by SSR additions, whereby adding SSR capacity generates additional SSR obligations. Second, some utility stakeholders propose that behind the meter projects should be SSR eligible.

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Staff can see the potential for managed distributed energy resources like a virtual power plant to align with our principles in particular treating this as a generating capacity standard and preserving the value proposition of resources with system and community benefits.

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However, we don't think that those managed behind the meter resources are well enough understood to recommend inclusion in the rules today.

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staff believes that it's proposed rules adequately balanced stakeholder concerns with the need

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to provide clarity on SSR compliance ahead of 2030 and we would like to again thank stakeholders

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for their extensive feedback as these proposed rules were developed. Staff recommends that the

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Commission open a formal rulemaking. This concludes my opening remarks and I'm available for questions.

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Thanks so much, Jean. I'm curious on the behind the meter piece. Did you think at all or how

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did you think about language that might in the rural point to that potential future for managed

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behind the meter resources as, or did it see an infeasible?

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I'm curious.

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I think we have some stakeholders who will sort of read the statement

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as all I'm composing, and I'm curious about that sort of nuance

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and how you thought about it.

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Right. Thank you for the question.

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And that is something that we considered.

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And I think PGN, particular in comments, was saying perhaps we could include some sort of revision

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to allow the commission to potentially reconsider this in the future if the situation is warranted,

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which is something that, as I'm sure you know, the commission said that you might be willing to do

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in the original rulemaking. So we, I might ask Council to speak to this further, but

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in having this conversation, it was pointed out by Joanna that having this rule in there

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doesn't preclude it from being changed in the future. And I don't know all of the logistics,

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but essentially a petition could be submitted, allowing for a reconsideration of that rule.

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But we felt that it made sense to have that rule in there for now because it's something that the commission was very clear about early on.

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So in our view, we're not trying to change how the rules work. We're just being very clear about this is what the commission already determined.

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Let's have that in the rules so everybody knows how it works.

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Okay, I appreciate that.

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Other questions for staff?

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I guess I would create and I'll see a brought up the capacity and connection capacity issue at this point or is that something that would be still considered in the in the formal we're making in staff's proposal.

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It certainly could be are you referring to surplus and our connection and shared in a right.

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Yeah, so that's actually something that we talked about pretty extensively as part of this rulemaking and there's a lot of consensus on that issue.

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We ultimately felt that adding explicit language to the rules wasn't necessary.

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We feel like there's nothing in the rules currently that precludes resources from being eligible if they use these specific interconnection agreement types.

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Now, I will say that Pacific War was asking for language to be written somewhere, whether

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it be in the commission order or maybe in the rules themselves clarifying that.

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But it's very much staff's position that the use of those interconnection types shouldn't

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impact the eligibility of a resource.

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So that's something that in the formal rulemaking we could consider adding explicit language.

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But we, again, felt it was unnecessary given the current rules, and we were also worried

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about writing something that might conflict with the statute.

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Okay, yeah, and I was thinking about

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creating and seeing those comments that they wanted to protect access for small projects,

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but you feel that staff has adequate tools to be able to kind of triage as issues come up within

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and the proposed rule framework.

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Well, I think as far as the access question goes, this, I think you're referring to them worrying about anti-competitive outcomes. And our feeling was that that was, so that's a valid concern, but we kind of felt it was outside of the scope of what we're considering as part of this rulemaking, whereas we're concerned about the eligibility piece, whereas that seems to relate more with, you know, the implementation of interconnection agreements. So that's something that we could certainly consider about how to add ruling,

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language to address that, but it was something that for now we felt was a little bit broader than what we were asked by the commission to consider.

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Thank you.

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Great.

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I am also curious on the.

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In the rule of language, you you pivoted.

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or revise the language around RPS eligible resources to be not those that are projects used

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to comply with the standard, but broader, but there was a little less discussion about

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sort of that change. I'm curious why you felt that needed clarification.

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Great. Thanks for the question. So that the the direct thing that prompted that change in language was so pacific or in dr 58 they were asking about community solar and whether those projects are SSR eligible and we feel that they should be, but it was pointed out by pacific or that.

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that none of their CSP projects are RPS approved generators.

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But we were also thinking in general that, you know,

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we wanted to distinguish between resource types,

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so that motivated some of the language and the rules.

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So moving from referring to a generator versus generation types,

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that's where that came from.

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But then moving from RPS approved to RPS eligible,

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we had community solar specifically in mind,

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but we were also thinking about in the future,

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there might be other resources that reasonably should be SSR eligible, but you know, for whatever

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reason they aren't RPS approved. So we just wanted to allow for a little bit more flexibility in

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that language. Okay. Okay.

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So then when I, so having a,

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changing it to A and or B, you felt like

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you needed to sort of revise what was previously won in order to I guess I'm not sure why I'm

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not saying the question very clearly. To add B you didn't necessarily need to change how A was

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framed but you wanted to be more general.

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Yes yes I think that's right and so again the community

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solar piece was what directly prompted this but we were also thinking about a future in which

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we might want to have that greater flexibility around that language. Yeah, okay. Okay, I appreciate

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that. What is probably not wildly clear about the old language is it meant if somebody didn't

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lot there because this is not a Rex embedded. Because Rex are not required for this standard,

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it sort of created a way for somebody to keep their project out of the count if they wanted to,

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if they wanted to. So because they were trying to protect their Rex, but I hear you on the breadth.

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And with the decisions on HB 2021, I don't know that that decision matters anymore.

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because our wrecks aren't greeny certified anymore so okay appreciate all of

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that work. My staff especially to go quickly like we had previously like we had

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asked and being really responsive to that.

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Let's turn to comments I know I had

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heard from OSEA but I'd love to see a show of hands as well

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And maybe I'll start with OSEA if you're on the line since you let us know that you wanted to speak.

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Morning, Angela.

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Morning.

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Thank you.

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Commissioner, Angela Crowley-Cook, Executive Director of OSEA.

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First of all, I appreciate all the work that staff did and also the speed at which this has happened.

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And I'm big.

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Because of the federal changes to tax credits and new deadlines, we really appreciate how quickly

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this rulemaking is going and hope that the rest of it will be fast as well.

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So in general,

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we're supportive of staff's recommendations, but with a few exceptions, excuse me, I'm

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recovering from a cold. And I'll have my colleague Greg go into more details on some of the

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those concerns we have, but they're surrounding not including storage in the denominator of

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the equation for what counts as the capacity, the total capacity for the requirement, the

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exclusion of small-scale renewables that have been used for compliance already being excluded

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We neither of those exclusions were discussed in the statute, and from our perspective, there's no reason to have those deductions.

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And it reduces compliance.

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Again, I'll have Greg go further into detail on those.

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But I'd like to spend some time talking about the discussion that the commission was just

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having regarding RPS compliance versus RPS eligible and the exclusion of net metering.

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OCS is very supportive of the commission's repeated exclusion of net metering from the

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at Renewable Standard in previous orders in the last public meeting when this rulemaking

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was ordered. So I think it's worth thinking about the legislative history here. Back when

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this requirement was first created, it was all about being RPS compliant. And in the minds

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of everyone then, wrecks were included in that definition of what would be considered eligible

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for small-scale renewables. That's one of the reasons why net metering was never discussed

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in conversations about this policy. It was never dreamed of being considered because net metering

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is not RPS eligible, it's not RPS compliant, and the same is true with community solar.

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And so OCS stands by the position that both community solar and net metering should not

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be included in this small scale renewable as eligible projects, because of the intent

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of this was for RPS eligible and compliant projects, so the REX going with the project.

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I think the opening the door in this way is leave the door open for a potential weakening

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of the standard and not following the true intent, which is for small scale projects,

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but above net metering, so between the two and 20 megawatt size range.

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But so we support the exclusion of netmeanering here.

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We hope to see the rules go further in the next stage of the role making.

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But overall we really appreciate staff's work and the revisions that they made in modifying what counted as capacity throughout the process.

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Thank you.

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Thank you.

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Questions for you?

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I'll

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turn to Greg with CREA.

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Good morning, Chair Tawny and commissioners Perkins and Powers.

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Can you hear me okay?

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Yes.

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So yeah, I'm speaking here today on behalf of the Community Renewable Energy Association, CREA.

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We did, as Angela mentioned, file comments with OSEA and Renewable Energy Coalition

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joined one of our rounds of comments too.

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So, we also really appreciate staff's consideration of our comments and incorporation of our recommendations

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into their rule and the very thorough explanation of the issues and various positions in

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the staff report, which was very good.

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We recognize this is an expedited rulemaking where the commission may be inclined to move

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to the formal phase based on the current staff proposal and address remaining disputed points in

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the formal rulemaking phase. And as Angela mentioned, we do largely support staff's proposal,

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but I wanted to just highlight.

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We're still going to wait two of the key issues, which Angela mentioned, where we still have a disagreement with staff, and which we filed joint comments on and be available to answer any questions the commissioners might have on those today. Those two key points I was going to address relate to the resources that are included in the denominator, which is the part of the equation where you're looking at what is the utilities aggregate electrical capacity.

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capacity under the statute, and that's the total number against which you apply the 10%

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to get to what how many small scale renewable facilities you need to have.

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And so the two, I think there's a lot of detail here, but the two key points I think where

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we have a disagreement right now with staff are on storage being excluded from the denominator

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and the small scale renewable facilities themselves being excluded from the denominator.

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On storage, we don't see how they should be excluded, storage, or at least we see an inconsistency in the commission's policies across small scale renewables on this point.

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And that is that in the ongoing purple docket and I think in some other purple dockets,

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utilities have proposed that storage is the avoided capacity resource.

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And that's what you should use to calculate the purple avoided costs that are paid to a QF.

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In our view, and staff's gotten behind that to a certain extent in those dockets.

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And so in our view, that argument contradicts treating storage as not a capacity resource

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when you're looking at what's the totally aggregate electrical capacity.

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We do acknowledge storage is a unique type of resource, but just wanted to flag

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that inconsistency in the treatment storage and point out that in our opinion it's not

221
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reasonable to use storage as a capacity resource to calculate avoided cost rates that are offered

222
00:22:12,180 --> 00:22:18,620
to the QFs and get at a lower avoided cost rate by doing that while simultaneously claiming

223
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that storage is not a capacity resource for purposes of calculating how many small-scale

224
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renewables be totally must acquire under this provision we are against.

225
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The other issue that is still in dispute is whether the small-scale renewable facilities themselves

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00:22:38,280 --> 00:22:44,360
should be in the denominator. As Angela mentioned, we disagree with staff's current proposal to

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exclude them from the denominator. The plain language of the statute says that the denominator

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is both the aggregate electrical capacity of the utility. There's no there's no exclusion in

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there for the SSR resources themselves. And we don't see how you get there with the way the statute's

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00:23:06,280 --> 00:23:06,620
written.

231
00:23:08,800 --> 00:23:14,920
As staff states, in this report, we do support staff's proposal to measure the compliance target

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00:23:14,920 --> 00:23:21,040
each year based on the aggregate electrical capacity at the beginning of the year, which

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we think mitigates the impact of this moving target problem utilities have identified with

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inclusion of SSRs in the denominator, so I wanted to point that out there.

235
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there is a way to kind of make the whole mechanism more workable without

236
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ignoring the language of the statute in American. So I think I'll stop on those

237
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issues. Again, we really appreciate stat work and I can answer any questions you

238
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have on those issues or anything else that we filed comments on.

239
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Okay, again, curious. It wasn't clear to me. Then are you suggesting storage would

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also be in the numerator? No storage to the numerator has a different requirement

241
00:24:04,760 --> 00:24:10,060
that there has to be an RPS resource so storage isn't an RPS resource and that

242
00:24:10,060 --> 00:24:18,830
would be why it's not in the numerator and I mean it's conceivable you could have

243
00:24:18,830 --> 00:24:25,970
behind the meter you know like a solar plus storage I think where it's all where

244
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is part of the facility where it's just charging from an RPS resource, but I still

245
00:24:32,830 --> 00:24:36,790
don't know if storage is technically itself an RPS resource at that point.

246
00:24:37,630 --> 00:24:43,530
So there's sort of two kinds of storage, there's standalone storage and there's co-located

247
00:24:43,530 --> 00:24:50,630
storage. You're you're drawing a distinction with a little mark gray area around the co-located

248
00:24:50,630 --> 00:24:55,870
storage. That could be, I don't think we got into that in detail in the comments, but I think

249
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didn't, you know, if you think through it, when you're looking at the

250
00:25:00,000 --> 00:25:28,440
The numerator, the, you're talking about an SSR facility, if it had storage with it, I would argue that the storage is generally just charging behind, behind, you know, the meter, and it's not actually increasing the capacity of the overall facility to the extent it's a part of the facility. If it's a separate standalone storage unit, it's charging from the grid, I would argue it's not a RPS compliant, right?

251
00:25:29,340 --> 00:25:33,620
Okay. Thanks for that. Other questions for Korea?

252
00:25:40,010 --> 00:25:46,190
Yeah, I guess I just struggled a little bit with the storage on the denominator.

253
00:25:47,890 --> 00:25:51,670
Just in the fact that it isn't a generating capacity.

254
00:25:52,470 --> 00:25:57,490
It's a capacity resource, but it isn't generating electricity.

255
00:25:57,810 --> 00:26:01,770
So how do you square that aspect of it, Greg?

256
00:26:01,770 --> 00:26:02,910
Well,

257
00:26:05,780 --> 00:26:09,020
I mean, it's I that sounds like the arguments we've been making in the

258
00:26:09,020 --> 00:26:14,400
purpose. So I don't want to get into to that about parties here. I think we've

259
00:26:14,400 --> 00:26:20,520
identified kind of an inconsistency there. It is treated as a capacity resource and in

260
00:26:20,520 --> 00:26:26,180
the utilities planning. So I think I'm working with it. It should be included as aggregate

261
00:26:27,460 --> 00:26:28,060
capacity.

262
00:26:31,300 --> 00:26:35,240
But I will I acknowledge yes, it doesn't generate electricity that

263
00:26:35,240 --> 00:26:44,020
I think it's the challenge with storage that wasn't considered, you know, it's relatively

264
00:26:44,020 --> 00:26:44,420
new.

265
00:26:44,700 --> 00:26:49,580
So it's as we move through the process, I know there's some, some rather gray areas

266
00:26:49,580 --> 00:26:50,680
or inconsistent language.

267
00:26:51,560 --> 00:26:52,000
Yes.

268
00:26:55,360 --> 00:26:55,900
Okay.

269
00:26:57,360 --> 00:26:58,920
Anything further for Korea?

270
00:27:00,160 --> 00:27:00,420
No.

271
00:27:00,760 --> 00:27:00,960
All right.

272
00:27:01,340 --> 00:27:02,060
Thanks so much, Greg.

273
00:27:02,640 --> 00:27:03,280
Thank you.

274
00:27:04,400 --> 00:27:05,480
I ran.

275
00:27:11,650 --> 00:27:15,250
Good morning Chair Ty, commissioners, Perkins and Power.

276
00:27:15,710 --> 00:27:17,590
Appreciate the opportunity to be here today

277
00:27:17,590 --> 00:27:19,170
and the work that everyone's done.

278
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I don't have any prepared comments.

279
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I think Angela and Greg did it well.

280
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I just wanted to know through the record

281
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that we support the earlier comments

282
00:27:27,990 --> 00:27:29,450
the Korean OSCS submitted

283
00:27:30,150 --> 00:27:33,350
and appreciate all the work that everyone's done in this case

284
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and look forward to further engagement.

285
00:27:36,430 --> 00:27:37,390
Thanks so much.

286
00:27:39,940 --> 00:27:40,240
All right.

287
00:27:40,240 --> 00:27:44,420
Right, Thomas with Pacific Corps.

288
00:27:50,460 --> 00:27:53,800
One second, I think you can hear me there, my camera clicked on.

289
00:27:54,480 --> 00:27:57,220
Good morning, Chair Tony, Commissioner Perkins, and Commissioner Power.

290
00:27:57,640 --> 00:28:02,080
For the record, I am Tom Burns, Vice President of Resource Planning and Acquisitions for Pacific Corps.

291
00:28:03,100 --> 00:28:09,260
Thank you for the opportunity to comment on AR674 regarding small scale renewable energy amendments.

292
00:28:09,260 --> 00:28:25,460
We very much appreciate staff's thoughtful proposal, which recognizes that while small scale resources are required to comprise 10% of the allocated generating capacity, their contribution to the overall generation cost may well exceed this threshold.

293
00:28:25,900 --> 00:28:37,410
The proposal's approach, removing storage resources from aggregate capacity, including front of the meter resources such as community solar and utilizing surplus interconnection.

294
00:28:37,410 --> 00:28:42,770
connection, meaningfully reduces customer cost while maintaining the intent of the small

295
00:28:42,770 --> 00:28:44,170
scale resource requirement.

296
00:28:44,850 --> 00:28:52,330
The company will be seeking further clarification on resource proximity rules, and in regards

297
00:28:52,330 --> 00:28:58,290
to the compliance year, we will also recommend that the compliance target volume be based

298
00:28:58,290 --> 00:29:03,990
on the aggregate generating capacity from four years previous on a rolling basis.

299
00:29:03,990 --> 00:29:10,250
This would allow developers to participate in interconnection studies, enable the utility

300
00:29:10,250 --> 00:29:15,930
to conduct an RFP, and ensure projects are delivered in time for compliance at the lowest

301
00:29:15,930 --> 00:29:21,870
cost to customers. That concludes my comments, and I'm available for questions.

302
00:29:27,540 --> 00:29:30,580
Thanks so much. Questions for Pacific War?

303
00:29:39,800 --> 00:29:40,220
Thank you.

304
00:29:41,440 --> 00:29:46,780
Sorry, I was struggling to find the place in your question, in your comments.

305
00:29:46,780 --> 00:29:55,680
I was a little bit confused in your discussion of the surplus interconnection proposal.

306
00:29:56,520 --> 00:29:59,660
You said I was trying to find the quote.

307
00:30:00,000 --> 00:30:27,040
Which I'm not going to be able to do on the fly. The staff's proposal would also avoid creating any unnecessary complications with a federal interconnection requirements that would result of the commission chose to instead codify surplus interconnection language. I was, I wasn't totally following the conflicts or necessarily understanding the conflicts you were thinking might occur.

308
00:30:29,460 --> 00:30:35,620
I'm going to, you know, there's a wide array of people that contribute to the comments

309
00:30:35,620 --> 00:30:39,180
for Pacific Orp, some of which are very much legal-minded.

310
00:30:39,600 --> 00:30:46,940
And I believe that that was specifically directed at codifying something within Oregon

311
00:30:46,940 --> 00:30:50,460
might come into conflict with the FERC interconnection process.

312
00:30:50,460 --> 00:30:59,020
us. So I do have someone that can speak more to that, but I don't think that that's necessary.

313
00:30:59,020 --> 00:31:00,280
I think I addressed the point.

314
00:31:09,440 --> 00:31:10,800
Chair, Tony, you're muted. Sorry.

315
00:31:11,740 --> 00:31:18,140
Thank you. So it was more of a hypothetical potential as opposed to a specific wording that

316
00:31:18,140 --> 00:31:20,560
had come up in the conversation that was concerning.

317
00:31:20,700 --> 00:31:20,940
Correct.

318
00:31:20,940 --> 00:31:21,100
Correct.

319
00:31:21,620 --> 00:31:21,900
Okay.

320
00:31:22,160 --> 00:31:22,540
Helpful.

321
00:31:22,640 --> 00:31:22,820
Correct.

322
00:31:23,680 --> 00:31:29,880
Keeping the lines straight between FERC and Assets on Interconnection isn't always straightforward,

323
00:31:30,120 --> 00:31:30,740
so appreciate that.

324
00:31:31,960 --> 00:31:33,100
Other questions for PAC?

325
00:31:33,580 --> 00:31:34,460
I think it was no.

326
00:31:37,320 --> 00:31:38,000
All right.

327
00:31:38,280 --> 00:31:38,800
Thank you so much.

328
00:31:38,840 --> 00:31:39,140
Thank you.

329
00:31:39,500 --> 00:31:39,720
Thank you.

330
00:31:39,980 --> 00:31:41,300
And Jason.

331
00:31:46,910 --> 00:31:47,670
Good morning.

332
00:31:49,050 --> 00:31:49,750
Good morning.

333
00:31:49,810 --> 00:31:50,250
Chair Tony.

334
00:31:50,890 --> 00:31:51,670
Commissioner Perkins.

335
00:31:51,870 --> 00:31:52,370
Commissioner Power.

336
00:31:52,850 --> 00:31:54,210
My name is Jason Salmy-Claughts.

337
00:31:54,850 --> 00:31:56,050
I'm with Portland General Electric.

338
00:31:56,050 --> 00:32:01,290
I appreciate the opportunity to engage with staff and stakeholders and

339
00:32:01,290 --> 00:32:08,150
commenting today. We wish to reiterate our concern stated in our comments,

340
00:32:08,430 --> 00:32:15,410
filed during the informal making September 11th and October 13th.

341
00:32:15,410 --> 00:32:24,130
We support commissions in 10 as expressed in order 25-232 to limit the scope of

342
00:32:24,130 --> 00:32:32,430
this rulemaking to address specific course DR58 petition, PG support staff's proposed

343
00:32:32,430 --> 00:32:38,730
division 91 rule amendments to address aggregate electrical capacity, and certain inputs

344
00:32:38,730 --> 00:32:44,950
necessary to calculate the SSR compliance. We're also supportive of staff's language clarifying

345
00:32:44,950 --> 00:32:51,810
community solar eligibility. However, we're opposed to elements of the proposal that appear

346
00:32:51,810 --> 00:32:59,070
to go beyond commission's direction in order 25-232 or that exceed the statutory authority

347
00:32:59,070 --> 00:33:01,290
as evidence in the plain language of the statute.

348
00:33:02,510 --> 00:33:07,950
This would be language excluding from qualifications behind the meter resources including rooftop

349
00:33:07,950 --> 00:33:13,990
solar or solar and batteries or any behind the meter generation that would otherwise be

350
00:33:13,990 --> 00:33:20,470
leveraged as a system resource to offset other large generation purchases and expenditures

351
00:33:20,470 --> 00:33:25,310
or clean energy strategies directed at affordability

352
00:33:25,310 --> 00:33:29,110
to reduce overall system and delivery costs.

353
00:33:30,210 --> 00:33:33,610
We believe the exclusion of behind-the-meter resources is not

354
00:33:33,610 --> 00:33:35,630
need to be addressed in the current rulemaking.

355
00:33:36,310 --> 00:33:39,110
It was not raised as a question by Pacificor.

356
00:33:41,070 --> 00:33:44,490
Pacificor's DR filing and the informal rulemaking process

357
00:33:44,490 --> 00:33:47,550
is afforded no significant opportunity to explore the issue.

358
00:33:48,310 --> 00:33:55,770
In short, we feel the proposed rules and seeking to avoid scope creep have gone too far in the

359
00:33:55,770 --> 00:33:56,430
other direction.

360
00:33:57,210 --> 00:34:03,370
Beyond the commission's direction, not to increase the scope of beyond specific course discrete

361
00:34:03,370 --> 00:34:08,830
questions, codifying these issues and rules, ignores the point previously acknowledged by

362
00:34:08,830 --> 00:34:15,410
the commission and AR622, naming that the role of these behind the meter resources and utility

363
00:34:15,410 --> 00:34:20,090
systems can evolve to become resources contributing to the state's small scale

364
00:34:20,090 --> 00:34:25,010
renewable requirement. We find other venues with the Commission and

365
00:34:25,010 --> 00:34:29,090
now the legislature through the microgrid bills and courage system direction for

366
00:34:29,090 --> 00:34:34,990
behind the meter, where to become an active and managed component of resource

367
00:34:34,990 --> 00:34:40,710
portfolios for the utilities. If adopted, the amendment would discourage

368
00:34:40,710 --> 00:34:43,750
development of behind-the-meter options.

369
00:34:45,850 --> 00:34:48,370
Perhaps if we were to make investments

370
00:34:48,370 --> 00:34:51,710
with behind-the-meter resources to optimize them

371
00:34:51,710 --> 00:34:53,570
as a system resource and then seek

372
00:34:53,570 --> 00:34:56,970
small-scale renewable consideration

373
00:34:57,710 --> 00:34:59,070
or attribution.

374
00:35:00,240 --> 00:35:04,020
And we ask for cost recovery, there could be a ruling on improvements.

375
00:35:06,780 --> 00:35:08,680
If we cut off from eligibility,

376
00:35:08,900 --> 00:35:14,460
a significant segment of potential CBRAs and microgrid projects that customers will support as part

377
00:35:14,460 --> 00:35:20,520
of a utility CEP, IRP proposal with negative impacts on statewide goals, utility customers ability

378
00:35:20,520 --> 00:35:27,980
to pursue such projects and requirements that they pay twice for compliance with SSR. We're a bit

379
00:35:27,980 --> 00:35:32,400
concerned about the exclusion of behind the meter resources here, especially when it comes to

380
00:35:33,660 --> 00:35:38,780
CBREs. CBREs could include behind the meter resources. So now we've

381
00:35:38,780 --> 00:35:45,760
and part defined what CBREs are for compliance purposes with SSR. So where would you put your money

382
00:35:45,760 --> 00:35:46,840
if you had limited funds?

383
00:35:49,540 --> 00:35:54,260
Staff assertion that utilities can simply seek waivers or ask to reopen

384
00:35:54,260 --> 00:36:00,640
but rule makings is, it is onerous.

385
00:36:01,140 --> 00:36:03,340
I mean, there are opportunities here to create language

386
00:36:03,340 --> 00:36:05,540
and opportunities without having to go to a,

387
00:36:06,220 --> 00:36:07,840
ask for a change in rules.

388
00:36:08,240 --> 00:36:09,680
Rules are rarely changed.

389
00:36:10,220 --> 00:36:11,880
It's difficult to change rules.

390
00:36:12,080 --> 00:36:17,840
That's why the commission exercises that power under the APA.

391
00:36:19,820 --> 00:36:27,040
But most of all, as alluded, at the time when affordability is a foremost issue for customers,

392
00:36:27,240 --> 00:36:35,560
utilities in the condition, looking at this through the customer lens are raising some concerns.

393
00:36:35,560 --> 00:36:40,120
The behind the meter exclusion fundamentally turns the SSR compliance into a surplus requirement

394
00:36:40,760 --> 00:36:43,320
for supporting QF market resources.

395
00:36:46,140 --> 00:36:52,520
We, therefore, encourage the Commission to open up formal rule making to address the

396
00:36:52,520 --> 00:37:02,200
questions raised in the Pacific Wars DR58, but move to strike staff's proposal –00302C

397
00:37:02,200 --> 00:37:11,040
and 3A amendments as being unnecessary and unsupported at this time and beyond the scope of the

398
00:37:11,040 --> 00:37:11,480
proceeding.

399
00:37:14,420 --> 00:37:20,080
And I'm available for questions I also brought along our council if there are

400
00:37:20,360 --> 00:37:33,970
sort of legal questions that I'm unable to answer. Thanks Jason. I you know we we had left a space

401
00:37:33,970 --> 00:37:40,190
open for future business models when we had engaged these roles previously.

402
00:37:42,350 --> 00:37:44,590
I'm curious if you've

403
00:37:44,590 --> 00:37:55,690
thought about wording or additions to staff's wording to differentiate utility

404
00:37:55,690 --> 00:38:03,050
dispatched resources or anything like that, as opposed to simply striking the rule,

405
00:38:04,370 --> 00:38:05,150
the proposed rule.

406
00:38:05,910 --> 00:38:12,470
I think that we would be open to having some language around

407
00:38:12,470 --> 00:38:33,990
optimizing and operating behind the meter resources as a system asset. I think one of the things that we've heard from others here in the preceding was concerned that rooftop solar right now is a reduction to load.

408
00:38:33,990 --> 00:38:41,250
it's not optimized through a system dispatch, so we could be open to

409
00:38:41,860 --> 00:38:46,970
a compromise there of course. You know that creates an incentive for the utility to make

410
00:38:46,970 --> 00:38:54,670
investments and optimizing and deploying those assets with customers or situating them

411
00:38:54,670 --> 00:39:00,950
on customer physical plans or in their homes. It's part of compliance here that would be

412
00:39:01,670 --> 00:39:02,690
very helpful.

413
00:39:05,500 --> 00:39:11,900
I appreciate that. Other questions for PTE on their comments? Or anything?

414
00:39:15,790 --> 00:39:19,710
Nope. All right. Thanks so much Jason. I appreciate it. Thank you.

415
00:39:23,710 --> 00:39:28,370
Anything you'd like to go back to staff with colleagues.

416
00:39:45,630 --> 00:39:52,490
This is detailed complex staff. So I want to give space to flip through the PDFs and find them.

417
00:39:54,510 --> 00:39:55,190
Okay.

418
00:39:55,190 --> 00:39:59,830
Well, I suggest perhaps we can move to delivery.

419
00:40:00,700 --> 00:40:12,020
If there's no follow-up questions, I just want to give folks any space, if they want to follow up. No? No. I didn't hear anything new that had already been fully briefed or addressed in the staff report.

420
00:40:14,060 --> 00:40:28,580
So I think the table of issues remain what they are right now. And I think you did a nice job of sort of teasing out some of the nuance as we've gone through comments from stakeholders over the last half hour or so.

421
00:40:33,120 --> 00:40:40,940
So, you know, these rules have been challenging since they were, since the law was passed.

422
00:40:43,400 --> 00:40:50,560
And the last round was quite finely balanced, particularly, you know, on the Rex issue,

423
00:40:50,560 --> 00:41:01,140
for example. But the landscape keeps moving and changing. The affordability challenges continue

424
00:41:01,140 --> 00:41:12,020
to grow. From my part, I have increasing concerns about sort of system reliability,

425
00:41:12,020 --> 00:41:19,800
following ELCCs and how do we get more, more RAA value out of the distribution system,

426
00:41:21,480 --> 00:41:29,700
and trying to keep these rules sort of aligned with those other pressures or operating in the

427
00:41:29,700 --> 00:41:38,280
context of all those other pressures. There's a real challenge, and so I'm comfortable moving

428
00:41:38,280 --> 00:41:46,880
forward into formal rulemaking. I am uncomfortable with the blanket statement on behind the meter,

429
00:41:47,140 --> 00:41:52,320
not because I think behind the meter needs to be counted right now, but because I think that

430
00:41:52,320 --> 00:41:58,220
parties will use that statement later to mean more than we intend, more than I intend right now,

431
00:41:58,680 --> 00:42:07,480
in terms of future flexibility. And I don't want future flexibility around business models that could

432
00:42:07,480 --> 00:42:14,840
really bring more RA into the distribution system to be disincentivized, and I

433
00:42:14,840 --> 00:42:20,260
worry that that rule once it's in the, once it's in the rule book, we'll get read

434
00:42:20,260 --> 00:42:24,580
as very broad as opposed to more nuance, which is sort of my intention

435
00:42:24,580 --> 00:42:32,590
certainly. I think the other details I'm comfortable sort of how we where we're

436
00:42:32,590 --> 00:42:43,510
and letting AHD bring us a set of choices on the other elements, but that's where I'm at right now.

437
00:42:43,870 --> 00:42:48,290
Happy to delve into the other details if folks want to explore them or have perspectives on them.

438
00:42:51,780 --> 00:42:54,620
Thank you, Chair Tony, excuse me.

439
00:42:55,700 --> 00:43:03,360
It is challenging. I think we have other dockets that touch on many of the issues that are explored here and that can make it a little tough

440
00:43:03,360 --> 00:43:10,900
Tough and there is, like I mentioned before, there is some inconsistency in language because of things that weren't necessarily considered when legislation was passed.

441
00:43:11,620 --> 00:43:14,340
And so those gray areas can create difficulties.

442
00:43:14,480 --> 00:43:21,040
I do think, you know, small scale resources are a way that we can get generation capacity on the system.

443
00:43:21,640 --> 00:43:30,340
Maybe more quickly than larger resources and that have benefit to local communities and potentially to the distribution system.

444
00:43:30,340 --> 00:43:35,400
I don't have the same concerns as you with the behind the meter statement.

445
00:43:35,560 --> 00:43:42,640
I think that there are other ways that we can get at incentivizing those types of resources

446
00:43:43,020 --> 00:43:48,560
and demand response type resources at both commercial and industrial and residential level.

447
00:43:48,920 --> 00:43:51,780
So I think we have other ways to get at those.

448
00:43:52,560 --> 00:43:58,540
But I hear you, we know how much change has happened just in the last couple of years

449
00:43:58,540 --> 00:44:04,280
and are anticipating rapid change in the industry in the coming years and so it's hard to foresee

450
00:44:04,280 --> 00:44:08,440
what challenges we're going to have in front of us and what new verability we're going to want.

451
00:44:09,400 --> 00:44:15,040
So I totally understand you're desired to preserve that ability to have flexibility.

452
00:44:16,220 --> 00:44:22,960
So I appreciate the discussion around battery storage and how that fits into the mix.

453
00:44:23,400 --> 00:44:27,980
I think that the nuance on small scale resources being in the denominator I think is

454
00:44:27,980 --> 00:44:34,840
I still have questions about that, and I have mixed emotions, and so that's an area

455
00:44:34,840 --> 00:44:40,500
that I think that further discussion is warranted.

456
00:44:41,060 --> 00:44:45,840
So that's just an area that I look at, and I think there's valid arguments on why we

457
00:44:45,840 --> 00:44:48,660
would include small-scale resources in the denominator.

458
00:44:52,050 --> 00:44:52,290
Thanks.

459
00:44:53,130 --> 00:44:59,950
I think my perspective is similar to Commissioner Parkinson, particularly with including...

460
00:45:00,000 --> 00:45:08,560
Small-scale renewables already occurred to date in the current denominator. Since we're sort of setting

461
00:45:08,560 --> 00:45:15,900
a, the rules are setting new side boards on a going forward basis. So I'd like some more

462
00:45:15,900 --> 00:45:21,240
conversation there to capture where we are right now.

463
00:45:25,480 --> 00:45:28,860
Comfortable moving forward today. And I think

464
00:45:28,860 --> 00:45:34,780
I think I also still have some questions behind the meeting resources and how they're utilized here.

465
00:45:37,760 --> 00:45:41,980
The bill was a product of compromise between legislative interests.

466
00:45:42,520 --> 00:45:47,860
I think some of the comments on the floor were representative of how legislators arrived at that compromise.

467
00:45:49,040 --> 00:45:56,020
And what was in and what was out was a key part of how legislators had their perspectives incorporated into the bill.

468
00:45:56,020 --> 00:46:00,120
that said, Chertani, I think your comments are spot on.

469
00:46:00,280 --> 00:46:06,160
We are in a different space now than we were in 2021.

470
00:46:09,540 --> 00:46:16,960
And I think we need to have a sharp eye towards overall impacts to bills as we move ahead with all requirements.

471
00:46:18,440 --> 00:46:25,360
So I'm comfortable with that and I think appreciate both of you and your work in this.

472
00:46:25,360 --> 00:46:29,500
this docket to help shape the next phase.

473
00:46:30,880 --> 00:46:36,660
I appreciate that and I think there is a great deal we're going to do in the distribution system.

474
00:46:36,660 --> 00:46:41,100
We're going to have to look to the distribution system for a lot of resource.

475
00:46:41,900 --> 00:46:47,380
I think as I think about how to manage that affordability with that reliability,

476
00:46:47,780 --> 00:46:53,380
with the policies, the sort of generation choices that the legislature has mandated,

477
00:46:53,380 --> 00:47:13,300
really trying to squeeze out absolutely as much reliability out of those generation choices as we can is is for me sort of the key way to keep the three the three legs of the stool and balance with each other.

478
00:47:13,300 --> 00:47:23,620
And this is a tricky one because it's really driving energy rich resources and not necessarily strong RA resources into the mix.

479
00:47:23,820 --> 00:47:34,100
And so how do we sort of squeeze out as much RA from them as we can, given that it's sort of how I'm approaching the balancing act.

480
00:47:34,100 --> 00:47:51,600
So appreciate that. I think there's lots we can do as the ALJs take this over and we move it to completion. So I'll move we adopt staffs proposed motion as outlined in the memo.

481
00:47:53,820 --> 00:47:56,280
I'll second and I will concur.

482
00:47:57,200 --> 00:48:05,160
Excellent. The motion is adopted, and we'll look forward to word-smithing and trying

483
00:48:05,160 --> 00:48:11,400
to sort of put a package together that accomplishes all the, all the challenges, all the different

484
00:48:11,400 --> 00:48:19,840
goals. But have to be honest all the time, because that's just what the system is. All right,

485
00:48:19,840 --> 00:48:30,180
Let's move on to RA1, which is speaking of. Today is all about the distribution system.

486
00:48:31,060 --> 00:48:35,880
Docket number, sorry, my screen's all flipped over.

487
00:48:36,260 --> 00:48:41,120
2, 3, 6, 2, the 2024 distribution system plan for PGE.

488
00:48:42,280 --> 00:48:48,520
And I think Nixon and Rebecca, if you're like they're going to present for us,

489
00:48:48,520 --> 00:48:50,260
if you guys would like to come forward.

490
00:48:58,910 --> 00:48:59,590
Good morning. Good

491
00:49:03,340 --> 00:49:05,700
morning, Chair Tony. Thank you. I'm

492
00:49:05,700 --> 00:49:13,480
pausing for a beat to see if Rebecca is having any connection issues. She was going to

493
00:49:14,120 --> 00:49:18,220
deliver our open remarks, which I can do if she is disconnected, but I'll

494
00:49:18,220 --> 00:49:22,000
it's okay with you. Pause for just a moment.

495
00:49:36,220 --> 00:49:41,140
Hearing from Rebecca, I will quickly jump in if that's

496
00:49:41,140 --> 00:49:48,640
Okay. Thank you for your patience. And so I need to grab the notes we prepared. Sorry about that.

497
00:49:51,190 --> 00:49:56,370
No worries. She was on, but it looks like she's disappeared. So I'm guessing that

498
00:49:56,370 --> 00:49:59,230
and some sort of challenge in is coming back into the meeting.

499
00:50:00,000 --> 00:50:29,500
We'll get started and she'll jump in if that's okay with you. Thank you very much for the time to chat this morning for the record. My name is Nick Sayon. I'm a senior utility analyst with PUC staff. Eventually, probably, we'll be joined by Rebecca Ferrelact, my co-author on the staff memo. We worked closely together on this, which is why we're intending to co-present today. Also on the line is Natasha Smith, assistant attorney general with DOJ.

500
00:50:29,500 --> 00:50:35,120
should we have specific legal questions come up as is sometimes the case.

501
00:50:36,120 --> 00:50:42,140
I'd like to begin by thanking PGE for its substantial efforts to develop the plan and engage

502
00:50:42,140 --> 00:50:50,520
with stakeholders. Staff finds that the PGE 2024 DSP meets the guideline requirements set

503
00:50:50,520 --> 00:50:56,780
fourth in order 24-421 and therefore we recommend the plan being accepted.

504
00:50:58,380 --> 00:51:02,960
The DSP guidelines require electric utilities to provide greater transparency around

505
00:51:02,960 --> 00:51:09,200
grid needs and justification of proposed solutions to promote spending discipline and establish

506
00:51:09,200 --> 00:51:11,120
a through line for future cost recovery.

507
00:51:12,140 --> 00:51:17,060
Through this planning docket, staff seeks to understand the utilities decision-making process

508
00:51:17,060 --> 00:51:22,460
and to identify and vet its spending in this area that represents one of the

509
00:51:22,460 --> 00:51:28,200
largest set of capital investments in customer rates. PGE's plan includes

510
00:51:28,200 --> 00:51:33,240
near-term investments of more than $2.4 billion over a five-year period from

511
00:51:33,240 --> 00:51:40,960
2024 through 2028 and that's across six spending categories. 80% of this spend

512
00:51:40,960 --> 00:51:46,940
addresses customer and partner commitments that's one category, capacity and

513
00:51:46,940 --> 00:51:52,900
flexibility to address load growth as a second category and compliance requirements as a third

514
00:51:52,900 --> 00:51:59,720
category. Staffs analysis concluded that PGE's proposed investments exceed study state spending

515
00:51:59,720 --> 00:52:05,320
by at least $200 million annually, and this is likely to put upward pressure on customer rates.

516
00:52:07,390 --> 00:52:14,110
PGE is currently seeking cost recovery for certain investments in its 2024 DSP through

517
00:52:14,110 --> 00:52:17,310
through Docket UE 459, and that is a contested case.

518
00:52:18,250 --> 00:52:21,910
Today, staff plans to focus remarks just on content

519
00:52:21,910 --> 00:52:25,090
from PGIS DSP, the 2024 plan.

520
00:52:27,610 --> 00:52:30,610
Staff commends PGIS and developed in a comprehensive plan

521
00:52:30,610 --> 00:52:32,450
that provides a granular forecast

522
00:52:32,450 --> 00:52:35,130
of expected investments by category,

523
00:52:36,110 --> 00:52:39,170
includes low growth and DER adoption forecasts

524
00:52:39,170 --> 00:52:43,430
at the substation level, provides updated baseline data,

525
00:52:43,430 --> 00:52:46,830
and discusses its virtual power plant, the VPP,

526
00:52:47,170 --> 00:52:49,250
with benefit cost analysis.

527
00:52:50,590 --> 00:52:53,830
Additionally, staff appreciate the company's six workshops

528
00:52:53,830 --> 00:52:55,750
and multiple office hours held

529
00:52:56,110 --> 00:52:58,910
to provide information in field stakeholder questions.

530
00:52:59,710 --> 00:53:03,610
And these, this engagement did exceed guideline requirements.

531
00:53:05,290 --> 00:53:08,970
However, staff found significant information gaps

532
00:53:08,970 --> 00:53:11,850
that hinder our ability to understand the company's justification

533
00:53:11,850 --> 00:53:13,870
of its many near-term investments.

534
00:53:15,150 --> 00:53:19,610
Specifically, staffs continues to see greater transparency

535
00:53:19,610 --> 00:53:23,570
into the relationship between PGE's most important grid needs

536
00:53:23,860 --> 00:53:25,450
and proposed solutions.

537
00:53:26,510 --> 00:53:28,510
Staff finds that the plan does not demonstrate

538
00:53:28,510 --> 00:53:31,950
a clear prioritization method for near-term investments

539
00:53:31,950 --> 00:53:34,430
or consistently demonstrate the origin

540
00:53:34,700 --> 00:53:36,410
or necessity of investments.

541
00:53:37,460 --> 00:53:39,490
There benefits to rate payers.

542
00:53:39,490 --> 00:53:42,810
and whether lower cost alternatives were considered.

543
00:53:44,490 --> 00:53:49,250
Additionally, it remains unclear to staff how PGE attributes the cost of large transmission

544
00:53:49,250 --> 00:53:54,050
projects to the distribution planning budget.

545
00:53:56,140 --> 00:54:02,020
Finally, PGE proposes expenditures over 20 years, so outside of just the action plan,

546
00:54:02,160 --> 00:54:07,260
the five-year action plan, over 20 years of $880 million for its VPP.

547
00:54:07,260 --> 00:54:23,920
The company's benefit cost analysis, as provided in the plan, presents a useful lens for this resource and staff believes PGE should next model the VPP resource within its upcoming IRP modeling process.

548
00:54:25,940 --> 00:54:37,020
Given the trend of increased distribution spending, it is increasingly important for utilities to demonstrate that investments are necessary and deliver measurable benefits to ratepayers.

549
00:54:37,020 --> 00:54:41,580
There is considerable room for improvement in PGE's plan.

550
00:54:43,320 --> 00:54:47,940
However, it has significantly advanced staff's understanding of PGE's investments

551
00:54:47,940 --> 00:54:51,360
since the company's last file plan.

552
00:54:52,400 --> 00:54:59,620
On a procedural note, the DSP guidelines require that utilities submit an interim update on

553
00:54:59,620 --> 00:54:59,960
you

554
00:55:00,000 --> 00:55:08,060
Project progress. One year after last file in the full DSP. Because UE 459 is currently underway,

555
00:55:08,600 --> 00:55:15,740
staff recommended a one year extension. After some additional feedback and discussion, staff now

556
00:55:15,740 --> 00:55:24,300
thinks it would be better to extend the interim update from December 20, 26 to March 15, 2027,

557
00:55:24,300 --> 00:55:32,200
effectively moving to Q1 of 2027 and that would include, sorry, allow inclusion of a full year

558
00:55:32,200 --> 00:55:35,200
of 2026 project data in the report.

559
00:55:37,260 --> 00:55:40,360
Staff would like to thank state holders for their valuable time

560
00:55:40,360 --> 00:55:45,920
and effort in providing feedback on PGE's plan. Staff expects to work with the company and state

561
00:55:45,920 --> 00:55:51,320
holders to evolve and improve distribution planning and increase transparency in future plans.

562
00:55:52,200 --> 00:55:56,860
Thank you very much for this time. I'm available to answer questions. And if

563
00:55:56,860 --> 00:56:01,440
while I've been chatting with you, Rebecca's back online. She's available to

564
00:56:01,440 --> 00:56:02,460
answer questions too.

565
00:56:05,720 --> 00:56:07,500
Thank you. Anything to add for Becca?

566
00:56:10,300 --> 00:56:11,540
Nothing to add for me.

567
00:56:12,100 --> 00:56:16,680
My apologies. My internet went out exactly the wrong time. So thank you my

568
00:56:16,680 --> 00:56:25,720
colleague Nick for taking those opening remarks. Absolutely. Very familiar with the

569
00:56:25,720 --> 00:56:29,660
It appears to questions for staff, colleagues.

570
00:56:33,280 --> 00:56:39,720
Well, thank you for the analysis and the detailed document

571
00:56:39,720 --> 00:56:42,700
that you provided to us, kind of summarizing the work

572
00:56:42,700 --> 00:56:43,340
that's been done.

573
00:56:46,000 --> 00:56:49,120
Talk to you about this as we were moving through this process.

574
00:56:49,120 --> 00:56:52,640
But I'd love to just hear you make a comment on,

575
00:56:52,860 --> 00:56:57,600
there's a repeated concern about lack of transparency.

576
00:56:57,600 --> 00:57:00,560
and lack of requested information.

577
00:57:01,460 --> 00:57:04,500
And I know CUB has brought this up in their filing

578
00:57:04,500 --> 00:57:05,420
that came in really late.

579
00:57:07,780 --> 00:57:12,380
However, I know there's the recommendation

580
00:57:12,380 --> 00:57:14,000
that we accept this plan.

581
00:57:15,100 --> 00:57:19,580
How do you square that need for more transparency

582
00:57:20,380 --> 00:57:21,980
with accepting the plan?

583
00:57:23,020 --> 00:57:24,300
What's the trade-off there?

584
00:57:24,880 --> 00:57:36,020
why should we accept a plan when we've repeated to be an asking for information that's really important to one of the largest investments that the utility is making that impacts customer rates.

585
00:57:40,280 --> 00:57:46,340
Thank you Commissioner Perkins for the question. It's a difficult one. It's one that frankly we wrestled with.

586
00:57:47,160 --> 00:57:53,100
We looked at the full set of guideline requirements one through nine I believe.

587
00:57:54,620 --> 00:57:57,860
and found that the plan does meet many of them.

588
00:57:59,240 --> 00:58:02,000
Partly, I noted those in my opening remarks.

589
00:58:03,500 --> 00:58:06,300
Our critiques are largely focused on guideline 6,

590
00:58:06,520 --> 00:58:10,860
which is the grid needs requirement and guideline 8,

591
00:58:10,940 --> 00:58:12,840
which is the near term action plan requirement.

592
00:58:13,760 --> 00:58:18,880
And in these instances, we argue strongly for ways in which the plan could be better,

593
00:58:19,000 --> 00:58:20,140
and needs to be better in the future.

594
00:58:21,320 --> 00:58:27,260
There are this set of shortcomings, and despite these, we felt the plan was on balance, adequate

595
00:58:27,260 --> 00:58:33,160
for acceptance. That is also contingent, not contingent, but builds on, probably is a better

596
00:58:33,160 --> 00:58:40,020
way to say it, that our belief that DSP is and should be an exercise and continuous improvement.

597
00:58:40,720 --> 00:58:47,440
And in that respect, PGE's plan does demonstrate incremental progress from the prior plan. It is

598
00:58:47,440 --> 00:58:53,640
important that that improvement continue going forward to future filings. There's a tremendous

599
00:58:53,640 --> 00:58:56,060
amount of detail about the

600
00:58:58,240 --> 00:59:02,680
technical details that were or weren't provided for any one of 100

601
00:59:02,680 --> 00:59:13,380
something projects. In summary, the plan was adequate for acceptance, and so rather than wrestle

602
00:59:13,380 --> 00:59:19,580
with those specific project details. I'll pause there to see if that is kind of an adequate

603
00:59:20,620 --> 00:59:28,160
answer for that high level answer for that question. Yeah, I think it's what is clearly

604
00:59:28,160 --> 00:59:35,720
wrestled with throughout the document. And you can see it in comments from stakeholders as well.

605
00:59:36,480 --> 00:59:41,560
So yeah, just wanted to kind of put that out on the table because I know it is a point of discussion

606
00:59:41,560 --> 00:59:42,900
that we're likely to have.

607
00:59:45,890 --> 00:59:49,310
Thanks for that, Commissioner Perkins. Anything else for staff?

608
00:59:50,430 --> 00:59:54,030
I think, you know, following up on Commissioner Perkins' question, I appreciate

609
00:59:54,970 --> 00:59:59,930
Nick and Rebecca how you've gracefully navigated that answer. I think

610
01:00:00,000 --> 01:00:29,980
I think it is challenging to receive substantive critiques of your staff report less than 24 hours before our meeting, which then, you know, puts us in a position of having to ask you that that complex sort of question live in this public meeting rather than being able to discuss it in detail. The timeframe is challenging. And so I wanted to note that and appreciate, you know, you sort of thinking through it in real time. It would be my strong preference to be able

611
01:00:29,980 --> 01:00:35,960
to have adequate time to talk through that with you if outside stakeholders have

612
01:00:37,520 --> 01:00:45,020
clear and I think very pointed concerns in the future. So a bit disappointed about timing,

613
01:00:45,440 --> 01:00:48,840
but thank you for working through that in real time with us.

614
01:00:54,380 --> 01:00:59,100
Wondered if how you think about, I appreciate that commissioner power.

615
01:01:01,620 --> 01:01:07,200
You know, we've thought a lot over the years about acceptance versus acknowledge versus

616
01:01:07,200 --> 01:01:15,640
approve, and I'm curious how you think about your very clear in the memo, this is not

617
01:01:15,640 --> 01:01:20,720
pre-approval, prudence review, remains where prudence review belongs, which we've been

618
01:01:20,720 --> 01:01:22,900
very consistent about as a commission.

619
01:01:24,900 --> 01:01:38,180
But I wonder if how you think about IRP acknowledgment versus TE and DSP acceptance and how you sort of applied that lens here.

620
01:01:42,810 --> 01:01:48,910
Thank you, Chair Tony. There's I think two aspects of that question immediately come to mind.

621
01:01:48,910 --> 01:02:10,790
One is that the level, the exercise of acceptance is two of the plan broadly or in whole, which is a distinction from IRP where there's an individual action plan with an action plan with individual items and also a long term plan, et cetera, that you are able to go through an evaluate on a specific basis.

622
01:02:11,590 --> 01:02:17,510
We haven't done that today in the DSP. It's just addressing the plan in whole. That's the way the guidelines structure review.

623
01:02:17,510 --> 01:02:19,090
So that's one point.

624
01:02:19,570 --> 01:02:27,150
The second point, I think, is perhaps more, you know, a big picture and more substantive is how much sure is this?

625
01:02:28,490 --> 01:02:32,710
I have a piece of been going on for several decades and we're not there yet.

626
01:02:33,190 --> 01:02:39,850
I would say that growth and development from our guideline development in 2020 to the first plans was pretty significant.

627
01:02:39,850 --> 01:02:44,410
and recognition of a need of growth and revised guidelines of 2024.

628
01:02:44,950 --> 01:02:52,670
And now, here with the first plan filed under those new guidelines, significant growth and progress again.

629
01:02:53,110 --> 01:02:58,910
But I do want to note, or sort of underscore, the points in the memo that we call that

630
01:02:58,910 --> 01:03:08,250
as those significant gaps and concerns where when we evaluate something,

631
01:03:08,250 --> 01:03:14,410
do we have the information to be able to really pass judgment on something specific?

632
01:03:14,850 --> 01:03:20,870
And I think those kinds of metrics and onifiable data were circling.

633
01:03:21,210 --> 01:03:27,930
We've gotten closer. We haven't dialed them in yet with respect to this plan before us today.

634
01:03:33,440 --> 01:03:40,860
Thanks. I appreciate that framing in terms of sort of the decision that you're asking us to take.

635
01:03:43,850 --> 01:03:50,990
And the complexity of those metrics, especially the cost effectiveness, sort of metrics.

636
01:03:52,890 --> 01:03:58,910
All right, so if there's nothing further for staff, I appreciate all the hard work on this.

637
01:04:00,370 --> 01:04:08,250
And just reflect back to what we started with in terms of the ever-spiraling smart grid reports and love that we were.

638
01:04:08,250 --> 01:04:17,710
So, fashion forward to be on our multiple, multiple revisions into our DSP guidelines at this point.

639
01:04:18,350 --> 01:04:23,250
So, appreciate all the work over the several years to get here.

640
01:04:24,170 --> 01:04:33,190
I'm going to ask for a raise of hands for anyone who would like to speak to the DSP and I see Fatima.

641
01:04:33,810 --> 01:04:39,070
if you can let us know if you're representing any organization or if you're

642
01:04:39,070 --> 01:04:39,870
not that's fine too.

643
01:04:50,720 --> 01:04:53,400
You should be able to turn your camera on and unmute yourself

644
01:04:54,080 --> 01:04:59,980
Fatima. Sorry, I think it was I dial it by accident. Sorry. No worries.

645
01:05:00,000 --> 01:05:04,540
No worries at all. All right, clear.

646
01:05:10,900 --> 01:05:15,420
Good morning. Can you hear all hear me okay? Lovely. Clear

647
01:05:15,420 --> 01:05:24,640
Valentine Fossum here with Oregon CUB. And I'd like to just start off by saying that we really

648
01:05:24,640 --> 01:05:31,560
appreciate working with staff on this. Nick and Rebecca have an excellent report here that's going

649
01:05:31,560 --> 01:05:36,860
to be very helpful for us. It's quite thorough as we move forward with evaluating the projects

650
01:05:36,860 --> 01:05:42,660
that are put into the DSP and then of course the next steps for recovery. So we, I just want

651
01:05:42,660 --> 01:05:47,300
to say that I really appreciate that we really appreciate here how that was laid out the level

652
01:05:47,300 --> 01:05:54,820
and the level of detail and scrutiny that's provided by this report. I also just want to say as well

653
01:05:54,820 --> 01:06:01,260
that throughout this whole process we appreciate the level of engagement from staff including the

654
01:06:01,260 --> 01:06:06,020
changed the procedural schedule when it was understood that there was a recovery proceeding

655
01:06:06,020 --> 01:06:10,460
going on, and also that more information was needed, and we would like another round

656
01:06:10,460 --> 01:06:11,280
of comments was needed.

657
01:06:11,420 --> 01:06:16,120
So I just want to start off by saying that we really appreciate working with staff throughout

658
01:06:16,120 --> 01:06:20,780
this whole process, and that this report was quite helpful.

659
01:06:22,060 --> 01:06:28,640
But it's from that, it's from what is found in the report, and our respect for what staff

660
01:06:28,640 --> 01:06:33,880
has found in this report, which was why we decided to make that comment. And I recognize

661
01:06:33,880 --> 01:06:41,540
it was late as we have a number of other competing deadlines for other PGE filings that are quickly

662
01:06:41,540 --> 01:06:47,500
approaching. But at the end of the day, though we wrestled with it and we had internal discussions,

663
01:06:47,940 --> 01:06:57,840
we still wanted to put forward this comment for you all. Again, after really reading and considering

664
01:06:57,840 --> 01:07:07,000
what staff had said, and though this comment was filed late, or not late, but at the last minute,

665
01:07:07,100 --> 01:07:13,240
I will say, the concerns around affordability are not new, and that is a theme throughout the

666
01:07:13,240 --> 01:07:20,960
staff report. The concerns about meaningful engagement and about transparency are not new.

667
01:07:23,080 --> 01:07:28,640
And we need these kind of things in order to be able to successfully look at a plan and

668
01:07:28,640 --> 01:07:34,020
be able to understand what is anticipated and use that information in the next steps

669
01:07:34,020 --> 01:07:37,320
throughout to get to recovery and the rate cases.

670
01:07:37,680 --> 01:07:42,700
And that is really what makes a thorough plan and an effective plan is be able to have that

671
01:07:42,700 --> 01:07:51,000
transparency and, you know, from looking at this plan, well, PG notes that the investments

672
01:07:51,000 --> 01:07:55,780
are necessary. And, again, that's not entirely clear, unfortunately, for the public, because

673
01:07:55,780 --> 01:08:01,900
of the lack of transparency of the information and the lack of information provided to staff

674
01:08:01,900 --> 01:08:06,800
and others in this plan, what I will say, what is clear and what is transparent is it is not

675
01:08:06,800 --> 01:08:17,060
afford, it is not here to be affordable, and so our concerns, I guess, rest on is a worth

676
01:08:17,060 --> 01:08:26,200
accepting a plan where from a sophisticated company that has had multiple rounds of working

677
01:08:26,200 --> 01:08:32,720
on DSPs that still does not provide the transparency, and yet is asking Oregonians to put the bill for

678
01:08:32,720 --> 01:08:41,320
significant increases in its distribution spending. Nick said something that really caught my

679
01:08:41,320 --> 01:08:48,540
ear earlier about the near-term investments and the lack of information there near-term investments

680
01:08:49,290 --> 01:08:54,500
while perhaps future investments, you know, comparatively, may have more uncertainty.

681
01:08:55,380 --> 01:09:00,080
Near-term investments should have the information available. They should be more certain,

682
01:09:00,080 --> 01:09:02,320
and especially if you're asking for recovery of them.

683
01:09:03,160 --> 01:09:05,940
And so it's quite concerning that staff found

684
01:09:05,940 --> 01:09:09,100
significant information gaps for the near-term investments.

685
01:09:10,280 --> 01:09:13,180
I know we have a comment in our part of our comment,

686
01:09:13,400 --> 01:09:17,120
I should say, where we do address the acceptance

687
01:09:17,120 --> 01:09:20,200
of near-term and the timeline aspect of that,

688
01:09:20,320 --> 01:09:22,560
both from an engagement level

689
01:09:22,560 --> 01:09:24,940
and then also the information availability level.

690
01:09:25,580 --> 01:09:29,460
But I think that was just something that,

691
01:09:29,460 --> 01:09:40,220
You know, I'm considering our comment and considering the staff feedback and what they found the report perhaps should be given some additional weight than perhaps will be initially put in our comments.

692
01:09:40,420 --> 01:09:51,020
So again, just to close, I want to say appreciate this report, nice work, and look forward to working with staff in the future as we go forward.

693
01:09:52,260 --> 01:09:59,820
And with this kind of level of detail, and I think response of this to the feedback that they were getting from stakeholders.

694
01:10:00,000 --> 01:10:01,240
Thank you.

695
01:10:05,000 --> 01:10:07,860
Thanks so much. Questions for cut.

696
01:10:12,020 --> 01:10:13,620
Okay. All right.

697
01:10:16,510 --> 01:10:23,890
I think I'll go to Fred and then come round to PGE to respond.

698
01:10:28,910 --> 01:10:41,810
Thank you, Chair Tony, and commissioners, Perkins, and power. Good morning. Fred here at the Northwest Energy Coalition. I'll keep this very short. First to say, it's been a long journey with a

699
01:10:41,810 --> 01:10:47,810
distribution system plan. I first want to thank the commission. We're setting up and executing a

700
01:10:47,810 --> 01:10:55,370
really good overall process. We're now going through the second round here with PGE. We can see

701
01:10:55,370 --> 01:11:05,350
really tremendous progress in this overall approach. It's actually exceeded my hopes in many ways

702
01:11:05,830 --> 01:11:11,630
in terms of providing information to the public and to you and providing a lot more context

703
01:11:11,630 --> 01:11:17,490
for filling in the gaps on this crucially important part of providing utility service.

704
01:11:18,130 --> 01:11:22,910
I also want to thank PGE for stepping up and really doing a lot of work,

705
01:11:23,330 --> 01:11:29,170
a huge amount of work, to pull all the pieces together and evolve their approach.

706
01:11:31,090 --> 01:11:37,170
And I especially want to thank Nick Sand on the Commission staff who's carried this through the whole way

707
01:11:37,170 --> 01:11:43,050
and is really advanced. I think we're advancing the state of the art here. Really

708
01:11:43,050 --> 01:11:45,570
want to express my appreciation for all that.

709
01:11:48,490 --> 01:11:50,790
But and I want to point to only one

710
01:11:50,790 --> 01:11:56,470
thing in the staff report to kind of summarize our thoughts. On page 12, the staff

711
01:11:56,470 --> 01:12:01,070
report talks about tightening the going forward, tightening the virtual power

712
01:12:01,070 --> 01:12:08,350
plan analysis and the consideration in the CPIRP process, as well as focusing on the future

713
01:12:08,350 --> 01:12:12,750
spending and customer benefits that pertain to that.

714
01:12:13,290 --> 01:12:19,030
And generally how the distribution system plan can provide more consistent context for

715
01:12:19,030 --> 01:12:20,330
cost review and recovery.

716
01:12:20,650 --> 01:12:22,610
I think that's really where our focus should be.

717
01:12:23,550 --> 01:12:28,450
We know that, as CUB just said, there's tremendous amount of bill pressure from this effort.

718
01:12:28,450 --> 01:12:38,830
And there's also a lot of focus on getting a better aim of all these very complex efforts toward providing delivered value to customers.

719
01:12:39,670 --> 01:12:45,470
This is a, this is a, the affordability question here is not a binary in our view.

720
01:12:45,690 --> 01:12:48,190
It's not either this plan is affordable or it's not.

721
01:12:48,950 --> 01:12:54,950
It's how affordable can it be and how effective can it be?

722
01:12:55,170 --> 01:12:58,230
That's really the key challenge that we've got.

723
01:12:58,810 --> 01:13:00,310
But I'm glad to have that challenge.

724
01:13:00,510 --> 01:13:09,130
I'm glad we have as much information as we've got that the company and the staff have spent a great deal of time on a huge amount of effort on.

725
01:13:09,130 --> 01:13:17,590
The approximately half a billion dollars a year of spending, this is a major component

726
01:13:18,310 --> 01:13:24,270
of what we pay in our bills, and the quality of service that we get.

727
01:13:25,090 --> 01:13:31,450
I think I've mentioned this previously, PGE's crews came and replaced the power pull at

728
01:13:31,450 --> 01:13:34,990
the end of my block earlier this year, over 100 years old.

729
01:13:35,530 --> 01:13:36,550
That's part of this.

730
01:13:36,550 --> 01:13:41,550
the very advanced kind of virtual power plant work is also part of this.

731
01:13:42,110 --> 01:13:49,550
It's really kind of been, for me, I kind of knew the complexities of the actually operating

732
01:13:49,550 --> 01:13:53,690
the distribution part of the utility. I had no idea.

733
01:13:54,570 --> 01:13:57,250
And now we have a much better idea. So for that, I thank you.

734
01:13:58,310 --> 01:14:03,730
And finally, just want to say we do have some concern about the ability to execute

735
01:14:03,730 --> 01:14:06,890
on this very ambitious, very broad-ranging approach.

736
01:14:07,470 --> 01:14:09,390
Does the company have the staff

737
01:14:10,320 --> 01:14:14,150
and the management processes to deliver on this

738
01:14:14,420 --> 01:14:16,070
is something we're watching closely?

739
01:14:17,110 --> 01:14:21,690
So overall, again, appreciation for getting to this point

740
01:14:21,920 --> 01:14:24,850
and we do look forward to continued progress

741
01:14:24,850 --> 01:14:26,710
on the distribution system plan.

742
01:14:26,970 --> 01:14:27,290
Thank you.

743
01:14:29,950 --> 01:14:31,020
Thank you for that, Fred.

744
01:14:34,100 --> 01:14:35,160
Any questions for Henwick?

745
01:14:35,160 --> 01:14:43,860
All right. I appreciate it. Jason.

746
01:14:47,770 --> 01:14:52,690
Good morning again. Chair Tawny, Commissioner

747
01:14:52,690 --> 01:14:58,910
Perkins, Commissioner Power for the Record. My name is Jason Salman-Klotz. I'm also here

748
01:14:58,910 --> 01:14:59,970
here with several...

749
01:15:00,000 --> 01:15:05,320
Local PGE members, PGE staff members, all who worked on the distribution system plan, in case

750
01:15:05,320 --> 01:15:10,820
you have some technical questions that I cannot answer. They're here as well, so there's

751
01:15:10,820 --> 01:15:18,840
a larger contingent of PGE at this meeting, just so you're aware. Our first ESP was developed

752
01:15:18,840 --> 01:15:25,360
in 21. The development of those guidelines was in part led by a Rocky Mountain Institute

753
01:15:25,360 --> 01:15:32,500
stakeholder-led process. The initial focus of the DSP then was community-centered planning,

754
01:15:32,680 --> 01:15:37,120
specifically addressing social and community interests in the distribution system evolution.

755
01:15:37,960 --> 01:15:42,840
Subsequent guideline updates to a certain part by concerns over rising rates,

756
01:15:43,500 --> 01:15:47,680
shifted the DSP focus to system planning and increased transparency regarding

757
01:15:47,680 --> 01:15:56,280
project spending. Projects on spending. PGE filed our comprehensive 2024 DSP, shortly after

758
01:15:56,280 --> 01:16:03,140
Commission adopted its newest guidelines in November of 2024. We understood the guidelines would

759
01:16:03,140 --> 01:16:09,060
continue to evolve. Staff indicated that this plan was highly informative to them, clarifying

760
01:16:09,940 --> 01:16:17,420
our planning methods, technical approaches, and resource management. We submitted over 600 pages

761
01:16:17,680 --> 01:16:21,800
of information trying to be as transparent as possible.

762
01:16:22,000 --> 01:16:24,500
We have detailed budgets, project tracking,

763
01:16:24,840 --> 01:16:28,520
justifications for both short-term and long-term needs.

764
01:16:29,480 --> 01:16:31,140
After a 10 month review,

765
01:16:31,740 --> 01:16:34,840
staff is focused on clarifying what additional information

766
01:16:34,840 --> 01:16:37,880
they need and how to integrate that data

767
01:16:37,880 --> 01:16:40,100
into their assessment of distribution activities.

768
01:16:40,580 --> 01:16:44,260
We welcome continued deeper engagement to craft

769
01:16:44,260 --> 01:16:46,620
the next evolution of the DSP guidelines.

770
01:16:46,620 --> 01:16:49,920
We know that that is part of the work that's ahead of us.

771
01:16:50,640 --> 01:16:55,360
During the development of the DSP and development of the DSP guidelines,

772
01:16:55,720 --> 01:17:01,180
we offer to sit down with staff at a regular cadence to walk them through each of the projects that we have going on,

773
01:17:01,320 --> 01:17:08,060
how those projects have changed or evolved, other budgets have changed or how money has moved from one project to another,

774
01:17:08,240 --> 01:17:15,860
or how some projects may have been reduced in size or scoped or had to not go forward because of funding concerns.

775
01:17:20,860 --> 01:17:26,200
The commission staff in the utility should be planful about how best to evolve the distribution

776
01:17:26,200 --> 01:17:29,360
system and the business model of the utility.

777
01:17:30,220 --> 01:17:35,640
This is why we voluntarily created the benefit cost analysis within the 2024 GSB.

778
01:17:36,140 --> 01:17:44,300
It demonstrates the value that developing the distribution system into a bidirectional system

779
01:17:44,300 --> 01:17:48,560
provides to customers in the nearly two-to-one benefit to cost for issue.

780
01:17:50,160 --> 01:17:56,660
PGE views the BCAA as a qualification of a new service paradigm, establishing a long-term

781
01:17:56,660 --> 01:17:59,040
benefit to the grid monetization.

782
01:18:00,940 --> 01:18:06,500
I and the entire PGE team want to thank commission staff for their engagement.

783
01:18:07,120 --> 01:18:12,400
Their questions, the curiosity, the patients that they have brought to this review process,

784
01:18:12,400 --> 01:18:31,260
We've had countless meetings with staff working to better understand how PGE plans and our distribution system, how they operate, how we operate the system, what components provide, what services, what dependencies interdependencies, this is a very big, very complex system.

785
01:18:31,260 --> 01:18:36,800
and it's engineering, heavy, that your staff is trying to better understand and that we're

786
01:18:36,800 --> 01:18:41,280
trying to share with them and communicate with them about how that system works, what

787
01:18:41,280 --> 01:18:43,360
those dependencies, interdependencies are.

788
01:18:46,360 --> 01:18:50,680
We've held 21 public workshops since 2022.

789
01:18:51,900 --> 01:18:58,540
We've had six office hours and 2024 where any party, any stakeholder could come and ask

790
01:18:58,540 --> 01:19:04,960
questions. At those office hours we have the staff that's here at the commission meeting,

791
01:19:05,720 --> 01:19:10,980
engineers, planners there to answer any question that may have been brought up.

792
01:19:11,780 --> 01:19:19,000
All of this material, the presentations, recordings of the meetings, are catalogs and posted

793
01:19:19,000 --> 01:19:25,300
on the DSP website. We believe that this is just part of a strong regulatory process.

794
01:19:26,400 --> 01:19:32,860
We provided an appendix E to the distribution system plan, which yes has been carried over into a separate

795
01:19:32,860 --> 01:19:38,640
docket. That's how helpful it was with regard to how transparent the information are on technical

796
01:19:38,640 --> 01:19:45,080
information and spending information. That was provided through that appendix through the DSP. Yes, it was

797
01:19:45,080 --> 01:19:52,860
provided in a confidential manner, but any party that was part of this docket who adhered to confidentiality

798
01:19:52,860 --> 01:19:57,740
requirements was able to review that material. CUB had access to all of that

799
01:19:57,740 --> 01:19:59,420
material as to staff.

800
01:20:01,240 --> 01:20:21,280
We look forward to working with the Commission, staff, and stakeholders to evolve the next ESP guidelines, and to better understand how to direct investment to meet the operations and policy goals of the Commission and the utility. Thank you. Open for questions if you have any. Thank you.

801
01:20:22,820 --> 01:20:33,580
I am curious, you've responded to this, the transparency conversation in one way, but

802
01:20:33,580 --> 01:20:42,280
I didn't hear a discussion, for example, of taking in the sense of staff's interest

803
01:20:42,280 --> 01:20:50,760
in understanding why some projects were prioritized, how you sort of racked and stacked needs, for

804
01:20:50,760 --> 01:20:56,340
For example, and I'm curious how you're metabolizing or, you know,

805
01:20:56,420 --> 01:21:01,280
understanding sort of staff's asks for the next iteration.

806
01:21:04,160 --> 01:21:10,800
Yeah, so we did provide a great deal of information about our capital planning process and how

807
01:21:10,800 --> 01:21:15,560
decisions are made, how activities are ranked within the capital planning process.

808
01:21:15,780 --> 01:21:21,740
And I think what staff is curious to know is before items came to the capital planning process,

809
01:21:21,740 --> 01:21:23,620
How were some of those decisions made?

810
01:21:24,080 --> 01:21:26,440
What were some of the decisions that engineers were facing?

811
01:21:27,000 --> 01:21:31,140
What were the benefits and costs that they were looking at?

812
01:21:31,320 --> 01:21:33,120
What are the trade-offs they were trying to make,

813
01:21:33,220 --> 01:21:35,640
given the limited amount of capital funds that they had?

814
01:21:35,760 --> 01:21:40,340
How were they making decisions about prioritizing things before they got to the capital process?

815
01:21:40,900 --> 01:21:43,940
And I think, in part, that's what they're looking for,

816
01:21:44,740 --> 01:21:48,760
and what they've identified as missing from the distribution system plan.

817
01:21:48,760 --> 01:21:54,360
They're looking to go deeper than our capital planning process, which gives a kind of rank order

818
01:21:54,360 --> 01:21:59,160
for the activities, but they're wondering what was brought to the capital planning process,

819
01:21:59,340 --> 01:22:05,220
and how our decisions made pre-capital planning process. Those are fair questions to ask,

820
01:22:05,380 --> 01:22:10,840
and we certainly are trying to share with them as much information as we could after we submitted

821
01:22:10,840 --> 01:22:16,900
in these last nine months or so as to how are our engineers making some of those decisions and

822
01:22:16,900 --> 01:22:20,160
trade-offs, what information we could share with them.

823
01:22:20,740 --> 01:22:22,700
And so I think that's just part of the evolution.

824
01:22:23,040 --> 01:22:28,560
And I think it also goes to understanding how the utility functions, how the utility

825
01:22:28,560 --> 01:22:33,480
makes decisions, what questions to ask, what information to ask for, and how to ask for

826
01:22:33,480 --> 01:22:34,120
that information.

827
01:22:35,620 --> 01:22:40,880
As I said earlier in my comments, we were open to during the guideline process sitting down

828
01:22:40,880 --> 01:22:44,840
with staff and going through these projects on a regular cadence on a regular basis.

829
01:22:44,840 --> 01:22:46,620
and so they could see how these changes

830
01:22:46,620 --> 01:22:49,020
or how some of the decisions were being made.

831
01:22:49,520 --> 01:22:51,220
And certainly we'd like to have those conversations

832
01:22:51,220 --> 01:22:53,900
and the lead up to the next guideline development.

833
01:22:55,840 --> 01:22:56,780
Is that helpful?

834
01:22:57,840 --> 01:23:00,820
So what, I'm also curious to have points

835
01:23:00,820 --> 01:23:03,420
to wanting more quantitative metrics.

836
01:23:05,140 --> 01:23:09,360
And we had a conversation in the last two weeks ago

837
01:23:09,360 --> 01:23:11,140
about quantitative metrics and transparency.

838
01:23:12,380 --> 01:23:15,100
You know, you've done some work

839
01:23:15,100 --> 01:23:23,140
on cost-benefit analysis, but many of these projects are simply required and I'm curious,

840
01:23:23,920 --> 01:23:30,360
you know, how much more rigorous, how much further can we expect you to be utilizing

841
01:23:31,290 --> 01:23:41,180
that sort of analysis? And it matters because staff is pointing to how much faster than

842
01:23:41,180 --> 01:23:50,260
sort of depreciation, capitals being deployed here, and maybe that's okay if it's displacing

843
01:23:50,260 --> 01:23:55,840
some other capital expense or some other operational expense that would emerge otherwise, but

844
01:23:55,840 --> 01:24:03,960
we don't see that necessarily here. There's simply sort of required projects, and that

845
01:24:03,960 --> 01:24:10,540
That leaves us, I think, a little bit in the dark on the cost benefit equation, you know,

846
01:24:10,740 --> 01:24:11,900
what would it cost to not?

847
01:24:13,660 --> 01:24:14,140
Yeah.

848
01:24:14,280 --> 01:24:15,160
I hear you on that.

849
01:24:15,260 --> 01:24:19,800
And I also think that goes to part of the non-wire solutions discussions that we're having

850
01:24:19,800 --> 01:24:21,100
as it's a related item.

851
01:24:23,420 --> 01:24:28,560
We conducted a cost benefit analysis on part of the investments in the DSP that was voluntary.

852
01:24:29,720 --> 01:24:34,120
The cost benefit analysis wasn't something required by the guidelines.

853
01:24:35,920 --> 01:24:42,560
Subsequent to submitting the DSP, staff started asking for information around

854
01:24:43,120 --> 01:24:46,600
a kind of cost benefit or risk informed decision making.

855
01:24:46,860 --> 01:24:48,620
We've provided some of that information.

856
01:24:49,240 --> 01:24:52,800
The risk informed decision making is a new process for us

857
01:24:52,800 --> 01:24:56,000
and it does give you the kind of quantitative information you're looking for.

858
01:24:56,000 --> 01:24:59,420
It was developed after.

859
01:25:00,000 --> 01:25:29,940
We were developing this distribution system plan and submitted this distribution system plan. It is a process and a metric that is being incorporated into our practices here at PGE. As we speak, it has not been completely finalized. We have given staff an insight into how the risk informed decision making mechanism works, how it's constructed, it's various components and factors. And we anticipate being able to use that in the next distribution system plan, which I think is going to give you

860
01:25:29,940 --> 01:25:35,660
In large part, what it is that you're looking for because it is a type of benefit cost analysis,

861
01:25:35,740 --> 01:25:41,600
although it is not wholly similar to the benefit cost analysis that you're used to seeing

862
01:25:41,600 --> 01:25:46,580
in energy efficiency or other demand response or other DSM investments.

863
01:25:48,880 --> 01:25:51,660
Okay, I appreciate that.

864
01:25:52,020 --> 01:25:54,340
Colleagues, questions for Jason?

865
01:25:54,340 --> 01:25:55,380
I

866
01:25:59,350 --> 01:26:08,050
appreciate the explanation of how EGE moved through the process still troubled by not

867
01:26:08,050 --> 01:26:12,170
getting the information staff, not getting the information they were requesting. I think

868
01:26:12,170 --> 01:26:19,130
you're setting a pretty high bar for our expectations for the next iteration, and I'm really

869
01:26:19,130 --> 01:26:25,150
hoping that you meet that. But I think it is an evolution, recognize that this process has

870
01:26:25,150 --> 01:26:40,930
has been evolving and the expectations have been evolving, but I just want to make it clear that you're setting a pretty high bar for the expectations and we're going to have high expectations in the next iteration of the DSP.

871
01:26:41,570 --> 01:26:52,170
I also want to challenge you a little bit in what you said about being willing to meet with staff all along the way to provide information on specific projects.

872
01:26:52,170 --> 01:26:55,910
If you were willing to do that, you should have been willing to provide that information

873
01:26:55,910 --> 01:27:00,730
in the document itself because you basically would be discussing that information.

874
01:27:01,090 --> 01:27:07,250
So, there's also type requirements, and it's obviously our staff is eccapacity.

875
01:27:07,410 --> 01:27:13,010
I know you guys also experience a lot of work and probably not enough capacity to get it done.

876
01:27:13,370 --> 01:27:16,410
So there's an efficiency side of that piece too.

877
01:27:18,170 --> 01:27:23,390
Okay. Thank you for the comments. I hear what you're saying. We have worked with staff

878
01:27:23,390 --> 01:27:28,990
as much as we can. If there's information that's been missing, I'm, you know, that they've

879
01:27:28,990 --> 01:27:30,830
asked for recently. I'm unaware of it.

880
01:27:36,000 --> 01:27:40,760
I guess my reading of staff's report pointed out lots

881
01:27:40,760 --> 01:27:54,100
of holes and then requests and unmet information requests. So I'm going by what has been in the

882
01:27:54,100 --> 01:27:59,600
staff report and reading through the record. So I think what I'm saying is my expectation is

883
01:27:59,600 --> 01:28:08,580
as we move into the next DSP that I don't want to see us going through this same discussion in the

884
01:28:08,580 --> 01:28:14,460
next round. My expectation is is that we will have a smoother process and that we will

885
01:28:14,460 --> 01:28:18,220
have the information we need, and staff will have the information they need to feel comfortable

886
01:28:18,220 --> 01:28:19,140
with what's put forward.

887
01:28:22,790 --> 01:28:26,450
Thanks for that Commissioner Perkins. Commissioner

888
01:28:26,450 --> 01:28:34,750
Power, any questions for the company? No. Okay. Jason, one last sort of piece I'm wondering how you're

889
01:28:34,750 --> 01:28:42,870
digesting. I see staff really pointing to continued maturity around the distribution system plan,

890
01:28:43,510 --> 01:28:47,690
the feedback loop that needs to happen with the integrated resource plan.

891
01:28:48,290 --> 01:28:53,270
So the distribution system is clearly going to be this why we've done this process

892
01:28:54,190 --> 01:28:59,190
and why we worked so hard to get out in front of distribution system planning. It is clearly going

893
01:28:59,190 --> 01:29:01,650
to be a key part of the resource stack.

894
01:29:03,670 --> 01:29:06,730
There's no question about that, that's our rules totally aside.

895
01:29:06,910 --> 01:29:12,670
It's going to be a clear part of how we get to reliability and decarbonized, a decarbonized

896
01:29:12,670 --> 01:29:13,150
system.

897
01:29:13,430 --> 01:29:21,570
I'm curious how you were thinking about or what you can take away from how you've matured

898
01:29:21,570 --> 01:29:27,410
your distribution system plan, how you plan to further mature your distribution system planning

899
01:29:27,950 --> 01:29:34,070
into the IRP process, where you're looking at connection points there.

900
01:29:36,670 --> 01:29:43,530
So our lead for Integrated Resource Planning at Jim Lindsay, I believe, is on the phone

901
01:29:43,530 --> 01:29:46,210
would it be all right if I ask him to respond to that question?

902
01:29:46,410 --> 01:29:47,930
I'm great to hear how Jim is thinking about it.

903
01:29:48,010 --> 01:29:53,570
So I hear, for example, Jimmie staff really asking, can't the IRP program modeling

904
01:29:55,030 --> 01:29:59,970
not just take a number for the VPP, but sort of tell you what a number might be for the VPP.

905
01:30:00,000 --> 01:30:29,860
The VPP based on, avoid, you know, avoid a cost, for example. So I'm curious how you're internalizing their, their feedback there. Thanks, Chair, Tony, commissioners, for the record. My name is Jimmy Lindsay, and I direct a resource planning activities, including our Integrated Resource Plan Clean Energy Plan. And yes, we reviewed staff's suggestions regarding incorporation of our sort of VPP measures into the

906
01:30:29,860 --> 01:30:35,780
IRP and we've been thinking directly about how can we, you know, be responsive to that feedback

907
01:30:35,780 --> 01:30:44,220
in the 26 IRP and I think you're right to sort of point out the past practice is, you know,

908
01:30:44,280 --> 01:30:50,000
attempting to like embed a certain amount of cost effective, you know, measures regarding

909
01:30:50,000 --> 01:30:59,520
flexible load and distributed storage and, you know, rooftop solar into our

910
01:30:59,520 --> 01:31:07,260
forecasts using a adopter tool. And we've been reflecting internally since

911
01:31:07,260 --> 01:31:10,460
receiving this staff report about, you know, how can be responsive to having

912
01:31:10,460 --> 01:31:15,160
the selection occurs, sort of more indulgenously or within the IRP models

913
01:31:15,160 --> 01:31:19,980
themselves. And that is something that we're looking to be responsive to in

914
01:31:19,980 --> 01:31:28,060
the 26-IRP and look to kind of, you know, first arrive at our methodological approach and

915
01:31:28,060 --> 01:31:33,060
share it with staff and look to successfully introduce it to the 26-IRP. I can't say

916
01:31:33,060 --> 01:31:41,120
that, you know, at this moment we've sort of identified the exact clear path on the methodology

917
01:31:41,120 --> 01:31:47,920
but I can say that that is something that we intend to be responsive to, look to kind of

918
01:31:47,920 --> 01:31:54,460
collaborate with staff and hopefully find some innovations here that are easy to implement in

919
01:31:54,460 --> 01:32:01,680
our responsive. And so that's what we intend to do. I think one sort of note that'll just make is

920
01:32:02,620 --> 01:32:08,680
the DSP and the IRP-CEP that these are iterative, cyclical things, something we tend to do

921
01:32:09,170 --> 01:32:17,260
you know every year. And I think we can make good progress in this 26IRP. You know it might sound

922
01:32:17,260 --> 01:32:23,980
And silly, it's, you know, the 26IRP's not due for another eight months, but just when

923
01:32:23,980 --> 01:32:30,540
we think about really substantive methodological changes, that can take a fair bit of time

924
01:32:30,540 --> 01:32:36,860
to develop, share with the audience, get feedback, perform, write about.

925
01:32:37,780 --> 01:32:42,080
And so we're starting now to try to make it within that timeline, but it's, you may see

926
01:32:42,080 --> 01:32:46,240
Yes, sort of improving in a couple of stepwise functions

927
01:32:46,240 --> 01:32:48,480
over the upcoming planning cycles.

928
01:32:49,020 --> 01:32:53,120
But my intention is to have sort of a good first response

929
01:32:53,120 --> 01:32:56,360
to staff in the commission in the 26th IRP.

930
01:32:57,760 --> 01:32:58,680
I appreciate that.

931
01:32:58,920 --> 01:33:01,580
You made significant progress in how you thought

932
01:33:01,580 --> 01:33:03,420
about energy efficiency, for example,

933
01:33:03,520 --> 01:33:07,700
taking ETO's number and also endogenously selecting

934
01:33:07,700 --> 01:33:09,620
energy efficiency over and above that

935
01:33:09,620 --> 01:33:17,420
that really gave us an early signal at how much more energy efficiency we might need to look to.

936
01:33:17,920 --> 01:33:26,280
I think given the uncertainties you're facing on BPA timelines, on transmission more generally

937
01:33:26,280 --> 01:33:35,080
into the BA, really thinking about the IRP in terms of scenarios and test cases that give us sort of

938
01:33:35,080 --> 01:33:42,780
as opposed to point forecasts is going to be really important in the face of the uncertainty that you have and from that perspective,

939
01:33:43,900 --> 01:33:49,220
you know, running some versions that give us some endogenous selection, you know, can be really important.

940
01:33:49,620 --> 01:33:51,940
So it doesn't, it's not all or nothing in my view.

941
01:33:51,940 --> 01:33:59,260
I think there's a lot that you can get from different sort of runs that give us different worlds and different futures.

942
01:33:59,260 --> 01:34:07,180
If there's a future where the BPA projects don't come together, then how much DER is selected, for example.

943
01:34:08,200 --> 01:34:16,400
But I appreciate that you're thinking about how to keep these processes in forming each other.

944
01:34:16,680 --> 01:34:24,080
Because I think that's the key for me in doing this process, is that they're in forming each other as we go along.

945
01:34:25,680 --> 01:34:27,240
Thank you for the question.

946
01:34:28,800 --> 01:34:31,800
All right. Any further dialogue with the company?

947
01:34:37,550 --> 01:34:39,470
Thank you, Jason. Thank you.

948
01:34:42,610 --> 01:34:49,630
All right. Anything that you'd like to go back to staff with or anyone else follow up questions?

949
01:34:51,230 --> 01:34:53,330
No, all right. Great.

950
01:34:56,350 --> 01:34:59,270
So from my perspective,

951
01:34:59,270 --> 01:34:59,510
and

952
01:35:01,620 --> 01:35:31,540
Distribution system planning is essential because it is both the single largest sort of source of capital spend. And also there are many hopes and dreams for how much it's going to contribute to the generation stack to reliability from that perspective to resilience. There are many hopes and dreams pinned on.

953
01:35:31,540 --> 01:35:39,640
the distribution system that are essential for decarbonizing and providing reliability in a

954
01:35:40,740 --> 01:35:42,200
challenged regional grid.

955
01:35:44,420 --> 01:35:50,780
And you know I see a lot of movement from you know in the smart grid

956
01:35:52,020 --> 01:35:59,000
land and ending some of the first distribution system efforts a lot of sort of chasing

957
01:35:59,000 --> 01:36:06,020
Chinese objects, but hard to see how they all connected, hard to see how they

958
01:36:06,020 --> 01:36:11,480
reinforced each other, how they delivered customer value. And that has improved.

959
01:36:11,820 --> 01:36:16,640
And I'm excited to hear about the risk-informed decision-making, because I would

960
01:36:16,640 --> 01:36:22,500
argue that is the commission pushing the company to be disciplined on the company

961
01:36:22,500 --> 01:36:26,680
responding and putting in a discipline mechanism, is it as far along as I'd

962
01:36:26,680 --> 01:36:31,880
like, probably not. But I see that feedback loop, that positive feedback loop happening

963
01:36:31,880 --> 01:36:42,520
and that that gives me hope for where we're headed. I am frustrated by that sort of talking

964
01:36:42,520 --> 01:36:47,360
past each other. I see the companies sort of feeling they've been responsive to data requests

965
01:36:47,360 --> 01:36:54,280
and staff articulating real gaps in analytical work. I see that same conversation happening

966
01:36:54,280 --> 01:37:00,640
in the wildfire space. I see the same conversation happening in a variety of venues.

967
01:37:02,340 --> 01:37:07,560
And I'm not quite sure how to, the company is answering very literally. And I think staff's

968
01:37:07,560 --> 01:37:14,800
asking more strategic questions. The company is struggling to answer. And so I look forward

969
01:37:14,800 --> 01:37:21,920
to staff in the company continuing to try to bridge that. And I'm happy for the commission to weigh in

970
01:37:21,920 --> 01:37:26,660
and support bridging that, talking past each other challenge that I'm observing.

971
01:37:28,160 --> 01:37:34,740
But in general, I'm comfortable accepting this plan, recognizing we are on a journey

972
01:37:34,740 --> 01:37:41,320
and we expect to your point, Commissioner Perkins, the continuous improvement that's laid

973
01:37:41,320 --> 01:37:48,820
out here, and that's with that sort of continued hope of improvement in meeting the challenge

974
01:37:48,820 --> 01:37:54,920
that I'm comfortable accepting what we have in front of us, but I'm really open to other

975
01:37:54,920 --> 01:37:57,440
perspectives if there's a different view.

976
01:38:00,020 --> 01:38:02,320
Oh, Cheritani, I appreciate your comments,

977
01:38:02,780 --> 01:38:09,460
and your articulation of the importance of the distribution system in addressing a range of needs.

978
01:38:11,580 --> 01:38:18,200
I have been feeling more and more sense of urgency in figuring out how we meet those challenges

979
01:38:18,200 --> 01:38:24,720
and also understanding the possible future scenarios, like you said, if this doesn't happen,

980
01:38:24,920 --> 01:38:30,040
then what does that mean over here? And that's what we need to really understand, but we also

981
01:38:30,040 --> 01:38:36,820
very much need to understand how that affects ratepayers. Are we making wise decisions

982
01:38:37,860 --> 01:38:43,660
that both give the benefit to the system but also are cost effective? And it's a challenge. And

983
01:38:43,660 --> 01:38:47,980
we're seeing this, like you said, in multiple dockets where we're trying to figure out strategically

984
01:38:48,200 --> 01:38:53,780
in a very rapidly changing environment what our options are moving forward so

985
01:38:53,780 --> 01:39:00,160
that we can so the company and we as regulators can be making good well-informed

986
01:39:00,160 --> 01:39:04,980
decisions and that's I think we're my frustration around not seeing information

987
01:39:04,980 --> 01:39:10,780
that we need comes from and yes we need to not talk best each other we need to be

988
01:39:10,780 --> 01:39:17,120
working in the same direction but both the company and us regulators need to be

989
01:39:17,120 --> 01:39:23,180
thinking strategically and in thinking about what the potential options are in the future and

990
01:39:23,180 --> 01:39:27,460
what those scenarios might be because there are a lot of different things that can happen

991
01:39:27,980 --> 01:39:33,520
and have been happening. So that's where my frustration comes from. I appreciate the progress

992
01:39:33,520 --> 01:39:39,620
that's been made from previous iterations. Is it exactly what I want to see? No. I've been

993
01:39:39,620 --> 01:39:45,800
likely to see exactly what I want to see every time. No. But like you said, I want to see that

994
01:39:45,800 --> 01:39:51,920
continuous improvement and I want to see a better alignment between the company and staff

995
01:39:51,920 --> 01:39:55,380
in terms of expectations and information that's put forward.

996
01:39:55,380 --> 01:39:59,960
So I, I am.

997
01:40:00,000 --> 01:40:28,280
I'm willing to accept what's put before us, but like I said, with the expectation of things being different in the next go round. And just to the comments around concerns about how we determine where we are in a cost recovery setting, I just want to lay it out there that this is not cost recovery. This is simply a distribution system plan, and it does not dictate decisions that we make in cost recovery dockets. I

998
01:40:33,430 --> 01:40:34,930
think you too have a lot covered it.

999
01:40:34,930 --> 01:40:37,190
I don't have anything for other to add.

1000
01:40:39,410 --> 01:40:41,670
I will prepare to accept a motion then.

1001
01:40:44,550 --> 01:40:48,950
I will move that we accept PGE's distribution system then.

1002
01:40:50,230 --> 01:40:50,650
I'll second.

1003
01:40:51,650 --> 01:40:54,170
I'll concur, and the motion is adopted.

1004
01:40:54,990 --> 01:40:58,230
We'll look forward to the next revision, as well as the IRP.

1005
01:40:59,650 --> 01:40:59,810
All right.

1006
01:41:00,690 --> 01:41:02,750
I think that's all on our agenda.

1007
01:41:02,750 --> 01:41:07,590
I'll see if there's anything further that needs to come before us this morning hearing

1008
01:41:08,900 --> 01:41:09,460
nothing.

1009
01:41:09,840 --> 01:41:10,680
Thank you all.

1010
01:41:10,680 --> 01:41:11,600
We are adjourned.