On March 31, 2026, the Oregon Public Utility Commission (Commission) adopted temporary rules related to small generator interconnection in response to Oregon Executive Orders (EO) 25-25 and 25-29. Many stakeholders, including the Renewable Energy Coalition, Oregon Solar + Storage Industries Association, Interstate Renewable Energy Council, Portland General Electric Company, and PacifiCorp, advocated for changes to Commission Staff’s proposed temporary small generator interconnection rules. The Commission issued Order No. 26-108 on April 1, 2026 adopting Staff’s recommendations.
EOs 25-25 and 25-29 direct the Commission and other agencies to accelerate development of solar and wind energy projects in Oregon that seek to qualify for federal clean energy tax credits and encourage the Commission to find opportunities to use its scope and authority to accelerate clean energy procurement. Commission Staff opened this temporary rulemaking to adopt rules to implement the EOs related to interconnection of small generators.
First, the rules formalized an opportunity for small generators to use third-party consultants to complete the System Impact Study (SIS). Small generators previously could have a third party complete the SIS, but the utility had to agree. The rules now give the small generator the right to have a third party complete the SIS. The rules also established guidelines for data sharing, required a liaison between the utility and interconnection customer to answer any questions about the third-party SIS, and timelines and processes for the utility reviewing the third-party SIS.
Second, the rules established 45 business day timelines for the SIS and Facilities Study. If the timeline is not met for the SIS, the applicant’s cost for the study will be reduced. When the delay is no more than 15 business days, the cost of the study will be reduced by 50 percent. When the delay exceeds 15 business days, the cost of the study will be reduced by 100 percent. The utility will be required to file a report with the Commission for any study that is provided to the applicant after 45 business days. However, the utility can request a waiver from the study timelines for good cause.
Third, the rules established a 600-day construction timeline. The option for a small generator to self-build is allowed if the utility will not meet the 600-day timeline. However, the utility can request a waiver from the construction timeline for good cause. Several interconnection stakeholders argued for a shorter construction timeline, but the Commission did not adopt a shorter timeline. Additionally, if the utility cannot interconnect the small generator within the 600-day timeline, then the small generator’s cost of interconnection studies and construction will be reduced.
Fourth, the Commission adopted a Limited Operation framework so that projects could operate at a limited capacity while upgrades were finalized in order to take advantage of expiring federal tax credits. The Commission decided to adopt the Limited Operation framework first introduced in Docket No. UM 2351 so that it applies to all utilities. Interconnection customers proposed revisions to the Limited Operation framework, but those changes will be addressed later in AR 683 or Docket No. UM 2111.
Sanger Green represented the Renewable Energy Coalition in the proceedings.
The Renewable Energy Coalition is an organization whose members include irrigation districts, water districts, corporations, small utilities, and individuals who own and operate nearly fifty qualifying facilities – small renewable energy generators that operate under the federal Public Utility Regulatory Policies Act. The Coalition advocates to ensure that small renewable generation projects continue to make an important contribution to the Northwest’s energy future.
Disclaimer
These materials are intended to as informational and are not to be considered legal advice or legal opinion, nor do they create a lawyer-client relationship. Information included about previous case results does not assure a similar future result.
