On March 31, 2026, the Oregon Public Utility Commission (Commission) approved PacifiCorp’s Tier 5 interconnection proposal for qualifying facility small generators with modifications. Many stakeholders, including Commission Staff, Community Renewable Energy Association, Oregon Solar + Storage Industrias Association, Renewable Energy Coalition, and WynneWorks LLC advocated for changes to PacifiCorp’s Tier 5 proposal. The Commission issued Order No. 26-109 on April 1, 2026 adopting Staff’s recommendations.
PacifiCorp was directed to file revised small generator interconnection procedures. In compliance with this direction, PacifiCorp proposed a Tier 5 that is intended to allow small generators that will likely not result in transmission-related Network Upgrades to bypass PacifiCorp’s cluster study and be studied serially. This is will hopefully allow more projects to be interconnected. The Commission directed PacifiCorp to make a number of changes to its proposal.
First, the Commission directed PacifiCorp to revise its Tier 5 proposal for small generators so that projects would be studied as Energy Resource Interconnection Service (ERIS) similar to how projects in the Oregon Community Solar Program are studied. Tier 5 eligibility is also limited to projects 10 MW or less.
Second, the Commission modified the Tier 5 Minimum Daytime Load (MDL) screen such that the small generator’s capacity, together with all other existing and proposed generation in the local area, must be less than 100 percent of the MDL of the relevant substation.
Third, the Commission directed PacifiCorp to update data related to MDL at least twice a year. This data can be used by interconnection customers to determine potential size for projects at various locations that could utilize the Tier 5 interconnection process.
Finally, 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 in Docket No. AR 683 so that it will apply to all utilities including Portland General Electric Company and Idaho Power Company. 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 Oregon Solar + Storage Industries Association and the Renewable Energy Coalition in the proceedings.
The Oregon Solar + Storage Industries Association advocates for clean, renewable, solar technologies. OSSIA members include businesses, non-profit groups, and other solar industry stakeholders.
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.
