On January 8 and September 4, 2025, the Oregon Public Utility Commission (Commission) approved revised small and large generator interconnection procedures (SGIP and LGIP) for Qualifying Facilities (QFs) for Oregon’s three investor-owned utilities, Portland General Electric Company (PGE), PacifiCorp, and Idaho Power Company (Idaho Power). These filings were necessary to bring the utilities in compliance with the Federal Energy Regulatory Commission’s (FERC) Order Nos. 2023 and 2023-A, which mandated revisions to the utilities’ Large Generator Interconnection Agreements (LGIAs) and LGIPs. Many stakeholders, including Commission Staff, Community Renewable Energy Association, Oregon Solar + Storage Industries Association, Renewable Energy Coalition lobbied for greater alignment with the FERC-approved agreements and procedures.
In Order No. 25-005 in Docket No. UM 2346, the Commission approved PGE’s proposal to shift state-jurisdictional interconnections over 20 megawatts (MW) to a cluster-study process aligned with FERC Order 2023, adopting Staff’s recommendation with four modifications. Stakeholders supported greater alignment between PGE’s state and federal interconnection rules but raised concerns about withdrawal penalties, restrictions on adding storage, missing study-delay penalty references, and omitted LGIA provisions from FERC Order 845 (surplus interconnection, provisional service, technology advancement, and option-to-build). The Commission agreed with the stakeholders’ recommended removal of language that limited adding non-QF storage and extending study-delay cross-references. The Commission ultimately declined to restore PGE’s earlier deletions of FERC Order 845-related LGIA sections. Staff found FERC’s withdrawal-penalty safeguards sufficient and recommended adopting the FERC penalty structure without caps.
In Order No. 25-355 in Docket No. UM 2351, the Commission approved PacifiCorp’s revised QF LGIP and LGIA aligning Oregon interconnections with FERC Orders 2023 and 2023-A, again following Staff’s recommendations. Stakeholders emphasized that the cluster process was disadvantaging small Oregon projects and recommended a separate small-generator path, capped withdrawal penalties, better study-delay penalties, and inclusion of non-financial readiness options and FERC Order 845 reforms. The Commission agreed that small, distribution-connected generators were being stranded and recommended a new streamlined interconnection option modeled on the Community Solar Program, to be proposed within 60 days. The Commission again rejected penalty caps but required PacifiCorp to add the missing FERC penalty and readiness provisions and to incorporate certain FERC 845 elements, including surplus interconnection use, provisional interconnection service, and option-to-build languages.
In Order No. 25-006 in Docket No. UM 2349, the Commission approved Idaho Power’s new procedures and agreements that convert from a serial to cluster-study approach for QFs larger than 20 MW. Stakeholders pressed for parity between QFs and non-QFs, requesting inclusion of FERC-mandated utility penalties for late studies, capped withdrawal penalties, affected-system procedures, storage provisions, and full adoption of FERC Order 845 reforms (surplus interconnection, provisional interconnection service, permissible technology advancement, and option to build). Additionally, the proposed LGIA provides a ten-year term, after which the customer can renew in one-year increments if they provide notice of intent to renew and the Company does not identify a material change in circumstances that requires a new LGIA. Stakeholders argued that the FERC-approved LGIA does not require notice and includes no provision to account for material changes. The Commission agreed with most stakeholders’ positions except on storage, which the Commission deferred to another docket, and capped withdrawal penalties. The final order required Idaho Power to add study-delay penalties, equal term flexibility, affected-system provisions, capacity-reduction language, and some FERC Order 845 elements including surplus interconnection, permissible technology advancement, and option to build.
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.
