Agencies, Commissions, Boards Involved:
Public Utility Commission (PUC); Oregon Department of Energy (ODOE) 

POSITIVE_SIGN.pngWhat’s going well:

The Public Utility Commission (PUC) published a very thorough work plan outlining its OCAP implementation, which included proposals related to greenhouse gas reduction, impacted communities, wildfire and process and public engagement. 

In developing the work plan, the PUC demonstrated a commitment to facilitating a robust, transparent public engagement process. The PUC provided ample opportunity for public comment, and--importantly--incorporated the public input it received to inform its proposal. For example, the PUC has committed to examining resource adequacy and the future role of natural gas as part of new dockets--both actions that stakeholders pushed for which were not included in the PUC’s preliminary work plan.

The PUC’s OCAP implementation work plan identified a commitment to enhancing equitable outcomes and increasing collaboration with advisory groups focused on equity and environmental justice. These activities will be developed and implemented under the direction of the PUC’s Director for Diversity, Equity and Inclusion-- a new position the PUC created as part of its efforts to prioritize equitable outcomes under OCAP. 

The PUC also included in its work plan a number of proposed actions to support GHG reduction, including: 

  • Expanded use of the social cost of carbon in integrated resource plan (IRP) guidelines and across PUC activities;
  • Initiatives to reduce life-cycle greenhouse gas emissions from natural gas;
  • Community-wide green tariffs targeting utilities’ greenhouse gas emission reductions; and
  • Prioritization of clean resources and appropriate valuation of their system contributions, especially when deployed to support low-and moderate-income customers. 

The PUC also adopted distribution system planning guidelines, an important first step in promoting a more accessible distribution grid. Separate from the work plan, our coalition was pleased that the PUC decided to extend the moratorium on utility shut-offs for customers unable to pay their bills to June 2021. 

Finally, as part of its work to prioritize climate and greenhouse gas emissions reductions in decision-making, the Oregon Department of Energy (ODOE) updated the rate new energy facilities must contribute under the Energy Facility Siting Council’s Carbon Standard on climate pollution for new power plants.

Areas for improvement:

The PUC has not indicated a commitment to prioritizing proposed actions to reach OCAP targets and reduce climate emissions and advance equitable outcomes. After the strong work plan, most of the actions identified have been delayed for months and/or don’t have identified start dates, and most work on emissions reduction has happened internally. The longer it takes to go through the necessary, deliberative processes, the longer it will be before the PUC to move beyond “pilot mentality” to comprehensive programs that prioritize greenhouse gas emissions reductions. 

Unfortunately, the PUC has also pushed back a number of timelines for various OCAP implementation work. Our groups recognize that the PUC has needed to allocate resources and staff capacity to carrying out its COVID-19 stipulation, and that there have been significant delays due to wildfires and ice storms.  We commend the PUC for hiring a Director of Diversity, Equity and Inclusion, which we understand has affected timelines for OCAP implementation, including related to energy burden issues.

Further, we were disappointed that the PUC did not include local generation--including solar, storage, and microgrids--as an appropriate response to improve community resilience or respond to wildfires. We will continue to push for local generation and resilience, as well as meaningful engagement with affected communities, in the context of the PUC’s wildfire mitigation plans.

Last but not least, we are concerned that the PUC has not committed to a start date for a Future of Gas proceeding that should explore, among other things, how to achieve our state’s greenhouse gas goals, and how best to protect consumers from stranded assets of existing fossil fuel infrastructure. As Oregon transitions off fossil fuels, gas utilities--along with their regulators and customers--will continue to face rising infrastructure costs of an aging gas system. The PUC should prioritize assessing the future of fossil gas to avoid stranded costs and cost effectively protect remaining gas customers--and specifically low-income ratepayers--from increasing rate impacts.  

Opportunities for progress:

With a number of ongoing dockets and proceedings upcoming in 2021, there are many opportunities to advance equitable outcomes and emissions reductions from Oregon’s utilities. In the coming months, our coalition will continue to push the PUC to:

  • Prioritize processes identified in the EO work plan to start and complete without further delay.
  • Open a proceeding to specifically assess the future role of fossil gas in Oregon.
  • Further commit to systematically incorporating the social cost of carbon through a public process.
  • Expand an intervenor funding system to support community-based organizations that will be involved in implementing adopted work plans.
  • Better illustrate how the public could engage on data and Integrated Resource Planning (IRP)-related implementation.
  • Help expand clean, affordable and equitable access to transportation electrification (TE), and identify barriers to TE and methods to provide benefits to low-income, BIPOC and underserved customers.
  • Publish explanatory briefings and other public-facing documents in a timely and accessible fashion.
  • Provide timely, accessible data for distributed resources and energy usage in a timely fashion.

Return to the full progress report