UE 452

The key events and submissions scheduled in the Portland General Electric (PGE) 2026 annual power cost update tariff (UE 452) proceeding are as follows:

- April 1, 2025: PGE filed its 2026 annual power cost update tariff.
- April 2, 2025: The Administrative Law Judge (ALJ) issued a memorandum requesting parties to confer and file a jointly proposed procedural schedule by April 15, 2025.
- April 15, 2025: PGE filed a jointly proposed procedural schedule after conferring with other parties.
- May 22, 2025: Workshop to walk through the initial step-log.
- June 23, 2025: Staff and intervenors’ opening testimony due.
- July 8, 2025: Settlement conference.
- July 15, 2025: Monet update.
- July 23, 2025: PGE reply testimony due.
- July 24, 2025: Responses to data requests shortened to 5 business days or best effort.
- August 1, 2025: Settlement conference.
- August 18, 2025: Staff and intervenors’ rebuttal testimony due.
- August 22, 2025: Settlement conference.
- September 5, 2025: PGE surrebuttal testimony filed (no later than 2:00 pm).
- September 8, 2025: Best effort response deadline for data requests submitted by 5:00 pm.
- September 12, 2025: Best effort response deadline for data requests.
- September 15, 2025: All parties cross-examination statements and hearing exhibits due.
- September 18, 2025: Hearing.
- September 25, 2025: All parties opening brief due.
- October 1, 2025: Monet update.
- October 2, 2025: Staff and intervenors’ reply briefs due.
- October 8, 2025: PGE final brief due.
- November 6, 2025: Target date for commission decision and monet update.
- November 17, 2025: Final monet update.

Settlement conference dates may be adjusted as agreed to by the parties without prior commission approval 1, 1, 1.

Docket UE 452 concerns Portland General Electric’s (PGE) 2026 Annual Power Cost Update (APCU) and Annual Update Tariff (AUT) filings before the Oregon Public Utility Commission. The proceeding reviews PGE’s forecast of net variable power costs (NVPC), the supporting documentation, and the impacts on customer rates effective January 1, 2026. The docket involves:

- Evaluation of PGE’s NVPC forecast, which increased to $48.3/MWh for 2026 (up from $45.6/MWh in 2025), primarily due to anticipated BPA transmission rate increases ($24.6 million) and new federal tariffs on Canadian natural gas ($16.8 million) 1.
- Review of compliance with prior commission orders and guidelines, including requirements for transparency, customer communication, and the provision of non-confidential summaries of power cost forecasts 2, 2.
- Consideration of PGE’s modeling methodology (including use of the Monet model) and planned updates, such as contract updates, load forecasts, and forward curves, with further filings expected in July, October, and November 2025 1, 2.
- Discussion of capacity needs, resource acquisition, and issues such as the treatment of costs related to the Washington Cap-and-Invest Program and the inclusion or deferral of related expenses 1, 2.
- Analysis of rate impacts, including a proposed $50.61 million increase in Schedule 125 prices and corresponding adjustments to other rate schedules 1.
- Use of a general protective order to designate certain filings and workpapers as confidential due to sensitive market and contract information 3.

The docket includes input from commission staff, intervenors, and PGE, addressing modeling assumptions, regulatory compliance, and ratepayer impacts. Final tariff prices and updates will be filed in November 2025, with ongoing opportunities for review and adjustments throughout the process.

The main financial and timeline risks and concerns discussed in this docket include:

Financial Risks:
- The 2026 net variable power cost (NVPC) forecast per-unit cost is $48.3/MWh, which is $2.67 higher than the 2025 forecast. The primary drivers are:
- An anticipated $24.6 million increase due to pending BPA transmission rate updates.
- A $16.8 million increase from federal tariffs on Canadian natural gas imports, with PGE unable to substitute this gas supply due to lack of alternatives. These costs are expected to be fully passed on to PGE by Canadian sellers 1, 1.
- The Seaside BESS investment, if included, is forecast to increase cost of service revenues by 1.5% (about $46.6 million) and result in a 1.3% bill increase for an average residential customer. However, the prudence and reasonableness of this recovery are still under review in a separate docket, introducing uncertainty over cost recovery 2.
- Washington Cap-and-Invest (CCA) compliance costs are not being forecasted due to their high uncertainty; instead, actual costs are being deferred for later recovery, with future rulemaking possibly impacting exposure and timing 1, 2.

Timeline Risks and Concerns:
- PGE's NVPC filings involve several updates throughout the year, including major updates by July 15, October 1, November 6, and November 15, which could affect the final rates and forecasts. These multiple update cycles create timing risk for finalizing rates and cost recovery 1, 2.
- The timeline for Seaside BESS cost recovery is uncertain because inclusion in customer rates depends on a separate expedited filing and commission approval, which has not yet occurred 1.
- Ongoing federal and state policy changes (e.g., tariffs, Washington CCA rulemaking, linkage with other carbon markets) introduce further timing and regulatory risk for forecasting and cost recovery 1, 1.

In summary, key risks include significant cost increases due to transmission rates and tariffs, uncertainty and deferral around carbon compliance costs, pending regulatory approvals for major investments, and a complex, multi-stage update process that can delay rate finalization.

The docket identifies several areas of growth for Portland General Electric (PGE) in the 2026 test year, with key considerations for each:

1. Retail Load Growth and Energy Deliveries:
- The 2026 retail load forecast is based on the September 2024 forecast, which reflects anticipated economic conditions in Oregon, operational changes among large customers, savings from new energy efficiency (EE) programs, and expected increases in electric vehicle (EV) adoption, building electrification, and customer-sited solar generation.
- Key considerations:
- The forecast excludes deliveries to direct access customers and is grossed-up for line losses before input into the power cost model.
- The growth is driven not only by economic activity but also by policy and technological shifts such as electrification and distributed energy resources 1.

2. Integration of Renewable Energy and Market Participation:
- PGE identifies participation in the California Independent System Operator's extended day-ahead market (EDAM) as a strategic growth area, expected to provide customer benefits ($6.1–17.5 million compared to $8.3–8.7 million in the Markets+ alternative).
- Key considerations:
- EDAM participation expands PGE’s resource footprint, enhances reliability, lowers costs, and supports decarbonization.
- It enables better integration of renewable energy by leveraging regional diversity and optimized planning, aligning with PGE’s goals to decarbonize, electrify, and improve performance 2.

3. Incremental Resource Acquisition:
- There is a plan to issue an RFP for 66 MW of Community-Based Renewable Energy (CBRE) resources by 2026.
- Key considerations:
- The docket tracks the acquisition process and any deviations from the 66 MW target, requiring explanations for shortfalls or delays 1.

4. Transmission and Policy-Driven Cost Increases:
- Anticipated increases in BPA transmission rates (BP-26 rate case) and federal tariffs on Canadian natural gas are highlighted as drivers of higher power costs.
- Key considerations:
- These external factors contribute to higher net variable power costs (NVPC), requiring careful modeling and regulatory review to match costs and benefits for customers 2.

5. Electrification and Customer-Sited Generation:
- Growth is expected from electrification (transport, buildings) and increased customer-sited solar.
- Key considerations:
- These trends necessitate updates to load forecasts, infrastructure planning, and rate design to accommodate changing usage patterns and distributed generation impacts 1.

Summary of Key Considerations:
- Load forecasts must account for economic, technological, and policy shifts.
- Market participation and renewable integration are critical for cost savings and reliability.
- Resource acquisition (like CBRE) is tracked for compliance and adequacy.
- External policy (tariffs, transmission rates) requires ongoing adjustment of cost models.
- Electrification and distributed energy require adaptive planning for grid impacts.

References:
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Identified stakeholders in the Portland General Electric (PGE) 2026 annual power cost update tariff docket (UE 452) include:

- Portland General Electric (PGE), the utility making the filing.
- Alliance of Western Energy Consumers (AWEC), which has intervened and is participating in the case, including conducting discovery, submitting testimony, and attending hearings 1, 2.
- Oregon Citizens’ Utility Board (CUB), which has submitted a notice of intent to request intervenor funds and will participate in the proceeding 3.
- Oregon Public Utility Commission (OPUC) staff and administrative law judges, overseeing and adjudicating the docket 1.
- Other investor-owned utilities (e.g., PacifiCorp, Avista, Puget Sound Energy, Idaho Power) coordinating with PGE on the BPA transmission rate strategy, but not explicitly listed as formal intervenors in UE 452 4.

Positions for or against specific proposals in the 2026 power cost update are not clearly detailed in the provided excerpts. However, it is clear that:
- AWEC is engaged as an intervenor but their specific positions for or against proposals are not stated in these excerpts 2.
- CUB is also participating, but their stance on specific proposals is not described 3.
- PGE is proposing the cost update and supporting recovery of certain investments and cost increases based on forecasted rates, BPA transmission costs, and federal tariffs 4.

No excerpts explicitly outline which stakeholders are for or against specific proposals within the docket.