Docket Number	Docket Name	Company
UM 1930	COMMUNITY SOLAR IMPLEMENTATION

Created Date	Comment Type	First Name	Last Name	Comment
3/31/2025 4:16:58 PM	General Comment	Louis	Stevens	I would like to voice my support for Community Solar Projects. There needs to be more capacity so that more residential customers can participate.
8/22/2025 5:45:29 PM	General Comment	Keith	Kueny	Comments of Farmers Conservation Alliance Docket No. UM 1930 Community Solar Program – Carve-out Capacity Expansion August 2025 Chair Tawney, Commissioner Perkins, Commissioner Power: Farmers Conservation Alliance (“FCA”) appreciates the opportunity to submit comments in response to Staff’s proposal regarding the expansion of carve-out capacity within the Community Solar Program (“CSP”). FCA strongly supports the expansion of carve-out capacity to ensure that projects delivering direct community benefits can move forward in a timely and equitable manner. FCA’s Mission and Perspective FCA is a nonprofit social enterprise that works alongside rural and agricultural communities across Oregon and the West to modernize irrigation systems, conserve water, and advance locally-sited renewable energy. Through this work, FCA has seen first-hand how distributed clean energy projects—including community solar—can provide multi-sector benefits: • Strengthening community resilience and lowering energy costs. • Advancing environmental outcomes by supporting renewable energy integration and water conservation. • Supporting rural economic development through construction and long-term operations. Need for Expanded Carve-out Capacity The CSP has demonstrated strong demand, especially for projects that: • Serve low- and moderate-income households. • Are co-located with agricultural or water management infrastructure, helping rural communities. • Provide geographically diverse generation outside major load centers. Remaining Tier 2 carve-out capacity is very limited (11.28 MW in Portland General Electric territory and 2.38 MW in Pacific Power territory as of August 12, 2025). Staff has also noted that pending and anticipated applications will exceed the current available capacity. Without expanded carve-out capacity, shovel-ready projects that could benefit communities will be delayed or cancelled, undermining program goals. Aligning Expansion with Community Benefits FCA urges the Commission to ensure that expanded carve-out capacity prioritizes projects with clear community benefits, such as: • Direct bill savings to low-income subscribers. • Partnerships with irrigation districts, tribes, and local governments to align solar development with water conservation and energy resilience goals. • Projects that integrate with broader resiliency planning (e.g., microgrids serving critical facilities). By expanding carve-out capacity, the Commission can ensure that these impactful projects are not left stranded due to administrative capacity caps rather than technical feasibility or demand. In terms of program access, rural and low-income communities have limited resources to apply for these opportunities. We urge careful consideration of the program requirements needed to participate to ensure that eligible communities can participate. At the same time, easing administrative access to the program should be balanced with appropriate standards for applicants to assure that project developers meet the mission and goals of the program, and also have the know-how and experience to complete the work. For example, history of project work by an applying entitiy, with references from communities that speak to the applicant’s qualifications, may help assure not only project success, but that the program’s intent is met. FCA respectfully requests that the Commission approve Staff’s proposal to expand carve-out capacity and consider additional steps to ensure that projects serving communities, particularly in rural and agricultural areas, are not excluded due to limited capacity allocations. Expanding carve-out capacity will ensure the Community Solar Program continues to deliver on its promise: equitable access to clean energy, resilience for communities, and opportunities for rural Oregon to participate in the clean energy economy. We thank Staff and the Commission for their leadership in this docket and look forward to continued engagement. Respectfully submitted, Farmers Conservation Alliance