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
11/10/2025 5:35:31 PM	General (Docket-Specific)	Fraser	Wick	I am a landlord and own a rental property with solar panels. As a PGE customer, when the tenants change, the new tenant loses the solar credits which were saved up. It would be beneficial for tenants if the credits could be transferred from one tenant to the next. Otherwise, landlords are disincentivized to install solar on their property or are otherwise required to bill the tenant for power, unnecessarily taking on additional risk for additional collections from their tenant.
6/15/2026 7:45:54 PM	General (Docket-Specific)	Pari	Kasotia	June 15, 2026 Oregon Public Utility Commission Attn: Filing Center 201 High Street SE, Suite 100 Salem, OR 97301 Re: UM 1930, Administrative costs and revenues comments Chair Tawney, Commissioner Perkins and Commissioner Power, Thank you for the opportunity to provide comments on Docket No. UM 1930 - Community Solar Implementation on the topic of Aligning Program Administrative Costs and Revenues. Luminace is a leading provider of decarbonization-as-a-service solutions to commercial, industrial, and public sector customers nationwide. We own and operate more than 1.3 gigawatts of zero carbon electricity generation resources, primarily distributed solar serving commercial and industrial customers, with additional investments in residential solar and fuel cells. We currently have 19 operating solar assets in Oregon with a total capacity of 51.47 MWdc. We are proud of our investments in Oregon and our ability to serve local residents especially low-income families. Luminace appreciates Oregon Public Utility Commission’s proactive approach to addressing increasing program costs. While we recognize that there are limited options to reduce costs and increase revenues, Luminace strongly recommends that any changes to the increases in administrative fees are applied proactively and not retroactively for the reasons stated below. Retroactive Changes Undermine Regulatory Certainty Developers like Luminace undertook financial decisions, in good faith, based on known participant administrative fees and clear understanding of the program rules at that time. The existing program rules were factored in aspects such as pricing subscriptions, long-term customer agreements, and tax equity commitments. Our investors committed millions of dollars to Oregon projects with the expectation that changes to policy frameworks would apply prospectively, not retroactively. While the program rules permit program fees to be updated annually, preserving prior values on operational projects is critical to maintaining Oregon’s reputation as a stable and reliable state to invest in clean energy infrastructure. Any retroactive changes to operational projects would severely undermine industry confidence and dampen future investment prospects. Retroactive Changes Create Financial Harm to Operational Projects Luminace has made substantial, long-term investments in Oregon and our priority is to safeguard financial integrity of our operational assets. Oregon currently charges Program Administration Fee and the Utility fee on all community solar projects. It is worthwhile to note that Luminace has chosen to pay all these fees on behalf of our subscribers. Any retroactive changes would impose unanticipated cost increases on companies like Luminace, reducing project revenues and undermining investor confidence in both existing assets and the future project pipeline. To preserve financial stability, Luminace may be compelled to pass these additional costs on to subscribers—ultimately increasing energy burdens for Oregon customers. Prospective Approach is the Right Path Forward Any adjustments to PA fees should be implemented only on a prospective basis that takes a gradual and flexible approach. This enables developers to be fully informed while pricing projects appropriately and create a long-term compliance plan without diluting investor confidence. The PUC should aggressively explore cost reduction strategies. The program has matured over the years, and the industry has created a well-functioning process. Streamlining aspects of the program will not only create efficiencies but also reduce administrative burden. For the reasons noted above, we respectfully urge the Committee to consider increase in administrative fees to future projects. Doing so will protect the economics of existing operational assets, maintain subscriber value proposition, and preserve investor confidence in Oregon’s community solar program. Thank you for your consideration and for your continued leadership. Sincerely, Pari Kasotia Head of Policy and Regulatory Affairs Luminace Pari.kasotia@luminace.com