Docket Number	Docket Name	Company
UM 2371	PGE 2025 ALL-SOURCE RFP	PORTLAND GENERAL ELECTRIC

Comment Number	Created Date	Email Received Date	Company Name	Comment Type	Source Type	First Name	Last Name	Email	Nearest City	Comment
UM 2371-1	5/16/2025 12:11:34 PM		PORTLAND GENERAL ELECTRIC	General Comment	Web	John	Zetterstrom		PORTLAND	• DEPCOM has actively supported several all-source bids, both directly for utilities and by assisting our developer partners through PPAs and self-build structures. We have concerns about the qualitative evaluation of bids under the 2023 all-source criteria. Our bids included extensive due diligence on EPC costs, which we believe should make them more 'firm' compared to compliant bids that have not considered these costs. • For instance, a bid entity that has not collaborated with an EPC familiar with Oregon's labor constraints and environment, nor partnered with local labor, should be considered less valuable than one with proven local engagement experience. DEPCOM, in its previous bid, presented a comprehensive labor plan tailored to the Oregon market's community and constraints. We believe such efforts should be qualitatively scored in the evaluation of bids. • We are concerned that RFP evaluations might prioritize bids lacking sophisticated supply chain approaches or those making unrealistic tariff assumptions over more de-risked approaches. We recommend that the RFP clearly levelize tariff assumptions. DEPCOM has collaborated closely with utilities to establish clearly defined terms and structures, including shared savings and contingency planning. We believe such well-structured approaches should be valued qualitatively. • In the same spirit as the above comments, we recommend that engineering maturity be included in bid evaluations qualitatively. For example, two offers may meet the same minimum bid requirements, but the offer with 60% design completion, which includes erosion control measures, electrical optimization, and environmental compliance, should be qualitatively valued over an offer with only 10% design completion. • We see there has been effort in the 2025 RFP to include non-pricing items as a consideration, but we do not feel non-commercial items like the above are clearly a part of the qualitative evaluation process.