Docket Number	Docket Name	Company
ETO 1	ENERGY TRUST OF OREGON 2026-2030 MULTIYEAR PLAN	ENERGY TRUST OF OREGON

Created Date	Comment Type	First Name	Last Name	Comment
9/12/2025 4:10:38 PM	General Comment	Julie	O'Shea	Farmers Conservation Alliance 102 State St Hood River, OR 97031 September 12, 2025 Public Utility Commission of Oregon 201 High Street, Suite 100 P.O. Box 1088 Salem, OR 97308-1088 RE: Docket ETO 1 Dear Public Utility Commission of Oregon, Farmers Conservation Alliance (FCA) appreciates the opportunity to comment on Energy Trust of Oregon’s (Energy Trust’s) Draft 2026-2030 Multiyear Plan. Energy Trust’s investments in rural energy efficiency and renewable energy have been critical to helping meet future energy needs while improving community resilience across Oregon. We help irrigation districts, ditch companies, and agricultural water providers modernize their infrastructure in a manner that provides agricultural, environmental, and community benefits at scale. FCA’s comments relate to our work with these irrigation communities across Energy Trust’s territory. In addition to the activities outlined in the Plan, we encourage Energy Trust to consider the comments below. • Long-duration storage. FCA encourages Energy Trust to consider long-duration storage as an approach to meeting energy needs in agricultural communities. Co-locating long-duration storage with irrigation pumps helps to unlock value by shifting energy demands away from peak periods, stabilizing markets, and lowering costs (see sections V.A and V.B) • Community resilience. FCA encourages Energy Trust to invest in near-term resilience projects while it develops programs and incentives for community resilience (see section V.E and Appendix 3 – Cross sector activities). We agree with Energy Trust’s interest in building support and capacity for resilience efforts, particularly in rural communities, and we also see value in completing near-term projects to demonstrate success. • Non-quantifiable benefits. FCA encourages Energy Trust to engage with the Oregon Public Utilities Commission about considering non-quantifiable benefits in the Total Resource Cost benefit-cost ratio (see Section VI). Agricultural energy projects often have non-energy co-benefits (e.g., water quality). Depending on the project, these benefits may or may not be quantifiable in a cost-benefit analysis. • Complementary funding and co-benefits. FCA encourages Energy Trust to consider opportunities to maximize complementary funding through co-benefits, (see section VI.B). Agricultural energy projects often provide co-benefits that attract complementary funding for project planning and implementation. This approach helps to leverage ratepayer funding while extending community benefits. • Continued investments in irrigated modernization. FCA encourages Energy Trust to continue investments in irrigation modernization across Oregon. Correspondingly, we also encourage Energy Trust to continue and increase coordination between its renewables, efficiency, and community resiliency activities with respect to those investments (see section V and Appendix 3). Oregon’s irrigated agriculture sector is somewhat unique with respect to the opportunities it provides for coordinated energy generation, efficiency, and resiliency (e.g., co-located water and energy infrastructure in rural areas). Increased coordination across Energy Trust’s activities in this sector will help to achieve the greatest outcomes for both ratepayers and rural communities. Energy Trust’s programs have transformed irrigation communities across Oregon. They created the foundation for previously unprecedented state and federal investments in on-the-ground projects that generate renewable energy, reduce energy use, and improve community resiliency. efficiency, and resiliency. We look forward to continuing to work with Energy Trust in 2026-2030, and we encourage you to reach out with any questions. Sincerely, Julie O’Shea Executive Director
9/15/2025 12:46:03 PM	General Comment	Natasha	Jackson	The Northwest Gas Association (NWGA) represents the natural gas utilities and transmission pipelines that provide warmth and comfort to more than 800,000 households and 86,000 businesses, institutions, and industries in Oregon. We respectfully submit the following feedback on Energy Trust of Oregon’s (ETO) Multiyear Plan. Our intent is to support a comprehensive, balanced, and responsible plan that achieves the best possible energy efficiency outcomes for customers. Our member utilities are committed to delivering higher levels of savings that benefit all customers, including those most burdened by energy costs. They have actively engaged in the development of the Multiyear Plan across a range of topics, appreciate the work of ETO staff, and are eager to collaborate on practical solutions-whether through home energy reports, alignment with low-income programs, or other opportunities. We recognize that balancing energy affordability and energy efficiency is a high priority for ETO. The OPUC’s request for accelerated savings acquisition over the next five years has led to ambitious targets. While we support cost-effective savings, early acquisition must be balanced with affordability concerns. Energy efficiency costs are just one of many rising expenses facing customers. Recent legislative actions in Oregon underscore how critical affordability has become, raising questions about how legislative priorities to reduce utility bills intersect with increased costs from this Plan. Assuming best-case scenarios that maximize savings potential may overestimate achievable outcomes, resulting in overfunding and higher customer bills. We are also concerned about rising non-incentive costs – particularly administrative expenses – at a time of federal funding uncertainty. Locking in these assumptions for five years poses significant risks. On the focus area of supporting community resilience, we urge consideration of natural gas as an essential part of the solution. Customers with access to both electricity and natural gas are more resilient than those relying solely on electricity. This was made clear during the January 2024 cold snap, when both systems were strained and large-scale disruptions were narrowly avoided. In response, gas and electric utilities have launched a joint, executive-led initiative to strengthen coordination across the region. This effort provides a critical foundation for regional planning and for addressing increasing threats to energy reliability. Extreme weather events are occurring more frequently and intensifying reliability challenges. Policies that encourage further electrification risk compounding these issues by adding strain to both the electric and gas systems – particularly as natural gas plays an increasing role in supporting electric generation. Renewable development is not yet keeping pace, with significant shortfalls in wind, solar, and storage capacity, and federal incentives have declined, adding further uncertainty for developers. Therefore, we urge that customer education and information under this Plan remain unbiased with respect to fuel choice. Given infrastructure realities – and the fact that natural gas customers directly contribute to ETO programs – equitable treatment of all energy resources is essential. Thank you for considering our comments. We look forward to continuing to collaborate with you on this important work.