Docket Number	Docket Name	Company
AR 681	MICROGRID FRAMEWORKS (HB 2065 & HB 2066 IMPLEMENTATION)

Created Date	Comment Type	First Name	Last Name	Comment
6/14/2026 5:47:10 PM	Oppose Docket	Joseph	Mazone	BEFORE THE PUBLIC UTILITY COMMISSION OF OREGON DOCKET NO. AR 681 COMMENTS OF JOSEPH MAZONE / LIMITLESS SOLUTIONS USA REGARDING THE MICROGRID REGULATORY FRAMEWORK STAFF UPDATE I. INTRODUCTION Limitless Solutions USA submits these comments to ensure the AR 681 framework protects private capital, respects the operational uniqueness of microgrids, and avoids the structural traps of past distributed energy programs. At its core, the drive for microgrid development is fundamentally about energy independence. Communities, businesses, and developers are seeking autonomy from fragile macro-grids, rigid regulations, and top-down utility control. In the spirit of that independence, the Commission's framework must facilitate local empowerment rather than extending utility monopolies over behind-the-meter innovation. To achieve high-velocity deployment, Track A must be fiercely protected. Non-governmental entities—such as Homeowner Associations (HOAs), industrial parks, commercial centers, and master-planned campuses—must be allowed to build resilience faster, free from utility micromanagement, while preserving the optionality to formally interconnect under Track B at a later date. For Track B, the regulatory mindset must shift: just because a utility owns the physical distribution wires does not mean a community cannot improve its own section of the grid. If a localized group wants to harden a radial line and isolate it during an outage, the rules must enable that improvement. This requires explicit streamlining of public-private partnerships (P3s), empowering private developers to handle the technical execution so communities aren't reliant on under-resourced municipal staffs. Furthermore, it means giving communities the tools—such as Community Choice Aggregation (CCA)—to acquire and allocate costs in a flexible, democratic fashion. Ultimately, microgrids are dynamic, localized energy systems balancing generation, storage, load, and islanding capability. They must not be shoehorned into rigid, export-only interconnection procedures built for conventional generators, nor bottlenecked by proprietary utility technology mandates. II. DIRECT RESPONSES TO STAFF QUESTIONS Q1: Should Track B be implemented as an overlay to Division 82, as a new division, or through another structure? COMMENT: Track B must be implemented through a separate, dedicated division within the OAR. Division 82 was designed for standard generator interconnection procedures, not for multi-variant microgrids. Microgrids are not simple export generators. A winter-peaking system may route summer excess into seasonal storage to preserve local value. Other systems act as import-only, normally open configurations treating the utility link purely as an emergency backup source. Treating dynamic load-matching systems as conventional generation projects under an SGIP overlay subjects them to study queues and assumptions that do not fit the asset class. Track B requires its own division capable of defining islanding functions and localized tariffs, mirroring the structural precedent of the Community Solar Program (OCSP). Q2: What minimum rule-level requirements should apply to microgrids that include utility-owned infrastructure within the microgrid boundary? COMMENT: The Commission should establish technology-neutral, outcome-based safety standards for islanding, protection coordination, and reconnection. Crucially, utilities must not be permitted to mandate proprietary, in-house software platforms or vendor-specific equipment unless proven strictly necessary for grid safety. Technical standards must not be weaponized as financial barriers to adoption. Q3: What should the Commission require for communities to initiate the microgrid zone approval process? COMMENT: Phase 1 must remain non-binding, low-cost, and accessible. The Commission must recognize that "community-led" does not mean "government-staff-led." Most rural municipalities lack power systems engineers. To solve this labor bottleneck, the Commission should establish a registry of pre-certified microgrid developers. Local public and private entities must be able to partner with vetted private developers to handle scoping, financing, and management. Furthermore, a designated "zone" must serve as a tool to unlock cost-recovery and land-use perks—not a geographic boundary limiting where microgrids can be proposed. Utilities must be mandated to cooperate with technically viable projects statewide. Q4: What tiered data-sharing requirements should be adopted under HB 2065? COMMENT: Granular circuit data is a prerequisite for mapping safe islanding logic. We propose a streamlined framework: Tier 1 (Public Screening): Utilities must update basic public mapping data at least quarterly (feeder configurations, capacities, DER saturation). Tier 2 (Standardized Non-Public): Enforce a strict 15-business-day shot-clock for utilities to deliver anonymized 15-minute interval load