Docket Number	Docket Name	Company
UG 527	NW NATURAL ALTERNATIVE RATE MECHANISM	NORTHWEST NATURAL

Created Date	Comment Type	First Name	Last Name	Comment
1/26/2026 12:32:22 AM	General Comment			Dear Chair Tawney and Commissioners Perkins and Powers, I am writing to voice my concerns about NW Natural’s proposal to purchase the Coos County Pipeline, and to use millions of ratepayer dollars to repair this aging gas infrastructure. Aging gas pipelines can be a community hazard causing leaks and explosions such as the one that occurred in San Bruno California. This pipeline has been controversial since it was first proposed in the late 1990s, with opponents filing multiple lawsuits citing the impacts of the project to the environment, private property and public safety. Now, as the state is working to meet its climate goals, and is increasingly pursuing building and industrial electrification, we must consider alternatives to maintaining and replacing fossil fuel infrastructure, and pursue opportunities for zonal electrification. As the Coos County Pipeline only serves a little over 2,000 customers, and as there are viable alternatives to the gas use on the coast, transitioning the pipeline customers off of fossil fuels offers an excellent chance to electrify one of the largest communities on the coast in Oregon, reducing harmful air pollution and greenhouse gas emissions. As NW Natural notes in its application, Coos County qualifies as an environmental justice community per ORS 756.010(5), which includes “coastal communities,” “rural communities,” “communities with limited infrastructure,” and “communities experiencing lower incomes” in its definition of environmental justice communities. As such, it is critical that we are making investments in the Coos County community to reduce climate and air pollution, outcomes which transitioning pipeline customers off of fossil fuels would achieve. My own home is fully powered by electricity and insulation and a heat pump has made my home energy efficient. I would love to add solar power someday to further improve that efficiency. Coos County rate-payers and residents deserve solutions and investments that make the region more economic, climate, and energy resilient. Investments can be made into microgrid planning especially for preparing for natural disasters, expanding programs to make heatpumps, solar panels, and home weatherization materials more accessible, and workforce development programs to support projects that bring sustainable, high-paying jobs to the region. Please deny NW Natural’s requests to put ratepayers on the hook to repair this unnecessary pipeline and instead consider non-pipeline alternatives to build community resilience and electrify the end users in Coos County. Thank you for your consideration. Donna Bonetti 1997 Oak St. North Bend, OR 97459 Sent from my iPad
1/28/2026 4:36:17 PM	General (Docket-Specific)	Rogue	Climate	This comment was submitted via email and included an attachment. Because our public comment system cannot process attachments, a full version of the comment has been docketed and can be accessed in the “Actions” tab in eDockets. Ashley Audycki, South Coast Coordinator, Rogue Climate Zoe Serrano, Legislative Coordinator, Rogue Climate Jess Grady-Benson, Organizing Director, Rogue Climate
1/29/2026 12:32:51 AM	General Comment			Hello, I am not seeing our comment filed in docket UM 2419. Can you please look into this and let me know if I need to take any further action? Warmly, Zöe Serrano (she / her) Legislative Coordinator zoe@rogueclimate.org<mailto:zoe@rogueclimate.org> rogueclimate.org Book a meeting with Z öe Work: 458-299-2397 https://ci3.googleusercontent.com/mail-sig/AIorK4wagE0p0BFGy3hxtvmlyiP4q6GD_gq21DxnL2o7dMShvb696WWlcqxsGvO6w6McmZThMctxYvs On Fri, Jan 23, 2026 at 3:12?PM Zoe Serrano <zoe@rogueclimate.org<mailto:zoe@rogueclimate.org>> wrote: Hello, Attached is our public comment for docket UM 2419. Please let me know if you have any questions or need additional information. Warmly, Zöe Serrano (she / her) Legislative Coordinator zoe@rogueclimate.org<mailto:zoe@rogueclimate.org> rogueclimate.org Book a meeting with Z öe Work: 458-299-2397 https://ci3.googleusercontent.com/mail-sig/AIorK4wagE0p0BFGy3hxtvmlyiP4q6GD_gq21DxnL2o7dMShvb696WWlcqxsGvO6w6McmZThMctxYvs
9/25/2026 12:35:10 AM	General Comment			To the Oregon Public Utility Commission and NW Natural Leadership: I am writing as an Oregon ratepayer to raise concerns about the pace and structure of recent NW Natural rate increases, and to request specific transparency and cost-allocation measures before further increases are approved. Rate History NW Natural residential rates rose roughly 25% in late 2024, following a rate case decided in December 2023 (Oregon Citizens' Utility Board, cited in OPB, October 2024). Rates increased further in late 2025, and NW Natural has filed for a new multi-year rate plan effective August 2026. This plan requests roughly a 20% increase for the first year for existing residential customers, followed by about 5% in each of the next two years (NW Natural, gas price disclosure page). OPB has reported that if approved, these cumulative changes would bring rates to more than 50% above 2020 levels. The Oregon general rate case ultimately resolved in October 2025 with a smaller base rate increase of 2.0% to the revenue requirement, an authorized return on equity of 9.5%, and a rate base of approximately $2.3 billion, up $180.1 million from the prior case (NW Natural Holdings Q3 2025 results). Oregon CUB has documented a pattern of 15-20% annual increase requests across Oregon's for-profit utilities over the past several years and has proposed a cap limiting future increases to 10%, or 7% plus inflation, whichever is lower. The Commission has not yet ruled on that proposal. Profit and Shareholder Returns While Oregon customers absorbed roughly a 25% rate increase in 2024, NW Natural Holdings' full-year 2025 net income rose to $113.3 million, up $34.4 million, or 43.7%, from $78.9 million in 2024. GAAP earnings per share rose from $2.03 to $2.77, with a record adjusted EPS of $2.93 (NW Natural Holdings 2025 annual results, reported Feb. 27, 2026). In its first quarter 2025 earnings release, the company stated this increase reflected, among other things, new rates for its gas utility in Oregon. The company raised its shareholder dividend for the 70th consecutive year in November 2025, to an indicated annual rate of $1.97 per share, and invested a record $467 million into utility systems in 2025, capital that expands the rate base against which future rate cases and allowed returns are calculated. I recognize NW Natural Holdings' results also reflect its 2025 SiEnergy and Pines acquisitions in Texas, and I am not asserting all of this profit growth is attributable to Oregon rates alone. But the company's own public statements tie part of this growth directly to Oregon's new rates, and that link deserves a clear, itemized public accounting rather than a bundled enterprise-wide earnings figure. I recognize that base distribution rates and the pass-through cost of gas itself (recovered through separate purchased gas adjustments) are different mechanisms, and that NW Natural does not earn margin on the commodity cost of gas. My concerns below are specific to the base rate and cost-recovery structure, not to wholesale gas price volatility, which is a separate issue. Specific Concerns 1. New-connection subsidies shifted to existing ratepayers, and an active legal challenge to end that shift. A 2022 OPUC order capped the line extension allowance, the subsidy that pays to connect new customers, at $2,875 per hookup, stepping down to $1,380 by November 2024. CUB subsequently found NW Natural exceeding even that cap, including an $86,553 subsidy for a single home in 2021. That finding led to an October 2024 order removing $13.7 million from customer rates and mandating a full phase-out of the subsidy by November 1, 2027. NW Natural is now challenging that order at the Oregon Court of Appeals, arguing in May 2026 that the phase-out is discriminatory against new customers and asking the case be sent back to OPUC. I am asking the Commission and the Department of Justice to defend the 2024 phase-out order in that appeal, since reversing it would restore a subsidy existing ratepayers fund with no established net benefit to them. 2. Seasonal timing of increases. Oregon CUB has specifically noted that back-to-back rate increases have repeatedly taken effect in winter months, when usage and bills are highest, and has asked the Commission to address this pattern directly (OPB, March 2025). 3. Stranded asset risk. NW Natural continues to grow its rate base through gas system investment at the same time Oregon policy is pushing toward electrification. Ratepayers bear the risk of funding infrastructure that may face accelerated retirement or reduced utilization under future state climate policy, without a clear public plan for how those costs would be allocated if that occurs. 4. Enterprise growth outside Oregon's service territory. NW Natural Holdings has expanded into Texas gas distribution (SiEnergy, Pines) and water utility operations (NW Natural Water) in recent years, and has increased its shareholder dividend for 70 consecutive years, including in 2025. I am not asserting Oregon ratepayer funds are being directly diverted to these ventures, but the overlap between rising Oregon rates, a 43.7% jump in parent-company net income, and continued enterprise-wide acquisition activity warrants a clear public accounting of how Oregon's authorized return on equity and rate base are ring-fenced from cross-subsidizing non-Oregon business lines. Requested Actions - Adopt Oregon CUB's proposed cap on annual rate increases (10%, or 7% plus inflation, whichever is lower) for NW Natural and other Oregon for-profit utilities. - Defend the 2024 line extension allowance phase-out order in NW Natural's pending Court of Appeals challenge, rather than allowing the subsidy to be reinstated. - Require NW Natural to publicly disclose, in every rate case and bill increase notice, the separate impact of the base rate increase versus the purchased gas cost adjustment, so customers can see what portion reflects utility-controlled costs versus wholesale market pass-through. - Require NW Natural to publish an itemized breakdown of how much of its enterprise-wide net income growth in each reporting year is attributable to Oregon rate increases specifically, separate from Texas and water utility acquisitions, so ratepayers can see the direct return their rate payments generate for shareholders. - Require a public accounting confirming that Oregon's authorized rate base and return on equity are not subsidizing NW Natural Holdings' non-utility or out-of-state ventures. - Require NW Natural to publish a stranded asset and long-term decarbonization cost-allocation plan, given the state's electrification policy trajectory, so ratepayers understand the future cost exposure of continued gas infrastructure investment. - Avoid scheduling approved rate increases to take effect during peak winter usage months where possible, consistent with CUB's affordability concerns. Oregon ratepayers have absorbed repeated double-digit increases in recent years while the company's net income grew 43.7% in 2025 alone and shareholder dividends increased for a 70th consecutive year. I am asking the Commission to adopt stronger structural protections and greater profit transparency, not simply to review this rate case in isolation. Sincerely, Megan Stack Portland, Oregon
10/29/2026 6:16:11 PM	Oppose Docket			Please please stop approving utility rate increases that are so significant! Stop giving in to corporate greed. A 7.3% increase for NW Natural is crazy. The cost of living in Polk County is already smothering us. Food prices are out of control. Gas prices are ridiculous. What happens when the majority of the state lives in poverty? We are getting wage increases at work and some of us are unemployed.
10/29/2026 8:38:21 PM	Oppose Docket			PUC why the hell would you allow a 7.3% increase rate when people are barely making it by?! I know people who are employed by the state who live check to check, and increasing bills is helping no one but big corporations like utility companies. Do better, tf.