---
kind: section
source_pdf: oregon-prosperity-council-report-june-2026.pdf
fingerprint: 8ac9aef8ca1b
page_range: [156, 158]
breadcrumb: ["Appendix E: Submissions & Feedback", "08. Pacific Power"]
source_links:
  pdf: "https://www.oregon.gov/gov/Documents/Oregon%20Prosperity%20Council%20Report_June%202026.pdf#page=156"
  raw_pages:
    - "../../.extracted/pages/page-0156.txt"
    - "../../.extracted/pages/page-0157.txt"
    - "../../.extracted/pages/page-0158.txt"
---

# 08. Pacific Power

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## TL;DR  *(generated · confidence: high)*

Pacific Power submits a framework for strategic planning and investment in electric energy infrastructure in Oregon. It proposes a Wildfire Fund with liability limitations and standards of care for wildfire mitigation, plus regulatory certainty mechanisms (interim rate adjustments, trackers, multi-year plans, pre-approvals) to reduce regulatory lag and enable capital investment while maintaining customer affordability and reliability protections.

**Key points** *(each cites a PDF page)*:

- Creation of a Wildfire Fund sourced from state governments, utilities (shareholders and customers), and private industry partners to compensate wildfire-impacted individuals and businesses and stabilize energy service. ([p. 157](https://www.oregon.gov/gov/Documents/Oregon%20Prosperity%20Council%20Report_June%202026.pdf#page=157))
- Implement limitations of liability relating to wildfires, including limitations on noneconomic damages, as the single most effective measure for supporting utilities and reducing costs borne by customers. ([p. 157](https://www.oregon.gov/gov/Documents/Oregon%20Prosperity%20Council%20Report_June%202026.pdf#page=157))
- Define standards of care by which a reasonable utility should operate to prevent wildfire, with rebuttable presumptions in court of law for utilities following approved wildfire mitigation plans. ([p. 157](https://www.oregon.gov/gov/Documents/Oregon%20Prosperity%20Council%20Report_June%202026.pdf#page=157))
- Apply limitations on attorney fees and subrogation claims related to wildfires to reduce overall costs for utilities and customers. ([p. 157](https://www.oregon.gov/gov/Documents/Oregon%20Prosperity%20Council%20Report_June%202026.pdf#page=157))
- Explore cost-recovery mechanisms including interim rate adjustments, trackers, true-up mechanisms, and multi-year plans to reduce regulatory lag and enable timely cost recovery. ([p. 157](https://www.oregon.gov/gov/Documents/Oregon%20Prosperity%20Council%20Report_June%202026.pdf#page=157))
- Evaluate pre-approvals and other regulatory processes to improve certainty for capital investments needed to deliver on state energy goals. ([p. 158](https://www.oregon.gov/gov/Documents/Oregon%20Prosperity%20Council%20Report_June%202026.pdf#page=158))
- Review customer protection guardrails (offramp protections) to ensure they function effectively against cost pressures while maintaining utility investment certainty. ([p. 158](https://www.oregon.gov/gov/Documents/Oregon%20Prosperity%20Council%20Report_June%202026.pdf#page=158))

Programs: Wildfire Fund · Wildfire mitigation plans · Multi-year rate plans · Standards of Care · Pre-approvals · Parties: Pacific Power

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> **Source:** PDF [pp. 156-158](https://www.oregon.gov/gov/Documents/Oregon%20Prosperity%20Council%20Report_June%202026.pdf#page=156) · raw: [156](../../.extracted/pages/page-0156.txt) · [157](../../.extracted/pages/page-0157.txt) · [158](../../.extracted/pages/page-0158.txt)

Breadcrumb: Appendix E: Submissions & Feedback > 08. Pacific Power

---
FRAMEWORK FOR ENSURING FINANCIALLY HEALTHY UTILITIES AND
CERTAINTY FOR CUSTOMERS RELATING TO INVESTMENT IN
ELECTRIC ENERGY INFRASTRUCTURE IN OREGON
A framework is needed to facilitate strategic planning, development, construction and investment
in electric energy infrastructure in Oregon to grow our economy, meet state energy goals,
mitigate impacts of extreme weather, address reliability and achieve improved rate certainty for
customers to address affordability. Progress toward development of this framework can be made
with an appropriately scoped Commission-led study.
Foundational Principles
The following principles serve as the foundation of the study:
 Oregon’s regulated utility model plays a critical role in supporting fairly-priced energy,
reliability and resiliency, sustainability, utility responsiveness and enabling economic
growth.
 Oregon has taken important steps to set out policies to ensure improved certainty for
customers, including multi-year rate plans and protection against cost causers.
 Sound energy policy, clear regulatory guidance, transparency, regulatory stability and
regulatory efficiency are necessary to secure long-term energy investment.
 Wildfire affects everyone and Oregon needs solutions that emphasize community
protection, wildfire prevention, responsible investment and rapid recovery.
 Healthy utilities are crucial to economic prosperity, growth and a competitive business
environment.
 Oregon is focused on clean generation development, innovation and resource diversity to
achieve a clean energy future.
 Transmission development is essential for delivering energy and meeting the shared
objective of powering Oregon's economic growth.
 The modern era of demand growth requires new tools and mechanisms to meet load
requirements in a timely and efficient manner, while protecting existing customers.
 We can bolster innovation, research and environmental stewardship by investing in new
technologies and grid solutions, without compromising reliability or affordability,
through robust and aligned data-driven analysis and transparent planning without
overburdening the development of solutions with time-intensive process.
 Customer service, affordability and reliability can be secured by creating a policy and
regulatory environment that enables investments for long-term value, system efficiency
and future rate certainty.
 Establish, enhance and optimize cost-recovery mechanisms and transparent data-driven
metrics to achieve balanced outcomes for customers, utilities and Oregon.
Study Framework
Using the foundational principles identified above, below are categories for collaboration to
secure Oregon’s energy future.
1

Wildfire Policy
 Creation of a Wildfire Fund. The goal is to create a fund that could be accessed in the
event of a catastrophic wildfire to compensate impacted individuals and businesses in a
timely way and provide a shared safety net for utilities facing high wildfire costs,
especially from catastrophic events. It is designed to make wildfire liability more
predictable and manageable – protecting customers, stabilizing energy service and
promoting investment in safety. Fund concepts create a pool of money potentially
sourced from multiple contributors, including state governments, utilities (shareholders
and customers) and other private industry partners related to wildfire prevention.
 Limitations of Liability. Along with funds, there should also be clear and effective
limitations of liability relating to wildfires, including limitations on noneconomic
damages. Limitations of liability are the single most effective measure for supporting
utilities and reducing the cost of the risk borne by customers. Limitations of liability are a
clear signal to investors about the risk they will bear by investing in a regulated utility in
the state. Limitations of liability, in combination with a Wildfire Fund, also have the
benefit of extending the overall life of funds created to compensate those affected by
fires.
 Standards of Care. Defining standards of care by which a reasonable utility should
operate to prevent wildfire provides certainty for utilities and customers. Wildfire
mitigation plans are developed by utilities and approved by the Commission. Policies
associated with certifying that a utility is operating to an approved wildfire mitigation
plan should provide rebuttable presumptions in a court of law.
 Lowering The Costs. Limitations on attorneys fees and subrogation claims serve to
reduce overall costs for utilities and customers. Certainty as to these costs help to ensure
capital investment and lower costs for customers.
Regulatory Certainty and Efficiency
 Regulatory Lag. Regulatory lag results in a drag on a utility’s financial ability to make
continual progress in the investments needed to reliably serve its customers in a way that
achieves state energy goals. It is important to more closely align cost recovery with when
costs are incurred for all elements of revenue requirement. All tools, inclusive of cost-
recovery mechanisms, that can improve efficiency and reduce regulatory lag should be
explored (i.e., interim rate adjustments, trackers, true-up mechanisms, multi-year plans,
etc.).
 Recovery of Operational Costs. New challenges in load growth and generation mix are
creating a significant amount of volatility and uncertainty in the ability of utilities to
recover the operational costs necessary to meet these challenges. Reviewing existing
mechanisms, and the possible development of new mechanisms, to ensure that they are
structured effectively to ensure that the incentives are aligned with the state’s energy
goals is important.
2

 Capital Recovery. Uncertainty in a utility’s ability to recover costs for the capital
investments needed to deliver on the state’s energy goals can result in a drag on that
utility’s ability to make the necessary investments. Regulatory processes that can be used
to improve certainty for the utility, with appropriate customer protections, will facilitate
growth in needed energy infrastructure while promoting economic development, and
these types of processes (i.e., pre-approvals) need to be evaluated.
 Guardrails. Customer protections are an important element of the clean energy transition.
These protections serve as an important backstop to reign in potentially unexpected cost
pressures that threaten affordability. A review of how these offramp protections are being,
or could be, implemented, is needed to ensure they are able to function as intended
considering both process and efficiency. Actions taken to trigger a guardrail need to be
made in a timeframe that does not challenge effectiveness or that increases uncertainty
and risk for the utility.
3

---

Parent: [Appendix E: Submissions & Feedback](./INDEX.md) · PDF: [pp. 156-158](https://www.oregon.gov/gov/Documents/Oregon%20Prosperity%20Council%20Report_June%202026.pdf#page=156)