August 20, Sincerely,

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1 Via Electronic and US Mail Public Utility Commission Attn: Filing Center 550 Capitol St. NE #215 P.O. Box 2148 Salem OR TEL ( FAX ( Suite SW Taylor August 20, 2012 Re: In the Matter of PORTLAND GENERAL ELECTRIC Request for Proposals for Renewable Resources Docket No. UM 1613 Dear Filing Center: Enclosed please find the original and five (5 copies of the Comments on behalf of the Industrial Customers of Northwest Utilities in the above-referenced docket. Enclosures Thank you for your assistance. Sincerely, UU /s/ Sarah A. Kohler Sarah A. Kohler cc: Service List

2 CERTIFICATE OF SERVICE I HEREBY CERTIFY that I have this day served the foregoing Comments on behalf of the Industrial Customers of Northwest Utilities upon the parties, on the service list, by causing the same to be deposited in the U.S. Mail, postage-prepaid, and via electronic mail. Dated at Portland, Oregon, this 20th day of August, Sincerely, UU/s/ Sarah A. Kohler Sarah A. Kohler (W PORTLAND GENERAL ELECTRIC PGE Rates & Regulatory Affairs 1WTC0702 V. Denise Saunders 1WTC SW Salmon St. pge.opuc.filings@pgn.com denise.saunders@pgn.com (W ESLER STEPHENS & BUCKLEY JOHN W STEPHENS 888 SW FIFTH AVE STE 700 PORTLAND OR stephens@eslerstephens.com; mec@eslerstephens.com (W RICHARDSON & O LEARY LLC GREGORY M ADAMS PETER J RICHARDSON PO BOX 7218 BOISE ID greg@richardsonandoleary.com peter@richardsonandoleary.com PUC STAFF DEPARTMENT OF JUSTICE MICHAEL T WEIRICH BUSINESS ACTIVITIES SECTION 1162 COURT ST NE SALEM OR michael.weirich@doj.state.or.us (W NW & INTERMOUNTAIN POWER PRODUCERS COALITION ROBERT D KAHN 1117 MINOR AVENUE, SUITE 300 SEATTLE WA rkahn@nippc.org;rkahn@rdkco.com (W RENEWABLE NORTHWEST PROJECT MEGAN WALSETH DECKER SENIOR STAFF COUNSEL 421 SW 6TH AVE., STE PORTLAND OR megan@rnp.org RNP DOCKETS dockets@rnp.org (W CITIZENS UTILITY BOARD OF OREGON OPUC DOCKETS ROBERT JENKS (W NORTHWEST PIPELINE GP TERESA HAGINS 8907 NE 219TH STREET BATTLE GROUND WA PAGE 1 CERTIFICATE OF SERVICE

3 G. CATRIONA MCCRACKEN 610 SW BROADWAY, STE 400 PORTLAND OR STEWART MERRICK 295 CHIPETA WAY SALT LAKE CITY UT (W REGULATORY & COGENERATION SERVICES, INC. Donald W. Schoenbeck 900 WASHINGTON ST STE 780 VANCOUVER WA PAGE 2 CERTIFICATE OF SERVICE

4 BEFORE THE PUBLIC UTILITY COMMISSION OF OREGON UM 1613 In the Matter of PORTLAND GENERAL ELECTRIC Request for Proposals for Renewable Resources COMMENTS OF THE INDUSTRIAL CUSTOMERS OF NORTHWEST UTILITIES The Industrial Customers of Northwest Utilities ( ICNU submits the following comments regarding Portland General Electric Company s ( PGE request for proposals ( RFP for over 100 megawatts of renewable resources. ICNU has reviewed the comments of the Northwest and Intermountain Power Producers Coalition ( NIPPC, and it appears that NIPPC has raised a number of legitimate concerns with PGE s renewable RFP. NIPPC has not identified any fatal or fundamental flaws with the RFP, but has recommended that the RFP be revised to add additional clarity, transparency and specificity, and to remove some onerous and unreasonable terms. While ICNU will review the responsive comments of PGE and the Staff recommendation, at this point ICNU recommends that the Oregon Public Utility Commission adopt NIPPC s reasonable recommendations. ICNU has also reviewed the comments of the Renewable Northwest Project ( RNP, and supports RNP s recommendation that the Commission to direct PGE to make its detailed scoring methodology available to bidders once it is finalized. PGE has elected to include a self-build benchmark resource in this renewable RFP, and ICNU notes that the vast majority of the concerns raised by NIPPC relate to potential PAGE 1 COMMENTS OF ICNU Telephone: (

5 biases in favor of utility ownership. PGE may argue that many of these provisions are necessary to protect ratepayers from the risks associated with contracting with independent third parties to construct generation resources that will be used to serve end-use consumer loads and meet PGE s renewable portfolio standard obligations. Some of these provisions, like aggressive liquidated damages provisions, limited cure rights, and limited ability to modify the contract templates, may be reasonable if there is no utility ownership option, but may only serve to bias the process in favor of PGE s option when a benchmark resource is included. Recent history demonstrates that utility-built wind projects have not performed as well as expected, and the best protection for ratepayers is an even playing field that allows the best and most economic projects to be selected as the winning bid. PGE is not required to include a self-build benchmark resource in this RFP, and the Commission should carefully consider all aspects of the RFP to ensure that the competitive bidding process is as fair as possible. Dated this 20th day of August, Respectfully submitted, /s/ Irion A. Sanger Irion A. Sanger Portland, Oregon ( phone ( facsimile ias@dvclaw.com Of Attorneys for Industrial Customers of Northwest Utilities PAGE 2 COMMENTS OF ICNU Telephone: (

CABLE HUSTON CABLE HUSTON IHNEDICT HAAGENSEN & LLOYD LLP. ATTORNEYS

I i CABLE HUSTON CABLE HUSTON IHNEDICT HAAGENSEN & LLOYD LLP. ATTORNEYS CHAD M. STOKES cstokes@cablehuston.com www.cablehuston.com July 12,2013 VIA ELECTRONIC FILING & U.S. MAIL Oregon Public Utility Commission