Public Filings

January 26, 2026 - Renewable NW's comments on Staff Report.

January 23, 2026 - Testimony on Washington's HB 1960 regarding renewable energy tax policy.

January 21, 2026 - Testimony on SB 5466 regarding improving reliability and capacity of the electric transmission system in Washington state.

January 12, 2026 - Comments of RNW regarding the Commission’s proceeding to develop a policy statement addressing alternatives to traditional cost of service ratemaking, Docket U-210590.

January 12, 2026 - RNW's Initial Comments OPUC Docket No. UM 2417: Identifying Priorities in Implementation of Executive Orders 25-25 and 25-29.

December 15, 2025 - Letter to the Whitman County Planning Commission regarding recommended amendments to the Commercial Wind Energy Facilities Ordinance.

December 5, 2025 - Comments on Behalf of the NW Energy Coalition and Renewable Northwest on Avista’s Final Clean Energy Implementation Plan (CEIP)(Docket UE-250746).

December 1, 2025 - RNW’s Answers to Staff’s Questions for Energy Stakeholders. OPUC Docket No. UM 2409: Investigation of Cost Effectiveness Analysis of Grid Enhancing Technologies in Utility Integrated Resource Plans

November 14, 2025 - RNW's initial comments in this formal rulemaking proceeding regarding revisions to Division 90 System Planning rules, Division 89 rules governing resource procurement for electric companies' competitive bidding rules, Division 001 governing information requests in resource procurement and competitive bidding, and the repeal of the existing OAR 860-027-0400 rule governing integrated resource planning.

November 7, 2025 - As a participant of the Data Center Workgroup, RNW submitted the following minority views on the Workgroup’s recommendations which are primarily suggestions for further clarification and strengthening of the recommendations.

November 4, 2025 - RNW's testimony on the Thurston County Comprehensive Plan 2045 draft dated November 4, 2025, and related proposed County Code revisions.

October 9, 2025 - Renewable NW's second round of comments on PacifiCorp's 2025 Integrated Resource Plan. The 2025 IRP is PacificCorp's second resource plan since the passage of House Bill 2021 ("HB 2021") - Oregon's clean energy law that requires utilities to reduce greenhouse gas emissions 80% by 2030, 90% by 2035, and 100% by 2040.

October 7, 2025 - RNW is a participant of the Washington Data Center Workgroup, this letter provides more detailed and nuanced comments on the Energy & Resource Impacts Subgroup draft recommendations in which RNW has expertise.

September 15, 2025 - Written testimony on Klickitat County's draft BESS Ordinance, intended to provide context as to why this draft ordinance requires broader review and revision to ensure that solar and BESS projects are permitted through the county rather than EFSEC.

August 8, 2025 - RNW's comments on BPA's public scoping period for the proposed MT to WA Transmission System Upgrade Project (M2W) emphasize its potential to address significant regional transmission capacity constraints and encourage BPA to maintain momentum.

July 29, 2025 - Renewable NW's comments on PacifiCorp’s 2025 Integrated Resource Plan. The 2025 IRP is PacifiCorp’s second resource plan since the passage of House Bill 2021 (“HB 2021”) - Oregon’s clean energy law that requires utilities to reduce greenhouse gas (“GHG”) emissions 80% by 2030, 90% by 2035, and 100% by 2040.

July 23, 2025 - RNW's comments on a set of four BPA Generator Interconnection Reform Business Practices are largely supportive of the proposed revisions.

July 17, 2025 - RNW, Interwest and ACP's joint comments urge FERC to accept CAISO's revised EDAM congestion revenue allocation proposal.

July 14, 2025 - Renewable NW's comments on the Oregon Public Utility Commission's Staff Report recommending conditional approval of Portland General Electric Company’s Draft 2025 All-Source RFP and RFP Scoring and Modeling Methodology

July 8, 2025 - Comments on updating existing Marion County code language for battery energy storage systems (BESS).

July 7, 2025 - Renewable NW's comments on PacifiCorp’s draft 2025 Request for Proposals and associated scoring and modeling methodology.

May 28, 2025 - RNW engaged in the Oregon PUC's investigation into integrated resource plan (IRP) and request for proposals (RFP) modernization, which has since become the formal rulemaking docket - AR 669. We have largely supported the concepts and language Staff has proposed; we think the changes to IRPs and RFPs envisioned in this docket will support greater visibility into utility compliance with state policy, focus resource planning on key questions and decisions, and streamline the IRP and RFP processes to some extent. We recommended additional requirements to increase transparency throughout the IRP process, which would enable Staff, the Commission, and interested parties to better assess the IRP’s validity and offer more informed recommendations.

May 28, 2025 - Comments on Workshop #1 - OPUC Docket AR 669 - Rulemaking to Amend Integrated Resource Plan Guidelines and Competitive Bidding Rules

May 16, 2025 - In response to PGE's draft 2025 RFP and informed by member feedback, RNW recommended that PGE modify the RFP to be more accommodating to emerging technologies, remove the novel escrow payment for shortlisted bids, allow ERIS for on-system bids, and make changes to its transmission proposal.

May 16, 2025 - Oregon Public Utility Commission regarding Portland General Electric Company’s Draft 2025 All-Source RFP. In these comments, Renewable Northwest discusses several issues with the Draft RFP and recommends nine discrete changes.

May 8, 2025 - RNW and our partner organizations - NW Energy Coalition, Climate Solutions, and Rewiring America - filed several rounds of comments in Washington's integrated system plan (ISP) rulemaking docket. The docket stems from the passage of HB 1589, which requires Puget Sound Energy to undertake integrated system planning between its electric and gas systems in an effort to decarbonize the gas system. We have weighed in on the definition of commercially available, the use of a cost test to determine the lowest reasonable cost of decarbonization, and the interpretation of emission reduction targets, among other things.

May 1, 2025 - RNW and ACP's joint limited protest on Portland General Electric's EDAM tariff revisions at FERC focus narrowly on the congestion revenue allocation proposal's impact on transmission customers' inability to hedge congestion risk.

April 25, 2025 - RNW, NW Energy Coalition, and Climate Solutions submitted comments in support of the revisions made by the Commission in the latest iteration of the CETA "use" rules. However, we also conveyed our concern that the previous, more stringent version of the rules was set aside in favor of a framework that permits resource shuffling and is likely to delay progress toward decarbonization.

April 24, 2025 - In response to Avista's draft 2025 RFP and informed by member feedback, RNW recommended that the company treat its evaluation methodology as nonconfidential, relax specific interconnection and transmission requirements, modify language around the financial evaluation framework, and provide bidders with an opportunity to address tariffs.

April 7, 2025 - RNW's formal comments on BPA's March 2025 DAM Draft Policy urge BPA to delay a final market commitment until ongoing governance and federal workforce reduction concerns can be sufficiently addressed. Comments include a comprehensive discussion of BPA's statutory obligations to the region.

March 19, 2025 - RNW's comments on BPA's March 7 Network Integration Transmission Service (NITS) workshop strongly discourage moving forward with alternatives that might minimize the value of BPA's long-term transmission rights.

March 18, 2025 - Supportive testimony for Oregon’s HB 3666 which establishes a process for issuing wildfire safety certificates for electric utilities.

March 18, 2025 - Supportive testimony of Oregon’s HB 2063, an agrivoltaics study bill.

March 12, 2025 - Testimony on Idaho's HB387 regarding decommissioning bonds for wind turbines.

March 11, 2025 - Supportive testimony of Oregon’s HB 3681, which was signed into law. The bill makes procedural fixes for energy permitting.

March 4, 2025 - Testimony on Idaho's HB347 regarding conditional use permits for the construction of energy facilities

March 4, 2025 - RNW's preemptive letter to the Administrator ahead of the release of BPA's DAM Draft Policy urges a refocusing on BPA's core functions and obligations during a time of great uncertainty in the federal landscape.

March 3, 2025 - RNW submitted comments on PacifiCorp's draft IRP, expressing concern with the company's lack of progress toward CETA targets, preferred portfolio which reduces renewable resource builds in favor of coal and market purchases, questionable renewable resource costs underlying the plan, and new state allocation framework, among other things.

February 25, 2025 - Supportive testimony of Oregon’s HB 3336, which was signed into law. The bill promotes the use of grid-enhancing technologies (GETs).

February 25, 2025 - Supportive testimony of Oregon’s HB 3628, a transmission package.

Feb 24, 2025 - An analysis of HB1960, Washington's County property tax fix bill

Feb 20, 2025 - Testimony on HB146 regarding light mitigation systems on wind facilities.

February 20, 2025 - RNW and our partner organizations - NW Energy Coalition, Climate Solutions, and Rewiring America - filed several rounds of comments in Washington's integrated system plan (ISP) rulemaking docket. The docket stems from the passage of HB 1589, which requires Puget Sound Energy to undertake integrated system planning between its electric and gas systems in an effort to decarbonize the gas system. We have weighed in on the definition of commercially available, the use of a cost test to determine the lowest reasonable cost of decarbonization, and the interpretation of emission reduction targets, among other things.

February 18, 2025 - RNW, Interwest, and ACP's joint limited protest on PacifiCorp's EDAM tariff revisions at FERC focus narrowly on the congestion revenue allocation proposal's impact on transmission customers' inability to hedge congestion risk.

February 5, 2025 - RNW engaged in the Oregon PUC's investigation into integrated resource plan (IRP) and request for proposals (RFP) modernization, which has since become the formal rulemaking docket - AR 669. We have largely supported the concepts and language Staff has proposed; we think the changes to IRPs and RFPs envisioned in this docket will support greater visibility into utility compliance with state policy, focus resource planning on key questions and decisions, and streamline the IRP and RFP processes to some extent. We recommended additional requirements to increase transparency throughout the IRP process, which would enable Staff, the Commission, and interested parties to better assess the IRP’s validity and offer more informed recommendations.

January 30, 2025 - Supportive testimony on HB1522, on wildfire mitigation plans, which was signed into law.

January 30, 2025 - Supportive testimony of Washington's SB 5466, transmission package.

January 29, 2025 - Testimony on HB 314, establishing a Montana Energy Authority

January 23, 2025 - Testimony on Montana's HB 326 regarding establishing a tax on electrical energy not produced by coal.

January 23, 2025 - Testimony on Montana's SB 160 regarding decomissioning requirements.

January 20, 2025 - Testimony on Washington's HB1188 that would require local government and Tribal approval of wind and solar siting recommendations by the energy facility site evaluation council.

January 17, 2025 - Regulatory division testimony regarding NorthWestern Energy’s application for authority to increase retail electric and natural gas utility service rates and for approval of electric and natural gas service schedules and rules and allocated cost of service and rate design

January 17, 2025 - Supportive testimony of Washington's SB5175, a photovoltaic recycling program-fix bill that was signed into law.

January 16, 2025 - Comments to Sherman County, OR regarding the County's role and responsibility to consider ordinances that balance the costs and benefits of solar development.

January 14, 2025 - RNW and our partner organizations - NW Energy Coalition, Climate Solutions, and Rewiring America - filed several rounds of comments in Washington's integrated system plan (ISP) rulemaking docket. The docket stems from the passage of HB 1589, which requires Puget Sound Energy to undertake integrated system planning between its electric and gas systems in an effort to decarbonize the gas system. We have weighed in on the definition of commercially available, the use of a cost test to determine the lowest reasonable cost of decarbonization, and the interpretation of emission reduction targets, among other things.

October 28, 2024 - Renewable Northwest’s comments regarding the Draft Programmatic Environmental Impact Statements for Utility-Scale Onshore Wind Energy Facilities and Utility-Scale Solar Energy Facilities

September 17, 2024 - Comments and recommendations submitted to Grant County, WA regarding energy-related amendments.

May 3, 2024 - RNW's formal comments on BPA's April 2024 DAM Policy Paper & Staff Recommendation urge more robust and transparent analysis of impacts to the region and to BPA's transmission service customers.

April 29, 2024 - RNW's comments on the Markets+ Tariff filing at FERC maintain our support for the continued development of day ahead markets while highlighting our concerns about potential seams issues that will arise from multiple markets in the West.

April 25, 2024 - Renewable Northwest’s comments on the Washington Department of Fish and Wildlife’s Revised Draft Guidelines for Solar and Wind Power Development

March 28, 2024 - Regulatory division testimony regarding the commission's investigation of Montana resource adequacy and risk profile

September 21, 2023 - RNW and PIO Partners' joint comments on the EDAM Tariff filing at FERC are broadly supportive of the tariff revisions, with specific comments focused on encouraging consistency and transparency in transmission access, seams management, GHG accounting, and market monitoring.

May 22, 2023 - Renewable NW's comments on Portland General Electric’s 2023 Integrated Resource Plan and Clean Energy Plan. This is the company’s first IRP since House Bill 2021 (“HB 2021”) passed in the 2021 Oregon legislative session, and its first ever CEP -- a new planning construct designed to demonstrate a path to achieving zero greenhouse gas emissions by 2040 while ensuring thorough consideration of potential benefits and impacts to Oregon’s communities.