Plain-English framing. Schedule 96 is Oregon's version of the separate-rate-class concept that New York's S10642 mandates: a tariff schedule specifically for data center loads with longer contract terms (typically 15-20 years), demand-charge floors, and emissions-linked interconnection rules. The OPUC approved the framework on April 21; PGE had until June 3 to file the implementing tariff details (rate cards, contract templates, allocation methodology), and Schedule 96 was supposed to go live June 10. What changed last Wednesday. PGE filed almost 200 pages of tariff text. OPUC staff flagged that the volume of updates exceeded what the original schedule allowed for review, and that several of the new rate cards used cost-allocation methodologies that hadn't been litigated in the April order. The Commission delayed the effective date to July 7 and reopened a 14-day comment period. What's actually contested. The 29% rate increase headline gets the press attention, but the substantive fight is on three smaller-but-load-bearing pieces: (1) the 'load ramp commitment' — how PGE will treat customers whose actual load comes in below their contracted ramp (penalty or credit?); (2) the 'on-site generation offset' — whether BTM gas counts against the customer's Schedule 96 load, and at what efficiency multiplier; (3) the 'emissions-linked interconnection rule' — what triggers a flag that load growth is incompatible with PGE's RPS commitments under HB 2021. Each is the kind of fight that's likely to recur in every state's Schedule-96-equivalent tariff design.
Primary source · OPB / Utility Dive / KOIN ↗
Why it matters
Schedule 96 is the leading-edge implementation of the separate-rate-class model that every state moratorium bill (including NY S10642) wants to copy. The fact that the implementing tariff slipped a month — and the substantive content of what's slipping — is the most useful planning input for every developer with a non-Oregon site and every state PUC drafting its own Schedule 96 equivalent. For Cliff's regulatory knowledge graph, the three contested pieces above are now reusable template fields for every other large-load tariff page: 'load ramp commitment', 'on-site generation offset rule', 'emissions-linked interconnection trigger'. For client-facing underwriting in Oregon specifically, the July 7 effective date now lines up almost exactly with the ERCOT July 10 Batch Zero effective date and the July 24 PCLR declaration deadline — so any developer with a multi-state portfolio (Oregon + Texas being a common pair for hyperscale colocation) is making the two interconnection decisions in the same week.
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