DRAFT Report on Siting and Permitting Large-Scale Electricity Infrastructure
EXECUTIVE SUMMARY
Executive Order 25-29 directs Oregon agencies to streamline siting and permitting processes for clean energy projects, energy storage, and transmission infrastructure. In response, the Oregon Department of Energy’s Energy Facility Siting Division evaluated its statutory authorities, rules, and practices to identify opportunities for greater efficiency while maintaining strong protections for public health, communities, and natural resources.
Oregon’s centralized siting system is administered by the Energy Facility Siting Council with staff support from ODOE’s Siting Division. It was designed to consolidate multiple state and local reviews into a single, standards based, quasi-judicial process. This approach ensures consistency, transparency, and robust environmental and public health protections. It also reduces duplication across agencies. However, as the scale and urgency of renewable energy and transmission development grow, pressures on EFSC and the Siting Division have increased.
This report finds that Oregon’s current siting framework already includes many streamlined elements: consolidated state review, one appellate path directly to the Oregon Supreme Court, statutory timelines, reimbursement mechanisms to support Tribal, local government, and peer state agency participation, and a lifecycle compliance program that ensures projects are built and operated as approved. Over the last decade, EFSC and ODOE have undertaken significant modernization through rulemaking, process improvements, digital tools, and clearer public guidance resulting in more predictability and more efficient reviews.
At the same time, several challenges continue to affect timelines and workload. These include the growing complexity and size of proposed projects, increased interest and public participation, staffing limitations tied to fee-based funding, the length and resource intensity of contested cases, and differences and interplay between state, local, Tribal, and federal review processes. Transmission projects, in particular, require coordination with multiple jurisdictions and agencies, which adds inherent complexity that is independent of the state process.
This report highlights substantial progress already made, such as restructuring EFSC’s rules, improving organization of application elements, strengthening coordination with Tribes and agencies, enhancing public engagement tools, updating standards (including wildfire prevention), and modernizing the amendment processes. Additional improvements are underway through ongoing rulemaking, expanded use of digital and geospatial tools, and early-phase coordination with applicants and Tribes. The report identifies additional ideas for action that the Department and potentially the Legislature could take to find further efficiencies within the Siting Program:
The Contested Case process should be evaluated to potentially remove steps, refine them, or place clearer time expectations. Done right, this could result in valuable time savings without negatively affecting the purpose and value of this step.
The Siting Division has begun to pilot careful integration of Artificial Intelligence (AI) for administrative tasks to reduce staff burden without compromising review quality, and this could be expanded.
For simultaneous state and federal reviews, information requirements for specific standards should be evaluated to determine if federal environmental review materials can meet Council standards.
Evaluate the Siting Division’s funding model and management structure to ensure it has the capacity to deliver timely project reviews, implement process improvements, and meet growing clean energy and transmission related demands.
Evaluate the ability to streamline the review of certain requirements that are more frequently consistent across projects.
Implement Oregon Energy Strategy actions related to adequate division funding and enhancing the Oregon Renewable Energy Siting Assessment Tool.
Implement the Oregon Department of Energy’s 2026-2029 Strategic Plan pillars related to engagement and collaboration; improving the understanding and clarity of the Siting Program; and identifying and addressing opportunities to make the program more accessible.
The Siting Program considers environmental justice and equitable practices in multiple ways, though the language used can be different as the Siting Program’s procedural and substantive requirements were developed before the state adopted a definition for environmental justice and equity. Through HB 4077, environmental justice is defined as, “equal protection from environmental and health risks, fair treatment and meaningful involvement in decision making of all people regardless of race, color, national origin, immigration status, income or other identifies with respect to the development, implementation and enforcement of environmental laws, regulations and policies that affect the environment in which people live, work, learn, and practice spirituality and culture." The ability of the public to participate in the EFSC process is important and valuable. Throughout this report there are examples of work that has been done and continued process improvements that identify environmental justice considerations.
Oregon’s siting system is comprehensive, protective, and includes many streamlined components. Continued and additional improvements focused on clarity, interagency coordination, predictable timelines, targeted rule updates, and administrative efficiency will help meet the goals of EO 25 29 while maintaining the state’s commitment to environmental stewardship, public participation, and accountable energy development.