PORTLAND GENERAL ELECTRIC CO /OR/

Previous wording

The information in this report includes statements that are forward-looking within the meaning of the Private Securities Litigation Reform Act of 1995. Such forward-looking statements include, but are not limited to, statements that relate to expectations, beliefs, plans, assumptions, and objectives concerning future results of operations, business prospects, loads, outcome of litigation and regulatory proceedings, capital expenditures, market conditions, events or performance, and other matters. Words or phrases such as “anticipates,” “believes,” “estimates,” “expects,” “intends,” “plans,” “predicts,” “projects,” “will likely result,” “will continue,” “should,” “based on,” “conditioned upon,” “considers,” “could,” “expected,” “forecast,” “goals,” “needs,” “promises,” “subject to,” “targets,” or similar expressions are intended to identify such forward-looking statements.

Current wording

The information in this report includes statements that are forward-looking within the meaning of the Private Securities Litigation Reform Act of 1995. Such forward-looking statements include, but are not limited to, statements that relate to expectations, beliefs, plans, assumptions, and objectives concerning future results of operations, business prospects, loads, outcome of litigation and regulatory proceedings, capital expenditures, market conditions, events or performance, and other matters. Words or phrases such as “anticipates,” “believes,”

Previous wording

In addition to any assumptions and other factors and matters referred to specifically in connection with forward-looking statements, factors that could cause actual results or outcomes for PGE to differ materially from those discussed in such forward-looking statements include:

Current wording

In addition to any assumptions and other factors and matters referred to specifically in connection with forward-looking statements, risks, uncertainties and other important factors that could cause actual results or outcomes for PGE to differ materially from those discussed in such forward-looking statements include:

Previous wording

•governmental policies, executive orders, legislative action, and regulatory audits, investigations, and actions, including those of the Federal Energy Regulatory Commission (FERC), the Public Utility Commission of Oregon (OPUC), the United States Securities and Exchange Commission (SEC), and the Division of Enforcement of the Commodity Futures Trading Commission, with respect to allowed rates of return, financings, electricity pricing and price structures, acquisition and disposal of facilities and other assets, construction and operation of plant facilities, transmission of electricity, recovery of power costs, operating expenses, deferrals, timely recovery of costs and capital investments, energy trading activities, and current or prospective wholesale and retail competition;

Current wording

•new or revised governmental policies, executive orders, legislative action, and regulatory audits, investigations, and actions, including those of the Federal Energy Regulatory Commission (FERC), the Public Utility Commission of Oregon (OPUC), and the Internal Revenue Service, with respect to allowed rates of return, financings, electricity pricing and price structures, acquisition and disposal of facilities and other assets, construction and operation of plant facilities, transmission of electricity, recovery of power costs, operating expenses, deferrals, timely recovery of costs and capital investments, energy trading activities, tax credits, and current or prospective wholesale and retail competition;

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•trade tariffs, inflation, and volatility in interest rates;

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•increases to operating costs that could result from changes to trade tariffs, rising inflation, and volatility in interest rates;

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•risks and uncertainties related to current or future All-Source RFP projects, including, but not limited to regulatory processes, transmission capabilities, system interconnections, inflationary impacts, supply chain constraints, supply cost increases (including application of trade tariffs), permitting and construction delays, available tax credits, counterparty credit risk, and legislative uncertainty;

Current wording

•risks and uncertainties related to current or future All-Source Request for Proposals (RFP) projects, including, but not limited to regulatory processes, transmission capabilities, system interconnections, inflationary impacts, supply chain constraints, supply cost increases (including application of trade tariffs), permitting and construction delays, available tax credits, counterparty credit risk, and legislative uncertainty;

Previous wording

•unseasonable or severe weather and other natural phenomena, such as the greater size and prevalence of wildfires in Oregon in recent years, which could affect public safety, customers’ demand for power, and PGE’s financial health and ability and cost to procure adequate power and fuel supplies to serve its customers, access the wholesale energy market, or operate its generating facilities and transmission and distribution systems, and the Company’s costs to maintain, repair, and replace such facilities and systems, and recovery of such costs;

Current wording

•severe weather and other natural phenomena, such as the greater size and prevalence of wildfires in Oregon in recent years, which could affect public safety, customers’ demand for power, and PGE’s financial health and ability and cost to procure adequate power and fuel supplies to serve its customers, access the wholesale energy market, or operate its generating facilities and transmission and distribution systems, and the Company’s costs to maintain, repair, and replace such facilities and systems, and recovery of such costs;

Previous wording

•default or nonperformance on the part of any parties from whom PGE purchases fuel, capacity, or energy, which may cause the Company to incur costs to purchase replacement power and related renewable attributes at increased costs;

Current wording

•default or nonperformance on the part of any parties from whom PGE purchases fuel, capacity, or energy, that may cause the Company to incur costs to purchase replacement power and related renewable attributes at increased costs;

Previous wording

•cybersecurity attacks, data security breaches, physical attacks and security breaches, or other malicious acts, internally or to third parties, that cause damage to the Company’s generation, transmission, or distribution facilities, information technology systems, inhibit the capability of equipment or systems to function as designed or expected, or result in the release of confidential customer, vendor, employee, or Company information;

Current wording

•cybersecurity attacks, data security breaches, physical attacks and security breaches, or other malicious acts, internally or to third parties, that cause damage to the Company’s generation, transmission, or distribution facilities, information technology systems, or employees, or inhibit the capability of equipment or systems to function as designed or expected, or result in the release of confidential customer, vendor, employee, or Company information;

Previous wording

The Company exists to power the advancement of society. PGE energizes lives, strengthens communities, and fosters energy solutions that promote social, economic, and environmental progress. The Company is committed to being a clean energy leader and delivering steady growth and returns to shareholders. PGE is focused on working with customers, communities, policy makers, and other stakeholders to deliver affordable, safe, reliable electricity service to all, while increasing opportunities to deliver clean and renewable energy, reducing greenhouse gas (GHG) emissions, and responding to evolving customer expectations. At the same time, the Company is building an increasingly smart, integrated, and interconnected grid that spans from residential customers to other utilities within the region. PGE is transforming all aspects of its business to empower its workforce to be even more results oriented to serve customers well. To create a clean energy future, PGE is focused on the following strategic imperatives:

Current wording

The Company exists to power the advancement of society. PGE energizes lives, strengthens communities, and fosters energy solutions that promote social, economic, and environmental progress. The Company is committed to our customers’ clean energy goals and delivering steady growth and returns to shareholders. PGE is focused on working with customers, communities, policy makers, and other stakeholders to deliver affordable, safe, reliable electricity service to all, while increasing opportunities to deliver clean and renewable energy, reducing greenhouse gas (GHG) emissions, and responding to evolving customer expectations. At the same time, the Company is building an increasingly smart, integrated, and interconnected grid that spans from residential customers to other utilities within the region. PGE is transforming all aspects of its business to empower its workforce to be even more results oriented to serve customers well. To create a clean energy future, PGE is focused on the following strategic imperatives:

Previous wording

Empowering customers and communities—PGE’s customers have a desire for purchasing clean energy, as over 225 thousand residential and small commercial customers voluntarily participate in PGE’s Green Future Program, the largest renewable power program by participation in the nation. In 2017, Oregon’s most populous city, Portland, and most populous county, Multnomah, each passed resolutions to achieve 100% clean and renewable electricity by 2035 and 100% economy-wide clean and renewable energy by 2050. Other jurisdictions in PGE’s service area have similar goals and continue to consider similar goals for the future.

Current wording

Empowering customers and communities—PGE’s customers have a desire for purchasing clean energy, as over 228 thousand residential and small commercial customers voluntarily participate in PGE’s Green Future Program, the largest renewable power program by participation in the nation. In 2017, Oregon’s most populous city, Portland, and most populous county, Multnomah, each passed resolutions to achieve 100% clean and renewable electricity by

Previous wording

The Resource Planning Process—PGE’s resource planning process includes working with customers, stakeholders, and regulators to chart the course toward a clean, affordable, and reliable energy future. With the passage of HB 2021, PGE created a Clean Energy Plan (CEP), which articulates the Company’s strategy to make continued progress towards the 2030, 2035, and 2040 emission reduction targets through an equitable transition to a decarbonized grid. The CEP is based on, and was filed in connection with, the Company’s 2023 Integrated Resource Plan (IRP). PGE filed its first combined IRP and CEP with the OPUC in March 2023. That filing projected PGE’s resource and capacity needs over the next 20 years and proposed an Action Plan to meet near-term needs, subject to the new HB 2021 emissions reduction requirements.

Current wording

The Resource Planning Process—PGE’s resource planning process includes working with customers, stakeholders, and regulators to chart the course toward a clean, affordable, and reliable energy future. With the passage of HB 2021, PGE created a Clean Energy Plan (CEP), which articulates the Company’s strategy to make continued progress towards the 2030, 2035, and 2040 emission reduction targets through an equitable transition to a decarbonized grid. The CEP is based on, and was submitted to the OPUC in connection with, the Company’s 2023 Integrated Resource Plan (IRP) in March 2023, the first combined IRP and CEP. That filing projected PGE’s resource and capacity needs over the next 20 years and proposed an Action Plan to meet near-term needs, subject to the new HB 2021 emissions reduction requirements.

Previous wording

The CEP/IRP Update identified a new Preferred Portfolio as a result of the refreshed analysis. PGE is not proposing any changes to the Action Plan that was acknowledged within the 2023 CEP/IRP, which supports the Company's progress toward emissions targets and Preferred Portfolio resource need procurement through the 2025 All-Source Request for Proposals (RFP). This approach represents the best combination of cost, risk, community benefit, and decarbonization.

Current wording

The CEP/IRP Update identified a new Preferred Portfolio as a result of the refreshed analysis. PGE is not proposing any changes to the Action Plan that was acknowledged within the 2023 CEP/IRP, which supports the Company's progress toward emissions targets and Preferred Portfolio resource need procurement through the 2025 All-Source RFP. This approach represents the best combination of cost, risk, community benefit, and decarbonization.

Previous wording

To better distinguish resource needs, the CEP/IRP Update reports the capacity from hybrid solar and battery storage resources by individual technology. This reporting change increases the stated need of the 2023 CEP/IRP Action Plan from a range of 2,700 to 3,700 MW, to an updated range of 3,500 to 4,500 MW of renewable energy and non-emitting capacity, inclusive of 2023 RFP projects, which remain under negotiation.

Current wording

To better distinguish resource needs, the CEP/IRP Update reports the capacity from hybrid solar and battery storage resources by individual technology. This reporting change increased the stated need of the 2023 CEP/IRP Action Plan from a range of 2,700 to 3,700 MW, to an updated range of 3,500 to 4,500 MW of renewable energy and non-emitting capacity, inclusive of 2023 RFP projects, which remain under negotiation.

Previous wording

•Seaside Grid—The 200 MW Battery Energy Storage System (BESS) facility, located in Portland, Oregon was placed in service on July 8, 2025 and is owned by PGE. As of June 30, 2025, the Company has recorded $340 million, including AFUDC, in construction work-in-progress (CWIP) for the Seaside Grid.

Current wording

•Seaside Grid—The 200 MW Battery Energy Storage System (BESS) facility, located in Portland, Oregon was placed in service on July 8, 2025 and is owned by PGE.

Previous wording

The agreements related to Clearwater and all BESS agreements represent the final procurement from the 2021 All-Source RFP. Resources required to meet the remaining 2030 need are anticipated to be procured through future acquisition processes, including, but not limited to, the 2023 All-Source RFP and future RFPs.

Current wording

The agreements related to Clearwater and all BESS agreements represent the final procurement from the 2021 All-Source RFP. Resources required to meet the remaining 2030 need are anticipated to be procured through future acquisition processes, including, but not limited to, the 2023 and 2025 All-Source RFPs and future RFPs.

Previous wording

The BESS facilities qualify for federal investment tax credits (ITCs). The agreements related to Clearwater qualify for production tax credits (PTCs) and are eligible under Oregon’s Renewable Portfolio Standard (RPS) .

Current wording

The BESS facilities qualify for federal investment tax credits (ITCs). The agreements related to Clearwater qualify for production tax credits (PTCs) and are eligible under Oregon’s Renewable Portfolio Standard (RPS). These projects are estimated to produce approximately $262 million in combined ITC and PTC benefits over time on behalf of customers.

Previous wording

Following passage of House Resolution 1, the One Big Beautiful Bill Act (OBBB), on July 4, 2025, PGE plans to provide an opportunity for all conforming 2023 RFP bidders to refresh their pricing. PGE, in collaboration with an independent evaluator, will work to update scoring and ranking to reflect pricing changes from bidders in the coming months.

Current wording

Following passage of House Resolution 1, the One Big Beautiful Bill Act (OBBB), on July 4, 2025, PGE provided an opportunity for all conforming 2023 RFP bidders to refresh their pricing to capture the impacts of the new legislation and recent trade tariffs. Evaluation of refreshed bids, including updates to bid scoring and ranking, was performed in collaboration with an OPUC-selected third-party independent evaluator.

Previous wording

Following the enactment of the OBBB and related executive orders in July 2025, PGE continues to evaluate the potential impact of these federal tax credit changes on project economics and overall portfolio cost. Loss of tax credit availability could increase renewable project costs and corresponding customer prices. In response, PGE incorporated additional information requirements into the RFP to better assess tax credit eligibility, supply chain risks, and cost implications. Further detail on the federal policy changes and associated risks is provided in "The One Big Beautiful Bill Act” section in this Overview.

Current wording

Following the enactment of the OBBB and related executive orders in July 2025, PGE continues to evaluate the potential impact of these federal tax credit changes on project economics and overall portfolio cost. Loss of tax credit availability could increase renewable project costs and corresponding customer prices. In response, PGE incorporated additional information requirements into the RFP to better assess tax credit eligibility, supply chain risks, and cost implications. Further detail on the federal policy changes and associated risks is provided in"The One Big Beautiful Bill Act” in the Laws and Regulations section of this Overview.

Previous wording

Both the 2021 and 2023 RFPs were the subject of regulatory and legal challenges initiated by NewSun Energy LLC, focused on the scoring methodology of the RFPs and OPUC acknowledgement of the final shortlists. Two of NewSun’s challenges to the 2021 RFP were dismissed as moot in recent court decisions. Although NewSun filed for review by the Oregon Supreme Court, in both cases the petitions for review were denied. PGE has joined the proceedings as an intervenor, and the remaining challenges are in various stages of litigation or regulatory review. PGE cannot predict the outcome of these proceedings or potential impact, if any, on its 2021 and 2023 All-Source RFP process.

Current wording

Various regulatory and legal challenges directed at the OPUC have been initiated by NewSun Energy LLC, related to PGE’s RFP process. PGE has joined the proceedings as an intervenor, and the challenges are in various stages of litigation or regulatory review. PGE cannot predict the outcome of these proceedings or potential impact, if any.

Previous wording

NewSun was an intervenor in the Clearwater RAC proceeding in Docket UE 427, in which the OPUC rejected NewSun’s proposals to change the RFP oversight process, but adopted conditions proposed by OPUC staff on how PGE should recognize Clearwater’s capacity factor and transmission assumptions in its AUT and PCAM beginning in 2025. PGE sought and received clarification of the OPUC’s February 21, 2025 order (Order 25-075) adopting the conditions, in Order 25-223, which granted certain of PGE’s requests and denied others. PGE has a Petition for Judicial Review of Order 25-075 pending at the Oregon Court of Appeals. PGE cannot predict the outcome or potential impact, if any, on future RFP, AUT, or PCAM proceedings.

Current wording

NewSun was an intervenor in the Clearwater RAC proceeding in Docket UE 427, in which the OPUC rejected NewSun’s proposals to change the RFP oversight process, but adopted conditions on how PGE should recognize Clearwater’s capacity factor and transmission assumptions in its Annual Power Cost Update Tariff (AUT) and power cost adjustment mechanism (PCAM) beginning in 2025. PGE sought and received clarification of the OPUC’s February 21, 2025 order (Order 25-075) adopting the conditions, in Order 25-223, which granted certain of PGE’s requests and denied others. Both PGE and NewSun have Petitions for Judicial Review of Order 25-075 pending at the Oregon Court of Appeals. PGE cannot predict the outcome or potential impact, if any, on future RFP, AUT, or PCAM proceedings.

Previous wording

In May 2024, PGE signed a non-binding memorandum of understanding in the development of the North Plains Connector, an approximately 415-mile, high-voltage direct-current (HVDC) transmission line to be constructed with endpoints near Bismarck, North Dakota and Colstrip, Montana. The parties entered negotiations with the United States Department of Energy (U.S. DOE) to finalize the project objectives, terms, and conditions, including the Company’s participation, which is expected to involve a 20% ownership share of the approximately $3.2 billion total investment of the project. In August 2024, the project was awarded a $700 million grant from the U.S. Department of Energy’s Grid Resilience and Innovation Partnerships (GRIP) program to further support its development and would reduce the overall total investment of the project. A portion of the GRIP funding is allocated to assess upgrades to the Colstrip Transmission System. See “Federal Grants” in this Overview for further discussion over the impacts of Federal grants and effect of Presidential executive orders.

Current wording

In May 2024, PGE signed a non-binding memorandum of understanding in the development of the North Plains Connector, an approximately 415-mile, high-voltage direct-current (HVDC) transmission line to be constructed with endpoints near Bismarck, North Dakota and Colstrip, Montana. The parties entered negotiations with the United States Department of Energy (U.S. DOE) to finalize the project objectives, terms, and conditions, including the Company’s participation, which is expected to involve a 20% ownership share of the approximately $3.2 billion total investment of the project. In August 2024, the project was awarded a $700 million grant from the U.S. DOE’s Grid Resilience and Innovation Partnerships (GRIP) program to further support its development and would reduce the overall total investment of the project. A portion of the GRIP funding is allocated to assess upgrades to the Colstrip Transmission System. See “Federal Grants” in the Laws and Regulations section of this Overview for further discussion over the impacts of Federal grants and effect of Presidential executive orders.

Previous wording

The U.S. DOE selected the Confederated Tribes of Warm Springs (CTWS), with PGE as a subrecipient under the grant, for a $250 million grant to upgrade the existing 230 kV Bethel-Round Butte Transmission line to 500 kV. The project will accelerate the development of transmission capacity, enabling new generation in Central and Eastern Oregon to reach customer demand loads in Western Oregon. The added capacity and associated upgrades will also increase resiliency of the transmission system as well as resiliency of the CTWS communities by increasing resources available to the CTWS to support economic growth opportunities. See“Federal Grants” in this Overview for further discussion over the impacts of Federal grants and the potential effect of Presidential executive orders.

Current wording

The U.S. DOE selected the Confederated Tribes of Warm Springs (CTWS), with PGE as a subrecipient under the grant, for a $250 million grant to upgrade the existing 230 kV Bethel-Round Butte Transmission line to 500 kV. The project will accelerate the development of transmission capacity, enabling new generation in Central and Eastern Oregon to reach customer demand loads in Western Oregon. The added capacity and associated upgrades will also increase resiliency of the transmission system as well as resiliency of the CTWS communities by increasing resources available to the CTWS to support economic growth opportunities. See“Federal Grants” the Laws and Regulations section of this Overview for further discussion over the impacts of Federal grants.

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•Wildfire Mitigation—PGE has a Wildfire Mitigation Program under which an annual Wildfire Mitigation Plan (WMP) is developed and submitted to the OPUC, as required by State law, to coordinate activities across the Company and with State-wide stakeholders. The 2025 WMP Update forecasts $53 to $57 million in operations and maintenance costs and an additional $57 to $78 million in capital investments, for the year ending 2025, to continue system hardening efforts, expand situational awareness capabilities, implement specific inspection and maintenance along with vegetation management, raise community and customer awareness, and take operational actions within high fire risk zones. PGE strives to improve regional safety by mitigating the risk that PGE’s electric utility infrastructure could cause a wildfire, while limiting the impacts of PSPS events and other mitigation activities on customers and increasing the resiliency of PGE assets to wildfire damage. In the six months ended June 30, 2025, PGE invested $24 million in capital projects related to wildfire mitigation and resiliency and utility asset management, consistent with the 2025 WMP Update.

Current wording

•Wildfire Mitigation—PGE has a Wildfire Mitigation Program under which an annual Wildfire Mitigation Plan (WMP) is developed and submitted to the OPUC, as required by State law, to coordinate activities across the Company and with State-wide stakeholders. The 2025 WMP Update forecasts $46 to $49 million in operations and maintenance costs and an additional $57 to $78 million in capital investments, for the year ending 2025, to continue system hardening efforts, expand situational awareness capabilities, implement specific inspection and maintenance along with vegetation management, raise community and customer awareness, and take operational actions within high fire risk zones. PGE strives to improve regional safety by mitigating the risk that PGE’s electric utility infrastructure could cause a wildfire, while limiting the impacts of PSPS events and other mitigation activities on customers and increasing the resiliency of PGE assets to wildfire damage. In the nine months ended September 30, 2025, PGE invested $45 million in capital projects related to wildfire mitigation and resiliency and utility asset management, consistent with the 2025 WMP Update.

Previous wording

In October 2023, the OPUC accepted PGE’s second TE plan, which covers the 2023 to 2025 time period and considers current and planned activities, along with forecasted EV loads. To date, PGE has incurred $11 million in capital expenditures under the current TE plan. PGE expects to submit its draft 2026-2028 TE plan on July 25, 2025.

Current wording

In October 2023, the OPUC accepted PGE’s second TE plan, which covers the 2023 to 2025 time period and considers current and planned activities, along with forecasted EV loads. To date, PGE has incurred $14 million in capital expenditures under the current TE plan.

Previous wording

Federal Grants—In November 2021, the $1.2 trillion Infrastructure Investment and Jobs Act (IIJA), which includes approximately $550 billion of new federal spending, was signed into law. PGE continues to pursue multiple areas under the IIJA, and other state and federal programs, for potential grant funding of projects. These projects target improvements in electrical system reliability and resiliency, wildfire situational awareness and mitigation, greater communications capabilities, advancements in customer usage analytics using artificial intelligence, renewable resources and advanced electrical grid support, hydro generation operations, and regional transmission capacity constraints.

Current wording

Federal Grants—PGE continues to monitor and pursue opportunities on behalf of customers to leverage state, federal, and private foundation funding programs to offset the cost of projects. These projects target improvements in electrical system reliability and resiliency, wildfire situational awareness and mitigation, greater communications capabilities, advancements in customer usage analytics using artificial intelligence, renewable resources and advanced electrical grid support, hydro generation operations, and regional transmission capacity constraints.

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Inflation Reduction Act of 2022—The IRA was signed into law in August 2022 with a majority of the provisions effective for tax years beginning after December 31, 2022.

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Inflation Reduction Act of 2022 (IRA)—The IRA was signed into law in August 2022 with a majority of the provisions effective for tax years beginning after December 31, 2022.

Previous wording

The United States Treasury and the Internal Revenue Service released extensive rules addressing credit transfer eligibility and application, including but not limited to, required registration, filing, and documentation for transferors and transferees to elect and claim a credit transfer. In December 2023, PGE received approval from the OPUC to transfer 2023 PTCs and record any difference in the full value and the discounted value in a property balancing account. Consistent with options available under the IRA, the Company transferred 2023 credits with the final transfer occurring in the first quarter of 2024. On April 17, 2024, PGE received approval from the OPUC to transfer 2024 and 2025 PTCs and record any difference between the full value and the discounted value in a property balancing account. On December 11, 2024, PGE received approval from the OPUC to transfer 2024 ITCs and return the net proceeds from the sale to PGE customers. PGE has entered into agreements to transfer 2023 through 2025 tax credits and transferred $13 million and $112 million, net of discounts, for cash proceeds in the first half of 2025 and in 2024, respectively. The Company expects to generate and transfer approximately $168 million in tax credits in 2025.

Current wording

The United States Treasury and the Internal Revenue Service released extensive rules addressing credit transfer eligibility and application, including but not limited to, required registration, filing, and documentation for transferors and transferees to elect and claim a credit transfer. In December 2023, PGE received approval from the OPUC to transfer 2023 PTCs and record any difference in the full value and the discounted value in a property balancing account. Consistent with options available under the IRA, the Company transferred 2023 credits with the final transfer occurring in the first quarter of 2024. On April 17, 2024, PGE received approval from the OPUC to transfer 2024 and 2025 PTCs and record any difference between the full value and the discounted value in a property balancing account. On December 11, 2024, PGE received approval from the OPUC to transfer 2024 ITCs and return the net proceeds from the sale to PGE customers.

Previous wording

The One Big Beautiful Bill Act—On July 4, 2025, the President signed the OBBB, which materially amends or repeals several renewable-energy tax incentives that were originally enacted under the IRA. It is expected that projects currently under construction and intended to be placed in service this year will remain eligible for the PTC or ITC amounts already reflected in balances; therefore, no adjustment was recorded in the quarter ended June 30, 2025. The transferability of tax credits, as provided under the IRA, also remains in effect. A July 7, 2025 executive order has added uncertainty with respect to the specific actions necessary to demonstrate a project’s start of construction. Further clarity is expected from the Secretaries of the Treasury and the Interior as it relates to their findings and actions taken under this executive order within 45 days.

Current wording

The One Big Beautiful Bill Act—The OBBB significantly amends or repeals several renewable-energy tax incentives originally enacted under the IRA. Projects currently under construction and expected to be placed in service during 2025 remain eligible for PTC or ITC benefits; accordingly, no adjustments were recorded in the quarter ended September 30, 2025. The transferability of tax credits, as provided under the IRA, also remains in effect. Following the July 7, 2025 executive order that added uncertainty with respect to the specific actions necessary to demonstrate a project’s start of construction, on August 15, 2025, the Treasury Department issued a notice for establishing the beginning of construction for wind and solar projects. The notice requires large projects to satisfy a physical-work test after September 2, 2025, eliminates certain inventory-procurement safe harbors, and accelerates the placed in service deadline to December 31, 2027.

Previous wording

The accelerated placed-in-service deadline for wind and solar, earlier phase-down for other technologies, and repeal of the permanent 10% ITC may reduce or eliminate the availability of renewable-energy credits on future projects. The Company cannot yet reasonably estimate the impact on PGE’s results of operations, financial position, and cash flows or on future capital expenditures, deferred-tax assets, current and future All-Source RFPs, and customer prices.

Current wording

These changes, together with the repeal of the permanent ten percent ITC, as outlined in the OBBB, are expected to reduce or eliminate the availability of renewable-energy credits on future projects. The Company cannot yet reasonably estimate the impact on PGE’s results of operations, financial position, and cash flows or on future capital expenditures, deferred tax assets, current and future All-Source RFPs, and customer prices.

Previous wording

See“The Resource Planning Process” in this Overview for information regarding the impact of OBBB on the RFP process.

Current wording

See“The Resource Planning Process” in the Investing in a Clean Energy Future section of this Overview for information regarding the impact of the OBBB on the RFP process.

Previous wording

The Company has a 20% ownership share in Colstrip and, in response to SB 1547, has accelerated depreciation of Colstrip to December 31, 2025. In order to meet PGE’s regulatory, legislative, and reliability requirements, the Company continues to evaluate the continuation of its ownership in Colstrip. See Note 8, Contingencies, in the Notes to Condensed Consolidated Financial Statements in Item 1.—“Financial Statements” for information regarding legal proceedings related to Colstrip.

Current wording

The Company has a 20% ownership share in Colstrip and, in response to SB 1547, has accelerated depreciation of Colstrip to December 31, 2025. . In order to meet PGE’s regulatory, legislative, and reliability requirements, the Company continues to evaluate its ongoing ownership in Colstrip. See Note 8, Contingencies, in the Notes to Condensed Consolidated Financial Statements in Item 1.—“Financial Statements” for information regarding legal proceedings related to Colstrip.

Previous wording

Any reduction in generation from Colstrip has the potential to provide additional capacity availability on the Colstrip transmission facilities, which stretch from eastern Montana to near the western end of that state to serve markets in the Pacific Northwest and neighboring states. PGE has an approximate 15% ownership interest in, and capacity on, the Colstrip transmission facilities. See“Investing in a Clean Energy Future” in this Overview for information regarding development in eastern Montana.

Current wording

Any reduction in generation from Colstrip has the potential to provide additional capacity availability on the Colstrip transmission facilities, which stretch from eastern Montana to near the western end of that state to serve markets in the Pacific Northwest and neighboring states. PGE has an approximate 15% ownership interest in, and capacity on, the Colstrip transmission facilities. See the Investing in a Clean Energy Future section of this Overview for information regarding development in eastern Montana.

Previous wording

•provide opportunity to pursue recovery of energy storage costs related to renewable energy in the Company’s Renewable Adjustment Clause (RAC) filings.

Current wording

•provide opportunity to pursue recovery of energy storage costs related to renewable energy in the Company’s RAC filings.

Previous wording

HB 3179—The Oregon Legislature in 2025 passed HB 3179 aimed at making energy bills more affordable and transparent for customers. Under the provisions of the legislation, which still awaits the Governor’s signature, the OPUC shall balance the interests of the utility investor and the consumer by considering the cumulative economic impact of the proposed price or schedule of prices on the electric or natural gas company’s residential customers. Electric or natural gas companies are required to file a multiyear rate plan on a regular interval that is no less than three and no more than seven years long. The OPUC shall require each electric and natural gas company to, at least annually, file with the OPUC, and make publicly available, a report on any price adjustments that the electric or natural gas company expects within the next 12 months. Such report must identify all price adjustment requests that an electric or natural gas company has filed or reasonably knows or anticipates to file. Any increase in residential prices may not take effect from November 1 to March 31.

Current wording

HB 3179—The Oregon Legislature in 2025 passed HB 3179 aimed at making energy bills more affordable and transparent for customers. Under the provisions of the legislation, which the Governor has now signed and which will require a significant amount of rulemaking to implement, the OPUC shall balance the interests of the utility investor and the consumer by considering the cumulative economic impact of the proposed price or schedule of prices on the electric or natural gas company’s residential customers. Electric or natural gas companies are required to file a multiyear rate plan on a regular interval that is no less than three and no more than seven years long. The OPUC shall require each electric and natural gas company to, at least annually, file with the OPUC, and make publicly available, a report on any price adjustments that the electric or natural gas company expects within the next twelve months. Such report, the first of which would be due at the end of 2026 at the earliest, must identify all price adjustment requests that an electric or natural gas company has filed or reasonably knows or anticipates to file. Any increase in residential prices may not take effect from November 1 to March 31.

Previous wording

On April 8, 2025, the President issued a proclamation, Regulatory Relief for Certain Stationary Sources to Promote American Energy, granting a two-year compliance exemption pursuant to the CAA Section 112(i)(4) for the EPA’s MATS rule. The EPA subsequently notified companies whether their sources had been granted the exemption. Colstrip was granted an exemption until July 8, 2029.

Current wording

On April 8, 2025, the President issued a proclamation, Regulatory Relief for Certain Stationary Sources to Promote American Energy, granting a two-year compliance exemption pursuant to the CAA Section 112(i)(4) for the EPA’s MATS rule. The EPA subsequently notified companies whether their sources had been granted the exemption. Colstrip was granted an exemption until July 8, 2029. Environmental groups have filed court challenges to the MATS exemptions.

Previous wording

On June 11, 2025, to advance the goals of the President’s Unleashing American Energy executive order, the EPA proposed to repeal the 2024 GHG emissions standards for fossil fuel-fired power plants promulgated under Section 111 of CAA. The EPA also proposed to repeal specific amendments to the updated MATS, that were promulgated in 2024, including the revised filterable particulate matter emissions standard. Additionally, on June 30, 2025, the EPA proposed to update the 2024 ELG Rule to extend compliance deadlines and explore flexibilities to promote reliable and affordable power generation.

Current wording

On June 11, 2025, to advance the goals of the President’s Unleashing American Energy executive order, the EPA proposed to repeal the 2024 GHG emissions standards for fossil fuel-fired power plants promulgated under Section 111 of CAA. The EPA also proposed to repeal specific amendments to the updated MATS, that were promulgated in 2024, including the revised filterable particulate matter emissions standard. Additionally, on June 30, 2025, the EPA proposed to update the 2024 ELG Rule to extend compliance deadlines and explore flexibilities to promote reliable and affordable power generation. On July 29, 2025, the EPA proposed to rescind the 2009 endangerment finding, which, if approved, would remove the EPA’s authority to regulate GHGs.

Previous wording

Corporate structure—On May 23, 2025, PGE filed a notice under Oregon law with the OPUC of its intent to submit a regulatory application for approval of a holding company reorganization. On July 25, 2025, the Company expects to submit the formal application to the OPUC. PGE believes that it is in the best interests of its customers and shareholders to update its corporate structure into a holding company structure. The structure currently contemplated involves placing a non-operating corporate entity over the Company’s existing structure. Additionally, this structure would allow for the formation of a subsidiary of the holding company that could hold existing and future transmission assets. The intent of the reorganization is to take advantage of the financial flexibility provided by a holding company structure, and to support construction of new transmission assets, reliability planning, and economic development.

Current wording

Corporate structure— On July 25, 2025, the Company submitted a formal application to the OPUC seeking approval of a holding company reorganization. PGE believes it to be in the best interests of its customers and shareholders to update its corporate structure into a holding company structure. The structure currently contemplated involves placing a non-operating corporate entity over the Company’s existing structure. Additionally, this structure would allow for the formation of a subsidiary of the holding company that could hold existing and future transmission assets. The intent of the reorganization is to take advantage of the financial flexibility provided by a holding company structure, and to support construction of new transmission assets, reliability planning, and economic development.

Previous wording

PGE believes that the full amount of the deferral is probable of recovery and submitted a request for recovery early in the third quarter of 2025, with price changes to be effective over a two-year period beginning April 1, 2026. The OPUC has significant discretion in making the final determination of recovery based on its assessment of prudency and interpretation of the earnings test application, either of which could result in all, or a portion of, the deferral being disallowed. As of December 31, 2024, PGE's preliminary return on equity, based on actual results, did not exceed the OPUC's authorized rate of return. Any disallowance would be a charge to earnings, which could be material to the Company’s financial condition, results of operations, or cash flows. For further information, see “January 2024 storm and damage”in the Regulatory Assets and Liabilities section of Note 3, Balance Sheet Components in the Notes to Condensed Consolidated Financial Statements in Item 1.—“Financial Statements.”

Current wording

PGE believes that the deferral is probable of recovery and submitted a request for recovery early in the third quarter of 2025, with price changes to be effective over a two-year period beginning April 1, 2026. The OPUC has adopted a procedural schedule in Docket UE 458 for the regulatory review process that expects an order in March 2026. The OPUC has significant discretion in making the final determination of recovery based on its assessment of prudency and interpretation of the earnings test application, either of which could result in all, or a portion of, the deferral being disallowed. As of December 31, 2024, PGE's preliminary return on equity, based on actual results, did not exceed the OPUC's authorized rate of return. Any disallowance would be a charge to earnings, which could be material to the Company’s financial condition, results of operations, or cash flows. For further information, see “January 2024 storm and damage”in the Regulatory Assets and Liabilities section of Note 3, Balance Sheet Components in the Notes to Condensed Consolidated Financial Statements in Item 1.—“Financial Statements.”

Previous wording

Reliability Contingency Event (RCE)—Under the RCE mechanism, PGE is allowed to pursue recovery of 80% of costs for RCEs above amounts forecasted in the Company’s AUT, without application of an earnings test, with the remaining 20% flowing through operating expenses and subject to the existing power cost adjustment mechanism (PCAM). As of June 30, 2025, PGE’s deferred balance related to RCEs was $95 million, which includes $92 million related to RCEs deferred in 2024 and $3 million related to RCEs deferred in 2025. This includes costs from multiple qualified RCEs during 2024, the most significant of which was related to the January storm event, and costs incurred during the first half of 2025. PGE filed the results of the 2024 PCAM with the OPUC on July 1, 2025, in Docket UE 457, which included a request for $86 million, without interest, in RCE costs incurred in 2024, initiating a regulatory review process that typically results in a final determination and order from the OPUC by the end of the year of filing. Any resulting refund or collection impacting customer prices is expected to be effective April 1, 2026. PGE believes the deferred amounts as of June 30, 2025 are probable of recovery. The OPUC has significant discretion in making the final determination of recovery. The OPUC’s conclusion of overall prudence could result in a portion, or all, of PGE’s deferrals being disallowed for recovery. Such disallowance would be recognized as a charge to earnings.

Current wording

Reliability Contingency Event (RCE)—Under the RCE mechanism, PGE is allowed to pursue recovery of 80% of costs for RCEs above amounts forecasted in the Company’s AUT, without application of an earnings test, with the remaining 20% flowing through operating expenses and subject to the existing PCAM. As of September 30, 2025, PGE’s deferred balance related to RCEs was $89 million, which includes $87 million related to multiple qualified RCEs deferred during 2024, the most significant of which was related to the January storm event, and $2 million related to RCEs deferred during the first nine months of 2025. PGE filed the results of the 2024 PCAM with the OPUC on July 1, 2025, in Docket UE 457, which included a request for $86 million, without interest, in RCE costs incurred in 2024, initiating a regulatory review process, The OPUC has adopted a procedural schedule for the regulatory review process that expects an order in March 2026. Any resulting refund or collection impacting customer prices is expected to be effective April 1, 2026. PGE believes the deferred amounts as of September 30, 2025 are probable of recovery. The OPUC has significant discretion in making the final determination of recovery. The OPUC’s conclusion of overall prudence could result in a portion, or all, of PGE’s deferrals being disallowed for recovery. Such disallowance would be recognized as a charge to earnings.

Previous wording

Power costs—Pursuant to the AUT process, PGE annually files an estimate of power costs for the following year. As approved by the OPUC, the 2025 AUT included a final increase in power costs for 2025, and a corresponding increase in NVPC, of $72 million from 2024 levels, which were reflected in customer prices effective January 1, 2025.

Current wording

Power costs—Pursuant to the AUT process, PGE annually files an estimate of power costs for the following year. As approved by the OPUC, the 2025 AUT included a final increase in power costs for 2025, and a corresponding increase in net variable power costs (NVPC), of $72 million from 2024 levels, which were reflected in customer prices effective January 1, 2025.