Re:	Portland General Electric Company

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1.	Please show us via example and related journal entries how the amortization of customer refunds for the ISFSI tax credits in 2011 increased depreciation expense. In this regard, when you disclose “offset in Revenues” in bullet points 1 through 3, we assume this means that your revenue requirement (tariffs) were reduced for this item. If our assumption is incorrect, please clarify it.

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•	The $18 million of ISFSI tax credits returned to customers in 2011 through reduced tariff revenues had the impact of increasing 2012 revenues as there were no additional ISFSI tax benefits returned to customers in 2012 (i.e., the amortization period ended December 31, 2011).

•	The $13 million increase in depreciation expense related to a shorter operating life for the Boardman plant had the impact of increasing revenues in 2012 (and in 2011 beginning in July when the approved tariff went into effect) as the OPUC authorized PGE to begin collecting the increased depreciation expense from customers.

•	The $5 million increase in amortization related to the Solar Feed-In Tariff had the impact of increasing revenues effective January 2012 as the OPUC authorized PGE to collect costs associated with this program from customers beginning in 2012.

2.

Please explain to us whether you have given any effect to the Oregon Tax Court’s ruling regarding the treatment of wholesale electricity sales in your effective tax rate computation or your uncertain tax provision. If so, please explain in detail how the ruling is reflected in your financial statements. If it is a contingency disclosure matter only, please advise how determined that no effect should be given in your historical financial statements for this ruling. Please also explain whether this ruling is in anyway related to the change in effective tax rate due to apportionment of state income taxes between Oregon and Washington. In any event, an explanation of the disparate treatment between the Tax Court’s ruling and the Oregon Department of Revenue may be helpful to the staff’s understanding.

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1.	In 2006, PGE requested and received a written opinion letter from the Oregon Department of Revenue (“DOR”) stating that electricity should be treated as the sale of tangible personal property.

2.	In 2007, the DOR issued an administrative rule, Oregon Administrative Ruling 150-314-665(2)-(c), stating that electricity should be treated as tangible personal property and apportioned to the state of contractual delivery. The tax years at issue in the Oregon Tax Court case were 2002, 2003 and 2004.

3.	PGE contacted the DOR in October 2012 to inquire about the impact of the Oregon Tax Court’s ruling. The DOR stated that the administrative ruling mentioned above was still in effect pending any further ruling or appeal. It is not clear if any ruling would be applied retroactively or prospectively.

3.

We note your disclosure that in May 2013 you discovered an error in your financial statements as a result of overbilling an industrial customer and concluded that the error is not material to any past annual or interim reporting period. However, it appears that the correcting adjustment may have a material impact on your results of operations for the three and six months ended June 30, 2013. As such, please provide us with your SAB 108 analysis for the three and six months ended June 30, 2013 that supports your conclusion. Please ensure your response addresses both quantitative and qualitative factors outlined in SAB 99 as well as any other factors considered.

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(1)	Whether the error arises from an item capable of precise measurement or whether it arises from an estimate and, if so, the degree of imprecision inherent in the estimate - The correction for the error was derived from measurable data (i.e., actual meter readings and billing rates for applicable periods) which results in a precise calculation of the impact of the error.

(2)	Whether the correction of the error hides a failure to meet analysts’ consensus expectations for the enterprise - To the best of our knowledge, the customer billing error and resulting out of period adjustment did not hide a failure to meet analysts’ consensus expectations for prior year earnings and full year 2013 earnings.

(3)	Whether the correction of the error changes a loss into income or vice versa - Although the adjustment of this item in Q2 2013 reduced revenues by $9 million, as discussed above, the impact of this item did not individually create a net loss for the quarter or for projected full-year 2013.

(4)	Whether the misstatement affects the registrant’s compliance with regulatory requirements - PGE is subject to various forms of regulatory compliance at the federal and state levels. This misstatement did not affect any compliance with these regulatory requirements.

(5)

Whether the error affects PGE’s compliance with loan covenants or other contractual requirements - PGE is required to meet earnings coverage and security provisions as set forth in the Indenture of Mortgage and Deed of Trust securing the Company’s First Mortgage Bonds. This error did not impact compliance with the Indenture. PGE’s credit facilities contain customary covenants and credit provisions, including a requirement that limits consolidated indebtedness, as defined in the credit agreements, to 65% of total capitalization (debt ratio). This error did not impact PGE’s covenants over the credit facilities as the debt ratio is well below the 65% limit. The error was not significant to retained earnings and did not materially alter the debt ratio.

•	the Company is responsible for the adequacy and accuracy of the disclosure in the Form 10-K and Form 10-Q;

•	Staff comments or changes to disclosure in response to Staff comments do not foreclose the Commission from taking any action with respect to the Form 10-K or Form 10-Q; and

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•	the Company may not assert Staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.