August 16, 2024

Maria M. Pope
President, Chief Executive Officer, and Director
Portland General Electric Co.
121 SW Salmon St.
Portland, OR 97204

        Re: Portland General Electric Co.
            Definitive Proxy Statement on Schedule 14A
            Filed March 6, 2024
            File No. 001-05532-99
Dear Maria M. Pope:

      We have limited our review of your most recent definitive proxy statement
to those issues
we have addressed in our comments.

       Please respond to this letter by providing the requested information
and/or confirming that
you will revise your future proxy disclosures in accordance with the topics
discussed below. If
you do not believe a comment applies to your facts and circumstances, please
tell us why in your
response.

       After reviewing your response to this letter, we may have additional
comments.

Definitive Proxy Statement on Schedule 14A
Pay Versus Performance Disclosures, page 81

1.     We note that you use diluted earnings per share as your Company-Selected
Measure
       pursuant to Item 402(v)(2)(vi) of Regulation S-K. However, on page 81 it
appears that
       your table discloses your Adjusted EPS of $1.88 for fiscal year 2020,
instead of your
       diluted EPS of $1.72. In future filings, please revise to disclose the
same Company-
       Selected Measure for all years presented.
2.     We note that your Summary Compensation Table includes a column showing
the change
       in actuarial present value of your PEO   s accumulated pension benefits,
but do not see a
       corresponding line in your Item 402(v)(2)(iii) of Regulation S-K
compensation actually
       paid calculations at the bottom of page 81. Item 402(v)(2)(iii)(A) of
Regulation S-
       K requires, in conducting your compensation actually paid calculation,
that you deduct the
       change in the actuarial present value of accumulated benefits under all
defined benefit and
       actuarial pension plans reported in the Summary Compensation Table.
Although we note
 August 16, 2024
Page 2

       the row in your compensation actually paid calculations table titled
Change FV of
       pension service cost during the year    we are unable to determine what
amounts are
       intended to be included there, since it appears you may have aggregated
all pension-
       related calculations in this row. Please tell us the source(s) of the
amounts included under
       this column heading and in your future disclosure, ensure that amounts
derived directly
       from another source, such as the Summary Compensation Table, are
included as they
       appear in that source. Your disclosure must also include separate line
items for each of the
       numerical amounts deducted and added pursuant to Item 402(v)(2)(iii) of
Regulation S-
       K and may not aggregate steps. For guidance, refer to Regulation S-K
Compliance and
       Disclosure Interpretations 128D.04.
        We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.

       Please contact Christopher Dunham at 202-551-3783 or Amanda Ravitz at
202-551-3412
with any questions.



                                                            Sincerely,

                                                            Division of
Corporation Finance
                                                            Disclosure Review
Program