sec_sw_dh.doc

November 22, 2000

Catherine A. Fisher
Assistant Director
United States Securities and Exchange Commission
Mail Stop 0508 CF
Washington, D.C. 20549

RE: ScottishPower SEC File No. 70-9669

Dear Ms. Fisher:

The Idaho Public Utilities Commission is apprised that ScottishPower plc in SEC File No. 70-9669 has requested authority to obtain financing to acquire exempt wholesale generators (EWGs) and foreign utility companies (FUCOs). ScottishPower operates and does business in the state of Idaho under the corporate name of PacifiCorp dba Utah Power & Light Company. PacifiCorp is an electrical corporation and public utility in the state of Idaho and is subject to the jurisdiction of the Idaho Commission with regard to its public utility operations and its retail electric rates.

As President of the Idaho Public Utilities Commission, I represent to the Securities and Exchange Commission that I have reviewed the Idaho Commission’s statutory authority pursuant to Title 61 Idaho Code. I have also reviewed the conditions of the ScottishPower/PacifiCorp merger approval in Idaho as set forth in Idaho PUC Case No. PAC-E-99-1, Order No. 28213 issued November 15, 1999, conditions that establish further regulatory authority and additional ratepayer protection and insulation from the effects of diversification. I can certify to the SEC that “the Idaho Commission has the authority and resources to protect ratepayers subject to its jurisdiction and intends to exercise its authority” by effectively regulating the Idaho operations of PacifiCorp. Reference Public Utility Holding Company Act, Section 33(a).

Please be apprised that the Idaho Public Utilities Commission expresses serious concern with the SEC’s apparent intent to authorize ScottishPower to incur an “aggregate investment” exceeding 100% of its “consolidated retained earnings.” As ScottishPower is asking for blanket investment authorization in this case and because such investments carry with them some inherent risk that may impact the financial viability of ScottishPower and its stock value, we recommend as a condition that any SEC approval require the detailed reporting of all FUCO and EWG investments to the SEC and the Idaho Public Utilities Commission.

Sincerely,

Dennis S. Hansen
President

bls/L:sec_sw_dh

Catherine A. Fisher
November 22, 2000
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