FERC.docx

December 12, 1996
Honorable Lois D. Cashell, Secretary
Federal Energy Regulatory Commission
888 First Street N.E., Room 1A
Washington, DC 20426
Dear Ms. Cashell:
This letter is submitted by the Idaho Public Utilities Commission in support of the filing of The Washington Water Power Company (WWP) with respect to WWP’s Direct Access Delivery Service Tariff.  To gain experience and information, the IPUC authorized a prototype experiment that provides a small number of WWP retail customers with the opportunity to purchase energy in the marketplace.
The IPUC does not wish at this time to engage the Federal Energy Regulatory Commission in a process to delineate state and federal jurisdiction, including evaluation of the seven factors presented by FERC in Order 888.  The IPUC would like the information that will be obtained from completion of service under the limited term WWP Direct Access Delivery Tariff.  In addition, we agree with WWP’s position that unbundling the commodity service alone does not result in any change in state regulation of the balance of utility services.
Accordingly, the Idaho Public Utilities Commission urges the Federal Energy Regulatory Commission to defer any federal regulation of the Direct Access Delivery Service Tariff in favor of the ongoing state regulation by the IPUC for the duration of the experiment.
Very truly yours,
Ralph NelsonMarsha H. SmithDennis S. Hansen
PresidentCommissionerCommissioner
bls/L-ferc.com