20001122SEC File No. 70-9669.pdf

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
Catherine A. Fisher
November 22, 2000
Page 2

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

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