November 25, 1998

 Via Federal Express

 Carole J. Washburn
 Secretary

Washington Utilities & Transportation Commission
1300 Evergreen Park Drive S.W.
Olympia WA  98504-7250

Re: Rules Relating to Securities, Liens, Affiliated Interests, Refunding of 
Notes, and Lease of
  Utility Facilities
Docket No. A-980085

Dear Ms. Washburn:

  Enclosed please find an original and eleven copies of the comments of the 
Industrial Customers of Northwest Utilities (“ICNU”) in response to the Notice 
of Opportunity to Submit Written Comments on Proposed Rule issued by the 
Commission in the above-captioned docket on November 9, 1998.  Please return 
one file-stamped copy of the comments in the self-addressed, stamped envelope 
provided.

  ICNU is an incorporated, non-profit association of large industrial electric 
customers in the Pacific Northwest, with offices in Portland, Oregon.  A list 
of the forty-two ICNU members is included as Attachment A.

  ICNU’s specific comments are as follows:

 WAC 480-146-010 – Filing

 ICNU believes that the proposed rule should be revised to allow for filing by 
facsimile or electronic mail.

WAC 480-146-091 – Reporting of Affiliated Interest Transactions

 ICNU believes that the definition of “Affiliated Interest Transactions” should 
be expanded to include transactions between a utility and a third party with 
whom the utility has a marketing or other strategic alliance.

 WAC 480-146-095 – Form of Lease Application

 ICNU believes that the form of lease application should include a statement 
explaining why the proposed lease is in the public interest.

  ICNU appreciates the opportunity to comment on the Commission’s proposed rule 
revisions.  If you have any questions, please do not hesitate to contact me.

      Sincerely yours,


      Melinda J. Horgan