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 Transfer of Property
Docket No. A-980084

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 12, 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 480-143-XX1 – General Contents
 
ICNU believes that the application for a transfer of property must include a 
detailed analysis of the fair market value of the property being transferred.

 WAC 480-143-040 – Public Hearing

 ICNU believes that upon the request of any customer, the Commission should 
hold a public hearing to determine whether the proposed property transfer is in 
the public interest.

 WAC 480-143-050 – Application In the Public Interest

 ICNU believes that any transfer of property to an affiliated interest should 
be at the higher of book value or fair market value.

  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