Bruce R. DeBolt
Senior Vice President & CFO
Telephone:  503.220.2406
Facsimile:  503.220.2584
Email:  brd@wnatural.com

      September 30, 1998


Secretary
WASHINGTON UTILITIES &
TRANSPORTATION COMMISSION
1300 S. Evergreen Park Drive SW
P.O. Box 47250
Olympia, WA 98504-7250

Re:  Docket No. U-971835 (Year 2000 Compliance)

  This is Northwest Natural Gas Company’s (NW Natural) quarterly report for the 
quarter ending September 30, 1998, in response to the Commission’s order dated 
May 27, 1998, regarding the Year 2000 issue.
  In its letter dated August 14, 1998, the Commission asked the utilities to 
add or update their Internet sites to include a web page devoted to Year 2000 
compliance efforts.  NW Natural maintains a page in its Website with 
information on our Year 2000 program.  The specific URL for the page is 
http://www.nng.com/about_us/reginfo/y2000.html.  We plan to update the page 
continually as our program progresses.
  We will transmit the cover letter for this quarterly report electronically, 
to the WUTC Records Center, so that the Commission may post it to the 
Commission’s Internet site.  The transmission will not include the detailed 
attachments listed below, but we will provide copies of these attachments in 
response to reasonable requests.

September 30, 1998
Page 2
  
  
  Company representatives who will be conversant in NW Natural’s Year 2000 
efforts are:
  
  Avi Lev
  Year 2000 Compliance Specialist
   Tel:  617.227.1397
   Fax:  617.227.1291
  E-mail: a1l@nwnatural.com
  
  Bruce R. DeBolt
  Senior Vice President & CFO
  Tel:  503.220.2406
  Fax:  503.220.2584
  E-mail: brd@nwnatural.com
  
  The company is preparing, but has not yet distributed, a notification to 
business customers regarding customer premises equipment.  We will report our 
progress on the Commission’s request for that notice as it occurs.  Our 
expectation is that the notice can be completed and transmitted to customers 
within the next month, so the Company hereby requests an extension of the 
September 30 request date through October 31, 1998.

  The current status of staffing, costs and specific application conversions in 
NW Natural’s Compliance Program is reported in the “Year 2000 Project Status 
Summary Report for Period 7/7/98—8/31/98,”attached.
  
  Also attached are copies of two reports recently provided to the company’s 
Y2K steering committee, one giving the status of “Non-IS” systems and the other 
the status of “Desktop Systems,” and a special report titled “Upstream 
Suppliers and Year 2000.”
  
  Finally, also attached is an updated version of the company’s Year 2000 Web 
page.  It should be installed in our Website (www.nwnatural.com) within the 
next week.

September 30, 1998
 Page 3
  
  
 If you have questions about NW Natural’s Year 2000 program, please call Mr. 
Avi Lev, Year 2000 Compliance Specialist, at 503.226.4211, extension 5728, or 
617.227.1397.

       Very truly yours,

       Bruce R. DeBolt

       Bruce R. DeBolt
       Senior Vice President and 
        Chief Financial Officer

BRD:la
Enclosures
Cc w/Enc.: Mark Dodson 
Chuck Beyer
      Dwayne Foley   
      Catherine Jones
      Susan Ackerman
     Avi Lev
Ross Wescott