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August 18, 2005

Mr. Jim Allegretto

Senior Assistant Chief Accountant

United States Securities and Exchange Commission

Mailstop 3561

100 F Street, NE

Washington, DC 20549

      Re:

      PacifiCorp

        Form 10-K for Fiscal Year Ended March 31, 2005

      Filed
        May 27, 2005

        File No. 1-5152

Dear Mr. Allegretto:

We have received your letter dated August 8, 2005, commenting on the above-referenced filing. Set forth below are our responses to the comments in the letter. Your comments are also included below for your convenience.

Form 10-K for Fiscal Year Ended March 31, 2005

General

            1.

            Where a comment below requests additional disclosure or other revisions to be made, these revisions should be included in your future filings, as applicable.

Response

      Included
        below are additional disclosures and other revisions PacifiCorp made in
        its recently filed Form 10-Q for the three months ended June 30, 2005,
        which will be reflected in future filings as well.

Consolidated
      Balance Sheets, page 65

            2.

            Please explain to us why your allowance for doubtful accounts as a percentage of accounts receivable decreased significantly from 9.9% at March 31, 2004 to 3.96%

Mr. Jim Allegretto

August 18, 2005

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      at
        March 31, 2005. Additionally, please be detailed in explaining why write-offs
        for the past 3 years consistently exceed the provision for doubtful accounts.

Response

    The decrease
      in PacifiCorp’s allowance for doubtful accounts as a percentage of
      accounts receivable from 9.9% at March 31, 2004 to 3.96% at March 31, 2005
      primarily resulted from the write-off of $12.0 million of individually significant
      wholesale accounts receivable. PacifiCorp’s allowance for doubtful
      accounts receivable includes not only a reserve for retail accounts receivable
      based on historical experience, but also reserves for specific retail and
      wholesale accounts receivable, which are recorded in the period in which
      collectibility becomes doubtful (with corresponding charges to net income).
      Accounts receivable are subsequently written off and reversed against the
      previously established reserve (with no impact on net income) in the period
      in which a triggering event occurs, including developments and settlements
      associated with legal and bankruptcy proceedings, payment defaults and other
      events.

    Net write-offs
      exceeded the provision for doubtful accounts from fiscal 2003 through fiscal
      2005 due to the level of write-offs related to amounts specifically reserved
      prior to fiscal 2003 as a result of the calendar 2000/2001 energy crisis.
      Write-offs of previously reserved amounts included $6.7 million of individually
      significant wholesale accounts receivable in fiscal 2003, $4.0 million of
      individually significant commercial retail accounts receivable in fiscal
      2004 and $12.0 million of individually significant wholesale accounts receivable
      in fiscal 2005 ($8.0 million of which were receivable from Enron Corp.).
      PacifiCorp’s write-offs and provision for doubtful accounts in each
      of fiscal 2003 through 2005 were also affected by a decline in the percentage
      of retail accounts receivable outstanding greater than 90 days from 11.7%
      to 8.1% to 5.4% as of March 31, 2003, 2004 and 2005, respectively, due to
      more rigorous collection efforts and more frequent receipt of security deposits
      from customers with credit risk.

Note 1 – Summary of Significant Accounting Policies, page 70

            3.

            Please explain to us the reason for extending the life of certain computer software systems to reflect operational plans. In this regard, you may want to describe the nature of the operational plans necessitating a change. Further, advise whether such change affects the results of the utility operations. If not, explain the nature of the software subject to amortization.

Mr. Jim Allegretto

August 18, 2005

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Response

      As
        part of its annual 10-year planning process during the three months ended
        June 30, 2004, PacifiCorp reviewed its information technology plan for
        the replacement and upgrade cycles for its integrated enterprise resource
        planning (ERP) and general ledger system, as well as PacifiCorp’s
        retail customer receivables, billing and service system. PacifiCorp’s
        combined investment in these major systems was $251.5 million. As a result
        of this review, PacifiCorp determined that it would not replace either
        of these systems during the subsequent 10 years, but would pursue a strategy
        of making upgrades every few years as needed. This information technology
        plan was consistent with PacifiCorp’s shift towards focusing available
        capital on utility infrastructure construction to support increasing customer
        growth.

    At the time
      the decision to extend the life of the ERP and general ledger system from
      10 to 15 years was made, PacifiCorp was into year 6 of the originally expected
      10-year life of the system. At the time the decision to extend the life
      of the retail customer receivables, billings and service system from 10
      to 18 years was made, PacifiCorp was into year 8 of the originally expected
      10-year life of the system. The ends of the extended useful lives for both
      systems are within the horizon of PacifiCorp’s 10-year plan and consistent
      with its information technology planning.

    ERP and
      General Ledger System – The decision not to
      replace this system and to extend its life was made due to the planned expansion
      of the functionality of the system, as well as the proven additional functionality
      provided by the last major upgrade. When this system was implemented in
      1998, PacifiCorp had anticipated significant changes in the regulatory environment
      as some states in which PacifiCorp operates had indicated a move towards
      a non-regulated operating environment, which would have increased the likelihood
      of technical obsolescence within the period of the original asset life.
      However, at the time of the aforementioned 10-year plan review, PacifiCorp’s
      status as a regulated utility remained unchanged and was well supported
      by the existing operational and reporting functionalities of the system.
      PacifiCorp further determined that replacing the system in such a short
      time frame would not be a prudent investment given demands for capital investment
      in utility infrastructure, the $152.6 million already invested in the system
      and its existing functionality, which supports operations across the company.

    Retail
      customer receivables, billings and service system
      – The decision not to replace this system and to extend its life was
      made due to proven benefits from the last major upgrade and the customization
      of the system for PacifiCorp’s service territories, current regulatory
      mandates and tariff-based rates. Based on the stable nature of PacifiCorp’s
      business, PacifiCorp determined that the system could be maintained

Mr. Jim Allegretto

August 18, 2005

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    and could
      effectively provide the necessary functionality to support operations and
      accounting for retail revenues. As a result, PacifiCorp determined that
      replacing the system would not be a prudent investment given demands for
      capital investment in utility infrastructure and the $98.9 million already
      invested in the system. Previous plans for replacement of this system were
      removed from PacifiCorp’s 10-year plan.

    The extended
      lives will more appropriately reflect the use of the systems over the period
      in which benefits will be obtained and services provided to customers. Both
      of these changes are reflected in the results of the utility operations
      for the year ended March 31, 2005 as disclosed in PacifiCorp’s Form
      10-K. Although there may be a short time lag as general rate cases are filed
      in each state, the impact on amortization of the change in lives is being
      reflected in lower annual revenue requirements for these systems, which
      are used in determining customers’ rates. Thus, over time, the net
      impact of this change in estimate on the results of the utility operations
      is expected to be minimal.

Note 3 – Derivative Instruments, page 79

            4.

            Please explain to us the rationale for changing to LIBOR in discounting your derivative portfolio. Assuming LIBOR is the appropriate index, explain why the change was made on September 30, 2004 as opposed to some other date. Please be specific as to the timeline of events that gave rise to such change. Lastly, it appears you treated this change as a change in estimate and accounted for it prospectively. Tell us why it does not constitute a change in principle. We may have further comment.

Response

    The timing
      of PacifiCorp’s change to the London Interbank Offered Rate (LIBOR)
      coincided with the implementation of International Accounting Standards
      (IAS) by PacifiCorp’s parent company, Scottish Power PLC, which is
      listed on both the London and New York Stock Exchanges. As PacifiCorp is
      consolidated under Scottish Power, it is required to report its financial
      information for Scottish Power’s reporting purposes under IAS and adopted IAS along
      with Scottish Power at April 1, 2005.

    In order to
      meet the IAS adoption date, the IAS implementation project was commenced
      in early fiscal 2005. During the implementation process, Scottish Power
      determined that it would utilize LIBOR for discounting purposes under IAS
      39. This decision prompted an evaluation by PacifiCorp of its continued
      use of the US Treasury rate during the three months ended September 30,
      2004. At that time, PacifiCorp elected to change its discount rate for US
      GAAP reporting purposes

Mr. Jim Allegretto

August 18, 2005

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      because
        it determined that LIBOR provides a better estimate than the US Treasury
        rate as an index for discounting PacifiCorp’s derivatives portfolio
        under SFAS 133. The change to LIBOR also minimized the costs of maintaining
        two separate interest-rate curves and contract valuation models under
        US GAAP and IAS.

    SFAS 133 guidance
      identifies only two acceptable benchmark interest rates, LIBOR and the US
      Treasury rate. At the time of its implementation of SFAS 133, PacifiCorp
      adopted the US Treasury rate because it was a readily available benchmark
      interest rate, based on PacifiCorp’s then-current data sources. In
      considering the change to LIBOR, PacifiCorp relied upon the definition of
      “fair value” in SFAS 133 (Appendix F) and determined that
      using LIBOR provides a better estimate under these criteria. For example,
      LIBOR includes a credit-risk premium that better reflects certain of the
      costs of, and risks involved in, corporate borrowings and offers a better
      estimate of the rate at which derivative contracts can be settled in an
      arm’s-length transaction in the energy and utility industries. LIBOR
      is also a commonly used discounting measure for derivative contracts in
      the energy and utility industries, and therefore its use for discounting
      purposes is consistent with the assumptions that a number of other market
      participants would use in determining fair value. Furthermore, advances
      under PacifiCorp’s revolving line of credit are generally based on
      LIBOR. For these reasons, PacifiCorp determined that its use of LIBOR would
      be more consistent with the objective of measuring the fair value of its
      contract derivative portfolio.

    PacifiCorp
      believes that this is a change in an accounting estimate from one acceptable
      index (the US Treasury rate) to another (LIBOR), in accordance with the
      guidance in paragraph 10 of APB 20. A derivative contract valuation model
      is an estimate, and inputs to this estimate, such as the discount rate,
      are part of the overall estimation process. Further supporting this assessment
      is Paragraph 11 of APB 20, which indicates that if there is an unclear differentiation
      between a change in accounting estimate and a change in accounting principle,
      such change can be considered a change in estimate.

    PacifiCorp
      disclosed the effects of this change in estimate with prospective application
      during the period of change. As described in the footnotes to PacifiCorp’s
      financial statements, the overall effects of this change in estimate were
      not material to PacifiCorp’s results of operations, cash flows or financial
      position.

            5.

            Please tell us what caused you to change your estimate from 3 to 6 years for periods covered by market quotes. We would expect that the ability to project further into the future arose over time. If this is not correct, then explain the specific one-time event that changed that ability. Otherwise, tell us why such change was not made as

Mr. Jim Allegretto

August 18, 2005

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      additional
        years became available over time rather than 3 years on March 31, 2005.
        Finally, given the significant downward adjustment in the fair value of
        non-trading contracts, please advise whether this calls into question
        the integrity of your modeling techniques for long-term contracts with
        no market quotes. We may have further comment.

Response

      The
        period covered by market quotes was changed as a result of a review of
        market price information availability at the end of fiscal 2005. This
        review resulted in increased confidence in PacifiCorp being able to obtain
        more reliable market price information through 6 years on a
        consistent basis. The factors leading to this increased confidence included
        a trend of more consistent market quotes and transactions for future periods,
        as well as an increase in PacifiCorp’s long-term natural gas hedging
        activity as a consequence of the company’s construction of additional
        utility infrastructure.

    Prior to the
      change, PacifiCorp used market price information for the first 3 years,
      a weighted blend of market-based prices and fundamental price forecast information
      for years 4 through 6 and fundamental price forecast information after year
      6. The primary reason PacifiCorp’s modeling technique relied upon a
      weighted blend of market-based quotes and fundamental price forecast data
      for years 4 through 6 was because the depth and availability of market price
      information to PacifiCorp for this period was considered insufficient to
      be relied upon exclusively for valuation purposes. PacifiCorp previously
      reviewed the reliability and consistency of available market data in the
      first quarter of fiscal 2004 and subsequently re-validated the availability
      of market price information in the third quarter of fiscal 2004 through
      data provided by a new vendor of electricity pricing information. Both reviews
      indicated that using 3 years of market data exclusively and weighted blending
      for years 4 through 6 was still appropriate. From the fourth quarter of
      fiscal 2004 until the end of fiscal 2005, there were no specific events
      suggesting a need to change the estimate in the interim period.

    PacifiCorp