Comments on the Load Profiling Report

The following is the text of the comments filed with the CPUC on 10/9/98
by Sierra Pacific Power Co.:

Sierra Pacific Power Company ("Sierra") submits the following comments
on the load profiling report.

Sierra requests that the report states that it only applies to those
utilities who take part in the ISO retail settlement process.  The
discussion in the report pertains to the three large utilities, PG&E,
SCE and SDG&E, who are members of the ISO/PX.  Those utilities also
serve direct access customers within the regulatory jurisdiction one
state.  There is no discussion of how these issues will apply to
multi-jurisdictional utilities like Sierra.  Sierra Pacific is not a
member of the ISO/PX, but is the transmission provider (as well as the
local distribution company) operating in a  separate control area
extending into two states, Nevada and California.  Currently, of the two
states, only California permits direct access to retail customers.
Nevada will permit direct access by January 1, 2000.  Sierra Pacific has
modified its FERC tariffs to accommodate direct access, but its tariffs
are separate and apart from those of the ISO.  Sierra's California sales
are less than 10% of its system sales.  Policies that apply to the three
large utilities may not be appropriate for a multi-jurisdictional
utility.  Sierra believes that it would be useful to have similar rules
in both states to minimize the costs and confusion that ESPs and
Scheduling Coordinators will face if confronted with two different
procedures depending upon where their customers are located.

Sierra requests that the Commission acknowledge that costs to implement
some of the policies described in the report will impose costs on our
ratepayers.  Sierra only has 40,000 retail customers to bear these
costs.  Until direct access begins in Nevada the implementation of
dynamic profiling to reduce unaccounted for error (UFE) will not be
appropriate for Sierra.  For example, Sierra's California sales alone
are less than its system UFE.  Policies designed to minimize UFE in
California will be ineffective for us unless some coordination with
Nevada is achieved.

Dated this 8th Day of October, 1998.

Respectfully submitted,

Sierra Pacific Power Company
PO Box 10100
Reno, NV 89520 

By /s/ David M. Norris
David M. Norris
Attorney for Sierra Pacific Power Company


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