Mail Stop 3561

 					August 8, 2005



Mr. David Mendez
Chief Accounting Officer
PacifiCorp
825 N.E. Multnomah Street
Portland, OR 97232

	Re:	PacifiCorp
		Form 10-K for Fiscal Year Ended March 31, 2005
		Filed May 27, 2005
		File No. 1-5152

Dear Mr. Mendez:

      We have reviewed your filing and have the following
comments.
Where indicated, we think you should revise your disclosures in
future filings in response to these comments.  If you disagree, we
will consider your explanation as to why our comment is
inapplicable
or a revision is unnecessary.  Please be as detailed as necessary
in
your explanation.  In some of our comments, we may ask you to
provide
us with information so we may better understand your disclosure.
After reviewing this information, we may or may not raise
additional
comments.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

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

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

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% 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.

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.

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.
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
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.

Note 17 - Retirement Benefit Plans, page 95
6. Please explain to us how you calculate the market related value
of
plan assets as that term is defined in SFAS 87.  Since there is an
alternative to how you can calculate this item, and it has a
direct
effect on pension expense, we believe you should disclose how you
determine this amount.


Item 9A. Controls and Procedures, page 106
7. We note your principal executive and financial officers
concluded
that your disclosure controls and procedures were effective, "in
all
material respects, in timely alerting management to material
information relating to PacifiCorp and its consolidated
subsidiaries
required to be included in its periodic reports filed pursuant to
the
Securities Exchange Act of 1934."  Please also state, if true,
whether the same officers concluded the controls and procedures
were
effective in "ensur[ing] that information required to be disclosed
by
an issuer in the reports that it files or submits under the Act is
accumulated and communicated to the issuer`s management, including
its principal executive and principal financial officers, or
persons
performing similar functions, as appropriate to allow timely
decisions regarding required disclosure."  See Exchange Act Rule
13a-
15(e).  Further, we note that you concluded that your disclosure
controls and procedures were effective in all material respects.
Given this qualifying language, it remains unclear whether your
principal executive officer and principal financial officer have
concluded that your disclosure controls and procedures are
effective.
Please revise your disclosure to state, in clear and unqualified
language, the conclusions reached by your principal executive
officer
and your principal financial officer on the effectiveness of your
disclosure controls and procedures.  Please also confirm to us
that
removal of this qualifying language does not result in a change in
your conclusion as to the effectiveness of disclosure controls and
procedures as of the end of the period covered by this report.
8. We note that you made no disclosures regarding changes in
internal
control over financial reporting as required by Item 308(c) of
Regulation S-K.  Please confirm to us, if true, that there were no
changes in your internal control over financial reporting during
the
last fiscal quarter that have materially affected, or are
reasonably
likely to materially affect, your internal control over financial
reporting.

Exhibits 31.1 and 31.2

9. Please eliminate reference to the titles, principal executive
officer and principal financial officer, in the introductory
paragraph of the Section 302 certifications.  Refer to Item
601(b)(31) of Regulation S-K.

*    *    *    *

      As appropriate, please respond to these comments within 10
business days or tell us when you will provide us with a response.
Please furnish a cover letter that keys your responses to our
comments and provides any requested information.  Detailed cover
letters greatly facilitate our review.  Please understand that we
may
have additional comments after reviewing your responses to our
comments.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing includes all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed investment decision.  Since the
company and its management are in possession of all facts relating
to
a company`s disclosure, they are responsible for the accuracy and
adequacy of the disclosures they have made.

	In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that:

* the company is responsible for the adequacy and accuracy of the
disclosure in the filing;

* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filing; and

* the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

      In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.

      You may contact Staff Accountant Sarah Goldberg at (202)
551-
3340 if you have questions regarding comments on the financial
statements and related matters.  Please contact me at (202) 551-
3849
with any other questions.

							Sincerely,


							Jim Allegretto
							Senior Assistant Chief
Accountant


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Mr. Mendez
PacifiCorp
August 8, 2005
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