Docket Number	Docket Name	Company
UI 531	PACIFICORP AFFILIATED INTEREST WITH SPECIAL PURPOSE ENTITY	PACIFIC POWER

Created Date	Comment Type	First Name	Last Name	Comment
12/5/2025 4:07:08 PM	Oppose Docket	John	Owen	The sale should not be allowed. If pacific corp thinks the liability is too large then the project should be ended. This is a way to limit payouts in-case of damage caused by the power line. Berkshire Hathaway should still be on the hook for damages
12/19/2025 3:30:43 PM	General Comment	Irene	Gilbert	This comment was submitted via email and included an attachment. Because our public comment system cannot process attachments, a full version of the comment has been docketed and can be accessed in the “Actions” tab in eDockets. To: Oregon Public Utility Commission December 8, 2025 From: Irene Gilbert Re: PacifiCorp Case No. UI 531 Comments This comment is submitted regarding the request for OPUC approval allowing PacifiCorp to sell their 55% interest in the Boardman to Hemingway Transmission Line to a shell company. The use of a sale with a 20 year lease back to PacifiCorp is creative, but not in the public interest. It is clear from PacifiCorp’s own statements that the company has serious financial issues. Allowing them to insulate Birkshire Hathaway from the obligations imposed due to their ownership of PacifiCorp would be a serious breach of the PUC requirement to protect utility customers of Oregon from unreasonable financial risk. This “sale” creates multiple risks to the public including, but not limited to: 1. As a wholly owned subsidiary of Birkshire Hathaway, there is a direct financial responsibility of that company for financial awards resulting from PacifiCorp actions regarding such things as future fires, a failure to restore the site should the B2H transmission line be abandoned or never completed, future litigation resulting from exceedances of the Oregon noise statutes which EFSC is allowing the utility to exceed and any other unforeseen litigation or problems resulting from the malfeasance of PacifiCorp. Setting up a shell company or LLC will insulate Birkshire Hathaway from their financial risk. 2. Once PacifiCorp becomes a “lease holder” rather than an “owner”, the ability of the PUC to place conditions on the company related to B2H will be lost. PacifiCorp will no longer be required to include the B2H in their Integrated Resource Plan. 3. The ability of the PUC to require the company to explore ways to use the B2H to serve the Oregon customers they claimed they would be serving to obtain the CPCN will no longer exist. 4. The sale of PacifiCorp’s 55% interest to another company will place into question the validity of the joint ownership agreements between Idaho Power and PacifiCorp. 5. The Idaho Power/PacifiCorp agreement provided PacifiCorp with a controlling interest and veto power regarding decisions related to the transmission line. It appears this authority will now be in the hands of a stand alone entity that owes no allegiance to the PUC, ODOE or other state agencies. Further,in the likely event that the company created to take ownership is an LLC it is questionable that these state agencies will be able to access the finances which are currently available to PacifiCorp as a wholly owned subsidiary of Birkshire Hathaway. Arguments supporting decisions in the original site certificate and amendments such as those which allowed for a $1.00 bond should PacifiCorp fail to restore the site were supported by the finances available from Birkshire Hathaway. 6. A change in ownership requires an Amended Site Certificate from the Oregon Department of Energy and Energy Facility Siting Council. This requires council to apply the standards as of the date of issuing the amended site certificate including the “need” for the development. 7. It also provides the opportunity to change the site certificate conditions which the PUC stated supported their refusal to revoke the CPCN. 8. Etc. SUMMARY This comment does not include multiple problems and questions which need to be addressed prior to allowing the sale of the majority interest in the B2H transmission line. Due to the lack of information included in the request from PacifiCorp, it is not possible to know many of the details of the request. What can be determined is that it will create an extreme risk to Oregon utility customers of having to pay for the results of future actions and litigation related to PacifiCorp. It also adds questions regarding the use of the CPCN to condemn private property for a transmission line which is nothing like the one described in the application or the CPCN. The legal questions that already exist due to PacifiCorp and Idaho Power actions in pursuing this transmission line under false pretenses continue to escalate as it moves further and further away from the description in the CPCN. Once PacifiCorp provides a complete application, and the formal public process starts, I will provide additional comments regarding the ownership and function of this development. Sincerely, Irene Gilbert, Co-Chair of Stop B2H and representing the Public Interest 2310 Adams Ave. La Grande, Oregon 97850 Email: ott.irene@frontier.com