Docket Number	Docket Name	Company
UM 2447	IDAHO POWER AND OREGON TRAIL ELECTRIC COOPERATIVE JOINT APPLICATION	IDAHO POWER COMPANY

Created Date	Comment Type	First Name	Last Name	Comment
6/12/2026 11:11:15 AM	Oppose Docket	Kristoffer	Ohlensehlen	Re: Docket UM 2447 I am a residential customer of Idaho Power in Vale, Oregon, and I am writing to oppose the proposed transfer of Idaho Power’s Oregon service territory to Oregon Trail Electric Cooperative (OTEC). My primary concern is that this transaction does not represent a genuine change in who supplies our power — it simply adds a middleman between the actual power generator and the customer. Idaho Power will continue to own and operate all generation and transmission infrastructure, and OTEC has entered into a multi-year agreement to purchase wholesale electricity from Idaho Power to serve former Idaho Power customers. Oregon Trail Electric does not generate any electricity of its own. Customers like me would be paying for the same power from the same source, only now routed through an additional layer of administration and debt. What troubles me further is the financial structure of this deal. OTEC plans to take out a loan of $154 million — expected to take 25 to 30 years to repay — and that debt will be carried by the ratepayers who become OTEC members, including me. Meanwhile, Idaho Power retains the ability to raise wholesale power prices, which would then be passed directly to those same customers through OTEC with no recourse. The claimed 17.6% rate increase Idaho Power says it would impose if the sale falls through feels like a pressure tactic rather than a necessity, given that Oregon represents less than 3% of Idaho Power’s total business. I urge the Commission to scrutinize whether this transaction genuinely serves the public interest of eastern Oregon ratepayers, or primarily serves Idaho Power’s interest in exiting a small, inconvenient service territory while retaining a guaranteed wholesale customer.
8/14/2026 12:35:33 AM	General Comment			There is concern amongst affected consumers about the speed and quality of service, especially during power outages. Idaho Power has a strong history of responding quickly and getting power back online rapidly. Can OTEC match that performance? Is it possible to impose a threshold response time requirement? What recourse will consumers have if service decreases dramatically? Bruno J. Jagelski Ontario, Oregon
8/15/2026 9:59:15 AM	Oppose Docket	April	Walker	I strongly oppose the proposed sale of Idaho Power’s Oregon distribution system to OTEC, and I urge the Oregon PUC to take a very hard look at what this means for the customers who will be forced into this change. This isn’t simply a business transaction between two utilities. It affects approximately 20,000 customers across rural Eastern Oregon, including residential customers, farmers, ranchers, irrigation users, businesses, and industries. These customers deserve to know exactly how this sale will affect their rates, reliability, service, and long-term costs. The proposed $154 million purchase price is a massive financial commitment. If OTEC takes on that cost, customers need clear answers about how the purchase will be financed and whether they will ultimately be paying for it through higher rates or other charges. Rural Eastern Oregon customers already face unique challenges. Long distances, severe weather, aging infrastructure, irrigation demands, and limited access to services make reliable electricity especially important. The PUC should require a detailed and transparent analysis showing that OTEC can maintain or improve reliability without placing an unreasonable financial burden on the customers being transferred. I am also concerned about the long-term implications of tying these customers to a new utility while OTEC enters into a multi-year wholesale power arrangement with Idaho Power. Before approving this sale, the PUC should examine not only what looks reasonable on paper today, but what this arrangement could mean for customers 5, 10, and 20 years down the road. Customers should not be treated as assets being transferred from one company to another. They are the people who will ultimately pay the bills and live with the consequences of this decision. I respectfully ask the Oregon PUC to put the interests of these 20,000 customers first, demand full financial and reliability transparency, and reject the proposed sale unless it can be clearly demonstrated that the transaction will provide measurable, long-term benefits to the customers affected. This decision deserves more than a handshake between utilities. It deserves scrutiny, transparency, and accountability.
8/15/2026 10:00:08 AM	Oppose Docket	Tylton	Walker	I strongly oppose the proposed sale of Idaho Power’s Oregon distribution system to OTEC, and I urge the Oregon PUC to take a very hard look at what this means for the customers who will be forced into this change. This isn’t simply a business transaction between two utilities. It affects approximately 20,000 customers across rural Eastern Oregon, including residential customers, farmers, ranchers, irrigation users, businesses, and industries. These customers deserve to know exactly how this sale will affect their rates, reliability, service, and long-term costs. The proposed $154 million purchase price is a massive financial commitment. If OTEC takes on that cost, customers need clear answers about how the purchase will be financed and whether they will ultimately be paying for it through higher rates or other charges. Rural Eastern Oregon customers already face unique challenges. Long distances, severe weather, aging infrastructure, irrigation demands, and limited access to services make reliable electricity especially important. The PUC should require a detailed and transparent analysis showing that OTEC can maintain or improve reliability without placing an unreasonable financial burden on the customers being transferred. I am also concerned about the long-term implications of tying these customers to a new utility while OTEC enters into a multi-year wholesale power arrangement with Idaho Power. Before approving this sale, the PUC should examine not only what looks reasonable on paper today, but what this arrangement could mean for customers 5, 10, and 20 years down the road. Customers should not be treated as assets being transferred from one company to another. They are the people who will ultimately pay the bills and live with the consequences of this decision. I respectfully ask the Oregon PUC to put the interests of these 20,000 customers first, demand full financial and reliability transparency, and reject the proposed sale unless it can be clearly demonstrated that the transaction will provide measurable, long-term benefits to the customers affected. This decision deserves more than a handshake between utilities. It deserves scrutiny, transparency, and accountability.
8/18/2026 7:35:25 PM	Oppose Docket			Oregon Trail Electric has intent to purchase the Oregon territory of Idaho Power. OTEC cannot even manage the territory they own let alone doubling their size with the intent of taking on only 20 additional employees for day to day operations. OTEC has increased our rates 3 times in the last year and only told the members of 2 increases, sneaking in the third. The attrition rate is at an all time high. The entire staff of directors have zero utility experience in the field in which they manage. This merger is going to cost all members in ways of rate increases and longer wait times for power restoration.
8/18/2026 7:45:33 PM	Oppose Docket			I am under the understanding that OTEC is trying to acquire new territories…OTEC cannot handle the territory that OTEC currently is operating because they under staffed and are treating the personal like number instead of a human doing the work. The new leadership is out for himself and trying to pad his resume and reputation so he can move on if/and if this comes to fruition. This will ONLY cost all of the members higher rates. Beware everyone. I am totally against this!
8/19/2026 10:46:35 AM	Oppose Docket			Turnover rates are excessive at OTEC, burdening the other employees with an inequity in job functions and associated pay scales. Less people to do more work. The environment has become one that has no leadership, and is more of a dictatorship being lead by fear of disciplinary actions being imposed with no warning. The GM absolutely does not have the best interest of consumers in mind for this territory expansion. The upper level of management under the GM have NO experience working for or leading an electric utility, which has a direct tie to turnover and wasteful spending. As a cooperative member, this territory expansion doesn’t make financial sense unless they raise the my rates to pay for it and nobody wants a rate increase in today’s world. Rural wages have not kept up with costs. The expectation that 20,000 additional meters over a large geographical area can be adequately served for the good of the coop members with an addition of only 20 employees is unrealistic. The business plan for OTEC to make this expansion happen is lacking significantly and the “boots on the ground” will be suffering, directly affecting cooperative members in the process. The lack of investment in existing facilities, employees, tools, and equipment, is a concern for acquiring more area. Fire mitigation resources are also lacking, and taking on the fire risk of high-desert will cost the membership greatly.
8/19/2026 8:08:06 PM	Oppose Docket	Page	Frederickson	I live in the small community of Halfway, Oregon which Idaho power has provided power to since power has been in this community. They have been so good to this community and provided the best of service as long as I have lived here which has been since 1991. I am a low income senior citizen and Idaho Power provides a discount for my situation which greatly helps me. I personally don't want them to sell our service area as this would cause financial hardship because the discount would go away and power bill will increase greatly. I am also concerned about getting the same good service. Thank you for allowing me to provide my input.
8/20/2026 12:35:46 AM	General Comment			Otec residential delivery charge is 38.50 per month, my understanding is the Oregon Idaho power customers will not have to pay that in the beginning, which is hard to believe since they will be part of Otec. Otec customers are subsidizing this sale . Sent from my iPhone
8/20/2026 12:35:50 AM	General Comment			I think it would be beneficial for the commission to have a survey of OTEC members for membership satisfaction of OTEC and the managements pour handling of its employees and members. OTEC is one week from having their union employees go on strike for unfair labor practices for unlawful termination of employees. Plus not willing to pay its current employees what the industry standards are for our geographical area. OTEC doesn’t have the man power to obtain more territory let alone staff their current territory. They have zero substation technicians, only one meter man and are down several lineman. The reputation of OTEC within the industry is very poor. The current management does not treat their employees well at all, inside employees and outside employees would tell you this (and it is not just Union groups being treated badly, it’s also non represented employees being treated badly as well. OTEC advertises a member owned cooperative, until a member wants to attend a board meeting and all of the hoops they must jump through to be allowed to attend. OTEC needs to be audited for customer satisfaction, BTI relationship , along with the new line school that OTEC financed, which is called Apex line school, run by BTI personnel. Thank you for your time, Tom Higgins
8/21/2026 12:35:22 AM	General Comment			Do the Idaho Power customers know that the delivery charge for a residential meter is 38.50 per month ? Sent from my iPhone
8/21/2026 9:14:08 AM	General (Docket-Specific)	JAMES	REED	I am asking if there are guidelines for response time to minor interruptions of service. Here in Halfway we use to have a Idaho Power office where one paid bills and conducted most any business. Only the building remains but for years Halfway and likely other such communities had a IPCO employee who could reset a breaker or assess damage in about a hour and less. Now Halfway residents have to wait for a service truck from Payette Idaho or near there. Response time is generally about 2.5 to 3 hours just for the employees to use a long gaff to reset a breaker in minutes. The Oregon Trail Electric Cooperative, being a much smaller concern, is likely more sensitive to profit margins and concern exists response times may diminish further?
8/21/2026 12:16:33 PM	General (Docket-Specific)	Eric	Ellis	I'm generally supportive of the proposal to sell Idaho Power's operations in Malheur County because it appears to save the local ratepayers over the amount that Idaho Power proposes to levy. However, I am concerned that the cost of the infrastructure and its effective maintenance is being distributed on a much smaller base of payers in a service area which is large and geographically distributed. I hope that the commission is actively investigating whether the new owning cooperative is adequately able to maintain the current level of service, and will be able to invest in future upgrades. Additionally, I hope that the Commission will encourage the cooperative to maintain or increase its commitment to microgeneration such as home solar and wind power; Idaho Power has actively turned away from these sources of generation in favor of utility-scale installations which help them protect their monopoly pricing power. The cooperative should be required to add and expand community solar systems such as the Verde Light installation in Ontario above the current limits that Idaho Power resisted.
8/24/2026 10:29:50 AM	Other	Norm	Cimon	Thank you for the opportunity to comment on Idaho Power’s proposed sale of it’s Oregon territory to the Oregon Trail Electric Cooperative (OTEC). As a member of Frontier Resilient Energy & Equity I see great potential in the proposed merger if important questions are answered about strategic planning. The expanded service area is easily the sunniest and windiest part of Oregon. The proposed sale will include customers who’ve taken advantage of Idaho Power’s net metering rules which will be adopted by OTEC. Those distributed energy resources (DERs), positioned in the new service area, provide a robust seed source for what could be an expanded business model. The way energy is produced, stored, and distributed, is changing very quickly across the world and in our country. While Northwest co-ops and PUDs have been primarily brokers for power from Columbia River system dams, that power will be limited in availability. Any additional power needed in the future for the added service area will be more expensive. Moreover, the abrogation of the agreement with Northwest native tribes to assist in the management and ultimate removal of the dams, has them back in court to preserve their treaty fishing rights. Every scientific and legal opinion has stated that those rights are threatened by the dams. The hundreds of tons of sediment built up behind the dams is also a very serious problem. All of that argues for OTEC to use this as an opportunity to rethink a business model that will require substantial changes over the next five to ten years. Included with these comments is a document which was sent to the OTEC CEO, a proposal to aggregate and sell DERs into an emerging market for those resources. It’s not the only possible model, but included with this testimony as an example delivering a number of benefits to the co-op while helping to shield ratepayers from energy purchases on the open market in 2030. The international engineering journal Energy makes it clear that: "The integration of Distributed Energy Resources (DERs) is reshaping modern energy systems... " We believe that OTEC should develop and market DERs given the rapidly changing energy ecosystem. The co-ops proposed expansion into an area that has great potential for that resource brings a number of possible benefits that would prepare OTEC for the transition. We are asking the OPUC to elicit information about the co-ops plans to move into this expanding domain as a requirement for approving the sale. OTEC would be wise to adopt that as part of its business model. That is the future.
8/24/2026 9:54:06 PM	General (Docket-Specific)	Tyson	Parker	PUC Public Comment Statement I have been a Journeyman Lineman at OTEC for almost a year, and during that time I have seen two very different sides of this company. On one side are the employees in the field—some of the best people I have ever had the opportunity to work with. These employees are dedicated, hardworking, and committed to providing reliable service to our members. On the other side is management. As of today, OTEC’s union bargaining unit is on strike, and I have serious concerns about the direction of the organization under its current leadership. In my experience, management has failed to provide clear, written expectations regarding after-hours call response requirements while still holding employees accountable to standards that have never been clearly communicated. I have also observed what I believe to be inconsistent application of disciplinary practices. As the Oregon Public Utility Commission considers Idaho Power’s proposed sale of its Oregon service territory to OTEC, I urge the Commission to carefully consider the perspectives and testimony of OTEC employees. Those of us who work in the field every day have firsthand knowledge of the company’s operations, culture, and leadership. I believe the Commission should closely evaluate whether OTEC’s current management structure is equipped to take on additional responsibilities while maintaining the level of service Oregon customers deserve. Thank you for your time and consideration.
8/25/2026 12:34:58 AM	General Comment			Chair Tawney and Commissioners: My name is Jonathan Tallman, and I live in Oregon. I ask the Oregon Public Utility Commission not to approve Idaho Power’s proposed sale of its Oregon distribution system to Oregon Trail Electric Cooperative unless the Commission first requires binding, enforceable protections guaranteeing sufficient and reasonably priced electricity for the transferred customers after September 30, 2030. This concern is not hypothetical. Approximately 49,000 Lake Tahoe-area customers are presently confronting a similar power-supply problem that is data center related. Liberty Utilities serves those customers through a distribution territory formerly connected to and supplied by NV Energy. Liberty owns and operates the local distribution system, but it has depended on NV Energy for approximately 75 percent of its power. NV Energy will stop providing full-requirements service after May 2027, leaving Liberty responsible for securing a replacement supply. Although officials say Lake Tahoe residents’ lights will not simply go out, those residents are now facing uncertainty over where their power will come from, whether adequate replacement power can be obtained and how much their rates may increase. Regional data-center growth has intensified the concern. Liberty told California regulators that unprecedented large-load growth from data centers contributed to NV Energy’s inability to continue full-requirements service, although NV Energy disputes that data centers caused its decision. The proposed Idaho Power–OTEC transaction has concerning similarities. Under this proposal: * OTEC would purchase Idaho Power’s Oregon distribution system and begin serving approximately 20,000 Oregon customers. * Idaho Power would stop serving these customers directly. * Idaho Power would retain all its Oregon generation assets. * Idaho Power would retain most Oregon high-voltage transmission assets above 100 kilovolts. * Idaho Power would retain ownership and control of the 500-kilovolt Boardman-to-Hemingway transmission line. * OTEC would initially depend on a wholesale power-supply agreement with Idaho Power. * That agreement would supply the transferred territory only through September 30, 2030. * After that date, OTEC says it plans to transition these customers to Bonneville Power Administration power. A plan to obtain BPA power, however, is not the same as a binding power-supply contract combined with guaranteed firm transmission rights. OTEC acknowledges that the specific BPA power mix will depend on BPA tier availability. OTEC also acknowledges that the existing transmission capacity between BPA and Idaho Power is fully subscribed, meaning there is presently insufficient transmission capacity to move large blocks of BPA power into eastern Oregon at scale. OTEC says B2H will solve that transmission problem. But Idaho Power—not OTEC—will own B2H. This means OTEC could own the distribution wires and have the legal obligation to serve the customers while another utility continues to control the generation and major transmission facilities necessary to deliver that electricity. That is the same basic structural vulnerability now confronting Lake Tahoe residents. The Commission’s public notice says it will determine whether this transaction serves customers’ interests and maintains reliable service. To make that determination, the Commission should require complete, public answers to the following questions: 1. How many average and peak megawatts will Idaho Power be contractually required to provide OTEC through September 30, 2030? 2. Can Idaho Power curtail, terminate or refuse to extend wholesale service because of its own resource needs, Idaho population growth, industrial development or data-center demand? 3. Has BPA made a binding commitment to supply all the transferred customers beginning October 1, 2030? 4. How much of the replacement supply will qualify for BPA Tier 1 pricing, and how much could require more expensive Tier 2 or market purchases? 5. Has OTEC secured binding, long-term and firm transmission rights over B2H and Idaho Power’s retained transmission system? 6. What happens if B2H is delayed, constrained, unavailable or insufficient to serve the transferred customers’ peak demand? 7. What backup supply and transmission arrangements will exist if the planned BPA transition is not completed by September 30, 2030? 8. Who will bear the additional costs if BPA power or transmission access is unavailable or more expensive than projected? 9. Can OTEC pass those additional wholesale costs directly to customers through its Power Cost Adjustment? 10. Have Idaho Power and OTEC incorporated projected regional data-center and other large industrial loads into their generation and transmission forecasts? 11. What ongoing authority will the Oregon PUC retain to protect customers from unreasonable rates and inadequate service after the territory is transferred from a regulated investor-owned utility to a cooperative? 12. Why should the Commission approve the sale before the post-2030 power supply and transmission arrangements are secured? The proposed transaction also raises rate concerns. OTEC indicates that transferred customers would face an increase of approximately 5.7 percent at closing. OTEC’s Power Cost Adjustment would then allow changes in wholesale power costs to be passed through to retail rates annually. OTEC also says there is no fixed timeline for combining the transferred customers and existing OTEC members into one rate structure. Accordingly, the Commission must evaluate more than whether the lights will remain on during the initial transition. It must determine what customers will pay, who will control their long-term power supply and what happens when the temporary Idaho Power agreement expires. Before approving this transaction, I ask the Commission to impose the following minimum condition: Idaho Power must remain obligated to provide full-requirements wholesale electric service beyond September 30, 2030, if necessary, until OTEC proves that binding BPA power-supply arrangements and sufficient firm transmission capacity are fully operational, legally enforceable and adequate to serve the entire transferred territory under projected peak-load conditions. The Commission should also require: * A publicly available long-term power-supply and transmission plan; * Independent verification of OTEC’s post-2030 capacity and transmission assumptions; * Contingency planning for delays or constraints involving B2H; * Protection against transferred customers bearing unreasonable replacement-power costs; * Consideration of regional data-center and large-load growth; * Periodic public progress reports before September 2030; and * Commission approval before Idaho Power’s full-requirements obligation may end. Lake Tahoe residents are now learning what can happen when a distribution utility depends on a temporary wholesale arrangement and the larger supplier later prioritizes its own system needs. Oregon has the opportunity to address that danger before approving this transaction. The Commission should not allow OTEC to purchase the customers and distribution wires without simultaneously ensuring that OTEC has a binding, affordable and deliverable source of electricity for those customers after 2030. Please include this comment in the official record for Docket UM 2447. Respectfully submitted, Jonathan Tallman Oregon
8/27/2026 12:34:49 AM	General Comment			A couple things I didn’t mention in the PUC meeting yesterday… 1) OTEC recently had two separate public contacts with primary power lines, one resulting in a fatality and the other no injury reported. As of yet, I personally haven’t seen any warnings to the public or comments even giving condolences to the family of the deceased. 2) OTEC has (since 2012) required their linemen to work on three man crews. It hasn’t mattered the voltage or complexity of the work involved. This is a dangerous practice that requires the safety watch to stop looking after the crew to handle all the ground work. Sent from my iPhone
9/1/2026 12:35:15 AM	General Comment			To: Oregon Public Utility Commission Attention: AHD - UM 2247 I live in Halfway, Oregon and I am writing to object to the Idaho Power Company's proposed sale of its Oregon territory, including Halfway, to Oregon Trail Electric Cooperative. Recent news reports have stated that OTEC, which serves about 60,000 customers in Eastern Oregon from John Day to La Grande, is understaffed and unable to keep up with maintenance and repair needs for its existing customer base. I do not think residents of Halfway would benefit from joining that customer base. The Halfway, Richland, and Oxbow areas are in the far east of Baker County, at least an hour's drive from Baker City. On the other hand, we are 17 miles from Idaho on the other side of Snake River. Our area has been well-served by Idaho Power from its Hells Canyon complex of hydro dams. I expect electricity rates will increase whether Halfway is served by Idaho Power or OTEC. I think Idaho Power, with much greater resources than OTEC, would do a better job maintaining the power infrastructure and providing service and repairs to our area. Thank you. Ellen M. Smith 291 Kellogg Street Halfway, OR 97834
9/1/2026 1:29:13 PM	Oppose Docket	janice	burchard	I don't feel like this would be a good purchase at the time. So no to the sell
9/3/2026 6:14:14 PM	Oppose Docket	Alfred	Hellbusch	I would like to submit my comments on the acquisition of Idaho Power territories by Oregon Trail Electric Cooperative (OTEC), I am the newest board member of OTEC just elected 8/6/26 to position #3 Harney County by the members of all districts I defeated the incumbent by a 60%-40% margin, I was not a board member when this acquisition was discussed and voted on, but I do not support this acquisition, and I am hearing from the members that elected me to serve and current customers of Idaho Power that reside in Harney County they are not in favor of this acquisition. The members are coming to me with concerns that OTEC cannot manage the territories they have now, how are they going to manage another 20,000 meters, the turnover rate of outside plant workers either being terminated or resigning since 2019 is over 10% of the work force, and from the data I have been able to obtain the national average for a utility is 3-7% in the article I read it said 3% is considered normal if it reaches 7% human resources should be working to get to the root cause of the problem, so far in 2026 twelve technicians have either been terminated or resigned, and their total personal employed is around 80-90 employees so they are above 10% already for 2026. OTEC just settled a strike with the local the union IBEW 125 and it was mostly about the unfair labor practices of OTEC, is what the union workers were telling me. If OTEC had a better record with their employees and members I would support this acquisition, but at this time I feel OTEC has a lot of internal problems that need to resolved before this acquisition is granted, I was asked by members to run for this board position because of these problems, and it is my duty to represent the members of Oregon Trail Electric to the best of my ability, and at the current time the members that are calling, texting, and messaging me they are not in support of the acquisition. Thank you for your time and I hope this acquisition will be denied at this time I do not feel it is in the best interest of the OTEC members and Idaho Power customers at this time.
9/8/2026 2:33:58 AM	Oppose Docket	Bennett	thede	I would think very hard about approving this as while Idaho power agrees to provide power for a certain amount of time does not guarantee that power will continue to be provided after those two (?) years. Considering the data center starting to go up in Idaho and the fact that this sale does not include power generation that Idaho owns in Oregon it is entirely possible that the cooperative (which is currently experiencing a full strike) will be unable to adequately facilitate the Idaho power customers' electrical needs in the most populated area in eastern Oregon with the current deal. Realistically even a 20% increase in the rate Oregon Idaho power people pay will still be a fraction of the rate most Oregonians pay.
9/17/2026 8:44:26 AM	Oppose Docket	Steve	Lewis	Letter entered by Consumer Services staff (DJ) on 9/17/2026. To Whom it May Concern; Should Idaho Power sell it's Oregon territory to Oregon Trail Electric Cooperative (O.T.E.C.) Not in our opinion for the following reasons: 1. This sale of Idaho Power's service area located in Oregon does not favor the people who are the consumers of power. It will make it far more expensive and highly unreliable. 2. O.T.E.C. (Oregon Trail Electric Cooperative) does not have the infrastructure, manpower, experience, equipment, and materials to support this additional service area and population demand. The area between southern Malheur County and north is 9,930 square miles. At least 6 hours driving time. 3. O.T.E.C. has less than 40 maintenance operational employees to cover their current Harney, Baker, Grant, and Union counties. A total of 6, 700 square miles. This is 32,000 meters and 60,000 residents. This means if the acquisition goes through, it will mean more than doubling their service area. The 9,930 additional square miles has approximately 32, 261 people with about 10,292 households all to be serviced by O.T.E.C. Total area will be 9,930 square miles plus 6,700 square miles equaling 16, 630 square miles. Idaho Power covers 24,000 square miles of southern Idaho with approximately 2,100-2,200 total employees with a high percentage of the workforce dedicated to field operations. 4. Idaho Power has a 99.9% reliability record for keeping the lights on. O.T.E.C. does not even post such facts. 5. O.T.E.C. is currently having labor problems with a strike of its maintenance employees. Along with this an apprenticeship program is non-existent relying on hiring trained people through technical schools 6. Also, we are opposed to the fact Oregon Public Utilities Commission will no longer have any oversight over O.T.E.C. The company should be followed and overseen for the public benefit. After all, it is a Public Utility, Electricity. For all of the above reasons, my wife and I are opposed to the sale of Idaho Power Oregon Territory to Oregon Trail Electric Cooperative. Thank you for your time. Steven R. Lewis /s/ Steven R. Lewis Frances R. Lewis /s/ Frances R. Lewis
10/19/2026 1:38:37 PM	General Comment	Riley	Hill	Docket No. UM 2447 Dear Chairperson Twaney and Commissioners Perkins and Power: RE: Failure of OTEC’s Proposed Governance Structure I am writing on behalf of Malheur County Poverty to Prosperity because OTEC’s proposed governance structure will unfairly and unreasonably disenfranchise its newly to-be-acquired members (a.k.a. former IPCo customers). It is incumbent upon this Commission to prevent this improper, and indeed illegal, exclusion of its soon-to-be-acquired and soon-to-be-former Idaho Power customers from equal and fair participation on OTEC governing board of directors. OTEC currently has a nine-member board of directors each of whom represents a distinct and specific geographic portion of the OTEC service area. OTEC’ acquisition of Idaho Power’s Oregon customers will more than double OTEC’s electric sales. That, of course, means that more than half of the cooperative’s revenues will be sourced from the newly annexed service territory. Therefore, the newly annexed service territory should have more than one half of the seats on the newly enlarged cooperative’s board of directors. Mr. Penning’s (OTEC Manager) direct testimony at page 12 beginning on line 11 brags that cooperatives are “democratic organizations” and that members/owners of OTEC have “equal voting rights.” Unless the newly annexed territories are given a minimum of 51% voting rights on the board Mr. Penning’s assertions will prove to be false. While OTEC has more individual member/customers (approximately 32,000) than Idaho Power’s service territory (approximately 20,000) the fact is that most of the newly configured utility’s large power users will be in the newly annexed territory. This discrepancy in revenue producing members should be reflected in a newly configured board of directors. The Commission’s approval of the proposed acquisition should therefore be contingent upon OTEC revising its organic documents to create a board of directors that is composed of a majority of members from the newly annexed service territories. Sincerely, Riley J Hill