ORA protested Sierra's initial application alleging that Sierra failed to provide sufficiently detailed information on ratemaking treatment of the proceeds and other elements of the auction to justify an exemption from Section 851. ORA suggested rejection of the initial application, and set forth a list of issues for closer scrutiny in a subsequent Section 851 filing. These issues included whether the proposed auction process maximizes the sales price of the plants being sold, whether the divestiture will insure system reliability, and ratemaking issues surrounding the proceeds and costs associated with the auction and divestiture. ORA also questioned the level of information provided in the application on Sierra's hydroelectric plants and the environmental costs and liabilities surrounding the auction.