20240912Staff Comments.pdf

RECEIVED
Thursday, September 12, 2024 10:31:52 AM
IDAHO PUBLIC
UTILITIES COMMISSION
ADAM TRIPLETT
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 10221
Street Address for Express Mail:
11331 W CHINDEN BLVD, BLDG 8, SUITE 201-A
BOISE, ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF ROCKY MOUNTAIN )
POWER'S APPLICATION FOR APPROVAL ) CASE NO. PAC-E-24-09
OF THE 2024 IDAHO WILDFIRE )
MITIGATION PLAN )
COMMENTS OF THE
COMMISSION STAFF
COMMISSION STAFF ("STAFF") OF the Idaho Public Utilities Commission, by and
through its Attorney of record, Adam Triplett, Deputy Attorney General, submits the following
comments.
BACKGROUND
On June 7, 2024, Rocky Mountain Power, a division of PacifiCorp ("Company"), applied
for approval of its 2024-2026 Idaho Wildfire Mitigation Plan("WMP").1 The Company
represents that its service territory in Idaho covers areas at risk of wildfires -which have been
increasing in frequency, severity, and cost across the Western United States.
' The Company initially filed the 2024 WMP on April 14, 2024, without an Application as required by Order No.
36045. After subsequent discussions between counsel for the Company and counsel for Commission Staff, the
Company applied for approval of the 2024 WMP.
STAFF COMMENTS 1 SEPTEMBER 12, 2024

The Company represents that the WMP describes its efforts to mitigate the risk of
wildfires and"describes the investments to construct, maintain, and operate electrical lines and
equipment in a manner that will minimize"this risk. Application at 2.
The Company represents that the WMP includes a baseline risk analysis and descriptions
of inspection procedures, vegetation management practices, system hardening efforts, public
safety power shutoff protocols, cost forecasts, and other technical information relevant to the
Company's wildfire risk mitigation efforts.
STAFF ANALYSIS
Staff reviewed the Company's Application, its Idaho WMP, and responses to Production
Requests. Staff believes that this filing complies with Commission Order No. 36045. Staff
recommends the Commission:
1. Acknowledge the WMP;
2. Order the Company to develop a least-cost, least-risk analysis to evaluate its wildfire
mitigation projects such as undergrounding lines, covered conductor, etc.;
3. Order the Company to include a line item in the Cost Forecast for Internal Labor of
the wildfire safety department.;
4. Order the Company to request Commission approval if it seeks a potential backup
rebate program;
5. Order the Company to create a rolling 5 year WMP, which should also include cost
forecasts that display previous year's budget to actual expenses;
6. Order the Company to provide an analysis and a comparison of alternatives it
considered for each project or program when recovery of costs are requested;
7. Order the Company to file a copy of version changes to the WMP with the
Commission when they occur(at least every 2 years)with the Commission Secretary
for the Commission records; and
8. Order the Company to conduct semi-annual (pre-fire season and post-fire season)
wildfire updates with the Commission. Staff is not opposed to an annual updates for
each of the utilities if the Commission deems it reasonable to do so.
Staff notes that the lack of comment on any portion of the Company's WMP should not
be construed as approval or support.
STAFF COMMENTS 2 SEPTEMBER 12, 2024

Idaho Wildfire Mitigation Plan
This is the Company's first filed Idaho WMP. The Company has similar WMPs in other
states that it operates in. The Company requested the Commission approve the WMP; however,
Staff recommends the Commission should acknowledge it. By acknowledging the WMP, the
Commission acknowledges that it has thoroughly reviewed it but does not determine prudency of
the investments within the WMP.
Wildfire Risk
The Company utilizes Technosylva's risk evaluation tools and models such as FireSight
to provide ignition risk scores along the Company's circuits. WMP at 13. FireSight has two
parts: Risk Associated with Ignition Location ("RAIL"), which represents the risk presented by
the asset based on its characteristics, and Risk Associated with Value Exposure ("RAVE"),
which assesses the characteristics of the area that is under risk of ignition. Id. The outputs of
RAIL and RAVE create a composite risk score which reflect predicted impact, expected fire
behavior, and difficulty of suppression and population characteristics.
The Company calculates composite risk scores2 for wind-driven wildfires and
fuel/terrain-driven wildfires for each circuit segment.3 The Company uses the model to provide
geographic risk areas, any of which that are in the range of the 851h to 100th percentile are
considered Fire High Consequence Areas ("FHCA"). At this time, the Company has not
identified any FHCAs in Idaho. However, the Company has identified Areas of Interest 1
(described with 65th-85th percentile) and Areas of Interest 2 (described with 451h-65th percentile).
As shown in Figure 11 from the WMP below, there are many areas that are identified as Areas of
Interest 1 and 2 through its Idaho service territory.
2 Composite Risk Score=RAIL+RAVE.Each score ranges from 0-1.
s Combine Composite Risk Score=(Wind Driven Composite Risk+Terrain Driven Composite Risk)
Largest Composite Score All Circuits
STAFF COMMENTS 3 SEPTEMBER 12, 2024

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Situational Awareness
The Company plans to spend approximately $800,000 through 2026 on situational
awareness in Idaho. The Company developed a meteorology department, which consists of four
full-time meteorologists, one data scientist, and one manager. The department uses a Weather
Research and Forecasting ("WRF") model to produce a 96 hour timescale for a comprehensive
weather forecast overlayed on the system's overhead distribution and transmission lines and
other utility assets.
Weather Stations—The Company plans to have 35 weather stations in Idaho by the end
of 2024. The data is used to help inform operational decision making. Additionally, the
Company plans to make the weather station data public through their situational awareness
website.4
4 PacifiCorp(pacificorpweather.com)
STAFF COMMENTS 4 SEPTEMBER 12, 2024

Risk Models—FireSight has a Wildfire Analyst Enterprise suite that has two seasonal
wildfire models that forecast the risk of a wildfire (FireCast) and potential behavior of a wildfire
(FireSim). Technosylva also created a Fire Potential Index("FPI") in 2023.5 Similarly, the
Company created a Modified Hot Dry Windy Index, and the Company uses both to guide
operational decision making. Staff is concerned that the Company might be duplicating efforts
on certain aspects of modeling with its FireSight tools and other tools the meteorology
department uses or create. The Company should work to streamline processes and reduce
redundancies.
Vegetation Management
The Company has a regular Vegetation Management Program, in which it contracts with
vegetation management service providers to work. The regular program has the standard to do
work on the distribution system on a three-year cycle. The Company has an Enhanced
Vegetation Management program for FHCAs, where off-cycle vegetation inspections are
scheduled annually. Enhanced Vegetation Management also includes increased minimum post-
work clearance distances. The Company plans to spend $1.56 million incrementally for wildfire
mitigation from the Company's current vegetation management practices through 2026.
Although the Company does not have FHCAs in Idaho, Enhanced Vegetation
Management may be scheduled as needed. Additionally, the Company's meteorology
department identifies high risk circuits to perform vegetation management on,using a different
criteria than FireSight's model. Company's Response to Production Request No. 19. Staff is
concerned that the Company's in-house experts use a different criteria than its third-party model.
Staff encourages the Company to try to explore cost saving opportunities with the overlapping
modeling.
As the Company continues to monitor potential FHCAs in Idaho, Staff encourages the
Company to look for ways to mitigate future expenses.
5 A FPI a supplementary metric that quantifies the potential for large or consequential wildfires based on weather,
fuels,and terrain.FPI categories are based on the FPI score."Extreme"is the score>37.5;"Very high"is the score
range of 23-37.5;"High"is the score range of 13.5-23;"Moderate"is the score range 10-13.5;"Low"is the score
range 5-10;and"Very Low"is the score range<5.
STAFF COMMENTS 5 SEPTEMBER 12, 2024

System Hardening
To reduce wildfire ignition or to reduce impacts of wildfire, the Company plans to harden
the infrastructure in FHCAs. Additionally, the Company utilizes tools such as Unmanned Aerial
Vehicles ("UAVs") with technology, such as LiDAR and detailed imagery, to aid in inspections
of equipment. The Company uses the data to inform its FHCAs and system hardening through
its corrections programs. As stated in the Company's response to Production Request No. 5,
there are no annual inspections with UAVs as Idaho does not have any FHCAs yet.
The Company has a Line Rebuild program in which the Company would replace, move,
or remove certain lines and other infrastructure. The Company plans may use covered conductor
for lines,potentially underground lines, and may install non-wooden poles. In the Company's
response to Production Request No. 8, the Company evaluates converting overhead lines to
underground lines on a project-by-project basis. To date, the Company has undergrounded one
distribution line in Idaho in 2023 for approximately $522,000. Staff recommends the Company
clearly identify the criteria used to decide when lines may be converted to covered conductor or
undergrounded within the WMP.
The Company plans to use microprocessor relays that react quicker than traditional
relays, expulsion fuses that do not expel an arch, and fault indicators. The Company forecasts to
spend $1.8 million annually through 2026 for system hardening. Staff recommends the
Commission order the Company to develop a least-cost least-risk analysis to evaluate its wildfire
mitigation projects such as undergrounding lines, covered conductor, etc.
System Operations
The Company plans to spend $13 million for capital investments and $2.61 million in
operation and maintenance ("O&M")through 2026 for system operations. The Company is
implementing elevated fire risk("EFR") settings throughout its service territory for reducing
potential ignition risk. In 2023, Idaho experienced 90 EFR outages between July and August.
The Company states that these operations have a greater impact on customer reliability and is
exploring different strategies to reduce the impact. In addition to EFR settings, the Company is
performing additional patrols of its lines to identify any defective equipment or conditions
around its infrastructure that may have an ignition risk.
STAFF COMMENTS 6 SEPTEMBER 12, 2024

The Company also has operational procedures for work performed during fire weather
conditions. Employees carry small fire suppression equipment and tools. The Company has also
purchased water trailers to help prep site work in fire conditions. Additionally, the Company has
purchased mobile communication devices for more remote areas without cellular service for
major events.
Industry Collaboration
The Company is participating in industry collaborations in workshops, forums,
consortiums and advisory boards to understand best practices of the industry and development of
new technology for wildfire mitigation. Staff commends the Company for working with the
industry and encourages the Company to work with the regulated electric utilities in Idaho to
help develop and refine its WMP. However, Staff is concerned about the potential cost to
participate in these platforms and the potential cost to ratepayers. Staff encourages the Company
to aim to mitigate these expenses while collaborating.
Public Safety Power Shutoffs ("PSPS")
The Company introduced its Idaho PSPS plan in 2023, as shown in Table 13 "2023
Completed Workshops and Exercises" in the WMP at 75. The PSPS program allows for the
Company to pro-actively de-energize power lines as a temporary and preventative measure of
wildfire ignition during extreme weather events.
During an event, the Company communicates with its Partner Safety Partners through its
Partner Safety Portal. This portal is active and accessible in all the states that the Company
operates in. The portal provides updated information on critical facilities and infrastructure,
contact information, and known backup generation capabilities. The Company has used the
Partner Safety Portal during its PSPS events in other states. Staff recommends the Company also
consider stakeholder and partner utilities communication in the event of de-energization as each
may be impacted by the event.
Additionally, the Company communicates with impacted customers through direct
notifications, calls, texts, emails, and its PSPS webpage through its website or mobile app. The
Company also has a communication plan for medically vulnerable customers and plans to set up
Customer Resource Centers, if needed. To date, no PSPS events have been executed in Idaho.
STAFF COMMENTS 7 SEPTEMBER 12, 2024

Staff reviewed the Company's PSPS plan and recognizes it's the Company's decision to
initiate a PSPS. Staff notes the importance of the Company to consider the risk of customer
shutoffs versus the risk of wildfire ignition. Additionally, Staff recommends the Company
clarify in its WMP to clearly identify areas of its Idaho service territory that may be subject to a
PSPS. Staff is unaware of how the Company plans to communicate with the Commission prior
to and during a PSPS event. It is important for the Commission to be notified of potential PSPS
events due to the Commission's role in statewide emergencies, ESF-12 coordination, and due to
the high volume of customer calls the Commission receives from the widespread customers
power shut-offs. Staff will work with the Company on establishing proper communication with
the Commission in the event of a potential PSPS.
Wildfire Encroachment System Operations Procedure ("SOP')
Different from a PSPS, the Company has an SOP to de-energize any powerline within a
wildfire encroachment area. This SOP provides specific guidelines on when a powerline would
be required to be de-energized due to an active wildfire. Staff echoes the same concerns on
notifying the impacted partner utilities and customers in the event of de-energization.
Forecasted Cost Summary
The WMP cost forecast consists of$22.26 million for capital expenditures and$9.02
million for O&M expenditures for 2024 through 2026. In the Company's response to Production
Request No. 3, it provided an updated and more detailed cost summary of the planned
investments, as shown in the table below. However, not shown is the Company's forecasted cost
of internal labor for its wildfire safety department. Staff notes that internal labor dedicated to the
wildfire program is not able to be tracked without a specified line item. Staff recommends the
Commission order the Company to include a line item in the Cost Forecast for Internal Labor of
the wildfire safety department.
As stated in the WMP, the Company has applied for grant funding to offset potential
impacts to the customer. WMP at 91. Staff supports continuation of the Company's efforts to
seeking alternative funding for wildfire mitigation objectives and describing each within its
WMP.
STAFF COMMENTS 8 SEPTEMBER 12, 2024

Table No. 1: Cost Forecast Summary
3 Year
2023 Actuals Total 2024 Total 2025 Total 2026 Total
Capital Investments Program Category
Risk Modeling and Drivers $ - $ 0.35 $ 0.37 $ 0.38 $ 1.10
*System Hardening $ - $ 1.80 $ 1.80 $ 1.80 $ 5.40
Asset Inspection&Coordination $ 3.33 $ 0.50 $ 0.50 $ 0.50 $ 1.50
Condition Corrections $ 3.33 $ 0.50 $ 0.50 $ 0.50 $ 1.50
Situational Awareness $ 0.18 $ 0.35 $ 0.74 $ 0.10 $ 1.19
Weather Station Installs $ 0.18 $ 0.25 $ 0.18 $ 0.05 $ 0.48
Operational Weather Forecasting $ - $ 0.01 $ - $ - $ 0.01
Wildfire Detection Network $ - $ - $ 0.30 $ - $ 0.30
Operations&Work Practices(Asset
Corrects i.e.,pole replacements) $ 1.52 $ 3.00 $ 5.00 $ 5.00 $ 13.00
TrainingApps and Ebooks $ - $ - $ - $ - $ -
Operational Capital $ 1.34 $ 3.00 $ 5.00 $ 5.00 $ 13.00
Rapid Response Communications $ 0.15 $ - $ - $ - $ -
Fire Preparedness Equipment $ 0.03 $ - $ - $ - $ -
Public Safety Partner Coordination $ - $ 0.07 $ - $ - $ 0.07
Capital Investments Total $ 5.03 $ 6.07 $ 8.41 $ 7.78 $ 22.26
0&M Investments Program Category
Risk Modeling and Drivers $ 0.20 $ 0.65 $ 0.67 $ 0.71 $ 2.03
FHCA Map Refresh $ 0.03 $ 0.01 $ 0.01 $ 0.05
RiskAssessment $ 0.61 $ 0.63 $ 0.66 $ 1.90
Advanced Data Analytics $ 0.02 $ 0.03 $ 0.03 $ 0.08
Situational Awareness $ 0.38 $ 0.21 $ 0.28 $ 0.31 $ 0.80
Meteorology Department $ 0.06 $ 0.06 $ 0.06 $ 0.17
Operational Weather Forecasting $ 0.01 $ 0.03 $ 0.03 $ 0.07
Weather Station Maintenance and Data $ 0.14 $ 0.19 $ 0.22 $ 0.55
Wildfire Detection Network $ - $ - $ - $ -
Operations&Work Practices $ 0.78 $ 0.87 $ 0.87 $ 0.87 $ 2.61
Patrols $ 0.25 $ 0.25 $ 0.25 $ 0.75
Rapid Response Communications $ - $ - $ - $ 0.01
Pre-EFR Corrections $ 0.10 $ 0.10 $ 0.10 $ 0.30
Vegetation Management $ 0.52 $ 0.52 $ 0.52 $ 1.56
*PSPS Program $ 0.02 $ 1.05 $ 1.05 $ 1.05 $ 3.15
Public Partner Coordination $ - $ 0.09 $ 0.09 $ 0.10 $ 0.28
Tabletop Exercises $ 0.01 $ 0.01 $ 0.01 $ 0.02
EmergencyMgmt. Team $ 0.09 $ 0.09 $ 0.09 $ 0.27
WMP Engagement&Plan Development $ 0.02 $ 0.05 $ 0.05 $ 0.05 $ 0.46*
STAFF COMMENTS 9 SEPTEMBER 12, 2024

WMP Engagement Strategy $ 0.02 $ 0.03 $ 0.03 $ 0.08
Industry Collaboration $ 0.01 $ - $ - $ 0.01
Plan Monitoring&Implementation $ 0.02 $ 0.02 $ 0.02 $ 0.07
0&M Investments Total $ 1.14 $ 2.94 $ 3.02 $ 3.09 $ 9.36**
WMP Grand Total $ 6.17 $ 9.01 $ 11.43 $ 10.87 $ 31.31
*This is a reactive spend, not a planned spend.
** Staff could not replicate the total provided.
Additional Comments
The Company had a section in its WMP for a backup power rebate program and stated
that it was exploring this program for Idaho customers. The Company currently has this program
in California and Oregon. Staff recommends the Commission order the Company to request
Commission approval of such a program.
The Company is not requesting recovery of its wildfire mitigation expenses in this case;
however, it is important to state that if the Commission decides to approve or to acknowledge the
WMP, it does not declare prudency of any of the investments within. The Company should file a
new case when seeking recovery of its wildfire mitigation expenditures. As the Company has
not clearly identified how each project or program is evaluated to be least-cost least-risk, Staff
recommends the Commission order the Company to provide an analysis and a comparison of
alternatives it considered for each wildfire mitigation project or program when recovery of costs
are requested.
To be in alignment with the other utilities in Idaho, Staff recommends the Commission
order the Company:
I. To create a rolling 5-year WMP, which should also include cost forecasts that display
previous year's budget to actual expenses;
2. Order the Company to file a copy of versions changes to the WMP with the
Commission when each occur(at least every 2 years) with the Commission Secretary
for the Commission records; and
3. Order the Company to conduct semi-annual (pre-fire season and post-fire season)
wildfire updates with the Commission. (Note: Staff is not opposed to an annual
updates for each of the utilities if the Commission deems it reasonable to do so.)
STAFF COMMENTS 10 SEPTEMBER 12, 2024

STAFF RECOMMENDATION
Staff recommends the Commission:
1. Acknowledge the WMP;
2. Order the Company to develop a least-cost least-risk analysis to evaluate its wildfire
mitigation projects such as undergrounding lines, covered conductor, etc.;
3. Order the Company to include a line item in the Cost Forecast for Internal Labor of
the wildfire safety department.;
4. Order the Company to request Commission approval if it seeks a potential backup
rebate program;
5. Order the Company to create a rolling 5 year WMP, which should also include cost
forecasts that display previous year's budget to actual expenses;
6. Order the Company to provide an analysis and a comparison of alternatives it
considered for each project or program when recovery of costs are requested;
7. Order the Company to file a copy of version changes to the WMP with the
Commission when they occur(at least every 2 years) with the Commission Secretary
for the Commission records; and
8. Order the Company to conduct semi-annual (pre-fire season and post-fire season)
wildfire updates with the Commission. (Note: Staff is not opposed to an annual
updates for each of the utilities if the Commission deems it reasonable to do so.)
Respectfully submitted this 12th day of September 2024.
Adam- Triplett
Deputy Attorney General
Technical Staff Kimberly Loskot
Michael Eldred
1:\Utility\UMISC\COMMENTS\PAC-E-24-09 Comments.docx
STAFF COMMENTS 11 SEPTEMBER 12, 2024

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 12th DAY OF SEPTEMBER
2024, SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN
CASE NO. PAC-E-24-09, BY &MAILING A COPY THEREOF, TO THE
FOLLOWING:
MARK ALDER JOE DALLAS
ROCKY MOUNTAIN POWER ROCKY MOUNTAIN POWER
1407 WEST NORTH TEMPLE STE 330 825 NE MULTNOMAH ST
SALT LAKE CITY UT 84116 STE 2000
E-MAIL: mark.alder(a�pacificom.com PORTLAND OR 97232
E-MAIL: ,joseph.dallasRpacificom.com
DATA REQUEST RESPONSE CENTER
E-MAIL ONLY:
datare uestgpacificoM.com
PATRICIA JORDAN,AECRETARY
CERTIFICATE OF SERVICE