20241007Compliance Filing.pdf

October 7, 2024

Commission Secretary
State of Idaho
Idaho Public Utilities Commission
11331 W. Chinden Blvd. Building 8, Suite 201-A
Boise, Idaho 83702-5983

RE: Case No. AVU -E-23-01, Avista Wildfire – 2024 Wildfire Plan Report

Avista Corporation, dba Avista Utilities (Avista or the Company), hereby submits its 2024 Wildfire
Plan Report, dated August 31, 2024, per Commission Order 35909 in Case No. AVU -E-23-01, at
page 16, paragraph 14:

14. Wildfire Resiliency Plan. The Settling Parties agree to the following
Wildfire Resiliency Plan (“WRP”) changes:

(f) The Company will file a copy of each version of its WRP with the
Commission.

If you have any questions regarding this filing, please call me at [phone] or by email at
[e-mail].

Sincerely,

/s/ Elizabeth Andrews

Elizabeth Andrews
Senior Manager, Revenue Requirements

Enclosures
Avista Corp.
1411 East Mission P.O. Box 3727
Spokane. Washington 99220-0500
Telephone [phone]
Toll Free 800-727-9170

Via Electronic Mail

RECEIVED
Monday, October 07, 2024
IDAHO PUBLIC
UTILITIES COMMISSION

1

2024
Working to prepare
for and reduce
wildfire risk.
Wildfire
Resiliency
Plan &
Report

2

TABLE OF CONTENTS

Statement from Avista Executive Management ..................................................................................... 3
Executive Summary ................................................................................................................................. 4
Avista’s Commitment to Wildfire Resiliency ........................................................................................... 5
Wildfire Plan Goals .............................................................................................................................. 6
Wildfire Plan Updates .......................................................................................................................... 7
Governance .......................................................................................................................................... 8
Wildfire Resiliency Program Elements..................................................................................................... 9
Grid Hardening .................................................................................................................................. 11
Enhanced Vegetation Management .................................................................................................. 20
Situational Awareness ....................................................................................................................... 29
Operations & Response ..................................................................................................................... 38
Community Outreach ............................................................................................................................ 52
Equity ................................................................................................................................................. 56
2023 Fire Season Recap ......................................................................................................................... 59
Impacts to Infrastructure ................................................................................................................... 60
2024 Fire Season Outlook ...................................................................................................................... 62
Challenges & Lessons Learned .............................................................................................................. 63
Continuous Improvement ...................................................................................................................... 65
Avista Wildfire Resiliency Plan Glossary of Terms .................................................................................... 74
Appendix A: Avista’s Wildfire Public Safety Shutoff Plan Summary ....................................................... 108

3

August 31, 2024
August 31, 2024
August 31, 2024
Statement from Avista Executive Management

2024 represents Avista’s 4th year of implementing the Wildfire Resiliency Plan. Avista’s wildfire
strategies are firmly rooted in our 135-year operating history and represent the collective knowledge
of Avista employees and fire agency professionals together with assistance from peer utilities, and
other experts and, most importantly, engagement with customers. This Wildfire Plan builds upon
strategies originally developed in 2020 and aligns with the Company’s mission to provide safe, reliable,
and affordable energy. Avista’s Wildfire Plan is designed to reduce fire risk associated with the
operation of electric transmission and distribution facilities and reflects our commitment to partner
with customers, communities, and those who manage forest landscapes and fight fires , as we all have
a role to play in minimizing the risk of wildfire.

Heather Rosentrater, Chief Operating Officer (COO)

______________________________________ Date: __________________________

Josh DiLuciano, Vice President Energy Delivery

______________________________________ Date: __________________________

Vern Malensky, Director Electrical Engineering

Date: __________________________

4

Executive Summary
Avista published its first Wildfire Resiliency Plan in June of 2020
and began to implement elements of the Plan in 2021. That work
introduced the risks, costs, and benefits of implementing a
holistic set of measures to reduce utility wildfire risk. The original
Plan built upon Avista’s operating history responding to and
mitigating wildfire activity, and we continue to do so four years
later. Our 2024 Report details the performance and investments
made since 2020 and serves to reaffirm Avista’s commitment to
reducing fire risk to communities and customers, as well as the
Company infrastructure that serves our customers.

Avista is making wildfire-related investments in four key areas:

• Grid Hardening – Investing in electric infrastructure to reduce spark-ignition outage events and
to protect critical assets from the impact of wildfires.

• Enhanced Vegetation Management – Reducing the number of vegetation-related issues that can
lead to outages and/or spark events by inspecting 100% of our powerline assets annually to
identify and mitigate risk trees. Adding remote sensing technologies such as LiDAR and satellite
imagery to enhance overall vegetation management information and decision-making.

• Situational Awareness – Providing both static and dynamic tools needed to identify, manage,
and react to wildfire risk.

• Operations & Emergency Response – Preparing for and effectively reacting to wildfire situations,
including remote automation and control of critical equipment, along with collaborating with
critical partners in reacting to wildfire events in a holistic and unified way.

Avista’s Wildfire Resiliency Plan is intended to accelerate and/or focus existing programs as well as
initiate new programs that reduce fire ignition risk related to Avista’s electric equipment and make our
system more resilient to the impact of fires. Avista’s Wildland Urban Interface (WUI) map indicates
that approximately 2,745 miles of our electric distribution lines (36% of our system) are located in high
fire consequence areas. These zones mark the intersection between forest land and human
development and are the focal point of Avista’s risk mitigation strategies , as they are the areas most
likely to be impacted by wildfire.

From 2020 when the initial Wildfire Plan work began through the end of 2023, Avista completed
upgrades on over 600 miles of distribution lines and installed nearly 4,200 steel transmission poles
(389 of these specific to Wildfire). Avista also made tremendous progress towards automating its
distribution protection system with upgrades to 208 devices. As of the end of 2023, Wildfire’s

5

Enhanced Vegetation Management program removed over 64,000 risk trees. We also performed other
resiliency work that will be discussed in more detail in the following pages. These investments will
reduce wildfire risk and improve system resiliency and customer reliability by reducing the number of
both outages and fire ignition events.

It is important to remember that most of the benefits of the Wildfire programs will not show up
immediately. Wildfire metrics are intended to reflect long-term trends on our system. Only long-term
trends are truly meaningful here; it is not practical or reasonable to look merely to end -of-year results
due to the variability of a variety of factors, most specifically weather conditions. In addition, a marked
change in these statistics will take the time it requires to replace thousands of crossarms across th e
system1 and mitigate vegetation issues across the 30,000 square miles of our service territory, for
example. None of these programs will be completed within a year but will be ongoing and offering
continual improvement.

Avista’s Commitment to Wildfire Resiliency
The risk of wildfire is ever present in the western United States. Research indicates that the frequency
of wildfires has quadrupled in some areas since the 2000s.2 In fact, the National Interagency Fire
Center has documented almost 70,000 wildfires per year since 1983.3 Multiple studies have found that
there is a significant increase in wildfire season length, wildfire frequency, and amount of burned area.
The wildfire season has been extended in many areas due to factors including warmer springs, longer
summer dry seasons, and the resulting drier soils and vegetation. Similarly, climate change threatens
to increase the frequency, extent, and severity of fires through increased temperatures and expanded
drought.4 Though we have always faced the threat of wildfires, that threat is also increasing both as a
function of population growth and population location. It has been estimated that 1 in 6 Americans
now live in areas of significant wildfire risk.5 6

Avista developed a wildfire plan to help mitigate this risk. Some examples in the Plan include modifying
operations to reduce the risk of fire ignition such as Avista’s Fire Safety Mode operations,
strengthening our infrastructure by migrating from wooden to fiberglass crossarms on distribution
poles, and installing steel rather than wood transmission poles to fire-harden the high voltage system.

As part of the Wildfire Resiliency Plan, Avista tracks metrics that help us determine the success of our
strategies and programs. Overhead equipment failures, pole fires, and spark-ignition events are among

1 Note that the Company has over 265,000 poles in the field. It will take several years to replace all of our wood crossarms.
2 “U.S. Fires Four Times Larger, Three Times More Frequent Since 2000,” University of Colorado at Boulder, March 16, 2022, U.S. fires four times larger,
three times more frequent since 2000 | ScienceDaily
3 NIFC (National Interagency Fire Center). Total wildland fires and acres (1983–2023). Accessed July 2024. Wildfires and Acres | National Interagency
Fire Center (nifc.gov)
4 “Climate Change Indicators: Wildfire,” United States Environmental Protection Agency, July 2022, Climate Change Indicators: Wildfires | US EPA
5 John Muyskens, Andrew Ba Tran, et al, “1 in 6 Americans Live in Areas with Significant Wildfire Risk,” The Washington Post, M ay 17, 2022, Map: See
where Americans are most at risk for wildfires - Washington Post
6 Wildfire Risk Map courtesy of FEMA, Wildfire | National Risk Index (fema.gov)

6

our key performance indicators. We also track the number of trees that fall or grow into powerlines.
Each of these measures represents a situation that may lead to a wildfire. Recent values are
summarized in Table 1. These values
represent a subset of unplanned
outages that can be managed in part
by upgrading powerlines and
equipment as well as removing risk
trees, which are primary objectives
of Avista’s Wildfire Plan.

Though reducing spark-ignition events is a core tenant of Avista’s Plan, we acknowledge that fire risk
cannot be completely eliminated, and that actions and investments must be balanced against
affordability, reliability, safety, and security, as well as other utility operating risks. Avista is committed
to a multi-year Wildfire Plan to reduce the number of fire ignition events and to make our system more
resilient to the impacts of wildfire while accounting for those considerations . This Plan describes that
commitment and the specific actions we are taking to achieve these goals.

Wildfire Plan Goals
The stated goals of Avista’s Wildfire Plan include:

1. Protecting Life and Property – To protect physical assets, property,
and most importantly, human lives, against the threat of wildfires. To
recognize fire potential in our operating and maintenance strategies
and take actions to reduce the risk of wildfire from the
interaction of Avista’s energy delivery system and the
environment, as well as the impacts of wildfire to
Avista’s system.

2. Emergency Preparedness – To recognize and react to wildfire as a recurring threat to
infrastructure, communities, and utility customers. To prepare and train for episodic wildfire events
and align operating practices with fire threat conditions to help mitigate wildfire risk.

3. Financial – To mitigate the probability and consequence of direct financial costs and liability
associated with large scale fire events.

This 2024 Wildfire Report highlights the progress and milestones achieved since 2020 and discusses
our wildfire mitigation strategies going forward. Avista started work on this plan in the second half of
2020. The combination of 2021 and 2022 served as the test bed for gathering direct feedback from
employees, fire agency professionals, customers, and others to help further shape and refine the Plan.
All of our programs have now come up to speed and are being fully implemented. Even so, we
continue to apply our goal of constant improvement and have experienced some significant

Table 1. Historic Outages

7

achievements in service to that goal. For example, our Fire Weather Dashboard has been enhanced
and refined with more data and improved analytics, and our WUI map has been updated to include
community impact information. While many of the elements of the 2020 Plan remain relevant, this
updated report enjoys the benefit of hindsight and provides focus for Avista’s approach to mitigating
fire risk going forward. In the following pages we will discuss the elements of our Plan, what has been
achieved, and how it has evolved over time.

Wildfire Plan Updates
Avista is continually reflecting on our Plan and updating and revising
its strategies to incorporate lessons learned, new information related
to fire risk, utility best practices, and in response to feedback from
customers, agency partners, regulators, and others including fellow
utilities. Avista uses a Plan-Do-Check-Adjust framework to adapt
business strategies, plans, and processes to align with changing business
and physical climates. In fact, initial core elements of the Wildfire Plan were
derived from a series of business process improvement workshops held to
identify opportunities to build upon Avista’s operating history and existing Company programs.

As more focus is being placed on wildfire resiliency and protection measures across the western U.S.,
opportunities arise for new and improved data to incorporate into our modeling. In one important
example, the U.S. Dept. of Agriculture together with the U.S. Forest Service provides free analytics and
mapping related to fire risk, including their Wildfire Hazard Potential Map (WHP)7 that defines wildfire
hazards and the associated prioritization of fuels management needs across the entire United States. It
is basically a fire-fuel model that shows the burnability of an area. They have also developed the
Housing Unit Impact (HUI) dataset8 which
contains a nationwide raster of housing
unit density measured in persons per
square kilometer. This information
incorporates the general consequences of
fire on people and the potential economic
impact of wildfire on communities and
infrastructure. These two relatively new
detailed modeling tools, used together,
provide a solid understanding of wildfire
risk. Avista’s WUI map built on this
foundation and incorporated our own
internal-use data for actual outage rates

7 “USDA USFS Wildfire Risk to Communities,” Download - Wildfire Risk to Communities Data is available as raster GIS data or as spreadsheets from the
USDA Forest Service Fire Modeling Institute.
8 “Wildfire Risk to Communities: Spatial Datasets of Wildfire Risk for Populated Areas in the United States,” fs.usda.gov/rds/archive/products/RDS-2020-
0060/_metadata_RDS-2020-0060.html
Figure 1. USDA-US Forest Service Wildfire Hazard Potential Map

8

and vegetation risk including historic feeder outages, vegetation conditions on each feeder, and feeder
health data to create a customized, detailed means of identifying risk areas across our service territory.
We have also honed and refined our Fire Weather Dashboard , which is the heart of our situational
awareness (and reaction) efforts. Since it was initially developed, it has been continually improved,
including model calibrations to best fit data to observed outcomes in real time, back -casting against
actual situations and conditions in order to test concepts and accuracy, and incorporation of the
updated WUI information described above. It is critical to continue to search for ways to improve our
ability to predict and react to wildfire risk, as this risk is only increasing with time.

Another example of our striving for continuous improvement is the incorporation of LiDAR and satellite
data acquisition into our vegetation management practices. Because these images are taken on a
regular basis, they show us where vegetation risk exceeds both reliability and fire mitigation thresholds
and give us valuable information regarding the location of problem (or potential problem) vegetation
issues over time. The analysis provided is invaluable in directing planners and line clearing crews to
specific locations on the system to perform maintenance and mitigate risk trees based on identified
location of risk rather than the traditional method of working on an entire circuit or polygon. This data
gives us the ability to send crews to the areas of greatest need with accuracy. Both of these tools and
the detailed, over-time analysis they provide will essentially learn Avista’s system and the vegetation
around our lines, and both allow planning work in a more precise and predictable way, streamlining
our vegetation management programs and helping to maximize their value.

Governance
The Wildfire Implementation Team is composed of individuals who
oversee and track the programs described here, who do the day-
to-day work of managing the programs and who track and report
on the results as well as the Wildfire Resiliency Manager.

Overall Plan implementation and guidance is governed by the
Wildfire Steering Committee whose membership reflects a
broad cross section of Avista departments. The Steering
Committee is responsible for on-going oversight of wildfire season preparedness and providing support
to the Wildfire Resiliency Manager, focused primarily on tactical issues. The Committee consists of
internal Avista stakeholders with responsibility for the outcome of wildfire preparedness and response
activities. This includes Risk, Legal, Regulatory, Asset Maintenance, Customer Service, Communications ,
and the Director of Electrical Engineering, who oversees the Wildfire program.

As Wildfire is an enterprise level risk, executive level oversight is essential for producing prudent and
cost effective outcomes for customers. The Wildfire Executive Committee oversees activities related to
operational response to weather conditions as well as broad Plan implementation, budget, and
strategies. This executive-level committee consists of officers and senior officers of Avista.

Figure 2. Avista Wildfire Governance

9

The Board of Directors are regularly kept apprised of the general Plan, program progress, new
strategies, and status. They provide an executive level of oversight that includes external expertise and
objective perspective to guide both implementation and plan related expenditures.

In the case of a wildfire or PSPS event, decision making is escalated through appropriate channels. This
typically begins with an Emergency Operations Process (EOP), a team comprised of cross-functional
Company specialists. These people represent the impacted areas of the utility and provide a high level
of experience and expertise. The EOP defines key roles and responsibilities for personnel, identifies
communications channels, and outlines strategies for engaging with fire protection professional and
emergency operating agency staff during expected or actual wildfire events, creating a consistent and
efficient approach. This group is responsible to prepare crews and employees, notify customers, and
manage the situation from initiation to full restoration.

Another aspect of governance and accountability includes gathering customer and first responder
feedback via our communications outreach efforts. This includes engaging continuously with partners
outside the Company such as the Washington Dept. of Natural Resources, the National Weather
Service, our Commissions, and many others. External engagement helps ensure that the Plan is
meeting all stakeholder objectives and hopes for the Program and that we continue to improve over
time.

Wildfire Resiliency Program Elements
Avista’s Wildfire Resiliency Plan groups our efforts into four
major program areas: (1) Grid Hardening, (2) Enhanced
Vegetation Management, (3) Situational Awareness, and (4)
Emergency Operations and Response. Each of these areas will be
described in further detail below.

Avista’s Wildfire Plan leverages several existing asset programs
and operating practices, building upon them whenever possible.
Many of these programs already have demonstrated benefits related to reducing the risk of fire or in
making the electric system more resilient, such as vegetation management and steel pole
replacements. The Wildfire Resiliency Plan adds additional funding and creates a focus for these
programs specifically related to high fire threat areas. Other programs suggested by the Plan are new
to Avista, including LiDAR and satellite imaging, cross-training with external fire professionals, and the
creation of a fire-weather risk monitoring system (our Dashboard). All of the Wildfire programs, new or
re-tooled, work in concert to provide a well-rounded and thorough approach.

Approved capital and Operating Expenses for Avista’s Wildfire Resiliency Plan through 2029 are shown
below, after which we will discuss each of the program areas and their related metrics and
expenditures. Note that the budget has only been approved through 2026.

10

Note that the additional $25 million in capital shown for 2026 and 2027 indicates the implementation
of an Enhanced Grid Hardening Program the Company is currently evaluating. Elements of this program
are described below. We anticipate this program increasing our capital budgets from that point
forward by an amount that will be determined after our first years of experience with this new
approach. The budget will be updated as we gain information and can more accurately measure these
costs.

Operating expenses, primarily related to Enhanced Vegetation Management, are expected to peak in
2023 and then gradually decline as subsequent year vegetation inspections hopefully reveal fewer
risk/hazard trees due to our vigorous efforts to mitigate them.
Figure 3. Avista’s Wildfire Resiliency Plan Actual and Projected Expenditures

Figure 4. Wildfire Plan Cost Breakout

11

Grid Hardening
Many sources of powerline outages are difficult to control, including
winter storms, strong wind events, lightning, and public-caused outages
including vehicular accidents and trees that are felled through
powerlines. However, by upgrading powerline conductor and equipment,
many types of failures are more manageable and represent a cost
effective means to reduce the overall number of outages and the
resulting potential for spark-ignition events.

Though Avista has well-established programs to replace poles, conductor,
and equipment, existing programs are condition-based and aligned with
reliability objectives. Wildfire grid hardening objectives are risk-based and
focused on reducing the number of (and potential for) spark ignition
events. Hardening powerlines, poles, and other equipment through updated designs and material
selections also helps the power system withstand higher wind speeds and other environmental factors
such a wildfire near or beneath our facilities. Thus, Wildfire system hardening focuses on the
prevention of equipment spark events as well as promoting equipment resilience during fire (and other
reliability risk) exposure. Grid hardening programs are a key component in protecting customer
reliability and safety as well as safeguarding our electric transmission and distribution systems from
wildfire risk – systems that our customers have paid for and depend upon.

We believe that our grid hardening Wildfire programs are already showing benefit. For example, in
2023, Avista recorded 65 spark ignition events as compared to the previous year which recorded 109
events, with the most significant reductions coming from fewer overhead equipment outages. This
reduction can at least in part be credited to the work being done to install wildlife guards and replace
aged overhead equipment as part of our
grid hardening efforts. While the vast
majority of spark-ignition events do not
result in fires or wildfires, it is an
important measure of fire risk
performance and the benefits offered by
Avista’s Wildfire programs.

We recorded 67 pole fires in 2023 versus
the 5-year average of 81.9 The
mechanism that causes pole fires is well-
known and is highly weather dependent.
This issue is related to periods of hot, dry

9 Note that there were 205 pole fires in 2015 and 154 poles fires in 2021 due to hot dry conditions followed by light rains, ideal conditions for electrical
tracking between poles and wood crossarms that can lead to pole fires. This compares to 92, 79, 68, and 66 poles fire per year in 2017 through 2020 and
51 pole fires in 2022.
0
0
00
0
200
2 0
200 20 20 20 20 20 202 202
u
m
b
e
r

o
f

P
o
l
e

i
r
e
s
Avista istorical Pole ires
Figure 5. Avista Historic Pole Fires
Pole fire from a wood crossarm
that burned the pole and
crossarm then traveled to the
ground.

12

weather when insulators become covered with dust and other contaminants, creating a path for
leakage current, which happens as insulating properties of overhead equipment naturally break down
over time. Leakage current is usually invisible and does not cause a heat signature, making it almost
impossible to detect. A light rain after the dry spell increases this leakage current and creates the right
conditions for pole fires, especially when the leakage current is concentrated between wood-to-wood
or wood-to-metal contacts such as the contact point between wood crossarms and wood poles. Wood
shrinkage and cracking around metal bolts holding wood crossarms to poles form a combustive -
friendly cavity for arcing and burning, and the burning process accelerates when the moisture of wood
increases. Fiberglass crossarms, which are naturally fire resistant due to their smooth surfaces and
composition, virtually eliminate pole fires.10

In the early 2000s, Avista began using fiberglass crossarms and, according to our field crews, this has
virtually eliminated fires on poles with these crossarms. As part of Wildfire Resiliency, the plan is for all
wood crossarms on structures located in elevated fire areas to be replaced with fiberglass units. The
number of pole fires should be significantly reduced over time with this work. Other Grid Hardening
efforts, described below, should significantly reduce outages that
could lead to sparks over time as equipment identified as related to
wildfire risk is methodically replaced, starting in the highest fire
threat zones. Avista supports four primary projects within Grid
Hardening:

• Distribution Grid Hardening
• Transmission Steel Pole Conversion
• Fire Resistant Wraps on Wood Transmission Poles
• Annual Fire Inspections on Transmission Lines

Table 2 indicates the Grid Hardening Program metrics, and Figure 6
depicts the associated program key performance outage metrics.
Over the life of the Plan, we anticipate replacing 1,000 wood transmission poles with steel in high fire
threat areas under the Wildfire budget, maintaining a rate of 211 miles per year of distribution grid
hardening, and wrapping 2,500 wood transmission poles per year from 2024 to 2029.

10 Each year in the U.S. there are over 3,000 pole fires. Pole fires are caused by periods of very dry conditions followed by moist ure, when leakage
current, which is normally present, heats and creates combustion in gaps where metal bolts connect wood crossarms to wood poles. This does not
happen with fiberglass crossarms. For more information, see: John Lauletta, “The Mystery of Dry Band Arcing & Pole Fire Causation,” The Mystery of Dry
Band Arcing & Pole Fire Causation | T&D World (tdworld.com)
Avista crews install a fiberglass
distribution crossarm.
Table 2. Grid Hardening Program Primary Metrics
Infrastructure Program Metrics 2020 2021 2022 2023
Distribution Grid Hardening (miles)61.2 150.5 180 214
Wildfire Transmission Steel Pole Conversion (units)n/a 169 118 102
Other Transmission Steel Pole Conversion (units)1,821 847 514 622
Transmission Wood Pole Wrap (units)1,235 1,938 1,454 1,533

13

Distribution Grid Hardening
The single largest capital program in the Wildfire Plan is Distribution Grid Hardening. As mentioned
earlier, though Avista has asset maintenance programs to replace poles and equipment, existing
programs are condition-based and aimed at reliability objectives. Wildfire Distribution Grid Hardening
focuses on upgrades most likely to reduce spark ignition events , directed in the highest fire threat
areas of our service territory. The scope of this work includes:

• Replace wood crossarms with fiberglass to mitigate pole fires.
• Replace copper and other small wire with modern steel-reinforced
wire to reduce conductor failures.
• Install wedge-bail clamps at hot tap connector locations to prevent
thermal failures.
• Add or replace wildlife guards to mitigate
electrical contacts with birds and animals.
• Replace wood distribution poles with
metal poles at critical span locations such
as highway and river crossings for
additional strength and resiliency.

Avista’s Grid
Hardening Work
0
00
200
00
00
00
00
00
00
Animal E uipment Conductor Pole ire par Event
u
m
b
e
r

o
f

O
u
t
a
g
e
s
rid ardening Related Outage etrics
2020 202 2022 202
Figure 6. Grid Hardening Related Outage Metrics
Bird contact with a regulator
which started a fire.

14

On average, Avista experiences about 80 pole fires per year, mostly related to wood crossarms and
specific weather conditions as described earlier. By replacing wood crossarms with fiberglass units,
leakage current is substantially reduced and pole fire risk is much lower. Old and obsolete wire types,
such as copper, fail at higher rates than do modern aluminum conductors, so replacing this wire
reduces line failure. Animals cause about % of Avista’s overall outages (45% of overhead equipment
outages) but animal guards at transformers and other connection points are an effective means of
reducing these electrical contacts that can lead to sparks. Though hot taps fail at a low rate, a majority
of our peer utilities use a bail type connector in conjunction with hot taps to prevent burn downs, thus
Avista crews are adding these connectors. At critical spans such as highways or river crossings, line
personnel are replacing wood poles with metal units to strengthen those spans.

All of these measures strengthen and reinforce our distribution system, making it more resilient to
outages which could lead to a spark. They should also aid in protecting general customer service and
Figure 8. Overhead Equipment Related Outages 2009 - 2023

Table 4. Distribution Grid Hardening Program Results
Figure 7. Number of Avista Fiberglass Crossarm Installations
0
200
00
00
00
000
200
00
00
00
200 200 200 20 20 20 20 20 202 202
u
m
b
e
r

o
f

C
r
o
s
s
a
r
m
s
Avista iberglass Crossarm Installa ons
Table 3. Distribution Grid Hardening
Financial Plan

15

reliability. Our accomplishments in this area through 2023 are shown in Table 4 above. Table 3
indicates the predicted level of expenditures for Grid Hardening through the period. It should be noted
that the mileage achieved varies each year based on the areas selected for hardening, as each situation
or segment presents unique challenges and requirements.

Enhanced Grid Hardening
In addition to existing undergrounding practices, the Company is developing a new program that we
call Enhanced Grid Hardening.

Converting overhead distribution line sections to underground cables has not historically been listed as
a specific component of our distribution grid hardening. In the past, Avista has conducted underground
conversion of overhead lines on a case-by-case basis, but in most existing situations the physical
challenges create an undue economic
burden,11 making conversion unfeasible.
According to the California Public Utilities
Commission, undergrounding costs about
$400 to $600 per trenched foot of
distribution line, about $2.1 to $3.2 million
per mile.12 For comparison, the typical
replacement costs for existing overhead
distribution lines range from about $86,700
to $126,900/mile.13 However, for new applications, such as a new subdivision or business
developments, costs can be more manageable. In fact, over the last five years Avista crews have
installed over 500 miles of underground cable and have removed over 100 miles of overhead lines in
these types of areas. Still to date Avista has converted less than 2% of our overhead lines to
underground cable under the Grid Hardening Program. However, going forward, Avista has made a
commitment that new distribution facilities located in specific areas with high fire risk will be
undergrounded to mitigate future risk.

Overhead distribution lines have the narrowest rights-of-way and lowest ground proximity of Avista’s
above-ground conductor. This creates potential conflicts with a multitude of foreign objects entering
the space of impact around our facilities. A large portion of these objects are trees/branches that are
propagated into the lines from weather events with strong sustained winds. By undergrounding
sections of conductor, we essentially eliminate the possibility of trees/branches impacting the
conductor during these weather events. This ultimately reduces outages, decreases safety and fire risk,
and increases reliability. It eliminates the risk of a powerline falling to the ground and starting a fire.

11 Underground cables are twice as expensive (or more) than overhead lines, in part due to restoration costs (sidewalks, roadway s, landscaping) and
environmental impacts. Maintenances costs for underground are also significantly higher due to the limited access. For more information: David Baker,
“Despite Being Safer, Underground Power Lines Are Very Expensive,” San Francisco Chronicle, October 23, 2017,
https://www.govtech.com/fs/infrastructure/despite-being-safer-underground-power-lines-are-very-xpensive.html..
12 California Public Utilities Commission, “Overhead to Underground Conversion Programs,” Slide 1 (pdi2.org)
13 “Cost Estimation O/H Lines,” ENG-TIPS.com, Cost Estimation O/H lines (4kV and 13.8kV) - Electric power & transmission & distribution - Eng-Tips
Enhanced Grid
Hardening
Enhanced Grid Hardening Concept

16

There are many cases where
sections of distribution
conductors do not pose highly
probable threats to nearby
communities, including urban
areas that are largely
unburnable or with available
firefighting resources, or long
sections of line with many
miles between one customer
and the next. But in some areas
of our service territory, large
fire growth risk potential is in
proximity to communities which are
vulnerable to total loss in the event of a wildfire. Thus, we are evaluating the concept of risk-ranking
these areas and prioritizing sectional undergrounding of existing overhead conductor in areas
identified at being most at risk, primarily the outskirts of these communities.

Avista is currently assessing the concept of undergrounding high risk sections of the distribution system
using a multitude of factors to determine the specific locations of highest wildfire risk surrounding the
overhead distribution facilities. We believe that the risk can be separated into three parts: Outage
Potential, Ignition Potential, and Community Impact from Wildfire. For Outage Potential, Avista is
consolidating historic outage data and percent treed areas in strike zones to estimate risk of an outage
occurring during a wind event during fire season on the overhead distribution system. In the Ignition
Potential category, Avista is utilizing the Wildfire Hazard Potential data,14 which is a summary of fuel
type, slope, and exposure used to assess the burnability and ignitability of a location. Lastly, Avista is
using the Housing Unit/Community Impact data from the U.S. Forest Service15 to estimate the impacts
of fires moving from Avista’s distribution lines to nearby communities, showing potential impacts and
losses if a fire were to occur. These datasets are currently being combined into one risk score that will
allow for a 250 meter resolution risk heat map, showcasing the areas of highest risk. By focusing on
areas where the wildfire growth modeling suggests large scale loss and high impacts to homes, people,
and communities, we will be able to identify areas where we can create direct risk reduction. By
concentrating on very specific areas and the conductor segments most at risk, we may be able to
provide this reduction without using a far more expensive “blanket” undergrounding policy applied
territory wide – a “surgical” approach versus a broadscale application.

We are in the process of evaluating this strategy, including application of the analytics to define and

14 This is the USDA Wildfire Hazard Potential map that quantifies the relative potential for wildfire that could be difficult to control. Wildfire Hazard Potential
| Missoula Fire Sciences Laboratory (firelab.org)
15 This data represents the impact of fire on housing units across the U.S. Wildfire Risk to Communities Housing Unit Impact (Image Service) | Wildfire
Risk to Communities Housing Unit Impact (Image Service) | ArcGIS Hub
Wildfire near Beacon Hill, Spokane WA, indicating the resiliency of steel poles (on
the left) versus traditional wood structures (on the right)
ire went through Avista’s
transmission lines near
Spokane. Steel (on the left)
was undamaged; wood
structure (on the right) was
destroyed.

17

prioritize risk areas across our service territory as well as identifying the best approach to defining and
quantifying risk. This program is still in the feasibility stage. In 2026 and 2027 we added $25 million to
the Grid Hardening capital budget primarily in service to this goal. This work will solidify our
understanding of what it will take to implement this new strategy and the actual costs and logistics
involved. We anticipate that this will increase our capital budgets from that point forward by an
amount that will be determined after our first year s of experience with this program, at which time the
budget will be updated accordingly.

Transmission Steel Pole Conversion
Transmission lines are particularly vulnerable to wildland fires.
Repairs to them can cost millions of dollars in addition to the
potential for significant impact to customers16 and the effect of
their loss on the stability of the Western Interconnected Grid (that
is, our neighboring utilities.) Avista began installing tubular steel
transmission poles in the late 1980s for added resiliency and has
systematically replaced wood transmission poles and structures
with steel since 2006, typically for poles which were damaged or
failed, or in the course of routine transmission line build projects.
Since then, reconstruction projects have converted a number of
circuits from wood to steel, and that trend will continue.
Currently about 40% of Avista’s transmission poles are steel,
which makes them more resilient to wildfire and other weather
events. Though Avista is committed to steel conversion, one of
the objectives of the Wildfire Resiliency Plan is to accelerate that process in fire prone areas.

In service to that goal, the Company has created a prioritized list of wood structures to be replaced
with steel based upon WUI zone location, historical fire patterns, and type of vegetation. This
segregation is significant from a cost perspective, as it allows us to separate our mitigation efforts into
poles in high canopy/forested areas which are candidates for steel replacement, and those in low
vegetation areas, which may be adequately protected with fire resistant mesh. The cost for
replacement of a wood pole with steel is several thousand dollars per pole versus a few hundred
dollars for installing mesh wrap on a pole. Thus, knowing where the poles are physically located and
the geography of the area has a significant budget impact.

In 2021, Avista conducted analysis using 50 years of fire history to determine which transmission lines
were experiencing recurring impacts from wildfires. This analysis indicated that several of our
transmission lines are particularly vulnerable to recurring wildfires. We are targeting our resiliency
efforts in these areas. Lines most at risk from fire, such as the Addy-Gifford and the Devil’s ap lines,

16 Avista Outage Data from 2009 to 2023 indicates that the average number of customers impacted by a distribution outage is 50 v ersus a transmission
outage average of 615 customers affected.
Above is a high canopy fire, below is a fire in
low-level vegetation.

18

are slated for wood to steel conversion. In 2021 and 2022, transmission upgrades were focused on the
21-mile of the Addy-Gifford 115 kV line which serves areas near the Columbia River including the
towns of Wellpinit and Inchelium, Washington, both of which are Named Communities. In 2023,
wildfire budgeted wood-to-steel conversion was undertaken for transmission lines near the Devil’s ap
Substation which connects the hydroelectric dams of the lower Spokane River (Nine Mile, Long Lake,
and Little Falls) with areas west of Spokane and communities including Reardan, Davenport, Odessa,
and Othello. In 2024 our wildfire related steel replacement work will continue to be focused on the
Devil’s ap lines.

Most transmission lines are part of a networked grid, and this redundancy helps
reduce or negate customer impact during outages. However, some lines, like
Addy-Gifford, operate in a radial one-way fashion. This makes the work very
challenging since the line must remain energized during construction. This kind
of complexity can impact the number of poles that can be replaced under the
allocated budget, as the costs are much higher in this type of circumstance.
Thus, as in this example, the number of transmission poles replaced will vary
from year to year depending upon the complexity of each project, as reflected in Table 5, which
indicates the number of wildfire-budgeted steel poles installed since the Wildfire Plan was
implemented, in addition to traditional condition-based replacement and
construction of new facilities. The table also includes the number of wood poles
that were protected using the fire resistant mesh wrap product described below.
The Wildfire Plan has budgeted approximately 1,000 steel pole replacements on
the transmission system through 2029, with approximately 10,000 wood
transmission poles receiving fire mesh wrap. Our work in this area through 2023 is
shown in Table 5.

Fire Resistant Wraps on Wood Transmission Poles
Avista began using fire-resistant paint to protect transmission poles as early as
2005. Though the paint has proven effective in protecting poles from fires, it has a
limited expected life and requires maintenance or replacement every 3 to 5 years.
Avista worked with Southern California Edison to adopt a more resilient product
for protecting transmission poles at risk from grassland fires. Fire resistant mesh
wrap incorporates a heat activated chemical on a steel mesh substrate. When
activated, the chemical expands to seal the pole and protect it from fire. This
Table 5. Transmission Grid Hardening Results
Transmission Steel Replacement Poles Installed 2020 2021 2022 2023
Transmission Steel Replacement Poles Installed: Wildfire Only n/a 169 118 102
Asset Condition/New Projects Poles Installed n/a 812 476 526
Failed/Damaged Replacement Poles Installed n/a 35 38 4
Planned/Ad Hoc Transmission Poles Installed n/a 0 0 92
Total Non-Wildfire Transmission Poles Installed 1,821 847 514 622
Number of Transmission Wood Pole Fire Resistant Wraps Installed 1235 1938 1454 1533
Fire resistant paint chips,
peels and falls off the
poles over time unless
repainted.
Transmission steel
replacement work.

19

product works well in protecting wood
poles that reside in low vegetation areas
where fires move quickly but tend to
stay low to the ground. Protecting wood
poles from the impacts of wildfire also
supports reliable operations for
customers.

Avista initially expected to wrap
approximately 1,000 wood transmission
poles per year, but the wrapping crews
grew so proficient at this work that we
have increased our prediction to
wrapping 2,500 per year starting in 2024.

Annual Wildfire-Specific Inspections on Transmission Lines
Avista conducts annual inspections of transmission lines prior to
the summer operating season as required by federal
regulations.17 Generally inspections are conducted via helicopter,
vehicle, or on foot, with maintenance personnel looking for failed
equipment, bird nests, broken insulators, and other structural
defects. The Wildfire Plan adds LiDAR inspections to the existing
transmission inspection methods, which is able to specifically
identify vegetation-related risk. In addition, Wildfire provides
funding to help Transmission Design mitigate issues identified in
inspections that could potentially increase wildfire risk.

Grid Hardening Financials
Distribution grid hardening represents the single largest capital investment in the Wildfire Plan,
comprising about 77% of total capital expenditures over the ten-year period (2020-2029), followed by
transmission steel replacement at about 11%. Table 6 indicates the costs for all grid hardening
programs including transmission inspections.

Note that “Transmission Inspection/Construction” is listed both in the Capital and &M portions of the
table. Inspection is an expense activity (O&M) while the follow -up capital maintenance is an investment
in plant.

17 FERC Reliability Standard FAC-003, Template - Standard (Results Based) (nerc.com) requires inspection of 100% of the interconnected transmission
grid annually.
Fire-resistant mesh wrap effectiveness demonstration.
Transmission ground patrol inspection

20

Enhanced Vegetation Management
Vegetation management is an integral part of maintaining overhead
electric distribution and transmission lines as well as reducing outage and
fire risk. Historically, utilities have trimmed and removed trees with a
focus on service reliability and grid security. Avista has a long history of
deploying industry best practices related to our vegetation management
work, including the use of tree growth inhibitors and herbicides to retard
shrub growth, together with cycle-based tree trimming and hazard tree
removals. Avista’s Wildfire Plan enhanced this work by splitting it into two
programs: routine inspections (which continue the existing vegetation
practices) and Enhanced Vegetation Management in which inspections
specifically concentrate on identifying and mitigating risk trees.18

Tree fall-in rates tend to be closely linked
with wind and weather events. When
vegetation comes into direct contact with
electric lines and conditions are right,
there is potential for fire ignition. As part
of the Wildfire Program, distribution
routine cycle trimming has been
decoupled from hazard tree inspection,
with each becoming its own standalone
program. The routine program will
continue with cycle-based trimming

18 “2023 State of Vegetation Management, Survey Findings,” AiDash, 2023, SOVM-2023-Survey-eBook-Final.pdf (aidash.com)
A dead tree falls into an Avista
distribution line.
Table 6. Grid Hardening Actual and Budget Expenditures

Figure 9. Interesting graphic from a survey of U.S. vegetation managers
regarding vegetation related outages in 2023. Courtesy of AiDash.18

21

focused on about 20% (about 1,500
miles) of the system each year on about
a five year cycle. In contrast, Avista’s
Wildfire Enhanced Vegetation
Management goal is to perform risk tree
inspections across 100% of the
transmission and non-urban distribution
systems every year.19 Our goal for wildfire
risk reduction is to identify every dead,
dying, diseased, or defective tree within strike distance of a powerline and remove that tree as quickly
as possible. In fact, the Vegetation Team has the goal of removing risk trees within six months of
identification if at all practicable.

A key performance measure of the Wildfire Plan is a reduction in the number of tree incidents that
lead to outages (and therefore potential spark events). Tree contacts with powerlines are categorized
as either grow-in risk (encroachment into lines) or fall-in risk. All risk trees with the potential of
imminent fall-in or contact hazard to the energized facilities are trimmed or removed to eliminate
potential for fire ignitions and outages. A risk tree is a visibly dead, diseased, or dying tree, or one
which possesses obvious structural defects that could fall into the conductor.20 Our historical outage
data indicates that trees fall into electric distribution lines about five times more often than they grow
into them. Table 7 indicates the tree
incident rates for both distribution and
transmission lines, and Figure 10 shows
Avista-related tree incidents over time.
There are far fewer tree incidents with
transmission lines than distribution lines
due to the well defined wide rights-of-way
around transmission lines versus the
distribution system, which lacks clearly
defined corridors.

As evident in Table 7, tree incidents on the
distribution system far exceed those on the
transmission grid. In most situations, transmission lines occupy dedicated corridor rights -of-way which
afford the utility greater authority to manage vegetation. Also, transmission systems are regulated by
federal agencies such as FERC and NERC with prescriptive mandates for vegetation management.21 A

19 This does not include WUI 0 or WUI 1 areas or inside city limits with populations over 10,000.
20 Tree assessments are in part regulated by ANSI A300 (Part 9)-2017 Tree Risk Assessment - a. Tree Failure. Part 9 - Tree Risk Assessment - Tree
Care Industry Association, LLC. Assessments conform to level 1 standards as performed from the center of the corridor using ground-based patrols (or
from a vehicle) and/or by analyzing high-resolution images captured via satellite.
21 FAC-003-4 Transmission Vegetation Management Regulations, Template - Standard (Results Based) (nerc.com)
Figure 10. Avista’s Tree-Related Outages
Table 7. Tree Incident Rates
Note that the risk tree program became fully operational in 2022.

22

premium is placed on
the reliability and
security of the nation’s
high voltage
transmission grid, and
that focus is reflected in
overall reliability
performance and
maintaining the integrity
of the interconnected
grid, including robust
transmission vegetation
management regulations
and requirements.

Avista’s Wildfire Plan did not alter the thorough vegetation maintenance practices on the transmission
system but did add LiDAR surveys to aid with inspections. LiDAR inspections are able to specifically
identify and measure vegetation type and precise distance from powerlines to identify fall in potential
to conductor. It can identify clearance issues that may be undetectable by other methodologies such as
ground inspections and provides a precise location of the issues found. LiDAR works very well for the
wide corridors of the transmission system.

We also added satellite digital data
collection for the distribution system, which
provides a huge volume of geospatial
information, enabling deeper and more
regular vegetation management
intelligence, including change detection.
Satellite based vegetation inspection works
well for the distribution system, as it can
cover large areas quickly and accurately,
providing detailed data on vegetation,
growth patterns, and risk to power
infrastructure. It can easily differentiate
between grassland, agricultural, or urban
areas and detect the species and health of
vegetation, thus can identify vegetation that is likely to grow into or fall into powerlines.

In 2023, a record setting 22,573 trees were removed near powerlines . These trees were weakened by
drought, disease, and insects. Insects such as the pine bark beetle and spruce moth have emerged as
significant contributors to tree mortality. Forest health and insect infestation issues continue to
Figure 11. Wildfire Risk Tree Program Work
0
,000
0,000
,000
20,000
2 ,000
2020 202 2022 202

u
m
b
e
r

o
f

r
e
e
s

R
e
m
o
v
e
d

Distribu on ransmission
0 0

The distribution system is often located in areas such as
on private property, lacking in defined corridors that
make it more difficult to access for vegetation
management.
The transmission system has wide well
defined rights-of-way. (This is the
Benewah-Pine Creek 230 kV line.)

23

increase the number of risk
trees in our service territory.
In 2022 and 2023 we found
that the actual number of risk
trees was nearly double earlier
estimates. Forest health was
made more dire by the historic
drought of 2021, but also
reflects increased levels of
insect damage combined with
human activity, all leading to
higher levels of tree mortality than expected. In fact, the USDA anticipates “substantial tree mortality
from insects and diseases through 202 ” in our region.22 As shown in Table 8, the number of tree
removals have significantly increased each year of the program. At the same time, we are seeing a
decline in tree-related outages. In 2022, 438 trees fell into electric lines. In 2023 this number was
reduced to 280, at least partially as a result of Avista’s dedicated vegetation efforts.

Reducing the number of
tree falls is an important
component of Avista’s
Wildfire Resiliency Plan
and positively impacts
both wildfire risk
reduction and customer
service and reliability.
Enhanced vegetation
management under the
Wildfire Plan represents
new activities such as
digital data collection
(LiDAR and satellite) as
well as incremental
activities beyond what
was historically
undertaken by Avista
vegetation managers.

22 “Forest Health Summary for the Pacific Northwest Region 2022: USDA Forest Service: Forest Health Protection, Oregon Department of Forestry, and
Washington Department of Natural Resources, July 11, 2022, Forest Health Summary for the Pacific Northwest Region 2022 (arcgis.com)
Table 8. Enhanced Vegetation Management Program Results *
These photos, taken 4 months apart, show the rapid impact of an insect infestation.
Enhanced Vegetation Management Program 2020 2021 2022 2023
Total Number of Trees Trimmed 3,129 4,313 13,036 9,989
Total Number of Hazard Trees Removed 10,091 12,796 18,959 22,573
Distribution Enhanced Vegetation Management Program 2020 2021 2022 2023
Miles of Distribution Risk Tree Inspections 2,811 5,245 6,466 6,546
Percent of Distribution Risk Tree Inspections Performed on Time 100%100%100%100%
Percent of Distribution Risk Tree Inspections Remediated n/a n/a 90%58% *
Number of Distribution Risk Trees Removed 10,091 12,796 15,678 19,511
Number of Distribution Risk Trees Trimmed 3,129 4,313 10,780 9,142
Miles of Distribution Satellite - AiDash Completed 85 7,675 7,675 7,675
Transmission Enhanced Vegetation Management Program 2020 2021 2022 2023
Total Miles of Transmission Risk Tree Inspections 1,355 2,270 2,270 2,270
Percent of Transmission Risk Tree Inspections Performed on Time 100%100%100%100%
Percent of Transmission Risk Tree Inspections Remediated n/a n/a 100% 96% *
Number of Transmission Risk Trees Removed 1,288 1,910 3,281 3,062
Number of Transmission Risk Trees Trimmed n/a 232 2,256 847
Acres of Transmission Corridor Clearing Completed 1,270 1,848 736 782
Miles of Transmission LiDAR Completed 540 1,143 2,270 1,679
Enhanced Vegetation Management Program 2020 2021 2022 2023
Miles of Distribution Risk Tree Inspections 2,811 5,245 6,466 6,546
Number of Distribution Risk Trees Removed 10,091 12,796 15,678 19,511
Miles of Distribution Satellite - AiDash Completed 85 7,675 7,675 7,675
Total Miles of Transmission Risk Tree Inspections 1,355 2,270 2,270 2,270
Number of Transmission Risk Trees Removed 1,288 1,910 3,281 3,062
Miles of Transmission LiDAR Completed 540 1,143 2,270 1,679
Other Vegetation Management Programs 2020 2021 2022 2023
Number of Trees Replaced Through the Customer Safe Tree Program n/a n/a 870 477
Number of Trees Removed Through Customer Requests n/a n/a 63 1,365
Fuel Reduction Partnership Acres of Trees and Brush Removed/Trimmed n/a n/a 211 179

24

Enhanced Vegetation Management activities include:
• 100% Distribution Risk Tree Inspections
• Transmission LiDAR
• Distribution Satellite Imaging
• Safe Tree Program
• Fuel Reduction Partnerships

Each of these activities will be discussed in more detail
below.

100% Distribution Risk Tree
As noted above, Avista increased the annual risk tree inspection of the electric distribution system
from 20% of the system each year to 100% of non-urban areas as part of the 2020 Wildfire Plan. The
Company began ramping up activities starting in 2020 and achieved 100% inspection starting in 2022.
Table 8 above indicates the program results by year. Avista is committed to removing risk/hazard trees
within six months of identification, and the Company continues to work with line clearance contractors
to build a local workforce in support of that goal.

Avista believes that the risk-based inspections provided by LiDAR and satellite imagery as well as
expansion of our existing risk tree inspection program to viewing nearly 100% of the system each year
will aid in identifying and mitigating risk tree issues going forward, though there will likely be some
time catching up on current risk tree inventory as the backlog of risk trees are removed , leading to
higher costs in the first few years of the program.

In June of 2023, Avista agreed to the following terms with the Idaho Public Utilities Commission (IPUC):
“ or the Distribution Risk ree Program, Avista will have a third party conduct a study, within a year of
Commission Order, to see what the most efficient vegetation management cycle should be in their
service area (i.e., 2 or year cycles).” Avista chose an industry leader specializing in utility vegetation
management and risk mitigation solutions and who had no other dealings with Avista to provide a
neutral third party evaluation. After several months of work, this provider, Iapetus, sent their report
and findings to Avista. The key observation from Iapetus was that Avista has a reasonable and
responsible approach which is aligned with “best-in-class” vegetation programs of other major utilities.
They commented that Avista has developed a Risk Tree Program by leveraging their internal
experience and history of tree outages and program performance and via collaboration with leading
*Note: The percent of risk trees remediated can be misleading. The program goal is to mitigate risk trees within 6
months of identification. In 2022 90% of the risk trees remaining at year end were less than 6 months old. In 2023 only
58% of the risk trees remaining at year end were less than 6 months old . This is due in part to the timing of the
respective inspections, with the 2023 inspection being completed earlier in the year than in 2022. However, 100% of
risk trees identified in 2023 were mitigated prior to fire season 2024. We did not track the % of remediations until 2022.
Fuel Reduction Work

25

wildfire mitigation programs
at electric utilities with more
mature and robust programs.

Based upon their review,
Iapetus found that Avista’s
approach to managing the
risk associated with utility-
caused wildfires as an annual
cycle is an effective strategy
and pointed to the evidence shown by the
reduction in actual tree fall-ins, which have
seen a 62% reduction since the Wildfire program began in 2020. They stated that by leveraging the
industry-accepted UAA/ISA guide, Best Management Practices – Utility Risk Tree Assessment,23 Avista
is utilizing the most current protocol in use today by North American utilities. They further noted that
Avista’s WUI risk tiers are aligned with the California approach to delineate high fire threat districts,
which is considered best practice. Their primary recommendation for improvement was collecting
more data about the root cause of tree-related outages, a suggestion that Avista’s Vegetation
Management team is pursuing.

Transmission LiDAR
Beginning in 2020, Avista has used LiDAR24 surveys to assess vegetation
encroachment and fall-in risks on the transmission system. It is a laser
survey technique that is highly accurate and able to identify tree health
as well as tree height and distance from powerlines. LiDAR data is
generally collected via a fixed wing aircraft or helicopter, so it is a
natural fit for wide and well-defined transmission corridors. The
resulting survey-grade data yields sub-centimeter accuracy, and when
combined with high resolution photography, it provides vegetation
planners with a robust assessment of both encroachment and risk tree
hazards. It can clearly identify dead, dying, diseased or structurally
defective trees both inside and outside our corridor rights-of-way and is
very accurate in calculating fall-in risk. LiDAR also provides computer-
aided precise location and identification of vegetation-based issues as they arise over time. LiDAR
works well for transmission inspections because it provides a high level of detail and accuracy,
including the placement of the conductor in the corridor, so areas wher e vegetation might impact the
lines are identifiable. Wide transmission corridors (versus the narrow corridors around most
distribution lines) make it easy for a helicopter or airplane to fly over them to collect LiDAR data.

23 International Society of Arboriculture (isa-arbor.com)
24 LiDAR stands for Light Detection and Ranging.
Avista transmission corridor
Iapetus Third Party Distribution Vegetation Program Evaluation

26

The digital data provided by LiDAR supplements traditional visual inspections and helps vegetation
planners prioritize and prescribe treatments including herbicide applications, tree trimming, and tree
removal with great accuracy. The data from the LiDAR scans, in conjunction with existing aerial and
ground inspections, is incredibly accurate. When combined with high
resolution photography, it provides vegetation planners with a
robust assessment of both slash and risk tree hazards. It also shows
the topography of our service territory. The associated analytics
track vegetation growth over time and are very accurate in
calculating fall-in risk. Historically, transmission lines were trimmed
on a calendar cycle, but LiDAR is changing that practice. Digital data
combined with machine learning computer algorithms allow our
System Forester to use a risk-based approach to treatments rather
than routine maintenance cycles alone.
While Avista is still calibrating LiDAR
information based on human observations, digital inspections are quickly
becoming the industry standard practice and allow for a complete vegetation
record, including the efficacy of field work along with the information
necessary to create future work plans.

Distribution Satellite Imaging
Similar to the LiDAR project for transmission, Avista is incorporating satellite
digital data to aid vegetation planners with the risk tree inspection and
planning process on the distribution system. This methodology allows for a
system-wide approach rather than conventional corridor collection (LiDAR),
which aligns well with distribution topologies, as it works very efficiently for
the trunk-and-lateral, non-linear configuration of the distribution system,
which lacks consistent defined flyable corridors. Satellite acquisition allows
collection over a broad area both in urban and rural areas. Satellite-based data,
however, is not as sophisticated as LiDAR, requiring several passes over the
system to collect the data needed. In addition, satellite images are not detailed
enough to include conductor placement. However, with satellite imaging, successive overpasses are
paired with artificial intelligence to effectively assess the risk of both tree encroachment (grow-in) and
strike potential (fall-in), thereby providing a data-driven approach to identifying and managing the risk
of vegetation encroachment on our distribution system.
Satellite systems are quickly evolving. These technologies apply machine learning computer algorithms
to large data sets and help vegetation planners create risk-based work plans rather than relying solely
on cycle trimming. For many years, Avista has used cycle trimming to maintain vegetation near
distribution lines on a rotating 5-year cycle. However, some areas have higher growth rates and may
require shorter trim cycles, while other areas with slow -growing trees may accommodate longer cycle
times. Beginning in 2020, Avista partnered with AiDash to provide satellite data along with their
LiDAR Image of transmission line
AiDash satellite image of
an Avista distribution line
showing tree proximity.

27

Intelligent Vegetation Management System (IVMS).25 Like the
LiDAR project, vegetation planners are working with AiDash
to calibrate the system and align computer-derived
assessment with field observations. Starting in 2023, Avista
vegetation planners transitioned their work plans to the IVMS
system. This allows them to customize the cycle trim times
and incorporate a risk-based approach to work planning. In
short, they will focus attention in areas with higher levels of
tree encroachment risk and outage rates as well as increased
fire risk rather than solely relying on cycle trimming.

Safe Tree Program
In 2022 Avista started a new program we initially called
“Customer Driven Right ree Right Place,” renamed the “Safe
ree Program.” his program is designed to work proactively
with customers in elevated fire threat areas who have tall-
growing trees under or adjacent to our powerlines and located
on their private property. The Safe Tree Program removes non-compatible vegetation (i.e., likely to
grow into powerlines), cleans up the debris, and replaces the previous tree with a low -growing species
of the customer’s choice if the customer wishes to do so,
all at no direct cost to the customer. Low growing
replacement species mature to a height that will not
interfere with overhead powerlines and should not require
ongoing trimming to keep them from becoming hazards to
powerlines. Interestingly, most of our customers are happy
to have trees they are concerned about removed without
requesting a replacement. For example, in 2022 we
worked with 52 landowners to remove 870 trees but they
only requested 63 replacement trees. In 2023 we removed
1,365 trees and replaced 477 trees as shown in Table 8
(page 23). We also implemented the “Safe ree Customer Service Portal” for this service on the
MyAvista website,26 allowing customers to communicate directly with our arborists and schedule this
work when it is convenient for them.

Fuel Reduction Partnerships
We believe that partnerships with non-Company entities are critical, as many agencies and groups are
also focused on wildfire risk reduction and there are many parts to play. Avista is working with a
variety of agencies who share a vested interest in wildfire mitigation. One of the ways we do this is by

25 AiDash Intelligent Vegetation Management System Intelligent Vegetation Management System (IVMS) - AiDash
26 Tree Pruning (myavista.com)
Satellite-derived vegetation information
Safe Tree Program Work

28

providing funding to state and tribal agencies to support their efforts in reducing dead trees and brush.
For example, the Washington Department
of Natural Resources (DNR) has embarked
on a 20-year plan to improve forest health
on 2.7 million acres of forest land in
central and eastern Washington.27 They
state that unhealthy forests are driving
catastrophic wildfire, in great part due to
large expanses of beetle kills in
Washington forests.28 As Hilary Franz,
Washington Commissioner of Public Lands,
states: “We have a forest health crisis in
our state……. ot dry conditions coupled
with diseased and dying forests are leading
to explosive wildfires.”29 Avista partners
directly with fire protection agencies
including the Washington Department of Natural Resources and the Idaho Department of Lands, the
Nez Perce Tribe, local and regional fire agencies, and others to help them reduce this risk. Through our
Fuel Reduction Partnerships, Avista financially assists these external agencies with fuel reduction on
their properties near our facilities, helping the agencies cover some of the funding gaps they face. Their
work helps create defensible space that can make the difference between a structure surviving a
wildfire or becoming a total loss.

In another example, the State of
Idaho identified several
communities that Avista serves
with overhead electrical service
that they classify as communities at
risk of wildfire.30 Avista works with
the State to help pay for fuels
reduction in these at-risk areas.
Note that the work in Idaho costs
more per acre to complete than in

27 Western Pine Beetle graphic from “Forest Health Highlights in Washington 2022,” Washington Dept. of Natural Resources,
https://www.dnr.wa.gov/publications/rp_fh_2022_forest_health_highlights.pdf, page 23.
28 Washington Policy Center, “What is Causing the Increase in Catastrophic Wildfire,” Oct. 6, 2022, What is causing the increase in catastrophic wildfire: a
short explainer » Publications » Washington Policy Center
29 Washington Dept. of Natural Resources “20 year Forest Health Strategic Plan: Central & Eastern Washington,”
https://www.dnr.wa.gov/ForestHealthPlan
30 Idaho Dept. of Lands “Good Neighbor Authority” is an agreement Idaho has with federal agencies to carry out forest, rangeland, and watershed
activities on federal lands within Idaho. Part of this is joint fuel reduction efforts. More information available in their brochure: \\c01m677\Fuel Reduction
Partnerships\GNA-report-Dec-2020.pdf and Fuel Reduction Partnerships\GNA-Update-January-2020.pdf
Fuel Reduction Work Before & After
Figure 12. Washington DNR chart indicating forest health issues due to
beetle kill.

29

Washington because the density of fuels is much higher and requires more mechanical treatment than
most areas in our Washington service territory. We have also been able to help fund Bonner County
Department of Emergency anagement’s BonFire Program.31 BonFire is a county-wide resource whose
goal is to provide technical expertise to landowners who wish to reduce fuels in and around their
homes. In addition to expertise, BonFire also provides labor resources to complete the fuel reduction
work prescribed. While this type of work benefits the people in that area directly, it also has a positive
impact in developing additional partnerships in Idaho counties, which will ideally lead to additional
partnerships with fire agencies.

Our Fuel Reduction program not only helps reduce fire risk for customers but has also done a great
deal to continue to bolster our relationships with great partners across Washington and Idaho . It is
another way Avista contributes in a very real way to reducing wildfire risk for the communities we
serve.

Enhanced Vegetation Management Financials
Table 9 indicates actual and projected costs for Enhanced Vegetation Management program from 2020
through 2029.

Situational Awareness
Avista developed tools under the Situational Awareness part of the Plan that are designed to identify
and manage risk, primarily the Fire Weather Dashboard and Avista’s WUI Map. Using the dynamic risk
model offered by the Fire Weather Dashboard and the information on areas of impact provided by our
customized WUI map, Avista can align system protection with fire threat conditions across the full
spectrum from nominal operations (non-fire season) to a base-level setting used during fire season
through elevating protection settings during critical fire weather conditions. This approach allows for
an almost hour-by-hour balance of fire safety and reliability. The Dashboard helps us minimize
customer impacts by elevating protection settings (and therefore increasing the risk of an outage) only

31 For more information: BonFire Program Bonner County - BonFire (bonnercountyid.gov)
Table 9. Enhanced Vegetation Actual and Budget Expenditures

30

in areas most at risk, while at the same time continually tracking risk levels to allow us to move back
into normal settings quickly once an event has passed. A new facet in the Situational Awareness
category is the addition of monitoring technology. We are currently working on adding wildfire
identification cameras and weather stations across our service territory to provide additional insights
and real-time information about conditions to help predict and/or identify fire situations.

Note that the budget for automation devices (both distribution and substation), initially in the
Situational Awareness category, were moved into Operations and Response to more closely align with
their purpose.

More details about our Situational Awareness programs are provided below.

Fire Weather Dashboard
A key part of Avista’s wildfire strategy is the ability to identify when risk is increasing. Avista developed
a computer algorithm to monitor, forecast, and allow us to adapt to elevated risk and fire-weather
events. This tool that we call the Fire Weather Dashboard was designed to indicate the moments
where utility-sourced fire potential is at its highest and when fire spread rates pose significant risk to
neighboring communities. It provides daily quantitative fire risk potential metrics for every feeder on
our distribution system and each transmission circuit . Knowing this risk helps the Company make
better operational decisions as to when electric facilities should be placed in any kind of elevated fire
mode (FSM) in order to protect customers. The Dashboard allows system operators to align circuit
protection settings with fire-weather conditions and minimize the potential for spark-ignition on a
circuit-by-circuit basis. It quantifies the daily fire risk for the upcoming week on all of Avista’s 0
distribution circuits and 72 transmission lines.

This monitoring system is similar to those used in California. In fact, Avista worked closely with San
Diego Gas & Electric to calibrate the system to achieve a balance between electric service reliability
and fire ignition potential. The Dashboard is the key to Avista’s fire season circuit protection program
known internally as Fire Safety Mode, described in more detail below.

31

The Dashboard is a sophisticated risk-based model developed within Avista and directly customized to
our system. It uses historical data based on our service territory that combines elements of the 7-day
National Weather Service forecast with infrastructure performance and underlying fire risk metrics.
This tool provides insights into each individual feeder in Avista’s distribution system, delivering a risk
level based on a comprehensive spectrum of information including wind speed and direction,
sustained wind levels, humidity and dryness levels, type of vegetation on each feeder, temperature,
condition of equipment, mode of operation, historic outage data, and more. It provides a dynamic look
at Avista’s daily fire risk and weather conditions across our system, identifying areas and times where
Figure 13. Screenshot of the Distribution Fire Weather Dashboard

32

problems may arise and when the risk is increasing beyond a desirable point. It provides notice to take
actions to mitigate potential risk on individual facilities throughout our system. It also has the ability to
track current fire paths and estimate potential risk to Avista’s infrastructure. When combined with the
dynamic operating capability provided by automat ed protection equipment, it guides the decision to
enable various levels of operations and protection systems (Fire Safety Mode operations) to mitigate
risk.

Figure 14. Screenshot of the Transmission Fire Weather Dashboard

33

WUI Map
The interface area between forest lands and human
development is referred to as Wildland Urban
Interface, commonly known as “WUI Zones,” which
are the transition zones between wilderness and
populated areas - basically where the built
environment meets the natural environment. Today,
more than one-third of the U.S. population lives in
the wildland urban interface.32 The attraction of
living in wooded areas and closeness to nature is
accelerating growth in the WUI. However, when
wildfires strike, the WUI’s mix of buildings with
forests and grasslands can set the stage for disaster.
Homes and businesses located in WUI zones are most
at-risk from the impact of wildfires and are often
located in rural areas lacking adequate fire
suppression resources. Approximately 126,200 Avista
customers33 (about 30%) reside in elevated risk fire
zones.

In contrast, incorporated urban areas exceeding
10,000 in population are typically identified as
“developed areas” for wildfire hazard potential and
are considered non-WUI, as they have well established
fire response facilities and non-burnable hardscape areas such as roads and parking lots to help serve
as fire containment zones. These areas tend to have firefighting and fire identification and response
capability. Thus, fire spread potential is constrained in these areas.

Avista believes that employing a WUI map helps identify and
prioritize areas of greatest risk and serves to inform
recommendations and operational decisions related to wildfire
resiliency and applying the Wildfire programs within our service
territory. In utilizing a WUI map specific to our service territory and
customer base, we can target our programs where they have the
potential to reduce the most risk and have the greatest positive
impact in the safety and protection of our customers and our
infrastructure. Avista’s WUI map is based upon characteristics of our
system such as:

32 USDA USFS “Wildland-Urban Interface Growth in the U.S.,” Wildland-Urban Interface Growth in the U.S. | US Forest Service Research and
Development (usda.gov)
33 As of 2023 based on customer meter count and the current Avista WUI map.
Figure 15. Avista’s WUI Map
Figure 16. Close-up of Avista’s
Distribution WUI Map

34

• Fuel concentration and vegetation density - areas with high volumes of trees based on data from
both the U.S. Department of Agriculture’s Wildfire azard Potential map34 and Avista’s specific
system characteristics based on our distribution satellite imaging data.

• Impacts to communities - areas identified by their probability for total loss if a wildfire were to
occur at that location. his information is obtained from the U.S. Department of Agriculture’s
Wildfire Housing Unit Impact dataset.35

• Our own historic outage data, focused on areas with higher levels of historic outages during fire
season as obtained from Avista’s Outage anagement System.
Using this information, Avista “WUI Risk Levels” were established:

• WUI ier 0 - None to low levels of fuel and outage potential, and low to moderate housing
impact (lowest). Statistically, this represents fire risk of less than the system average minus ½
of the dataset’s standard deviation (low).

• WUI ier – Low to moderate levels of fuel and outage potential and low to moderate
housing impact (low). Fire risk is greater than WUI 0 but less than the system average
(moderate).

• WUI ier 2 – Moderate to high levels of fuel and outage potential and moderate housing
impact (medium). Fire risk is above the system average but less than the system average plus
½ the standard deviation (elevated).

• WUI ier – High levels of fuel, outage potential, and housing impact (high). Fire risk is above
WUI 2 levels (extreme).

he combination of WUI 2 and represents approximately % of Avista’s distribution system where
fire risk exceeds the overall system average (high). As of 2023, Avista had over 126,000 customers
located in high fire risk areas.

34 “Wildfire Hazard Potential for the United States,” fs.usda.gov/rds/archive/products/RDS-2015-0047-4/_metadata_RDS-2015-0047-4.html
35 “Wildfire Risk to Communities: Spatial Datasets of Wildfire Risk for Populated Areas in the United States,” fs.usda.gov/rds/archive/products/RDS-2020-
0060/_metadata_RDS-2020-0060.html
State
Miles %Miles %Miles %Miles %Miles %Miles %
WA 2,670 35%780 10%1,056 14%652 8%1,708 22%5,158 67%
ID 1,181 15%349 5%418 5%619 8%1,037 13%2,567 33%
Total 3,851 50%1,129 15%1,474 19%1,271 16%2,745 36%7,725 100%
Low (0)Moderate (1) Miles Elevated (2)Extreme (3)Total Miles
Distribution Line Miles
WUI 2 & 3
Table 10. Avista’s WUI Miles

35

Having a WUI map helps Avista apply grid hardening programs most effectively to reduce equipment
failures, reduce the chance for sparks, and make the grid more resilient to the impact of fire where the
risk is highest. It informs vegetation planners on how best to prioritize their tree trimming and removal
work plans and allows us to maximize the value of the Wildfire Plan dollars spent. We are also looking
into addition tools to help us evaluate risk and further quantify how our programs are reducing risk in
our elevated WUI areas.36

Wildfire Cameras
Wildfire identification cameras are invaluable in quickly identifying a fire start as well as pinpointing its
precise location. Early detection of ignition increases the likelihood of timely containment and
suppression of wildfires, saving lives and reducing property losses. Camera technology can also assist
first responders with evacuation planning and routes if required, thereby protecting a community if it
needs to evacuate. Interestingly, a recent study states that only 5% of 911 fire calls are actually a fire,37
but that must be verified by dispatching a truck to the scene, which is costly and time consuming. With
the AI technology offered by ultra-high-definition wildfire cameras such as those offered by Pano AI,
confirmation of an actual fire and its location can be made. This technology allows dispatching
resources directly to the latitude and longitude of the smoke so firefighters do not have to search for
the fire, saving invaluable time. Their system also provides information on the nearest water sources as
well as wind direction to further aid first responders.

In 2023 the UMS Consulting Group applied for a federal grant under the DOE Grid Resiliency and

36 Washington State WUI Map courtesy of Ashely Blazina and Kirk Davis, Washington Dept. of Natural Resources, February 25, 2022,
https://storymaps.arcgis.com/stories/7016c437623a445997c072a05e26afbb and Idaho WUI zone map courtesy of the USDA Map of the Wildland-Urban
Interface of the Conterminous United States, page 24, The 2010 wildland-urban interface of the conterminous United States (usda.gov)
37 Haje Jan Kamps, “Wildfire detection startup Pano AI extends its $20M Series A with another $17M,” TechCrunch Magazine, July 10, 2023, Wildfire
detection startup Pano AI extends its $20M Series A with another $17M | TechCrunch
Washington and Idaho
State WUI Zone Maps

36

Innovation Project (GRIP)38 to help utilities mitigate fire risk exposure,
specifically to increase situational awareness including the application of
surveillance cameras to identify fire ignition. Avista joined with UMS and
several other utilities including Inland Power
& Light, Portland General Electric, and BPA, as
well as vendors including AiDash (Avista’s
satellite vendor) and Pano AI (wildfire camera
vendor) to file a joint application for funds
from this grant. This application was
approved in October of 2023, including
funding of $38 million to install wildfire
cameras across Washington, Idaho, Oregon,
and California with another $38 million in cost sharing by the participants.
Avista’s portion of this was about $2 million. A match in funding from each participant is required. For
Avista, this level of funding and our associated match would have provided funding for 10 camera
installation sites plus a requirement of about $10,000 per location in annual O&M costs.

However, as this process proceeded Avista found that UMS did not involve participants in any of the
planning, scoping, or budgeting for this grant. In fact, they submitted numerous materials to the Dept.
of Energy on Avista’s behalf of which we were completely unaware, including documents that reflected
a budget that did not adequately cover Avista’s costs with no ability to increase the proposed
allocations. In addition, the Company learned that we would be required to engage with
subcontractors of U S’s choosing and adhere to reporting requirements that were
either redundant with or would require us to divert resources away from our
existing wildfire mitigation efforts. It was determined that Avista would proceed
with the wildfire camera installation on our own, as wildfire cameras can
monitor vast areas susceptible to fire and early detection of ignition increases
the likelihood of timely containment and suppression of wildfires, saving lives
and reducing property losses.

Avista partnered with Pano AI, a company that provides cameras, surveillance,
24 hour monitoring, and computer machine learning to identify fire starts.
With this system, a full 360° view is captured every two minutes. If the
system detects a smoke plume, Pano staff are alerted. If the smoke plume is
verified as a fire start, first responders and utilities are alerted and sent
directly to the site. The Washington Dept. of Natural Resources (DNR)

38 The Infrastructure Investment and Jobs Act (IIJA), aka Bipartisan Infrastructure Law (BIL), was signed into law by President Biden on November 15,
2021. The law authorizes $1.2 trillion for transportation and infrastructure spending, with $550 billion of that going toward new investments and programs.
In early 2023, as part of this Act, the U.S. Dept. of Energy (DOE) offered $918 million in grants to utilities across America to inspire grid resilience efforts.
This grant is called “DOE Grid Resiliency and Innovation Project (GRIP). Grid Resilience and Innovation Partnerships (GRIP) Program | Department of
Energy
Wildfire detection
cameras and associated
AI can pinpoint and
precisely locate fires
when they first start.

37

recently selected Pano AI to install 20 cameras in the state of
Washington, which presents a great partnering opportunity for Avista.
We are also partnering with the Idaho Dept. of Lands for key sites in
our Northern Idaho service territory. We joined with these state
agencies to fund 10 camera installations. Washington Commissioner of
Public Lands Hilary Franz is working with legislators in Washington D.C.
to get more funding for these cameras for the Dept. of Natural
Resources and their partners in this endeavor, including Avista.39

By August of 2024, five of the ten cameras were in place, with the
remaining cameras scheduled for completion by the end of September.
These cameras almost immediately proved their value. On Thursday,
August 8th, 2024, our Eastern Lincoln County camera detected a fire
and promptly notified the Washington DNR. This notification triggered an immediate response from
DNR aircraft and ground resources. Due to the early detection and situational awareness provided, the
forward progress of the fire was quickly halted. While the total acreage of the incident was estimated
to be 20-30 acres, the DNR indicated that the fire would have been significantly larger if more time had
elapsed before they received accurate information on the fire’s location and behavior to appropriately
scale their response.

Avista has access to the camera systems and fire start reporting from Pano AI. While Avista fully defers
fire response to state and local fire agencies, knowing the proximity of fires to critical infrastructure
will help System Operators protect equipment and customers with real-time access to fire activity.

Weather Stations
Weather stations enhance a utility’s knowledge of an area’s weather situation, including dangerous
weather conditions approaching and on-the-ground observations. Weather conditions directly affect
the potential for a fire to occur and spread. Weather stations can monitor relative humidity,

39 Courtney Flatt, “How AI is helping detect wildfires in Washington,” Sept. 11, 2023, How AI is helping detect wildfires in Washington - OPB
Pano AI Functionality

38

temperatures, wind speeds and gusts, all key factors in fire prediction.
Regional weather stations better inform decision makers related to
issues such as potential fire risk and elevating protection settings, which
is especially helpful given the size of our service territory. These stations
supplement the information from the National Weather Service and
improve our information when making operational decisions, which is
particularly important as we consider Public Safety Power Shutoffs.

In 2024 Avista joined with a consortium of utilities across the Northwest in applying for a federal grant
that will, if accepted by the Dept. of Energy, help provide funding for weather stations across the
Northwest, though we will be pursuing these stations regardless. Due to this project being in
preliminary stages, at this point we have not yet assigned budget dollars to cameras or weather
stations.

Situational Awareness Financials
Table 11 indicates actual and projected costs associated with our Situational Awareness programs to
date. Note that we have included placeholders for wildfire cameras and weather stations, as we do not
yet have a solid estimate of the costs around these elements, but these expenditures will be broken
out of what is currently being shown in the Fire Weather Dashboard, thus the total Situational
Awareness budget should not be changed.
Operations & Response
Avista developed a two-pronged Operations and
Response strategy designed to react to wildfire risk both
operationally and through critical partnerships. First, it is
important to be able to manage the system with rapid
identification of increasing risk and have the ability to
react accordingly. A key way of doing this is through
protection settings changes and remote monitoring and
control of equipment, specifically substation SCADA
installations and Fire Safety Mode automation devices. Automation strategies and systems enable
remote monitoring and control of transmission and distribution equipment, providing not only direct
Table 11. Situational Awareness Actual and Budget Expenditures
PG&E installs a weather station.

39

control of this critical equipment, but also allowing system operators and planners to fully see and
react to short term operating risks. In this area of the Plan, investment expenditures are primarily
related to upgrading, replacing, or installing equipment to help us monitor and control protection
equipment out in the field, on distribution lines, or in substations to allow quick response to fire
weather and associated risk.

Another aspect of this element of the Plan has little or no budget, as it is focused primarily on
relationships. Though planned investments in utility infrastructure and vegetation maintenance
represent the bulk of our Wildfire Plan costs, human investments in training, partnerships, and
engagement with customers are also an important feature of Wildfire Resiliency. This aspect of the
Operations and Response part of the Plan encompasses both internal and external resources with a
goal of reacting to wildfire threat in a thoughtful, proactive, and coordinated manner, along with the
ability to rapidly respond as needed. Its purpose includes building solid working relationships with
outside entities and first responders, developing both internal and external joint response strategies,
and tracking the progress and benefits of the Wildfire Plan programs to allow continuous
improvement. Avista has a tradition of ‘doing the right thing’ for customers and the communities we
serve. Working together to promote safety and manage the risk of wildfire is not a new concept, but
simply one that commands a unified and holistic response. Elements of our Operations and Emergency
Response efforts are designed to accomplish this, as described below.

Automation
Automation equipment provides “eyes” on some
of our most critical infrastructure in high fire
threat areas. For example, midline circuit
reclosers are often deployed on long distribution
lines where substation-based equipment cannot
adequately protect the entire length of the
circuit. Urban distribution
lines are typically 5 to 10 miles in length, while rural counterparts can
extend hundreds of miles. any of Avista’s circuit breakers do not support
monitoring or control, which means they cannot be remotely operated,
requiring manual intervention to make changes to settings or to identify an
issue. This may take several hours depending on location and crew
availability. Part of the Wildfire Resiliency Plan is installing modern circuit
reclosers on circuits deemed potentially at risk. These new reclosers are
capable of remote observation and operation so do not require manual
intervention. We are also updating some “dark” substations located in high
fire threat areas, meaning those currently lacking automation and
communications equipment, so they can be monitored and controlled
remotely as well.

Diagram of a distribution
recloser
Example of Avista’s use of a recloser

40

Avista operates about 330 midline reclosers outside of the
substation. Of these, 240 distribution reclosers (both midline
and substation) require protection setting upgrades in order to
be Fire Safety Mode capable and able to aid in implementing
wildfire protection measures.40 The vast majority of these
devices are located on circuits that serve rural areas in high fire
threat (typically WUI 2 and 3) regions. Many of these devices
lack communication controls and must be switched or altered
manually by physically accessing the device. Other circuit
reclosers are modern units and will support automated Fire Safety Mode but require software
upgrades.

In addition to updating or installing automated reclosers on
the distribution system midlines, fifteen Avista substations are
located in high threat fire areas and lack communications
equipment. Another thirty substations require hardware
upgrades to support a fully automated Fire Safety Mode
system. This work includes 129 substation breakers that serve
downstream WUI 2 or 3 zones. Additional units both on the
distribution grid (midline devices) and those located in
substations require some level of hardware upgrades such as
recloser replacement and/or upgrades to electronics. Others need major installations, such as SCADA
monitoring systems. Upgrading these units is a significant project and is expected to run the through
2029.

Avista plans to modernize
4-5 substations per year,
with the goal of forty-five
stations capable of remote monitoring and control by
2029.41 It is important to realize that the cost of updating
one substation does not accurately reflect the cost of updating another substation. Each one is its own
individual project with unique equipment and material requirements. For example, one existing station
may already have integrated fiber, while a different rural station would require $500k+ to install new
fiber/T1 for providing a communications connection. Another example could be that an existing station
may already have a panel house to integrate protection and communications equipment, while
another substation may require us to construct a new panel house. Some substations may have one or
two transmission and/or distribution lines associated with them while others may have many lines
connected with them, adding complexity and cost to the equipment required. Some may require

40 These 240 devices were selected based on the downstream WUI tier zones that are served (Tiers 2 and 3 were mandated by the Pr ogram, while some
Tier 1 were also included based on historical events).
41 Note that this number is based upon allocated budgets.
Substation circuit breaker
Avista substation upgrade work.
Table 12. Operations & Response Program Status
Note: This program did not begin until 2021.

41

complete replacement of equipment while others may only need upgrades. All substation sites have
different requirements; thus, it is not prudent to assume that each site will cost the same to upgrade.

Wildfire Emergency Operating Procedure (EOP)
The Emergency Operating Plan (or EOP) is an incident
command structure that defines workflow processes and
unified command configurations deployed during emergency
events. It includes defining key roles and responsibilities,
identifying communications channels, and operating
procedures to be used during emergency events such as storms
or wildfire. In accordance with the Wildfire Resiliency Plan, a
specific EOP and associated procedures were developed for
wildfire situations. hese events differ from “traditional” weather events such as high winds and ice
storms in that those situations are caused by situations outside of the Company’s control. A wildfire
event may, on the other hand, be a result of Company operations, so has an additional level of focus
and action.

In 2023 we finalized Emergency Operating Procedures specific to wildfire response and set up a
tabletop exercise to test the design against a simulated fire situation. We invited emergency and land
management agencies across our service territory including the Red Cross, the Idaho Department of
Lands, and the Washington Department of Natural Resources to be observers in this wildfire exercise
scenario. Avista’s incident management teams went through this situation as if it were occurring. They
developed strategies including customer outreach, crew
placement, damage assessment, mutual assistance requests,
and planned restoration efforts from the beginning of the
scenario event until final restoration and return to normal
operations. The involvement of state and local agencies
allowed the teams to practice coordination efforts. This
practice paid off shortly after the exercise when Avista crews
successfully joined the Incident Command Structure (ICS) for
the Gray Fire in Medical Lake in 2023.

Avista’s strong relationships with fire professionals, strengthened by our work with them on the Plan
and bringing them into our internal discussions and EOP processes, is also helping Avista successfully
engage with them in actual wildfire situations. This teamwork approach helps our personnel
understand what is expected of them and how they can assist and support fire command.

Cross Training with First Responders
Avista employs approximately 290 electric line operating personnel across 12 operating districts. These
employees respond to a variety of electric trouble calls including those that involve structure fires as
Avista restores power in Medical Lake in 2023
EOP exercise at Avista in 2023

42

well as wildland fires. Divisional managers are responsible
for conducting basic fire training at their monthly safety
meetings. A prominent theme in that training is direct
contact and coordination with fire authorities prior to
conducting any line inspections or attempting to re-
energize portions of electric circuits. We recognize that in
a wildfire event safety comes first, and that police and fire
authorities command the scene, but as part of the Plan,
Avista partners directly with fire protection agencies to
cross-train personnel so that Avista first responders
understand fire incident command structures, their role during an active event, and fire safety. In turn,
fire professionals are educated about the hazards associated with electric operations to help keep
them safe when working near our equipment. Though Avista crews routinely respond to pole fire
events and have basic firefighting training and equipment, they are not professional firefighters, and
we defer fully to those professionals. Cross training helps keep everyone safe.

Expedited Response Agreements
During development of the 2020 Wildfire Plan, Avista met with several fire agencies including those in
Spokane County. These discussions led to an agreement in 2022 with Spokane County whereby Avista
transmission operators notify fire officials of transmission line faults during fire season. Fire crews are
then dispatched directly to the scene to determine whether the incident resulted in fire activity. This
initial agreement, known internally as Expedited Response, was so successful that by 2023 Avista had
signed agreements that fire professionals, including the Idaho Dept. of Lands (IDL), the U .S. Forest
Service, and the Washington Dept. of Natural Resources (DNR) will respond to transmission level
outages in both
Idaho and
Washington. In
Washington, the
DNR has agreed
to manage all fire
response even
outside of their
jurisdiction.

The goal of these
agreements is to
get a rapid
response to the
site of the fault. If
the fault causes a
spark event and a fire
Figure 17. Avista’s Expedited Response Agreements started in po ane County in 0 and now cover
nearly our entire service territory.
Cross-training to keep first responders safe.

43

results, trained firefighters and apparatus are onsite and able to engage the fire quickly. A quick
response is key to keeping fires smaller. Nearly 100% of our service territory is
covered by these agreements, which have no expiration date and no cost
associated with the responses. In 2023 we used our expedited response
agreements 4 times in Washington State and 2 times in Idaho. To date, there have
been no fires found while using these expedited response agreements , but the
increased level of safety and peace of mind these partnerships provide is
invaluable.

Wildfire Partnerships
As evidenced in the discussions above, Avista has always had good relationships
with the firefighting agencies that have jurisdiction on the lands that our
facilities occupy. hese experts were helpful in formulating Avista’s initial Wildfire Resiliency Plan and
have continued to be crucial partners in this effort.

These long term partnerships have been created in part due to Avista’s willingness to quickly respond
to fires at the request of fire officials. For example, we respond to fire incidents on our distribution
facilities by opening fuses to protect firefighters, and we also de-energize transmission lines at the
request of fire commanders. Avista regularly works with fire officials in both Washington and Idaho to
share information about our operations and what we are doing to decrease accidental fire starts fro m
our facilities. During these meetings we also solicit information about agency priorities and high -risk
areas to better coordinate our fire mitigation activities. Avista is recognized as a partner with the major
fire agencies and is invited to participate with them in pre-fire season planning meetings and post-fire
season reviews as well as coordination during fire events.

Since 2022, Avista has been building relationships
and partnering with local emergency managers, first
responders, fire districts and elected officials across
our Washington and Idaho service territory in
support of Avista’s Wildfire Resiliency Plan. his
includes county and city emergency managers, local
emergency planning committees, local public health
jurisdictions, fire chiefs, critical infrastructure
providers, public safety leaders, and a variety of
elected officials, especially in our highest fire threat regions. Interactions with these key public safety
partners include attending meetings to present and discuss the Wildfire Resiliency Plan (including
PSPS), working with municipalities and agencies to identify critical infrastructure, updating the
notification process (who, how and when) for Extreme F ire Safety Mode (FSM) and PSPS, and working
with some of these partners to identify locations for Community Resource Centers (CRCs) in the event
of a PSPS. We also invite these partners to participate in tabletop exercises to continue to build
readiness, awareness, and relationships around PSPS, and to participate as guest experts in Avista’s
Avista has partnered with firefighters throughout our history.

44

series of annual Wildfire
Telephone Town Hall
meetings.

Avista is also an active
participant in the Inland
Empire Fire Chiefs
Association. We were asked
to join in their meetings to
add input on critical
infrastructure capabilities
and needs during wildfire
and other emergency
responses. This group
includes the Fire Chief of the
City of Spokane and the Chiefs of Spokane County as well as the Spokane County Department of
Emergency anagement and the Spokane County Sheriff’s Department. Along with information
sharing, this relationship has brought a heightened awareness of how fire and emergency response is
coordinated and how the utility can integrate into emergency response efforts.

Avista has also taken a lead role in information sharing and learning regarding wildfire with other
utilities in the Pacific Northwest. Starting in 2019, Avista began organizing and hosting the Pacific
Northwest Wildfire Working Group meetings. This group shares information on planning, mitigation
strategies, and logistical constraints on a regular basis. Attendees in this meeting typically include
Idaho Power, Portland General Electric, Puget Sound Energy, Northwestern Energy, PacifiCorp, and
Chelan County Public Utility District among others. These meetings have been helpful for all
participants in understanding the components of neighboring utilities wildfire plans and the challenges
in implementing them as well as discussions around best practices in the industry.

As Avista’s Wildfire Plan was being developed, we reached out to our California contemporaries,
specifically Southern Cal Edison and San Diego Gas & Electric.42 These utilities were very open in
sharing their experiences, their plans, and their strategies. They became mentors as we went through
the process of developing our own wildfire plan, and they helped guide us in creating our focus areas
and tactics, openly sharing the benefit of their more than ten years of experience (at that time) in this
area. In return, Avista has been very open in sharing our Wildfire Plan and strategies with fellow
utilities, most frequently in the Northwest. In fact, both Idaho Power and Northwestern based their
initial wildfire plans on Avista’s plan and have adopted our strategies and program philosophies as
well. Avista is considered a leader in the Northwest in this endeavor. Our Wildfire Resiliency Plan
creator and manager, David James, became recognized as a national leader in Wildfire.

42 We contacted Pacific Gas & Electric (PG&E) but due to their involvement in litigation, they were reluctant to participate or provide guidance.
ome of Avista’s Partners

45

Avista is also involved with the Western Energy Institute and other utility -based organizations to gain
learning and information-sharing related to emerging issues pertinent to utilities. The risk that wildfire
poses to utilities throughout the West is always a central topic. Along with regular attendance, Avista
has shared what we are doing in response to the wildfire threat and have gained a better
understanding of what other utilities are doing to address the same issues. This is another forum in
which we can share and learn about industry standards, best practices, methodologies, lessons
learned, and successes that we can apply to our own plan and strategies .

The benefits of these relationships are too numerous to list. Our external partners have helped design,
create, and shape our Wildfire Resiliency Plan since the beginning. They have collaborated with us in
actual fire situations, advised and guided policy and strategy, and shared ideas and best practices to
help us make the best possible choices. Synergy is a very powerful force when bringing diverse groups
of people together to address an issue that is of concern to them all.

Fire Safety Mode Operations
Electric utilities use automatic
reclosing to improve system
reliability through managing
momentary faults on overhead
conductor that may result in
extended outages and impacts to
customers. Electric faults occur
when equipment fails or when
weather and wind cause branches
or trees to fall into powerlines, for
example. Equipment failures,
vegetation contacts, wind, snow,
and lightning are significant
contributors to line faults, and
each line fault represents
interruptions to electric
service as well as the potential
for a spark to occur, as all electrical faults involve a release of energy before the fault is interrupted by
the utility’s protective equipment, which isolates the fault location and attempt s to reclose the line to
restore customer service. For circuits that pass through high fire risk areas, automatic reclosing may
not be desirable due to the increased risk of ignition from repeated arcing as the line tests to try to
reclose and restore service. In response, the Company developed a methodology for using the
distribution protection system to reduce the chance of a spark event.

Fire Safety Mode has five levels of risk as shown in Figure 18. The Fire Risk Index (FRI) is based on a
number of elements including weather (wind speed and gusts), fuels in the area (grasses, shrubs,

Fire Safety
Mode
Operations
Levels
Figure 18. Fire Safety Mode Operation Steps and Fire Risk Index Levels

46

trees), topography (fires on flat lands are easier to fight than those on steep slopes), community risk,
historic outages on the identified equipment during fire season, humidity, soil conditions, etc. The five
Fire Risk Index levels are:

1) Green (Low)—Risk of fire spread is low to near zero e.g., typical winter conditions: FRI score
of 0 – 4.0.

2) Blue (Moderate) – Risk of outage is high, while fire spread is low, or Risk of outage is low,
while fire spread is high, or Risk of outage is moderate and fire spread is moderate: FRI score of
4.1 - 5.4.

3) Yellow (High) (Extreme FSM) – Risk of outage is high, while fire spread is moderate, or Risk of
outage is moderate, while fire spread is high, or Risk of outage is high and fire spread is high:
FRI score of 5.5 - 6.4.

4) Orange (Very High) (Extreme FSM) – Risk of outage is extreme, while fire spread is high, or
Risk of outage is high, while fire spread is extreme, or Risk of outage is very high and fire spread
is very high: FRI score of 6.5 to 6.9.

5) Red (Extreme)– Risk of outage is extreme, and risk of fire spread is extreme FRI: >7.0

The FRI supports operational decision-making to reduce potential wildfire risk. Base Fire Safety Mode
protection settings are typically considered beginning at an FRI of about 3.5 and moved to extreme
settings at about 5.5. The Company will consider the possibility of initiating a PSPS when the FRI
forecast is at 7.0 or greater, or where other factors applicable to the situation warrant such
consideration. Factors
to be considered may
include, without
limitation, fire risk
potential, relative
humidity, field
observations and
measurements,
anticipated duration of
events, geographic
characteristics, critical
infrastructure, wind
direction and speeds,
medically vulnerable
populations, proximity
to aid, utility resources
available, etc. This list

ire risk
index:
0 2 .
ormal Opera ons Base ire
Safety ode
Extreme
Protec on
Se ng
PSPS
ire Danger
Ra ng
Classi ca ons
Low oderate igh ery
igh Extreme
System
Protec on
Se ngs
ormal Opera ons Base ire Safety ( S ) ode
Original ire Safety ode
Elev
ated
Ex
treme
Relia ility Ris Wildfire Ris

Relia ility Ris Wildfire Ris
Automated ire
Safety
anual ire
Safety
0 2 . .
Ex
treme ormal Opera ons
ire risk
index:
Ris
Figure 19. Fire Safety Mode Operations in 2020 Versus 2024

47

of considerations is non-exhaustive, as each weather situation is unique and involves unique
characteristics, risks, and considerations.

Avista already makes a great effort to reduce the number of faulted circuits with existing programs
such as Wood Pole Management, Vegetation Management, and adding sectionalizing devices such as
reclosers. Since the early 2000s, during fire season Avista has transitioned into the mode of limiting the
number of circuit recloses on circuits deemed potentially at risk during fire season. This operational
methodology is an important defensive strategy against wildfire ignition. Previously known as “Dry
Land ode,” this operating mode, which we now call ire Safety ode ( S ), involves both identifyi ng
electric circuits that operate in elevated fire threat areas and the reconfiguration of their associated
protection systems to allow these protection devices to be remotely and automatically adjusted for
wildfire threat based on the operating location and threat level.

Historically, this has been a manual process of turning on the system at the beginning of fire season
(typically early July) and then returning to normal operation at the end of fire season (usually early
October). Through the Company’s Wildfire program, we have added additional safety measures
including modernizing this system so that reclosers can support higher modes of protection and can be
remotely monitored and operated, and by adding Fire Safety Mode operations. FSM can significantly
reduce spark ignition potential by adjusting the sensitivity of the protection system for electric circuits
that operate in elevated fire threat areas when there are forecasted significant weather events during
wildfire season. It allows reconfiguring protection systems so protection devices can be remotely and
automatically adjusted for wildfire threat based on the operating location and the estimated risk at
that location.

Avista’s ire Safety ode has gone through three iterations since its inception in the 2000s, starting
with the initial on/off methodology. In 2020, with the implementation of Avista’s Wildfire Resiliency
Plan, the Company began moving to a modified protection setting scheme that was aligned with fire
risk, including automated operations and remote monitoring capability. This new approach had five
modes of operation: normal operations, base fire safety mode (described below), elevated mode
(removed in 2024 but which allowed a circuit to close back in for temporary faults), extreme (described
below), and de-energizing or Public Safety Power Shutoffs (officially adopted in 2024.) The diagram
above, Figure 19, depicts the 2020 Fire
Safety Mode strategy as it compares to 2024.

An additional upgrade to the Fire Safety
Mode methodology is our use of the Severe
Fire Danger Index (SFDI) developed by
the U.S. Forest Service.43 This is a

43 “Severe Fire Danger Index: A Forecastable Metric to Inform Firefighter and Community Wildfire Risk Management,” US Forest Service, Severe Fire
Danger Index: A forecastable metric to inform firefighter and community wildfire risk management | US Forest Service Research and Development
(usda.gov)
Table 13. Fire Safety Mode Operations
Note: We implemented this program in 2023.

48

forecastable metric that can help predict extreme fire conditions based on historical data related to
fire intensity and spread potential. When this data is combined with current wildfire situations it helps
predict fire intensity, the likelihood of resulting damage, and the potential for loss of life. This metric
helps firefighters and communities by providing critical information to help improve early warnings and
situational awareness. Avista overlays the SFDI information over our service territory within the Fire
Weather Dashboard, and when the resulting analytics indicate a risk level of about 3.5, we typically
enter Fire Safety Mode.

The current version of Fire Safety Mode has the levels of reclosing operations (system protection
settings) described below:

1) Normal Operations – (blue) During non-fire season, circuit breakers automatically reclose
multiple times before locking out, with a focus on reliability and maintaining customer service.

2) Base Level Fire Safety Mode – (yellow) If a circuit is set to this protection level, when it trips it
waits a predetermined length of time then recloses to test the circuit. If the circuit tests bad the
second time it will stay off until manually inspected before being placed back in service. This
level is used on specifically identified circuits during the bulk of fire season to limit automatic
reclosing of faulted circuits, reducing spark ignition energy levels and associated potential for
fire ignition.

3) Extreme Fire Safety Mode – (orange) Circuits considered in extreme danger are configured for
instantaneous tripping and non-reclosing so if the circuit trips, it does not test or try to reclose. It
stays off until it is inspected and released back into service. This level of protection operates at
significantly reduced energy levels, and once the feeder trips due to a fault condition, mitigates
the impact of future system faults due to the feeder being in an off status until conditions are
safe and the feeder is patrolled and re-energized. This level can impact customer reliability, as it
may take several hours to patrol the entire line and mitigate any issues found. Thus, this
extreme protection level will only be used for high fire risk weather conditions due to its
potential to have a significant impact on customer outage times. At this risk level, spark ignition
danger takes priority over service reliability.

4) Public Safety Power Shutoff (PSPS)/De-Energizing – (red) For extreme weather events
exceeding Extreme Fire Safety Mode conditions, the Company will selectively implement de -
energization on feeders or sections of feeders as a measure of last resort in coordination with
our partners and first responders. Note that we have implemented de-energization at the
request of first responders as a course of business throughout our history primarily to keep
firefighters safe when working near our equipment . However, with the implementation of our
PSPS Plan, when it is clear that the safety benefits exceed the costs and risks of shutting off
power to customers, the Company may selectively implement proactive de -energization of
circuits deemed at exceedingly high risk. This is likely to be based upon the Dashboard predicting
a risk level of 7 and above on the circuit as well as projected wind speed and gusts, humidity,

49

vegetation dryness levels, etc. The Company recognizes that this action can have a significant
impact on customers. When a circuit is de-energized for a PSPS event, the entire length of the
circuit must be inspected to ensure conditions are safe before reenergizing. Therefore such a
decision will be made with great care. More information on PSPS can be found below.

Note: The major difference between Fire Safety Mode (FSM) Operations and PSPS is that FSM circuits
are only removed from service when an actual fault is experienced on the line, while PSPS circuits are
proactively disconnected based on an assessment of risk.

Although many elements of Wildfire Resiliency are aimed at reducing outage events and possible fire
starts, we realize that it is impractical to expect perfect reliability,
especially during fire season wind events. By altering protection schemes
on select circuits, Avista can achieve a better balance between reliability
and fire safety objectives. This means that at times of extreme risk,
customer reliability may be sacrificed in order to focus on customer
safety. We believe that if this balance is carefully considered and
decisions are made with the sophisticated analysis and guidance
provided by the Fire Weather Dashboard, we can help make our system
safer in times of fire threat while minimizing customer impact.

Public Safety Power Shutoffs
Public Safety Power Shutoffs (PSPS) happen when electric companies preemptively turn off
the power to specific areas in order to reduce the risk of wildfires and to help keep customers and
communities safe. It is an effort to prevent electrical equipment from starting a severe, fast spreading
wildfire in high fire threat areas by turning off powerlines during extreme weather based upon a
calculation of risk, typically when high winds and other adverse weather
conditions combine to increase the risk of wildfire. It is considered a top tier
mitigation tool to help prevent utility involved wildfires in extreme fire threat
situations.

As part of its operational mitigation strategies related to Fire Safety Mode
operations, Avista developed a Public Safety Power Shutoff Plan for
proactively de-energizing facilities located in high risk areas during extreme
weather conditions that have the potential to propagate large destructive
wildfires. Our PSPS Plan, to be implemented for the first time (if needed)
during the 2024 fire season, is essentially the last step in our Fire Safety
Mode operations, though the major difference between Fire Safety Mode
Operations and PSPS is that Fire Safety circuits are only removed from
service when an actual fault is experienced on the line, while PSPS circuits
are proactively disconnected based on an assessment of risk.

Avista may initiate a PSPS if
the Company determines
that a combination of
critical conditions at certain
locations creates the
potential for consequential
risk of wildfire ignition,
spread, and severe resulting
harm, and that those risks
outweigh the corresponding
risks associated with
initiating the PSPS.

50

Many factors go into considering whether it would be prudent to initiate a PSPS and the assessment of
risk, including environmental factors such as wind speed and direction, relative humidity levels, outage
data (that is, feeder health and likelihood it might trip off), and fuel conditions (includes moisture
content, type of vegetation, topography, and tree mortality rates in the area ). Community factors are
also a major consideration, including impacted population and number of structures, firefighting
capabilities in the area, and the potential impact to customers including expected outage duration and
potential restoration timelines.44 Infrastructure elements are also considered including the type of
conductor, poles, and crossarms, the design and strength of overhead facilities, as well as vegetation
types and amounts near infrastructure.

The Company believes that the use of proactive de-energization must be carefully considered, as this
can have a significant impact on our customers in the number of outages they may experience, in the
length of those outages, and in the associated risks and costs involved . To assist customers during
these extreme events, the Company has an extensive plan to coordinate with public safety partners,
municipalities, and tribal authorities as well as providing an outage map on our website, a specialized
customer CARES team45 to assist special needs customers, proactive customer education and outreach,
and Community Resource Centers. Special consideration is also given to critical service providers who
are integral to the processes and functionality of society (such as hospitals, airports, traffic systems,
communications systems) as well as customers who are medically vulnerable (such as those dependent
upon medical equipment), proximity to aid for customers in remote locations, and other factors. Avista
recognizes that losing power can have a significant impact on our customers, thus will evaluate the use
of protection settings, including PSPS, with great sensitivity and consideration.

In 2024 Avista put together a robust notification plan for PSPS events including email, IVR (Interactive
Voice Response) callouts, press releases, web banners, outage map updates, social media, text alerts
(during outage), as well as engagement with community-based organizations and public safety
partners. Restoration timeframes are especially important to customers; estimates for outage duration
and time for customer restoration depend on the magnitude of the event and can be highly variable. In
response, communications around these estimates are updated frequently as new information
becomes available.

44 Note that in the case of a PSPS event, duration times may be extended due to the requirement to manually inspect each de-energized circuit from
beginning to end to ensure that it is safe to place it back into service. This is also the case for circuits that trip off while placed in Extreme Fire Safety
Mode.
45 CARES (Customer Assistance Referral and Evaluation Services) is a specialized team within Avista’s customer contact center that supports our most
vulnerable customers, assisting with resources such as food, housing, and medical care.

51

Prior to an event Avista will utilize multiple communication channels to reach customers and inform
them about a potential PSPS event in their area, including available customer services. This information
will also be published to our social media pages and provided to emergency management partners to
disseminate. We will also connect customers with Washington and Idaho 211 services for additional
assistance that Avista cannot provide. In addition, we have a robust partnership with access and
functional needs population support agencies who will be notified of potential PSPS events in an effort
to further support customers.

This year Avista will be standing up community resource centers (CRCs) in areas impacted by PSPS
events. We have partnered with a third party contractor to help assist with CRC setup and operation.
CRCs generally include air conditioning, electronic and medical device charging, snacks/water/ice, and
information regarding the outage. Avista is also offering a battery backup program to qualified life
support customers who have been verified through a medical provider (at no cost to the customer).
The batteries will be shipped directly to the customer’s residence. A specialized customer support
team will assist with the battery order and answer questions about the program.

Avista also updated our existing Outage Map to provide additional communications related to a PSPS
event. Customers can go to the outage map to see if they are in an area which could potentially be
experiencing a PSPS in the coming days or if they are in an area where one is occurring. Up to 7 days
out customers would be able to see if they are in a PSPS Watch, at approximately 2 days they would be
able to see if they are in a PSPS Warning and they would be able to see if their outage is related to a
PSPS event as well.

All of our Operations and Response programs are designed to protect our customers by reducing the
chance for spark events, rapidly reacting to increasing wildfire threat, and working with customers and
external partners to prepare for and react to wildfire. As described earlier, expenditures in this area
primarily related to the cost of automating equipment to enable remote control and operation.
Table 14. Operations & Response Actual and Budget Expenditures

52

Community Outreach
A key element of the Company’s Wildfire Resiliency Plan is
ensuring that all interested persons know that the plan is
in place and that the Company is taking the right
precautionary steps to reduce the potential for and impact
of a wildfire. A strong and effective strategic
communications campaign is critical in ensuring broad
awareness and in demonstrating Avista’s commitment to
reducing the impact of wildfires.

Avista’s Wildfire communications plans are directed at all
of Avista’s key participants including customers,
employees, state and local government officials and
regulators, law enforcement, fire departments, emergency
management agencies, local media, and shareholders. Our
wildfire communications goals are to create awareness of
Avista’s work to prevent or mitigate the risk of wildfires,
promote the safety and well-being of all customers, to
engage customers in programs that impact them and their
communities, and to help our customers and employees
stay safe.

he Company’s overarching Wildfire Resiliency
Communication Plan objectives include:

• Build awareness among all key participants of the significant actions and investments Avista is
making to prevent or mitigate the risk of wildfires.

• Instill confidence in Avista as a proactive and responsible corporate
citizen.

• Demonstrate Avista’s focus on prioritizing the safety and well -being
of its customers and the communities it serves.

• Provide examples of the Wildfire Resiliency Plan in action and show
progress as it is implemented.

• Engage customers in programs that impact them and their
communities.

We have a variety of ways we communicate with customers about
wildfire-related work on the system that may impact their service. We
Avista
Communications
•Avista Connections
Newsletters
•Customer Emails
•Fire Safety Mode
Specific Outreach
•Telephone Town Halls
•Print Ads
•Avista Website
•Community Meetings

53

utilize newsletters, customer emails, phone calls, social media, Avista’s website, and local media
outlets. When projects directly impact customers, they are directly notified of work happening in their
area and its purpose.

One of our most effective means of reaching customers specifically related to wildfire and our Fire
Safety Mode operations (including PSPS) are Avista’s annual Telephone Town Hall Meetings. Avista
uses this platform to communicate broadly with all electric customers, including especially vulnerable
customers, about overall wildfire risk and preparations for fire season. We request that customers
ensure that their contact information is up to date so we can reach them. In addition to providing
information and answering customer questions, this platform also yields helpful information about
how our customers are preparing and what is most concerning to them. We also share updates on our
current and future wildfire plan progress and plans. Emergency management professionals, public
safety partners, and key community leaders from each region are invited for their associated town hall.

In 2022 we reached out to nearly 36,000 customers in 8 counties and 3 tribal governments. In 2023 our
customer engagement extended to 16 counties including outreach to over 90,000 electric residential
customers and 640 public safety partners, tribal, and key community leaders. This engagement was in
coordination with associated emergency response agencies who participated in the discussions. Each
year we learn more from these meetings about how to improve communications with customers. For
example, Telephone Town Hall Meetings are now offered in both English and Spanish. Also, in 2024 we
started our communications earlier to create the opportunity to reach more impacted people including
city councils and county commissions, key stakeholder interest groups, medically vulnerable
customers, medical service providers, as well as including more media and language options. These
platforms are an excellent way to gather feedback and input used to continually improve our outreach.

The Company also sends mailed
and emailed newsletters in
advance of fire season to
educate all electric customers
about Avista’s Wildfire
Resiliency Plan and inviting
participation in our Town Hall
events. Wildfire related updates
are provided throughout fire
season. We also run a series of
print ads in more rural
communities related to the
Wildfire Plan and PSPS. More
than 130 ads run in 33 different publications, including several in Spanish, reach ing a circulation of
about 250,000. We also host community meetings with emergency management organizations led by
our regional business manager team. This team also works with account executives to identify and

54

engage with critical infrastructure in their areas (such as water, wastewater/sewer, healthcare
facilities, emergency responders) for education and support. In all of these platforms we ask customers
to make sure their contact information is up to date with Avista so we can reach them as needed about
changes to operations in their area.

Specialized Outreach
• CARES Network. In 2022 we began an effort to better support our medically vulnerable customers.
We developed an outreach framework for proactively notifying life support customers on elevated
Fire Safety Mode (FSM) feeders. The process is very similar to what we do for planned outage
notifications, utilizing Avista’s CARES outreach teams. he CARES (Customer Assistance Referral
and Evaluation Services) eam is a specialized team within Avista’s customer contact center that
supports our most vulnerable customers by helping them with their Avista account and acting as a
liaison between the customer and community partner support networks. They are specially
trained to help people who need assistance with their energy bills or other resources such as food,
housing, and medical care. Customers with medical equipment in the home are also handled with
special consideration by this team. This team works to specifically identify and reach out to our
most vulnerable customers related to wildfire preparation and notification. 2022 was spent
primarily in designing and preparing this outreach, which was then used in 2023 with great
success. One of the things they accomplished was adding a life support customer flag to all the
feeder lists, making it possible for Avista to quickly ident ify special needs customers who may be
impacted by an event and proactively call them to make sure they are aware of potential outages
in their area due to the weather along with potential wildfire threat and available support.

• Community Response Ambassadors. In 2023 Avista launched an employee team of volunteer
Community Response Ambassadors who train with the Red Cross to provide help and support to
our most vulnerable customers during outage events.

• Beyond English Communication. We have identified that five percent of Avista customers speak a
primary language other than English and of those, 95 percent speak Spanish as their primary
language. Avista developed a variety of materials in Spanish which are distributed through our
outreach channels and community events. We launched a Spanish version of our website in April
of 2024. We include a Spanish option for all of our telephone townhalls. Our ad campaign was
created in Spanish and is running in Spanish publications across our service territory. Avista’s
website and outage map are now available in English and Spanish. All wildfire -related print
materials are also available in English and Spanish. In 2024 Avista hosted a booth at the Latinos en
Spokane’s El ercadito event to share various programs with the Latino population in Spokane,
including wildfire and PSPS. We are also working on including additional language options. This
year for the Telephone Town Hall Events we provided either Russian or Spanish for the 6 events.
There were 79 customers that identified as Russian, and for Spanish, 1,192 customers, providing a
total of 1,271 non-English speaking customers. We also have a language line option for customer
service so that customers can talk to someone in their own language.

55

• Other Specialized Communication. Another
specialized focus is for those with hearing
impairment. Avista’s notification process for active
events involves email, social media posts, web
banners, text, and phone callouts. Our videos are
also subtitled. We are working with the
Washington State Dept. of Social and Health
Services (DSHS) and the Office of Deaf and Hard of
Hearing to further our outreach to this audience,
including how to best translate our messages into
American Sign Language. Avista presented its
Wildfire Resiliency Plan to approximately 80
staff from DSHS and then collected feedback
and answered questions specifically related to
customer support around potential outage or
PSPS events. Avista is remaining in contact
with DSHS to continue to refine and improve
our communications in this area.

• Critical Infrastructure Customer Identification. The
Company completed identification of critical commercial/industrial
customers for notification during elevated Fire Safety Mode protection settings or in the event of
a PSPS. These are customers who provide critical support services to society such as police and fire
stations, large airports, traffic control, communication towers, etc. Recognizing who these
customers are, the critical services they provide, and where they are located makes it possible to
do as much as possible to protect their energy supply and/or restore their service as quickly as
possible for public safety.

• Tribal Outreach. Discussion topics in our community outreach efforts with the tribes include
concern for tribal elders and medically vulnerable tribal members. The tribes are partnering with
Avista to further identify these vulnerable populations (some tribes already have partial lists) and
see what can be done to help and support them in the case of an extended power outage.

• PSPS Outreach. In 2024 the Company reached out to over 14,000
first responders, emergency managers, critical customer groups,
service providers, health organizations, city and county leaders,
state agencies, and others to provide education around our PSPS
Plan and to strategize about protecting and supporting customers
through potential outages.46

46 More details about the 2024 PSPS Outreach can be found in Appendix A.

Avista
outreach
materials
in Russian
Agency Partners 94
City/County 418
Emergency Management 201
First Responders 60
Medical 117
Service Provider 20
Town Hall 13,262
TOTAL 14,172
2024 PSPS Meeting Participation

56

• Equity Advisory Group. Avista is also working closely with its Equity Advisory Group to fully
develop and identify ighly Impacted Communities and ulnerable Populations (“ amed
Communities”) unique to the Company’s service territory. he identification of customer barriers,
development of workable solutions, and implementation of an effective multilingual
communication strategy is an ongoing process, but one that Avista believes to be integral to the
success of the Wildfire Plan as well as FSM and/or PSPS planning and implementation. Avista is
steadfast in ensuring that all customers have access to programs and utility-related information.
These efforts will be reflected in our wildfire outreach efforts going forward, especially in the
areas of public safety and notification, but also in relation to providing information about our
Wildfire Plan and its associated programs.

• Named Communities/Medically Vulnerable. Avista attends community events throughout our
service territory with a particular focus on Named Communities. Many of these communities are
rural or represent limited-income populations. In addition to information on bill assistance
options, we also distribute materials on wildfire resiliency and PSPS. We begin communicating
with customers in February with a bill insert, in both English and Spanish, asking customers with
medical needs to contact us so we can reach out to them to ensure that we are reaching all
customers with medical needs when there are risk events. This goes beyond our life support
customers to include all customers with medical equipment that requires electricity. We ask
customers to report themselves or family members if they need specialized assistance. In
conjunction with this effort, Avista developed a Community Response for Vulnerable Populations
During Outages (CRVP) Stakeholder Group which includes nearly 40 representatives from
organizations and agencies that serve vulnerable populations, as well as municipal departments
and emergency managers. The vulnerable populations represented by the membership in this
group include refugees and immigrants, seniors and aging populations, folks with disab ilities,
limited-income communities, and those with high health risks. In 2024 Avista invited the CRVP
group to attend a 2-hour workshop at our headquarters focused solely on wildfire at which we
shared Avista’s Wildfire Resiliency Plan, provided handouts on the Public Safety Power Shutoff,
and gathered information/feedback on how best to reach our vulnerable communities with this
information. Avista also offers a battery
backup program to qualified Life Support
customers.

Equity
The Washington State Legislature enacted
clean energy transformation standards
legislation that applies to all electric utilities,47
and as part of this regulation, utilities must file
a Clean Energy Implementation Plan (CEIP)

47 Clean Energy Transformation Act - Washington State Department of Commerce

57

every four years. As part of the CEIP,
Avista must ensure equity (fair
treatment) for all customers, especially
vulnerable customers, which are
designated as “Named Communities”
which are defined as one or a
combination of the following
populations:

• ighly Impacted Community means
a community designated as such by
the Washington Department of
Health based on being within the
limits of an Indian reservation
and/or suffering environmental
health disparities such as pollution,
hazardous waste, poverty, or
cardiovascular disease.48

• ulnerable Populations mean
communities that experience a
disproportionate cumulative risk
from environmental burdens due
to adverse socioeconomic factors,
including high unemployment, high
housing and transportation costs
relative to income, limited access
to food and health care, and linguistic
isolation, as well as sensitivity factors
such as low birth weight and higher rates of hospitalization.49

In Avista’s Washington service territory, 34% of the areas Avista serves have populations designated as
Highly Impacted Communities or Vulnerable Populations as defined by the Washington State
Department of Health. ore than % of Avista’s high fire threat districts coincide with 20 0 census
tracts that are “overburdened and underserved” according to the Council on Environmental Quality’s
(CEQ) Climate and Economic Justice Screening Tool.50 This includes tribal areas served by Avista.

48 Washington State Department of Health, “Instructions for Utilities to Identify Highly Impacted Communities,” Instructions for Utilities to Identify Highly
Impacted Communities | Washington State Department of Health
49 Ibid.
50 Climate and Economic Justice Screening Tool, Explore the map - Climate & Economic Justice Screening Tool (geoplatform.gov)
Figure 20. Vulnerable Population Areas in Avista’s Washington ervice
Territory

58

In Washington State,
1,044 of 1,708 miles
of powerlines
located in high fire
risk zones are
located in
underserved and
financially
overburdened
communities.
Avista utilized
information from
the Washington
State Health
Disparities Map to
identify these
populations.51 In
Idaho, 794 of 1,037
miles of distribution line miles are
located in underserved areas and high fire risk zones.52 Avista’s WUI map indicates that 1,838
powerline miles are located in underserved communities out of the total mileage of 2,746 (67%) across
our service territory.

Those most at risk from wildfires are typically also the most disadvantaged and economically
challenged communities. These communities are often located in rural areas where electric service is
threatened by terrain, weather, and human factors. By focusing on areas of highest risk, the bulk of the
resources allocated to the Wildfire Plan will flow to these disadvantaged communities. Thus, by
definition, Avista’s most capital intensive program, electric distribution grid hardening, will have a
positive impact on these communities. This work will not only reduce fire risk in some of our most
vulnerable communities, but also significantly improve reliability for these customers.

51 Washington State Dept. of Health “Washington Environmental Health Disparities Map,” Washington Environmental Health Disparities Map | Washington
State Department of Health
52 Idaho overburdened and underserved areas can be found on the Climate and Economic Justice Screening Tool: Explore the map - Climate & Economic
Justice Screening Tool (geoplatform.gov)
Figure 21. Washington State Disparities Map

59

2023 Fire Season Recap
In our area, spring water supply conditions for 2023 were
much better than normal with higher than average
precipitation over the prior winter and spring. As a result, no
part of Washington or Northern Idaho experienced extreme
drought conditions. However, above-normal temperatures in
July through September created an opportunity for expansion
of drought areas primarily in western Washington. Conditions
in eastern Washington and northern Idaho remained stable.53
Even so, there were about 200 more fires in Washington
compared to 2022, though the number of acres burned was
down by 15% due to well coordinated response from the
Washington Dept. of Natural Resources and their strategic
placement of firefighters and equipment across the state. Commissioner of Public Lands Hilary Franz
stated, "Statewide, we saw the second-most ignitions in Washington’s history this year [2023],
including the tragedies that were the Gray and Oregon fires. But we kept 95 percent of DNR protection
fires under 10 acres and remained well below the 10-year average for acres burned – a testament to
the investments we have made in resources like additional aircraft, more firefighters, better training,
and the great work done by firefighters and interagency partners."54

According to the Washington State Department of Natural Resources, 1,884 fires were counted in
Washington in 202 with , acres burned. Of those fires, were considered “large” (over 00
acres of forest land or 300 acres of grassland). The state further estimates that over 400 homes were
destroyed in these fires.55 The number of fires was about 200% of normal with the acres burned at
about 88% of normal. Besides fires of unknown cause, 57% of the fires in Washington were caused by
human activity.56

In Idaho, the number of fires compared to 2022 dropped by nearly 200 . The Idaho Dept. of Lands
reported 284 wildfires on public lands in Idaho in 2023, in which all but 78 were human caused.57 The
National Interagency Fire Center reported a total of 892 wildfires across the state, but t he number of
acres burned was at a twelve year low at only 87,801 acres, almost half of what burned in 2022.58

53 Idaho | Drought.gov and Washington | Drought.gov.
54 DNR, “Commissioner Franz, DNR Leaders Recap Wildfire Season, Celebrate Partnerships,” October 25, 2023, Commissioner Franz, DNR Leaders
Recap Wildfire Season, Celebrate Partnerships | WA - DNR
55 Lauren Gallup, “Washington state endures ‘catastrophic’ 2023 wildfire season with high ignitions, property loss,” OPB, October 18, 2023, Washington
state endures ‘catastrophic’ 2023 wildfire season with high ignitions, property loss - OPB
56 Washington Dept. of Natural Resources DNR Wildfire Intel Dashboard, Wildfire Intel Dashboard (arcgis.com)
57 Idaho Reports, “State Reports 284 Wildfires This Season, Most Human-Caused,” October 17, 2023, State reports 284 wildfires this season, most
human-caused - Idaho Reports (idahoptv.org)
58 National Interagency Fire Center, “Wildland Fire Summary and Statistics Annual Report 2023,” National Interagency Coordination Center Wildland Fire
Summary and Statistics Annual Report 2022 (nifc.gov)
Northwest
drought
conditions in mid-
summer 2023

60

Impacts to Infrastructure
In 2023 Avista lost 266 structures (transmission
and distribution) to wildfire.

On July 8, 2023, approximately one acre was
burned near Avista’s oxon-Pine Creek 230 kV
transmission line near Kingston, Idaho. The
suspected cause of the fire is a broken bond
wire, which came loose and made contact with
a wood crossarm.

On July 17, 2023, about 250 acres burned in
Ritzville, Washington. The suspected cause of
the fire is a combine in a wheat field. This fire
destroyed nine Avista distribution poles as well
as two buildings.

On July 2 , 202 , close to Avista’s Plummer,
Idaho substation, it is suspected that a broken
crossarm on a transmission structure on the
Benewah-Pine Creek 115 kV line caused a small
fire. This fire was approximately 20 feet in
diameter and was quickly extinguished by the local fire department. This fire burned some brush but
no structures.

On August 3,
2023, a
wildfire
burned
through the
right-of-way
under the
Shawnee-
Sunset 115 kV
line near our
Spangle, Washington substation, destroying one of our
transmission H-frame structures. This fire grew to about an acre
in size before it was extinguished. No public structures were damaged. Cause is unknown .

61

On August 18, 2023, the Gray Fire burned
through the communities of Medical Lake and
Four Lakes, Washington. This fire started in
the early afternoon in a rural area and spread
rapidly due to hot, dry conditions and
sustained southwesterly winds that gusted to
35 mph. This fire destroyed 259 homes and
structures, prompted the mass evacuation of
residents, and was linked to the death of a
local man. It was not contained until
September 1, 2023. Over 1,700 electric and
295 Avista natural gas customers
were impacted, and Avista lost
255 distribution poles.
Investigators have attributed this
fire to sparks from a security
light (not owned or operated by
Avista) that ignited brush
nearby. Avista had 13 crews
helping with service restoration work, with crews from Spokane,
Coeur d’Alene, Colville, Pullman, and Davenport. Electric service
was restored within three days for the people returning to their
homes, and gas service was restored in 4-5 days.

he other large fire in Avista’s service territory in 202 was the
Oregon Road Fire, in Elk, Washington, (north of Spokane) which also started on August 18 and tripled
in size in one day, growing to nearly 11,000 acres. One hundred
twenty six houses and 258 outbuildings were destroyed by this fire.
One person was killed. It took almost three weeks to completely
contain this fire. Fire officials have stated that the fire was “human-
caused, spontaneous combustion” but have not been more specific.
Avista did not suffer any damage from this fire and has no facilities
located in the fire’s boundary.

On August 29, 2023, the last fire of the season impacting our
infrastructure occurred near Orofino, Idaho. A 30 mph wind drove
the fire across 53 acres, destroying six homes and multiple
outbuildings. Avista lost one transmission H-frame structure in this
fire. The cause of this fire is under investigation.
Images from the Gray Fire in Medical Lake
•10,085 Acres
•Caused by faulty outdoor
light.
•259 homes & buildings lost.
•1 fatality
•

62

2024 Fire Season Outlook
Long term in the
Northwest, the
number, size, and
severity of wildfires
has increased in
recent years,
primarily associated
with increased
temperature and
drought, hotter and
drier summers (and the associated drier soils
and vegetation), earlier spring melting leading
to decreased summer water availability, and
reduced snowpack. These climate changes
lead to additional risk factors such as invasive
grasses that provide fuel. Other influences include land use, prior fire suppression practices that led to
increased forest density and fuel levels, invasive species that have damaged the health of trees, and
the largest factor, human activity, which accounts for 70-90% of wildfires in the Northwest.59

As far as the outlook for 2024, scientists are predicting a shift to La Niña for 2024, which can bring dry,
hot summer conditions and perhaps a later start to typical fall precipitation, which could mean a
stronger and longer wildfire season.60 Drought.gov predicted stronger areas of drought in Northern
Idaho, especially along the Montana border, primarily due to concerns about low snow amounts and
possible early snowmelt. They note that warm and dry drought conditions are persisting across both
Idaho and Washington with near record low snow water equivalent measurements.61 The National
Weather Service agrees that drought conditions through much of the Northwest will persist. They
report that snowpack was below normal across the Northwest, ranging from 56% to 77% of normal,
and they also predicted a warm dry summer.62 In response, the Washington Dept. of Ecology issued a
drought emergency for much of Washington state on April 16 (exceptions for Seattle, Tacoma, and
Everett). A drought emergency is declared when there is less than 75% of normal water supply and the
risk of “undue hardship.” They state that there is just not enough water contained in the mountain
snow and in area reservoirs to prevent serious impacts on water users and the environment.63

59 USDA Climate Hub, “Climate Change and Wildfire in Idaho, Oregon, and Washington,” Climate Change and Wildfire in Idaho, Oregon, and Washington
| USDA Climate Hubs
60 Kelly Kizer Whitt, “U.S. Wildfire Season Outlook Suggests a Slow Start,” EarthSky, April 19, 2024, U.S. wildfire season outlook suggests a slow start
(earthsky.org)
61 NOAA Drought.gov “Snow Drought Current Conditions and Impacts in the West,” Snow Drought Current Conditions and Impacts in the West | April 3,
2024 | Drought.gov
62 National Weather Service National Oceanic and Atmospheric Administration, WA Drought page (weather.gov)
63 “Statewide Drought Declared Due to Low Snowpack and Dry Forecast,” Dept. of Ecology News Release, April 19, 2024, Apr. 16 - Drought Declaration -
Washington State Department of Ecology
Drought maps courtesy of Drought.gov. Current as of August 2024

63

Challenges & Lessons Learned
Scaling the Vegetation Program to 100%
Scaling the vegetation management risk tree program to complete 100% risk inspection annually
continues to be a much bigger and more expensive proposition than originally anticipated. As
mentioned earlier, Avista expanded its risk/hazard tree program from a program concurrent with cycle
trimming (about 20% of the system annually) to include a 100% risk tree inspection and remediation
program upon implementation of the Wildfire Resiliency Plan. Vegetation planners had preliminary
forecasts of the volume of dead, dying, and diseased trees that could potentially strike powerlines
prior to 2022. However, in 2022 and 2023 we found that the actual number of risk trees was nearly
double earlier estimates. Forest health has been made more dire by the historic drought of 2021 but
also reflects increased levels of insect activity combined with human activity, all leading to higher levels
of tree mortality than expected. Avista removed nearly 19,000 dead, dying, or diseased trees w ithin
strike distance of our facilities in 2022 and 22,573 trees in 2023. (Note that this value does not include
the over 5,000 trees removed as a result of the Gray Fire.) These are a record levels of tree removals
for Avista that we see continuing into the future.

Vegetation Contractor Cost and Availability
This is another area that continues to challenge. In
addition to finding more risk trees than anticipated,
tree-related labor resources have been an issue.
Utilities across the western U.S. are all competing for
the same labor resources, leading to large increases
in vegetation contract crew costs as shown in the
graphic on the right. AiDash, who commissioned this
study of utilities across the U.S., notes that 62% of
the utility vegetation contractors increased their
costs – sometimes substantially – in 2023.64

Avista’s primary vegetation inspection contractor has been repeatedly unable to recruit and retain
enough inspectors to complete the work. Given the level of competition for resources, contractors – if
we are able to secure them - are able to command 60-hour work weeks, lodging, and per diem
allowances, unexpectedly increasing costs for this critical program. As an example of the issues around
acquiring an adequate level of crews, the Gray Fire led to Avista contract crews removing over 5,000
risk trees related to this fire over the short span of four weeks. They removed trees that had been
damaged by the blaze and were at risk of falling during future weather events. This single event led to
approximately 37 crew weeks lost to this extensive risk tree response, creating complications in getting
planned vegetation work back on schedule. As mentioned previously, impacts from forest health
(drought, insects, disease, weather, and fire) continue to create spikes in risk trees on the system , and

64 Source of graphic: “2023 State of Vegetation Management, Survey Findings,” AiDash, 2023, SOVM-2023-Survey-eBook-Final.pdf (aidash.com)
Figure 22. Costs of Vegetation Management Contractors
Across the U.S. from 2022 to 2023

64

this necessitates the addition of labor accordingly, which will likely continue to elevate costs into the
future.

Customer Access for Vegetation Work
Another issue that is cropping up is permitting and acquiring customer permission to access trees for
removal. The Vegetation Team is developing strategies to deal with these barriers, focusing on the fact
that it is in everyone’s best interests to remove danger trees for public safety, protection of customer
reliability, and prevention of wildfires, but these types of issues create unanticipated delays and can
also increase costs. We have experienced times when it has taken several years to secure permission to
remove risk trees. The Vegetation team is continually working on strategies to mitigate this issue.

Digital Data Provider Issues
In 2023 we completed 6,466 miles of
satellite inspections on the
distribution system. However, the
transmission LiDAR inspections did
not meet the target of 2,086 miles.
We were only able to capture 1,679
miles within budget. Our original
vendor’s delivery and billing was so
late that some of the work they
performed for us in 2022 was not
billed until 2023, throwing off our
2023 inspection budget and causing
us to not meet our objectives. In
response, we switched to a new
vendor for 2024 and are expecting
that this change will provide us with
more reliability.

Learning and Incorporating Digital
Inspection Data
As mentioned earlier, Avista is also
beginning to incorporate remotely
sensed LiDAR and satellite imagery
data into the vegetation management
programs. These are new technologies to the Company and will need more experience and refinement
before they truly begin replacing boots-on-the-ground labor resources. However, after our initial
experience in 100% inspection and subsequent mitigation, this should become more of a known
quantity, making it easier to right size the labor required to complete this work on an annual basis.
Sample of an Avista Digital Data Report

65

Continuous Improvement
Avista’s Wildfire Resiliency Plan is built upon the concept of Plan-Do-
Check-Adjust. We are continually evaluating the efficacy of our programs
and adjusting them as we see opportunities for improvement. We have
made some significant improvements since the Plan began. Some of
these improvements are summarized below.

Communications
As described previously, we have significantly increased, expanded, and enhanced our wildfire-related
customer communications over the years of our Plan implementation, specifically with customer
engagement activities such as the town hall meetings and through additional communication materials
and strategies (including expanding beyond English-alone materials). We are now conducting direct
outreach in all 16 counties within our service territory, including outreach to hundreds of community
leaders, emergency management professionals, and first responders. We continue to search for
meaningful ways to engage with customers across our service territory to improve their safety. As an
example, having a survey done of the languages spoken across the service territory in order to provide
materials they can read and understand. We are reaching out to more interested parties as we identify
them, including city and town councils,
county commissioners, tribal leaders, and
medical service providers for example, as
well as employing more media outreach.
Each year of engagement with our
customers and partners through all of our
various channels provides additional
insights into who our stakeholders are and
their needs and interests so we can more
effectively reach them. As mentioned
previously, we have significantly expanded
our outreach, including non-English and for
those who are hearing impaired.

Outreach to Vulnerable Customers
We have developed an additional focus on
identifying and reaching our most
vulnerable customers, including the ability
to quickly identify and contact critical and
life support customers to warn them of the
potential for elevated protection settings
or a Public Safety Power Shutoff. In 2023
we added a life support customer flag to all the Avista’s Wildfire Website for Customers

66

feeder lists, making it possible for Avista to quickly identify these special needs customers and
proactively call them to make sure they are aware of potential outages due to the weather as well as
potential wildfire threat and options for support. Also, in 2023 Avista launched an employee team of
volunteer Community Response Ambassadors who trained with the Red Cross to provide help and
support to our most vulnerable customers, especially during outage events. This year Avista also
developed a Community Response for Vulnerable Populations During Outages (CRVP) Stakeholder
Group which includes nearly 40 representatives from organizations and agencies that serve vulnerable
populations (as well as municipal departments and emergency managers) to inform them of our
Wildfire and PSPS plans and strategies and to gather information/feedback on how best to reach our
vulnerable customers with this information. We are also in the process of providing some medical
equipment-dependent customers with battery backup power systems to protect them in case of
outages, specifically in relation to Public Safety Power Shutoffs, which can entail extended outage
duration. In all of our outreach efforts we encourage customers to update their contact information
with Avista (and medical status if applicable) to ensure that we can reach them.

Identifying Critical Service Providers
As mentioned above, the Company has made a significant effort to identify and work with customers
who provide services critical to societal well-being including hospitals, specialty care centers, dispatch
centers, police and fire departments, communications providers, water systems, and more to help
prioritize re-energizing their service.
Some of these entities are key to
responding to and mitigating outages,
for example communications required
to work with Avista crews in the field
performing the work, the power
required to open the bay doors at a
fire station, or energy needed to
operate water pumps to fight fires.
Knowing the location and needs of
these providers will reduce the
impacts of an outage event and
increase levels of public safety.

WUI Map Refinement
Over the past two years we have significantly improved the inputs to our WUI map to define risk areas
more clearly and to specifically include structural and human impact. This includes incorporating data
from the USDA with the Housing Unit Impact (Wildfire Risk to Communities) dataset that integrates
wildfire likelihood and intensity with generalized consequences to homes . This data includes the
exposure of each home based on adjacent vegetation, the probability of a wildfire burning at a specific
location, and the potential consequences of a wildfire at a given location. This very detailed data helps
Avista identify very specific risk areas related to our customers and their location within the service

67

territory. We have also incorporated and updated the USDA Wildfire Hazard Potential map that
quantifies the relative potential for wildfire that could be difficult to control . This data helps prioritize
where fuel treatments might be beneficial.65 hese datasets are updated in Avista’s WUI map as new
information becomes available. The information is free and publicly available.

We are also working with other utilities to create a fire risk map for all western states, perhaps
incorporating the static fire risk data as a layer in Esri’s Living Atlas of the World. Avista is the leader in
this effort, which may enable all of the participating utilities to better define and mitigate wildfire risk.

Fire Weather Dashboard Upgrades
Fires ignitions from all sources including natural, human-
caused, and utility-caused fires seem to randomly occur
within Avista’s service territory. his appears to be confirmed
by the Washington Dept. of Natural Resources list of fire
causes in Washington State in 2023, as shown in pie chart.
However, fires of severe consequence and size have regularly
occurred in areas that Avista has modeled as being at high
risk, indicating the accuracy of our Dashboard. For example,
both of the large fires of consequence in 202 within Avista’s
service territory, in Medical Lake and Elk, Washington,
occurred in areas that Avista’s ire Weather Dashboard
modeled as high risk at the time of the fires, and the Dashboard
also predicted fires of 10,000 acres, which is what occurred. These trends indicate that focusing
mitigations in areas we have identified as high fire risk areas should be effective in decreasing utility -
related fires of severe consequence. By directing ou r actions in high-risk areas, we are more efficiently
dealing with causal factors that could result in severe impacts to our customers and communities.

We are still working on a comprehensive comparison of actual fire events, but preliminary findings
suggest good correlation between the dynamic forecasted risk and the actual events that took place.
We have done some initial work to assess the risk forecast versus the outcomes of certain events and
see strong correlation with the areas where we acted based on our forecasted risk modeling and actual
large impact fires. The data we are seeing is well within the normal forecast error for estimating the
average worst case fire sizes. The two large fires in 2023 mentioned above were started miles from any
Avista facility but were helpful data points in ensuring that where we acted (initiated Fire Safety Mode
operation) and actual fire size show good correlation with actual outcomes.

Avista continues to enhance its fire risk models as we gain experience and incorporate feedback from
peers including fire agencies and weather forecasting professionals. We have added additional

65 These datasets are available as raster GIS data, tabular summaries by state, county, and community, or in a white paper. Located here: Download -
Wildfire Risk to Communities
Figure 23. Washington Dept. of Natural
Resources Fire Causes 2023

68

modeling inputs, capability, and refinement to our Fire Weather Dashboard to advance our ability to
forecast and identify risk. This is an ongoing process as we learn from each fire season through analysis
of actual events and back-casting.

Wildfire Emergency Operating Procedures
In 2022 we developed a robust Emergency Operating Procedure related to Wildfire response as
described previously. In 2023 and 2024 we tested it in realistic tabletop exercises that included
external partners such as the Red Cross, Washington Dept. of Natural Resources, and Idaho Dept. of
Lands. We plan to host exercises with external partners and internal stakeholders each year prior to
fire season to hone skillsets, develop comfort with each others practices and “language,” as well as
develop and refine strategies for customer outreach, crew placement, damage assessment, mutual
assistance requests, and planned restoration efforts. This work will evolve and improve with
experience. For example, shortly after the 2023 practice exercise, Avista was invited to participate with
the Gray Fire Incident Command, ensuring that fire and utility crews worked safely together in the
field. During this event Avista de-energized specific powerlines where firefighters were working and
Fire Command permitted Avista work crews to come into the area when it was safe to ensure that
customers had power and gas service when they returned home after the fire.

Fire Safety Mode Operations
In 2024 we further refined and enhanced Fire Safety Mode operations to provide a comprehensive
scale of risk reduction based upon actual conditions. We are utilizing actual experience, such as the
2022 and 2023 fire seasons, to refine and improve these efforts. After experiencing use of Fire Safety
Mode (FSM) over the past couple of fire seasons, in 2024 we chose to modify the trigger levels for
modifying protection settings. Previously we had five FSM settings:

1. Normal Operations (at trigger points 0 to 3)
2. Base Fire Safety Mode
(basically putting the
circuits “on alert”
during fire season with
trigger points set a 3 to
6.4)
3. Elevated FSM (with
trigger points between
6.5 and 6.9)
4. Extreme FSM (trigger
points 7 to 7.5)
5. Potential De-
energization/Public
Safety Power Shutoff
(above 7.5)

ire risk
index:
0 2 .
ormal Opera ons ire Safety
ode
Extreme
Protec on
Se ng
PSPS
ire Danger
Ra ng
Classi ca ons
Low oderate igh ery
igh Extreme
System
Protec on
Se ngs
ormal Opera ons Base ire Safety ( S ) ode
Original ire Safety ode
Elev
ated
Ex
treme
Relia ility Ris Wildfire Ris
Poten al
PSPS
Poten al
PSPS
Relia ility Ris Wildfire Ris
Automated ire
Safety
anual ire
Safety
0 2 . .
Ex
treme ormal Opera ons
ire risk
index:
Ris
Figure 24. Fire Safety Mode Comparison: 2020-2023 vs. 2024

69

With the new version of FSM, the Elevated set points have been eliminated, so trigger points are:

1. Normal Operations are typically (approximately) from 0 to 3.4
2. Base Fire Safety Mode (trigger points 3.5 to 5.4)
3. Extreme (trigger points from 5.5 to 6.9)
4. PSPS starting at 7.0

These changes (including the original FSM concept) are highlighted in Figure 24. The new strategy
utilizes trigger points reported by the Dashboard as well as expected accuracy of the weather
forecasts, potential impacts to customers, and other factors to determine fire risk levels. We have also
added the U.S. Forest Service Severe Fire Danger Index data to the Dashboard to further refine its
analytics, as mentioned above. We believe that these adjustments will enhance our ability to protect
our customers during high fire risk weather events by reducing the point at which our protection
settings will be activated. After 2024, as we experience our first wildfire season with the addition of
Public Safety Power Shutoffs in the strategy, these levels may again be adjusted based on experience.

Public Safety Power Shutoffs
We now have a full plan and strategy around Public Safety Power Shutoff events including new trigger
points (as described above), an online live outage map, customer resource center options, provision of
battery backup systems for medically vulnerable customers in high risk areas, a specialty customer
service team to reach out and support our most vulnerable customers, and additional efforts to
mitigate impacts on critical societal service providers. With our PSPS Plan, Avista will consider de-
energizing distribution circuits in order to protect our customers and employees based on a
combination of critical risk conditions at specific locations with a consequential risk of ignition and the
potential for significant fire spread and community impact. This is the first year in which we have a
PSPS plan, and as we gain experience in this area, this plan will be improved and refined.

We are learning through this evolution is that the biggest concerns of our public safety partners during
a PSPS event are access to water and concern for medically vulnerable individuals in the event of a
summertime power outage. Many municipalities and agencies (especially those in rural areas) do not
have back-up generation for critical water and wastewater treatment facilities, which is high cause for
concern and one we are working to address. We have also learned that although each individual
county has its own emergency management system, not all are as robust
as Spokane County so there is room for improvement in that area as
well.

Enhanced Grid Hardening/Undergrounding
Avista has had a strong grid hardening program in place for many years,
focused on improvements made to overhead distribution to mitigate
wildfire risk and increase reliability. These efforts reduce the risk of
outages and equipment failures that could potentially lead to wildfire Undergrounding Distribution
Conductor

70

during high fire risk periods. Avista sees the value in enhancing our grid hardening and risk reduction
efforts through undergrounding overhead facilities in select, high risk areas. Avista is working to
identify areas where large fire growth is coupled with proximity to communities which are vulnerable
to total loss in the event of a wildfire. These areas will be risk-ranked and prioritized for sectional
undergrounding of existing overhead conductor. This strategy will reduce wildfire risk and increase
safety to the communities facing the highest risk from Avista’s distribution electric facilities. It will also
allow Avista to mitigate the most risk for the least cost related to conversion to underground by
providing resources to efficiently eliminate risk at a surgical rather than a system-wide level. In 2025
we will begin a cost feasibility study on this strategy, and we anticipate that experience that will guide
this work (and the associated expenditures required) going forward.

Working Effectively with Fire Professionals
Avista has always worked to create and maintain effective
relationships with fire professionals, but through the
Wildfire Plan have greatly expanded our engagement. We
cross-train with fire professionals at the start of each fire
season to prepare for events and have participated with
them in their Incident Command Structure in actual fire
situations. Fire professionals and emergency management
personnel also participate with us in events such as our Emergency Operations exercises and telephone
town hall meetings, and in our Public Safety Power Shutoff preparations and planning. Our
engagement with these professionals, the joint understanding this promotes, and the ability to learn
and understand each side’s strategies, work processes, and terminology has been invaluable in actual
fire situations. We continue to seek out ways to engage and partner with first responders.

Expedited Response
As part of working effectively with fire professionals, Avista
engaged with first responders including the Washington Dept. of
Natural Resources and the Idaho Dept. of Lands to create Expedited
Response Agreements. Over the past couple years, we have
expanded these Expedited Response Agreements with firefighting
agencies to cover nearly 100% of our service territory. The goal of
these agreements is to get a quick response to the site of a
transmission-level fault during fire season. If the fault causes a
spark event and a fire results, trained fire fighters and apparatus
respond and are able to engage the fire quickly, which is key to
keeping fires smaller. In 2023 we used our expedited response agreements 4 times in Washington
State and 2 times in Idaho. To date, there have been no fires found in these responses. The
agreements have no expiration date, and there is no cost associated with the responses. This cost-free
program is an excellent addition to our wildfire risk reduction strategies and plays a role in reducing
fire risk – and spread – across our service territory.
Firefighters put out ground fire caused by a
pole fire.
Cross Training with Firefighters

71

Fuel Reduction Partnerships
Fuel reduction measures reduce the
fuels that allow fires to burn hotter,
faster, and with higher flame lengths
as well as eliminating ladder fuels
that allow fires to move into
treetops, where they are much
harder to control.66 A recent major
joint study undertaken by the U.S. Forest Service, The Nature
Conservancy, and the University of Montana found that this type of proactive forest management adds
significant value by changing how fires behave and reducing their severity.67 In 2022, Avista partnered
with the Washington State Dept. of Natural Resources (DNR) to assist our customers in completing
hazardous fuel reduction treatments on their property. As mentioned earlier, in 2023 the Company
expanded this effort to include engagement with the Idaho Dept. of Lands, the U.S. Forest Service, the
Nez Perce Tribe, and local and regional fire agencies across our service territory. This work reduces the
risk of fire starts and fire spreading across our service territory by supporting key partners with
financial assistance in removing fuel on their properties located near our facilities or within our service
territory.

Safe Tree Program
Our Safe Tree Program was started in Kellogg, Idaho, in 2022 and the results were overwhelmingly
favorable. As a result, we extended this program in WUI 2 and WUI 3 areas across the service territory.
It works with customers directly to remove risk trees on their property. We also added a platform to
the Company’s website allowing customers to request Safe ree work directly.68 he “Safe ree
Customer Service Portal”69 for this service is now available on the MyAvista website, allowing
customers to communicate directly with arborists and schedule this work when it is convenient for
them. The website takes customers through a series of questions to ensure that they are qualified for
this free service. They are then scheduled in the order in which their requests are received. We see a
real win-win with this program as we protect our customers from a potential hazard situation, reduce
reliability risk, and provide offsets to future vegetation management work on their trees and the
associated costs.

Strategizing with Peers
We continue to work with and learn from our utility peers and join with them to strategize and develop
best practices. We are also partnering with them in attempting to acquire federal grant funding, on

66 For more information on the benefits of fuel reduction, see a fuel reduction treatment analysis by the US Forest Service at An evaluation of the Forest
Service Hazardous Fuels Treatment Program—Are we treating enough to promote resiliency or reduce hazard? | US Forest Service Research and
Development (usda.gov)
67 “Comprehensive Science Review Shows Fuel Treatments Reduce Future Wildfire Severity,” The Nature Conservancy, June 24, 2024, Comprehensive
Science Review Shows Fuel Treatments Reduce Future (nature.org)
68 Note that only eligible customers are allowed to request this service. The portal can be found at: Safe Tree Program (myavista.com)
69 https://www.myavista.com/safety/were-doing-more-to-protect-against-wildfires or email [e-mail]
Fuel Reduction Efforts Before & After

72

regional and national wildfire interest forums, directly through sharing information, ideas, and
strategies, and in any other arena possible. For example, Avista has visited San Diego Gas & Electric and
worked with the wildfire experts there on strategies and proven methodologies. San Diego has been a
mentor for Avista since we began developing our Plan, and we are continuing this engagement, as they
are considered a utility industry leader in wildfire practices. We also join ed with our Northwest peers in
working on the Washington Legislature’s mandated wildfire plan in an attempt to ensure that it
provides comprehensive, useful information that could be applied consistently to all of us. We
regularly invite all of our connected utilities to tabletop exercises and have offered to have joint
discussions with all who would like to engage further. This sharing will continue to be a benefit.

Expanded Use of Digital Data
Digital data is both a learning
experience and a source of continuous
improvement. In acquiring digital data
on both the transmission and
distributions systems for identifying risk
trees, we are becoming familiar with the
large amount of data these tools provide
and how to use all of this information to
focus our vegetation efforts in areas that
should provide the most positive impact
and risk reduction. This data is detailed
and very comprehensive and we are
finding new uses for it all the time. For
example, the analytics provided by
LiDAR analysis allow our System Forester
to focus tree work on the transmission system where it will
provide the most value and protection, that is, where the most risk trees are present and using it to
help us differentiate between high canopy and low vegetation areas for transmission resiliency
planning (steel replacement versus fire mesh wrap as mentioned above). We are using satellite data to
help refine our WUI maps by identifying vegetation near our facilities , pinpointing areas where
vegetation-related risk is highest. There are many uses for this detailed information.

We believe that the over-time analysis provided by the LiDAR and satellite tools will change the way
our Vegetation Management programs are managed. The analysis provided is invaluable in directing
planners and line clearing crews to specific locations on the system to perform maintenance and
mitigate risk trees rather than the traditional method of working on an entire circuit or polygon. This
data gives us the ability to send crews to the areas of greatest need with accuracy. Both of these tools
essentially learn Avista’s system and the vegetation around our lines to identify issues and growth
rates over time, and both allow planning work in a more precise and predictable way, streamlining our
vegetation management programs and helping to maximize their value.
Example screenshot of digital data results.

73

Prioritizing Steel Grid Hardening
We have refined the Transmission Steel Replacement Program to include not only WUI map
designations, but also the fire history and number of occurrences near each of our lines. Avista layered
the fire maps associated with our service territory over our transmission system. This allowed us to see
the historic fires that have occurred within strike distance of our transmission lines as well as acquire a
count of the frequency of the fires near each line, identifying lines or segments most likely to
experience fire issues based on actual events, helping inform the level of risk.

To add another dimension
to this data, we layered a
vegetation dataset over our
transmission line maps to
indicate whether the lines
are in high tree level or
forested areas versus low-
growth and/or developed
areas. This segregation is
significant from a cost
perspective, as it allows us
to separate our mitigation
efforts into poles in high
canopy/forested areas which are candidates for steel
replacement, and those in low vegetation areas which may be adequately protected with fire resistant
mesh. The cost for replacement of a wood pole with steel is several thousand dollars per pole versus a
few hundred dollars for installing mesh wrap on a pole. Thus, knowing where the poles are physically
located and the geography of the area, has a significant budget impact.

Avista Steel Transmission Pole Replacement Work

74

Avista Wildfire Resiliency Plan Glossary of Terms

Access and Functional Needs (AFN): Customers who are especially vulnerable, such as those who are
disabled, dependent on electrically operated medical equipment, who are transportation
disadvantaged, etc.

ADMS: Advanced Distribution anagement System. his is the replacement system for Avista’s current
inhouse-created Outage Management System (OMS) designed to manage and track all planned and
unplanned outages that affect the grid. It is an enterprise level system. Wildfire is among many
other Company users of this system.

Animal Guards: Parts installed to act as a barrier to stop animals such as
squirrels and birds from coming into contact with energized power
equipment.

Asset: Electric lines, structures, equipment, or supporting hardware in
the service of providing electric power to customers.

At-Risk Species: Species of vegetation that have an elevated risk of: (1) coming into contact with
powerlines, (2) causing an outage or ignition, and/or (3) are easily ignitable and within close
proximity to potential arcing, sparks and/or other utility equipment thermal failures. “At -risk
species” are a function of species-specific characteristics including growth rate, failure rate of
limbs, trunk, and/or roots (as compared to other species), height at maturity, flammability,
vulnerability to disease or insects, etc.

Backburn/Backfire: A fire set along the inner edge of a fire line to
consume the fuel in the path of a wildfire and/or change the
direction of force of the fire to help get it under control.

Bail Connector: A protection device installed on hot taps to hold
the conductor if the hot tap fails, preventing live conductor
from falling to the ground and potentially starting a fire.

Base Level Fire Safety Mode (FSM): This is Avista’s current “normal” ire Safety ode protection
scheme that has the goal of balancing reliability and fire risk potential. In this configuration, circuit
breakers will provide a fast trip to clear temporary fault conditions such as animal contact, small
tree branch, or lightning disturbance with a short
pause before a reclose attempt. If the circuit
remains faulted, such as wire-down or a tree in the
line, the nearest upstream fuse will operate and
isolate the faulted line section. This reduces the
spark-ignition potential associated with temporary faults and slightly increases the level for
permanent faults. When protection devices are operating in Base Level Fire Safety mode, only the
Animal Guard

75

time delay overcurrent element is active, meaning both the instantaneous tripping and automatic
reclosing are disabled.

Baseline: A measure, typically of the current state or condition, which establishes a starting point for
comparison with measures from other states or conditions.

Brush: Refers to vegetation dominated by shrubby, woody plants, or low growing trees.

Bulk-Power System: This includes all facilities and control systems necessary for operating the
interconnected electric transmission network (or any part of it) as well as the electric energy from
generation facilities needed to maintain transmission system reliability. This includes facilities that,
if disrupted, would impact the grid beyond just one location or utility.

Burning Index: An estimate of the potential difficulty of fire containment , judged by the flame length
at the most rapidly spreading portion of a fire’s
perimeter.

CAIDI: CAIDI refers to “Customer Average Interruption
Duration Index.” It is calculated as total minutes of
customer interruption divided by the total number of
customers interrupted. CAIDI describes the average
time required to restore service. It only includes
customers who actually experienced an interruption.

CAIFI: CAI I refers to “Customer Average Interruption requency Index.” It is calculated by dividing the
number of interruptions by the number of customers experiencing interruptions. It describes how
many interruptions each impacted customer experiences.

CARES: Customer Assistance Referral and Evaluation Services is a specialized team within Avista’s
customer contact center that supports our most vulnerable customers, assisting with resources
such as food, housing, and medical care.

Cascading Outage: The uncontrolled successive loss of system elements triggered by an incident at any
location that can cause a cascading outage that rolls across several sections or the entire
interconnection. Usually there is one or more initiating events, such as heavy loading. For example,
a transmission line experiencing high temperatures and sagging into a tree, causing the line to fail,
which shifts the load it was carrying to other interconnected lines, overloading them, and triggering
cascading events in widespread electric service interruption that reaches a point where it cannot
be stopped from spreading beyond the area in which it started.

CEIP / Clean Energy Implementation Plan: Washington State’s RCW . 0 , the Clean Energy
Transformation Act (CETA).70 This Act requires all retail sales of electricity to Washington customers

70 RCW 19.405.040: Greenhouse gas neutrality—Responsibilities for electric utilities—Energy transformation project criteria—Penalties. Chapter 19.405

76

be greenhouse gas neutral by January , 20 0. Avista’s CEIP work impacts Wildfire as the CEIP team
works to communicate better with customers, including on wildfire preparation , Fire Safety Mode,
and Public Safety Power Shutoff impacts.

CEMI: Stands for “Customers Experiencing
ultiple Interruptions” which indicates
the ratio of customers experiencing 1 or
more sustained interruptions as a
percent of the total number of
customers served. This is a customer-
centric measurement that helps identify “worst served” customers.

Circuit: The path for transmitting electric current from the device that creates
the current (generator) across all associated equipment (such as the wire or
conductor, switches, transformers, breakers, etc.) to the end user, as shown
in the graphic on the right.

Circuit Breaker: An essential device usually located in a substation for
interrupting excessive current flow typically initiated by a fault or heavy
loading. Circuit breakers cut the power until someone can fix the problem. In
addition, using a circuit breaker, interruption and reclosing times can be
adjusted to keep temporary faults from resulting
in a sustained outage. The circuit breaker can
sense whether the fault is transient and choose
to keep the electricity flowing. If it is a serious
fault that must be addressed, the breaker halts
the flow.

Circuit Mile: The total length in miles of separate
circuits regardless of the number of conductors
used per circuit.

Circuit Recloser: Circuit reclosers are similar to
household breakers. They shut off the power when
trouble has been detected then automatically test
the line to see if the trouble has been removed. If
the problem is only temporary, the recloser
automatically resets itself and restores electrical
power. Adding communications to circuit reclosers

RCW: WASHINGTON CLEAN ENERGY TRANSFORMATION ACT

Electric Circuit
Circuit Breaker

Circuit Breaker

77

provides monitoring and control functionality, including the
ability to operate the device remotely. Also, by placing circuit
reclosers at strategic locations, Avista Distribution Operations
can re-task or control those devices during periods of elevated
fire danger to operate in fire protection mode rather than in
their typical reliability mode. In other words, if there is a high-
risk situation, the reclosers can be set to not automatically
reclose.

Community Response Ambassadors: An Avista employee team of
volunteers who train with the Red Cross to provide help and
support to our most vulnerable customers during outage events.

Complex: As related to fire, this is when two or more individual fire
incidents located in the same general area are assigned to a single incident commander or unified
fire command and typically given one name that includes the word “Complex” to indicate that the
fire has individual components.

Condition-Based: Maintenance based on the way equipment is performing, its age, number of times it
was actuated, and/or other factors that indicate the actual condition of an asset.

Conductor: This is the wires or lines suspend ed from towers or poles that
help electricity to pass from one location to another, generally made of
aluminum reinforced with steel or composite materials, though some low
and medium voltage conductor is made of copper.

Consumer Average Interruption Duration Index: CAIDI is the average
duration of an interruption, calculated based on the total number of
sustained (over five minutes in length) interruptions in a year, considered
the average restoration time over the course of a year across the entire
utility.

Control Line: A completed fuel break around the fire. This break
may include natural barriers, manually created barriers, and/or
mechanically constructed fire lines in an attempt to control the
fire.

Cooperating Agency/Partner: For Avista, this includes external fire
professionals, agencies that provide customer assistance, law
enforcement, the Red Cross, emergency management agencies, state and local governments,
tribes, etc. that the Company works with in planning and implementing our Wildfire Plan as well as
in actual fire or fire threat situations.
Building a Control Line

78

Critical Facilities/Infrastructure: Referring to outage events, these are
elements critical to public safety such as emergency services, schools,
jails/prisons, healthcare and medical services, water, waste and
wastewater systems, communications, some manufacturing, and
transportation. Referring to the utility, these are elements of the
electrical grid that are required in order to provide customer service as
well as human health and safety. Critical infrastructure is a
priority for restoration of service.

Crossarm: A crossarm is a piece of hardware providing an
attachment point for insulators to support the loading of
overhead conductors. The crossarm is typically made of
wood, steel, or fiberglass.

Crowning: A crown fire is defined as a fire that has ascended from the ground into the forest canopy
and is spreading through it, usually in conjunction with the
surface fuels. When a forest fire spreads from treetop to
treetop it often begins advancing at great speed, well in
advance of the fire on the ground, and becomes
extremely dangerous and difficult to control.

Customer Choice Right Tree Right Place Program: his has been renamed the “Safe ree Program.” It
is a partnership with private landowners to remove trees located on private property that are likely
to come into contact with power lines. This program reduces the chances of these trees contacting
powerlines and creating fire potential, danger to the customer, or loss of reliability.

Customer Hours: In reference to power outages, this is the total number of
customers multiplied by the average number of hours of power outages.

Cutout: A “C” shaped piece of insulated hardware with a tubular insulator that is
designed to melt or break when the circuit going through it exceeds its rated
value. This serves to disconnect one section of the line from another section of
the line for maintenance or repair or to prevent an outage from spreading.

Cycle Trimming: At Avista, the routine vegetation management
program divides the system into five segments which are patrolled
on a rotating five-year basis, meaning about 20% of the system is
inspected and subject to trimming each year. The Wildfire program
added a 100% risk tree inspection to non-urban areas of the
distribution system in addition to the routine cycle trimming to more
rapidly identify and address vegetation issues that may lead to fire.

Danger Tree: At Avista, a danger or risk tree is a tree with the
potential of imminent fall-in hazard to energized facilities. This is a
Crowning Fire
A sic and damaged “danger” tree
located adjacent to power lines.
Above: Transmission
crossarm
Left: Distribution
crossarm
Cutout

“Melt”
tube.

79

tree within or adjacent to the utility right-of-way that is
dead, diseased, or dying or has a structural defect or lean
that makes it likely to fail in whole or in part and contact
electrical equipment or facilities.

Dead Fuels: Fuels with no living tissue, so moisture content
is governed almost entirely by atmospheric moisture
(relative humidity and precipitation).

Dead Fuel Moisture: Moisture content of dead vegetation,
which responds to current environmental conditions. This is
critical in determining fire risk potential.

Defensible Space: An area, either naturally or human-made,
where material capable of causing a fire to spread has been treated, cleared, reduced , or changed
to act as a barrier between an advancing wildland fire and the loss of life, property, or resources. In
practice, “defensible space” is often defined
as a buffer, an area a minimum of 30 feet
around a structure that is cleared of
flammable brush or vegetation. In forested
areas, this buffer area increases to 100 feet of
space.

Digital Data Collection: At Avista, this means
collecting LiDAR and satellite images of our
transmission and distribution systems in order to help pinpoint vegetation issues and other
encroachments, which allows us to plan vegetation field work and mitigate problematic vegetation
more accurately.

Dispatcher: A person who receives reports of discovery and status of outages, confirms their locations,
and takes action to provide people and equipment likely to be needed , sending them to the proper
place with all available information in order to make repairs or manage a situation effectively.

Distribution (DX): Electric facilities that have a voltage that is 60 kV or lower.

Distribution Automation: Avista’s Wildfire Program to aid in implementing wildfire protection
measures. This program will fund upgrading or replacing 240 devices (including about 50 midline
and substation breakers) to enable dynamic protection settings, allowing these devices to be
monitored and operated remotely and automatically during fire season.

Distribution Grid Hardening: Avista’s Distribution rid ardening Program targets portions of circuits
located in high-risk fire areas with the goal of reducing spark ignition outages. This work includes
replacing wood crossarms with fiberglass units, replacing end-of-life wood poles, changing out

80

obsolete small copper wire with modern steel reinforced aluminum wire, instal ling wildlife guards
to reduce animal related events, eliminating open wire secondary districts, installing wedge
connected stirrups to provide protection and additional strength at hot tap connection points, and
undergrounding conductor when cost-justified.

Distribution Infrastructure Upgrades: In Avista’s Wildfire Plan, this means making improvements to
our distribution system including adding wildlife guards, replacing wood crossarms with fiberglass,
replacing wood poles with steel in specific locations, and replacing replaced obsolete equipment
that has known spark potential. These changes are designed to increase resiliency and reduce the
potential for sparks. Also called Distribution Grid Hardening.

Drip Torch: A hand-held device for igniting fires by dripping flaming
liquid fuel on the materials to be burned; consists of a fuel fount,
burner arm and igniter. Fuel used is generally a mixture of diesel
and gasoline. This tool is used to create back burns to help control a
fire’s spread.

Drought Index: A number representing net effect of evaporation,
transpiration, and precipitation in producing cumulative moisture
depletion in the soil. Studies done by NASA found a strong
correlation between dry soil and an increase in fires.71 Dry soil can
help create favorable ignition conditions, especially in regard to its
impacts on the health of vegetation.

Dry Land Mode (DLM): Renamed Fire Safety Mode, this is a non-
reclosing distribution protection scheme used during summer fire
season (typically July and August) on circuits determined to be at
risk for fire activity based on a variety of factors including
vegetation, past events, and age of equipment. This strategy
modifies the protection settings of equipment in the field in
response to fire threat conditions as a way to reduce the chance of utility equipment creating a
spark.

Easement: An agreed-upon use of land by someone other than the landowner. An easement allows
building on someone else’s property versus a right-of-way which only allows access to travel across
someone else’s property.

Elevated Fire Safety Mode : Circuits whose fire risk exceeds nominal levels are modified to increase
protection levels. This is similar to Base DLM/FSM but instead of a time delay tripping step the
circuit will instantly trip if it tests bad. This allows service restoration for temporary faults but will

71 Karl B. Hille, “NASA Study Finds a Connection Between Wildfires and Drought,” Jan. 9, 2017, NASA Study Finds a Connection Between Wildfires and
Drought - NASA

( rip, wait, test, then reclose if good)

( rip, test, then reclose if good no
delay/wait)

( ormal Opera ons , mul ple recloses allowed)

( rip and stay o un l manually
inspected)

Drip Torch
Original Dry Land Mode Levels

81

de-energize the entire circuit for permanent faults by
tripping off at the breaker.

Elevated Fire Threat Areas: These are WUI Tiers 2
and 3 in which there is a higher risk for the ignition
and rapid spread of wildfires due to the proximity of
flammable vegetation, vegetation ignitability, human
activity and habitation zones, and other
environmental conditions.

Elevated Wildfire Risk: This means that based on
existing weather and vegetation conditions, wildfires are possible should ignitions occur. At this
level, the Company considers making changes to the distribution protection systems to reduce this
risk.

Emergency First Responder Training: Protects both
firefighters and utility workers in the event of a fire
event by providing proper training in response to both.
Avista first responders (field crews) are trained by fire
personnel in fire safety and engaging with fire incident
command, and fire responders are trained in safely
operating around power equipment.

Emergency Operating Procedures (EOP): An EOP is a command structure that shifts normal operations
to emergency response, with service restoration typically the primary objective. For a Wildfire EOP,
the primary focus is safety, and the engagement includes outside fire and emergency-related
entities to prepare for potential or actual wildfire events. The Wildfire EOP defines key roles and
responsibilities for personnel, identifies communications channels, and outlines strategies for
engaging with fire protection professional and emergency operating agency staff during expected
or actual wildfire events, creating a consistent and efficient joint approach.

Enhanced Grid Hardening: Avista is working to identify specific areas where large fire growth is
coupled with proximity to communities which are excessively vulnerable to total loss in the event
of a wildfire. These areas are being risk-
ranked and prioritized for sectional
undergrounding of existing overhead
conductor. This strategy will reduce
wildfire risk and increase safety to the
communities facing the highest risk from
Avista’s distribution electric facilities. his
strategic approach will allow Avista to
mitigate the most risk for the least cost related to conversion to underground, allowing resources

oat oat
Training with Firefighters

82

to efficiently eliminate risk at a surgical rather than a system -wide level.

Enhanced Vegetation Management: Avista’s Wildfire Plan created a separate vegetation management
program from our existing routine vegetation management practices. This new program has the
goals of inspecting 100% of the non-urban distribution system for risk trees annually and mitigating
any such trees found within six months of identification. The Wildfire Plan also added LiDAR and
satellite data collection for the transmission and distribution systems to provide detailed
vegetation data to aid our vegetation managers in identifying, prioritizing, and developing plans to
mitigate vegetation risk in the highest risk areas.

Episodic Wildfires: Wildfires that do not occur frequently or regularly.

Equity Advisory Group: Avista’s specialized team that is working specifically with vulnerable customers
and Named Community members to identify barriers and develop workable solutions for their
needs, including multilingual communications and ensuring accessibility to programs and materials.

Expedited Fire Response: In Avista’s Wildfire Plan, this is an agreement with state, local, and regional
firefighting agencies to send fire crews directly to the site of a transmission trip during fire season
event so if the fault results in a fire, it is managed immediately.

Extreme Fire Behavior: "Extreme" implies a level of fire behavior that ordinarily precludes methods of
direct control action. One or more of the following is usually involved: high rate of spread, prolific
crowning and/or spotting, presence of fire whirls, and/or a strong convection column. Predictability
is difficult because such fires often exercise some degree of influence on their environment and
behave erratically, often dangerously.

Extreme Fire Safety Mode: Circuits whose fire risk is judged to be extreme are configured in a way
similar to the crew safety mode called “ ot Line old.” In this
configuration, auto reclosing is disabled, and instantaneous
tripping is enabled. A circuit that experiences a fault will trip off
and stay off at the first instance. It does not test or try to reclose.
The circuit must be manually inspected to ensure it is safe before it is placed back in to service.

Extreme Wildfire Risk: This means that based on existing weather and vegetation conditions, a large,
rapidly growing wildfire is possible should ignition occur.

Fault: A fault is an abnormal condition present on the power system, usually a short circuit caused by
lightning, tree contact, windblown object in the lines, or other similar problem.

Fault Reduction: In the utility world, this means decreasing the number of faults by prioritizing
reliability programs that strengthen the utility’s infrastructure, which is especially important in
higher wildfire risk areas.

83

Feeder: A distribution circuit (feeder) coming
out of a substation, consisting of a three-
phase main feeder that splits into laterals at
the customer level. Avista’s distribution
system follows the industry standard of using
relatively short sections of main feeder trunk
supporting longer connected lateral lines that
carry electricity to the customer’s service
line.

Fiberglass Crossarms: Pole fires are a well understood
phenomenon within the electric utility community.
Electric current tracking during summer months leads
to increased rates of pole fires. Fiberglass crossarms
reduce or eliminate electric current tracking and hence,
pole fires. Fiberglass crossarms are smooth and
resistant to contamination, do not rot or degrade over
time, and are much lighter while being up to six times
stronger than wood. In addition, fiberglass crossarms
are inherently self-extinguishing, so perform well in fire
situations.

Fire Behavior: The manner in which a fire reacts to the influences of fuel,
weather, and topography. Fire behavior provides an indication to
firefighters on how to best battle the blaze.

Fire Behavior Forecast: A prediction of probable fire behavior, usually prepared by a fire professional,
in support of fire suppression or prescribed burning operations.

Fire Behavior Index: A scale that captures fire severity as a function of flame length (intensity of burn)
and rate of spread.

Fire Break: A natural or constructed barrier used to stop or
check fires that may occur, or to provide a control line
from which to work.

Crews bulldoze a fire
brea at the fire’s edge
along the fire front.
Pole Fire on a
Wood Crossarm
Fiberglass Crossarm

84

Fire Front: The part of a fire within which continuous flaming combustion is taking place. The fire front
is usually assumed to be the leading edge of the fire perimeter. In ground fires, the fire front may
be mainly smoldering combustion.

Fire Ignition Events: When a spark is created by the interaction of utility equipment and its
surroundings (such as when a tree falls into a powerline) and results in a spark that, under the right
circumstances, could become a fire.

Fire Mesh Wraps: Avista uses Genics Fire Mesh, a wire mesh treated with
intumescent graphic that, when exposed to extreme heat, rapidly expands to
form a barrier between the fire and the wood pole. These wraps help prevent
low-burning fires from accessing wood poles, protecting them from damage
or destruction.

Fire Perimeter: The entire outer edge or boundary of a fire.

Fire Prone: Areas where fires are most likely to occur or have
a higher tendency to occur, often as a result of drought,
forest health issues or insect infestations, human
interaction, large amounts of dry undergrowth, low levels
of humidity, etc.

Ford Corkscrew Fire Perimeter
A piece of fire
mesh wrap

85

Fire Retardant: Avista uses two primary forms of fire retardant protection on the transmission system
and on some distribution poles. Historically we have placed fire resistant paint on wood
transmission structures starting near the ground line and several feet up the pole, which is an
effective means of preventing damage caused by ground fires. This product must be re -applied
every 3-5 years. Fire resistant mesh is a new product the Company is switching to. It is chemically
reactive to extreme heat, expanding to protect wood poles from fire. This product does not require
ongoing maintenance and is quick and easy to apply for about the same cost.

Fire Risk Potential: This incorporates weather and fuels information to rate the overall fire threat at a
particular location as well as a fire’s likely behavior should one start.

Fire Safety Mode (FSM): Formerly called Dry Land Mode, Fire Safety Mode is a non-reclosing
distribution protection scheme used during summer fire season (typically July through September)
on circuits determined to be at risk for fire activity based on a variety of factors including
vegetation, past events, and age of equipment. If not in elevated or PSPS mode, these circuits are
configured so that when they trip, they will wait for a predetermined length of time then test the
circuit. This allows the line to go back into service for incidental and transitory faults such as a tree
branch touching the line, thus having a focus on reliability. Under Fire Safety Mode operations,
reclosing is limited or not allowed to help prevent equipment from failing and creating a spark , thus
focusing on safety.

Fire Safety Mode Automation: Avista’s plan to upgrade midline and substation devices in areas at risk
for wildfire to enable these devices to be operated remotely and automatically in response to fire
situations.

Fire Safety Mode Ready Devices: Midline and substation devices located in high risk fire areas that
Avista’s Wildfire Program will upgrade or replace to allow protection settings to be operated
remotely and automatically in reaction to wildfire or wildfire risk situations.

Fire Season: The time of year that wildfires are most likely to take place for a given geographic region
due to seasonality, historical events and weather conditions, vegetative characteristics, etc.

Fire Spread: This is a measurement to help firefighters determine how far and fast a fire may spread.
The intensity and movement of a wildfire ultimately depends on three factors: fuel, weather , and
topography. A fuel’s composition, including moisture level, chemical makeup and even density,
influences how quickly a fire will spread. The moisture content of fuel helps determine how much
area may burn. If vegetation has a low moisture level and is very dry, a fire will burn faster and
more intensely because the heat does not have to eliminate water. The size and amount of fuel
also affects wildfire behavior. Small fuel sources such as grasses typically burn quicker and do not
generate as much heat as trees and other large fuel sources. And while a small amount of fuel will
cause a fire to spread slowly with lower intensity, a lot of fuel will cause a fire to spread faster with
more intensity. Some plants, trees and shrubs also contain oils and resin s that cause them to burn
more quickly and intensely. Weather conditions such as wind, temperature and humidity also play

86

a major role in the behavior and
spread of a wildfire. Wind supplies
fire with additional oxygen. This
can cause a fire to move across a
landscape at a much faster rate.
Topographical features of a
landscape, such as slope,
elevation, and aspect, can also
facilitate wildfire progression. If a
fire ignites at the bottom of a
steep slope, for example, it will
spread more quickly uphill
because heat rises.

Fire Threat Areas: Areas which have the highest likelihood of impacting people and property and
where additional action may be needed to reduce wildfire risk. Threat level is based on elements
such as population, topography, vegetation type, and historical fires in the area.

Fire Threat Conditions/Fire Danger Rating: This considers current and antecedent weather, fuel types,
and both live and dead fuel moisture to estimate the likelihood of a fire occurring as well as
potential fire behavior should a fire occur.

Fire Triangle: The “fire triangle” is composed of fuel, heat, and oxygen. Fire is the
effect of a chemical reaction known as combustion, which occurs between
oxygen in the air and some sort of fuel that has been heated to its flash
point (the lowest temperature at which it will ignite.) Fuel is any kind of
flammable material, including trees, grasses, shrubs, and even houses.
These materials emit a vapor. Heat brings these fuels to their flash point, causing the vapor to
evaporate and mix with oxygen. Oxygen is the naturally occurring element needed for igniting and
sustaining a fire. When burning fuel is exposed to oxygen from the air, a chemical reaction occurs
that releases heat and generates combustion. A fire can only occur when all three components
react together.

Fire Weather: Weather conditions that influence fire risk, ignition, behavior, and suppression.

Fire Weather Dashboard: his is Avista’s primary means of determining fire risk across our system. It is
a risk-based computer program that combines the 7-day weather forecast with equipment
performance and fire risk levels based on time of year, drought conditions, type of vegetation and
moisture levels, sustained winds, wind gusts, and more. It indicates the risk level on each of Avista’s
In a forest where res rarely happen, fuel
Builds up. here is (grass,logs,
woody debris, brush), (shrubs,
small trees), and .
Surface res
spread quickly
through brush and
debris.
Ladder fuels allow
the re to move up
toward the forest
canopy.
ree crown res are
so intensethat they
are di cult to
control.

87

distribution circuits for the upcoming
week and highlights the maximum
expected daily risk for every feeder on
Avista’s distribution and transmission
systems.

Fuel: Combustible material. Includes,
vegetation, such as grass, leaves,
ground litter, plants, shrubs, and trees
that feed a fire.

Fuel Concentration/Density: Mass of fuel
(vegetation) in an area which could
combust in a wildfire.

Fuel Management: Removing, thinning, or otherwise altering vegetation to reduce the potential rate
of propagation or intensity of wildfires.

Fuel Moisture Content: Amount of moisture in a given mass of fuel
(vegetation), measured as a percentage of its dry weight.

Fuel Reduction: Manipulation, including removal of fuels (vegetation
management) to reduce the likelihood of ignition and/or to lessen
potential damage and resistance to control.

Fuel Reduction Partnerships: Partnering with external land management
agencies, leveraging funding to remove fuels near Avista facilities. Sharing
the cost allows both parties to do more work than each could accomplish
with individual budgets.

Fuse: A device that limits the
amount of current flowing through
the circuit. The fuse is constructed
with a small piece of metal that,
when exposed to high current
typically caused by a fault, melts and interrupts the flow of
electricity. Fuses are typically placed on lateral tap lines off
the main circuit.

Grid: General design of an electric grid, whether looped or
radial, with consequences for reliability and ability to
support de-energization (e.g., being able to deliver electricity
from an additional source).

Fuel Reduction Efforts
Fuse

Fire Weather Dashboard Screenshot

88

Grid Hardening: Actions such as equipment upgrades,
maintenance, and planning for more resilient
infrastructure, taken in response to the risk of
undesirable events (such as outages or wildfires) or
undesirable conditions (such as old or unreliable
equipment) of the electrical system in order to
reduce or moderate those events and conditions,
informed by an assessment of the relevant risk
drivers or factors. In the Wildfire Plan, this
specifically means adapting transmission and distribution materials and construction to minimize
the potential for utility-involved fires in addition to protecting utility infrastructure in the event of a
fire.

Hazard Tree: A risk or hazard tree is defined as one that
is dead, dying, diseased or exhibits obvious structural
defects such as a co-dominate stem which pose an
increased fall-in risk with conductor during severe
weather. At Avista, a “risk tree” is a tree with the
potential of imminent fall-in hazard to energized
facilities.

Herbicides: Typically used on the right-of-way to control
incompatible tall growing species and noxious weeds. For the past several years, at Avista herbicide
applications have primarily consisted of treating the stumps of fast-growing deciduous trees after
they are removed to prevent resprouting. These applications are recorded within the same work
records as the tree removals which are generally categorized as risk tree work.

High Canopy: Forested areas with tall
mature trees. In these types of
areas, fire can spread from the
ground into the tree tops, where
it becomes difficult to control. In
relation to utility infrastructure,
this high fire can access the tops
of poles and structures and burn
them down to the ground. Thus,
replacing more burnable wood
poles with steel helps protect
against this type of high level fire.

High Risk Fire Areas: Areas in Avista’s service territory that have been identified as most at risk for
wildfire and associated damage, locations in wildland urban interfaces (WUI zones) for which there
High Canopy Fire near the Noxon-Pine Creek transmission line in 2023.

Fuse

89

is little or no fire protection (typically rural or remote areas), or which have experienced historic
wildfires.

High Value Locations: In Avista’s Wildfire Plan, this
refers to situations where wood poles are
replaced with steel to add strength and durability
at high consequence locations such as high-
volume traffic areas, railroad, highway, and river
crossings, at hard angles, or if access for
maintenance is particularly difficult. These are
locations where mechanical or fire-related pole
failures could lead to increased safety risks and
reliability impacts.

High Wind Advisory or Warning: Level of wind risk
from weather conditions as declared by the
National Weather Service (NWS). The difference
between a high wind advisory and a high wind
warning is the level of winds associated with the
event. Advisories go into effect for sustained
winds of 40 mph or less with gusts of at least 45
mph. Warnings are issued if sustained winds are
above 40 mph and gusts are 50 mph and above.

Highly Impacted Communities: As defined in
Washington State, highly impacted communities must meet at least one of the following criteria:
are within the limits of an Indian reservation and/or suffer environmental health disparities such as
pollution, hazardous waste, poverty, or cardiovascular disease.72

Hot Line Hold: A hot-line hold is an assurance to the worker that an automatic protective device has
been set to not reclose in the event the line or equipment becomes de -energized, typically used
when line crews are working on a powerline or power equipment issue. With a hot line hold, the
applicable device will not be re-energized until the appropriate dispatcher determines workers are
in the clear. A hot line hold always pertains to
energized lines or equipment. In this configuration,
auto reclosing is disabled, and instantaneous
tripping is enabled.

Hot Tap: A connection to the utility’s powerline. A hot
tap is a connection that can easily be removed

72 Washington State Dept. of Health, “Instructions for Utilities to Identify Highly Impacted Communities,” Instructions for Utilities to Identify Highly Impacted
Communities | Washington State Department of Health
Hot Tap Connectors

90

versus a wedge connector, which is more permanent. The traditional hot line tap is attached via a
bolt. Over time this type of connection can come loose and arc and spark and can melt through the
conductor, dropping it to the ground. Thus, adding parts that keep the conductor from falling may
help prevent fires.

Ignition probability: The relative possibility that an ignition will occur, quantified as a number between
0% and 100% (where 0% indicates impossibility and 100% indicates certainty). The higher the
probability of an event, the more certainty there is that the event will occur. (Often informally
referred to as likelihood or chance).

Impact/Consequence of Ignitions: The effect or outcome of a wildfire ignition upon objectives, which
may be expressed by terms including, but not limited to, maintaining health, and safety, ensuring
reliability, and minimizing economic and/or environmental damage.

Incident: A human-caused or natural occurrence, such as wildland fire, that requires emergency service
action to prevent or reduce the loss of life or damage to property or natural resources.

Incident Command Structure (ICS): The combination of facilities, equipment, personnel, procedures,
and communications operating within a common organizational structure, with responsibility to
manage assigned resources to effectively manage an incident. Every incident needs to have
someone in charge, overseeing the event and the associated response, ensuring that adequate
supplies and manpower are in place, to know who is operating and where, and to identify who
might be impacted and how to protect them. The ICS provides a standardized approach to the
command, control, and coordination of emergency response, providing a common hierarchy within
which all responders (including Avista) can be effective, as well as commonly understood
procedures designed to keep everyone safe and communicating effectively. It helps provide an
orderly, systematic approach to incidents.

InciWeb: This is an Interagency All-Risk Incident Information
Management System that provides a single source for fire
incident related information and a standardized reporting
tool for public use. Fire information is available for events
across the U.S.

Infrastructure: This refers to the equipment Avista utilizes in
order to serve customers, including poles, transformers,
conductor, switches, substations, etc.

Inherent Risk: In Avista’s Wildfire Plan, this is the current state
wildfire risk level which reflects Company wildfire defense
strategies initially in place.
InciWeb Fire Map

91

Insulator: Insulators have the duty of keeping the electrically
charged line from touching the poles or towers so the line can
continue to transmit and is not
grounded. Insulators must be strong enough
to withstand the weight of the conductor
and the potential stress of the electricity
wanting to connect to the earth. They are
designed to be non-conducting, but getting
wet can cause flashovers, which is why
many insulators are designed with an
umbrella or petticoat at the top to keep the lower part insulated from the rain.73 Extreme weather,
sun and vandalism can reduce the strength of the insulator, making it more likely to break and
cause an outage so insulators are monitored during inspections. There are many kinds of insulators
depending upon their application.

Insulator Pin: This is a piece of overhead hardware that fastens the insulator to
the crossarm. The insulator pin is bolted through the crossarm and the
insulator is screwed onto the top of the insulator pin.

IVR: Interactive Voice Response is a technology that allows telephone users to interactive with a
computer-operated telephone system with voice
recognition technology. It allows automatic call
distribution, allowing the Company to reach out to
multiple customers at the same time.

Ladder Fuels: Fuels which provide a vertical path between
the ground strata and higher vegetation, allowing fire
to carry from surface
fuels into the crowns of
trees or shrubs with
relative ease. These
fuels help initiate and
assure the continuation
of crowning where the
fire spreads very rapidly
from treetop to treetop, becoming much more difficult
and dangerous to control.

Lateral: In the distribution system, these are circuits that
break off from the main feeder trunk (that comes out of
the substation) and deliver electricity to customer’s

73 For more than you ever wanted to know about insulators, see: Glossary of Insulator Terms (insulators.info)
Strings of transmission insulators,
sometimes called bells

Strings of insulators, sometimes called
“Bells”
Dead-end Insulator

Dead-end Insulator
Stay Insulator

Insulator with pin
ote the “petticoat”
Insulator
with pin

Insulator
with pin
Note the
“petticoat
”
Ladder Fuel Diagram

92

homes (service lines). The laterals normally have fuses to separate them from the mainline if they
are faulted.

LiDAR: Light Detection and Ranging, sometimes called 3-D laser scanning, which can be used to make
high resolution representations of the earth’s surface. At Avista it is used on
the transmission system to identify vegetation
encroachment and risk trees. It works well for
transmission due to the open linear transmission
rights-of-way. LiDAR is primarily collected via
helicopter and fixed wing aircraft.

Lightning Arrester: A piece of hardware that
reduces voltage surges from direct or nearby
lightning strikes. When a lighting strike occurs, the
overhead conductor experiences higher than normal voltage levels. This
high voltage is dissipated via the lighting arrester,
mitigating potential damage to equipment.

Line Miles: The number of miles of transmission and/or
distribution line. Differs from circuit miles because
individual circuits, such as the two circuits of a double-
circuit line, are not counted separately in circuit miles
but are counted as separate in line miles.

Live Fuel Moisture Content: Moisture content within living
vegetation, which can retain water longer than dead fuel.
Moisture content is the most critical factor related to how
much fuel is available to burn in a wildfire. When
moisture content in living vegetation reaches a critical low
threshold, fire danger increases.

Managed Risk: In Avista’s Wildfire Plan, this is the future
state wildfire risk level as it is impacted by the addition of
Wildfire Resiliency elements like grid hardening.

Medical Baseline Customers: Residential customers with qualifying medical conditions and/or who are
dependent on power for qualifying medical devices for certain medical needs. For example,
customers that have specific heating and cooling, breathing, or mobility needs.

Member of the Public: Any individual not employed by the utility.

Metrics: In Avista’s Wildfire Program, these are measurements that track how much utility wildfire
mitigation activity has changed the conditions of utility wildfire risk exposure or the ability to
manage and reduce wildfire risk.

LiDAR Image

93

Midline (Midpoint) Circuit Reclosers: Often used on long distribution lines where substation-based
equipment cannot adequately protect the entire length
of the circuit. Avista’s Wildfire Plan adds
communications to these midline circuit reclosers in
order to provide monitoring and control functionality,
including the ability to operate the device remotely. By
placing automated midline circuit reclosers at strategic
locations, Avista Distribution Operations can re-task
those devices during periods of elevated fire danger to
operate in fire protection mode rather than in their
typical reliability mode. In other words, if there is a high-
risk situation, the reclosers can be set to not automatically reclose.

Miles Completed: In the Avista Vegetation Management Plan, this is a calculated value that equates to
the known overhead line mileage within a work polygon multiplied by the percentage of planned
work completed within that polygon. Completion of planned work means executing the plan
(trimming, removing, replacing) to the Company’s specifications.

Miles Patrolled: The number of miles inspected via foot, vehicle, or aerial patrols. Miles patrolled and
miles planned effectively mean the same thing within the vegetation work plans.

Miles Planned: In Avista’s Wildfire Resiliency Plan, this is the number of miles of risk tree inspections
projected for completion. Miles patrolled and miles planned effectively mean the same thing within
the vegetation work plans.

Mitigation: A measure or activity
proposed or in process that is
designed to reduce the
impact/consequences and/or the
likelihood/probability of a risk
event such as wildfire.

Momentary Outage: The IEEE defines
“momentary” outages as a brief
loss of power (less than five
minutes in length) caused by the
opening and closing operation of an interrupting device.

Multi-Agency Coordination/Partnerships: A generalized term which describes the functions and
activities of representatives of involved agencies and/or jurisdictions who come together to make
decisions regarding the prioritizing of incidents, and the sharing and use of critical resources. Also
refers to agencies who work together, sometimes via financial assistance, in reducing fire risk.

94

Named Communities: According to
Washington State, these are
communities that are highly impacted by
adverse socioeconomic conditions,
pollution, and climate change, or who
experience a disproportionate risk of
environmental burdens. They are
comprised of a combination of “ ighly
Impacted Communities” and “ ulnerable
Populations” (each defined elsewhere in this report).

National Weather Service: An agency of the United States federal government tasked with providing
weather forecasts, warnings of hazardous weather, and other weather-related products to
organizations and the public for the purposes of protection, safety, and general information. Most
of its products are in the public domain and available free of charge.

Normal Fire Season: A season or time of year when weather, fire danger, number and distribution of
fires are about average.

“ ” : This is the original program implemented by Avista in the early 2000s, when,
during the summers, Avista changed the distribution system to turn off automatic re -closing when
a fault occurs in certain parts of the system at the beginning of fire season (typically June) and back
on at the end of fire season (usually September). Note that when breakers are automated, they
move from “Old” ire Safety ode to Base ire Safety ode.

OMS/OMT: Outage Management System or Outage Management Tool. This is an Avista inhouse
developed tool for tracking electric outage cause information (such as car hit pole, tree fall -in,
wind, pole fire, etc.) as well as time stamp, reason, type, number of customers impacted, and
length of outage. The OMS was designed to record actual events based upon cause, not impact,
with the goal of repairing or replacing equipment that has or could lead to an outage. The current
OMS does not include provisions for tracking outcomes
beyond direct customer impacts, so is not set up to capture if
an outage results in a fire unless that is noted in Dispatcher
comments.

Open Wire Secondary Districts: Three conductors with 120/240
volts that run pole to pole below the primary conductors
(primary conductors are on top of the pole in an overhead
distribution system). It is called “open wire” because the
three wires are clearly visible as opposed to a design in which
the three conductors are bundled together. Sometimes called
“Secondary ain.”

ome of Avista’s Wildfire Partners
Open Wire Secondary Districts

95

Operations and Response: any of Avista’s circuit breakers cannot be remotely operated and require
manual intervention to make changes to settings or to identify an issue. This may take several
hours depending on location and crew availability. Avista’s Wildfire Program funds communications
and control equipment that will help us have “eyes” on critical equipment out in the field as well as
be able to control and adjust it remotely in case of fire or high fire threat conditions. This
automation equipment as well as our work with internal and external partners in reducing the risk
of wildfire are part of the “Operations and Response” portion of Avista’s Wildfire Resiliency Plan.

Outstanding Plan: A still-to-be-completed plan. As inspections are performed, plans are created that
consist of one or more units of work that need to be performed. Sometimes completion of a plan is
delayed due to customer permission, access, inclement weather, etc. and thus are categorized as
“outstanding.”

NIFC/National Interagency Fire Center: Located in Boise, Idaho, this is the home
to the National Interagency Coordination Center (NICC) and National Multi-
Agency Coordination (NMAC) groups, which provide unified guidance to fire
agencies, coordinate fire response, manage firefighting resources, and track
and document fires, sources, size, and impact across the United States.

Patrol: In Avista’s Wildfire Plan, this refers to ground, vehicle, and aerial
inspections of our transmission and distribution systems to identify vegetation or structural issues,
right-of-way infringement or encroachment, ground profile changes, etc.

Patrol Inspection: A visual inspection of applicable utility equipment and structures that is designed to
identify obvious structural problems and hazards.

Peak Fire Season: That period of the fire season during which fires are
expected to ignite most readily, to burn with greater than average
intensity, and to create damages at an unacceptable level.

Plan-Do-Check-Adjust: A continuous improvement technique also known as
the Deming Circle or Shewhart Cycle. Avista’s Wildfire program uses this
technique to help continue to grow and improve the program.

Planned Outage: Electric outage announced ahead of time by the utility.

Pole Fires: Pole fires are a significant contributor to wildfire risk. The
mechanism that causes pole top fires is well-known. This issue is related
to periods of hot, dry weather when insulators become covered with dust
and other contaminants, creating a path for leakage current. A light rain after the dry spell
increases leakage current and creates the right conditions for pole fires. This leakage current is
concentrated between wood-to-wood contacts such as the contact point between wood crossarms
and wood poles. Fiberglass crossarms virtually eliminate pole fires. Avista has been installing

96

fiberglass crossarms since the early 2000s. As part of Wildfire Resiliency, the Company has an
additional focus on replacing wood crossarms on structures located in elevated fire areas.

Pole Wraps: Avista uses Genics Fire Mesh, a wire mesh treated with an
intumescent coating that, when exposed to extreme heat, rapidly
expands to form a barrier between the fire and the wood pole. These
wraps help prevent low-burning fires from accessing wood poles,
protecting them from damage or destruction. Mesh is more durable than
the fire-resistant paint and is considerably less expensive than replacing a
wood pole with steel. At Avista, pole wraps are used in areas subject to
routine grassland, sage-shrub, or other low level fires.

Polygons: Between 20 and 20 Avista’s egetation anagement planning was changed from circuit
level to polygon level. Polygons contain many circuits. Prior to switching to the polygon method,
the overhead line mileage of a circuit was multiplied by the percentage of the circuit
planned/inspected to arrive at Miles Planned and the percentage of the work on the circuit
completed was multiplied by overhead line mileage to arrive at Miles Completed.

Polygon Planned Work Completed: This is a Vegetation Management work polygon that has 100
percent Miles Planned and 100 percent Miles Completed and thus requires no further remediation
– all tree work has been completed. It is technically possible that an inspection could lead to no
work needed at all, but it is not something that has been encountered in practice.

Polygon Planned Work Not Done: The entire vegetation management work polygon has been
planned/inspected but tree work is incomplete. This category helps keep track of inspections and
work spanning between two plan years, so that those polygons will be carried into the following
year for completion.

Preparedness: Condition or degree of being ready to cope with a potential fire situation .

Preventive Maintenance (PM): The
practice of maintaining equipment on
a regular schedule based on risk,
elapsed time, run-time meter readings,
or number of operations. The intent of
PM is to prevent maintenance
problems or failures before they take place by following routine and comprehensive maintenance
procedures. The goal is to achieve fewer, shorter, and more predictable outages.
Installing Pole Wraps

97

Priority Essential Services: Critical
first responders, public safety
partners, critical facilities and
infrastructure, operators of
telecommunications
infrastructure, and water
utilities/agencies. It is important
for a utility to know who and
where these customers are
located so they can be prioritized
for service restoration during an
outage or de-energization.

Program Targets: Quantifiable
measurements of activity
identified in WMPs and subsequent updates used to show progress towards reaching the
objectives.

Progress Metrics: Measurements that track how much utility wildfire mitigation activity has changed
the conditions of utility wildfire risk exposure or utility ability to manage wildfire risk exposure, in
terms of leading indicators of ignition probability and wildfire con sequences.

Protection System: This comprises protective relays,
associated communication systems, voltage and
current sensing devices, station batteries, and DC
control circuitry designed to protect equipment and
facilities.

Protective Relays: These devices detect and attempt to identify and correct
faults. They read measurements such as current, voltage, and frequency and can be set to
recognize when these indicate a problem. For example, if a protective relay senses that a circuit
breaker is interrupting the system, it can disconnect it.

Public Safety Power Shutoff (PSPS): When electric companies preemptively turn off the power to
specific areas of the system
to reduce the risk of wildfires
and to help keep customers
and infrastructure safe. These
events differ from typical
outages because they are
based on a prediction of risk
rather than the occurrence of
an actual event.

Public Safety Power Shutoff Deciding Factors
Protective Relay

98

PSPS Event: Defined as the time from the when the first public
safety partner is notified of a planned public safety de -
energization to the final customer being re-energized.

PSPS Risk: The potential for the occurrence of a PSPS event
expressed in terms of a combination of various outcomes
of the event and their associated probabilities.

PSPS Weather: Weather that exceeds a utility's risk threshold and creates decisions around initiating a
PSPS in specific areas of the system.

Radial: A transmission or distribution line that does not have a redundant feed – it is a single line
running from the generator to the customer, so if this line is
lost, customers lose service, versus a redundant system that
has another line or lines available to serve load if one line is lost
(see Looped or Redundant). These are common for low density
rural areas where more complex systems are cost prohibitive.

Rate of Spread: The relative activity of a fire in
extending its horizontal dimensions. It is expressed
as the rate the total perimeter of the fire is
growing, as rate of forward spread of the fire
front, or as rate of increase in area, depending on
the intended use of the information. Usually, it is
expressed in acres per hour for a specific period in
the fire's history.

Reburn: The burning of an area that has been
previously burned but that contains flammable
fuel that ignites when burning conditions are more favorable.

Recloser: A device that operates similarly to a circuit breaker but is
installed on a distribution circuit. Reclosers are available for both single-
phase and three-phase fault interruptions. The main purpose of a
recloser is to sectionalize a portion of a circuit from the rest of the circuit
to prevent outages from spreading.

Red Flag Warning (RFW): Level of wildfire risk based on weather
conditions, as declared by the National Weather Service. This is a term
used by fire weather forecasters to alert the public to an ongoing or
imminent critical fire weather pattern that would allow for rapid fire starts and/or spread, as well
as extreme fire behavior. This pattern must coincide with fuels that are critically dry and fire danger
that is moderate to high.
Fire Rate of Spread
Viper Recloser

Viper Recloser
Public Safety Power Shutoff Typical Timeline

99

Redundant: This is also called a looped system. In the transmission
world, this means that more than one line or route runs between
the generation source and the end customer, so if one line is lost,
the power is rerouted via another line and the customer suffers
either a shorter outage or no outage at all.

Relative Humidity (RH): Relative humidity is expressed as a percent of the amount of moisture in the
air to the amount of moisture needed to saturate the air. Humidity can either dampen or dry out
potential fuel. When relative humidity decreases, fire behavior increases because fine fuels like
grass and pine needles become drier
quickly. Heavy fuels are less easily
affected by changes in humidity, and it
often takes a larger or longer-lasting
event to affect their moisture
significantly. Low humidity levels dry out
vegetation fuels on a short-term basis,
and they can also cause a short-term
spike in fire danger. The relative humidity
is lowest when the air temperature is
high and the dewpoint temperature is
low. The dewpoint temperature is the
temperature when the air needs to be
cooled to become saturated. When there are cooler temperatures and/or high atmospheric
moisture levels, it reduces fire danger.

Reliability: Maintaining customer service continuity.

Restoration: When a
threat has ended
and it is safe to
begin making
repairs, crews are
organized and
dispatched to the
site of a power
outage. Typically,
the priority is to
restore service to as many
customers as possible through line switching and by isolating faulted circuits with preference given
(as possible) to critical service providers and vulnerable customers and communities.

Right Tree Right Place: his has been renamed the “Safe ree Program.” It is a partnership with private
Line Patrol:
All Clear is declared by
decision makers
ield Crews obilized
Broad Communica ons to
Customers Including elp
With Support Resources
Restore Power:
Start with Cri cal
Infrastructure, Commercial
Zones with Equity
Considera ons
Communicate Es mated
Restora on ime to
Customers
Complete Repairs:
ain runk Lines
Branch Lateral Circuits
Individual Customers
Update Communicate
Es mated Restora on ime
to All
Event Ends:
EOP is Declared Over
A er Ac on Review With
Emergency st Responders
PSPS Report to Regulators
hank ou to Crews
Customers
Typical PSPS Restoration Process

100

landowners to remove risk trees
on their private property that are
at risk of coming into contact
with powerlines and creating fire
potential or loss of reliability.

Risk Based: Making decisions based
upon how much risk is involved.
Typically, a utility identifies
specific risks to elements such as
safety of employees, first
responders, and the public as well as financial well-being, customer reliability impacts, probability
of occurrence, and consequence of occurrence among other factors. This is done in order to
develop programs and plans which seek to reduce those risks.

Risk Based Vegetation Inspections: A new vegetation management goal based on the Company’s
Wildfire Plan that requires 100% of non-urban distribution areas to be inspected for vegetation
issues each year. At Avista, this called our Enhanced Vegetation Management program.

Risk Event: An event with probability of ignition, including wires down, contacts with objects, events
with evidence of heat generation, and other issues that cause sparking or have the potential to
cause sparks.
Risk Tree: At Avista, a visibly dead, diseased, damaged, or dying tree or one
which possesses obvious structural defects that could fall into energized
facilities.

Right-of-Way (ROW): A right-of-way is the right to come onto a property
owned by another. For a utility, this
allows us to do maintenance and/or
tree trimming work on land that is
not our own.

Right-of-Way Work: ROW work
includes re-clearing or reclaiming
the right-of-way with planning and
completion of work at the span (from one pole to the next)
level as opposed to spot work planned and completed at the
individual tree level.

Routine Vegetation Inspections: As opposed to risk-based vegetation inspections, routine inspections
consist of cycle-based tree trimming, focused on about 1,500 miles (20% of the system) annually.

Run-to-Failure: A maintenance approach that replaces equipment only when it fails.
Avista Transmission Right-of-Way Restored with
Low-Growing Vegetation
Risk Tree

101

Rural: Areas of our service territory with small population s, often having less access to services such as
firefighting. This is typically an area with a population of less than 1,000 persons per square mile as
determined by the U.S. Census.

SAIDI: SAIDI refers to “System Average Interruption Duration Index.” It is calculated by multiplying the
average duration of customer interruptions by their total number and then dividing by the total
number of customers in the system. SAIDI describes the total duration of the average customer
interruption. It is calculated by dividing the sum of all customer interruption minutes by the
number of customers served (for a year).

SAIFI: SAI I refers to “System Average Interruption requency Index.” It describes the average number
of non-momentary interruptions a customer experiences in a year (not including major event days).
It is calculated by dividing the total number of customer interruptions by the average number of
customers served during a year.

Safe Tree Program: This is a partnership with private landowners to remove risk trees on their
property to reduce the chances of their trees contacting powerlines and creating fire potential or
loss of reliability. At Avista this program is offered to customers in high fire threat (typically WUI 2
or 3) areas who have trees likely to come into contact with our powerlines. At the customer’s
request the tree is removed, the debris cleared, and a new low-growing tree is planted in the same
place (if they wish to do so) at no cost to the customer.

Safety Hazard: A condition that poses a significant threat to human life or property.

Sag: For overhead transmission lines, sag is
the difference between the point of
support, being the transmission pole or
tower, and the lowest point on the
conductor. Calculating sag is critical, as
conductor must be held at a safe tension
level to ensure that it does not break
under its own weight or the added weight of snow and/or ice or as it is stressed by wind, loads, or
ambient temperatures. Engineers also carefully calculate the amount of sag to ensure that the
conductor remains a safe distance from the ground. This is especially tricky when the line is on
uneven terrain.

Satellite Imaging: In Avista’s Wildfire Plan, this means using satellites to capture
images of the distribution system to detect vegetation issues and changes in
vegetation over time. Satellite-powered artificial intelligence systems such as
that used by Avista can predict vegetation growth years in advance. Satellite
imaging works well for the distribution system, which is more widespread
and convoluted than the transmission system and is located in a wide variety
of environments not always accessible or visible from the aircraft used to collect LiDAR images.

102

Severe Fire Danger Index (SFDI): This is a forecastable metric that can help forecast extreme fire
conditions based on historical data related to fire intensity and spread potential. When this data is
combined with current wildfires it helps predict fire intensity, potential resulting dam age and loss
of life. This metric helps firefighters and communities by providing critical information to help
improve early warnings and situational awareness. When we are entering Fire Safety Mode, Avista
overlays this information over our service territory, and when it indicates any “extreme” levels we
declare Fire Safety Mode operations.

Situational Awareness: ools designed to identify and manage risk, primarily Avista’s ire Weather
Dashboard and WUI Map. In the future this will include weather stations and wildfire cameras.

Slash: Branches or limbs less than four inches in diameter, and bark and split product debris left on the
ground as a result of utility vegetation management or other vegetation management work. Slash
can become a fuel for wildfires.

Span: The space between adjacent supporting poles
or structures on a circuit consisting of electric
lines and equipment.

Spark Ignition Event: A situation when something
such as equipment failure creates a spark that can potentially lead to a fire.

Spark Ignition Potential: The risk of heat (usually via spark or arc) creating the ability for a fire to start,
spread, and do damage.

Spark Ignition Source: Something that
creates a spark that may lead to a fire under
the right circumstances, such as a failed piece
of equipment, blown fuse, or conductor that
touches dried vegetation on the ground.

Steel Conversion: One of Avista’s wildfire resiliency strategies is to replace wood transmission poles in
areas at an elevated risk of fire with steel, as steel is less likely to be damaged and fail when
exposed to fire or other damage risk.

Strike Distance: A term used to describe a tree that has the potential to impact powerlines and
other equipment.

Supervisory Control & Data Acquisition: Control system architecture comprising computers,
networked data communications and graphical user interfaces (GUI) for high-level process
supervisory management, used to monitor and control a variety of critical infrastructure in
manufacturing, power generation, and other complex circuit infrastructure. It provides the ability,
for example, to monitor and control reclosers to isolate and/or reroute power during outages or

103

fire events. SCADA provides insights for operators
into the operation of the system in addition to
helping them remotely control and operate it.

Substation SCADA / Substation Fire Safety Mode
Automation: Provides automation that allows
remote control and operation of substation
equipment to allow it to respond more quickly if fire
conditions indicate elevated risk. In Avista’s Wildfire
Plan, fifteen remote substations located in high fire
risk areas will be upgraded with communications
equipment and hardware/software that allows them to
support fully automated Fire Safety Mode operations.

Surface Fuels: Loose surface litter on the soil surface, normally consisting of fallen leaves or needles,
twigs, bark, cones, and small branches; also grasses, forbs, low and medium shrubs, tree seedlings,
heavier branches, downed logs, and stumps interspersed with or p artially replacing the litter. These
fuels are more susceptible to fire and fire spread as they tend to react to humidity and dry out
more quickly.

Sustained Outage: The IEEE defines a sustained
outage as a disruption in power supply lasting
more than five minutes. It is the de-energized
condition of a line resulting from a fault or
disturbance following an unsuccessful automatic
reclosing sequence and/or unsuccessful manual
reclosing procedure.

Switch: A disconnection point used to interrupt the flow of electricity.
Switches can be mounted on overhead lines, on underground lines , and in
substations. Switches mounted overhead and underground are used as a
disconnection point as well as a sectionalizing device. During outages the switch can be opened in
order to sectionalize the faulted or damaged part of the circuit. Switches mounted in a substation
can be used to isolate devices in a substation, such as a regulator, to protect them in case of fault.

System Average Interruption Duration Index (SAIDI): SAIDI is a system-wide tally of the total number
of minutes per year of sustained outage per customer served. It is measured in units of time,
usually minutes or hours, and is measured over the course of a year. It basically measures the
average length of time an average customer is without power over the course of a year.

System Average Interruption Frequency Index: SAIFI is the average number of sustained interruptions
per customer during the year. It is the number of non-momentary outages the average customer
experiences in a year.

Air Switch in open position
Air switches waiting to be
installed.
Simplified SCADA Diagram

104

Third-party Contact: Contact between a piece of electrical equipment and another object, whether
natural (tree branch) or human (vehicle).

Tiers: In Avista’s Wildland Urban Interface, the power system is divided into sections based upon the
risk of a fire occurring and having impact. These are called Tiers and include: Tier 0 (Low or no risk),
Tier 1 (Moderate), Tier 2 (Elevated), and Tier 3 (Extreme).

Transmission: Electric facilities that have a voltage of 60 kV or above.

Transmission Corridor: The right-of-way
associated with a transmission line in
which the utility has the right to remove
vegetation that may interfere with the
line.

Transmission Line Inspection: Avista
uses ground patrols, aerial inspections, and LiDAR data to inspect their
transmission lines and structures each year. Transmission inspections are
regulated by NERC and, in the Western Grid, by WECC (Western
Electricity Coordinating Council) requirements.74

Transmission Steel Conversion: Avista’s effort to replace wood poles specifically in areas with elevated
fire risk with steel poles to protect both infrastructure and customer reliability. The Company has
experienced wildfire burning through steel pole lines with no impact from the
fire.

Tree Fall-In: Trees (or limbs) that are dead, dying, or damaged by illness, by
lumberjack errors, storms, etc. that fall and come into contact with powerlines,
often causing an outage.

Tree Grow-In: Trees planted under powerlines that over time grow into and contact
those lines.

Trip and Reclose: (T/R) A trip and reclose occurs when a circuit breaker is able to
clear a fault and quickly restore power by closing the circuit breaker to put the
line back in service.

TX: Transmission.

Undergrounding: Undergrounding is the replacement of overhead distribution powerlines with
underground cables. In Avista’s current Grid Hardening efforts, select portions of distribution
overhead line will be converted to underground facilities where feasible and cost justified. In the

74 FAC-501-WECC-2: Transmission Maintenance, WECC-0120 Posting 5 FAC-501-WECC-2 Transmission Maintenance Posting 5 Clean (nerc.com)
Tree Fall-In
Tree Grow-In
Avista Transmission
Corridor
Transmission Work on Chelan-
Stratford 115 kV line

105

new Enhanced Grid Hardening Program, areas of our distribution system at particularly high risk
will be undergrounded based on extensive analysis. Converting facilities to underground fully
mitigates potential spark-ignition risk.

Unplanned Outage: Electric outage that occurs with no advance notice from the utility.

Urban: Population centers such as cities and towns, typically having access to firefighting resources.
Includes areas with a population of more than 1,000 persons per square mile as determined by the
United States Bureau of the Census.

Utility-Related Ignitions: Ignitions involving utility infrastructure or utility employees as determined by
official investigation.

Vegetation Issues: This typically means trees and other vegetation that
has the potential to or has contacted powerlines and which is likely to
cause an outage.

Vegetation Management, Risk-Based: Under
Avista’s Wildfire Plan, risk tree inspections are
increased to 100% of non-urban polygons in an
effort to mitigate the potential for vegetation to
contact powerlines and create an outage or
spark event.

Vegetation Management, Routine: Trimming, removal, and other
remediations of vegetation used to maintain utility right-of-way
and reduce the risk of outages, ignitions, or other disruption and
danger. At Avista, routine vegetation management is five-year
cycle with 20% of the system completed each year.

Vegetation Risk Index: Risk index indicating the probability of vegetation-caused outages and/or the
potential for ignitions along a particular circuit based on the vegetation species, density, height,
growth rate, etc.

Vulnerable Populations: The State of Washington defines vulnerable populations as people who are
unable to care for themselves, have a developmental disability, or receiving healthcare services.75

Wedge Connected Stirrups: The traditional hot line tap is attached via a
bolt. Over time this type of connection can come loose, arc and spark,
and melt through the conductor, dropping it to the ground. The
wedge connected stirrup device prevents the hot tap from being
directly connected to the conductor. The stirrup attaches in such a

75 Washington State Dept. of Social & Health Services, “Vulnerable Adult,” Vulnerable Adult | DSHS (wa.gov)
Wedge Connected
Stirrup
Vegetation Issues

106

way that if the connection loosens and if the stirrup melts, the conductor is still intact and does not
fall to the ground. A wedge connected stirrup is a more permanent connection to the powerline
than a hot tap.

Wildfire Impact/Consequence: The effect or outcome of a wildfire affecting objectives, which may be
expressed in terms including, although not limited to, health, safety, reliability, economic and/or
environmental damage.

Wildfire Mitigation Plan: A
thoughtful approach to
addressing the utility’s
responsibility in
preventing their
equipment from starting
a wildfire, while at the
same time protecting
assets paid for by
customers.

Wildfire Programs:
Activities, practices, and
strategies that are only
necessitated by wildfire
risk beyond that required by minimum reliability and/or safety requirements. Such programs are
not indicated or in common use in areas where wildfire risk is minimal (e.g., territory with no
vegetation or fuel) or under conditions where wildfires are unlikely to ignite or spread (e.g., when
rain is falling).

Wildfire Risk: The potential for the occurrence of a wildfire event expressed in terms of ignition
probability and wildfire impact/consequence, and the likelihood that an ignition will grow to
become a large or rapidly growing wildfire due to dry vegetation and weather conditions.

Wildfire Risk Reduction: The average percentage difference between the current state of risk and
future state risk levels as wildfire measures are implemented.

Wildland Urban Interface: Or WUI, is the zone of transition between wilderness (unoccupied land) and
land developed by human activity; basically, where the natural environment (typically forested
areas) meets the built environment. Homes and businesses located in WUI zones are most at-risk
from the impact of wildfires, as they are often located in rural areas lacking adequate fire
suppression resources. The WUI map helps to identify and prioritize these areas of greatest risk and
serves to inform the recommendations and operational decisions related to wildfire resiliency.
Using a WUI map specific to our service territory, we can target our programs where they have the
potential to reduce the most risk and have the greatest positive impact in the safety and protection

107

of our customers and infrastructure.76

Wire Down: Instance where an electric transmission or distribution conductor is
broken and falls from its intended position to rest on the ground or on a
foreign object. If the conductor contacts dry materials on the ground and is
live, the sparks created can lead to a fire.

Wood Pole Wraps: Avista uses Genics Fire Mesh, a wire mesh treated with an
intumescent material that, when exposed to extreme heat, rapidly expands to
form a barrier between the fire and the wood pole. These wraps help prevent
low-burning fires from accessing wood poles, protecting them from damage or
destruction.

76 Source of map: USDA/USFS “Understanding the Wildland-Urban Interface (1990-2020),” September 20, 2023, Understanding the Wildland Urban
Interface (1990-2020) (arcgis.com)
’ Mesh Pole
Wrap Test
Percent of
Homes in the
WUI by County

108

Appendix A: Avista’s Wildfire Public Safety Shutoff
Plan Summary

Based on Avista’s PSPS Plan Version 1.0 – July 2024

Summary of Avista’s PSPS Plan
202 represents Avista’s first year of implementing a Public Safety Power Shutoff (PSPS) Plan. As part
of its operational mitigation strategies, Avista developed a PSPS Plan to guide the assessment and
decision making process when determining whether to proactively de-energize electrical facilities in
areas identified as being at extreme wildfire risk, times when conditions are so severe that it is deemed
unsafe to operate our electrical facilities. This effort reduces the potential of those electrical facilities
becoming a wildfire ignition source or creating safety concerns for our customers, communities, and
employees. The PSPS Plan identifies relevant considerations, decision process flow, and
implementation protocols before, during, and after a PSPS event, subject to the recognition that each
situation is unique and that actual considerations and/or actions will vary depending on the
circumstances. In general, the Plan will be active durin g wildfire season (typically June-October),
reviewed annually, and updated as necessary prior to the start of each wildfire season.

Note that nothing in this Plan supersedes the general authority of the Company to de -energize a power
line during an emergency or as requested by firefighters, and a decision (i.e., to protect fire response
personnel or to protect company assets from fire damage) might be made without complying with the
notification and outreach sections of the PSPS Plan. In addition, extreme weather events are, by their
nature, unpredictable and unique, so the specific considerations applicable to any decision regarding
possible de-energization may vary based on each individual circumstance. Based on the inherently
disruptive nature of power outages, PSPS events must be carefully evaluated to balance wildfire risk
with potential PSPS impacts on Avista customers and the communities we serve. Thus, a planned de-
energization is a measure of last resort to reduce public safety risk.

The key goals Avista considers as foundational for the PSPS Plan are listed below:

• Advancing the safety of customers, communities, and Avista employees

• Collaborating with key external stakeholders (agencies, counties, local governments, public
safety partners, tribes and first responders)

• Minimizing both potential wildfire risk and power outage impacts to communities and
customers

• Maintaining reliable electric service

As described in the report above, Avista uses a customized WUI map to identify areas at highest risk of
wildfire occurrence and impact. Communities such as Chewelah and Colville border national forest

109

lands, as do many other areas including Sandpoint, St. Maries, Grangeville, and portions of the
Lewiston/Clarkston Valley, placing them at higher risk. Spokane County, having seen significant
population growth, also has an increasing number of housing developments within high fire threat
areas, increasing the risk of wildfire impacts. According to our current WUI map, approximately 2,746
miles of electric distribution lines are in high fire risk areas, or about 36% of the system. In 2023 the
Company identified the top 25 most at-risk distribution feeders across our service territory in the
Spokane, Coeur d’Alene, Sandpoint, Kellogg, and rangeville areas.77 This list is based on the Avista Fire
Weather Dashboard, the WUI map, historic wildfires, historic outage data, and scenario planning.
These are the feeders most likely to experience a PSPS event, but this list does not preclude Avista
from initiating a PSPS on other circuits in its service territory and the list may change over time.

At this time, PSPS is only being considered for use on Avista’s electric distribution system; use of PSPS
on Avista’s transmission system is not currently part of this PSPS plan. Avista’s transmission system is
part of the Bulk Electric System (BES) which requires strict operational standards for maintaining
integrity of the grid. Additional analysis of the impacts of PSPS on Avista’s transmission system and
development of the process to implement a transmission PSPS are required before being incorporated
into this Plan.

Preparation
Each year as Avista prepares for fire season, we engage with public safety partners, state and local
governments, critical facilities, tribal partners, communities, and customers regarding wildfire
prevention and Wildfire Resiliency Plan mitigation activities, as well as to provide education in safely
and effectively implementing the PSPS plan. The Director of Electrical Engineering along with the
Wildfire Resiliency Manager coordinate and facilitate activities of multiple Avista business units for
wildfire prevention and mitigation activities including Fire Safety Mode and PSPS operations, while
Business & Public Affairs, Customer Solutions, and Corporate Communications facilitate public
outreach and coordination efforts with external stakeholders. Coordination with agencies like the
Washington State Dept. of Natural Resources (DNR) and Idaho Dept. of Lands (IDL) are part of this
work.

Decision-Making
As a general matter, Avista would initiate a PSPS if the Company determines, based on the
circumstances and information available at the time, that a combination of critical conditions at certain
locations creates a consequential risk of wildfire ignition and severe resulting harm, and that those
risks outweigh the corresponding risks associated with initiating the PSPS. As described earlier in this
report, the Fire Risk Index (FRI) generated by the Fire Weather Dashboard will be one of the deciding
factors. As a reminder, these levels are:

1) Green (Low)—Risk of fire spread is low to near zero e.g., typical winter conditions: FRI score

77 Details are available in Avista’s Public Safety Power Shutoff Report located on Avista’s website: Public Safety Power Shutoffs (myavista.com)

110

of 0 – 4.0.

2) Blue (Moderate) – Risk of outage is high, while fire spread is low, or Risk of outage is low,
while fire spread is high, or Risk of outage is moderate and fire spread is moderate: FRI score of
4.1 - 5.4.

3) Yellow (High) (Extreme FSM) – Risk of outage is high, while fire spread is moderate, or Risk of
outage is moderate, while fire spread is high, or Risk of outage is high and fire spread is high:
FRI score of 5.5 - 6.4.

4) Orange (Very High) (Extreme FSM) – Risk of outage is extreme, while fire spread is high, or
Risk of outage is high, while fire spread is extreme, or Risk of outage is very high and fire spread
is very high: FRI score of 6.5 to 6.9.

5) Red (Extreme)– Risk of outage is extreme, and risk of fire spread is extreme : FRI: >7.0

The FRI supports operational decision-making to reduce potential wildfire risk. Fire Safety Mode which
includes enhanced protection settings are used begins at an FRI of approximately 3.5, and elevating to
extreme FSM is typical at levels of 5.5. The Company will consider the possibility of initiating a PSPS
when the FRI forecast is at 7.0 or greater, and where other factors applicable to the situation warr ant
such an action. All of these levels and associated decisions are approximate, as the final decision is
based upon a number of factors such as expected accuracy of the weather forecasts, potential impacts
to customers, and other factors.

Timelines
PSPS Watch. Avista will transition from normal wildfire season operations to PSPS Watch
approximately 7-2 days prior to a potential PSPS event at the direction of the Director of Electrical
Engineering (Wildfire Lead) when conditions indicate elevated risk. During the PSPS Watch phase,
Avista will activate the PSPS Assessment Team who will meet as
needed to discuss current and forecasted weather conditions
and other critical information. An operational risk assessment
will be performed to determine, risks, and vulnerabilities. The
Director of Electrical Engineering will determine whether to
remain at a PSPS Watch, escalate to PSPS Warning, or de-
escalate to seasonal FSM operations. The PSPS Assessment Team
will decide if Avista will issue a preliminary notification of a
potential PSPS event to public safety partners, critical facilities
operators, governmental agencies, and emergency management
partners. An Emergency Operating Plan (EOP) briefing will also
be initiated as early as 7 days prior to the initiation of a PSPS
Event.

PSPS Assessment Team
• Director of Electrical Engineering
• Wildfire Resiliency Manager
• Director of Business & Public Affairs
• Electric Operations
• Corporate Communications
• Regulatory
• System Operations
• Customer Service
• Manager of Social Impact
• Legal

111

PSPS Warning. 48-24 hours in advance of a potential event if it is
believed that a PSPS outage is either probable or is already
scheduled, the full PSPS team will be placed on stand-by.
Executives will be given detailed information. Operations will
help determine which circuits should be de-energized and begin
developing a restoration plan. Impacted customers will be
contacted and are warned to take steps to prepare for an
outage. Internal stakeholders such as line crews and provisioners
will begin preparations. The utility continues to coordinate with
identified external partners such as first responders and
community support organizations to provide them with
information and develop a joint strategy.

PSPS Event. The power has been shut off. Information on all channels is continuously updated,
including the outage map, to keep customers informed about the situation and when the Company
expects to restore power.

PSPS End. An “all clear” is issued based on weather projections and in consultation with necessary
parties. At this point, Avista determines that the threat has ended and that it is safe to begin making
repairs. Crews are organized and dispatched. This process may take several days. Communications will
continue to be a priority. It is important that customers are kept informed throughout this process,
including estimated restoration time.

Restoration
One of the challenges when using PSPS is the process of re-energization.
Power restoration following a PSPS is akin to a major storm. In traditional
utility restoration efforts, the priority is to restore service to as many
customers as possible through line switching and by isolating faulted
circuits. Restoration efforts may also include a consideration of customers
most heavily impacted by outages or located in Named Communities.

If a utility de-energizes lines for a PSPS event, facilities cannot be re-energized until all impacted
circuits and lines are thoroughly inspected or patrolled to ensure that the situation is safe. After
inspection, lines are re-energized segment by segment. Patrol of all impacted overhead electric
facilities can only commence once the weather event has subsided and it is safe for crews to enter the
area. Restoration following a typical PSPS event normally requires three to six days depending upon
the location, crew availability, the total number of lines to be inspected, and other factors. For this
reason, several PSPS events in California have taken up to 14 days for full restoration. Restoration
efforts following a PSPS will always require additional time to fully inspect each circuit and line even if
they weren’t damaged during the weather event and must account for the fact that a situation that
would lead to a PSPS is likely to cause damage system -wide, not only on PSPS circuits.
Full PSPS Team
• PSPS Assessment Team plus:
• Wildfire Executive Committee
o President and COO
o VP of Energy Delivery
o VP of Community Affairs &
Chief Customer Officer
o Sr. VP and General Counsel
o Sr. VP CFO Treasurer
o Regulatory Affairs Officer
o Director of Corporate
Communications

112

Customer Communications & Support
Strong partnerships have been developed between Avista and local public safety and health
organizations, other utilities, tribal and community leaders, and emergency management agencies to
assist in the coordination for any event which impacts the communities we serve. Avista will serve as
the initiating agency in the event of a PSPS and will coordinate with all local agencies as appropriate. If
requested, an Avista employee may be dispatched to the affected State or County Emergency
Operations Centers in the role of Liaison Officer and will provide a constant and direct conduit for
information.

As discussed previously in this report, multiple channels of communication will be used before, during,
and after a PSPS event. Avista Regional Business Managers will maintain regular outreach with local
jurisdictions including voice and email notifications during the event with specific information about
the location of a PSPS event and estimated restoration times. This information is also included on our
website and outage map. As mentioned previously, Avista has a Customer Service CARES Team which is
engaged with medically vulnerable customers and acts as a liaison to support those customers and any
who are identified as being on life support.

Another way Avista will support customers during a PSPS event is to operate Community Resource
Centers (CRCs). CRCs are an integral part of ensuring that customers affected by PSPS events have
access to basic resources and up-to-date information during a PSPS event. Avista utilizes a contracted
vendor, FireDawg, for logistical support in deploying CRCs. CRCs will be activated once a PSPS de -
energization is imminent. The center(s) will generally be open from the beginning of a PSPS event until
final re-energization, with typical hours of operation being 8 am to 8 pm. CRCs generally include air
conditioning, electronic and medical device charging, snacks/water/ice, and information regarding the
outage. Avista will utilize brick-and-mortar facilities for CRC locations unless such a facility is not
available, in which case FireDawg will deploy a large generator-powered trailer or tent. Avista
personnel, Community Resource Ambassadors, and the contracted vendor will staff the center(s) to
assist and provide information to customers in need.

Avista has identified many potential locations for CRCs throughout the service territory based upon
estimated customer needs. The work of formalizing agreements and securing additional locations for
CRCs is ongoing and will continue into 2025. Avista is working both internally and externally with local
public safety partners, other community partners, and tribal leadership to identify appropriate CRC
sites. In most circumstances one CRC location will be established within each de-energized area and
will provide the ability for the community to have specific needs met during a PSPS event.

In 2024 the Company reached out to over 14,000 first responders, emergency managers, critical
customer groups, service providers, health organizations, city and county leaders, state agencies, and
others to provide education around our PSPS Plan and to strategize about protecting and supporting
customers through potential outages. Details of this engagement can be found in the tables below.

113

Date:Agency/Event:Representatives:Attendees:Topics:
January 29th Horizon Hospice Executive Director and Case Manager 3 Potential implications of PSPS and extended outages and opportunities to
partner together
February 8th
Lakeland
Village/Eastern State
Hospital
Managers of Facilities at Eastern State Hospital and Lakeland
Village 5 Implications of upcoming PSPS and discussing opportunities for
communication and collaboration during emergency events
March 14th
Idaho Office of
Emergency
Management, North
Central Region
Emergency Managers from Clearwater, Latah, Lewis, Idaho, Nez
Perce, City of Lewiston, National Weather Service, Kootenai
Health, Public Health North Central District and Nez Perce County
17 Shared about PSPS, discussed medically vulnerable customers, questions
about length of outage, CRCs
March 21st North Idaho Healthcare
Coalition
Kootenai Health, Kootenai County EMS, North Central Health
District, Panhandle Health District 20-25 Discussed impacts of PSPS and introducing the topic to the group, also
discussed work with medically vulnerable customers
March 22nd
Community Resilience
& Vulnerable
Populations Luncheon
Executive Directors of Providence, Multicare, Aging & Long Term
Care of EW; representatives from WA State DOH, Spokane
Regional Health District, DSHS, Horizon Hospice, Indian Health
Services
15-20
Discussed impacts of PSPS and how we can continually improve our reach
and service to medically vulnerable customers. Also discussed continued
desire to partner together
April 10th Shoshone County LEPC 17 Discussed Wildfire Resiliency and PSPS, questions about medically
vulnerable, backup generation
April 11th Bonner County LEPC 22 Discussed Wildfire Resiliency and PSPS, questions about medically
vulnerable, backup generation
April 17th Benewah County LEPC 16 Discussed Wildfire Resiliency and PSPS, questions about medically
vulnerable, backup generation
April 18th
Idaho County Local
Emergency Planning
Committee
Cottonwood Fire Dept., North Idaho Healthcare Coalition, Public
Health N. Idaho, Elk City Fire Dept., Idaho County Mapping,
Harpster Fire Dept., Idaho Office of Emergency Mgmt., 3 Rivers
Ham Radio, Lewis County Ham Radio, Idaho County Emergency
Mgmt. and Idaho Dept. of Lands
17 Discussed PSPS, questions about medically vulnerable, length of outages,
CRCs
April 23rd City of Spokane City of Spokane Mayor and Cabinet 18 Discussed PSPS and medically vulnerable customers, other partnerships
and data sharing opportunities
May 2nd Spokane Fire Chiefs
Meeting
Spokane Fire Chiefs, Providence Emergency Manager, Dept. of
Natural Resources, Spokane County 18-20
Discussed PSPS and changes to Fire Safety Mode (FSM), discussed water
resources, where to send information about potential PSPS event and
water resources in event of wildfire
May 6th
Public Health
Emergency Planning
Region Meeting (9 East)
Spokane Regional Health District, NE Tri-County Health, Whitman
County Public District, Lincoln County Public Health, Adams County
Health District
12-14 Discussed PSPS and medically vulnerable customers, wells and
wastewater treatment
May 7th
Press Conference
regarding PSPS
presented by Heather
Rosentrater (President
and CEO of Avista)
Partners: City of Spokane, Spokane County, Dept. of Natural
Resources and Idaho Dept. of Lands, Spokane County Fire Chiefs 20-24 Provided an overview of PSPS and the importance of partnerships helping
keep our communities safe
May 8th
Lewis County
Emergency Planning
Committee
Lewis County Emergency Mgmt., Lewis County Sheriff, 3 Rivers
Amateur Radio, Idaho Transportation Dept., City of Nez Perce,
Kamiah Fire Protection, National Weather Service, Nez Perce
Tribe, Craigmont Rural Fire Dept., Winchester Rural Fire Dept.,
Public Health North Central District, Lewis County Commission and
City of Nez Perce Planning and Zoning,
17 PSPS discussion, questions about communication timeline, length of
outage, backup generation for wastewater treatment plants
May 8th CDA Executive Round
Table 35 Discussed Wildfire Resiliency and PSPS, questions about medically
vulnerable, backup generation, water resources for rural customers
May 13th
Community Response
for Vulnerable
Population During
Outages
Spokane County, Spokane Transit, WSDOT, Spokane Regional
Health District, Aging and Long Term Care of EW, Spokane
Neighboorhood Action Partners, Disability Action Center NW,
International Rescue Committee
18
Discussed PSPS/medically vulnerable customers and strategized about
most important issues for vulnerable populations and things we should be
focused on going forward
May 13th City of Spokane Fire
Chiefs
Spokane Fire Chief, executive chief staff, wildland planner,
wildland group battalion chiefs 12 Discussed PSPS and updates to FSM, discussed medically vulnerable
customers and continued efforts to partner together for outreach events
May 14th,
Panorama Counties
School and Community
Emergency Responders
Meeting
Stevens County, Kettle Falls School District, ESD 101, Newport
School District, Pend Oreille School District 12-14 Discussed PSPS and using schools as potential CRC locations
May 14th Stevens County
Commissioners Meeting
Stevens County Commissioners, Stevens County Emergency
Manager, Fire Personnel 15 Discussed PSPS and Wildfire Resiliency Program
May 15th Medical Lake Recovery
Group
Agencies and organizations around the community who assist in
disaster recovery 80 Discussed PSPS and Wildfire Resiliency Program
May 16th Providence Hospitals Providence Emergency Manager and Facilities Managers 5 Discussed PSPS for the hospitals, best points of contacts, backup
generation
May 20th Commercial and
Industrial Accounts Various industrial and commercial accounts Discussed PSPS and Wildfire Resiliency Program answered questions from
group
May 20th
Washington State
Department of Social
and Health Services
DSHS employees from around the state 70+
Discussed PSPS and the implications of DSHS facilities, discussed
communications and implored folks to discuss this topic with their local
municipalities
May 22nd Kootenai County LEPC 25 Discussed Wildfire Resiliency and PSPS, questions about medically
vulnerable, backup generation, water resources for rural customers
May 24th
Asotin County Local
Emergency Planning
Committee
Asotin County Dept. of Emergency Mgmt., Washington State
Emergency Mgmt., Nez Perce County/City of Lewiston Emergency
Mgmt., Garfield County Emergency Mgmt., National Weather
Service, Avista, City of Asotin Mayor, Asotin County Public Works,
Asotin County Commission, Asotin County Conservation District,
Asotin County Fire Chief, Asotin County Sheriff, Asotin County
Health District, Tri State Health.
15 Discussed PSPS and questions about length of outages, communications
prior to PSPS event
Wildfire Outreach Summary 2024

114