20250131Direct V. Malensky_Exhibits.pdf

RECEIVED
Friday, January 31, 2025
IDAHO PUBLIC
UTILITIES COMMISSION
DAVID J. MEYER
VICE PRESIDENT AND CHIEF COUNSEL FOR
REGULATORY & GOVERNMENTAL AFFAIRS
AVISTA CORPORATION
P.O. BOX 3727
1411 EAST MISSION AVENUE
SPOKANE, WASHINGTON 99220-3727
TELEPHONE: [phone]
FACSIMILE: [phone]
[e-mail]
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION ) CASE NO. AVU-E-25-01
OF AVISTA CORPORATION FOR THE )
AUTHORITY TO INCREASE ITS RATES )
AND CHARGES FOR ELECTRIC AND ) DIRECT TESTIMONY
NATURAL GAS SERVICE TO ELECTRIC ) OF
AND NATURAL GAS CUSTOMERS IN THE ) VERNON L. MALENSKY
STATE OF IDAHO )
1
FOR AVISTA CORPORATION
(ELECTRIC ONLY)

1 I. INTRODUCTION
2 Q. Please state your name, employer and business address.
3 A. My name is Vernon L. Malensky and I am employed as the Director of Electrical
4 Engineering for Avista Corporation (Avista or Company), In this role I also lead Avista's
5 Wildfire Resiliency Program. My business address is 1411 East Mission Avenue, Spokane,
6 Washington.
7 Q. Would you briefly describe your educational background and professional
8 experience?
9 A. Yes. I graduated from the University of Idaho in 2006 with a B.S. in Civil
10 Engineering. I am a registered professional civil engineer in the State of Washington and the
11 State of Idaho. I joined Avista in 2012 after spending six years with T-O Engineers, Inc. (now
12 known as Ardurra). Since joining Avista in 2012, I have held various positions supporting
13 both natural gas and electric operations,including Gas Design Engineer,Project Manager(Gas
14 Control Room and Washington Advanced Metering Infrastructure), Manager of Washington
15 Advanced Metering Infrastructure, Manager of Engineering Projects, Gas Operations
16 Manager, Manager of Gas Compliance and Integrity Management, and Manager of Energy
17 Efficiency Engineering.
18 In 2022, I became the Director of Electrical Engineering where my primary
19 responsibilities include management and oversight of transmission line design, distribution
20 engineering, substation engineering, system protection engineering, as well as project
21 management and construction services and design for the Spokane region. In 2023, my
22 primary responsibilities transitioned to also include management and oversight of joint use
23 services and the wildfire resiliency program.
Malensky, Vern 1
Avista Corporation

I Q. What is the scope of your testimony in this proceeding?
2 A. My testimony and exhibits discuss the status of the Company's Wildfire
3 Resiliency Plan("Wildfire Plan"or"Plan"), reiterate its goals and objectives, and summarize
4 the technical and operational aspects of the Plan. Avista's Wildfire Plan reflects the
5 Company's 135-year operating history combined with Avista's efforts to quantify and respond
6 to the financial, safety-related, and service reliability risks associated with wildfires. While I
7 discuss this plan in detail within my testimony and exhibits, Company witness Ms. Andrews
8 sponsors the O&M expense adjustment associated with the Company's Wildfire Plan and
9 reflected in the Wildfire balancing account,and Company witness Ms. Benjamin includes any
10 capital additions that transfer to plant prior to or during the Two-Year Rate Plan as proposed
11 by the Company, within her capital adjustments.
12 A table of contents for my testimony is as follows:
13 Description Page
14 I. Introduction 1
15 II. Elements of the Wildfire Plan 4
16 A. Enhanced Grid Hardening 5
17 B. Enhanced Vegetation Management 8
18 C. Enhanced Situational Awareness 11
19 D. Enhanced Operational Readiness 12
20 III. Program Costs 22
21 IV. Summary of Recent Improvements 28
22
23 Q. Are you sponsoring exhibits in this proceeding?
24 A. Yes. I am sponsoring Exhibit No. 11, Schedules 1 8:
25 • Schedule I —Avista 2024 Wildfire Resiliency Plan
26 • Schedule 2 -Avista 2024 Wildfire Resiliency Communications Plan
27 • Schedule 3 —Avista Distribution Risk Tree Program - Iapetus Report
28 • Schedule 4 -Vegetation Management Third Party Evaluation Summary
29 • Schedule 5 - Avista Washington State Mandated Wildfire Resiliency Report
30 Pursuant to HB 1032
31 • Schedule 6 -Avista Wildfire Public Safety Power Shutoff Plan 2024
32 • Schedule 7 -Avista Exponent Undergrounding Report October 30, 2024
Malensky, Vern 2
Avista Corporation

I • Schedule 8—Wildfire Resiliency Business Case
2
3 Q. What was the intensity of the 2024 fire season specific to Idaho?
4 A. The Idaho Dept. of Lands (IDL)reported 301 wildfires on their public lands in
5 Idaho in 2024 compared with 284 in 2023. The National Interagency Fire Center reported a
6 total of 1,453 wildfires across Idaho in 2024, up from 892 wildfires in 2023, with 826,000
7 acres burned versus the number of acres burned in 2023, which was at a twelve year low at
8 only 87,801 acres.' Major areas impacted included the Boise and Payette River regions. IDL
9 provided information on the 2024 fires for Illustration No. 1 below.
10 Illustration No. 1 —2024 Idaho Wildfires
I I Idaho Number of Wildfires Incidents:2024
2024 Idaho Fires Railroads
12 Misuse of fire bya minoi
-Wr Iq Arson 0
13 FPO"- Fireworks Q
Power/Utility Q
Recreation/Ceremony
14 Caused, 184, Equipment/vehide us'
' Undetermined/Other
15 Debris and open burnin
Natural mmmill
0 20 40 60 80 10'
16 Number of Incidents
17
18 Q. How did wildfires impact Avista infrastructure in the 2024 fire season?
19 A. One of the biggest fires in our service territory was the Gwen Fire near
20 Juliaetta, Idaho, that started on July 24 (lightning caused) and burned nearly 30,000 acres.2 It
21 destroyed 38 homes and businesses as well as 122 outbuildings. Avista lost 14 transmission
22 poles and 4 distribution poles in this fire. The County Line Fire near Plummer, Idaho, burned
t Statistics I National Interagency Fire Center and YTD-State and Agency
2 InciWeb: Idids 2024 Gwen Fire- I InciWeb
Malensky, Vern 3
Avista Corporation

1 192 acres and destroyed several structures on our Benewah-Pine Creek 230 line.3 A fire near
2 the Shawnee Substation destroyed 7 distribution poles. Altogether in 2024 Avista lost 38
3 transmission poles and 13 distribution poles to wildfire. This compares to 2023 when we lost
4 3 transmission structures and 264 distribution structures,primarily as a result of the Gray Fire
5 in the State of Washington.
6
7 II. ELEMENTS OF THE WILDFIRE PLAN
8
9 Q. Please describe the primary elements of the Wildfire Plan.
10 A. Avista has developed a wildfire strategy and mitigation effort focused in four
11 primary areas:
12 • Grid Hardening—this involves investing in electric infrastructure to reduce spark-
13 ignition outage events and to protect critical assets from the impact of wildfires at
14 the distribution level, including replacing wood crossarms with fiberglass,
15 replacing small wire, adding protective devices, undergrounding, and more. The
16 Company also invests at the transmission level,replacing wood poles with steel or
17 wrapping them with a fire-resistant protective cover in high fire risk areas. The
18 Company is also developing an Enhanced Grid Hardening program which involves
19 undergrounding high fire risk sections of the distribution system.
20
21 • Enhanced Vegetation Management — This includes 100% risk tree inspection in
22 non-urban areas each year, the addition of digital data collection (LiDAR and
23 satellite images), Fuel Reduction Partnerships, and the Safe Tree Program. In
24 accordance with the direction of the Idaho Public Utilities Commission (IPUC),
25 we also had a third-party study the effectiveness of this program and the preferred
26 inspection cycle. The results of this study are attached as Exhibit No. 11, Schedule
27 3 (Avista Iapetus Risk Tree Report Final Delivered) and Schedule 4 (Avista
28 Vegetation Management Third Party Evaluation Summary).
29
30 • Situational Awareness — these are elements designed to help us identify and
31 respond to risk, including the Avista WUI map, the Fire Weather Dashboard,
32 installation of wildfire identification cameras and localized weather stations.
33
34 • Operations and Response—this area is focused on automating our system to allow
35 remote control and operation of key equipment including Fire Safety Mode
36 automation devices(midline reclosers, SCADA installations)as well as Fire Safety
s Coeur d'Alene/Post Falls Press, Sept. 3, 2024, "County Line Fire Fully Contained Near Plummer," Coun
Line Fire fully contained near Plummer I Coeur d'Alene Press
Malensky, Vern 4
Avista Corporation

I Mode and Public Safety Power Shutoff (PSPS) operations during critical fire
2 weather, as well as Expedited Response Agreements and other partnerships and
3 relationships with external agencies such as first responders.
4
5 These elements are described in more detail in Exhibit No. 11, Schedule 1 - Avista Wildfire
6 Plan 2024 Final.4
7 A. Enhanced Grid Hardening
8 Q. Please provide more information about the Enhanced Grid Hardening
9 Program.
10 A. Avista has had a strong grid hardening program in place for many years,
11 focused on improvements made to overhead distribution to mitigate wildfire risk and increase
12 reliability. These efforts protect customer reliability by reducing the risk of outages and
13 equipment failures that could potentially lead to wildfires during high fire risk periods. Avista
14 sees the value in enhancing our grid hardening and risk reduction efforts through
15 undergrounding overhead facilities in select, high risk areas. Avista is working to identify
16 areas where potential large fire growth is coupled with proximity to communities which are
17 vulnerable to total loss in the event of wildfire. These identified areas will be risk-ranked and
18 prioritized for sectional undergrounding of existing overhead conductor. This strategy will
19 reduce wildfire risk and increase safety for the communities facing the highest risk from
20 Avista's distribution electric facilities, allowing Avista to mitigate the most risk for the least
21 cost by using a surgical rather than a system-wide replacement program. As described below,
a The Company has also included,for informational purposes,Exhibit No. 11,Schedule 5,Avista's Washington
Electric Utility Wildfire Mitigation Plan Pursuant to HB1032, dated October 31, 2024. This report is a
Washington State mandated report requiring all electric utilities in the State of Washington to submit a Wildfire
Resiliency Plan in an approved format and in accordance with the elements identified by the State. This plan as
well as Avista's standard Wildfire Resiliency Plan,can be found on our website. Though the State plan format
differs from our traditional Wildfire Resiliency Plan(Exhibit No. 11, Schedule 1),they are basically the same.
Both plans reflect our commitment to partner with customers, communities, and those who manage forest
landscapes and fight fires.
Malensky, Vern 5
Avista Corporation

I Avista engaged an external consulting firm,Exponent Consulting to perform a cost-benefit on
2 this concept to help us determine the safety and reliability benefits as well as the cost of
3 undergrounding distribution lines. Exponent's report is attached as Exhibit No. 11, Schedule
4 7.
5 Q. What is the expected risk reduction from Enhanced Grid Hardening?
6 A. Part of this risk reduction involves the precise approach used to identify areas
7 for Enhanced Grid Hardening work. There are many cases where sections of distribution
8 conductors do not pose highly probable threats to nearby communities, including urban areas
9 that are largely unbumable or with available firefighting resources, or long sections of line
10 with many miles between one customer and the next.Both cases show lower wildfire risk than
11 would be necessary to invest in Enhanced Grid Hardening. However, by focusing on areas
12 where wildfire growth modeling suggests the potential for large scale loss to communities and
13 high impacts to homes and people, we should be able to create a direct risk reduction using a
14 precise, focused approach versus using a cost-prohibitive blanket undergrounding policy.
15 Q. Please describe the criteria for the Enhanced Grid Hardening Program.
16 A. Avista is currently assessing concepts including undergrounding and utilizing
17 covered conductor in high-risk sections of the distribution system based on a multitude of
18 factors. We believe that the risk can be separated into three parts: Outage Potential, Ignition
19 Potential,and Community Impact from Wildfire.For Outage Potential,Avista is consolidating
20 historic outage data, asset fragility analysis, and percent treed areas in strike zones to estimate
21 risk of an outage occurring as the result of a wind event on the overhead distribution system.
22 In the Ignition Potential category, Avista is utilizing the Wildfire Hazard Potential data,s
s This is the USDA Wildfire Hazard Potential map that quantifies the relative potential for wildfire that could be
difficult to control.Wildfire Hazard Potential I Missoula Fire Sciences Laboratory(firelab.org)
Malensky, Vern 6
Avista Corporation

I which is a summary of fuel type, slope, and exposure used to assess the burnability and
2 ignitability of a location. Lastly, Avista is using the Housing Unit/Community Impact data
3 from the U.S. Forest Service to estimate the impacts of fires moving from Avista's
4 distribution lines to nearby communities, showing potential impacts and losses if a fire were
5 to occur. These datasets are combined into one risk score that should result in a risk heat map
6 showcasing the areas of highest risk. By focusing on areas where wildfire growth modeling
7 suggests large scale loss and high impacts to homes,people,and communities,we will be able
8 to identify areas where we can create direct risk reduction.
9 We are in the process of evaluating this strategy,including application of the analytics
10 to define and prioritize risk areas across our service territory as well as identifying the best
11 approach to defining and quantifying risk using the tools described above. This program is
12 still in the feasibility stage. Starting in 2026, we added $25 million to the Wildfire capital
13 budget in support of our overall wildfire efforts, including Enhanced Grid Hardening. Once
14 this work is undertaken, we will solidify our understanding of what it takes to implement this
15 new strategy, and the actual costs and logistics involved. We anticipate that this will increase
16 our capital budgets from that point forward by an amount that will be determined after our
17 first years of experience with this program, at which time the budget will be updated
18 accordingly.
19 Q. Did Avista perform a cost-benefit analysis of this new program?
20 A. Yes. The Commission requested that we develop a formal process for
21 undergrounding distribution lines to include project criteria, a selection process, and cost-
6 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
Malensky, Vern 7
Avista Corporation

I benefit analysis for completed and future undergrounding of distribution line projects related
2 to wildfire mitigation prior to the Company's next general rate case(i.e.,this case).As a result,
3 Avista engaged an external consulting firm, Exponent Consulting,' to perform a cost-benefit
4 analysis on feeders in Avista's overhead distribution system as a means of determining the
5 safety and reliability benefits as well as the cost of undergrounding distribution lines. The
6 safety aspect considered the economic value associated with loss of life and injuries;reliability
7 considered the financial impact of service outages; direct financial impact included directs
8 costs of implementing undergrounding projects, including outage costs and operations and
9 maintenance ("O&M") costs. The cost-benefit ratio developed defined the benefits of
10 undergrounding via the sum of reduced costs over the expected life of the project divided by
11 the costs associated with undergrounding. Exponent Consulting utilized a variety of aspects
12 including estimating ranges of outages with and without an underground project, costs related
13 to these outages,maintenance costs,and reductions in wildfire risk. The results of this analysis
14 can be found in Exhibit No. 11, Schedule 7.
15 B. Enhanced Vegetation Management
16 Q. Please describe your work with a third party vendor in evaluating the
17 efficacy of Avista's vegetation management programs.
18 A. In June of 2023, Avista agreed to the following settlement terms with the
19 IPUC: "For the Distribution Risk Tree Program,Avista will have a third party conduct a study,
20 within a year of Commission Order, to see what the most efficient vegetation management
7 Exponent Consulting is an international engineering and scientific consulting firm which has been evaluating
the root cause of failures and accidents since 1967, expanding into investigations, data analysis,
statistics,cost/benefit, and best practices related to the power industry in the 1970s. They are a well-respected
industry expert in industry operations and practices.
Malensky, Vern 8
Avista Corporation

I cycle should be in their service area(i.e., 2- or 3-year cycles)."8
2 Following the agreement, the vegetation management team began work to identify a
3 potential vendor. Iapetus Infrastructure Services (IIS), a company specializing in utility
4 vegetation management and risk mitigation solutions, had introduced themselves and their
5 services to the Avista vegetation management team the previous year. These services included
6 program evaluations and outage investigations. Due to the reputation of the company in the
7 industry and with other utilities and the significant expertise offered by Iapetus,9 Avista
8 reached out to them. As Iapetus had no other dealings with Avista and were independent of
9 the vendors currently under contract, they would also be impartial regarding outcome. The
10 following Scope of Services was agreed to:
11 1) Understand the key points in Avista's distribution risk tree program to assess the
12 optimum frequency of maintenance per service area. All areas of review will be
13 made within the context of Avista's Wildfire Resiliency Plan.
14 a. Fire risk profile
15 b. Infrastructure components
16 c. Wildfire Resiliency Plan - Interviews/questions from Iapetus review of the
17 document
18 2) Evaluate Avista's risk assessment strategy
19 3)Analyze Avista's data on workload, cost, and tree failure
20 4) Understand how industry research informs the management of tree risk programs
21 a. Regional practices
22 b. Industry practices and data on tree failure
23 c. Existing practices at Avista
24 5)Present findings, model various scenarios, and provide recommendations
25
26 After several months of work, Iapetus sent their report and findings to Avista (a copy
27 is included in Exhibit No. 11, Schedule 3). The key observation from Iapetus was that Avista
28 has a reasonable and responsible approach which is aligned with "best-in-class" vegetation
s Case Nos.AVU-E and AVU-G-23-01,Order No.35909,Stipulation and Settlement page 15, Sec. 14(a).
9 For example, some of their advisors have over 40 years of experience in this industry, such as Senior Iapetus
Advisor Phil Charlton, Ph.D., who is a well-respected industry expert including being Utility Arborist
Association(UAA)Executive Director for 10 years. The Iapetus podcast"Trees&Lines:A Utility Vegetation
Management Podcast,"has thousands of followers.
Malensky, Vern 9
Avista Corporation

I programs of other major utilities. Iapetus found that Avista's approach to managing the risk
2 associated with utility-caused wildfires as an annual cycle is an effective strategy,pointing to
3 the evidence shown by the reduction in actual risk tree fall-ins, which have seen a 62%
4 reduction since the Wildfire program began in 2020. It stated that by leveraging the industry-
5 accepted UAA/ISA guide,Best Management Practices— Utility Risk Tree Assessment,Avista
6 is utilizing the most current protocol in use today by North American utilities. They further
7 noted that Avista's WUI risk tiers are aligned with the California approach to delineate high
8 fire threat districts, which is considered best practice. Iapetus' primary recommendation for
9 improvement was collecting more data about the root cause of tree-related outages,which the
10 Avista Vegetation Management Team is undertaking. The comments from Iapetus are shown
11 in Table No. 1 below. The full report can be found in the attached Exhibit No. 11, Schedule
12 3, see "Key Observations" summary at page 4.
13 Table No. 1 —Yd Party Vendor Risk Tree Program Comments
14 Ob
Consideringthe impactthat drought and tree mortality has had on forests in the Westem United States,Avista has implemented an effective strategyto reduce
15 Rhk Tree Cyrlee the pate ntial for util ity-caused wi ldfires.As the Risk Tree Program matu res,the i nventory of rl sk trees id entifi ed and re moved shou Id conti nue to red uce in
numbers as long as the goal sand objectives remain in I inewith current standards,An annual cycle is cons iste nt with best-in-class programs at other major
16 util iti es i n the West.
17 Risk Tree
Avista has taken a comprehensive approach to identify and mitigate risk treesthat pose a hazard tothe overhead distri bution system.This approach has a two-
Strategy fold benefit of reduci ng the volume of trees that can potentially result i n a uti lity-caused wildfire,aswelIas reduce the types oftree-related event thatcause
18 interruption of electrical service.
IdeitifyingRisk By I everagi ng the inclustry-accepted UAA/lSA guide,gestMonagement Practices-Udity Risk Tree Assessment,Avista is util izi ng the most current protocols in
19 Trees use today by North American Utilities to identify off-ROW risktrees that pose a hazarcl to the electri cal grid and potentially pose a wil dire risk.
Outage Avista should commit tostudyirg the root causes oftree-related outages through accurate reportingand thorough post-outage investigations.A commitment to
20 Investigatfans post-incident investigations does not mean everyoutage needs to be investigated;however,the more data,the betterthe analysis.
21 Q. What do you anticipate changing due to this third-party evaluation?
22 A. As a result of this assessment and the recommendation to study the root causes
23 of tree-related outages, the Vegetation Team is working to add an investigation program to
Malensky, Vern 10
Avista Corporation

I their portfolio, with hopes to have it in place by early 2025. It is too early to predict how this
2 will impact changes in the current program or the number of outages experienced, but the
3 team believes this work will help them target potential problem trees with even greater
4 accuracy, including gathering and analyzing data to spot trends and helping identify potential
5 gaps in current processes or scopes of work.
6 C. Enhanced Situational Awareness
7 Q. Turning to some of the elements that are new to the Plan,what is the status
8 of the use of wildfire cameras?
9 A. By the end of November 2024, nine of ten planned wildfire cameras were
10 installed(six in Washington,three in Idaho). The camera locations were chosen based on high
11 fire risk areas in Avista's service territory and in partnership with the Washington Dept. of
12 Natural Resources (DNR) and the Idaho Dept. of Lands (IDL). Three of these cameras are in
13 Northern Idaho.10 The tenth camera, located on Saddle Mountain East,just outside of Othello,
14 Washington, was installed at the end of December.11
15 These cameras almost immediately proved their value. On Thursday, August 8th,
16 2024, our Eastern Lincoln County, Washington camera detected a fire and promptly notified
17 Washington DNR. This notification triggered an immediate response from DNR aircraft and
18 ground resources. Due to the early detection and situational awareness provided, the forward
19 progress of the fire was quickly halted. While the total acreage of that incident was estimated
20 to be 20-30 acres,the DNR indicated that the fire would have been significantly larger if more
21 time had elapsed before they received accurate information on the fire's existence, location,
10 The Idaho cameras are located on Gold Mountain in the Idaho Panhandle National Forest near Sagle, Gold
Cup Mountain in Bonner County near Priest River,and Hoodoo Mountain near Blanchard,all in North Idaho.
11 The cameras in Washington are in Colville, South Spokane County, eastern Lincoln County near Ford,WA,
and in Stevens County.
Malensky, Vern 11
Avista Corporation

I and behavior. The detailed information provided by the camera allowed DNR to appropriately
2 scale their response and quickly manage and contain the situation.
3 Q. What is the value in adding local weather stations to your Situational
4 Awareness strategies?
5 A. Weather stations enhance a utility's knowledge of an area's weather situation
6 with on-the-ground observations, including indications that dangerous weather conditions are
7 approaching. Weather conditions directly affect the potential for a fire to occur and spread.
8 Weather stations can monitor relative humidity, temperatures, wind speeds and gusts, all key
9 factors in fire prediction. Regional weather stations better inform operation decisions,
10 supplement the information from the National Weather Service, and improve our information
11 when making operational decisions. This is especially important as we consider PSPS.Avista
12 is continuing to work toward installation of local weather stations in key areas of our service
13 territory. In the meantime, in 2024 the Company deployed several handheld weather meters
14 with field personnel to gather real-time weather information during fire season. Crews were
15 able to test the process of weather data collection and how it is relayed to key personnel. The
16 meters were used during Avista's PSPS event to provide weather updates from the location of
17 the outage to Operations, the Wildfire and PSPS teams, and to the Emergency Operations
18 team that was managing the PSPS event. I will discuss that PSPS event later.
19 D. Enhanced Operational Readiness
20 Q. Has the Company utilized Fire Safety Mode?
21 A. Yes. Since the early 2000s, the Company has operated distribution lines
22 located in high fire risk areas with automatic reclosing and instantaneous tripping disabled
23 during wildfire season. Traditionally this was a manual process of turning on the system at
Malensky, Vern 12
Avista Corporation

I the beginning of fire season (typically early July) and then returning to normal operation at
2 the end of Ere season (usually early October). In 2020, with the implementation of Avista's
3 Wildfire Resiliency Plan,the Company began moving to a modified protection setting scheme
4 that was aligned with Ere risk, including automated operations and remote monitoring
5 capability, including different levels of protection beyond simply on and off. These levels
6 include Base Fire Safety Mode, Extreme Protections Settings, and Public Safety Power
7 Shutoff. More details about this program are provided in the 2024 Wildfire Plan, Exhibit No.
8 11, Schedule 1.
9 In 2024 we entered Fire Safety Mode on June 26, and elevated protection settings on
10 five days, twice in August and in September and once in October, elevating 48 feeders (28
11 unique feeders) and 63 devices (37 unique devices). One feeder tripped while in extreme Fire
12 Safety Mode impacting 1,753 customers. Fire Safety Mode operations ended on October 16,
13 2024.
14 Q. Were the elevated settings used in Fire Safety Mode effective, and did they
15 work as intended?
16 A. We have learned through utilizing elevated Fire Safety Mode settings that these
17 additional safety measures do not cause a large number of outages to our customers without
18 good cause (meaning an actual event leading to a fault). During the fire weather events in
19 2023 and 2024, we elevated multiple circuits. In these two years, only two feeders tripped,
20 meaning all other circuits maintained customer service. None of the elevated circuits was
21 involved in a fire start. We believe that this experience helps prove that this strategy is
22 successful and that it operates as predicted. Further,the insights gained from actual experience
23 are allowing us to modify our thresholds for action going forward, knowing that outages that
Malensky, Vern 13
Avista Corporation

I may occur would be the result of actual impact to the system rather than strictly an estimate
2 of risk. Thus,Avista can be more conservative in risk mitigation through using these elevated
3 protection settings.12
4 In 2023 Avista did not have a formal PSPS in place but had a formal plan in place for
5 2024 and elevated to this level one time, as discussed below. Along with the PSPS plan we
6 will continue to operate Fire Safety Modes at lower thresholds than would be used for a PSPS
7 to mitigate more moderate fire weather conditions.
8 Q. Would you describe the difference between enhanced protection settings
9 (FSM) and Public Safety Power Shutoff(PSPS)?
10 A. Yes. When a PSPS, circuits are preemptively removed from service based on
11 a calculated level of fire risk. In Fire Safety Mode, circuits are only removed from service
12 when an actual fault is experienced on the line. In both cases, circuits can be out of service for
13 several hours to several days depending upon conditions, as they must be manually inspected
14 before reenergizing to ensure that it is safe to place lines back into service.
15 Q. Please provide more details about Avista's PSPS plan.
16 A. PSPS happens when electric companies preemptively turn off the power to
17 specific areas to reduce the risk of wildfires and help keep customers and communities safe.
18 It is an effort to prevent electrical equipment from starting a severe, fast spreading wildfire in
19 high fire threat areas by turning off powerlines during extreme weather based upon a
20 calculation of risk, typically when high winds and other adverse weather conditions combine
21 to increase the risk of wildfire.
22 Avista developed its PSPS Plan to mitigate this risk. Our PSPS Plan involves turning
iz This methodology has been adopted by the utilities in California as a means of reducing the use and impact of
Public Safety Power Shutoff events. Wildfire and Wildfire Safety(ca.Rov)
Malensky, Vern 14
Avista Corporation

I off power to select and specifically identified areas when severe weather makes utility
2 equipment unsafe to operate. It identifies relevant considerations and decision process flow
3 and implementation protocols before, during, and after a PSPS event, recognizing that this is
4 subject to each situation being unique and that actual considerations and/or actions will vary
5 depending on the circumstances. We further note that nothing in Avista's PSPS Plan
6 supersedes the general authority of the Company to de-energize a power line during an
7 emergency. A decision (i.e., to protect fire response personnel or to protect company assets
8 from fire damage) might be made without complying with the notification and outreach
9 sections of the PSPS Plan (attached as Exhibit No. 11, Schedule 6). In addition, extreme
10 weather events are, by their nature, unpredictable and unique, so the specific considerations
11 applicable to possible de-energization may vary based on the specific circumstances.
12 As a general matter, Avista would initiate a PSPS if the Company determines, based
13 on the circumstances and information available at the time, that a combination of critical
14 conditions at certain locations creates a consequential risk of wildfire ignition and severe risk
15 resulting in harm, and that those risks outweigh the corresponding risks associated with
16 initiating the PSPS. This determination would take into consideration,without limitation, fire
17 risk potential,relative humidity, field observations and measurements, anticipated duration of
18 events,geographic characteristics and critical infrastructure,wind direction and speeds,utility
19 and firefighting resources available, etc. This list of considerations is non-exhaustive, as each
20 weather situation is unique and involves a wide variety of characteristics, risks, and
21 considerations.
22 Q. How are you preparing for a PSPS event?
23 A. The single most important part of a PSPS program is a well-developed and
Malensky, Vern 15
Avista Corporation

I comprehensive communications strategy. Keeping customers and utility stakeholders well
2 informed before,during,and after a PSPS event is essential to minimizing the effects of power
3 outages and protecting Avista's reputation. In 2024, the first year of Avista's PSPS Plan,
4 throughout our service area, we conducted outreach to all Avista customers, agency partners,
5 city, and county emergency management organizations and first responders, community
6 leaders, medical and other service providers to provide information and education around the
7 Company's PSPS efforts and to help prepare and support customers during a potential PSPS
8 event.
9 PSPS preparedness is a cyclical effort involving specialized communications and
10 many associated parties including Avista personnel, public safety partners, state and local
11 governments, communities, and customers. Prior to wildfire season Avista communicates
12 broadly with customers about wildfire preparations and expected operations, including PSPS,
13 as described in Exhibit No. 11, Schedule 2. Avista's main objectives of preparedness are
14 performing wildfire prevention and mitigation activities and engaging with external first
15 responders, critical facilities, Tribal partners, and communities to develop relationships and
16 provide education to implement this plan safely and effectively.
17 Q. How do you support customers during PSPS event?
18 A. Strong partnerships have been developed between Avista and local public
19 safety,health, other utilities, and emergency management agencies over the last several years
20 to assist in the coordination for any event which impacts the communities we serve. Avista
21 will be the initiating agency in the event of a PSPS in our service territory and will coordinate
22 with all local agencies as appropriate. In order to support our communities during such an
23 event, we plan to provide a real-time outage/PSPS map on our website, activate Avista's
Malensky, Vern 16
Avista Corporation

I Customer Service CARES (Customer Assistance Referral and Evaluation Services) Team13
2 who actively engage and act as a liaison for medically vulnerable customers in the impacted
3 areas,and provide Community Resource Centers in strategic areas with air conditioning,water
4 and snacks, communications and charging capabilities, restrooms, etc. Avista is also offering
5 a battery backup program to qualified Life Support customers who have been verified through
6 a medical provider to support them through a potential outage. We connect customers with
7 Washington and Idaho 211 services for additional assistance that Avista is unable to provide.
8 Prior to an event, Avista will utilize multiple communication channels to reach
9 customers and inform them about a potential PSPS event in their area, including notification
10 of available customer services. This information will also be published to our social media
11 pages and provided to emergency management partners to disseminate. In addition, we have
12 a strong partnership with access and functional needs population support agencies who will
13 be notified of potential PSPS events to further support customers. We anticipate improving
14 and modifying these and other PSPS operations and tactics over time as we experience these
15 events.
16 Q. Have you implemented a PSPS?
17 A. Yes. On Sunday, September 29, 2024, the Spokane area experienced strong
18 winds, blowing dust, and dry conditions that created high fire risk. Our Dashboard indicated
19 extreme risk on one of our circuits in North Spokane. In response, Avista implemented our
20 first ever Public Safety Power Shutoff. Approximately 1,500 customers were impacted from
13 The CARES (Customer Assistance Referral and Evaluation Services) Team 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,who work with medical providers to verify customer needs.
Malensky, Vern 17
Avista Corporation

1 2 p.m. to 11 p.m. During this event, Avista set up a Customer Resource Center at Mead High
2 School to provide information, charging stations, snacks, and water for impacted customers.
3 Q. Tell us more about the PSPS Battery Backup Program.
4 A. With the implementation of PSPS we knew medically vulnerable customers
5 could be significantly impacted when the power is out. A PSPS event can be lengthy due to
6 the requirement to fully inspect the impacted line before putting it back into service to ensure
7 that it is safe to re-energize. We developed the Battery Backup Program to protect medically
8 qualified customers on life support with a battery backup system for use during power outages.
9 We engaged with partners including Aging and Long-Term Care of Eastern Washington who
10 worked with us to develop this program and determine what size battery would be needed in
11 order to support customer medical devices for multiple hours.14
12 Avista's CARES Team works with medical providers to verify customers having
13 significant dependency on electricity for medical devices and their eligibility for the program.
14 Postcards regarding this program were sent out in early June 2024 to registered life support
15 customers in the highest wildfire threat areas of our service territory. As of November 2024,
16 of the 207 postcards mailed, Avista has delivered 96 batteries.
17 Q. Does the Company have specific communication plans related to
18 Wildfire?
19 A. Yes, it does. A key element of the Company's Wildfire Resiliency Plan is
20 ensuring that all who are interested know that the plan is in place and that Avista is taking the
21 right precautionary steps to reduce the potential for and impact of a wildfire. A strong and
is Avista partnered with Goal Zero to provide a 3000x battery,essentially a 3000-watt battery. Goal Zero works
with other utilities across the Western United States to provide batteries for their battery programs so was a
trusted and recommended provider.
Malensky, Vern 18
Avista Corporation

I effective strategic communications campaign is critical to the Company in ensuring broad
2 awareness and to demonstrate Avista's commitment to reducing the impact of wildfires. Our
3 wildfire communications goals are to create awareness of Avista's plan to prevent or mitigate
4 the risk of wildfires,promote the safety and well-being of all customers,to engage customers
5 in programs that impact them and their communities,and to help our customers and employees
6 stay safe.
7 On the customer side, we use a wide variety of means to reach our customers as
8 described in Avista's 2024 Wildfire Resiliency Communications Plan provided as Exhibit No
9 11, Schedule 2. We utilize newsletters, customer emails, phone calls, social media, Avista's
10 website, and local media outlets. When projects directly impact customers, they are directly
11 notified of work happening in their area and its purpose. One way we reach out to customers
12 is through annual spring Telephone Town Hall events intended to reach all electric customers
13 across our service territory. These customer engagements are centered on overall wildfire risk
14 and preparations for fire season as well as Fire Safety Mode and Public Safety Power Shutoff
15 operations.Emergency management professionals,public safety partners,and key community
16 leaders from each region are also invited to provide additional information and perspective.
17 Another facet of our communications work is the specialized outreach framework we
18 developed to help educate elected, community, and Tribal leaders as well as emergency
19 management agencies and first responders about wildfire resiliency and Avista's Plan,as well
20 as to gather insights from them about how to better engage with communities, share
21 information on how to best coordinate activities before, during, and after an event, and help
22 community leaders better help answer questions and support their citizens during events.
23 Another important part of the communications piece of the Plan relates to creating
Malensky, Vern 19
Avista Corporation

I emergency readiness both within the Company and with our community partners. We work
2 with fire agencies across our service territory in response to outage events, engage with the
3 Tribes on fuel reduction efforts and their specialized communications needs, and actively
4 engage with customers through a variety of means from emails and bill inserts to direct
5 engagement. All of these partnerships and related communications are integral to the success
6 of our plan, as Wildfire is too critical a situation for us to deal with strictly on our own.
7 We are also working on including additional language options.We have identified that
8 five percent of Avista customers speak a primary language other than English and of those,
9 95 percent speak Spanish as their primary language, encouraging us to focus on Spanish
10 outreach. In response,Avista developed a variety of materials in Spanish which are distributed
11 through our various communications channels and community events. We also launched a
12 Spanish website in April of 2024, added an outage map in Spanish, and had a Spanish option
13 for all six of our Telephone Town Halls in the summer of 2024. We are also focused on
14 ensuring additional customers can access these materials by subtitling videos and working to
15 translate our messages into American Sign Language and other languages we have identified
16 in our customer base, including Russian.
17 Another feature of our communications outreach is requests for customers, especially
18 those who are medically vulnerable or who have special needs, to update their contact
19 information with Avista so we can reach out to them in preparation for outages, including
20 connecting them with Avista's Customer CARES (Customer Assistance Referral and
21 Evaluation Services) Team. We are continually reevaluating and improving our customer
22 outreach, as this is such a critical means of helping keep our customers safe. More details
23 about our communications efforts can be found in Exhibit No 11, Schedule 2.
Malensky, Vern 20
Avista Corporation

I Q. Would you please provide more details about your fuel reduction efforts
2 with external agencies, specifically in Idaho?
3 A. We are actively engaged with several land management agencies to assist them
4 with fuel reduction near our facilities. For example, the State of Idaho identified several
5 communities that Avista serves with overhead electrical service that the State classifies as
6 communities at risk of wildfire. Avista works with these communities to reduce their fire risk,
7 including mitigating dead trees on or adjacent to Avista-owned facilities and corridors,
8 thinning small diameter trees, and removing brush. In another example, we have helped with
9 funding for the Bonner County Department of Emergency Management's BonFire Program.15
10 BonFire is a county-wide resource whose goal is to provide technical expertise to landowners
11 who wish to reduce fuels in and around their homes. In addition to expertise, this program
12 provides labor resources to complete the fuel reduction work prescribed.
13 Q. What other external partnerships has Avista developed and how do they
14 benefit the Plan?
15 A. Avista works with many diverse external parties in planning and executing our
16 Wildfire Plan. These partnerships began in 2019 with the initial development of the Plan as
17 we called upon outside experts to help us develop our wildfire risk reduction strategies, and
18 we have continued to grow these partnerships and add to them over time. Some of these parties
19 gain direct monetary benefits, such as the Safe Tree Program that replaces risk trees on
20 customer private property at no cost to our customers or our work on fuel reduction with
21 Bonner County's BonFire Program. Other partnerships have no cost associated with them,but
22 provide direct benefit such as the Washington Dept. of Natural Resources calling upon
is htWs://www.bonnercop]tyid. ova/departments/EmerizencyManalzementibonfire
Malensky, Vern 21
Avista Corporation

I Avista's Fire Weather Dashboard to help them strategically place firefighting resources across
2 the State based upon the Dashboard's analysis of risk. Some partners join with us in Ere risk
3 reduction activities such as the Expedited Response contracts, others help prepare and support
4 our customers and communities such as public health and safety agencies. Some examples are
5 listed below:
6 • Customers— Safe Tree Program,preparations for PSPS.
7 • Idaho Dept. of Lands (IDL) and Washington Dept. of Natural Resources (DNR) —
8 shared wildfire cameras and use of Ere risk analysis (Avista's Fire Weather
9 Dashboard), expedited response agreements,joint fuel reduction efforts, cooperative
10 participation in emergency operations exercises.
11 • Firefighters/First Responders — development of our Plan and strategies, working
12 together to keep firefighters safe in fire situations including opening fuses on the
13 distribution system or de-energizing transmission lines as requested, participating in
14 Emergency Operations training, Avista's joining with Fire Incident Command during
15 wildfire events.
16 • State and Local Agencies -helping fund fuel reduction efforts with the State of Idaho,
17 Bonner County BonFire Program, DNR, IDL, and local/regional fire agencies such as
18 the City of Spokane and Town of Malden.
19 • Public Safety,Health, and Emergency Management Agencies—PSPS preparation and
20 response, participation in joint emergency operations exercises, working together to
21 identify special needs customers, and providing appropriate outreach and support.
22 • Neighboring Utilities — sharing best practices, assisting with their wildfire plans and
23 strategies,joint preparation for wildfire events (EOP participation), and PSPS related
24 communications and cooperative engagement.
25 • Communities and Local Leaders — participation in Telephone Town Halls, working
26 together to prepare citizens for outages and to provide support and services (such as
27 libraries, schools, and business owners who provide Customer Resource Centers for
28 customers during PSPS events).
29 • Tribes — helping us identify their specialized communications needs and their most
30 vulnerable members for support, especially during PSPS events.
31
32 III. PROGRAM COSTS
33 Q. What are the current capital and expense cost estimates for the Wildfire
34 Plan from 2020 to 2029?
Malensky, Vern 22
Avista Corporation

I A. Revised in 2024, the updated system-wide Wildfire Resiliency Plan program
2 costs include capital investment(spend)of approximately$387.2 million16 from 2020 to 2029
3 with corollary operating expenses of$126.3 million (all electric system numbers). Note that
4 the budget has been approved through 2026. Included in Table No. 2 below are the system
5 (Idaho and Washington electric) annual capital additions and O&M expenses (actual and
6 expected spend) for the 10-Year period 2020—2029.
7 Table No. 2 —Wildfire Annual Capital Investment & Operating Expense (System)
8 IIIs) 2020 A I21 Adual 2022 Adual 2023I ' 2025 2026I I . 2029 I i
9 (apital $3,421 $19,375 $26,066 $28,319 $33,750 $35,250 $60,250 $60,250 $60,250 $60,250 $387,181
10 0&M $2,430 $7,602 $17213 $19,727 $16,721 $15,391 $B1811 $g130 $11,050 $10,160 $126,296
11 These total capital investments and expenses of the Wildfire Plan will be directly assigned or
12 allocated to Avista's Idaho and Washington jurisdictions over time as the costs occur. The
13 following Illustration No. 2 indicates the total estimated approved capital and operating
14 expense on a per year basis (Washington and Idaho electric) through 2026 and estimated(but
15 not approved) expenditures for 2027 through 2029. Note that 2026 through 2029 show an
16 addition of$25 million in capital expenditures related to the implementation of the Enhanced
17 Grid Hardening Program the Company is currently developing as well as many other
18 enhancement efforts across the program. This program and other enhancements will increase
19 our capital budgets by an amount that will be more accurately defined after actual experience
20 with this new strategy. The budget will be updated as we gain information and can more
16 The$387.2 million 10-Year Capital Total as described here and shown in Table No. 2 above,is not reflected
in the current 2023 Wildfire Resiliency Business Case(provided as Exhibit No. 11,Schedule 8)reporting$310.9
million,as it does not reflect the estimated incremental annual$25 million of capital additions for enhanced grid-
hardening for the period 2026-2029. This$25 million of capital additions for 2027 (Rate Year 2)has also not
been included in the Company's transfers to plant amounts included in this case,as sponsored by Ms.Benjamin,
as the actual needed 2027 grid-hardening capital investment is still under assessment.
Malensky, Vern 23
Avista Corporation

I accurately measure these costs.
2 Illustration No. 2—Annual Wildfire Resiliency Plan Costs (System)
3
Avista Wildfire Resiliency Plan Expected Cost
4 $70,000
5 $60,000
6 L $50,000
0
$40,000
7
$30,000
8
0
~ $20,000
9 $10,000
10 $0 -
2020 2021 2022 2023 2024 2025 2026 2027 2028 2029
11 Actual Actual Actual Actual
0Capita1 $3,421 $19,375 1 $26,066 $28,319 $33,750 $35,250 $60,250 $60,250 $60,250 $60,250
N O&M $2,430 $7,602 $17,273 $19,727 $16,721 $15,391 $13,812 $12,130 $11,050 $10,160
12
13 The individual recommendations that result in these costs estimates are provided in
14 the updated 2024 Wildfire Plan(Exhibit No. 11, Schedule 1). By far the single largest capital
15 investment is associated with electric distribution and transmission grid hardening, which
16 accounts for the majority of our capital expenditures.
17 For operating expenses,the primary expenditure is related to vegetation management,
18 which accounts for over 80% of the Wildfire O&M budget. Operating expense levels which
19 peaked in 2023 are gradually declining as subsequent year risk tree inspections should reveal
20 fewer risk/hazard trees due to our vigorous efforts to mitigate them. However,the majority of
21 operating expense items are generally related to risk-based enhanced vegetation management
22 expenses; those could increase in the future, however, as changes in the climate and potential
23 disease could increase the need for more vegetation management.
Malensky, Vern 24
Avista Corporation

I Q. What are the specific costs Avista is seeking to recover in this general rate
2 case over the proposed Two-Year Rate Plan?
3 A. As discussed by Ms.Andrews,specific costs proposed by Avista in this general
4 rate case reflect the expected costs to be charged to Idaho electric operations over the
5 Company's proposed Two-Year Rate Plan. While Company witness Ms. Schultz sponsors
6 the wildfire deferral amortization adjustment and incorporates the incremental costs
7 associated with the Company's Wildfire Plan within her Electric Pro Forma Study for the
8 Two-Year Rate Plan, and witness Ms. Benjamin sponsors the capital additions adjustments
9 pro formed by the Company, Ms. Andrews sponsors the Wildfire Expense Adjustment and
10 discusses the Wildfire Balancing Account proposed baseline update for the Two-Year Rate
11 Plan and the overall costs in this case associated with the Wildfire Plan.
12 Specifically,Ms.Andrews explains within her direct testimony,that the Company has
13 pro formed a level of Idaho wildfire transmission and distribution O&M expense totaling
14 $5,740,00017 annually for the Two-Year Rate Plan, and that this amount is the Company's
15 proposed Wildfire Expense Balancing Account baseline to be utilized over the Two-Year Rate
16 Plan.18
17 Ms.Andrews also explains that the pro forma capital additions adjustments(sponsored
18 by Ms. Benjamin), includes capital additions above test period levels related to Wildfire Plan
19 investment, reflecting Idaho's share of Wildfire Plan transmission and distribution net capital
20 additions of projects transferring to plant between July 1, 2024, and August 31, 2027. These
21 additions result in the overall increase in Idaho electric rate base (net of A/D and ADFIT) of
17 The Pro Forma level of wildfire expense of$5.74 million reflects an increase of$.59 million from test period
levels(twelve-months-ending 06.30.2024)of$5.15 million.
18 The$5.74 million baseline would remain in effect until the baseline is revised in a future general rate case.
Malensky, Vern 25
Avista Corporation

1 $19.4 million in Rate Year 1 and $17.0 million for Rate Year 2, or $36.4 million over the
2 Two-Year Rate Plan. Finally, Ms. Andrews provides details on the Wildfire Balancing
3 Account deferred expense incurred by the Company for Idaho operations through September
4 30, 2024, of$6.5 million, and the proposed two-year amortization to recover these deferred
5 expenses ($6.5 million), annually at $3.25 million, from September 1, 2025, through August
6 31, 2027.
7 In summary, reflecting each of these wildfire costs, therefore, result in an overall
8 increase to the Idaho electric revenue requirement included in this case totaling approximately
9 $8.8 million, or $6.7 million and $2.1 million in Rate Year 1 and Rate Year 2, respectively,
10 and an increase in net rate base, as noted above, of$19.4 million in Rate Year 1 and $17.0
11 million in Rate Year 2. Approval of these proposed incremental costs is an important element
12 of the Company's wildfire program and helps support the level of wildfire mitigation efforts
13 proposed in the Company's Wildfire Plan.
14 Q. How will any offsetting benefits be captured in the form of operating and
15 maintenance savings?
16 A. As discussed by Ms.Andrews,the operation of the balancing account for O&M
17 costs will be net of cost savings, thereby capturing over time any embedded cost savings.
18 Q. Please provide more information about other funding sources the
19 Company has pursued related to Wildfire.
20 A. In 2023, Avista applied for a grant through the Infrastructure Investment and
21 Jobs Act (IIJA), aka Bipartisan Infrastructure Law (BIL). Part of this law included $10.5
22 billion in grants to enhance grid flexibility and improve the resilience of the power grid,
Malensky, Vern 26
Avista Corporation

I known as the DOE Grid Resiliency and Innovation Project (GRIP).19 Avista applied for
2 funding from this grant to upgrade powerlines located in high fire threat areas but was not
3 selected as a recipient.
4 In 2023 the Idaho Governor's Office of Energy and Mineral Resources (OEMR)
5 awarded Avista a grant of$230,000 to fund 50% of the cost to underground a section of the
6 Dalton 133 feeder which serves about 500 customers in Northern Idaho. This feeder has a
7 high number of customers experiencing multiple outages in a year. This undergrounding
8 project was completed in October of 2023. We applied for three additional grants from the
9 OEMR to complete grid hardening in Northern Idaho,but these were not awarded to Avista.
10 The Company also spearheaded the application for another GRIP grant with a
11 consortium of utility providers from Washington to South Dakota in addition to National
12 Laboratories, universities, and private innovators to bolster wildfire resiliency through
13 development of a state-of-the-art unified wildfire risk methodology and application tool. The
14 tool was planned to include a wildfire risk model, a weather model, and a geospatial view of
15 utility infrastructure that would be used by fire agencies and first responders.All of the partner
16 utilities would share this tool (along with the costs). It would cover a vast territory of about
17 126,000 square miles and over 4.6 million customers. It was envisioned that the tool will help
18 guide long-term planning investments for wildfire mitigation and serve as a real-time decision
19 support tool for wildfire-related decisions such as elevating protection settings or
20 implementing a Public Safety Power Shutoff. We were informed in late 2024 that this
19 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 I Department of Energy
Malensky, Vern 27
Avista Corporation

I application was unsuccessful.
2
3 IV. SUMMARY OF RECENT IMPROVEMENTS
4 Q. Would you provide an overview of the recent improvements you have
5 made related to the Plan?
6 A. Yes. Avista's Wildfire Resiliency Plan is built upon the concept of Plan-Do-
7 Check-Adjust. We are continually evaluating the efficacy of our programs and adjusting them
8 as we see opportunities for improvement.We have made some significant improvements since
9 the Plan began. These improvements have been described in more detail in the testimony
10 above,but in summary we have:
11 • Increased and enhanced our wildfire-related customer communications efforts,
12 specifically with customer engagement activities such as the town hall meetings,
13 which have been expanded to all customers in our service territory.
14
15 • Added additional language options (with Spanish being a focus) to our
16 communication outreach, as well as translating our messages into American Sign
17 Language and providing subtitling to allow us to reach more customers.
18
19 • Created a Community Response for Vulnerable Populations During Outages
20 (CRVP) Stakeholder Group which includes nearly 40 representatives from
21 organizations and agencies that serve vulnerable populations(as well as municipal
22 departments and emergency managers) to inform them of our Wildfire and PSPS
23 plans and strategies and to gather information/feedback on how best to reach our
24 vulnerable customers with this information.
25
26 • Supplemented support for our most vulnerable customers using our Customer
27 Assistance Referral and Evaluation Services (CARES) Team, a specialized team
28 within Avista's customer contact center that focuses on this work, acting as a
29 liaison between the customer and community partner support networks. We also
30 launched an employee team of volunteer Community Response Ambassadors who
31 trained with the Red Cross to provide additional help for these customers,
32 especially during outage events.
33
34 • Developed outreach specific to area Tribes, including working with them to
35 identify their vulnerable populations including Tribal elders and medically
36 vulnerable Tribal members to help support them in case of an extended power
Malensky, Vern 28
Avista Corporation

I outage.
2
3 • Worked with Avista's Equity Advisory Group to fully develop and identify Highly
4 Impacted Communities and Vulnerable Populations ("Named Communities")20
5 unique to the Company's service territory to allow working through the barriers
6 specific to this customer group in wildfire education, preparation, and support.
7
8 • Developed the ability to quickly identify and contact life support customers for
9 specialized support and outreach by adding a life support customer flag to all the
10 feeder lists so we can proactively call to make sure they are aware of wildfire threat
I I and potential outages due to the weather and provide options for support.
12
13 • Created a program to provide customers who have gone through the process of
14 being verified through their primary care physician as having 24-hour dependency
15 on medical equipment with battery backup power systems to protect them in case
16 of outages, specifically in relation to PSPS, which can entail extended outage
17 duration.
18
19 • Completed identification of critical commercial and industrial customers and
20 service providers for notification during elevated Fire Safety Mode protection
21 settings or in the event of a PSPS.These are customers who provide critical support
22 services to society such as police and fire stations, large airports, traffic control,
23 communication towers, etc. Recognizing who these customers are, the critical
24 services they provide, and where they are located makes it possible to do as much
25 as possible to protect their energy supply and/or restore their service as quickly as
26 possible for public safety.
27
28 • Implemented a comprehensive PSPS outreach program. In 2024 the Company
29 reached out to over 14,000 first responders,emergency managers,critical customer
30 groups, service providers, healthcare organizations, city and county leaders, state
31 agencies, and others to provide education around our PSPS Plan and to strategize
32 about protecting and supporting customers through potential outages.
33
34 • Continually improve the inputs to our WUI map by updating information we use
35 from the USDA(both the Housing Unit Impact and the Wildfire Hazard Potential
36 data as mentioned previously) to help us more clearly and specifically include
37 structural and human impact as well as areas where fires may be particularly
38 difficult to control. It further enables our ability to identify the areas of highest risk
39 of impact in our service territory. This information is free and publicly available.
40
41 • Added additional modeling inputs, capability, and refinement to our Fire Weather
42 Dashboard to advance our ability to forecast and identify risk, including use of
20 Washington State Department of Health,"Instructions for Utilities to Identify Highly Impacted Communities,"
Instructions for Utilities to Identify Highly Impacted Communities I Washington State Department of Health
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)
Malensky, Vern 29
Avista Corporation

I correlating dynamic forecasted risk and actual events that took place, as well as
2 back-casting to prove the Dashboard concepts, analysis, and output.
3
4 • Added the U.S. Forest Service Severe Fire Danger Index data to the Dashboard to
5 further bolster our decision-making around use of Fire Safety Mode and PSPS.
6 This is a forecastable metric that can help predict extreme fire conditions based on
7 historical data related to fire intensity and spread potential. When this data is
8 combined with current wildfire situations it helps predict fire intensity, the
9 likelihood of resulting damage, and the potential for loss of life. It is another
10 valuable data point in helping us determine risk and protect lives and property.
11
12 • Assessing the concept of undergrounding distribution powerlines in select, high
13 risk areas. Avista is working to identify areas where large fire growth may be
14 coupled with proximity to communities which are vulnerable to total loss in the
15 event of a wildfire. These identified areas will be risk-ranked and prioritized for
16 sectional undergrounding of existing overhead conductor. This strategy will
17 reduce wildfire risk and increase safety to the communities facing the highest risk
18 from Avista's distribution electric facilities and should mitigate the most risk for
19 the least cost by performing this work at a surgical rather than a system-wide level.
20 We have engaged a consultant to assist us in this complex analysis.
21
22 • Partnered with the Washington Dept. of Natural Resources and the Idaho Dept. of
23 Lands in installing ten wildfire identification cameras across our service territory,
24 three in Idaho and seven in Washington. Wildfire identification cameras are
25 invaluable in quickly identifying a fire start as well as pinpointing its precise
26 location, dispatching resources directly to the latitude and longitude of the smoke
27 so firefighters do not have to search for the fire, saving invaluable time.
28
29 • Developed a robust Emergency Operating Procedure (EOP)related specifically to
30 Wildfire situations. Created realistic EOP annual tabletop exercises that include
31 external partners such as the Red Cross, Washington Dept. of Natural Resources,
32 and Idaho Dept. of Lands to practice wildfire response in a coordinated,consistent,
33 efficient manner.
34
35 • Expanded the Fuel Reduction Partnership program beyond Washington State to
36 include engagement with the Idaho Dept. of Lands, the U.S. Forest Service, the
37 Nez Perce Tribe, and local and regional fire agencies across our service territory.
38
39 • Continuing to refine and enhance Fire Safety Mode operations to provide a
40 comprehensive scale of risk reduction based upon actual conditions. We are
41 utilizing actual experience, such as the 2022,2023, and 2024 fire seasons,to refine
42 and improve these efforts and set our trigger points for action to increase safety.
43
44 • Extended our Safe Tree Program, which works with customers directly to remove
45 risk trees on their property, into all WUI 2 and WUI 3 areas across the service
46 territory and added a platform to the Company's website for this program. The
Malensky, Vern 30
Avista Corporation

I website allows customers to request Safe Tree work directly(if they are qualified),
2 communicating with arborists to schedule this work at their convenience.
3
4 • By engaging with first responders such as the Washington Dept. of Natural
5 Resources and the Idaho Dept. of Lands, created Expedited Response Agreements
6 that cover nearly 99% of our service territory. These agreements do not have end
7 dates and have no cost. This professional fire response to transmission-level faults
8 during fire season helps ensure that any fires that may result do not spread.
9
10 • Worked with a third party to validate the effectiveness of our Vegetation
11 Management Programs and the most efficient vegetation management cycle in our
12 service area. This analysis determined that Avista has a reasonable and responsible
13 approach which is aligned with"best-in-class"vegetation programs of other major
14 utilities, that our one-year Risk Tree inspection cycle is aligned with industry best
15 practices, as are our WUI Tier designations.
16
17 • In acquiring digital data for both the transmission and distributions systems for
18 identifying risk trees,we are becoming familiar with the large amount of data these
19 tools provide and how to use all this information to focus our vegetation efforts in
20 areas that should provide the most positive impact and risk reduction. We believe
21 that these tools are helping us plan vegetation work in the areas of greatest need
22 with accuracy in a more precise and predictable way, streamlining our vegetation
23 management programs and helping to maximize their value.
24
25 • Created a strategy to prioritize steel transmission pole replacements in the highest
26 risk areas based on a spectrum of inputs including actual historic fires and
27 topography,moving beyond utilizing WUI zone alone. We are also using satellite-
28 acquired digital data to help determine whether transmission lines are in treed areas
29 (candidates for steel replacement) or in low-vegetation areas (candidates for fire
30 mesh wrap). Knowing where the poles are physically located, and the geography
31 of the area has a significant budget impact. The cost for replacement of a wood
32 pole with steel is several thousand dollars per pole versus a few hundred dollars
33 for installing mesh wrap on a pole so this analysis should benefit our budget.
34
35 • Continued to actively seek out and build valuable partnerships and connections to
36 support our wildfire efforts with both external partners and customers, including
37 working with and learning from our utility peers to strategize and develop best
38 practices.
39
40 Q. Does this conclude your pre-filed direct testimony?
41 A. Yes.
Malensky, Vern 31
Avista Corporation

DAVID J. MEYER
VICE PRESIDENT AND CHIEF COUNSEL FOR
REGULATORY & GOVERNMENTAL AFFAIRS
AVISTA CORPORATION
P.O. BOX 3727
1411 EAST MISSION AVENUE
SPOKANE, WASHINGTON 99220-3727
TELEPHONE: [phone]
[e-mail]
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION ) CASE NO. AVU-E-25-01
OF AVISTA CORPORATION FOR THE )
AUTHORITY TO INCREASE ITS RATES )
AND CHARGES FOR ELECTRIC AND ) EXHIBIT NO. 11
NATURAL GAS SERVICE TO ELECTRIC ) OF
AND NATURAL GAS CUSTOMERS IN THE ) VERNON L. MALENSKY
STATE OF IDAHO )
1
FOR AVISTA CORPORATION
(ELECTRIC)

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TABLE OF CONTENTS
Statement from Avista Executive Management.....................................................................................3
ExecutiveSummary.................................................................................................................................4
Avista's Commitment to Wildfire Resiliency........................................................................................... 5
WildfirePlan Goals .............................................................................................................................. 6
WildfirePlan Updates..........................................................................................................................7
Governance..........................................................................................................................................8
Wildfire Resiliency Program Elements..................................................................................................... 9
GridHardening .................................................................................................................................. 11
Enhanced Vegetation Management.................................................................................................. 20
SituationalAwareness....................................................................................................................... 29
Operations & Response..................................................................................................................... 38
CommunityOutreach............................................................................................................................52
Equity................................................................................................................................................. 56
2023 Fire Season Recap.........................................................................................................................59
Impactsto Infrastructure................................................................................................................... 60
2024 Fire Season Outlook...................................................................................................................... 62
Challenges& Lessons Learned.............................................................................................................. 63
ContinuousImprovement...................................................................................................................... 65
Avista Wildfire Resiliency Plan Glossary of Terms.................................................................................... 74
Appendix A:Avista's Wildfire Public Safety Shutoff Plan Summary....................................................... 108
2
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 1,Page 2 of 114

Statement from Avista Executive Management
2024 represents Avista's 411 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: August 31, 2024
Josh DiLuciano,Vice President Energy Delivery
Date: August 31, 2024
Vern Malensky, Director Electrical Engineering
I i
Vmot,. 14 Date: August 31, 2024
3
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 1,Page 3 of 114

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 P
introduced the risks, costs, and benefits of implementing a
holistic set of measures to reduce utility wildfire risk.The original
,40�Plan built upon Avista's operating history responding to and Avista Y" ;
p p g Y p g
Wildfire
mitigating wildfire activity, and we continue to do so four years Resiliency
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
4
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 1,Page 4 of 114

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 the
system'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 1983.1 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.'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.'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 1 ScienceDaily
3 NIFC(National Interagency Fire Center).Total wildland fires and acres(1983-2023).Accessed July 2024.Wildfires and Acres I National Interagency
Fire Center(nifc.gov)
4"Climate Change Indicators:Wildfire,"United States Environmental Protection Agency,July 2022,Climate Change Indicators:Wildfires I US EPA
5 John Muyskens,Andrew Ba Tran,et al,1 in 6 Americans Live in Areas with Significant Wildfire Risk,"The Washington Post,May 17,2022,Map:See
where Americans are most at risk for wildfires-Washington Post
5 Wildfire Risk Map courtesy of FEMA,Wildfire I National Risk Index(fema.gov)
5
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 1,Page 5 of 114

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 Outage Issue 20192020 I I 1
represent a subset of unplanned Pole Fires 68 66 15a 56 67 82.2
outages that can be managed in part Tree Fall-In all 42O 363 376 22a 358.8
by upgrading powerlines and Tree Grow-In 96 72 83 59 53 72.6
Overhead Equipment 655 608 622 750 641 655.2
equipment as well as removing risk Bird/Animal0utages 538 525 565 51 5573 543
trees,which are primary objectives Spark Events 99 164 115 109 65 110.4
of Avista's Wildfire Plan. Table 1.Historic Outages
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, ��eG�o`e Human
��`� • Life
and most importantly, human lives, against the threat of wildfires.To eo
G
recognize fire potential in our operating and maintenance strategies o�`a� Homes&
and take actions to reduce the risk of wildfire from the �eva���e\�` Property
interaction of Avista's energy delivery system and the Electric service
� Disruption
environment, as well as the impacts of wildfire to Utility
Financial Infrastructure
Avista's system. Liability
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
6
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 1,Page 6 of 114

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 Wildfire},
to fire risk, utility best practices, and in response to feedback from =3 Resilieney
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)'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) dataset'which
contains a nationwide raster of housing
/'
� e
unit density measured in persons per
'
�•` :�- square kilometer.This information
* SA,
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
Figure 1. USDA-US Forest Service Wildfire Hazard Potential Map internal-use data for actual outage rates
"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-
00601 metadata RDS-2020-0060.html
7
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 1,Page 7 of 114

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 Directors
The Wildfire Implementation Team is composed of individuals who Executive
oversee and track the programs described here,who do the day Committee
-
to-day work of managing the programs and who track and report Steering
on the results as well as the Wildfire Resiliency Manager. Committee
F, Wildfire
Overall Plan implementation and guidance is governed by the Team
Wildfire Steering Committee whose membership reflects a
Figure 2.Avista Wildfire Governance
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.
8
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 1,Page 8 of 114

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.
A
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.
9
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 1,Page 9 of 114

Avista Wildfire Resiliency Plan Expected Cost
$70,000
$60,000
$50,000
$40,000
16
-o
`p$30,000
0
0
L
~ $20,000
$10,000
$0 2020 YE 2021 YE 2022 YE 2023 YE
A 2024 2025 2026 2027 2028 2029
Actual Actual Actuals Actuals
■Capital $3,421 $19,375 $26,066 $28,319 $33,750 $35,250 $60,250 $60,250 $35,250 $35,250
0 Operating 1 $2,430 $7,602 $17,273 $19,727 $16,721 $15,391 $13,812 $12,130 $11,050 $10,160
Figure 3.Avista's Wildfire Resiliency Plan Actual and Projected Expenditures
Operating Expenditures 2020-2027 Capital Expenditures 2020-2027
AM--I
Digital Data
Vegetation 7% 1
Dist.Management Other
Pole Wraps k Total Capital, Hardening1%
Steel
Other 4� Replacement
8% 11%
L— Iq L.——.A L— 14
Figure 4. Wildfire Plan Cost Breakout
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.
10
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 1, Page 10 of 114

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.
is
Though Avista has well-established programs to replace poles, conductor, Pole fire from a wood crossarm
and equipment, existing programs are condition-based and aligned with that burned the pole and
reliability objectives. Wildfire grid hardening objectives are risk-based and crossarm then traveled to the
focused on reducing the number of(and potential for) spark ignition ground.
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
Avista Historical Pole Fires grid hardening efforts. While the vast
zso
majority of spark-ignition events do not
200 — result in fires or wildfires, it is an
important measure of fire risk
o150 performance and the benefits offered by
a
Avista's Wildfire programs.
loo
£ ...
Z 50 We recorded 67 pole fires in 2023 versus
the 5-year average of 81.9 The
0 — mechanism that causes pole fires is well-
2009 2011 2013 2015 2017 2019 2021 2023
known and is highly weather dependent.
Figure 5.Avista Historic Pole Fires 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.
11
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 1, Page 11 of 114

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."
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 overtime 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: "{J
• Distribution Grid Hardening )-
• Transmission Steel Pole Conversion
• Fire Resistant Wraps on Wood Transmission Poles n
• Annual Fire Inspections on Transmission Lines -�
Y
Table 2 indicates the Grid Hardening Program metrics, and Figure 6 Avista crews install a fiberglass
depicts the associated program key performance outage metrics. distribution crossarm.
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.
ProgramInfrastructure
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
Table 2.Grid Hardening Program Primary Metrics
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 moisture,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 I TO World(tdworld.com)
12
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 1, Page 12 of 114

Grid Hardening Related Outage Metrics
800
700
600
� I
- � soo
o
0 400
300
-r• z 200
100
Animal OH Equipment Conductor Pole Fire Spark Event
Bird contact with a regulator M 2020 hd 2021 ■2022 u 2023
which started afire.
Figure 6.Grid Hardening Related Outage Metrics
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. I .
• Replace wood distribution poles with
metal poles at critical span locations such p
as highway and river crossings for
additional strength and resiliency. <�y
-i
Avista's Grid
A 4 Hardening Work
Atec
0
13
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 1, Page 13 of 114

MileageYear
2020 63 $3,115,000 Percent of Distribution Grid Hardening Projects Planned vs Completed 11 92% 74% 90% 101%
2021 146 $11,848,000 Miles of Overhead Distribution Grid Hardening Planned 66.5 204 201 211
2022 180 $15,095,000 Miles of Distribution Grid Hardening Completed 61.2 150.5 180 214
2023 210 $17,650,000 Circuit Miles of Overhead Conductor Installed/Replaced 61 149 179 209
Underground Miles Constructed 0 1 1 5
2024 1 264 $22,900,000 Number of Wildlife Guards installed 598 1363 2555 2299
2025 255 $22,900,000 Number of Crossarms installed 666 977 1636 1448
2026 246 $22,900.000 Number of Distribution Steel Poles Installed 0 16 31 2
2027 238 $22,900.000 Number of Distribution Wood Poles Installed 32 115 323 375
2028 230 $22,900.000 Number of Open Wire Secondary Districts Removed(by Polygon) 0 3 4 7
2029 222 $22,900.000 Number of Wedge/Bail Clamps at Hot Tap Connection Points Installed 200 2550 4785 4738
Number of Lightning Arrestors Installed 191 599 467 851
Totals 2,053 $185,108,000 Number of Cutouts Installed 208 550 949 914
Table 3.Distribution Grid Hardening Number of Insulators Installed 3023 4615 9563 7888
Financial Plan Number Distribution Fire Resistant Mesh Installed 6 201 100 49
Table 4.Distribution Grid Hardening Program Results
Avista Fiberglass Crossarm Installations Arrester
1800 4%
1600
1400
� 1200 1',
° 1000 Animal
Pole/Crossarm
u 2%
800
w �
600
E
Z 400
200
0 Insulator
2005 2007 2009 2011 2013 2015 2017 2019 2021 2023 3%
Figure 7.Number of Avista Fiberglass Crossarm Installations Figure 8.Overhead Equipment Related Outages 2009-2023
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 8%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
14
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 1, Page 14 of 114

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 o ® o o
Commission, undergrounding costs about In
Community Protected
$400 to$600 per trenched foot of 4-
distribution line, about$2.1 to $3.2 million 3 Miles Out Enhanced Grid 5 Miles Out
per mile.12 For comparison, the typical • Hardening •-
replacement costs for existing overhead Enhanced Grid Hardening Concept
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,roadways,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/i nfrastructu re/d espite-bei ng-safer-u nd erg round-power-I i nes-are-very-xpensive.html..
12 California Public Utilities Commission,"Overhead to Underground Conversion Programs," Slide 1 (pdi2.org)
11"Cost Estimation O/H Lines,"ENG-TIPS.com,Cost Estimation O/H lines WV and 13.8kV)-Electric power&transmission&distribution-Eng-Tips
15
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 1, Page 15 of 114

There are many cases where
sections of distribution Fire went through '
transmission lines near
conductors do not pose highly Spokane. (
on the left)
probable threats to nearby "=� was un..ICI ..ed, ..ucture(on the right) I,
communities, including urban
ucturareas that are largely
unburnable or with availablelaw
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 Wildfire near Beacon Hill,Spokane WA,indicating the resiliency of steel poles(on
proximity to communities which are the left)versus traditional wood structures(on the right)
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
I 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)I Wildfire
Risk to Communities Housing Unit Impact(Image Service)I ArcGIS Hub
16
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 1, Page 16 of 114

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 years 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 w ,.
transmission poles in the late 198Os for added resiliency and has
Above is a high canopy fire,below is afire in
systematically replaced wood transmission poles and structures low-level vegetation.
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 Gap lines,
16 Avista Outage Data from 2009 to 2023 indicates that the average number of customers impacted by a distribution outage is 50 versus a transmission
outage average of 615 customers affected.
17
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 1, Page 17 of 114

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 Gap
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 Gap lines.
Transmission Steel Replacement Poles Installed 2020 1 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
0 Total Non-Wildfire Transmission Poles Installed 1,821 847 514 622
Number of Transmission Wood Pole Fire Resistant Wraps Installed 1235 1 1938 1454 1533
I I Table 5.Transmission Grid Hardening Results
=- - 7Most transmission lines are part of a networked grid, and this redundancy helps
reduce or negate customer impact during outages. However, some lines, like
now_-[ 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
Transmission steel of complexity can impact the number of poles that can be replaced under the
replacement work. 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 Fire resistant paint chips,
peels and falls off the
wrap incorporates a heat activated chemical on a steel mesh substrate. When poles over time unless
activated,the chemical expands to seal the pole and protect it from fire. This repainted.
18
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 1, Page 18 of 114

product works well in protecting wood y t
poles that reside in low vegetation areas _ , - :.
where fires move quickly but tend to
stay low to the ground. Protecting wood �' s' i" ".. '=
poles from the impacts of wildfire also
supports reliable operations for
customers.
Avista initially expected to wrap
r
approximately 1,000 wood transmission _+,ti# � F'�r ««a. ° , �
poles per year, but the wrapping crews
grew so proficient at this work that we
have increased our prediction to Fire-resistant mesh wrap effectiveness demonstration.
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.
Transmission ground patrol inspection
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 O&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.
19
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 1, Page 19 of 114

Grid Hardening
ii, i i i i 1 is i
$1 $1 $94 $0 $200 $2D0 $200 $200 $200 $200 $1,186
$74 $5,455 $4,021 $3,623 $3,788 $3,960 $3,950 $3,960 $3,960 $3,960 $36,759
$1,513 $7,134 $9,985 $11,594 $13,528 $13,740 $28,740 $28,740 $13,740 $13,740 $142,455
$1,602 $4,714 $5,945 $7,452 $8,948 $9,160 $19,160 $19,160 $9,160 $9,160 $94,460
$0 $16 $3,626 $2,375 $2,798 $3,000 $3,0DD $3,000 $3,000 $3,000 $23,805
$3,190 $17,319 $23,661 $25,044 $29,252 $30,050 $55,060 $55,060 $30,060 $30,060 $298,766
$3,421 $19,375 $26,066 $28,319 $33,750 $35)M $60)M $60,250 $35,250 $35,250 $337,181
93% 89% 91% 89% 87% 85% 91% 91% 85% 85% 89%
$137 $172 $251 $74 $150 $1% $ISD $a $150 $150 $1,534
$178 $421 $72D $655 $550 $550 $550 $550 $550 $550 $5,274
is $316 $593 $971 $729 $700 $700 $70D $70D $700 $700 $6,809
$2,430 $7,602 $17,273 $19,727 $16,721 $15,391 $13,612 $12,130 $11,050 $10,160 $126,296
is 13% 8% Al4% 41 5% 5% 6% 6% 7% 5%
Table 6.Grid Hardening Actual and Budget Expenditures
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 A dead tree falls into an Avisto
specifically concentrate on identifying and mitigating risk trees. distribution line.
Tree fall-in rates tend to be closely linked 2% 2%
U.S.Vegetation-Related
with wind and weather events. When outages
5%
vegetation comes into direct contact with IF ,ttm Grow-Ins
electric lines and conditions are right, • Fall-Ins
Hazard Trees Outside the ROW
there is potential for fire ignition. As part Green Trees
of the Wildfire Program, distribution Dead Trees
Vines
routine cycle trimming has been unknown
decoupled from hazard tree inspection, Weather:Lightninglice Storms
with each becoming its own standalone
program.The routine program will
Figure 9.Interesting graphic from a survey of U.S.vegetation managers
continue with cycle-based trimming regarding vegetation related outages in 2023.Courtesy ofAiDash.18
18 "2023 State of Vegetation Management,Survey Findings,"AiDash,2023,SOVM-2023-Survey-eBook-Final.Ddf(aidash.com)
20
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 1, Page 20 of 114

focused on about 20% (about 1,500
Tree Incidents I ' 2020 2021 2022I
Average miles) of the system each year on about
Distribution a five year cycle. In contrast, Avista's
Tree Grow-In 96 72 83 59 53 73
Tree Fall-In 411 420 363 376 224 359 Wildfire Enhanced Vegetation
Transmission Management goal is to perform risk tree
Tree Grow-In 0 3 0 0 0 1 inspections across 100%of the
Tree Fall-In 0 9 1 3 3 3 transmission and non-urban distribution
Table 7.Tree Incident Rates systems every year.19 Our goal for wildfire
Note that the risk tree program became fully operational in 2022. 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.21 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 Avista Tree Related Outages
incident rates for both distribution and 450
transmission lines, and Figure 10 shows 400 —
Avista-related tree incidents overtime. 350
� T •Fa-Ins
There are far fewer tree incidents with 9 300
transmission lines than distribution lines a 250 -
N00
0 SWOO
due to the well defined wide rights-of-way o 200 -0-
around transmission lines versus the 1507 ree G row-ns
distribution system, which lacks clearly Z 100
�#_L�11 1
defined corridors. 50
2009 2011 2023 2015 2017 2019 2021
As evident in Table 7,tree incidents on the
distribution system far exceed those on the Figure 10.Avista's Tree-Related Outages
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
99 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)
21
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 1, Page 21 of 114

premium is placed on
the reliability and
security of the nation's � .
high voltage
transmission grid, and `
I
that focus is reflected in
overall reliability
performance and
maintaining the integrity
of the interconnected `�$ �s� The distribution system is often located in areas such as
Nl'Pi b tF "LC
grid, including robust The transmission system has wide well on private property,locking in defined corridors that
defined rights-of-way.(This is the make it more difficult to access for vegetation
transmission vegetation genewah-Pine Creek 230 kV line.) management.
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. UDAR works very well for the
wide corridors of the transmission system.
We also added satellite digital data Avista Vegetation Management Risk Trees Removed
collection for the distribution system,which 25,000
22,573
provides a huge volume of geospatial o 20,000 18,959
information, enabling deeper and more F
regular vegetation management 15,000 12,796
ai
aj
intelligence, including change detection. 0 10,000 10,091
Satellite based vegetation inspection works
well for the distribution system, as it can 5,000
z
cover large areas quickly and accurately, 0
providing detailed data on vegetation, 2020 2021 2022 2023
growth patterns, and risk to power ■Distribution ATransmission
infrastructure. It can easily differentiate
between grassland, agricultural, or urban Figure11. Wildfire Risk Tree Program Work
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
22
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 1, Page 22 of 114

increase the number of risk
trees in our service territory. r
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 These photos,taken 4 months apart show the rapid impact of an insect infestation.
higher levels of tree mortality than expected. In fact, the USDA anticipates "substantial tree mortality
from insects and diseases through 2027" 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.
Enhanced Vegetation Management Program 2020 2021 2022 2023
Reducing the number of ITotal 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
tree falls is an important
Distribution Enhanced Vegetation Management Program 2 2021 2022 2023
, 0
component of Avista's Miles of Distribution Risk Tree Inspections 2,811 5,245 6,466 6,546
Wildfire Resiliency Plan 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%*
and positively impacts Number of Distribution Risk Trees Removed 10,091 12,796 15,678 19,511
both wildfire risk Number of Distribution Risk Trees Trimmed 3,129 4,313 10,780 9,142
reduction and customer Miles of Distribution Satellite-AiDash Completed 85 7,675 7,675 7,675
service and reliability. Transmission Enhanced Vegetation Management Program 2020 2021 2022 2023
Total Miles of Transmission Risk Tree Inspections 1,355 2,270 2,270 2,270
Enhanced vegetation 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%*
management under the
Number of Transmission Risk Trees Removed 1,288 1,910 3,281 3,062
Wildfire Plan represents Number of Transmission Risk Trees Trimmed n/a 232 2,256 847
Acres of Transmission Corridor Clearing Completed 1,270 1,848 736 782
new activities such as Miles of Transmission LiDAR Completed 540 1,143 2,270 1,679
digital data collection
Enhanced Vegetation Management Program 2020 2021 2022 2023
(LiDAR and satellite) as Miles of Distribution Risk Tree Inspections 2,811 5,245 6,466 6,546
well as incremental 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
activities beyond what 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
was historically Miles of Transmission LiDAR Completed 1 540 1 1,143 2,270 1,679
undertaken by Avista
OtherVegetation Management Programs 2020 2021 2022 2023
vegetation managers. INumber 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
Table 8.Enhanced Vegetation Management Program Results*
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)
23
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 1, Page 23 of 114

*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.
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.
Fuel Reduction Work
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):
"For the Distribution Risk Tree 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 3 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
24
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 1, Page 24 of 114

wildfire mitigation programs Iapetus Third Party Evaluation Findings
observation Comments
at electric utilities with more Consideringthe impact that drought and tree mortality has had on forests in the Western United States,
Avista has implemented an effective strategyto reduce the potential for utility-caused wildfires.As the
mature and robust programs. Risk Tree cycle Risk Tree Program matures,the inventory of risk trees identified and removed should continue to reduce
in numbers as long as the goals and objectives remain in line with current standards.An annual cycle is
consistent with best-in-class programs at other major utilities in the West.
Based upon their review, Avista has taken a comprehensive approach to identify and mitigate risk trees that pose a hazard to the
Risk Tree overhead distribution system.This approach has a two-fold benefit of reducing the volume of trees that
Iapetus found that Avista's strategy can potentially result in a util ity-caused wildfire,as well as reduce the types of tree-related events that
approroach to managing the cause interruption of electrical service.
ach g g identifying Risk By leveraging the industry-accepted UAA/ISA guide,Best Management Practices-utility Risk Tree
risk associated with utility- Trees Assessment,Avista is utilizing the most current protocols in use today by North American Utilities to
identify off-ROW risk trees that pose a hazard to the electrical grid and potentially pose a wildfire risk.
caused wildfires as an annualAvista should commit to studying the root causes of tree-related outages through accurate reporting and
thorough post-outage investigations.A commitment to post-incident investigations does not mean every
cycle is an effective strategy [��
outage needs to be investigated;however,the more data,the better the analysis.
and pointed to the evidence shown by the Iapetus Third Party Distribution Vegetation Program Evaluation
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. r
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 -dill
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- Avista transmission corridor
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 where 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.
25
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 1, Page 25 of 114

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
A .- robust assessment of both slash and risk tree hazards. It also shows
R. n the topography of our service territory. The associated anal tics
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
LiDAR Image of transmission line
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 Imaging3
Similar to the LiDAR project for transmission,Avista is incorporating satellite ?;,
u
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 AiDosh'satellite image of
collection over a broad area both in urban and rural areas. Satellite-based data, an Avista distribution line
however, is not as sophisticated as LiDAR, requiring several passes over the showing tree proximity.
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
26
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 1, Page 26 of 114

Intelligent Vegetation Management System (IVMS).25 Like the
aLiDAR project,vegetation planners are working with AiDash
to calibrate the system and align computer-derived N
assessment with field observations. Starting in 2023, Avista
vegetation planners transitioned their work plans to the IVMS r
system.This allows them to customize the cycle trim times I i '
and incorporate a risk-based approach to work planning. In
short,they will focus attention in areas with higher levels of t
tree encroachment risk and outage rates as well as increased y
fire risk rather than solely relying on cycle trimming.
Safe Tree Program 1
In 2022 Avista started a new program we initially called
"Customer Driven Right Tree Right Place," renamed the "Safe /
d
Tree Program."This program is designed to work proactively
with customers in elevated fire threat areas who have tall- Satellite-derived vegetation information
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
r•
u ssiz hti., 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
Safe Tree Program Work 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 Tree 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(mvavista.com)
27
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 1, Page 27 of 114

providing funding to state and tribal agencies to support their efforts in reducing dead trees and brush.
For example,the Washington Department
WESTERN PINE BEETLE 10•YEAR TREND
of Natural Resources (DNR) has embarked FOR TOTAL ACRES AFFECTED IN
on a 20-year plan to improve forest health WASHINGTON figure 12.
on 2.7 million acres of forest land in = So —AeerapAaes
IS 'Data not shorn for
central and eastern Washington.27 They t020 due 10 tUngg
Y ao - msurvry methods and
.�. reduced wrvry area.
state that unhealthy forests are driving gS -
catastrophic wildfire, in great part due to 30
large expanses of beetle kills in € :s Average Anres
s m
Washington forests.28 As Hilary Franz, W
� ,s —
Washington Commissioner of Public Lands, ,D
states: "We have a forest health crisis in S
our state....... Hot, dry conditions coupled 02011 :014 :g,s 2016 2017 2018 m,g 7020 :021 20::
with diseased and dying forests are leading
to explosive wildfires."29 Avista partners Figure 12. Washington DNR chart indicating forest health issues due to
directly with fire protection agencies beetle kill.
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 t
Idaho identified several
communities that Avista serves
with overhead electrical service
that they classify as communities at
risk of wildfire.30 Avista works with _ y
the State to help pay for fuels t c
reduction in these at-risk areas.
Note that the work in Idaho costs
more per acre to complete than in Fuel Reduction Work Before&After
27 Western Pine Beetle graphic from"Forest Health Highlights in Washington 2022,"Washington Dept.of Natural Resources,
hftps://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:11c01 m6771Fuel Reduction
PartnershipslGNA-report-Dec-2020.pdf and Fuel Reduction PartnershipslGNA-Update-January-2020.pdf
28
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 1, Page 28 of 114

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 Management'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.
Enhanced Vegetation Management
$1,239 $3,152 $6,023 $5,404 $5,720 $4,901 $4,410 $3,969 $3,572 $3,215 541,605
$0 $2,624 $7,948 $10,600 $7,223 $6,209 $5,588 $5,029 $4,526 W73 553,819
$0 $0 $260 $741 51,200 $1,200 $1,200 $500 $300 $200 $5,601
$o SO $159 $225 $300 $300 5300 $300 $300 $300 $2,183
$59 $327 $494 $511 $107 $107 $107 $107 $107 $107 $2,033
5491 5450 $680 $783 5900 $900 $900 $900 $900 5900 57,805
�• $1,790 $6,553 $15,563 $18,263 $15,450 $13,616 $12,505 $10,805 $9,705 $8,7% $113,047
�• $2,4301 $7,6021 $17,273 $19,7271 $16,721 $15,3911 513,812 $12,130 $11,050 $10,160 $116,296
1 ;1 74% 86%1 L 951M 92% A% 91% 89% Sol am 90%
Table 9.Enhanced Vegetation Actual and Budget Expenditures
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)
29
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 1, Page 29 of 114

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 350
distribution circuits and 72 transmission lines.
+ A EI
Forecast Temperature Wind Humidity Vegetation/ Equipment Human Impact
(Sustained,gusts, Fuel Conditions (Condition&
direction) Outage History)
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.
30
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 1, Page 30 of 114

y -
• " ' FIR:2.3
FR:2A
Area_Oflire H,.Safe 04-25 04-
RECASTS FR:0.0 Fr„I�Ily�
1 C :�FR:0:0
MRX FIRE RISK •$ FIR:0.0 i;,kafie .
Spokane NON-DLM .3 0.5
FR:MIj
Spokane NON-DLMFIR:0•$,P } 1
eA qr
Spokane NON-DLM � T.. A' aem
o
(8) CDA NON-DLM
(�23)
MWSWNMNCd
Area Filter
AVERAGE HOURLYWIND GUST 05-02 Feeder
Area Office FR
35 mph .......... .......... .......... .....
CDA w 30mph 2.0 INT12F2
25 mph
Colville w E = = 1.9 SUN12F2
20mph p...............
Davenport w 15mph 7,9 WAK121`4
0 nph
Deer Park Low 1.4 RA7233
S,h
Grangeville w 0mph puouuuu..up.ouuouwo..nu.......oueuuou. 0.9 DRY1208
12.00 Apr 27 12:00 Apr 28
�upda�e:iminu.e ago„ WlndGust WlndSpeed FlreRisk WlndDirection 1.4 SUN12F5
Figure 13.Screenshot of the Distribution Fire Weather Dashboard
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
31
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 1, Page 31 of 114

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 automated protection equipment, it guides the decision to
enable various levels of operations and protection systems (Fire Safety Mode operations)to mitigate
risk.
Transmission Filter ti y
U R _Ri 2
EUD wi.dS,.... windG..... rtAaRveFlo... Rre_risk
Lol.-O.o 13 mph 21 mph 8% IF -3.0{{{{{{
Chelan-So-... 18 mph 9% I M — n
Crimhfield... 1S mph 23 mph 9% FR+2.2 J - FRo 1.8
�.7 -.
Cleanva e.. 14 mph 23 mph 9% FR 3 FR:1 6 FR:2:2
R�'
Dry Creek 14 mph 22 mph 10% FR:2.1 FR:,21,;,
Dry Creek.. 19 mph 2.2 ph 9% FR:0.0 .n FR
Churwate. 14m h 23m h 10% 2 'FR:0.0r,. FR:2L1' , c
P p FR'0.0 FR 00 FR 121. D
Dry Creek_ 19 mph 23 mph 9% SI'-L- FR 1 5 r,111 y
Dry Creek. 14 mph 23 mph 10%
Dry Creek... 15 mph 24 mph 9% •fK�s -FR' ti
Hmvai-No... 14 mph 22 mph 10%
Lob-Poun... 13 mph 22 mph 9%
1 )
North Lew... 13 mph 21 mph 9% I
I
Clearwate_. 13 mph 21 mph 10%
Hmvai- . 13 mph 21 mph 10%
ev 'I
Dil's Ga_. 19 mph 2t mph 10%
Stratford-&- 14 mph 21 mph 12% SyWwrc Cw�ry,Bv�a�aH.N Mm�sym.... USGS.EPA NPS 11—:US Oqau.cmdJr 1.wno,,OR�dWAJIaNFi,�E: He�e.v � ...NLy E..
Lolu-Nea P... 13 mph 20 mph 12% AVAFACIL SFDI MAP
Mosoow C... 14 mph 20 mph 12% FIRE RISK
Airway H.... 13 mph 18 mph 12%
Devil's Ga_. 13 mph 18 mph 11%
Airway H.... 12 mph 18 mph 10% Low MwNreb
Larson-S.— 14 mph 20 mph 14%
Lind-Neison 12 mph 20 mph 11%
Lmd-Shaw_. 12 mph 17 mph 10%
Saddle M... 14 mph 22 mph 12% 6n to J.i 2P 1.122 i�i z4
Wilbur Tap 14 mph 20 mph 14%&
AVERAGE HOl1RLY WIND GUST
Hatwai-M... 13 mph 20 mph 12% 5m
Grange 01... 12 mph 16 mph 15%
Airway H.... 12 mph 17 mph 12%
B.—S.... 12 mph 20 mph 11% 1-0
Flint Road... 12 mph 17 mph 12% Lo 1-0
Moscow2... 10 mph 17 mph 11% W
Neilson-W... 12 mph 18 mph 11%
O.ph
North Lew... 13 mph 20 mph 13% �I to J�IM 1.12i JU12a
Sunset-W... 12 mph 17 mph 11%
gYWind Gust Wnd Speed Wind Direnion Relative Humidity Temp P dp Ptobabiky
FRP Dedzion Tab
Figure 14.Screenshot of the Transmission Fire Weather Dashboard
32
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 1, Page 32 of 114

WUI Map '--
2023 Wildfire Risk Tiers
The interface area between forest lands and human ��f
development is referred to as Wildland Urbany `;
Interface, commonly known as WUI Zones, which
are the transition zones between wilderness and r
populated areas- basically where the built ,
environment meets the natural environment. Today, _
more than one-third of the U.S. population lives in Spoke �Oe 'e^°
the wildland urban interface.32 The attraction of WA
living in wooded areas and closeness to nature is
accelerating growth in the WUI. However,when I F
wildfires strike,the WUI's mix of buildings with �- r
t.m.da
forests and grasslands can set the stage for disaster. / yr} Md,eow "
I ,Homes and businesses located in WUI zones are most tewi;t
at-risk from the impact of wildfires and are often
located in rural areas lacking adequate fire
ll.
suppression resources. Approximately 126,200 Avista
customers33 (about 30%) reside in elevated risk fire Electri,Dmtnbuti..System
mn Wldfre Risk Tiers
L..lol
zones. 1elti OR
Elevated(l)
High(3)
In contrast, incorporated urban areas exceeding
paol
10,000 in population are typically identified as gCV1;,e^
"developed areas"for wildfire hazard potential and
are considered non-WUI, as they have well established Figure 15.Avista's WUI Map
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.
WUI Risk Tiers
—LOW(0) Avista believes that employing a WUI map helps identify and
.Moderate(1)
-Elevated(2) prioritize areas of greatest risk and serves to inform
�Edreme(3) recommendations and operational decisions related to wildfire
resiliency and applying the Wildfire programs within our service
eur NAlana territory. In utilizing a WUI map specific to our service territory and
Co
Spokane s customer base,we can target our programs where they have the
potential to reduce the most risk and have the greatest positive
�p� ! impact in the safety and protection of our customers and our
' Infrastructure.Avlsta's WUI map Is based upon characteristics of our
Figure 16.Close-up of Avista's system such as:
Distribution WUI Map
31 USDA USFS"Wildland-Urban Interface Growth in the U.S.,"Wildland-Urban Interface Growth in the U.S.I US Forest Service Research and
Development(usda.gov)
33 As of 2023 based on customer meter count and the current Avista WUI map.
33
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 1, Page 33 of 114

• Fuel concentration and vegetation density-areas with high volumes of trees based on data from
both the U.S. Department of Agriculture's Wildfire Hazard 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.This information is obtained from the U.S. Department of Agriculture's
Wildfire Housing Unit Impact dataset.ss
• Our own historic outage data,focused on areas with higher levels of historic outages during fire
season as obtained from Avista's Outage Management System.
Distribution Line Miles
State Low(0) Moderate(1)Miles Elevated(2) Extreme(3) WU12&3 Total Miles
Miles % 1 miles % I Miles % Miles % miles I % miles F--5.7
2,670 35%1 780 10%1 1,056 14%1 652 8%1 1,708 22%1 5,158 67%
1,181 15%1 349 1 5%1 418 1 5% 619 1 8%1 1,037 1 13%1 2,567 33%
3,851 50%1 1,129 1 15%1 1,474 1 19%1 1,271 16%1 2,745 1 36%1 7,725 100%
Table 10.Avista's WUI Miles
Using this information, Avista "WUI Risk Levels" were established:
• WUI Tier 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
of the dataset's standard deviation (low).
• WUI Tier 1—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 Tier 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
the standard deviation (elevated).
• WUI Tier 3—High levels of fuel, outage potential, and housing impact (high). Fire risk is above
WUI 2 levels (extreme).
The combination of WUI 2 and 3 represents approximately 36%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.
31"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
34
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 1, Page 34 of 114

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
1
G Washington and Idaho
�L( State WUI Zone Maps
1•'.�Nww + n.�' Y` !� J'afiofWls. ��
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'31
but that must be verified by dispatching a truck to the scene,which is costly and time consuming. With
the Al technology offered by ultra-high-definition wildfire cameras such as those offered by Pano Al,
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 Al extends its$20M Series A with another$17M,"TechCrunch Magazine,July 10,2023,Wildfire
detection startup Pano Al extends its$20M Series A with another$17M I TechCrunch
35
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 1, Page 35 of 114

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 •S�roamliva
well as vendors including AiDash (Avista's
satellite vendor) and Pano Al (wildfire camera
vendor)to file a joint application for funds
from this grant.This application was Wildfire detection
approved in October of 2023, including cameras and associated
funding of$38 million to install wildfire Al can pinpoint and
precisely locate fires
cameras across Washington, Idaho, Oregon, when thev first start.
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 UMS's choosing and adhere to reporting requirements that were
either redundant with or would require us to divert resources away from our
[AN] existing wildfire mitigation efforts. It was determined that Avista would proceed
�Y with the wildfire camera installation on our own,as wildfire cameras can
yYe Fave a new 19rvliM
�•°9P"s monitor vast areas susceptible to fire and early detection of ignition increases
,o sP,aad last.
Ganuned Fl,e:3°s""e'� ° the likelihood of timely containment and suppression of wildfires, saving lives
petec,wn T�e:2020-8-2°.'�16.9
Co`tY'0 prnado
SM1a�Yer"9Sa lca Mason
and reducing property losses.
RM1ed Ma;ieBN2�lepsa'.
Avista partnered with Pano Al, 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)
Pano Al Notification
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 I Department of
Energy
36
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 1, Page 36 of 114

recently selected Pano Al to install 20 cameras in the state of
Washington,which presents a great partnering opportunity for Avista. r 6
We are also partnering with the Idaho Dept. of Lands for key sites in
our Northern Idaho service territory. We joined with these state WASHINGTON
• Colville Mountain
agencies to fund 10 camera installations. Washington Commissioner of • Lilienthal Mountain
Public Lands Hilary Franz is working with legislators in Washington D.C. • Scoop Mountain
• Stanger Mountain
to get more funding for these cameras for the Dept. of Natural • Mount Spokane
Resources and their partners in this endeavor, including Avista.39 • Devils Gap
• Krell Ridge
By August of 2024,five of the ten cameras were in place, with the IDAHO
remaining cameras scheduled for completion by the end of September. • Gold Mountain
These cameras almost immediately proved their value. On Thursday, • Gold Cup Mountain
• Hoodoo Mountain
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 Al. 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.
LEGACY Bystander sees fire Initial resources are Confirmati.on and Full containment
APPROACH and calls 911 deployed to confirm dissemination by resources deployed+
incident&location radio utilities notified
WITH Pano Stations First responders& Full containment & Accelerate utility
PANC) au aitically detect utilities are notified+ resources deployed wildfire mitigation
smoke receive live video
through Pano 360 plans+activities
14
tr.
Pano Al Functionality
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 Al is helping detect wildfires in Washington,"Sept.11,2023,How Al is helping detect wildfires in Washington-OPB
37
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 1, Page 37 of 114

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 r __
improve our information when making operational decisions, which is
particularly important as we consider Public Safety Power Shutoffs.
PG&E installs a weather station.
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.
Situational Awareness
Budget(in Mausands) 2020 Actual 2021 Actual 2022 Actwl 2023AMA! 2024 2025 2026 2027 2028 2029 Total
Fire Weather Dashboard $198 $189 $64 S447 $1,272 $40 S40 540 $40 S40 S2,370
Wildfire Cameras so $0 $0 so $0 So $0 $0 So $0 s0
Weather Stations 0 0 0 0 0 0 0 0 0 0 s0
Total SituarlaralAxareness(rap) $198 $199 S64 $417 $1,272 $40 540 $40 $40 $40 S2,370
Total Wildfire Capital Budget S3,421 $19,375 $26,066 $28,319 $33,750 535,250 $60,250 $60,250 $35,250 $35,250 S337,181
SA of capita/Budger 6% 1% 0% 2% 4% 0% 0% 0% 0% 0% 1%
Fire Weather Dashboard so $0 $41 $70 S75 S75 $75 $75 $75 $75 $561
Total Shatiarall Anareness(O&M) So SO $41 $70 $75 $75 $75 S75 S75 $75 $561
Total MWIre 08M Budget $2,430 $7,602 $17,273 $19,727 $16,721 $15,391 $13,912 S1L $11,050 $10,160 $126,296
SA%of O&M Budget 0% 0% 0% 0% 0% 0% 1% 1% 1% 1% 0%
Table 11.Situational Awareness Actual and Budget Expenditures
Operations & Response l �.........•� �1 r;�u;��
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
38
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 1, Page 38 of 114

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.
F.,"lateral
Automation Clrcults
Automation equipment provides"eyes" on some Main Trunk Midline
fuzes) CircultNo
of our most critical infrastructure in high fire ( j Rec,oset _,
J
threat areas. For example, midline circuit
Risk
Su lstalion W Elevated 2 er
reclosers are often deployed on long distribution circot Recloeer
(SCADA) Risk
lines where substation-based equipment cannot _.
adequately protect the entire length of the Example ofAvista's use of a recloser
circuit. Urban distribution
IEEE Bushing lines are typically 5 to 10 miles in length, while rural counterparts can
Interface
Vacuum extend hundreds of miles. Many of Avista's circuit breakers do not support
Interrupter
Voltage monitoring or control, which means they cannot be remotely operated,
Sensor
requiring manual intervention to make changes to settings or to identify an
Epoxy issue.This may take several hours depending on location and crew
Encapsulation Current/ y p g
Voltage
Sensors availability. Part of the Wildfire Resiliency Plan is installing modern circuit
Drive
Assembly reclosers on circuits deemed potentially at risk.These new reclosers are
Manual
open capable of remote observation and operation so do not require manual
Handle
Magnetic . intervention. We are also updating some "dark" substations located in high
Actuator
fire threat areas, meaning those currently lacking automation and
Position
Indicator communications equipment, so they can be monitored and controlled
Diagram of a distribution remotely as well.
recloser
39
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 1, Page 39 of 114

+ 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
Substation circuit breaker 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 rA
located in high threat fire areas and lack communications ! yj -
equipment. Another thirty substations require hardware '
upgrades to support a fully automated Fire Safety Mode
system.This work includes 129 substation breakers that serve
C'_f
downstream WUI 2 or 3 zones. Additional units both on the
distribution grid (midline devices) and those located in Avista substation upgrade work.
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 7Safety
eclosers Commissioned/Settings Only n/a 65 100 1
4-5 substations per year, tributionMidlineReclosersInstalled n/a 7 17 7
with the goal of forty-five installed n/a 2 0 9
stations capable of remote monitoring and control by Table 12.Operations&Response Program Status
2029.41 It is important to realize that the cost of updating Note:This program did not begin until 2021.
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 Program,while some
Tier 1 were also included based on historical events).
41 Note that this number is based upon allocated budgets.
40
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 1, Page 40 of 114

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 i e
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 Avista restores power in Medical Lake in 2023
wildfire situations.These 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
"1 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
t 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.
EOP exercise at Avisto 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
41
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 1, Page 41 of 114

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 Cross-training to keep first responders safe.
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 2022 �.�'.-E 2�23 ��>F
Washington. In
0 25 50 100 Miles 0 25 50 100 Miles
Washington,the '
DNR has agreed m
'
to manage all fire ;ai
response even Montana Montana
outside of their
jurisdiction. Was was
The goal of these
agreements is to
get a rapid
response to the Oregon Oregon
site of the fault. If
the fault causes a Figure 17.Avista's Expedited Response Agreements started in Spokane County in 2022 and now cover
spark event and a fire nearly our entire service territory.
42
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 1, Page 42 of 114

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
d�PSNINGTpN
covered by these agreements,which have no expiration date and no cost
associated with the responses. In 2023 we used our expedited response
PC
agreements 4 times in Washington State and 2 times in Idaho. To date,there have ; o
been no fires found while using these expedited response agreements, but the gyro
R NATUaP
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. These 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 from
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.This
includes county and city emergency managers, local
emergency planning committees, local public health
Avista has partnered with firefighters throughout our history. 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 Fire 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
43
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 1, Page 43 of 114

series of annual Wildfire ti��p�tT� \l� y�Eprye 01,�", 9,
Telephone Town Hall Q 9N d SDg
meetings. yF L ��
UTc T
Avista is also an active AI2AfH TACOMA►OWEN
� ..
Im ... ................
participant in the Inland Powli �pSNINp,GN
WASHINGTON STATE DEPT OF
Empire Fire Chiefs PUGET :" T�=� nATURAL
Association. We were asked ®SOUND = °ENERGV
RESOURCES ,�,iqGa
SpokInd be
�NglU0.�
to join in their meetings to S"ING,°N SOUHIIM-11101GYIA
add input on critical CHRAN COUNTY J EDISON`
infrastructure capabilities ;`,, p�G NOrthWesterri
NATUOL Drier
° gy
44 " ' �.and needs during wildfire
and other emergency �PAC f'IFICORP
responses.This group
includes the Fire Chief of the Some ofAvista's Partners
City of Spokane and the Chiefs of Spokane County as well as the Spokane County Department of
Emergency Management 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.
44
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 1, Page 44 of 114

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 Fire Safety
Electric utilities use automatic Mode
reclosing to improve system Operations
reliability through managing Levels
momentary faults on overhead
conductor that may result in
extended outages and impacts to
customers. Electric faults occur
when equipment fails or when �o I
weather and wind cause branches Risk Based Settings
-------------- ----- --------------
Reliability Based Settings n
or trees to fall into powerlines,for i
example. Equipment failures,
vegetation contacts, wind, snow,
71
and lightning are significant \0 5.5-7, Public
0-3.5 3.5-5.5 Extreme Safety
contributors to line faults, and Normal Fire Safety Protection Power
Operations Operations Settings Shutoffs
each line fault represents
interruptions to electric Figure 18.Fire Safety Mode Operation Steps and Fire Risk Index Levels
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 attempts 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,
45
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 1, Page 45 of 114

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
Firerisk 0 1 2 3 4 5 6 6.5 7 7.5 9t0 be considered may
index:
Automated Fire Potential
Base Fire Safety include,without
2020 Fire Safety y(FSM)Mode PSPs
Safety Mode limitation,fire risk
Strategy: Manual Fire Potential
Safet ' �'• ' Original Fire Safety Mode PSPS potential, relative
y humidity,field
Reliability Risk WIkIWreRlsk observations and
measurements,
Firerisk 0 1 2 3 4 5 5.5 6 7 anticipated duration of
index:
events, geographic
st Extreme
2024 Fire Base Fire
Safety ProtSyecemtion OperationsProtection characteristics, critical
y settings Safety Mode Se ling
Mode infrastructure,wind
Strategy:
Fire Danger
Rating Moderate MEW,
direction and speeds,
Classifications
medically vulnerable
RellabilWyW9k WildTireRisk populations, proximity
to aid, utility resources
Figure 19.Fire Safety Mode Operations in 2020 Versus 2024 F available, etc.This list
46
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 1, Page 46 of 114

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 Mode,"this operating mode, which we now call Fire Safety Mode (FSM), involves both identifying
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 Fire Safety Mode 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. Fire safety Mode#of Elevated Operation Days 4
Fire Safety Mode#of Circuits Elevated 20
Fire Safety Mode#of Circuits Elevated That Tripped Off 2
An additional upgrade to the Fire Safety Number of Faults Without Ignition Events 2
Mode methodology is our use of the Severe Number of Customers Impacted From Elevated Tripped Circuits 961
Fire Danger Index(SFDI) developed by Expedited Response Requests 6
the U.S. Forest Service.43 This is a Table 13.Fire Safety Mode Operations
Note:We implemented this program in 2023.
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 I US Forest Service Research and Development
usda. ov
47
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 1, Page 47 of 114

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,
48
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 1, Page 48 of 114

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 Avista may initiate a PSPS if
on select circuits, Avista can achieve a better balance between reliability the Company determines
that a combination of
and fire safety objectives.This means that at times of extreme risk, critical conditions at certain
customer reliability may be sacrificed in order to focus on customer locations creates the
safety. We believe that if this balance is carefully considered and potential for consequential
risk of wildfire ignition,
decisions are made with the sophisticated analysis and guidance spread,and severe resulting
provided by the Fire Weather Dashboard,we can help make our system harm,and that those risks
safer in times of fire threat while minimizing customer impact. outweigh the corresponding
risks associated with
initiating the PSPS.
Public Safety Power Shutoffs :U�
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
O conditions combine to increase the risk of wildfire. It is considered a top tier
PSPS mitigation tool to help prevent utility involved wildfires in extreme fire threat
Considerations
situations.
QFire Risk Index
C ritical Customers As part of its operational mitigation strategies related to Fire Safety Mode
Operational
Criticality operations,Avista developed a Public Safety Power Shutoff Plan for
I�Medically Vulnerable proactively de-energizing facilities located in high risk areas during extreme
II Actual Weather Conditions weather conditions that have the potential to propagate large destructive
Duration&Event wildfires. Our PSPS Plan,to be implemented for the first time (if needed)
Utility Resources during the 2024 fire season, is essentially the last step in our Fire Safety
Available
Mode operations,though the major difference between Fire Safety Mode
Fire Spread Risk
Operations and PSPS is that Fire Safety circuits are only removed from
Proximity to Aid
service when an actual fault is experienced on the line, while PSPS circuits
are proactively disconnected based on an assessment of risk.
49
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 1, Page 49 of 114

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.
J
High Winds Low Dry Fire Population Public
(Including Red Humidity Vegetation Threat &Structures Safety
Flag warnings) that could serve to electric Risk
as fuel 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 team41 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.
50
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 1, Page 50 of 114

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.
Operations&Response
i �Waugmm r
r $il $1,355 $1,599 $1,273 5438 %50 $650 5650 5650 5550 57,946
SO $515 $741 $1,555 $2,788 5 500 $4,500 $4,500 $4,500 $4,500 $28,099
S3 S3 SO SO SD SO SO SO 50 9 $0
5331 $1,868 $2,3401 $2,8281 $3,226 4150 $5,1501 $5,150 55,150 $5,150 s36,045
$3,421 $19,375 $26,0% $28,319 533,150 $35,250 $60,250 A,250 $95,M $35,250 $337,181
1% 10% 9% 10%1 NJ 15% 9% 9% 15% 15% 11%
Table 14.Operations&Response Actual and Budget Expenditures
51
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 1, Page 51 of 114

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 Wildfire season
reducing the impact of wildfires. is here.
Avista is ready.
Avista's Wildfire communications plans are directed at all
of Avista's key participants including customers, Dry vegetation and high winds increae the chances of
virilemployees, state and local government officials and andrs ez gut Mats is doing our part to keep ourSya:em
and communities safe.
We are partnering with property owner to mrnmm ar trim
regulators, law enforcement,fire departments, emergency trees nmrour lines.We are nuking improvements to nuke
our syrem stronger.And we arc changing operations when
management agencies, local media, and shareholders. Our hot windy foreouts are predicted,In area of higher risk.vre
on set the system to be more semitiot-.meaning we don't try
wildfire communications goals are to create awareness of and came-We automaticallyato the liningwmes in contact
g with a line_We physitatly patrol the fine when it's sate to
make sure there is no fire danger before reenergiang.
Avista's work to prevent or mitigate the risk of wildfires, Our system isbuItto keep outagestoa minimum buthelp
us keep you informed.Log in and update your contact
promote the safety and well-being of all customers,to infodr-aniZon our,mbtite.Also sign uptorete;,re
pmweroutage alerts by text or mobile app.
engage customers in programs that impact them and their Clkktheword-autag:in the top navigation to
locate the page.We just want to keep you safe.
communities, and to help our customers and employees Leam more about our wildfire_res at
my—ista.cornJwi tdfira
stay safe.
The 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.
Avista
• Demonstrate Avista's focus on prioritizing the safety and well-being Communications
of its customers and the communities it serves. •Avista Connections
Newsletters
• Provide examples of the Wildfire Resiliency Plan in action and show . Customer Emails
progress as it is implemented. . Fire Safety Mode
Specific Outreach
• Engage customers in programs that impact them and their . Telephone Town Halls
communities. • Print Ads
•Avista Website
We have a variety of ways we communicate with customers about • Community Meetings
wildfire-related work on the system that may impact their service. We
52
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 1, Page 52 of 114

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 Community Outreach
and emailed newsletters in
Washinton
advance of fire season to •Dept.ofLandsNR/Idaho
•Nez Farce Tribe -F.M a is fer{dl -
educate all electric customers WLAI Z&3
•Spokane Tribe C�Mli+ C sftmrsLeAk (Tenerd s. :
Tirs
about Avista's Wildfire • Specific
Colville Tribe � �� Cuy ��
Resiliency Plan and inviting gat
First Responders \i7
participation in our Town Hall � VulncraMc
•Spokane County
events. Wildfire related updates
•Stevens County
are provided throughout fire Kootenai County
season. We also run a series of •BenewahCounty
print ads in more rural Emergency Managers 4 I
communities related to the
�iVISTA
Wildfire Plan and PSPS. More
than 130 ads run in 33 different publications, including several in Spanish, reaching 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
53
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 1, Page 53 of 114

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.The CARES (Customer Assistance Referral
and Evaluation Services)Team 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 identify 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 Mercadito 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.
54
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 1, Page 54 of 114

• 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 n
also subtitled. We are working with the 1
Washington State Dept. of Social and Health t
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 Bow ManNpoeaNNe
sy�� oTxnjoj,Hl1N 311e e3ona"O�TN npN
American Sign Language.Avista presented its °a° m° y¢ x�poNN
Wildfire Resiliency Plan to approximately 80
staff from DSHS and then collected feedback °�° ••.� e -� �'„
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 ; Avisto
our communications in this area. outreach
'M � '° " materials
• Critical Infrastructure Customer Identification.The in Russian
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.
2024 PSPS Meeting Participation
• PSPS Outreach. In 2024 the Company reached out to over 14,000 Agency Partners 94
first responders, emergency managers, critical customer groups, city/county 418
service providers, health organizations, city and county leaders, Emergency Management 201First Responders 60
state agencies, and others to provide education around our PSPS Medical 117
Plan and to strategize about protecting and supporting customers Service Provider 20
through potential outages.46 Town Hall 13,262
TOTAL 14,172
46 More details about the 2024 PSPS Outreach can be found in Appendix A.
55
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 1, Page 55 of 114

• Equity Advisory Group.Avista is also working closely with its Equity Advisory Group to fully
develop and identify Highly Impacted Communities and Vulnerable Populations("Named
Communities") unique to the Company's service territory.The 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 disabilities,
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 Iy �l In s I� �I ��I I�� I M
a Clean Energy Implementation Plan (CEIP) Equality doesn't mean Equity
47 Clean Energy Transformation Act-Washington State Department of Commerce
56
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 1, Page 56 of 114

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 ti
f
populations:
• Highly Impacted Community means ,
a community designated as such by 0
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 _.
• Vulnerable Populations mean
communities that experience a
disproportionate cumulative risk
from environmental burdens due
to adverse socioeconomic factors, ,end
including high unemployment, high ="
housing and transportation costs
relative to income, limited access
to food and health care, and linguistic Figure 20.Vulnerable Population Areas in Avista's Washington Service
isolation, as well as sensitivity factors Territory
such as low birth weight and higher rates of hospitalization.41
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. More than 65%of Avista's high fire threat districts coincide with 2010 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 I Washington State Department of Health
49 Ibid.
50 Climate and Economic Justice Screening Tool,Explore the map-Climate&Economic Justice Screening Tool(geoplatform.gov)
57
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 1, Page 57 of 114

In Washington State, vananno """"'yU�MYNA)otsford randfnr
1,044 of 1,708 miles
Duncan
of powerlines
located in high fire
risk zones are `
located in � .
underserved and
financially
Rank i�4'�M1 , fi•1/1 a
overburdened High
communities. 10
Avista utilized 8
information from 6 s'�Sti S
s
the Washington 4 _ r 5ton
State Health
z
Disparities Map to �} ---
identify these `ow _ {
populations.slln - Portland
Idaho, 794 of 1,037 Figure 21. Washington State Disparities Map
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 I 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)
58
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 1, Page 58 of 114

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."
Even so,there were about 200 more fires in Washington Northwest DO-Abnormally Dry
Dl-Moderate Drought
compared to 2022,though the number of acres burned was drought D2-Severe Drought
conditions in mid- D3-Extreme Drought
gh
down by 15%due to well coordinated response from the summer 2023 D' Ex`e ° °gh`
� Total Area in D—Drought(Dl-D4)
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 2023 with 165,365 acres burned. Of those fires, 41 were considered "large" (over 100
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.16
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 the 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 I Drought.gov and Washington I 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 I 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(arcqis.com)
51 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)
59
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 1, Page 59 of 114

Impacts to Infrastructure Noxon-Pine Creek 230kV
In 2023 Avista lost 266 structures (transmission
and distribution)to wildfire.
On July 8, 2023, approximately one acre was t
burned near Avista's Noxon-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 ,. About 1 acre
a wood crossarm. Suspected Cause:Broken bond wire
Burned trees and brush
Ritzville,WA—July 17th
On July 17, 2023, about 250 acres burned in
,F 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.
• 250Acres On July 29, 2023, close to Avista's Plummer,
• Believed to a combine-caused fire Idaho substation, it is suspected that a broken
• 2 abandoned buildings lost crossarm on a transmission structure on the
• Destroyed 9 distribution poles
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.
• Fire about 20 feet in diameter
'd Right outside Plummer Substation
a
Shawnee-Sunset 115 kV—August 3 On August 3, Broken transmission crossarm
• No public structures damaged
2023, a Burned brush
wildfire Quick response by fire department
burned
through the
right-of-way
underthe
Shawnee-
Sunset 115 kV Benewah-Pine Creek 115 kV—July 29th
About 1 acre in size
• Outside Spangle Substation line near our
• Damaged 1 transmission structure
• No public structures damaged Spangle,Washington substation, destroying one of our
Burned brush a
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.
60
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 1, Page 60 of 114

On August 18, 2023,the Gray Fire burned
through the communities of Medical Lake and
Four Lakes, Washington.This fire started in
�i
the early afternoon in a rural area and spread
rapidly due to hot, dry conditions and . ; _•
n
sustained southwesterly winds that gusted toa ti
35 mph. This fire destroyed 259 homes and
structures, prompted the mass evacuation of
residents, and was linked to the death of a �' > ,_3
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 Images from the Gray Fire in Medical Lake
255 distribution poles. CVay Fire Medical Lake—
r
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 • 1o,os5Acres
was restored within three days for the people returning to their •Caused by faulty outdoor
light.
homes, and gas service was restored in 4-5 days. •259 homes&buildings lost.
• 1 fatality
The other large fire in Avista's service territory in 2023 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
Hospital Fire Oro ino— ugust 29th 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.
• 53Acres
• Cause:Under Investigation On August 29, 2023, the last fire of the season impacting our
• Destroyed 6 homes&multiple outbuildings
• Destroyed 1 transmission H-Frame infrastructure occurred near Orofino, Idaho. A 30 mph wind drove
4.
the fire across 53 acres, destroying six homes and multiple
a' outbuildings.Avista lost one transmission H-frame structure in this
fire.The cause of this fire is under investigation.
61
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 1, Page 61 of 114

2024 Fire Season Outlook Drought&Dryness11,Dl,ies %.3%
OD-Abnormally Dry 36.3%
Dl-htad—Drought 37.6%
Long term in the D2-severe Drought 3.3%
L D3-Ex[reme 0
Drought .0%
N-B
Northwest the TototA in Dr Drought
3.D%
I , Total Area in Drought(Dl-D9) 4a.T%
number, size, and
severity of wildfires E..
has increased in 0
recent years,
primarily associated
with increased
temperature and D 0
drought, hotter and Drought&Dryness Categories %ot wA
DO-Abnormally Dry 33.6%
drier summers(and the associated drier soils Dl-Aodemte Drought
Da-severe Drought
and vegetation), earlier spring melting leading D3-Extreme Drought
D4-Exceptional Drought 0.01.
to decreased summer water availability, and Total Area in Drought(Dl-D4) s8.3%
reduced snowpack.These climate changes Drought maps courtesy of Drought.gov.Current as of August2024
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 Nina 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.61
59 USDA Climate Hub,"Climate Change and Wildfire in Idaho,Oregon,and Washington,"Climate Change and Wildfire in Idaho,Oregon,and Washington
I 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 I April 3,
20241 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
62
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 1, Page 62 of 114

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 within
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 U.S.Vegetation-Related
addition to finding more risk trees than anticipated, Contract Costs
tree-related labor resources have been an issue. 0 Remained Flat
Utilities across the western U.S. are all competing for 0Increased 1%-5%
Increased 6%-10%
the same labor resources, leading to large increases 0 Increased 11%-15%
in vegetation contract crew costs as shown in the Increased Over 75%
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 Figure 22.Costs of Vegetation Management Contractors
costs—sometimes substantially—in 2023.64 Across the U.S.from 2022 to 2023
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)
63
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 1, Page 63 of 114

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 NIVI5 O(OSPAVAL
In 2023 we completed 6,466 miles of Tree Health Assessment
satellite inspections on the Fpn-band orthophoto images and forest metric.are used to identify stressed vegetation it the corridor.
w—sed orthophotos are displayed in both the RGB(true cold)and CIR(Color Inhe(ed)to analyze the
status of each tree.CIR imagery penetrates atmospheric haze and assists in det—Ming the health by looking
distribution system. However,the at the chlorophyll reflectance in the vegetation.Infrared Refkctence(IR)is an indicator of vegetation health
by showing chlorophyll reflectivity in the vegetation.The healthier the vegetation the higher the reflectance
aantt- brighter red viuWix ti When vegetaton appear stressed.the vegetation appears light red to gray
transmission LiDAR inspections did
Q.
not meet the target of 2,086 miles. health-.•..ssmenL-era conducted on all vegetation in the ROW that are determined to be at potential risk for
falhng into conductions This method is conservative by design to redme the risk of omission For th.Aveta
We were only able to capture 1 679 Transmisz on VM 2023 project,Use health was ml dsd ase separate layer on the INWE platform with each
l idenbhad tree fond m the vegetation aegmentabon p--s assigned a healthy.stressed,or very str--sad
healthattnbuteSee the`'age b " ":.ue`l" for ah-wn`f healthy,rtr—d.and—y:t—sedre tez lxatcd
miles within budget. Our original
on the Nwon-Puw Meek Trion—ion ..it—th accarnpanyrg 3D UOAR imagery fa a selected
group of tree
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 Tne Health altribulr and 3D LiDAR Paint Claud
Imagery visualised n.ar Prieherd,ID
that this change will provide us with
more reliability. Tree,Health Analyzit;Legend
Icon Attribute Descnpt—
Heathy TKe tO%avearea
• Lan Man
Learning and Incorporating Digital P N•w�epelyge
O .etna'.Sed Tree to to 30%atrereea P•e1a
Inspection Data warm polygon
• very Stre--d T— W—«ttun 30%at—ae
As mentioned earlier, Avista is also .kv.w mPolygon
beginning to incorporate remotely
sensed LiDAR and satellite imagery Sample of an Avista Digital Data Report
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.
64
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 1, Page 64 of 114

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
WildCre
and adjusting them as we see opportunities for improvement. We have
� Resilieney
made some significant improvements since the Plan began. Some of a�
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, o©
county commissioners,tribal leaders, and
medical service providers for example, as
well as employing more media outreach.
Each year of engagement with our
"r e
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 M9
our outreach, including non-English and for
those who are hearing impaired.
Safe Tree Program
uktngaproamve aFproamao prerant[mun taetweentreesvegelat ana power lines In Yeur omgon e rore Yw wq In wasnllgtan laano,or
to Weanw win You as a Islaawner,to replan Vees on Your GopwaY Vlal mule[one Into
Outreach to Vulnerable Customers � w�emlln at no[mueYo" ryam""apama
m you as as�Your veesrm removal ano repu[ement.It You aevae b 90 imwv4 our
We have developed an additional focus on
vie appxlatt Yourpatrermip to keep our[ommumry sate wr mare lnrormauon.please eaun wereaoing moreupwte[t agalmtwllenres
identifying and reaching our most °
vulnerable customers, including the ability mrs mry ry
to quickly identify and contact critical and A wise investment inpreparedness yam",son
keeping people ano pmperryvre.aa,vre are wgnmmg our[lrramnreguxm ra
pleu�entlnq mnlga"ng ano mauang melmpxt pr wianea wnnanrn mnan<ea auyxv avlppre aeplpnry Emergenry aesponrers
life support customers to warn them of the rs p"a„[omaaa
potential for elevated protection settings eery aaa
NMaVI Iency P.an
or a Public Safety Power Shutoff. In 2023
we added a life support customer flag to all the Avisto's Wildfire Website for Customers
65
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 1, Page 65 of 114

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. En
Some of these entities are key to
responding to and mitigating outages, Se„,,,, care cenrers
Emergency Services Basic Services
for example communications required I
to work with Avista crews in the field ft
Vulnerable
performing the work the power Access for First Population
r Populations
Responders
required to open the bay doors at a
fire station, or energy needed to Va. h
Transportation c omm u n Ic,ttions
operate water pumps to fight fires.
Knowing the location and needs of public
I L 111 m
salary
these providers will reduce the ,�., .—I&S i er
Traffic Systems - - --
40
impacts of an outage event and SupportAgencles 04 Was[eviacer,
I A Cooling Canters
increase levels of public safety. SShelters
Government Facilities
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
66
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 1, Page 66 of 114

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 These 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 DNR Fire Causes 2023
Fires ignitions from all sources including natural, human- Misc.
Natural 8%
caused, and utility-caused fires seem to randomly occur 10% Celebration
$'%O Equi,/Vehicle
within Avista's service territory.This appears to be confirmed ,%
by the Washington Dept. of Natural Resources list of fire �✓�;�-,--____ Arson
causes in Washington State in 2023, as shown in pie chart. Debris Burning 1%
Jr, _/Firearms
However,fires of severe consequence and size have regularly 1%
Power Gen
occurred in areas that Avista has modeled as being at high lJndetermIne:`i 3%
risk, indicating the accuracy of our Dashboard. For example, sml%ng
both of the large fires of consequence in 2023 within Avista's Ra1%oad
service territory, in Medical Lake and Elk, Washington, Figure23. Washington Dept.of Natural
occurred in areas that Avista's Fire Weather Dashboard Resources Fire Causes 2023
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 our 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
67
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 1, Page 67 of 114

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
Fire risk 0 1 2 3 4 5 6 6.5 7 7.5 9
(basically putting the index, i
circuits "on alert" 2020-2023Fire Automated FireNormal Hea Potential
Safety Mode safety ac atee PSPS
during fire season with Strategy: Manual Fire �_ Poten al
SafetyMode - - PSPS
trigger points set a 3 to
6.4) rtetsnmty Rbk
3. Elevated FSM (with
Fire risk p 1 2 3 4 5 5.5 6 7
trigger points between index: i
System Extreme
2024 Fire Fire Safety
6.5 and 6.9) Safe Protection a Or Protection
Mode Settings Mode Setting
4. Extreme FSM (trigger Strategy:
Fire Danger
lating Very
points 7 to 7.5) Classifications High High
5. Potential De- MoawMyl9ak
energization/Public
Safety Power Shutoff
(above 7.5) Figure 24.Fire Safety Mode Comparison:2020-2023 vs.2024
68
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 1, Page 68 of 114

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
Undergrounding Distribution
outages and equipment failures that could potentially lead to wildfire Conductor
69
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 1, Page 69 of 114

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 Cross Training with Firefighters '
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 r
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 1 +.
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 Firefighters put out groundfire caused by a
respond and are able to engage the fire quickly, which is key to poiefire.
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.
70
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 1, Page 70 of 114

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 isrrzr_t,
harder to control.66 A recent major r
joint study undertaken by the U.S. Forest Service,The Nature Fuel Reduction Efforts Before&After
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 Tree work directly.68 The "Safe Tree
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?I US Forest Service Research and
Development(usda.gov)
61"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.mvavista.com/safety/were-doing-more-to-protect-against-wildfires or email [e-mail]
71
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 1, Page 71 of 114

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 joined 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 40 Poiigons Unapproved(0) Approved(Unplanned)(82) Planning(185) Active(191) Completed(2)
Digital data is both a learning R Year
experience and a source of continuous
�� t� per ,Itl,317wy i�i,1n`v wtk
improvement. In acquiring digital data �,, �, 'y�G7�,�g� a�1�. ,,,,,� , t3 6p:: ) M.•p�
on both the transmission and11 4 •:a{ x e- ; � I
distributions systems for identifying risk �` $�: • ��` � ,...
trees we are becoming familiar with the
large amount of data these tools provide
' iU
and how to use all of this information to 4A 'ai!
focus our vegetation efforts in areas that �u.
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 Example screensnorof digital data results.
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.
72
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 1, Page 72 of 114

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 IL
-
growth and/or developed
areas. This segregation is
significant from a cost
4
perspective, as it allows us
to separate our mitigation `FMIA .
efforts into poles in high Avisto Steel Transmission Pole Replacement Work
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.
73
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 1, Page 73 of 114

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 Management System.This 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.
I Animal Guards: Parts installed to act as a barrier to stop animals such as
Animal Guard 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.
J
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. v ,
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" Fire Safety Mode 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
D.., Time Delay pause before a reclose attempt. If the circuit
Instantaneous„Tripping Open Period Tripping remains faulted, such as wire-down or a tree in the
.second)
Auto-Reclose 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
74
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 1, Page 74 of 114

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. CAM
Customer Average
Interruption Duration
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 SAIFI CAIFI
System Average AIL System Average
customers who actually experienced an interruption. interruption Frequency Interruption Duration
CAIFI: CAM refers to "Customer Average Interruption Frequency 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 19.405,the Clean Energy
Transformation Act (CETA).70 This Act requires all retail sales of electricity to Washington customers
0 RCW 19.405.040:Greenhouse gas neutrality—Responsibilities for electric utilities—Energy transformation project criteria—Penalties.Chapter 19.405
75
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 1, Page 75 of 114

be greenhouse gas neutral by January 1, 2030. 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. power plant transmission lines carry Electric Circuit
generates electricity electricity long distances
distribution lines carry
CEML Stands for"Customers Experiencing f�/"' electricity to houses
Multiple Interruptions"which indicates
the ratio of customers experiencing 1 or
more sustained interruptions as a step ownriscrcitys
step down electricity
translarmer steps before it enters houses
percent of the total number of p neighborhood
M up voltage for transformer steps
customers served.This is a customer-
transmission down voltage
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 t'
loading. Circuit breakers cut the power until someone can fix the problem. In
addition, using a circuit breaker, interruption and reclosing times can be Circuit Breaker
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 ICircuitMil '
the flow. I� B Line Miles
Circuit Mile:The total length in miles of separate
Circuit Recloser
1 Relays circuits regardless of the number of conductors
;. Modern circuit reclosers are used per circuit.
controlled via microprocessor
relays.In this photograph,a
Schweitzer SEL-351R relay is Circuit Recloser: Circuit reclosers are similar to
ii beingtested priorto installation.
' Equipment connected to household breakers.They shut off the power when
communication systems(SCADA
&DMS(are continuously trouble has been detected then automatically test
monitored and capable of
remote operation.This the line to see if the trouble has been removed. If
I' ! functionality is an important
element in Avista's wildfire the problem is only temporary,the recloser
strategy.
automatically resets itself and restores electrical
power.Adding communications to circuit reclosers
RM WASHINGTON CLEAN ENERGY TRANSFORMATION ACT
76
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 1, Page 76 of 114

provides monitoring and control functionality, including the
ability to operate the device remotely. Also, by placing circuit A Lesson
reclosers at strategic locations,Avista Distribution Operations
can re-task or control those devices during periods of elevated What happens if
lightning strikes?
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: CAI DI 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.
�Ilflrr� 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
t 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.
77
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 1, Page 77 of 114

Critical Facilities/Infrastructure: Referring to outage events,these are F
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. -i
{ Above:Transmission
Crossarm:A crossarm is a piece of hardware providing an crossarm
attachment point for insulators to support the loading of
/ { Left:Distribution
overhead conductors.The crossarm is typically made of crossarm
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:This has been renamed the "Safe Tree 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 :.` cutout
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 "Melt"
the line for maintenance or repair or to prevent an outage from spreading. tube.
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
y ; / /0 added a 100% risk tree inspection to non-urban areas of the
-i distribution system in addition to the routine cycle trimming to more
�
rapidly identify and address vegetation issues that may lead to fire.
A sick and damaged"danger"tree
located adjacent to power lines. 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
78
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 1, Page 78 of 114

DEAD FUEL MOISTURE CLASSES tree within or adjacent to the utility right-of-way that is
dead, diseased, or dying or has a structural defect or lean
Cured Grass Needle Litter 0ow�ed wood 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).
Moisture and flammability of dead fuels is governed
by the weather conditions around them.Fine dead
fuels,like grass and litter,gainand lose t moisture Dead Fuel Moisture: Moisture content of dead vegetation,
from hour to hour as the sun rises and sets,the
temperature risesandfalls,and moisture moves which responds to current environmental conditions.This is
between the fuel and the air.Peak burning
conditions typically°"urlate in the after"°°". critical in determining fire risk potential.
Larger dead woody fuels dry more slowly and
usually burn most readily during the peak season.
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 Creating Defensible Space
as a buffer, an area a minimum of 30 feet
around a structure that is cleared of 30-foot-defensible space 70 feet too feet
flammable brush or vegetation. In forested
Game Vent aoet � G �p a,-
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 Grid Hardening 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
79
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 1, Page 79 of 114

obsolete small copper wire with modern steel reinforced aluminum wire, installing 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 Drip Torch: A hand-held device for igniting fires by dripping flaming
t` liquid fuel on the materials to be burned; consists of a fuel fount,
pburner 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 PA94MM
depletion in the soil. Studies done by NASA found a strong (Trip and stay off until manually
correlation between dry soil and an increase in fires.71 Dry soil can t
help create favorable ignition conditions, especially in regard to its Elevated Fire Safety Mode
(Trip,test,then reclose if good—no
impacts on the health of vegetation. delay/wait)
Dry Land Mode (DLM): Renamed Fire Safety Mode, this is a non Base Level Fire Saf,Jo
-
(Trip,wait,test,then rec
reclosing distribution protection scheme used during summer fire t
season (typically July and August) on circuits determined to be at
Non-Fire Season
risk for fire activity based on a variety of factors including (Normal Operations,multiple recloses allowed)
vegetation, past events, and age of equipment. This strategy
Original Dry Land Mode Levels
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 StudV Finds a Connection Between Wildfires and
Drought-NASA
80
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 1, Page 80 of 114

de-energize the entire circuit for permanent faults by
ITY tripping off at the breaker.
Elevated Fire Danger means that weather and land conditions are
favorable for erratic fire spread,if a fire does start. Elevated Fire Threat Areas:These are WUI Tiers 2
Stay safe from fire danger with those tips! ,,.� ti- - and 3 in which there is a higher risk for the ignition
Properly discard cigarettes-don'ttoss and rapid spread of wildfires due to the proximity of
them from a vehicle
• Avoid parking on dry grass and check
flammable vegetation,vegetation ignitability, human
trailers for dragging chains. �. activity and habitation zones, and other
Avoid activifiesthal cause open flames
or sparks - "'+ environmental conditions.
Mild►;
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 ° g.
ri
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. Training with Firefighters
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 dM, �e a
conductor.This strategy will reduce � • ° ° 10 111
L J
wildfire risk and increase safety to the Community Protected
communities facing the highest risk from %i6o
5 Miles out
Avista's distribution electric facilities.This ..
strategic approach will allow Avista to
mitigate the most risk for the least cost related to conversion to underground, allowing resources
81
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 1, Page 81 of 114

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 "Hot Line Hold." In this
configuration, auto reclosing is disabled, and instantaneous Instantaneous Breaker L/O
tripping is enabled. A circuit that experiences a fault will trip off Tripping
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 into 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.
82
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 1, Page 82 of 114

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 pole Fire on a
stronger than wood. In addition,fiberglass crossarms Wood Crossarm _ I�
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 Fiberglass Crossarm
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. - -I W
;�Y f
Fire Break:A natural or constructed barrier used to stop orR.-I +'
check fires that may occur, or to provide a control line
from which to work.
bulldozeCrews
break at thefire's edge
along
83
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 1, Page 83 of 114

Fire Behavior Index
In Forest Fuels r
V.A. 24-50
Fire Behavior - -. y; 12-24
Index r
L
~ y til
.A..L.1 �
Fire Danger
High Catastrophic
Rating
y _ High probability of
Fire Behavior . Increased likelihood loss in life and
Increasing focus on of community loss property.
F irestypically defensive &significant
Typical prescribed suppressed with suppression consequences.
burn conditions. offensive fire strategies.Aerial
1.
r Fire likely to self- Fires likely to be management suppression likely
IL eutinguish self-sustaining. strategies. be effective.
"A
ire Behavior is made up of steps or transitions triggered by a change in fire behavior,suppression response,or potential for impacts.
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 \\'
a s a
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.
Ford Corkscrew Fire Perimeter
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. . ...,
84
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 1, Page 84 of 114

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 resins that cause them to burn
more quickly and intensely. Weather conditions such as wind,temperature and humidity also play
85
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 1, Page 85 of 114

Firc Spread 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
TO*Own landscape at a much faster rate.
Topographical features of a
landscape, such as slope,
It
elevation, and aspect, can also
tndaer ive�
facilitate wildfire progression. If a
sL,r, Ft,� fire ignites at the bottom of a
t.vesteep slope,for example, it will
Ina forest where fires rare Iy happen,fuel Surface fires Ladder fuelsallow Tree crown fires are spread more quickly uphill
Builds up.There is surface fuel(grass,logs, spread quickly the fire to move up so intensethat they
woody debris,brush),ladder fuels(shrubs, through brush and toward the forest are difficult to because heat rises.
small trees),andtree crowns. debris. canopy. control.
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:This 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
86
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 1, Page 86 of 114

distribution circuits for the upcoming MAX FIRE RISK `
week and highlights the maximum o . `'FR<<:' FR
expected daily risk for every feeder on
Avista s distribution and transmission 5.7
r` FR
systems. •- r
mMAX WIND SPEED FR E2A
FR:32 -
Fuel: Combustible material. Includes, 41 F
so FR3<.T
vegetation, such as grass, leaves, -r
ground litter, plants, shrubs, and trees o 25.3 m FR' FR a
that feed a fire.
Fuel Concentration/Density: Mass of fuel "°""� NWS WARNINGS
(vegetation) in an area which could
oWM>i.n
Combust in a wildfire. Fire Weather Dashboardscreenshot
Fuel Management: Removing,thinning, or otherwise altering vegetation to reduce the potential rate
of propagation or intensity of wildfires.
\ \I UM 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
S
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
4
l�. sy � 1l agencies, leveraging funding to remove fuels near Avista facilities. Sharing
- Fuel Reduction Efforts �:?I-
the cost allows both parties to do more work than each could accomplish
with individual budgets. c
r
Fuse:A device that limits the
Generation Transmission
amount of current flowing through Fuse
O iO,
the circuit.The fuse is constructed
III Transmission line with a small piece of metal that, :-
Power station 'ansfmme. when exposed to high current
_ typically caused by a fault, melts and interrupts the flow of
werline
Substation electricity. Fuses are typically placed on lateral tap lines off
�
Distribution Po the main circuit.
Substation
Consumption Grid: General design of an electric grid, whether looped or
Powerline O
radial, with consequences for reliability and ability to
support de-energization (e.g., being able to deliver electricity
Nome Commercial facliry from an additional source).
87
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 1, Page 87 of 114

Grid Hardening: Actions such as equipment upgrades, Fiberglass with polymer ribs Insulator
maintenance, and planning for more resilient Eyebolt ✓
infrastructure,taken in response to the risk of Hot clamp
undesirable events (such as outages or wildfires) or 3. Bracket
undesirable conditions (such as old or unreliable Lightning arrestor
equipment) of the electrical system in order to i
reduce or moderate those events and conditions, / Disconnect switch
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.
Primary
Hazard Tree: A risk or hazard tree is defined as one that —Hazard Tree Line
is dead, dying, diseased or exhibits obvious structural N Secondary
defects defects such as a co-dominate stem which pose an L1pe
increased fall-in risk with conductor during severe Service Drop
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 t.
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
High Canopy Fire near the Noxon-Pine Creek transmission line in 2023.
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
88
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 1, Page 88 of 114

is little or no fire protection (typically rural or remote areas), or which have experienced historic
wildfires.
Lineman's Safety Equipment
High Value Locations: In Avista's Wildfire Plan,this SAFO YGLASSES ld
bl«k haaaredna sen glare. / HARD HAT
refers to situations where wood poles are p"i"Itidyy when wcrkingonanergind Mae. Made fmm ham plaali"Ith inner
web—M.M.I'll—hea
unl—I aldls to attach acceasariea
replaced with steel to add strength and durability EAR PROTECTION such as ear prdteaidn.Eatendee
brim prole<Is lace Iram lalling debris.
t
Mounla into hardhal slots and has Factory-tested for dielacldc strength.
at high consequence locations such as high- eplaceablatdamddahidn,.Ginarenl
ypes have alnarenl noise resudldn
ratings.(nol pictures)
volume traffic areas, railroad, highway, and river RaUBBERaSLEEVES
w
amdam:aa mdlaaa robber that
crossings, at hard angles, or if access for to Fall bodyNcs,,Hii-se° uhi,to,�iunal`[nntact nth
levaleo bucket.d,Mts
attaches to buck boom wilA energized power source.
maintenance is particularly difficult.These are anyard.ad Inking snap adds
SHIRT
locations where mechanical or fire-related pole RUBBER GLOVES bb%Modacryll db%coltdn
Olelecteolested,rubber name reeistanl fabric tine
'hit.1-d gldvda Idr Mason. slachiag with nnmelalec
failures could lead to increased safety risks and protection.Glove thickness bulldhi.
dictates the level of voltage
line Deraonnel may work.
reliability impacts.
LANYARD
Nylon e1raP wits lasing
snap hoows connects to
High Wind Advisory or Warning: Level of wind risk baemao;sate""'mesa„"
back)t wck wo. prevem
tolling.(nol pidmed)
from weather conditions as declared by the
National Weather Service (NWS).The difference RUBBER GLOVE
PROTECTORS
harp
between a high wind advisory and a high wind Leather gloves with Velcro HOTSTICK
lightening strap ens attached Insulated.diolecMc-tested
.Worn aver insulated fiberglass tool for moving or
warning is the level of winds associated with the mrange vinyl cunbb,,gl,,ea 10 reduce 0daring troth h.ac.0' edju=ling live electrical equipment
Puncturing«t s
objects.
event.Advisories go into effect for sustained
EANS
winds of 40 mph or less with gusts of at least 45 lon asislant Goadnl
p RK B T tP%nywith name resistanl
Lace to lde,steel dr ant'hmg.
mph. Warnings are issued if sustained winds are etemlc.taa I alher boots
with ealra ercA
Idr climbing
supPda
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
YYYY
tap is a connection that can easily be removed Hot Top Connectors
72 Washington State Dept.of Health,"Instructions for Utilities to Identify Highly Impacted Communities,"Instructions for Utilities to Identify Highly Impacted
Communities I Washington State Department of Health
89
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 1, Page 89 of 114

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. a
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
90
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 1, Page 90 of 114

Insulator: Insulators have the duty of keeping the electrically
charged line from touching the poles or towers so the line can ��` G,,
continue to transmit and is not
grounded. Insulators must be strong enough Stay Insulator
to withstand the weight of the conductor >
,K and the potential stress of the electricity
wanting to connect to the earth.They are
s ff
q"W
designed to be non-conducting, but getting
Strings of transmission insulators, wet can cause flashovers, which Is why
sometimes called bells Dead-end Insulator
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. .1 Ira
Insulator
Insulator Pin:This is a piece of overhead hardware that fastens the insulator to with pin
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 Vertical Fuel Arrangement
distribution, allowing the Company to reach out to
multiple customers at the same time. Aerial Fuels�
Ladder Fuels: Fuels which provide a vertical path between Ladder..Fuels
the ground strata and higher vegetation, allowing fire
to carry from surfaceSurface Fuels
Ladder Fuel Diagram fuels into the crowns of ;.
trees or shrubs with
'.• l�» x 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)
91
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 1, Page 91 of 114

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
LiDAR Image 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
1_I
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 1 circuit Mil '
individual circuits, such as the two circuits of a double- B Line Miles
circuit line, are not counted separately in circuit miles
but are counted as separate in line miles.
LIVE FUEL MOISTURE CONTENT
Live Fuel Moisture Content: Moisture content within living I . 0
vegetation,which can retain water longer than dead fuel.
Moisture content is the most critical factor related to how MOISTURE CONTENT GRASSES TREES/SHRUBS
much fuel is available to burn in a wildfire. When 150-300% GROWING CYCLE GROWING CYCLE
120-150% RESIST SPREAD RESIST SPREAD
moisture content in living vegetation reaches a critical low 100-120% RESIST SPREAD RESIST SPREAD
B0-100% BECOMING LESS FLAMMABLE SHRUBS
threshold,fire danger increases. RESISTANT TO SPREAD BURN AGGRESSIVELY
n FUELS CONTRIBUTE CONTRIBUTES TO
50-80% TO SPREAD FIRE INTENSITY
30.50% COMPLETELY CURED DORMAN7,LEAFLE55
Managed Risk: In Avista s Wildfire Plan,this is the future _ DEAD FUELS DEAD FUELS
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.
92
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 1, Page 92 of 114

Midline (Midpoint) Circuit Reclosers: Often used on long distribution lines where substation-based
equipment cannot adequately protect the entire length
Sectionalizing Midpoint
of the circuit. Avista s Wildfire Plan adds recloser recloser
communications to these midline circuit reclosers in Substatan 1 -_ ��
order to provide monitoring and control functionality, Faye
including the ability to operate the device remotely. By Tie
placing automated midline circuit reclosers at strategic recloser O
locations,Avista Distribution Operations can re-task
those devices during periods of elevated fire danger to saoseerartz
operate in fire protection mode rather than in their Sectionalizing Midpoint
recloser recloser
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 Why outages
proposed or in process that is Construction
0 Weather may occur:
designed to reduce the UNDO
impact/consequences and/or the
likelihood/probability of a risk Animals inthesystem
event such as wildfire. i_ (�
It I I Vandalism Vehiclewrecks
Momentary Outage:The IEEE defines
,'momentary" outages as a brief t V Fallen
trees
loss of power(less than five I Fire
Aging equipment
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.
93
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 1, Page 93 of 114

Named Communities:According to amma
9 C�"ommunities AF
Washington State,these are '� *EMERGENCY
v f M�VA AGEMENY
communities that are highly impacted by
uSlLli/FS
adverse socioeconomic conditions, sT'�I�ES' ;`�° " --
o
pollution, and climate change, or who RESOURCES �°� ,0
experience a disproportionate risk ofREM " IJTC " I
environmental burdens.They are „r,,,,, µ • WATER
DISTRICTS ICTS
�� k �Q
comprised of a combination of"Highly � �l° / rjk*
Impacted Communities and Vulnerable
Populations" (each defined elsewhere in this report). Some ofAvista's Wildfire Partners
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.
"Old" Fire Safety Mode: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" Fire Safety Mode to Base Fire Safety Mode.
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
Primary Phase Conductor
beyond direct customer impacts, so is not set up to capture if Distribution
an outage results in a fire unless that is noted in Dispatcher Transformer prima,y Netural Conductor
comments.
Second—Dlai»
Open Wire Secondary Districts:Three conductors with 120/240
volts that run pole to pole below the primary conductors z
(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
v,
the three conductors are bundled together. Sometimes called
"Secondary Main." Open Wire Secondary Districts
94
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 1, Page 94 of 114

Operations and Response: Many 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 NGENcyA
to the National Interagency Coordination Center(NICC) and National Multi- r� A.
Agency Coordination (NMAC)groups, which provide unified guidance to fire o Z
agencies, coordinate fire response, manage firefighting resources, and track y a
and document fires, sources, size, and impact across the United States.
Borse.ldah°
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
95
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 1, Page 95 of 114

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.
yre
•• " ° Pole Wraps: Avista uses Genics Fire Mesh, a wire mesh treated with an
r - 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 2017 and 2018 Avista's Vegetation Management 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 Types of Maintenance
practice of maintaining equipment on
a regular schedule based on risk, Preventative Corrective
Maintenance Maintenance
elapsed time, run-time meter readings,
or number of operations.The intent of
Component Failure Condition predictive Risk Based Deferred Emergency
PM is to prevent maintenance Finding Based
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.
96
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 1, Page 96 of 114

Priority Essential Services: Critical m
first responders, public safety1& s , i i ,f'�;
Care Centers
partners, critical facilities and Emergency Services Basic Services
infrastructure, operators of I
..........
telecommunications
infrastructure and water �—°' Vulnerable
Access for First - Populations
utilities/agencies. It is important Responders
for a utility to know who and
where these customers are Transportation G' � Communications
located so they can be prioritized
for service restoration during an Public +
ry
Water&Sewer
outage or d I e-energlzatlon. Traffic Systems Suppon Agencies ' 0 Wastewater
'�� '�1 _ — Cooling Centers
Program Targets: Quantifiable 1 &Shelters
Government Facilities
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 consequences.
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 Protective Relay
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 At �G>
and infrastructure safe.These r�
events differ from typical
outages because they are
based on a prediction of risk Weather Red Flag Spark Ignition Fire Behavior
Forecasts Warning - Risk
rather than the occurrence of
an actual event. Public Safety Power Shutoff Deciding Factors
97
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 1, Page 97 of 114

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 7-2 utys Hoar Days
' De-energize
of the event and their associated probabilities.
Public Safety Power Shutoff Typical Timeline
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
1211111111M,L �n lost, customers lose service, versus a redundant system that
has another line or lines available to serve load if one line is lost
Power Radial Line Plant (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 ,r "'r
front, or as rate of increase in area, g on B��etl Area depending Rate otsp�eadl$istanceRime
p n "s;
•k!W
the intended use of the information. Usually, it is Primary factors`affecting
expressed in acres per hour for a specific period in rate ofspreI
the fire's history.
y IneceRSf�d.I�CC intensity SAY ' a
°IS'°Pe Reburn:The burning of an area that has been
f
previously burned but that contains flammable
fuel that ignites when burning conditions are more favorable. Fire Rateofspreaa
4
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
P to prevent outages from spreading.
Red Flag Warning(RFW): Level of wildfire risk based on weather
Viper Recloser 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.
98
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 1, Page 98 of 114

�n Redundant:This is also called a looped system. In the transmission
n world,this means that more than one line or route runs between
Redundant
or Looped the generation source and the end customer, so if one line is lost,
System the power is rerouted via another line and the customer suffers
Powe
Plant 4 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 VMr—,a
B
quickly. Heavy fuels are less easily hd-ln."t'l, r-vapor
to wat« wafe cap aaty
apo,
affected by changes in humidity, and it
often takes a larger or longer-lasting la seFlopa�ity
to hold water
event to affect their moisture vapor
Water Water Water
significantly. Low humidity levels dry out vapor vapor apar
vegetation fuels on a short-term basis, 20 50% 100%
relative relative miallm
and they can also cause ashort-term humidity humidity humidity
5 VM. 11 n.M. 5 AM.
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 l;
f ,DALL-CLEAR
repairs, crews are
organized and
Line Patrol: Restore Power: _7� Complete Repairs: Event Ends:
dispatched to the "All Clear"is declared by Start with Critical Main Trunk Lines EOP is Declared Over
decision-makers Infrastructure,Commercial Branch Lateral Circuits After Action Review With
site of a power Field Crews Mobilized Zones with Equity Individual Customers Emergency 11t Responders
Considerations
•Broad Communications to Update&Communicate PSPS Report to Regulators
outage.Typically, Customers Including Help Estimated Restoration Time Thank You to Crews&
the priority is to With Support Resources
restore service to as many Typical PSPS Restoration Process
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:This has been renamed the "Safe Tree Program." It is a partnership with private
99
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 1, Page 99 of 114

landowners to remove risk trees
on their private property that areFTall
the Right Tree in the Right Place
at risk of coming into contact Medium Small Wire Border outer
Zone Zone Zone Zone Zone
with owerlines and Creatin fireTrees no Trees no taller Nan 25 No veer Onlysmall Treesnotaller
p g taller than feet at maturity trees or than distance
40 feet at shrubs to wire at
potential or loss of reliability. maturity maturity
Transmission
tine
Risk Based: Making decisions based 0lstrlbutlon
tlne
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
r
4 facilities.
k
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 i
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 Avista Transmission Right-of-Way Restored with
individual tree level. Low-Growing vegetation
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.
100
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 1,Page 100 of 114

Rural:Areas of our service territory with small populations, 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: SAIFI refers to "System Average Interruption Frequency 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 I ��Span�►
support, being the transmission pole or ---sag on cold day
tower, and the lowest point on the FVA --------- ---Maximum Sag
conductor. Calculating sag is critical, as Full load,hot day
conductor must be held at a safe tension y
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.
101
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Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 1,Page 101 of 114

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 damage 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:Tools designed to identify and manage risk, primarily Avista's Fire 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. Y
Span:The space between adjacent supporting poles
_
or structures on a circuit consisting of electric ._.SP�1__ __.SPAN 2___
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
�f 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
102
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 1,Page 102 of 114

fire events. SCADA provides insights for operators
DistOps Dispatcher
into the operation of the system in addition to
helping them remotely control and operate it.
Wide Area
Substation SCADA/Substation Fire Safety Mode Communications
Automation: Provides automation that allows Communication
circuit
remote control and operation of substation Remote
equipment to allow it to respond more quickly if fire . . .Terminal
Units
conditions indicate elevated risk. In Avista's Wildfire • • • 10Hardware
Plan,fifteen remote substations located in high fire sub- sub- sub-
station station I station
risk areas will be upgraded with communications Simplified SCADA Diagram
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 partially 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.
i
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 c
reclosing procedure. Air Switch in open position
Switch: A disconnection point used to interrupt the flow of electricity.
Air switches waiting to be
Switches can be mounted on overhead lines, on underground lines, and in installed.
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.
103
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 1,Page 103 of 114

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).
4
Transmission: Electric facilities that have a voltage of 60 kV or above. - —
Avista Transmission
Corridor 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 Work on Chelan-
Stratford 115 kV line
4 Transmission Line Inspection: Avista
r 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
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. Tree Grow-In
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)
104
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 1,Page 104 of 114

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 anf
effort to mitigate the potential for vegetation to F,i I Vegetation Issues
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 K <
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.71
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 Wedge Connected
directly connected to the conductor.The stirrup attaches in such a Stirrup
75 Washington State Dept.of Social&Health Services,"Vulnerable Adult,"Vulnerable Adult I DSHS(wa.gov)
105
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 1,Page 105 of 114

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 0 f.
equipment from starting
:r..,
a wildfire, while at the
same timeYlrotectin O Wildfire Ignition ©Source of Fire Damage Urban Conflagration
protecting Wildfires can start through both natural and The damage caused by fires comes from If a wildfire reaches a neighborhood of
man-made events.Most wildfire ignitions are radiant heat(flames),embers(burning closely spaced homes,fire can easily spread
i
assets paid for by man-made,either directly(e.g..campfires)or chunks of fuel),and smoke.Fires send from house to house.If aided by wind,the
indirectly(e.g.,utlity line spark).Because of embers into the air,which travel downwind entire neighborhood may quickly burn down.
this,wildfires often occur In proximity to and may jump natural barriers,such as rivers
customers. humans-in towns and along road. and road.If they land on dry vegetation,they Smoke Damage
can start new fires.This process of spreading Fires create large amounts of smoke which
©Fire Spread can be repeated over and over. Is then transported by the wind.If the
Wildfire Programs: Fire spreads by wind and through available concentration of smoke Is high enough,it
fuels.If either goes away,the fire will usual) 0 Ignition of Structures
y can result in insurance loss from evacuation
stop spreading. Buildings can be ignited by flames or embers orders(additional living expense),business
Activities, practices, and which land on the surface of a building or fly closures(business Interruption),and
into vents and windows. contents loss from contamination.Smoke
strategies that are only can cause damage far beyond the fire
g y perimeter during a wildfire event.
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
106
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 1,Page 106 of 114

of our •
t•
46.
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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.
Wire Down: Instance where an electric transmission or distribution conductor is
Wood • • Avista uses Genics Fire Mesh, a wire mesh treated with an
inturnescent 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 ••• poles, protecting them fromdamage • Avista's M' ole
Wrap Test '
destruction.
Source76 of 1 .' "Understanding the Wildland-Urban991 1 1September1 2023, • . 1Urban
Interface •'1 1 1
1
Exhibit •
Case • ` 1
Schedule • 107of

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
2024 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 during 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
108
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Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 1,Page 108 of 114

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 Grangeville areas."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
"Details are available in Avista's Public Safety Power Shutoff Report located on Avista's website:Public Safety Power Shutoffs(mvavista.com)
109
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 1,Page 109 of 114

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) (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 warrant
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 PSPS Assessment Team
and other critical information.An operational risk assessment • Director of Electrical Engineering
will be performed to determine, risks, and vulnerabilities.The • Wildfire Resiliency Manager
Director of Electrical Engineering will determine whether to • Director of Business&Public Affairs
remain at a PSPS Watch, escalate to PSPS Warning, or de- • Electric Operations
escalate to seasonal FSM operations.The PSPS Assessment Team • Corporate Communications
will decide if Avista will issue a preliminary notification of a • Regulatory
•System Operations
potential PSPS event to public safety partners, critical facilities .SystomOper eraio
ce
operators, governmental agencies, and emergency management • Manager of Social Impact
partners. An Emergency Operating Plan (EOP) briefing will also . Legal
be initiated as early as 7 days prior to the initiation of a PSPS
Event.
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Case No.AVU-E-25-01
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Schedule 1,Page 110 of 114

PSPS Warning.48-24 hours in advance of a potential event if it is Full PSPS Team
believed that a PSPS outage is either probable or is already • PSPS Assessment Team plus:
scheduled,the full PSPS team will be placed on stand-by. . Wildfire Executive Committee
Executives will be given detailed information. Operations will o President and COO
help determine which circuits should be de-energized and begin o VP of Energy Delivery
developing a restoration plan. Impacted customers will be o VP of Community Affairs&
contacted and are warned to take steps to prepare for an Chief Customer Officer
outage. Internal stakeholders such as line crews and provisioners o Sr. VP and General counsel
o Sr. VP CFO Treasurer
will begin preparations.The utility continues to coordinate with o Regulatory Affairs Officer
identified external partners such as first responders and o Director of Corporate
community support organizations to provide them with Communications
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.
It is important to note
Restoration that a PSPS event and
associated complexities
One of the challenges when using PSPS is the process of re-energization, related to patrol and
repair work does not
Power restoration following a PSPS is akin to a major storm. In traditional account for the outages
on other circuits and
utility restoration efforts, the priority is to restore service to as many there would likely be
customers as possible through line switching and by isolating faulted hundreds of such
outages in an event of
circuits. Restoration efforts may also include a consideration of customers this magnitude.
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.
111
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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.
112
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Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 1,Page 112 of 114

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
partnertogether
Lakeland Managers of Facilities at Eastern State Hospital and Lakeland Implications of upcoming PSPS and discussing opportunities for
February 8th Village/Eastern State Village 5 communication and collaboration during emergency events
Hospital
Idaho Office of Emergency Managers from Clearwater,Latah,Lewis,Idaho,Nez
March 14th Emergency Perce,City of Lewiston,National Weather Service,Kootenai 17 Shared about PSPS,discussed medically vulnerable customers,questions
Management,North Health,Public Health North Central District and Nez Perce County about length of outage,CRCs
Central Region
March 21st North Idaho Healthcare Kootenai Health,Kootenai County EMS,North Central Health 20-25 Discussed impacts of PSPS and introducing the topic to the group,also
Coalition District,Panhandle Health District discussed work with medically vulnerable customers
Community Resilience Executive Directors of Providence,Multicare,Aging&Long Term Discussed impacts of PSPS and how we can continually improve our reach
Care of EW;representatives from WA State DOH,Spokane
March 22nd &Vulnerable Regional Health District,DSHS,Horizon Hospice,Indian Health 15-20 and service to medically vulnerable customers.Also discussed continued
Populations Luncheon desire to partnertogether
Services
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
Cottonwood Fire Dept.,North Idaho Healthcare Coalition,Public
Idaho County Local Health N.Idaho,Elk City Fire Dept.,Idaho County Mapping, Discussed PSPS,questions about medically vulnerable,length of outages,
April 18th Emergency Planning Harpster Fire Dept.,Idaho Office of Emergency Mgmt.,3 Rivers 17 CRCs
Committee Ham Radio,Lewis County Ham Radio,Idaho County Emergency
Mgmt.and Idaho Dept.of Lands
April 23rd City of Spokane City of Spokane Mayorand Cabinet 18 Discussed PSPS and medically vulnerable customers,other partnerships
and data sharing opportunities
Spokane Fire Chiefs Spokane Fire Chiefs,Providence Emergency Manager,Dept.of Discussed PSPS and changesto Fire Safety Mode(FSM),discussed water
May 2nd Meeting Natural Resources,Spokane County 18-20 resources,where to send information about potential PSPS event and
water resources in event of wildfire
Public Health Spokane Regional Health District,NETri-County Health,Whitman Discussed PSPS and medically vulnerable customers,wells and
May 6th Emergency Planning County Public District,Lincoln County Public Health,Adams County 12-14
Region Meeting(9 East) Health District wastewater treatment
Press Conference
regarding PSPS Partners:Citypartnerships p of Spokane,Spokane County,De t.of Natural Provided an overview of PSPS and the importance of artnershi s helping
Rosentrater(President
May 7th presented by Heather Resources and Idaho Dept.of Lands,Spokane County Fire Chiefs 20-24 keep our communities safe
and CEO of Avista)
Lewis County Emergency Mgmt.,Lewis County Sheriff,3 Rivers
Lewis County Amateur Radio,Idaho Transportation Dept.,City of Nez Perce,
May 8[h Emergency Planning
Kamiah Fire Protection,National Weather Service,Nez Perce 17 PSPS discussion,questions about communication timeline,length of
Tribe,Craigmont Rural Fire Dept.,Winchester Rural Fire Dept., outage,backup generation for wastewater treatment plants
Committee Public Health North Central District,Lewis County Commission and
City of Nez Perce Planning and Zoning,
May 8th CDA Executive Round 35 Discussed Wildfire Resiliency and PSPS,questions about medically
y Table vulnerable,backup
generation,water resources for rural customers
Community Response Spokane County,Spokane Transit,WSDOT,Spokane Regional
for Vulnerable Health District,Aging and Long Term Care of EW,Spokane Discussed PSPS/medically foryvulnerable customersandhings wesed about
May lath 18 mostimportant issues forvulnerable populations and things we should be
Population During Neighboorhood Action Partners,Disability Action Center NW,
Outages International Rescue Committee focused on going forward
May 13th City of Spokane Fire Spokane Fire Chief,executive chief staff,wildland planner, 12 Discussed PSPS and updates to FSM,discussed medically vulnerable
y Chiefs wildland group battalion chiefs customers and continued efforts to partner togetherfor outreach events
Panorama Counties
May 14th, School and Community Stevens County,Kettle Falls School District,ESD 101,Newport 12-14 Discussed PSPS and using schools as potential CRC locations
Emergency Responders School District,Pend Oreille School District
Meeting
May 14th Stevens County Stevens County Commissioners,Stevens County Emergency 15 Discussed PSPS and Wildfire Resiliency Program
Commissioners Meeting Manager,Fire Personnel
May 15th Medical Lake Recovery Agencies and organizations around the community who assist in 80 Discussed PSPS and Wildfire Resiliency Program
Group disaster recovery
May 16th Providence Hospitals Providence Emergency Manager and Facilities Managers 5 Discussed PSPSforthe hospitals,best points of contacts,backup
generation
May 20[h
Commercial and Discussed PSPS and Wildfire Resiliency Program answered questions from
I Various industrial and commercial accounts ndustrial Accounts group
Washington State Discussed PSPS and the implications of DSHS facilities,discussed
May 20th Department of Social DSHS employees from around the state 7Ot communications and implored folks to discuss this topic with their local
and Health Services municipalities
May 22nd Kootenai County LEPC 25 Discussed Wildfire Resiliency and PSPS,questions about medically
vulnerable,backup generation,water resources for rural customers
Asotin County Dept.of Emergency Mgmt.,Washington State
Emergency Mgmt.,Nez Perce County/City of Lewiston Emergency
Asotin County Local Mgmt.,Garfield County Emergency Mgmt.,National Weather
Discussed PSPS and questions about length of outages,communications
May 24th Emergency Planning Service,Avista,City of Asotin Mayor,Asotin County Public Works, 15
Committee Asotin County Commission,Asotin County Conservation District, prior to PSPS event
Asotin County Fire Chief,Asotin County Sheriff,Asotin County
Health District,Tri State Health.
113
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Case No.AVU-E-25-01
V.Malensky,Avista
Schedule 1,Page 113 of 114

Date: Agency,Even[: Representatives: Attendees: Topics:
June loth Spokane Valley Council 1 City Councl Member with Spokane Valley Discussed PSPS and questions about length of outages,communications
Member Discussion onto PSPS event and medical) vulnerablecustomers
Discussed Wildfire/PSPS Resiliency and what Avesta is doing within their
Stevens&Ferry Counties and 4vlzta speakers,to inclutle the communities to prepare for wildfire season sharing Info about our
NE Washington Dire for of Electrical Engineering,Manager of WF Resiliency, Vegetation Management programs,Operational changes,the WMP,CRC's,
une llth Telephone Town Hall -2 and what our guest speakers within the community are using to address
Event Electric Operations Manager,and guest speakers from local Fire Agencies and Emergency Managers nP the threat of wildfire.This was a live event,allowingthe le on The
callcalltoask questions.answering 15 g them ward:the last minutes of the
call
lcwis-Clark Valley Chamber members,business leaders,elected officals,
June 12[h amber of Commerce educational institutions and other VIPs from the Lewis-Clark ]Sot Discussed Avesta's Wildfire Resiliency Program and briefly discussed the
(presenter Heather Valley,active and retired potential for PSPS
Rosentrater
June 13th Spokane Tribe yearly Fire Mgmt.Officer,Wildlife Manager and Acting Forestry Manager Discussed AWVa's Wildfire Resiliency Program and discussed the
wildfire meeting with Spokane Tribe potential for PSPS,also discussed best points of contact during emergency
Colville Confederated Natural Resources Director,Emergency Mgmt.Coordinator, Discussed Avista's Wildfire Resiliency Program and discussed The
June 13th Tribe yearly wildfire Assistant Forest Manager,Forest Manager,Health and Human
meeting Services Director,and Fire Chief of Nespelem, contact
potential for PSPS,also discussed best points of during emergency
June 13th Nez Perm Tribe yearly Fire Preverdlon&Mflfgation Specialist,Natural Resource Manager Discussed Avista's Wildfire Resiliency program and discossed the
wildfire meeting and Deputy Executive Director Potential for PSPS,also discussed best points of contact during emergency
Discussed Wildfire/PSPS Resiliency and what Avesta is doing within their
Kootenai,Benewah,Bonner,and Shoshone Counties and Avesta commun Ries to prepare forweldfire season sharing info about our
North Idaho Telephone speakers,to include the Director of Electrical Engineering, Vegetation Management programs,Operational changes,the WMP,CRCs,
June 13th Town Hall Event Manager of WF Resiliency,Electric Operations Manager,and guest 2,0]6 antl what our guest speakers with
the community are using to address
speaker from Idaho Dept.of Lands the threat of wildfire.This was a live event,allowing the people on the
call to ask questions,answering them towards the last 15 minutes of the
call
June 1]Ri Providence Hospice ExeaHve Director and Care Coordinator Discussed PSPS and questions about length of outages,communications
Care of Spokane prior to PSPS event and medically vulnerable customers
Discussed Wildfire/PSPS Resiliency and what Avesta is doing within their
Clearwater,Asohn,Lewis County,Lewis Clark Valley,Nez Pence mmunnies to prepare for wildfire season sharing info about our
N.Central Idaho and Whitman Counties and Avesta speakers,to include the Director Vegetation Management programs,Operational changes,the WMP,CRCs,
June lath Telephone Town Hall of Electrical Engineering,Manager of WF Resiliency,Electric 2,275 and what ourguest speakers within the community are using to address
Event Operations Manager,and guest speakers from Idaho Dept.of the threat of wildfire.This was a live event,allowing the people on thv
Lands and County Fire Chief call to ask questions,answering them towards the last IS minutes of the
call
North Central Multi County emergency managers from Asotin,Clearwater,Idaho, Discussed Avista's Wildfire Resiliency Program and briefly discussed the
June 20th Agency Coordinating Lewis and Nez Pence counties as well as the City of lewiston,Nez 65 potential for PSPS
Group Pence Tribe As well as Idaho Office of Emergency Mg-[.
Northern Spokane County,Deer Park,West Plains,Greater Discussed Wildfire/PSPS Resiliency to include what Avista is doing within
Spokane Region Spokane Valley areas,Southern Spokane County,and Avesta their communf[ies to prepare for wildfire season to include,Vegetation
June 2t th Telephone Town Hall speakers,to include the Director of Electrical Engineering, 2 40] Management,Operations,the WMP,CRCs,and guest speakers from our
Event Manager of WF Resiliency,Electric Operations Manager,and guest partners within the community.This wasalive event,allowing the people
speaker from Chen Fire,and Spokane County Emergency Mgmt. on the call to ask questions,answeringthem toward,the last 15 minutes
zPea Cheney po ty rgenry Br^ of the call
Discussed Wildfire/PSPS Resiliency and what Avesta is doing within their
City of Spokane,and Avista speakers,to Include the Director of communities to prepare for wildfire season sharing info about our
City of Spokane Vegetation Management programs,Operational changes,the WMP,CRCs,
June 25th Telephone Town Hall Elec(nical Engineering,Operations Manager of Vegetation Mgmt, 3634 and what ourguest speakers within the community are using to address
Electric Operations Manager,and guest speaker from the Cety of
Event Spokane Fire,and Director of Emergency Mgmt. the threat of wildfire.This was a live event,allowing the people on the
call to ask questions,answering them towards the last 15 minutes of the
Panhandle call
June. Health/Medical Reserve 32 Discussed Wildfire Resiliency and PSPS,q uestfons about medical ly
Co vulnerable,backup generation,water resources for rural customers
Junes lath Stevens County Flre Fire Chiefsfrom Stevens County area antl Stevens County 16 Discussed Wildfire Resiliency and PSPS,questlonsabout medically
Chiefs Meetin Emer a Maria a vulnerable,backup generation,water resources for rural customers
Liberty take City Council,City Administrator,Liberty lake Mayor, Discussed Wildfire Resiliency and PSPS,questions about medical ly
July 2 d liberty lake City Council other Liberty lake City staff,Spokane Valley Fire Dept.,Liberty 20 vulnerable,backup generation,water resources for rural customers
Lake Police,plus several Libe Lake citizens
July2nd Medical take City City Council and members from public 30 Dacisssed Wildfire Resiliency Plan and PSPS
Councl
Discussed Wildfire/PSPS Resiliency and what Avesta is doing within then
Adams,letah,Lincoln,Whitman Counties,and Avista speakers,to mm—dies to prepare forweldfire season sharing info about our
Palouse Region Vegetation Management programs,Operational changes,[he WMP,CRCs,
July 2nd Telephone Town Hall silienincludethe Director ofElectrical ageEngs, ring,Manager r WF 2,929 and what our guest speakers within the community are using to address
Resiliency,Electric Operations Whit Manager,and guest speakers from
Event Pullman Fire,and Whitman County Emergency Mgmt. the threat of questions,
answering
was t live event,allowing the people on the
call to ask questions,answering them towards the last 15 minutes of tho_
call
Jul ath Conversation with Regional Director Discussed PSPS and best contacts durin
y Verizon Wireless Hiona dung emergency
Kootenai County Fire& Discussion focused on vulnerable water districts without backup
July 9th Resale/Northam Lakes 11 generation and communications during PSPS
Fire District
Idaho Regional Wildfire Emergency Mgmt.personnel from Asotin,Her Pence,Lewis,Idaho,
July 22th prep Discussion Group Clearwaterand latah counties,aswellasthe Nez Pence Tribe and a Discussed Wildfire Resiliency Plan and PSPS
the Idaho Office of Emer e Mgmt.
July 11th Meeting with Spokane County Library Dlstrlcl Operations Manager of Spokane County Libraries Discussed specifics of PSPS Plan and request to use locations for CRi
Presentation to Faith Representatives from various faiths Including Christian,LDS, Discussed specifics of Wildfire Resiliency and PSPS Plans and request l.:
July 12fh Based Regional Buddhist,Sikh,salvation army
Committee 61U
potentially use church locations In rural areas for CRCs
Committee
Meeting with Discussed specifics of PSPS communications strategy and ooncems ab,.i s
July 24th Whitworth Water Executive Director and Lead Engineer
dis for ba
District ckup generation water tre t
Follow-up with Discussed new methods to reach customers in rural areas and the effo rt:
July 25th agencies working in WSDOi and Disability Action Center NW rural Communities t0 combat false InfprtnaflOn
July 27th Settlers Day Deer Park, Citizens from Deer Park and surrounding area 20 Had booth open to discuss PSPS and wildfire progWA I
ram
August 3rd Family Day(Location: General public(put on by group of rellglous organizations In the 150-200 Had booth o to discuss PSPS and wildfire
gu City of Spokane PNWre Ion open program
August 14th Meeting with AT&T t0 AT&T employees from Washington,Idaho and California and 8-10 Discussed PSPS and best contacts during emergency
discuss PSPS rotacols S ne Coun Emer e M cot
August 15th S kane Fere District 5 Fire Commissioner 1 Discussed Wildfire Resiliency Plan and PSPS and answered uestions
114
Exhibit No. 11
Case No.AVU-E-25-01
V.Malensky,Avista
Schedule 1,Page 114 of 114

AVISTA'S WILDFIRE RESILIENCY PLAN
2024 Communications Plan
Overview
The 2024 communications plan builds on the last four years of Wildfire Resiliency
communications plans. The scope of this plan is broad communications to customers about
Avista's wildfire resiliency work and direct customer communications regarding work or events
that may impact them. It does not include communication between Avista staff and first
responders or community outreach led by the Regional Business Manager or Wildfire Resiliency
Teams but includes support for those efforts.
Objectives
We aim to partner with our customers in preparing for and preventing wildfire while also
reinforcing our main communications objectives and:
• Build awareness among all key stakeholders of the significant actions and investments
Avista is taking 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.
• Promote preparedness for potential outages, including PSPS.
The Wildfire Resiliency Plan identified four main components—Grid Hardening, Vegetation
Management, Situational Awareness and Operational Readiness. We continue to support each
of these elements, highlighting projects in each area as proof points of Avista's plan in action.
PSPS and Customer Preparedness
• Encourage customers to be prepared for outages, including updating their contact
information with Avista.
• Partner with emergency management and fire agencies to promote public safety and
demonstrate support for PSPS as a mitigation strategy.
• Continue to reinforce key messages of Avista's Wildfire Resiliency Plan and remind
customers of the significant actions and investment Avista is taking.
• Encourage customers considered medically vulnerable to contact Avista CARES team.
• Educate customers on PSPS and enhanced protection settings so they understand why
these measures might be needed and when Avista will contact them.
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 2, Page 1 of 4

Tactic Timing/Details
Press Release • May— Develop joint press release with partners before the start of
wildfire season. Explain elements of the plan with a particular focus
on the addition of PSPS.
• June/July—Announcing start of Fire Safety Mode for the season
• As needed throughout the season based on conditions and weather
events
Press • May—With partners, same time as press release
Conference
Website • April/May - Update Avista's wildfire pages
• April/May - Create dedicated PSPS page.
Bill Inserts • February— Insert about Medically Vulnerable customers with CTA to
contact Avista's CARES Team (translated into Spanish)
• May/June — Insert about PSPS and preparing for wildfire season
with CTA to update contact information (translated into Spanish)
Emails • March/April — Encourage medically vulnerable sign up
All WA/ID . May— Coincides with press release
electric
customers • June/July—Announcing Fire Safety Mode as begun
As needed throughout the season based on conditions and weather
events
Internal • May— Employee meeting announcing new elements of the plan with
a particular focus on PSPS
• E.View or E.View extra with content from press release
• Updates through All-Employee meetings
Additional • One pagers for PSPS and general wildfire program
materials and
collateral • Support RBM efforts to conduct series of meetings and telephone
town halls
• Telephone town halls available in Spanish
Print Ads . Continue previous two years' print campaign in smaller papers
reminding customers wildfire season is coming.
• Translate ads and include in Spanish speaking publications
Video a Utilize videos created in 2023 regarding Fire Safety Mode and the
Fire Weather Dashboard
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 2, Page 2 of 4

• Create third video about PSPS
Vegetation Management— Right Tree, Right Place, Fuel Reduction, Safe Tree
• As part of Avista's Wildfire Resiliency Plan, Avista has elevated its approach to
vegetation management, particularly in targeted, high risk geographic areas, to further
reduce the risk of trees making contact with electrical lines.
• Electric customers in high-risk areas (WUI Tier 2-3) may be eligible for a program where
Avista will remove and replace incompatible trees with low growing, compatible species.
In 2022, we named this program Safe Tree, and it has expanded to several counties. It
currently has a waitlist.
Tactic Timing/Details
Customer Targeted outreach to customers identified who qualify for program.
Communication
• Additional follow-up outreach from program.
• Created "Safe Tree" program that included postcards and emails to
eligible customers along with web form.
Website • Online form on the wildfire webpage.
Avista-Owned Success stories from pilot program shared on Connect blog,
Channels possible Connections article, social media posts.
Grid Hardening
• As grid hardening projects continue throughout our service territory, we are working with
that team to notify customers who will be impacted by the work and reinforce why we are
doing it.
• Grid hardening projects offer a tangible example of how Avista is investing in its wildfire
plan.
• In 2024 and 2025, Avista is completing an undergrounding project as a feasibility effort
to inform moat undergrounding (or covered conductor) strategy.
Tactic Timing/Details
Customer . Ongoing, Postcards alerting customers of work that is happening in
Communication their area. To be mailed within two weeks of work for each project.
• Outreach to community impacted by undergrounding
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 2, Page 3 of 4

Earned Media . As appropriate, actively pitch media stories about grid hardening
and wildfire resiliency as work happens in an area
Avista-Owned . As appropriate and available, stories, like wood-to-steel
Channels transmission upgrades, can be used on our own channels like
Connect, Connections and social media.
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 2, Page 4 of 4

Avista Statement of Approval
In the 2023 Idaho Public Utilities Commission Case No. AVU-E-23-01 parties agreed to the following:
For the Distribution Risk Tree program, the Company 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 3-year
cycles).
In accordance with this directive, the Company hired an external vegetation management evaluation
service, Iapetus Infrastructure Services, to look at the key points of Avista's risk tree program, assess
the optimum frequency of maintenance across the service area, examine our fire risk profile, compare
our existing program to industry best practices, and to evaluate our strategies and their effectiveness.
Their report is attached. In summary, Iapetus found that Avista's approach to managing the risk
associated with utility-caused wildfires as an annual cycle is a reasonable and responsible approach
and that Avista is using best-in-class practices in this area. They sited, as partial evidence of this, a
reduction in actual tree fall-ins since the risk tree program began in 2020 of 62%. A summary of their
investigations is shown below:
Observation Comments
Considering the impact that drought and tree mortality has had on forests in the Western United States,
Risk Tree Avista has implemented an effective strategy to reduce the potential for utility-caused wildfires.As the
Cycle Risk Tree Program matures,the inventory of risk trees identified and removed should continue to reduce
in numbers as long as the goals and objectives remain in line with current standards.An annual cycle is
consistent with best-in-class programs at other major utilities in the West.
Avista has taken a comprehensive approach to identify and mitigate risk trees that pose a hazard to the
Risk Tree overhead distribution system.This approach has a two-fold benefit of reducing the volume of trees that
Strategy can potentially result in a utility-caused wildfire,as well as reduce the types of tree-related events that
cause interruption of electrical service.
Identifying By leveraging the industry-accepted UAA/ISA guide, Best Management Practices-Utility Risk Tree
Risk Trees Assessment,Avista is utilizing the most current protocols in use today by North American Utilities to
identify off-ROW risk trees that pose a hazard to the electrical grid and potentially pose a wildfire risk.
Outage Avista should commit to studying the root causes of tree-related outages through accurate reporting and
Investigations thorough post-outage investigations.A commitment to post-incident investigations does not mean every
outage needs to be investigated;however,the more data,the better the analysis.
We fully support their findings and have committed to the only recommendation they had for
improvement, to perform a more thorough investigation and documentation of root causes for tree-
related outages.
Vern Malensky, Director Electrical Engineering
Date: August 26, 2024
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 3, Page 1 of 19

AllV
---
/" IST
A�iI/
Distribution Risk Tree Program
MAY 2024
r
PROGRAM
ASSESSMENT ye ^
fir;.
Iapetus
infrastructure services
PREPARED BY:
Adam Warf
Dr. Philip Charlton
Steve Hallmark
Iapetus Infrastructure Services, LLC
3900 Essex Lane, Suite 775
Houston, TX 77027
LEGAL DISCLAIMER:Recommendations made in this report are for Avista's internal use only.IIS is not responsible for Avista's action(s)or
inaction in response to these recommendations.Assumptions made by IIS in the composition of this report were made based upon information
collected by and from Avista. Gaps in information are noted,but numbers may be skewed as a result of missing or inaccurate data provided.
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 3, Page 2 of 19

Executive Summary
Introduction
In 2020, Avista Utilities (Avista) began a risk tree inspection program on the distribution
system. Trees meeting predetermined risk criteria are scheduled for tree maintenance
within six months of identification. Its first full annual system assessment was completed
in 2022.
In June 2023, Avista agreed to the following terms with the Idaho Public Utilities
Commission (PUC):
For the Distribution Risk Tree program, the Company 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 3-year cycles).
In response to the Commission Order (the "Order") above, Avista contracted Iapetus
Infrastructure Services ("IIS") to evaluate its current Distribution Risk Tree Program and
provide recommendations for enhancing its approach to timing of inspections and
subsequent mitigation measures.
Assessment Process
As directed by Avista, IIS performed a detailed review of Avista's Distribution Risk Tree
Program to assess the optimum frequency of maintenance per service area (i.e., one-,
two- or three-year cycles). All areas of review were made within the context of Avista's
Wildfire Resiliency Plan.
The team utilized the following process for this assessment:
1. Review Avista's Enhanced Vegetation Management and Wildfire Resiliency
Plans.
2. Assess Avista's tree-specific performance including tree-related outage data and
work completion records.
3. Interview Avista's Vegetation Management team.
4. Develop and document recommendations.
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 3, Page 3 of 19

Key Observations
Avista has developed a Risk Tree Program leveraging their internal experience and
history of tree outages and program performance, as well as collaboration with leading
wildfire mitigation programs at electric utilities with more mature and robust programs.
Based upon this review, the IIS team finds that Avista's approach to managing the risk
associated with utility-caused wildfires as an annual cycle is a reasonable and
responsible approach. IIS has identified the following major areas of focus to enhance
the foundation of Avista's Risk Tree Program and become a more progressive, best-in-
class program.
Observation Comments
Risk Tree Considering the impact that drought and tree mortality has had on
Cycle forests in the Western United States, Avista has implemented an
effective strategy to reduce the potential for utility-caused wildfires.
As the Risk Tree Program matures, the inventory of risk trees
identified and removed should continue to reduce in numbers as long
as the goals and objectives remain in line with current standards. An
annual cycle is consistent with best-in-class programs at other major
utilities in the West.
Risk Tree Avista has taken a comprehensive approach to identify and mitigate
Strategy risk trees that pose a hazard to the overhead distribution system.
This approach has a two-fold benefit of reducing the volume of trees
that can potentially result in a utility-caused wildfire, as well as
reduce the types of tree-related events that cause interruption of
electrical service.
Identifying By leveraging the industry-accepted UAA/ISA guide, Best
Risk Trees Management Practices— Utility Risk Tree Assessment, Avista is
utilizing the most current protocols in use today by North American
Utilities to identify off-ROW risk trees that pose a hazard to the
electrical grid and potentially pose a wildfire risk.
Outage Avista should commit to studying the root causes of tree-related
Investigations outages through accurate reporting and thorough post-outage
investigations. A commitment to post-incident investigations does not
mean every outage needs to be investigated; however, the more
data, the better the analysis.
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 3, Page 4 of 19

Table of Contents
ExecutiveSummary ........................................................................................................2
Introduction .................................................................................................................. 2
AssessmentProcess....................................................................................................2
KeyObservations......................................................................................................... 3
Avista Distribution Risk Tree Program............................................................................. 5
Wildfire Resiliency Plan................................................................................................ 5
FireRisk Profile............................................................................................................ 6
Risk Assessment Strategy........................................................................................... 8
Risk Tree Workload, Cost, and Tree Failure.............................................................. 10
IdentifyingRisk Trees............................................................................................. 10
Post-outage Investigations ..................................................................................... 12
Tree-related Outages................................................................................................. 13
Cycle Length and Objectives.................................................................................. 15
Historical Risk Tree Workload ................................................................................ 16
IISConsulting Team...................................................................................................... 18
AdamWarf................................................................................................................. 18
SteveHallmark........................................................................................................... 18
Dr. Phil Charlton......................................................................................................... 18
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 3, Page 5 of 19

Avista Distribution Risk Tree Program
Wildfire Resiliency Plan
Wildfires are generally defined as "unplanned, uncontrolled fires fueled by an area of
combustible vegetation" and, like all fires, require three fundamental elements to exist:
fuel, oxygen, and heat. The fuel supply across North America has increased over the
past few decades due to political policies around fire suppression and forest
management, the introduction of non-native grasses, and dryer climates and droughts
that left forests damaged by insects and disease. Oxygen often comes in the form of
high winds that can spread the fires quickly. Sparks that initiate the fires are primarily
generated by human activities and weather, but about 10% of wildfire ignitions are
sparked by faults in electrical infrastructure or electric equipment failure.' In recent
years, wildfires have emerged as a significant risk to public safety and to the bulk power
system (BPS) assets that serve the Western Interconnection of North America.
Wildfires initiated by electric utility infrastructure prompted the state of California to
enact legislation in 2018 that required each electrical corporation, local publicly owned
electric utility, and electrical cooperative to do two things: 1) construct, maintain, and
operate its electrical lines and equipment in a manner that will minimize the risk of
catastrophic wildfire posed by those electrical lines and equipment and 2) prepare and
submit wildfire mitigation plans (WMPs) on an annual basis for review and approval by
the California Public Utility Commission (CPUC).
Recognizing the value of WMPs, a significant number of electric utilities outside of
California in the Western US have voluntarily developed their own WMPs to identify and
reduce their wildfire risk exposure. Both investor-owned and publicly owned utilities
(e.g., municipal, cooperative, REA, and federal utilities) have developed WMPs as
guiding documents to codify their risk reduction efforts as they relate to wildfires.
Electric Utilities in the Western US with WMPs include:
• Bonneville Power
• Idaho Power
• Northwestern Energy
• PacifiCorp
• Puget Sound Energy
A WMP details a utility's initiatives and activities for reducing the risks of its lines and
equipment igniting wildfires in the high fire risk areas of its service territory. The risks
associated with the equipment vary depending upon several factors: age and condition,
population density (ingress and egress), surrounding climate, terrain and vegetation,
"Wildfire Mitigation Webinar Series." U.S. Department of Energy, Office of Electricity.April 2021.
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 3, Page 6 of 19

voltage class and type of construction, and policies and regulations around land/forest
management. New technologies and increasing data capture have enabled companies
to perform risk analyses at the asset level, allowing them to prioritize activities and
develop initiatives for specific lines and equipment. This granularity provides for more
effective and efficient mitigations.
While each utility's risks are unique, general metrics for various aspects of the plan
enable a utility to assess the outcomes and measure the performance of individual
initiatives. Identifying plan successes and deficiencies ensures that the iterative
development process is one of continuous improvement.
In general, WMPs describe how the utilities' electric systems are designed, constructed,
operated, inspected, and maintained to promote wildfire safety, prevention, mitigation,
and recovery.
Fire Risk Profile
As identified in the Wildfire Resiliency Plan, Avista has committed to reducing fire risk to
its communities, customers, and the company. Like other utility wildfire plans, Avista is
making investments in four key areas:
1. Grid Hardening — to invest in electric line infrastructure to reduce spark-ignition
outage events and protect critical assets from the impact of wildfires.
This has become a key focus of utilities that are exposed to the highest
probability of utility-caused wildfire ignitions, as well as protecting assets from
any wildfire that encroaches on the utility's assets. Some examples include
undergrounding, fire-resistant overhead construction materials (e.g. composite
poles, or fire-retardant wrapped material on poles), as well as the use of tree wire
and construction standards that reduce the failure potential of overhead lines.
2. Enhanced Vegetation Management — to inspect 100% of distribution line
assets annually and combine remote sensing technologies such as LiDAR and
satellite imagery to aid in overall vegetation management decision-making.
Annual inspections of overhead electrical facilities in high fire risk (or high fire
threat) areas of a utility's footprint are becoming commonplace, and in certain
states a regulatory requirement. Such inspections take place for infrastructure
(typically poles and hardware), as well as to identify hazardous trees.
3. Situational Awareness — to automate Avista's non-reclosing protection strategy
and align short-term, weather-related fire risk with system protection levels.
This is a basic tenet of a utility wildfire risk reduction effort. Seasonal adjustments
to reclosure settings are an accepted standard for many utilities in high fire risk
areas. Increasingly, remote switching at the sub-circuit level is being deployed to
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 3, Page 7 of 19

isolate electrical facilities damaged by wildfire, as well as proactive de-energizing
of line segments during high fire threat periods. It should be noted that proactive
de-energizing is a very complex process for any utility to deploy, and requires
significant buy-in among the utility, regulators, and customers.
As documented in Avista's Wildfire Resiliency Report:
"Avista has developed a computer algorithm to monitor, forecast, and adapt to
fire-weather events. Avista's Fire Weather Dashboard combines the National
Weather Service's 7-day forecast with Avista infrastructure data to quantify the
daily fire risk on 350 distribution circuits. This 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. 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. This monitoring system supports Avista's fire
season circuit protection program known internally as Dry Land Mode."
Observation: San Diego Gas & Electric (SDG&E) has been at the forefront of
managing wildfire risk and developed one of the most
comprehensive utility wildfire management programs in the United
States. Leveraging SDG&E's experience and knowledge is
commendable.
4. Emergency Response & Operation — to help customers be better prepared for
wildfires and partner with emergency first responders before, during, and after
fire events.
Emergency Response Plans are core to a utility's ability to effectively manage
the complexities of any emergency, including wildfire. By actively engaging local
and state agencies in the development and execution of a utility emergency
response plan, all parties involved can perform at their highest level. In turn, the
customers are best served with reliable information that keeps them informed
and able to make informed decisions.
These are core principles of a proactive Wildfire Mitigation Plan (WMP), which is the
term typically used by most electric utilities in the Western United States. These
principles provide focus for the utility on design and maintenance practices that can best
reduce the risk of utility-caused wildfires, as well as establish clear operating
procedures during periods of elevated wildfire potential. Avista has established a
framework for a plan to identify and reduce risk from wildfire on their system.
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 3, Page 8 of 19

Risk Assessment Strategy
For this report, IIS will focus specifically on the Risk Assessment Strategy as it relates to
the Distribution Risk Tree Program.
In 2019, Avista developed the initial wildland urban interface (WUI) map that combined
data from the Wildfire Hazard Potential with the location of Avista electric lines in areas
of low, medium, and high population. This analysis indicated that 3,240 miles of Avista's
7,725-mile distribution system were located in high fire threat districts (42% of the
system). Avista's 2020 Wildfire Plan focused on grid hardening and vegetation
programs in these elevated risk areas.
In 2023, Avista's WUI map was updated and now includes additional data which
measures the impact of fire on human development. The USDA's Housing Unit Impact
dataset14 combined with the Wildfire Hazard Potential data mentioned previously, was
used to refine the Avista WUI map. Areas shown on the 2023 WUI map with either an
orange or pink highlight indicate these high fire risk zones. Communities like Chewelah
and Colville border national forest lands, as do many other areas including Sandpoint,
St. Maries, Grangeville, and portions of the Lewiston/Clarkston Valley, placing them
more at risk. In total, 2,746 miles of electric distribution lines are in high fire risk areas or
about 36% of the system. This analysis indicates slightly lower risk values as compared
to 2019.
The WUI map serves to identify and prioritize the areas of highest risk. The Avista WUI
identifies three wildfire risk levels: rrarl
Grand Forks
k
Tier 1: Moderate levels of fuel and low to
moderate housing densities (low) C
A
Tier 2: Moderate to high levels of fuel s "
and moderate housing densities `akNaS ''��
Re—tw - -
(medium)
.4t ;Qa.o-,�,
ro '"' ,1.
Tier 3: High fuel levels and moderate to
high housing densities (high)
i �
^vision
e
Kennewick
r
e
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 3, Page 9 of 19

By overlaying the vegetation management polygons with the WUI map, the percentages
of the polygon with a tier 3 (highest risk), tier 2, and tier 1 WUI designation were
calculated. These percentages were then used to generate a risk score for each
vegetation management polygon. A weight was applied to each of the WUI tier levels to
ensure that tier 3 areas are placed at higher priority levels than WUI tiers with lower risk.
The following table demonstrates how the overall risk weighting score for Avista is
calculated on each vegetation management polygon.
Table 1. Weighting calculation example for risk tree prioritization
WUI Tier Weight applied Sample calculation CDA R P4 (WUI %) x weight
3 10 0.229 x 10 = 2.29
2 5 0.655 x 5 = 3.275
1 1 0.009 x 1 = 0.009
Overall risk score 5.574
In 2017, the California Public Utilities Commission adopted the CPUC Fire-Threat Map
which describes the boundaries of a new High Fire Threat District (HFTD) where utility
infrastructure and operations will have stricter fire-safety regulations. The CPUC Fire-
Threat Map incorporates the fire hazards associated with past powerline wildfires and
ranks fire-threat areas based on the risks that utility-associated wildfires pose to people
and property.
The main team that handled the development of the CPUC Fire-Threat Map was a
group of utility mapping experts known as the Peer Development Panel (PDP), with
oversight from a team of independent experts known as the Independent Review Team
(IRT). The members of the IRT were selected by CAL FIRE and CAL FIRE served as
the Chair of the IRT. The development of CPUC Fire-Threat Map includes input from
many stakeholders, including investor-owned and publicly-owned electric utilities,
communications infrastructure providers, public interest groups, and local public safety
agencies. Additional information on California's approach can be found at the California
PUC Fire Safety Rulemaking Background webpage.
The process that Avista has utilized to define Risk Tiers is comparable to the California
approach utilized to delineate the High Fire Threat Districts.
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 3, Page 10 of 19

Risk Tree Workload, Cost, and Tree Failure
Identifying Risk Trees
Industry research has shown that the vast majority (80% or more) of tree-caused
outages are a result of trees or tree parts falling from off the ROW.
• On TransAlta's distribution system, where all overhangs were removed, 90-98%
of tree-caused outages were due to tree failure 2
• Niagara Mohawk reported 86% of tree-caused outages result from trees outside
the right-of-way 3
• Puget Sound Energy found 66% of all outages were caused by trees greater than
15 feet from the nearest conductor 4
• A survey of 71 utilities by the University of Wisconsin found about 81% of
outages are due to off-ROW trees, broken branches, and whole tree failures
rather than on-ROW grow-ins 5
Risk is the combination of the likelihood of an event and severity of the potential
consequences. The Utility Arborist Association developed, and the International Society
of Arboriculture published, the Utility Risk Tree Assessment best management practices
which aid in the development of this tool.
The likelihood a tree will cause an outage, damage utility infrastructure, or cause a
wildfire is dependent on the likelihood that a) the tree will fail and b) the failed tree will
impact the electrical system.
Table 2. Likelihood matrix presented in the UAA//SA Utility Risk Tree Assessment
Likelihood Likelihood of Impact on the System
of Failure Very low Low Medium High
Imminent Unlikely Somewhat likely Likely Very likely
Probable Unlikely Unlikely Somewhat likely Likely
Possible Unlikely Unlikely Unlikely Somewhat likely
Improbable Unlikely Unlikely Unlikely Unlikely
2 Guggenmoos, S. 1996. "Outage statistics as a basis for determining line clearance program status."
UAA Q. 5(1).
3 Finch, K.E., and C.Allen. 2001. "Understanding Tree-Caused Outages." EEI Natural Resource
Conference.Apr. 2001. Palm Springs, CA.
4 Rogers, B.I. 2001. "Puget Sound Energy Tree Watch Program." EEI Natural Resource Conference,Apr.
2001, Palm Springs, CA
5 "Utility Vegetation Management in North America," College of Natural Resources, University of
Wisconsin—Stevens Point, and CNUC. March 22, 2021.
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 3,Page 11 of 19

Tree risk rating is based on the likelihood of failure and impact combined with the
severity of the consequence of impact. The severity of consequence will differ for 69kV
vs 7.2kV, single- vs multi-phase lines, sections with and without special equipment, and
so forth. Following is a risk rating matrix which combines these factors.
Table 3. Risk Tree Rating Matrix presented in the UAA11SA Utility Risk Tree Assessment
Likelihood of Consequence of Failure
Failure & Impact Negligible Minor Significant Severe
Imminent Low Moderate High Extreme
Probable Low Moderate High High
Possible Low Low Moderate Moderate
Improbable Low Low Low Low
The consequence assessment should reflect what portion of the system is involved
(e.g., 69kV, multi-phase, single-phase) and Wildfire Hazard Potential (WHP)
designation.
Observation: By leveraging the industry-accepted UAA/ISA guide, Best Management
Practices— Utility Risk Tree Assessment, Avista is utilizing the most
current protocol in use today by North American Utilities to identify off-
ROW risk trees that pose a hazard to the electrical grid and potentially
pose a wildfire risk.
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 3,Page 12 of 19

Post-outage Investigations
One of the greatest challenges facing UVM professionals is knowing which trees cause
outages and how. Utilities cannot effectively manage a problem they do not understand.
Not all tree species have the same failure rate. Not all portions of the system respond
the same to tree contact (1- vs 3-phase) and the consequence of failure varies widely
(e.g., 69kV vs 1-phase 7.2KV). Best Management Practices— Utility Risk Tree
Assessment provides general guidance regarding risk factors, but best practices utilities
collect utility-specific data through post-outage investigations. Utilities need to study the
root causes of their specific tree-related outages to replace intuition, anecdotal
evidence, and generalized industry data with reliable data.
The Avista VM team does not currently investigate tree-related interruptions. Utilities
that begin post-event investigation of tree-related outages initially find a 25-40% error
rate in unaudited reporting.
Observation: Avista should commit to studying the root causes of tree-related outages
through accurate reporting and thorough post-outage investigations. A
commitment to post-incident investigations does not mean every outage
needs to be investigated; however, the more data, the better the
analysis. Those selected for investigation should include incidents on all
voltages, construction types, and in both storm and non-storm situations.
They should also be timely—conducted close to the outage occurrence.
The objective of these investigations is to understand which trees fail, how they fail, and
how they impact the electrical system. These post-outage investigations should be
performed by an experienced arborist to:
• Give direct feedback on which trees are causing the majority of interruptions
• Provide learning opportunities for the arborist
• Refine assessment criteria
These investigations should go beyond simply indicating it was a "tree-related event" to
identifying distinct characteristics about the tree and the site surrounding it. The data
can then be used to drive the risk tree mitigation process. Data collected during post-
outage investigations often include:
• Voltage • Orientation to the line
• Line configuration (single-wire • Tree or tree part that failed
primary, 2-wire primary, etc.) . Nature of failure (trunk failure,
• Tree species branch failure, uprooted tree, etc.)
• Height • Condition of tree or tree part failure
• Diameter . Site conditions
• Distance to the line • Date of last maintenance
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 3,Page 13 of 19

Tree-related Outages
Since the full rollout of the Risk Tree Program, Avista has documented that more than
60% of the tree-related outages in Idaho from 2020 to 2023 occurred in Tiers 2 and 3.
Tree-related Outages by Tier
400
a
350
6 300
ca
250
0 200
150
= 100
z 50 ■
Tier 0 Tier 1 Tier 2 Tier 3
■2020 2021 2022 2023
Note: Although the WUI map identifies three wildfire risk levels, Avista also collects
outage data for Tier 0 (i.e., nominal risk with low levels of fuel).
Over the past ten years in Idaho, 92% of spark-related outage events fall into five basic
cause categories: animal, weather, public, tree, and equipment. Of these categories,
electric utilities can have the most influence over reducing equipment- and tree-related
events. Animal, weather, and public are much harder to predict and guard against.
Spark-related Outage Events (2014-2023)
Public
18%
Weather
8%
■ Equipment
54%
Tree
8%
— ■ Other
■ Animal 8%
4%
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 3,Page 14 of 19

As covered previously under the Fire Risk Profile section of this report, Avista has
identified Grid Hardening and Enhanced Vegetation Management as two of the four
areas for reducing wildfire risk on the company's electrical grid.
Additionally, research and industry data has shown the following:
1. Unless the distribution lines are entirely enveloped by vegetation, a shorter cycle
seldom results in fewer tree-related interruptions.6
2. At distribution voltages (15kV and below), trees in incidental contact are unlikely
to result in an electrical fault (phase-to-ground) causing an interruption.
• Tree grow-ins represent only 2-14% of all tree-caused outages.',$
• At voltage gradients below 2kV per foot, the probability of a fault occurring is
almost zero.9
3. Due to the above, almost all tree-related outages are caused by whole trees or
limbs falling on the conductors and creating a phase-to-phase electrical fault or
physical damage rather than by tree growth resulting in incidental contact with
the lines.10
Observation: Avista has taken a comprehensive approach to identify and mitigate risk
trees that pose a hazard to the overhead distribution system. This
approach has a two-fold benefit by reducing the volume of trees that can
potentially result in a utility-caused wildfire, as well as reduce the types
of tree-related events that cause interruption of electrical service.
6 Guggenmoos, S. 1996. "Outage statistics as a basis for determining line clearance program status."
UAA Q. 5(1).
Rees, W.T., Jr., T.C. Birx, D.L. Neal, C.J. Summerson, F.L. Tiburzi, Jr., and J.A. Thurber. 1994. "Priority
Trimming to Improve Reliability." ISA conference presentation, Halifax, NS.
8 Finch, K.E., and C. Allen. 2001. "Understanding Tree-Caused Outages." EEI Natural Resource
Conference.Apr. 2001. Palm Springs, CA.
9 Russell, D. et. al. 2011. "Best Practices in Vegetation Management for Enhancing Electric Service in
Texas." PUCT Project 38257.
10 Guggenmoos, S. 2003. "Effects of Tree Mortality on Power Line Security." Arboriculture & Urban
Forestry, 181-196.
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 3,Page 15 of 19

Cycle Length and Objectives
As currently designed and implemented, Avista's Enhanced Vegetation Management
Program incorporates two primary components relative to management of vegetation on
the overhead distribution system: Routine and Risk Tree.
The Routine Maintenance Program emphasizes maintaining a five-year cycle for
addressing the vegetation on the entire distribution system and preventing grow-in
outages. To meet these objectives, the routine maintenance program prioritizes work
based on time since last trim and number of grow-in related outages.
The Risk Tree Program objective is to identify risk trees, with the potential of imminent
fall-in or grow-in hazard to the energized facilities, and ensure they are trimmed or
removed to eliminate potential for fire ignitions and outages. A risk tree is defined as
visibly dead, diseased, dying, or possessing obvious structural defects that could fall
into the conductor. The corresponding risk tree annual patrol identifies trees which are
deemed a threat to reliability and pose a fire risk.
The Routine Maintenance Program and Risk Tree Program are interrelated because
risk inspections and mitigation are performed as part of routine maintenance if a
polygon is on the routine plan for the year. This allows for planning and mitigation work
to happen using the same planners and crews. While the Risk Tree Program and
Routine Maintenance work planning and mitigation contracts are separate, this enables
Avista to move crews between programs as needed to meet work plan objectives and
gain efficiencies.
Observation: Implementing an extensive risk tree assessment and mitigation program
is a best practice today. This includes documenting the root cause of
outages (e.g., which trees/conditions result in failure) and aggressively
targeting higher risk, off-ROW trees (see previous reference).
Important to note: The optimum cycle for preventing tree growth into the conductors
may be different from the optimum cycle for off-ROW risk tree mitigation.
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 3,Page 16 of 19

Historical Risk Tree Workload
Beginning in 2020 when Avista implemented the system-wide patrol of the overhead
distribution system, the annual volume of risk trees abated has increased year-over-
year. Expenditures had initially shown an annual cost per tree increase for 2020-22, but
a reduction in cost per tree in 2023.
Idaho Risk Tree Expenditures
16000 $600
14000 $500
'0 12000
a) 10000 $400
fy
8000 $300
a� V)
6000 $200 v
n 4000
01� 2000 $100
0 $0
2020 2021 2022 2023
Total Risk Trees Completed Cost/Risk Tree
Contributing factors include:
• More than 90% of the U.S. West was in moderate drought or worse by late June
2021. More than a quarter was in exceptional drought, the highest level,
indicating widespread risk of crop loss, fire, and water shortages."
Moderate drought or worse Severe drought or worse —Extreme drought or worse —Exceptional drought
IuC'
80
60
40
20
0 AAL A Ak
2000 2002 2004 2006 2008 2010 2012 2014 2016 2018 2020
Data as of June 24,2021
Chart:The Conversation!r -BY-ND-C:_urcr r,n_i,hAcrito,-�,nt-r,dsta
tt "National Drought Highlights Report," U.S. Drought Monitor, June 24, 2001.
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 3,Page 17 of 19

• Trees in Western forests have been dying at an alarming rate over the past two
decades due to droughts, high temperatures, pests, and fires.12
• Labor cost and availability has had a significant impact on utilities. Based upon
Avista's experience in 2022, the increased volume of risk trees required
mobilization of crews from outside the region to accomplish the workload.
Conversely, by achieving a stabilized workforce in 2023, per unit costs
decreased by 17%.
To determine if a program is influencing system performance, one of the most valuable
measures for a risk tree program is to show a reduction in the occurrence of actual tree
fall-ins. For the evaluation period from 2020 to 2023, Avista has recognized a 62%
reduction in tree fall-ins.
Idaho Tree Events by Outage Type
350
300
v, 250
c
> 200
w
m 150
100
50
0
2020 2021 2022 2023
■Tree Fall-In ■Tree Grow-in
Observation: Considering the impact that drought and tree mortality has had on
forests in the western United States, Avista has implemented an
effective strategy to reduce the potential for utility caused wildfires. By
maintaining the current annual cycle of identifying and abatement of risk
trees, the inventory of risk trees identified and removed should continue
to reduce in numbers so long as the goals and objectives remain
consistent with current practices. By doing so, the annual cycle should
continue to reduce the overall risk exposure from hazard trees.
12 Daniel Johnson and Raquel Partelli Feltrin, "Trees are dying of thirst in the Western drought,"
The Conversation, June 29, 2021.
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 3,Page 18 of 19

IIS Consulting Team
Adam Warf
Mr. Wares experience includes leading business development strategies for a
Q r utility vegetation management consulting firm, vegetation management field
1 , operations at two major investor-owned utilities in the southeastern US,
project management at a variety of utilities in the mid-Atlantic and southeastern regions,
and vegetation management program development and assessments across the
country. His utility arboricultural experience provides a broad understanding of the many
different methods used to create a successful utility right-of-way vegetation
management program, including remote sensing, work management solutions, data
analytics, optimization, and the utilization of third-party consulting foresters for planning
and auditing duties.
Steve Hallmark
Mr. Hallmark serves in a senior leadership role to IIS' Chief Operating Officer,
driving strategic solutions, innovation, and an entrepreneurial vision to power
and energy companies. Mr. Hallmark has extensive experience managing
large-scale utility vegetation management programs, including budget, regulatory
compliance, and contract design and enforcement. Over the years, he has served in a
leadership capacity on vegetation management issues and acted as a government and
industry liaison. Most recently, he served as part of a team at the direction of the
California Governor's Office overseeing PG&E's Wildfire Mitigation Program. With over
40 years of utility vegetation management and line construction practices experience,
Mr. Hallmark is recognized as a highly qualified subject matter expert on a national
level.
Dr. Phil Charlton
,0 Dr. Charlton has worked with over 150 electric utilities in seven countries,
helping to develop long-term vegetation management programs for distribution
W line clearance and transmission rights-of-way maintenance. Most of these
studies required detailed evaluation of the vegetation conditions, work practices, and
operating procedures. Dr. Charlton has also been active in industry research since
1980. His research has encompassed cost and effectiveness issues related to rights-of-
way maintenance, environmental concerns with use of herbicides, wetlands protection,
reliability, and more.
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 3,Page 19 of 19

Vegetation Management Third Party Evaluation Summary
Iapetus Infrastructure Services (IIS) performed a detailed review, completed in May of 2024, of Avista's
Distribution Risk Tree Program to assess the optimum frequency of maintenance per service area (i.e.,
one-,two-or three-year cycles) as requested by the Idaho Public Utilities Commission 2023 GRC Case
AVU-E-23-01, Order No 35684.1 All areas of review were made within the context of Avista's Wildfire
Resiliency Plan.The IIS team utilized the following process for this assessment:
1. Review Avista's Enhanced Vegetation Management and Wildfire Resiliency Plans.
2. Assess Avista's tree-specific performance including tree-related outage data and work
completion records.
3. Interview Avista's Vegetation Management team.
4. Develop and document recommendations.
In summary, based upon their review,the IIS team found that Avista's approach to managing the risk
associated with utility-caused wildfires as an annual cycle is a reasonable and responsible approach. IIS
summarized the following major areas of focus related to Avista's Vegetation Management Program,
with one recommendation to enhance this foundation (Outage Investigations) as shown below:
Observation Comments
Risk Tree Considering the impact that drought and tree mortality has had on
Cycle forests in the Western United States. Avista has implemented an
effective strategy to reduce the potential for utility-caused wildfires.
As the Risk Tree Program matures, the inventory of risk trees
identified and removed should continue to reduce in numbers as long
as the goals and objectives remain in line with current standards. An
annual cycle is consistent with best-in-class programs at other major
utilities in the West.
Risk Tree Avista has taken a comprehensive approach to identify and mitigate
Strategy risk trees that pose a hazard to the overhead distribution system.
This approach has a two-fold benefit of reducing the volume of trees
that can potentially result in a utility-caused wildfire, as well as
reduce the types of tree-related events that cause interruption of
electrical service.
Identifying By leveraging the industry-accepted UAA/ISA guide. Best
Risk Trees Management Practices— Utility Risk Tree Assessment. Avista is
utilizing the most current protocols in use today by North American
Utilities to identify off-ROW risk trees that pose a hazard to the
electrical grid and potentially pose a wildfire risk.
Outage Avista should commit to studying the root causes of tree-related
Investigations outages through accurate reporting and thorough post-outage
investigations. A commitment to post-incident investigations does not
mean every outage needs to be investigated; however. the more
data. the better the analysis.
In June 2023,Avista agreed to the following terms with the Idaho Public Utilities Commission(PUC):"For the Distribution Risk Tree program,
the Company 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 3-year cycles)."
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 4, Page 1 of 2

IIS further found that:
1. By leveraging the industry-accepted UAA/ISA guide, Best Management Practices — Utility
Risk Tree Assessment, Avista is utilizing the most current protocol in use today by North
American Utilities to identify of ROW risk trees that pose a hazard to the electrical grid
and potentially pose a wildfire risk.
2. The process that Avista utilizes to define WUI Risk Tiers is comparable to the California
approach utilized to delineate the High Fire Threat Districts
3. Avista should commit to studying the root causes of tree-related outages through
accurate reporting and thorough post-outage investigations. A commitment to post-
incident investigations does not mean every outage needs to be investigated; however,
the more data, the better the analysis.
4. Avista has taken a comprehensive approach to identify and mitigate risk trees that pose
a hazard to the overhead distribution system. This approach has a two-fold benefit by
reducing the volume of trees that can potentially result in a utility-caused wildfire, as
well as reduce the types of tree-related events that cause interruption of electrical
service.
5. One of the most valuable measures for a risk tree program is to show a reduction in the
occurrence of actual tree fall-ins. For the evaluation period from 2020 to 2023, Avista
has recognized a 62% reduction in tree fall-ins.
6. Considering the impact that drought and tree mortality has had on forests in the
western United States, Avista has implemented an effective strategy to reduce the
potential for utility caused wildfires. By maintaining the current annual cycle of
identifying and abatement of risk trees, the inventory of risk trees identified and
removed should continue to reduce in numbers so long as the goals and objectives
remain consistent with current practices. By doing so, the annual cycle should continue
to reduce the overall risk exposure from hazard trees.
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 4, Page 2 of 2

Avista Utilities
Washington Electric Utility Wildfire
Mitigation Plan Pursuant to HB1032
October 31, 2024
Version 1.0
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 5, Page 1 of 41

Statement from Avista Executive Management
2024 represents Avista's 4th full year of implementing the Wildfire Resiliency Plan. Avista's wildfire
strategies are firmly rooted in our 138-year operating history and represent the collective knowledge of
Avista employees and fire agency professionals together with assistance from peer utilities, and most
importantly, engagement with customers. This Plan was created in compliance with Washington HB 1032
requiring all electric utilities in the State of Washington to submit a Wildfire Resiliency Plan in an approved
format and in accordance with the elements identified by the State. This plan as well as Avista's standard
Wildfire Resiliency Plan, can be found on our website. Though the State plan format differs from our
traditional plan, they are basically the same. Both plans reflect our commitment to partner with customers,
communities, and those who manage forest landscapes and fight fires.
We all have a role to play in minimizing the risk of wildfire.
Heather Rosentrater, President and Chief Operating Officer (COO)
Date: October 31, 2024
Josh DiLuciano, Vice President Energy Delivery
Date: October 31, 2024
Vern Malensky, Director Electrical Engineering
t/'� I Date: October 31, 2024
1
Avista 2021-2023 DNR Wildfire Resiliency Plan
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 5, Page 2 of 41

Table of Contents
Statement from Avista Executive Management................................................................................. 1
1.0 Executive Summary.......................................................................................................................4
2.0 Wildfire Resiliency Plan Overview................................................................................................4
2.1 Purpose of the Wildfire Mitigation Plan...............................................................................................5
2.2 Description of Where the Wildfire Plan Can Be Found Online...........................................................6
2.3 Best Practices Cross-Reference Table...............................................................................................6
3.0 Utility Overview..............................................................................................................................6
3.1 Utility Description and Context Setting Table.....................................................................................7
4.0 Objectives of the Wildfire Mitigation Plan....................................................................................9
4.1 Minimizing Sources of Ignition..........................................................................................................10
4.2 Resiliency of the Electric Grid...........................................................................................................15
5.0 Roles and Responsibilities ......................................................................................................... 16
5.1 Utility Roles and Responsibilities......................................................................................................17
5.2 Coordination with Local Utilities and Infrastructure Providers..........................................................18
5.3 Coordination with Local Tribal Entities..............................................................................................19
5.4 Emergency Management/Incident Response Organization............................................................19
6.0 Wildfire Risks & Drivers Associated with Design, Construction, Operation & Maintenance . 21
6.1 Risks and Risk Drivers Associated with Topographic and Climatological Risk Factors...................21
6.1 Enterprise-Wide Safety Risks...........................................................................................................23
7.0 Wildfire Preventative Strategies .................................................................................................24
7.1 Weather Monitoring...........................................................................................................................24
7.1.1 Current Strategy Overview........................................................................................................... 24
7.1.2 Planned Updates.......................................................................................................................... 25
7.2 Design and Construction Standards.................................................................................................25
7.2.1 Current Strategy Overview........................................................................................................... 25
7.2.2 Planned Updates.......................................................................................................................... 26
7.3 Fuel and Vegetation Management....................................................................................................26
7.3.1 Current Strategy Overview........................................................................................................... 26
7.3.2 Planned Updates.......................................................................................................................... 27
7.4 Asset Inspections and Response.....................................................................................................27
7.4.1 Current Strategy Overview........................................................................................................... 27
7.4.2 Planned Updates.......................................................................................................................... 29
7.5 Workforce Training............................................................................................................................29
7.5.1 Current Strategy Overview........................................................................................................... 29
7.5.2 Planned Updates.......................................................................................................................... 29
2
Avista 2021-2023 DNR Wildfire Resiliency Plan
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 5, Page 3 of 41

7.6 Relay and Recloser Policy................................................................................................................30
7.6.1 Current Strategy Overview........................................................................................................... 30
7.6.2 Planned Updates.......................................................................................................................... 30
7.7 De-Energization/Public Safety Power Shutoff................................................................................31
7.7.1 Current Strategy Overview........................................................................................................... 31
7.7.2 Planned Updates.......................................................................................................................... 33
8.0 Community Outreach and Public Awareness............................................................................ 33
8.1 Current Community Outreach and Public Awareness Program.......................................................33
8.2 Planned Updates..............................................................................................................................35
9.0 Restoration of Service................................................................................................................. 35
10.0 Evaluating the Plan.................................................................................................................... 36
10.1 Metrics and Assumptions for Measuring Plan Performance ..........................................................36
10.2 Identifying and Addressing Areas of Continued Improvement in the Plan.....................................37
10.3 Monitoring the Effectiveness of Inspections...................................................................................37
AppendixA......................................................................................................................................... 39
A.1 Metrics Tables..................................................................................................................................39
AppendixB.........................................................................................................................................40
B.1 Commerce Reported DNR Reported Utility Involved Wildfires........................................................40
3
Avista 2021-2023 DNR Wildfire Resiliency Plan
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 5, Page 4 of 41

1.0 Executive Summary
Provide a brief overview of the Wildfire Mitigation Plan (WMP) and the associated material provided to assist the consumers of
the information. The below text can be kept and added to, edited, or removed for a utility-specific narrative.
Since 2020 Avista has responded to the increasing threat of wildfires within our service territory with a
robust and well-rounded Wildfire Resiliency Plan focused on reducing the likelihood of a wildfire caused
by Avista's Idaho and Washington electric operations, protecting the safety of our employees, customers,
communities, and infrastructure, and preparing ourselves, our system, and external partners for a wildfire
event. The Company produces an annual plan outlining our programs, strategies, performance metrics,
and goals, as well as a state required plan that is produced every three years (beginning in 2024). Though
these plans have two formats, they are, collectively, the same Plan, with the goals of:
• Supporting safe and reliable operations by protecting human lives, safeguarding property, and
protecting physical assets against the threat of wildland fires through the implementation of
Avista's Wildfire programs and Company operations.
• Reducing 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.
• Preparing and training for episodic wildfire events, ensuring emergency preparedness for
ourselves and our partners, and aligning operating practices with fire threat conditions.
• Protecting the energy delivery infrastructure that serves our customers and mitigating the
probability and consequence of direct financial and liability costs associated with large scale fire
events.
Avista's Wildfire Resiliency Plan recommendations also reflect cost prudency and were adopted based
on their ability to leverage existing asset programs and operating practices, promote public safety, and
mitigate financial risks. Avista's Plan is comprised of four major categories. The first category is grid
hardening to reduce spark ignition events and make Avista's electrical system more resilient to the
impacts of wildfire. Second is enhanced vegetation management practices to reduce vegetation-related
risk, often a factor in creating heat events or sparks. The third involves situational awareness, primarily
monitoring technology as well as a Wildland Urban Interface map of our service territory to help us identify
and focus in on the areas of our system most likely to be at risk. Fourth is emergency operations and
planning, which includes automation of equipment to allow us to quickly react to fire threat situations,
partnerships and cross-training with external stakeholders, as well as operational tactics such as
Enhanced Protection Settings (Fire Safety Mode) and Public Safety Power Shutoffs to help us react to
wildfire risk.
2.0 Wildfire Resiliency Plan Overview
Avista is charged with safely, reliably, and affordably delivering energy services to its customers. At the
same time, Avista recognizes that the threat of wildfire impacts all of us at our homes, communities, and
businesses. Our Wildfire Resiliency Plan serves as a testament to our commitment and the responsibility
4
Avista 2021-2023 DNR Wildfire Resiliency Plan
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 5, Page 5 of 41

we take in working to mitigate the risk of our equipment being involved in sparking a fire event, protecting
the safety of our customers and communities, and protecting the infrastructure that reliably serves our
customers.
2.1 Purpose of the Wildfire Mitigation Plan
This Wildfire Mitigation Plan describes in detail the range of activities that a Utility or joint Utilities are taking to mitigate the threat
of utility involved wildfires, including various programs, policies, and procedures. This plan complies with the requirements of
HB 1032 for investor and customer owned electric utilities (IOU/COU) to prepare a wildfire mitigation plan by October 31, 2024,
and every three years thereafter.
The risk of wildfire is ever present in the western United States. Though we have always faced the threat
of wildfires, that threat is increasing both as a function of population growth and location and as the result
of a changing climate. Avista's Wildfire Resiliency Plan was developed as a risk-based approach to
mitigating wildfires, which is critical for customers, communities, investors, and the regional economy.
Avista has taken a proactive approach for many years to manage wildfire risks and impacts, and through
its Wildfire Resiliency Plan, the Company has identified additional wildfire mitigation efforts for
implementation, as described further in this report.
The goal of Avista's Wildfire Resiliency Plan is to reduce the likelihood of a wildfire caused by Avista's
electric operations, reduce the risks associated with utility involved fires, protect the safety of customers,
employees, and first responders, and to lessen the degree and impact of electric system damage and
outages related to wildfire.
Avista is continually balancing wildfire risk and reliability risk. The recommendations contained in this
Plan are based on the ability to reduce wildfire-related risk while considering this balance. It is important
to note that though 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. Using our strategy of altering protection schemes on select circuits based on data and the
analysis provided by our Fire Weather Dashboard,Avista can achieve a better balance between reliability
risk and wildfire risk 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 balancing customer service
and reliability.
The Wildfire Resiliency Plan recommendations consider inherent risk (no defenses) and managed risk
(with defenses) and investments needed to fund the programs necessary to achieve the Plan's
objectives. Since the Plan was developed as a risk-based approach to mitigating wildfires, as a part of
the Company's wildfire resiliency analysis, the Company focused on understanding the risk exposure of
wildfires in general as well as the opportunity to reduce risk through specific actions taken associated
with the Company's transmission and distribution areas. We believe it is critical to act in protecting our
customers as well as the infrastructure that serves those customers.
The Washington State Mandated Wildfire Resiliency Plan, in compliance with HB 1032, will be filed with
the State by October 31, 2024, and every three years thereafter.
5
Avista 2021-2023 DNR Wildfire Resiliency Plan
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 5, Page 6 of 41

2.2 Description of Where the Wildfire Plan Can Be Found Online
Provide a description of how the public and other reviewers can find WMP information online, if available. It is recommended
that utilities host their WMP on the utility website in a location that is relatively easy to find and prioritizes the most current and
up to date WMP.
Avista maintains a current copy of this Washington State Wildfire Resiliency Plan, as well as Avista's full
service territory Wildfire Resiliency Plan on the Company's MyAvista.com website under "Safety" and
"Wildfire Resiliency."
2.3 Best Practices Cross-Reference Table
Provide any industry standard or other best practices (Standards may include guidance from FEMA, US Forest Service, NERC
regulations, NST, OSHA guidelines, etc.) referenced within the WMP including what section and page number in the form of
hyperlinks. Standards that do not have a specific reference within the text but apply to the entirely of the plan can be listed
without additional information. If no industry-wide standards or practices are utilized, this table may be left blank.
Statutory Requirement/Standards Section & Page Number
HB 1032—By October 31,2024, and every three
years thereafter, each Investor-owner and
Consumer-owned Utility must review,if Sec. 4,p. 4
appropriate revise, and adopt its wildfire
mitigation plan
ANSI A300 (Part 9)-2017 Tree Risk Assessment-
Section 7.3.1, n. 25, 26
Tree Failure
American National Standards Institute
(ANSI)/American Society for Quality(ASQ)
Z1.4-2008 Sampling Procedures and Tables for Section 10.3,p. 35
Inspection by Attributes
FERC Reliability Standard FAC-003 Section 7.3.1,pp. 26, 27
NERC Standard TOP-001-4 Section 7.7.1,p. 29
3.0 Utility Overview
In the following sections,provide an overview of the utility,its service area, and general description of the purpose of the Wildfire
Mitigation Plan(WMP).
Avista Utilities serves electric and natural gas customers within a 30,000 square mile service territory
containing approximately 1.7 million people in Washington (62%), Idaho (28%), and Oregon (gas only:
10%). We have approximately 414,000 retail electric customers and 378,000 natural gas customers.'
From Avista's 2024 Quick Facts. 365756ed-8fd4-48f4-9abe-e79ef78c730b (avistacorp.com)
6
Avista 2021-2023 DNR Wildfire Resiliency Plan
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 5, Page 7 of 41

3.1 Utility Description and Context Setting Table
Provide a brief description of the utility and include the context-setting table. For utilities operating in multiple states, complete
the table below only for the areas within Washington state. If any of the information is not tracked, not applicable, or not known,
please leave that section blank and provide a summary of the exception. They note that for many utilities this will be a reference
to a Public Safety Power Shutoff(PSPS) event. These events, whether through a formally defined PSPS program or not, are
recognized as a safety measure of last resort initiated by utilities to pre-emptively de-energize specific powerlines during critical
fire weather to reduce the risk of the electric system being involved in an ignition. The decision to either have or not have this
type of practice is at the operational discretion of the individual utility.
7
Avista 2021-2023 DNR Wildfire Resiliency Plan
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 5, Page 8 of 41

Utility Name Avista Utilities Notes:
Service Territory Size(sq miles) 30,000 Square Miles
[1.48]%Open Water
[0]%Perennial Ice/Snow
[1-19]%Developed:Open Space
[.85]%Developed.Low Intensity
[.51]%Developed Medium Intensity
[.09]%Developed High Intensity
[.22]%Barren Land This information is for our
Sen-ice Territory Make-up [-05]%Deciduous Forest Washington and Idaho Service
[42.5 1]%Evergreen Forest Territories.We do not have this
[-09]%Mixed Forest data broken out by state.
[18.571%Scr ub'Shrub
[16.17]%Crrassland'Herbaceous
[.88]%Pasture'Hay
[16.31]%Cultivated Crops
[.45]%Woody Wetlands
[.62]%Emergent Herbaceous Wetlands
[8]%Wildland Urban Interface[14]%Wildland Urban Intermix
Interface(based
Service Territory on total area)Midland Urban []NA/Not tracked(please add any other detail below) Washington Only
a
Customers Served 408,000 retail electric customers
Account Demographic []%Residential[]%Agricultural[]0 o CommerciaU'Tndustrial[]
NA/Not tracked(please add any other detail below
REVENUE_CIASS COUNT PERCENT
01 Residential 714965 89.49%
21 Commercial-Firm 81997 10.26% Avista does not track customers
22 Commercial-Interruptible 28 0.004% with the suggested categories.Our
31 Industrial-Firm 824 0.1096
customer classes are defined by
[Note:Please pros isle as a percent of 39 Pumping-Irrigation 548 0.07%
41 lndustnal-Interruptible 25 0.003% the Commission.Those classes are
total customers sem•ed l
80Interdepartmental 2401 0.03%] indicated in this response.
91 Commercial Transportation 62 0.01%
92 Industrial Transportation 99 0.01%
93Interdepartmental Transportation 6 0.001%
NA Not Applicable 1331 0.02%
Utility Equipment Make-up(circuit
miles) Overhead Dist.:7,675
This data is in circuit miles and
[.',Vote:Pleasepro>•icle brrefclescription Overhead Trans-:2,270 includes Avista's entire service
Underground Dist.:4,906
of how line miles are measured or territory.
calculated] Underground Trans.:0
Has developed protocols to pre- Yes.No[] Avista has developed a PSPS
emptivel shut off electricity in A summary or description of protocols can be prodded in program which was implemented
response to elevated wildfire risks?3 section 7- for the 2024 wildfire season.
Yes—NO.
Has previously pre-emptively shut off If ves, then proNide the following data for the three trailing
electricity in response to elevated calendar years: 'No PSPS events from 2021-2023.
wildfire risk? Number of shut-off events:[I7]
Customer:accounts that lost service for >10 minutes: [0 ]For
prior response,average duration before service restored:[n'a]
8
Avista 2021-2023 DNR Wildfire Resiliency Plan
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 5, Page 9 of 41

4.0 Objectives of the Wildfire Mitigation Plan
In this section, please state the objectives of the mitigation plan and how each objective supports a response and recovery
system that is focused on public safety. For any section where a program overlaps two or more elements of the plan, it is
acceptable to select the most applicable element to describe the program and reference that section where applicable for other
areas. It is not necessary to repeat the program description multiple times.
Research indicates that climate change has fueled the increase in wildfires across the Western U.S. and
that the frequency of wildfires has quadrupled since the 1980s. Fire season is also longer. Most areas
across the western United States report 80 additional days of fire season.2 The U.S. Forest Service has
extensive fire records for the Western states which indicate a tripling in fires larger than 1,000 acres, from
an average of about 50 fires in 1970 to nearly 150 today.' Conditions are becoming more and more
condusive to large, destructive wildfires, and U.S. utility electric assets are located in areas that are
becoming increasingly vulnerable to wildfires.
Avista published its first Wildfire Resiliency Plan in June of 2020 following 18 months of development
which included working with peer utilities, internal subject matter experts, and regional wildfire and
emergency response agencies. Based on the input provided by this array of participants, the Company
identified actions to reduce wildfire risk grouped into four categories, all of which are designed to work
together to protect customer, employee, and first responder safety, and protect critical assets to help
ensure customer reliability and service. Our programs are grouped into four primary categories:
• Grid Hardening—Strengthen and upgrade infrastructure to reduce equipment failures, decrease
the potential for spark events, and protect poles and equipment from the impact of wildfires.
• Enhanced Vegetation Management—Remove dead, dying, and diseased trees that could strike
powerlines. Employ remote sensing such as LiDAR and satellite-derived information to aid in
vegetation inspections and risk tree identification to help reduce the potential for vegetation-
related outages that can impact customer service and/or lead to a spark.
• Situational Awareness — Develop and utilize tools to predict, identify, and respond to risk, both
static risk in our service territory (via the WUI map) and dynamic real time risk (using Avista's Fire
Weather Dashboard).
• Emergency Response & Operations — Align utility system protection with fire-weather
conditions in order to enhance the safety of customers, especially during high fire threat weather.
Recognize wildfire as separate and distinct from other weather events and partner closely with
emergency first responders and firefighters before, during, and after an event to increase safety.
2 John T.Abatzoglou and A. Park Williams, "Impact of Anthropogenic Climate Change on Wildfire Across Western US Forests,"
Proceedings of the National Academy of Sciences,October 10,2016, Impact of anthropogenic climate change on wildfire across
western US forests i PNAS
3 Climate Central, "Graph: Hotter Years, More Fires in Western States,"https://www.climatesignaIs.org/resources/graph-hotter-
yea rs-more-fi res-western-states
9
Avista 2021-2023 DNR Wildfire Resiliency Plan
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 5,Page 10 of 41

The elements within each of these program areas are specifically designed to address safety for people,
communities, and infrastructure. Programs to reduce the risk of spark or heat events include distribution
grid hardening measures such as replacing outdated equipment and installing wildlife guards, as well as
identifying and mitigating risk-trees (trees with the potential of imminent fall-in hazard to energized
facilities). Programs to protect infrastructure include replacing wood poles with steel and wrapping wood
poles with fire resistant mesh in high fire threat locations. The Wildfire Resiliency Plan also has a strong
focus on preparation as a means of reducing risk, including the development of our Fire Weather
Dashboard, which models fire risk on a feeder-by-feeder and section-by-section basis. It also includes
use of the Fire Safety Mode operating practice, installation of additional monitoring and control equipment
in high fire threat areas, and "people" preparation including formalizing procedures inside and outside of
the Company to address wildfire situations, as well as working with external partners on training,
coordination, and response.
Avista's Wildfire Resiliency Plan is intended to accelerate existing infrastructure programs as well as
conduct new programs to reduce fire ignition risk from electric lines and to make systems more resilient
against the impact of fires. Avista's Wildland Urban Interface (WUI) map indicates that 2,746 miles (36%)
of its electric distribution lines are located in high fire consequence areas, of which 1,708 miles reside in
Washington (22%). These zones reveal the intersection between forest land and human development
and are the focal point of Avista's risk mitigation strategies.
4.1 Minimizing Sources of Ignition
Describe steps taken to reduce likelihood of ignitions from energized equipment.
Most of Avista's Wildfire Program elements are related to minimizing the chance for a spark or heat event
occurring. Some of our programs are more specifically focused on this mitigation, including our
distribution grid hardening efforts, enhanced vegetation management practices, situational awareness
strategies, and operational tactics.
Distribution Grid Hardening
Distribution grid hardening efforts are intended to reduce the number of spark-ignition events on the
distribution system and to protect critical infrastructure from the impacts of fire, focused primarily on
portions of electric circuits located in high fire threat areas. Though Avista has asset maintenance
programs to replace poles and equipment, existing programs are condition-based and support reliability
objectives. Wildfire Distribution Grid Hardening focuses on upgrades most likely to reduce spark ignition
events and poles fires. The scope of this work includes:
• Replace wooden crossarms with fiberglass to mitigate pole fires.
• Replace small or outdated wire with modern steel-reinforced wire to reduce conductor failures.
• Install wedge-bail clamps at hot tap connector locations to help prevent thermal failures.
• Underground distribution lines where financially feasible.
• Add or replace wildlife guards to mitigate electrical contacts with animals and birds.
• Replace wood with metal poles at critical span locations such as highway and river crossings.
10
Avista 2021-2023 DNR Wildfire Resiliency Plan
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 5,Page 11 of 41

On average, Avista experiences about 80-90 pole fires per year mostly related to wood crossarms. In the
U.S., about 25% of pole fires lead to collateral damage including wildfire.' By replacing wood crossarms
with fiberglass units, leakage current is substantially reduced, and pole fire risk is much lower.
Animals cause about 8%of Avista's outages (animal related outages are the number five cause of power
outages in the U.S.)'Wildfires caused by animals are increasingly common due to issues such as ignition
of nesting materials and other animal-related debris or electrocuted birds and animals falling to the
ground, igniting dry vegetation below.' Installation of animal guards at transformers and other connection
points is an effective means of reducing these electrical contacts.
Though hot taps fail at a low rate, a majority of peer utilities use a bail type connector in conjunction with
hot taps to prevent conductor drops, which can lead to live wires coming in contact with dry vegetation
on the ground, 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 and reduce
the risk of pole failure. They also replace end-of-life wood poles and equipment and install lightning
arresters to help prevent lightning storms from sparking fires. These efforts are focused on the areas of
our system identified by our Wildland Urban Interface (WUI) maps as being at highest risk.
Enhanced Vegetation Management
Effective vegetation management is an integral part of maintaining overhead electric distribution and
transmission lines. Historically, utilities have trimmed and removed trees with a focus on improving
reliability and reducing the frequency of outages. Avista has a long history of using proactive approaches
to identify and address potential vegetation-related issues before they result in outages. However, with
the increasing threat of wildfires as a result of poor forest health, past fire suppression activities, and
periods of prolonged drought, through the Wildfire Resiliency Plan, Avista enhanced our existing
vegetation management practices especially in elevated fire threat areas. This was accomplished by
splitting the existing vegetation management program into two programs: routine inspections (which
continue the existing vegetation practices) and risk tree inspections which will encompass 100% of our
non-urban distribution system each year. This new program that we call "Enhanced Vegetation
Management" focuses specifically on risk trees, those most likely to be a hazard to electrical facilities.
This new program includes new elements such as digital data collection, Fuel Reduction Partnerships,
and the Safe Tree Program. All of these programs are designed to identify and mitigate vegetation issues
to help prevent outages and spark events.
Situational Awareness
Avista has developed a computer algorithm to monitor, forecast, and adapt to fire-weather events.
Avista's Fire Weather Dashboard combines the National Weather Service's 7-day forecast with Avista
4"National Survey Takes a Look at Pole Fire Causation and Mitigation,"T&D World, November 11, 2019, National Survey
Takes a Look at Pole Fire Causation and Mitigation I T&D World (tdworld.com)
5 Krysti Shallenberger, 7 ways animals threaten the power grid," UtilityDive, October 21, 2016, 7 ways animals threaten the
power grid I Utility Dive
6 Brian McGowan, Michael Anderson, Luis Puigcerver, "Increase Reliability in the Power Grid and Reduce Wildlife-Related
Fire Risk,"T&D World, Sept. 20, 2020, Increase Reliability in the Power Grid and Reduce Wildlife-Related Fire Risk I T&D
World (tdworld.com)
11
Avista 2021-2023 DNR Wildfire Resiliency Plan
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 5,Page 12 of 41

infrastructure data to quantify the daily fire risk on all of our distribution circuits. This allows system
operators to align circuit protection settings with fire-weather conditions and to minimize the potential for
spark-ignition on a circuit-by-circuit basis. 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. This monitoring system supports Avista's fire
season circuit protection program known internally as Fire Safety Mode.
Avista developed the Fire Safety Mode (FSM) operating program in the early 2000s in response to a
number of active fire years in the late 1990s. Historically, circuit reclosers are programmed to
automatically reclose several times after detecting a line fault in order to maximize service reliability.
Electric faults occur when equipment fails or when weather and wind cause branches or trees to fall into
powerlines, for example. All electrical faults involve a release of energy before the fault is interrupted by
the utility's protective equipment. The vast majority of electrical faults do not result in fire ignition, and
most distribution faults are temporary, such as animal contacts, lightning, and small tree branches.
Temporary faults can be cleared by de-energizing a circuit and then re-energizing a couple of seconds
later to maintain customer service. On the other hand, if the fault is permanent such as a broken
conductor or when trees fall into powerlines, a combination of circuit breaker operation and line fuses is
used to isolate the fault and limit the number of impacted customers. However, in some situations this
series of reclose attempts can add to fire ignition potential. Avista engineers developed the FSM program
to limit automatic reclosing on circuits with elevated fire ignition risk.
Avista also developed a Wildland Urban Interface(WUI)map of our service territory which identifies areas
of our system that are most likely to be impacted by wildfire, helping prioritize the work required to clear
vegetation hazards and to harden electric lines. Avista's WUI risk mapping is oriented towards potential
utility-caused fires combined with significant impact to communities. Understanding where our greatest
risk areas are located is an important component in implementing the Wildfire Resiliency Plan, helping
us prioritize the application of solutions.
Operations and Emergency Response
A large part of Operations and Response includes the ability to monitor and control electric transmission
and distribution equipment, which is critical when responding to wildfires and addressing wildfire risk.
Centralized aggregation of data (such as SCADA) received from the power system provides visibility and
allows operators to quickly adjust protection and controls to match fire risk (or other) conditions.
Automation and communications equipment let us rapidly disable reclosing or, in extreme cases, shut off
power in response to increased fire hazard in accordance with established procedures.As part of Avista's
Wildfire Resiliency Plan, we are working to make sure key protection devices out on the powerlines and
in substations can be operated remotely to quickly respond to fire weather and the associated risk. Thus,
the Plan includes installing or upgrading midline and substation breakers to enable dynamic protection
settings, allowing these devices to be monitored and operated remotely and automatically during fire
season, as well as SCADA installations at substations in high fire risk locations to enable substation
monitoring and operation during high fire threat conditions.
One important defensive strategy against wildfire ignition is Avista's Fire Safety Mode (FSM)
operations, which can significantly reduce spark ignition potential by adjusting the sensitivity of the
protection system when there are forecasted significant weather events during wildfire season. Since
12
Avista 2021-2023 DNR Wildfire Resiliency Plan
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 5,Page 13 of 41

the early 2000s, during fire season Avista has transitioned into the mode of limiting the number of
circuit recloses on selected feeders on circuits deemed potentially at risk. This operational methodology
is an important defensive strategy against wildfire ignition by both identifying 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. This
practice allows us to reduce the number of times a line will try to reclose if it trips off, reducing the
chance for a spark.
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 from the threat of wildfire. It is an effort to prevent electrical equipment from starting a severe, fast
spreading wildfire by turning off powerlines during extreme weather based upon a calculation of risk,
typically when high winds, low humidity, 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 to proactively de-energize facilities
located in high risk areas during extreme weather conditions that have the potential to propagate
wildfire. Our PSPS Plan is essentially the last step in our Fire Safety Mode operations plan, 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.
The primary objective of Wildfire Resiliency is to reduce the number of utility-involved ignition events and
to minimize the damage to infrastructure resulting from wildfires. The bulk of that effort is rooted in long-
term planning and implementation of methods such as clearing vegetation away from powerlines,
automation, operational strategies, and increasing the resiliency of infrastructure. However, wildfires will
continue to occur, so Wildfire Resiliency also includes support elements such as first responder training,
developing relationships with key internal and external partners, and emergency operations procedures.
The Operations and Emergency Response part of the Plan encompasses both internal and external
resources with a goal of reacting to wildfire threat in a proactive and coordinated manner, along with the
ability to rapidly respond as needed. These strategies are described below:
• Wildfire Emergency Operating Procedure (EOP)
Avista uses a formal Incident Command Structure (ICS) to respond to electric and natural gas
emergencies called Emergency Operating Procedures (EOP). This system may be activated
several times each year in response to severe weather conditions and other high impact events.
Avista expanded its existing EOP to incorporate a specific wildfire function in order to coordinate
with fire officials during an event.
To customize Avista's EOP work to Wildfire, we brought fire professionals into our internal
discussions and EOP processes, which has also allowed us to successfully integrate into their
Fire Incident Command (ICS) structure during actual fire events. In Washington State, the
Department of Natural Resources is responsible for most non-federal fire suppression, and in
Idaho, the Department of Lands takes the lead. In either state, responses to fires larger than 100
13
Avista 2021-2023 DNR Wildfire Resiliency Plan
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 5,Page 14 of 41

acres triggers an ICS. The ICS is a standardized approach to the command, control, and
coordination of the fire response from beginning to end, allowing the various agencies responding
to the fire to work together efficiently. It provides components such as common terminology,
integrated communications, and a unified command structure over all of the jurisdictions and
personnel involved. Avista's strong relationships with these fire professionals, strengthened by
our work with them to develop and implement the Plan and their participation in our EOP
processes, ensures that Avista is successfully engaged with them in a fire situation. This
integration enables our personnel to understand what is expected of them and how they can assist
and support fire command.
• Cross Training on Fire Safety
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 as well as wildland fires. Each year in-person training is provided to all electric line
personnel with a focus on safety during wildfire response. 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 during fire season. We recognize that in a
wildfire event safety comes first, and that police and fire authorities command the scene. Though
Avista crews respond to pole fire events and have basic firefighting training and equipment, they
are not professional firefighters. We defer fully to fire professionals.
Avista conducts annual fire safety and electrical hazard training with fire agency partners across
the service territory, including joint training sessions with fire protection personnel. Fire
professionals provide fire safety training to Avista first responders and, in turn, Avista conducts
electrical hazard training for fire personnel. It is important that Avista personnel understand the
safety precautions taken during an active fire situation and that Avista first responders understand
fire incident command structures and their role during an active event. Likewise, it is essential
that fire personnel understand the hazards associated with electric operations and firefighting
operations in the vicinity of utility facilities. This program is designed to promote the safety of
everyone involved in a wildfire situation.
• Expedited Response Agreements
This entails agreements with local fire departments, the Washington Department of Natural
Resources, and the Idaho Department of Lands to dispatch fire patrol personnel to transmission-
level outage locations during fire season. The goal of these agreements is to get a quick response
to the site of the fault. 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. A quick response is key to keeping
fires smaller. Expedited Response is initiated when Avista System Operations makes a request
and provides an exact location of the incident to the appropriate entity, enabling fire department
response to go directly to the scene with any required available information. Avista has signed
agreements in place that fire professionals will respond to transmission level outages in both
Idaho and Washington. Nearly 100% of our transmission system is covered by Expedited
Response agreements. These agreements have no cost and no end date.
14
Avista 2021-2023 DNR Wildfire Resiliency Plan
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 5,Page 15 of 41

• Weekly Fire Threat Assessment Meetings
During fire season, Avista hosts meetings to discuss fire threat, the potential to elevate protection
settings (Fire Safety Mode) as appropriate, share current information, and coordinate efforts.
These meetings provide a forum for Avista district managers to report on fires in our operating
districts including impacts or potential impacts to our infrastructure as well as discuss elevating
system protection settings (Fire Safety Mode) in response to fire threat situations.
4.2 Resiliency of the Electric Grid
Describe the utility's ability to withstand fire weather conditions and quickly recover services.
As mentioned above, most of Avista's Wildfire Program elements are related to minimizing the chance
for a heat or spark event to occur. Some of our programs are more specifically focused on resiliency,
including our steel replacement program and transmission wood pole fire resistant mesh wraps.
Transmission Steel Pole Conversion
Transmission lines are particularly vulnerable to wildland fires. Avista began installing tubular steel
transmission poles in the late 1980s 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. 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. The
Company has created a prioritized list of wood structures to be replaced with steel based upon WUI zone
location, historical fire patterns, and in high canopy areas where steel poles would be the best choice
(versus low-vegetation areas where fire protection may be provided with fire mesh wrap at the base of
the wooden pole). Steel poles have the added benefit of increasing reliability, as they are less likely to
fail. Steel poles are stronger and less prone to wind, fire, lightning, bird, and insect damage. They also
resist catastrophic "domino effect" failure when a tension release from a pole being knocked down can
cause a long line of consecutive poles to snap, and are resistant to structural failure, which can lead to
an ignition if it results in a wire down. Steel poles that are incorporated within a steel structure that includes
a steel cross arm, commonly referred to as an H-Frame, provide more resistance to failure from severe
weather events. Steel poles have a longer life expectancy and typically require less maintenance and
repair than wooden poles.
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 low-level fires, it has a limited expected life and requires
maintenance every 3 to 5 years. Avista worked with Southern California Edison to adopt a more resilient
product for protecting wood transmission poles at risk from grassland or other low-level fires. Fire
resistant mesh wrap incorporates a heat activated chemical on a steel mesh substrate that is wrapped
around the base of wood poles. When activated by extreme heat, the chemical expands to seal the pole
and protect it from fire. This product works well in protecting wood poles that reside in areas where fires
move quickly and tend to stay low to the ground.
Restoration of Service
15
Avista 2021-2023 DNR Wildfire Resiliency Plan
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 5,Page 16 of 41

For all utilities, restoration of service following any outage to as many customers as quickly as possible
is a top priority. Restoration efforts may also, if possible, include consideration of customers most heavily
impacted by outages or located in Named Communities. If Avista de-energizes a line for Public Safety
Power Shutoff or if a line placed in elevated protection settings trips out of service, the process of
restoration may take longer, as facilities cannot be re-energized until conditions are safe and all lines are
thoroughly inspected to ensure that any safety related issues are mitigated before the line is returned to
service. Restoration time for any event is impacted by crew availability and location, the accessibility of
the impacted circuit, how many circuits were impacted across the service territory, how much damage
was done, when firefighters allow access to the area, employee safety, and other factors.
5.0 Roles and Responsibilities
Provide within these sections an organizational overview of the utility and wildfire management or response personnel,
coordination efforts with other local utilities and infrastructure providers, and any currently obligated or voluntary emergency
management communication efforts. It is up to the discretion of each utility to determine the specific needs of the communities
they serve and how best to prepare for any emergency situation, including wildfire.
The Wildfire Implementation Team is comprised of a manager who oversees wildfire-related programs,
plans, and strategies as well as his associated staff. Plan implementation is governed by an Avista
steering committee whose membership reflects a broad cross-section of departments including
Regulatory, Financial, Risk, Insurance, Electric Operations, Community Relations, Corporate
Communications, Real Estate, Environmental, Legal, and Asset Maintenance. In addition to governance
by the steering committee, an executive management team routinely meets to monitor progress and
discuss forward-looking strategies. Wildfire is an enterprise level risk and executive level oversight is
essential for producing prudent and cost effective outcomes for customers. Thus, Avista's officers and
the Board of Directors are provided consistent progress reports. We also gather customer and first
responder feedback via our communications outreach efforts and engage continuously with partners
outside the Company such as the Washington Dept. of Natural Resources, Idaho Dept. of Lands, the
National Weather Service, our Commissions, and others to gather input, insights, and expertise. All of
this engagement helps ensure that the Plan is meeting all stakeholder objectives and goals for the
program and that we continue to improve over time.
Working With External Parties
An important part of the Wildfire Resiliency Plan relates to emergency readiness with our community
partners. We have learned that partnerships are absolutely critical, and we continue to add and enhance
these relationships whenever we can. Since the beginning of the Wildfire Resiliency Plan, we have
focused on outreach. The Company has developed close and integral partnerships with outside agencies
including first responders and state and federal agencies. The Company is also cross-training with first
responders regarding fire situation command and response and in working safely near electric facilities.
The Wildfire Team participates in Washington Dept. of Natural Resources and Idaho Dept. of Lands fire
briefings during fire season. We also work with fire agencies across our service territory in response to
outage events. This includes de-energizing facilities upon their request in order to keep firefighters safe.
It also includes our Expedited Response strategy where these professionals respond to transmission
level outages during fire season. We engage with the Tribes on fuel reduction efforts and communications
needs unique to them. We actively engage with customers through a variety of means, from emails and
16
Avista 2021-2023 DNR Wildfire Resiliency Plan
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 5,Page 17 of 41

bill inserts to direct face-to-face engagement, telephone town hall events, events, phone calls and/or
emails.All of these partnerships are integral to the success of our plan, as Wildfire is too critical a situation
for us to deal with strictly on our own.
In the case of implementing a PSPS or wildfire-related Emergency Operating Procedure (EOP), external
agencies that may be impacted (such as the Washington Dept. of Natural Resources, the Idaho Dept. of
Lands, the U.S. Forest Service) are brought into the process to provide input and ideas as well as to
receive a heads-up regarding Avista's information on fire risk that may be related to their jurisdictions.
Customers and communities that are directly impacted by these actions are informed and provided
updates prior to, during, and after an event.
We also coordinate with external agencies to reduce the chance of wildfires by reducing fuel loading near
our facilities. Through our Fuel Reduction Partnerships, Avista financially assists these external agencies
with fuel mitigation near our facilities. Partnerships include the U.S. Forest Service, the Washington Dept.
of Natural Resources, the Idaho Dept. of Lands, area tribes, counties, and local and regional fire
agencies. This work includes removal of dead trees and underbrush and thinning small diameter trees
on or adjacent to Avista-owned facilities and corridors. Some of these funds are also used to help these
agencies provide assistance, expertise, and educational opportunities to property owners. For example,
Avista's partnership with Bonner County's Dept. of Emergency Management provides funding for their
BonFire Program,7 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.
5.1 Utility Roles and Responsibilities
Please provide a utility wildfire program organizational chart highlighting the wildfire specific staff/positions within the utility. The
utility should also provide a detailed description of the wildfire specific roles within the utility and the responsibilities of said roles.
The Wildfire organization at Avista is based out of the Electrical Engineering group, led by the Director of
Electrical Engineering. The Wildfire Team is comprised of a manager who oversees the wildfire programs,
plans, and strategies. They are supported by a Wildfire Program Specialist who oversees external
relationships including Expedited Response, provides training/cross-training, monitors the Fire Weather
Dashboard, and manages situational awareness tools. The Wildfire Analyst is responsible for
Commission work, writing the wildfire resiliency plans, providing presentations, and collecting and
reporting plan-related metrics. This team does the day to day work related to Avista's Wildfire Resiliency
Plan, including managing relationships with other groups within the Company who do the physical work
related to our programs such as vegetation management, transmission and distribution grid hardening,
and installing the equipment on the distribution grid to control and monitor operations. The Sr. Wildfire
Resiliency Program Manager and the Wildfire Community Safety Manager report to the Wildfire
BonFire Program Information: https://www.bonnercountyid.gov/departments/EmergencyManagement/bonfire
17
Avista 2021-2023 DNR Wildfire Resiliency Plan
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 5,Page 18 of 41

Dennis
Resiliency Manager and lead the Company's F
Vermillion
Public Safety Power Shutoff plan development I L Chief Execufve Officer
and implementation as well as associated
customer engagement and communications Heather Rosentrater
and managing Customer Resource Centers
during a PSPS event.
The Wildfire Steering Committee is
responsible for on-going oversight of wildfire Vern Malensky
season preparedness and providing support to Director Electrical Engineering
the Wildfire Resiliency Manager, focused
Matt Ugaldea
primarily on tactical changes. The committee Manager Wildfire Resiliency
consists of internal Avista stakeholders with
responsibility for the outcome of wildfire Lisa LaBolle Brett Connor Lange RobynBrookshire
preparedness and response activities. This Wildfire easiness Analyst Wildfire Program Specialist Wildfire Community Safety Sc Wildfire Resiliency
Manager Program Manager
includes representation from Risk, Legal,
Regulatory, Asset Maintenance, Customer Service, and Communications.
Activities related to operational response to weather conditions are overseen and directed by Avista's
Executive Wildfire Leadership Team, consisting of officers and senior officers of the Company. This team
provides strategic direction related to wildfire activities and final operational approval when placing
feeders elevated protection setting operating mode. In the case of a wildfire or PSPS event, decision
making is escalated through the 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. They
guide the work and the decisions regarding escalating a situation, prepare crews and employees, notify
customers, and manage the situation from initiation to full restoration. They also make the call whether
to involve executive leadership. 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.
5.2 Coordination with Local Utilities and Infrastructure Providers
Describe any coordination and communication involving other local utilities and infrastructure providers which are essential to
wildfire response and recovery(e.g., water utilities, gas utilities, phone%able/internet providers, local emergency management
and first responders).
Avista Regional Business Managers have been coordinating and communicating about our Wildfire
Resiliency Plan with a number of partners over the past several years including local emergency
managers, local emergency planning committees, fire districts and departments, tribes, state and national
wildfire responders (DNR, IDL, BLM) and elected officials in high fire threat municipalities. Avista has
also been working closely with our municipalities, large customers and other local utilities (especially
water purveyors) to identify critical infrastructure (such as water supply, wastewater treatment facilities,
hospitals, emergency operations centers and the radio towers that support them) on our system, down
18
Avista 2021-2023 DNR Wildfire Resiliency Plan
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 5,Page 19 of 41

to the meter number. We have conversations with our public safety partners, including the Red Cross,
about the services essential to wildfire response and recovery. We have also been establishing and
enhancing partnerships with community and health organizations that support vulnerable populations in
the event of a power outage.
5.3 Coordination with Local Tribal Entities
Describe any coordination with adjacent Tribes that may be impacted or have emergency response needs in the event of a
wildfire scenario.
Avista holds Town Hall Meetings in all of our elevated WUI zones each year prior to fire season. These
meetings are designed to educate elected, community, and tribal leaders about wildfire resiliency and
Avista's Plan, as well as to gather insights about how to better engage with these communities going
forward. The goal of these meetings is to inform first responders on Avista's Wildfire Resiliency Plan,
share information on how to best coordinate activities before, during, and after an event, to educate
customers on the Company's efforts to reduce wildfire risk, and to notify them about our strategy to
elevate system protection settings (Fire Safety Mode and Public Safety Power Shutoffs) during critical
fire weather events, including the potential impacts of these efforts. An important factor in this
engagement is ensuring that potentially impacted community leaders understand the possibility for more
frequent and longer power outages during Fire Safety Mode activation so they can help answer questions
and support their citizens.
Specific community outreach efforts with the Tribes have included a number of discussion topics
especially concerning tribal elders and medically vulnerable tribal members. The Tribes are partnering
with Avista to further identify these vulnerable populations (some already have partial lists) and to
strategize on what can be done to help support all tribal members, especially these vulnerable customers,
in the case of an extended power outage. We also work closely with the Tribes while performing grid
hardening and transmission resiliency work that impacts their land and members.
5.4 Emergency Management/Incident Response Organization
Describe utility's efforts(if any) to coordinate with relevant safety agencies as well as other relevant local and state agencies to
establish roles, responsibilities, and structure of communication for emergency management system alerts. Coordination efforts
may include but are not limited to:
•Emergency management system structure during red flag conditions and wildfires
•Relevant training exercises the utility may participate in relating to red flag conditions and wildfires
(It is recommended as a best practice that utilities adopt or adapt an industry recognized Incident Management System as a
guide).
The Emergency Operating Plan or EOP is an incident command structure that defines workflow
processes and unified command structures deployed during emergency events. It includes defining key
roles and responsibilities, identifying communications channels, and emergency operating procedures to
be used during emergency events. The vast majority of the major events that lead to an Avista Emergency
Operating Procedure (EOP) are weather related, coming about due to extreme wind, dangerous
temperatures, or snow/ice events. Avista has developed an EOP specific to wildfire events, as it is
imperative that wildfire events or potential wildfire conditions be managed in a specific, detailed, and
19
Avista 2021-2023 DNR Wildfire Resiliency Plan
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 5,Page 20 of 41

thoughtful way that has a strong emphasis on the safety of people, places, and infrastructure and also
that includes critical external partners. Prescribed procedures must be adopted and followed at all levels
of the Company in order to manage a wildfire or potential wildfire situation adequately and successfully.
At the same time, the Company must integrate into firefighting efforts in a way that supports their work
and increases their safety.
In 2023 we finalized our Emergency Operating Procedures specific to wildfire response and set up an
extensive tabletop exercise to test the design against a simulated fire situation. We invited emergency
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 tabletop exercise
wildfire scenario. The exercise included a realistic situation related to a wildfire event and allowed
participants to "experience" and react to this event and develop a unified approach, specifically related
to working together in fire Incident Command Structures (ICS) in place during wildfire events. The ICS
provides a standardized approach to the command, control, and coordination of the fire response from
beginning to end, allowing the various agencies responding to the fire to work together efficiently. It
provides components such as common terminology, integrated communications, and a unified command
structure over all of the jurisdictions and personnel involved. Avista's strong relationships with fire
professionals, strengthened by our work with them on the Wildfire Resiliency Plan, have brought them
into our internal discussions and EOP processes. Working together in this way, practicing response
together, ensures that Avista is successfully engaged with them in an ICS situation, and that our
personnel understand what is expected of them and how they can assist and support fire command.
It should be noted that in most large wildfire situations, local response (city, county) is superseded by
state and federal authorities. In Washington State, the Department of Natural Resources is responsible
for most non-federal fire suppression. Fires larger than 100 acres trigger a Fire Incident Command
Structure (ICS). Avista defers to the leadership of these organizations in a wildfire event.
Avista has always had good relationships with the firefighting agencies that have jurisdiction on the lands
that our facilities occupy. During fire season the Wildfire Team holds fire risk meetings to provide updates
and information sharing as well as gather feedback from operations managers and non-Company
associated parties. Divisional managers are responsible for conducting basic fire training at one of their
monthly safety meetings, but as part of the Wildfire Resiliency 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
understand the hazards associated with electric operations to help keep them safe when working near
our facilities. 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.
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 Management and the
Spokane County Sheriff's Department. Along with information sharing, this relationship has brought a
20
Avista 2021-2023 DNR Wildfire Resiliency Plan
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 5,Page 21 of 41

heightened awareness of how fire and emergency response is coordinated and how the utility can
integrate into emergency response efforts.
Emergency Management organizations around the service territory take part in our spring telephone town
hall meetings. Avista uses this platform to communicate broadly with customers, community leaders, and
first responders from highly impacted communities located in elevated fire risk zones, including
vulnerable populations and medically vulnerable customers. These meetings review Avista's
preparations for fire season and potential operations such as Fire Safety Mode and Public Safety Power
Shutoffs. In addition to answering customer questions, this platform also yields helpful information about
how our customers are preparing and what is most concerning to them. In these meetings we share
updates on our current and future wildfire plan progress as well. Emergency management professionals,
public safety partners, and key community leaders from each region are invited to participate in their
associated town hall meeting.
It is important to note that Red Flag conditions are only one factor Avista considers in evaluating fire risk.
Due to the size of our service territory at over 30,000 square miles, weather risks vary significantly across
our system. To manage this variability, our Fire Weather Dashboard was developed to model and predict
fire risk on each individual feeder in Avista's system in real time. A spectrum of information goes into this
analysis including a variety of National Weather Service information such as wind speed and direction,
sustained wind levels, humidity and dryness levels, temperature, and drought conditions, as well as
Avista-specific information including type of vegetation on each feeder, condition of equipment, type of
equipment, mode of operation, historic outage data, population and human impact, and other factors to
develop a prediction of wildfire risk. This information is far more detailed than the more general Red Flag
Warning.
6.0 Wildfire Risks & Drivers Associated with Design, Construction,
Operation & Maintenance
Within these sections, provide any specific information regarding the risks and risk drivers specific to the utility service territory
and surrounding areas as well as enterprise-wide safety risks.
6.1 Risks and Risk Drivers Associated with Topographic and Climatological Risk
Factors
List primary risk drivers for wildfires specific to the utility service area and briefly describe the utility's prioritization of stated risks
(what is most important in a service area),and what climate conditions or geographic characteristics the utility's wildfire mitigation
strategy incorporates. Example risk drivers may include Extended drought; Vegetation type;High winds; Steep terrain;Lack of
early fall rain.
A variety of factors go into Avista's assessments around wildfire risk and how this risk can be effectively
mitigated. Our risks are captured both in our static Wildland Urban Interface (WUI) map specific to our
service territory and which informs where we will focus our mitigation efforts, and in our dynamic Fire
Weather Dashboard, which models real-time fire risk on a feeder-by-feeder basis. In general, for Avista,
wind is the number one most impactful factor contributing to wildfire risk. We cannot have high risk without
high winds. Relative humidity is typically the second most important determining factor, as it influences
fuel moisture levels and therefore burnability. Avista's risk drivers include:
21
Avista 2021-2023 DNR Wildfire Resiliency Plan
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 5,Page 22 of 41

Vegetation Type
Vegetation type is a key driver in the risk assessment for utilities as it shows areas that have higher flame
lengths and higher probabilities of fire occurrence and spread rates. This can also help describe areas of
lower risk like urban core areas that are less burnable. The spread of wildfires varies based on the
flammable material present and in vertical arrangement or slope. Ground fires typically burn by first
smoldering in organic material on the ground and are fed by leaf and timber litter, grass, and low-lying
shrubs and plants. Ladder fires are fed by the fuels between the ground and the tree tops such as small
trees and downed logs. Crown fires, those in the tree tops, are dependent upon the density of trees. If
trees are close together, the fire can spread more easily. It is important to know the geographic
characteristics of an area in order to predict fire risk and behavior. Avista has identified the areas of our
system with the most tree cover near our powerlines using the USDA Forest Service Wildfire Hazard
Potential map.$ We also use our LiDAR and satellite inspection data to help us identify vegetation type
and location.
Slope and Exposure
Slope and exposure indicate areas where fires will grow faster under certain conditions and provide less
time and access to attack the fire from first responders. For example, fuels uphill from a fire are more
readily dried and warmed by the fire than those downhill, yet burning logs can roll downhill from the fire
to ignite other fuels. Thus, slope is an important factor. Exposure provides both rainfall and sunlight,
allowing surface plants to proliferate, providing fuel for fire spread. Exposure is also a factor in how quickly
vegetation dries out if it is located in a sunny versus a shaded area.
Winds
Winds are critical in risk assessment as this can indicate how quickly fires will travel and grow. Wind is
the major lateral driver for most wildfires that become extremely large in a single burn window. Winds are
also the most variable and hardest factors to predict in analyzing wildfire risk. Wind affects wildfire in a
variety of ways. It can dry out vegetation, it can carry burning embers that spread the fire, and it can
cause vegetation to fall or come in contact with power equipment. In fact, strong winds can be the primary
cause of a spark transforming into a wildfire. In Avista's service territory, the least impactful winds for tree
damage are from the Southwest, as this is our "normal" wind direction and the trees have self-
strengthened to be more durable to winds in this direction. Winds from the North tend to do the most
damage to our system, especially related to tree fall-ins. Thus, the predicted directionality of the wind is
a factor included in our calculations of fire risk.
Humidity
Humidity is another key driver in determining wildfire risk. Relative humidity affects wildfires by either
dampening or drying out potential fuel, thus hour-by-hour changes in fuel moisture are tracked as a
forecasted value. Low humidity levels dry out vegetation fuels on a short-term basis, and they can also
cause a short-term spike in fire danger. When there are cooler temperatures and/or high atmospheric
moisture levels, fire danger is reduced. At a microscopic scale, the increase or decrease in humidity is
8 Source: Wildfire Hazard Potential I Missoula Fire Sciences Laboratory (firelab.org) Data is available as raster GIS data or as
spreadsheets from the USDA Forest Service Fire Modeling Institute.
22
Avista 2021-2023 DNR Wildfire Resiliency Plan
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 5,Page 23 of 41

pushing and pulling moisture out of vegetation depending on humidity and temperature, which can
increase or decrease the intensity of a wildfire directly.
Drought
Drought leads to lack of moisture in the soil, which prevents plants from absorbing water, increasing the
amount of dead and dry vegetation, which then becomes fuel for wildfires. Dry vegetation causes fires to
spread more quickly and become more intense.
Burn Index/Energy Release Component
The Burn Index and Energy Release Component are values derived from the United States Forest
Service (USFS) Severe Fire Danger Index.' This index is a value that has been shown to best provide
an accurate location of 90% of the burned acres on all historic back casting done by the USFS. It does
not necessary correlate to ignition but rather those spaces that are primed for large growth fires and
where those fires could happen at a forecasted level.
Probability of Loss of Homes
The probability of loss of homes is a key driver in the risk assessment for utilities as it shows the areas
and communities near utility services that are at the highest risk levels for total loss during a wildfire. This
data is compilation of a multitude of datasets and consolidated down to the structures near the utility's
service territory. Avista acquires this information from the USDA Forest Service Wildfire Hazard Potential
Map (WHP)10 which indicates the burnability of an area, and from the USDA Housing Unit Impact (HUI)
dataset" which incorporates the general consequences of fire on people and the potential economic
impact of wildfire on communities and infrastructure. Conservative wildfire spread is then assessed and
summed to attempt to account for a potential loss of homes if a wildfire were to occur in a particular place.
We note that climatology may change utility risk over time. Things like prolonged droughts and low rainfall
will increase risk. Further, this will potentially turn lower risk areas today into higher risk areas of
tomorrow. Lastly, increases in urban development into the wildland urban interface will increase the
likelihood of community-altering wildfires in the future. Much of this is difficult to estimate or predict.
6.1 Enterprise-Wide Safety Risks
Describe the utility's methodology for identifying and assessing enterprise-wide safety risks related to wildfires. Risk areas may
include Operational, Procedural, System Sensitivities. Example risk drivers may include: Contact from Object (i.e., animal,
balloon, vegetation, vehicle); Equipment/Facility Failure (i.e., Capacitor Bank, Conductor, Crossarm, Fuse, Insulator,
Transformer, etc.); Wire to Wire Contact
9 Severe Fire Danger Index: A forecastable metric to inform firefighter and community wildfire risk management I US Forest
Service Research and Development(usda.gov)
10 Source: Wildfire Hazard Potential I Missoula Fire Sciences Laboratory(firelab.org) Data is available as raster GIS data or as
spreadsheets from the USDA Forest Service Fire Modeling Institute.
11 Wildfire Risk to Communities:Spacial 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
23
Avista 2021-2023 DNR Wildfire Resiliency Plan
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 5,Page 24 of 41

Avista tracks the metrics most closely related to wildfire risk in our service territory. One of these
operational risk areas is related specifically to vegetation contacts with our facilities. We track the number
of these events that cause these outages as well as the number of risk trees we mitigate on both the
transmission and distribution systems and the number of miles inspected (including ground, aerial, LiDAR
and satellite). This helps us determine if our vegetation management practices are having positive effect
in reducing fall-in and grow-in risk.
Other operational wildfire risk areas are related to our equipment and elements that could lead to spark
events; thus, we track overhead equipment failures (arresters, conductor, crossarms, cutouts and fuses,
insulators, reclosers and regulators, switches, and overhead transformers). We also track the number of
outages related to pole fires. In relation to these outages, we monitor the miles of distribution grid
hardening accomplished as we work toward hardening all of the elevated fire risk areas of our system.
These outages are shown in Appendix A.
Additional operational risk areas involve our work in automating our system to react to increases in fire
threat conditions. This includes installation of automation and control devices at both the midline and
substation level on the distribution system. We track the number of these devices we install each month
as we work toward automating all of these devices located in high fire threat areas.
Procedural risk is addressed through training of our personnel (and cross-training with fire personnel),
development and practicing Emergency Operations Procedures specific to wildfire situations, as well as
weekly assessment meetings during wildfire season that include both internal and external participants
to ensure readiness and to work together to determine operations.
7.0 Wildfire Preventative Strategies
Within these sections, provide any specific information regarding current prevention strategies, lessons learned from the
prevention activities, and considerations for the future state.
7.1 Weather Monitoring
7.1.1 Current Strategy Overview
Provide details on weather monitoring (if any) conducted by the utility. The following is a list of possible weather monitoring
sources:United States National Weather Service, United States Forest Service Wildland Fire Assessment System, National Fire
Danger Rating System.
Avista forecasts short-term fire risk via our Fire Weather Dashboard by combining elements of the
National Weather Service 7-day hourly weather forecasts with Avista's circuit health, performance metrics
and historical data based on our service territory. Our 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. During fire season
Avista continuously tracks localized weather patterns to identify consistently dry conditions that promote
lower fuel moisture, as well as extreme wind conditions, as an acute risk-based warning system for
wildfire potential. Because weather cannot be controlled, Avista desires to prioritize where there is
24
Avista 2021-2023 DNR Wildfire Resiliency Plan
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 5,Page 25 of 41

increased potential for wildfire given current conditions, fuel, terrain, and prior ignition events so we can
react accordingly.
7.1.2 Planned Updates
Describe changes (if any) to weather monitoring that are anticipated in the upcoming three years. If applicable, describe what
led to the change and the anticipated benefit or improvement once implemented. If it is a pilot program, describe the pilot period.
The Dashboard has been calibrated over time to best fit data to observed outcomes in real time and
through back casting. These calibrations simplify action points and ensure proper weighting of factors. It
may also be updated based upon revisions to Avista's WUI map, which is an input to the model. The WUI
map is updated each time the underlying data is updated. Inputs are provided by the U.S. Forest Service
Fire Modeling Institute's Wildfire Hazard Potential Map12 which defines the relative potential for wildfire,
and the USDA Housing Unit Impact dataset13 which indicates the consequences of wildfire on
communities and infrastructure. Updates of the WUI map into the Dashboard analytics allows us to have
an increased view of potential impact to communities in our service area as new data becomes available.
In addition, Avista is participating with the Washington Department of Natural Resources (DNR) and the
Idaho Department of Lands (IDL) in the installation and monitoring of ten wildfire cameras in key locations
across Washington and Northern Idaho in the fall of 2024.
7.2 Design and Construction Standards
7.2.1 Current Strategy Overview
Detail any instances where the utility is engaged in system re-design and hardening practices or other efforts for purposes of
wildfire mitigation. If any industry best practices are being utilized, note the standard or code, as applicable, and how the utility
achieves that standard in its processes.
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, these failures are more
manageable and should reduce the overall number of outages and 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 focused on reducing the number of (and potential for) spark ignition or heat events, thus we have
enhanced these existing programs by focusing hardening efforts in high fire threat areas based upon our
WUI map and historic fire patterns. 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. Wildfire system hardening focuses on
12 Source: Wildfire Hazard Potential I Missoula Fire Sciences Laboratory(firelab.org) Data is available as raster GIS data or as
spreadsheets from the USDA Forest Service Fire Modeling Institute.
13 This data is acquired from the USDA/US Forest Service Housing Unit Impact(HUI)dataset which contains a nationwide raster
of housing unit density measured in persons per square kilometer and incorporates the general consequences of fire on people
and the potential economic impact of wildfire on communities and infrastructure. fs.usda.gov/rds/archive/products/RDS-2020-
0060/ metadata RDS-2020-0060.html
25
Avista 2021-2023 DNR Wildfire Resiliency Plan
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 5,Page 26 of 41

the prevention of equipment spark events as well as promoting equipment resilience during fire (and
other reliability risk) exposure. Grid hardening programs are key to protecting both our customers and
our electric transmission and distribution systems from wildfire risk, with a focus on high fire threat areas.
Avista's Grid Hardening measures include distribution grid hardening measures such as replacing
outdated equipment, adding strength such as wedge/bail clamps, and installing wildlife guards, as well
as identifying and mitigating risk-trees (trees with the potential of imminent fall-in hazard to energized
facilities). On the transmission system, programs to protect infrastructure include replacing wood poles
with steel and wrapping wood poles with fire resistant mesh in high fire threat locations are utilized. These
elements were described earlier in this report.
7.2.2 Planned Updates
Describe any changes to design and construction standards that are anticipated in the upcoming three years. If applicable,
describe what led to the change and the anticipated benefit or improvement once implemented.
Avista is developing a new program 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, making conversion expensive and unfeasible unless it was for new applications such
as a new subdivision or business development. However, going forward, Avista has made a commitment
that new distribution facilities located in specific areas within high fire risk zones will be installed
underground to mitigate future risk. We are currently risk-ranking communities in our service territory
which are excessively vulnerable to total loss in the event of a wildfire. We believe that by focusing on
zones where the wildfire growth modeling suggests large scale loss to communities and high impacts to
homes, people, and communities, thus concentrating on very specific areas and the conductor segments
most at risk and carefully prioritizing this work, we may be able to provide a direct risk reduction. This
concept is currently being developed and will be evaluated in 2026 to determine cost and feasibility.
7.3 Fuel and Vegetation Management
7.3.1 Current Strategy Overview
Detail any instances where the utility has or is developing or implementing programs and practices to manage fuels and
vegetation for purposes of wildfire mitigation. If any industry standards are used as a baseline for Vegetation Management,
please cite and briefly describe the standard(s).
Effective vegetation management is an integral part of maintaining overhead electric distribution and
transmission lines. Avista's Vegetation Team uses a proactive approach to identify and address
potential vegetation-related issues before they result in outages. Avista's vegetation management
program, with implementation of the Wildfire Plan, was broken into two distinct programs: routine cycle
maintenance and risk tree mitigation (known as the Enhanced Vegetation Management Program.
Avista's routine cycle distribution vegetation management program consists of cycle trimming and risk
tree inspections. Note that Avista's definition of"risk tree"is a visibly dead, diseased, or dying tree, or
one which possesses obvious structural defects that could fall into conductor. This is in part regulated
26
Avista 2021-2023 DNR Wildfire Resiliency Plan
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 5,Page 27 of 41

by ANSI A300 (Part 9)-2017 Tree Risk Assessment - a. Tree Failure.14 Avista's 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. In alignment with its Wildfire
Resiliency Plan, Avista added the goal of inspecting the entire distribution system annually for risk trees
using a combination of satellite data and visual inspection. Transmission annual inspections are
conducted with a combination of ground and aerial inspections in accordance with NERC/FERC
regulations.15 The Wildfire Resiliency Plan added LiDAR inspections to the existing transmission
inspection methods, which is able to specifically identify and mitigate vegetation-related risk not always
visible using traditional inspection methods.
The Wildfire Resiliency Plan also added the new program of Fuel Reduction Partnerships with external
parties such as the Idaho Dept. of Lands and Washington Dept. of Natural Resources, partnering with
these state agencies as well as regional counties and area Tribes to reduce fuels/vegetation on their
properties near our facilities. And, in addition, the Wildfire Resiliency Plan added the Safe Tree
Program to remove and/or replace trees located on customer property in danger of contacting
powerlines.
7.3.2 Planned Updates
Describe changes to the utility's vegetation management practices(if any) that are anticipated in the upcoming three years. If
applicable, describe what led to the change and the anticipated benefit or improvement once implemented.
Avista's Enhanced Vegetation Management Program has been in place since 2020 and is in full
operation. We inspect 100% of our system each year for risk trees and will continue to do so into the
future. A recent goal, added in 2023, is mitigation and removal of risk trees within six months of
identification.
7.4 Asset Inspections and Response
7.4.1 Current Strategy Overview
Detail any instances where the utility is engaged in inspection practices or pilot projects (e.g., use of LiDAR, infrared, drones,
etc.) for purposes of wildfire mitigation. For any inspection program descriptions, include detail on remediation practices. If
industry standards are used as a basis for inspections,please cite and briefly describe the standard(s).
As part of Avista's Wildfire Resiliency Plan we perform risk tree inspections across 100% of the non-
urban, high fire risk areas of the distribution system every year with the stretch goal of remediating risk
trees within six months of identifying them. Inspection methodologies include boots-on-the-ground,
ground and aerial surveys, and LiDAR and satellite imaging. As mentioned above, Avista's definition of
a risk tree is and our inspection standards are defined by ANSI A300 (Part 9)-2017 Tree Risk Assessment
- a. Tree Failure.16 Assessments conform to level 1 standards.
14 ANSI A300 Standards, https://treecareindustryassociation.org/business-support/ansi-a300-standards/
15 FERC Reliability Standard FAC-003, https://www.nerc.com/pa/Stand/Reliability%20Standards/FAC-003-4.pdf requires
inspection of 100%of the interconnected transmission grid annually.
16 ANSI A300 Standards, https://treecareindustryassociation.org/business-support/ansi-a300-standards/
27
Avista 2021-2023 DNR Wildfire Resiliency Plan
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 5,Page 28 of 41

LiDAR and satellite data collection was added by Avista's Wildfire Resiliency Plan in order to complement
and supplement routine manual inspections. These new technologies provide a high level of detail
regarding the health and location of vegetation across the system with a goal of reducing tree contacts
with powerlines, one of the most common causes of outages and sparks.
In 2020 as the Wildfire Resiliency Plan was getting started, we began the addition of both satellite and
LiDAR data collection for our distribution and transmission systems. Digital inspections are quickly
becoming the industry standard practice, as it allows for a complete vegetation record, including the
efficacy of field work along with the information necessary to create future work plans. Digital data
collection techniques provide detailed data on vegetation, growth patterns, and risk to power
infrastructure, and can easily differentiate between grassland, agricultural or urban areas, and can detect
the species and health of vegetation, thus can identify vegetation that is likely to grow into or fall into
powerlines. Because these images are taken on a regular basis, they show us where vegetation risk
exceeds both reliability and fire mitigation thresholds and provide valuable information regarding the
location of problem (or potential problem)vegetation issues overtime. 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. Both
the satellite and LiDAR tools and associated analytics will essentially learn Avista's system and the
vegetation around our lines, allowing us to plan vegetation work in a more precise and predictable way,
streamlining our vegetation management programs and helping to maximize their value.
The transmission system is inspected annually via ground, aerial, and LiDAR. LiDAR works well for
transmission because most transmission lines have open linear rights-of-way like roads and railways,
allowing LiDAR data to be primarily collected via a fixed wing aircraft or helicopter. 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 identify dead, dying, diseased or structurally defective trees both inside and outside corridor rights-
of-way and is very accurate in calculating fall-in risk. 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 where vegetation might impact the lines are identifiable. LiDAR inspections not only
pinpoint potential vegetation issues, but also identify issues that could create risk such as corroded
attachment hardware, ground profile changes, excessive sag, unauthorized encroachments or
attachments and thermal issues. We note that transmission inspections are regulated by FERC Reliability
Standard FAC-003 which requires inspection of 100% of the interconnected transmission grid annually."
Failure to meet this requirement can result in substantial fines.
Avista uses satellite data collection on the distribution system, which allows for a system-wide approach
rather than conventional corridor collection (LiDAR). Satellite-based data is not as sophisticated as
LiDAR, requiring several passes over the system to collect the data needed, and satellite images are not
detailed enough to include conductor placement. However, satellite imaging aligns well with distribution
topologies, as it works very efficiently for the trunk-and-lateral, non-linear configuration of the distribution
system, which often lacks well-defined flyable corridors. Satellite acquisition allows collection over a
" FERC Reliability Standard FAC-003, https://www.nerc.com/pa/Stand/Reliability%20Standards/FAC-003-4.pdf
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Avista 2021-2023 DNR Wildfire Resiliency Plan
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 5,Page 29 of 41

broad area both in urban and rural areas using successive overpasses, pairing this information with
computer-based machine learning algorithms to assess the risk of both tree encroachment ("grow-in")
and hazard tree risks ("fall-in"). Satellite imagery 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 and provide 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 calculate vegetation that is likely to grow into or fall into
powerlines.
7.4.2 Planned Updates
Describe any changes to the utility's inspection program that are anticipated in the next three years. If applicable, describe what
led to the change and the anticipated benefit or improvement once implemented.
No major changes or updates anticipated. We believe that the combination of inspection methods Avista
utilizes is invaluable in directing planners and line clearing crews to the areas of greatest need with
accuracy. A small "change" may be in finding additional uses for the data analysis gained from LiDAR
and satellite imaging.
7.5 Workforce Training
7.5.1 Current Strategy Overview
Describe any wildfire mitigation related workforce training or work rules/practices.
The Company provides annual fire safety training as part of the field crew safety meetings. Our crews
also cross-train with first responders and fire professionals regarding working safely around the electric
system.
In 2023, as we finalized our Wildfire Emergency Operating Procedures (EOP), we set up an extensive
tabletop exercise to test our EOP design against a simulated fire situation. We invited emergency
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 tabletop exercise
wildfire scenario. The exercise included a realistic situation related to a wildfire event and allowed
participants to "experience," train, and react to this event together. This event highlighted the value of
having Avista embedded with Fire Incident Command. Working together in this way helps ensure that
direct communication and coordination between Avista and the fire agency responders will be effective
and efficient and that fire and utility crews can work safely in the field. This exercise provided an excellent
opportunity to train Avista employees in successfully managing an actual wildfire situation as well as in
effective engagement with external parties and will be conducted annually.
7.5.2 Planned Updates
Describe any changes to workforce training efforts that are anticipated in the next three years. If applicable, describe what led
to the change and the anticipated benefit or improvement once implemented.
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Avista 2021-2023 DNR Wildfire Resiliency Plan
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 5,Page 30 of 41

We will continue to work with our external partners and participate in Incident Command Responses as
needed, learning from both joint exercises and actual situations, and folding what we learn into our wildfire
planning and into future training. We will continue to train and practice with our crews and fire
professionals to ensure a strong and effective response to wildfire situations. This includes annual
exercises related to Wildfire EOPs and Public Safety Power Shutoff events. These joint exercises and
real life experiences will help us continue to refine our skills and capabilities related to actual fire events,
and further strengthen our relationships with our external partners.
7.6 Relay and Recloser Policy
7.6.1 Current Strategy Overview
Describe the utility's associated protective devices and relay practices, including the use of pulse reclosers and other
programmable controlled reclosers. Additionally, describe if the utility changes relay settings to more quickly or easily de-
energize a circuit during certain conditions.
Electric utilities use automatic reclosing to improve system reliability by preventing momentary faults on
overhead conductors that may result in extended outages and impacts to customers. However,for circuits
that pass through high fire risk areas, automatic reclosing is not always desirable during certain conditions
due to the increased risk of ignition. Since the early 2000s, during fire season Avista has transitioned into
the mode of limiting the number of circuit recloses on selected feeders during fire season on circuits
deemed at risk. This operational methodology is an important defensive strategy against wildfire ignition.
This operating mode, which we call Fire Safety Mode (FSM), involves both identifying electric circuits that
operate in elevated fire threat areas and the reconfiguration of their associated protection systems to
allow protection devices to be remotely and automatically adjusted for wildfire threat based on the
operating location and threat level. Fire Safety Mode reduces the potential for spark events and the risk
of fire.
Avista's Fire Weather Dashboard allows system operators to better understand timing and extent of the
risk, providing the opportunity for the Company prepare and to act in order to mitigate potential spark-
ignition events. When combined with the dynamic operating capability provided by automation equipment
such as distribution and substation reclosers, the Dashboard guides the decision to enable various levels
of operations (including Fire Safety Mode and Public Safety Power Shutoffs) to mitigate risk. Based on
the Fire Risk Potential Score from the Dashboard, we can move from Non-FSM (non-fire season where
multiple reclose attempts are permitted) to Base FSM (where protection settings are set to limit non-
reclosing but fuses will operate), to Extreme FSM (where a single instantaneous overcurrent condition
will trip and fuses will not operate), to PSPS level where the line will be de-energized.
However, by disabling reclosing, utilities are prioritizing wildfire risk over reliability risk, so this decision is
carefully considered. The Company attempts to carefully balance the safety of the public with the need
to maintain reliability and customer service.
7.6.2 Planned Updates
Describe any changes to relay or recloser operations that are anticipated in the next three years. If applicable, describe what
led to the change and the anticipated benefit or improvement once implemented.
30
Avista 2021-2023 DNR Wildfire Resiliency Plan
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 5,Page 31 of 41

Avista's Public Safety Power Shutoff Plan was ready for the 2024 fire season. We will continue to refine
the trigger points for system protection based on the Dashboard Fire Risk Potential score as we gain
experience with the use of both FSM and PSPS.
7.7 De-Energization /Public Safety Power Shutoff
7.7.1 Current Strategy Overview
Provide information about plans(if any) to proactively de-energize as it pertains to wildfire mitigation, this can include, but is not
limited to Public Safety Power Shutoff guidelines. Summarize the conditions (if any) under which the utility may de-energize to
prevent ignitions. Describe the protocols the utility would utilize when determining the appropriateness of proactive de-
energization. If a utility does not plan on enacting proactive de-energization,please list other mitigation strategies to limit asset
related ignitions under critical fire weather conditions.Additionally, utilities describe notification protocols and procedures ahead
of, during, and following a proactive de-energization.Detail on restoration of service following a de-energization can be provided
in Section 9.
Avista has developed a scale of actions to be taken prior to implementing de-energization by using
enhanced protection settings through our Fire Safety Mode strategy, thus the threshold for implementing
PSPS would be relatively high. The decision to do this is highly impactful to customers, including real
financial consequences as well as the potential for loss of water, food spoilage, dangers associated with
loss of traffic signals and communications, and other impacts that often hit the most vulnerable customers
hardest. Determining when to implement a PSPS event will include factors such as the fire risk index, the
impact on critical customers, operational criticality, effects on medically vulnerable customers, customer
proximity to aid/support, the potential duration of the event, the utility resources available, the potential
for fire spread, and actual weather conditions.
Generally, de-energization is more commonly used on the distribution systems than on transmission
systems. Transmission level PSPS events are very complex due to regulatory requirements and overall
bulk electric system impacts. This is due in great part to mandatory NERC and FERC requirements
around maintaining system reliability for Avista and the Western Interconnection. Remaining in
compliance with these requirements is designed to keep the Western Interconnection stable and is
regulated under federal mandates. Therefore, Avista's PSPS program will focus primarily on distribution,
and potentially include the transmission lines only after a thorough analysis of Avista's transmission
system and of the impacts a PSPS event would have on Avista's reliability and compliance obligations.18
The Company is taking a very measured, thoughtful, and cautious approach to proactive de-energization
for PSPS, because in this case, unlike de-energizing for planned work for example, facilities cannot be
re-energized until conditions are safe and all lines are thoroughly inspected, which can take a significant
amount of time. The process of de-energizing the system is less challenging than re-energizing it. De-
energizing lines for a PSPS event, given the scope of the restoration efforts and the anticipated duration
of the outages, presents a substantial cost to the utility—and to customers, in great part because a PSPS
'$Since PSPS would not initially involve Avista's transmission system, interconnected transmission providers(BPA, PAC, Idaho
Power, etc.) should be minimally affected. Avista should also be able to continue to serve BPA's transfer customers.
Interconnected transmission operations are regulated under NERC Standard TOP-001-4. TOP-001-4.pdf(nerc.com)
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Avista 2021-2023 DNR Wildfire Resiliency Plan
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 5,Page 32 of 41

would only be considered during an extreme weather event in which many circuits beyond those that
have been proactively de-energized and potentially be impacted as well.
Once lines are de-energized for a PSPS event, facilities cannot be re-energized until conditions are safe
and all circuits and lines are thoroughly inspected or patrolled to ensure that it is safe to re-energize. After
inspection, lines are re-energized segment by segment. Patrol of all impacted overhead electric facilities,
both transmission and distribution, can only commence once the weather event has subsided. While the
overall duration of PSPS events is uncertain, many utilities report durations between 3-6 days. 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 the full length of each circuit and line that was
de-energized. 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.
Notification protocols and procedures are critical in implementation of Fire Safety Mode and a PSPS.
Prior to fire season the Company communicates with customers about Avista's Wildfire Resiliency Plan,
what FSM and PSPS are, and how these operations may impact them. Our education and outreach
efforts are designed to help customers prepare for wildfire season and the associated actions we may
take in order to protect them, including resources available to impacted customers, identification of and
communicating with critical infrastructure customers, working with regulators and local community
leaders, and engaging with first responders and emergency management personnel. An important factor
in this engagement is ensuring that community leaders understand the potential for more frequent and
longer power outages during Fire Safety Mode activation so they can help answer questions and support
their citizens. The company works with customers, first responders, emergency managers, and
community leaders across the service territory, specifically those in elevated fire threat areas,
including public safety and tribal partners, prior to wildfire season.
In the case of a PSPS event, Avista has a multi-step communications plan. From 2 to 7 days out
from a potential event, we begin a PSPS Watch in which we monitor the weather forecasts, begin
internal discussions and preparations (pre-EOP) and begin notifying key public safety and tribal
partners as well as critical customers likely to be impacted. From 48 hours to within 1 hour of the
estimated event, we begin the PSPS Warning process in which we reach out to additional external
public safety partners and begin notifying customers directly if they are within the expected PSPS
area. When a PSPS is executed, public safety partners, critical infrastructure customers, and all
impacted customers are notified, if possible, up to 24 hours in advance. During this time, we utilize
an Outage Map tool located on our website which will provide PSPS specific information regarding
the location of the event, and any other pertinent event information. The map will be updated
throughout the event to keep customers informed. Avista also has a specialized customer service
team in place to engage with medically vulnerable customers to ensure that they have a plan in place
or to assist if they need help and support. These same parties are also notified when service has
been restored. It should be noted that weather is dynamic and Avista may modify the PSPS plan
and process to accommodate changing levels of risk. Any changes will be communicated to
customers as early as possible.
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Avista 2021-2023 DNR Wildfire Resiliency Plan
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 5,Page 33 of 41

7.7.2 Planned Updates
As the Company experiences its first season with a PSPS Plan, it is anticipated that goals, set points,
and expectations will be refined. Communications may also be refined and improved over time based
on customer and external partner feedback and suggestions.
8.0 Community Outreach and Public Awareness
8.1 Current Community Outreach and Public Awareness Program
Provide a description of customer communication efforts or programs related to wildfire mitigation performed over the past three
years. If any evaluations or assessments of customer communications were performed, briefly describe the findings as
appropriate. This may include efforts to increase awareness that a WMP exists, notification of activities under the WMP, etc. If
the Utility utilizes proactive de-energization (or PSPS) protocols, this section may be used to describe any efforts made to
educate or interact with the public regarding customer awareness of the utility's protocols.
Examples may include, but are not limited to, interaction with the Fire Adapted Communities Learning Network, initiatives to
reach customers with limited English proficiency, or interagency meetings to promote best management practices. Examples of
evaluations may include number of impressions, customers reached, or resources provided/requested.
Avista is committed to partnering with emergency first responders, community leaders, and customers in
our Wildfire communications. The original 2020 Wildfire Resiliency Plan noted customer outreach as a
goal and described some of the initial meetings with fire departments, elected leaders, regulators, and
peer utilities that were foundational in development of our initial Plan. Avista's communication outreach
extends well beyond wildfire issues and has adopted an `all-means and all-channels' approach to
communicating with customers and other interested persons.
Starting in 2022, Avista established a cross-functional team including regional business managers,
corporate communication specialists, tribal relations employees, customer engagement, electric
operations, and the Wildfire Resiliency team to improve and expand Avista's customer outreach related
to wildfire. Each year the Company sponsors a series of meetings with first responder groups and county-
level emergency management offices along with police, fire, and emergency dispatch centers, ambulance
services, volunteer support, and elected officials throughout Washington and Idaho in order to provide
information about Avista's Wildfire Resiliency Plan and fire season operating strategies. Avista also
meets with members of the Colville Confederated, Spokane, and Nez Perce Tribes. Meetings have been
convened with the Washington Department of Natural Resources, the U.S. Forest Service, the Bureau
of Land Management, Idaho Department of Lands, and the Spokane City Council. An additional
communications framework was developed to assist employees who routinely meet with local emergency
first responders.
Each year prior to fire season, Avista conducts a series of residential customer telephone townhall
meetings. In these meetings, Avista employees provide an overview of the Wildfire Resiliency Plan as
well as information about changes to the protection system during fire season and how that might impact
them. At each meeting a fire agency or emergency management expert is available to answer questions
about fire safety, home preparedness, evacuations, and other emergency response issues. The focus of
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Avista 2021-2023 DNR Wildfire Resiliency Plan
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 5, Page 34 of 41

these meetings is to connect with customers who live in high fire threat areas. The convenience of
attending by telephone allows customers to connect with utility employees and fire professionals more
easily. Questions ranged from "who do I contact about a tree near a powerline" to "how should I prepare
for a fire" to "how are evacuations handled in my area." We are expanding these communications to
provide messages in multiple languages.
In 2022, our first year of town hall meetings, we reached out to nearly 36,000 customers in 8 counties
(Washington and Idaho) including 225 county emergency managers,fire officials, tribal leaders from three
tribes, and elected officials. In 2023 we expanded this outreach to over 90,000 customers in 16 counties
across our service territory, including over 640 community leaders and emergency response
organizations.
Conducting telephone townhall meetings require significant planning, coordination, and internal support,
but the benefits both to customers and the Company are tremendous. It is important that we partner
closely with emergency professionals, community leaders, as well as customers to understand fire risk
and to work together before, during, and after a wildfire event. Providing clear and concise communication
together with receiving feedback are important components of implementing a successful wildfire
mitigation plan.
Related specifically to PSPS, we rolled out PSPS as an added part of our wildfire strategies in 2024. In
May of 2024 we held a press briefing with local fire agencies and others to talk about the 2024 season
and overall preparedness, with an emphasis on PSPS and elevated protection settings. In addition to
earned media, we use all our Avista channels, such as email, customer newsletters, bill inserts, and
social media to spread awareness of our wildfire work and PSPS.
For our most vulnerable customers, Avista has a Customer Service CARES team which is specifically
trained to engage with medically vulnerable customers and acts as a liaison between the customer and
community partner support networks. A PSPS event may especially impact medically vulnerable
customers, necessitating additional outreach to ensure these customers have a plan to be prepared for
the de-energization. The CARES Team will provide additional notifications to customers who are
considered "Life Support" to help ensure that they have what they need during these events. 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.
In addition, we launched an employee team of volunteer Community Response Ambassadors who
trained with the Red Cross to provide help and support. We have also made a significant effort to identify
critical commercial/industrial customers for notification during elevated Fire Safety Mode protection
settings. 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. Specialized community outreach efforts with the tribes included a number
of discussion topics including 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 support them in the case of an extended power outage.
34
Avista 2021-2023 DNR Wildfire Resiliency Plan
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 5,Page 35 of 41

8.2 Planned Updates
Describe any changes to customer communication and public awareness strategies or programs that are anticipated in the next
three years. If applicable, describe what led to the change and the anticipated benefit or improvement once implemented.
We added PSPS as part of our wildfire work for the 2024 fire season. Continuing changes include
expanding our language options beyond English-only. For example, in 2023 we offered materials and
translation options for our Town Hall Meetings in Spanish. We are also working with our Equity Advisory
Group to fully develop and identify Highly Impacted Communities and Vulnerable Populations ("Named
Communities") unique to our service territory to help identify barriers to participation and education and
specialized accessibility needs.
9.0 Restoration of Service
Within this section,provide the detailed process for restoring service after an outage as outlined by the utility during high wildfire
risk conditions or following a de-energization or wildfire event. When applicable, reference specific sections within the utility's
restoration plan (if available) that detail the utility's protocols before during and after restoration. (Here they note that the State
Energy Office—Energy Emergency Management is available to support development and assessment of restoration activities
or assist with any questions or concerns.)
Power restoration following a PSPS is akin to that of 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. However, if a utility de-energizes lines for a PSPS event, facilities cannot be re-energized
until conditions are safe and all lines are thoroughly inspected and re-energized segment by segment as
it is deemed safe to do so. Patrolling all impacted overhead electric facilities, both transmission and
distribution, will only commence once the weather event has subsided and when fire response leadership
(if involved) gives the all-clear. Restoration following a typical PSPS event are variable, but may require
up to three to six days perhaps longer, as restoration efforts following a PSPS require the time it takes to
fully inspect each de-energized circuit, even if the circuits weren't damaged during the weather event, to
ensure that it is safe to re-energize the line. Factors impacting the length of these outages include crew
availability, terrain and accessibility of the impacted lines, length of the feeder, etc.
Typically, a restoration process will begin with the "all clear" being issued by decision-makers including
fire professionals if applicable. Field crews will then be mobilized and broad communications to impacted
customers will begin, including providing help with resources as appropriate. Restoration typically starts
with critical infrastructure and commercial zones. To complete repairs, main trunk lines are the focus
followed by branch lateral circuits, then individual customers. Communications are updated to provide
estimated restoration times. Once the event is over and all power has been restored, the Company
conducts an after-action review with emergency first responders to identify areas for improvement.
For Avista, like many utilities, it seems likely that PSPS would be limited to the highest fire risk zones
while areas of lower risk may be subject to elevated protection levels. Avista operates 350 electric
distribution lines over 7,650 miles. It is conceivable that following a major fire-weather event, 50 to 100
or even more of these circuits could be de-energized either through pre-emptive action (PSPS), circuit
breaker operation settings (Fire Safety Mode), or due to weather impacts such as a tree falling across a
line. Circuits that have not been moved to elevated settings or de-energized may also be impacted by
35
Avista 2021-2023 DNR Wildfire Resiliency Plan
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 5,Page 36 of 41

the storm and require repair. Most, if not all, of Avista in-house resources would be focused on the
patrol/inspection effort system wide.
Outage scenarios that would lead to consideration of a PSPS could also be of a large enough magnitude
for Avista to initiate a mutual aid request from other utilities as well as the need for outside contractors,
which could have an impact on restoration time depending upon where these crews are based, in addition
to the significant cost involved. Avista's field operations will coordinate with the PSPS Assessment Team
to develop estimated restoration times and a plan specific to the situation. Outage times will be impacted
by conditions and dependent upon when it is safe to re-energize.
As Avista further develops and refines its restoration efforts specific to an actual PSPS, the Company will
need to prioritize balancing and allocating additional resources to circuits that may have been impacted
by storm damage in Named Communities, in areas with critical customers, and in areas with large
numbers of customers. This will help ensure that restoration efforts are equitable for the most vulnerable
and highly impacted customers that may not have equal means or access to resources during prolonged
outages. This additional effort will take more time and resources during the restoration process but
ensures that equity is being applied to the PSPS restoration process.
10.0 Evaluating the Plan
Within these sections,provide information on how the utility tracks and evaluates the performance of its wildfire mitigation plan
and the associated mitigation efforts. If this is an initial WMP submission, some sections may not apply or have any historical
context. In such cases, the section can be used to describe future states if such information is known. If leaving blank, please
indicate that the information is not yet available.
10.1 Metrics and Assumptions for Measuring Plan Performance
Provide metrics that are relevant to the utility's wildfire mitigation efforts described in the WMP and that measure or benchmark
the utility's performance on such mitigation efforts. If desired, full metrics or tracking can be attached in the Appendix.
Our Wildfire programs are tracking a variety of data, statistics, and achievements. For example, a
decreasing number of tree-related outages should indicate the benefits of our Enhanced Vegetation
Management program, and our distribution grid hardening efforts should reduce the number of overhead
equipment outages over time. We are also tracking the number of pole fires, as these should be positively
impacted by grid hardening investments, specifically replacing wood crossarms with fiberglass
crossarms. However, 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 the system, change out aged equipment,
and mitigate vegetation issues system wide, for example. None of these programs will be completed
within a year but will be ongoing and offering continual improvement.
Metrics track the progress of our primary programs and support the Wildfire goal of continual
improvement based on data and experience. Our four primary programs: Grid Hardening, Enhanced
36
Avista 2021-2023 DNR Wildfire Resiliency Plan
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 5,Page 37 of 41

Vegetation Management, Emergency Operations & Response, and Situational Awareness, are grouped
into three broad metrics categories: Performance, Infrastructure, and Vegetation Management.
In the Performance category we collect metrics about pole fires, tree fall-ins and grow-ins, overhead
equipment failures, etc.
In the Infrastructure category we collect metrics about Grid Hardening efforts including the number of
miles of distribution grid hardening achieved, the number of transmission steel pole conversions
completed, and the number of transmission fire-resistant mesh wraps installed. This category also
includes the progress being made to add the automation and communication equipment necessary to
enable Fire Safety Mode operation, including equipment at both the distribution midline and substation
levels.
The Vegetation category is focused on hazard tree identification and remediation. We track several
metrics related to this program including number of hazard trees identified and mitigated, number of miles
inspected, and number of satellite (Distribution) or LiDAR (Transmission) miles completed. All of these
metrics help us track the improvements brought about by our programs (such as a reduction in the
number of tree-related outages) and highlight areas where more focus is needed (such as areas of the
system or equipment experiencing more outages than typical.)Tracking metrics also ensures that we are
meeting performance goals such as 100% inspection of the system each year for risk trees. Some of our
key metrics can be found in Appendix A.
10.2 Identifying and Addressing Areas of Continued Improvement in the Plan
When applicable, describe adjustments, improvements, or additions to the plan derived from established metrics including,
lessons learned, or any other processes contributing to continuous improvement efforts.
Avista's Wildfire effort focuses on the "Plan-Do-Check-Adjust" methodology, thus we are constantly
monitoring the impacts of our programs and the work happening in the industry, as well as seeking the
guidance of our partners and peers. We are continuously searching for areas of improvement and
refinement, which is evidenced by the fact that our Fire Weather Dashboard risk model has been
upgraded to new levels of sophistication, we have developed strong and invaluable partnerships with first
responders and fire professionals, and we are establishing data-driven means of determining the most
cost-effective grid hardening and vegetation management strategies. We consider our Wildfire Resiliency
Plan a dynamic program that will be improved over time with experience and associated increases in
expertise.
Some lessons learned as we have implemented the Plan include things that are within our control, such
as the cultural changes required to implement elevated protection settings and PSPS. Others, such as
tree mortality and the significantly escalated amount of vegetation work required, are outside of our
control and require additional (and sometimes unexpected) amounts of money and manpower.
10.3 Monitoring the Effectiveness of Inspections
Describe processes for monitoring the performance of inspections,including inspections performed by contractors. This section may
include any assurance or control protocols for reviewing inspection quality.
37
Avista 2021-2023 DNR Wildfire Resiliency Plan
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 5,Page 38 of 41

Vegetation work is inspected after completion using several techniques depending on work type. All
hazard trees are photographed by the work prescriber on Fieldnote. Fieldnote associates the photo with
the plan and GPS point of the tree to be mitigated. When work is complete, the contractor takes a photo
of the work when it is completed, resulting in a geo-referenced before and after photo series. In addition
to before and after photo logs, field audits are completed. The target sample size of the audits is
determined based on the American National Standards Institute (ANSI)/American Society for Quality
(ASQ)Z1.4-2008 Sampling Procedures and Tables for Inspection by Attributes.19 Using this method, the
sample size is selected based on the population size. In this case it is the number of polygons in the
annual workplan for each program. A two-stage sampling
procedure is used, with the first stage sampling stage 1 stage z
determining the polygons to be audited and the Random probability
second stage sample determining which jobs are sample of polygons Random probability
audited within each polygon. An audit plan is from the annual work sample selected
polygons
within
the selected p
generated for the Wildfire Risk Tree Program and plan
another for the Routine Vegetation Maintenance
Program.
Multistage random sampling involves random sampling of a population based on natural clusters within
that population and then sampling an attribute within the selected clusters. In this case, the natural cluster
would be the vegetation work polygon, and the attribute sampled within the selected polygons would be
the specific jobs. Two stage random sampling requires that cluster elements are heterogeneous, each
cluster is a small portion of the entire population, and each cluster is mutually exclusive. Avista's
distribution vegetation sampling plan meets these requirements. In addition to the audit process, Avista
staff periodically conduct field visits to check on work progress and work practices.
As mentioned previously, vegetation inspections of the transmission system are regulated at the federal
level. NERC's Electric Reliability Standard for Vegetation Management20 is designed to prevent
vegetation-related outages which could lead to cascading, that is, outages that impact large areas of the
interconnected grid. This Standard directly addresses inspection requirements. The Standard mandates
documented maintenance specifications, strategies, procedures, and processes to prevent flash-over,
including considering engineered sag and sway of the conductor, as well as the interdependence of
vegetation growth rates, treatment methods and the frequency of inspection. It directs transmission and
generation owners to have an imminent threat procedure whereby the applicable control center is notified
of vegetation conditions that could cause an outage at any moment. Further, each owner must complete
annual work plans to prevent violation of the standard. Each utility's vegetation management plan must
conform to requirements. Utilities can be fined as much as much as one million dollars per violation per
day for FAC-003 violations.21
19 ANSI/ASQ Z1.4&Z1.9 Sampling Plan Standards for Quality Control I ASQ
20 NERC Transmission Vegetation Management Standard FAC-003-2, FAC-003-2 TR December 17 2010.pdf(nerc.com)
21 Randall H.Miller,"FAC-003-4 Revisited,"CNUC,April 29,2020, FAC-003-4 Revisited-CN Utility Consulting(wearecnuc.com)
38
Avista 2021-2023 DNR Wildfire Resiliency Plan
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 5,Page 39 of 41

Appendix A
A.1 Metrics Tables
External Risk
Metric Type External Risk Event 2021 20221
Red Flags Warning Days'for Weather
Avista does not maintain historic
Red Flag Warnings Zone that includes Utility Service #of Days
weather data
Territory
High Wind Warning Days'in Weather
Avista does not maintain historic
High Wind Conditions Zone that Includes Utility Service #of Days
weather data
Territory
Circuit Miles(in High Risk Areas as 3,240 2,746 2,746 #Miles Based on Avista's WUI Map
Defined by the Utility)
As Percentage of Total Distribution
42% 36% 36% % Based on Avista's WUI Map
Increase of Customers/Infrastructure Circuit Miles
in High Risk Areas Customer Accounts in[High Risk Area
126,200 126,200 126,200 #Cust.Accounts Based on Avista's WUI Map
as Defined by Utility]
As Percentage of Total Customer
31% 31% 31% % Based on Avista's WUI Map
Accounts
Votes: 'Red Flag Warnings and High Wind Warnings are declared by the National Weather-Service.
Performance Metrics
Metric Type External Risk Even[W 2021 2022 2023 Units Comments
Circuit Miles Inspected 5,245 6,466 6,546 #of Circuit Miles Vegetation Management-
1.Distribution Inspections Wildfire Only:Risk7ree
Count of Inspection Findings #of Circuit Miles The Wildfire Program does not
trackthis.
Patrol Inspections Performed 2,270 2,270 2,270 #of Circuit Miles Vegetation Management-
2.Transmission Inspections Wildfire Only;Risk Tree
Count of Inspection Findings #of Circuit Miles The Wildfire Program does not
track this.
Vegetation Management-
3a.Vegetation Inspections Circuit Miles Inspected 5,245 6,466 6,546 #of Miles Wildfire Only:Risk Tree
Distribution #Risk Trees Vegetation Management-
CountoflnspeRion Findings 12,7% 15,678 19,511
Removed Wildfire Only:Risk Tree
Circuit Miles Inspected 2,270 2,270 2,270 #of Mlles Vegetation Management-
3b.Vegetation Inspections Wildfire Only:Risk Tree
Transmission #Risk Trees Vegetation Management-
Countof Inspection Findings 1,910 3,281 3,062
Removed lWildfire Only:Risk Tree
Outage
Metric Type category 202=jr2022r
Animal 585 538 590
Planned 3106 2846 2861
Equipment 820 967 838
Pole Fire 140 51 56
Outage Event Distribution Public 520 579 602
Vegetation Caused 560 471 355
Weather 3582 1715 445
Unknown 481 425 401
Animal O O 0
Planned 5 16 16
Equipment 13 29 28
Outage Event Transmission Pole Fire 14 0 11
Public 15 2 3
Vegetation Caused il 10 6
Weather 1121 50 15
Unknown 211 311 3
39
Avista 2021-2023 DNR Wildfire Resiliency Plan
Exhibit No. 11
Case No.AVU-E-25-01
V.Malensky,Avista
Schedule 5,Page 40 of 41

Appendix B
B.1 Commerce Reported DNR Reported Utility Involved Wildfires
,
OBJECT General_ Discovered Longitud Avista Info
IDD Incident Name LJ Fire Number LJ Causes AcrJ _Date) LatituLvj e J Utility_Narr{JShared FiJ x LJ V LJ Available
5 ALADDIN FORK 2023-WANES-001335 Powergen 0.1 06/10/2023 48.6196 -117.776 AVISTA CORP Not Shared -117.776 48.6196 No Information
6 COLUMBIA DAISY 2023-WANES-001342 Powergen 0.1 06/11/2023 48.36533 -118.163 AVISTA CORP Not Shared -118.163 48.36533 No Information
10 ALADDIN POLE 2023-WANES-001322 Powergen 0.4 06/08/2023 48.61038 -117.802 AVISTA CORP Not Shared -117.802 48.61038 No Information
17 MARTIN ROAD 2023-WANES-001555 Powergen 0.1 07/06/2023 48.27855 -118.13 AVISTA CORP Not Shared -118.13 48.27855 No Information
r 20 SKIDMORE ROAD 2023-WANES-001717 Powergen 0.1 07/24/20233 48.45862 -117.897 AVISTA CORP Not Shared -117.897 48.45862 No Information
22GOLD 2023-WANE5-001789 Powergen 0.3 08/02/2023 48.5399 -117.971 AVISTA CORP Not Shared -117.971 48.5399 No Information
25 SILVER QUEEN 2023-WANES-001822 Powergen 0.1 08/05/2023 48.56475 -118.113 AVISTA CORP Not Shared -118.113 48.56475 No Information
38 HOUSE CANYON 2023-WANES-002032 Powergen 0.2 08/25/2023 47.9318 -117.685AVISTACORP Not Shared -117.685 47.9318 No Information
42ONION 2023-WANES-002148 Powergen 0.1 09/13/2023 48.72088 -117.877AVISTACORP Not Shared -117.877 48.72088 No Information
45SPRINGDALE 2024-WANES-001059 Powergen 0.1 03/20/2024 48.04417 -117.777 AVISTA CORP Not Shared -117.777 48.04417 No Information
47 LONG PRAIRIE 2024-WANES-001093 Powergen 0.1 04/04/2024 48.1498 -117.763 AVISTA CORP Not Shared -117.763 48.1498 No Information
51 MUDGETT 2024-WANES-001203 Powergen 9.6 05/16/2024 48.0238 -118.216 AVISTA CORP Not Shared -11811�6 48.0238 Some Information,
55 PARK RAPIDS 2024-WANES-001362 Powergen 0.106/23/2024 48.51275 -117.683 AVISTA CORP Not Shared -117.683 48.51275 No Information
60WALLBRIDGE 2024-WANES-001559 Powergen 0.1 07/21/2024 47.96086 -117.552 AVISTA CORP Not Shared -117.552 47.96086 No Information
62 STENSGAR CREEK 2024-WANES-001638 Powergen 0.1 07/27/204f 48.2953 -117.938 AVISTA CORP Not Shared -117.938 48.2953 No Information
64 HUNTERS CAMPGROUND 2024-WANES-001671 Powergen 3.5 08/01/2024 48.11668 -118.223 AVISTA CORP Not Shared -118.223 48.11668 Some Information
67 EVANS LINE 2024-WANES-001777 Powergen 0.5 08/13/2024 48.72453 -118.036 AVISTA CORP Not Shared -118.036 48.72453 Some Information
68 DEEP LAKE 2024-WANES-001494 Powergen 2.2 07/12/2024 48.8699 -117.6 AVISTA CORP Not Shared -117.6 48.8699 Some Information
70 CEDAR CREEK 2024-WANES-001885 Powergen 0.1 08/23/2024 48.98337 -117.567 AVISTA CORP Not Shared 117.567 48.98337 No Information
71CASHMERE 2024-WANES-001871 Powergen 0.608/23/2024 48.3312 -117.874 AVISTA CORP Not Shared 117.874 48.3312 No Information
72ADDY 2024-WANES-001870 Powergen 0.3 08/23/2024 48.3375 -117.871 AVISTA CORP Not Shared -117.871 48.3375 No Information
73 ROCKY LANE 2024-WANES-001872 Powergen 0.1 08/23/2024 48.49813 -117.899AVISTACORP Not Shared -117.899 48.49813 No Information
74MELLENBERGER 2024-WANES-001874 Powergen 0.408/23/2024 48.6005+88 -118.142AVISTACORP Not Shared -118.142 48.60058 No Information
75MCNITT 2024-WANES-001876 Powergen 0.3 08/23/2024 48.80247I -118.112 AVISTA CORP Not Shared -118.112 48.80247 No Information
76DOYLE 2024-WANES-001878 Powergen 0.2 08/23/2024 48.74817 -118.135 AVISTA CORP Not Shared -118.135 48.74817 No Information
83 BOULDER 2024-WANES-002069 Powergen 0.27 09/25/2024 48.95685 -118.212 AVISTA CORP Not Shared -118.212 48.95685 No Information
84WEBLEY 2024-WANES-002060 Powergen 0.3 09/25/2024 48.56625 -117.979AVISTACORP Not Shared -117.979 48.56625 Some information
87PACKMULE 2023-WANES-001253 Powergen 0.2 05/27/2023 47.88848 -117.459AVISTACORP Shared -117.459 47.88848 No Information
88KEENE 2023-WANES-001375 Powergen 0.1 06/15/2023 47.58278 -117.659 AVISTA CORP Shared -117.659 47.58278 No Information
89 KATIELANE �2023-WANES-001770 Powergen 12.4 0713012023 4757868 -117.333 AVISTA Shared -117.333 47.57868 Inland
90 PEASE HILL 2023-WANES-001964 Powergen 0.1 08/17/2023 47.85587 -117.458 AVISTA CORP Shared -117.458 47.85587 No Information
H59391 GRAY 2023-WANES-001974 Powergen#### 0811812023 4753803 117.744 A VISTA CORP Shared -117.744 4753803 Inland
92MONROE 2023-WANES-002004 Powergen 0.108/21/2023 47.82957 -117.443 AVISTA CORP Shared -117.443 47.82957 No Information
NORTHEUCLID 2024-WANES-001202 Powergen 1 0511612024 47.68643 -117.559 AVISTA CORP Shared -117559 4768643 Inland
94 HAWK CREEK 2024-WANES_-001255 Powergen 1.5 0610312024 47.71127 -118.272 AVISTA CORP Shared -118.272 47.71127 Inland
95HAWK 2024-WANES-001259 Powergen 0.106/04/2024 47.71872 -118.277AVISTACORP Shared -118.277 47.71872 No Information
96HELENA 2024-WANES-001627 Powergen 0.1 07/26/2024 47.60014 -117.388AVISTACORP IShared -117.388 47.60014 No Information
97 STERLING 2024-WANES-001756 Powergen 0.2 08/10/2024 47.36118 -117.623 AVISTA CORP Shared -117.623 47.36118 No Information
98WAVERLY 2024-WANES-002031 Powergen 0.1 09/19/2024 47.37628 -117.316 AVISTA CORP Shared -117.316 47.37628 No Information
40
Avista 2021-2023 DNR Wildfire Resiliency Plan
Exhibit No. 11
Case No.AVU-E-25-01
V.Malensky,Avista
Schedule 5,Page 41 of 41

Docusign Envelope ID:B96EE566-86D7-486D-B927-42308BC579F1
• 11
AVISTA
WILDFIRE PUBLIC SAFETY
POWER SHUTOFF PLAN
July 2024
Version: 1 .0
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 6, Page 1 of 36

Docusign Envelope ID: B96EE566-86D7-486D-B927-42308BC579F1
Avista Corporation Wildfire Public Safety Power Shutoff Plan
Statement from Avista Executive Management
2024 represents Avista's 1st year of implementing the Public Safety Power Shutoff Plan. This Plan
adds to the work being done to minimize risk of wildfire in Avista's 2023 Wildfire Resliency Plan.
The framework for operational izing a PSPS Plan at Avista is firmly rooted in our 135-year operating
history and represents the collective knowledge of Avista employees and fire agency professionals
together with assistance from peer utilities, and most importantly, engagement with customers. It
also reflects our commitment to partner with customers, communities, and those who manage
forest landscapes and fight fires.
We all have a role to play in minimizing the risk of wildfire.
Heather Rosentrater, President& Chief Operating Officer(COO)
A.
FDocuSigned by:
�'Ia.� 30-12-2024 1 6:26 PM PDT
Date:
Josh DiLuciano, Vice President Energy Delivery
DocuSigned by:
�bS� 3ul-12-2024 1 5:32 PM PDT
A7f`7'IA7 IF IA f1R Date:
Vern Malensky, Director Electrical Engineering
V
DocuSigned by:
UUU tta&AwA� 30-12-2024 1 3:48 PM PDT
f1R(:d FFSCRf1QFdf7R Date:
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 6, Page 2 of 36

Docusign Envelope ID: B96EE566-86D7-486D-B927-42308BC579F1
Avista Corporation Wildfire Public Safety Power Shutoff Plan
Document Owner: The Wildfire Resiliency team is responsible for maintaining this
document. This includes coordinating with Emergency Management in scheduling annual
reviews and exercises, updating content based on annual reviews and exercises, and
redistributing new versions of the document to stakeholders.
The plan will be reviewed and exercised annually. The scale of the exercise will be
determined by the Wildfire Executive Committee in coordination with Wildfire Resliency
personnel and key leadership.
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 6, Page 3 of 36

Docusign Envelope ID: B96EE566-86D7-486D-B927-42308BC579F1
TABLE OF CONTENTS
Tableof Contents............................................................................................................ 1
Listof Figures.................................................................................................................. 3
1. Introduction................................................................................................................................4
2.Acronyms..................................................................................................................... 5
3. Public Safety Power Shutoff Overview ........................................................................ 6
4. Purpose & Scope......................................................................................................... 6
5. PSPS Risk-Informed Decision Making......................................................................... 7
1. Wildfire Risk......................................................................................................... 7
1. PSPS Feeders & Circuits........................................................................... 7
2. PSPS Weather Monitoring and Review............................................................. 12
1. Fire Risk Index......................................................................................... 12
2. National Weather Service Red Flag Warning .......................................... 13
3. Agency Input............................................................................................ 14
6. PSPS Operations..................................................................................................... 14
1. General.............................................................................................................. 14
2. Decision Process for PSPS ............................................................................... 14
3. Event Response & Management....................................................................... 14
4. De-energization Protocols ................................................................................. 16
5. PSPS Recovery (Monitor, Patrol, Restore)........................................................ 16
7. Roles & Responsibilities ............................................................................................ 19
1. Electric Field Operations ................................................................................... 19
2. Electric Distributions Operations........................................................................ 19
3. Director of Electrical Engineering ...................................................................... 19
4. Wildfire Resiliency ............................................................................................. 20
5. Corporate Communications............................................................................... 20
1
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 6, Page 4 of 36

Docusign Envelope ID: B96EE566-86D7-486D-B927-42308BC579F1
6. Customer Service ............................................................................................. 20
7. Business and Public Affairs .............................................................................. 21
8. Supply Chain Management ............................................................................... 21
9. Fleet Management............................................................................................. 21
10. Substation Operations ..................................................................................... 21
11. Vegetation Management.................................................................................. 21
12. Products and Services..................................................................................... 22
13. Geographic Information Systems..................................................................... 22
14. Executive Officers............................................................................................ 22
15. Legal ................................................................................................................ 23
16. Regulatory ....................................................................................................... 23
17. Emergency Management ................................................................................ 23
18. Finance ............................................................................................................ 23
8. Community Outreach & Preparedness .................................................................... 23
1. Coordination with Public Safety Partners and Municipalities ............................. 23
2. Community Support........................................................................................... 24
3. Proactive Customer Communications ............................................................... 26
4. Information Sharing ........................................................................................... 26
9. Continuous Improvement......................................................................................... 27
10.Financial Administration........................................................................................... 27
11. Reporting ................................................................................................................. 27
12.After-Action Report .................................................................................................. 28
13.Training.................................................................................................................... 28
14.Exercises ................................................................................................................. 28
2
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 6, Page 5 of 36

Docusign Envelope ID: B96EE566-86D7-486D-B927-42308BC579F1
List of Figures
Figure 1
PSPS Top 25 Avista Wildfire Risk Feeders Map............................................................................................. 8
Figure 2
PSPS Spokane & Coeur d/Alene Risk Feeders Map...................................................................................... 9
Figure 3
PSPS Sandpoint & Kellogg Risk Feeders Map............................................................................................. 10
Figure 4
PSPS Grangeville Risk Feeders Map............................................................................................................ 11
Figure 5
Organizational Process Flow......................................................................................................................... 16
Figure 6
RestorationProcess ...................................................................................................................................... 18
Figure 7
CommunicationTimeline ............................................................................................................................... 25
Appendix A: Notification Plan
3
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 6, Page 6 of 36

Docusign Envelope ID: B96EE566-86D7-486D-B927-42308BC579F1
1 . INTRODUCTION
In the Northwest, the number, size, and severity of wildfires has increased in recent
years. This trend is expected to continue as temperatures rise and drought persists.'
Avista published its first Wildfire Resiliency Plan in June of 2020 (the 2020 Plan). That
plan introduced the risks, costs, and benefits of implementing a holistic set of measures
to reduce utility wildfire risk. The 2020 Plan built upon Avista's operating history
responding to and mitigating for wildfire activity in addition to adopting other risk
mitigation strategies employed by peer utilities. Avista updated its Wildfire Resiliency
Plan in 2023 (the 2023 Plan); the 2023 Plan details the performance and investments
made from 2020 through 2023 and serves to reaffirm Avista's commitment to reducing
fire risk to communities, customers, and the Company. Similar to other utility wildfire
plans, Avista is making investments in four key areas:
Grid Hardening — to invest in electric line infrastructure to reduce spark-ignition outage
events and to protect critical assets from the impact of wildfires.
Enhanced Vegetation Management— to inspect 100% of distribution line assets within
wildfire risk tiers 2 and 3 annually and combine remote sensing technologies such as
LiDAR and satellite imagery to aid in risk tree management.
Situational Awareness —to automate Avista's non-reclosing protection strategy,
identify dynamic short term fire related risk and align with system protection levels.
Emergency Response & Operation —to help customers and communities be better
prepared for wildfires and partner with emergency first responders before, during, and
after fire events.
As part of its operational mitigation strategies, Avista has developed this Public Safety
Power Shutoff Plan (PSPS Plan or Plan) to guide the assessment and decision making
process when determining to proactively de-energize electrical facilities in identified
areas of extreme wildfire risk when conditions are so severe 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 not only our
customers and communities but Avista staff as well. This 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 during wildfire season (typically June-October), reviewed
annually and updated as necessary prior to the start of the next wildfire season.
1 USDA Climate Hub,"Climate Change and Wildfire in Idaho,Oregon,and Washington,"hftps://www.climatehubs.usda.gov/hubs/northwesUtopic/climate-change-and-wildfire-idaho-
oregon-and-washington
4
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 6, Page 7 of 36

Docusign Envelope ID: B96EE566-86D7-486D-B927-42308BC579F1
2. ACRONYMS
AAR — After Action Review
AE —Account Executive
COO—Chief Operations Officer
CRC — Community Resource Center
DNR— Department of Natural Resources
DOT — Department of Transportation
EM — Emergency Management
EOC — Emergency Operations Center
EOP — Emergency Operations Plan
ERT — Estimated Restoration Time
EWC — Executive Wildfire Committee
FRI — Fire Risk Index
FSM — Fire Safety Model
FWW—Fire Weather Watch
GIS — Geographic Information System
ICS — Incident Command Structure
IPUC — Idaho Public Utility Commission
IVR— Interactive Voice Response
NWS — National Weather Service
OEM — Office of Emergency Management
PG&E — Pacific Gas & Electric
PSPS — Public Safety Power Shutoff
PUC — Public Utilities Commission
RBM — Regional Business Manager
RFW—National Weather Service issued Red Flag Warning
WRMAA—Western Region Mutual Assistance Agreement
WUTC — Washington Utility and Transportation Commission
Formerly known as Dry Land Mode(DLM)
5
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 6, Page 8 of 36

Docusign Envelope ID: B96EE566-86D7-486D-B927-42308BC579F1
3. PUBLIC SAFETY POWER SHUTOFF OVERVIEW
Over the last several decades, the western United States (U.S.) has experienced an
increase in the intensity of wildland fires (wildfires). There have been several factors
contributing to this trend, including climate change, increased human encroachment in
wildland areas, historical land management practices and changes in forest health.
Recent events in western states have increased awareness of electric utilities' role in
wildfire prevention and mitigation.
Avista has always prioritized keeping our communities and customers safe and
continues to prioritize safety by increasing the resiliency of Avista's transmission and
distribution (T&D) facilities. As part of its operational mitigation practices, Avista
developed this PSPS Plan to proactively de-energize electrical facilities in extreme
weather conditions where it is deemed unsafe to operate. Based on the inherently
disruptive nature of power outages, PSPS events must be carefully evaluated under this
Plan to balance wildfire risk with potential PSPS impacts on Avista customers and the
communities it serves. For Avista, a planned de-energization is a measure of last resort
to reduce public safety risk.
4. PURPOSE & SCOPE
This PSPS Plan identifies relevant considerations, decision process flow and
implementation protocols before, during and after a PSPS event. The Plan will be active
during wildfire season and reviewed and updated annually as necessary prior to the
start of the next wildfire season.
Nothing in this Plan supersedes the general authority of the Company to de-energize a
power line during an emergency, 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 this 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 the specific
circumstances.
The key goals Avista considers for the foundation of the of the 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 on
communities and customers
• Maintaining reliable electric service
6
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 6, Page 9 of 36

Docusign Envelope ID: B96EE566-86D7-486D-B927-42308BC579F1
5. PSPS RISK-INFORMED DECISION MAKING
1 . Wildfire Risk
Avista's 2019 Wildland Urban Interface (WUI) map combined data from the Wildfire
Hazard Potential with the location of Avista electric lines in areas of low, medium, and
high population. This analysis indicated that 3,240 miles of Avista's 7,725 mile
distribution system were located in high fire threat districts (42% of the system).
In 2023, Avista's WUI map was updated and now includes additional data which
measures the impact of fire on human development. The USDA's Housing Unit Impact
Dataset-14 combined with the Wildfire Hazard Potential data mentioned previously, was
used to refine the Avista WUI map. Communities such as Chewelah and Colville border
national forest 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 , has an increasing number
of housing developments within high fire threat areas, increasing the risk of wildfire
impacts. According to the updated data, 2,746 miles of electric distribution lines are in
high fire risk areas, or about 36% of the system. Although this analysis indicates slightly
lower risk values compared to 2019, it still demonstrates significant fire risk potential
throughout the service territory.
The unpredictable nature of wildfire and weather patterns create significant challenges
with forecasting PSPS events. Real-time evaluations and decision-making are therefore
critical in making PSPS determinations and, depending on the associated wildfire risk,
those determinations may result in proactive de-energization in areas not originally
anticipated, or in decisions not to proactively de-energize a line depending on the
circumstances.
1. PSPS Feeders & Circuits
In 2023, Avista developed a list of 25 distribution feeders with the highest likelihood of
being included in a PSPS event (the Top 25 List); this list was developed using the
existing Avista Fire Weather Dashboard, wildfire data, historic outage data and scenario
planning. This Top 25 List was developed as part of Avista's risk-based approach to
preparedness. The Top 25 List assists with the planning and preparedness process to
support our customers in the event of a PSPS event; the list does not preclude Avista
from initiating a PSPS on other feeders or circuits in its service territory. 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.
7
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 6,Page 10 of 36

Docusign Envelope ID: B96EE566-86D7-486D-B927-42308BC579F1
The maps below include those feeders where a PSPS event is most likely to occur:
Top 25 Avista Wildfire Risk Feeders
Feeder Names
BLU322 LIB12F3
BUN424 LTF34F1
CKF711 MEA12F2
DAL133 ORO1281
FOR12F 1 OSB521
— GLN121`2 RAT233
GRN12F3 SAG741
— GRV1271 SAG742
GRV1273 SE12F2
KAM1291 SE12F4
KAM1292 SUN12F2
— KAM1293 WAK12F2
KOO1298 WEI1289
KOO1299
Miles
0 5 10 20 30 40
Figure 1
PSPS Top 25 Avista Wildfire Risk Feeders Map
8
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 6,Page 11 of 36

Docusign Envelope ID: B96EE566-86D7-486D-B927-42308BC579F1
Avista Wildfire Risk Feeders
in Spokane, Washington
and Coeur d'Alene, Idaho Areast-14
-
s
I
M•Ii�J L.I-
Feeder Names
BLU322 RAT233
DAL133 SAG742
FOR12F1 SE12F2
GLN12F2 SE12F4
LIB12F3 SUN12F2
LTF34F1 WAK12F2
MEA12F2
N
Miles
0 5 10 20 30 40
Figure 2
PSPS Spokane&Coeur d/Alene Risk Feeders Map
9
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 6, Page 12 of 36

Docusign Envelope ID: B96EE566-86D7-486D-B927-42308BC579F1
Avista Wildfire Risk Feeders
in Sandpoint, Idaho and Surrounding Areas
Feeder Names
CKF711 SAG742
SAG741
N
Miles �m
0 1.5 3 6 9 12
Avista Wildfire Risk Feeders
in Kellogg, Idaho and Surrounding Areas
r K,n Q.nn Smdtervlll• KdI..+Iq
r auln' Gindv.n=1
Feeder Names
BUN424
— OSB521
N
Miles
0 1.5 3 6 9 12
Figure 3
PSPS Sandpoint& Kellogg Risk Feeders Map
10
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 6, Page 13 of 36

Docusign Envelope ID: B96EE566-86D7-486D-B927-42308BC579F1
Avista Wildfire Risk Feeders
in Grangeville, Idaho and Surrounding Area
Feeder Names
GRV1271 KOO1298
GRV1273 KOO1299
KAM 1291 ORO1281
KAM1292 WE11289
KAM 1293
N
Miles
0 5 10 20 30 40
Figure 4
PSPS Grangeville Risk Feeders Map
11
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 6,Page 14 of 36

Docusign Envelope ID: B96EE566-86D7-486D-B927-42308BC579F1
2. PSPS Weather Monitoring and Review
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.
1. Fire Risk Index
In addition to the Fire Risk Tiers (Low, Moderate, Elevated, High) Avista developed a
Fire Risk Index (FRI) to compare ignition potential and wildfire spread potential
across Avista's service areas. The FRI converts data on weather; prevalence of fuel
(shrubs, trees, grasses); topography; community risk; historic summer outages; Severe
Fire Danger Index; Fire Preparedness; and percentage of treed overhead spans into a
numerical FRI score to forecast the short-term wildfire threat in geographical areas
throughout Avista's service area. FRI scores range from 0 (very green, wet fuels with
low to no wind or high humidity) to 9 (very brown and dry, both live and dead dry fuels
with very low humidity and extreme wind speeds). FRI scores are grouped into the
following 5 index levels:
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. Fire
Safety Mode which includes enhanced protection settings are used beginning at an FRI
of 5.5 to reduce the risk of potential ignition. The Company will consider the possibility
12
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 6,Page 15 of 36

Docusign Envelope ID: B96EE566-86D7-486D-B927-42308BC579F1
of initiating a PSPS when the FRI forecast is at 7.0 or greater, and 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 and critical
infrastructure, wind direction and speeds, medically vulnerable populations, proximity to
aid, utility resources available, etc. This list of considerations is non-exhaustive, as each
weather situation is unique and involves unique characteristics, risks, and
considerations. During wildfire season, Avista will determine a daily FRI on each feeder
as described in our 2023 Wildfire Resliency Plan and related white paper documents.
2. National Weather Service Red Flag Warning
A Red Flag Warning (RFW) is a forecast warning issued by the National Weather
Service (NWS) to inform the public, firefighters and land management agencies that
conditions are ideal for wildland fire combustion and rapid spread. RFWs are often
preceded by a Fire Weather Watch (FWW), which indicates weather conditions that
could occur in the next 12-72 hours resulting in a Red Flag Warning.
The NWS has developed different zones across the nation for providing weather alerts
(such as RFWs) to more discrete areas. These zones are shown on this NWS
webpage: Fire Weather.
The following thresholds are used by most NWS offices:
Daytime:
• Relative humidity of 25% or less
• Sustained winds greater than or equal to 10 miles per hour (mph) with
gusts greater than or equal to 20 mph over a four-hour period
Nighttime:
• Relative humidity of 35% or less
• Sustained winds greater than or equal to 15 mph with gusts greater than
or equal to 25 mph over a three-hour period
Lightning:
• The NWS rarely issues RFWs for lightning in the western United States.
For this to occur, the Lightning Activity Level—a measure of lightning
potential specifically as it relates to wildfire risk—needs to be at 3 or
higher.
Although Red Flag Warnings are used as a tool for forecasting, they are only one factor
Avista considers when determining initiation of a PSPS event. Initiating a PSPS will
13
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 6,Page 16 of 36

Docusign Envelope ID: B96EE566-86D7-486D-B927-42308BC579F1
require a refined and focused approach for specific feeders rather than an entire
geographic area; consequently, a RFW cannot be used as the sole determinative factor
in whether to initiate a PSPS in any specific region or area.
5.2.3. Agency Input
Coordination with agencies like the Washington State Department of Natural Resources
(DNR) and Idaho Department of Lands (IDL) will also aid in the decision making for
PSPS events. During wildfire season, DNR provides weekly briefings which assist in
analyzing drought conditions and weather forecasts. IDL also holds meetings during
wildfire season to provide updates on wildfires and weather conditions.
6. PSPS OPERATIONS
1 . General
PSPS preparedness is a cyclical effort involving Avista, public safety partners, state and
local governments, communities and customers. Avista's main objectives of
preparedness are: 1) performing wildfire prevention and mitigation activities; and 2)
engaging with external public safety partners, critical facilities, tribal partners and
communities to develop relationships and provide education to safely and effectively
implement this 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 while Business & Public Affairs, Customer
Solutions and Corporate Communications facilitate public outreach and coordination
efforts with external stakeholders.
2. Decision Process for PSPS
The weather monitoring and situational awareness criteria outlined in Chapter 5, in
addition to other factors mentioned, will assist Avista in determining whether a PSPS
event may be warranted. The decision of whether to initiate a PSPS in any given
situation will be made by a team of individuals utilizing the information that is available
to them at the time.
6.3 Event Response & Management
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). During the PSPS Watch phase, Avista will
14
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 6,Page 17 of 36

Docusign Envelope ID: B96EE566-86D7-486D-B927-42308BC579F1
activate the PSPS Assessment Team, which includes Director of Electrical
Engineering, Wildfire Resiliency Manager, Director of Business and Public Affairs (or
delegate), a representative from Electric Operations (or Director), a representative from
Corporate Communications (or Director), Regulatory, System Operations, Customer
Service, Manager of Social Impact (or delegate) and Legal representatives. The PSPS
Assessment Team will meet as needed to discuss current and forecasted weather
conditions and other critical information regarding a potential PSPS event. The Director
of Electrical Engineering will facilitate the PSPS Assessment Team meetings and
conference calls to ensure operational readiness for a potential event. The Director of
Electrical Engineering and Wildfire Resiliency Manager will provide a recommendation
to the Wildfire Executive Committee taking into account input from other support roles
on the PSPS Assessment Team. 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 and critical
facilities operators. The first notification to governmental agencies and emergency
management partners could occur during the 7-2 day PSPS Watch phase.
An Emergency Operating Plan (EOP) briefing will be initiated as early as 7 days prior to
the initiation of a PSPS Event. The Director of Electric Operations will aid in the
coordination of the PSPS event in close collaboration with the Director of Electrical
Engineering (Wildfire Lead). See Figure 5 for organizational process flow and
transition into the EOP event. The procedures and incident management structure
outlined in the most current edition of the Avista Emergency Operations Plan will be
followed to coordinate the response for a PSPS event once fully transitioned to an EOP.
During PSPS Watch, the PSPS Assessment Team will review the PSPS Plan and
supporting documents. An operational risk assessment will be performed as well to
determine, risks and vulnerabilities. A determination will be made whether to escalate to
PSPS Warning by the Director of Electrical Engineering approximately 48-24 hours in
advance of a potential event. Within one hour of initiating a PSPS Warning notification,
the full PSPS team will be placed on stand-by and team member availability will be
determined. The full PSPS team is the PSPS Assessment Team plus the Wildfire
Executive Committee including the President and COO, VP of Energy Delivery,
the VP of Community Affairs and Chief Customer Officer, Sr. VP and General
Counsel, Sr. VP CFO Treasurer and Regulatory Affairs Officer and Director of
Corporate Communications.
15
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 6, Page 18 of 36

Docusign Envelope ID: B96EE566-86D7-486D-B927-42308BC579F1
PSPS Assessment Corporate
Director of 40MM Communications
Electrical Director of
Engineering Electric
(Wildfire Lead) Operations
� l
.. . Area Manager
SupplyAsset
SupportPSPS Assessment
Business and Committee Customer
Public Affairs Service
Community Electric
Outreach Operations
OperationsCorporate Substation Vegetation
Communications
System Emergency
Operations Management
Products
Services
Figure 5
Organizational Process Flow
4. De-energization Protocols
Distribution Operations will develop the switching plan(s)for the PSPS execution after
adoption of this PSPS plan. A final review of the switching plans by the Director of
Transmission Operations and System Planning will be completed prior to any PSPS
execution by the Electric Operations Director. The final approval to initiate a PSPS or
not to initiate a PSPS will be provided by the Wildfire Executive Committee, in
consultation with the PSPS Assessment Team. After the final approval to activate
PSPS is received, the Manager of Distribution Operations receives instruction from
the Electric Operations Director to execute de-energization protocols; the appropriate
operator(s)will begin switching activities with field personnel (if necessary).
5. PSPS Recovery (Monitor, Patrol, Restore)
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
16
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 6,Page 19 of 36

Docusign Envelope ID: B96EE566-86D7-486D-B927-42308BC579F1
Named Communities.
One of the challenges when using PSPS is the process of re-energization. If a utility de-
energizes lines for a PSPS event, facilities cannot be re-energized until all circuits and
lines are thoroughly inspected or patrolled. After inspection, lines are re-energized
segment by segment. Patrol of all impacted overhead electric facilities, both
transmission and distribution, can only commence once the weather event has
subsided. Restoration following a typical PSPS event normally
requires three to six days, however, several PSPS events in It is important to note
California have taken up to 14 days for full restoration. Restoration that a PSPS event and
efforts following a PSPS will always require additional time to fully associated complexities
inspect each circuit and line, even if they weren't damaged during related to patrol and
the weather event. repair work does not
account for the outages
on other circuits and
The hypothetical scenario modeled for this report considered there would likely be
implementation of a PSPS with sustained winds (those lasting over hundreds of such
a 2-minute period)2 greater than 50 mph. It is important to note that outages in an event of
in such conditions, circuits that have been placed in elevated or this magnitude.
extreme protections schemes (and perhaps even more than that)
would also likely be impacted. In other words, there would likely be additional damage
to other distribution circuits and to the transmission system. In this scenario, there may
be as many as 25 distribution circuits, with 1,500 miles of distribution line to patrol, as
well as potentially 1,000 miles of transmission line to patrol. Transmission has been
included here only to analyze potential resources needed; however, transmission is not
being considered for PSPS.
One element of the PSPS restoration plan includes pre-staging two-man crews at
known PSPS facility locations when conditions are safe to do so, since PSPS locations
are identified in advance of the storm. The PSPS restoration plan also accounts for the
need to assign additional resources to impacted transmission and distribution lines
outside of the affected PSPS areas, with patrol activities commencing when the all-clear
is given. Avista's goal is to complete patrol/inspection within the first 24-48 hours, but
this estimate is heavily dependent upon the amount of damage the system sustained
and crew availability.' It is also impacted by the ability to use aerial patrols, which may
be grounded due to wind/weather.
2 Note that assessment times are completely separate from repair times—one does not impact the other.In addition,this 24 hour estimate is
only for the PSPS portion of the outages,which in this example would be 17 circuits,should take about 24 hours to patrol.
17
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 6,Page 20 of 36

Docusign Envelope ID: B96EE566-86D7-486D-B927-42308BC579F1
Power.ilia
ot
Restore
Line Patrol: Start with Critical Complete Repairs., Event Ends
"All Clear"is declared by Infrastructure,Commercial Main Trunk Lines •• is Declared • -
decision-makers Zones with Equity Branch Lateral Circuits After Action Review With
Field Crews Mobilized Considerations Individual Customers Emergency 15t Responders
Broad Communications to Communicate Estimated U... . Regulators
IncludingCustomers Help Customers Estimated Restoration
SupportWith Resources
Customers
Figure 6
Restoration Process
Most, if not all, of Avista in-house resources would be focused on the patrol/inspection
effort.3 Scenarios that would lead to consideration of a PSPS would likely be of a large
enough magnitude for Avista to initiate a mutual assistance request from other utilities,
as well as the need for outside contractors. Availability of these additional resources
could have an impact on restoration time depending upon where these crews are
based.
As Avista further develops and refines its restoration efforts, specifically after the
occurrence of a PSPS, the Company will need to prioritize balancing and allocating
additional resources to circuits that may have been impacted by storm damage in
Named Communities, in areas with critical customers, and in areas with large numbers
of customers. This will help ensure that restoration efforts are equitable for the most
vulnerable and highly impacted customers that may not have equal means or access to
resources during prolonged outages. This additional effort will take more time and
resources during the restoration process but ensures that equity is being applied to the
PSPS restoration process.
3 Avista has learned through experience that only about 80%of our total field resources are available at any given time(due to illness,
vacation,etc.),meaning that in the event of a PSPS-level situation the Company will have about 125 qualified line personnel available.
18
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Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 6,Page 21 of 36

Docusign Envelope ID: B96EE566-86D7-486D-B927-42308BC579F1
7. ROLES & RESPONSIBILITIES
1. Electric Field Operations
• Work closely with PSPS Assessment Team on field conditions and Estimated Restoration
Times (ERTs).
• Participate in After-Action Reviews (AARs) (further discussed in Section 12 below) and
ensure modifications to PSPS protocols are implemented as necessary.
2. Electric Distribution Operations
• Develop and implement safe and reliable power shutoff protocols and procedures.
• Ensure System and Regional Dispatch employees are appropriately trained to perform
relevant responsibilities under this PSPS Plan, and that such employees receive timely
information regarding wildfire risk and weather conditions for purposes of performing those
responsibilities in the event of a PSPS.
• Participate in the PSPS Assessment Team with PSPS evaluation and decision-making.
• Safely restore service to PSPS areas when notified by Electric Field Operations it is safe to re-
energize.
• Participate in AARs and ensure modifications to PSPS protocols are implemented as
necessary.
3. Director of Electrical Engineering
• Serves as the Wildfire Lead
• Activate the PSPS Assessment Team if a PSPS is likely.
• Support EOC Director in facilitating PSPS event.
• Participate in AARs and ensure modifications to PSPS protocols are implemented as
necessary.
4. Wildfire Resiliency
• Oversee wildfire mitigation program (including this Plan) and support cross departmental
collaboration.
19
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 6,Page 22 of 36

Docusign Envelope ID: B96EE566-86D7-486D-B927-42308BC579F1
• Monitor daily, weekly and long-term weather and wildfire forecasts.
• Monitor weather conditions for Fire Weather Watches, Red Flag Warnings and High Wind
Watches and Warnings.
• Communicate with Washington Department of Natural Resources (DNR) and Idaho
Department of Lands (IDL).
• Oversee operation of the Customer Resource Centers and designated contractor prior to and
during PSPS event.
• Participate in AARs and ensure modifications to PSPS protocols are implemented as
necessary.
5. Corporate Communications
• Work directly with the Assessment team to create external messages to share with
stakeholders and customers regarding PSPS events.
• Implement its developed Notifications Plan to notify customers and employees on a wide
range of channels and in coordination with Avista's Customer Service and Community
Outreach teams. See appendix A: PSPS Notification Plan for additional details.
• Participate in AARs and ensure modifications to PSPS protocols and communication
practices are modified as necessary.
• Ensure a coordinated and cohesive external and internal communication and notification
plan is in place and reviewed annually.
6. Customer Service
• Respond to customer calls and respond to questions with information provided by Corporate
Communications.
• Ensure customer service representatives are trained to manage customer interactions during
a PSPS event.
• CARES Team will provide additional communications to Life Support customers managed
under their case load.
• Participate in AARs and ensure modifications to PSPS protocols are implemented as
necessary.
7. Business and Public Affairs
• Communicate with external partners, governmental agencies, public safety partners and
critical business customers on updates and status regarding PSPS watches, PSPS 20
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 6,Page 23 of 36

Docusign Envelope ID: B96EE566-86D7-486D-B927-42308BC579F1
warnings, activity and following a PSPS outage.
• Coordinate internally with Corporate Communications and Wildfire Executive Committee to
ensure consistent communications with external partners and customers.
• Participate in AARs and ensure modifications to PSPS protocols are implemented as
necessary.
8. Supply Chain Management
• Ensure contract resources are appropriately trained to perform all relevant responsibilities
under this PSPS Plan.
• Participate in AARs and ensure modifications to PSPS protocols are implemented as
necessary.
9. Fleet Management
• Ensure employees are appropriately trained to perform all relevant responsibilities under
this PSPS Plan.
• Ensure readiness of resource pool equipment for a PSPS event.
• Participate in AARs and ensure modifications to PSPS protocols are implemented as
necessary.
10. Substation Operations
• Monitor substations and perform actions to support PSPS operations.
• Coordinate activities with Dispatch and Customer Service.
• Participate in AARs and ensure modifications to PSPS protocols are implemented as
necessary.
11. Vegetation Management
• Following de-energization, and when it is safe to do so, Electric Field Operations will report
impacts to infrastructure and assets from vegetation, as appropriate.
• Vegetation Management will work toward removing risk trees created by the wind or storm
event in order to re-energize system.
• Ensure contractors and field personnel are appropriately trained to perform all relevant
responsibilities under this PSPS Plan.
• Use reasonable efforts to ensure contract resources are available and prepared for PSPS
events.
• Participate in AARs and ensure modifications to PSPS protocols are implemented as
necessary.
12. Products and Services
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Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 6,Page 24 of 36

Docusign Envelope ID: B96EE566-86D7-486D-B927-42308BC579F1
• Provide necessary updates to outage map vendor.
• Assist with Estimated Restoration Time calculations with the Operations Managers
• Update Internal Communications Portal with current Estimated Restoration Times (ERTs)
during an event.
• Participate in AARs and ensure modifications to PSPS protocols are implemented as
necessary.
7.13.Geographic Information Systems
• Work with Electric Operations and Corporate Communications to ensure PSPS boundary
information for PSPS GIS maps is accurate and up to date for emergency planning partners.
• Before wildfire season and during preliminary notifications of a potential PSPS event,
provide relevant GIS data within the confines of applicable law to public safety partners.
• Participate in AARs and ensure modifications to PSPS protocols are implemented as
necessary.
7.14.Executive Officers
• Provide guidance and direction as part of the Wildfire Executive Committee where
appropriate in order to evaluate whether to initiate PSPS event.
• Provide oversight for additional Plan changes prior to next wildfire season.
• Participate in AARs and ensure modifications to PSPS protocols are implemented as
necessary.
7.15.Legal
• Provide legal guidance in evaluating a potential PSPS event.
• May direct AARs after a PSPS event (or potential event in which the PSPS Assessment
Team is activated).
• Involved in reviewing communications and holding statements to customers, media, public
safety partners, critical facilities, and involved communities.
• Participate in AARs and ensure modifications to PSPS protocols are implemented as
necessary.
7.16. Regulatory
• May provide regulatory guidance in evaluating a potential PSPS event.
22
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Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 6,Page 25 of 36

Docusign Envelope ID: B96EE566-86D7-486D-B927-42308BC579F1
• May be involved in reviewing communications to customers, public safety partners and
critical facilities.
• Assist in/direct regulatory reporting/filing activities.
• Participate in AARs and ensure modifications to PSPS protocols are implemented as
necessary.
7.17.Emergency Management
• Coordination and assistance with activation and operation of EOP event.
• Help facilitate the AARs and ensure modifications to PSPS protocols are implemented as
necessary.
7.18. Finance
• Provide financial accounting assistance for EOP event (for example, providing a Project and
Task code for event tracking purposes).
• Participate in AARs and ensure modifications to PSPS protocols are implemented as
necessary.
8. COMMUNITY OUTREACH & PREPAREDNESS
1. Coordination with Public Safety Partners and Municipalities
Strong partnerships have been developed between Avista and local public safety, health, other utilities,
and emergency management agencies over the last several years to assist in the coordination for any
event which impacts the communites we serve. Avista will serve as the initiating agency in the event of
a PSPS and will coordinate with all local agencies as appropriate. Avista will collaborate with those
agencies with expertise and consider any recommendations offered by state and local emergency
management agencies. Any non-outage related issues or incidents that arise during a PSPS will be
handled by local emergency management and public safety.
Avista Regional Business Managers will maintain regular outreach with local jurisdictions to include
voice and email notifications and communication during the event. Additionally, 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.
2. Community Support
In addition to proactive outreach to public safety partners, municipalities and tribal entities, support will
also be necessary for residential customers.
Outage Map
Effective communications regarding location of PSPS events and restoration times will be critical to
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V. Malensky,Avista
Schedule 6, Page 26 of 36

Docusign Envelope ID: B96EE566-86D7-486D-B927-42308BC579F1
support customers before and during the event. Avista has an Outage Map tool which will provide PSPS
specific information regarding the location of the event, and any other pertinent event information. The
map will be updated throughout the event to keep customers informed.
CARES Team
Avista has a Customer Service CARES Team which is engaged with medically vulnerable customers
and acts as a liaison to support those customers. A PSPS event will greatly impact medically vulnerable
customers necessitating additional outreach to ensure these customers have a plan needed to be
prepared for the de-energization. The CARES Team will provide additional notifications to these
customers who are considered Life Support in CC&B.
Community Resource Centers (CRCs)
Another way Avista will support customers during a PSPS event is to operate Community Resource
Centers (CRCs). CRCs are an integral part in ensuring customers affected by PSPS events have
access to basic resources and up-to-date information, during the PSPS event.
Avista utilizes a contracted vendor, FireDawg for logistical support in deploying CRCs during a PSPS
event. 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, during Avista crew patrols, and final re-energization in
communities affected. The typical hours of operation will be 8AM-8PM, unless otherwise noted. Avista
will utilize brick and mortar facilities for CRC locations unless a facility is not available or feasible in
which case the CRC contractor, FireDawg will deploy a large generator powered trailer or in last resort
instances a tent. Avista personnel including available wildfire staff and 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 located throughout the service territory.
Locations have been strategically chosen to provide the flexibility to select the location that best suits
customers' needs based on event specifics. This work of formalizing agreements for CRC locations is
ongoing and will continue to be developed into 2025 as more locations are secured. Avista will continue
to work both internally and externally with local public safety partners, other community partners, and
tribal leadership to identify appropriate CRC sites. A future appendix will be added which will generally
include locations identified and specific details regarding the site configuration with maps and diagrams.
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.
Services/Resources generally provided include:
24
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Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 6,Page 27 of 36

Docusign Envelope ID: B96EE566-86D7-486D-B927-42308BC579F1
• Shelter from environment • Communications capability such as Wi-fi
• Air conditioning access, Sat Phone, Radio, Cellular
• Potable water & Non-perishable light snacks phone etc.
• Seating and tables . Charging stations for Cell Phones,
• Restroom facilities AM/FM/Weather radios,
• Refrigeration & Heating for medicine and/or computers, medical devices, etc.
baby needs • Portable ADA Ramp
• Interior and area lighting
• On-site security
• Televisions
• Ice
On an annual basis, Avista will evaluate the effectiveness of these tools and programs used to support
customers and determine if changes are needed.
25
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Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 6,Page 28 of 36

Docusign Envelope ID: B96EE566-86D7-486D-B927-42308BC579F1
8.3. Proactive Customer Communications
Although the size of Avista's service area, geographic and environmental diversity, and
unpredictable nature of Washington and Idaho weather make it challenging, Avista is
committed to providing as much advance notice as reasonably possible in preparation
for a PSPS event. Figure 7 provides Avista's optimal communication timeline for PSPS
events, circumstances permitting.
PSPS Timeline uescription of Planned Communications
Awareness/ Pre-Wildfire Season—Provide education throughout service territory to
customers, Public Safety and Tribal Partners, monitor weather conditions
Preparedness and seasonal forecasts and provide internal PSPS training.
7-2 days—Monitor the weather forecasts, Internal EOP Activation, begin
PSPS notifying public safety partners of potential PSPS, begin planning for CRC
Watch operation. First notifications to affected public safety and tribal partners
and affected customers occur during this initial phase.
PSPS tribal
hours- 1 hour—Additional notification to affected public safety and
tribal partners to inform of potential pending PSPS event, additional
Warning notifications to customers within potential PSPS boundary.
PSPS Execute PSPS initiation—Notify Public Safety Partners, operators of critical facilities
(if possible)and all customers within the PSPS boundary. Provide updates in
(Power Off) 24-hour intervals until re-energization begins.
Restoration—When re-energization begins, if possible, notification to
affected Public Safety and Tribal Partners, operators of critical facilities and
Restore all affected customers. Once re-energization is complete, provide final
notifications to all affected and Public Safety Partners.
Figure 7
Communication Timeline
8.4. Information Sharing
Coordination with both internal and external partners is instrumental to the success of
any emergency event. Avista will coordinate with public safety partners, municipalities,
and industrial/commercial customers in advance of a PSPS event. This will help these
partners prepare necessary communication functions and establish communication
26
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Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 6, Page 29 of 36

Docusign Envelope ID: B96EE566-86D7-486D-B927-42308BC579F1
protocols for critical decision-making before and during a PSPS event, including
restoration activities.
9. CONTINUOUS IMPROVEMENT
Avista will strive to continuously improve the effectiveness of this PSPS Plan, which will
include periodic review and assessments. Avista participates in industry events, table-
top exercises, and other functional activities to keep abreast of industry-best practices
and lessons learned so that it may adapt its planning and processes as appropriate.
Avista's PSPS Plan is reviewed annually to ensure that it reflects Avista's current
policies and implementation procedures with updates, as needed, to the program's
organizational structure, training and education, responsibilities, operations, reporting,
record keeping, and any other changes. The end products of these reviews are new or
revised documents, if necessary, including revised versions of this Plan.
10. FINANCIAL ADMINISTRATION
Avista will track expenses related to PSPS events for WUTC and IPUC reporting
and potential recovery. Expense should be tracked for the entire PSPS event
(PSPS Watch through conclusion of the Post-Incident Review and filing the
PSPS event report with the WUTC or IPUC) to include, without limitation, time
reporting, equipment and supplies used to set up customer resource centers and
provided to customers (e.g., water, ice, etc.)
11 . REPORTING
Employees are required to manage information regarding PSPS events pursuant to
Avista's Information Retention Policy and underlying standards. Avista will submit
reports to the WUTC and IPUC as required.
12. AFTER-ACTION REPORT
An AAR is a structured review or de-brief process used to evaluate the effectiveness of
the Plan and potential areas for improvement. This process may be performed after a
PSPS event and may be confidential at the direction of Legal to improve the PSPS
processes and procedures.
Generally, the After-Action Report could include:
• Explanation of the decision to de-energize, factors contributing to the decision.
• Explanation of how the utility determined that the benefit of de-energization
27
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Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 6,Page 30 of 36

Docusign Envelope ID: B96EE566-86D7-486D-B927-42308BC579F1
outweighed potential public safety risks.
• Location, time, and duration of event.
• Number of affected customers, broken down by residential, medically
vulnerable, commercial/industrial, and others.
• Describe wind-related damage to utility overhead powerline facilities in the
areas where power was shutoff.
• Describe customer communications and notifications.
• Whether CRCs were activated, and the location, resources provided and
duration of the CRCs.
• Describe the engagement with local and state public safety partners and
community partners with regards to advanced outreach/notification during the
PSPS event.
• Summarize the number and nature of complaints received as a result of PSPS
event and include claims that are filed against Avista because of the PSPS.
• Lessons learned by Avista from the PSPS event
13. TRAINING
Avista will strive to provide regular training, prior to or shortly after the beginning of
wildfire season (annually), to relevant employees on their respective roles in executing
this PSPS Plan.
14. EXERCISES
Avista's Director of Electrical Engineering in partnership with the Emergency
Management Team will exercise this PSPS Plan at least annually using various
scenarios and testing of all or any portion(s) of the Plan which may include:
• Improving communication efforts with public safety partners which may include
testing text and/or phone alerts
• Testing tactical operational plans such as reporting field observations or
positioning employees at manually operated disconnects to test timing for de-
energization and field inspections of distribution infrastructure
28
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Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 6,Page 31 of 36

Docusign Envelope ID: B96EE566-86D7-486D-B927-42308BC579F1
• Discussing and/or practicing roles and responsibilities of both strategic and
tactical operations, including decision-making handoffs and hypothetical
scenarios
• Discussing and/or developing re-energization plans
• Testing capacity limits on incoming and outgoing communications systems
29
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Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 6,Page 32 of 36

Docusign Envelope ID: B96EE566-86D7-486D-B927-42308BC579F1
Appendix A:
Avista PSPS Notification Plan
Overview
Avista's comprehensive Wildfire Resiliency Plan, launched in 2020, identified four categories of
focus: grid hardening, enhanced vegetation management, situational awareness, and
emergency response and operations. The goals of the plan have remained consistent:
1. Emergency Preparedness —To recognize wildfire as a recurring threat to infrastructure,
communities, and utility customers.
2. Protect Life and Property—To protect physical assets, property, and human lives against
the threat of wildfires. To recognize fire potential as a manageable risk element of our operating
and maintenance strategies.
3. Financial —To mitigate the probability and consequence of direct financial costs and liability
associated with large-scale fire events.
In emergency response and operations, Avista has evolved its strategies over time. Fire Safety
Mode now has an extreme setting. Customers on impacted circuits are notified when their
protection settings are increased to prepare them for potential outages.
Public Safety Power Shutoffs (PSPS), a temporary, preemptive power shut off to electrical
circuits in select areas of our system to keep communities and customers safe, is a new tactic in
the plan. Due to the potential hardships that a temporary power shut off may cause, especially
to vulnerable individuals and communities, it is critical that that in times of extremely high fire
risk, Avista provides advanced notice of a possible power shut off. This advanced notice is
important to individuals and communities in their own planning in preparation for, and living with,
an electrical outage event.
Objectives
To ensure all customers are aware of any potential or planned PSPS event, the objectives of
the notification plan are to:
• Develop strategies to ensure timely notifications are made.
• Create clear and consistent messaging based on each event.
• Utilize a broad range of channels, both owned and earned, to communicate.
• Provide updated information as quickly as possible throughout an event.
Public Safety Power Shutoffs-Preparation
Building on the multi-channel communications supporting wildfire resiliency, in 2022 we turned
our efforts toward operational changes, specifically changes to Dry Land Mode, now called Fire
Safe Mode. We continued to notify customers that we had gone into our base-level Fire Safe
Mode and implemented new notifications for all customers on impacted circuits when we went
1
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Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 6,Page 33 of 36

Docusign Envelope ID: B96EE566-86D7-486D-B927-42308BC579F1
into elevated or extreme settings. When there was a need for an elevated protection setting, we
sent emails and did Interactive Voice Response (IVR) call-outs (recorded phone messages)to
all customers on the impacted circuits, including times we planned to go into the elevated mode.
While the existing communications and outreach plan and framework provide a solid foundation
to build from, successful and effective implementation of a Public Safety Power Shut Off(PSPS)
requires its own dedicated effort and strategy.
The first step, before wildfire season begins, is to educate customers about PSPS and what it
means for them and their communities. Corporate Communications will work on a campaign to
bring awareness to all wildfire resiliency efforts and outage preparedness. We will also work in
coordination with community outreach efforts to support their initiatives and strategies. The
community outreach work is separate from this notification plan, which is more tactical in
implementing a PSPS.
During a PSPS Event
When a PSPS event is being considered, the following strategies and actions will be
implemented:
• Communications will be integrated into the Pre-EOP/EOP structure to receive the most
up-to-date information and thoroughly understand the potential impact to customers.
• Communications will develop messages based on the situation, including messages for
each stage of the event.
• Communications will receive the list of customers on impacted circuits and share with all
departments that need the information, such as customer service and community
outreach.
• Communications will determine executive availability and identify media spokespeople
at the executive and management levels.
o Determine appropriate spokespeople for different events like press conferences,
media updates, one-on-one interviews, if needed.
• Communications will develop key talking points for the specific event, including facts,
status and steps Avista is taking.
• Communications will consult with Legal and executive leadership to approve messaging.
• Communications will determine most effective media channels.
• Communications will monitor ongoing media and social media coverage. Respond
appropriately.
• Communications will report out on ongoing communications efforts at all EOP meetings.
• Communications will update messaging as event develops and give updates to
customers at a minimum of every 24 hours after PSPS has been implemented.
Notification Methods:
• Customer email
o Repurposed for internal communication to employees
• Customer IVR callout, initiate by Customer Service with messaging from Corp Comm
• Website banner and wildfire/PSPS page updates
• Social media channels, such as Facebook
• Outage map updated
• Outage texts sent to customers
2
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Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 6,Page 34 of 36

Docusign Envelope ID: B96EE566-86D7-486D-B927-42308BC579F1
• Messages amplified by regional partners and community-based organizations
Timeline During Event:
= I - 4 4 4* ! .
When 72-48 hours 48-24 hours 4-1 hours During As soon as its PSPS is over
safe
PSPS looks Power is being Power is shut We have Restoration
What PSPS is possible necessary shut off off begun is complete
restoration
Email Email
IVR Email IVR
• Press
Text alert IVR Release
May include Press social
Email updates Release Media
Email IVR depending Social Text alert
Email IVR Social Media on Media Web
IVR Press Release estimated Web
Text alert banner
Other Social Media outage time banner end
1101H: appropriate Web banner Web banner Social webpage and
channels and webpage and webpage Media updates updatewebpage
n updates
Partner CBOs updates Outage map Web Outage Outage
Outage map banner and map to map to
webpage have have
updates updated updated
Outage ERTs ERTs
map
Coordination with Stakeholders:
Notifications to audiences outside of broad customer communications are conducted by the
following roles/teams within Avista:
• Wildfire Team
o Fire Agencies
o Emergency Medical Response Agencies
o DNR/IDL
• Regulatory Officer
o WUTC and/or IPUC
• Tribal Relations Advisor
o Any impacted Tribal partners
• RBM Team
o Local elected/community leaders
o Red Cross
o Community-based organizations
3
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Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 6,Page 35 of 36

Docusign Envelope ID: B96EE566-86D7-486D-B927-42308BC579F1
• AE Team
o Critical infrastructure
o Commercial customers
• CARES Team
o Medically vulnerable customers
• Internal Corp Comm
o Avista employees
Notification Cancellation
If conditions change and fire risk has decreased, customers will be informed that Avista will not
implement a PSPS event. All communication channels will reflect that new message. If an
elevated protection setting is still warranted, customers will be notified of that, as they may still
be more likely to experience an outage.
4
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 6,Page 36 of 36

E lx
ponent'
Cost-Benefit Analysis for
Avista Undergrounding
Projects
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 7, Page 1 of 61

Exponent'
Cost-Benefit Analysis for Avista Undergrounding Projects
Prepared For:
Heather Webster
Manager Asset Maintenance Program Delivery
Avista Corp.
Spokane, WA 99202
Prepared By:
�� omf��
Ezra Jampole, Ph.D., P.E. Kristen Hollingsworth, Ph.D.
Exponent, Inc.
149 Commonwealth Drive
Menlo Park, CA 94025
October 30, 2024
© Exponent, Inc.
Page ii 2407043.000-9196 Exhibit No. 11
tplver1.0
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October 30, 2024
Contents
Page
List of Figures v
List of Tables vi
Limitations vii
Executive Summary 1
Project Background 3
Cost-Benefit Analysis Components 4
Methodologies 5
Outages Customer Impacts Analysis 5
Outage Direct Costs 21
Operations and Maintenance 24
Vegetation Management 24
Other O&M 26
Wildfire Losses 26
Wood Poles Failure Rates 30
Overview of Methodology 30
Hazard Curves 32
Fragility Curves 34
Calculated Wood Pole Failure Rates 41
Calculating Benefit-Cost Ratios 41
Costs of Undergrounding 43
Cost-Benefit Analysis Results 44
Recommendations for Future Study 49
Rationale for Incorporating Scenario Risk Analysis 51
Fat-tailed distributions and uncertainty 51
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Scenario risk analysis as a complementary method 53
Application to Avista's Proposed Undergrounding Projects 53
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October 30, 2024
List of Figures
Page
Figure 1. Total customer count(top) and total customer outage hours (bottom)for each outage
reason and subreason combination. 6
Figure 2. Total customer count(top) and total customer outage hours (bottom) for each feeder
where the feeder names are shown for visual context only and not intended to be
legible. 7
Figure 3. Distribution of total feeder lengths and proposed undergrounded feeder lengths for
370 and 195 feeders,respectively. 8
Figure 4. Distribution of total customers per feeder for 384 feeders. 8
Figure 5. Distribution of mitigated interruption costs per year for 195 feeders with proposed
undergrounding. 21
Figure 6. Distribution of mitigated direct costs per year for 195 feeders with proposed
undergrounding. 24
Figure 7. Histogram of vegetation management costs per year per mile for each feeder. 25
Figure 8. Example Hexes from Avista's Consequence Analysis. 27
Figure 9. Proportion of wildfires and acres burned in California caused by electric power from
2016 to 2020. 28
Figure 10. Sample hazard curve (left)and fragility curve(right). 32
Figure 11. Contours from ASCE Hazard Tool for 300-year wind speed. 33
Figure 12. Contours from ASCE Hazard Tool for 700-year wind speed. 33
Figure 13. Example wind speed hazard curve and underlying MRI data. 34
Figure 14. Loss of strength and increased dispersion as wood poles age(from EPRI, 1986). 35
Figure 15. Histogram of wood pole ages for each shell rot condition code. 38
Figure 16. Estimate of Remaining Strength as a function of age;used in the absence of shell rot
condition code or explicit measurement of remaining strength. 39
Figure 17. Example relationship between pole age and fragility curve dispersion parameter,/3. 40
Figure 18. Histogram of estimated wood pole annual failure rates. 41
Figure 19. Distribution of the estimated cost to underground for 177 feeders. 43
Page v 2407043.000-9196 Exhibit No. 11 E�j TM
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Schedule 7,Page 5 of 61

October 30, 2024
List of Tables
Page
Table 1. System-Wide Parameters Calculated Using All Available Outages 11
Table 2. Feeder Specific Outage Rates for Feeders with Proposed Undergrounding 12
Table 3. Proportion Mitigation Effectiveness due to Undergrounding 16
Table 4. Example Outage Benefit Calculation for a Feeder 17
Table 5. Outage Benefit Analysis Results for Feeders with Proposed Undergrounding 18
Table 6. Example Mitigated Annual Direct Cost Calculation for a Feeder 22
Table 7. Assumed remaining strength for different shell rot conditions. 37
Table 8. Mapping of Age to Remaining Strength 38
Table 9. Cost-Benefit Analysis Results by Feeder 44
Page vi 2407043.000-9196 Exhibit No. 11 IX TM
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October 30, 2024
Limitations
The study presented in this report is intended for use by Avista Corp. to assist with their
decisions regarding underground sections of their distribution feeders. Proper application of this
report requires recognition and understanding of the limitations of both the scope and
methodology of the study.
The risk assessment methodology forming the basis of the results presented in this report is
based on mathematical and statistical modeling of physical systems and processes as well as data
from third parties. Given the nature of these evaluations, significant uncertainties are associated
with the various hazard and loss computations, some of which are accounted for in the
methodology, while other uncertainties such as as-built construction details, modifications,
current conditions, material characteristics, among others cannot be explicitly incorporated into
the analyses. These uncertainties are inherent in the methodology and subsequently in the
generated hazard and loss results. These results are not facts or predictions of the loss that may
occur as a result of future events or any specific event; as such, the actual losses may be
materially different from those presented in this study. Furthermore, the assumptions adopted in
determining these loss estimates do not constitute the exclusive set of reasonable assumptions,
and the use of a different set of assumptions or methodology could produce materially different
results.
Page vii 2407043.000-9196 Exhibit No. 11 EXrM
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V.Malensky,Avista
Schedule 7,Page 7 of 61

Executive Summary
This study contains a cost-benefit analysis ("CBA") of selected portions of feeders on Avista's
overhead to inform potential distribution undergrounding projects on around 190 feeders in
Washington and Idaho. The purpose of the undergrounding projects is to improve reliability and
reduce the likelihood of an Avista-caused ignition and consequent wildfire. The analysis
contained herein considers three key components that are relevant to utilities: safety, reliability,
and direct financial considerations. Safety considers the economic value associated with loss of
life and injuries; reliability considers the financial impact of service outages; and direct financial
considers includes directs costs of implementing undergrounding projects, direct costs from
outages, and operations and maintenance ("O&M") costs.
Fundamentally, the CBA calculates benefit-cost ratios ("BCR") for each potential
undergrounding project. The BCR is the ratio of the benefits of undergrounding, i.e., the sum of
the reduced costs over the expected life of the project, assumed to be 76.5 years, divided by the
costs associated with the undergrounding project. Ultimately, all benefits and costs are translated
to a monetary figure to be included in the BCR calculation. A discount rate of 6.89%was used,
to be consistent with other Avista investment decisions. A BCR greater than 1 indicates that the
benefits exceed the costs, suggesting that the undergrounding project on that feeder is financially
advisable. Conversely, a BCR less than 1 indicates that the costs exceed the benefits, suggesting
that the undergrounding project on that feeder is not financially advisable.
The benefits are calculated using a variety of methodologies:
• Reliability benefits are calculated by estimating rates of outages with and without an
undergrounding project. Analysis of historical outages from around 40 mechanisms was
undertaken, with statistical checks for whether each mechanism's outage rate (outages
per mile per year) is feeder-specific, or if a general rate is applicable to the mechanism.
The effectiveness of the undergrounding mitigation was estimated based on subject
matter expertise and engineering judgement. Combined initial outage rates with
mitigation effectiveness and customer counts, the change in expected number of outages
is computed. This is translated to a dollar value using Avista-specific customer
interruption costs for Washington and Idaho.
• Changes in direct costs are estimated based on historical costs of outages and the change
in outage rates.
• Changes in O&M costs are calculated based on historical Avista data on maintenance
costs for overhead and underground feeders and the length of each feeder that is intended
to be undergrounded.
• Reductions in costs associated with Avista-caused wildfire are calculated by apportioning
expected annual losses from FEMA's National Risk Index to utility-caused fires, and to
specific feeders based on the relative risk and estimated wood pole and tree fall failure
rates along the feeder. Wood pole failure rates were calculated using fragility curves,
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October 30, 2024
relating wind speed to probability of failure, and hazard curves, relating frequency of
exceedance to wind speed, with reference to remaining strength and pole condition from
test and treat data.
• Costs associated with undergrounding projects were provided by Avista and consider
fixed costs associated with project labor, civil construction costs, truck and lateral build
costs, distribution automation costs, and service transfer and overhead wreckout costs.
Calculated BCRs range from values of 0.06 to 11, indicating that there is varying financial utility
in performing specific undergrounding projects. While some of the proposed undergrounding
projects have BCR values less than 1, components of the analysis that consider contributions to
the "benefits" consider both the consequence and the frequency of the consequence. In
particular, the wildfire frequency, which is typically low, is considered in FEMA's calculation of
wildfire losses, which informed this study. However, a catastrophic wildfire would have drastic
consequences far exceeding the cost of any undergrounding projects, if it were to occur,
potentially causing irreparable harm to Avista and its customers. It is thus worth considering the
severity of the consequences, independent of the frequency of their occurrence, as part of the
decision-making process for undergrounding. Scenario-based risk analysis, which considers only
consequences and no probability, is a valid academic exercise for making decisions on low-
probability high-consequence hazard mitigation.
Several recommendations for further study were identified through the course of this analysis:
• Wildfire consequence modeling that explicitly estimates structures burned, acres burned,
and lives lost, as well as estimates of ignition probabilities along specific feeders, would
improve the wildfire cost portion of the model;
• Data collection of remaining pole strength and connectivity between poles and
conductors would enable more sophisticated fragility-based analysis of poles, which
informs the wildfire model.
• The current analysis only considers undergrounding projects specifically identified by
Avista, however, optimization strategies could be used to identify projects with high
BCRs;
• Other contributors to costs and benefits, such as aesthetic benefits (home values),
construction-associated injuries and fatalities, and economic impact on ratepayers could
be considered.
Page 2 2407043.000-9196 Exhibit No. 11 E�j TM
Case No.AVU-E-25-01
V.Malensky,Avista
Schedule 7,Page 9 of 61

October 30, 2024
Project Background
Avista is currently preparing its Wildfire Resiliency Plan("WRP")update for calendar year
2024. In conjunction with that plan, Avista is considering strategically undergrounding sections
of their distribution system to reduce wildfire risk. Exponent has been asked to perform a cost-
benefit analysis for undergrounding projects being considered on a feeder-by-feeder basis.
Exponent has performed a cost-benefit analysis of undergrounding projects on each selected
feeder, considering costs (estimated by Avista), and the benefits derived from the expected
reduction in consequences considering life-safety, economic loss,protection of property, and
customer outage duration. Quantitative risk analysis techniques have been used throughout the
assessment. The analysis has produced benefit-cost ratios for the projects proposed on each
feeder, considering the estimated project design life.
Page 3 2407043.000-9196 Exhibit No. 11 E�j TM
Case No.AVU-E-25-01
V.Malensky,Avista
Schedule 7,Page 10 of 61

October 30, 2024
Cost-Benefit Analysis Components
Cost-benefit analyses for utility projects typically consider three key components:
1. Safety: loss of life and injuries to people and property associated with the
projects, e.g., stemming from changes in wildfire risk.
2. Reliability: customers impacted by the project in terms of outage hours.
3. Financial: direct costs associated with the project, including both the cost of
executing the project and costs or benefits associated with maintenance.
Exponent has considered these three key components through a variety of analyses.
Safety:
- Loss of life and injuries to people, land, and property is considered within the
analysis of reductions in expected wildfire event rates when undergrounding
projects are implemented.
Reliability:
- Analysis of outage data including outage rates, outage durations, and customers
impacted on each feeder, combined with consideration of how undergrounding
affects the likelihood of different types of outages is used to determine the
expected change in customer-outage hours for each feeder with proposed
undergrounding segments.
Financial:
- The direct costs of implementing each undergrounding project was calculated by
Avista for each feeder. Exponent understands that these costs include restoration
and environmental considerations.
- The change in direct costs associated with outages is estimated, with
consideration to how undergrounding affects the likelihood of different types of
outages.
- The change in operations and maintenance ("O&M") costs are estimated based on
Avista's O&M historical costs for the overhead and underground components of
their system.
Page 4 2407043.000-9196 Exhibit No. 11 IX TM
Case No.AVU-E-25-01
V.Malensky,Avista
Schedule 7,Page 11 of 61

October 30, 2024
Methodologies
Outages Customer Impacts Analysis
The purpose of this analysis is to determine the benefit, in terms of dollars, due to the reduction
in frequency and duration of outages when select feeder sections are undergrounded.
To perform the outage benefit analysis, Avista provided datasets for outages, feeder lengths, and
total customers per feeder. The outage dataset contains reported outages by feeder between
January 2018 and June 2024, and categorized the outages into 38 reason and subreason
combinations. For each outage, the outage dataset includes the outage duration (hours) and the
number of customers impacted. Figure 1 shows the total customer count and total outage
duration by outage reason and subreason combination. Weather and its subreasons has the
highest total customer count and total outage duration. Figure 2 shows the total customer count
and total customer outage hours by feeder. Some feeders have more impacted customers, while
other feeders have more total outage hours. The feeder length dataset includes total overhead
(OH) feeder lengths and proposed undergrounded feeder lengths. Figure 3 shows the distribution
of the total OH feeder lengths and proposed undergrounded feeder lengths. The overhead system
is comprised of primarily shorter feeders (<25 miles) and the proposed undergrounded sections
are typically less than 10 miles. Figure 4 shows the distribution of total customers per feeder,
ranging from a few customers to around 3,500 customers.
Page 5 2407043.000-9196 Exhibit No. 11 E�j TM
Case No.AVU-E-25-01
V.Malensky,Avista
Schedule 7,Page 12 of 61

October 30, 2024
600
500
o
U a 400
m
a o 300
t
U 200
co
a 100
H
0
U) 6
= 5
c6 n 4
0 .2
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a� E
g �2
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U 1
m
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�oco � 5 �oc.\a o�e e nod'5,tiO� Or oc�ceeee`°ee�e\c` ec
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t�,�4Q�\\�`�•Q�`�`��`�J\e�o-J\Q pJ Q,d,4�,r`Q.�Q�P� Q,���
Q.4J4J\�.dJ4J\4J\Q�'c3 �4 Q. J\Q J\Q�'p��\• �O
Outage Reason: Subreason
Figure 1. Total customer count (top) and total customer outage hours (bottom)for each
outage reason and subreason combination.
Page 6 2407043.000-9196 Exhibit No. 11 TM
Case No.AVU-E-25-01 JJ
V. Malensky,Avista
Schedule 7,Page 13 of 61

October 30, 2024
80
o —60
U N
`m C:
co
o 5 40
fn 0
7 aL+
U �_
Fa 20
H
0
500
y
0
x 400
0
� rn
m
300
O N
E w 200
0
U 100
m
F
0 _
3 ..= R
Feeder Name
Figure 2. Total customer count (top) and total customer outage hours (bottom) for each
feeder where the feeder names are shown for visual context only and not
intended to be legible.
Page 7 2407043.000-9196 Exhibit No. 11 E/Vj rM
Case No.AVU-E-25-01
V.Malensky,Avista
Schedule 7,Page 14 of 61

October 30, 2024
90
OTotal Feeder Length
80 0 Proposed Undergrounded Feeder Length
70
;n 60
50
0
�5 40
E
Z 30
20
10
0
0 50 100 150 200
Feeder Length (mi)
Figure 3. Distribution of total feeder lengths and proposed
undergrounded feeder lengths for 370 and 195
feeders, respectively.
60
50
E 40
0)
-a
LL
am
0 30
s
E
Z 20
10
0
0 500 1000 1500 2000 2500 3000 3500 4000
Total Customers per Feeder
Figure 4. Distribution of total customers per feeder for 384
feeders.
Page 8 2407043.000-9196 Exhibit No. 11 E/VTM
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 7,Page 15 of 61

October 30, 2024
The provided datasets were used to determine the benefit associated with reduced customer
hours interrupted due to undergrounding projects on each feeder, which we refer to as the
mitigated cost. The procedure to determine the mitigated cost is as follows:
l. The outage rate is the frequency of service interruptions per unit feeder length. The
outage rate for an outage reason and subreason combination could be specific to the
feeder or be consistent system-wide. For example, a feeder may be located in an area
with more squirrels, which would increase the frequency of ANIMAL: Squirrel outages
for that feeder relative to other feeders. Conversely, a certain EQUIPMENT OH related
outage may equally affect all feeders because the equipment is subject to random failures
and relatively unaffected by age or environmental factors. For each outage reason and
subreason combination (o), the feeder specific or system-wide outage rate (R°)
(outages/yr./mi.) is determined according to:
outages°
_ t x ELF
system-wide
R° — outages°,F
lfeeder specific
txLF
Where outages°,F is the number of outages on a specific feeder (F) for an outage reason
and subreason combination, outages° is the number of outages for an outage reason and
subreason combination, t is the time (yrs.) over which the outages occurred, LF is the
length of feeder, and Z LF is the total length of all considered feeders. The system-wide
and feeder specific outage rates are shown in Table 1 and Table 2, respectively.
2. For an outage reason and subreason combination, statistical significance checks were
performed to determine whether outage rates for each subreason are likely to be feeder-
specific or if it is more appropriate to apply the system-wide outage rate. The designation
for whether the outage rate is feeder-specific or uses a system-wide rate for each outage
reason and subreason combination is provided in Table 1.
3. It is assumed that the proportion of customers impacted by an outage is specific to the
outage reason and subreason combination,but not feeder-specific. For each outage
reason and subreason combination (o), the average proportion of customers impacted by
an outage (CI°) is determined as follows:
n
1 Custlmpi,F
_
CIO n I CustTotF
Where n is the number of outages for an outage reason and subreason combination,
Custlmpi,F is the customers on feeder F impacted by outage instance i, and CustTotF is
the total number of customers on feeder F.
Page 9 2407043.000-9196 Exhibit No. 11 EX rM
Case No.AVU-E-25-01
V.Malensky,Avista
Schedule 7,Page 16 of 61

October 30, 2024
4. It is assumed that the duration of outages is specific to the outage reason and subreason
combination,but not feeder-specific. For each outage reason and subreason combination
(o), the average duration of an outage (Do) is determined as follows:
n
1
Do = n Di
i=1
Where n is the number of outages for an outage reason and subreason combination and
Di is the duration (hours) of outage instance L
5. The annual customer outage-hours per feeder(ACOHF) is determined using parameters
determined from the outage dataset as follows:
°total
ACOHF = Y, Ro LF CustTotF CIO Do
0=1
Where ototai is the total number of outage reason and subreason combinations. The
calculated parameters are shown in Table 1, Table 2, and Table 5.
6. The mitigated annual customer outage-hours is the reduction in customer outage hours if
the proposed undergrounding projects are completed. The mitigated annual customer
outage-hours per feeder(Mitigated ACOHF) is determined using parameters related to
undergrounding according to:
Ototal
Mitgated ACOHF = Y, ACOHF UGF MEo
0=1
Where °total is the number of outage reason and subreason combinations, UGF is the
proportion of the feeder that is proposed to be undergrounded (see Table 5), and MEo is
the proportion mitigation effectiveness of undergrounding to reduce outages for the
outage reason and subreason combination (see Table 3). An example of the calculation of
Mitigated ACOHF for a feeder is shown in Table 4.
7. For each feeder, the interruption cost per customer outage-hour, ClCostF, was
determined using the state specific interruption cost and the proportion of poles on the
feeder located in that state. Avista provided the interruption costs per customer outage-
hour of$94.62/hr. and $127.37/hr. for Washington and Idaho, respectively. For a limited
number of poles located in Montana, the Idaho interruption costs per customer outage-
hour were used.
8. The mitigated annual interruption cost is the reduction in annual costs if the proposed
undergrounding projects are completed and is calculated as follows:
Mitgated AICostF = Mitgated ACOHF x ClCostF
Page 10 2407043.000-9196 Exhibit No. 11 EX rM
Case No.AVU-E-25-01
V.Malensky,Avista
Schedule 7,Page 17 of 61

October 30, 2024
An example of the calculation for one feeder is shown in Table 4.
The feeder-specific annual reduction in costs associated with customer interruptions is shown in
Table 5 and Figure 5. Table 5 shows the results for 195 feeders with proposed undergrounding,
and Figure 7 shows a histogram of the mitigated annual interruption costs provided in Table 5.
Table 1. System-Wide Parameters Calculated Using All Available Outages
Outage Reason: Feeder Specific or System-Wide R. Do (hrs.) Clo
Subreason System-Wide Outage Rate? (outages/yr./mi.)
ANIMAL: Bird Feeder Specific N/A 1.69 0.037
ANIMAL:Other System-Wide 0.00327 1.88 0.053
ANIMAL: Protected System-Wide 0.00018 1.60 0.073
ANIMAL:Squirrel Feeder Specific N/A 1.46 0.015
COMPANY:Other System-Wide 0.01059 1.39 0.150
EQUIPMENT OH: Feeder Specific N/A 2.05 0.049
Arrester
EQUIPMENT OH: System-Wide 0.00018 2.38 0.121
Capacitor
EQUIPMENT OH: System-Wide 0.01047 3.24 0.149
Conductor-Pri
EQUIPMENT OH: Feeder Specific N/A 2.01 0.005
Conductor-Sec
EQUIPMENT OH: Feeder Specific N/A 2.61 0.081
Connector-Pri
EQUIPMENT OH: System-Wide 0.00828 1.82 0.004
Connector-Sec
EQUIPMENT OH: System-Wide 0.00164 3.15 0.093
Crossarm-rotten
EQUIPMENT OH: Feeder Specific N/A 2.29 0.032
Cutout/Fuse
EQUIPMENT OH: System-Wide 0.00247 2.92 0.226
Insulator
EQUIPMENT OH: System-Wide 0.00142 2.86 0.102
Insulator Pin
EQUIPMENT OH:Other System-Wide 0.00373 2.30 0.078
EQUIPMENT OH: Pole- System-Wide 0.00112 4.59 0.020
rotten
EQUIPMENT OH: System-Wide 0.00030 2.38 0.523
Recloser
EQUIPMENT OH: System-Wide 0.00020 2.60 0.339
Regulator
EQUIPMENT OH: System-Wide 0.00040 1.40 0.417
Switch/Disconnect
EQUIPMENT OH: Feeder Specific N/A 3.88 0.025
Transformer-OH
EQUIPMENT OH:Wildlife System-Wide 0.00002 4.39 0.009
Guard
MISCELLANEOUS:SEE System-Wide 0.00114 2.38 0.004
REMARKS
POLE FIRE: Pole Fire System-Wide 0.00890 4.47 0.230
PUBLIC:Car Hit Pole Feeder Specific N/A 3.03 0.247
PUBLIC: Fire Feeder Specific N/A 1.54 0.013
PUBLIC:Other Feeder Specific N/A 1.82 0.040
PUBLIC:Tree System-Wide 0.00403 2.87 0.074
Page 11 2407043.000-9196 Exhibit No. 11 �j �jTM
Case No.AVU-E-25-01 JJ
V. Malensky,Avista
Schedule 7,Page 18 of 61

October 30, 2024
Outage Reason: Feeder Specific or System-Wide R. Do (hrs.) CIo
Subreason System-Wide Outage Rate? (outages/yr./mi.)
TREE:Service Feeder Specific N/A 2.05 0.003
TREE:Tree Fell Feeder Specific N/A 3.15 0.099
TREE:Tree Growth Feeder Specific N/A 1.93 0.032
TREE:Weather Feeder Specific N/A 5.63 0.071
WEATHER:Heat System-Wide 0.00004 7.96 0.002
WEATHER:Lightning Feeder Specific N/A 3.99 0.070
WEATHER:Snow/Ice Feeder Specific N/A 10.29 0.063
WEATHER:Wildfire System-Wide 0.00030 9.57 0.497
WEATHER:Wind Feeder Specific N/A 17.22 0.074
UNDETERMINED: Feeder Specific N/A 2.10 0.098
Undetermined
Table 2. Feeder Specific Outage Rates for Feeders with Proposed Undergrounding
Feeder Specific Ro (outages/yr./mi.)
ANIMAL EQUIPMENT OH PUBLIC TREE WEATHER UNDETER-
MINED
U =
- O
C0 (L
y L �
ULL d O N E
Feeder a o r o C
Name* a` C) C) L U LL o U) � U m U) D
9CE12F4 0.018 0.036 0 0.036 0 0 0 0.054 0.073 0.036 0.018 0.018 0 0 0.018 0.054 0.109 0.073
9CE12F6 0.018 0.018 0.036 0.009 0 0 0 0.0180.0180 0.009 0.118 0.018 0 0 0.236 0.517 0.018
AIR12F1 0.033 0.047 0.014 0 0.003 0.011 0.011 0.017 0.003 0.008 0 0 0.003 0 0.019 0.006 0.053 0.022
AIR12F2 0.045 0 0.011 0.011 0.011 0.011 0 0.123 0.034 0.011 0 0 0 0 0.011 0.034 0.056 0.034
AIR12F3 0.110 0 0 0 0 0.027 0 0 0.055 0.027 0 0 0 0 0.027 0.027 0.055 0.055
APW112 0.023 0.058 0.023 0.035 0.023 0.012 0.012 0.081 0.058 0.012 0.035 0.070 0.012 0.012 0.058 0.023 0.336 0.104
APW113 0.026 0.026 0.013 0 0 0.026 0.013 0.013 0 0 0 0.052 0.039 0.026 0.026 0.091 0.389 0.065
ARD12F2 0.044 0.019 0.003 0.005 0.022 0.011 0.003 0.008 0.022 0.005 0 0.047 0.003 0.005 0.069 0.077 0.069 0.159
AVD151 0.014 0.054 0.020 0 0 0.020 0.014 0.020 0.034 0.014 0 0.047 0.007 0.007 0.014 0.054 0.440 0.027
AVD152 0.040 0 0.027 0 0 0.027 0.013 0.053 0.053 0 0.027 0.013 0.053 0 0 0.080 0.306 0.067
BEA12F2 0.056 0.152 0.008 0.032 0.016 0.024 0.016 0.064 0.032 0.040 0.024 0.040 0.032 0.024 0.008 0.112 0.176 0.080
BEA13T09 NaN NaN NaN NaN NaN NaN NaN NaN NaN NaN NaN NaN NaN NaN NaN NaN NaN NaN
BIG411 0.032 0.011 0 0.011 0.021 0 0.011 0 0.021 0 0.011 0.159 0.011 0.021 0 0.042 0.127 0.117
BIG412 0 0 0 0.023 0 0 0.023 0 0.047 0.023 0 0.094 0 0.023 0 0.070 0.329 0.023
BIG413 0 0 0 0 0 0 0 0 0 0 0 0.183 0 0.061 0 0 0.122 0.061
BKR12F1 0.090 0.090 0 0 0 0 0 0 0.090 0.030 0 0.030 0.030 0 0 0 0.179 0.060
BKR12F2 0.110 0.028 0.055 0 0 0 0.028 0.055 0.083 0.028 0 0.055 0 0.028 0 0 0 0.028
BKR12F3 0.080 0.080 0 0 0.013 0.013 0 0 0.027 0 0.027 0.013 0 0.013 0.013 0.027 0.094 0.027
BLA311 0 0.019 0.010 0 0 0.024 0.014 0.014 0.005 0 0 0.062 0 0.033 0.019 0.024 0.163 0.053
BLD12F4 0.130 0.142 0.012 0.036 0 0.012 0.047 0.047 0.036 0.012 0 0 0 0.012 0.047 0.024 0.107 0.107
BLD12F5 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
BLD12F6 NaN NaN NaN NaN NaN NaN NaN NaN NaN NaN NaN NaN NaN NaN NaN NaN NaN NaN
BLU321 0.026 0.016 0.013 0.023 0.005 0.016 0.003 0.018 0 0.010 0.005 0.109 0.016 0.010 0.005 0.116 0.287 0.067
BLU322 0.039 0.024 0.016 0.024 0 0.008 0 0.016 0.008 0.024 0 0.087 0 0 0.024 0.087 0.623 0.032
BUN423 0.100 0.025 0 0.025 0.025 0.050 0.025 0.050 0.025 0.025 0 0.025 0.025 0.050 0 0.100 0.100 0.075
BUN424 0 0 0 0 0 0 0 0 0 0 0 0.078 0 0 0.039 0.039 0.233 0.039
BUN426 0.019 0.152 0.038 0.076 0 0.019 0.019 0.152 0.019 0.038 0.019 0 0 0.019 0.019 0.057 0.114 0.152
CDA123 0.008 0.015 0.054 0.054 0 0.008 0.008 0.015 0.046 0.015 0.008 0.108 0.008 0.023 0.015 0.132 0.774 0.054
CDA125 0 0.127 0.020 0.039 0.010 0 0.029 0.127 0.029 0.020 0.029 0.059 0.049 0.020 0 0.117 0.536 0.068
CFD1210 0.212 0.234 0.032 0.011 0.021 0.021 0.011 0.011 0.011 0 0 0.011 0.011 0 0.032 0 0.021 0.106
CFD1211 0.028 0.068 0.006 0.017 0.006 0.006 0.006 0 0.011 0.006 0.011 0.023 0.028 0.011 0.023 0 0.023 0.051
CGC331 0 0 0 0 0 0 0 0 0 0 0 0.095 0 0 0 0 0.190 0
CHE121=1 0.010 0.077 0.039 0 0.010 0.010 0.010 0.029 0 0 0 0.068 0.010 0.010 0 0.135 0.396 0.077
CHE12F4 0.026 0.034 0 0.009 0 0 0.009 0.009 0.009 0 0.017 0.052 0.009 0.043 0.009 0.121 0.259 0.034
Page 12 2407043.000-9196 Exhibit No. 11 EX TM
Case No.AVU-E-25-01
V.Malensky,Avista
Schedule 7,Page 19 of 61

October 30, 2024
Feeder Specific Ro (outages/yr./mi.)
ANIMAL EQUIPMENT OH PUBLIC TREE WEATHER UNDETER-
MINED
U
a) - C•
N L N
`o o =3 E ° c
5 `m a -0 `-' `m
LL
Feeder -a c c ° c = a) (D m O C-o En 3 m
Name* m �n a` ci ci ii o in � in D
CHW12F2 0.076 0.037 0.003 0.009 0 0.033 0.021 0.012 0.006 0.015 0.006 0.061 0.012 0.018 0.049 0.064 0.055 0.152
CHW12F3 0.026 0.021 0.003 0.005 0.002 0.016 0.011 0.007 0.007 0 0 0.051 0.003 0.016 0.015 0.102 0.082 0.130
CHW12F4 0.048 0.030 0.003 0.010 0 0.028 0.008 0.005 0.005 0.005 0.005 0.050 0.005 0.003 0.033 0.098 0.103 0.196
CKF711 0.023 0.023 0.005 0.009 0 0.019 0.014 0.009 0 0.005 0 0.107 0.014 0.014 0.014 0.009 0.173 0.042
CKF712 0.049 0.038 0 0 0 0.005 0.011 0.005 0.005 0.005 0 0.070 0.005 0.005 0.022 0.032 0.291 0.054
CLA56 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0.046 0.015
CLV12F2 0.020 0.037 0.010 0.013 0.017 0.023 0.010 0.020 0.013 0.023 0.007 0.053 0.007 0.017 0.017 0.067 0.073 0.104
CLV12F4 0.077 0.040 0.009 0.006 0.020 0.031 0.014 0.014 0.014 0.003 0.006 0.049 0.006 0.017 0.020 0.086 0.083 0.140
CLV34F1 0.038 0.006 0.010 0.004 0.004 0.035 0.010 0.007 0.006 0.008 0.001 0.064 0.003 0.017 0.045 0.088 0.080 0.143
COB12F1 0.026 0.046 0.013 0 0.020 0.013 0.007 0 0.007 0.007 0 0.065 0.013 0.033 0.026 0.124 0.163 0.052
C0612F2 0.059 0.009 0.015 0.006 0.006 0.006 0.006 0.027 0.012 0.003 0 0.006 0.009 0.006 0.024 0.062 0.035 0.053
COT2401 0.035 0.014 0 0 0.021 0.014 0.028 0.028 0 0 0.007 0.007 0.014 0 0.014 0.035 0.049 0.028
CRG1261 0.004 0.004 0 0.004 0.004 0.004 0.011 0 0.015 0 0 0.011 0.004 0.004 0.038 0.019 0.023 0.034
DAL131 0.057 0.081 0.049 0.024 0.016 0.016 0.008 0.016 0.016 0.040 0.008 0.049 0.016 0.016 0.008 0.040 0.429 0.049
DAL132 0 0.063 0.126 0 0 0.063 0 0.189 0.032 0.063 0 0 0 0.032 0 0 0.790 0
DAL133 0.012 0.061 0.012 0.012 0 0 0.012 0.012 0.012 0.024 0.024 0.134 0 0.049 0 0.012 0.268 0.061
DAL135 0.052 0.069 0 0 0 0.035 0 0 0.017 0 0 0.017 0.017 0 0.017 0 0.225 0.035
DAL136 0.020 0.020 0 0.039 0 0.020 0.020 0.020 0 0.020 0 0.020 0 0 0 0 0.610 0
DEP12F1 0.050 0.013 0.003 0.010 0 0.018 0.008 0.013 0.010 0.008 0.003 0.013 0.003 0.008 0.030 0.085 0.063 0.038
DEP12F2 0.070 0.021 0 0.014 0.007 0.004 0.007 0.018 0.007 0.007 0 0.007 0.007 0 0.028 0.063 0.074 0.056
DER651 0.007 0 0.003 0.003 0.003 0.014 0.007 0 0.003 0.007 0.003 0.109 0.007 0.044 0.017 0.150 0.095 0.051
DER652 0.013 0.021 0 0.004 0.004 0.017 0.004 0.013 0.009 0 0 0.056 0.013 0.043 0.017 0.142 0.060 0.099
DRY1208 0.039 0.169 0.013 0.013 0.013 0 0.013 0.065 0.026 0.013 0.026 0.039 0.013 0 0.104 0 0.013 0.039
DRY1209 0.039 0 0.013 0.004 0.013 0.004 0.004 0.009 0.034 0 0 0.004 0 0 0.022 0.004 0.065 0.065
EFM12F1 0.087 0.045 0.014 0.010 0.003 0.007 0.007 0.010 0.010 0 0.003 0.017 0.007 0.003 0.014 0.024 0.076 0.062
EFM12F2 0.061 0.061 0 0.020 0.020 0.020 0.020 0 0 0 0 0 0 0 0 0 0.041 0
F&C12F2 0.079 0.013 0.013 0.066 0 0.013 0 0.026 0.013 0 0.013 0.026 0.013 0 0.026 0.079 0.185 0.013
FOR12F1 0.007 0.007 0.007 0 0.002 0.007 0.002 0.015 0.020 0.002 0 0.017 0.002 0 0.015 0.039 0.015 0.034
FOR121F2 0.004 0 0.004 0 0 0.004 0.004 0 0.029 0 0 0.022 0 0.004 0.007 0.029 0.076 0.004
FWT12F2 0.038 0.077 0.013 0.051 0.026 0.038 0 0.051 0.026 0.013 0 0.013 0.026 0.038 0.038 0.218 0.243 0.077
FWT12F3 0.030 0.060 0 0.030 0 0 0.120 0 0.015 0.015 0.045 0.015 0.015 0.015 0.030 0.210 0.389 0.045
GIF12F1 0.025 0.002 0.004 0.004 0.006 0.008 0.002 0.004 0.008 0 0 0.041 0.002 0.031 0.025 0.118 0.091 0.079
GIF34F1 0.044 0.004 0.005 0.005 0.005 0.012 0.004 0.003 0.005 0.001 0.001 0.027 0.002 0.003 0.028 0.038 0.061 0.099
GIF34F2 0.008 0.016 0.001 0.004 0.003 0.021 0.005 0.003 0.009 0.003 0.001 0.044 0.001 0.017 0.017 0.137 0.122 0.095
GLN12F1 0.015 0.122 0.005 0.046 0.010 0.026 0.015 0.026 0.026 0.015 0.020 0.077 0.041 0.015 0.026 0.602 0.230 0.122
GLN12F2 0.054 0.070 0.023 0.016 0 0 0.016 0.023 0 0 0.008 0.054 0.023 0.016 0 0.062 0.202 0.070
GRA12F1 0.087 0.034 0.013 0.027 0.020 0 0.020 0.040 0 0 0.013 0.027 0.013 0.020 0.013 0.013 0.087 0
GRA121`2 0.079 0.084 0.030 0.035 0.005 0.010 0.015 0.025 0.010 0.015 0.005 0.020 0.015 0.005 0.035 0.060 0.169 0.084
GRA12F3 0 0.084 0 0.042 0 0.042 0 0.155 0.014 0.028 0.014 0.028 0 0.014 0.028 0 0.112 0.028
GRN12F1 0.041 0.027 0.005 0.009 0.005 0.059 0.018 0.018 0.023 0.005 0 0.068 0.009 0.005 0.045 0.082 0.073 0.154
GRN121`2 0.036 0.033 0.004 0.007 0.015 0.025 0.004 0.015 0.011 0.004 0.004 0.047 0.007 0.022 0.047 0.112 0.080 0.170
GRN12F3 NaN NaN NaN NaN NaN NaN NaN NaN NaN NaN NaN NaN NaN NaN NaN NaN NaN NaN
GRV1271 0 0.035 0.018 0.012 0.006 0.012 0.006 0.006 0.006 0.012 0 0.065 0.012 0 0.012 0.071 0.041 0.041
GRV1272 0 0.034 0 0.017 0 0.034 0.034 0 0.034 0.017 0.017 0.017 0.034 0 0 0.102 0.034 0.051
GRV1273 0.014 0.006 0 0.004 0 0.021 0 0.002 0.008 0.006 0 0.068 0.010 0.008 0 0.054 0.016 0.060
GRV1274 0.037 0.110 0.025 0.025 0 0.012 0 0 0.049 0 0.025 0.025 0.012 0 0.012 0.123 0.061 0.037
H&W12F1 0.029 0 0 0 0 0 0.014 0.057 0.029 0 0 0 0 0 0.014 0 0.029 0.014
H&W12F3 0.023 0.028 0 0.005 0 0.014 0.014 0.019 0.019 0.005 0 0.005 0 0.023 0.033 0.028 0.108 0.028
HUE141 0.062 0.021 0.062 0.021 0.010 0.021 0 0.062 0.021 0.031 0.010 0.021 0.021 0.021 0.021 0.021 0.312 0.062
HUE142 0.068 0.010 0.029 0 0 0.029 0.010 0.068 0 0.010 0 0.010 0 0 0.019 0.058 0.087 0.068
IDR251 0.043 0.021 0 0.021 0 0 0 0.043 0 0 0 0 0 0 0 0 0 0
IDR253 0.047 0.060 0.021 0.004 0.017 0.017 0 0.072 0.009 0.009 0 0.017 0.004 0.004 0.009 0.060 0.192 0.081
INT12F1 0 0 0 0 0 0 0.097 0 0.291 0 0 0 0 0 0 0 0.485 0.097
INT12F2 0.018 0.018 0 0 0.006 0 0.006 0.012 0.006 0.018 0 0.018 0 0.006 0.006 0 0.036 0.048
JUL661 0 0.009 0 0 0 0.009 0.027 0.036 0.009 0.009 0.009 0.054 0.018 0.018 0.063 0.018 0.027 0.063
JUL662 0.006 0.036 0.012 0 0 0 0.012 0.012 0.006 0 0 0.024 0.012 0 0.012 0.030 0.036 0.047
KAM1291 0 0.068 0 0.011 0.011 0.023 0.011 0.023 0.045 0.011 0.011 0.045 0.023 0 0.101 0.034 0.034 0.079
Page 13 2407043.000-9196 Exhibit No. 11 EX TM
Case No.AVU-E-25-01
V.Malensky,Avista
Schedule 7,Page 20 of 61

October 30, 2024
Feeder Specific Ro (outages/yr./mi.)
ANIMAL EQUIPMENT OH PUBLIC TREE WEATHER UNDETER-
MINED
U
a) - C•
N L N
`o o =3 E ° c
5 `m a -0a m °' 9 o `LL (D
Feeder A= c c o c = _ a) a) m U
Name* m �n a` ci 0, ii o in it � in D
KAM1292 0 0 0 0 0.016 0.016 0 0.016 0.016 0 0 0.033 0 0 0.066 0.049 0.049 0.181
KAM1293 0.011 0.032 0.043 0.011 0.011 0.011 0.032 0 0.011 0 0.011 0.043 0 0.011 0.086 0.064 0.054 0.075
KET12F1 0 0 0 0.052 0 0 0.052 0 0.104 0 0 0 0 0.052 0.259 0.259 0.052 0
KET12F2 0.037 0.016 0.004 0.002 0.002 0.012 0.009 0 0.032 0.005 0 0.035 0.002 0.005 0.042 0.070 0.079 0.119
K001298 0.006 0.012 0.006 0 0 0 0.018 0.006 0.025 0 0.006 0.043 0 0.006 0.012 0.049 0.018 0.018
K001299 0.043 0.006 0 0 0.019 0.031 0.006 0 0.006 0.006 0.012 0.025 0.006 0.006 0.012 0.019 0.025 0.081
1-13121 1 0 0 0 0 0 0 0 0.016 0 0 0 0 0 0 0.016 0.016 0 0.032
LIB12F2 0.112 0 0.014 0 0 0.014 0 0.014 0 0.014 0.014 0 0 0 0.014 0.014 0.140 0.042
LIB12F3 0.044 0.051 0 0.022 0 0 0.007 0 0.022 0.044 0.022 0.059 0.007 0.015 0 0.029 0.139 0.102
LOL1266 0.015 0.024 0.010 0 0 0 0.005 0.029 0.024 0.010 0.019 0.015 0.015 0 0.005 0.010 0.005 0.029
1-01-1359 0.047 0.031 0.010 0.005 0.010 0.010 0.016 0.021 0.031 0.005 0.005 0.052 0.026 0.005 0.037 0 0.021 0.089
L0012F1 0.006 0.042 0.006 0.018 0 0.006 0.006 0.024 0.018 0.012 0 0.036 0.012 0.006 0.012 0.060 0.079 0.073
L0012F2 0.014 0.070 0 0.007 0.007 0 0.014 0 0.021 0.007 0.007 0.077 0.007 0.028 0.007 0.146 0.042 0.077
LTF341`1 0.020 0 0.002 0.004 0.006 0.006 0.004 0.004 0.004 0 0 0.026 0 0.004 0.018 0.032 0.074 0.044
M15514 0.019 0.107 0 0.069 0.006 0.019 0 0.032 0.038 0.006 0.019 0.025 0.013 0.057 0.013 0.164 0.234 0.063
M15515 0.024 0.033 0 0.016 0.016 0.008 0 0.033 0.049 0.033 0.008 0.008 0 0.008 0 0.041 0.049 0.073
M23621 0.016 0.005 0 0.011 0.011 0 0 0.011 0 0.005 0 0.044 0.011 0.033 0.005 0.065 0.054 0.071
MEA12F1 0 0.038 0 0 0 0 0.038 0.058 0.019 0.019 0 0.019 0.019 0.019 0.115 0.096 0.154 0.038
MEA12F2 0.042 0.116 0.011 0.021 0.021 0 0.021 0.011 0.032 0.011 0.032 0.095 0.053 0.042 0.042 0.063 0.168 0.074
MEA12F3 0 0.054 0 0 0 0 0 0 0.027 0 0 0 0 0 0 0.027 0.054 0
MIL121`3 0.127 0.064 0.025 0.038 0 0 0.013 0.038 0.013 0.013 0.025 0 0 0 0.064 0.114 0.102 0.064
MIS431 0.018 0.002 0.005 0.014 0.011 0.014 0.005 0.007 0.007 0.011 0.002 0.072 0.002 0.009 0.023 0.081 0.221 0.047
MLN12F1 0.014 0.031 0.007 0.010 0 0.017 0.007 0.041 0.017 0.007 0 0.024 0 0.014 0.010 0.099 0.075 0.038
MLN12F2 0.008 0.027 0 0.012 0.008 0.012 0.008 0 0.008 0 0.004 0.019 0 0.031 0.008 0.058 0.116 0.027
NE12F3 0.034 0.056 0.017 0 0.006 0.022 0 0.050 0.028 0.011 0.006 0.034 0.017 0.006 0.006 0.050 0.173 0.017
NE121`4 0.042 0.042 0.007 0.049 0.021 0.021 0 0.064 0.028 0.035 0.021 0.028 0 0.007 0.007 0.035 0.078 0.056
NRC351 0.067 0.067 0 0 0 0 0 0 0 0 0 0.067 0 0 0.067 0.133 0 0.200
NW12F1 0.010 0.067 0 0.019 0.010 0.019 0.010 0.038 0.029 0.010 0 0.019 0.029 0.019 0.019 0.029 0.200 0.048
NW12F2 0.064 0.140 0.025 0.025 0 0.013 0.051 0.025 0.038 0.013 0 0.089 0.025 0 0.038 0.254 0.496 0.025
NW12F3 0.011 0 0 0.033 0 0 0 0.033 0.022 0.011 0 0.033 0.022 0.033 0 0.089 0.301 0.022
ODN731 0.034 0.014 0.041 0.003 0.007 0.014 0.021 0.014 0.007 0.017 0.007 0.106 0.014 0.014 0 0.082 0.216 0.058
ODN732 0 0.032 0.021 0 0 0.011 0 0.021 0 0.011 0.011 0.086 0 0.043 0 0.021 0.428 0.043
OLD721 0.077 0.027 0.018 0 0.005 0.014 0.009 0.023 0.023 0.023 0.009 0.055 0.005 0.023 0 0.032 0.136 0.064
0RI12F1 0.023 0.020 0.005 0.005 0 0.023 0.005 0.008 0.008 0.005 0 0.067 0.005 0.018 0.028 0.105 0.097 0.102
ORI12F2 0.057 0.057 0 0.029 0.029 0 0 0 0 0 0 0 0.029 0 0.057 0.057 0.115 0.057
OR112F3 0.018 0.015 0.003 0.005 0.003 0.030 0.008 0 0.010 0 0.002 0.099 0.007 0.016 0.048 0.115 0.095 0.094
OR01280 0 0 0 0.072 0 0.036 0.018 0 0.036 0 0 0.090 0 0.018 0 0.018 0.271 0.036
OR01281 0.005 0.011 0.011 0.011 0 0.033 0.011 0 0.011 0.005 0 0.126 0.005 0.016 0.055 0.027 0.071 0.082
OR01282 0 0.056 0 0.022 0.011 0.022 0 0.011 0.022 0.011 0.011 0.056 0 0 0.022 0.011 0.112 0.078
OSB521 0.009 0.009 0 0.028 0.009 0 0.009 0.019 0.019 0.009 0.009 0.047 0.028 0 0.019 0.056 0.224 0
OSB522 0 0 0 0 0 0 0 0 0 0 0 0.194 0 0 0 0.097 0.024 0
PDL1202 0.039 0.193 0.010 0.048 0.048 0.019 0.029 0.048 0.077 0.048 0.077 0.048 0.058 0 0.097 0 0.106 0.058
PDL1203 0.069 0.233 0 0.043 0.026 0.026 0.043 0.034 0.060 0.034 0.017 0.034 0.009 0.017 0.043 0 0.069 0.086
PDL1204 0.018 0.072 0 0.036 0 0.036 0 0.054 0.018 0.018 0 0 0.018 0 0.018 0.018 0.018 0.036
PF212 0.030 0.163 0.059 0.030 0.015 0 0 0.015 0.015 0.015 0 0.015 0.030 0.030 0.045 0.015 0.282 0.059
PF213 0.066 0.121 0.011 0.011 0 0 0.022 0.055 0.044 0.022 0.011 0.044 0.033 0 0 0 0.165 0.066
PIN441 0 0.079 0.079 0.008 0.039 0.031 0.008 0.016 0.047 0 0.008 0.071 0 0.024 0.008 0.228 0.401 0.063
PIN442 0 0.037 0 0 0 0 0.056 0.019 0.056 0 0.019 0.093 0 0.037 0.037 0.037 0.243 0
PIN443 0.013 0.076 0.016 0.009 0.009 0.009 0.003 0.019 0.003 0.009 0.003 0.041 0 0.016 0.013 0.123 0.240 0.047
PRA221 0 0 0.045 0.045 0 0.045 0.022 0.067 0.022 0 0 0 0 0 0 0 0.067 0.090
PRA222 0.079 0.132 0 0 0 0.026 0 0.026 0.040 0.013 0.013 0.053 0 0 0.013 0 0.290 0.079
PRV751 0.025 0 0.025 0 0.013 0.013 0.025 0 0 0.013 0 0.075 0 0.038 0.013 0.050 0.213 0.013
PRV752 0.026 0.003 0.009 0.003 0.006 0.003 0.003 0.009 0.009 0.006 0.003 0.057 0 0.009 0.006 0.043 0.164 0.040
PVW241 0.071 0.071 0.007 0 0.057 0.014 0 0.042 0.021 0 0 0 0 0 0.007 0 0.078 0.113
PVW243 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
RAT233 0.012 0.014 0.009 0.007 0.009 0.021 0.005 0.035 0.012 0.009 0.005 0.051 0.005 0.002 0.012 0.105 0.135 0.056
RDN12F1 0.029 0.008 0.004 0.004 0.006 0.006 0.004 0.006 0.006 0 0.002 0.002 0.002 0.004 0.025 0.019 0.017 0.031
Page 14 2407043.000-9196 Exhibit No. 11 EX TM
Case No.AVU-E-25-01
V.Malensky,Avista
Schedule 7,Page 21 of 61

October 30, 2024
Feeder Specific Ro (outages/yr./mi.)
ANIMAL EQUIPMENT OH PUBLIC TREE WEATHER UNDETER-
MINED
U
cn a` �
N L �
`o o =3 E ° c
5 `m a o a °' 9 o `m
Feeder c c ° m = = Z aa) �aa) o
3 v m
Name* m �n a` 0 US ii o in in D
RDN12F2 0.008 0.004 0.002 0.004 0.011 0.015 0 0.004 0.002 0.002 0 0.013 0 0.002 0.004 0.023 0.017 0.019
SAG741 0.012 0.015 0.030 0.009 0 0.006 0.012 0.045 0.003 0.015 0.003 0.185 0.009 0.027 0.021 0.098 0.426 0.021
SAG742 0.031 0.067 0.021 0 0.005 0.005 0.016 0.041 0.005 0 0.021 0.078 0.016 0.010 0.016 0.052 0.393 0.057
SE12F2 0.065 0.032 0 0.016 0.008 0.008 0.008 0.016 0.032 0.024 0.016 0 0.008 0.008 0.008 0.040 0.202 0.040
SE121`4 0 0.084 0.028 0.042 0.028 0.014 0 0.028 0.028 0.028 0.014 0.056 0.042 0.028 0.028 0.294 0.547 0.042
SE12F6 0 0.084 0.056 0.056 0 0 0 0 0 0 0 0 0 0 0 0 0.028 0.056
SIP12F3 0.118 0 0.039 0 0 0 0.039 0.079 0 0 0 0 0 0 0 0 0 0.158
SIP12F4 0.134 0.149 0.015 0.015 0.015 0.060 0.007 0.052 0.060 0.030 0.037 0.022 0.007 0.015 0.037 0.007 0.082 0.112
SLK121`1 0.037 0.048 0.007 0.015 0 0.004 0.004 0.007 0.029 0.011 0.018 0.022 0.007 0 0.004 0.011 0.037 0.077
SLK12F2 0.057 0.015 0.011 0.004 0.015 0.019 0.008 0.008 0 0.004 0 0.008 0.008 0.004 0.015 0.011 0.159 0.079
SLK12F3 0.018 0 0 0 0.018 0.009 0 0.044 0.018 0.009 0 0.009 0 0 0.009 0.009 0.009 0.026
SLW1348 0.087 0.319 0 0.116 0 0 0.029 0 0 0 0.116 0.029 0 0 0.029 0 0.087 0
SLW1358 0.063 0.295 0.021 0.011 0.021 0.032 0.021 0.021 0.021 0.032 0.084 0.042 0.011 0.021 0.032 0.011 0.042 0.063
SLW1368 0.059 0.163 0.030 0.044 0.015 0.030 0.015 0.015 0.044 0 0.015 0.030 0.015 0.015 0.030 0.015 0.119 0.030
SOT521 0.069 0.228 0.010 0.020 0.020 0.069 0.010 0.059 0.059 0.030 0.010 0.020 0.020 0 0.010 0 0.079 0.119
SOT523 0.106 0.032 0 0.007 0.018 0.009 0.012 0.009 0.002 0.005 0 0.016 0.007 0.002 0.021 0.002 0.037 0.101
SPI121`1 0.029 0.002 0 0.004 0.004 0.002 0 0.002 0.018 0.009 0.007 0.022 0.002 0.007 0.009 0.029 0.057 0.044
SPL361 0.019 0.050 0 0.044 0.006 0.019 0.012 0.025 0.006 0.012 0.069 0.125 0.006 0.031 0.006 0.087 0.406 0.075
SPT4S21 0.016 0.054 0.037 0.004 0.004 0.021 0.008 0.012 0.004 0.004 0.004 0.103 0.012 0.066 0.016 0.049 0.334 0.091
SPT4S23 0.007 0.047 0.020 0.007 0.007 0.007 0 0.014 0.041 0.007 0.014 0.061 0 0 0.014 0.034 0.359 0.068
STM631 0.043 0.015 0.006 0.009 0.009 0.046 0.006 0.018 0.015 0 0.006 0.114 0.018 0.009 0.021 0.233 0.215 0.061
STM633 0.032 0.007 0.002 0.012 0.010 0.049 0.010 0.017 0.005 0.007 0.005 0.090 0.010 0.015 0.034 0.234 0.124 0.095
STM634 0.003 0 0.003 0.003 0 0.008 0 0 0.006 0.003 0 0.031 0 0 0.011 0.025 0.059 0.039
SUN12F1 0 0.060 0 0.048 0 0 0.012 0.036 0.024 0.012 0.024 0.084 0.060 0.024 0.012 1.222 0.863 0.060
SUN12F2 0.012 0.046 0.006 0 0 0.017 0 0.006 0.017 0.023 0.012 0.006 0.006 0.023 0.046 0.110 0.151 0.069
SUN12F4 0.019 0.019 0.006 0.019 0.006 0.026 0 0.045 0.013 0 0.006 0.013 0 0 0 0.083 0.083 0.032
SUN12F5 0.042 0.004 0.023 0.004 0 0.008 0.008 0.011 0.015 0.004 0 0.023 0.015 0.008 0.015 0.065 0.103 0.027
SWT2403 0.014 0.005 0.009 0 0.009 0.005 0 0.036 0.018 0.005 0 0.005 0.014 0 0.005 0.005 0.027 0.059
TEN1253 0.032 0 0.064 0.032 0 0.032 0 0.032 0 0.032 0.032 0 0 0 0 0 0.032 0.095
TEN1254 0.049 0.029 0.019 0.029 0 0 0.019 0.058 0.058 0.010 0.039 0.010 0.029 0 0.029 0.010 0.039 0.029
TEN1255 0.023 0.058 0.035 0.070 0.012 0 0 0.081 0.070 0.070 0 0.058 0.023 0 0.023 0 0.093 0.093
TEN1256 0.045 0 0.009 0 0.009 0 0.009 0.045 0.018 0.018 0.009 0.045 0 0 0.018 0 0.018 0.136
TEN1257 0.052 0.069 0.034 0.017 0.017 0 0.017 0.043 0.043 0.026 0.009 0.026 0 0 0.086 0 0 0.026
VAL12F1 0.007 0.015 0.006 0.004 0.003 0.017 0.004 0.017 0.017 0.007 0.003 0.037 0 0.028 0.017 0.117 0.069 0.118
VAL12F2 0.082 0.051 0 0.021 0.005 0.010 0.010 0.015 0.021 0.010 0.005 0.051 0.005 0.005 0.046 0.113 0.087 0.257
VAL121`3 0.032 0.042 0.005 0.011 0 0.037 0.026 0.042 0.016 0.021 0.021 0.042 0.011 0.047 0.016 0.137 0.131 0.184
WAK12F1 0.029 0.118 0.044 0 0 0.015 0.029 0.015 0 0.029 0.015 0.074 0.015 0 0.133 0.118 1.430 0.074
WAK121`2 0.026 0.026 0 0 0 0 0 0.064 0.013 0.013 0 0.052 0.039 0.026 0.013 0.090 0.129 0.026
WAK12F3 0 0.031 0.015 0.031 0.015 0 0 0.015 0.015 0.031 0.015 0.031 0.061 0.015 0.061 0.092 0.275 0.076
WAK12F4 0.039 0.019 0.010 0 0 0.010 0.010 0.019 0.010 0 0.0190.0390 0.019 0.010 0.087 0.107 0.155
WAL542 0.011 0.023 0.011 0.011 0.011 0 0.011 0.023 0.023 0.011 0 0.080 0.011 0.011 0 0.080 0.034 0.034
WAL543 0.004 0.016 0.008 0.004 0.004 0.016 0 0.012 0.012 0.004 0 0.140 0.004 0.029 0.016 0.095 0.115 0.025
WAL544 0.048 0.060 0.012 0.036 0.012 0.036 0 0 0.024 0.012 0 0.048 0.024 0 0 0.084 0.084 0.072
WAL545 0.012 0.012 0.023 0.012 0 0.035 0.012 0 0.046 0.012 0.023 0.104 0 0.012 0 0.058 0.150 0.046
WAS781 0.026 0 0 0.009 0.004 0.004 0.009 0.004 0.013 0.004 0 0 0.004 0 0.013 0.004 0.026 0.035
WE11289 0.004 0.011 0.004 0.011 0 0.007 0.007 0.011 0 0.004 0.011 0.076 0.011 0.036 0.025 0.079 0.029 0.036
WIL12F2 0.020 0 0.005 0.005 0.029 0.022 0.002 0.003 0.008 0 0 0.005 0 0 0.005 0.005 0.017 0.022
*NaN parameters indicate that outage data was not available for the feeder. In these cases,the system-wide outage rate was used
for analysis.
Page 15 2407043.000-9196 Exhibit No. 11 EX TM
Case No.AVU-E-25-01
V.Malensky,Avista
Schedule 7,Page 22 of 61

October 30, 2024
Table 3. Proportion Mitigation Effectiveness due to Undergrounding
Outage Reason: ME, Reasoning
Subreason
ANIMAL: Bird 1 not applicable to underground lines
ANIMAL:Other 1 not applicable to underground lines
ANIMAL: Protected 1 not applicable to underground lines
ANIMAL:Squirrel 1 not applicable to underground lines
COMPANY:Other 0.5 undergrounded lines require less frequent maintenance
EQUIPMENT OH: 0.8 undergrounded lines have fewer arresters that are typically installed at transition points or
Arrester critical equipment locations and have lower maintenance requirements
EQUIPMENT OH: 0'8 undergrounded lines have fewer capacitors for reasons including a stable operating
Capacitor environment and an inherently more efficient design
EQUIPMENT OH: 0.8 underground conductors experience fewer outages because they are more protected,but
Conductor-Pri outages do occur(e.g.,from construction or water intrusion)
EQUIPMENT OH: 0'8 underground conductors experience fewer outages because they are more protected,but
Conductor-Sec outages do occur(e.g.,from construction or water intrusion)
EQUIPMENT OH: 0'8 underground lines have fewer connectors since there are longer continuous sections and
Connector-Pri stable environmental conditions.
EQUIPMENT OH: 0.8 underground lines have fewer connectors since there are longer continuous sections and
Connector-Sec stable environmental conditions.
EQUIPMENT OH: 1 not applicable to underground lines
Crossarm-rotten
EQUIPMENT OH: 1 underground lines no not use overhead style cutouts or fuses and instead use alternative
Cutout/Fuse protective devices such as circuit breakers or protective relays
EQUIPMENT OH: underground lines have fewer insulators due to integrated cable insulation and fewer
Insulator 0'8 installation points
EQUIPMENT OH: 1 not applicable to underground lines(insulator pins are for overhead lines to support and
Insulator Pin secure the insulators)
EQUIPMENT OH:Other 0.5 underground lines have fewer equipment related outages due to reduced exposure to
physical damage and enhanced durability(robust insulation and protective sheaths)
EQUIPMENT OH: Pole- 1 not applicable to underground lines
rotten
EQUIPMENT OH: 1 underground lines generally do not use reclosers except in some advanced or specialized
Recloser installations of reclosers designed for underground environments
EQUIPMENT OH: underground lines have fewer regulators which reflects a reduced need for voltage
Regulator 0.6 regulation due to the stability of underground environments and higher cost and installation
complexity
EQUIPMENT OH: underground lines have fewer switches or disconnects due to less frequent switching points
Switch/Disconnect 0'4 and the higher cost and complexity to install/maintain
EQUIPMENT OH: underground lines have fewer transformers dur to higher cost and complexity of
Transformer-OH 0.5 installations,different design and distribution requirements,and reduced environmental
exposure.
EQUIPMENT OH:Wildlife1 not applicable to underground lines
Guard
MISCELLANEOUS:SEE 0 without more information this category is considered unmitigated by undergrounding
REMARKS
POLE FIRE: Pole Fire 1 not applicable to underground lines
PUBLIC:Car Hit Pole 1 not applicable to underground lines
PUBLIC: Fire 0 in the event of a house fire,either overhead or underground lines will be deenergized
PUBLIC:Other 0.8 outages related to the public are reduced by undergrounding since the lines are protected,
however there can still be outages(e.g.,from construction or vandalism/theft)
PUBLIC:Tree 1 underground lines are protected from tree related outages
TREE:Service 1 underground lines are protected from tree related outages
TREE:Tree Fell 1 underground lines are protected from tree related outages
TREE:Tree Growth 1 assuming canopy growth and not root growth, underground lines are protected from tree
related outages
TREE:Weather 1 underground lines are protected from tree related outages
Page 16 2407043.000-9196 Exhibit No. 11 ��jTM
Case No.AVU-E-25-01 11
V. Malensky,Avista
Schedule 7,Page 23 of 61

October 30, 2024
Outage Reason: ME, Reasoning
Subreason
WEATHER: Heat 0 when capacity is constrained on the grid,the load will be dropped for either overhead or
underground lines
WEATHER:Lightning 0.8 underground lines are less vulnerable to lightning damage,but ground strikes and voltage
surges can occur
underground lines are generally protected from snow/ice damage(snow and ice do not
WEATHER:Snow/Ice 1 have a direct effect on underground lines,but winter weather does complicate
repair/maintenance and increased use of electricity in cold weather stresses the system)
WEATHER:Wildfire 0.5 underground lines mitigate wildfire risk,but overhead and underground lines are
deenergized when any wildfire approaches
WEATHER:Wind 1 underground lines are generally protected from wind damage
UNDETERMINED: 0.91 weighted average based on number of outages from other categories
Undetermined
Table 4. Example Outage Benefit Calculation for a Feeder
Feeder Outage RO LF CustTotF CIO Do ACOHF UGF MEo Mitigated CICOstF Mitigated
Name Reason: (outages/ (mi.) (hrs.) ACOHF AICOstF
Subreason yr./mi.)
9CE12F4 ANIMAL:Bird 0.01816 8.48 1020 0.037 1.69 9.93 0.257 1 2.55 $94.62 $241.41
9CE12F4 ANIMAL:Other 0.00327 8.48 1020 0.053 1.88 2.84 0.257 1 0.73 $94.62 $68.99
9CE12F4 ANIMAL:Protected 0.00018 8.48 1020 0.073 1.60 0.18 0.257 1 0.05 $94.62 $4.44
9CE12F4 ANIMAL:Squirrel 0.03632 8.48 1020 0.015 1.46 7.04 0.257 1 1.81 $94.62 $171.20
9CE12F4 COMPANY:Other 0.01059 8.48 1020 0.150 1.39 19.01 0.257 0.5 2.44 $94.62 $231.13
9CE12F4 EQUIPMENT OH: 0 8.48 1020 0.049 2.05 0 0 $94.62 $0.00
Arrester 0.257 0.8
9CE12F4 EQUIPMENT OH: 0.00018 8.48 1020 0.121 2.38 0.45 0.09 $94.62 $8.73
Capacitor 0.257 0.8
9CE12F4 EQUIPMENT OH: 0.01047 8.48 1020 0.149 3.24 43.62 8.97 $94.62 $848.59
Conductor-Pri 0.257 0.8
9CE12F4 EQUIPMENT OH: 0.03632 8.48 1020 0.005 2.01 3.04 0.62 $94.62 $59.09
Conductor-Sec 0.257 0.8
9CE12F4 EQUIPMENT OH: 0 8.48 1020 0.081 2.61 0 0 $94.62 $0.00
Connector-Pri 0.257 0.8
9CE12F4 EQUIPMENT OH: 0.00828 8.48 1020 0.004 1.82 0.51 0.11 $94.62 $9.95
Connector-Sec 0.257 0.8
9CE12F4 EQUIPMENT OH: 0.00164 8.48 1020 0.093 3.15 4.15 1.07 $94.62 $100.82
Crossarm-rotten 0.257 1
9CE12F4 EQUIPMENT OH: 0 8.48 1020 0.032 2.29 0 0 $94.62 $0.00
Cutout/Fuse 0.257 1
9CE12F4 EQUIPMENT OH: 0.00247 8.48 1020 0.226 2.92 14.12 2.90 $94.62 $274.62
Insulator 0.257 0.8
9CE12F4 EQUIPMENT OH: 0.00142 8.48 1020 0.102 2.86 3.58 0.92 $94.62 $87.12
Insulator Pin 0.257 1
9CE12F4 EQUIPMENT OH: 0.00373 8.48 1020 0.078 2.30 5.76 0.74 $94.62 $70.05
Other 0.257 0.5
9CE12F4 EQUIPMENT OH: 0.00112 8.48 1020 0.020 4.59 0.88 0.23 $94.62 $21.40
Pole-rotten 0.257 1
9CE12F4 EQUIPMENT OH: 0.00030 8.48 1020 0.523 2.38 3.23 0.83 $94.62 $78.47
Recloser 0.257 1
9CE12F4 EQUIPMENT OH: 0.00020 8.48 1020 0.339 2.60 1.52 0.23 $94.62 $22.21
Regulator 0.257 0.6
9CE12F4 EQUIPMENT OH: 0.00040 8.48 1020 0.417 1.40 2.01 0.21 $94.62 $19.54
Switch/Disconnect 0.257 0.4
9CE12F4 EQUIPMENT OH: 0 8.48 1020 0.025 3.88 0 0 $94.62 $0.00
Transformer-OH 0.257 0.5
9CE12F4 EQUIPMENT OH: 0.00002 8.48 1020 0.009 4.39 0.01 0.00 $94.62 $0.16
Wildlife Guard 0.257 1
9CE12F4 MISCELLANEOUS: 0.00114 8.48 1020 0.004 2.38 0.10 0 $94.62 $0.00
SEE REMARKS 0.257 0
9CE12F4 POLE FIRE:Pole 0.00890 8.48 1020 0.230 4.47 79.02 20.31 $94.62 $1,921.59
Fire 0.257 1
9CE12F4 PUBLIC:Car Hit Pole0.05447 8.48 1020 0.247 3.03 352.64 0.257 1 90.63 $94.62 $8,575.26
9CE12F4 PUBLIC:Fire 0.07263 8.48 1020 0.013 1.54 12.48 0.257 0 0 $94.62 $0.00
9CE12F4 PUBLIC:Other 0.03632 8.48 1020 0.040 1.82 22.65 0.257 0.8 4.66 $94.62 $440.69
Page 17 2407043.000-9196 Exhibit No. 11 ��jTM
Case No.AVU-E-25-01 11
V. Malensky,Avista
Schedule 7,Page 24 of 61

October 30, 2024
Feeder Outage RO LF CustTotF CIO Do ACOHF UGF MEO Mitigated ClCostF Mitigated
Name Reason: (outages/ (mi.) (hrs.) ACOHF AlCostF
Subreason yr./mi.)
9CE12F4 PUBLIC:Tree 0.00403 8.48 1020 0.074 2.87 7.40 0.257 1 1.90 $94.62 $179.85
9CE12F4 TREE:Service 0.01816 8.48 1020 0.003 2.05 0.81 0.257 1 0.21 $94.62 $19.61
9CE12F4 TREE:Tree Fell 0.01816 8.48 1020 0.099 3.15 49.26 0.257 1 12.66 $94.62 $1,197.90
9CE12F4 TREE:Tree Growth 0 8.48 1020 0.032 1.93 0 0.257 1 0 $94.62 $0.00
9CE12F4 TREE:Weather 0 8.48 1020 0.071 5.63 0 0.257 1 0 $94.62 $0.00
9CE12F4 UNDETERMINED: 0.07263 8.48 1020 0.098 2.10 129.57 30.26 $94.62 $2,863.44
Undetermined 0.257 0.91
9CE12F4 WEATHER:Heat 0.00004 8.48 1020 0.002 7.96 0.00 0.257 0 0 $94.62 $0.00
9CE12F4 WEATHER: 0.01816 8.48 1020 0.070 3.99 44.14 9.07 $94.62 $858.61
Lightning 0.257 0.8
9CE12F4 WEATHER: 0.05447 8.48 1020 0.063 10.29 305.57 78.53 $94.62 $7,430.67
Snow/Ice 0.257 1
9CE12F4 WEATHER:Wildfire 0.00030 8.48 1020 0.497 9.57 12.31 0.257 0.5 1.58 $94.62 $149.61
9CE12F4 WEATHER:Wind 0.10895 8.48 1020 0.074 17.22 1199.99 0.257 1 308.39 $94.62 $29,180.26
Feeder Total 2337.81 582.70 $55,135.41
Table 5. Outage Benefit Analysis Results for Feeders with Proposed Undergrounding
Feeder Name* LF (mi.) UGF Mitigated ACOHF ClCostF Mitigated AlCostF
9CE12F4 8.48 0.257 582.70 $94.62 $55,135
9CE12F6 16.99 0.136 4,259.97 $94.62 $403,078
AIR12F1 55.37 0.656 5,062.63 $94.62 $479,026
AIR12F2 13.77 0.353 1,506.36 $94.62 $142,532
AIR12F3 5.61 0.862 150.58 $94.62 $14,247
APW112 13.28 0.136 3,516.24 $127.37 $447,864
APW113 11.86 0.310 2,172.04 $127.37 $276,652
ARD12F2 56.13 0.179 2,312.64 $94.62 $218,822
AVD151 22.72 0.782 23,822.35 $127.37 $3,034,252
AVD152 11.55 0.099 994.38 $127.37 $126,654
BEA12F2 19.28 0.125 3,176.48 $94.65 $300,665
BEA13T09 1.14 0.098 0.07 $94.62 $6
BIG411 14.50 0.556 2,210.56 $127.37 $281,559
BIG412 6.55 0.340 283.23 $127.37 $36,074
BIG413 2.53 0.853 4.04 $127.37 $515
BKR12F1 5.15 0.083 290.16 $94.62 $27,455
BKR12F2 5.59 0.395 53.23 $94.62 $5,036
BKR12F3 11.51 0.185 469.81 $94.62 $44,453
BLA311 32.20 0.756 2,953.94 $125.72 $371,377
BLD12F4 13.00 0.909 6,047.88 $94.62 $572,250
BLD12F5 0.65 0.015 0.00 $94.62 $0
BLD12F6 1.04 0.520 0.31 $94.62 $30
BLU321 59.52 0.251 14,482.21 $127.37 $1,844,599
BLU322 19.51 0.972 13,205.76 $127.37 $1,682,018
BUN423 6.14 0.030 64.47 $127.37 $8,212
BUN424 3.97 0.844 37.04 $127.37 $4,718
BUN426 8.09 0.288 373.04 $127.37 $47,514
CDA123 19.88 0.251 14,327.47 $127.37 $1,824,890
CDA125 15.79 0.079 3,431.42 $127.37 $437,060
CFD1210 14.49 0.609 1,896.81 $94.62 $179,476
CFD1211 27.03 0.406 1,084.76 $94.62 $102,640
CGC331 1.62 0.307 3.48 $127.37 $443
CHE12F1 15.93 0.010 192.48 $94.62 $18,213
CHE121`4 17.86 0.566 8,303.39 $94.62 $785,667
CHW12F2 50.61 0.418 5,324.48 $94.62 $503,802
CHW12F3 93.76 0.207 3,720.09 $94.62 $351,995
CHW12F4 61.28 0.190 2,001.91 $94.62 $189,421
CKF711 33.02 0.549 5,573.93 $127.37 $709,951
CKF712 28.52 0.210 2,055.85 $127.37 $261,854
CLA56 9.95 0.815 19.83 NaN NaN
CLV12F2 46.08 0.470 7,635.74 $94.62 $722,493
CLV12F4 53.91 0.376 8,133.53 $94.62 $769,595
CLV34F1 207.44 0.139 12,538.89 $94.62 $1,186,430
Page 18 2407043.000-9196 Exhibit No. 11 -F--I�jTM
Case No.AVU-E-25-01 11
V. Malensky,Avista
Schedule 7,Page 25 of 61

October 30, 2024
Feeder Name* LF (mi.) UGF Mitigated ACOHF CICostF Mitigated A/CostF
C0B12F1 23.63 0.819 15,611.87 $94.62 $1,477,195
COB12F2 52.05 0.897 14,660.71 $94.62 $1,387,196
COT2401 21.94 0.020 43.63 $127.37 $5,558
CRG1261 40.76 0.008 12.28 $127.37 $1,564
DAL131 19.02 0.479 13,158.38 $127.37 $1,675,982
DAL132 4.87 0.114 1,914.60 $127.37 $243,863
DAL133 12.65 0.748 6,277.74 $127.37 $799,596
DAL135 8.89 0.401 942.86 $127.37 $120,092
DAL136 7.83 0.345 3,697.06 $127.37 $470,895
DEP121`1 61.53 0.747 18,182.61 $94.62 $1,720,439
DEP121`2 43.80 0.516 8,680.69 $94.62 $821,367
DER651 45.28 0.111 922.93 $127.37 $117,554
DER652 35.90 0.370 1,953.12 $127.37 $248,768
DRY1208 11.83 0.351 741.92 $94.62 $70,200
DRY1209 35.78 0.429 443.12 $94.62 $41,928
EFM12F1 44.42 0.609 6,680.21 $95.95 $640,964
EFM12F2 7.52 0.755 519.88 $94.62 $49,191
F&C12F2 11.65 0.331 3,025.45 $94.62 $286,268
FOR121`1 62.83 0.922 3,494.44 $94.62 $330,644
FOR12F2 42.76 0.541 1,350.99 $94.62 $127,831
FWT12F2 12.03 0.036 554.68 $94.62 $52,483
FWT12F3 10.28 0.004 43.78 $94.62 $4,142
GIF12F1 79.53 0.108 1,612.53 $94.62 $152,578
GIF34F1 148.01 0.019 478.84 $94.62 $45,308
GIF34F2 114.86 0.267 9,891.06 $94.62 $935,892
GLN12F1 30.16 0.013 938.96 $94.62 $88,845
GLN12F2 19.78 0.625 11,769.76 $94.62 $1,113,655
GRA12F1 22.87 0.098 997.05 $94.62 $94,340
GRA12F2 31.04 0.690 14,216.81 $94.62 $1,345,194
GRA12F3 10.95 0.014 100.76 $94.62 $9,534
GRN12F1 33.97 0.483 5,723.35 $94.62 $541,543
GRN12F2 42.44 0.764 7,522.00 $94.62 $711,732
GRN12F3 0.36 0.021 0.00 NaN NaN
GRV1271 26.16 0.611 1,745.67 $127.37 $222,346
GRV1272 9.06 0.059 50.58 $127.37 $6,442
GRV1273 79.14 0.466 3,028.69 $127.37 $385,765
GRV1274 12.54 0.019 51.30 $127.37 $6,533
H&W12F1 10.78 0.533 87.94 $94.62 $8,321
H&W12F3 32.80 0.702 2,923.11 $94.62 $276,584
HUE141 14.79 0.105 1,632.05 $127.37 $207,875
HUE142 15.84 0.636 8,057.97 $127.37 $1,026,344
IDR251 7.16 0.920 154.89 $127.37 $19,729
IDR253 36.17 0.863 24,637.19 $127.37 $3,138,039
INT12F1 1.59 0.409 994.85 $94.62 $94,133
INT12F2 25.61 0.868 3,150.60 $94.62 $298,110
JUL661 17.01 0.009 10.08 $127.37 $1,284
JUL662 25.94 0.118 139.32 $127.37 $17,745
KAM1291 13.66 0.962 1,486.24 $127.37 $189,302
KAM1292 9.37 0.967 200.89 $127.37 $25,587
KAM1293 14.38 0.774 1,279.15 $127.37 $162,926
KET12F1 2.97 0.899 88.79 $94.62 $8,401
KET12F2 87.66 0.170 3,156.15 $94.62 $298,635
K001298 24.98 0.721 1,076.13 $127.37 $137,066
K001299 24.85 0.793 975.06 $127.37 $124,193
L1312F1 9.54 0.598 30.97 $94.62 $2,931
LIB12F2 11.00 0.494 927.97 $94.62 $87,805
LIB12F3 21.04 0.678 8,693.80 $96.08 $835,314
LOL1266 31.82 0.522 2,091.27 $127.37 $266,365
LOL1359 29.48 0.137 1,024.88 $127.37 $130,539
L0012F1 25.45 0.654 3,950.77 $94.62 $373,821
L0012F2 22.09 0.863 3,568.88 $94.62 $337,688
LTF34F1 77.21 0.411 2,464.67 $94.62 $233,207
M15514 24.37 0.075 3,023.79 $127.37 $385,141
M15515 18.87 0.035 238.84 $126.70 $30,261
M23621 28.29 0.038 162.04 $127.37 $20,639
MEA12F1 8.01 0.266 1,200.18 $94.62 $113,561
MEA12F2 14.66 0.897 8,172.88 $94.62 $773,318
MEA12F3 5.72 0.328 78.74 $94.62 $7,451
Page 19 2407043.000-9196 Exhibit No. 11 -F--I�jTM
Case No.AVU-E-25-01 11
V. Malensky,Avista
Schedule 7,Page 26 of 61

October 30, 2024
Feeder Name* LF (mi.) UGF Mitigated ACOHF CICostF Mitigated AICostF
MIL12F3 12.12 0.224 1,718.96 $94.62 $162,648
MIS431 68.33 0.045 1,138.92 $127.37 $145,064
MLN12F1 45.06 0.958 9,635.73 $94.62 $911,732
MLN12F2 39.82 0.977 9,730.13 $94.62 $920,665
NE12F3 27.51 0.305 4,497.34 $94.62 $425,539
NE12F4 21.81 0.129 1,091.80 $94.62 $103,307
NRC351 2.31 0.227 2.33 $127.37 $296
NW12F1 16.14 0.445 5,401.95 $94.62 $511,133
NW12F2 12.11 0.324 4,987.15 $94.62 $471,884
NW12F3 13.79 0.178 2,475.91 $94.62 $234,271
ODN731 44.95 0.467 14,347.82 $127.37 $1,827,482
ODN732 14.39 0.305 585.89 $127.37 $74,625
OLD721 33.84 0.901 7,638.61 $127.28 $972,273
OR112F1 60.14 0.635 7,573.39 $94.62 $716,595
OR112F2 5.38 0.867 205.04 $94.62 $19,401
OR112F3 93.55 0.237 8,236.34 $94.62 $779,323
OR01280 8.53 0.964 2,104.35 $127.37 $268,031
OR01281 28.19 0.651 3,084.71 $127.37 $392,900
OR01282 13.78 0.573 1,039.14 $127.37 $132,355
OSB521 16.48 0.260 1,542.81 $127.37 $196,508
OSB522 6.35 0.813 9.89 $127.37 $1,259
PDL1202 15.95 0.039 357.99 $94.62 $33,873
PDL1203 17.86 0.096 537.48 $94.62 $50,857
PDL1204 8.55 0.724 509.82 $94.62 $48,239
PF212 10.37 0.023 180.41 $127.37 $22,979
PF213 14.00 0.146 1,412.45 $127.37 $179,904
PIN441 19.60 0.286 4,279.37 $127.37 $545,064
PIN442 8.23 0.422 780.19 $127.37 $99,372
PIN443 48.81 0.325 10,072.47 $127.37 $1,282,931
PRA221 6.86 0.111 160.02 $127.37 $20,382
PRA222 11.67 0.077 1,172.34 $127.37 $149,320
PRV751 12.31 0.709 1,976.77 $127.37 $251,781
PRV752 53.63 0.674 13,329.75 $127.37 $1,697,811
PVW241 21.76 0.461 3,541.34 $127.14 $450,258
PVW243 1.87 0.574 8.19 $127.37 $1,043
RAT233 66.24 0.755 47,014.80 $127.37 $5,988,275
RDN12F1 79.88 0.069 257.17 $94.62 $24,333
RDN12F2 72.66 0.057 104.45 $94.62 $9,883
SAG741 51.72 0.606 28,906.30 $127.37 $3,681,796
SAG742 29.75 0.676 18,356.61 $127.37 $2,338,081
SE12F2 19.04 0.534 9,598.86 $94.62 $908,244
SE12F4 10.99 0.206 4,290.51 $94.62 $405,968
SE12F6 5.49 0.113 58.46 $94.62 $5,532
SIP12F3 3.91 0.058 3.18 $94.62 $301
SIP12F4 20.67 0.050 577.10 $94.62 $54,605
SLK12F1 41.96 0.558 3,599.40 $94.62 $340,575
SLK121`2 40.70 0.233 2,397.83 $94.62 $226,883
SLK12F3 17.48 0.820 154.71 $94.62 $14,638
SLW1348 5.31 0.694 629.69 $127.37 $80,203
SLW1358 14.64 0.077 358.75 $127.37 $45,694
SLW1368 10.38 0.267 923.22 $108.10 $99,798
SOT521 15.54 0.188 825.79 $94.62 $78,136
SOT523 66.75 0.150 852.44 $94.62 $80,658
SPI12F1 70.20 0.047 404.41 $94.62 $38,266
SPL361 24.67 0.530 15,946.81 $127.37 $2,031,145
SPT4S21 37.33 0.759 28,279.23 $127.37 $3,601,926
SPT4S23 22.71 0.059 1,497.89 $127.37 $190,786
STM631 50.15 0.576 30,549.00 $127.33 $3,889,751
STM633 63.17 0.129 4,348.90 $127.37 $553,919
STM634 54.92 0.094 538.66 $127.37 $68,609
SUN12F1 12.85 0.053 4,290.49 $94.62 $405,966
SUN12F2 26.59 0.811 15,114.56 $94.62 $1,430,140
SUN12F4 24.03 0.458 5,017.56 $94.62 $474,761
SUN12F5 40.49 0.763 5,302.42 $94.62 $501,715
SWT2403 34.11 0.283 735.56 $127.37 $93,689
TEN1253 4.85 0.058 18.65 $127.37 $2,376
TEN1254 15.86 0.106 345.71 $127.37 $44,034
TEN1255 13.28 0.100 779.63 $127.37 $99,302
Page 20 2407043.000-9196 Exhibit No. 11 EX TM
Case No.AVU-E-25-01
V.Malensky,Avista
Schedule 7,Page 27 of 61

October 30, 2024
Feeder Name* LF (mi.) UGF Mitigated ACOHF CICostF Mitigated A/CostF
TEN1256 16.98 0.290 587.35 $127.37 $74,810
TEN1257 17.86 0.089 338.27 $127.37 $43,085
VAL121`1 111.85 0.469 16,030.68 $94.62 $1,516,823
VAL12F2 30.00 0.560 2,034.90 $94.62 $192,542
VAL12F3 29.30 0.532 4,615.51 $94.62 $436,720
WAK12F1 10.44 0.589 28,438.44 $94.62 $2,690,845
WAK12F2 11.94 0.374 1,852.77 $94.62 $175,309
WAK12F3 10.08 0.133 1,200.69 $94.62 $113,609
WAK12F4 15.86 0.901 7,061.93 $94.62 $668,200
WAL542 13.55 0.115 167.31 $127.37 $21,310
WAL543 37.33 0.062 366.10 $127.37 $46,630
WAL544 12.86 0.595 1,066.57 $127.37 $135,850
WAL545 13.37 0.222 763.66 $127.37 $97,268
WAS781 34.93 0.106 63.78 $94.62 $6,035
WE11289 42.76 0.325 1,674.90 $127.37 $213,332
WIL12F2 90.56 0.009 33.96 $94.62 $3,213
Total 834,738.99 $92,801,089
'NaN results indicate that input data was not available for the feeder
60
50
40
LL
a�
a�
30
a�
E
n
Z 20
10
0
OM 1M 2M 3M 4M 5M 6M
Mitigated Interruption Cost($)/Year
Figure 5. Distribution of mitigated interruption costs per year for 195
feeders with proposed undergrounding.
Outage Direct Costs
The purpose of this analysis is to determine the direct costs related to resolving outages (and the
associated failures) for OH feeders that would be mitigated by undergrounding. The procedure to
determine the mitigated failures and outages' direct cost is described as follows:
Page 21 2407043.000-9196 Exhibit No. 11 �j �jTM
Case No.AVU-E-25-01 JJ
V. Malensky,Avista
Schedule 7,Page 28 of 61

October 30, 2024
1. Avista provided the straight time rate (STR) of$1,077.49/hr. associated with resolving
outages. This rate considers the typical composition of one work crew and assumes that
only one crew is deployed for an outage. In reality, the number of crews can be greater
than one.
2. It is assumed that the crew is deployed for the duration of the outage.
3. The annual direct cost of outages that is mitigated (on a feeder) is calculated by summing
the reduced direct costs associated with all outage reasons and subreasons, and is termed
Mitigated ADCostF, which is calculated as follows:
Ototal
Mitigated ADCostF = Y, MEo RF,o UGLF Do STR
0=1
Where ototal is the number of outage reason and subreason combinations, ME, is the
mitigation effectiveness (proportion) of undergrounding to reduce outages for the outage
reason and subreason combination, RF,o is the feeder specific or system-wide outage rate
(outages/yr./mi.) for the feeder and outage reason and subreason combination, UGLF is
the length of the feeder that is to be undergrounded, and Do is the average outage
duration (hrs.) for the outage reason and subreason combination. MEo, RF,o, and Do were
calculated as part of the outage benefit analysis and shown in Table 2 and Table 3.
The results of the failures and outages direct cost analysis are shown in Table 6 and Figure 6.
Table 6 shows an example of the calculation for one feeder, and Figure 7 shows the distribution
of the mitigated direct cost for 195 feeders with proposed undergrounding.
Table 6. Example Mitigated Annual Direct Cost Calculation for a Feeder
Feeder Outage Reason: MEo RF,o UGLF Do STR Mitigated ADCostF
Name Subreason (outages/ (mi.) (hrs.) ($/hr.)
yr./mi.)
9CE12F4 ANIMAL:Bird 1 0.01816 2.18 1.69 $1,077.49 $72.20
9CE12F4 ANIMAL:Other 1 0.00327 2.18 1.88 $1,077.49 $14.42
9CE12F4 ANIMAL:Protected 1 0.00018 2.18 1.60 $1,077.49 $0.68
9CE12F4 ANIMAL:Squirrel 1 0.03632 2.18 1.46 $1,077.49 $124.18
9CE12F4 COMPANY:Other 0.5 0.01059 2.18 1.39 $1,077.49 $17.23
9CE12F4 EQUIPMENT OR 0 2.18 2.05 $1,077.49 $0.00
Arrester 0.8
9CE12F4 EQUIPMENT OR 0.00018 2.18 2.38 $1,077.49 $0.80
Capacitor 0.8
9CE12F4 EQUIPMENT OR 0.01047 2.18 3.24 $1,077.49 $63.65
Conductor-Pri 0.8
9CE12F4 EQUIPMENT OR 0.03632 2.18 2.01 $1,077.49 $136.98
Conductor-Sec 0.8
9CE12F4 EQUIPMENT OR 0 2.18 2.61 $1,077.49 $0.00
Connector-Pri 0.8
9CE12F4 EQUIPMENT OR 0.00828 2.18 1.82 $1,077.49 $28.24
Connector-Sec 0.8
9CE12F4 EQUIPMENT OR 0.00164 2.18 3.15 $1,077.49 $12.09
Crossarm-rotten 1
9CE12F4 EQUIPMENT OR 0 2.18 2.29 $1,077.49 $0.00
Cutout/Fuse 1
Page 22 2407043.000-9196 Exhibit No. 11 -F--I�jTM
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October 30, 2024
Feeder Outage Reason: ME, RF,,, UGLF Do STR Mitigated ADCostF
Name Subreason (outages/ (mi.) (hrs.) ($/hr.)
yr./mi.)
9CE12F4 EQUIPMENT OH: 0.00247 2.18 2.92 $1,077.49 $13.55
Insulator 0.8
9CE12F4 EQUIPMENT OH: 0.00142 2.18 2.86 $1,077.49 $9.52
Insulator Pin 1
9CE12F4 EQUIPMENT OH: 0 5 0.00373 2.18 2.30 $1,077.49 $10.08
Oer9CE12F4 EQUIPMENT OH: 0.00112 2.18 4.59 $1,077.49 $12.03
Pole-rotten 1
9CE12F4 EQUIPMENT OH: 0.00030 2.18 2.38 $1,077.49 $1.68
Recloser 1
9CE12F4 EQUIPMENT OH: 0.00020 2.18 2.60 $1,077.49 $0.73
Regulator 0.6
9CE12F4 EQUIPMENT OH: 0.00040 2.18 1.40 $1,077.49 $0.52
Switch/Disconnect 0.4
9CE12F4 EQUIPMENT OH: 0 2.18 3.88 $1,077.49 $0.00
Transformer-OH 0.5
9CE12F4 EQUIPMENT OH: 0.00002 2.18 4.39 $1,077.49 $0.21
Wildlife Guard 1
9CE12F4 MISCELLANEOUS: 0.00114 2.18 2.38 $1,077.49 $0.00
SEE REMARKS 0
9CE12F4 POLE FIRE:Pole Fire 1 0.00890 2.18 4.47 $1,077.49 $93.33
9CE12F4 PUBLIC:Car Hit Pole 1 0.05447 2.18 3.03 $1,077.49 $387.16
9CE12F4 PUBLIC:Fire 0 0.07263 2.18 1.54 $1,077.49 $0.00
9CE12F4 PUBLIC:Other 0.8 0.03632 2.18 1.82 $1,077.49 $124.10
9CE12F4 PUBLIC:Tree 1 0.00403 2.18 2.87 $1,077.49 $27.12
9CE12F4 TREE:Service 1 0.01816 2.18 2.05 $1,077.49 $87.27
9CE12F4 TREE:Tree Fell 1 0.01816 2.18 3.15 $1,077.49 $134.45
9CE12F4 TREE:Tree Growth 1 0 2.18 1.93 $1,077.49 $0.00
9CE12F4 TREE:Weather 1 0 2.18 5.63 $1,077.49 $0.00
9CE12F4 UNDETERMINED: 0.07263 2.18 2.10 $1,077.49 $325.34
Undetermined 0.91
9CE12F4 WEATHER: Heat 0 0.00004 2.18 7.96 $1,077.49 $0.00
9CE12F4 WEATHER: Lightning 0.8 0.01816 2.18 3.99 $1,077.49 $136.11
9CE12F4 WEATHER:Snow/Ice 1 0.05447 2.18 10.29 $1,077.49 $1,315.63
9CE12F4 WEATHER:Wildfire 0.5 0.00030 2.18 9.57 $1,077.49 $3.36
9CE12F4 WEATHER:Wind 1 0.10895 2.18 17.22 $1,077.49 $4,405.51
Feeder Total $7,558.15
Page 23 2407043.000-9196 Exhibit No. 11 _F__1�jTM
Case No.AVU-E-25-01 11
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Schedule 7,Page 30 of 61

October 30, 2024
35
30
25
i
20
E 15
Z
10
5
0
OK 50K 100K 150K 200K 250K 300K 350K 400K
Mitigated Direct Cost($)/Year
Figure 6. Distribution of mitigated direct costs per year for
195 feeders with proposed undergrounding.
Operations and Maintenance
Exponent calculated the change in Operations and Maintenance ("O&M") costs associated with
each undergrounding project associated with vegetation management and other O&M costs.
Vegetation Management
Avista provided Exponent with vegetation management costs for each feeder from January 2020
to August 2024 (4.67 years), which we understand does not include administrative costs
(representing around 10% of the total cost for vegetation management). We understand that
Avista's vegetation management program runs on a 5-year cycle, in addition to yearly spend,
thus the data does not quite represent a full cycle of costs. Lacking further information, Exponent
proceeded on the basis that the available data is approximately representative of the costs for
vegetation management for each feeder.
To determine the change in costs for vegetation management stemming from the underground
projects, Exponent performed the following steps:
1. The average cost per year is calculated for each feeder. The value is divided by
0.9 to include administrative costs.
Page 24 2407043.000-9196 Exhibit No. 11 E/Yj rM
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October 30, 2024
2. The average cost per year per mile for each feeder is calculated by dividing the
average cost per year for a feeder by the length of the feeder.
3. For feeders without vegetation management cost data, it is assumed that cost per
year per mile is equal to the overall average cost per year per mile across all
feeders (considering that feeders have different lengths). Figure 7 shows a
histogram of the cost per mile per year for vegetation management for each
feeder. The average is around $1,900/year/mile.
4. It is assumed that undergrounding is 100% effective at reducing vegetation
management costs.
5. The annual benefit associated with vegetation management, for a feeder, is
calculated as the vegetation management cost per mile per year multiplied by the
length of the feeder that is to be undergrounded, multiplied by the mitigation
effectiveness of undergrounding for vegetation management(100%).
300
250 243
200
LA
a,
tea, 150
a)
U
100
50
32
0
QQQ� QQQ� QQQ� QQQ� QQQ� QQQ� QQQ� QQQ
QQQN \QQQ QQQ QQ QQ QQ
(ONQ Q Q
Average Cost/Year/Mile
Figure 7. Histogram of vegetation management costs per year per mile for each feeder.
Page 25 2407043.000-9196 Exhibit No. 11 E/Vj TM
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October 30, 2024
Other O&M
Avista provided Exponent with O&M costs from 2019 through 2023 (5 years), omitting
vegetation management costs, for both their current approximately 7,700 line miles of overhead
feeder(approximately $67 million) and approximately 5,000 line miles of underground feeder
(approximately $3.8 million). Costs were not apportioned to feeders. The change in O&M costs
(non-vegetation management) is determined as follows:
1. The O&M cost per year per mile for both overhead and underground is calculated
on a system-wide basis. The average cost per year per mile for overhead is
approximately $1,700, and the average cost per year per mile for underground is
approximately $150. The large difference in yearly O&M costs per mile is likely
because the underground sections are newer than the overhead sections. This bias
will continue to exist, however, as underground sections replace overhead
sections.
2. The change in yearly cost for a feeder when undergrounding is implemented is
calculated by multiplying the length of the undergrounding segment by the
difference in yearly cost per mile between underground and overhead sections.
Wildfire Losses
The purpose of this analysis is to determine the benefit due to reduced losses from Avista-caused
wildfires, in terms of dollars, associated with undergrounding different feeders. Losses
associated with wildfires are typically expressed in terms of dollars, consisting of contributions
from deaths, structures burned, and acres burned. To date, Avista has not conducted analyses to
determine the expected deaths, structures burned, and acres burned for fires started at various
points in their system, or studies of the probability of ignitions occurring at various points in
their system.
However, Avista has performed a relative risk analysis of the consequences of ignitions
occurring at different locations on their system and spreading 3 miles in every direction from
different locations on their system, each identified by a hex (Figure 8). That analysis considers
local conditions such as vegetation, structure density, and population density. Relative risk
scores are expressed in terms of ratio to the average consequence of all hexes in Avista's system.
These risk scores are calculated for hexes along Avista's entire system. Each hex also contains a
percentage of the area that is treed.
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October 30, 2024
Hex for Proposed UG
Hex for Current OH and UG J_
— Proposed UG
— Current OH
Current UG
Ink
r 4
1'
d s
Figure 8. Example Hexes from Avista's Consequence Analysis.
In the absence of Avista-specific consequence data that can be translated into dollars, and the
associated probabilities, Exponent has developed a methodology that leverages data from
FEMA's National Risk Index' to determine reductions in losses associated with Avista-caused
wildfires when undergrounding is implemented on selected feeders.
FEMA's National Risk Index estimates the risk due to a variety of natural hazards, including
wildfires. That risk is expressed in terms of Expected Annual Loss (EAL), considering building
value, population, and agricultural value. The EAL is in units of dollars of loss per year
associated with a particular hazard in a particular census tract. FEMA calculates the EAL using
an equation that combines values for exposure, annualized frequency, and historical loss ratios
for each of 18 hazard types. EALs are calculated for each census tract level in the United States.
Exponent has used the EAL for wildfire as a basis for calculating financial losses associated with
Avista-caused wildfires.
The FEMA EAL's for wildfire include losses associated with both utility-caused and non-utility-
caused wildfires. While there is no definitive information regarding the proportion of wildfire
' https:Hhazards.fema.gov/nri/map
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October 30, 2024
losses that are from utility-caused wildfires, an auditor's report2 in California estimated that 19%
of acres burned in California between 2016 and 2020 were from electric utility-caused wildfires
(Figure 9). On that basis, Exponent has assumed that 19% of the EAL from FEMA's NRI data
can be attributed to electric utility-caused wildfires. It must be recognized that there is
uncertainty associated with this value and there is likely to be significant fluctuation from year to
year and region to region.
WILDFIRES WILDFIRES CAUSED BY ELECTRICAL POWER
MACRISBURNED
2016 2,816 245,000 270 10% 3,000 1%
2017 3,470 467,000 408 12 250,000 54
2018 3,504 1,063,000 297 8 247,000 23
2019 3,086 130,000 304 10 84,000 65
2020 3501 1,459,000 335 10 59,000 4
Totals 16,377 3,364,000 1,614 10% 643,000 19%
Source: Cal Fire's Wildfire Activity Statistics reports,2016 through 2020.
Note: These data consist primarily of wildfire incidents within the Cal Fire direct protection area responded to by Cal Fire personnel.
Figure 9. Proportion of wildfires and acres burned in California caused by electric power
from 2016 to 2020.
The EAL from census tracts must also be apportioned to specific feeders being considered for
undergrounding. The procedure to determine how to apportion the EAL from a census tract to a
feeder is as follows:
1. The expected annual loss due to wildfires in the census tract, from FEMA's NRI, is
termed EALi, where i indicates the census tract.
2. The proportion of losses within the census tract that are attributed to electric utility-
caused wildfires is termed PU, and is assumed to be 0.19.
3. The proportion of the census tract that is in Avista service territory is calculated via a GIS
overlay of Avista's service territory with a GIS map of the census tracts. The variable is
termed PA1. This recognizes that a census tract may contain multiple electric utility
operators, all of whom likely contribute to the wildfire risk. As specific information is not
known about the consequences of wildfires caused by other utilities, a simplifying
assumption was made that the losses attributed to Avista would be based on the
proportion of the census tract that is Avista service territory.
4. As there can be multiple feeders within a census tract, and only portions of feeders are
typically undergrounded, the wildfire losses must be apportioned to each hex within the
census tract. This is done by calculating a weighting factor, WFh, for each hex within the
2 California State Auditor Report 2021-117
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October 30, 2024
census tract. The weighting factor each hex is based on a combination of the risk score
for the hex, RSh, and a proxy for the probability of ignition based on a combination of the
average wood pole failure rate within the hex and an estimate of the tree failures in the
hex. The average wood pole failure rate within the hex is expressed as, 1.f,h, and its
calculation is described in the next section. In the absence of more precise data on tree-
induced ignitions, the tree failure rate, tf,h, is estimated as the ratio of tree-induced
outages on the feeder to wind outages on the feeder multiplied by the A1f,h, and then
multiplied by the ratio of the percentage of the hex that is treed to the average percentage
treed of all hexes on the feeder. It is recognized that this is not an actual tree-induced
ignition rate but is merely a mechanism for considering the likelihood of tree-induced
ignitions relative to wood pole failure-induced ignitions.
_ tree outage on feeder % Treed in Hex
tf,h wind outages on feeder X �f'h X Avg. % Treed on Feeder
5. The weighting factor for the hex is calculated by multiplying the risk score for the hex by
the sum of the average wood pole failure rate and the estimated tree failure rate.
WFh = [Af h + tf,h] X RSh
An emphasis is placed on tree and pole failure as these tend to occur in windier
conditions, and dry, windy conditions are conducive to wildfire ignitions in general and
larger wildfires in particular. Weighting factors are determined in this way for each hex
within the census tract.
6. It is assumed that if a section of a feeder has been undergrounded, the contribution to the
wildfire losses is zero, as it is highly unlikely that there will be a large wildfire caused by
an undergrounded segment.
7. Within a census tract, losses are apportioned to the section of a particular feeder that is a
candidate to be undergrounded by summing the weighting factors for all hexer on that
feeder within the census tract that are in sections to be undergrounded and dividing by the
sum of the weighting factors for all hexes within the census tract. As losses are being
determined on a feeder-by-feeder basis, the weighting factor for each hex must also be
weighted by the proportion of the hex that belongs to the particular feeder, PFh. This
value is typically 1; however, some hexes contain multiple feeders. This apportionment
factor is termed, PMf,i.
PMf, ZUG zone WFh X PFh
i =
census tract i WFh
If the entirety of Avista's lines within a census tract were to be undergrounded, the sum
of PMf,i for all feeders in the census tract would be equal to 1.
8. It is assumed that wildfire losses associated with any sections to be undergrounded are
100%mitigated by the undergrounding.
Page 29 2407043.000-9196 Exhibit No. 11 E�j TM
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October 30, 2024
9. The expected annual mitigated losses due to Avista-caused wildfires for a feeder,
EALf,,,,, are calculated by summing, for all census tracts that contain the feeder, the
apportionment factor for the feeder in the census tract multiplied by the EAL for the
census tract and the proportion of the census tract that is Avista service territory, and
multiplying that summation by the proportion of losses that are assumed to be caused by
electric utilities.
EAL f,m = PU PMf,iEALIPAi
all census tracts,i,
containing feeder,f
10. This process is repeated to determine the mitigated wildfire losses for all feeders that
Avista has identified as candidates for undergrounding.
Wood Poles Failure Rates
Overview of Methodology
As part of Exponent's evaluation of losses associated with wildfires, Exponent used average pole
failure rates within hexes to weight hexes for apportioning losses from census tract data. This
section details the methodology used to estimate failure rates for individual wood poles.
The following data was available for individual wood poles:3
- Pole class
- Pole location (latitude/longitude)
- Installation date and/or year manufactured
- Pole top condition qualitative ranking (Do nothing, needs further review, replace
pole)
- Shell rot condition qualitative ranking (New, good, fair, bad, immediate attention
required)
- Remaining strength (as a percentage of new pole strength)
- Cross arm condition qualitative ranking (New, good, fair,bad, immediate
attention required)
Exponent performed a quantitative risk analysis ("QRA")to determine the annual failure rate of
each wood pole. The concept within QRA is that vulnerability is determined numerically based
on data and via mathematical and scientific analysis. This method is in contrast to qualitative risk
analysis, whereby the relative risk of components is determined by expert opinion and
3 Some poles do not have all these data field populated.
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October 30, 2024
experience without the same mathematical rigor. Exponent has used a methodology called
Performance-Based Engineering ("PBE") to perform this assessment.
As part of this methodology, the concepts of hazard curves and fragility curves play pivotal roles
in quantifying the relationship between the hazard intensity and the vulnerability of different
components. The hazard curve illustrates the rate of exceeding a given level of load intensity,
e.g., the frequency that the 3-second wind gust is expected to exceed a certain speed. The
fragility curve defines the likelihood of exceeding some predefined damage state (i.e.,failure) at
a corresponding hazard intensity, e.g., the probability of wood pole failure given a-second wind
gust speed. Sample hazard and fragility curves for wind are shown in Figure 10.
The hazard and fragility functions can be combined to calculate the annual rate, /., at which the
unwanted outcomes are expected to occur(i.e., the frequency of failures, or failure rate, for
short). In this report, Exponent refers to this integration as the Probability Framework Equation.
For low exceedance frequencies, the annual rate approximates the annual probability of failure.
The annual exceedance frequency, annual failure rate, and annual probability of failure are often
used synonymously in this context and, while not exactly the same, are normally very close for
practical ranges of failure probabilities. The Probability Framework Equation is:
00
A = f P(f Jim) I d1 dh dim
0
Where p(f I im) is the probability of an outcome f conditioned on the intensity of the hazard im,
dh
dim I is the absolute value of the derivative of the hazard curve (i.e., the slope of the hazard
curve), and the integration is performed over all possible intensities of hazards. In other words,
the Probability Framework Equation is the integration of the fragility curve with the derivative of
the hazard curve.
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October 30, 2024
1.00E+03 \ 1
c 1.00E+01 0.9
f6 0.8
v 1.00E-01 y
u 0.7
x —
w 1.00E-03 16 0.6
LL
o w
0
u 1.00E-05 >0.5
C Y
d —
v 1.00E-07 0.4
v a
2 0.3
1.00E-09 a
0.2
c
Qc 1.00E-11 0.1
1.00E-13 0
0 20 40 60 80 100 120 0 20 40 60 80 100 120 140
3-Second Gust Windspeed[m/s] 3-Second Gust Windspeed[m/s]
Figure 10. Sample hazard curve (left) and fragility curve (right).
Hazard Curves
Hazard data was acquired from the Applied Technology Council's hazard tool,'which yields
wind speeds corresponding to mean recurrence intervals ("MRI", also referred to as "return
periods") for 10, 25, 50, 100, 300, 700, 1700, and 3000 years. American Society of Civil
Engineers ("ASCE")hazard tools shows contour maps for certain recurrence intervals,
reproduced for 300-year and 700-year wind speeds in Figure 11 and Figure 12, respectively. It is
seen that there is no significant variation in wind speeds corresponding to a particular MRI in
Eastern Washington and Western Idaho (i.e., Avista's service territory). There is some,but not
significant, variation in wind hazard curves across Avista's service territory. Exponent therefore
acquired baseline wind speed MRIs for several sites spaced out geographically within Avista's
service territory using the available hazard tools, and then interpolated to determine the MRI
parameters at the location of each individual pole. Finally, for each pole, a Gumbel hazard curve,
using the below equation, was fit to the wind speed MRI data.
1
h(im) — ( M-loc
1 — e-e scale
Where h is the probability of exceedance of 3-second gust speed, im, and loc and scale are the
location and scale parameters of the Gumbel distribution, respectively. Figure 13 shows an
example hazard curve fit to MRI wind speed data.
4 https:Hhazards.atcouncil.org/
5 https:Hascehazardtool.org/
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October 30, 2024
' Wes'N pan w
J'A
2 d
Figure 11. Contours from ASCE Hazard Tool for 300-
year wind speed.
,A
Figure 12. Contours from ASCE Hazard Tool for 700-
year wind speed.
Page 33 2407043.000-9196 Exhibit No. 11 xTM
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October 30, 2024
100
>, 10-1
c�
0
L
102
U
(B
N
U
x 10-3
w
c
c
Q 104
0 20 40 60 80 100 120 140
3-Second Wind Gust Speed [mph]
Figure 13. Example wind speed hazard curve and underlying MRI data.
Fragility Curves
Baseline (notional) new pole fragility curve
Fragility curves are typically defined by lognormal cumulative distribution functions with
median, µ, and dispersion, f3, parameters:
p(f d im) = 1 2 1 + erf(In im im fl — µ
Where im is the value of the intensity measure, e.g., 3-second wind gust speed, and p(f I im) is
the probability of failure of the asset at that value of im. The median corresponds to the wind
speed at which half of poles would fail. The dispersion parameter will be lower when there is
less uncertainty in the strength of the pole, and higher when there is more uncertainty
surrounding the strength of the pole. For example, all else being equal, strength estimates for an
older pole will be less certain due to an uncertain rate of degradation, thus reflected in a higher
dispersion parameter. Higher dispersion reduces the steepness of the fragility curve.
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October 30, 2024
Either decreased capacity or increased uncertainty(dispersion) will cause the probability of
failure in practical ranges of hazard intensity to increase, thereby increasing the calculated
vulnerability associated with that asset. For instance, wood poles can decay over time, thus
reducing their structural capacity. However, we lose confidence in a wood pole's capacity to
resist wind as the pole approaches the end of its design life, even if it is in visually good
condition. Strength reduction shifts the bell curve model of capacity to the left, and increased
uncertainty (higher standard deviation) causes it to fatten. As an example, consider the results of
strength tests of new and existing poles conducted by the Electric Power Research Institute
(Figure 14). The strength distribution of older wood poles has shifted the bell curve to the left,
while increased variability(uncertainty) is illustrated by the fattening of the curve.
—poles of average age 30 years —new poles
T
C
W
7
W
I
I I
I
0 3,000 6,000 9,000 12,000 15,000
Groundline Strength(psi)
Figure 14. Loss of strength and increased dispersion as wood poles age (from EPRI, 1986).
Fragility curves can be estimated through detailed engineering analysis, experimentation, review
of historical data, or, in the absence of information, expert consensus. It is expected that the
fragility curve will be different for poles of different classes or ages. Wood poles are designed
(or classed)based on environmental loads from wind, ice, or wind concurrent with ice accretion.
In addition,wood poles are most often replaced or strengthened because their capacity to resist
wind has degraded such that they can no longer bear loads prescribed by design standards.
Estimating the fragility function median strength parameter for each individual overhead
structure asset would require either knowing the loads to which it was designed or performing
sag-tension calculations, both of which would require substantial research and/or calculation. For
the purposes of this study,which is aimed at providing approximate estimates of failure rates for
the purposes of apportioning wildfire losses between hexes, Exponent estimates a fragility curve
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for each wood pole as if it were a new asset (notional fragility) based on failure rates described in
the technical literature. The fragilities are then adjusted based on the wind hazard curve at
individual poles and based on the pole's remaining strength, shell rot condition code, or age.
The median strength used for the notional fragilities of wood poles has been informed by
reliability-based design targets provided by publicly available technical literature. One such
document is Reliability-Based Design of Transmission Line Structures: Final Report, Publication
EL-4793 by the Electric Power Research Institute. Based on calibration studies, the document
provides a range of target reliability indices ranging from 2.7 to 3.2. Similarly, Reliability-based
Design of Utility Pole Structures, a 2006 publication by the American Society of Civil
Engineers, suggests an annual failure rate of 0.00046 (based on a 50-year reliability index of 2.0)
for existing wood poles. Based on engineering judgement, this lower reliability index(2.0) is
adopted for the notional new wood pole fragility curve, recognizing that it is intended for poles
that have been in service because a) in our experience, wood poles fail more frequently than steel
structures, even when in almost new condition, and b)the potential for under-build, which can
increase the wind load beyond the design intent.
Specifically, the new pole dispersion parameter is estimated to be 0.3, based on engineering
judgement, and the new pole median at a particular location, is back-calculated from the
Probability Framework Equation. Every pole, when new, will thus have the same initial failure
rate (and dispersion), but varying median because of the different hazard curves at each site.
Modifying fragility curve to account for condition
The notional fragility curve for each pole is modified to account for observational data and the
age of the pole. The hierarchy for modification is as follows:
1. Where pole remaining strength data is provided, the new pole strength is
multiplied by the remaining strength parameter, RS, which can theoretically range
from 0 to 100%. Because the wood pole fragility curves relate wind speed to the
probability of failure, and wind force is proportional to wind speed squared, the
modification to the median of the fragility curve is modified as follows:
Padjusted — Ynew RS
2. Where pole remaining strength data is not provided, but the shell rot condition
code is provided, the remaining strength is estimated based on the condition code.
Shell rot condition code is used for this purpose instead of pole top condition code
because the shell rot condition code is a better proxy for the likelihood of
groundline failure due to wind loading. Review of the relationship between
remaining strength data, where provided, and the shell rot condition code of the
same pole did not reveal a consistent trend. Thus, the mapping of shell rot
condition code to assumed remaining strength assumes that poles with a condition
code of"new"will have a remaining strength of 1, and poles classified as
Page 36 2407043.000-9196 Exhibit No. 11 IX TM
Case No.AVU-E-25-01
V.Malensky,Avista
Schedule 7,Page 43 of 61

October 30, 2024
"immediate attention required"will have a remaining strength of 0.67.E The
remaining strength corresponding to "good," "fair," and"bad" are interpolated
between the "new" and "immediate attention required"remaining strength values,
as indicated in Table 7.
Table 7. Assumed remaining strength for different shell rot conditions.
Shell Rot Condition Code Remaining Strength Parameter
New 1
Good 0.9175
Fair 0.835
Bad 0.7525
Immediate Attention Required 0.67
3. Where a pole does not have a remaining strength value or a shell rot condition
code, the age of the pole is used to estimate the remaining strength. Figure 15
shows a histogram of pole ages for each shell rot condition code. As expected,
poles with condition code "new" are mostly young (between 0 and 15 years old),
and as the condition code progresses to good, fair, bad, and immediate attention
required, the typical ages increases. It is notable that a number of young poles
have lower condition codes,potentially due to infant mortality. Based on a review
of the data, a mapping between age, and remaining strength, shown in Table 8 and
plotted in Figure 16, was developed and is used where only age information is
available about a pole.
6 This aligns with guidance in California's G.O.95 that poles must be replaced when they have lost one third of
their original strength.
Page 37 2407043.000-9196 Exhibit No. 11 EX rM
Case No.AVU-E-25-01
V.Malensky,Avista
Schedule 7,Page 44 of 61

October 30, 2024
3500 Histograms of Ages by SHELLROT DESCRIPTION
0 BAD
0 FAIR
3000 0 GOOD
OIMMEDIATE ATTENTION REQUIRED
ONEW
2500
2000
c
0
U 1500
1000
500
0 Loll.. . . . . . =�f=L F !
0 20 40 60 80 100 120
Age
Figure 15. Histogram of wood pole ages for each shell rot condition code.
Table 8. Mapping of Age to Remaining Strength
Age Range Remaining Strength
0to7years 1
7 to 31 years 1 — (age — 7) (1 —0.9175)
31 - 7
31 to50years 0.9175 — (age —31) 0.9175 — 0.835( 50 - 31 )
0.9175 — 0.835
> 50 years 0.835 — (age— 50)( 50 — 31 )
Page 38 2407043.000-9196 Exhibit No. 11 E�TM
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 7,Page 45 of 61

October 30, 2024
1
0.9
m
0.8
m
E 0.7
CU
M
0.6
a)
0.5
L
ll+^�
vJ
o) 0.4
E 0.3
a)
Of 0.2
0.1
0
0 20 40 60 80 100
Age [years]
Figure 16. Estimate of Remaining Strength as a function of age; used in the absence of
shell rot condition code or explicit measurement of remaining strength.
The dispersion parameter, (3, is also assumed to be age-dependent, to account for the fact that
there is more certainty in new wood pole strength than in older wood pole strength. The steps to
determine the age-dependent value of/3 are as follows:
1. The new pole dispersion value is termed/lo and is assumed to be equal to 0.3.
2. The new-pole fragility curve median, µn,e, is back-calculated based on(lo, and
assumed new pole failure rate discussed previously, and the hazard curve for the
site.
3. The fragility curve median at the end of life, µEOL, is assumed to be 2/3 of the
new pole median.
4. The failure rate at the end of life, AEOL, is estimated using the Probability
Framework Equation with the hazard curve for the site, µEOL, and(3o.
5. An intermediate dispersion value, /30, is back-calculated using the hazard curve
for the site, AEOL, and µnew
6. A rate of change parameter, p, between the new pole dispersion, flo, and the
maximum dispersion, is calculated as follows, assuming the maximum
Page 39 2407043.000-9196 Exhibit No. 11 E�j TM
Case No.AVU-E-25-01
V.Malensky,Avista
Schedule 7,Page 46 of 61

October 30, 2024
value the dispersion parameter will ever take (extremely old pole) is l3r„ax = 0.5,
C = 0.2, and the Design Life of the poleR F'
is 80 years.
In (~max — D)
_ C
P Design Lide
7. The value of/3 at any age is calculated as follows:
ll(age) _ fl .ax — C - eP age
Figure 17 shows the dispersion value for a wood pole of various ages ranging between 0 and 150
years at an example location.
0.42
0.4
0.38
0.36
0.34
0.32
0.3
0 50 100 150
Age [years]
Figure 17. Example relationship between pole age and fragility curve dispersion parameter,
X
Page 40 2407043.000-9196 Exhibit No. 11 -F--I�jrM
Case No.AVU-E-25-01 t.
V. Malensky,Avista
Schedule 7,Page 47 of 61

October 30, 2024
Calculated Wood Pole Failure Rates
Figure 18 shows a histogram of estimated pole annual failure rates.
x 104
5
4.5
4
3.5
3
c
0 2.5
U
2
1.5
1
0.5
0 0.02 0.04 0.06 0.08 0.1
Annual Failure Rate
Figure 18. Histogram of estimated wood pole annual failure rates.
Calculating Benefit-Cost Ratios
Benefit-cost ratios are calculated for individual feeders based on the cost of undergrounding
sections of that feeder and the calculated benefits associated with undergrounding. The benefits
are calculated for the current system configuration. It is unknown when each project will be
undertaken, and information is not available on vulnerabilities in future years, e.g., changing
wildfire consequences, thus all analysis is performed as if the project will be undertaken
immediately, and that benefits are the same in the future year as in the current year(adjusted for
the time-value of money, using the discount rate).
The annual benefit in year zero for feeder i, Bi,o, is calculated as the sum of benefits from the
various analysis components for that feeder:
Page 41 2407043.000-9196 Exhibit No. 11 IX TM
Case No.AVU-E-25-01
V.Malensky,Avista
Schedule 7,Page 48 of 61

October 30, 2024
Bi,0 = 0&M (non — veg.) + 0&M(veg) + Outage Customer Impact + Outage Repair
+ Wildfire
In future year y, measured from today, the annual benefit for feeder i, Bi,y, considering the
discount rate, d, is calculated as:
_ Bi,O
Bi,y (1 + d)y
The benefit-cost ratio for each feeder, BCRi, is calculated as follows:
n
BCRi = y=1 Bi,y
Ci
Where Ci is the cost of the undergrounding project on feeder i, assumed to be incurred
immediately and n is the expected useful life of the underground segment. Avista estimates that
the expected useful life of the undergrounding projects is 98 years, while the economic book life
is 55 years. Exponent has therefore used the average value of 76.5 years in calculations of benefit
cost ratios.
It is common to assume two different values of the discount rate in public projects:
• 7%: which considers the market rate of return on capital
• 3%: which considers the rate of return on capital after taxes
Avista has used a value of 6.89%when calculating benefit cost ratios for other projects, thus, for
consistency, Exponent has adopted that value for this study. It is noteworthy that a lower value
will result in higher benefit-cost ratios.
Page 42 2407043.000-9196 Exhibit No. 11 EX rM
Case No.AVU-E-25-01
V.Malensky,Avista
Schedule 7,Page 49 of 61

October 30, 2024
Costs of Undergrounding
To determine the benefit to cost ratio of proposed undergrounding projects, Avista provided the
estimated cost to underground 2,074.3 miles of OH distribution lines over 177 feeders. The cost
per feeder is estimated using 5 categories:
1. fixed costs, which consider project labor,
2. civil construction costs, which consider excavation and conduit installation work,
3. trunk and lateral build costs, which consider cable installation,pad mount
transformers, and service riser installation,
4. distribution automation costs, which consider equipment installation to transition
from underground to overhead lines, and
5. service transfer and overhead wreckout costs, which consider the removal of the
existing overhead infrastructure and maintaining power supply during
construction.
For each feeder, the costs are summed across all categories. Figure 19 shows the distribution of
the estimated costs of undergrounding projects for 177 feeders.
40
35
i 30
a�
25
LL
6 20
L
15
Z 10
0
N � l0 00 O N V 0 00 O N V t0 00 O N � W 00 O N � W 00
to to to to -I -I i rl e-I N N N N N m m m m m V V 1* 1:T -1
Vl t/1 t/1 Vl t/1• t/1• t/? t/? th V1 t/� t/1• t/? V} t/� t/1• t/? V? -Ln to
O rq ZT t0
00 O N � W 00 O N t0 00 O N 0 CO O N � 0
-I N N N N N m m m m m 4 -4 Tr Ic:T
Estimated Cost ($)to Underground
Figure 19. Distribution of the estimated cost to underground for 177 feeders.
Page 43 2407043.000-9196 Exhibit No. 11 �j X TM
Case No.AVU-E-25-01 JJ
V.Malensky,Avista
Schedule 7,Page 50 of 61

October 30, 2024
Cost-Benefit Analysis Results
In the cost-benefit analysis, the estimated cost of undergrounding projects was compared to the
benefits of completing the undergrounding projects for each feeder. Table 9 shows the results of
the cost-benefit analysis. The benefit-cost ratio ("BCR") evaluates whether the benefits outweigh
the project cost for each feeder. A higher BCR indicates a feeder that derives more benefit per
dollar spent. A BCR greater than 1 indicates that the benefits exceed the costs, suggesting that
the undergrounding project on that feeder is financially advisable. Conversely, a BCR less than 1
indicates that the costs exceed the benefits, suggesting that the undergrounding project on that
feeder is not financially advisable. The BCR can thus be used to prioritize investments, ensuring
that resources are allocated to undergrounding projects with the greatest potential for positive
returns.
Table 9. Cost-Benefit Analysis Results by Feeder
Feeder O&M O&M Veg. Outage Repair Wildfire Total Benefit Cost ($) Benefit-
Name Reduction Management Reduction Reduction Reduction ($)over the of Under- Cost Ratio
Benefit Reduction Benefit Benefit Benefit time horizon grounding (BCR)
($/yr.) Benefit($/yr.) ($/yr.) ($/yr.) ($/yr.) of 76.5 years Project
9CE12F4 $3,454 $13,606 $55,135 $7,558 $492 $1,237,048 $873,177 1.42
9CE12F6 $3,669 $2,900 $403,078 $30,176 $246 $6,783,990 $3,304,405 2.05
AIR12F1 $57,599 $23,400 $479,026 $57,647 $62,140 $10,479,806 $33,075,636 0.32
AIR12F2 $7,712 $2,860 $142,532 $10,953 $3,871 $2,588,735 $6,144,234 0.42
AIR12F3 $7,669 $7,047 $14,247 $9,593 $4,537 $664,321 $10,076,103 0.07
APW112 $2,871 $4,153 $447,864 $14,635 $44 $7,238,714 $1,686,068 4.29
APW113 $5,836 $4,004 $276,652 $34,088 $1,237 $4,961,044 $1,981,731 2.50
ARD121`2 $15,958 $13,559 $218,822 $32,900 $1,689 $4,361,553 $3,221,763 1.35
AVID 151 $28,172 $64,533 $3,034,252 $169,664 $2,101 $50,852,194 $19,671,802 2.59
AVID 152 $1,807 $1,559 $126,654 $8,499 $2 $2,135,405 $2,291,407 0.93
BEA121`2 $3,830 $5,119 $300,665 $14,601 $57 $4,998,899 $1,636,467 3.05
BIG411 $12,774 $77,088 $281,559 $33,007 $397 $6,240,681 $11,133,726 0.56
BIG412 $3,530 $9,376 $36,074 $17,060 $58 $1,018,948 $2,085,508 0.49
BIG413 $3,416 $3,480 $515 $7,588 $76 $232,393 $4,763,644 0.05
BKR12F2 $3,495 $4,198 $5,036 $2,591 NaN $236,173 $4,031,713 0.061
BKR12F3 $3,379 $353 $44,453 $5,966 $11 $834,958 $2,025,847 0.41
BLA311 $38,573 $75,535 $371,377 $102,053 $598 $9,066,533 $11,351,137 0.80
BLD12F4 $18,739 $43,623 $572,250 $43,516 $0 $10,453,847 $10,338,295 1.01
BLD12F6 $854 $1,026 $30 $2,225 $0 $63,755 $0 NaN,
BLU321 $23,687 $60,056 $1,844,599 $114,412 $167 $31,493,107 $8,652,279 3.64
BLU322 $30,044 $55,508 $1,682,018 $254,002 $355 $31,169,493 $12,228,115 2.55
BUN424 $5,313 $48,066 $4,718 $17,976 $99 $1,174,250 $7,596,558 0.15
BUN426 $3,691 $5,213 $47,514 $10,580 NaN $1,032,826 $1,910,005 0.541
CDA123 $7,914 $23,490 $1,824,890 $84,946 $443 $29,932,444 $2,684,363 11.15
CDA125 $1,981 $5,214 $437,060 $16,051 $22 $7,096,301 $770,927 9.20
CFD1210 $13,995 $7,862 $179,476 $16,850 $21,017 $3,687,458 $7,348,476 0.50
CFD1211 $17,384 $8,257 $102,640 $13,445 $53,755 $3,013,483 $12,187,942 0.25
CHE12F4 $16,029 $16,491 $785,667 $71,137 $3,405 $13,762,067 $9,281,687 1.48
CHW12F2 $33,576 $55,399 $503,802 $65,872 $24,157 $10,525,932 $15,339,288 0.69
CHW12F3 $30,810 $30,576 $351,995 $69,502 $5,733 $7,532,370 $13,278,795 0.57
Page 44 2407043.000-9196 Exhibit No. 11 _F__1�jTM
Case No.AVU-E-25-01 11
V. Malensky,Avista
Schedule 7,Page 51 of 61

October 30, 2024
Feeder O&M O&M Veg. Outage Repair Wildfire Total Benefit Cost ($) Benefit-
Name Reduction Management Reduction Reduction Reduction ($)over the of Under- Cost Ratio
Benefit Reduction Benefit Benefit Benefit time horizon grounding (BCR)
($/yr.) Benefit($/yr.) ($/yr.) ($/yr.) ($/yr.) of 76.5 years Project
CHW12F4 $18,445 $27,697 $189,421 $48,013 $9,627 $4,519,944 $5,008,289 0.90
CKF711 $28,732 $66,759 $709,951 $77,506 $8,957 $13,749,366 $8,466,977 1.62
CKF712 $9,477 $8,106 $261,854 $39,378 $2,171 $4,948,241 $1,926,087 2.57
CLA56 $12,856 $6,896 NaN $8,397 NaN $433,934 $5,458,364 0.08b
CLV12F2 $34,332 $56,346 $722,493 $68,908 $27,402 $14,020,315 $13,442,572 1.04
CLV12F4 $32,141 $52,268 $769,595 $75,221 $17,840 $14,599,679 $11,457,505 1.27
CLV34F1 $45,649 $66,140 $1,186,430 $104,571 $5,160 $21,704,581 $18,389,916 1.18
COB12F1 $30,696 $107,775 $1,477,195 $104,964 $2,880 $26,569,160 $15,473,049 1.72
COB12F2 $74,009 $168,939 $1,387,196 $95,450 $3,001 $26,647,552 $36,177,799 0.74
DAL131 $14,441 $18,478 $1,675,982 $87,120 $167 $27,689,548 $7,071,593 3.92
DAL132 $883 $851 $243,863 $9,012 $51 $3,925,776 $1,319,229 2.98
DAL133 $15,005 $55,022 $799,596 $60,941 $175 $14,348,021 $8,227,240 1.74
DAL135 $5,651 $1,013 $120,092 $17,243 $17 $2,220,099 $2,766,107 0.80
DAL136 $4,285 $5,146 $470,895 $32,014 $112 $7,899,823 $3,381,428 2.34
DEP12F1 $72,888 $59,777 $1,720,439 $127,325 $14,091 $30,746,966 $47,579,593 0.65
DEP12F2 $35,860 $37,380 $821,367 $62,362 $7,704 $14,871,142 $16,822,972 0.88
DER651 $7,942 $15,274 $117,554 $22,444 $11,894 $2,699,421 $7,221,062 0.37
DER652 $21,028 $14,973 $248,768 $49,481 $12,187 $5,340,580 $13,255,296 0.40
DRY1208 $6,580 $3,183 $70,200 $7,097 $9,654 $1,490,919 $6,846,238 0.22
DRY1209 $24,351 $1,997 $41,928 $27,439 $36,094 $2,031,925 $11,926,917 0.17
EFIVIUR $42,896 $76,977 $640,964 $66,251 $1,886 $12,779,243 $19,842,971 0.64
EFM12F2 $8,999 $18,432 $49,191 $7,297 $124 $1,295,594 $5,558,612 0.23
F&C12F2 $6,118 $11,899 $286,268 $19,844 $264 $5,000,773 $6,180,256 0.81
F0R12F1 $91,870 $42,688 $330,644 $66,776 $124,228 $10,115,898 $31,191,984 0.32
FOR12F2 $36,690 $29,043 $127,831 $46,774 $15,583 $3,945,199 $8,517,115 0.46
GIF12F1 $13,583 $10,218 $152,578 $32,817 $850 $3,238,011 $5,714,195 0.57
GIF34F1 $4,415 $3,136 $45,308 $6,383 $653 $923,314 $928,572 0.99
GIF34F2 $48,702 $43,623 $935,892 $140,408 $172,678 $20,677,165 $17,912,746 1.15
GLN12F2 $19,589 $47,683 $1,113,655 $67,506 $4,695 $19,317,873 $12,348,191 1.56
GRA12F1 $3,563 $83 $94,340 $6,147 $18 $1,605,579 $4,035,650 0.40
GRA12F2 $33,973 $22,900 $1,345,194 $105,520 $1,413 $23,262,341 $13,388,298 1.74
GRN12F1 $26,012 $21,502 $541,543 $58,129 $14,386 $10,198,628 $12,728,154 0.80
GRN12F2 $51,392 $76,698 $711,732 $129,333 $12,020 $15,125,520 $22,580,410 0.67
GRV1271 $25,344 $21,210 $222,346 $36,103 $164,355 $7,235,496 $8,755,295 0.83
GRV1272 $848 $783 $6,442 $1,304 $695 $155,269 $210,125 0.74
GRV1273 $58,438 $77,723 $385,765 $57,736 $1,304,711 $29,048,975 $25,818,927 1.13
H&W12F1 $9,112 $407 $8,321 $5,854 $249 $369,104 $6,060,581 0.06
H&W12F3 $36,504 $27,801 $276,584 $69,412 $13,819 $6,538,130 $12,583,923 0.52
HUE141 $2,458 $5,544 $207,875 $11,248 $102 $3,502,869 $2,371,955 1.48
HUE142 $15,967 $4,526 $1,026,344 $31,938 $4 $16,630,158 $14,793,905 1.12
IDR251 $10,452 $6,998 $19,729 $2,845 $129 $618,967 $8,168,768 0.08
IDR253 $49,460 $133,242 $3,138,039 $162,204 $699 $53,702,899 $26,875,637 2.00
INT12F1 $1,031 $1,760 $94,133 $6,200 $116 $1,591,511 $1,550,953 1.03
INT12F2 $35,255 $44,544 $298,110 $26,319 $41,208 $6,866,709 $29,521,037 0.23
JUL662 $4,868 $2,697 $17,745 $4,688 $4,004 $524,160 $1,764,077 0.30
KAM1291 $20,826 $15,129 $189,302 $28,928 $57,794 $4,809,383 $10,460,518 0.46
KAM1292 $14,361 $7,199 $25,587 $22,142 $61,036 $2,009,061 $3,551,360 0.57
KAM1293 $17,659 $12,976 $162,926 $31,316 $117,194 $5,273,276 $7,879,804 0.67
KET12F1 $4,239 $3,455 $8,401 $14,375 $1,612 $494,563 $4,190,394 0.12
Page 45 2407043.000-9196 Exhibit No. 11 -F--I�jrM
Case No.AVU-E-25-01 11
V. Malensky,Avista
Schedule 7,Page 52 of 61

October 30, 2024
Feeder O&M O&M Veg. Outage Repair Wildfire Total Benefit Cost ($) Benefit-
Name Reduction Management Reduction Reduction Reduction ($)over the of Under- Cost Ratio
Benefit Reduction Benefit Benefit Benefit time horizon grounding (BCR)
($/yr.) Benefit($/yr.) ($/yr.) ($/yr.) ($/yr.) of 76.5 years Project
KET121`2 $23,690 $14,290 $298,635 $46,252 $34,474 $6,433,610 $9,626,263 0.67
K001298 $28,529 $22,327 $137,066 $25,374 $139,779 $5,442,908 $11,459,623 0.47
K001299 $31,223 $17,175 $124,193 $27,724 $58,929 $3,996,433 $14,297,268 0.28
L1312F1 $9,044 $10,861 $2,931 $2,825 $16,367 $647,894 $7,154,287 0.09
L1B121`2 $8,617 $6,567 $87,805 $18,434 $6 $1,871,908 $7,740,000 0.24
L1B121`3 $22,626 $69,234 $835,314 $55,540 $297 $15,153,833 $8,665,521 1.75
LOL1266 $26,358 $8,587 $266,365 $12,287 $51,830 $5,633,316 $14,252,548 0.40
LOL1359 $6,403 $4,216 $130,539 $5,790 $1,623 $2,290,328 $4,491,816 0.51
L0012F1 $26,375 $23,144 $373,821 $48,126 $20,787 $7,588,436 $15,360,515 0.49
L00121`2 $30,232 $68,162 $337,688 $64,533 $25,054 $8,103,575 $14,066,031 0.58
LTF34F1 $50,287 $24,888 $233,207 $70,584 $19,469 $6,142,156 $14,591,603 0.42
M15514 $2,917 $3,128 $385,141 $13,741 $2,295 $6,277,613 $1,025,668 6.12
M15515 $1,037 $244 $30,261 $1,365 $110 $508,966 $527,854 0.96
M23621 $1,697 $806 $20,639 $2,712 $96 $400,040 $1,670,575 0.24
MEA12F1 $3,373 $8,999 $113,561 $10,889 $22 $2,109,543 $1,765,510 1.19
MEA12F2 $20,842 $58,552 $773,318 $71,851 $215 $14,256,106 $13,023,921 1.09
MEA12F3 $2,976 $2,220 $7,451 $2,861 $9 $239,200 $1,508,814 0.16
MIL12F3 $4,307 $6,560 $162,648 $11,717 $8 $2,855,595 $958,065 2.98
MIS431 $4,851 $5,821 $145,064 $17,743 $37 $2,674,887 $2,742,918 0.98
MLN12F1 $68,445 $39,756 $911,732 $138,831 $8,703 $17,997,362 $27,703,175 0.65
MLN12F2 $61,695 $98,812 $920,665 $133,104 $3,777 $18,777,154 $31,648,995 0.59
NE12F3 $13,314 $9,289 $425,539 $38,608 $127 $7,505,550 $4,368,913 1.72
NE12F4 $4,453 $2,355 $103,307 $8,158 $68 $1,824,309 $1,390,713 1.31
NRC351 $831 $769 $296 $1,421 NaN $51,146 $322,341 0.161
NW12F1 $11,385 $42,836 $511,133 $35,644 $7,437 $9,379,461 $6,520,124 1.44
NW12F2 $6,219 $18,216 $471,884 $52,442 $3,543 $8,514,157 $2,176,352 3.91
NW12F3 $3,896 $13,749 $234,271 $18,044 $778 $4,173,637 $4,693,211 0.89
ODN731 $33,304 $80,048 $1,827,482 $125,866 $6,414 $31,958,544 $18,515,509 1.73
ODN732 $6,966 $13,150 $74,625 $40,357 $2,086 $2,114,768 $2,915,590 0.73
OLD721 $48,316 $40,403 $972,273 $118,885 $4,052 $18,251,115 $22,581,848 0.81
OR112F1 $60,562 $37,003 $716,595 $151,133 $5,826 $14,970,497 $21,064,418 0.71
OR112F2 $7,388 $11,172 $19,401 $16,703 $1,078 $859,291 $3,326,213 0.26
OR112F3 $35,106 $64,021 $779,323 $92,301 $6,445 $15,064,195 $13,634,614 1.10
OR01280 $13,040 $12,339 $268,031 $50,216 $16,285 $5,548,281 $7,569,623 0.73
OR01281 $29,073 $55,752 $392,900 $51,969 $109,986 $9,861,140 $18,457,982 0.53
OR01282 $12,513 $24,898 $132,355 $24,079 $73,177 $4,116,334 $8,062,702 0.51
OSB521 $6,803 $10,331 $196,508 $23,270 $192 $3,655,136 $5,319,648 0.69
OSB522 $8,184 $122,034 $1,259 $12,008 $2,365 $2,248,397 $11,620,708 0.19
PDL1202 $974 $496 $33,873 $2,423 $300 $586,818 $294,681 1.99
PDL1203 $2,723 $2,039 $50,857 $5,101 $1,831 $964,275 $731,657 1.32
PDL1204 $9,817 $3,659 $48,239 $8,360 $3,621 $1,136,092 $7,777,763 0.15
PF213 $3,248 $1,991 $179,904 $8,586 $85 $2,987,792 $2,770,413 1.08
PIN441 $8,871 $26,902 $545,064 $62,492 $155 $9,919,773 $4,657,020 2.13
PIN442 $5,506 $16,238 $99,372 $20,906 $86 $2,190,698 $5,233,884 0.42
PIN443 $25,128 $75,672 $1,282,931 $105,416 $618 $22,965,806 $12,475,591 1.84
PRA221 $1,209 $1,851 $20,382 $1,610 $79 $387,417 $0 NaNa
PRA222 $1,425 $2,450 $149,320 $5,814 $44 $2,451,941 $1,567,063 1.56
PRV751 $13,834 $15,519 $251,781 $47,241 $0 $5,062,133 $4,947,875 1.02
PRV752 $57,310 $68,305 $1,697,811 $149,909 $0 $30,420,384 $16,196,161 1.88
Page 46 2407043.000-9196 Exhibit No. 11 _F__I�jTM
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October 30, 2024
Feeder O&M O&M Veg. Outage Repair Wildfire Total Benefit Cost ($) Benefit-
Name Reduction Management Reduction Reduction Reduction ($)over the of Under- Cost Ratio
Benefit Reduction Benefit Benefit Benefit time horizon grounding (BCR)
($/yr.) Benefit($/yr.) ($/yr.) ($/yr.) ($/yr.) of 76.5 years Project
PVW241 $15,895 $3,381 $450,258 $24,025 $282 $7,612,928 $16,057,115 0.47
PVW243 $1,700 $2,042 $1,043 $152 $11 $76,291 $0 NaNa
RAT233 $79,252 $111,069 $5,988,275 $222,348 $2,073 $98,707,160 $31,387,900 3.14
RDN12F1 $8,719 $1,280 $24,333 $5,487 $17,845 $888,933 $1,342,455 0.66
RDN12F2 $6,596 $1,002 $9,883 $3,892 $8,637 $462,625 $1,241,310 0.37
SAG741 $49,682 $131,856 $3,681,796 $325,351 $3,933 $64,632,250 $20,258,720 3.19
SAG742 $31,891 $51,561 $2,338,081 $180,658 $872 $40,128,124 $21,069,397 1.90
SE12F2 $16,125 $27,985 $908,244 $49,817 $24,192 $15,822,134 $6,884,458 2.30
SE12F4 $3,580 $8,836 $405,968 $33,183 $81,842 $8,222,878 $3,648,567 2.25
SE12F6 $982 $336 $5,532 $686 $62 $117,113 $407,237 0.29
SIP12F4 $1,623 $746 $54,605 $3,389 $10 $930,696 $574,939 1.62
SLK12F1 $37,123 $168,062 $340,575 $34,760 $49,954 $9,719,218 $14,822,750 0.66
SLK12F2 $15,008 $4,856 $226,883 $35,754 $7,200 $4,465,936 $9,548,410 0.47
SLK12F3 $22,723 $6,701 $14,638 $11,016 $34,261 $1,377,217 $17,700,697 0.08
SLW1348 $5,844 $5,581 $80,203 $11,541 NaN $1,590,434 $5,639,092 0.281
SLW1358 $1,790 $2,049 $45,694 $3,021 $1,733 $836,865 $631,323 1.33
SLW1368 $4,397 $2,134 $99,798 $10,002 $16,094 $2,041,427 $3,600,332 0.57
SOT521 $4,638 $2,087 $78,136 $8,878 $796 $1,457,351 $2,096,482 0.70
SOT523 $15,851 $3,586 $80,658 $15,973 $10,840 $1,956,381 $11,867,926 0.16
SPI12F1 $5,260 $4,573 $38,266 $6,202 $23 $837,448 $2,273,394 0.37
SPL361 $20,748 $66,124 $2,031,145 $130,430 $3,137 $34,709,790 $5,948,465 5.84
SPT4S21 $44,906 $77,746 $3,601,926 $233,095 $5,814 $61,100,026 $23,820,987 2.56
SPT4S23 $2,118 $1,820 $190,786 $10,459 $54 $3,163,877 $1,650,836 1.92
STM631 $45,800 $185,718 $3,889,751 $223,800 $5,269 $67,063,606 $11,195,018 5.99
STM633 $12,919 $22,229 $553,919 $49,751 $1,021 $9,863,571 $5,898,158 1.67
STM634 $8,195 $9,842 $68,609 $9,192 $350 $1,482,817 $3,031,607 0.49
SUN12F1 $1,074 $4,275 $405,966 $20,879 $315 $6,667,457 $1,619,437 4.12
SUN12F2 $34,189 $91,263 $1,430,140 $104,749 $20,844 $25,916,678 $21,697,324 1.19
SUN12F4 $17,461 $15,924 $474,761 $33,791 $2,958 $8,399,955 $9,322,910 0.90
SUN12F5 $48,999 $30,778 $501,715 $99,930 $94,708 $11,964,605 $22,257,740 0.54
SWT2403 $15,303 $12,614 $93,689 $10,408 $48,033 $2,775,557 $7,847,782 0.35
TEN1254 $2,663 $1,941 $44,034 $2,980 $213 $799,013 $3,752,313 0.21
TEN1255 $2,114 $1,967 $99,302 $4,125 $661 $1,667,504 $3,156,702 0.53
TEN1256 $7,801 $10,873 $74,810 $6,441 $0 $1,540,416 $7,488,853 0.21
TEN1257 $2,510 $1,531 $43,085 $1,818 NaN $754,519 $1,964,556 0.38b
VAL12F1 $83,189 $55,397 $1,516,823 $183,083 $56,056 $29,205,848 $29,185,922 1.00
VAL12F2 $26,612 $23,571 $192,542 $72,460 $7,355 $4,972,201 $8,816,281 0.56
VAL12F3 $24,713 $35,034 $436,720 $85,608 $5,703 $9,061,036 $7,718,155 1.17
WAK12F1 $9,753 $37,640 $2,690,845 $181,035 $2,517 $45,041,523 $7,846,832 5.74
WAK12F2 $7,075 $31,133 $175,309 $19,477 $481 $3,599,208 $3,530,871 1.02
WAK12F3 $2,124 $5,107 $113,609 $9,709 $107 $2,014,165 $2,877,197 0.70
WAK12F4 $22,646 $89,009 $668,200 $56,624 $9,703 $13,044,507 $14,800,359 0.88
WAL542 $2,475 $7,493 $21,310 $3,630 $444 $544,973 $2,794,603 0.20
WAL543 $3,681 $13,543 $46,630 $9,881 $531 $1,144,852 $3,184,585 0.36
WAL544 $12,137 $24,361 $135,850 $25,917 $541 $3,064,742 $12,116,118 0.25
WAL545 $4,703 $15,002 $97,268 $12,912 $205 $2,005,430 $2,442,398 0.82
WAS781 $5,895 $1,181 $6,035 $3,469 $17,600 $526,916 $906,922 0.58
WE11289 $22,017 $18,487 $213,332 $32,762 $104,536 $6,029,610 $19,744,578 0.31
WIL12F2 $1,223 $166 $3,213 $604 $1,494 $103,286 $0 NaN,
Page 47 2407043.000-9196 Exhibit No. 11 �j �jTM
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October 30, 2024
a The Avista provided cost is$0, so the BCR cannot be calculated.
b The BCR calculation excludes one or more benefits due to unavailable input data.
Page 48 2407043.000-9196 Exhibit No. 11 E�TM
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October 30, 2024
Recommendations for Future Study
Exponent has several recommendations for areas of further study and consideration. These are
not intended to distract from the validity of the current Benefit Cost Ratio values. In fact, it is
expected that consideration of these items will result in a net increase in Benefit Cost Ratios on
most feeders.
1. The present analysis created generic fragility curves for wood poles based on
assumed new pole failure rates, location, age, and asset condition score. There
was insufficient data to consider including the conductor span, diameter, material
and quantity, which would result in more precise estimates of the fragility curves,
when combined with information such as the class of pole.'It is recommended
that Avista link conductor and pole data to enable this analysis and refinement of
fragility curves.
2. Asset condition codes and remaining strength were only available for some poles.
Future analyses will be more precise if condition and remaining strength data is
collected for the remaining wood poles.
3. Benefit analyses have all been conducted on the basis of the present system
configuration and condition. In reality, assets will continue to age, new feeders
will be added and change configuration, additional connections to the system will
be incorporated, customer usage may change, maintenance will alter the
propensity for outages, and changing weather patterns may affect wildfire
consequences and outage rates. Future assessments could consider these issues,
which would result in different realized benefits of undergrounding projects in
different years.
4. Avista's current wildfire risk analysis determines relative consequences based on
fires started at specific locations along their feeders. Future analysis could
consider consequences in terms of lives lost, injuries, acres burned, and structures
burned directly, and it could also consider the probability of ignition
quantitatively.
5. Wildfires not only cause direct loss of life and destroy buildings, farmland, and
forests, but also release significant amounts of smoke, which can have a
substantial impact on human health. These impacts on human health from air
quality degradation have not been considered as part of this study,but could be
considered in future studies.
6. This cost benefit analysis has considered projects individually, as opposed to
considering the system as a whole. For example, the sequencing of
undergrounding projects has not been considered. Future studies could consider
E.g.,Darestani,Y.M.and Shafieezadeh,A.,2019.Multi-dimensional wind fragility functions for wood utility
poles.Engineering Structures,183,pp.937-948.
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October 30, 2024
the phasing of projects, such that not all projects begin in a nominal year zero, to
determine the overall benefit cost ratio of an undergrounding program consisting
of multiple feeders.
7. The current cost benefit analysis has considered only feeders identified and costed
by Avista. Future studies could dynamically identify sections of feeders that yield
the most significant benefit from undergrounding, and then determine final
benefit cost ratios to inform decisions on which feeders to underground.
8. Aesthetic benefits from undergrounding distribution lines, such as the change in
property values, were not considered, as there is not currently reliable information
on how undergrounding distribution lines impact property values.' Studies do
indicate that views of overhead transmission lines negatively affect property
values.9
9. Construction-associated injuries and fatalities stemming from undergrounding
projects were not considered because Avista does not currently consider them for
other projects. This could be considered in the future,but it is recommended that
this be treated consistently across Avista projects, and not just for
undergrounding.
10. Avista could consider how undertaking undergrounding projects changes the
demand for labor.
11. Avista could consider the economic impact of the undergrounding projects on rate
payers.
8 Industrial Economics,Inc.The benefits,costs,and economic impacts of undergrounding New York's electric grid.
June 27,2023.p.37.
9 Des Rosiers,F.,2002.Power lines,visual encumbrance,and house values.J.Real Estate Res.23(3).
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October 30, 2024
Rationale for Incorporating Scenario Risk Analysis
The cost-benefit analysis relies on quantitative and probabilistic methods to determine annual
losses attributed to wildfires. The prediction of low-probability, high-consequence natural hazard
events, such as wildfires, and their impacts on populations and property is associated with large
uncertainty, dependencies between the underlying variables, and likely non-stationarity due to
the effects of climate change. As a result, analysis of the risks of low-probability, high-
consequence events poses significant challenges and motivates the use of complementary
methods beyond conventional probabilistic risk assessment, such as scenario risk analysis.
Examples from several fields of study demonstrate that scenario risk analysis has the capacity to
improve understanding of the exposure to rare events, identification of their physical and social
impacts, and assessment of the benefits associated with potential mitigation and preparation
strategies.
Fat-tailed distributions and uncertainty
Probabilistic hazard assessments generally utilize frequency-size distributions to estimate the
occurrence of extreme events. Determining the probability distributions of extreme events is
difficult because of their rare occurrence,but research over several decades has shown that the
distributions associated with many natural hazard characteristics and their impacts follow power-
law type distributions (L e.,P(x)— x'). The probability functions of power-law type
distributions, such as the Pareto distribution, exhibit a slow (polynomial)rate of decay of
increasingly large observations. This means that tail events are much more likely compared to a
Gaussian distribution in which the probability decays exponentially. Power-law distributions are,
therefore, known to be `fat-tailed' (i.e., having a higher probability of tail or extreme events), as
opposed to thin-tailed Gaussian distributions.
There is large uncertainty in predicting low-probability, high-consequence events because
observations of such events are very sparse, and the observational time span is typically not long
enough. Therefore, the distributions fitted to the observed data tend to match the central
tendencies of the data well but may underestimate the rare tail events,10 whereas distributions
fitted to the extreme tail events must cope with very small, if any, associated observations. The
10 King,G.,&Zeng,L.(2001).Logistic regression in rare events data.Political analysis,9(2),137-163.
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October 30, 2024
large uncertainty in the occurrence of the tail events may lead to hazard and risk estimates that
are highly sensitive to the distribution parameters and modeling assumptions.11,12,13,14
Examples of fat-tailed frequency-size distributions of natural hazard variables include the
discharge from flood events,15 the volume of landslides," and the areas burned by wildfires.17 In
addition, even if the characteristics of the hazard are not fat-tailed, many studies have shown that
the damages imposed by the hazards tend to be fat-tailed due to the properties of the underlying
impacted population centers;18 for example, the economic damages from tropical cyclones in the
U.S. between 1900 and 2012,19 and the damage imposed by tornadoes in the U.S.11 were recently
shown to be fat-tailed.
Because of the fat-tail property of the impacts of hazard events, empirical evidence demonstrated
that the few most damaging events contribute highly to the cumulative damage impacts of
several hazards. For example, a study of flood damage in Germany attributed 20% of total
cumulative damages to events rarer than a probability of 1%per year.2'Another example is an
analysis of the cost of 174 weather disasters published by the U.S.National Oceanic and
Atmospheric Administration, in which the few most costly disasters dominate: the single most
costly disaster accounts for approximately 15% of the cumulative impacts, and the top five
events account for approximately 31%. 21 Similarly, in a dataset of earthquake-related fatalities
from 100 events, the same study finds that the single most damaging earthquake contributes 14%
relative to the 100 events, and the ten most damaging events contribute 65%.21 Similar trends
Jo,H.H.,&Ko,Y.L.(2014).Large variance and fat tail of damage by natural disaster.In Vulnerability,
Uncertainty,and Risk:Quantification,Mitigation,and Management(pp.2744-2753).
12 Weitzman,M.L.(2011).Fat-tailed uncertainty in the economics of catastrophic climate change.Review of
Environmental Economics and Policy.
13 Conte,M.N.,&Kelly,D.L.(2021).Understanding the improbable:A survey of fat tails in environmental
economics.Annual review of resource economics,13,289-310.
14 Malamud,B.D.(2004).Tails of natural hazards.Physics World,17(8),25.
15 Malamud,B.D.,&Turcotte,D.L.(2006).The applicability of power-law frequency statistics to floods.Journal of
hydrology,322(1-4),168-180.
16 Brunetti,M.T.,Guzzetti,F.,&Rossi,M.J.N.P.I.G.(2009).Probability distributions of landslide volumes.
Nonlinear Processes in Geophysics,16(2),179-188.
17 Malamud,B.D.,Millington,J.D.,&Perry,G.L.(2005).Characterizing wildfire regimes in the United States.
Proceedings of the National Academy of Sciences,102(13),4694-4699.
18 Gabaix,X.(1999).Zipf's Law and the Growth of Cities.American Economic Review,89(2),129-132.
19 Conte,M.N.,&Kelly,D.L.(2018).An imperfect storm:Fat-tailed tropical cyclone damages,insurance,and
climate policy.Journal of environmental economics and management,92,677-706.
20 Merz,B.,Elmer,F.,&Thieken,A.H.(2009).Significance of"high probability/low damage"versus"low
probability/high damage"flood events.Natural Hazards and Earth System Sciences,9(3),1033-1046.
21 Etkin,D.A.,Mamuji,A.A.,&Clarke,L.(2018).Disaster risk analysis part 1:the importance of including rare
events.Journal of homeland security and emergency management,15(2),20170007.
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October 30, 2024
were found for fatalities corresponding to industrial disasters, U.S. tornadoes, and structural
fires.
Scenario risk analysis as a complementary method
Standard probabilistic risk assessment may underestimate the impacts of rare events because of
the difficulty to estimate their probabilities and quantify their impacts, and the sensitivity of the
risk to the variables of the hazard and modeling decisions. In addition, some studies suggest that
risk analysis based on fat-tailed power laws may still underestimate rare risk events.22
Specifically, the presence of outliers (defined as extreme events which may be significantly
larger than the predictions of power-law distributions) has been documented.
In response to these challenges, research studies have advocated for explicitly including rare
events or worst-case scenarios in disaster risk analysis, or focusing on tail (or rare) exposures
instead of the mean exposure.23 An example of this approach is the improvements to the National
Seismic Hazard Maps of Japan in response to the devastating impacts of the 2011 Tohoku
earthquake; these improvements included the incorporation of low-probability earthquakes
which were not previously incorporated in the analysis, and for which scientific evidence exists,
even if they have not been historically observed. Other studies have emphasized the importance
of possibilistic thinking:24 complementing probabilistic thinking by envisioning worst-case
scenarios and including them within risk analyses and planning processes, with the goal of
identifying weaknesses in complex systems and strengthening networks.21 Conducting scenario
(or deterministic)risk analysis, in addition to standard probabilistic assessments, is an effective
method to include the effects of rare events in risk analysis. As such, scenario risk analysis
would complement the cost-benefit analysis (which includes probabilistic components) to further
understand rare events and inform decision making when prioritizing undergrounding projects as
risk mitigation measures.
An example of applying this type of thinking comes from the nuclear industry, which refers to
"beyond design basis" events. Plants are typically designed for, e.g., very rate flood elevations,
but evaluate what happens when flood waters exceed that elevation, often resulting in further
mitigations such as installing emergency pumps and moving critical equipment to higher
elevations.
Application to Avista's Proposed Undergrounding Projects
While some of the proposed undergrounding projects have BCR values less than 1, components
of the analysis that consider contributions to the "benefits" consider both the consequence and
22 Sornette,D.(2009).Dragon-kings,black swans and the prediction of crises.arXiv preprint arXiv:0907.4290.
23 Taleb,N.N.(2008).The fourth quadrant:a map of the limits of statistics.An Edge original essay,Edge.
24 Clarke,L.(2006).Worst cases:Terror and catastrophe in the popular imagination.University of Chicago Press.
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October 30, 2024
the frequency of the consequence. In particular, the wildfire frequency, which is typically low, is
considered in FEMA's calculation of wildfire losses, which informed this study. However, a
catastrophic wildfire could have drastic consequences far exceeding the cost of any
undergrounding projects, if it were to occur, potentially causing irreparable harm to Avista and
its customers. It is thus worth considering the severity of the consequences, independent of the
frequency of their occurrence, as part of the decision-making process for undergrounding.
Page 54 2407043.000-9196 Exhibit No. 11 E�j TM
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V.Malensky,Avista
Schedule 7,Page 61 of 61

Wildfire Resiliency Plan Business Case
Wildfire Resiliency (rev. December 2023)
EXECUTIVE SUMMARY
The threat of wildfires poses a significant risk to utilities across the western United States. In June
of 2020, Avista published its first "Wildfire Resiliency Plan" which detailed twenty-eight actions
to mitigate the risk of wildfire. The Plan includes upgrades to infrastructure aimed at reducing
spark-ignition events and protecting critical infrastructure from the threat of wildfires. As of
December of 2023, the current 10-year Capital Cost Forecast stands at $310,862,000. Total
program expenditures (CAPx and OPx) are estimated at $433,466,000.
All values below include past and future capital costs from 2020 to 2029.
System &Transmission
Situational awareness tools (technology) $(1,923,000)
Transmission Inspection Capital Maintenance ($1,486,000)
Steel Conversion of Transmission Lines ($37,137,000)
Electric Distribution
Fire Safe Mode Automation (35,367,000)
Wood Pole Management Make-Ready for Grid Hardening ($23,747,000)
Enhanced Distribution Grid Hardening ($210,519,000)
Wildfire Resiliency (Capital Plan Forecast 2020-2029) $310,862,000
The initial June 2020 estimate of $268,965,000 was revised upward to $310,862,000 as of
December 1, 2023. The most significant change to cost is the addition of an enhanced grid
hardening scope in 2026, which includes undergrounding of overhead electric facilities in high fire
risk zones, and Wood Pole Management (make-ready) costs that were not originally forecast as
part of Wildfire Resiliency as this program was folded into the Wildfire Resiliency Plan. Additional
enhanced grid hardening (undergrounding of overhead electric facilities) in high fire risk zones
are being considered beyond 2026 that may impact the Wildfire Resiliency Plan budget in future
years.
Wildfire Resiliency Plan Development
The threat of wildfire has grown steadily across the western U.S. and reflects the combination of
climate uncertainty producing hotter and drier summers combined with increasing housing
development near forested areas where fires are part of the recurring natural cycle. In 2018,
Avista executive management requested that a holistic strategy be delivered to better understand
the financial risk of wildfires and what safeguards might be established to mitigate the risk. After
18 months of development by the Wildfire Steering Committee, Avista's initial Wildfire Resiliency
Plan was published in June 2020. The Wildfire Plan is publicly available on Avista's public-facing
website and has been shared with state regulators, other stakeholders, and peer utilities. Since
June 2020, Avista has invested nearly $76 million dollars in capital upgrades to T&D
(Transmission & Distribution) facilities (2020-2023) and expects that investment to grow by $33
million dollars in 2024. These investments are part of an overall strategy to mitigate the financial
risk that is estimated between $490 million to $4.7 billion dollars over a 10-year time horizon. The
2022 financial risk report was compiled by subject matter experts across the company including
legal, risk management, electric operations, engineering, asset maintenance, and asset
management groups.
Business Case Justification Narrative Page 1 of 12
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 8, Page 1 of 12

Wildfire Resiliency Plan Business Case
Wildfire Resiliency (rev. December 2023)
The Wildfire Plan has been the subject of two Washington General Rate Cases and two General
Rate Cases in Idaho. Hundreds of requests for information have been provided by the Company
along with testimony and direct consultation with Commissioners, Commission Staff, and Public
Counsel. In addition, the Avista Board of Directors receives bi-annual status updates describing
Wildfire Plan tactics, goals, progress, and course corrections. In 2022, a community outreach plan
was developed which included meetings with emergency management agencies and first
responders as well as engagement with over 36,000 customers living in high-fire threat areas. In
2023 this effort was expanded to include all 16 counties containing elevated fire risk zones, over
90,000 residential customers, and 640 public safety partners and key community leaders. Also in
2022, Avista declared Elevated Fire Safety Mode (FSM) on two separate occasions when fire
threat conditions became critical during high wind and low humidity events. In 2023 we elevated
FSM on four days during wildfire season.
Recently, Avista submitted a concept grant proposal as part of the DOE's Grid Resiliency and
Innovation Program (GRIP) to convert 175 miles of overhead distribution lines to underground
cable systems where customers are experiencing high outage rates combined with high fire threat
in areas defined as `overburdened and underserved'. Current capital resource levels are not
sufficient to complete upgrades to all 2,746 miles of distribution lines located in high-fire threat
areas, leaving nearly 700 miles remaining untreated by the end of 2029. Of those 700 miles, 175
miles have been identified as having both high fire risk and poor electric reliability. Unfortunately,
Avista was not chosen in the first round for this grant. As of December of 2023, Avista is
participating in the second round of the GRIP grant funding process as an attempt to secure
additional federal funds for our programs.
Avista remains committed to mitigating the risk of wildfires while maintaining a balance between
costs, risk, and affordability.And lastly,to ensure that our process is transparent to both regulators
and customers and that we are open to feedback and inquiry.
VERSION HISTORY
Version Author Description Date Notes
0 David James Initial Submission to Capital April 1, Initial submission
Planning 2020
1 David James Refresh using the 2020 BC July 29, No revision to capital
narrative template 2020 requirements
Revised Submission for 2023- September Capital Forecast was
2 David James 2027 Capital Budget Cycle 1, 2022 $268,965,000 is now
$290,091,000
Revised per updated BC December 2020-2029 Capital
3 Matt Ugaldea Forecast is
template 1st, 2023 $310,862,000
Has been reviewed by BCRT
BCRT Katie Snyder and meets necessary 04/14/2023
requirements
Business Case Justification Narrative Page 2 of 12
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 8, Page 2 of 12

Wildfire Resiliency Plan Business Case
Wildfire Resiliency (rev. December 2023)
GENERAL INFORMATION
YEAR PLANNED SPEND AMOUNT PLANNED TRANSFER TO
($) PLANT ($)
2024 33,750,000 33,750,000
2025 35,250,000 35,250,000
2026 60,250,000 60,250,000
2027 35,250,000 35,250,000
2028 35,250,000 35,250,000
2029 35,250,000 35,250,000
Project Life Span 10 years 2020-2029
Requesting Organization/Department Electric Operations
Business Case Owner Vern Malensky, Director of Electric Engineering
Business Case Sponsor Josh DiLuciano,VP of Energy Deliver
Sponsor Organization/Department Electric Operations(A50)
Phase Execution
Category Program
Driver Customer Service Quality& Reliability
1Is z-A-11
2023 Wildfire Risk Tiers '"V
Wildfire Resiliency Plan 'i-1,V05 TA
r
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Business Case Justification Narrative Page 3 of 12
Exhibit No. 11
Case No.AVU-E-25-01
V.Malensky,Avista
-Schedule 8, Page-3-of 12

Wildfire Resiliency Plan Business Case
Wildfire Resiliency (rev. December 2023)
1. BUSINESS PROBLEM
1.1 What is the current or potential problem that is being addressed?
The risk of wildfires is increasing throughout the western United States. Data from the
U.S. Forest Service indicates a 300% increase in the number of wildfires since 1970.
Data specific to wildfires in Washington and Idaho fires suggest that the financial impact
of fire has increased by 400 to 500% over the last several decades. Though the overall
percentage of powerline-involved wildfires remains relatively low (about 3% based on
current Washington Department of Natural Resources statistics), catastrophic wildfire
is differentiated from other natural disasters in that cause and origin investigations may
lead to claims for fire suppression costs, property damage, timber loss, and personal
injury. In 2022, a group of subject matter experts examined the probability of large
wildfires and their impact on Avista customers. The 10-year financial risk liability is
estimated between $490 million and 4.7 billion dollars.
1.2 Discuss the major drivers of the business case and the benefits to the customer?
Wildfire does not align with traditional utility growth, maintenance, or capacity-related
business drivers. Unlike most asset replacement programs, Wildfire Resiliency is a risk-
based, not a condition-based program. Therefore, it is best aligned with Customer
Service Quality & Reliability and is designed to mitigate financial risk.
1.3 Identify why this work is needed now and what risks there are if not approved or
is deferred—Avista published both a 2020,2022 and 2023 Wildfire Resiliency Plan and
has committed to the execution of this Plan at the highest levels of the Company
including the Board of Directors. Wildfire represents is a Tier-1 Level Enterprise risk.
1.4 Discuss how the proposed investment, whether project or program, aligns with
the strategic vision, goals, objectives, and mission statement of the
organization —At the heart of the Wildfire Plan is the commitment to protecting
customers. Wildfire represents an increasing risk to human lives and property and
mitigating that risk goes well beyond utility wildfire plans. It is forged in a partnership
between people, communities, government, and business. Avista is the steward of
stakeholder assets and in addition to providing safe, and reliable energy we are duty
bound to protect the financial interests of both the Company and the communities that
we serve. The wildfire plan addresses this through four strategic focus areas:
1. Customers — by reducing the number of utility-involved wildfires we serve the
best interests and help protect the safety and wellbeing of our customers.
2. People—Avista 1 It responders must be well trained and equipped to work in
challenging environments including active wildfire scenes. In addition, our critical
partners such as fire first responders should be trained in awareness of safety
issues related to working around power equipment.
3. Perform-Avista's 10-year Wildfire Plan is a risk-based strategy that has been
peer reviewed and benchmarked with other NW utilities including NorthWestern
Energy and Idaho Power. Avista program managers are ensuring that strategic
goals and commitments are being honored.
4. Invent—Avista has developed sophisticated computer modeling to monitor the
short and long-term risks of wildfire. These risk models help to guide and direct
the resource commitments and operating strategies to mitigate wildfires.
Business Case Justification Narrative Page 4 of 12
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 8, Page 4 of 12

Wildfire Resiliency Plan Business Case
Wildfire Resiliency (rev. December 2023)
1.5 Supplemental Information
Several supporting documents are available for your review upon request:
• 2023 Wildfire Resiliency Plan
• 2023 Wildland Urban Interface Risk Map
• 2022 Wildfire Resiliency Risk Report
• 2021 Year-End Wildfire Resiliency Report
• 2020 Avista Wildfire Resiliency Plan
2020 Wildfire Resiliency Cost Plan
• 2020 Wildfire Risk Assessment
• 2019 Wildfire Plan Charter
In June 2019, a series of risk workshops were convened to identify potential defensive
strategies. These workshops were facilitated by the Business Process Improvement Team
with support from Senior Risk Manager Bob Brandkamp, and Senior Asset Management
Analyst Jeff Smith. Over the course of 6 workshops, 160 mitigation strategies were identified
with 60 strategies analyzed in detail and ultimately, 28 strategies were adopted into the
Wildfire Plan. In addition to internal processes, Avista participated in several utility forums
sponsored by the Western Energy Institute including the Wildfire Planning & Mitigation
Workshop. In general,the approach to fire mitigation is consistent throughout the utility sector
and is categorized into four functional groups:
• Enhanced Grid Hardening — Targeted investments in T&D infrastructure to reduce
spark-ignition events and to make the grid more resilient to the impact of wildfires.
• Enhanced Vegetation Management — Avista is committing additional resources to
inspect and remove risk/hazard trees on the distribution system where data indicates
that fall-in outage risk is 5 times higher than the risk of grow-ins. This commitment is
paired with remote sensing capabilities and detailed data collection including
Transmission LiDAR and Distribution satellite imaging to provide high-quality,
actionable vegetation health and encroachment data.
• Situational Awareness — To automate Avista's 20-year Dry Land Mode system
(rebranded in 2023 as Fire Safety Mode) to align system protection settings with
short-term fire risk.
• Emergency Response & Operations — To plan, prepare, and train for large-scale
wildfire events so that employee safety is balanced with service restoration and that
Avista maintains strong partnerships with emergency first responders before, during,
and after an event.
Business Case Justification Narrative Page 5 of 12
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 8, Page 5 of 12

Wildfire Resiliency Plan Business Case
Wildfire Resiliency (rev. December 2023)
2.1 Please summarize the proposed solution and how it helps to solve the business
problem identified above.
The following scope elements are outlined in the Company's 2023 Wildfire Resiliency
Plan. They are reprinted below. Only capital projects are shown.
Wildfire Project ID Project Scope Resource
Category (2020-2029) (2020-2029)
Distribution Grid 2,746 miles. Includes accelerated wood pole $210.5M
Hardening management inspections.
Grid About 600 steel pole installations per year in
Hardening Transmission Steel Pole critical fire threat areas; about 100 of these under $37.1M
the Wildfire budget.
Transmission Inspection Aerial Inspection to identify fire ignition issues $1.5M
and maintenance repairs.
Automated Distribution 52 midline circuit reclosers installed to automate $7,3M
Circuit Reclosers DLM function.
Situational Fire Mode Ready 139 compatible circuit reclosers automated for Embedded cost
Awareness Communications DLM function.
Automated Substation 57 substation circuit reclosers automated for DLM $28M
Circuit Reclosers function.
2.2 Describe and provide reference to CIRRIIRR analyses, relevant studies,
documentation, metrics, data, analysis, risk reduction, or other information that
was considered when preparing this business case (i.e., samples of savings,
benefits or risk avoidance estimates; description of how benefits to customers
are being measured; metrics such as comparison of cost($)to benefit(value), or
evidence of spend amount to anticipated return).
Wildfire Resiliency is a risk-based plan. Inherent and mitigated risks were assessed in
three categories:
• Financial —The costs to replace T&D infrastructure associated with wildfire
events and the response to third-party claims for fire suppression costs and
financial damages.
• Customer- The cost impact to customers including the costs of electric service
disruption.
• Safety —The costs associated with worker injuries and public safety.
Business Case Justification Narrative Page 6 of 12
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 8, Page 6 of 12

Wildfire Resiliency Plan Business Case
Wildfire Resiliency (rev. December 2023)
The following table is reprinted from the May 2022 Wildfire Resiliency Risk Report. In this report,
several fire and storm-related events were assessed including potential direct and indirect costs.
Fire events related to transmission were analyzed separately from distribution. In general, the
risk associated with transmission is damage to infrastructure from wildfires while the risk
associated with distribution is the sourcing of fires and the subsequent impact on people and
property.
Scenario vDescriptionOptimistic Max Pessimistic
Transmission- Wildfire impact on transmission line.
general wildflre' Transmission lines are impacted approximately $12.OM WF $84.4M SME
3 to 5 times annually.
TransmissionTrees that fall into powerlines create a fire $36.2M WF $757.OM SME
tree fall ignition situation.
Though transmission lines incur 50 times fewer
Transmission- faults than do distribution lines,contact with
transmission lines(animal, lightning,phase $12.9M WF $323.9M SME
all other sources contact)can release significant energy and
create fire ignition probability.
Many distribution line faults occur during
Distribution nominal weather conditions(low winds,
nominal weather seasonal temperatures)and though fire can be $2.9M SME $270.9M SME
sourced in these situations, rarely do these fires
grow and spread.
D Distribution line faults that occur during high
0 = wind events may result in rapid fire spread. $1.8M SME $156.7M SME
The Labor Day 2020 and 1991 Firestorm events
Distribution stand out as the most damaging storm events in
i mph recent Avista history. In both events,tree $423.7M SME $3,113.5M WF
nd evW9 contacts with powerlines sourced significant fire
activity
Totals $489.5M $4,706.4M
The risk costs shown in the table include cost avoidance for both capital assets and financial
risk associated with both nominal and large-scale wildfire events. The internal rate of return is
the ratio of these risk costs to the total resource investments from 2020 through 2029.
IRR Optimistic Outcomes: $489.5/$410 = 1.2x risk: cost over 10 years
IRR Pessimistic Outcomes: $4,706/$410 = 11x risk: cost over 10 years
These risk costs include both direct (hard dollar) and indirect (soft dollar) costs and are
dominated by the risk of a low-probability, high-impact event. During the workshops, an event
magnitude similar to the 1991 Firestorm was assumed.
Metrics associated with the wildfire are gathered and published on a monthly basis. These
monthly reports date back to June 2020 when the Wildfire Plan was formally accepted, and
work began to stand up the various programs. The following is an example of monthly reporting
which indicates costs, project performance, as well as key metrics such as spark-ignition
events, distribution pole fires, and the fall-in and grow-in rates associated with vegetation
outages.
Business Case Justification Narrative Page 7 of 12
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 8, Page 7 of 12

Wildfire Resiliency Plan Business Case
Wildfire Resiliency (rev. December 2023)
The February 2023 Wildfire 9-pager is attached to illustrate the key perfoimance metrics that
are reported to team members, employee stakeholders, and executive managers.
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had a very productive
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and Monona to jointly —
develop best practices.
Business Case Justification Narrative Page 8 of 12
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 8, Page 8 of 12

Wildfire Resiliency Plan Business Case
Wildfire Resiliency (rev. December 2023)
2.3 SUMMARIZE IN THE TABLE, AND DESCRIBE BELOW THE DIRECT OFFSETS' OR
SAVINGS (CAPITAL AND O&M) THAT RESULT FROM UNDERTAKING THIS INVESTMENT
The Company recognizes a potential for costs savings and cost shifts from operating and
maintenance expense towards capital investment. Furthermore, one of the objectives of this
plan is to reduce the number of equipment failures and tree-related outages and by doing
so, avoid emergency response and customer outage costs. However, the overall impact of
cost savings and cost shifts will not be well understood until the plan is fully operational and
longer-term performance data can be obtained and analyzed.
At this time, there are no direct offset savings regarding the investment of capital or expense
dollars to currently report. It is assumed that in the future, the investments made now will
result in offsets in Avista's Vegetation Management, Grid Hardening and Electric Operations
departments. However, no direct offsets have been realized as of 2023. The operation of
the Wildfire Expense balancing account approved in the Company's Washington and Idaho
jurisdictions for O&M costs will be net of cost savings, thereby capturing over time any
embedded cost savings.
2.4 IN THE TABLE, AND DESCRIBE BELOW THE INDIRECT OFFSETS (CAPITAL AND
O&M) THAT RESULT FROM UNDERTAKING THIS INVESTMENT
Indirect cost offsets due to wildfire mitigation efforts are staggering when compared with
direct cost offsets. However, the concept of estimating offsetting costs from an event that
didn't occur becomes complicated. The question of how many fires the investment prevents
becomes rhetorical and can never truly be answered. In 2022, Avista looked at the physical
damage to our facilities, the estimated drop in our stock prices and the impact to our
customers to determine what a theoretical cost of a utility-involved fire might be. Several
groups of subject matter experts were convened and used a rubric to determine what cost
impacts would be avoided if fire was prevented due to our protection and mitigation
techniques. The subject matter expert teams included the Wildfire Team (WF) who
developed a set of optimistic (best case) and pessimistic (worst case) outcomes.
Concurrently the subject matter experts (SME) group, which included employees from
electric operations, engineering, and risk management completed the same exercise. The
table below represents that work. The variability in the estimate demonstrates how difficult
proving a negative can be. Regardless, Avista has estimated indirect cost offsets could be
between $530 Million and $3.7 Billion dollars over the life of the 10-year plan.
Indirect Costs to
$55.8M $1,695.2M $36.4M $645.6M
Avista
Costs(impact to
AVA $41.6M $638.3M $77.OM $911.3M
shareholders)
Impact To
$432.8M $1,356.7M $436.3M $818.8M
Customers(ICE)
Totals $530.2M $3690.2M $549.7M $2,375.7M
Business Case Justification Narrative Page 9 of 12
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 8, Page 9 of 12

Wildfire Resiliency Plan Business Case
Wildfire Resiliency (rev. December 2023)
2.5 Describe in detail the alternatives, including the proposed cost for each alternative,
that were considered, and why those alternatives did not provide the same benefit as
the chosen solution. Include those additional risks to Avista that may occur if an
alternative is selected.
Historically, Avista has had a number of Asset Maintenance programs that addressed the
risk of wildfire impacts on our system including existing vegetation management and grid
hardening programs. Avista responded the growing risk of wildfire by establishing a wildfire
resiliency program that built on these historical Asset Maintenance programs specifically
addressing wildfire risk. Based on environmental factors and known recent historical wildfire
impacts, it was determined prudent to enhance our previously establish mitigative measures
and to increase the focus of programs in high fire threat areas.
During the Spring of 2019, Avista conducted a series of Business Process Improvement
(BPI)-led workshops to identify potential mitigative measures along with the costs and risk
costs associated with those actions. Over 160 individual tactics were identified which were
then narrowed to 60 viable options. A year-long evaluation and advocacy process ultimately
produced the June 2020 Wildfire Resiliency Report which identified 28 individual activities
to support the Wildfire Plan. In 2023, the Wildfire Plan was updated and the number of
projects and processes was reduced by consolidating activities down to a list of 16. Many
of the elements such as grid hardening and automated protection systems capitalized on
existing programs such as grid modernization and Avista's history of setting reclosers to
non-reclose mode during fire season. But other elements were new, such as work to
develop the Fire Weather Dashboard, the WUI risk model, creating fuel reduction
partnerships with state agencies, and the Customer Choice Right Tree, Right Place (Safe
Tree) program. The 2023 Wildfire Plan represents the Company's commitment to mitigating
spark-ignition events and is supported by the Wildfire Steering Committee, the Wildfire
Executive Committee, and the Avista Board of Directors. The current WF Plan calls for the
investment of nearly $433 million dollars (CapX and OPx) over the 10-year period between
2020 and 2029.
2.6 Identify any metrics that can be used to monitor or demonstrate how the
investment delivered on remedying the identified problem (i.e., how will success
be measured).
The 2023 Wildfire Plan describes the goal of reducing the number of spark-ignition events
(fire likely) through a series of investments. Metrics associated with this risk reduction are
reflected in the table below:
Direct offsets are defined as those hard cost savings Avista customers will gain due to the work
under this business case. Such savings could include reductions in labor, reduced maintenance
due to new equipment, or other.
Business Case Justification Narrative Page 10 of 12
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 8,Page 10 of 12

Wildfire Resiliency Plan Business Case
Wildfire Resiliency (rev. December 2023)
2022
Overhead Equipment Failure 654 651 590 612 745 650
Pole Fire 77 68 65 154 50 83
Spark Event 125 99 147 109 107 117
Trees Fall into Lines 315 399 375 353 175 363
Trees Grori Into Lme5 97 94 69 81 59 80
These metrics are measured monthly..
2.7 Please provide the timeline of when this work is scheduled to commence and
complete if known.
The Wildfire program was initially expected to complete all capital upgrades by the end of
2029, but it is anticipated that wildfire-related programs will extend beyond that timeframe.
2.8 Please identify and describe the Steering Comm itteelgovernance team that is
responsible for the initial and ongoing approval and oversight of the business case,
and how oversight will occur.
A Wildfire Steering Committee was established in 2019 and has provided direct input(work
product) and guidance during the evaluation, plan formation, and execution phases of the
Plan. Current members include:
David Howell, Ops Dir Bruce Howard, Env Dir Jillian Caires, Legal
Melanie Rose, RBM Annie Gannon, Corp Com Bob Brandkamp, Risk
Marie Tyrie, Corp Com Liz Andrews, Rates Heather Webster,Asset Mnt
Matt Ugaldea, Wildfire Vern Malensky, Eng. Dir
In addition to the Wildfire Steering Committee, an Executive level group meets monthly
to discuss Plan strategies and emerging issues. Members of that group include:
Heather Rosentrater, Sr VP & COO Josh DiLuciano, VP of Energy
Delivery
Latisha Hill, VP of Economic Vitality Kevin Christie, SR VP External
Affairs
Greg Hesler, SR VP & General Vern Malensky, Dir. Electric
Counsel Engineering
Business Case Justification Narrative Page 11 of 12
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 8, Page 11 of 12

Wildfire Resiliency Plan Business Case
Wildfire Resiliency (rev. December 2023)
3. APPROVAL AND AUTHORIZATION
The undersigned acknowledge they have reviewed the Wildfire Resiliency Business Case
and agree with the approach it presents. Significant changes to this will be coordinated with
and approved by the Lndersigned or their designated representatives.
Signature: W I L- Date: _l Z. 41 Z-�
Print Name: Vern Malensky
Title: Director of Electric Engineering
Role: Eusiness Case Owner
Signature: I�_- Date: /z z �
Print Name: Josh DiLuciano
Title: Vice President of Energy Delivery
Role: Business Case Sponsor
Signature: Date: / Z
Print Name: Matt Uga ea
Title: Wildfire siliency Manager
Role: Steering/Advisory Committee Review
Business Case Justification Narrative Page 12 of 12
Exhibit No. 11
Case No.AVU-E-25-01
V. Malensky,Avista
Schedule 8,Page 12 of 12