20250213Application.pdf

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LISA D. NORDSTROM RECEIVED
Lead Counsel Thursday, February 13, 2025
InordstrornC�idahopower.com IDAHO PUBLIC
UTILITIES COMMISSION
February 13, 2025
VIA ELECTRONIC FILING
Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg 8,
Suite 201-A (83714)
PO Box 83720
Boise, Idaho 83720-0074
Re: Case No. IPC-E-25-05
In the Matter of the Application of Idaho Power Company for Review of the
Company's Current Wildfire Mitigation Plan and Authorization to Defer
Newly Identified Incremental Wildfire Mitigation Costs
Dear Commission Secretary:
Attached for electronic filing, please find Idaho Power Company's Application in
the above-entitled matter.
If you have any questions about the attached documents, please do not hesitate
to contact me.
Very truly yours,
�(�., .�• �h��-.-ram
Lisa D. Nordstrom
LDN:sg
Attachments

LISA D. NORDSTROM (ISB No. 5733)
MEGAN GOICOECHEA ALLEN (ISB No. 7623)
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
Inordstrom(a�idahopower.com
mgoicoecheaallen(a)idahopower.com
Attorneys for Idaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION )
OF IDAHO POWER COMPANY FOR ) CASE NO. IPC-E-25-05
REVIEW OF THE COMPANY'S )
CURRENT WILDFIRE MITIGATION ) APPLICATION AND UPDATE
PLAN AND AUTHORIZATION TO DEFER )
NEWLY IDENTIFIED INCREMENTAL )
WILDFIRE MITIGATION COSTS )
Idaho Power Company ("Idaho Power" or "Company"), in accordance with Idaho
Code § § 61-524 and -525 and Rule 52, Rules of Procedure' of the Idaho Public Utilities
Commission ("Commission" or "IPUC"), respectfully submits its 2025 Wildfire Mitigation
Plan ("WMP" or "Wildfire Plan") for review and requests that the Commission issue an
order authorizing the Company to defer through calendar year 2025—or until the
Company's next general rate case ("GRC") goes into effect—newly identified costs
associated with expanded wildfire mitigation efforts, as detailed in the 2025 WMP and
discussed in this Application. In conjunction with this request, the Company provides an
Hereinafter cited as RP.
APPLICATION AND UPDATE - 1

update on existing cost deferral authority associated with vegetation management and
insurance costs and requests the Commission confirm that the Company is correctly
interpreting its current authority for continued deferral of these previously approved
incremental cost categories as provided by Order No and 35717,2 and later extended
through the Settlement Stipulation for the Company's 2023 GRC.3 The Company will
continue to monitor these previously approved WMP cost categories going forward and
will report to the Commission in a future proceeding if deferral authority beyond the time
periods addressed in this case is warranted.
Idaho Power filed its initial wildfire mitigation cost deferral application in January
2021 and its second wildfire deferral application in October 2022. Since then, the
Company has navigated multiple wildfire seasons, using each as an opportunity to
evaluate and refine its mitigation strategies. More specifically, the Company has used the
recent wildfire seasons to gain insights and knowledge on wildfires and wildfire mitigation
activities, identify areas for expanded mitigation efforts, and grapple with cost areas that
continue to grow regardless of the Company's best efforts for efficiency—this has been
particularly true in the areas of vegetation management and insurance, as discussed
more in this Application.
In this Application, the Company has assessed its programmatic and personnel
needs following one of the most active fire seasons in recent memory and during which
the Company issued its first Public Safety Power Shutoff ("PSPS"). After a full evaluation
2 In the Matter of the Application of Idaho Power Company for an Accounting Order Authorizing the
Deferral of Incremental Wildfire Mitigation and Insurance Costs, Case No. IPC-E-21-02, Order No. 35077
(Jun. 17, 2021).
3 In the Matter of the Application of Idaho Power Company for Authority to Increase Its Rates and
Charges for Electric Service in the State of Idaho and for Associated Regulatory Account Treatment,
Case No. IPC-E-23-11, Order No. 36042 (Dec. 28, 2023).
APPLICATION AND UPDATE -2

of the 2024 season, Idaho Power has formed the enclosed list of necessary and justified
costs to expand its wildfire program, build necessary expertise, and continue to enhance
its wildfire mitigation efforts consistent with industry best practices and tools.
The Company respectfully requests the Commission's approval to defer the Idaho
jurisdictional share of newly identified incremental operation and maintenance ("O&M")
expenses related to wildfire mitigation until identified expenses can be included in base
rates or an alternate collection method is established. While the Company believes that
the newly identified incremental costs reflect wildfire mitigation costs generally approved
for deferral by the Commission in Order Nos. 35077, 35717 and 36042, Idaho Power
wishes to provide the Commission with opportunity for timely review of such incremental
costs to ensure transparency and alignment going forward. Consistent with the approach
in Idaho Power's prior wildfire cost deferral applications, the Company will seek the
amortization of these deferred costs, including a review of the actual costs associated
with mitigation efforts, in a future Commission proceeding. Idaho Power is not seeking to
change customer rates at this time.
To assist in the review of this Application and Update, Idaho Power provides the
following table of contents:
Description Page
I. Background 4
II. Forecast of New Incremental O&M for Wildfire Mitigation 7
Quantifying Wildland Fire Risk 9
Situational Awareness 9
Wildfire Mitigation Program & Personnel 11
Enhanced Vegetation Management 13
III. Update on Ongoing Wildfire Mitigation Deferrals 14
IV. Proposed Accounting Treatment 15
V. Modified Procedure 16
VI. Communications 16
VII. Request for Relief 17
APPLICATION AND UPDATE - 3

Additionally, accompanying and in support of this Application is Attachment 1:
Idaho Power's 2025 Wildfire Mitigation Plan.
I. BACKGROUND
Case No. IPC-E-21-02
1. On January 22, 2021, Idaho Power filed its first WMP4 with the Commission,
along with a request to defer incremental wildfire-related costs.5 In that application, the
Company provided an overview of wildfires in the West, discussed the evolving nature of
wildfire risk, introduced the structure and function of the WMP, and estimated costs of
wildfire mitigation efforts between 2021 and 2025. Specifically, the Company sorted
estimated incremental wildfire mitigation-related O&M expenditures into six categories:
Quantifying Wildland Fire Risk; Situational Awareness; Mitigation—Field Personnel
Practices; Mitigation—Transmission and Distribution ("T&D"); Enhanced Vegetation
Management; and Communications.
2. Idaho Power's application in Case No. IPC-E-21-02 estimated $46.6 million
in incremental O&M to implement wildfire mitigation measures. The Company requested
the authority to defer the Idaho jurisdictional share of incremental wildfire costs above a
base of 2019 actual costs.
3. This application also addressed other wildfire-related costs, namely
insurance. The Company noted that it had experienced a marked increase in insurance
costs in recent years, largely due to the impact of larger and more frequent wildfires and
natural disasters across the U.S. Idaho Power stated its expectation that insurance costs
would continue to rise but also stated that insurance costs tend to be volatile, making it
4 Idaho Power Company's Wildfire Mitigation Plan 2021 (Jan. 2021 (V1.0)).
5 See Case No. IPC-E-21-02, Application (Jan. 22, 2021).
APPLICATION AND UPDATE -4

difficult to estimate costs more than a year in advance. As a result, the Company did not
provide out-year estimates of insurance but requested the authority to defer the Idaho
jurisdictional share of annual insurance costs above 2019 levels.
4. Finally, Idaho Power identified capital investments it would make to "harden"
its system and infrastructure to wildfire events. The Company did not seek deferral of
those investments but rather requested the authority to defer actual depreciation
expenses associated with incremental capital investments made under the WMP.
5. On April 8, 2021, Commission Staff filed comments in support of the
Company's application, stating:
Staff reviewed the Company's Wildfire Plan to reduce the risk
posed by wildfires and the proposed accounting treatment
and believes they are reasonable. Staff recommends the
Commission approve the Company's Application to allow the
deferral of prudently incurred incremental O&M costs and
depreciation expenses associated with wildfire mitigation.6
6. On June 17, 2022, the Commission issued Order No. 35077 approving the
Company's deferral request. In particular, the Commission acknowledged enhanced
vegetation management as a critical component of the Company's wildfire mitigation
efforts:
We have reviewed the Company's forecast of incremental
O&M expenses for wildfire mitigation during 2021-2025. The
largest portion of this is attributed to incremental vegetation
management expenses. We agree that the Company should
operate its proposed three-year cycle of enhanced vegetation
management activities for four to five years to verify the cycle
can be beneficially maintained. As the Company increases its
vegetation management activities, we find it reasonable for it
to defer its Idaho jurisdictional share above its 2019 actual
costs.'
6 Case No. IPC-E-21-02, Comments of the Commission Staff at 2 (Apr. 8, 2021).
Id., Order No. 35077 at 7-8.
APPLICATION AND UPDATE - 5

7. With respect to insurance, the Commission found it reasonable for the
Company to defer the Idaho jurisdictional share of incremental insurance costs above the
2019 base level, noting that "[i]nsurance protects the Company and its customers from
unforeseen wildfire-related costs which have caused utility bankruptcy in recent years."$
8. The Commission also found it reasonable for Idaho Power to defer actual
depreciation expense associated with incremental capital investments and record such
investments in appropriate plant accounts as assets are placed in service.
Case No. IPC-E-22-27
9. On October 20, 2022, Idaho Power submitted its second wildfire cost
deferral application, requesting the authority to defer an additional $16.2 million in new
and expanded wildfire mitigation O&M across seven categories: Quantifying Wildland Fire
Risk; Situational Awareness; Mitigation—Field Personnel Practices; Mitigation—T&D;
Enhanced Vegetation Management; Communications; and Information Technology.9
Additionally, the Company provided an update on insurance costs and sought
confirmation from the Commission that Idaho Power was operating consistent with the
Commission's intent in Order No. 35077 to continue to defer the incremental costs
associated with insurance.
10. In Order No. 35717, the Commission granted the Company's request to
defer additional wildfire mitigation-related O&M, stating:
8 Id. at 8.
9 See In the Matter of Idaho Power Company's Application for Review of the Company's Current Wildfire
Mitigation Plan and Authorization to Defer Newly Identified Incremental Wildfire Mitigation Costs, Case
No. IPC-E-22-27, Application (Oct. 10, 2022).
APPLICATION AND UPDATE -6

We have reviewed the Company's Application and believe its
proposals described in its WMP, including the implementation
of the PSPS plan, are reasonable and grant the Company's
request for a deferred accounting of the associated costs.10
11. The Commission also reiterated its prior decision to allow ongoing deferral
of the Company's incremental insurance costs, stating:
The Company may defer its Idaho jurisdictional incremental
O&M expenses, incremental insurance expenses, and
depreciation expenses for its capital expenditures related to
the WMP through 2025, or the effective date of rates from the
Company's next general rate case, whichever comes first."
Case No. IPC-E-23-11
12. In Order No. 36042, the Commission approved the Settlement Stipulation
filed in the 2023 GRC, allowing the Company to continue deferring incremental vegetation
management and insurance expenses exceeding the 2022 baseline until either the next
general rate case or through 2025.
II. FORECAST OF NEW INCREMENTAL O&M FOR WILDFIRE MITIGATION
13. Development of the Company's 2025 WMP came on the heels of the most
active fire season in recent history. The National Interagency Fire Center ("NIFC")
recorded 252 wildfire starts and 1,509,455 acres burned in or near Idaho Power's service
area during the 2024 season 12 with 996,76211 acres burned in the State of Idaho. While
the number of fire starts was slightly above the 30-year average of 235, the number of
acres burned almost doubled the 30-year average of 860,725.14 Drawing from its
1° Case No. IPC-E-22-27, Order No. 35717 at 8 (Mar. 23, 2023).
" Id., at 9.
12 Attachment 1 — Idaho Power's 2025 Wildfire Mitigation Plan at 13.
13 National Interagency Coordination Center—Wildland Fire Summary and Statistics Annual Report 2024,
at 44. https://www.nifc.gov/sites/default/files/NICC/2-
Predictive%20Services/Intelligence/Annual%2OReports/2024/annual report 2024.pdf
14 Attachment 1 — Idaho Power's 2025 Wildfire Mitigation Plan, at 13.
APPLICATION AND UPDATE - 7

experiences during 2024's active fire season, Idaho Power conducted a comprehensive
evaluation of its entire wildfire program including activities, tools, and personnel, and
identified several critical measures to strengthen and enhance its existing efforts. These
items fall into four categories: Quantifying Wildland Fire Risk, Situational Awareness,
Wildfire Program & Personnel, and Enhanced Vegetation Management. The Company's
internal wildfire program and personnel were broken into its own category in this filing to
ensure a clear understanding of how the Company intends to grow its internal wildfire
team to provide necessary expertise and coverage of wildfire issues.
14. The costs presented below in this Application constitute additional costs
(i.e., costs above what was previously forecasted and presented to the Commission in
Case Nos. IPC-E-21-02 and IPC-E-22-27). For each category, Idaho Power identifies the
need for the additional incremental spending to bolster wildfire mitigation work.
15. In total, Idaho Power requests to defer approximately $23.2 million in
incremental O&M expenses associated with new or expanded wildfire mitigation efforts.
These estimates are measured on a system-wide basis, but the Company is seeking to
defer only the Idaho jurisdictional share of new incremental expenses.
Table 1. Forecast of Idaho Power System New Incremental O&M Expenditures
Related to Wildfire Mitigation, 2025 ($000s)
2025
Quantifying Wildland Fire Risk
D;mamic Risk Modeling Tools I. 2,11131-1
Situational Awareness
Ideather Forecasting-System development and support 1 215
Drone Beyond Visual Line of Sight Waiver 1 120
Aerial Drone Inspection Pilot Project $ 214
Standby Helicopter Service $ 358
Wildfire Program&Personnel
%iildfire Team Program Labor $ 618
Patrolmen for Wildfire Safety Inspections $ 253
PSPS and Event flanagement Support $ 188
Vegetation Management
Transition toVaintain 3-year Vegetation Management Cycle $ 18,522
Enhanced Practices for Distribution Red&Yellow Risk Zones
(Pre-Fire Season PatrolslMitigation,Pole Clearing,Removals,
WOrk8A $ 715
Forecast New Incremental O&M Expenditures Total S 23,233
APPLICATION AND UPDATE - 8

Quantifying Wildland Fire Risk:
16. Assessing and monitoring wildfire risk is the cornerstone of Idaho Power's
wildfire mitigation efforts. Beginning in 2025, the Company is transitioning to a wildfire risk
modeling platform that will give Idaho Power more granular insight into wildfire risk across
the Company's service area, allow the Company to incorporate weather modeling into
risk assessments, and help the Company produce updated risk maps of its service area
and transmission corridors.
17. The Company will also expand its fire spread simulation modeling to gain
deeper insight into fire behavior and the potential consequence of wildfire ignitions within
the Company's service area. Additionally, Idaho Power will be investing in a variety of
tools and databases to help the Company assess the efficacy of its wildfire mitigation
spending with respect to risk reduction.
18. In 2025, Idaho Power plans to invest approximately $2 million in advanced
wildfire risk modeling tools to enhance its wildfire mitigation efforts. Initial risk maps
developed in 2020, laid a critical foundation for the Company's programmatic
development, operational practices, and infrastructure investments. However,
advancements in modeling technology now offer superior capabilities, including real-time
weather data and sophisticated fire behavior models for more precise, risk informed
decision making.
Situational Awareness:
19. Situational awareness plays a vital role in the Company's ability to
adequately prepare for and operate during times of heightened wildfire risk. Each wildfire
season, through its own experience as well as those of other utilities, Idaho Power learns
APPLICATION AND UPDATE - 9

more about how to enhance situation awareness through a variety of means. For the
coming fire season and beyond, the Company has identified four (4) areas for expanded
situational-awareness efforts.
20. First, Idaho Power has developed a weather tool that allows the Company's
atmospheric scientists to combine weather models and other data, thereby enhancing the
Company's accuracy with weather modeling and reducing forecast-to-forecast variability.
In 2025, the Company will rely on a contractor, the National Center for Atmospheric
Research, to complete an evaluation and validation of the data to identify any outlying
results and improve focus of the machine learning methodology used to produce
forecasts. This ensemble approach also provides information to inform up-to-the-minute
decision-making for issuing Fire Potential Index readings and PSPS events.
21. Second, Idaho Power will pursue a waiver from the Federal Aviation
Commission to operate drones beyond the visual line of sight ("BVLOS"). Today, the
Company's drones cannot be operated out of the line of site of its pilots, thereby limiting
the reach and usefulness of drones for conducting inspections and performing other
wildfire-related and infrastructure assessments. The BVLOS waiver would allow drone
operators to inspect Idaho Power facilities in more remote and hard-to-reach locations,
which would allow the Company to collect high-quality data, enhancing the efficiency of
inspections.
22. Third, Idaho Power will also begin an aerial drone inspection pilot project to
explore more standardized use of drones for line and facility inspections. This pilot
program will evaluate the value of fully integrating drones into the wildfire program by
beginning with specific areas of focus to determine necessary workflows for completing
APPLICATION AND UPDATE - 10

the inspections and whether drone data collection can match or surpass the quality of in-
person inspections.
23. Finally, the Company is expanding its contract for standby helicopter
service. This standby service was incredibly valuable during the 2024 fire season to
enable accurate and rapid assessment of the Company's infrastructure following storms
and to determine if any debris or other obstructions had impacted Idaho Power's lines. In
recent years, the Company has encountered growing difficulties in securing helicopter
availability on short notice during the summer months, a time characterized by heightened
wildfire risks and the potential for major outages in remote areas. Expanding the standby
service over the peak months of wildfire season ensures availability during this critical
time, enabling enhanced situational awareness, faster response times, reduced impacts,
and more timely restoration for customers.
24. The amounts listed above—totaling $907,000 for 2025—are incremental to
the Company's prior deferral and reflect additional expenditure beyond the situational
awareness costs previously presented to the Commission.
Wildfire Mitigation Program & Personnel
25. Idaho Power's wildfire mitigation program has grown significantly in the last
few years. For much of this time, the Company operated with existing personnel who were
reallocated to perform wildfire functions. One of the key lessons from the past year is that
wildfire work is truly a year-round effort that requires dedicated staff to prepare for,
manage, and learn from each wildfire season.15 While the Company adheres closely to
15 Idaho Power's 2025 Wildfire Mitigation Plan at 17 ("Idaho's wildfire season is defined by Idaho Code §
38-115 as extending from May 10 through Oct. 20 each year, or as otherwise extended by the Director of
the Idaho Department of Lands ("IDL").")
APPLICATION AND UPDATE - 11

the official wildfire season in Idaho running from May 10 to October 20, the work to
mitigate risks, maintain readiness and analyze lessons learned extends well beyond
these months. In 2025, the Company will add key personnel to ensure adequate expertise
and coverage in several areas.
26. To strengthen Idaho Power's wildfire mitigation efforts, the Company will
hire additional personnel to support critical functions essential for reducing wildfire risk
and enhancing system safety. The new roles include Wildfire Mitigation Specialists, who
will oversee the development, implementation, and compliance of wildfire mitigation
programs and projects. Their responsibilities will encompass managing risk modeling
activities, leading technology pilot initiatives, supporting system hardening efforts, and
formulating comprehensive fire response strategies. They will also play a role in
overseeing fuel reduction initiatives, conducting detailed risk assessments, and fostering
collaboration with both internal teams and external stakeholders to continuously improve
mitigation strategies.
27. In addition, Idaho Power will employ Patrolmen dedicated to performing
critical safety inspections of power lines in wildfire prone areas. Their duties will include
conducting pre-season patrols to proactively identify potential hazards, performing
thorough post-incident assessments to evaluate infrastructure integrity following wildfire
events, and utilizing drone-based inspections to detect and address ignition risks that may
not be visible through traditional methods.
28. Furthermore, a PSPS and Wildfire Event Management Specialist will be
added to provide critical support during wildfire seasons and PSPS events. This specialist
will serve as a central point of coordination and communication, helping to ensure smooth
APPLICATION AND UPDATE - 12

and effective information flow between Idaho Power, internal employees, customers, and
affected communities. Their role will be pivotal in maintaining operational efficiency,
enhancing emergency response efforts, and ensuring that timely, accurate information
reaches all stakeholders during critical events.
29. These positions are vital to sustaining Idaho Power's ongoing efforts to
reduce wildfire risk and enhance public safety. The total cost for these new positions in
2025 is $1,059,000, as shown in the table above.
Enhanced Vegetation Management:
30. As Idaho Power has explained in its prior wildfire deferrals, vegetation
management is both imperative to the Company's wildfire mitigation efforts and a source
of significant challenge. The availability of qualified labor has diminished while demand
for vegetation management services has grown across the Western United States.
Importantly, the vegetation management companies hired by Idaho Power and other
utilities are not simple arborists or landscapers. Vegetation management companies
qualified to work near electrical lines and equipment require special certifications and
training. The limited number of companies offering such qualified services are in high
demand in many Western states, and especially in California where labor rates are higher.
Higher turnover among skilled equipment operators, combined with the growing demand
for pruning techniques that require climbing, has created a need for more contract crews
than originally anticipated.
31. To help address these challenges, the Company has hired an internal three-
person vegetation management crew to help reduce ongoing pruning costs, improve
production levels, and mitigate rising expenses associated with contracted services. This
APPLICATION AND UPDATE - 13

initial crew will serve as a pilot program, allowing Idaho Power to evaluate its performance
and cost-effectiveness. The results of the pilot program will help determine the long-term
viability of internal crews and whether future expansion is warranted. Based on updated
projections, the Company estimates an additional $18.5 million will be required for
vegetation management to achieve a three-year pruning cycle.
32. Additionally, the Company will continue to invest in Enhanced Vegetation
Management practices in Tier 3 and Tier 2 wildfire risk zones.16 Enhanced practices
include annual patrols to identify pruning needs before trees contact power lines; mid-
cycle pruning for fast-growing trees; increased incentives to customers that own trees that
consistently regrow more rapidly than the three-year cycle (so-called "cycle buster" trees);
clearing and sterilizing soil around select distribution poles; and post-trimming audits on
all pruned trees in Tier 3 and Tier 2 wildfire risk zones.
33. In total, the Company forecasts spending an additional $19.2 million on
vegetation management in 2025.
III. UPDATE ON ONGOING WILDFIRE MITIGATION DEFERRALS
34. A feature of the Company's Commission-authorized 2023 GRC settlement
was ongoing authority to defer vegetation management and insurance costs either
through the end of 2025 or until the effective date of new rates in the Company's next
GRC, whichever came first. Subsequently, the Company made a limited-scope rate filing,
which was not contemplated by the 2023 GRC settlement, related to a limited set of
revenue requirement categories. Given the limited nature of that case, of which vegetation
16 Idaho Power's 2025 Wildfire Mitigation Plan, Section 3.2.2. Establishing Wildfire Risk Zones at 35.
(Based on quantitative modeling and qualitative adjustments, "[tjiers are established which, if exceeded,
would classify an area as Tier 2 (elevated risk) or Tier 3 (higher risk). ... Idaho Power color-codes the
tiers—yellow for Tier 2 and red for Tier 3 wildfire risk zones.")
APPLICATION AND UPDATE - 14

management and insurance costs were outside the scope, the Company does not believe
that proceeding would have precipitated termination of its deferral authority earlier than
the end of 2025.
35. In the Company's estimation, the Commission's order in the 2023 GRC
allows for continued deferral of both vegetation management and insurance costs through
2025. The base amount for deferred vegetation management costs is $24,848,875, and
for deferred insurance costs, it is $14,489,412. Any costs exceeding these amounts will
continue to be deferred until the earlier of the Company's next general rate case or
through 2025.17 The Company will continue to monitor these costs going forward and will
report to the Commission in a future proceeding if deferral authority beyond the time
periods address in this case is warranted.
36. The Company offers this update to ensure aligned understanding of the
Commission's intent and to ensure a difference of interpretation is clarified at the earliest
convenience, such that the Company can properly account for expenses via the cost
deferral mechanism.
IV. PROPOSED ACCOUNTING TREATMENT
37. Idaho Power seeks authorization from the Commission to defer, for future
amortization, the Idaho jurisdictional share of incremental wildfire mitigation O&M
expenses until these costs can be included in base rates or an alternate collection
method. The estimated O&M presented in this Application reflects new and expanded
activities and costs that are not duplicative of the costs presented in the Company's prior
wildfire cost deferral filings or in the 2023 GRC. Idaho Power will continue to measure all
" Case No. IPC-E-23-11, Direct Testimony in Support of Settlement Stipulation of Timothy E. Tatum at 13
(filed Oct. 27, 2023).
APPLICATION AND UPDATE - 15

actual wildfire-related costs from 2022 base levels, as authorized by the Commission in
Order No. 36042.
38. The Company will track actual expenses beginning January 1, 2025, and
proposes to record such incremental O&M amounts that would be subject to the deferral
in accordance with the Code of Federal Regulations to the Federal Energy Regulatory
Commission ("FERC") Account 182.3 (Other Regulatory Assets). The detailed costs and
recovery method of the costs associated with the Company's wildfire mitigation efforts will
be addressed in a future regulatory proceeding.
V. MODIFIED PROCEDURE
39. Idaho Power believes that it would be appropriate to process this case by
means of modified procedure (i.e., by written submission rather than by hearing) in
accordance with the provisions of RP 201, et seq. However, if the Commission prefers
another procedure for processing this case, Idaho Power will present its case in support
of the relief requested in this Application.
VI. COMMUNICATIONS
40. Communications and service of pleadings, with reference to this Application
should be sent to the following:
Lisa D. Nordstrom Kelley Noe
Megan Goicoechea Allen Regulatory Consultant
Idaho Power Company Idaho Power Company
P.O. Box 70 P.O. Box 70
Boise, Idaho 83707 Boise, Idaho 83707
Inordstrom(a-)idahopower.com knoe(o-)-idahopower.com
mgoicoecheaallen(a)_idahopower.com
dockets(a)idahopower.com
APPLICATION AND UPDATE - 16

VII. REQUEST FOR RELIEF
41. In ongoing consideration of the growing threat of wildfires in the West, Idaho
Power continues to examine its own practices, the practices of others, and industry
lessons learned to advance and implement effective wildfire mitigation measures. Taking
action to reduce the risk of wildfires is critical for Idaho Power's customers, the
communities in which the Company operates, and investors who provide capital to the
Company.
42. To that end, Idaho Power has reviewed its wildfire mitigation efforts and
identified several new and expanded actions to further reduce wildfire risk, which have
been incorporated into the 2025 WMP presented in this case.
43. The additional incremental O&M costs identified in this Application are vital
to ensuring that Idaho Power can implement necessary wildfire mitigation measures
across its service area. To continue to serve its customers safely and reliably through the
current fire season and beyond, the Company requests Commission confirmation of
Idaho Power's current authority to defer incremental vegetation management and
insurance costs as measured from a 2022 cost base and authorization to defer for later
ratemaking treatment the Idaho jurisdictional share of certain newly identified incremental
O&M costs associated with the actions and measures identified in this Application and
beginning January 1, 2025.
DATED at Boise, Idaho, this 13t" day of February 2025.
LISA D. NORDSTROM
Attorney for Idaho Power Company
APPLICATION AND UPDATE - 17

BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC-E-25-05
IDAHO POWER COMPANY
ATTACHMENT NO. 1
IDAHO POWER'S 2025 WILDFIRE MITIGATION
PLAN