20250710Supplement to Application.pdf

RECEIVED
July 10,2025
IDAHO PUBLIC
ADAM TRIPLETT UTILITIES COMMISSION
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 10221
Street Address for Express Mail:
11331 W CHINDEN BVLD,BLDG 8, SUITE 201-A
BOISE, ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF COMMISSION STAFF'S ) CASE NO. GNR-E-25-02
APPLICATION FOR APPROVAL OF A FILING )
PROCESS FOR WILDFIRE MITIGATION ) STAFF'S SUPPLEMENT
PLANS TO APPLICATION
Staff, pursuant to the Rules of Procedure of the Idaho Public Utilities Commission
("Commission"), submits additional information pertinent to this case in this Supplement to the
Application for a Wildfire Mitigation Plan Filing Process, Case No. GNR-E-25-02, filed on June
18, 2025 ("Original Application").
This Supplement includes the proposed "Commission Wildfire Mitigation Plan ("WMP")
Guidelines" pursuant to the minimum requirements in Idaho Code § 61-1803(3)(a)(g) and the
proposed"Need to Know Document"for electric municipalities and cooperatives to file with each
WMP. This Supplement provides additional information to the case and includes Staff's requests
for requiring each utility to include Staff's recommended components within each WMP as laid
out in Exhibit No. 1 and requiring each electric municipality and cooperative to file an "Need to
Know"document with its initial WMP filing as laid out in Exhibit No.2.Additionally,Staff intends
STAFF'S SUPPLEMENT TO APPLICATION
1

to address rolling WMPs,additional components to include within a WMP,amendments to WMPs,
and compliance reports.
I. BACKGROUND
On June 18,2025, Staff filed its Original Application to establish a regulatory filing process
for WMPs. Effective July 1, 2025, Idaho Code Title 61 Chapter 18 requires the Commission to
review and approve annual WMPs within six months while considering 1) the consistency of the
plan with the public health, safety, and welfare, 2) the feasibility of the plan and the cost of its
implementation, and 3) the degree to which the plan adequately minimizes wildfire risk and
proposes to respond to wildfires that do occur. Idaho Code § 61-1804.
The Original Application included a discussion of Staff's proposed filing process which
includes initial filing dates, annual review dates and requirements, compliance report
requirements,notice requirements,electric municipalities and cooperatives filings,review,charges
by the Commission, and other recommendations. In its Original Application, Staff proposed to file
a supplemental document to its Application on July 10, 2025, to include 1) Staff's proposed
guidelines outlining additional minimum requirements to be included within WMPs,and 2) Staff's
proposed "Need to Know Document" for electric municipalities and cooperatives to file with the
Commission to aid in Staff's review of each respective WMP.Application at 5.
On June 30, 2025, Staff met with the electric utilities to discuss Staff's Original
Application, a draft of Staff's proposed guidelines, compliance reports, filing dates, Commission
review and WMP costs. Following that meeting, Staff received feedback from multiple utilities
and has incorporated some of their feedback into Staff's proposed guidelines.
In a motion filed on June 18,2025, Staff proposed staggered filing dates for electric utilities
to allow for a regulatory process to be developed within this case.A regulatory process included
discussion of annual reviews of WMPs, components to be included within a WMP and compliance
reports pursuant to Idaho Code § 61-1803(3-5), and other recommendations such as investor-
owned utilities ("IOUs") meeting with the Commission for annual updates.
Staff provided notice of this supplement in its Original Application and does not believe
this will necessitate a change in its request for a Commission order by September 5, 2025.
STAFF'S SUPPLEMENT TO APPLICATION
2

II. PROPOSED WMP GUIDELINES
Each WMP must address each requirement contained in Idaho Code § 61-1803(3)(a)-(g)
with sufficient detail for the Commission to determine whether the plan reflects a reasonable
balancing of mitigation costs with the resulting reduction of wildfire risk. The plan's scope and
detail in discussing these requirements should be balanced with the electric corporation's size,
wildfire exposure, and operational complexity.
In previous orders,the Commission has ordered Idaho Powers and Rocky Mountain Power2
to have rolling WMPs and to file each updated version with the Commission. Avista Corp has a
ten-year WMP, in which each updated version is filed with the Commission.3 Staff believes it is
important to have a rolling plan as it shows the projections of mitigation efforts and estimated
expenditures over an extended period of time. A WMP should be able to detail its continuous
comprehensive approach to wildfire risk mitigation. Staff requests that each WMP should represent
at a minimum a three-year rolling plan, which would allow for Staff to review the projected
expenses for multiple years as the plan is implemented. As an example, if a multi-year plan for
2026-2028 is submitted,the subsequent plan update should be focused specifically on 2027-2029.
In Staff's Original Application, Staff stated it would propose additional minimum
requirements beyond the requirements listed in Idaho Code § 61-1803(3)(a)-(g) to be included in
a WMP to provide similar guidance to all utilities that plan to file a WMP. Application at 3-4.
Further, there may be other electric corporations that have not created a WMP prior to this new
legislation; therefore, the guidelines will assist each utility in its creation of its WMP. Following
collaboration with the interested parties in this case, Staff requests the Commission order each
utility to follow these reasonable guidelines listed within Exhibit No. 1 for any WMP to meet the
requirements for approval. Staff proposes the Commission accept Exhibit No. 1 as the
Commission's WMP Guidelines for each electric corporation's WMP filings.
Staff requests that the Commission order any further guidance on minimum requirements
to be within a WMP it deems necessary.
1 Order No.36042.This order approved the Stipulation and Settlement of Idaho Power's 2023 General Rate Case.The
Parties agreed to extend the WMP forecast to five years for each version. Stipulation and Settlement at 16.
2 Order No. 36405 at 7.The Commission ordered Rocky Mountain Power to file updated versions of its WMP every
three years.
3 Order No.35909.This order approved the Stipulation and Settlement of Avista's 2023 General Rate Case.The Parties
agreed to file a copy of each version of its WMP with the Commission. Stipulation and Settlement at 16.
STAFF'S SUPPLEMENT TO APPLICATION
3

For IOUs, Staff recommends that any recovery mechanism not be included in its WMPs.
Rather,recovery of wildfire mitigation costs should occur in a separate filing such as a general rate
case.
III. AMENDMENT OF WILDFIRE MITIGATION PLAN
In discussion with the utilities,the utilities requested the ability to amend filed or approved
WMPs with substantive changes and seek Commission approval for the amendments. Staff is not
opposed to amendments to the WMP; however Staff believes the utilities should provide an
explanation as to why amendments are necessary in its comments to this case. Staff believes
amendments should be adjustments to a utility's next WMP, as part of the utility's comprehensive
approach to continually improving wildfire mitigation efforts. Staff also proposes that any
amendments to WMPs would not have retroactive approval.
IV. COMPLIANCE REPORT
Pursuant to Idaho Code § 61-1803(5),an electric corporation with a Commission-approved
WMP shall submit a report detailing the electric corporation's compliance with that Commission-
approved WMP. Staff understands the utilities have some concerns with Staff's original proposal
of when to file compliance reports.As Staff believes the compliance reports will be necessary in
its review of WMPs, Staff proposes an alternative solution.
Staff proposes the electric corporation file its Compliance Report in the same docket in
which the WMP is approved one-year and 60 days following Commission approval of the WMP.
To aid in Staff's review of an annual WMP filing, Staff proposes the electric utilities provide a
compliance status update with its annual WMP filing, detailing its compliance and updates on
meeting its measurable targets/goals from the last Commission approved WMP to help inform any
changes to its new WMP.
In Staff's Original Application, Staff proposed compliance reports to include a list of any
fire that occurred within a utility's service territory during the compliance year.Application at 8.
After discussion with the electric utilities, Staff understands how this may be a burdensome task.
Staff proposes a more specific request for the compliance report to include a list of any fire that
ignites within a 1/4 mile of utility infrastructure or any fire that has burned into the utility's
infrastructure. Staff believes this will be informative to understand the fire risk of each utility.
STAFF'S SUPPLEMENT TO APPLICATION
4

V. NEED TO KNOW DOCUMENT
As stated in Staff's Original Application, the PUC does not typically regulate electric
municipalities and cooperatives and most of their operations are unfamiliar to Staff and the
Commission.Original Application at 5. Idaho Code § 61-1803 authorizes municipal corporations
and cooperatives to submit WMPs for the Commission's review. Staff believes Commission
approval of the WMP is necessary for these entities to benefit from the presumption created by
Idaho Code § 61-1805 and liability limitations under Idaho Code § 61-1806.Id.
Included as Exhibit No. 2 to this Supplement is Staff's initial draft of the "Need to Know
Document". This document will provide a baseline knowledge of an electric municipality or
cooperative. The document will require the municipalities and cooperatives to provide basic
information of a utility's operations, finances, and some of its current operating procedures. Staff
believes that this information will aid in Staff's review of balancing costs of mitigation efforts to
wildfire risk reduction based on the size and complexity of the electric corporation as required by
Idaho Code § 61-1803(3).
Staff requests the Commission order any electric municipalities and cooperatives that wish
to file a WMP for approval by the Commission to include detailed responses to the"Need to Know
Document" along with its WMP filing.
VI. COMMUNICATIONS AND SERVICE OF PLEADINGS
Communication and service of pleadings, exhibits, orders, and other documents relating to
this proceeding should be sent to the following:
Adam Triplett Taylor Thomas
Deputy Attorney General Idaho Public Utilities Commission
P.O. Box 83720 P.O. Box 83720
Boise, ID 83702-0074 Boise, ID 83702-0074
adam.triplett(&,puc.idaho.gov taylor.thomasC&,puc.idaho.gov
VII. REQUEST FOR RELIEF
Staff respectfully requests the Commission issue an order by September 5, 2025.
STAFF'S SUPPLEMENT TO APPLICATION
5

From Staff's Original Application, Staff requests a Commission Order:
1) Directing the issuance of quarterly invoices to each electric municipality and
cooperatives based on time and expense principles pursuant to Idaho Code § 61-1004
to review its WMP;
2) Requiring each utility to file WMPs on Staff's proposed annual review dates;
3) Requiring each utility to file its compliance report as a separate document;
4) Requiring each utility to provide a cost-benefit analysis to justify its expenditures to
risk mitigation for each WMP filing;
5) Requiring each compliance report to identify monthly targets with estimated costs and
monthly actuals with actual costs for measurable targets, goals, and metrics for
components of its WMP, explaining where each component within the compliance
report ties to its approved WMP;
6) Requiring each compliance report to explain how the utility complied with each
minimum requirement in Idaho Code § 61-1803(3) and any Commission orders within
this case or future orders, explaining any discrepancies;
7) If the Commission desires to continue wildfire update meetings with IOUs, require
annual update meeting dates to occur during the third week of May, outside of each
IOU's respective planned WMP annual review; and
8) Requiring each electric utility's notice to interested entities to include information
about how to participate in the Commission's proceeding,the case number, and provide
a copy of the notice to the Commission in its filing.
In addition to Staff's initial requests, Staff further requests a Commission order:
9) Requiring each WMP to represent at a minimum a three-year rolling plan;
10) Requiring an electric corporation to follow the guidelines listed within Exhibit No. 1
for any WMP to meet the requirements for approval;
11) Accepting Exhibit No. 1 as the Commission's WMP Guidelines for each electric
corporation's WMP filings;
12) With any further guidance on minimum requirements to be within a WMP it deems
necessary;
STAFF'S SUPPLEMENT TO APPLICATION
6

13) Order that any amendments to WMPs would not have retroactive approval;
14) Requiring the electric corporation to file its compliance report one-year and 60 days
after its WMP is approved,detailing its compliance with its previously approved WMP
in the docket that approved its WMP;
15) Requiring the electric utilities provide a compliance status update with its annual
WMP filing, detailing its compliance and updates on meeting its measurable
targets/goals to help inform any changes to its new WMP;
16) Requiring that each compliance report contain a list of any fire that occurred within'/4
mile of the utility's infrastructure or any fire that has burned into the utility's
infrastructure during the compliance year, explaining any unofficial or official
reported4 causes of ignition for the fire, the approximate location of the start of the
fire, and if there was any damage to company infrastructure, structures, property or
any persons; and
17) Requiring each electric municipality and cooperative to file an "Need to Know
Document" as filed in Exhibit No. 2 with its initial WMP filing.
Respectfully submitted this 1 Oth day of July 2025.
Adam Triplett
Deputy Attorney General
4 As reported by but not limited to the electric utility, State Fire Marshal, Department of Lands, Local Fire
Departments,Districts,and Associations.
STAFF'S SUPPLEMENT TO APPLICATION
7

CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 10`h day of July 2025, I served the foregoing STAFF'S
SUPPLEMENT TO APPLICATION, in Case No. GNR-E-25-02, via Electronic Mail to the
following:
Idaho Power Company: PacifiCorp d/b/a Rocky Mountain Power:
Megan Goicoechea Allen [e-mail] Joe Dallas ioseph.dallas(a_pacificorp.com
Donovan Walker dwalker(a)idahopower.com Mark Alder [e-mail]
Lisa C. Lance llance(a)idahopower.com data [e-mail]
Matt Larkin [e-mail]
Connie Aschenbrenner caschenbrenner(a)idahopower.com
Tim Tatum ttatum(a)idahopower.com
Riley Maloney [e-mail]
dockets(a idahopower.com
Avista Corporation: Atlanta Power:
Shawn Bonfield shawn.bonfield(abavistacorp com Nick Jones [e-mail]
David Meyer [e-mail] [e-mail]
Liz Andrews liz.andrews(abavistacorp.com [e-mail]
avistadockets(a)avistacorp.com
Raft River: Lower Valley Energy:
Chad Black [e-mail] Jim Webb [e-mail]
City of Bonners Ferry: Idaho County Light&Power:
Mike Klaus mklaus0bbonnersferry.id.gov Max Beach mbeachPiclp.coop
Fall River Electric: Idaho Falls Power:
Bryan Case bryan.case(a-Ofallriverelectric.com Bear Prairie bprairie ifpower.org
Linden Barney linden.barney(@fallriverelectric.com Stephen Boorman sboorman(a)ifpower.org
Randy Wakefield randy.wakefield(&fallriverelectric.com Richard Malloy rmalloyaifpower.org
David Peterson d ave.petersonafallriverelectric.com
Northern Lights, Inc.: Kootenai Electric Cooperative:
Annie Terracciano annie.terraccianoanli.coop Michael G.Andrea mandreaakec.com
Kristin Burge kristin.burge a nli.coop Thomas Maddalone tmaddaloneakec.com
Trevor Kelly trevor.kelly(a nli.coop
Lost River Electric Cooperative: Clearwater Power:
Brad Garnett brad CaArecoop.com Tell Stanger tstanger - clearwaterpower.com
United Electric: Idaho Consumer-Owned Utilities
Michael Darrington mdarrington -uec.coop Association:
Will Hart whart _ icua.coop
STAFF'S SUPPLEMENT TO APPLICATION
8

PotlatchDeltic Corp:
Peter J. Richardson peter richardsonadams.com
Michele Tyler micheLe.tyler(@potLatchdettic.com
Anna Torma anna.torma(cbpotlatchdeltic.com
Wade Semeliss [e-mail]
Brian Schlect brian.schlect(c potlatchdeltic.com
Jeremy Pisca iaisca(a)rischpisca.com
KERI J. AWKER
Legal Assistant to Adam Triplett
STAFF'S SUPPLEMENT TO APPLICATION
9

EXHIBIT NO. I
Idaho Public Utilities Commission
Wildfire Mitigation Plan Guidelines

Intention of the Wildfire Mitigation Plan Guidelines
The intention of this document is to serve as guidelines for creating a Wildfire Mitigation
Plan ("WMP") for approval by the Commission.
As required by I.C. § 61-1803(3),a WMP at a minimum must include the elements outlined
in I.C. § 61-1803(3)(a)-(g). Staff recommends the Commission consider the areas detailed in each
section below to be included in the utilities WMP filing as written. Staff will review this
information in each WMP filing for approval by the Commission.
I.C. § 61-1803(3)(a) - Geographical Risk Assessments
"Identifying geographical areas where an electric corporation has infrastructure or
equipment that the electric corporation considers may be subject to a heightened
risk of wildfire at the time the wildfire mitigation plan is finalized by the electric
corporation"
The electric corporation must include a description of the wildfire risk assessment or model
used to guide wildfire mitigation activities. The assessment should identify geographic areas with
elevated fire risk, considering factors such as vegetation, weather, topography, historical fire
occurrence, structure density, and asset location.
The electric corporation should provide a map of the identified risk areas within its service
territory within this section of its WMP. The identified risk areas should be defined with different
level of fire risks to the utility. There must be an explanation of what determines each level of risk
and risk assessments of each service territory should be updated annually in the WMP.
I.C. § 61-1803(3)(b) - Preventative Actions and Programs
"Preventative actions and programs that the electric corporation will carry out to
reduce the risk of wildfire."
The electric corporation must describe all preventative actions and programs that it will
carry out to reduce the risk of wildfire, in addition to actions and programs specified in statute and
by this Commission. For the three large investor-owned utilities,' Staff recommends that previous
1 Avista Corp.,Idaho Power,and Rocky Mountain Power.
WMP GUIDELINES 2 EXHIBIT NO. 1

areas of focus of each utility's WMPs continue to be included within its WMPs. A WMP's
preventative actions and programs may include,but is not limited to:
• Situational Awareness efforts
o Which may include use of technology to aid in weather monitoring, fire season
outlook, daily, weekly, and monthly weather and fire modeling risk, etc.
o Consistent with 61-1803(3)(f) and Staff's proposed requirements within.
• Asset Inspections
o Frequency and standards of inspections for each type of electric infrastructure
within areas of elevated wildfire risk.
o Consistent with 61-1803(3)(g)(i) and Staff's proposed requirements within.
• System hardening strategies
o Which may include pole replacements, line rebuilding, or undergrounding if
necessary, strategic fuse or reclosers installations, etc.
• Enhanced vegetation management practices in risk zones
o Which may include shorter vegetation management cycles than routine cycles,
risk tree programs, etc.
o Consistent with 61-1803(3)(g)(iii) and Staff's proposed requirements within.
• Operation practices during heightened wildfire risk days or zones.
o Which may include restrictions to workforce practices, potential use of pro-
active de-energization (Consistent with 61-1803(3)(g)(ii) and Staff's proposed
requirements within), etc.
• Workforce Preparedness
o Which may include workforce training, equipment provided to employees to
reduce the risk of wildfire, etc.
• Pilot Programs
o If applicable.
• Community education
o Which may include public service announcements to create awareness and
provide education of wildfire risks,providing preventative measures, etc.
o Consistent with 61-1803(3)(c) and 61-1803(3)(d)
• And any additional requirements ordered by the Commission.
WMP GUIDELINES 3 EXHIBIT NO. 1

I.C. § 61-1803(3)(c) - Public Outreach and Engagement
"Community outreach and public awareness efforts that the electric corporation
will use before, during, and after wildfire season to identify and inform the public
of relevant wildfire risks and notify the public of wildfire-related outages."
This section should include discussion of how each utility maintains community outreach
and public awareness before, during, and after wildfire season to support customer awareness and
education of wildfire risks and notify the public of wildfire-related outages. This discussion should
include, but is not limited, to the following:
• Description of customer communication efforts related to wildfire mitigation, including
efforts to increase awareness and education of the utility's plan, explanation of key
mitigation activities, and efforts supporting public readiness.
• If the utility utilizes de-energization, a description of public education efforts and
communication protocols for before, during, and after a de-energization event. The
communication protocols should clearly identify which customers could and will be
impacted if a de-energization event is pursued and identify any advanced notifications for
critical infrastructure or customers, which may include but not limited to, hospitals and
other medical facilities, schools, police, fire, emergency operation centers, any
jails/prisons, other utilities, and vulnerable customers.
• Explanation of the communication methods the electric corporation intends to use, such as
mail, flyers, emails, calls, texts, a notification system, its website, etc.
I.C. § 61-1803(3)(d) - Government Outreach
"Outreach efforts to coordinate with federal, state, tribal, and local officials and
agencies on wildfire preparedness and emergency response plans."
The electric corporation must describe how it engages with and coordinates with federal,
state, tribal, and local officials and agencies on wildfire preparedness and emergency response in
the plan year. This discussion may include,but is not limited to:
• If applicable, Public Safety Power Shutoff ("PSPS") tabletop exercises with interested
parties and agencies
WMP GUIDELINES 4 EXHIBIT NO. 1

• Communication with the agencies and the ESF-12 coordinator within the PUC.
• If applicable, mitigation efforts with the agencies.
The WMP must detail all relationships (such as BLM and Forest Service)
it has established that may benefit the wildfire mitigation program, contribute to program costs, or
provide cost sharing opportunities in its WMP.
I.C. § 61-1803(3)(e) - Method of Line Design
"Financially prudent and reasonably practicable methods of line design for new,
planned, and existing lines to mitigate fire risk."
The electric corporation must describe how its methods of line design for new lines and
planned upgrades reduce wildfire ignition potential in heightened wildfire risk areas. This must
include evaluation of costs to wildfire risk reductions. Additionally, this must include how the
electric corporation clearly identifies, selects, and evaluates projects that are least-cost, least-risk
for the following, but is not limited to:
• Line rebuilding within the WMP.
• Undergrounding lines within the WMP.
• Installation of covered conductor.
• Installation of non-wooden cross arms.
• If any, describe any flexible infrastructure such as automatic reclosers and remote-
controlled devices that support remote operations.
I.C. § 61-1803(3)(f) - Situational Awareness and Monitoring
"Monitoring of forecasted and current weather data for the purpose of assessing and
responding to current and anticipated fire risk."
This section should include a description of how the electric corporation monitors
forecasted and current weather conditions for the purpose of assessing and responding to current
and anticipated wildfire risk. This description must include,but is not limited to, the following:
• Identification of systems, tools, or external resources used to monitor weather, fire
potential, or other situational awareness indicators.
WMP GUIDELINES 5 EXHIBIT NO. 1

• If applicable, a description of how the utility utilizes weather forecasting, fire potential
modeling, or similar tools, to inform mitigation activities and operational decisions.
• Discussion of how situational awareness capabilities are integrated into daily or seasonal
wildfire operations.
• Discussion of how the electric utility become aware of another electric corporation's de-
energization (e.g., Bonneville Power Administration) and how that is integrated into
operations.
Developing Standards,Procedure, and Schedules
Idaho Code 61-1803(3)(g) requires each electric corporation to "[develop] standards,
procedures, and schedules, subject to timely approval of access to rights-of-way, if necessary..."
for the 1) Infrastructure Inspection and Maintenance, 2) De-Energization, and 3)Vegetation
Management.
I.C. § 61-1803(3)(g)(i) - Infrastructure Inspection and Maintenance
"Inspection of the electric corporation's assets, infrastructure, and facilities within
the areas that are identified as heightened fire risk areas in the wildfire mitigation
plan, were financially prudent and reasonably practicable."
This section should provide a summary of electric corporation's programs for the
inspection of electric infrastructure, assets, and facilities within areas identified as heightened
wildfire risk areas to identify and correct conditions that could contribute to wildfire ignition. This
summary must include, but is not limited to, the following:
• Description of inspection standards for each type of infrastructure, assets, and facilities.
• Description of schedules for inspections for each type of infrastructure, asset, and facility.
• Description of baseline routine inspection methods and enhanced inspection methods for
higher fire risk areas, which may include the use of advanced or pilot technologies.
• Explanation of how identified defects are classified,prioritized, and corrected.
• Measurable targets/goals to be achieved within the WMP. E.g., miles of lines inspected,
corrected identified defects, etc.
WMP GUIDELINES 6 EXHIBIT NO. 1

I.C. § 61-1803(3)(g)(ii) -De-Energization
"De-energization of the electric corporation's power lines,if considered appropriate
by the electric corporation."
If an electric utility plans to use de-energization as part of its wildfire mitigation efforts,
this section must address the standards, criteria, and operational protocols, for de-energization for
encroachment of a wildfire, proactive de-energization (PSPS) to reduce fire risk, de-energization
if requested by a fire agency, de-energization from 3rd party energy providers, and de-energization
for planned utility work for wildfire mitigation. This discussion must include, but is not limited
to the following:
• A summary of the conditions under which de-energization may be used, if applicable.
• The criteria or protocols for evaluating its appropriateness to engage.
• Summary of the electric corporation's operational protocols for before, during, and after a
de-energization event.
• Description of how the electric corporation will coordinate with local emergency
managers,operators of critical facilities,and affected communities before,during,and after
a de-energization event.
• Descriptions of other operations for limiting impact to affected communities; which may
include community resource centers, emergency generators, backup batteries, etc.
I.C. § 61-1803(3)(g)(iii) -Vegetation Management
"Vegetation management within the areas that are identified as heightened fire risk
areas in the wildfire mitigation plan and are within the electric corporation's rights-
of-way or lands adjacent thereto and that threaten the power lines or other electric
corporation infrastructure. If live marketable timber is identified for removal from
timber company land adjacent to the rights-of-way, compensation at fair market
value shall be made to the landowner for such timber."
This section must provide an overview of the utility's vegetation management program
aimed at reducing the risk of vegetation-related contact with electric infrastructure in areas with
heightened wildfire risk within its rights-of-way or lands adjacent thereto. Elements of this
vegetation management section overview should include, but is not limited to, the following:
WMP GUIDELINES 7 EXHIBIT NO. 1

• Identification, description, and citation of vegetation management standards for elevated
wildfire risk areas.
• Explanation of how vegetation management standards, procedures, and schedules are
different or the same as routine vegetation management.
• Description of the current and planned vegetation management practices used to mitigate
wildfire risk, including any enhancements in designated wildfire areas.
• The electric corporation must explain how the electric utility considered vegetation
management recommendations by other federal, state, and county agencies into its
standards.
• Must include measurable targets/goals to be achieved within the WMP. E.g.,miles of lines
completed, risk trees removed, etc.
• Explanation of how identified risk trees are classified,prioritized, and corrected.
Other Items to Include in a WMP
1) An update of lessons learned from the previously approved WMP within the annual filings
for WMP review and approval.
2) A breakdown of each program category's forecasted costs by year for both capital and
O&M expenditures through the length of the WMP.
3) A section in which it describes how the electric corporation addresses each of the
Commission's orders and Staff's recommendations.
WMP GUIDELINES 8 EXHIBIT NO. 1

EXHIBIT NO. 2
Electric Municipalities and Cooperatives
"Need To Know" Document

Electric Municipality and Cooperative Wildfire Mitigation Plan
Need to Know Document
Pursuant to Idaho Code § 61-1803(3), a Wildfire Mitigation Plan ("WMP") must be
reflective and commensurate with the size and complexity of the electric corporation's operations
and of the nature of the fire risk. A WMP must also reflect a reasonable balancing of mitigation
costs with the resulting reduction of wildfire risk.
The purpose of this document is to collect basic information that will aid in Staff's review
to process a WMP. Please provide the following information and provide the document along with
each respective WMP filing.
1. Name of Utility
2. Location of Utility:
a. Located inside of the Wildland Urban Interface?
3. Please provide a map of the Company's service territory. Please identify the Company
assets and provide a PDF zoomable.
4. Total number of Customers:
a. Residential
b. Commercial
c. Other
5. How is energy supplied to the Company? i.e., BPA, utility-owned generation, etc.
a. What is the name plate capacity in Megawatts ("MW") of utility-owned generation
sources?
b. What is the capacity factor of utility-owned generation sources?
6. What is the annual amount of energy in Megawatt-hours that the utility serves?
7. What is the peak demand in MW and when does it occur?
8. Standard operating procedures ("SOP") for infrastructure management and vegetation
management?
a. Annual spend?
b. Annual incremental spend proposed in WMP from SOP?
9. Last 3 years of financial statements:
a. Income Statement
b. Cash Flow Statement
c. Balance Sheet
NEED TO KNOW DOCUMENT 1 EXHIBIT NO. 2