20250805Comment_1.pdf

The following comment was submitted via PUCWeb:
Name:Telly Stanger
Submission Time: Aug 5 2025 4:35PM
Email: tstanger clearwaterpower.com
Telephone: [phone]
Address: 4230 Hatwai Road
Lewiston, ID 83501
Name of Utility Company: Clearwater Power Company
Case ID: GNR-E-25-02
Comment: "Clearwater Power Company(CPC) would like to offer comments on four
aspects of case GNR-E-25-02.
1) Expedited Filing Schedule: CPC has had a board approved Wildfire Mitigation Plan
(WMP) in place for several years and is ready to submit this plan to the IPUC immediately.
We respectfully request that the commission establish a schedule for submitting WMPs for
approval that ensures that WMPs for all electric corporations can be reviewed and
approved as early as practical and, in any event, before the 2026 wildfire season.
2) Exemption or Major Modification of Cost-Justification Requirements on non-
regulated utilities: As a rural electric cooperative, Clearwater Power Company is regulated
by a democratically elected Board of Directors who approve budgets and maintains the
organization's fiduciary responsibility to it's members to be operated as a not-for-profit
utility.The Act requires the Commission to ensure that WMPs satisfy certain minimum
requirements and requires that the Commission to consider the feasibility and cost of
implementation of WMPs. CPC respectfully submits that the Commission can satisfy the
requirements of the Act by obtaining resolutions or attestations from the governing boards
of non-IOUs that those boards have reviewed the applicable costs and feasibility of their
WMPs and determined that they reflect a reasonable balancing of mitigation costs with the
resulting reduction of wildfire risk.
3) Fire Reporting: The Act does not require that utilities report the existence or causes
of fires. The fire reporting request is overly burdensome and not the duty of a utility. The
Commission should obtain this kind of information from the appropriate state and federal
agencies.
4) Annual Compliance Reports: More work needs to be done between the PUC and all
utilities on the annual compliance reporting requirements. We believe that the current
scope of the proposed requirements for annual compliance reporting extends beyond the
scope of the legislative intent. CPC respectfully recommends that the Commission
conduct workshops with all electric corporations to determine what should be included in
annual reports required by the Act.
Sincerely,
Telly Stanger Chief Executive Officer
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