20250807Comments.pdf

' Kootenai Electric
COOPERATIVE RECEIVED
August 7, 2025
IDAHO PUBLIC
UTILITIES COMMISSION
August 7, 2025
Via Email Only
Secretary Monica Barrios-Sanchez
Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd. Building 8, Suite 201-A
Boise, ID 83714
Email: [e-mail]
Re: Comments of Kootenai Electric Cooperative, Inc.
Case No. GNR-E-25-02
Dear Secretary Barrios-Sanchez:
Please find attached Kootenai Electric Cooperative, Inc.'s ("KEC") comments for filing
in the above-referenced proceeding. Please let me know if you have any questions regarding the
attached filing.
Sincerely,
lsl Michael G. Andrea
Michael G. Andrea
General Counsel
Attachment
cc: Service List
9014 W. Lancaster Rd. I Rathdrum, ID 83858 M © O
TEL [phone] I TOLL FREE 800-240-0459 I FAX [phone]
EMAIL [e-mail] I WEB kec.com

Michael G. Andrea(ISB No. 8308)
General Counsel
Kootenai Electric Cooperative, Inc.
9014 W Lancaster Rd
Rathdrum, ID 83858
Phone: [phone]
Email: [e-mail]
Attorney for Kootenai Electric Cooperative, Inc.
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF COMMISSION )
STAFF'S APPLICATION FOR ) CASE NO. GNR-E-25-02
APPROVAL OF A FILING PROCESS FOR )
WIDLFIRE MITIGATION PLANS ) COMMENTS OF KOOTENAI
ELECTRIC COOPERATIVE, INC. TO
COMMISSION STAFF'S APPLICATION
FOR APPROVAL OF A FILING
PROCESS FOR WILDFIRE
MITIGATION PLANS
Pursuant to the Idaho Public Utilities Commission's ("Commission") Rule of Procedure
203, and the Notice of Modified Procedure issued in this proceeding on July 24, 2025 (Order No.
36686), Kootenai Electric Cooperative, inc. ("KEC") submits these comments in response to
Commission Staff s Application for a Wildfire Mitigation Plan Filing Process ("Application")
and Staffs Supplement to Application("Supplement") in the above-captioned matter.
Comments are due on or before August 7, 2025. Order No. 36686.
As more fully discussed herein, KEC respectfully requests that the Commission establish
a schedule for submitting wildfire mitigation plans ("WMPs") for approval pursuant to the
Wildfire Standard of Care Act("Act") that ensures that WMPs for all electric corporations that
desire to file a wildfire mitigation plan can be reviewed and approved by the Commission as
early as practical and, in any event,before the 2026 wildfire season. KEC further requests that
the Commission limit the information regarding costs related to WMPs that electric corporations,
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and in particular electric corporations that are not public utilities, are required to provide to the
Commission. 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. See I.C. § 61-1804(1). KEC respectfully submits that the
Commission satisfy the requirements of the Act by obtaining resolutions or attestations from the
governing bodies of non-IOUs that those governing bodies have reviewed the applicable costs
and feasibility of their WMPs and determined that(i) they reflect a reasonable balancing of
mitigation costs with the resulting reduction of wildfire risk, and(ii) that the WMPs include
financially prudent and reasonably practicable methods of line design for new,planned, and
existing lines to mitigate fire risk. See I.C. § 61-1803(3), 61-1804(l). The Commission should
ensure that its review and approval of WMPs does not inadvertently usurp non-public utility
electric corporations' governing bodies' authority with regard to costs and rates.
Finally, as a general matter, the Commission should ensure that all information that the
Commission requires electric corporations to provide is useful and necessary to review and
approve WMPs and updates to those WMPs, and that such requirements are not overly broad or
unduly burdensome. KEC requests that the Commission direct Commission Staff to hold
workshops with electric corporations to determine the appropriate information to be provided in
periodic reports required by the Act.
I. Background
In the 2025 legislative session, the Idaho Legislature enacted the Wildfire Standard of
Care Act. 2025 Idaho Sess. Laws Ch. 249 (S.B. 1183). The Act allows electric corporations that
are not public utilities, including KEC, to adopt and file WMPs with the Commission"at any
time permitted by the commission." I.C. § 61-1803(2)(b). The Commission is required to
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approve or reject WMPs that are filed with the Commission within six (6)months of the date
such WMPs are filed. I.C. § 61-1804(1).
The Act provides that"[a] commission-approved plan shall establish measures for the
electric corporation to prepare for and address wildfire risk and shall establish the electric
corporation's duty to its members and the public." I.C. § 61-1805. Importantly, the Act
establishes "a rebuttable presumption that an electric corporation acted without negligence if,
with respect to the cause of a wildfire, the electric corporation reasonably implemented a
commission-approved wildfire mitigation plan." I.C. § 61-1806(1). Finally, the Act provides
electric corporations the ability to perform vegetation management and fire mitigation work on
private,public and tribal property over the landowner's objection so long as such work is
performed in accordance with a commission-approved WMP. I.C. § 61-1807.
Since the enactment of the Act, KEC has been preparing a WMP to comply with the
requirements of the Act. KEC's intent is to file its WMP as soon as possible so that its WMP is
approved by the Commission well before the 2026 wildfire season.
On June 18, 2025, Commission Staff submitted its Application. Staff states that its
primary objective in this proceeding is to establish a regulatory process that each investor-owned
utility("IOU"), electric municipality and cooperative utility can follow to comply with the Act.
Application at 1. Staff proposes staggered filing dates for the IOUs and recommends that other
electric corporations, including cooperatives, file their WMPs "no earlier than December 1,
2025[.]" Id. at 6-7.
On July 10, 2025, Commission Staff submitted its Supplement. In its Supplement, Staff
provides additional information and includes a request to require each utility to include Staff's
recommended components as set forth in Exhibit 1 to the Supplement. Supplement at 1. Staff
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also requests that each electric municipality and cooperative file a"Need to Know" document as
set forth in Exhibit 2 to the Supplement. Id. at 1-2.
II. Comments
KEC appreciates Commission Staff initiating this proceeding to establish a process for
filing WMPs to comply with the Act. KEC respectfully submits the following comments in
response to Staff s Application and Supplement.
A. The Commission Should Establish an Expedited Schedule for Filing WMPs
to Ensure that All Electric Corporations have an Opportunity to have an
Approved WMP Before the Start of the 2026 Wildfire Season.
The Act authorizes the Commission to order WMPs to be filed at a date determined by it
and may stagger filing dates. I.C. § 61-1803(2)(a). Electric corporations that are not public
utilities may adopt and file a WMP "at any time permitted by the commission." I.C. § 61-
1803(2)(b). The Commission is required to approve or reject WMPs that are filed with the
Commission within six (6)months of the date such WMPs are filed. I.C. § 61-1804(1).
In its Application, Staff proposed a schedule for filing WMPs. Application at 6-7.
Pursuant to Staff s proposed schedule, the first investor-owned utility("IOU"), Idaho Power,
would not be allowed to file its WMP until October 1, 2025. Id. at 6. That is almost a month
after Staff anticipates a final order in this proceeding. See Application at 9 (requesting an order
by September 5, 2025); Supplement at 2 (stating that Staff does not believe the Supplement will
necessitate a change in its request for an order by September 5, 2025). Rocky Mountain Power
and Avista, would not be able to file until October 17 and November 10, 2025, respectively. Id.
Staff further proposes that all other electric corporations, including KEC, be prohibited from
filing WMPs until at least December 1, 2025. Id. at 7.
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Staff states that it believes that its proposed filing dates "will provide sufficient time for
the Commission to review and approve or reject all currently anticipated WMPs before the next
fire season, defined as May 10 October 20 each year by the Idaho Department of Lands." Id. at
2.nl. However, Staff anticipates that at least eleven non-IOU entities intend to file a WMP with
the Commission. Id. at 6. Accordingly, if Staff s proposed schedule is adopted, the Commission
will need to review at least twelve (Atlanta Power's and eleven non-IOU entities') WMPs in the
period from December 1, 2025 to May 9, 2026. See id. at 6-7.
It is important that all electric corporations are afforded an opportunity to have an
approved WMP well before the start of the 2026 wildfire season so that they can be prepared to
implement their approved plans before the wildfire season commences. Staff s proposed
schedule for filing WMPs calls into question the ability for KEC, and other non-IOU utilities, to
have an approved WMP prior to the 2026 wildfire season.1
KEC requests that the Commission establish a schedule for filing WMPs that, to the
extent practical, ensures that all electric corporations (IOUs and non-IOUs) are afforded an
opportunity to have an approved WMP as soon as reasonably possible. Specifically, the
Commission should allow the IOUs to start filing their WMPs as soon as a final order is issued in
this proceeding. The Commission should also consider shortening the amount of time between
each IOU's filing.z The remaining electric corporations, including KEC, should be allowed to
file their WMPs no later than November 1, 2025, to ensure that all WMPs are reviewed and
approved(or rejected)no later than May 1, 2026. See I.C. § 61-1804(1) (requiring the
1 KEC notes that,if the Commission takes the full six months allowed under the Act to review and approve or reject
a WMP filed on December 1,2025,such WMP would not be approved until the end of May 2026—nearly a month
after the start of the 2026 wildfire season.
2 Staff proposes 17 days between the first IOU(Idaho Power's)filing and Rocky Mountain Power's filing,24 days
between Rocky Mountain Power's filing and Avista's filing,and 21 days between Avista's filing and the earliest
date that all other electric corporations would be allowed to file their WMPs.
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Commission to review and accept or reject each WMP within six months of receiving such
WMP).
B. The Commission Should Limit its Requests for, and Review of, Information
Regarding Costs of Electric Corporations that are Not Public Utilities to
Ensure that the Commission is Not Engaging in Rate Regulation or
Otherwise Usurping the Authority of the Governing Bodies of those Utilities.
The Act requires WMPs to identify the means for mitigating wildfire risk that reflect a
reasonable balancing of mitigation costs with the resulting reduction of wildfire risk including,
among other things, financially prudent and reasonably practical methods of line design for new,
planned, and existing lines to mitigate fire risk. I.C. § 61-1803(3). In reviewing WMPs, the
Commission is required to ensure that the minimum requirements of the Act are satisfied and is
to consider, among other things, "the feasibility of the plan and the cost of its implementation."
I.C. § 61-1804(1).
Commission Staff requests a significant amount of information regarding costs to be
included with, or in, each WMP and/or compliance report that is filed with the Commission,
including:
• A cost-benefit analysis to justify the utility's expenditures for risk mitigation in its WMP
(Supplement at 6);
• An evaluation of costs to wildfire risk reductions associated with its methods of line
design for new lines and planned upgrades to reduce wildfire ignition potential in
heightened wildfire risk areas (Supplement at Exhibit 1);
• A breakdown of each program category's forecasted costs by year for both capital and
O&M expenditures through the length of the WMP (Supplement at Exhibit 1); and
• Identification in each annual compliance report of monthly targets with estimated costs
and monthly actuals with actual costs for measurable targets, goals, and metrics for
components of the utility's approved WMP (Supplement at 6).
Staffs requests for information do not distinguish between public utilities and electric
corporations that are not public utilities. The information requested by Staff goes well beyond
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what is necessary for the Commission to satisfy the requirements under the Act. More
fundamentally, to the extent that Staff requests information from electric corporations that are
not public utilities to "justify the utility's expenditures" (Supplement at 6), such requests are not
appropriate.
Much of the information that Staff is requesting will not provide useful information to
the Commission for its review. For example, Staff requests cost-benefit analysis to justify
expenditures for risk mitigation for each WMP. Supplement at 6. This request fails to recognize
that, in most instances, wildfire risk mitigation is just one of several factors that may be
considered with regard to any particular expenditure. In most instances, it is difficult, and
probably impossible, to distinguish between the costs attributable to wildfire risk mitigation
associated with certain activities—such as undergrounding lines, installing steel poles, replacing
outdated equipment, and even vegetation management—and costs of normal operations or costs
to improve service or for reliability. To perform the requested cost-benefit analysis, utilities
would need to assign a certain portion of such costs to wildfire risk mitigation. Any such
assignment of costs to wildfire mitigation (as opposed to some other purpose, such as reliability)
would be arbitrary, at best. Therefore, the requested cost-benefit analysis would not provide any
useful information.
The same issue discussed above with regard to Staff s request for a cost-benefit analysis
applies equally to other cost information requested by Staff, including its request for an
evaluation of costs to wildfire risk reductions associated with its methods of line design for new
lines and planned upgrades to reduce wildfire ignition potential in heightened wildfire risk areas.
See Supplement at Exhibit 1. In rare cases, some action may be taken specifically for wildfire
mitigation. In most instances, wildfire mitigation is just one of many factors that is considered in
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deciding on methods of line design for new lines and planned upgrades. Assigning costs to any
specific factor would be arbitrary. Attempting to evaluate the costs of wildfire risk reductions
associated with methods of line design would be a purely academic endeavor that would not
yield any useful information for the Commission to evaluate.
Staff s requests also are likely to usurp non-IOUs' governing boards' authority with
regard to costs and rates. Electric corporations that are not public utilities (i.e. the non-IOU
utilities) are not subject to rate regulation by the Commission. See, e.g.,Bollinger v. Fall River
Rural Elec. Coop., Inc., 152 Idaho 632, 641 n.7, 272 P.3d 1263, 1272 n.7 (2012); Clearwater
Power Co. v. Washington Water Power Co., 78 Idaho 150, 151, 299 P.2d 484, 485 (1956);
Sutton v. Hunziker, 75 Idaho 395, 401, 272 P.2d 1012, 1015 (1954). While the Act does require
the Commission to ensure the minimum requirements of the Act are satisfied and to consider the
feasibility of the WMP and the costs of its implementation, the Act does not authorize the
Commission to engage in rate regulation of electric corporations that are not public utilities. See
I.C. § 61-1804(1). Therefore, to the extent that Staff requests information from any electric
corporation that is not a public utility to "justify its expenditures" or to explain how the utility
"evaluates projects that are least-cost", such requests are not appropriate. See Supplement at 6,
Exhibit 1,page 5. The governing bodies of non-IOUs, such as KEC's board of directors, are
charged with reviewing their respective utility's costs and regulating rates. The Commission
should ensure that its review of WMPs and updates and periodic reports under the Act does not
infringe upon the authority of the non-IOUs' governing bodies.
KEC respectfully submits that the Commission can satisfy the requirements of the Act
without usurping non-IOU' governing bodies' authority. For example, the Commission can
satisfy the requirements of the Act by obtaining assurance from each non-IOUs' governing body
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(in the form of an attestation or board resolution, for example) that such governing body has
reviewed the feasibility of its WMP and the costs of its implementation and has determined that
(i) the WMP reflects a reasonable balancing of mitigation costs with resulting reduction of
wildfire risk, and(ii) the methods of line design for new, planned, and existing lines to mitigate
fire risk are financially prudent and reasonably practicable. See I.C. §§ 61-1803(3), 61-1804(1).
KEC intends to file a WMP for review and approval by the Commission and is prepared
to work with the Commission and Commission Staff to satisfy the requirements of the Act. KEC
is also prepared to work collaboratively with Staff to develop a process for attesting to its board's
review of its WMP and its costs of implementing its WMP.
The Commission should ensure that the information non-IOUs are required to submit to
the Commission is necessary and is useful and does not create undue burden on those utilities.
The non-IOU utilities are considerably smaller than the IOUs and do not have the staff that is
available to the larger IOUs. Finally, the Commission should ensure that it is not inadvertently
infringing on non-IOUs' governing boards' authorities and regulating non-IOUs' rates through
its review and approval of WMPs.
C. The Commission Should Reject Staffs Request for Utilities to Report Fires.
In its Supplement, Staff requests that the Commission require 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 reported 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[.]" Supplement at 7 (internal footnote omitted). This request is overly broad, unduly
burdensome, and exceeds the requirements of the Act.
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The Act requires electric corporations to submit reports on an annual basis (or such other
basis as the Commission may prescribe). I.C. § 61-1803(5). These reports are required to
include "documentation describing the development and adoption of the wildfire mitigation
plan's components and measures,the wildfire mitigation expenditures, and the work taken to
develop and adopt the plan's components and measures." Id. In sum, the Act requires each
utility with an approved WMP to provide a report regarding its development and work on the
mitigation plan and a description of its wildfire mitigation expenditures. The Act does not
require or contemplate that utilities report the existence or causes of fires.
KEC is not the appropriate entity to report on the existence or causes of fires. KEC has
no way of knowing about all fires that occur in the areas that it serves. Fires may occur at
locations within 1/4 mile of KEC's infrastructure without KEC knowing, or having any reason to
know, about the fire. This is especially true if the location where the fire occurs is served by a
utility other than KEC.3 Additionally, KEC is not the appropriate entity to determine or report
the causes of any fires. To the extent that an official cause of a fire is determined by a qualified
agency or entity, the Commission should obtain such cause from that qualified agency or entity.
To the extent that there is no official cause of a fire, KEC cannot speculate on the cause.
KEC does not object to some limited reporting regarding the occurrence and general
location of any fire that it is aware of and that directly impacts its electric system. The scope of
that reporting should be addressed in workshops (see request for workshops below)to determine
the contents of periodic reports. To the extent that the Commission desires to collect information
about all fires within a 1/4 of a mile of KEC's infrastructure and the causes of those fires, it should
3 KEC notes that Avista and KEC have facilities in the same general geographic areas in and around Kootenai
County,Idaho. In several locations in the area that it serves,KEC's electric system in close proximity to Avista's
facilities.
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obtain that information from the appropriate agency or entity, such as state and local fire
districts, the Idaho Department of Lands,National Interagency Fire Center, the National Fire
Incident Reporting System, and/or the Integrated Reporting of Wildfire Information(IRWIN)
system. Requiring utilities like KEC to monitor, investigate, and report the official or unofficial
causes of all fires within 1/4 mile of their infrastructure would require significant additional
staffing and would be unduly burdensome.
D. The Commission Should Conduct Workshops with All Electric Corporations
to Determine What Should be Included in Reports Required by the Act.
The Act requires utilities with approved WMPs to submit periodic reports describing
their development of WMP components and measures and descriptions of their wildfire
mitigation expenditures. Specifically, the Act requires each electric corporation with an
approved WMP to,
submit a report to the commission updating the commission on the electric corporation's
compliance with its wildfire mitigation plan on an annual basis or such other basis as the
commission may prescribe by rule or order. The report shall include documentation
describing the development and adoption of the wildfire mitigation plan's components
and measures, the wildfire mitigation expenditures, and the work taken to develop and
adopt the plan's components and measures.
I.C. § 61-1803(5).
The information that Staff requests to be included in each such report includes:
• Identification of monthly targets with estimated costs and monthly actuals with actual
costs for measurable targets, goals, and metrics for components of the utility's approved
WMP;
• An explanation of 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;
• 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; and
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• A list of any fire that occurred within 1/4 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 reported 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 person.
Supplement at 6-7.
The information that Staff is requesting is not limited to descriptions of development of WMP
components and measures and descriptions of their wildfire mitigation expenditures. Staff s
requests regarding periodic reporting go well beyond the requirements of the Act.4
The Commission should not issue an order mandating the contents of periodic reports at
this time. To ensure that the periodic reports that are submitted provide useful information to the
Commission and comply with the requirements of the Act, KEC requests that the Commission
direct Staff to conduct workshops with electric corporations to discuss the information to be
included in those reports and to provide the Commission recommendations for periodic reports
based on those workshops. Such workshops will ensure that the periodic reports required by the
Commission provide useful information and do not create undue burdens on utilities or the
Commission. Staff requests that the first report be submitted one year and 60 days after the first
WMP is approved. Supplement at 4, 7. Therefore, there is ample time for the parties to conduct
such workshops before the first report is due to be filed.
E. The Commission Should Ensure that Any Guidelines Regarding WMPs
Provide Sufficient Flexibility to Allow Smaller Electric Corporations the
Ability to Develop WMPs that are Reflective of and Commensurate with the
Size and Complexity of Their Operations and the Nature of the Fire Risk.
Staffs Supplement states that"[fJollowing collaboration with the interested parties in this
case, Staff requests the Commission order each utility to follow these reasonable guidelines
a KEC notes that in some instances, Staff s requests appear to be duplicative(compare the first and third bullet
above,for example).
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listed within Exhibit No. 1 for any WMP to meet the requirements for approval."' Supplement at
3. The Act requires WMPs to "be developed using approaches and methods that are designed to
protect the public interest and are reflective of and commensurate with the size and complexity
of the electric corporation's operations and the nature of the fire risk." I.C. § 61-1803(3).
KEC is concerned that the requirements in Exhibit 1 are designed for larger IOUs. For
example, Staff s Exhibit 1 includes a requirement for all electric corporations to "include how
the electric corporation clearly identifies, selects, and evaluates projects that are least-cost, least-
risk" for projects such as line rebuilding, undergrounding, etc. Supplement at Exhibit 1, page 5.
Similarly, Staff s request that each WMP represent a minimum three-year rolling plan to "allow
Staff to review the projected expenses for multiple years as the plan is implemented." Id. at 3.
These requirements go beyond the requirements of the Act and may infringe on non-IOUs'
governing bodies' authority. As discussed above, wildfire mitigation is just one of many factors
that is considered in evaluating projects such as line rebuilding and undergrounding. Requesting
information about how the utility identifies projects that are least-cost necessarily requires
information about factors that are not related to wildfire mitigation. Requesting smaller utilities
to project expenses up to three years out creates similar concerns.
KEC appreciates the guidelines provided by Staff in Exhibit 1 to its Supplement.
However, those guidelines appear to be developed primarily for, and in collaboration with, larger
IOUs and should not be rigidly applied to all electric corporations. The Commission should
ensure that any guidelines regarding WMPs provide sufficient flexibility to allow smaller electric
5 Exhibit 1 to Staff s Supplement appears to be the result of collaboration between Staff and the IOUs. KEC did
participate in a Staff presentation on WMPs and subsequently had a conversation with Staff about the cost
information being requested from non-IOUs but otherwise has not collaborated with Staff on the contents of WMPs.
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corporations the ability to develop WMPs that are reflective of and commensurate with the size
and complexity of their operations and the nature of the fire risk. See I.C. 61-1803(3).
III. Conclusion
KEC appreciates the opportunity to submit comments for consideration in this
proceeding. As more fully discussed above, KEC respectfully requests that the Commission (i)
adopt a schedule for filing WMPs that ensures that all electric corporations have an opportunity
to obtain an approved WMP prior to the 2026 wildfire season, (ii) ensure that any information
that non-IOUs are required to submit to the Commission is useful and necessary and that such
information is not used to inadvertently regulate the rates of those non-IOU utilities or otherwise
usurp the authority of the non-IOU utilities' governing bodies, (iii)reject Staff s request to
require electric corporations to report fires and the official or unofficial causes of those fires, and
(iv) require Staff to conduct workshops with electric corporations to determine what information
should be included in periodic reports and to provide the Commission recommendations for
those reports based on those workshops before the Commission issues any order mandating the
contents of those periodic reports. Finally, the Commission should ensure that any guidelines
regarding WMPs provide sufficient flexibility to allow smaller electric corporations the ability to
develop WMPs that are reflective of and commensurate with the size and complexity of their
operations and the nature of the fire risk. See I.C. 61-1803(3).
Respectfully submitted this 7th day of August 2025.
KOOTENAI ELECTRIC COOPERATIVE, INC.
lsl Michael G. Andrea
Michael G. Andrea
General Counsel
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CERTIFICATE OF SERVICE
I HEREBY CERTIFY that I have this 7th day of August 2025, served the foregoing
Comments of Kootenai Electric Cooperative, Inc. upon all parties of record in this proceeding by
electronically providing a copy thereof to:
Commission Staff:
Adam Triplett
Deputy Attorney General
Idaho Public Utilities Commission
PO Box 83720
Boise, ID 83702-0074
Email: [e-mail]
Avista Corporation:
Anni Glogovac Elizabeth Andrews
Counsel for Regulatory Affairs Sr. Manager of Revenue Requirements
PO Box 3727 PO Box 3727
1411 E. Mission Ave., MSC-13 1411 E. Mission Ave., MSC-27
Spokane, WA 99220-3727 Spokane, WA 99220-3727
Email: [e-mail] Email: [e-mail]
w/copy to:
[e-mail]
Bennett Lumber Products, Inc.
Idaho Forest Group
Manulife Investment Management,
Molpus Woodlands Group,
Stimson Lumber Company:
Pendrey P. Trammell
Smith+Malek, PLLC
601 E. Front Ave., Ste. 304
Coeur d'Alene, ID 83814
Email: [e-mail]
CERTIFICATE OF SERVICE

City of Idaho Falls:
Stephen Boorman Michael A. Kirkham
Interim General Manager City Attorney
City of Idaho Falls, Idaho—Idaho Falls Power City of Idaho Falls, Idaho
PO Box 50220 PO Box 50220
140 S. Capital Ave. 375 "D" Street
Idaho Falls, ID 83402 Idaho Falls, ID 83402
Email: [e-mail] Email: [e-mail]
Idaho Department of Lands:
J.J. Winters Tyre Holfeltz
Attorney for Idaho Department of Lands Wildfire Risk Mitigation Program Manager
300 N. 61 Street, Ste. 103 300 N. 61 Street, Ste. 103
Boise, ID 83702 Boise, ID 83702
Email: [e-mail] Email: [e-mail]
Idaho Power Company:
Megan Goicoechea Allen Tim Tatum
Donovan E. Walker Riley Maloney
Lisa C. Lance Connie Aschenbrenner
Idaho Power Company Idaho Power Company
PO Box 70 PO Box 70
Boise, ID 83707 Boise, ID 83707
Email: mgoicoecheaallen@idaho Email: [e-mail]
[e-mail] [e-mail]
[e-mail] [e-mail]
w/copy to:
[e-mail]
PotlatchDeltic Corporation:
Michele Tyler, Esq.
Peter J. Richardson Anna Torma
Richardson Adams, PLLC Wade Semeliss
515 N. 271h St. Brian Schlect, Esq.
Boise, ID 83702 601 W. First Ave. Ste. 1600
Email: [e-mail] Spokane, WA 99201
Email: [e-mail]
[e-mail]
[e-mail]
[e-mail]
CERTIFICATE OF SERVICE

Risch Pisca, PLLC
Attn: Jeremy Pisca
407 W. Jefferson Street
Boise, ID 83702
Email: [e-mail]
Rocky Mountain Power:
Mark Alder Joe Dallas
Idaho Regulatory Affairs Manager Senior Attorney
1407 West North Temple, Suite 330 825 NE Multnomah, Suite 2000
Salt Lake City, Utah 84116 Portland, OR 97232
Email: [e-mail] Email: [e-mail]
lsl Michael G. Andrea
Michael G. Andrea
General Counsel
CERTIFICATE OF SERVICE