20250807Comments_1.pdf

1 Lost River Electric Cooperative,Inc.
Tel: [phone]
P.O.Box 420
LR�i,49W­ Mackay,ID 83251
[e-mail]
RECEIVED
August 6, 2025 August 7, 2025
IDAHO PUBLIC
Idaho Public Utilities Commission UTILITIES COMMISSION
P.O. Box 83720 Boise, ID 83720-0074
11331 W. Chinden Blvd. Building 8, Suite 201-A
Boise, ID 83714
Submitted via email
RE: Case No. GNR-E-25-02
Idaho Public Utilities Commission and Staff,
I express my appreciation to staff of the Idaho Public Utilities Commission(Commission)for the
time and effort spent in preparing to implement the Wildfire Standard of Care Act (Act). I also
extend my thanks to staff for being open to ideas for suggestions in how proposed compliance to
the Act will be implemented. This correspondence relates to the specific content forwarded by
Commission staff within STAFF'S SUPPLEMENT TO APPLICATION CASE NO. GNR-E-25-
02 (accepted 07/10/2025).
Under Section VII Request for Relief of the document, seventeen items were presented for
recommended compliance with the Act. Of these items the following, I wish to address three
(items 4, 5 and 16). I have no specific recommendations for the remaining items other than
indicating my general support of Commission staff recommendations regarding such and
respectfully requesting that the Commission remain open to proactive dialogue in developing
those items.
Items Section VII Request for Relief:
4) Requiring each utility to provide a cost-benefit analysis to justify its expenditures to
risk mitigation for each WMP filing;
I ask that the Commission refine this interpretation of the Act to consider both the size and
complexity of a utility's operation with regard to wildfire mitigation practices. Precise and
complex metrics in determining the "cost-benefit" of a wildfire mitigation practice or
expenditure verses justification of a generally accepted and reasonable wildfire mitigation
practice that comports with other components of an approved wildfire mitigation plan ought to
suffice this requirement. I can see that this requirement might likely become overly burdensome
for smaller utilities wishing to submit a plan for Commission approval.
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
------------------Member-owned since 1939-----------------

1 Lost River Electric Cooperative,Inc.
Tel: [phone]
y P.O.Box 420
t Mackay,ID 83251
[e-mail]
components of its WMP, explaining where each component within the compliance
report ties to its approved WMP;
In interest of overburdening small utilities who wish to file a wildfire mitigation plan with the
Commission, I believe that a roundtable or workshop type forum for developing effective
methodology for annual reporting would be beneficial to both the Commission and participating
utilities in setting this standard. "Monthly"reporting to the extent stated in this proposed
requirement appears to be overly burdensome for small utilities (i.e. small member-owned
cooperatives)who generally report these metrics on Rural Utilities Service Form 7 and Internal
Revenue Service Form 990 filings which are filed on an annual basis.
16) Requiring that each compliance report contain a list of any fire that occurred within
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;
I acknowledge progress that the Commission has made to-date with regard to refinement of this
reporting requirement relative to the initial scope of detail proposed. I do not see the specific
requirement in the Act that mandates reporting of wildfire occurrence, other than such reporting
would be helpful for informing the Commission as it monitors developments associated with the
type of events described in sections 61-1806 LIABILITY (1) and 61-1803 WILDFIRE
MITIGATION PLANS (3) c and (5). I urge the Commission to limit language in this item
request strictly to (1)those fires that were either ignited or may reasonably determined to have
been ignited from a utility's system or as a result of a utilities actions, or(2) those wildfire events
that materially impacted a utility.
Finally, with Commission staff having revised initial proposed filing date timeframes to a
currently indefinite status, I urge Commission staff to expedite the initial filing dates (allowing
for staggering) for all utilities to occur well prior to the 2026 wildfire season.
Respectfully,
-6UA �- %6&W%X0Z_
Brad J. Garnett
General Manager
------------------Member-owned since 1939-----------------