20250807Comments_3.pdf

The following comments were submitted via PUCWeb:
Name: Chad Black
Submission Time: Aug 7 2025 9:02AM
Email: cblack(@rrelectric.com
Telephone: [phone]
Address: PO Box 617
Malta, ID 83342
Name of Utility Company: Raft River Rural Electric Cooperative, INC
Case ID: GNR-E-25-02
Comment: "I would ask the filing process be such that small non-regulated cooperative
utitlities can file their wildfire mitigation plans in a timely manner to ensure protection for
2026. 1 would also mention that there does not need to be cost-justification requirements
as part of the filing process, as small member owned cooperatives are governed by local
democratically elected boards.This also would eliminate the need of overburdensome
requirments like reporting every fire, cause of ignition, and other details of each fire, as
there are state and federal agencies that can porovide this information if absolutely
necessary. It is also my hope that we can work together with the commision to establish
reasoneable, prudent and pragmatic annual reporting requirements, to obtain compliance
with the legislative intent. I hope these comments are helpful and will be considered. I
appreciate the oppurtunity. "
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Name: Max Beach
Submission Time: Aug 7 2025 9:44AM
Email: mbeach((:biclp.coop
Telephone: [phone]
Address: 1065 Highway 13
Grangeville, ID 83530
Name of Utility Company: Idaho County Light and Power
Case ID: GNR-E-25-02
Comment: "Idaho PUC,
Thank you for allowing us to make these comments and explain a little information about
our cooperative.
Idaho County Light and Power is a locally owned, not-for-profit electric cooperative serving
parts of Idaho County and Lewis Counties in North Central Idaho. We were formed in 1938
and serve 4,600 meters through 1,000+ miles of powerline. With 14 dedicated employees,
serving our membership is of high priority. We operate under seven board members
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elected by the membership serving 3-year terms. The board hires a general manager that
oversees day to day operations. We are one of the smaller electric cooperatives in Idaho
and primarily serve residential and small commercial members.
Comments on GNR-E-25-02 regarding the Wildfire bill that was recently enacted into law.
1. We are hoping that the Idaho PUC will consider expediating the filing dates for non-PUC
regulated utilities who are ready to file.
2. Since ICL&P is regulated by an elected board of directors and operate on a not-for-
profit basis, we ask that the proposed cost-justification requirements not be overly
burdensome on small utilities. We would also be interested in the Idaho PUC accepting a
utility board approved resolution that elected board members have approved any costs
associated with our wildfire mitigation plans.
3. Fire Reporting: We believe that the fire reporting requirements are overly burdensome
for small utilities and not our duty to report as we are not the ones that put out the fires, in
most instances. This information would be better suited to come from the appropriate
state and federal agencies.
4. Annual Compliance Reports: More work and discussion needs to happen between the
Idaho PUC and 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."
Thank you for your time.
Max Beach
General Manager of Idaho County Light& Power
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The following comment was submitted via PUCWeb:
Name: Michael Darrington
Submission Time:Aug 7 2025 11:19AM
Email: [e-mail]
Telephone: [phone]
Address: 1330 21 st St
Heyburn, ID 83336
Name of Utility Company: United Electric Co-op, Inc.
Case ID: GNR-E-25-02
Comment: "Thank you for the opportunity to comment on Staff's Application for a Wildfire
Mitigation Plan Filing Process (Application) as described in Case No. GNR-E-25-02. These
comments are submitted on behalf of United Electric Co-op, Inc. (United).
United is a distribution electric cooperative that provides service to its member-customers
in Cassia and Minidoka counties of Southern Idaho. United is governed by an eight-member
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Board of Directors (Board) elected from the cooperative's membership. United's Board
establishes policies, direction, and vision for the cooperative and exercises its fiduciary
responsibility to ensure that United is managed in a manner consistent with industry
standards and good business practices.
United has been preparing its wildfire mitigation plan in accordance with the requirements
of the Wildfire Standard of Care Act (Act) and intends to submit an application seeking the
Commission's approval of the plan once complete and pursuant to the Commission's
process. In anticipation of submitting a Board approved wildfire mitigation plan to the
Commission, United respectfully offers the following comments and recommendations in
Case No. GNR-E-25-02.
Cost-Justification -
Utilities like United are not regulated by the Commission.As a cooperative utility, United
operates and delivers energy to its member-customers at-cost pursuant to the policies and
regulatory requirements of its elected Board. Due to the structure and practice of the
cooperative business model, that includes Board oversight of the utility's budget, policy
development and jurisdiction, and fiduciary responsibilities of the Board that includes
prudent and reasonable cost management, United believes utilities not regulated by the
Commission should be exempt from the proposed cost-justification requirements.The Act
provides the requirements for the Commission to approve wildfire mitigation plans that
considers the feasibility and cost of implementation of the plans. However, United believes
the Commission should rely upon the local Board's approval of its utility's wildfire
mitigation plan as a reasonable determination of the feasibility of the plan and the cost of
implementing the plan. Alternatively, the proposed requirements should be extensively
modified to reflect the business model and Board oversight of not-for-profit utilities.
Fire Reporting-
Staff recommends the Commission require that each compliance report associated with
wildfire mitigation plans contain a list of any fire that occurred within one quarter mile of
the utility's infrastructure or a fire that has burned into the utility's infrastructure during the
compliance year. United believes this requirement is overly broad, burdensome, and
extends beyond the requirements of the Act. In fact, it is United's understanding and belief
the Act does not require that utilities report the existence or cause of fires. While United
may not be opposed to providing general, limited, and relevant information associated with
a fire that it may be aware of and that has a direct impact on the utility's system, any cause
of fire, activity and actions taken, or specific fire related information should be obtained by
an appropriate and qualified agency or entity to provide such information.
Filing Dates and Annual Compliance Reporting- United understands the Act allows the
Commission to schedule filing dates for utilities submitting plans for approval, however,
the current proposal puts utilities that are not regulated by the Commission at a
disadvantage. United respectfully requests the Commission consider more flexible filing
options for cooperatives that are ready to file so they have the opportunity for their plans to
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be approved prior to the 2026 fire season. Utilities need flexibility to seek Commission
approval of wildfire mitigation plans based on each utility's assessment of fire risk and
seasonality.
Finally, United respectfully requests that more work be done between the Commission,
Staff, and all utilities on the annual compliance reporting requirements. United believes
the current scope of the proposed requirements for annual compliance reporting extends
beyond the scope of the legislative intent of the Act. United is willing to participate in
workshops, if the Commission desires to schedule, to consider what information is
necessary and relevant to be included in compliance reports.
United appreciates the opportunity to submit these comments and for the work the
Commission and Staff are performing in this case. United's primary goal in obtaining
Commission approval of a wildfire mitigation plan is to meet the intent and requirement of
the Act while preserving the independent roles and responsibilities of United's Board.
United looks forward to working with Staff and the Commission to provide what is needed
for Commission approval as directed by the Act."
Sincerely,
Michael Darrington
General Manager
United Electric Co-op, Inc.
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