20250807Comments.pdf

' 11
RECEIVED
August 7, 2025
Avista Corp. IDAHO PUBLIC
1411 East Mission P.O. Box 3727 UTILITIES COMMISSION
Spokane, Washington 99220-0500
Telephone [phone]
Toll Free 800-727-9170
August 7, 2025
Monica Barrios-Sanchez
Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd
Building 8, Suite 201-A
Boise, ID 83714
RE: Case No. GNR-E-25-02 — Commission Staff s Application for Approval of a Filing
Process for Wildfire Mitigation Plans
Dear Commission Secretary:
Enclosed for electronic filing with the Commission is Avista's comments in Case No. GNR-E-25-
02.
Please direct any questions regarding these comments to Liz Andrews at 509-495-8601 or
liz.andrews(a,avi stacorp.com.
Sincerely,
l sl '5*k' d 1'�oa'Z w
Elizabeth Andrews
Sr. Manager of Revenue Requirements
liz.andrewskavistacorp.com
509-495-8601

Anni Glogovac, Pro Hac Vice Counsel
Counsel for Regulatory Affairs
Avista Corporation
1411 E. Mission Avenue
P.O. Box 3727
Spokane, Washington 99220
Phone: [phone]
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 ) COMMENTS OF AVISTA
PLANS ) CORPORATION
I. BACKGROUND
Avista Corporation, doing business as Avista Utilities (hereinafter "Avista" or
"Company"), in accordance with the Idaho Public Utilities Commission's ("Commission") Rules
of Procedure 201, and the Notice of Modified Procedure in this matter, Order No. 36686, submits
these Comments regarding approval of Commission Staff s Application for a Wildfire Mitigation
Plan ("WPM") filing process that would be submitted for approval under the Wildfire Mitigation
Standard of Care Act ("WSCA"),which took effect July 1, 2025.
On June 18, 2025, Commission Staff ("Staff') submitted 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
' Staff's Application for a Wildfire Mitigation Plan Filing Process,page 3.
Comments of Avista Corporation Page 1
Case No. GNR-E-25-02

Code § 61-1804. The Original Application included a discussion of Staffs 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. Staff also signaled its intent to file a
supplemental document on July 10, 2025, to include 1) Staffs proposed guidelines outlining
additional minimum requirements to be included within WMPs, and 2) Staffs 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.2
On June 30, 2025, Staff hosted a workshop with electric utilities to discuss Staff s Original
Application submitted on June 18,2025,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 incorporating some of that feedback into Staffs 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.3 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.
On July 10, 2025, Staff submitted its Supplemental to Application including additional
information and Staff s 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.4
2 Id.,page 5
3 Staff proposed staggered filing dates for each utility, including, for Avista, an initial temporary filing date of
November 10,2025,and annual review filings by December 1.
a Staff's Supplement to Application,page 1.
Comments of Avista Corporation Page 2
Case No. GNR-E-25-02

II. AVISTA'S COMMENTS
Avista appreciates Staff s thorough review of the requirements per the Wildfire Mitigation
Standard of Care Act, effective July 1, 2025, and the effort put forth by Staff to establish a
regulatory filing process for utility Wildfire Mitigation Plans. Avista is supportive of Staffs
recommendations, including the initial temporary and annual review filing dates for Avista, as
defined in Staff s Original and Supplemental Applications, with the exception of certain language
within the following Staff proposal areas, where clarification and or recommended changes are
needed: 1) No. 5 — Monthly Targets; 2) No. 8 —Notice to Interested Entities; 3) No. 9 — Three-
Year Rolling Plan; 4) No. 11 — Exhibit No. 1 Guidelines; 5) No. 13 — Retroactive Approval; 6)
No. 14 - Compliance Report Timing; 7)No. 15 —Compliance Status Update; and 8)No. 16—Fire
Occurrence Reporting. With regard to these specific areas, Avista, along with Idaho Power
Company, and PacifiCorp dba Rocky Mountain Power (collectively referred to as the "Joint
Utilities") have submitted Joint Comments discussing the Joint Utility recommendations for the
Commission's consideration.
DATED at Spokane, Washington, this 7th day of August 2025.
AVISTA CORPORATION
By
Anni Glogovac
Counsel for Regulatory Affairs
Comments of Avista Corporation Page 3
Case No. GNR-E-25-02

CERTIFICATE OF SERVICE
I HEREBY CERTIFY that I have this 7th day of August, 2025, served the foregoing Comments
upon all parties to Case No. GNR-E-25-02, through electronic mail:
Commission Staff: Kootenai Electric Cooperative:
Adam Triplett Michael G. Andrea
Deputy Attorney General General Counsel for KEC
Idaho Public Utilities Commission 9014 W. Lancaster Rd.
P.O. Box 83720 Rathdrum, ID 83858
Boise, ID 83702-0074 mandreakkec.com
adam.triplett(a�puc.idaho.gov
Thomas Maddalone
Monica Barrios-Sanchez Safety Director for KEC
Idaho Public Utilities Commission 9014 W. Lancaster Rd.
11331 W. Chinden Blvd Rathdrum, ID 83858
Building 8, Suite 201-A tmaddalonekkec.com
Boise, ID 83714
secretgakpuc.idaho.gov
Rocky Mountain Power: IDL:
Joe Dallas J.J. Winters
Senior Attorney Attorney for IDL
Rocky Mountain Power 300 N. 6th St., Ste 103 Boise, ID 83702
825 NE Multnomah, Suite 2000 jwinters(c-r�,idl.idaho.gov
Portland, OR 97232
joseph.dallaskpacificorp.com Tyre Holfeltz
Wildfire Risk Management Program
Mark Alder Manager 300 N. 6th St., Ste 103
Idaho Regulatory Affairs Manager Boise, ID 83702
Rocky Mountain Power tholfeltzkidl.idaho.gov
1407 West North Temple, Suite 330
Salt Lake City, UT 84116
mark.alderkl2acificorp.com
Data Request Response Center
datarequestgpacificorp.com
IDAHO FALLS: BENNETT:
Michael A. Kirkham Pendrey P. Trammell
Attorney for City of Idaho Falls Smith+Malek, PLLC
P.O. Box 50220 601 E. Front Ave., Ste. 304
Idaho Falls, ID 83402 Coeur d'Alene, ID 83814
mkirkham(&idahofalls.gov service(ksmithmalek.com
Stephen Boorman
Interim General Manager- Idaho Falls Power
Box 50220
Idaho Falls, ID 83402
sboorman('c6fpower.org

IDAHO POWER: POTLATCH:
Megan Goicoechea Allen Peter J. Richardson
Donovan E. Walker Richardson Adams, PLLC
Lisa C. Lance 515 N. 27th Street
P.O. Box 70 Boise, ID 83702
Boise, ID 83707 petergrichardsonadams.com
mgoicoecheaallen(&idahopower.com
dwalkergidahopower.com Jeremy Pisca
llancegidahopower.com Risch Pisca, PLLC
jpiscagrischpisca.com
Tim Tautm
Riley Maloney Michele Tyler
Connie Aschenbrenner Anna Torma
ttatumgidahopower.com Wade Semeliss
rmaloneykidahopower.com Brian Schlect
caschenbrennergidahopower.com michele. . lerkpotlatchdeltic.com
dockets(&idahopower.com anna.torma(a�potlatchdeltic.com
wade.semeliss&potlatchdeltic.com
brian.s chlect(kpotlatchdeltic.com
Is/Athena Allen
Athena Allen
Regulatory Affairs Analyst