20250807Comments_2.pdf

The following comment was submitted via PUCWeb:
Name: Kristin Burge
Submission Time: Aug 7 2025 5:12PM
Email: kristin.burge(cbnli.coop
Telephone: [phone]
Address: 421 Chevy St
Sagle, ID 83864
Name of Utility Company: Northern Lights, Inc.
Case ID: GNR-E-25-02
Comment: "Comments on GNR-E-25-02—S1183 Wildfire Standard of Care Act
We believe in some areas, GNR-E-25-02, exceeds the intent of the legislation as written
and as captured in the legislative record. Northern Lights, Inc. (NLI) respectfully submits
the following comments and implores the Commissioners to seriously and equitablyweigh
the legislative record and intent against the staff's diligence, albeit burdensome and
overbearing interpretations of some sections.
Expediated Filing Schedule:
NLI recommends that non-IOU electric utilities be permitted to submit by November 1,
2025. This timeline will ensure the Commission has sufficient opportunity to conduct a
thorough review prior to the onset of the 2026 fire season.
Exemption or Major Modification to Cost-Justification Requirements on non-IPUC-
regulated utilizes.
While it is possible to assign a dollar value to the work committed to wildfire mitigation,
distinguishing between routine operational costs and expenses directly attributable to
wildfire mitigation efforts may prove challenging. NLI submits its Wildfire Mitigation Plan
budget to our approving authority, and it should be accepted bythe Commission, as we are
not subject to regulation by the Idaho Public Utilities Commission (IPUC).
Fire Reporting in our Service Territory.
Northern Lights, Inc. (NLI) does not have the resources to effectively determine the cause
of fires occurring within a'/a mile of its equipment. Determining fire origin is more
appropriately handled by the responding fire agency. NLI may not be aware of all fires
within a 1/4 of it's equipment as there are many areas where other utilities are adjacent to
NLI's equipment.
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Sincerely,
Kristin Burge
Engineering& Operations Manager
Northern Lights, Inc.
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IDAHO CONSUMER-OWNED
UTILITIES ASSOCIATION
PO Box 1898
Boise, ID 83702
208-334-3873
Idaho Consumer-Owned Utilities Association (ICUA) comments on GNR-E-25
-02—S1183 Wildfire Standard of Care Act
The Idaho Consumer-Owned Utilities Association (ICUA) represents 20 rural electric
cooperatives and municipal power companies serving over 140,000 Idahoans across the State of
Idaho. Our utilities are self-governed by democratically elected boards of directors and city
councils—our members are not rate-regulated by the Idaho Public Utilities Commission (IPUC).
We purchase and distribute 96% of our power through the Bonneville Power Administration and
as not-for-profit utilities we operate "at-cost".
In November of 2023, ICUA along with Idaho's investor-owned utilities, participated in Governor
Little's "Wildfire Task Force". Along with dozens of stakeholders from across Idaho, we were
divided into subcommittees, and each subcommittee was tasked with providing the Governor
with a report on the wildfire priorities for each sector of expertise.
The utility/insurance subcommittee submitted a report to the Governor with our priority
recommendation being a system for utilities to codify their wildfire mitigation plans through an
IPUC approval process, meeting a standard of care, and providing if the plan is approved, some
liability protection.
In August of 2024, Governor Little released his "Wildfire Report Recommendations 2024."
On page two of the Governor's report, recommendation two states: "State-levellegislation
adopting clear wildfire liability standards for electric utilities based upon utilities
implementing wildfire mitigation measures contained in their Wildfire Mitigation Plans."
Based on the Governor's priority and the electric utility's priority being aligned, ICUA led the
effort in drafting a comprehensive Wildfire Standard of Care act based on the successful
legislative model and implementation of law passed in Utah.
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Idaho's "Wildfire Standard of Care Act" S1183 passed successfully in the 2025 legislative session
and was signed into law by Governor Little on April 1, 2025.
From the inception of the concept of this legislation, the IPUC and countless stakeholders were
involved, and through that involvement the draft changed countless times based on input.
As the drafters of 51183, we have an intimate and clear understanding of the legislative intent
of the legislature. Our bill sponsors public testimony, legislative committee testimony, and floor
debate also clearly show a record of the legislative intent.
We believe in some areas, GNR-E-25-02, exceeds the intent of the legislation as written and as
captured in the legislative record. ICUA respectfully submits the following comments and
implores the Commissioners to seriously and equitably weigh the legislative record and intent
against the staff's diligence, albeit burdensome and overbearing interpretations of some
sections.
1. Filing Dates: While we understand that the legislation allows the PUC to stager filing
dates for utilities submitting plans for approval, the current proposal puts non-IPUC
regulated utilities at a disadvantage. We would like the Commission to consider
expediating filing dates for non-IPUC regulated utilities who are ready to file so that they
have the opportunity for their plans to be approved prior to the 2026 fire season. ICUA
is committed to helping the IPUC in any legislative efforts they undertake for additional
FTEs to aid this new regulatory responsibility.
2. Cost-Justification: Non-IPUC regulated utilities should either be exempt from the
proposed cost-justification requirements, or the proposed requirements need to be
heavily modified to more accurately reflect the business model of not-for-profit utilities.
We are not regulated by the IPUC; we are regulated by elected boards of directors and
city councils and operate "at cost". We suggest that if not exempted from the overly
burdensome proposed requirements, that the IPUC would accept a resolution from the
non-PUC regulated utilities board of directors or city councils affirming that the utilities
elected regulators have approved of any costs associated with their plan and that they
are justified. The legislative attempt of this section of the bill was not to justify each
utility's wildfire mitigation costs, it was to prevent the IPUC from inequitably comparing
small consumer-owned utilities against large investor-owned utilities. Basic kwh sales,
customers per line, number of employees, and miles of distribution should be adequate
to meet the legislative intent.
3. Fire Reporting: The fire reporting requirement 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. The Act does not require or contemplate that utilities report
the existence or causes of fires.
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4. Annual Compliance Reports: More work needs to be done between the IPUC 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. The legislative intent of the "annual reporting" was
initially based on the previous S1124 bill requiring filing of Wildfire Mitigation Plans
(WMP) with the IPUC every three years. The passed and Governor signed S1183
changed to annual filing of WMP's. Through the legislative record and clear discussions
with IPUC staff, the "annual compliance report" is meant to be an addendum to the next
year's filing giving a brief overview of the implementation of the previous year's plan.
As the original authors of S1183 who spent over three years of diligent work on the precise
language of the legislation, we humbly request that the Commissioner's thoroughly consider
ICUA's comments and the comments from all consumer-owned utilities across the state, and
that our suggested changes are directed to staff. ICUA is completely committed to working with
you and the IPUC staff as we work through this new process together. Please use ICUA as a
resource now and in the future.
Sincerely,
U)e"4; ,4
Will Hart, Executive Director
Idaho Consumer-Owned Utilities Association (ICUA)
[e-mail]
208-334-3873
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