20250821Staff Comments.pdf

RECEIVED
August 21, 2025
ADAM TRIPLETT IDAHO PUBLIC
DEPUTY ATTORNEY GENERAL UTILITIES COMMISSION
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 10221
Street Address for Express Mail:
11331 W CHINDEN BLVD, BLDG 8, SUITE 201-A
BOISE, ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF COMMISSION )
STAFF'S APPLICATION FOR APPROVAL ) CASE NO. GNR-E-25-02
OF A FILING PROCESS FOR WILDFIRE )
MITIGATION PLANS )
REPLY COMMENTS OF THE
COMMISSION STAFF
COMMISSION STAFF ("STAFF") OF the Idaho Public Utilities Commission
("Commission"), by and through its attorney of record, Adam Triplett, Deputy Attorney General,
submits the following comments.
BACKGROUND
On June 18, 2025, Staff applied to establish a filing process for Wildfire Mitigation Plans
("WMPs") submitted under the Wildfire Standard of Care Act ("WSCA"). Staff requested the
matter be processed by Modified Procedure, and that the Commission issue an order adopting a
WMP filing process no later than September 5, 2025. Staff filed its Application to establish a
regulatory filing process for WMPs, which included proposed filing dates, annual review dates
and requirements, compliance report requirements, notice requirements, electric municipalities
and cooperative filings for review, charges by the Commission, and other recommendations.
STAFF REPLY COMMENTS 1 AUGUST 21, 2025

On June 18, 2025, Staff filed a motion before the Commission to set initial temporary
filing dates for WMPs.
On June 30, 2025, the Commission issued a Notice of Application and Notice of
Intervention Deadline, establishing a deadline for interested parties to petition to intervene.
Order No. 36660.
On July 10, 2025, Staff filed its Supplemental Application which included Staff's
proposed guidelines outlining additional requirements to be included within WMPs, Staff's
proposed"Need to Know Document", and some alternative proposals from the Original
Application.
On July 16, 2025, the Commission issued an interlocutory order suspending the filing of
WMPs before a final order issued in this case. Order No. 36674 at 2. The Order also allowed
for interested parties to propose schedules for the filing of WMPS in their comments filed in this
case. Id.
REPLY COMMENTS
On August 7, 2025, interested parties and utilities submitted comments on Staff's
proposals within its Original Application and Supplemental Application. Staff will address
portions of the interested parties and electric corporations comments. The absence of a comment
on any topic does not imply Staff agreement.
A. Filing Timeline
In their comments, a majority of the interested parties requested an expedited filing
timeline to file each of their respective WMPs for approval prior to the start of the 2026 fire
season.' In its comments, Idaho Consumer-Owned Utilities Association("ICUA") and United
Electric Co-op, Inc. ("United Electric") raised the concern that Staff's proposed dates put non-
regulated utilities at a disadvantage. See ICUA, Public Comment(August 7, 2025) at 2 and
United Electric, Public Comment(Aug. 7, 2025) at¶6.
In its comments, PotlatchDeltic Corp. ("PotlatchDeltic") was concerned that Staff's
initial proposal is too aggressive. PotlatchDeltic Comments at 8. PotlatchDeltic recommended a
filing timeline for the Commission to consider one WMP filing at a time, starting with the larger
' Clearwater Power Company,City of Idaho Falls,Kootenai Electric Cooperative,Raft River Rural Electric
Cooperative,Idaho County Light and Power,United Electric,ICUA,and Northern Lights,Inc.
STAFF REPLY COMMENTS 2 AUGUST 21, 2025

Investor-Owned Utility ("IOUs"), no earlier than January 1, 2026, to gain the expertise and
experience necessary to evaluate subsequent plans. PotlatchDeltic Comments at 9.
Staff Reply:
As stated in Staff's Original Application, Staff was unaware of the preparedness of each
of the electric corporations that have indicated filing WMPs with the Commission for approval.
Original Application at 7. Through this docket and interested parties' comments, Staff has
become aware that many of the electric municipalities and cooperatives are ready to file
immediately.
Pursuant to Idaho Code §§ 61-1803(2)(a)-(b), Staff requests the Commission set
staggered filing dates for each IOU and any electric municipalities or cooperatives that wish to
file. The Commission does not typically regulate electric municipalities and cooperatives.
Through Idaho Code § 61-1803(2)(b), the Commission will now have the authority to approve
WMPs from these electric corporations. Staff anticipates 15 WMPs to be filed for Commission
approval in addition to other regular cases that come before the Commission. Staff does not
believe it is feasible for the Commission to approve all 15 WMPs prior to the 2026 fire season as
it does not ensure adequate time for sufficient reviews and recommendations of WMPs from
Staff and interested parties.
However, Staff proposes alternatives to its initial proposal, where Staff believes it does
not put non-regulated electric municipalities and cooperatives at a disadvantage, while increasing
the number of cases filed to expedite reviews and prevent a voluminous amount of plan
submissions. Staff proposes the following two schedules as options for initial temporary filing
months. Both options list the order of filings based on the electric corporations' size,
complexity, and request of the electric utility.2 While these schedules do not guarantee all
electric corporations to receive a Commission order before the start of the 2026 fire season, they
do ensure that the majority secure orders in advance, with the remaining utilities receiving theirs
near the beginning of the fire season.
2 Kootenai Electric and Northern Lights,Inc.requested non-IOU electric utilities be permitted to submit its WMPs
by November 1,2025.
STAFF REPLY COMMENTS 3 AUGUST 21, 2025

Option No. 1: Staff's Preferred Schedule
Electric Corporation Permitted To File
Month Large Utility Medium Utility Small Utility
No earlier than Idaho Power Kootenai Electric Raft River
October 1
No earlier than hts Idaho County Light
November 1 Avista Northern Lig and Power
No earlier than PacifiCorp City of Idaho Falls United Electric
December 1
No earlier than Atlanta Power* Clearwater Power Lost River Electric*
Januaryl
No earlier than Lower Valley Fall River* City of Bonners
Februar 1 Energy* Ferry*
No earlier than Any other electric corporation that wishes to file
March 1
Option No. 2
Month Electric Corporation Permitted To File
No earlier than Idaho Power Kootenai Electric City of Idaho Falls
October 1
No earlier than Avista Northern Lights Clearwater Power
November 1
No earlier than PacifiCorp Raft River Idaho County Light
December 1 and Power
No earlier than Atlanta Power* United Electric Lost River Electric*
Januaryl
No earlier than Lower Valley Fall River* City of Bonners
February 1 Energy* Ferry*
No earlier than Any other electric corporation that wishes to file
March 1
*These utilities did not request an expedited filing timeline.
Option No. 1 is Staff s preferred schedule as Staff believes this proposal strikes a
reasonable balance of WMPs that Staff can feasibly review and timely provide adequate
recommendations to the Commission. To balance Staffs workload, Staff proposes to have one
large, medium, and small electric corporation file each month based on Idaho customer count,
followed with those electric utilities that did not request expedited filing.
Option No. 2 lists the electric corporations in order of the largest to smallest customer
count, followed with those electric corporations that did not request an expedited filing timeline.
STAFF REPLY COMMENTS 4 AUGUST 21, 2025

This schedule option front-loads Staff s workload, which does not provide the necessary balance
to timely and adequately review the filings ; however, this option does provide a clear, consistent
criteria for developing the schedule.
In both alternatives, the comment schedule will be determined for each case when a
WMP is filed. Staff requests the Commission issue an order with a WMP filing schedule that
seeks a reasonable balance of expedited filings.
Additionally, if Staff believes, due to workload and other factors, it can further expedite
filings beyond what the Commission orders in this case, Staff will request the Commission allow
identified electric corporations to be permitted to file its WMP earlier than proposed in this
filing.
Annual Filings
In Staffs Original Application, Staff requested the Commission issue an order requiring
electric corporations file their annual review one year after the previous filing date of an
approved plan and specific dates for the IOUs. See Original Application at 7. As Staff is
proposing alternative WMP filing schedules, this may change the order of filing annual reviews
for the IOUs. Therefore, Staff requests the Commission issue an order requiring each electric
corporation file one year after the previous filing date of an approved plan that aligns with the
WMP schedule the Commission believes is reasonable. In the electric corporation's initial WMP
filing with the Commission, Staff may request alternative dates for annual filings but believes
this is a reasonable starting point for annual filings at this point in time.
B. Proposed WMP Requirements
Length of WMP
In the Joint Utility Comments submitted by Idaho Power, Avista, and Rocky Mountain
Power("RMP"), the three large IOUs believe that Staff s request for each WMP to represent a
three-year rolling plan would create a"significant administrative burden". Joint Utility
Comments at 6. The Joint Utilities alternatively proposed to be required to submit a three-year
3 Idaho Power,RMP,and Avista.
STAFF REPLY COMMENTS 5 AUGUST 21, 2025

static plan, which would subsequently only update the years within the first three-year cycle until
the start of the next three-year cycle. Id.
Staff Reply:
Staff does not agree with the Joint Utilities' proposal to submit three-year static plans.
Staff believes that there is precedent to have rolling WMPs with the Commission. As stated in
Staffs Supplemental Application, Order No. 36042 requires Idaho Power"...to extend the WMP
forecast to five years for each version." Supplemental Application at 3. Subsequently, Idaho
Power has submitted its 2024 and 2025 WMP for review, which has rolled its plan forward from
the previous plan and extended its planning forecast to be five years.
In PAC-E-24-05 Reply Comments, RMP recommended its WMP correspond with a
three-year planning horizon, which aligned with RMP's schedule of updates in Utah and
Wyoming. PAC-E-24-05 Reply Comments at 4. The Commission ordered RMP to file updated
versions of its WMP every three years. Order No. 36405 at 7.
Staff believes the Joint Utilities' proposed static WMP schedule does not align with its
previous orders and its standard WMP planning cycles. Staff requests the Commission require
each WMP to have at a minimum a three-year forecast for each version. As an example, if a
multi-year plan for 2026-2028 is submitted, the subsequent plan update should be focused
specifically on 2027-2029.
IOUs vs Non-Regulated Electric Corporation Requirements
In its comments, the City of Idaho Falls requests the Commission exempt or limit the
WMP information electric municipalities are required to provide. See City of Idaho Falls
Comments at 4. Additionally, it stated, "The proposed process would require electric city
systems to provide the Commission with detailed, granular data, monthly targets, cost-benefit
analyses, goals, and metrics for each of the components of a WMP." Id. The electric
municipality believes it is "extraordinarily burdensome". Id.
In its comments, Kootenai Electric also filed comments requesting that the proposed
guidelines should be more flexible for smaller electric corporations. See Kootenai Electric
Comments at 13.
STAFF REPLY COMMENTS 6 AUGUST 21, 2025

Staff Reply:
Staff believes that the proposed guidelines are not extensive or burdensome and are
considerate of the size and complexity of each electric corporation. Staff s intention with the
proposed guidelines is to have the Commission adopt the additional requirements to further
define what is required within Idaho Code §§ 61-1803(3)(a)-(g) and to create a standard of what
is to be included within each WMP for all electric corporations that plan to file with the
Commission.
In Idaho Code Title 61, Chapter 18, the only differentiation between IOU and non-
regulated electric corporation provided for in the WSCA is that IOUs are required to file a WMP
with the Commission, while non-regulated electric corporations have the option not to file for
WMP approval. See Idaho Code § 61-1803(2). To gain the liability benefits provided for in
Idaho Code § 61-1806, a non-regulated electric corporation must have a Commission approved
WMP. Therefore, Staff does not believe flexibility in the application of the requirements laid out
in statute is appropriate.
As required by Idaho Code § 61-1803(3)(g), each electric corporation's WMP is required
to "[develop] standards, procedures, and schedules, subject to timely approval of access to rights-
of-way, if necessary..." for the 1) Infrastructure Inspection and Maintenance, 2) De-
Energization, and 3) Vegetation Management.
In Staffs proposed guidelines as Exhibit No. 1, only under the sections of Idaho Code §
61-1803(3)(g)(i) - Infrastructure Inspection and Maintenance and Idaho Code § 61-
1803(3)(g)(iii) -Vegetation Management, did Staff request "...measurable targets/goals to be
achieved within the WMP..."be included within the WMP. See Exhibit No. 1 at 6 and 8. Staff
believes this information is necessary to understand how the electric corporations plans to
implement its WMP within its planning cycle. The Commission should use this information as it
considers the feasibility of the plan, the cost of implementation, and the degree to which the plan
adequately minimizes wildfire risk as required by Idaho Code §§ 61-1804(b)-(c).
Staff believes that the proposed WMP guidelines are reasonable and should be adopted
by the Commission as additional minimum requirements to Idaho Code §§ 61-1803(3)(a)-(g).
STAFF REPLY COMMENTS 7 AUGUST 21, 2025

Standard Operating Procedures within WMPs
In the Joint Utility Comments, the IOUs requested that they not be required to include
discussions on 1) de-energization requests by first responders and 2)planned de-energization for
maintenance, circuit hardening, or similar activities as proposed in Staff s Exhibit No. 1 as these
instances should be considered as standard operational practices. Joint Utility Comments at 8.
Additionally, a concern brought by municipalities and cooperatives is how to separate
actions for wildfire mitigation from its standard operations. 4 Several have also mentioned
concerns about the projects that span more than just wildfire mitigation. See Northern Lights,
Public Comment (Aug. 7, 2025) at¶3, Kootenai Electric Cooperative Comments at 7, and City
of Idaho Falls Comments at 5. The concerns seemed to focus on how to allocate costs for each
of those purposes. For example, a transmission line rebuild project might be done for reliability,
line worker safety, aged infrastructure, and wildfire mitigation.
Staff Reply:
As it comes to the discussion of de-energization in certain circumstances mentioned in
comments, Staff believes it is not necessary to define the standards, criteria, and operational
protocols within the WMP as it is already in the utility's defined Standard Operational
Procedures ("SOP") to de-energize in the identified circumstances of 1) request by fire agencies
or 2)planned utility work. Staff proposes to remove these two circumstances from Staff s
proposed minimum requirements. Included as Updated Exhibit No. 1 to these comments, Staff
revised this section to address these changes.
To address the concerns of separating wildfire mitigation work from SOP, Staff believes
the WMP should be the comprehensive plan of how a utility addresses wildfire mitigation. As
required in the Idaho Code §§ 61-1803(3)(a)-(g), certain minimum requirements must be
clarified and defined within each WMP.
Staff understands that wildfire mitigation is only one part of an electric corporation's
operations, and many projects will cross the line from pure wildfire mitigation into other
purposes. Staff does not believe allocation of costs is needed. Instead, it would be better to
include the full costs of the project within the WMP and then mention that there were other
criteria beyond just wildfire mitigation for each project with an explanation of those criteria.
Additionally, Staff suggests that if any mitigation effort is done with extended benefits beyond
a Northern Lights,Inc.Public Comments and through discussions with electric corporations.
STAFF REPLY COMMENTS 8 AUGUST 21, 2025

wildfire mitigation, the electric corporation should describe how its work is either part of SOP or
is incremental to its SOP within the WMP. Staff believes that most, if not all, of this information
should be available as it would be used in the approval process by the electric corporations'
governing boards.
"Least Cost, Least Risk"Requirement in Line Design
In its comments, several electric corporations had concerns with the phrase "least-cost,
least-risk" in Staffs proposed additional requirements for line design in Exhibit No. 1.5 The City
of Idaho Falls also commented on its concern of the Commission's evaluation of line design
would"...effectively allow the Commission a seat at the Council's table for all of Idaho Falls'
new line designs and operational upgrades." City of Idaho Falls Comments at 5. Kootenai
Electric comments echoed similar concerns stating, "Staffs requests also are likely to usurp non-
IOUs' governing boards' authority with regard to costs and rates." Kootenai Electric Comments
at 8.
Staff Reply:
To address the concerns of the City of Idaho Falls and Kootenai Electric, Idaho Code §
61-1803(3)(e)requires each WMP to include at a minimum, "Financially prudent and reasonable
practicable methods of line design for new,planned, and existing lines to mitigate fire risk".
Staff believes the concern of the Commission encroaching into "non-IOUs' governing boards'
authority with regards to costs and rates"is unfounded and the electric corporation is statutorily
required to include its methods for line design within its WMP.
As Staff has considered comments from the interested parties, Staff proposes to modify
the language in its proposal to remove "least-cost, least-risk" and replace it with"...reflect a
balance of mitigation costs with resulting reduction in wildfire risk"to be consistent with the
language of Idaho Code § 61-1803(3). The Updated Exhibit No. 1 now reads as the following:
"Additionally, this must include how the electric corporation clearly identifies, selects, and
evaluates projects that reflect a balance of mitigation costs with resulting reduction in wildfire
risk, for the following, but not limited to."
5 See City of Idaho Falls,Kootenai Electric,and the Joint Utility Comments at 9.
STAFF REPLY COMMENTS 9 AUGUST 21, 2025

Included as Updated Exhibit No. 1 to these comments, Staff has revised the section to
address these changes. Staff believes it is necessary to include this information within a WMP as
it further defines how the Commission may wish to review Idaho Code § 61-1803(3)(e). Staff
requests the Commission adopt these additional minimum requirements to be included within
WMPs included as Updated Exhibit No. 1 to these comments.
Amendments to WMPs
The Joint Utilities believe the three-year rolling plan lacks clarity of how compliance will
be measured and how conflicts between different versions of the WMP will be resolved. See
Joint Utility Comments at 6-7. Additionally, the Joint Utilities disagree with Staff s request that
any amendments should not have retroactive approval. Id. at 9. They believe that it discourages
them to act swiftly to real-time circumstances and encourages delay in innovation or efficiency.
Id. 9-10.
Staff Reply:
Idaho Code § 61-1803(4) states, "Commission-approved wildfire mitigation plans shall
be implemented upon approval by the commission... ." Staff s interpretation of the legislation is
that the approved WMP should be implemented and is effective upon Commission approval until
a new WMP is approved by the Commission. Additionally, Staff reiterates that WMP should be
effective from the Commission's order date or if otherwise stated by the Commission and
believes approval should not be retroactive from the Commission's order date. Staff requests the
Commission issue an order in this case that clarifies the effective period when it approves each
WMP. Absent an order from the Commission clarifying the effective date of each WMP, Staff
would propose effective dates in each filing requesting an approval of the WMP.
Staff s Supplemental Application encouraged the electric corporations to provide an
explanation in comments for why amendments were necessary. Supplemental Application at 4.
Staff is not opposed to electric corporations filing amendments to a filed or approved WMP;
however, substantive changes would likely impact the entire WMP and the Commission could,
through its authority, approve or reject the plan within six months. Idaho Code § 61-1804. Staff
requests the Commission issue an order clarifying if it would accept any amendments to filed or
approved WMPs and clarify if any amendments would have retroactive approval.
STAFF REPLY COMMENTS 10 AUGUST 21, 2025

C. Filing Process and Recommendations
A few comments addressed the need for Staff s proposed filing process to clarify the
statutory requirement for the participation of Idaho Department of Lands ("IDL") in the review
process of WMPs.6
Staff Reply:
Although not explicitly mentioned in Staff s Original Application or Supplemental
Application, Idaho Code § 61-1804(3) requires the Commission to consult with interested parties
and as listed in Idaho Code § 61-1804(2), including the state forester from IDL.
On June 171h, 2025, Staff participated in an informal discussion with the state forester and
the wildfire risk mitigation program director from IDL. Through this discussion, IDL indicated
its intention to intervene in each WMP filing for the foreseeable future and will review WMPs
and provide recommendations within each case.
As Idaho Code § 61-1804(3) is written, such recommendations from the state forester
with respect to vegetation management, reduction to wildfire fuels, and other duties of the state
forester under title 38 of Idaho Code, are presumed reasonable and appropriate. However, if the
Commission determines the recommendations are not just, reasonable, or in the public interest,
the Commission must document its reasoning in its order approving or rejecting the plan.
D. Cost Justification
Rate Regulation Issues
Some non-regulated electric corporations have mentioned that the process proposed by
Staff may be straying into rate regulation. See Kootenai Electric Comments at 8, and City of
Idaho Falls Comments at 9.
Staff Reply:
For rate regulation to occur, the Commission must go through the steps of establishing a
revenue requirement, cost of service allocation, and rate design to establish rates. Staff has not
proposed any of these steps within its WMP filing procedures proposal. Everything Staff is
proposing in this case serves is only to assist in"...balancing of mitigation costs with the
resulting reduction of wildfire risk... ." Idaho Code § 61-1803(3).
6 See IDL Comment at 1,Joint Utility Comments at 8,and Bennett/IFG/MIM/MWG/Stimson Comments at 4.
STAFF REPLY COMMENTS 11 AUGUST 21, 2025

At no point is Staff considering if any action is prudent for recovery from ratepayers.
The goals for this analysis is to have a full record to determine if the WMP meets the
requirements laid out in Idaho Code § 61-1803. There is no part of the WSCA nor any part of
Staffs proposed process that allows the Commission to propose rates or to determine if any
project or expenditure is prudent. Therefore, Staff does not believe its recommendations are
suggesting rate regulation, and its request for costs and financial information is reasonable.
Cost-Benefit Analysis/Cost Justification
Several non-regulated electric corporations have requested that Staff's requested cost-
benefit analysis be changed for non-regulated electric corporations due to the difficulty of
complying and because of their different organizational structures. Staff's proposed minimum
requirements also included the request for each WMP to include a breakdown of each program
category's forecasted costs by year for both capital cost and operations and maintenance
expenditures over the WMP's time horizon. See City of Idaho Falls Comments at 4, Kootenai
Electric Comments at 8, ICUA, Public Comment(Aug. 7, 2025) at 2, and United Electric,Public
Comment(Aug. 7, 2025) at¶4.
Staff Reply:
Idaho Code § 61-1803(3) states, "At a minimum, each wildfire mitigation plan shall
identify means for mitigating wildfire risk that reflect a reasonable balance of mitigation costs
with the resulting reduction of wildfire risk... ." In addition, Idaho Code § 61-1804 states factors
the Commission shall consider in reviewing WMPs, including "The feasibility of the plan and
the cost of its implementation... ."
Staff has, therefore, proposed that the electric corporations applying for approval of a
WMP provide the costs of the projects and operations in the plan. See Exhibit No. 1 at 8. This is
not to replace the authority of the respective electric corporation's governing board or to even to
determine if these costs are prudent for recovery from the ratepayers. The purpose of requesting
this information is so that Staff can accurately give recommendations to the Commission, and
that the record is complete for the Commission to issue a full, accurate, and supported order on
the WMP.
STAFF REPLY COMMENTS 12 AUGUST 21, 2025

As stated earlier, Idaho Code § 61-1803 does not provide any differentiation between
IOUs and non-regulated utilities in the requirement of a WMP or factors for approval. Therefore,
Staff does not believe changes are appropriate to the requirements laid out in statute.
Per Idaho Code § 61-1803(3), the WMP"...shall be developed using approaches and
methods that ... are reflective of and commensurate with the size and complexity of the electric
corporation's operation..." Staff believes that the size and capability of the electric corporation
should be taken into account, and therefore, Staff is not proposing to require every electric
corporation to file the exact same type of cost or wildfire risk reduction reports.
A large electric corporation like Idaho Power or RMP will have resources to provide a
highly complex and detailed cost analyses and explanation of need, while much smaller electric
corporations, like Atlanta Power, may provide a much simpler cost analysis and explanation of
need. Staff expects that the electric corporations will provide the Commission with the same
information that is used to determine if their WMP balances the cost of mitigation with wildfire
risk reduction reviewed by their governing boards.
E. Compliance Reports
A majority of the comments addressed concerns with Staff s proposed requirements to be
included within compliance reports, such as fire reporting,justifying expenditures, and monthly
goals/targets. Five electric municipalities and cooperatives have requested further collaborations
and requests Staff hold workshops to determine the appropriate information necessary to be
included within compliance reports.
Additionally, the Joint Utilities proposed an alternative filing schedule to Staffs proposal
of submitting the compliance report one year and 60 days after a WMP is approved. Joint Utility
Comments at 10. The Joint Utilities recommended staggered compliance filing due dates to be
the first day of the month on April, May, and June each year for Idaho Power, RMP, and Avista.
Id.
Staff Reply:
To address the many concerns regarding proposed requirements within compliance
reports, Staff agrees with the interested parties' requests to hold workshops to determine the
7 Clearwater Power Company,City of Idaho Falls,Kootenai Electric,Lost River Electric Cooperative,and United
Electric.
STAFF REPLY COMMENTS 13 AUGUST 21, 2025

necessary information to include within compliance reports. Staff believes issues such as
monthly targets and expenditures can be a resolved in workshops. Staff requests the Commission
order Staff to hold two workshops with the interested parties and to file collaborated standard
compliance report requirements to the Commission by December 31, 2025, for approval. If
parties cannot come to a resolution on collaborated standard compliance report requirements,
Staff proposes the parties each file its proposed compliance report requirements to the
Commission by December 31, 2025.
Additionally, Staff is willing to discuss potential compliance report filing dates within its
two workshops with the interested electric corporations. Therefore, Staff does not request the
Commission order specific dates or a specific timeframe, at this time, for this statutorily required
compliance report.s
F. Other Clarifications
"Fair Market Value"of Timber
In its comments, the Joint Utilities were concerned about uncertainty brought by Idaho
Code § 61-1803(3)(g)(iii) which requires that landowners be compensated at fair market value if
live marketable timber is identified for removal from timber company land adjacent to an electric
corporation's right- of-way. The Joint Utilities requested the Commission clarify how "fair
market value" is to be determined to reduce future confusion and potential landowner frustration.
See Joint Utility Comments at 12.
Staff Reply:
As written, "fair market value" is not defined within the legislation. As part of Idaho
Code § 61-1803(3)(g), WMPs must include developing standards,procedures, and schedules
subject to timely approval of access to rights-of-way. In this case, Staff believes the electric
corporations should only provide the standards, procedures, and schedules of how the electric
corporation will determine or achieve "fair market value" in any occurrence within their WMPs.
Staff encourages the electric corporations to work with interested parties to determine a"fair
market value."
8 Idaho Code § 1803(5). The Commission has the authority to prescribe the basis on when compliance reports are to
be submitted to the Commission.
STAFF REPLY COMMENTS 14 AUGUST 21, 2025

To address the potential cost recovery concerns for IOUs, cost recovery will be
determined in a future rate proceeding, where the IOU will have the burden of proof for how
"fair market value"was achieved and the Commission will determine prudency at that time.
Timber Companies Contacts or Maps
In its comments, the Joint Utilities believe that collaboration among all stakeholders to
develop or identify either a working list of timber companies or a centralized resource that maps
timber company land would be a valuable tool in supporting compliance with Idaho Code § 61-
1803(3)(g)(iii). See Joint Utility Comments at 12.
Staff Reply:
Staff generally supports this recommendation. However, IDL may be the most
reasonable agency to host this information.
Public Comments
As of August 21, 2025, there are 7 public comments from electric municipalities,
cooperatives, and associations representing similar parties. Staff has incorporated some of the
concerns brought by the interested parties into its reply comments. However, if there are any
more comments filed late by interested parties, Staff recommends the Commission consider late
comments.
STAFF RECOMMENDATIONS
From Staff's Original Application, Staff requests a Commission Order:
1) Directing the issuance of quarterly invoices to each electric municipality and
cooperatives based on time and expense principles pursuant to Idaho Code § 61-1004
to review its WMP;
2) If the Commission desires to continue wildfire update meetings with IOUs, require
annual update meeting dates to occur during the third week of May, outside of each
IOU's respective planned WMP annual review; and
3) Requiring each electric corporation's notice to interested entities to include
information about how to participate in the Commission's proceeding, the case
number, and provide a copy of the notice to the Commission in its filing.
STAFF REPLY COMMENTS 15 AUGUST 21, 2025

From Staff s Supplemental Application, Staff requests a Commission order:
4) Requiring each WMP to represent, at a minimum, a three-year forecast for each
version;
5) Requiring an electric corporation to follow the guidelines listed within Updated
Exhibit No. 1 for any WMP to meet the requirements for approval;
6) Accepting Updated Exhibit No. 1 as the Commission's WMP Guidelines for each
electric corporation's WMP filings;
7) Providing any further guidance on minimum requirements to be within a WMP it
deems necessary; and
8) Requiring each electric municipality and cooperative to file an"Need to Know
Document" as filed in Exhibit No. 2 with its initial WMP filing.
In addition to Staffs initial requests, Staff further requests a Commission order:
9) Requiring each electric corporation to provide a cost analysis and explanation of need
to justify its forecasted expenditures to wildfire risk mitigation for each WMP filing;
10)Containing a WMP filing schedule that seeks a reasonable balance of expedited
filings;
11)Requiring each electric corporation to file its WMP for its annual review one year
after the previous filing date of an approved plan that aligns with the WMP filing
schedule the Commission believes is reasonable;
12)Clarifying the effective period of an approved WMP;
13)Clarifying if the Commission would accept any amendments to filed or approved
WMPs and clarify if any amendments to WMPs would have retroactive approval; and
14)Requiring Staff to hold two workshops with the interested parties and to file
collaborated standard compliance report requirements and compliance report filing
dates to the Commission by December 31, 2025, for approval. If parties cannot come
to a resolution on collaborated standard compliance report requirements and filing
dates, each party must each file a proposed compliance report requirements and
compliance report filing timeline to the Commission by December 31, 2025.
STAFF REPLY COMMENTS 16 AUGUST 21, 2025

Respectfully submitted this 21st day of August 2025.
Adam Triplett
Deputy Attorney General
Technical Staff: Kimberly Loskot, Joseph Terry
I:\Utility\UMISC\COMMENTS\GNR-E-25-02 Reply Comments.docx
STAFF REPLY COMMENTS 17 AUGUST 21, 2025

EXHIBIT NO. I
Idaho Public Utilities Commission
Wildfire Mitigation Plan Guidelines
Updated Exhibit No. 1
Case No. GNR-E-25-02
Staff Reply Comments
August 21, 2025

Intention of the Wildfire Mitigation Plan Guidelines
The intention of this document is to serve as guidelines for creating a Wildfire Mitigation
Plan ("WMP") for approval by the Commission.
As required by I.C. § 61-1803(3),a WMP at a minimum must include the elements outlined
in I.C. § 61-1803(3)(a)-(g). Staff recommends the Commission consider the areas detailed in each
section below to be included in the utilities WMP filing as written. Staff will review this
information in each WMP filing for approval by the Commission.
I.C. § 61-1803(3)(a)- Geographical Risk Assessments
"Identifying geographical areas where an electric corporation has infrastructure or
equipment that the electric corporation considers may be subject to a heightened
risk of wildfire at the time the wildfire mitigation plan is finalized by the electric
corporation"
The electric corporation must include a description of the wildfire risk assessment or model
used to guide wildfire mitigation activities. The assessment should identify geographic areas with
elevated fire risk, considering factors such as vegetation, weather, topography, historical fire
occurrence, structure density, and asset location.
The electric corporation should provide a map of the identified risk areas within its service
territory within this section of its WMP. The identified risk areas should be defined with different
level of fire risks to the utility. There must be an explanation of what determines each level of risk
and risk assessments of each service territory should be updated annually in the WMP.
I.C. § 61-1803(3)(b) - Preventative Actions and Programs
"Preventative actions and programs that the electric corporation will carry out to
reduce the risk of wildfire."
The electric corporation must describe all preventative actions and programs that it will
carry out to reduce the risk of wildfire, in addition to actions and programs specified in statute and
by this Commission. For the three large investor-owned utilities,' Staff recommends that previous
'Avista Corp.,Idaho Power,and Rocky Mountain Power. Updated Exhibit No. I
Case No. GNR-E-25-02
WMP GUIDELINES 2 Staff Reply Comments
August 21, 2025

areas of focus of each utility's WMPs continue to be included within its WMPs. A WMP's
preventative actions and programs must include, but is not limited to:
• Situational Awareness efforts
o Which may include use of technology to aid in weather monitoring, fire season
outlook, daily, weekly, and monthly weather and fire modeling risk, etc.
o Consistent with 61-1803(3)(f) and Staff's proposed requirements within.
• Asset Inspections
o Which must include the frequency and standards of inspections for each type of
electric infrastructure within areas of elevated wildfire risk.
o Consistent with 61-1803(3)(g)(i) and Staff's proposed requirements within.
• Enhanced vegetation management practices in risk zones
o Which may include shorter vegetation management cycles than routine cycles,
risk tree programs, etc.
o Consistent with 61-1803(3)(g)(iii) and Staff's proposed requirements within.
• Operation practices during heightened wildfire risk days or zones.
o Which may include restrictions to workforce practices, potential use of pro-
active de-energization
o Consistent with 61-1803(3)(g)(ii) and Staff's proposed requirements within.
• Community education
o Which may include public service announcements to create awareness and
provide education of wildfire risks,providing preventative measures, etc.
o Consistent with 61-1803(3)(c) and 61-1803(3)(d)
• And any additional requirements ordered by the Commission.
A WMP's preventative actions and programs may include, but is not limited to:
• System hardening strategies
Which may include pole replacements, line rebuilding, or undergrounding if
necessary, strategic fuse or reclosers installations, etc.
• Workforce Preparedness
o Which may include workforce training, equipment provided to employees to
reduce the risk of wildfire, etc.
Updated Exhibit No. 1
Case No. GNR-E-25-02
WMP GUIDELINES 3 Staff Reply Comments
August 21, 2025

• Pilot Programs_
o If applicable.
I.C. § 61-1803(3)(c) - Public Outreach and Engagement
"Community outreach and public awareness efforts that the electric corporation
will use before, during, and after wildfire season to identify and inform the public
of relevant wildfire risks and notify the public of wildfire-related outages."
This section should include discussion of how each utility maintains community outreach
and public awareness before, during, and after wildfire season to support customer awareness and
education of wildfire risks and notify the public of wildfire-related outages. This discussion should
include, but is not limited, to the following:
• Description of customer communication efforts related to wildfire mitigation, including
efforts to increase awareness and education of the utility's plan, explanation of key
mitigation activities, and efforts supporting public readiness.
• If the utility utilizes de-energization, a description of public education efforts and
communication protocols for before, during, and after a de-energization event. The
communication protocols should clearly identify which customers could and will be
impacted if a de-energization event is pursued and identify any advanced notifications for
critical infrastructure or customers, which may include but not limited to, hospitals and
other medical facilities, schools, police, fire, emergency operation centers, any
jails/prisons, other utilities, and vulnerable customers.
• Explanation of the communication methods the electric corporation intends to use, such as
mail, flyers, emails, calls, texts, a notification system, its website, etc.
I.C. § 61-1803(3)(d) - Government Outreach
"Outreach efforts to coordinate with federal, state, tribal, and local officials and
agencies on wildfire preparedness and emergency response plans."
The electric corporation must describe how it engages with and coordinates with federal,
state, tribal, and local officials and agencies on wildfire preparedness and emergency response in
the plan year. This discussion may include,but is not limited to:
Updated Exhibit No. 1
Case No. GNR-E-25-02
WMP GUIDELINES 4 Staff Reply Comments
August 21, 2025

• If applicable, Public Safety Power Shutoff ("PSPS") tabletop exercises with interested
parties and agencies
• Communication with the agencies and the ESF-12 coordinator within the PUC.
• If applicable, mitigation efforts with the agencies.
The WMP must detail all relationships (such as BLM and Forest Service)
it has established that may benefit the wildfire mitigation program, contribute to program costs, or
provide cost sharing opportunities in its WMP.
I.C. § 61-1803(3)(e)- Method of Line Design
"Financially prudent and reasonably practicable methods of line design for new,
planned, and existing lines to mitigate fire risk."
The electric corporation must describe how its methods of line design for new lines and
planned upgrades reduce wildfire ignition potential in heightened wildfire risk areas. This must
include evaluation of costs to wildfire risk reductions. Additionally, this must include how the
electric corporation clearly identifies, selects, and evaluates projects that reflect a balance of
mitigation costs with resulting reduction in wildfire risk for the following,but is not limited to:
• Line rebuilding within the WMP.
• Undergrounding lines within the WMP.
• Installation of covered conductor.
• Installation of non-wooden cross arms.
• If any, describe any flexible infrastructure such as automatic reclosers and remote-
controlled devices that support remote operations.
I.C. § 61-1803(3)(f) - Situational Awareness and Monitoring
"Monitoring of forecasted and current weather data for the purpose of assessing and
responding to current and anticipated fire risk."
This section should include a description of how the electric corporation monitors
forecasted and current weather conditions for the purpose of assessing and responding to current
and anticipated wildfire risk. This description must include, but is not limited to, the following:
Updated Exhibit No. 1
Case No. GNR-E-25-02
WMP GUIDELINES 5 Staff Reply Comments
August 21, 2025

• Identification of systems, tools, or external resources used to monitor weather, fire
potential, or other situational awareness indicators.
• If applicable, a description of how the utility utilizes weather forecasting, fire potential
modeling, or similar tools, to inform mitigation activities and operational decisions.
• Discussion of how situational awareness capabilities are integrated into daily or seasonal
wildfire operations.
• Discussion of how the electric utility become aware of another electric corporation's de-
energization (e.g., Bonneville Power Administration) and how that is integrated into
operations.
Developing Standards, Procedure, and Schedules
Idaho Code 61-1803(3)(g)requires each electric corporation to "[develop] standards,
procedures, and schedules, subject to timely approval of access to rights-of-way, if necessary..."
for the 1) Infrastructure Inspection and Maintenance, 2) De-Energization, and 3)Vegetation
Management.
I.C. § 61-1803(3)(g)(i)- Infrastructure Inspection and Maintenance
"Inspection of the electric corporation's assets, infrastructure, and facilities within
the areas that are identified as heightened fire risk areas in the wildfire mitigation
plan, were financially prudent and reasonably practicable."
This section should provide a summary of electric corporation's programs for the
inspection of electric infrastructure, assets, and facilities within areas identified as heightened
wildfire risk areas to identify and correct conditions that could contribute to wildfire ignition. This
summary must include, but is not limited to, the following:
• Description of inspection standards for each type of infrastructure, assets, and facilities.
• Description of schedules for inspections for each type of infrastructure, asset, and facility.
• Description of baseline routine inspection methods and enhanced inspection methods for
higher fire risk areas, which may include the use of advanced or pilot technologies.
• Explanation of how identified defects are classified, prioritized, and corrected.
Updated Exhibit No. 1
Case No. GNR-E-25-02
WMP GUIDELINES 6 Staff Reply Comments
August 21, 2025

• Measurable targets/goals to be achieved within the WMP. E.g., miles of lines inspected,
corrected identified defects, etc.
I.C. § 61-1803(3)(g)(ii)-De-Energization
"De-energization of the electric corporation's power lines,if considered appropriate
by the electric corporation."
If an electric utility plans to use de-energization as part of its wildfire mitigation efforts,
this section must address the standards, criteria, and operational protocols, for de-energization for
encroachment of a wildfire, proactive de-energization (PSPS) to reduce fire risk, and de-
energization from Yd party energy providers. This discussion must include, but is not limited to
the following:
• A summary of the conditions under which de-energization may be used, if applicable.
• The criteria or protocols for evaluating its appropriateness to engage.
• Summary of the electric corporation's operational protocols for before, during, and after a
de-energization event.
• Description of how the electric corporation will coordinate with local emergency
managers,operators of critical facilities,and affected communities before,during,and after
a de-energization event.
• Descriptions of other operations for limiting impact to affected communities; which may
include community resource centers, emergency generators, backup batteries, etc.
I.C. § 61-1803(3)(g)(iii) -Vegetation Management
"Vegetation management within the areas that are identified as heightened fire risk
areas in the wildfire mitigation plan and are within the electric corporation's rights-
of-way or lands adjacent thereto and that threaten the power lines or other electric
corporation infrastructure. If live marketable timber is identified for removal from
timber company land adjacent to the rights-of-way, compensation at fair market
value shall be made to the landowner for such timber."
This section must provide an overview of the utility's vegetation management program
aimed at reducing the risk of vegetation-related contact with electric infrastructure in areas with
Updated Exhibit No. 1
WMP GUIDELINES 7 Case No. GNR-E-25-02
Staff Reply Comments
August 21, 2025

heightened wildfire risk within its rights-of-way or lands adjacent thereto. Elements of this
vegetation management section overview should include,but is not limited to, the following:
• Identification, description, and citation of vegetation management standards for elevated
wildfire risk areas.
• Explanation of how vegetation management standards, procedures, and schedules are
different or the same as routine vegetation management.
• Description of the current and planned vegetation management practices used to mitigate
wildfire risk, including any enhancements in designated wildfire areas.
• The electric corporation must explain how the electric utility considered vegetation
management recommendations by other federal, state, and county agencies into its
standards.
• Must include measurable targets/goals to be achieved within the WMP. E.g., miles of lines
completed, risk trees removed, etc.
• Explanation of how identified risk trees are classified,prioritized, and corrected.
Other Items to Include in a WMP
1) An update of lessons learned from the previously approved WMP within the annual filings
for WMP review and approval.
2) A breakdown of each program category's forecasted costs by year for both capital and
O&M expenditures through the length of the WMP.
3) A section in which it describes how the electric corporation addresses each of the
Commission's orders and Staff's recommendations.
Updated Exhibit No. I
Case No. GNR-E-25-02
WMP GUIDELINES 8 Staff Reply Comments
August 21, 2025

EXHIBIT NO. 1
Idaho Public Utilities Commission
Wildfire Mitigation Plan Guidelines
Updated Exhibit No. 1-Redlined
Case No. GNR-E-25-02
Staff Reply Comments
August 21, 2025

Intention of the Wildfire Mitigation Plan Guidelines
The intention of this document is to serve as guidelines for creating a Wildfire Mitigation
Plan("WMP")for approval by the Commission.
As required by I.C.§61-1803(3),a WMP at a minimum must include the elements outlined
in I.C.§61-1803(3)(a)-(g).Staff recommends the Commission consider the areas detailed in each
section below to be included in the utilities WMP filing as written. Staff will review this
information in each WMP filing for approval by the Commission.
I.C.§61-1803(3)(a)-Geographical Risk Assessments
"Identifying geographical areas where an electric corporation has infrastructure or
equipment that the electric corporation considers may be subject to a heightened
risk of wildfire at the time the wildfire mitigation plan is finalized by the electric
corporation"
The electric corporation must include a description of the wildfire risk assessment or model
used to guide wildfire mitigation activities.The assessment should identify geographic areas with
elevated fire risk, considering factors such as vegetation, weather, topography, historical fire
occurrence,structure density,and asset location.
The electric corporation should provide a map of the identified risk areas within its service
territory within this section of its WMP. The identified risk areas should be defined with different
level of fire risks to the utility.There must be an explanation of what determines each level of risk
and risk assessments of each service territory should be updated annually in the WMP.
I.C.§61-1803(3)(b)-Preventative Actions and Programs
"Preventative actions and programs that the electric corporation will carry out to
reduce the risk of wildfire."
The electric corporation must describe all preventative actions and programs that it will
carry out to reduce the risk of wildfire,in addition to actions and programs specified in statute and
by this Commission. For the three large investor-owned utilities,'Staff recommends that previous
Avista Corp.,Idaho Power,and Rocky Mountain Power.
WMP GUIDELINES 2 UPDATED EXHIBIT
NO. 1
Updated Exhibit No. 1-Redlined
Case No. GNR-E-25-02
Staff Reply Comments
August 21, 2025

areas of focus of each utility's WMPs continue to be included within its WMPs. A WMP's
preventative actions and programs mi stay include,but is not limited to:
• Situational Awareness efforts
o Which may include use of technology to aid in weather monitoring,fire season
outlook,daily,weekly,and monthly weather and fire modeling risk,etc.
o Consistent with 61-1803(3)(f)and Staff's proposed requirements within.
• Asset Inspections
o Which must include the Efrequency and standards of inspections for each type
of electric infrastructure within areas of elevated wildfire risk.
o Consistent with 61-1803(3)(g)(i)and Staff's proposed requirements within.
• Enhanced vegetation management practices in risk zones
o Which may include shorter vegetation management cycles than routine cycles.
risk tree programs,etc.
o Consistent with 61-1803(3)(g)(iii)and Staff's proposed reauirements within.
• Operation practices during heightened wildfire risk days or zones.
o Which may include restrictions to workforce practices, potential use-of-pro-
active de-energization
o 4Consistent with 61-1803(3)(g)(ii)and Staff's proposed requirements within.,
etc-.
Formatted:Indent:Left: 1.25", No bullets or
• Community education numbering
o Which may include public service announcements to create awareness and
provide education of wildfire risks,providing preventative measures,etc.
o Consistent with 61-1803(3)(c)and 61-1803(3)(d)
Formatted:Indent:Left: 1.25", No bullets or
• And any additional requirements ordered by the Commission. numbering
t......" Formatted:Indent:Left: 0.75", No bullets or
numbering
A WMP's preventative actions and programs may include,but is not limited to: '. %" Formatted:No underline
Formatted:Normal, No bullets or numbering
• System hardeningstrategies
trategies
,e—Which may include pole replacements, line rebuilding, or undergrounding if
Formatted:Indent:Left: 1.25", No bullets or
necessary,strategic fuse or reclosers installations,etc. numbering
Formatted:Space Before: Auto
r Formatted:Underline
Formatted:Left,Indent:Left: 1.25",Space After: 8 pt,
Line spacing: Multiple 1.08 li, No bullets or numbering
WMP GUIDELINES 3 UPDATED EXHIBIT
NO. 1
Updated Exhibit No. 1-Redlined
Case No. GNR-E-25-02
Staff Reply Comments
August 21, 2025

proposed Foqairvmonis within),0�.=
• Workforce Preparedness
o Which may include workforce training, equipment provided to employees to
reduce the risk of wildfire,etc.
• Pilot Programs
,e--If applicable.
o Formatted:List Paragraph,Bulleted+Level:2+
r. mitt' .a..ea4i.._ Aligned at: 1"+Indent at: 1.25"
I.C.§61-1803(3)(c)-Public Outreach and Engagement
"Community outreach and public awareness efforts that the electric corporation
will use before,during,and after wildfire season to identify and inform the public
of relevant wildfire risks and notify the public of wildfire-related outages."
This section should include discussion of how each utility maintains community outreach
and public awareness before,during,and after wildfire season to support customer awareness and
education of wildfire risks and notify the public of wildfire-related outages.This discussion should
include,but is not limited,to the following:
• Description of customer communication efforts related to wildfire mitigation, including
efforts to increase awareness and education of the utility's plan, explanation of key
mitigation activities,and efforts supporting public readiness.
WMP GUIDELINES 4 UPDATED EXHIBIT
NO. 1
Updated Exhibit No. 1-Redlined
Case No. GNR-E-25-02
Staff Reply Comments
August 21, 2025

• If the utility utilizes de-energization, a description of public education efforts and
communication protocols for before, during, and after a de-energization event. The
communication protocols should clearly identify which customers could and will be
impacted if a de-energization event is pursued and identify any advanced notifications for
critical infrastructure or customers, which may include but not limited to, hospitals and
other medical facilities, schools, police, fire, emergency operation centers, any
jails/prisons,other utilities,and vulnerable customers.
• Explanation of the communication methods the electric corporation intends to use,such as
mail,flyers,emails,calls,texts,a notification system,its website,etc.
I.C.§61-1803(3)(d)-Government Outreach
"Outreach efforts to coordinate with federal, state, tribal, and local officials and
agencies on wildfire preparedness and emergency response plans."
The electric corporation must describe how it engages with and coordinates with federal,
state,tribal,and local officials and agencies on wildfire preparedness and emergency response in
the plan year. This discussion may include,but is not limited to:
• If applicable, Public Safety Power Shutoff("PSPS") tabletop exercises with interested
parties and agencies
• Communication with the agencies and the ESF-12 coordinator within the PUC.
• If applicable,mitigation efforts with the agencies.
The WMP must detail all relationships (such as BLM and Forest Service)
it has established that may benefit the wildfire mitigation program,contribute to program costs,or
provide cost sharing opportunities in its WMP.
I.C.§61-1803(3)(e)-Method of Line Design
"Financially prudent and reasonably practicable methods of line design for new,
planned,and existing lines to mitigate fire risk."
The electric corporation must describe how its methods of line design for new lines and
planned upgrades reduce wildfire ignition potential in heightened wildfire risk areas. This must
WMP GUIDELINES 5 UPDATED EXHIBIT
NO. 1
Updated Exhibit No. 1-Redlined
Case No. GNR-E-25-02
Staff Reply Comments
August 21, 2025

include evaluation of costs to wildfire risk reductions.Additionally, this must include how the
electric corporation clearly identifies, selects, and evaluates projects that reflect a balance of
mitigation costs with resulting reduction in wildfire risk are least eost,least r:w for the following,
but is not limited to:
• Line rebuilding within the WMP.
• Undergrounding lines within the WMP.
• Installation of covered conductor.
• Installation of non-wooden cross arms.
• If any, describe any flexible infrastructure such as automatic reclosers and remote-
controlled devices that support remote operations.
I.C.§61-1803(3)(f)-Situational Awareness and Monitoring
"Monitoring of forecasted and current weather data for the purpose of assessing and
responding to current and anticipated fire risk."
This section should include a description of how the electric corporation monitors
forecasted and current weather conditions for the purpose of assessing and responding to current
and anticipated wildfire risk.This description must include,but is not limited to,the following:
• Identification of systems, tools, or external resources used to monitor weather, fire
potential,or other situational awareness indicators.
• If applicable, a description of how the utility utilizes weather forecasting, fire potential
modeling,or similar tools,to inform mitigation activities and operational decisions.
• Discussion of how situational awareness capabilities are integrated into daily or seasonal
wildfire operations.
• Discussion of how the electric utility become aware of another electric corporation's de-
energization (e.g., Bonneville Power Administration) and how that is integrated into
operations.
Developing Standards,Procedure,and Schedules
Idaho Code 61-1803(3)(g)requires each electric corporation to"[develop]standards,
procedures,and schedules,subject to timely approval of access to rights-of-way,if necessary..."
WMP GUIDELINES 6 UPDATED EXHIBIT
NO. 1
Updated Exhibit No. 1-Redlined
Case No. GNR-E-25-02
Staff Reply Comments
August 21, 2025

for the 1)Infrastructure Inspection and Maintenance,2)De-Energization,and 3)Vegetation
Management.
I.C.§61-1803(3)(g)(i)-Infrastructure Inspection and Maintenance
"Inspection of the electric corporation's assets,infrastructure,and facilities within
the areas that are identified as heightened fire risk areas in the wildfire mitigation
plan,were financially prudent and reasonably practicable."
This section should provide a summary of electric corporation's programs for the
inspection of electric infrastructure, assets, and facilities within areas identified as heightened
wildfire risk areas to identify and correct conditions that could contribute to wildfire ignition.This
summary must include,but is not limited to,the following:
• Description of inspection standards for each type of infrastructure,assets,and facilities.
• Description of schedules for inspections for each type of infrastructure,asset,and facility.
• Description of baseline routine inspection methods and enhanced inspection methods for
higher fire risk areas,which may include the use of advanced or pilot technologies.
• Explanation of how identified defects are classified,prioritized,and corrected.
• Measurable targets/goals to be achieved within the WMP. E.g.,miles of lines inspected,
corrected identified defects,etc.
I.C.§61-1803(3)(g)(ii)-De-Energization
"De-energization of the electric corporation's power lines,if considered appropriate
by the electric corporation."
If an electric utility plans to use de-energization as part of its wildfire mitigation efforts,
this section must address the standards,criteria,and operational protocols,for de-energization for
encroachment of a wildfire,proactive de-energization(PSPS)to reduce fire risk,de _r_r-giz4_ie
if requested by a fire e and de-energization from 3' party energy providers, and
energizatien for planned ttfifity work for wildfire mitigation. This discussion must include,but is
not limited to the following:
• A summary of the conditions under which de-energization may be used,if applicable.
• The criteria or protocols for evaluating its appropriateness to engage.
WMP GUIDELINES 7 UPDATED EXHIBIT
NO. 1
Updated Exhibit No. 1-Redlined
Case No. GNR-E-25-02
Staff Reply Comments
August 21, 2025

• Summary of the electric corporation's operational protocols for before,during,and after a
de-energization event.
• Description of how the electric corporation will coordinate with local emergency
managers,operators of critical facilities,and affected communities before,during,and after
a de-energization event.
• Descriptions of other operations for limiting impact to affected communities;which may
include community resource centers,emergency generators,backup batteries,etc.
I.C.§61-1803(3)(g)(iii)-Vegetation Management
"Vegetation management within the areas that are identified as heightened fire risk
areas in the wildfire mitigation plan and are within the electric corporation's rights-
of-way or lands adjacent thereto and that threaten the power lines or other electric
corporation infrastructure.If live marketable timber is identified for removal from
timber company land adjacent to the rights-of-way, compensation at fair market
value shall be made to the landowner for such timber."
This section must provide an overview of the utility's vegetation management program
aimed at reducing the risk of vegetation-related contact with electric infrastructure in areas with
heightened wildfire risk within its rights-of-way or lands adjacent thereto. Elements of this
vegetation management section overview should include,but is not limited to,the following:
• Identification,description, and citation of vegetation management standards for elevated
wildfire risk areas.
• Explanation of how vegetation management standards, procedures, and schedules are
different or the same as routine vegetation management.
• Description of the current and planned vegetation management practices used to mitigate
wildfire risk,including any enhancements in designated wildfire areas.
• The electric corporation must explain how the electric utility considered vegetation
management recommendations by other federal, state, and county agencies into its
standards.
• Must include measurable targets/goals to be achieved within the WMP.E.g.,miles of lines
completed,risk trees removed,etc.
WMP GUIDELINES 8 UPDATED EXHIBIT
NO. 1
Updated Exhibit No. 1-Redlined
Case No. GNR-E-25-02
Staff Reply Comments
August 21, 2025

• Explanation of how identified risk trees are classified,prioritized,and corrected.
Other Items to Include in a WMP
1) An update of lessons learned from the previously approved WMP within the annual filings
for WMP review and approval.
2) A breakdown of each program category's forecasted costs by year for both capital and
O&M expenditures through the length of the WMP.
3) A section in which it describes how the electric corporation addresses each of the
Commission's orders and Staff's recommendations.
WMP GUIDELINES 9 UPDATED EXHIBIT
NO. 1
Updated Exhibit No. 1-Redlined
Case No. GNR-E-25-02
Staff Reply Comments
August 21, 2025

CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this i�ay of August 2025, I served the foregoing
REPLY COMMENTS OF THE COMMISSION STAFF in Case No. GNR-E-25-02, via
Electronic Mail to the following:
Idaho Power Company: PacifiCorp d/b/a Rocky Mountain Power:
Megan Goicoechea Allen [e-mail] Joe Dallas joseph.dallas(&yacificorp.com
Donovan Walker dwalkerka,idahopower.com Mark Alder [e-mail]
Lisa C. Lance llancekidahopower.com datarequestkpacificorp.com
Matt Larkin [e-mail]
Connie Aschenbrenner [e-mail]
Tim Tatum ttaturnkidahopower.com
Riley Maloney rmalongy(&idahopower.com
dockets(c�r�,idahopower.com
Avista Corporation: Atlanta Power:
Anni Glogovac [e-mail] Nick Jones [e-mail]
Elizabeth Andrews [e-mail]
avistadockets(c-r�,avistacorp.com
Raft River: Lower Valley Energy:
Chad Black cblack@a,rrelectric.com Jim Webb jimklvenergy.com
City of Bonners Ferry: Idaho County Light&Power:
Mike Klaus [e-mail] Max Beach [e-mail]
Fall River Electric: Idaho Falls Power:
Bryan Case [e-mail] Michael A.Kirkham [e-mail]
Linden Barney linden.bamey_kfallriverelectric.com Stephen Boorman sboormankifpower.org
Randy Wakefield randy.wakefield(c-r�,fallriverelectric.com
David Peterson [e-mail]
Northern Lights,Inc.: Kootenai Electric Cooperative:
Annie Terracciano annie.terracciano(c-r�,nli.coop Michael G.Andrea mandrea(a,kec.com
Kristin Burge kristin.burgeknli.coop Thomas Maddalone [e-mail]
Trevor Kelly trevor.kellyknli.coop
Lost River Electric Cooperative: Clearwater Power:
Brad Gamett bradklrecoop.com Tell Stanger [e-mail]
United Electric: Idaho Consumer-Owned Utilities Association:
Michael Darrington mdarrin on(a)uec.coop Will Hart whartkicua.coop
Idaho Department of Lands: CTIA—The Wireless Association:
J.J.Winters jwinters(kidl.g_ov Matthew DeTura MDeTurakctia.org
Tyre Holfeltz [e-mail] Benjamin Aron [e-mail]
CERTIFICATE OF SERVICE
Page 1 of 2

PotlatchDeltic Corp: Bennett Lumber Products, Inc.,Idaho Forest
Peter J. Richardson [e-mail] Group,Manulife Investment Management,
Michele Tyler [e-mail] Molpus Woodlands Group, and Stimson
Anna Torma [e-mail] Lumber Company:
Wade Semeliss [e-mail] Pendrey P.Trammell [e-mail]
Brian Schlect brian.schlectkpotlatchdeltic.com
Jeremy Pisca jpiscaArischpisca.com
US Telecom—The Broadband Association:
B. Lynn Follansbee lfollansbeekustelecom.org
Kathleen Slatterly Thompson ksthompsonAustelecom.org
PATRICIA JORD , SECRETARY
CERTIFICATE OF SERVICE
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