20250930Final_Order_No_36774.pdf

Office of the Secretary
Service Date
September 30,2025
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF COMMISSION ) CASE NO. GNR-E-25-02
STAFF'S APPLICATION FOR APPROVAL )
OF A FILING PROCESS FOR WILDFIRE ) ORDER NO. 36774
MITIGATION PLANS )
On June 18,2025, Staff("Staff')of the Idaho Public Utilities Commission("Commission")
applied to establish a filing process for Wildfire Mitigation Plans ("WMPs") submitted under the
Wildfire Standard of Care Act ("WSCA"). See Idaho Code § 61-1801 et seq. 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.
On June 18, 2025, Staff moved for a Commission order setting 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. The Commission granted intervention to PotlatchDeltic Corporation ("Potlatch"),
Idaho Power Company,Avista Corporation, d/b/a Avista Utilities, Kootenai Electric Cooperative,
Inc. ("KEC"), Rocky Mountain Power, a Division of PacifiCorp, the Idaho Department of Lands
("IDL"), the City of Idaho Falls ("Idaho Falls"), Bennett Lumber Products, Inc., Idaho Forest
Group, Manulife Investment Management, Molpus Woodlands Group, and Stimson Lumber
Company. Order Nos. 36673, 36692, 36697, and 36699.
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 ("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.
ORDER NO. 36774 1

On August 7,2025,interested parties and utilities submitted comments on Staff's proposals
within its Original Application and Supplemental Application.I
On August 21, 2025, Staff filed reply comments.
Having reviewed the record, the Commission now issues this Order establishing a
procedure and filing schedule for WMPs submitted for approval under the WSCA.
BACKGROUND
On February 21, 2025, the first version, Senate Bill 1124a, of the WSCA was introduced
in the Idaho Senate State Affairs Committee. After several amendments,that version failed to pass
in the Senate. Subsequently, a revised version of the WSCA, Senate Bill 1183, was enacted and
took effect on July 1, 2025. The law requires the Commission to annually approve WMPs for
investor-owned utilities ("IOUs"). Idaho Code § 61-1803(2)(a), -1803(4). Municipal and
cooperative utilities ("Unregulated Entities") may also submit WMPs for the Commission's
review. Id. at § 61-1803(2)(b), -1803(4). The Commission can determine filing deadlines for
WMPs, staggering them as needed. Id. at § 61-1803(2)(a)—(b), -1803(4), -1803(5). Under the
WSCA, if a wildfire results in a lawsuit against an electric corporation, "there is a rebuttable
presumption that the electric corporation acted without negligence if, with respect to the cause of
the wildfire, the electric corporation reasonably implemented a commission-approved wildfire
mitigation plan."Idaho Code § 61-1806.
THE APPLICATION
Staff seeks to establish a clear regulatory process for all IOUs, municipalities, and
cooperatives to follow and that satisfies the requirements of the WSCA. To accomplish this, Staff
proposes filing procedures, guidelines for WMPs, recommended filing dates, and the key
components that should be included in WMPs. Staff also requests that the Commission clearly
define the necessary elements of a WMP and associated compliance reports, as required by Idaho
Code §§ 61-1803(3) and 61-1803(5). Staff further requests direction on any other information the
Commission believes should be included in these filings.
1 On August 20,2025,Potlach filed comments responding to comments from interested parties filed by the August 7,
2025, public comment deadline. Under IDAPA 31.01.01.202.01(d), a Notice of Modified Procedure establishing a
comment deadline and a deadline for replies by the moving party. The Notice of Modified Procedure issued in this
case established an August 7,2025,comment deadline and an August 21,2025,reply deadline.Potlach is not the party
who filed the Application,which initiated this proceeding. Thus,Potlatch is not the moving parry authorized to file
comments by the August 21,2025,reply comment deadline. Instead,Potlatch had to file all its comments by August
7,2025.Accordingly,Potlatch's comments filed on August 20,2025,are untimely and will not be considered.
ORDER NO. 36774 2

PARTY AND PUBLIC COMMENTS
Fifteen IOUs, municipalities, cooperatives, and electric customers filed comments. While
some concerns expressed were unique to individual parties, multiple entities shared many of the
same issues.
I. Filing Timeline
Several intervenors raised concerns about the timeline for submitting WMPs. Because the
Commission has six months to approve or reject a proposed plan, these commentors worry that
some WMPs will not be approved before the next wildfire season. Accordingly,these commenters
argued that Staff s proposed schedule unfairly affects Unregulated Entities—such as
municipalities and cooperatives—by leaving them insufficient time to get their WMPs approved.
Instead of Staffs proposed filing schedule,they recommended a more flexible timeline that would
let these entities submit their WMPs earlier to ensure timely approval.For example,one suggestion
was for IOUs to file their plans immediately after the Commission issues its final order in this case,
with Unregulated Entities submitting by November 1,2025. However, one commenter, an electric
customer, felt the proposed schedule was too rushed and suggested that no plans be submitted
before January 1, 2026.
IL Justification of Costs
Many intervenors were concerned about having to justify the costs of complying with a
WMP. Idaho Falls and KEC argued that requiring them to explain their spending could lead to a
review of their rates and internal operations. They are worried that such financial scrutiny could
interfere with the authority of their own governing bodies. As a result,they urged the Commission
to limit its inquiries into the costs related to their WMPs.
Some commenters—mainly smaller municipalities and cooperatives—argued that cost
justification is either unnecessary or should not apply to Unregulated Entities. Others pointed out
that wildfire mitigation costs are often hard to separate from routine operational expenses.Because
of this, they felt that Staff s proposal is overly burdensome.
These commenters suggested that, instead of detailed cost breakdowns, signed attestations
or formal resolutions from their governing bodies should be enough to meet the minimum
requirements of the WSCA. These documents could show that the entities have reasonably
weighed wildfire mitigation costs and considered cost-effective, practical approaches—like
responsible line design for both new and existing infrastructure. Alternatively, Idaho Falls
ORDER NO. 36774 3

proposed using a system like the North American Electric Reliability Corporation's ("NERC")
periodic spot checks and audits to review costs.
III.Fire Reporting
Fire reporting requirements were another key concern for intervenors. Idaho Falls argued
that Staff s proposal to report fires within a quarter mile of utility infrastructure goes beyond what
the WSCA requires and is overly burdensome due to the high number of fires in its service area.
Instead, it suggested that Staff rely on the U.S. Department of the Interior's Wildland Application
Information Portal for fire data.
Other intervenors said they lack the resources to report all fires within a quarter mile of
their infrastructure. They recommended that this information be gathered from existing sources
instead. Those who did not entirely oppose fire reporting still supported a more limited approach.
They generally suggested only reporting the occurrence and general location of fires that directly
affect their systems.
Idaho's three largest IOUs proposed a narrower requirement: report only those fires that
are over one acre in size, are either known to the utility or reported by the National Interagency
Fire Center ("NIFC"), occur within a high wildfire risk area and within a quarter mile of utility
infrastructure during the compliance year, and include only causes that are publicly available
through NIFC at the time the compliance report is prepared.
IV.Compliance Reports
The intervenors generally asserted that the compliance reporting rules proposed by Staff
were too burdensome and went beyond what the WSCA intended. The IOUs argued that setting
monthly progress targets could create a false impression that they are not complying with their
WMPs. According to the IOUs, plans usually have annual goals that guide actions throughout the
year.
The IOUs suggested that compliance reports be submitted on a staggered schedule: Idaho
Power on April 1, Rocky Mountain Power on May 1, and Avista Corporation on June 1 each year.
These reports would include results from the previous calendar year and should be limited to
clearly known and measurable outcomes identified at the time each WMP is prepared.
The Unregulated Entities recommended that the Commission reject Staffs proposed
compliance reporting process. They argued that reporting requirements should differentiate
between regulated IOUs and Unregulated Entities,with the latter facing less strict rules.As a result,
ORDER NO. 36774 4

they called for further discussions and workshops with Staff to create a reporting process that
aligns with their interpretation of the WSCA.
V. Proposed Requirements for WMP
Intervenors were generally concerned about being required to develop rolling WMPs with
a three-year planning horizon. The IOUs believed such plans would impose a significant
administrative burden. Instead, they supported static three-year plans without the inclusion of
least-cost, least risk evaluations of line design. KEC expressed similar concerns, urging more
flexibility in the guidelines governing WMPs from Unregulated Entities.
Idaho Falls also urged flexibility in the requirements for WMPs. Specifically, Idaho Falls
argued that Staff s proposed process would require it to submit extensive and detailed information
to the Commission—including monthly targets, cost-benefit analyses, goals, metrics, and specific
data for each part of its WMP. According to Idaho Falls, this would be overwhelmingly
burdensome. As noted above, Idaho Falls recommended adoption of NERC's process for
evaluating system reliability. This process involves regular confirmation of compliance by an
electric municipality's governing board, along with occasional spot checks and audits. Idaho Falls
asserted that this method is cheap, streamlined, and familiar to municipalities, making it a more
practical way for municipal utilities to show compliance.
Customer comments on this issue sought stricter requirements for WMPs. For example,
one customer commenter asserted that the non-exhaustive list of "Preventative Actions and
Programs" that Staff indicated may be included in a WMP is required under Idaho Code § 61-
1803(3)(b). Another commenter recommended that each WMP include detailed descriptions of
every wildfire-related damage claim the electric corporation paid over the last two decades,
regardless of whether the company admitted liability,paid voluntarily, or because of a court order
or arbitration.
VI.Coordination with the Idaho Department of Lands
The IOUs generally supported Staffs proposed WMP requirements, with a few minor
adjustments and reforms. Specifically, they requested that discussions of de-energization exclude
circumstances where power is terminated at the request of first responders or for planned activities
like maintenance or circuit hardening. Although such shut offs may be part of broader wildfire
mitigation efforts, the IOUs characterized them as routine operational procedures.
ORDER NO. 36774 5

Many commentors, including the IOUs, recommended that the Commission clarify how it
will evaluate recommendations from other governmental agencies, like the Idaho Department of
Lands ("IDL"). When describing how input from federal, state, and local agencies was considered
in developing vegetation management standards, the IOUs emphasized that they must operate
within specific easements or rights-of-way and comply with the National Electrical Safety Code.
Therefore, they recommended that the Commission limit its explanation to how agency
recommendations directly relating to surface fuels, fuel reduction, or vegetation near utility
infrastructure were considered. Comments from IDL itself echoed some of these concerns.
VII. Timber Protections
A group of commentors expressed concern over the lack of what they believed were
adequate protections for marketable timber in Staff s proposed WMP guidelines. Idaho Code §
61-1803(3)(g)(iii) requires that landowners be compensated at fair market value ("FMV") for the
removal of live,marketable timber. However,these commentors noted that neither the WSCA nor
Staffs proposed guidelines outlined a process for valuation, notice, or dispute resolution.
To address this, these commentors proposed that the Commission require each WMP
include a written inventory of all proposed tree removals, identification of an independent third-
party timber appraiser if marketable timber is involved, and a procedure allowing landowners to
object or seek expedited mediation prior to any timber removal. Inclusion of these requirements
would reduce the likelihood of post hoc legal disputes.
The IOUs agreed that clarifying how FMV will be determined could reduce confusion and
landowner frustration when timber removal is necessary. Additionally, they also believed that
collaborating with all stakeholders to develop a list of timber companies or a centralized map of
timber lands would support compliance with the FMV compensation requirement for any timber
that is removed.
VIII. Retroactivity
The IOUs disagreed with Staffs proposed prohibition of retroactive amendments to
WMPs. They argue that this limitation does not reflect the practical challenges of implementing a
WMP or the required flexibility and innovation during the plan year, while still complying with
the WSCA and maintaining eligibility for its liability protections. Accordingly, the IOUs believe
they should be allowed—even encouraged—to respond quickly to changing conditions and adopt
more efficient or cost-effective wildfire mitigation strategies, even after a WMP has been
ORDER NO. 36774 6

approved. According to the IOUs, without the ability to amend a WMP mid-year (subject to
Commission review and approval), the WSCA may unintentionally discourage innovation and
efficiency by forcing utilities to follow outdated plans strictly,just to preserve liability protections.
STAFF REPLY COMMENTS
Staff s reply comments responded to the key concerns raised by the intervenors, clarifying
that any issues not specifically addressed should not be interpreted as agreement or approval. Staff
also incorporated some concerns that were originally brought up in public comments.Additionally,
a proposed set of WMP guidelines was included as an exhibit with the reply comments. Staff s
responses to individual issues are discussed in the sections below.
I. Filing Schedule
Staff indicated that many electric municipalities and cooperatives, in addition to Idaho's
three largest IOUs, are ready to file their WMPs with the Commission. Accordingly, Staff stated
that it expects up to 15 WMPs to be submitted, in addition to the Commission's usual caseload.
Staff stated that reviewing and approving all 15 WMPs before the 2026 fire season is unrealistic
and would not allow sufficient time for proper review and stakeholder input.
To address this, Staff has proposed alternative filing schedules, aiming to avoid
overwhelming the review process while still ensuring fairness to Unregulated Entities. Staff s two
proposed schedules account for each utility's size, complexity, and expressed preferences.
Although the proposed schedules may not allow every utility to receive an order approving its
WMP before the start of the 2026 fire season, the few that do not should receive one shortly
thereafter. The following two tables reflect Staffs two proposed filing schedule options:
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 Avista Northern Lights Idaho County Light
November 1 and Power
No earlier than PacifiCorp City of Idaho Falls United Electric
December 1
No earlier than Atlanta Power' Clearwater Power Lost River Electric'
January 1
No earlier than Lower Valley Fall River's City of Boners
Februaryl Energy* I Ferry*
No earlier than Any other electric corporation that wishes to file
March 1
ORDER NO. 36774 7

OOntion 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'
January 1
No earlier than Lower Valley Fall River* City of Boners
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.
Staff Reply Comments at 4. Staff preferred Option 1, believing it offered a balanced and
manageable review schedule. Under this option, one large, one medium, and one small utility
(based on Idaho customer count)would have the opportunity to file a WMP each month,beginning
October 1, 2025. Electric corporations who requested expedited filing would file before those that
did not.
Option 2 schedules filings from the largest to the smallest utility, followed by those not
requesting expedited review. Although this approach uses a clear and consistent method, Staff
noted it front-loads the workload and may not allow sufficient time for thorough review. Under
both options, the comment period for each WMP will be set when the plan is filed, in accordance
with the Commission's Rules of Procedure 31.01.01 et. seq. Staff requested that the Commission
adopt a filing schedule that reasonably balances expedited requests. Staff also stated that if it later
determines it can manage additional filings sooner than expected, it will formally ask the
Commission to allow certain utilities to file their WMPs ahead of schedule.
II. Annual Filings
Staffs original application requested that the Commission require electric corporations to
file their annual WMP reviews one year after the approval date of their previous plan, with set
dates for the IOUs. However, since Staff is now proposing alternative filing schedules, the timing
for annual reviews may shift. Instead of the schedule proposed in the Original Application, Staff
requested that the Commission direct each electric corporation to file its annual review one year
after the approved filing date, consistent with whatever WMP schedule the Commission adopts.
Although alternative annual filing dates may be proposed in the initial WMP submissions, Staff
believed this is a reasonable starting point for annual review filings.
ORDER NO. 36774 8

III.WMP Forecast and Planning Horizon
Staff disagreed with the IOUs' proposed static,three-year WMPs. Staff believed the IOUs
proposal for static plans does not align with prior orders or the Commission's planning standards.
As noted in Staff s Supplemental Application, Order No. 36042 requires Idaho Power to extend
the forecast of its WMP to five years. Idaho Power has followed this approach, submitting rolling
plans for 2024 and 2025 that build on prior versions and extend the forecast accordingly. Rocky
Mountain Power also develops its WMP with a three-year planning cycle, consistent with its
schedules in Utah and Wyoming.See Order No. 36405.Accordingly, Staff recommended that each
WMP include, at minimum, a three-year forecast.
IV.WMP Requirements for IOUs and Unregulated Entities
Staff believed its proposed WMP guidelines are reasonable, not overly burdensome, and
account for the varying size and complexity of each electric corporation. The purpose of the
guidelines is to help the Commission clearly define what must be included in a WMP under Idaho
Code §§ 61-1803(3)(a)—(g), and to establish consistent expectations for all electric corporations
choosing to file with the Commission.
Staff asserted that the only difference between IOUs and Unregulated Entities corporations
under the WSCA is that IOUs are required to file WMPs, while Unregulated Entities have the
option to do so. However,to receive the liability protections offered under Idaho Code § 61-1806,
Unregulated Entities must have a Commission-approved WMP. Consequently, Staff does not
support applying different standards and believes all filers seeking these protections must meet the
same statutory requirements.
The WSCA contains standards,procedures, and schedules for infrastructure inspection and
maintenance, de-energization practices, and vegetation management. These may be subject to the
availability of access to rights-of-way. Staffs proposed guidelines request measurable targets and
goals for the sections on infrastructure inspection and maintenance and vegetation management.
Staff viewed this information as critical to understanding how a utility plans to carry out its WMP
within the designated planning cycle. This information can also aid the Commission's evaluation
of whether the plan is feasible, cost-effective, and sufficient to reduce wildfire risk, as required by
Idaho Code §§ 61-1804(b) and (c). Accordingly, Staff recommended that the Commission adopt
its proposed WMP guidelines as minimum requirements for WMPs in addition to those listed
under Idaho Code §§ 61-1803(3)(a)—(g).
ORDER NO. 36774 9

V. Standard Operating Procedures in WMPs
Staff believed it was unnecessary for WMPs to include detailed standards, criteria, or
operational protocols for de-energization. De-energizations carried out at the request of fire
agencies or for planned utility work are already covered under each utility's Standard Operating
Procedures ("SOPs"). Consequently, Staff proposed removing these two situations from the
minimum WMP requirements.
In response to concerns about separating wildfire mitigation activities from routine SOPs,
Staff maintained that the WMP should serve as the utility's comprehensive wildfire mitigation
strategy. Staff acknowledged that wildfire mitigation is just one aspect of a utility's broader
operations and that many projects may serve multiple purposes. Rather than trying to split or
allocate costs,however, Staff recommended including the full project cost in the WMP,along with
an explanation if the project also addresses goals beyond wildfire mitigation. Furthermore, if a
mitigation activity provides benefits beyond wildfire risk reduction, Staff recommended that
electric corporations explain in their WMPs whether the effort is part of normal operations or goes
beyond what is covered in their SOPs. Staff believed most of this information already exists, as it
would be developed during internal approvals by each electric corporation's governing board.
VI."Least Cost,Least Risk" Line Design Requirements
Staff did not believe that including line design methods in a WMP infringes on the authority
of the governing boards of Unregulated Entities over costs or rates. Rather, this requirement is
clearly outlined in the WSCA and applies to all electric corporations that submit a WMP. To
support the contention, Staff noted that Idaho Code § 61-1803(3)(e)requires all WMPs to include,
at a minimum, "financially prudent and reasonably practicable methods of line design for new,
planned, and existing lines to mitigate fire risk."
In response to other comments, Staff revised the language in its proposed guidelines to
better align with the WSCA. Specifically, Staff removed the phrase "least-cost, least-risk" and
replaced it with language that reflects "a balance of mitigation costs with the resulting reduction
in wildfire risk,"which more accurately reflects the text of Idaho Code § 61-1803(3).
Staff s updated proposed guidelines now state:
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...
ORDER NO. 36774 10

Staff s Reply Comments -Exhibit 1 at 6.
Staff believed this level of detail is important for the Commission's review of WMPs under Idaho
Code § 61-1803(3)(e). Staff requested that the Commission adopt the revised language described
above as part of the minimum requirements for all WMPs.
VII. WMP Amendments
Staff opposed the retroactive application of WMPs without the express approval of the
Commission. Idaho Code § 61-1803(4) states that Commission-approved WMPs must be
implemented upon approval. Staff interpreted this to mean that a WMP becomes effective on the
date of the Commission's approval and remains so until approval of a new WMP. Staff requested
clarification of the effective period for each approved WMP. If no such clarification is provided,
Staff will propose effective dates in each individual WMP filing.
Although Staff is not opposed to utilities filing amendments to approved or pending
WMPs, it noted that significant updates or modifications could affect the entire plan. Under Idaho
Code § 61-1804, the Commission must approve or deny amended plans within six months.
Therefore, Staff requested the Commission clarify whether it will accept amendments to filed or
approved WMPs, and whether any such amendments could be approved retroactively.
VIII. IDL Participation
Neither Staff s Original nor Supplemental Application addressed the requirement under
Idaho Code § 61-1804(3) which requires the Commission to consult with interested parties,
including the state forester, as identified in Idaho Code § 61-1804(2). During informal discussions
with the state forester and IDL wildfire risk mitigation program director, IDL expressed its intent
to intervene in all future WMP filings to review each plan and provide recommendations. Under
Idaho Code § 61-1804(3), the state forester's recommendations—particularly those related to
vegetation management, fuel reduction, and responsibilities under Title 38 Idaho Code—are
presumed reasonable and appropriate. If the Commission finds any recommendation unjust,
unreasonable, or not in the public interest, however, it must explain its reasoning in the order
approving or rejecting the WMP. Idaho Code § 61-1804(3).
IX.Cost Justification
In response to comments suggesting that its proposed process could constitute rate
regulation regarding Unregulated Entities, Staff asserted that its proposals are solely intended to
satisfy the requirements of Idaho Code § 61-1803(3),which calls for balancing wildfire mitigation
ORDER NO. 36774 11

costs with the resulting risk reduction. Staff disclaimed any intent to evaluate whether any project
or action is prudent for cost recovery from ratepayers of Unregulated Entities in the WMP. Rather,
the purpose of collecting cost and financial information is to create a complete record to determine
whether each WMP meets the statutory requirements. Neither the WSCA nor Staff s proposal
gives the Commission authority to set rates or judge cost recovery. Therefore, Staff believed its
recommendations do not constitute rate regulation and that requesting financial information is
reasonable and appropriate.
X. Cost-Benefit Analysis
Staff proposed requiring electric corporations to submit WMPs with cost estimates for their
planned projects and operations. According to Staff, this proposed requirement is not intended to
override the authority of the utility's governing board or to determine whether costs are prudent
for rate recovery. Rather, its purpose is to ensure Staff can make informed recommendations with
a record sufficient to support a Commission decision.
To support this proposed requirement, Staff noted that Idaho Code § 61-1803(3) requires
each WMP to include strategies that reflect a reasonable balance between mitigation costs and
wildfire risk reduction. Additionally, Idaho Code § 61-1804 directs the Commission to consider
the feasibility and cost of implementing each plan. Staff also observed that the WSCA does not
distinguish between IOUs and Unregulated Entities regarding WMP content or approval standards.
Therefore, Staff did not support altering the statutory requirements to allow more flexibility for
Unregulated Entities.
However,Staff acknowledged that each WMP should be tailored to the size and complexity
of the utility, as required by Idaho Code § 61-1803(3), and therefore does not expect all utilities to
provide the same level of detail in their cost or risk analyses. Larger companies like Idaho Power,
Avista or Rocky Mountain Power may submit more detailed financial analyses, while smaller
utilities, such as Atlanta Power, may provide simpler submissions.
XI.Compliance Reports
In response to concerns expressed about the proposed compliance reporting requirements,
Staff agreed to hold workshops to determine what information should be included in these reports.
Staff believed issues like monthly targets and expenditure tracking can be resolved collaboratively
in workshops. To that end, Staff requested that the Commission direct it to hold two workshops
with interested parties and submit a joint proposal for standard compliance report requirements by
ORDER NO. 36774 12

December 31, 2025. If consensus cannot be reached, each party would submit its own proposal by
that same date.
Staff also indicated its openness to discussing potential compliance report filing deadlines
during the workshops. Therefore, at this time, Staff does not recommend the Commission set
specific filing dates or timeframes for the required compliance reports. Ultimately, Staff expected
each electric corporation to provide the same type of information their governing boards would
use to evaluate whether their WMP appropriately balances cost and wildfire risk as required by
the WSCA.
XIL Fair Market Value of Timber
Staff observed that the term"fair market value"is not defined in the WSCA. Staff believed
electric corporations should outline how they will determine or achieve fair market value in
relevant situations within their WMPs. Staff encouraged electric corporations to collaborate with
interested parties to establish a fair and consistent approach to determining fair market value.
XIII. Timber Company Contacts or Maps
Staff generally supported the proposed collaboration among stakeholders to create a
working list of timber companies or a centralized map of timber-owned lands. However, Staff
indicated that IDL may be the more appropriate agency to host such information.
XIV. Late Filed Comments
Due to the compressed timeline of this case, Staff recommended that the Commission
consider any late filed comments.
COMMISSION DISCUSSION AND FINDINGS
The Commission has jurisdiction over this matter pursuant to the authority and power
granted it under Title 61 of the Idaho Code, including the WSCA. The purpose of WSCA is to
provide electric service that is safe, reliable, and affordable, while minimizing risk to the public.
See Idaho Code § 61-1802. Addressing wildfire risk is a growing priority for electric utilities, and
proper planning is essential to both prevent wildfires and respond effectively when they occur. To
foster this planning, the WSCA provides liability protections to electric corporations that comply
with a Commission-approved WMP. See Idaho Code § 61-1806. The Commission's experience
and expertise in regulating electric utilities led the Idaho Legislature to assign it the responsibility
of reviewing and approving required and voluntarily filed WMPs.To ensure a timely and thorough
ORDER NO. 36774 13

review of proposed WMPs, the Commission establishes the following filing schedule, guidelines,
and essential components for WMPs.
I. Filing Schedule
Idaho Code § 61-1803 authorizes the Commission to set the filing schedule for WMPs.
Staff anticipates the filing of as many as 15 WMPs before the 2026 wildfire season. To avoid a
flood of filings and promote orderly, efficient review of WMPs, we find it reasonable to adopt
Staff s proposed Option 1 filing schedule. This schedule allows one large, one medium, and one
small utility (based on its number of Idaho customers) to submit its proposed WMP for approval
each month. Additionally, we find it reasonable to allow electric corporations that requested
expedited filing to submit their WMPs before those that did not. In sum, we find Staffs proposed
Option No. 1 to be a balanced and manageable initial review schedule.
We acknowledge that the approved filing schedule may not allow every electric
corporation to obtain a Commission-approved WMP before the 2026 wildfire season. However,
we anticipate that those that do not are likely to receive one shortly thereafter. Furthermore, we
find it reasonable to ensure some flexibility in the filing schedule. Specifically, should Staff
subsequently determine that it can handle more WMP filings, we direct Staff to formally request
Commission approval to update the approved filing schedule and allow certain electric
corporations to file WMP ahead of schedule.
II. Annual Reviews and WMP Updates
Commission-approved WMPs must be reviewed and updated annually. Idaho Code § 61-
1803(4). To maintain a balanced and manageable review schedule going forward, we find it
reasonable to direct electric corporations to file updated WMPs one year after the approval date of
their previously approved WMP.
III.WMP Requirements for IOUs and Unregulated Entities
Several Unregulated Entities argued that they should be treated differently from IOUs,
suggesting fewer requirements or more flexibility than IOUs is appropriate. Other than permitting,
rather than requiring, Unregulated Entities to submit WMPs, the WSCA does not expressly treat
Unregulated Entities differently than IOUs. Compare Idaho Code § 61-1803(2)(a) with Idaho
Code § 61-1803(2)(b). Instead, the WSCA addresses differences among electric corporations by
requiring that each WMP be tailored to the scope and complexity of the corporation's operations.
Idaho Code § 61-1803(3). Acknowledging this minor discrepancy does not otherwise authorize
ORDER NO. 36774 14

different treatment of Unregulated Entities.Therefore we will not impose fewer requirements upon
Unregulated Entities solely based on their regulatory status.
IV.WMP Projections and Planning Horizon
We next consider the planning timeframe for WMPs. Consistent with established practice,
we find it reasonable to require electric corporations to develop rolling WMPs with a minimum
three-year planning horizon. As stated in prior proceedings, WMPs must incorporate long-term
planning while maintaining the flexibility to address emerging risks as they arise. See Order No.
36405.Requiring each iteration of a WMP to roll the planning and forecast horizon forward serves
the need for long-term planning while still allowing flexibility to address emergent threats.
Although this approach may place a greater burden on electric corporations than a static three-year
plan, we find that the improved wildfire risk reduction provided by a rolling plan justifies the
additional burden.
V. Exclusion of Standard Operating Procedures in WMPs
We concur with Staff s view that WMPs need not contain exhaustive standards or
procedures for every possible instance of live de-energization. Standards and protocols for de-
energization requested by fire agencies or for planned work that are included in an electric
corporation's SOPS may not be part of its wildfire mitigation strategy. Accordingly, standards and
protocols for these kinds of de-energizations need not be duplicated in a WMP.
However,a WMP should be a comprehensive plan to address wildfire risk.Although many
of an electric corporation's projects may support multiple objectives beyond wildfire mitigation,
it is not necessary to separate the costs among those different purposes. Rather, a WMP should
include the full cost of the project with an explanation of any additional objectives the project
serves beyond wildfire mitigation. If a project provides benefits beyond wildfire risk mitigation,
the WMP should explain whether the effort is part of its SOPs or exceeds them.
VI.Line Design Requirements
Idaho Code § 61-1803(3)(e) requires WMPs to include line design methods for new,
planned,and existing lines that are both financially prudent and reasonably practicable for wildfire
risk mitigation. Accordingly, WMPs must explain how an electric corporation's line design
methods reduce the potential for wildfire ignition,including a cost evaluation. This cost evaluation
need not be least-cost, least risk,but it must show how the mitigation project strikes the necessary
ORDER NO. 36774 15

"balance of mitigation costs with the resulting reduction in wildfire risk"required by the WSCA.
See Idaho Code § 61-1803(3)(e).
VII. WMP Amendments and Retroactivity
Idaho Code § 61-1806(l) creates a rebuttable presumption that an electric corporation
acted without negligence if, with respect to the cause of the wildfire, the electric corporation
reasonably implemented a commission-approved WMP. This rebuttable presumption applies to
any action or omission reasonably consistent with an approved WMP in effect when the fire began.
This rebuttable presumption applies only to actions or omissions reasonably consistent with the
approved WMP in effect when the fire began.Idaho Code§ 61-1806(1). Stated differently,a WMP
must be approved to provide liability protection to electric corporations. More importantly, this
liability protection applies only to fires ignited while the approved WMP is effective. A plain,
ordinary reading of the statutory text indicates a WMP is effective upon Commission approval,
and that this approval cannot be retroactive to cover prior fires.
With respect to mid-year amendments to approved plans, we find it reasonable to permit
their filing. However, to avoid disrupting the review of other WMPs, electric corporations must
first consult with Staff to discuss the proposed amendment and coordinate a filing date that
supports efficient review of all plans. Once filed, proposed amendments will be processed in
accordance with the Commission's Rules of Procedure.
VIII. IDL and State Forester Recommendations
Under Idaho Code § 61-1804(3), the state forester's recommendations, particularly those
related to vegetation management,fuel reduction,and responsibilities under Title 38,are presumed
reasonable and appropriate. We will apply this statutory presumption when reviewing WMPs.
However, we decline to set a definitive framework for how IDL's recommendations will be
considered at this time,as each WMP is expected to differ.As a result,the relevance and persuasive
force of IDL's comments and recommendations may vary from case to case.
IX.Cost Justification
One of the most contested aspects of this case is Staff s proposal to require a cost-benefit
analysis in WMPs to justify spending on projects related to WMPs. To support this proposed
requirement, Staff argued that such an analysis was necessary to determine whether planned
expenditures were justified relative to anticipated wildfire risk reduction benefits. However, some
Unregulated Entities were concerned that explaining their expenditures could result in review of
ORDER NO. 36774 16

their rates and internal management,potentially undermining the authority of their own governing
authorities.
Under Idaho Code § 61-1803(3), WMPs must reasonably balance anticipated wildfire risk
reductions against the anticipated mitigation costs. Assessing whether the WMP has achieved this
balance requires a review of the cost-benefit analysis underlying the expenditures outlined therein.
Additionally,Idaho Code § 61-1804 requires the Commission to consider the feasibility and cost
of implementing each WMP when deciding whether or not to approve a WMP.Review of the cost-
benefit analysis supporting WMP expenditures can inform the Commission's consideration of
those costs.Finally,the WSCA is intended to guide the prudent use of resources to address wildfire
risks with justifiable costs,keeping utility rates affordable and protecting Idaho residents and their
property.Idaho Code § 61-1802. Including a cost-benefit analysis in WMPs supports this goal by
requiring electric corporations to perform a balancing test that assesses whether expenses are
prudent.
Accordingly, we find it reasonable to direct all electric corporations to include a cost-
benefit analysis in their proposed WMPs that justifies the expenditures for risk mitigation
described within. This directive does not amount to rate regulation. Rate regulation occurs when a
government body sets the prices a company can charge. The WSCA grants the Commission
authority solely to approve or reject a proposed WMP, not to regulate the rates an Unregulated
Entity charges. The Commission has no authority other than that given to it by the legislature. It
exercises a limited jurisdiction, and nothing is presumed in favor of its jurisdiction. See United
States v Utah Power&Light Co., 98 Idaho 665, 667, 570 P.2d 1353, 1355 (1977).
Furthermore,unlike IOUs,Unregulated Entities are not obligated to obtain a Commission-
approved WMP and may choose not to pursue one. Seeking Commission approval of a WMP may
influence an Unregulated Entity's decisions,including those related to service rates.However, any
rate changes made to obtain approval of a WMP for an Unregulated Entity would be entirely
voluntary and subject to their own processes only. This is not rate regulation.
X. Timber Protections
Idaho Code § 61-1803(3)(g)(iii) requires that landowners be compensated at FMV for the
removal of live, marketable timber from timber company land adjacent to a utility right-of-way.
Some commenters recommended establishing guidelines for valuation, notice, and dispute
resolution related to timber removal to help prevent future legal conflicts. We decline to do so.
ORDER NO. 36774 17

The WSCA does not define what constitutes FMV. Nor does the WSCA expressly grant the
Commission authority do provide such a definition. Accordingly, we lack the authority to do so.
See United States v Utah Power&Light Co., 98 Idaho at 667, 570 P.2d at 1355 (holding that the
Commission's jurisdiction is limited to that granted by statute).
Moreover, determining the amount a landowner should receive for removed timber is akin
to fixing damages in a civil case. The power to determine and award civil damages is the exclusive
province of the judicial courts and beyond the Commission's jurisdiction. See Pounds v. Denison,
115 Idaho 381, 384, 766 P.2d 1262, 1265 (Ct. App. 1988) (holding that awarding civil damages is
the exclusive province of judicial courts;McNeal v. Idaho Pub. Utilities Comm'n, 142 Idaho 685,
691, 132 P.3d 442, 448 (2006) (observing that the Commission is not a judicial court), abrogated
on other grounds by Verska v. Saint Alphonsus Reg'l Med. Ctr., 151 Idaho 889, 265 P.3d 502
(2011). We do, however, encourage electric corporations to collaborate with interested parties to
establish a fair and consistent approach to determining fair market value. Similarly,we encourage
the electric corporations to develop a list of timber companies or a centralized map of timber lands
to support compliance with the FMV compensation requirement for any timber that is removed.
XI.Compliance Reports
Finally, under Idaho Code § 61-1803(5), electric corporations with an approved WMP
must submit an annual compliance report to the Commission, unless directed otherwise by
Commission rule or order. Such reports must provide documentation detailing how the
components and measures of the WMP were developed and adopted,the related expenditures, and
the actions taken to implement the plan.
Given the substantial number of comments on Staff s proposed compliance report
requirements, we find it reasonable to direct Staff to conduct two workshops to determine the
necessary report content. These workshops should address topics such as fire reporting
requirements, monthly compliance targets and expenditures, filing dates, and achieving
consistency in language and formatting across all WMPs. Following the workshops, interested
parties may submit joint proposed standard compliance report requirements by December 31,
2025. If consensus is not reached, individual proposals may be submitted by the same date.
XIL Staff s Proposed WMP Guidelines
Attached to Staff s reply comments as Exhibit No. 1 is a revised set of proposed guidelines
for electric corporations to follow for the WMP filings. Considering our decisions above general
ORDER NO. 36774 18

lack of objection to Staff's Exhibit No. 1, we find it reasonable to accept and approve it as
guidelines for each electric corporation's WMP filing. Each electric corporation must comply with
these guidelines for its WMP to satisfy the requirements for approval going forward.
XIII.Staffs Proposed "Need to Know" Document
Attached to Staff s Supplemental Application as Exhibit No. 2, is a proposed "Need to
Know" document. The purpose of this document is to gather essential information to support
Staffs review and processing of a WMP from an Unregulated Entity. As previously stated,Idaho
Code § 61-1803(3) requires WMPs to be reflective and commensurate with the size and
complexity of the electric corporation's operations and of the nature of the fire risk it faces. We
find it reasonable to direct Unregulated Entities to submit a completed copy of Staff s proposed
"Need to Know" document with their initial WMP filings to aid Staff in its review of the plan.
XIV.Annual Wildfire Update Meetings
Before the WSCA was enacted, the Commission held annual meetings with Idaho's three
largest IOUs to receive updates on wildfire conditions and their mitigation efforts. We will
continue to hold these meetings. To avoid having them overlap with WMP annual reviews, these
meetings shall occur annually during the third week in May, or as close thereto as reasonably
possible. Additionally, as Unregulated Entities may now submit WMPs, we find it reasonable to
offer them the opportunity to participate in these meetings, should they choose to do so.
XV. Review Fees for WMP from Unregulated Entities
Idaho Code § 61-1803(2)(b) authorizes the Commission to assess Unregulated Entities a
reasonable fee for reviewing their WMPs. This is necessary because,unlike IOUs that are assessed
special regulatory fees annually,Unregulated Entities generally do not pay fees that cover the cost
of their supervision and regulation. Accordingly, we find it reasonable to direct Staff to issue
quarterly invoices to each Unregulated Entity based on time and expense principles to review its
WMP pursuant to Idaho Code § 61-1004. If a Unregulated Entity has no outstanding balance
during a quarter, the issuance of an invoice is unnecessary.
XVI.Notices to Interested Parties
Idaho Code § 61-1804(2) requires electric corporations to provide notice to certain
interested parties within five days of filing a WMP for review and approval. To facilitate the
participation of those interested parties in the review process,we find it reasonable to direct electric
corporations to include the information Staff proposed in these notices. Specifically, this notice
ORDER NO. 36774 19

must include a copy of the notice to the Commission of the filing of the WMP, the case number
for the case in which the WMP will be reviewed, and information about how to participate in the
proceeding.
ORDER
IT IS HEREBY ORDERED that electric corporations shall file their WMPs with the
Commission for review according to the schedule reflected in Option No. I from Staff s reply
comments and reproduced in Exhibit A attached to this Order.
IT IS FURTHER ORDERED that electric corporations shall file updated WMPs for their
annual review one year after the filing date of their previously approved WMP.
IT IS FURTHER ORDERED that electric corporations shall develop rolling WMPs with
a minimum three-year planning horizon.
IT IS FURTHER ORDERED that WMPs need not contain exhaustive standards or
procedures for de-energization requested by fire agencies or for planned work that are included in
an electric corporation's Standard Operating Procedures.
IT IS FURTHER ORDERED that WMPs must explain how an electric corporation's line
design methods reduce the potential for wildfire ignition, including a cost evaluation.
IT IS FURTHER ORDERED that, before filing a mid-year amendment to an approved
WMP, electric corporations must consult with Staff to discuss the proposed amendment and
coordinate a filing date that supports efficient review of all plans.
IT IS FURTHER ORDERED that all electric corporations must include a cost-benefit
analysis in their proposed WMPs that justifies the expenditures for risk mitigation described
within.
IT IS FURTHER ORDERED that Staff shall hold two workshops to determine the required
content of compliance reports. Topics covered in these workshops should include fire reporting,
monthly compliance targets, expenditures, filing timelines, and establishing consistency in
language and formatting of all WMPs. Following the workshops, interested parties may submit
joint proposed standards by December 31, 2025, or individual proposals if consensus is not
reached.
IT IS FURTHER ORDERED that Staffs proposed WMP guidelines reflected in Staffs
Exhibit No. 1 attached to its reply comments are accepted and approved guidelines for each electric
corporation's WMP filing. A copy of Staffs Exhibit I is attached to this Order as Exhibit B.
ORDER NO. 36774 20

IT IS FURTHER ORDERED that Unregulated Entities shall submit a completed copy of
Staff s proposed"Need to Know"document with their initial WMP filings to aid Staff in its review
of the plan. A copy of Staffs "Need to Know" document is attached to this Order as Exhibit C.
IT IS FURTHER ORDERED that annual meetings to update the Commission on wildfire
conditions in Idaho and the IOUs mitigation efforts shall occur annually during the third week in
May, or as close thereto as reasonably possible. Unregulated Entities may participate in these
meetings.
IT IS FURTHER ORDERED that Staff shall issue quarterly invoices to each Unregulated
Entity based on time and expense principles pursuant to Idaho Code § 61-1004 to review its WMP
unless the Unregulated Entity has no outstanding balance for such costs.
IT IS FURTHER ORDERED that the notice to interested parties required under Idaho
Code § 61-1804(2) shall include a copy of the notice to the Commission of the filing of the WMP,
the case number for the case in which the WMP will be reviewed, and information about how to
participate in the proceeding.
THIS IS A FINAL ORDER. Any person interested in this Order may petition for
reconsideration within twenty-one (21) days of the service date upon this Order regarding any
matter decided in this Order. Within seven (7) days after any person has petitioned for
reconsideration, any other person may cross-petition for reconsideration. See Idaho Code § 61-
626.
ORDER NO. 36774 21

DONE by Order of the Idaho Public Utilities Commission at Boise, Idaho this 30ffi day of
September 2025.
G
Grp
DWARD LODGE, RE I ENT
fHNR. HAMMOND JR., COMMISSIONER
DAYN HARDI ,'COMMISSIONER
ATTEST:
ga4l _A_
La Calderon Robles
Interim Commission Secretary
I:\Legal\ELECTRIC\GNR-E-25-02_WW Process\orders\GNRE2502_final_at.docx
ORDER NO. 36774 22

Exhibit A
Case No. GNR-E-25-02
Order No. 36774
Exhibit A—WMP Filing 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 Avista Northern Lights Idaho County Light
November 1 and Powcr
No earlier than PacifiCorp City of Idaho Falls United Electric
December I
No earlier than Atlanta Power Clcarwatcr Powcr Lost River Electric
Januarvl
No earlier than Lower Valley Fall Rivcr City of Boners
February 1 Energy Ferry
No earlier than Any other electric corporation that wishes to file
March 1

Exhibit B
Case No. GNR-E-25-02
Order No. 36774
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EXHIBIT NO. 1
Idaho Public Utilities Commission
Wildfire Mitigation Plan Guidelines

Exhibit B
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Order No. 36774
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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
1 Avista Corp.,Idaho Power,and Rocky Mountain Power.
WMP GUIDELINES 2 UPDATED EXHIBIT NO. 1

Exhibit B
Case No. GNR-E-25-02
Order No. 36774
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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 hardeningstrategies
trategies
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.
WMP GUIDELINES 3 UPDATED EXHIBIT NO. 1

Exhibit B
Case No. GNR-E-25-02
Order No. 36774
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• Pilot Pro rg ams
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:
WMP GUIDELINES 4 UPDATED EXHIBIT NO. I

Exhibit B
Case No. GNR-E-25-02
Order No. 36774
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• 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:
WMP GUIDELINES 5 UPDATED EXHIBIT NO. 1

Exhibit B
Case No. GNR-E-25-02
Order No. 36774
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• 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.
WMP GUIDELINES 6 UPDATED EXHIBIT NO. 1

Exhibit B
Case No. GNR-E-25-02
Order No. 36774
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• 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
WMP GUIDELINES 7 UPDATED EXHIBIT NO. 1

Exhibit B
Case No. GNR-E-25-02
Order No. 36774
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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.
WMP GUIDELINES 8 UPDATED EXHIBIT NO. 1

Exhibit C
Case No. GNR-E-25-02
Order No. 36774
1 of 2
EXHIBIT NO. 2
ELECTRIC MUNIPALITIES AND COOPERATIVES
"NEED TO KNOW" DOCUMENT

Exhibit C
Case No. GNR-E-25-02
Order No. 36774
2 of 2
Electric Municipality and Cooperative Wildfire Mitigation Plan
Need to Know Document
Pursuant to Idaho Code § 61-1803(3), a Wildfire Mitigation Plan ("WMP") must be
reflective and commensurate with the size and complexity of the electric corporation's operations
and of the nature of the fire risk. A WMP must also reflect a reasonable balancing of mitigation
costs with the resulting reduction of wildfire risk.
The purpose of this document is to collect basic information that will aid in Staff's review
to process a WMP. Please provide the following information and provide the document along with
each respective WMP filing.
1. Name of Utility
2. Location of Utility:
a. Located inside of the Wildland Urban Interface?
3. Please provide a map of the Company's service territory. Please identify the Company
assets and provide a PDF zoomable.
4. Total number of Customers:
a. Residential
b. Commercial
c. Other
5. How is energy supplied to the Company? i.e., BPA, utility-owned generation, etc.
a. What is the name plate capacity in Megawatts ("MW") of utility-owned generation
sources?
b. What is the capacity factor of utility-owned generation sources?
6. What is the annual amount of energy in Megawatt-hours that the utility serves?
7. What is the peak demand in MW and when does it occur?
8. Standard operating procedures ("SOP") for infrastructure management and vegetation
management?
a. Annual spend?
b. Annual incremental spend proposed in WMP from SOP?
9. Last 3 years of financial statements:
a. Income Statement
b. Cash Flow Statement
c. Balance Sheet
NEED TO KNOW DOCUMENT 1 EXHIBIT NO. 2