20251010APPLICTION.pdf

w10AW POWER.
MEGAN GOICOECHEA ALLEN RECEIVED
Corporate Counsel October 10, 2025
mgoicoecheaallen(abidahopower.com IDAHO PUBLIC
UTILITIES COMMISSION
IPC-E-25-32
October 10, 2025
VIA ELECTRONIC FILING
Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg 8,
Suite 201-A (83714)
PO Box 83720
Boise, Idaho 83720-0074
Re: Case No. IPC-E-25-32
Idaho Power Company's 2026 Wildfire Mitigation Plan
Dear Commission Secretary:
Attached please find Idaho Power Company's Application to be filed in the above-
entitled matter.
If you have any questions about the attached documents, please do not hesitate
to contact me.
Very truly yours,
Megan Goicoechea Allen
MGA:cd
Attachments

MEGAN GOICOECHEA ALLEN (ISB No. 7623)
LISA LANCE (ISB No. 6241)
Idaho Power Company
1221 West Idaho Street (83702)
P. O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: (208) 388- 6936
mgoicoecheaallen(a�,idahopower.com
Ilance(c)_idahopower.com
Attorneys for Idaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER )
COMPANY'S 2026 WILDFIRE ) CASE NO. IPC-E-25-32
MITIGATION PLAN )
APPLICATION
COMES NOW, Idaho Power Company ("Idaho Power" or "Company"), and in
accordance with Idaho Public Utilities Commission ("Commission" or "IPUC") Rule of
Procedure' 52 and Order No. 36774,2 respectfully submits its 2026 Wildfire Mitigation
Plan ("WMP" or "Wildfire Plan"), included as Attachment No. 1, and requests the
Commission issue an order approving such plan.
Though the 2026 Idaho Power Wildfire Mitigation Plan is the sixth edition of the
plan, it is the first being filed for approval pursuant to the Wildfire Standard of Care Act
("WSCA"), Idaho Code § 61-1801 et seq. Pursuant to the WMP Filing Schedule3 adopted
Idaho Administrative Procedures Act (IDAPA) 31.01.01.
zln the Matter of Commission Staffs Application for Approval of a Filing Process for Wildfire Mitigation
Plans, Case No. GNR-E-25-02, Order No. 36774 (Sep. 30, 2025).
3 Exhibit A to Order No. 36774.
APPLICATION - 1

by the Commission, Idaho Power's WMP shall be filed with the Commission for review no
earlier than October 1st, with updated WMPs filed annually, one year after filing the
previously approved WMP. The Company notes that the timing of its inaugural filing under
the WSCA, while compliant with the Commission-approved filing schedule, was
postponed slightly to ensure compliance with the Commission-specific WMP filing
requirements set forth in Order No. 36774 issued on September 30th. Moving forward, the
Company intends to file its updated WMP for the Commission's annual review on or about
October 1st
In support of this Application, Idaho Power is submitting a Notice of Wildfire
Mitigation Plan Filing contemporaneously herewith and represents as follows:
I. INTRODUCTION
1. As Idaho Power explained in its Application in IPUC Case No. IPC-E-21-
02,4 the Western United States ("U.S.") has experienced an increase in the frequency and
intensity of wildland fires ("wildfires"). A variety of factors have contributed to this trend,
including changing climatic conditions, increased human encroachment in wildland areas,
historical land management practices, and changes in wildland and forest health.
2. While Idaho has not experienced fires to the same magnitude as some other
western states,5 Idaho's wildfire season has grown longer and more intense. Warmer
temperatures, reduced snowpack, and earlier snowmelt contribute to drier conditions,
extending the period of heightened fire risk.6
4 In the Matter of Idaho Power Company's Application for an Accounting Order Authorizing the Deferral of
Incremental Wildfire Mitigation and Insurance Costs, Case No. IPC-E-21-02, Application (Jan. 22, 2021).
5 Wildland Fire Summaries 2019-2024. Statistics I National Interagency Fire Center(nifc.gov)
6 Western Fire Chiefs Association. Idaho Fire Season:In-Depth Guide I WFCA
APPLICATION - 2

3. Idaho Power is focused on the safety of its customers and communities,
and to safely delivering reliable, affordable energy. The purpose of Idaho Power's WMP
is to guide mitigation strategies and reduce risk. Over the past five years under its WMP,
Idaho Power has worked to reduce wildfire risk by hardening its electrical system,
expanding situational awareness capabilities, upgrading the capabilities of the grid, and
enhancing vegetation management programs.
4. This Application is submitted in accordance with Idaho Code § 61-
1803(2)(a) and is premised on the Company's continued efforts to reduce wildfire risk for
the safety of Idaho Power's customers, the continued and reliable delivery of electricity to
approximately 630,000 retail customers in Southern Idaho, and good stewardship of the
beautiful and natural lands within Idaho Power's service area and beyond. Accordingly,
the mitigation measures outlined in the Company's 2026 WMP are also intended to
reduce potential risk associated with the Company's infrastructure or equipment, such as
operation of its 277 substations, as well as approximately 3,700 miles of overhead
transmission lines and 17,200 miles of overhead distribution lines within the state of
Idaho.' These overhead assets represent about 79 percent of Idaho Power's total
overhead transmission line assets and 89 percent of its total overhead distribution line
assets.
5. The 2026 WMP is built around a geographical risk assessment, which
utilizes a risk-informed approach that considers wildfire probability and consequence to
identify areas that may be subject to potential heightened wildfire risk in locations where
While the Company's 2026 WMP also encompasses assets and activities within the State of Montana,
because this Application is before the IPUC for approval specific to Idaho Power's operations in Idaho, all
discussion in this Application is confined to operations and activities occurring within Idaho.
APPLICATION - 3

Idaho Power has infrastructure or equipment. Additionally, the Company employs a risk-
informed cost and benefit balancing approach to select and prioritize various wildfire
mitigations carried out to reduce the risk of wildfire.
6. As more thoroughly discussed below, the Company's 2026 Wildfire Plan
identifies the methods and means for mitigating wildfire risk that reflect a reasonable
balancing of mitigation costs with the resulting reduction of wildfire risk, complying with
the requirements of Idaho Code § 61-1803(3) and the additional directives from the
Commission set forth in Order No. 36774 issued in GNR-E-25-02 on September 30, 2025,
including the IPUC WMP Guidelines provided as Exhibit B to that order. The Company's
2026 Wildfire Plan also complies with other directives from the IPUC contained in prior
orders as noted in Section II below.
II. IDAHO POWER'S 2026 WILDFIRE MITIGATION PLAN
7. To assist the Commission in its review of its 2026 Wildfire Plan, the
Company provides the following high-level overview of the WMP's conformity with the
various statutory and regulatory requirements and recommendations, including
identifying where in the Company's WMP content specific to the various statutory and
regulatory requirements and recommendations can be found. The Company is providing
this information for ease of reference and it should not be considered exhaustive. In the
event of any conflict or inconsistency between this Application and the WMP, the latter
shall govern.
APPLICATION - 4

A. Compliance with WSCA Requirements, IPUC WMP Guidelines, and Order
No. 36774.
(1) WMP Element — Cost-Benefit Approach
Idaho Code§ 61-1803(3) IPUC WMP Guidelines Corresponding Location
(Order No. 36774) in WMP
Each wildfire mitigation plan WMPs must include a cost-benefit Section 1. Introduction
shall be developed using analysis that justifies the Section 2. Geographical
approaches and methods that expenditures for risk mitigation Risk Assessment
are designed to protect the described within.
public interest and are reflective Section 3. Cost-Benefit
of and commensurate with the Approach
size and complexity of the Section 4. Situational
electric corporation's operations Awareness and Monitoring
and of the nature of the fire risk. Section 5. Mitigation Activity:
At a minimum, each wildfire Workforce Preparedness
mitigation plan shall identify a
means for mitigating wildfire risk Section Mitigation Activity:
that reflect a reasonable Line Operation
ation Practices
balancing of mitigation costs Section 7. Infrastructure
with the resulting reduction of Inspection and Asset
wildfire risk, including the Management
elements outlined below. Section 8. Methods of Line
Design
Section 9. Vegetation
Management
Section 10. Additional
Preventative Actions and
Programs
Section 11. Public Outreach
and Engagement
Section 12. Government,
Industry, and Peer Utility
Outreach
Section 13. Performance
Monitoring
Section 14. WMP Cost
Summary
Appendix A: Wildland Fire
Preparedness and
Prevention Plan
Appendix 8:Public Safety
Power Shutoff Plan
Appendix F: Wildfire
Mitigation Activities & Cost
Forecast 2026-2030
8. The Company's approach to mitigating wildfire risk is designed to protect
the public interest and reflects the size and complexity of Idaho Power's operations and
APPLICATION - 5

the specific fire risks present within the areas in Idaho where the Company has
infrastructure or equipment. Idaho Power's risk-based cost and benefit approach to
selecting wildfire mitigations is designed to reasonably balance the costs of mitigation
activities with the resulting reduction in wildfire risk. This starts with understanding the
potential costs of wildfires, assessing drivers of potential wildfire risk and, finally, using a
variety of strategies to select cost-effective mitigations to reduce wildfire risk.
9. Potential Costs. In assessing the potential consequence of wildfire risk,
Idaho Power considered several sources of data on the costs of major wildfires, though
ultimately determined that obtaining a precise calculation of the potential costs of future
wildfires is not possible. Quantifying the precise costs of wildfires is inherently uncertain
because outcomes vary by jurisdiction, weather, fuels, topography, location, population
density, and exposure. Litigation outcomes and community impacts can also differ widely
from event to event. Additionally, while fire suppression costs can be roughly estimated
on a per-acre basis, the actual cost of fire suppression can vary greatly depending on the
same variety of factors. Nonetheless, publicly available analyses of recent wildfires
illustrate the magnitude of potential avoided costs when prudent mitigation reduces the
likelihood or consequences of catastrophic events.
10. Risk Analysis and Drivers. The next step in the Company's selection of
cost-effective mitigations is to understand potential wildfire risk drivers. Idaho Power's
WMP risk management framework provides Idaho Power with a structured approach to
wildfire mitigation planning by enabling systematic identification, assessment, and
management of wildfire risk. While not all risk can be eliminated, Idaho Power's goal with
APPLICATION - 6

its WMP is to proactively prepare and enhance its infrastructure and operational practices
to prepare for and address wildfire risk.
11. Using its WMP risk management framework, Idaho Power gathered
information from internal subject matter experts regarding potential ignition risk drivers
and developed the below risk bow-tie diagram as a visual representation of equipment-
specific wildfire ignition risks, including key drivers, scenarios, likelihood, and potential
impacts.
Figure 1
Risk bow-tie diagram
Risk Drivers Triggering EventImpacts
L -AW-1
lation
Animals
Vehicle collision
Other Property Damage
$Li
nn
Insulator
Transformer Wildfire Ignition
Conductor/Splice/Connector Financial Loss
Wood poles
ified
rlmk
High winds and low humidity .• and Reliability
Lightning
Vandalism
Construction activities/Work nmental
12. Mitigation Selection. Idaho Power's mitigation selection is informed by its
risk driver identification and its identification of wildfire risk zones. This approach allows
Idaho Power to direct its mitigations toward the geographic areas and infrastructure that
may be subject to heightened wildfire risk and to employ mitigations that are most likely
to achieve a reduction in wildfire risk. Each type of mitigation employed by Idaho Power
APPLICATION - 7

is designed to reduce one or more of the risk driver frequencies and/or minimize the
potential impacts or outcomes. In addition, while mitigations are primarily intended to
reduce the risk of wildfire, co-benefits, such as increased safety, reliability, and resiliency
of the system may also be achieved. Idaho Power's approach to selecting mitigations for
wildfire risk encompasses a variety of factors and considers various strategies to identify
mitigations that reflect a reasonable balancing of mitigation costs with the resulting
reduction of wildfire risk, as presented in the 2026 WMP.
(2) WMP Element - Geographical Risk Assessments
Idaho Code§ 61-1803(3)(a) IPUC WMP Guidelines Corresponding Location
(Order No. 36774) in WMP
Identifying geographical areas The electric corporation must include a Section 2. Geographical
where an electric corporation description of the wildfire risk Risk Assessment
has infrastructure or equipment assessment or model used to guide Appendix C: Wildfire Risk
that the electric corporation wildfire mitigation activities. The Zone Map Book
considers may be subject to a assessment should identify
heightened risk of wildfire at the geographic areas with elevated fire
time the wildfire mitigation plan risk, considering factors such as
is finalized by the electric vegetation, weather, topography,
corporation. 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.
13. Idaho Power's approach to mitigating wildfire risk starts by assessing
wildland fire risk using qualitative and quantitative strategies to identify geographic areas
where Idaho Power has infrastructure or equipment that may be subject to a heightened
risk of wildfire (referred to as Wildfire Risk Zones).
APPLICATION - 8

14. To accomplish this, Idaho Power has worked with an external consultant
that specializes in assessing and quantifying the threat of wildfire in different geographic
areas using a risk-based methodology for wildfire spread modeling. This risk-based
methodology relies upon weather modeling, fire spread modeling, and Monte Carlo
simulations, among other modeling techniques, and is commonly used across the
industry and consistent with conventional definitions of risk — an event's probability is
multiplied by its potential negative consequences or impacts should that event occur, as
demonstrated below.
Figure 2
Wildfire risk-based methodology
Fire Probabi Ity ConsequenceHISUNIC211weather 10
Temperature H Igher
wind .• . .irect.
RelaVve Humidity Acres Burned 0
L Topography -A 0 Moderate
Fuel Moisture Content
(dead or alive)
The components are defined as follows:
• Fire Probability. Fire volume (i.e., spatial integral of fire area and flame length) is
used as Fire Probability because rapidly spreading fires are more likely to escape
initial containment efforts and become extended fires relative to slowly developing
fires. Data inputs used in the fire spread model to determine the fire volume (Fire
Probability) include historical weather, topography, fuel type, and fuel moisture
content.
APPLICATION - 9

• Consequence. Estimation of the fire's impact on acres burned and structures (i.e.,
homes, businesses, and other human-made structures).
• Wildfire Risk. The highest wildfire risk areas are those where both the Fire Probability
and Consequence are elevated. Conversely, combinations of low Fire Probability and
elevated Consequence, or elevated Fire Probability and low Consequence, typically
indicate lower wildfire risk.
15. The Company's uses its wildfire risk modeling process to generate draft risk
tiers using the Jenks optimization$ method to bin the resulting risk model data, reflecting
risk relative to the modeled areas. These draft tiers were then considered by the Company
in conjunction with qualitative factors in establishing Idaho Power's wildfire risk zones
depicted in the 2026 WMP, including but not limited to, ingress/egress considerations; fire
response capabilities; federal, state, and local fire agency input on areas of concern
including home ignition zones; and customer input gained during outreach meetings on
factors such as neighborhood growth in the wildland urban interface and areas of
community concern. This consideration process is detailed in Figure 3.
Figure 3
Risk zone evaluation and determination process
DefensibleFFC U"�t
Input
Wildfire Risk Model
Wildfire
consequences from Ground Review Risk Zone
probabilistic fire Determination
spread model. A
•Vegetation condition Localized Input
•Ingress/egress routes 0
•
Federal and State
resource agencies
Fire professionals Risk Zone
Suppression capability Calibration
Response time
L L_ _A
8 Jenks optimization is a data classification method commonly used to determine the best arrangement of
values into different classes while seeking to minimize each class's average deviation from the class
mean and maximizing each class's deviation from the means of the other groups.
APPLICATION - 10

16. Based on Idaho Power's modeling and assessment process, the Company
has identified wildfire risk zones that may be subject to heightened wildfire risk: Tier 3 and
Tier 2 zones. Relative to Tier 2 zones, Tier 3 zones are generally assessed as having
greater possible wildfire risk. To aid in customer and public understanding, Idaho Power
color-codes these tiers on maps — yellow for Tier 2 and red for Tier 3.
17. Idaho Power's approach to risk modeling includes iterative review. Annual
qualitative risk area adjustments, occurring once per calendar year, are used to account
for unique factors that may increase or decrease risk due to changes that have occurred
over time, such as wildfire events that alter vegetation composition. A full and up-to-date
risk zone map can be viewed in detail on Idaho Power's website, and individual addresses
can be entered on the map to determine proximity to identified risk zones.9
(3) WMP Element - Preventative Actions and Programs
Idaho Code§ 61- IPUC WMP Guidelines Corresponding Location
1803(3)(b) (Order No. 36774) in WMP
Preventative actions and The electric corporation must describe Section 4. Situational
programs that the electric preventative actions and programs it will carry Awareness and
corporation will carry out to out to reduce the risk of wildfire, in addition to Monitoring
reduce the risk of wildfire. actions and programs specified in statute and by Section 5. Mitigation
the IPUC. For the three large investor-owned Activity: Workforce
utilities, a WMP's preventative actions and Preparedness
programs must include, but is not limited to, the p
following: Section 6. Mitigation
Activity: Line Operation
Situational Awareness Efforts Practices
■ May include use of technology to aid in Section 7. Infrastructure
weather monitoring; fire season outlook; Inspection and Asset
daily, weekly, and monthly weather and fire Management
modeling risk, etc. Section 8. Methods of
■ Consistent with 61-1803(3)(f) and the IPUC Line Design
WMP Guidelines.
Section 9. Vegetation
Asset Inspections Management
■ Must include the frequency and standards of Section 10. Additional
inspections for each type of electric Preventative Actions and
infrastructure within areas of elevated wildfire Programs
risk.
■ Consistent with 61-1803(3)(g)(i) and the
9 Protecting the Grid-Wildfire Risk Zones, idahopower.com/outages-safety/wildfire-safety/protecting-grid/.
APPLICATION - 11

IPUC WMP Guidelines. Section 11. Public
Outreach and
Enhanced Vegetation Management Practices in Engagement
Risk Zones Section 14. WMP Cost
■ May include shorter vegetation management Summary
cycles than routine cycles, risk tree
programs, etc. Appendix A: Wildland
■ Consistent with 61-1803(3)(g)(iii) and the Fire Preparedness and
Prevention Plan
IPUC WMP Guidelines.
Appendix 8: Wildfire
Operation Practices during Heightened Wildfire Public Safety Power
Risk Days or Zones Shutoff Plan
■ May include restrictions to workforce Appendix F: Wildfire
practices, potential use of proactive de- Mitigation Activities &
energization. Cost Forecast 2026-
■ Consistent with 61-1803(3)(g)(ii) and the 2030
IPUC WMP Guidelines.
Community Education
■ May include public service announcements
to create awareness and provide education
of wildfire risks, providing preventative
measures, etc.
■ Consistent with 61-1803(3)(c) and 61-
1803(3)(d).
A WMP's preventative actions and programs
may include, but is not limited to, the following:
System Hardening Strategies
■ May include pole replacements, line
rebuilding, or undergrounding if necessary,
strategic fuse or reclosers installations, etc.
Workforce Preparedness
■ May include workforce training, equipment
provided to employees to reduce the risk of
wildfire, etc.
Pilot Programs
■ If applicable
18. Idaho Power carries out numerous preventative actions and programs to
reduce the risk of wildfire in compliance with the requirements of the WSCA as well as
the IPUC WMP Guidelines. The Company notes that, relative to preventative actions and
programs required by Idaho Code § 61-1803(3)(b), the IPUC WMP Guidelines address a
number of different mitigation efforts that are also separately identified in other
subsections of the WSCA. For ease of review and in order to avoid duplication, in those
APPLICATION - 12

instances where the IPUC WMP Guidelines identify a preventive action/program that is
also encompassed by another subsection of Idaho Code § 61-1803(3), the Company
discusses its compliance with both provisions in the discussion of the corresponding
statutory requirement as noted below.
19. Situational Awareness efforts. See discussion of Idaho Code § 61-
1803(3)(f).
20. Asset Inspections. See discussion of Idaho Code § 61-1803(3)(g)(i).
21. Enhanced vegetation management practices in risk zones. See discussion
of Idaho Code § 61-1803(3)(g)(iii).
22. Operation practices during heightened wildfire risk days or zones. See
discussion of Idaho Code § 61-1803(3)(g)(ii).
23. Community education. See discussion of Idaho Code § 61-1803(3)(c)-(d).
24. System hardening strategies. See discussion of Idaho Code § 61-
1803(3)(e).
25. Workforce Preparedness. Idaho Power's wildfire mitigation strategy
includes procedural personnel measures to reduce potential ignition risk and the spread
of wildfires. Idaho Power developed a Wildland Fire Preparedness and Prevention Plan
(the "Plan"), included as an appendix to the Company's 2026 Wildfire Plan, to provide
guidance to Idaho Power employees to help prevent the accidental ignition and spread of
wildland fires associated with employee work activities in locations under conditions
where there is a heightened risk of wildfire. The Plan includes information on fire season
tools and equipment required on the job site, daily situational awareness regarding
locations where wildfire risk is heightened, expected actions and mechanisms for
APPLICATION - 13

reducing on-the-job wildfire risk, as well as reporting requirements in the event of fire
ignition and training requirements. Applicable Idaho Power employees are expected to
be aware of the provisions of the Plan and operate in accordance with the Plan.
26. Pilot Programs. Idaho Power uses pilot projects to learn about and assess
the risk reduction benefits of newer mitigation approaches and/or technologies. Pilot
projects may be considered as a complement to or alternative for existing risk mitigation
approaches. These projects support learning with respect to cost, labor, and time
requirements and inform risk-based decisions when comparing, selecting, and prioritizing
mitigation strategies for the future. Currently, the following projects are in a pilot status:
• Standby helicopter services for pre- and post-event inspections
• Fuels reduction shared stewardship
• Line monitoring technology
• Covered conductor
• 3-D Pole Loading
• High impedance relay protections
• FAA waivers and aerial drone inspections
(4) WMP Element— Public Outreach and Engagement
Idaho Code§ 61- IPUC WMP Guidelines Corresponding Location
1803(3)(c) (Order No. 36774) in WMP
Community outreach and This section should include discussion of Section 11. Public Outreach
public awareness efforts how each utility maintains community and Engagement
that the electric outreach and public awareness before, Appendix 8: Wildfire Public
corporation will use before, during, and after wildfire season to support SafetyPower Shutoff Plan
during, and after wildfire customer awareness and education of
season to identify and wildfire risks and notify the public of wildfire-
inform the public of related outages. This discussion should
relevant wildfire risks and include, but is not limited, to the following:
notify the public of wildfire- Description of customer communication
related outages. efforts related to wildfire mitigation,
including efforts to increase awareness
and education of the utility's plan,
APPLICATION - 14

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 is 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.
27. Communication is an important part of Idaho Power's wildfire mitigation
efforts. Idaho Power engages in community outreach and public awareness efforts
before, during, and after wildfire season to inform the public of wildfire risks and to notify
the public of wildfire-related outages. The Company's wildfire-related communications are
guided by the following objectives: educating customers about how to prepare for wildfire-
related outages, including where to find outage and Public Safety Power Shutoff("PSPS")
information, and how to update contact information to enhance communication regarding
any potential outage events; raising awareness about Idaho Power's wildfire mitigation
work; and explaining how customers can reduce wildfire risk.
28. Each year, Idaho Power organizes education campaigns focused on wildfire
risk and outage preparedness. These campaigns promote the Company's wildfire
mitigation activities and customer outage communication, provide awareness and
APPLICATION - 15

education on preparing for wildfire season, and publicize ways customers can prevent
wildfires.
29. Idaho Power communicates with customers and the public through a variety
of channels to help maximize reach and effectiveness including, but not limited to, social
media, news media, customer newsletters, printed materials including flyers and bill
inserts, phone calls, text, and email. The Company also hosts public meetings and open
houses focused on outage preparedness, safety, and wildfire prevention, including PSPS.
These efforts are complemented by participation in coordinated preparedness events led
by community-based organizations.
(5) WMP Element — Government Outreach
Idaho Code§ 61-1803(3)(d) IPUC WMP Guidelines Corresponding Location
(Order No. 36774) in WMP
Outreach efforts to coordinate The electric corporation must describe how Section 4.6 Wildfire
with federal, state, tribal, and it engages with and coordinates with Detection Cameras
local officials and agencies on federal, state, tribal, and local officials and Section 10.2.2 Fuels
wildfire preparedness and agencies on wildfire preparedness and Reduction Shared
emergency response plans. emergency response in the plan year. This Stewardship (Pilot)
discussion may include, but is not limited
to: Section 11. Public
■ If applicable, PSPS tabletop exercises Outreach and
with interested parties and agencies. Engagement
■ Communication with the agencies and Section 12. Government,
the ESF-12 coordinator within the Industry and Peer Utility
PUC. Engagement
■ If applicable, mitigation efforts with the
agencies.
The WMP must detail all relationships
(such as Bureau of Land Management
[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.
30. Idaho Power recognizes the importance of engaging with various levels of
government — federal, tribal, state, and local — as an integral part of wildfire
preparedness and emergency response plans. Prior to the start of wildfire season, Idaho
APPLICATION - 16

Power offers to meet with state and federal land-management agencies in Idaho to review
the Company's approach for wildfire mitigation and discuss wildfire season operations.
Additionally, throughout the year Idaho Power engages with federal, tribal, state, and local
agencies to share information, receive feedback on mitigation approaches (including
vegetation management practices), and to identify and work toward activities that are
mutually beneficial and may be considered in subsequent WMPs.
(6) WMP Element— Method of Line Design
Idaho Code§ 61- IPUC WMP Guidelines Corresponding Location
1803(3)(e) (Order No. 36774) in WMP
Financially prudent and The electric corporation must describe Section 3. Cost-Benefit
reasonably practicable how its methods of line design for new Approach
methods of line design for lines and planned upgrades reduce Section 6. Mitigation Activity:
new, planned, and existing wildfire ignition potential in heightened Line Operation Practices
lines to mitigate fire risk. wildfire risk areas. This must include
evaluation of costs to wildfire risk Section 8. Methods of Line
reductions. Additionally, this must include Design
how the electric corporation clearly Section 10. Additional
identifies, selects, and evaluates projects Preventative Actions and
that reflect a balance of mitigation costs Programs
with resulting reduction in wildfire risk for Section 14. WMP Cost
the following, but is not limited to: Summary
■ Line rebuilding within the WMP.
■ Undergrounding lines within the Appendix F. Wildfire
WMP. Mitigation Activities & Cost
■ Installation of covered conductor. Forecast 2026-2030
■ Installation of non-wooden cross
arms.
■ If any, describe any flexible
infrastructure such as automatic
reclosers and remote-controlled
devices that support remote
operations.
31. The Company's wildfire mitigation strategy includes financially prudent and
reasonably practicable methods of line design for new, planned, and existing lines to
mitigate fire risk. As explained above, in considering mitigation measures, including line
design methods, to reduce wildfire risk, Idaho Power uses a cost-benefit approach and
APPLICATION - 17

applies various strategies to achieve risk reduction that reasonably balances mitigation
costs against mitigation effectiveness.
32. In the context of line design methods, Idaho Power's wildfire mitigation
efforts include design and system hardening activities such as line rebuilding, installation
of covered conductor, strategic undergrounding of powerlines, and systematic
replacement of hardware, equipment, and materials that provide for additional wildfire
protection, as well as use of automatic reclosers and remote-controlled devices that
support remote operations. As discussed more fully in Section 3 of the WMP, many of
these activities may also provide co-benefits including improved safety, reliability, and
resiliency of the system.
33. In assessing construction (rebuild, hardening and/or upgrade) work for its
transmission and distribution lines, Idaho Power applies a systematic, risk-based
approach in which Idaho Power designers evaluate each project to determine if it strikes
the necessary balance of mitigation costs with the resulting reduction of wildfire risk
required by the WSCA.
34. The Company's WMP includes a detailed description of how its design
methods for new lines and planned upgrades reduce wildfire ignition potential in
heightened wildfire risk areas, including an evaluation of costs, and explains the process
and strategies used by the Company to identify, select, and evaluate projects that reflect
a balance of mitigation costs with resulting reduction in wildfire risk. By way of example,
the Company may use strategic undergrounding as an alternative to conducting overhead
circuit hardening upgrades as a mitigation approach in select areas where risks justify the
costs. While underground conversion of overhead distribution lines can provide benefits,
APPLICATION - 18

including reduced wildfire ignition risk, improved reliability, and lower long-term vegetation
maintenance needs, underground conversion projects require extensive planning and
coordination and often have higher up-front costs than overhead hardening work. In
general, overhead hardening efforts provide the benefit of being able to impact a greater
number of circuit miles and customers in a shorter time horizon with less up-front
investment than undergrounding. However, there may be certain risk, reliability, ongoing
cost savings, and other benefits of underground infrastructure relative to overhead. Idaho
Power deliberately assesses overhead-to-underground powerline conversion projects in
accordance with the criteria delineated in Section 8.4.2 of the 2026 WMP to ensure the
chosen mitigation approach reflects a balance of mitigation costs with resulting reduction
in wildfire risk.
(7) WMP Element — Situational Awareness and Monitoring
Idaho Code§ 61- IPUC WMP Guidelines Corresponding Location
1803(3)(0 (Order No. 36774) in WMP
Monitoring of forecasted This section should include a description Section 2. Geographical
and current weather data of how the electric corporation monitors Risk Assessment
for the purpose of forecasted and current weather conditions Section 4. Situational
assessing and responding for the purpose of assessing and Awareness and Monitoring
to current and anticipated responding to current and anticipated
fire risk. wildfire risk. This description must include, Section 5. Mitigation
but is not limited to, the following: Activity: Workforce
■ Identification of systems, tools, or Preparedness
external resources used to monitor Section 6. Mitigation
weather, fire potential, or other Activity: Line Operation
situational awareness indicators. Practices
■ If applicable, a description of how the Section 10. Additional
utility utilizes weather forecasting, fire Preventative Actions and
potential modeling, or similar tools, to Programs
inform mitigation activities and
operational decisions. Appendix A: Wildland Fire
■ Discussion of how situational Preparedness and
awareness capabilities are integrated Prevention Plan
into daily or seasonal wildfire Appendix B: Wildfire
operations. Public Safety Power
■ Discussion of how the electric utility Shutoff Plan
becomes aware of another electric
corporation's de-energization (e.g.,
Bonneville Power Administration) and
how that is integrated into operations.
APPLICATION - 19

35. Visibility and readily available access to current and forecasted
meteorological conditions, fuel conditions, and information about fire behavior is an
aspect of Idaho Power's wildfire mitigation strategy. Idaho Power uses several tools,
including fire weather stations, wildfire detection cameras, and a Fire Potential Index
("FPI") - an internally developed tool that converts environmental, statistical, and scientific
data into a numeric forecast of the short-term fire potential. These tools support the
Company's daily operational decision making and response to active wildfires.
36. Idaho Power created its FPI tool to support operational decision-making to
reduce wildfire threats and risks. The tool takes data on weather, prevalence of fuel (i.e.,
trees, shrubs, grasses), and topography, and converts that data into a numeric forecast
of the short-term fire threat for each of Idaho Power's wildfire risk zones. The FPI
produces a score of 0 to 16, with scores of 0 to 11 falling in the Green category, indicating
lower potential for a fire greater than or equal to 1,000 acres to develop and spread, based
on various components (a "Large Fire"). Scores of 12 to 14 fall in the Yellow category,
indicating elevated potential for a Large Fire, and scores of 15 to 16 fall in the Red
category, indicating a higher potential for a Large Fire. During wildfire season, the FPI is
calculated and issued each weekday for a seven-day forecast period to help Idaho Power
personnel take steps in advanced planning and preparation.
37. To further enhance Idaho Power's situational awareness, the Company has
partnered with the National Center for Atmospheric Research to develop a system that
uses multiple weather models to enhance forecast accuracy, allowing forecasters to
calculate probabilities of the timing, location, and intensity of various weather events and
APPLICATION - 20

helping them communicate potential outcomes more effectively. Idaho Power's
Atmospheric Science group also uses high-resolution modeling and forecasting
capabilities, combined with existing fire weather stations and publicly available weather
and fuel data, to develop and circulate FPI forecasts. In 2026, Idaho Power plans to install
approximately 55 fire weather stations on existing powerline poles in locations proximal
to wildfire risk zones to reflect real-time wind conditions at powerline height. Finally, Idaho
Power contracts with ALERTWest who installs AI-enabled wildfire detection camera sites.
This network of cameras, owned by various members of the Idaho Fire Camera
Interoperability Committee, and the associated software solution is used by first
responders, emergency management personnel, and Idaho Power to detect wildfire, track
real-time weather and fuel conditions, and allow first responders and Idaho Power to
better allocate the appropriate resources in the event of a fire. To date, the Company has
installed six wildfire detection cameras in Idaho through ALERTWest in areas where they
provide visibility to overhead assets or surrounding terrain in certain wildfire risk zones.
38. Beginning in late 2024, Idaho Power began integrating Technosylva's
Wildfire Risk Analyst Enterprise ("WFA-E") software into its approach for wildfire risk
identification and quantification. WFA-E is a cloud-based SaaS platform that provides
wildfire spread prediction capabilities to support operational response, what-if scenario
analysis, and wildfire risk forecasting. WFA-E is comprised of a daily operational risk
package consisting of various on-demand capabilities which, once implemented, the
Company intends to use in conjunction with its FPI tool to support operational decisions
that reduce wildfire threats and risks.
APPLICATION - 21

(8) WMP Element — Infrastructure Inspection and Asset Management
Idaho Code§ 61- IPUC WMP Guidelines Corresponding Location
1803(3)(g)(i) (Order No. 36774) in WMP
Developing standards, This section should provide a summary of Section 7. Infrastructure
procedures, and schedules, an electric corporation's programs for the Inspection and Asset
subject to timely approval of inspection of electric infrastructure, Management
access to rights-of-way, if assets, and facilities within areas Section 9. Vegetation
necessary, for the following identified as heightened wildfire risk areas Management
actions: to identify and correct conditions that
could contribute to wildfire ignition. This Section 10. Additional
(i) Inspection of the electric summary must include, but is not limited Preventative Actions and
corporation's assets, to, the following: Programs
infrastructure, and 0 Description of inspection standards Appendix F: Wildfire
facilities within the areas for each type of infrastructure, assets, Mitigation Activities & Cost
that are identified as and facilities. Forecast-2026-2030
heightened fire risk 0 Description of schedules for
areas in the wildfire inspections for each type of
mitigation plan, where infrastructure, asset, and facility.
financially prudent and 0 Description of baseline routine
reasonably practicable. 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.)
39. The Company's wildfire mitigation strategy relies in part on its various asset
management programs, including inspections and maintenance activities. To reduce
wildfire risk and continue to safely operate the grid, Idaho Power evaluates and
implements a robust set of asset inspection initiatives, as shown below in Table 1, with
annual targets contained within the 2026 WMP's Appendix F. As part of these efforts,
Idaho Power continually evaluates industry advancements and strives to incorporate new
technologies in its inspection processes.
APPLICATION - 22

Table 1
Overview of transmission and distribution inspection programs
Transmission
Transmission Asset Inspection Programs Description
Aerial Visual Inspection Program Except where prohibited by government agencies,perform annual patrols
on lines that are under the jurisdiction of the Western Electricity
Coordinating Council(WECC)and non-WECC transmission lines located in
Tier 3 wildfire risk zones using helicopters or drones and document
identified defects according to priority.Complete repairs according to
priority definition.
Ground Visual Inspection Program Perform annual patrols and document identified defects according to
priority.Complete repairs according to priority definition.
Detailed Visual(High Resolution Perform 10-year cycle patrols and document identified defects according to
Photography)Inspection Program priority.Complete repairs according to priority definition.
Wood Pole Inspection and Treatment Perform 10-year cycle inspection and treatment and document identified
Program rejects according to priority.Complete replacement according to priority
definition.
Cathodic Protection and Inspection Perform periodic structure-to-soil potential testing on select towers with
Program direct-buried anodes at intervals determined by Idaho Power.Perform
annual rectifier and ground-bed testing on impressed current corrosion
protection(ICCP)systems;including measurement and recording of the
results.Complete repairs and adjustments as determined by Idaho Power.
Wood Pole Wildfire Protection Program Install fire mesh wraps on selected poles.
Distribution
Distribution Asset Management Description
Programs
Wood Pole Inspection and Treatment Perform 10-year cycle inspection and treatment and document identified
Program rejects according to priority.Complete replacement according to priority
definition.
Line Equipment Inspection Program Complete annual inspections and mitigate defects.
Ground Detailed Inspection Program Perform 3-year cycle patrols and document identified defects according to
priority.Complete repairs according to priority definition. In Tier 3 and
select Tier 2 Risk Zones,patrols are performed annually.
Thermography(Infrared)Inspections Complete inspections of targeted lines and equipment using thermal
imaging(infrared)cameras.
(9) WMP Element - Line Operation Practices
Idaho Code§ 61- IPUC WMP Guidelines Corresponding Location
1803(3)(9)(ii) (Order No. 36774) in WMP
Developing standards, If an electric utility plans to use de- Section 6. Mitigation
procedures, and schedules, energization as part of its wildfire Activity: Line Operation
subject to timely approval of mitigation efforts, this section must Practices.
access to rights-of-way, if address the standards, criteria, and Section 14. WMP Cost
necessary, for the following operational protocols for Summary
actions: de-energization for encroachment of a
wildfire, proactive de-energization Appendix 8: Wildfire Public
(ii) De-energization of the (PSPS) to reduce fire risk, and de- Safety Power Shutoff Plan
electric corporation's energization from third-party energy
power lines, if providers. This discussion must
APPLICATION - 23

considered appropriate include, but is not limited to the
by the electric following:
corporation. ■ 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.
40. To reduce wildfire risk in a way that balances mitigation costs, Idaho Power
implements line operational practices during heightened wildfire risk days and/or in areas
with potential heightened wildfire risk. Wildfire mitigation operational practices fall in the
following categories: temporary operating procedures for distribution lines in wildfire risk
zones during wildfire season; temporary operating procedures for transmission lines
during wildfire season; Idaho Power's emergency de-energization operational strategy for
transmission and distribution lines related to wildfire during the wildfire season; and a
PSPS strategy.
41. The Company's distribution operational protection strategy utilizes
Enhanced Protection Settings ("EPS"), sometimes referred to as sensitive powerline
settings, to reduce the probability of ignition during fault events on Idaho Power's
distribution system. EPS are generally enabled based on various criteria in automatic
APPLICATION - 24

reclosing protective devices where the zone of protection overlaps with, or is located
within, Tier 2 or Tier 3 wildfire risk zones. While EPS help reduce wildfire risk by operating
more sensitively to fault conditions, they also increase the likelihood of customer outages.
For this reason, Idaho Power only enables EPS when the conditions and protocols
defined within the current version of its WMP are met.
42. The Company's transmission line operational strategy varies based on the
line's voltage and location. During wildfire season, Idaho Power temporarily modifies its
operating procedures for transmission lines 115 kilovolts ("kV") and above to include
practices related to information collection, notification, and procedures for "testing"10 and
closing in on "locked out"11 transmission lines. Depending upon the transmission line's
designation and location, among other criteria that may be applicable, a patrol is typically
required prior to re-energization. Transmission lines located in Tier 3 zones and operating
at 69 kV and below are operated in normal settings mode, but no "testing" of such type of
line that may have "locked out" will occur during the time of a red FPI. Instead, the line
will either need to be patrolled before re-energizing, or the Company may choose to wait
until the FPI level drops out of the red category prior to re-energizing without a patrol.
43. As used within the Company's 2026 WMP, a PSPS is defined as the
proactive de-energization of electric transmission and/or distribution facilities during
extreme weather events to reduce wildfire risk. The decision regarding PSPS is based on
several dynamic factors, and each weather event is unique.
10 Transmission line "testing" refers to the human act of re-energizing a line without completing a physical
field patrol or observation of a line.
11 "Locked out" in this context refers to the process of the protection systems going through a series of
trip/reclose attempts before finally staying de-energized.
APPLICATION - 25

(10) WMP Element—Vegetation Management
Idaho Code§ 61- IPUC WMP Guidelines Corresponding Location
1803(3)(g)(iii) (Order No. 36774) in WMP
Developing standards, This section must provide an Section 9. Vegetation
procedures, and schedules, overview of the utility's vegetation Management
subject to timely approval of management program aimed at Section 10. Additional
access to rights-of-way, if reducing the risk of vegetation-related Preventative Actions and
necessary, for the following contact with electric infrastructure in Programs
actions: areas with heightened wildfire risk
within its rights-of-way or lands Section 12. Government,
(iii) Vegetation management adjacent thereto. Elements of this Industry and Peer Utility
within the areas that are vegetation management section Outreach
identified as heightened overview should include, but are not Section 14. WMP Cost
fire risk areas in the limited to, the following: Summary
wildfire mitigation plan 0 Identification, description, and Appendix F: Wildfire
and are within the citation of vegetation Mitigation Activities & Cost
electric corporation's management standards for Forecast-2026-2030
rights-of-way or lands elevated wildfire risk areas.
adjacent thereto and that ■ Explanation of how vegetation
threaten the power lines management standards,
or other electric procedures, and schedules are
corporation different or the same as routine
infrastructure. If live vegetation management.
marketable timber is Description of the current and
identified for removal planned vegetation management
from timber company practices used to mitigate wildfire
land adjacent to the risk, including any enhancements
rights-of-way, in designated wildfire areas.
compensation at fair The electric corporation must
market value shall be explain how the electric utility
made to the landowner considered vegetation
for such timber. 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.
44. Vegetation management remains an important mitigation strategy for Idaho
Power. Idaho Power's Vegetation Management Program ("VMP") addresses public
safety, regulatory compliance, electric reliability and helps safeguard transmission and
distribution lines from trees and other vegetation that may cause an outage or damage
facilities. Specifically, these types of lines are inspected periodically, and trees and
APPLICATION - 26

vegetation are cleared away from the line while certain trees are removed entirely. In
addition, the VMP addresses the clearing of vegetation near the base of certain poles and
line structures.
45. The Company also employs enhanced vegetation management practices
in both Tier 2 and Tier 3 wildfire risk zones. These practices include mid-cycle patrols and
pruning in the second year of the cycle to address "cycle buster"12 trees, along with annual
patrols, which may identify new hazard trees,13 "hot spots",14 or unexpected vegetative
growth that poses an imminent threat of contact with energized facilities.
46. Each year the company sets targets for vegetation management efforts in
wildfire risk zones, as presented in the 2026 WMP's Appendix F, and also strives to
complete annual, once per calendar year auditsl5 for all pruning work performed in Tier 2
and Tier 3 wildfire risk zones. These audits confirm that pruning cuts meet specification
and proper clearance was obtained.
12 "Cycle Buster" in this context refers to trees that grow at a rapid rate, requiring a more frequent
trimming schedule than the normal trim cycle.
13 "Hazard Tree" is any vegetation issue that poses a threat of causing a line outage but has either a low
or medium risk of failure in the next month. Hazard trees will be further defined as posing either a medium
hazard or low hazard. Assessing whether a tree is a hazard or high priority tree requires the exercise of
judgment. Idaho Power defines a Hazard Tree and the associated hazard level to be those designated in
the opinion of the inspector.
14 "Hot Spots"—Locations where vegetation shows evidence of contact with energized conductors or
other electric system components.
15 Within this context, the term "audit" is used in an informal context and does not mean a formal audit
conducted by the Company's Audit Services Department.
APPLICATION - 27

(11) WMP Element— Other Items from Order No. 36774
IPUC WMP Guidelines/Order No. 36774 Corresponding Location
in WMP
An update of lessons learned from the previously approved WMP Section 13. Performance
within the annual filings for WMP review and approval. Monitoring and Metrics
Section 14. WMP Cost Summary
A breakdown of each program category's forecasted costs by year Appendix D: Idaho and Montana
for both capital and operations and maintenance (O&M) Requirements and
expenditures through the length of the WMP. Recommendations Crosswalk
Appendix F: Wildfire Mitigation
A section in which Idaho Power describes how it addresses each Activities & Cost Forecast-2026-
of the Commission's orders and Staffs recommendations. 2030
Rolling WMPs shall be developed with a minimum three-year
planning horizon.
B. Compliance with Prior Commission Directives.
47. The Company filed its initial WMP with the Commission in Case No. IPC-E-
21-02 and has submitted subsequent WMPs for the Commission's visibility and review
through Case Nos. IPC-E-22-2716 and IPC-E-25-05.17 Through Commission Orders
issued in the aforementioned cases, the Commission has directed Idaho Power to
incorporate certain requirements in the development of its ongoing WMPs. The
Company's 2026 WMP fully incorporates these directives as highlighted below.
48. The Company notes, however, that these Orders were issued prior to the
enactment of the WSCA and/or the Commission establishing a filing process for WMPs
submitted under the WSCA through the issuance of Order No. 36774 in GNR-E-25-02.
As a result, some of the directives set forth in these previously issued orders are
16 In the Matter of Idaho Power Company's Application for Review of the Company's Current Wildfire
Mitigation Plan and Authorization to Defer Newly Identified Incremental Wildfire Mitigation Costs, Case
No. IPC-E-22-27, Application (Oct. 20, 2022). The Company's 2022, 2023 and 2024 Wildfire Plans were
all filed in Case No. IPC-E-22-27.
17 In the Matter of the Application of Idaho Power Company for Review of the Company's Current Wildfire
Mitigation Plan and Authorization to Defer Newly Identified Incremental Wildfire Mitigation Costs, Case
No. IPC-E-25-05, Application (Feb. 13, 2025).
APPLICATION - 28

duplicative of the requirements adopted in Order No. 36744 and others may appear to
impose different standards than the WSCA. Therefore, the Company respectfully
requests the Commission clarify as part of its order in this proceeding whether the most
recent WMP-related requirements adopted as part of Order No. 36774 supersede prior
Commission orders.
Commission Order No. 3674Z Case No. IPC-E-25-05 Corresponding Location
in WMP
List all pilot projects in the WMP, including the status of the Section 3. Cost-Benefit Approach
pilot and an explanation of the how the Company is evaluating Section 8. Methods of Line Design
least-cost, least-risk solutions.
✓ Addressed in WMP Guidelines (Order No. 36774) Section 10. Additional Preventative
Actions and Programs
Detail how the Company identifies, selects, and evaluates Appendix D: Idaho and Montana
projects as least-cost, least-risk for line rebuilding, Requirements and Recommendations
undergrounding, and covered conductor to be consistent with Crosswalk
Idaho Code§ 61-1803(3)(g), effective July 1, 2025.
✓ Addressed in WMP Guidelines (Order No. 36774)
Add a section to the WMP to explain how the Company
addressed Staffs recommendations and discuss other high-
level major changes/updates to the WMP since the last filing.
✓ Addressed in WMP Guidelines (Order No. 36774)
Commission Order No. 3604Z Case No. IPC-E-23-11
In future iterations of its WMP, IPC agrees to break down Section 13. Performance Monitoring
internal labor expenses for all WMP programs and to extend and Metrics
the WMP forecast to five years for each version. The Company Appendix F: Wildfire Mitigation
also agreed to explore methods to reduce costs with Activities & Cost Forecast-2026-2030
communication and education regarding wildfire and PSPS.
Commission Order No. 35717, Case No. IPC-E-22-27
Require the Company to detail relationships it has that may Section 4. Situational Awareness and
benefit the wildfire mitigation program, contribute to program Monitoring
costs, or provide for cost sharing opportunities. Section 10. Additional Preventative
✓ Addressed in WMP Guidelines (Order No. 36774) Actions and Programs
Require the Company to provide details of all funding alternative,, Section 12. Government, Industry and
sources pursued within the WMP. Peer Utility Outreach
Appendix D: Idaho and Montana
Requirements and Recommendations
Crosswalk
APPLICATION - 29

III. REQUIRED STAKEHOLDER COMMUNICATION
49. 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.
Additionally, to facilitate the participation of those interested parties in the review process,
the Commission adopted Staff's recommendation to include certain information in these
notices. More specifically, Staff recommended that the Commission require "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."18
50. Accordingly, and as required by Idaho Code § 61-1804(2) and pursuant to
the additional directive in Order No. 36774, Idaho Power is providing notice of its WMP
filing to the state forester, cities, counties, fire protection districts, fire protection
associations, and timber protection associations within the Company's Idaho service
area, which includes the case number for this proceeding and information about how to
participate in the Commission's proceeding; a copy of the Company's letter, including a
list of entities to which it is being provided, is attached to the Company's Notice of Wildfire
Mitigation Plan Filing filed contemporaneously herewith. Idaho Power believes this
satisfies the requirements of Idaho Code § 61-1804(2) and Order No. 36774; however,
the Company will, in the alternative, bring the WMP filing to the attention of interested
entities through any other means directed by the Commission.
'$ GNR-E-25-02, Staff Comments at 15 (Aug. 21, 2025). The Company notes that the language in Order
No. 36777 differs from the language in Staff's recommendation regarding the notice to interested parties
required under Idaho Code § 61-1804(2) and appears to contemplate an additional requirement of"notice
to the Commission of the filing of the WMP." To the extent the Commission did not intend to deviate from
Staff's recommendation, the Company respectfully requests the Commission issue an errata to Order No.
36774 aligning the ordering language related to notice under Idaho Code § 61-1804(2)with Staff's
recommendation.
APPLICATION - 30

51.
IV. MODIFIED PROCEDURE
52. Idaho Power believes that a technical hearing is not necessary to consider
the issues presented herein and respectfully requests that this Application be processed
under Modified Procedure, i.e., by written submission rather than by hearing. Procedural
Rule 201, et. seq. However, the Company stands ready to present testimony supporting
this Application in a technical hearing if the Commission determines such a hearing is
required.
V. COMMUNICATIONS AND SERVICE OF PLEADINGS
53. Communications and service of pleadings, with reference to this Application
should be sent to the following:
Megan Goicoechea Allen Tim Tatum
Lisa Lance Connie Aschenbrenner
Regulatory Dockets Riley Maloney
Idaho Power Company Idaho Power Company
1221 West Idaho Street (83702) 1221 West Idaho Street (83702)
P.O. Box 70 P.O. Box 70
Boise, Idaho 83707 Boise, Idaho 83707
mgoicoecheaallen(a-__idahopower.com ttatum idahopower.com
Ilance(a�idahopower.com caschenbrenner(a�-idahopower.com
dockets(a)_idahopower.com rmaloney(a-idahopower.com
VI. CONCLUSION
54. Wildfire risk in the West is increasing, and Idaho Power continues to take
proactive measures to adjust to that increasing risk, particularly considering the
magnitude of damages and loss of life associated with events outside of Idaho in recent
years. Taking actions to reduce the risk of wildfires is critical for Idaho Power's customers,
APPLICATION - 31

the communities in which the Company operates, and investors who provide capital to
the Company.
55. To that end, and consistent with Idaho Code § 61-1803(2)(a), the
Company's sixth WMP being submitted herein is the product of the Company having
conducted a comprehensive, rigorous assessment of wildfire risk across its service area
using approaches and methods that are designed to protect the public interest and are
reflective of and commensurate with the size and complexity of the Company's operations
and the specific fire risks present within the areas in Idaho where the Company has
infrastructure or equipment. From the 2026 Wildfire Plan, the Company has identified
several actions necessary to mitigate wildfire risk that reflect a reasonable balancing of
mitigation costs with the resulting reduction of wildfire risk. Specifically, Idaho Power
currently estimates spending $53 million during 2026 in Operations and Maintenance
("O&M") expenses in Idaho to further wildfire mitigation measures; however, this amount
will likely change in the future as the Company reviews and refines its WMP and
associated mitigation activities. In addition to 2026's estimated $53 million in O&M
expenses, Idaho Power's wildfire mitigation efforts also include capital investments in
system infrastructure, many of which may also provide co-benefits such as increased
safety, reliability and resiliency of the system.
56. Accordingly, the Company requests the Commission review and issue an
order approving its 2026 WMP, finding it complies with Order Nos. 36774, 36742, 36042,
and 35717, as well as, the requirements of the WSCA, finding it meets the minimum
requirements stated in Idaho Code § 61-1803; is consistent with public health, safety and
welfare; is feasibly implemented; and adequately minimizes wildfire risk and proposes to
APPLICATION - 32

respond to wildfires that do occur. The Company also requests the Commission clarify
within its order whether the most recent WMP-related requirements adopted as part of
Order No. 36774 supersede prior Commission orders, and whether the Company can file
its updated WMP for the Commission's annual review on or about October 1st of each
year going forward.
Respectfully submitted this 10th day of October, 2025.
MEGAN GOICOECHEA ALLEN
Attorney for Idaho Power Company
APPLICATION - 33

BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC-E-25-32
IDAHO POWER COMPANY
ATTACHMENT NO. 1

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IDAHO & MONTANA
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02025Idaho Power

N IDAHD POWER,
Idaho and Montana Wildfire
Mitigation Plan 2026
Updated October 10, 2025
©2025 Idaho Power

Idaho Power Company Wildfire Mitigation Plan 2026
Table of Contents
1. Introduction .............................................................................................................................. 1
1.1. Overview.......................................................................................................................... 1
1.2. Background ...................................................................................................................... 1
1.3. Idaho Power Profile and Service Area ............................................................................. 1
1.4. Asset Overview................................................................................................................. 3
1.5. Legal and Regulatory Context.......................................................................................... 5
1.6. Summary of Idaho Power's Plan for Mitigating Wildfire Risk.......................................... 5
2. Geographical Risk Assessment.................................................................................................. 7
2.1. Objective.......................................................................................................................... 7
2.2. Identifying Areas of Heightened Wildfire Risk................................................................. 7
2.2.1. Wildfire Risk Modeling Process .............................................................................. 8
2.2.2. Wildfire Risk Zone Establishment Process.............................................................. 9
2.3. Wildfire Risk Zones......................................................................................................... 11
3. Cost-Benefit Approach............................................................................................................ 15
3.1. Objective........................................................................................................................ 15
3.2. Risk-Based Cost and Benefit Analysis of Wildfire Mitigation......................................... 15
3.3. Risk Analysis and Drivers................................................................................................ 16
3.4. Mitigation Selection....................................................................................................... 18
4. Situational Awareness and Monitoring.................................................................................. 21
4.1. Overview........................................................................................................................ 21
4.2. Fire Potential Index........................................................................................................ 21
4.2.1. FPI Components.................................................................................................... 21
4.3. FPI Review and Evaluation............................................................................................. 23
4.4. Forecast Ensemble......................................................................................................... 23
4.5. Fire Weather Stations .................................................................................................... 24
Page i

Idaho Power Company Wildfire Mitigation Plan 2026
4.6. Wildfire Detection Cameras........................................................................................... 24
4.7. Fire Spread Predictive Tools........................................................................................... 26
5. Mitigation Activity: Workforce Preparedness ........................................................................ 27
5.1. Overview........................................................................................................................ 27
5.2. Wildland Fire Preparedness and Prevention Plan ......................................................... 27
6. Mitigation Activity: Line Operation Practices......................................................................... 29
6.1. Overview........................................................................................................................ 29
6.2. Distribution Operational Protection Strategy................................................................ 29
6.3. Transmission Line Operational Strategy........................................................................ 30
6.3.1. Wildfire Season Temporary Operating Procedure for Transmission Lines
115 kilovolt (kV) and Above.................................................................................. 30
6.3.2. Tier 3 Zone Transmission Operational Strategy 69 kV & Below........................... 31
6.3.3. Transmission Lines Where Idaho Power Is Not the Operator.............................. 31
6.3.4. De-energization by Other Electric Corporations................................................... 31
6.4. Emergency De-energization When Wildfire is Approaching......................................... 31
6.5. Restoration of Electrical Service After a Wildfire De-Energization................................ 32
6.6. Mutual Assistance.......................................................................................................... 32
6.7. PSPS ............................................................................................................................... 33
6.7.1. PSPS Plan............................................................................................................... 33
6.8. Community Resource Centers ....................................................................................... 33
7. Infrastructure Inspection and Asset Management................................................................. 35
7.1. Overview........................................................................................................................ 35
7.2. 2026 T&D Asset Inspection Targets............................................................................... 36
7.3. T&D Inspection Overview and Correction Timeframes................................................. 36
7.4. Wood Pole Inspection and Treatment Program............................................................ 37
7.5. Transmission Inspection and Asset Management Programs......................................... 38
7.5.1. Transmission Aerial Visual Inspection Program.................................................... 38
7.5.2. Transmission Ground Visual Inspection Program................................................. 38
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Idaho Power Company Wildfire Mitigation Plan 2026
7.5.3. Transmission Detailed Visual (High-Resolution Photography)
Inspection Program............................................................................................... 38
7.5.4. Transmission Thermal Imaging (Infrared) Inspections......................................... 39
7.5.5. Transmission Cathodic Protection and Inspection Program ................................ 39
7.5.6. Transmission Wood Pole Mesh Wrap................................................................... 39
7.6. Distribution Inspection and Asset Management Programs........................................... 39
7.6.1. Visual Inspection................................................................................................... 39
7.6.2. Line Equipment Inspection Program .................................................................... 40
7.6.3. Thermal Imaging (Infrared) Inspections ............................................................... 40
7.6.4. Wood Pole Inspection and Treatment Program................................................... 40
7.6.5. Pole Attachments.................................................................................................. 40
8. Methods of Line Design .......................................................................................................... 41
8.1. Overview........................................................................................................................ 41
8.2. Siting and Design of New Transmission Lines................................................................ 41
8.2.1. Transmission Steel Poles....................................................................................... 41
8.3. Transmission Line Rebuild Projects................................................................................ 41
8.4. Distribution Hardening................................................................................................... 42
8.4.1. Overhead Primary Hardening Program ................................................................ 42
8.4.2. Overhead to Underground Conversion ................................................................ 44
8.4.3. New Underground Construction........................................................................... 45
8.4.4. Feeder Segmentation............................................................................................ 45
9. Vegetation Management........................................................................................................ 47
9.1. Overview........................................................................................................................ 47
9.2. Program Components.................................................................................................... 47
9.2.1. Summary of Vegetation Management Activities and Schedules ......................... 48
9.2.2. 2026 Vegetation Management Targets................................................................ 49
9.2.3. Fair Market Value of Timber................................................................................. 49
9.3. Transmission Vegetation Inspection and Management................................................ 50
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Idaho Power Company Wildfire Mitigation Plan 2026
9.3.1. Transmission Vegetation Inspections................................................................... 50
9.3.2. Transmission Line Clearing Cycles ........................................................................ 50
9.3.3. Transmission Line Clearing Quality Control and Assurance ................................. 50
9.4. Distribution Vegetation Inspection and Management.................................................. 51
9.4.1. Distribution Line Clearing Cycles .......................................................................... 51
9.4.2. Distribution Vegetation Inspections..................................................................... 51
9.4.3. Distribution Line Clearing Procedures.................................................................. 51
9.4.4. Distribution Line Clearing Quality Control and Assurance ................................... 52
9.5. Pole Clearing of Vegetation ........................................................................................... 52
10. Additional Preventative Actions and Programs...................................................................... 53
10.1. Wildfire Suppression and Response .............................................................................. 53
10.2. Pilot Projects .................................................................................................................. 53
10.2.1. Standby Helicopter Services: Pre- and Post-Event Inspections (Pilot) ................. 53
10.2.2. Fuels Reduction Shared Stewardship (Pilot)......................................................... 54
10.2.3. Line Monitoring Technology (Pilot) ...................................................................... 54
10.2.4. Covered Conductor (Pilot) .................................................................................... 55
10.2.5. 3-D Pole Loading (Pilot)......................................................................................... 55
10.2.6. High Impedance Relay Protections (Pilot) ............................................................ 55
10.2.7. FAA Waivers and Aerial Drone Inspections (Pilot)................................................ 56
11. Public Outreach and Engagement .......................................................................................... 57
11.1. Objective ........................................................................................................................ 57
11.2. Community Engagement ............................................................................................... 57
11.2.1. Public Safety Partners........................................................................................... 57
11.2.2. Critical Facilities .................................................................................................... 57
11.2.3. Customers............................................................................................................. 58
11.2.4. Lessons Learned from 2025 Community Engagement Efforts ............................. 58
11.3. Event-Specific Communication ...................................................................................... 60
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Idaho Power Company Wildfire Mitigation Plan 2026
11.4. Key Communication Methods ....................................................................................... 60
11.5.Timing of Outreach ........................................................................................................ 60
11.6. Idaho Power Internal Communications — Employees.................................................. 61
12. Government, Industry, and Peer Utility Outreach ................................................................. 63
12.1. Objective........................................................................................................................ 63
12.2. Government Engagement.............................................................................................. 63
12.3. Peer Utility Engagement................................................................................................ 63
13. Performance Monitoring........................................................................................................ 65
13.1. WMP Compliance........................................................................................................... 65
13.2.Annual Review and Compliance Reporting.................................................................... 65
13.3. 2025 Lessons Learned.................................................................................................... 65
13.3.1. Community Outreach and Engagement............................................................... 65
13.3.2. Fire Weather Station Network.............................................................................. 65
13.3.3. Aerial Inspections.................................................................................................. 66
13.3.4. PSPS Event Management Tools and Processes .................................................... 66
14. WMP Cost Summary............................................................................................................... 67
List of Tables
Table 1
Overhead transmission and distribution line mileage and substations by state* ...................... 4
Table 2
Idaho Power's overhead transmission and distribution lines by risk zone in Idaho and
Montana..................................................................................................................................... 11
Table 3
Safety, reliability, and resilience co-benefits of wildfire mitigation initiatives ......................... 20
Table 4
Overview of T&D inspection programs...................................................................................... 35
Table 5
2026 asset inspection targets.................................................................................................... 36
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Idaho Power Company Wildfire Mitigation Plan 2026
Table 6
Summary of asset inspections and schedules ........................................................................... 37
Table 7
Distribution asset management targets.................................................................................... 42
Table 8
Idaho Power overhead distribution primary hardening program methods.............................. 43
Table 9
Vegetation Management Program initiatives............................................................................ 48
Table 10
Idaho and Montana vegetation management inspection schedule*........................................ 48
Table 11
2026 vegetation management targets* .................................................................................... 49
Table 12
Idaho Power community engagement, 2025 ............................................................................ 58
Table 13
Estimated O&M expenses for wildfire mitigation, $000s (2026)* ............................................ 67
Table 14
2026 WMP forecasted capital investments, $000s ($)*............................................................ 68
List of Figures
Figure 1
Idaho Power service area............................................................................................................. 2
Figure 2
Wildfire risk-based methodology................................................................................................. 8
Figure 3
Risk zone evaluation and determination process...................................................................... 10
Figure 4
Idaho Power wildfire risk zones within Idaho............................................................................ 13
Figure 5
Idaho Power WMP risk management framework..................................................................... 16
Figure 6
Riskbow-tie diagram ................................................................................................................. 17
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Idaho Power Company Wildfire Mitigation Plan 2026
Figure 7
FPIcategories............................................................................................................................. 22
Figure 8
Green-Up component of FPI...................................................................................................... 22
Figure 9
FuelsComponent of FPI............................................................................................................. 23
Figure 10
WeatherComponent of FPI ....................................................................................................... 23
Figure 11
Idaho wildfire detection camera interoperability map ............................................................. 25
Figure 12
Wildland fire personnel clear vegetation and wrap poles during the Rock Fire in
Idaho, 2025. ............................................................................................................................... 53
Figure 13
Salmon transmission line corridor pre-treatment (2025) ......................................................... 54
Figure 14
Salmon transmission line corridor post treatment (2025). ....................................................... 54
Figure 15
Public open house meetings throughout Idaho Power's service area...................................... 60
List of Appendices
Appendix A
Wildland Fire Preparedness and Prevention Plan
Appendix B
Public Safety Power Shutoff(PSPS) Plan
Appendix C
Wildfire Risk Zone Map Book
Appendix D
Idaho and Montana Requirements and Recommendations Crosswalk
Appendix E
Idaho Power Transmission Line Map Book
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Idaho Power Company Wildfire Mitigation Plan 2026
Appendix F
Wildfire Mitigation Activities and Cost Forecast 2026-2030
Page viii

Introduction

Idaho Power Company Wildfire Mitigation Plan 2026
1. Introduction
1.1. Overview
Idaho Power is focused on the safety of its customers and communities and to safely delivering reliable,
affordable energy.The purpose of Idaho Power's Wildfire Mitigation Plan (WMP) is to guide mitigation
strategies and reduce risk.The company's WMP identifies methods and means for mitigating wildfire risk
that reflect a reasonable balancing of mitigation costs with the resulting reduction of wildfire risk.
1.2. Background
In recent years,the western United States has experienced an increase in the frequency and intensity of
wildland fires(wildfires).A variety of factors have contributed to this trend, including changing climatic
conditions, increased human encroachment in wildland areas, historical land management practices, and
changes in wildland and forest health. Idaho has not experienced fires to the same magnitude as some
other western states,1 but warmer temperatures, reduced snowpack, and earlier snowmelt contribute
to drier conditions, extending the period of heightened fire risk.2
Idaho's wildfire season is defined by Idaho Code § 38-115 as extending from May 10 through October 20
each year, or as otherwise extended by the Director of the Idaho Department of Lands (IDL). For
example, in 2024,the director extended wildfire season to November 1, 2024.3
Montana's wildfire season is defined by Montana Code § 76-13-102 as the period of each year beginning
May 1 and ending September 30. Similarly, Montana's wildfire season can be extended by the Montana
Department of Natural Resource pursuant to Montana Code §76-13-203.
1.3. Idaho Power Profile and Service Area
Idaho Power, headquartered in Boise, Idaho, is an investor-owned utility engaged in the generation,
transmission, and distribution of electricity. Idaho Power is regulated by the Federal Energy Regulatory
Commission (FERC) and the state public utility commissions of Idaho and Oregon. Idaho Power's service
area includes 24,000 square miles across southern Idaho and eastern Oregon, with approximately 19,255
square miles of that service area in Idaho (Figure 1).The company serves more than 650,000 customers,
approximately 630,000 of which reside in Idaho.
1 Wildland Fire Summaries 2019-2024.Statistics I National Interagency Fire Center(nifc.gov)July 29,2025
2 Western Fire Chiefs Association. Idaho Fire Season:In-Depth Guide I WFCA Accessed October 8, 2024
3 Idaho Department of Lands Rescinds Extended Closed Fire Season Order-Department of Lands
Page 1

Idaho Power Company Wildfire Mitigation Plan 2026
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Figure 1
Idaho Power service area

Idaho Power Company Wildfire Mitigation Plan 2026
1.4. Asset Overview
Idaho Power delivers electricity to customers via 317 substations, approximately 4,688 miles of overhead
transmission lines, and approximately 19,320 miles of overhead distribution lines.Approximately 79%of
Idaho Power's transmission line assets are in Idaho, with approximately 1% being in Montana.
Approximately 89%of Idaho Power's distribution line assets are in Idaho. Table 1 summarizes the
overhead powerline asset information by state. Additional detailed information on Idaho Power's assets
is included in Section 7.
Page 3

Idaho Power Company Wildfire Mitigation Plan 2026
Table 1
Overhead transmission and distribution line mileage and substations by state*
TOTAL IDAHO OREGON MONTANA NEVADA WYOMING
Asset-OH**Pole Miles
Line Miles Line Miles % Line Miles % Line Miles % Line Miles % Line Miles %
46 kV Transmission Lines 373 373 100.00% 0.00%
69 kV Transmission Lines 1,035 665 63.00% 320 32.00% 50 5.00%
115 kV Transmission Lines 3 3 100.00%
138 kV Transmission Lines 1,461 1,254 85.00% 141 10.00% 66 5.00%
161 kV Transmission Lines 84 84 100.00% 0.00%
230 kV Transmission Lines 1,154 935 81.00% 219 19.00%
345 kV Transmission Lines 475 365 77.00% 0.00% 110 23.00%
500 kV Transmission Lines 103 53 51.00% 50 49.00%
Total OH Transmission Lines 4,688 3,729 79.20% 733 16.00% 50 1.10% 66 1.40% 110 2.30%
Total OH Distribution Lines 19,320 17,221 89.20% 2,099 10.80%
Total OH Pole Miles 24,008 20,950 87.20% 2,832 11.90% 50 0.20% 66 0.30% 110 0.50%
TOTAL IDAHO OREGON MONTANA NEVADA WYOMING
Asset-Substations
Substations Substations % Substations % Substations % Substations % Substations %
Total#Substations 317 277 87.38% 37 11.67% 2 0.63% 1 0.32% 0 0
*Numbers are approximate."Total#Substations'only includes Idaho Power-owned facilities.
**OH refers to overhead lines.
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Idaho Power Company Wildfire Mitigation Plan 2026
1.5. Legal and Regulatory Context
As allowed by the Wildfire Standard of Care Act(WSCA), Idaho Code § 61-1801 et seq., Idaho Power filed
this Idaho and Montana 2026 WMP with the Idaho Public Utilities Commission (IPUC)for approval by the
Commission as to the Idaho portion of the plan. Idaho Code § 61-1803 codifies the specific elements
required to be documented within a WMP.The IPUC also issued Order No. 36774 governing the filing
requirements of a WMP in Case No. GNR-E-25-02.This WMP complies with these requirements.
Pursuant to Montana Code Section 69-2-XX2,4 effective May 13, 2025, Idaho Power also filed this WMP
with its statutory"approval authority," as the appropriate body responsible for its corporate governance.
Montana Code Section 69-2-XX2 establishes requirements for the WMP as to the Montana portion of
this plan.
Prior to the adoption of the WSCA, Idaho Power filed a WMP covering both its Idaho and Oregon 2025
operations (known as the 2025 Wildfire Mitigation Plan) with the IPUC for informational purposes on
February 13, 2025, in Case No. IPC-E-25-05. Idaho Power will submit a separate WMP filing to the Public
Utility Commission of Oregon (OPUC) December 31, 2025,that pertains to its operations in Oregon.
1.6. Summary of Idaho Power's Plan for Mitigating Wildfire Risk
Idaho Power's approach to mitigating wildfire risk is designed to protect the public interest and reflects
the size and complexity of Idaho Power's operations and the specific fire risks present within the areas in
Idaho and Montana where Idaho Power has infrastructure or equipment.The WMP is built around the
following key components,which are detailed in subsequent sections.
• Geographical Risk Assessment. Idaho Power uses a risk-informed approach that considers
wildfire probability and consequence to identify areas that may be subject to potential
heightened wildfire risk in areas where Idaho Power has infrastructure and equipment.
• Mitigation Approach.The company employs a risk-informed cost and benefit balancing
approach to select and prioritize wildfire mitigations carried out to reduce the risk of wildfire,
such as the following:
• Situational awareness capabilities;
• Workforce preparedness;
• Operational practices, including enhanced protection settings;
• Asset management and inspection programs;
• System hardening and other line design strategies;
• Vegetation management around electric infrastructure;
°Montana House Bill 490(2025),Chapter No.68.Title and codification subject to determination by the Montana Code Commissioner.
Page 5

Idaho Power Company Wildfire Mitigation Plan 2026
• Additional preventative actions and programs;
• Customer and stakeholder communication and outreach; and
• Coordination with government agencies, industry groups, and peer utilities
• Performance Monitoring. Idaho Power monitors program performance and compliance.
In this document, Idaho Power lays out its intended wildfire mitigation efforts for 2026.All plans
identified by Idaho Power are subject to change due to operational experience or factors beyond Idaho
Power's control, including emergencies, adverse weather, unplanned events, permitting or contracting
delays, supply chain issues, or acts of God.This plan covers Idaho Power's WMP efforts in both Idaho
and Montana during 2026.A new plan will be filed annually that contains requirements for the
corresponding year.
Page 6

Section
&Wam
Geographical
Risk Assessment

Idaho Power Company Wildfire Mitigation Plan 2026
2. Geographical Risk Assessment
2.1. Objective
Idaho Power's approach to mitigating wildfire risk starts by assessing wildland fire risk using qualitative
and quantitative strategies to identify geographic areas that may be subject to a heightened risk of
wildfire where Idaho Power has infrastructure and equipment.Those areas are identified as wildfire risk
zones. Mitigation actions and programs are prioritized for those areas.
2.2. Identifying Areas of Heightened Wildfire Risk
Idaho Power has worked with an external consultant that specializes in assessing and quantifying the
threat of wildfire in different geographic areas through a risk-based methodology for wildfire spread
modeling.'This approach is used by other utilities in California, Oregon, Idaho, Montana, Nevada, and
Utah to identify and quantify wildfire risk.
This wildfire risk-based methodology is consistent with conventional definitions of risk — an event's
probability is multiplied by its potential negative consequences or impacts should that event occur. For
Idaho Power's wildfire risk assessment,this formula is shown in Figure 2.
5 Lautenberger,C.W.,"Mapping areas at elevated risk of large-scale structure loss using Monte Carlo simulation and wildland fire modeling,"Fire
Safety Journal 91:768-775(2017).
Page 7

Idaho Power Company Wildfire Mitigation Plan 2026
wind'' Higher
.••. • �.
Relative Humidity
I
0 Moderate
Fuel Moisture Content Lower
(dead
or allve)
Figure 2
Wildfire risk-based methodology
Each component is defined as follows:
• Fire Probability. Fire volume (i.e., spatial integral of fire area and flame length) is used as Fire
Probability because rapidly spreading fires are more likely to escape initial containment
efforts and become extended fires relative to slowly developing fires. Data inputs used in the fire
spread model to determine the fire volume (Fire Probability) include historical weather,
topography,fuel type, and fuel moisture content.
• Consequence. Estimation of the fire's impact on acres burned and structures (i.e., homes,
businesses, other human-made structures).
• Wildfire Risk. Fire Probability multiplied by the Consequence.The highest wildfire risk areas are
those where both the Fire Probability and Consequence are elevated. Combinations of low Fire
Probability and elevated Consequence, or elevated Fire Probability and low Consequence,
typically indicate lower wildfire risk.
2.2.1. Wildfire Risk Modeling Process
The wildfire risk modeling process employed by Idaho Power incorporates the following major steps:
1. A 12-year fire weather climatology was developed using the Weather Research and
Forecasting (WRF) model to recreate historical days of fire weather significance in
geographic areas where Idaho Power has infrastructure and equipment. This analysis
generated high-resolution hourly gridded fields of relative humidity, temperature, dead
Page 8

Idaho Power Company Wildfire Mitigation Plan 2026
fuel moisture, and wind speed/direction that was used as input to a Monte Carlo-based
fire modeling analysis.
2. Estimates of seasonal variation in live fuel moisture across areas where Idaho Power has
infrastructure and equipment were developed.This was accomplished by analyzing
historical fuel measurements and/or weather station observations.This step was
necessary because live fuel moisture data is needed for fire spread modeling, but the WRF
weather model does not provide live fuel moistures.
3. The federal LANDFIRE program was used to provide high-resolution
(approximately 100 feet) fuel rasters for use in fire spread modeling.'
4. The data developed above (WRF climatology, live fuel moisture, and LANDFIRE data)
was used to drive a Monte Carlo'fire spread modeling analysis. This Monte Carlo
simulation was accomplished by randomly selecting an ignition location and a day from the
fire weather climatology developed in step 1 above. Ignition locations were limited in the
model to be within a 240-meter (m) buffer surrounding Idaho Power's overhead
transmission and distribution (T&D) lines (i.e., 120 m on either side). The model used equal
ignition probability for all overhead distribution and transmission asset types.$ Urbanized
areas having underground circuitry were not included in the model due to a low
probability of wildfire associated with underground electrical equipment. For each
combination of ignition location and time of ignition, fire progression was then modeled
for 12 hours. For each modeled fire, potential fire impacts to structures were quantified
using structural location data. This was repeated for millions of combinations of ignition
location and time of ignition.
5. The Monte Carlo results were processed, and GIS-based data depicting fine-grained
wildfire risk was developed. This risk was then illustrated using GIS-based wildfire risk
maps.
2.2.2. Wildfire Risk Zone Establishment Process
Based on the previously described modeling processes, draft risk tiers were generated using the Jenks
optimization method to bin the resulting risk model data, reflecting risk relative to the modeled areas.
Jenks optimization is a data classification method commonly used to determine best arrangement of
values into different classes while seeking to minimize each class's average deviation from the class mean
and maximizing each class's deviation from the means of the other groups.The draft tiers were then
considered by Idaho Power in conjunction with qualitative factors in establishing Idaho Power's wildfire
risk zones depicted in the 2026 WMP, including but not limited to ingress/egress considerations; fire
6 Lautenberger,C.W.,"Mapping areas at elevated risk of large-scale structure loss using Monte Carlo simulation and wildland fire modeling,"Fire
Safety Journal91:768-775(2017).
'ibid.
8 All transmission and distribution lines owned and operated by Idaho Power and jointly owned assets were included in the analysis.
Furthermore,the proposed Boardman to Hemingway(B2H)500-kV line route was also included in this analysis.
Page 9

Idaho Power Company Wildfire Mitigation Plan 2026
response capabilities; federal, state, and local fire agency input on areas of concern including home
ignition zones; and customer input gained during outreach meetings on factors such as neighborhood
growth in the wildland urban interface and areas of community concern. This consideration process is
detailed in Figure 3.
ustome'r
Input
Wildfire Risk Model
4 Wildfire
Review potential
. -
model.consequences from Ground
view 0 Risk Zone
probabilistic fire Determination
spread
conditionVegetation Ingress/egress routes Localized Input aLh.-
Defensible
Situational awareness PP
capability . Federal and State
L resource agencies
• Fire professionals PpRi'sk Z
•Suppression
L-0 Response time L:
Figure 3
Risk zone evaluation and determination process
Incorporating Local Feedback into Risk Zone Establishment
At least once during each calendar year, Idaho Power attends a Local Emergency Planning Committee
(LEPC) meeting. Among other topics,this forum provides a platform to receive valuable feedback from
county-level public safety partners on wildfire mitigation efforts, including risk zones. Prior to the start of
wildfire season, Idaho Power offers to meet with state and federal land-management agencies in Idaho
to review the company's approach to wildfire mitigation and discuss wildfire season operations.These
forums provide the opportunity to discuss Idaho Power's risk modeling process and gain feedback on
localized areas relative to wildfire risk.The feedback gained from these collective efforts supports Idaho
Power's understanding of suppression capabilities, ingress/egress routes, and localized factors that may
influence fire regime,which is used as part of the qualitative assessment of risk zones.
Wildfire Risk Zone Calibration with Peer Utilities
Idaho Power engages with peer utilities and forums to benchmark and evaluate the company's WMP
preventative actions and programs, including risk modeling and wildfire risk zone development. In 2025,
Page 10

Idaho Power Company Wildfire Mitigation Plan 2026
Idaho Power participated in conversations with Rocky Mountain Power, Portland General Electric(PGE),
PacifiCorp, Bonneville Power Administration (BPA), and Avista to better understand each utility's
approach to risk assessment and WIMP development, based on their distinct service territories.
Since joining the International Wildfire Risk Management Consortium (IWRMC) in 2023, Idaho Power has
also participated in subgroups within the forum, including one focused on risk-based topics, such as risk
assessments, mapping, and modeling. Idaho Power continues to work with peer utilities to inform
collective understanding and decision making around wildfire risk modeling.
Ongoing Evaluation of Wildfire Risk
Idaho Power's approach to risk modeling includes iterative review.Annual'qualitative risk area
adjustments are used to account for unique factors that may increase or decrease risk due to changes
that have occurred over time, such as wildfire events that alter vegetation composition.
2.3. Wildfire Risk Zones
Based on the process described above, Idaho Power has identified wildfire risk zones that may be subject
to heightened wildfire risk:Tier 3 and Tier 2 zones. Relative to Tier 2 zones,Tier 3 zones are generally
assessed under the process described above as having greater possible wildfire risk.
Idaho Power's wildfire risk zones reflect risk relative to the areas modeled by Idaho Power only, and not
absolute risk.To aid in customer and public understanding, Idaho Power color-codes the tiers on maps—
yellow for Tier 2 and red for Tier 3.
The following two-tier wildfire risk map in Figure 4, is illustrative of Tier 2 and Tier 3 wildfire risk zones
located in Idaho. Idaho Power's modeling and assessment process determined no wildfire risk zones
near its infrastructure and equipment located in Montana.Table 2 depicts total line miles of overhead
transmission and distribution lines by risk zone in Idaho and Montana.
An illustrative map book of all zones located in Idaho is included in Appendix C. Appendix E illustrates the
extent of Idaho Power's transmission system, including transmission line assets in Montana.A full and
up-to-date risk zone map can be viewed in detail on Idaho Power's website, and individual addresses can
be entered on the map to determine proximity to identified risk zones."
Table 2
Idaho Power's overhead transmission and distribution lines by risk zone in Idaho and Montana
Tier 2* Tier 3*
Total line %of total
Total miles in lines in
line wildfire risk wildfire Total line %All Total line %All
Asset miles zones risk zones miles Lines miles Lines
Transmission Lines(ID) 3,729 375 10% 287 8% 88 2%
Transmission Lines(MT) 50 0 0% 0 0% 0 0%
9 All references to`annual'or'annually'in this WMP mean once per calendar year,unless stated otherwise.
o Idaho Power.Protecting the Grid-Wildfire Risk Zones,accessed August 29,2025,idahopower.com/outages-safety/wildfire-safety/protecting-
grid/.
Page 11

Idaho Power Company Wildfire Mitigation Plan 2026
Tier 2* Tier 3*
Total line %of total
Total miles in lines in
line wildfire risk wildfire Total line %All Total line %All
Asset miles zones risk zones miles Lines miles Lines
Distribution Lines(ID) 17,221 1,714 10% 992 6% 722 4%
Distribution Lines(MT)
Total Line Miles 21,000 2,089 10% 1,279 6% 810 4%
*Except when otherwise indicated,total line mile counts encompass Idaho Power-owned lines located in Idaho and Montana only.The data
reviewed by Idaho Power did not support the establishment of any risk zones in Montana in 2026.
Page 12

Idaho Power Company Wildfire Mitigation Plan 2026
N
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Figure 4
Idaho Power wildfire risk zones within Idaho
Page 13

Idaho Power Company Wildfire Mitigation Plan 2026
Page 14

Section
Cost Benef it
Approach
t4kuJ

Idaho Power Company Wildfire Mitigation Plan 2026
3. Cost-Benefit Approach
3.1. Objective
The WSCA requires that Idaho Power perform a reasonable balancing of the costs of mitigation with
reduction of wildfire risk.This section details Idaho Power's risk-based cost and benefit approach to
selecting wildfire mitigations. Idaho Power's WMP is designed to reasonably balance the costs of
mitigation activities with the resulting reduction in wildfire risk.
3.2. Risk-Based Cost and Benefit Analysis of Wildfire Mitigation
Idaho Power's cost-benefit approach to selecting wildfire mitigations starts with understanding the
potential costs of wildfires, assessing drivers of potential wildfire risk, and,finally, using a variety of
strategies to select cost-effective mitigations to reduce wildfire risk.
In assessing the potential consequence of wildfire risk, Idaho Power considered several sources of data
on the costs of major wildfires.
The recoverable damages in wildfire litigation in Idaho are identified in Idaho Code § 61-1806(2).The
recoverable damages in wildfire litigation in Montana are similar and are set out in Montana Code
Section 69-2-XX2. Wildfire costs can also include the cost of restoring Idaho Power property.
Ultimately, Idaho Power found that obtaining a precise calculation of the potential costs of future
wildfires is not possible. Quantifying the precise costs of wildfires is inherently uncertain because
outcomes vary by jurisdiction, weather,fuels,topography, location, population density, and exposure.
Litigation outcomes and community impacts can also differ widely from event to event. Additionally,
while fire suppression costs can be roughly estimated on a per-acre basis; the actual cost of fire
suppression can vary greatly depending on the same variety of factors.
Nonetheless, publicly available analyses of recent wildfires illustrate the magnitude of potential avoided
costs when prudent mitigation reduces the likelihood or consequences of catastrophic events. For
example, in Idaho, the Moose Fire in 2022—which grew to approximately 130,000 acres—cost
approximately$100 million to suppress,"as did the Pioneer Fire in 2016.12 The Charlotte Fire in
Pocatello (2012) destroyed 66 homes, burned approximately 1,038 acres, and estimates at the time
gauged damages at$12 million, though officials noted that timely response helped protect
approximately$472 million in property value.13 In eastern Washington in 2023,the Gray and Oregon
11 Idaho Rangeland Resource Commission,Steve Stueber,Careless Camper Ignites Moose Wildfire,idrange.org/range-stories/central-
idaho/human-caused-moose-fire-causes-widespread-
impacts/#:—:text=The%20Moose%2OCreek%20fire%20ended,fires%20five%20m iles%20away%2C%20downwind.
z Fire Research and Management Exchange System,frames.gov/documents/catalog/calkin et al 2016 PioneerFirelnquiry.pcif.
13 Debbie Bryce,3 Years Later—Survivors remember the devastating 2012 Charlotte Fire,Idaho State Journal,June 28,2015,
idahostatemournal.com/members/3-years-later-survivors-remember-the-devastating-2012-charlotte-fire/article 04fd7bd8-1d64-11e5-bd2f-
ab6d571a8626.html.
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Idaho Power Company Wildfire Mitigation Plan 2026
fires together destroyed over 350 homes and caused multiple fatalities.14 Costs and damages associated
with the 2020 Idaho wildfire season alone are estimated between $100 to $250 million."
In more catastrophic events outside of Idaho, the costs are exponentially higher.The recovery costs of
the Maui wildfires in 2023 are expected to exceed $12 billion,16 and in California, costs and damages
associated with the 2025 Los Angeles wildfires are estimated between $28.0 billion and $53.8 billion.17
This data supports the conclusion that the costs of Idaho Power's wildfire mitigation efforts, summarized
in Section 14 below, are reasonable investments to avoid the potential costs associated with wildfire.
3.3. Risk Analysis and Drivers
Idaho Power's next step in selecting cost-effective mitigations is to understand potential wildfire risk
drivers. Idaho Power's risk management framework is reflected in the six distinct steps summarized in
Figure 5.
improvementMonitor, review, Risk Identification
L continuous
WMP Risk Analysis
Objectives
MitigationRisk ..
Figure 5
Idaho Power WMP risk management framework
The framework provides Idaho Power with a structured approach to wildfire mitigation planning by
enabling systematic identification, assessment, and management of wildfire risk.While not all risk can be
14 ArcGIS StoryMaps,Gray and Oregon Wildfires,storymaps.arcgis.com/stories/9a77e2ece6d642lebc9c6a6O635742c8.
11 Shaun Goodwin,Wildfires and droughts:Idaho's costliest climate disasters since 2020 have cost billions, Idaho Statesman,January 14,2023,
idahostatesman.com/news/weather-news/article271122137.html.
16 Kevin Knodell,Overall costs for the Maui wildfires are expected to top$12 billion,The Star Advertiser,November 21,2024,
staradvertiser.com/2024/08/10/hawaii-news/overall-costs-for-mau i-wildfires-a re-expected-to-top-12-bill ion.
17 Matt Horton et al.,Impact of 2025 Los Angeles Wildfires and Comparative Study,Institute for Applied Economics,February 2025,LAEDC-2025-
LA-W i I dfi res-Stu dy.pdf.
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Idaho Power Company Wildfire Mitigation Plan 2026
eliminated, Idaho Power's goal with its WMP is to proactively prepare and enhance its infrastructure and
operational practices to prepare for and address wildfire risk.The company continues to work to identify,
analyze, evaluate, mitigate, and monitor risks associated with wildfire.
Using this framework, Idaho Power gathered information from internal subject matter experts regarding
potential ignition risk drivers and developed a risk bow-tie diagram, shown in Figure 6, as a visual
representation of equipment-specific wildfire ignition risks, including key drivers, scenarios, likelihood,
and potential impacts.
F_ Risk Drivers Triggering Event Risk Impacts
Contact from a foreign object r Safety
Animals
Vehicle collision
L Property Damage
Insulator
Transformer Wildfire Ignition
Conductor/Splice/Connector Financial Loss
Wood poles
specified
r-ng
ds and low humidity
Vandalism
Construction adivitieslVllork Environmental
Figure 6
Risk bow-tie diagram
The bow-tie analysis considers the risk exposure across all Idaho Power-owned and operated overhead
T&D facilities.The bow-tie is constructed using three components described below.
• The Triggering Event:The event Idaho Power aims to avoid that could impact the company's
ability to meet its objectives of providing safe, reliable, and affordable energy.
• Risk Drivers: Factors that may potentially lead to an ignition are listed on the left side of the bow
tie. Actual conditions play a key role in whether a wildfire occurs because of an ignition, and it is
important to note the risk drivers shown are only an indication that a risk event may occur.
• Contact from a foreign object-Contact with foreign objects, including vegetation, animals,
balloons, and other wind-blown objects.
• Equipment failure—The unexpected failure of line equipment due to discrete (internal) or
destructive (external) conditional changes.
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Idaho Power Company Wildfire Mitigation Plan 2026
• Environmental—Extreme weather conditions that include high wind, low humidity, and
drought, which contribute to increasing risk of wildfire.
• Other—Overhead powerlines may be at risk of vandalism or physical attack. Construction
activities, including activities performed by sub-contractors, near overhead powerlines may
be a risk driver if proper safety precautions are not taken to eliminate inadvertent
equipment contact.
• Risk Impacts: While most fires are extinguished quickly,the right side of the bow-tie describes
the range of possible outcomes associated with the risk event. Impacts vary largely based on
where and when the event occurs and actual conditions.The impacts shown are worst-case
scenarios.
Based on the results of this consultation, Idaho Power has identified the risk drivers shown in the risk
bow-tie. Of these, Idaho Power focuses its efforts on selecting cost-effective mitigations to address key
risk drivers.Additionally,the company annually assesses information gathered by the wildfire mitigation
team pertaining to risk drivers, including information from ignition tracking efforts, and evaluates
chosen mitigations.
3.4. Mitigation Selection
Idaho Power's mitigation selection is informed by its risk driver identification and its identification of
wildfire risk zones.This approach allows Idaho Power to direct its mitigations toward the geographic
areas and infrastructure that may be subject to heightened wildfire risk and to employ mitigations that
are most likely to achieve a reduction in wildfire risk. Each type of mitigation employed by Idaho Power is
designed to reduce one or more of the risk driver frequencies and/or minimize the potential impacts
or outcomes.
Idaho Power's approach to selecting mitigations for wildfire risk encompasses a variety of factors,
including geographical risk assessment; reasonable balancing of cost and efficacy; benchmarking and
discussions with peer utilities; consultation with government entities and agencies; and consideration of
potential alternatives.
To achieve risk reduction that reasonably balances mitigation costs against mitigation effectiveness,
the company typically applies one or more of the following strategies, as it deems appropriate, in
selecting mitigations to reduce wildfire risk drivers:
1. Risk-informed planning and prioritization. Mitigation is generally prioritized to circuits and
segments with the highest wildfire consequence and exposure, sequencing work where
potential safety and reliability benefits are expected to be greatest.
2. Alternatives analysis. For each mitigation, when reasonable and possible, Idaho Power
evaluates feasible alternatives, including materials, configurations, and operating
practices, and selects the mitigation that reflects a reasonable balancing of cost with
risk reduction.
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Idaho Power Company Wildfire Mitigation Plan 2026
3. Vendor and delivery evaluation. For technology enablement, the company evaluates
vendor platforms against internal/contracted builds and chooses the cost-effective
delivery path that provides required functionality and integration while minimizing
ongoing lifecycle costs.
4. Procurement discipline. Competitive sourcing, phasing, and scrutiny are used to validate
performance and cost.
5. Strategic reliance on pilot projects. Pilot projects are used to calibrate benefit relative to
cost, labor, and time. This allows Idaho Power to assess the learnings associated with each
pilot project and, when Idaho Power deems appropriate, make a case-by-case
determination as to whether to scale up that program, which will be determined in future
WMPs.
6. Performance monitoring and adaptive management. Idaho Power tracks implementation
performance outcomes, such as outage and ignition metrics, customer outage impacts,
and operational lessons learned; results inform future scope to maintain cost-effectiveness
over time.
7. Targeted deployment of operational mitigations. Operational mitigations are deployed to
reduce duration and extent of customer impacts while reducing wildfire risk.
8. Leveraging existing operations to reduce wildfire risk. Idaho Power works to build on
existing processes, systems, and personnel, when possible, to deploy wildfire mitigation
strategies, including by augmenting existing processes with new technology.
9. Leveraging partnership access and dollars to reduce wildfire risk. Idaho Power partners
with other entities on wildfire mitigation strategies such as fuels management and wildfire
detection camera deployment to achieve risk mitigation benefits at reasonable costs
for customers.
By generally using the process and strategies described above when selecting mitigation measures to
reduce wildfire risk, Idaho Power believes the mitigations identified in this 2026 WMP reflect a
reasonable balancing of mitigation costs with the resulting reduction of wildfire risk.
In this WMP, Idaho Power introduces and discusses its wildfire mitigations in detail as follows:
• Situational awareness and monitoring efforts (Section 4)
• Workforce preparedness (Section 5)
• Line operation practices (Section 6)
• Infrastructure inspection and asset management (Section 7)
• Methods of line design, including system hardening strategies (Section 8)
• Vegetation management efforts (Section 9)
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Idaho Power Company Wildfire Mitigation Plan 2026
• Additional preventative actions and programs (Section 10)
• Public outreach and engagement (Section 11)
• Government, industry, and peer utility outreach (Section 12)
• Performance monitoring (Section 13)
Notably,while mitigations are primarily intended to reduce the risk of wildfire, co-benefits, such as
increased safety, reliability, and resiliency of the system may also be achieved (Table 3).
Table 3
Safety, reliability, and resilience co-benefits of wildfire mitigation initiatives
Wildfire Mitigation Safety Reliability Resiliency
Defined as the potential to Defined as the ability of Defined as the ability for
pose a danger,risk,or the power system to the grid system to adapt
injury to life or property withstand instability, to, withstand,and quickly
uncontrolled events, recover from disruptive
cascading failures,or events or changes within
unanticipated loss of the surrounding
system components environment
Situational Awareness and Monitoring X X X
Operational Practices X
Asset Inspections X X
System Hardening—Overhead X X X
System Hardening—Underground X X X
Vegetation Management X X
Geographic Risk Assessment X
Public Outreach and Engagement X
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Section
&I AA
Situational
Awareness
and
Monitoring

Idaho Power Company Wildfire Mitigation Plan 2026
4. Situational Awareness and Monitoring
4.1. Overview
Access to current and forecasted meteorological conditions,fuel conditions, and information about fire
behavior is an aspect of Idaho Power's wildfire mitigation strategy. Meteorological and fuel conditions
can vary across the locations where Idaho Power has infrastructure or equipment. Idaho Power monitors
forecasted and current weather data for the purpose of assessing and responding to current and
anticipated fire risk. Idaho Power leverages its internal Atmospheric Science group's
modeling/forecasting capabilities, its existing fire weather stations, and publicly available weather/fuel
data to develop projections of current and future wildfire potential in wildfire risk zones.This wildfire
potential information is then available to relevant operations personnel to factor into operational
decision-making as discussed further below.
4.2. Fire Potential Index
In 2020, Idaho Power created a Fire Potential Index(FPI) tool to support operational decision-making to
reduce wildfire threats and risks.The tool takes data on weather, prevalence of fuel (i.e.,trees, shrubs,
grasses), and topography, and converts that data into a numeric forecast of the short-term fire threat for
each of Idaho Power's wildfire risk zones.The FPI is issued, during wildfire season,for a seven-day period
to provide an operational planning horizon that informs decision-making based on current and
forecasted daily fire potential.
Idaho Power's FPI is based on original work completed by San Diego Gas and Electric (SDG&E),the
United States Forest Service, and the National Interagency Fire Center(NIFC), and is modified for Idaho
Power.Since the original development of the FPI, Idaho Power has continued to enhance its
meteorological and weather forecasting capabilities to enhance FPI accuracy.
The benefit of developing an internal FPI and enhancing the company's meteorological forecasting
capabilities includes greater situational awareness of Idaho Power's system during critical peak summer
months. Idaho Power's situational awareness activities are evaluated annually, as necessary, to support
the company's wildfire preparedness.This provides Idaho Power field personnel a tool to assess the fire
potential on a consistent basis in wildfire risk zones. Given the benefits that result from the FPI and
enhanced forecasting capabilities, Idaho Power did not consider alternatives to the development of
these critical tools.
4.2.1. FPI Components
The FPI reflects key variables as follows: the state of native grasses and shrubs (green-up), woody fuels
(ratio of dead fuel moisture component to live fuel moisture component), and weather(sustained wind
speed and dew point depression). Each of these variables is assigned a numeric value, and those
individual numeric values are summed to generate a Fire Potential value from 0 to 16,which expresses
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Idaho Power Company Wildfire Mitigation Plan 2026
the degree of fire potential expected for each of the 7 days included in the forecast.The FPI scores are
grouped into the following index levels:
• Green: FPI score of 0 through 11 indicates lower potential for a large fire*to develop and
spread, based on the variable components described below.
• Yellow: FPI score of 12 through 14 indicates an elevated potential for a large fire* to develop and
spread, based on the variable components described below.
• Red: FPI score of 15 through 16 indicates a higher potential for a large fire* to develop and
spread, based on the variable components described below.
*A large fire,for the purposes of FPI scoring, is a fire greater than or equal to 1,000 acres.
FPI Categories
Normal Elevated Higher
FPI Range 0 to 11 12 to 14 15 to 16
Figure 7
FPI categories
The state of native grasses and shrubs, or the Green-Up Component, of the FPI is determined using
satellite data for locations within wildfire risk zones.This component is rated on a 0-to-5 scale ranging
from very wet (lush)to very dry (cured).The scale is tied to the Normalized Difference Vegetation Index
(NDVI),which ranges from 0 to 1, as follows:
Green-Up Component
Very Very
NDVI Wet/Lush: 0.64 to 0.60 0.59 to 0.55 0.54 to 0.50 0.49 to 0.40 Dry/Cured
1.00 to 0.65 0.39 to 0.00
Score 1 2 3 4
Figure 8
Green-Up component of FPI
The Fuels Component(FC)of the FPI measures the overall state of potential woody fuels that could
support a wildfire. Values are assigned based on the overall state of available fuels (dead or live)for a fire
using the following equation:
FC= FD/LFM
Where FC represents Fuels Component in the scale below, FD represents 100-hour Dead Fuel Moisture
(using a 1-to-3 scale), and LFM represents Live Fuel Moisture (percentage).This data is collected from
satellite sources and regional databases supported by state and federal agencies.
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Idaho Power Company Wildfire Mitigation Plan 2026
The product of this equation represents the Fuels Component reflected in the FPI as follows:
Very Wet Very Dry
dho 1 2 3 4 5
Figure 9
Fuels Component of FPI
The Weather Component of the FPI represents a matrix of sustained wind speeds and dew-point
depression using the following scale.This data is sourced from the WRF products produced by Idaho
Power using its High-Performance Computing (HPC) system. In addition to the HPC-system-produced
WRF data, several national level meteorological products are used.These products include regional
weather observations used to validate model information.
Dewpoint
Depression/Wind 55 mph 6 to 11 mph 12 to 18 mph 19 to 25 mph 26 to 32 mph >_33 mph
>_502F 4 4 4 5 5
402F to 492F 3 3 4 4 5
302F to 392F 3 3 3 4 4
202F to 292F 3 3 3 3 3 4
102F to 192F 2 2 2 2 3
<102F 0 1 1 1 1 2
Figure 10
Weather Component of FPI
4.3. FPI Review and Evaluation
The FPI process is reviewed annually after completion of the fire season. Evaluation of the FPI process is
used to assess and validate Idaho Power's wildfire preparedness approach.
4.4. Forecast Ensemble
In 2024, Idaho Power partnered with the National Center for Atmospheric Research (NCAR) to develop a
system that uses multiple weather models to enhance forecast accuracy. This method, known as a multi-
model ensemble, compares different model outputs to predict a range of possible weather scenarios.
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Idaho Power Company Wildfire Mitigation Plan 2026
This allows forecasters to calculate probabilities of the timing, location, and intensity of various weather
events, helping them communicate potential outcomes more effectively. Idaho Power will continue to
evaluate next steps for future WMPs.
4.5. Fire Weather Stations
Idaho Power's Atmospheric Science group uses high-resolution modeling and forecasting capabilities,
combined with existing fire weather stations and publicly available weather and fuel data,to develop
and circulate daily FPI forecasts. In 2026, Idaho Power plans to install approximately 55 fire weather
stations in locations proximal to wildfire risk zones. Fire weather station placement is on existing
powerline poles to best reflect real-time wind conditions at powerline height.
4.6. Wildfire Detection Cameras
Idaho Power contracts with ALERTWest who installs AI-enabled wildfire detection camera sites.
The network of cameras and the associated software solution is used by first responders, emergency
management personnel, and Idaho Power to detect wildfire,track real-time weather and fuel conditions,
and allow first responders and Idaho Power to better allocate the appropriate resources in the event of a
fire. Idaho Power's detection cameras are placed in locations that provide viewsheds of wildfire risk
zones or company infrastructure.
While informal coordination for wildfire detection camera siting and interoperability has been occurring
for the past two years between the IDL, Idaho Power, and the Bureau of Land Management (BLM),
a formal recommendation was put forth by the Idaho Governor's Office in 202418 recommending the
state formalize a working group process.The recommendation included direction to the IDL, Idaho Office
of Emergency Management, Office of Energy and Mineral Resources, and the Idaho Department of
Transportation to establish an interoperability system that included engagement with entities
participating or interested in wildfire detection camera operations.The Idaho Fire Camera
Interoperability Committee (IFCIC) was established in early 2025 to deliver on the
governor's recommendation.
To date, Idaho Power has installed six wildfire detection cameras in Idaho through ALERTWest in areas
where they provide visibility of overhead assets or surrounding terrain in certain wildfire risk zones.
These cameras are part of an AI-enabled wildfire detection camera network that totals 27 cameras
owned by various members of the IFCIC. In 2026, Idaho Power plans to install up to two additional
cameras in Idaho, pending site approval and permitting. By working closely with the IFCIC and local
public safety partners, Idaho Power achieves efficiencies in siting locations and cost savings for its
installed sites. In some cases, local partners have provided tower space at no cost, or installations were
collectively designed to eliminate the need for towers all together.
Idaho Power plans to continue to collaborate with the IFCIC to identify future camera locations, focusing
on opportunities that deliver mutual benefits and cost efficiencies while reducing wildfire risk.
8 Wildfire Report Recommendations,August 2024.Available at:IOEMADMINCOPIER-20240418092717
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Idaho Power Company Wildfire Mitigation Plan 2026
Beaverhead-Deerlodge
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Idaho Wildfire Detection Camera Interoperability
Tier 2 Risk Areas
O Tier 3 Risk Areas
Idaho Power Regions 0 25 50 100 .. IDAW
Miles POMR
Figure 11
Idaho wildfire detection camera interoperability map
Page 25

Idaho Power Company Wildfire Mitigation Plan 2026
4.7. Fire Spread Predictive Tools
Beginning in late 2024, Idaho Power began integrating Technosylva's Wildfire Risk Analyst Enterprise
(WFA-E) software into its approach for wildfire risk identification and quantification. WFA-E is a
cloud-based SaaS platform that provides wildfire spread prediction capabilities to support operational
response, what-if scenario analysis, and wildfire risk forecasting. WFA-E is comprised of a daily
operational risk package,which includes FireRisk and FireSim software and forecast data, and a
mitigation planning package, which includes FireSight analysis and software. Idaho Power uses the
on-demand capabilities of FireSim and FireRisk in conjunction with the company's internal FPI tool to
support operational decisions that reduce wildfire threats and risks. FireSight is used by Idaho Power to
support ongoing assessment of geographical risk and inform mitigation investments. Each product is
described in greater detail below:
• FireSim provides an on-demand capability within WFA-E to create spread predictions and obtain
detailed information on potential impacts within seconds of an incident notification.
Impact analysis, including at-risk populations, structures and buildings, critical facilities, and
company assets, is automatically undertaken with each prediction.
• FireRisk integrates weather forecasts with FireSim modeling to perform hundreds of millions of
fire simulations daily to produce both current and near-term risk forecasts. New forecasts are
derived daily and intended to provide accurate and timely analysis of possible wildfire events.
Baseline risk and consequence metrics are derived by identifying at-risk populations, buildings,
and critical facilities that may be impacted. Risk metrics are calculated hourly for infrastructure
assets to support possible Public Safety Power Shutoff(PSPS) de-energization analysis.
• FireSight generates millions of simulations to estimate potential wildfire spread scenarios under
varying fire weather conditions across the 600 most significant wildfire days within a 20-year
historical weather database.These simulations can then be used to estimate the potential
consequences of failure and ignition at the feeder and sub-feeder level, informing Idaho Power's
assessment of geographic risk.
Idaho Power is still in the process of implementing this software package. Idaho Power may use FireSim
for operational decision making in 2026. FireRisk and FireSight are still in the process of implementation.
Their operational utilization is still being developed.The descriptions above state how Idaho Power
anticipates using them once operational.
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Section
Mitigation
Activity:
Workforce
Preparedness

Idaho Power Company Wildfire Mitigation Plan 2026
5. Mitigation Activity: Workforce Preparedness
5.1. Overview
The nature of Idaho Power's operations can mean that employees and contractors perform work in the
field during wildfire season. For this reason, Idaho Power considers wildfire risk associated with
employee and contractor actions in this WMP, as described further below. Idaho Power also contracts
with firefighting personnel on a case-by-case, as-needed basis to protect crews and infrastructure from
direct wildfire threats.
5.2. Wildland Fire Preparedness and Prevention Plan
The Wildland Fire Preparedness and Prevention Plan (the Plan), included as Appendix A to this WMP,
informs Idaho Power personnel about the following:
• Annual wildfire season tools and equipment required to be available when on the job site
• Daily situational awareness, including weather conditions, regarding locations with a heightened
risk of wildfire
• Expected wildfire ignition prevention actions while working, and reporting instructions in the
event of fire ignition
• Training and compliance requirements for employees in those situations covered by the WMP
Idaho Power employees in situations covered by the Plan should conform to the Plan as detailed therein.
Idaho Power's contractors bear responsibility for their own actions and should ensure that they take
adequate fire mitigation measures. Idaho Power may also require that contractors performing field work
abide by fire mitigation terms as part of their contract.These terms require contractors to follow
practices intended to mitigate against wildfire mitigation risk.
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Idaho Power Company Wildfire Mitigation Plan 2026
Page 28

Section
wk�,afi
Mitigation
Activity:
Line Operation
Practices

Idaho Power Company Wildfire Mitigation Plan 2026
6. Mitigation Activity: Line Operation Practices
6.1. Overview
To reduce wildfire risk in a way that balances mitigation costs, Idaho Power implements line operational
practices during heightened wildfire risk days and/or in areas with potential heightened wildfire risk.
Wildfire mitigation operational practices fall in the following categories:
• Temporary operating procedures for distribution lines in wildfire risk zones during
wildfire season
• Temporary operating procedures for transmission lines during wildfire season
• Idaho Power's emergency de-energization operational strategy for T&D lines related to wildfire
during the wildfire season
• A PSPS strategy
6.2. Distribution Operational Protection Strategy
Sometimes called sensitive powerline settings, Enhanced Protection Settings (EPS) are used to reduce
the probability of ignition during fault events on Idaho Power's distribution system. EPS are generally
enabled based on the criteria described below in automatic reclosing(AR) protective devices where the
zone of protection overlaps with, or is located within,Tier 2 or Tier 3 wildfire risk zones, i.e., on lines
located in wildfire risk zones and/or lines that traverse a zone and extend beyond the zone's boundaries
to any point of segmentation, or the end of the line. EPS helps reduce wildfire risk by operating more
sensitively to fault conditions, but they also increase the likelihood of customer outages. For this reason,
Idaho Power enables EPS only under the conditions and protocols defined in this WMP.19 AR protective
devices include feeder relays (at head end of feeder) and reclosers.
• EPS Mode 1:Auto-reclose turned off.This allows only a single trip, which eliminates traditional
re-energizations to test whether the fault has cleared on the line.
EPS Mode 1 is operated as a seasonal setting. It is typically enabled by wildfire risk zone
grouping20 only during declared wildfire season when the following conditions are met within
said wildfire risk zone grouping, as determined by FPI criteria or by assessments by Idaho
Power's Atmospheric Science group:
• At least 40%of the zones within a grouping reach elevated (yellow) FPI levels, or
• Any single zone within the grouping reaches a high (red) FPI level
Mode 1 remains in effect until the end of declared wildfire season.
9 Similar protection philosophies are applied in line work contexts to ensure worker safety.
0 Groupings of wildfire risk zones are based on zones that have geographic areas with similar terrain,elevation,and vegetation characteristics.
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Idaho Power Company Wildfire Mitigation Plan 2026
• EPS Mode 2:Auto-reclose turned off and trip settings set to instantaneous lockout.This is a
more sensitive setting that will cause the automatic reclosing device to lockout prior to most
fuses. Mode 2 is designed to minimize the energy of a fault to reduce ignition risk.
EPS Mode 2 is enabled for a wildfire risk zone when the forecasted FPI is 15 or higher(red) and
the forecast predicts wind speeds meeting or exceeding zone-specific wind criteria established
for that zone by Idaho Power based upon historic climatology. EPS Mode 2 will remain in effect
until forecasted conditions no longer warrant the setting. Idaho Power's zone-specific wind
speed criteria are set out in the 2026 Operational Wind Speed Guidelines for EPS and PSPS by
Risk Zone.
Mode 2 applies only to AR devices that have fast trip or instantaneous trip capability. Not all AR
devices protecting wildfire risk zones currently have this capability.
EPS settings are activated remotely from Idaho Power's Distribution Control Center when remote control
is available through SCADA.When SCADA control is not available on an AR device, qualified company
personnel enable the EPS modes manually at the AR device, which requires additional time to
implement once the decision is made.
6.3. Transmission Line Operational Strategy
6.3.1. Wildfire Season Temporary Operating Procedure for Transmission Lines
115 kilovolt (kV) and Above
During wildfire season, Idaho Power temporarily modifies its operating procedures for transmission
lines.Those modifications are,generally, as follows:
For transmission lines rated up to 230 kV, a patrol is typically required prior to re-energization.The
exception is for 161 kV and 230 kV lines designated in the company's Energy Management System as
traversing highly populated areas. In these cases, if the fault location can be determined with high
confidence through relay fault data and GIS tools, operators have discretion to sectionalize the faulted
segment and re-energize the unfaulted section to restore load without a patrol.
For 345 kV and 500 kV transmission lines, operators may exercise discretion to test21 the line to maintain
grid reliability and stability, but only if one of the following criteria is met:
• The outage de-rates a rated path or forces curtailments
• The outage directly impacts customers or Idaho Power's ability to serve load.
• The outage strands or islands generation that is required for load service or system reliability.
A transmission line"test"or transmission line"testing"refers to the human act of re-energizing a line without completing a physical field
patrol or observation of a line.
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Idaho Power Company Wildfire Mitigation Plan 2026
If none of these criteria apply,testing will not be performed, and the line will be patrolled prior to
re-energization.
6.3.2. Tier 3 Zone Transmission Operational Strategy 69 kV& Below
During wildfire season, Idaho Power determines a daily FPI as described in Section 4 of this WMP.
The FPI informs the transmission line operational strategy for those lines owned and operated by Idaho
Power located in Tier 3 zones. These lines will be operated in normal settings mode but with no "testing"
of a line that may have "locked out"22 during the time of a red FPI. In the event of a fault on the specified
transmission line(s) during a red FPI,the line will operate as normal and may "lock out" at which time
the line(s)will need to be patrolled before re-energization.Alternatively, Idaho Power may choose to
wait until the FPI level drops out of the red category prior to re-energizing without a patrol.
6.3.3. Transmission Lines Where Idaho Power Is Not the Operator
Idaho Power both fully owns and co-owns transmission lines in Idaho for which Idaho Power is not the
FERC-registered Transmission Operator(TOP) responsible for the safe and reliable monitoring and
operation according to North American Electric Reliability Corporation (NERC) standards governing
transmission lines.The FERC-registered TOP for all Idaho Power full and co-owned transmission lines is
responsible for determining and implementing any and all transmission line operational strategies
intended to mitigate against wildfire risk. Idaho Power is not responsible to implement wildfire
mitigations for lines operated by a different party.
6.3.4. De-energization by Other Electric Corporations
Idaho Power may be notified by other electric corporations in advance of de-energization if they intend
to de-energize a transmission line that may impact one or more transmission lines operated by Idaho
Power. Idaho Power considers the impact of potential de-energization on the bulk electric system,which
includes the status of transmission lines operated by other electric corporations,when deciding whether
to deenergize under Sections 6.4 and 6.7.
6.4. Emergency De-energization When Wildfire is Approaching
In the event of a wildfire near or approaching Idaho Power infrastructure,the company will conduct an
emergency de-energization of overhead transmission or distribution lines only if requested by the lead
firefighting agency, including the designated incident commander for that fire or those operating at the
local, state, or federal level, and if Idaho Power can determine to its satisfaction the identity of the line
for which de-energization is requested.The lead firefighting agency makes the determination because
they are generally in the best position to analyze the fire risk and water needs in any situation, subject to
Idaho Power's bulk electric considerations noted below.
Upon a request to de-energize transmission circuits, Idaho Power will also evaluate potential impacts to
overall grid reliability and system stability. Idaho Power may opt not to de-energize a transmission
""Lockout"refers to the process of the protection systems going through a series of trip/reclose attempts before finally staying deenergized.
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Idaho Power Company Wildfire Mitigation Plan 2026
segment or circuit if it determines the requested de-energization may cause grid instability or reliability
issues that could impact a large number of customers (such as a de-energization that could impact 1,000
or more customers) or impact the bulk electric system, or if Idaho Power believes it poses a risk to public
safety.
Idaho Power will de-energize upon a request for emergency de-energization that meets the above
criteria as soon as reasonably possible. Idaho Power strives to de-energize in response to such a request
within one hour of the request being validated,though in some instances the de-energization may take
longer than one hour.
If Idaho Power learns of a fire located in a wildfire risk zone through a report to Dispatch or LSO, Idaho
Power will enable EPS Mode 2 (when configured) on distribution lines located within that wildfire risk
zone or intersecting the wildfire risk zone to the nearest zone of protection segmentation point if the
following are met: (1)the FPI is 15 or higher(red) and (2)the weather forecast predicts wind speeds
meeting or exceeding the zone-specific wind criteria identified above. EPS Mode 2 will remain in effect
until the lead firefighting agency communicates to Idaho Power that the fire is no longer a threat to
Idaho Power infrastructure or equipment, or until either the FPI or wind speed no longer justify Mode 2
enablement.
6.5. Restoration of Electrical Service After a Wildfire De-Energization
Idaho Power personnel restore electrical service when it is safe to do so following a wildfire.
Following an emergency or unplanned de-energization of lines at set forth in Section 6.4, Idaho Power
will use qualified line personnel to conduct "emergency" patrols (inspections) of the de-energized lines,
unless Idaho Power determines a patrol is unnecessary.These patrols identify outage causes, damaged
facilities, and restoration requirements (number of crews, crew sizes, and necessary materials).
If damage is detected,trained field crews report to the site where damage has occurred with equipment
and new materials and develop a plan to remove and rebuild or repair damaged facilities. Depending on
the situation, contracted field crews — such as line crews and vegetation management crews — are also
deployed to assist in restoration efforts. Restoration work may take hours or— in some cases, days —
to complete.
6.6. Mutual Assistance
Idaho Power is a member of the Western Region Mutual Assistance Group (WRMAG), of which most
western U.S. electric utilities are also members. Member utilities provide emergency repair and
restoration assistance to other member utilities requesting assistance when dealing with damaged
electric facilities following a significant wildfire or weather event. In the event of a wildfire that causes
widespread damage to Idaho Power's system, Idaho Power may request restoration assistance via
the WRMAG.
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Idaho Power Company Wildfire Mitigation Plan 2026
6.7. PSPS
A PSPS, as used in this WMP, is defined as the proactive de-energization, when deemed appropriate by
Idaho Power, of electric transmission and/or distribution facilities during extreme weather events to
reduce wildfire risk. A PSPS event requires extensive planning and strategy leading up to, during,
and after a PSPS event to minimize the impact of PSPS events on stakeholders.
PSPS is not the practice of de-energizing lines in the following types of situations:
• Unplanned de-energization of lines required for emergencies and during outage
restoration situations.
• Planned line or station work activities that require a planned outage (Idaho Power currently has
a planned outage customer notification process in place for these situations).
• Reactive de-energization of electric transmission and/or distribution facilities in response to
existing/encroaching wildfire threatening to burn into such facilities as set forth in Section 6.4.
• Automated de-energization of electric transmission and/or distribution facilities caused by faults
on the line.
6.7.1. PSPS Plan
Idaho Power developed its Wildfire Public Safety Power Shutoff Plan (Appendix B)to guide its
implementation of this wildfire mitigation strategy. Idaho Power will conduct PSPS only in wildfire risk
zones.The decision regarding PSPS is based on several dynamic factors, and each weather event
is unique.
6.8. Community Resource Centers
Each county has unique needs during outage events, requiring a customized,flexible approach. Through
annual meetings with county emergency managers, local public safety partners, and Local Emergency
Planning Committees(LEPC), Idaho Power refines county-specific strategies in preparation for potential
large-scale, extended outages.These strategies include working with emergency managers to identify
Community Resource Center (CRC) locations for potential activation during a PSPS event.
Beginning with the 2026 wildfire season, Idaho Power will have a mobile CRC trailer that may be used in
large-scale, extended outages.This unit can be staged where needed in response to sustained outages of
Idaho Power equipment.The trailer is equipped with a generator, climate control, charging stations for
durable medical equipment and personal devices, canopy tents for additional shade, and a monitor
system to provide real-time updates about the emergency event.
Idaho Power is not responsible for providing a local emergency response or coordinating local
emergency response resources;that is the role of the local emergency managers. However, if a PSPS
event is forecasted, Idaho Power will strive to collaborate with public safety partners to identify and
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Idaho Power Company Wildfire Mitigation Plan 2026
meet the needs of the community. Services provided in collaboration with emergency managers could
include the following, as appropriate, depending on the situation:
• Stand-up of a CRC
• CRC location(s) and logistics included in community outreach/outage notifications
• CRC resources
• Food, water, and other basic needs
• Charging stations for durable medical equipment and personal devices
• Potential coordination of auxiliary services, which may be used for medical services, housing
assistance,family reunification, etc.
Idaho Power recognizes the challenges faced by vulnerable populations.The company also recognizes
that local communities and emergency managers are specially equipped for the care of vulnerable
populations in PSPS situations and defers to their expertise and abilities. Idaho Power may take
measures to try to support these emergency managers and vulnerable customers during PSPS outages.
Outreach efforts also emphasize the importance of personal preparedness, particularly for customers
with medical or mobility needs. Idaho Power encourages individuals to understand their unique needs
and develop a plan before an outage.This includes identifying back-up power options for life-support
equipment or refrigerated medications, updating contact information and outage notification
preferences, and knowing where to go if power is lost. Customers are also advised to coordinate with
medical supply companies or caregivers and to be aware of emergency shelters with power.
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Section
1
Mitigation
Activity:
Infrastructure
Inspection and Asset
Management

Idaho Power Company Wildfire Mitigation Plan 2026
7. Infrastructure Inspection and Asset Management
7.1. Overview
Idaho Power's wildfire mitigation strategy relies in part on its various asset management programs,
including inspection and maintenance activities.Table 4 provides a summary of Idaho Power's T&D asset
inspection programs,which will be discussed in greater detail throughout this section.The work
described herein may be completed by Idaho Power employees or contractors, at Idaho
Power's election.
Table 4
Overview of T&D inspection programs
Transmission
Transmission Asset Inspection Programs Description
Aerial Visual Inspection Program Except where prohibited by government agencies,perform annual patrols on
lines that are under the jurisdiction of the Western Electricity Coordinating
Council(WECC)and non-WECC transmission lines located in Tier 3 wildfire
risk zones using helicopters or drones and document identified defects
according to priority.Complete repairs according to priority definition.
Ground Visual Inspection Program Perform annual patrols and document identified defects according to
priority.Complete repairs according to priority definition.
Detailed Visual(High Resolution Photography) Perform 10-year cycle patrols and document identified defects according to
Inspection Program priority.Complete repairs according to priority definition.
Wood Pole Inspection and Treatment Program Perform 10-year cycle inspection and treatment and document identified
rejects according to priority.Complete replacement according to priority
definition.
Cathodic Protection and Inspection Program Perform periodic structure-to-soil potential testing on select towers with
direct-buried anodes at intervals determined by Idaho Power.Perform
annual rectifier and ground-bed testing on impressed current corrosion
protection(ICCP)systems,including measurement and recording of the
results.Complete repairs and adjustments as determined by Idaho Power.
Wood Pole Wildfire Protection Program Install fire mesh wraps on selected poles.
Distribution
Distribution Asset Management Programs Description
Wood Pole Inspection and Treatment Program Perform 10-year cycle inspection and treatment and document identified
rejects according to priority.Complete replacement according to priority
definition.
Line Equipment Inspection Program Complete annual inspections and mitigate defects.
Ground Detailed Inspection Program Perform 3-year cycle patrols and document identified defects according to
priority.Complete repairs according to priority definition.In Tier 3 and select
Tier 2 Risk Zones,patrols are performed annually.
Thermography(Infrared)Inspections Complete inspections of targeted lines and equipment using thermal imaging
(infrared)cameras.
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Idaho Power Company Wildfire Mitigation Plan 2026
7.2. 2026 T&D Asset Inspection Targets
Table 5
2026 asset inspection targets
Wildfire Mitigation Plan Asset Inspection Initiatives 2026 Goal
Transmission Inspections
Wildfire Pre-Season Patrol—Tier 3 Risk Zones(structures) 1,118
Infrared Thermography Patrol(structures) 1,118
Distribution Inspections
Wildfire Pre-Season Patrol—Tier 3 Risk Zones and select Tier 2 Risk Zones(poles) 19,382
Infrared Thermography Patrol—Tier 3 Zones(poles) 4,000
7.3. T&D Inspection Overview and Correction Timeframes
The WSCA requires that Idaho Power develop standards, procedures, and schedules— subject to timely
approval of access to rights-of-way—if necessary,for the inspection of its assets, infrastructure,
and facilities within the areas identified as wildfire risk zones.To meet that requirement, Idaho Power
sets out the following:
Idaho Power employees or contractors inspect Idaho Power equipment for potential defects. Defects are
categorized as Priority 1, Priority 2, or Priority 3 based on the following criteria:
• Priority 1: Defects that, depending on the circumstances, require reporting and repair as soon as
reasonably possible, generally within 30 days.Timeframes can be extended as a result of
conditions such as access issues, weather, and/or materials lead time.
• Priority 2: Defects that, depending on the circumstances,generally require reporting and
correction within 24 months of identification, and the correction of these defects are scheduled
during crews' normal work schedules.Timeframes can be extended beyond 24 months as a
result of conditions such as materials lead time, including the correction as part of a broader
project, and access issues.
• Priority 3: Defined by Idaho Power as potential issues that may need correction over time and
should be monitored, but do not pose a threat to the system.A Priority 3 designation may also
be used by Idaho Power personnel for tracking certain line construction practices. Correction of
Priority 3 issues may be deferred until the next major work activity on the circuit, up to a
maximum of 10 years after discovery on transmission facilities. On distribution facilities, Priority
3 issues may be monitored until the issues qualify as Priority 1 or Priority 2 defects.
Idaho Power line patrol employees receive training annually on defect classification.
Table 6 summarizes Idaho Power's inspection initiatives and frequency in relation to wildfire risk zones.
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Idaho Power Company Wildfire Mitigation Plan 2026
Table 6
Summary of asset inspections and schedules
Idaho and Montana
Asset Inspection Type Non-Risk Zone Idaho Tier 2 Idaho Tier 3
Transmission Defect Inspections
Visual Annually Annually Annually
Detailed 10 Years 10 Years 10 Years
Groundline(Wood Pole Test and Treat) 10 Years 10 Years 10 Years
Infrared Patrol None None Annually
Distribution OH*Defect Inspections
Visual/Detailed 3 Years 3 Years 3 Years
Groundline(Wood Pole Test and Treat) 10 Years 10 Years 10 Years
Wildfire Mitigation/Potential Ignition Source Patrol None Select Zones Annually Annually
Infrared Inspections None None Annually
*OH refers to overhead lines.
7.4. Wood Pole Inspection and Treatment Program
Idaho Power strives to visually inspect, sound, and bore wood poles on transmission and distribution
systems for defects and decay on a 10-year cycle. Poles are categorized according to the following:
• Reported: Any wood pole inspected and found to be installed within 10 years of the
manufactured date or last inspection date.
• Treated: Any wood pole inspected and found to be installed 11 years or more prior to the
inspection date and determined to be in sound enough condition to warrant treatment.
• Rejected: Any wood pole determined to fit any of the following criteria:
• Has less than 4 inches of shell at 48 inches above the ground line; or
• Less than 2 inches of shell at 15 inches above the ground line; or
• Less than 2 inches of shell at the ground line; or
• Is deteriorated and does not meet minimum strength criteria; or
• Fails a visual inspection
Rejected poles are classified as Priority or Non-Priority, which determines the replacement or
remediation timeframe. Priority rejected poles are those with an effective circumference of less than
50% of the original circumference or 13%or less of the original strength.These poles are scheduled for
replacement or reinforcement as soon as reasonably possible,generally within 30 days of being
classified as rejected. Non-Priority rejected poles include all other rejected poles and are scheduled for
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Idaho Power Company Wildfire Mitigation Plan 2026
replacement or reinforcement within two years of being classified as rejected. Both Priority and Non-
Priority replacements may be subject to delays related to permitting, access, or construction constraints.
7.5. Transmission Inspection and Asset Management Programs23
Idaho Power's transmission inspection and asset management programs include condition-based aerial
visual inspections,ground visual inspections, detailed visual (generally using high-resolution
photography) inspections,thermal imaging inspections,transmission wood pole inspection and
treatment, cathodic protection, and fire-resistant mesh wrap.
On an annual basis, Idaho Power assesses the inspection needs of its transmission lines.
That determination is prioritized and approved by leadership. Idaho Power's goal is to complete 100%of
the work each year; however, emergencies, operational issues, or other unplanned events can occur and
disrupt the annual work plan. All work is completed in accordance with safety and
applicable requirements.
7.5.1. Transmission Aerial Visual Inspection Program
Annually, Idaho Power performs aerial visual inspections of certain of its transmission lines. Idaho Power
uses helicopters carrying qualified Idaho Power personnel for the aerial visual inspection of transmission
lines identified as WECC Path Lines.This method of line inspection is also used on an annual basis
pre-wildfire season for non-WECC transmission lines located in Tier 3 zones. UAVs serve as a
supplemental inspection tool that can be deployed at Idaho Power's discretion where traditional aerial
patrols are not conducted, or when patrolmen require a closer assessment of components at the top of a
structure. Idaho Power strives to complete these inspections prior to the start of the wildfire season;
however, spring weather and snow levels may create access issues and delay the completion until July 1
in some areas.
7.5.2. Transmission Ground Visual Inspection Program
Annually, qualified Idaho Power personnel (i.e.,trained in transmission line inspection procedures and
experienced in line construction) complete ground visual inspections of all transmission lines. Ground
patrols are completed using four-wheel-drive vehicles, all-terrain vehicles (ATV), utility-terrain vehicles
(UTV), and/or on foot. Personnel may also be equipped with UAVs.Through these inspections, potential
line defects are identified, documented, and scheduled for repair based on their classification.
7.5.3. Transmission Detailed Visual(High-Resolution Photography)
Inspection Program
In addition to the annual inspections and associated maintenance noted herein, Idaho Power also
completes detailed visual inspections generally utilizing high-resolution photography.This inspection is
23 Idaho Power owns and co-owns transmission lines in Idaho for which another entity is the Operator.The Operator performs maintenance and
inspection of those transmission lines.Idaho Power does not perform wildfire mitigation activities for transmission lines for which it is not the
Operator.
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Idaho Power Company Wildfire Mitigation Plan 2026
typically completed using helicopters, UAVs, and contracted professionals operating high-definition
cameras. If potential line defects are noted,they are scheduled for repair consistent with defect
classification set forth in Section 7.3.The detailed visual inspections are completed on a 10-year cycle in
conjunction with the 10-year cycle of wood pole ground line inspection and treatment.
7.5.4. Transmission Thermal Imaging (Infrared) Inspections
Before July 1, Idaho Power annually inspects certain transmission line connectors and splices within Tier
3 zones using thermal imaging (infrared) cameras.These inspections are conducted using hand-held and
drone-mounted cameras with thermal-sensing technology and can help identify defects associated with
overheating equipment.
As part of the thermography inspections,temperature gradients are analyzed to detect potential
problems, and repairs of issues found are prioritized based on their severity consistent with defect
classifications.A combination of Idaho Power personnel and contracted resources are used to perform
thermography inspections. Idaho Power's thermography technicians coordinate repair activities found by
internal and contracted resources.
7.5.5. Transmission Cathodic Protection and Inspection Program
Cathodic protection systems are employed on select steel transmission towers.These systems use either
an ICCP or direct-buried sacrificial magnesium anodes. Structure-to-soil potential testing is performed
periodically at intervals determined by Idaho Power on select towers with direct-buried anodes located
within wildfire risk zones. For ICCP systems, rectifiers and ground-beds are tested annually for
functioning, including measurement and recording of the results. Based on test results, repairs and
adjustments are completed as determined by Idaho Power.
7.5.6. Transmission Wood Pole Mesh Wrap
Idaho Power plans to install mesh wrapping on approximately 750 transmission wood poles located in
the Tier 3 and Tier 2 zones in 2026 to protect the integrity of those poles. In 2025, 772 poles were
wrapped with fire-resistant mesh. At Idaho Power's discretion, the company may use mesh in additional
areas outside wildfire risk zones in areas that exhibit frequent fire return intervals.
7.6. Distribution Inspection and Asset Management Programs
Idaho Power's distribution inspection and asset management programs include condition-based,
detailed, and ground visual inspection; distribution wood pole inspection and treatment; and line
equipment inspections, as noted below.
7.6.1. Visual Inspection
Annually, qualified line patrol personnel (trained in distribution line inspection procedures and
experienced in distribution line construction) complete visual wildfire mitigation inspections of the
distribution lines located in Tier 3 zones and Tier 2 zones selected by Idaho Power to identify Priority 1
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Idaho Power Company Wildfire Mitigation Plan 2026
defects (defined in Section 7.3).The ground patrols are completed using four-wheel-drive vehicles,ATVs,
UTVs, or on foot.They involve inspection at each individual pole and incorporate the use of visual
observation, binoculars, and/or UAVs, as Idaho Power inspectors deem appropriate. Helicopters may not
be practical for carrying out distribution patrols in areas with greater population and structural and
vegetation density. However,there are instances where the company may use helicopters on a case-by-
case basis to conduct such patrols.
These inspections identify potential line defects that are visually identifiable by the inspector that might
result in an outage or ignition and that need to be repaired as soon as reasonably possible.The
identified defects are then documented, prioritized, and scheduled for repair consistent with defect
classification, as discussed in Section 7.3.
Idaho Power strives to complete distribution inspections under this Section 7.6.1 prior to the start of
each wildfire season; however, access issues may delay completion until July 1 in some areas.
7.6.2. Line Equipment Inspection Program
Idaho Power strives to inspect line equipment in all wildfire risk zones, including capacitor banks,
automatic reclosing devices, and regulators, annually prior to July 1 using line operations technicians.
The inspection is a visual inspection. When electronic controls are present, control data is also analyzed.
7.6.3. Thermal Imaging (Infrared) Inspections
At its discretion, Idaho Power annually inspects selected distribution lines and equipment within Tier 3
zones using thermal imaging (infrared) cameras. Identified risks are prioritized and mitigated consistent
with defect classification system set out in Section 7.3.
7.6.4. Wood Pole Inspection and Treatment Program
On a 10-year inspection cycle, wood poles are visually inspected, sounded, and bored for defects and
decay.The procedure for the Distribution Wood Pole Inspection and Treatment Program is consistent
with and elaborated on earlier in this section under the Transmission Wood Pole Inspection and
Treatment Program.
7.6.5. Pole Attachments
Idaho Power is obligated by Idaho Code § 61-538 and associated regulations to allow attachments
owned by third party attaching entities (i.e., cable, broadband, or telecommunications providers) on its
poles.The attaching entity is solely responsible to perform its work according to industry standards,to
maintain its equipment in good working order, and take steps to prevent wildfire caused by their
equipment and actions.
Page 40

Section
am-
Methods of
Line Design

Idaho Power Company Wildfire Mitigation Plan 2026
8. Methods of Line Design
8.1. Overview
Idaho Power's wildfire mitigation strategy includes financially prudent and reasonably practicable
methods of line design for new, planned, and existing lines to mitigate fire risk.
On an annual basis, Idaho Power assesses construction (rebuild, hardening and/or upgrade) work for its
transmission and distribution lines.That determination is prioritized and approved by leadership. Idaho
Power's goal is to complete 100%of the work each year; however, emergencies, operational issues, or
other unplanned events can occur and disrupt the planned work. All work is completed in accordance
with safety and applicable requirements. Specific wildfire mitigation design and construction practices
are discussed further below.
8.2. Siting and Design of New Transmission Lines
Idaho Power uses financially prudent and reasonably practicable methods of line design for its new lines,
and Idaho Power will apply this WMP to new transmission lines located in Idaho and Montana,
once constructed.
8.2.1. Transmission Steel Poles
Idaho Power has existing wood 138-kV and above transmission poles on its system, which is allowed
under this WMP. However,when building new 138-kV lines, Idaho Power will use steel poles or
structures unless, in Idaho Power's discretion,the use of wood poles is more feasible than steel poles
based on factors such as limited supply or availability of steel poles, engineering specifications, right-of-
way constraints, permitting requirements, and project timelines.This approach is designed to enhance
wildfire mitigation, improve transmission line resiliency, reduce future rebuilding costs after fire events,
and provide greater reliability for customers.
8.3. Transmission Line Rebuild Projects
Idaho Power takes steps to repair or replace transmission line components on an ongoing basis as part of
asset management assessments. Idaho Power considers wildfire risk as part of the prioritization of
transmission line rebuild projects.These projects will increase resiliency of the transmission system
related to wildfire and have the co-benefit of improving reliability for customers.
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Idaho Power Company Wildfire Mitigation Plan 2026
8.4. Distribution Hardening
Distribution hardening is an ongoing effort under the WMP that,to-date, remains focused on circuits in
Tier 3 zones and, as with all mitigations selected, reflects a reasonable balancing of mitigation costs with
reduction of wildfire risk. Overhead distribution infrastructure located in Tier 3 zones is analyzed,
inspected, and hardened as Idaho Power deems appropriate using the strategies indicated below. Idaho
Power's design and approach depend on inspection findings, proximity to fuels that may be conductive
to wildfires, and risk model data.
Hardening investments may include line rebuilding, component change-outs, installation of covered
conductor, and/or strategic undergrounding of powerlines intended to improve safety and reliability and
reduce ignition risk. Idaho Power distributes hardening work across its service territory to maximize
system-wide wildfire risk reduction.The company is prioritizing hardening efforts in Tier 3 zones and
expects to be approximately 50%complete in all Tier 3 zones in Idaho by the end of 2025. Looking
ahead, Idaho Power intends to complete 70 to 80 line-miles of hardening for 2026.To expedite
completion, projects are scheduled to make efficient use of both internal construction crews and
external contractors, enabling work to proceed concurrently across multiple locations.The cadence and
identification of structures and equipment selected to harden is at the discretion of the Wildfire
Mitigation and T&D Engineering Director, or their designee.
Prior to developing its WMP, Idaho Power successfully implemented many of the same hardening
measures as part of the company's reliability program. On average, outage data and analytics showed
customer outages were reduced by approximately 38% in areas where hardening projects were carried
out. With the success of reducing outages, many of these same activities used to increase reliability were
chosen to be part of the WMP to reduce ignition potential in Tier 3 zones.
Idaho Power estimates spending approximately$32 million in 2026 on distribution hardening and
infrastructure upgrades across its system.Table 7 and 14 summarize the incremental capital investments
the company is making to harden its system and further reduce wildfire risk. These hardening activities
are implemented on a rolling basis over the course of multiple years consistent with internal
prioritization analysis and scheduling.
Table 7
Distribution asset management targets
Initiative Distribution Hardening Activity 2026 Planned
Distribution System System Hardening(miles) 72
Hardening*
Overhead Line Converted to Underground(miles) 20
Feeder Segmentation Installation or Relocation of Automatic Reclosing Devices 5
*Excludes reliability improvement projects outside of wildfire risk zones
8.4.1. Overhead Primary Hardening Program
Overhead primary hardening includes upgrading and strengthening overhead powerlines to reduce
wildfire risk and improve safety. Idaho Power's core hardening strategies are listed below.
These strategies and equipment were evaluated by patrolmen,trouble men, reliability engineers, and
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Idaho Power Company Wildfire Mitigation Plan 2026
the company's Methods and Materials department to determine cost-effective solutions that balance
overall costs with expected risk reduction. Not all of these strategies are employed in all scenarios.At
their discretion, Idaho Power personnel select the appropriate hardening methods on a case-by-case
basis. Idaho Power's team researches and evaluates emerging technologies relative to primary hardening
to determine if any should be adopted in the future.The full list of currently implemented methods is in
Table 8.
Table 8
Idaho Power overhead distribution primary hardening program methods
Overhead Distribution Primary Hardening Program Methods*
• Replace"small conductor"with new 4 ACSR or larger conductor.
• Replace or repair damaged conductor.
• Re-tension loose conductors,including slack spans as required.
• Replace wood-stubbed poles with new wood poles.
• Replace rejected poles with new wood poles.
• Replace wood crossarms with new fiberglass crossarms.
• Replace steel insulator brackets with new steel pins/fiberglass crossarms.
• Replace wedge dead ends on primary taps with new polymer dead end strain insulators.
• Replace aluminum dead end strain insulators with new polymer dead end strain insulators.
• Replace porcelain switches with new polymer switches.
• Install bird/animal guarding.
• Replace hot line clamps:
• Replace aluminum stirrups.
• Install avian switch cover.
• Relocate arresters below the fuse.
• Update the following capacitor banks:
• Replace swelling capacitors.
• Replace oil-filled switches with vacuum style.
• Replace porcelain switches with polymer switches.
• Install disconnect switches on CSP transformers.
• Install avian switch cover.
• Update down guys.
• Replace/Install down-guy insulators with fiberglass insulators.
• Re-tension down guys.
• Tighten hardware.
• Replace all arresters with non-expulsion arresters.
• Replace all expulsion fuses with energy limiting or SMU Power fuses.
*Design is informed by inspection findings and other factors considered as part of the mitigation selection process
These methods represent a toolkit of options rather than a prescriptive set of actions to be applied in
every case. Not all measures will be implemented on each project; for example, newer construction may
already include avian covers, polymer switches, and recently installed poles may not require
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Idaho Power Company Wildfire Mitigation Plan 2026
replacement. Instead, Idaho Power applies a systematic, risk-based approach in which Idaho Power
designers evaluate each project in the field to determine the specific hardening needs for that location.
8.4.2. Overhead to Underground Conversion
As an alternative to conducting overhead circuit hardening upgrades,the company considers converting
overhead distribution circuits in wildfire risk zones to underground and does so by reasonably balancing
mitigation costs of undergrounding with the resulting reduction in wildfire risk.
Underground conversion of overhead distribution lines can provide benefits, including reduced wildfire
ignition risk, improved reliability, and lower long-term vegetation maintenance needs. In certain
locations, undergrounding also enhances community safety by reducing outage exposure for critical
facilities and improving system resilience in areas with limited access or evacuation routes.
While underground conversions of the distribution system are used in certain circumstances,the
up-front cost can vary based on voltage level, configuration, equipment requirements, permitting,
and ground suitability. Underground costs are generally estimated to be higher than the cost of carrying
out overhead hardening work. In general, overhead hardening efforts provide the benefit of being able
to impact a greater number of circuit miles and customers in a shorter time horizon with less up-front
investment than undergrounding. However,there may be certain risk, reliability, ongoing cost savings,
and other benefits of underground infrastructure relative to overhead. Idaho Power evaluates these
alternatives annually in the development of annual WMPs and is not required to undertake
undergrounding or hardening measures beyond what is reasonably planned and approved for a
given year.
In 2025,the company converted 12 miles of overhead powerlines to underground and plans to convert
approximately 20 miles of overhead line to underground in 2026.These 20 miles reflect the company's
total obligation to underground lines in 2026.
The company will select the locations for the nonconsecutive 20 miles of underground conversion in
2026 by reasonably balancing the following areas to assess costs and potential for wildfire
risk mitigation:
• Wildfire risk modeling and quantification, showing areas with elevated risk of wildfire spread and
impacts to people and property.
• Fire history where overhead powerlines may be susceptible to repeated wildfire events over
their lifetime (i.e., fire return interval).
• Community safety risks, including areas with limited egress or evacuation routes and constrained
access for fire suppression resources.
• Outage exposure for critical facilities, including but not limited to hospitals,water suppliers, and
nursing homes.
• Vegetation exposure, including areas with dense fuels or elevated likelihood of vegetation-
related faults, such as falling trees.
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Idaho Power Company Wildfire Mitigation Plan 2026
• Weather vulnerability, such as locations subject to frequent lightning or high winds.
• Accessibility constraints, such as steep terrain, remote locations, or right-of-way limitations.
• Feedback from local officials or fire agencies on topography and fuels in areas conducive to rapid
fire spread that may impact highly valued resources, watersheds, or critical facilities.
• Overall number of customers that may benefit from a particular project.
• Condition and age of existing infrastructure, especially where age or type of original construction
would otherwise require significant upgrades.
• Long-term operational savings, such as reduced vegetation maintenance, outage response, or
wildfire-related restoration costs.
8.4.3. New Underground Construction
Customer growth and new developments in wildland urban interface (WUI) areas present challenges for
Idaho Power when working to decrease wildfire risk.As people increasingly move into areas with more
wildfire risk,the company expands its infrastructure to serve customers while balancing cost and
mitigating for wildfire risk. Idaho Power evaluates new developments to determine if near-term risk
levels warrant underground construction at the onset of a project; specifically, the company may
consider a new development's location,wildland fuels, suppression and response capabilities,
and egress/ingress routes when determining if underground construction is warranted.The risk
reduction benefits, cost of underground construction, potential cost savings of underground relative to
overhead infrastructure, and potential reliability benefits, as well as other potential benefits will be
explored in each instance.
8.4.4. Feeder Segmentation
Idaho Power has expanded the use of overcurrent protection devices (i.e., reclosers)to isolate areas of
higher wildfire risk from areas with lower risk—a practice called segmentation. Feeder segmentation
may include installation of new devices, relocation of existing devices, and/or upgrading remote
communication capabilities (i.e., SCADA).
Reclosers provide a point of de-energization for PSPS and are also used to implement EPS, resulting in
the ability for Idaho Power to minimize impacts from de-energization and unplanned EPS outages,
particularly for customers outside wildfire risk zones. Segmentation is also used to break up longer
circuits in wildfire risk zones which, in the event of an outage, expedites restoration by reducing patrol
time and cost by limiting the line miles that must be patrolled prior to safe re-energization.
Segmentation is most efficiently accomplished through remote-controlled devices. Remote
communications allow for real time setting changes and de-energization, providing significant time
saving and avoiding costs that would otherwise be incurred if devices were manually adjusted in
the field.
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Idaho Power Company Wildfire Mitigation Plan 2026
Idaho Power prioritizes new recloser installations and upgrades based on the following criteria:
• SCADA Operability:The first consideration is whether an existing recloser or circuit breaker can
be remotely operated via Idaho Power's SCADA system. Remote operability is key for timely and
safe execution of PSPS events and eliminates the need for manual field switching during wildfire
conditions.
• EPS Compatibility:The second criterion is the device's ability to support EPS. Existing equipment
is assessed for compatibility with Mode 1 and Mode 2 configurations, and upgrades are
implemented where necessary to promote reliable operation under elevated fire risk conditions.
• Minimizing Customer Impacts: A third factor involves identifying areas where customers are
located outside wildfire risk zones but are served by circuits that extend into them. In such cases,
reclosers may be strategically installed near the boundary of wildfire risk zones to isolate high-
risk segments and minimize patrol times during PSPS events and help avoid unnecessary outages
for customers located in lower-risk areas.The company plans to complete additional
segmentation upgrades at five sites in Idaho in preparation for the 2026 wildfire season.These
include installing, upgrading, and commissioning reclosers to provide remote monitoring and
control, which will enable efficient implementation of PSPS and EPS Mode 1 and Mode 2 during
the wildfire season, as necessary.
Page 46

Section
LAP AOM
Vegetation
Management

Idaho Power Company Wildfire Mitigation Plan 2026
9. Vegetation Management
9.1. Overview
Idaho Power's T&D Vegetation Management Program (VMP) addresses public safety,
regulatory compliance, electric reliability, and helps to safeguard lines from trees and other vegetation
that may cause an outage or damage to facilities. Specifically, the lines are inspected periodically,
and trees and vegetation are cleared away from the line while certain trees are removed entirely.
In addition,the VMP addresses the clearing of vegetation near the base of certain poles and line
structures.The responsibilities of the VMP include the planning, scheduling, and quality control of
VMP-associated work.The VMP is active year-round and complies with applicable NESC,federal,
and state requirements.
Idaho Power faces challenges that impede its ability to complete all aspects of its vegetation
management goals.These include, but are not limited to, landowners who refuse pruning or removal of
trees, shortage of qualified labor resources in the vegetation line clearing industry, inclement weather
and terrain limiting access to overhead electric facilities during some seasons, urban growth that
increases the number of trees near overhead electric facilities, and cycle-buster trees that grow back
after pruning more rapidly than other trees in the inventory. As more fully described throughout this
section, Idaho Power has developed standards, procedures, and schedules, subject to timely approval of
access to rights-of-way, if necessary,for vegetation management within areas identified as wildfire risk
zones within Idaho Power's rights-of-way or lands adjacent thereto to address potential vegetation risk
to Idaho Power's power lines or other infrastructure.
Notwithstanding these obstacles, Idaho Power adheres to the VMP outlined below to the
extent practicable.
9.2. Program Components
Idaho Power employs enhanced vegetation management practices in both Tier 2 and Tier 3 wildfire risk
zones.These practices include mid-cycle patrols and pruning in the second year of the cycle to address
"cycle buster"21 trees, along with annual patrols, which may identify new hazard trees,25 "hot spotS,"26
or unexpected vegetative growth that poses an imminent threat of contact with energized facilities.
When pruning or removing trees, Idaho Power generally leaves all wood greater than 4 inches in
diameter on landscaped property, and in non-landscaped areas, leaves wood in place to biodegrade.
24 Cycle Buster—Trees that grow at a rapid rate,requiring a more frequent trimming schedule than the normal trim cycle.
25 Hazard Tree—Any vegetation issue that poses a threat of causing a line outage but has either a low or medium risk of failure in the next
month.Hazard trees will be further defined as posing either a medium hazard or low hazard.Assessing whether a tree is a hazard or high
priority tree requires the exercise ofjudgment.Idaho Power defines a Hazard Tree and the associated hazard level to be those designated in
the opinion of the inspector.
16 Hot Spots—Locations where vegetation shows evidence of contact with energized conductors or other electric system components.
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Idaho Power Company Wildfire Mitigation Plan 2026
In addition, Idaho Power strives to complete annual (meaning once per calendar year) audits21 for all
pruning work performed in Tier 2 and Tier 3 wildfire risk zones.The audits confirm that pruning cuts
meet the specification and proper clearance was obtained.Table 9 summarizes vegetation management
activities with respect to wildfire risk zones.
Table 9
Vegetation Management Program initiatives
Vegetation Management Program Initiatives
Transmission Description
Pre-Wildfire Season Inspection and Mitigation Perform annual pre-wildfire season inspections no later than June 15*
each year and mitigate noted"hot spots"and hazard trees.
Line Clearing Cycles:28 Strive to maintain 3-year Complete annual cycle pruning work plan.
cycle for valley areas and 6-year cycle for
mountain areas
Tree Removals—Hazard Trees Remove targeted hazard trees.
Targeted Pole Clearing Complete annually targeted structures.
100%CA/QC Audits in Tier 3 and Tier 2 zones Complete annual CA/QC audits.
Distribution Description
Pre-Wildfire Season Inspection and Mitigation Perform annual pre-wildfire season inspections no later than June 15*
each year in Tier 3 and Tier 2 zones and mitigate noted "hot spots"
and hazard trees.
Line Clearing Cycle:Strive to maintain 3-year cycle Complete annual cycle pruning work plan.
Mid-Cycle Pruning in Tier 3 and Tier 2 zones Complete annual mid-cycle pruning work plan in Tier 3 and Tier 2
zones.
Tree Removals—Cycle Busters/Hazard Trees Complete annual cycle pruning work plan.
Targeted Pole Clearing Complete annually targeted structures.
100%QA/QC Audits in Tier 3 and Tier 2 zones Complete annual QA/QC audits.
*Inclement weather may limit access to overhead electric facilities prior to June 15
9.2.1. Summary of Vegetation Management Activities and Schedules
Table 10
Idaho and Montana vegetation management inspection schedule*
Vegetation Management
Inspections and Activity Schedule Non-Risk Zone Tier 2 Zone Tier 3 Zone
Transmission
Hazard Tree Patrol on NERC/WECC Lines Annually Annually Annually
27 Throughout this document,the term"audit"is used in an informal context and does not mean a formal audit conducted by the company's
Audit Services Department.
8 Line Clearing Cycles—T&D clearing of lines defined on a periodic basis.
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Idaho Power Company Wildfire Mitigation Plan 2026
Vegetation Management
Inspections and Activity Schedule Non-Risk Zone Tier 2 Zone Tier 3 Zone
Cycle Patrol/Pruning—Valley Locations 3 Years 3 Years 3 Years
Cycle Patrol/Pruning—Mountain Locations 6 Years 6 Years 6 Years
Wildfire Mitigation Patrol/Pruning None None Annually
Cycle Buster Patrol/Pruning 18 Months 18 Months 18 Months
(Documented Cycle-Buster Trees)
Distribution
Wildfire Mitigation Patrol/Pruning None Annually Annually
Cycle Patrol/Pruning 3 Years 3 Years 3 Years
Mid-Cycle Patrol/Pruning None 2 Years after Cycle 2 Years after Cycle
Prune Prune
Cycle Buster Patrol/Pruning None Covered by Covered by
Mid-Cycle Mid-Cycle
Post-Pruning Audit Inspections Sampling 100% 100%
*Idaho Power strives to maintain the cycles identified herein.Idaho Power is working toward achieving the 3-year cycles identified in this table
but may not meet them in all instances.
9.2.2. 2026 Vegetation Management Targets
Table 11
2026 vegetation management targets*
Vegetation Management Initiatives 2026 Goal(ID)
Transition to a 3-Year Pruning Cycle(Circuits) 213
Annual Patrol—Tier 3&Tier 2 Risk Zones(Circuits) 139
Annual Mitigation—Tier 3&Tier 2 Risk Zones(Circuits) 139
Mid-Cycle Patrols—Tier 3&Tier 2 Risk Zones(Circuits) 15
Initiative
Mid-Cycle Pruning—Tier 3&Tier 2 Risk Zones(Circuits) 15
Identified Hazard Trees Pruned 100%of all identified
Identified Hazard Trees Removed 100%of all identified
Audits of Pruning Activities—Tier 3&Tier 2 Risk Zones(Worksites) 100%of all identified
*Idaho Power strives to meet the targets identified herein but may not meet them in all cases.
9.2.3. Fair Market Vaiue of Timber
If live marketable timber is identified for removal from timber company land adjacent to Idaho Power's
rights-of-way, compensation at fair market price will be made available to the landowner for such timber.
The process utilized to determine how fair market value was achieved will be documented and
consistent with the WSCA, Idaho Code § 61-1803(3)(g)(iii).
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Idaho Power Company Wildfire Mitigation Plan 2026
9.3. Transmission Vegetation Inspection and Management
Maintaining a vegetation-free clearance zone near transmission lines has long been a priority for Idaho
Power.The clearance zone is voltage-level dependent and defined by federal and state regulations.
9.3.1. Transmission Vegetation Inspections
Utility arborists annually conduct aerial and/or ground patrols on each applicable transmission line to
identify and mitigate vegetation hazards. In addition,transmission patrol personnel inspect all overhead
transmission lines operating at 46 kV or higher that are located within Tier 3 wildfire risk zones once a
year to identify transmission defects and vegetation hazards. During these inspections,the patrol
personnel identify hazardous vegetation, within or adjacent to the ROW, which could fall in or onto the
transmission lines or associated facilities.The patrol personnel also evaluate the hazardous vegetation
based on the level of potential threat posed, categorizing the vegetation as a higher priority,29 medium
hazard, or lower hazard. Hazardous vegetation found is reported to the utility arborist and documented.
Any hazardous vegetation categorized as higher priority and that presents a risk to cause an outage at
any moment is expected to be reported without any intentional time delay to the grid operator.
The utility arborist conducts a follow-up inspection if potential hazard trees or grow-ins are identified.
The utility arborist prioritizes and schedules remedial action for all reported vegetation issues.
9.3.2. Transmission Line Clearing Cycles
Transmission lines are cleared on long-term cycles based on three years for urban and rural valley areas
and six years for mountain areas.The duration of pruning cycles is influenced by vegetation type.Areas
dominated by slower-growing coniferous species, such as pine and fir, can often sustain longer
maintenance cycles due to slower crown expansion and reduced encroachment risk. In contrast, areas
with fast-growing deciduous species, such as cottonwood, willow, or aspen,generally require more
frequent pruning to maintain clearances and reduce the likelihood of contact with energized conductors.
The pruning cycle in mountain areas is longer than the cycle in valley locations because the trees in
mountain areas are almost entirely slower growing conifer species. In most cases,vegetation is cleared
primarily through manual cutting of targeted trees and tall shrubs. When appropriate, tree-growth
regulators and spot herbicide treatments are applied in compliance with federal or state requirements.
These treatments are effective for reducing regrowth of sprouting deciduous shrubs and trees and
extending maintenance cycles.
9.3.3. Transmission Line Clearing Quality Control and Assurance
Outside of wildfire risk zones, audits are performed on a random sample of pruning
worksites.These audits are performed through a combination of the contracted arborists that planned
the work and Idaho Power's utility arborists. In Tier 2 and Tier 3 zones, audits are performed on 100%of
29 Idaho Power defines"higher priority"vegetation as any vegetation condition likely to cause a line outage with a high risk of failure in the next
few days or weeks.Higher-priority vegetation could also be vegetation that is in good condition but has grown so close to the lines that it
could be brought into contact with the line through a combination of conductor sag and/or wind-induced movement in the conductor or the
vegetation.Assessing whether vegetation is a hazard or higher-priority requires the exercise of judgment.Idaho Power defines"higher-
priority vegetation"to be that which is designated in the opinion of the inspector.
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Idaho Power Company Wildfire Mitigation Plan 2026
pruning work.The audits are performed by a combination of contracted arborists and Idaho Power's
utility arborists to check if pruning cuts meet specification and proper clearance was achieved.This
quality control and assurance program has proven valuable.These audits have discovered trees that
were not properly pruned.As a result, Idaho Power requested the pruning contractor re-prune these
circuits to achieve satisfactory results.
9.4. Distribution Vegetation Inspection and Management
Idaho Power strives to clear distribution lines throughout the company's service area on a three-year
cycle. Additionally, in Tier 2 and Tier 3 zones, Idaho Power performs annual vegetation line inspections
and mid-cycle clearing of the lines in the second year.The following sections describe Idaho Power's line
clearing cycle and inspection processes.
9.4.1. Distribution Line Clearing Cycles
Idaho Power strives to clear distribution lines on a three-year cycle. In Tier 2 and Tier 3 zones,
Idaho Power strives to perform mid-cycle pruning in the second year to remove faster growing
vegetation to help clear lines of vegetation for the full pruning cycle. In addition, Idaho Power clears lines
on an "as-needed basis" in the situations where fast, unexpected growth occurs and is reported by an
employee or customer.
9.4.2. Distribution Vegetation Inspections
In addition to regular cycle pruning activities, utility arborists annually conduct ground patrols to identify
potential vegetation hazards of each distribution line in Tier 2 and Tier 3 zones. Distribution patrol
personnel also inspect the lines in Tier 3 and select Tier 2 zones annually. During these inspections,
patrol personnel identify infrastructure defects and hazardous vegetation, within or adjacent to the
ROWS,which could fall on to the distribution lines or associated facilities.The patrol personnel then
evaluate, based on their experience and judgment, the level of threat posed by the hazardous vegetation
by categorizing the vegetation as a higher priority, medium hazard, or lower hazard. Hazardous
vegetation found is reported to the utility arborist and documented. Any hazardous vegetation
categorized as a higher priority is also expected to be reported to the grid operator without any
intentional time delay.The utility arborist conducts a follow-up inspection if potential hazard trees or
grow-ins are identified.The utility arborist prioritizes and schedules any remedial action for all reported
vegetation issues.
9.4.3. Distribution Line Clearing Procedures
In most cases,vegetation is cleared as scheduled work and includes, but is not limited to,the pruning of
encroaching branches,the removal of dead branches overhanging power lines, weak branch
attachments, and dead or dying trees leaning toward Idaho Power facilities.Vegetation clearing methods
include crews using chainsaws or specialized pruning machines. Trees are cleared using a pruning
procedure called directional or natural pruning, a method recommended by the International Society of
Arboriculture, and the ANSI A300 standards.
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Idaho Power Company Wildfire Mitigation Plan 2026
When appropriate,tree-growth regulators and spot herbicide treatments are applied in compliance with
federal or state requirements.These treatments are effective for reducing regrowth of sprouting
deciduous shrubs and trees and extending maintenance cycles.
Through its VMP, Idaho Power has a target to maintain clearance distance between vegetation and
conductors as follows:
• Five feet for conductors energized at 600 through 50,000 volts.
• Clearances may be reduced to three feet if the vegetation is not considered to be readily
climbable because the lowest branch is greater than 8 feet above ground level.
• New tree growth no larger than % inch in diameter may intrude into this minimum clearance
area, provided it does not come closer than 6 inches to the conductor.This new growth is
identified during line patrols and removed.
• For conductors energized below 600 volts, vegetation is pruned to prevent the vegetation from
causing unreasonable strain on electric conductors.
Idaho Power strives to maintain these clearance distances throughout the full pruning cycle by using a
combination of routine patrols and proactive vegetation maintenance strategies.
9.4.4. Distribution Line Clearing Quality Control and Assurance
Similar to Idaho Power's vegetation audit process for transmission lines in non-wildfire risk zones, audits
are performed on a random sample of pruning worksites.Audits are performed through a combination
of contracted arborists and Idaho Power's utility arborists. In Tier 2 and Tier 3 zones, audits are
performed on all pruning work. If an audit indicates unsatisfactory results, such as improper pruning,
Idaho Power requests the pruning contractor re-prune circuits to achieve satisfactory results.
9.5. Pole Clearing of Vegetation
Idaho Power has historically cleared vegetation from the base of certain transmission wood poles and a
limited number of distribution wood poles in Idaho.These vegetation clearing practices are an effective
method of minimizing wildfire damage to existing wood poles and, at the same time, help to reduce the
ignition potential at the base of the pole. Where acceptable and permissible, Idaho Power removes or
clears vegetation in a 20-foot radius surrounding wood poles and applies a weed-control herbicide that
remains effective for several years.
Page 52

Section
6mkj
Additional
Preventative
Actions and
Programs

Idaho Power Company Wildfire Mitigation Plan 2026
10. Additional Preventative Actions and Programs
10.1. Wildfire Suppression and Response
Idaho Power field crews carry certain fire
suppression equipment for use pursuant to the 40
Wildland Fire Preparedness and Prevention Plan;
however,they are not professionally trained
firefighters and are instructed not to place
themselves in a hazardous position when responding
to wildfires. When responding to an active wildfire,
Idaho Power personnel take appropriate direction
from the incident commander(IC) or another fire
response entity official with jurisdiction over
the incident.
In 2024, Idaho Power began utilizing a contracted
wildland fire engine and wildland fire personnel in
certain situations to protect critical infrastructure,
provide situational awareness, and coordinate with
wildfire incident command. For example, in 2025Mt
Idaho Power deployed wildland fire personnel to the
Rock Fire near Tamarack Ski Resort in Idaho.
In addition to attending daily situation briefings with
incident command, contracted fire personnel cleared
Figure 12
vegetation and wrapped wood distribution poles Wildland fire personnel clear vegetation and wrap poles
threatened by a nearby wildfire. during the Rock Fire in Idaho,2025.
Based on the benefits demonstrated over the past two wildfire seasons, Idaho Power is evaluating
options to continue to achieve these benefits moving forward.
10.2. Pilot Projects
Idaho Power uses pilot projects to learn about and assess the risk reduction benefits of newer mitigation
approaches and/or technologies. Pilot projects may be considered as a complement to or alternative for
existing risk mitigation approaches.These projects support learning with respect to cost, labor, and time
requirements and inform risk-based decisions when comparing, selecting, and prioritizing mitigation
strategies for the future.
10.2.1. Standby Helicopter Services: Pre- and Post-Event Inspections (Pilot)
Project Overview and Status:To support PSPS and post-event restoration, Idaho Power uses a pilot
project with standby helicopter service to conduct pre-storm patrols, assess de-energized or damaged
lines following a PSPS or wildfire, and expedite power restoration efforts. Helicopter access enhances
Idaho Power's ability to assess risks and minimize customer impacts associated with wildfire events. Due
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Idaho Power Company Wildfire Mitigation Plan 2026
to limited availability of regional aviation resources during peak wildfire season, a standby contract
structure promotes aircraft availability when needed.
Based on the benefits demonstrated over the past two wildfire seasons, Idaho Power plans to continue
using standby helicopter service in 2026 to promote timely patrols and restoration efforts when Idaho
Power determines appropriate based on considerations such as access or distance.
10.2.2. Fuels Reduction Shared Stewardship (Pilot)
Initiative Overview and Status:Since 2023,
Idaho Power has participated in multiple
partner-initiated fuels reduction projects that exhibit
potential for reducing wildfire risk adjacent to Idaho
Power rights-of-way and wildfire risk zones.
The purpose of this effort is to enhance forest
resilience to wildfire, decrease hazardous fuel
accumulations near Idaho Power infrastructure,
and increase powerline resiliency while minimizing
the risk of ignitions. Established project partners 7
include IDL, the U.S. Forest Service (USFS),the BLM, c "
the National Forest Foundation, and local counties.
Figure 13
Additionally, Idaho Power serves on a cross-utility Salmon transmission line corridor pre-treatment
committee focused on sharing lessons learned and (2025)
fostering innovative approaches for partner-driven
fuels mitigation programs.
In 2026, Idaho Power plans to continue to seek out and engage in partner-initiated fuels reduction
projects that exhibit meaningful potential for reducing wildfire risk adjacent to Idaho Power rights of way
and wildfire risk zones, and any future WMPs will include any collaborative fuels reduction projects.
10.2.3. Line Monitoring Technology (Pilot)
Initiative Overview and Status: Idaho Power has begun a
pilot project incorporating line monitors into its distribution
system on selected circuits located within, or traversing
through,wildfire risk zones. Line monitors are devices
installed on overhead powerlines that use advanced
sensing technologies that may help provide real-time data
about the condition and performance of the electrical grid.
The integration of line monitors with wildfire mitigation
efforts may provide multiple benefits, including fault
detection, historical perspective on fault locations, and Figure 14
transient capture capabilities. Salmon transmission line corridor post
treatment(2025).
Page 54

Idaho Power Company Wildfire Mitigation Plan 2026
To determine installation locations, Idaho Power evaluates candidate areas within wildfire risk zones
where the circuit segment serves fire-prone terrain. Site selection is further guided by the availability of
reliable cellular communications, which is essential for real-time data transmission.The company
prioritizes feeder segments located outside substations and at locations along the line where, in Idaho
Power's opinion,visibility into system behavior would provide potential operational benefit.
The company plans to install approximately 30 new communicating line monitors in Idaho in and around
selected wildfire risk zones in 2026. Data will be collected and analyzed using advanced analytics in
partnership with the equipment vendor. The goal of the pilot project is to determine effectiveness of the
advanced line monitors in identifying potential arcing and early detection of failing devices.
10.2.4. Covered Conductor(Pilot)
Initiative Overview and Status: Idaho Power is piloting covered conductor as an additional alternative
for wildfire risk reduction.As a field trial in 2024, Idaho Power installed approximately one mile of
covered conductor, including single-phase and three-phase distribution, in a Tier 3 wildfire risk zone near
Pocatello, Idaho.The objective of the trial was to understand the feasibility of construction and
maintenance, as well as prepare construction standards, identify required material and equipment, and
establish safe and efficient work practices.The insights gained are refining the company's designs,
construction standards, and processes for broader implementation.
Idaho Power intends to continue the pilot project in 2026,targeting the installation of approximately one
mile of a 34.5-kV distribution circuit.This phase of the pilot project will evaluate the feasibility of
installing covered conductor at this higher distribution voltage, which requires more complex live-line
construction methods, specifically,the exclusive use of hot sticks. Building on the lessons learned from
phase one,this next phase will assess the tools,techniques, and overall viability of hot-stick installation.
10.2.5. 3-D Pole Loading (Pilot)
Initiative Overview and Status:As part of an ongoing pilot project, Idaho Power has contracted with a
company who is using modeling software that creates 3-D representations of selected Idaho Power
structures and surroundings in Tier 3 wildfire risk zones to improve understanding of potential loading
constraints on equipment that could lead to a failure.This effort involves analyzing the structural
integrity of utility poles to assess whether they can withstand various forces, such as wind, weight of
equipment, and other environmental factors.These assessments help identify structural deficiencies
based on pole class and the amount of equipment and joint use attachments installed.
The pilot project will be extended through 2026 to continue evaluating capabilities, refining
methodologies, and gathering additional insights that may inform future asset management practices.
10.2.6. High Impedance Relay Protections (Pilot)
Initiative Overview and Status: Idaho Power is piloting high impedance fault locating in selected wildfire
risk areas in collaboration with our recloser equipment vendor.This effort involves installing, configuring,
and testing advanced and modified Form 7 recloser controls at five selected locations, each connected
with wireless SCADA connectivity for remote monitoring.The goal of the pilot project is to develop a set
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Idaho Power Company Wildfire Mitigation Plan 2026
of advanced high impedance fault configuration parameters and sensing capabilities to successfully
detect high impedance faults in the future while minimizing the false positive events prevalent in
previous industry attempts to detect high impedance faults.
The company expects the pilot project to run over the next two years to continue evaluating, calibrating,
and gathering event history and performance data to determine the viability of
expanded implementation.
10.2.7. FAA Waivers and Aerial Drone Inspections (Pilot)
In 2025,the company secured two waivers: one authorizing patrolmen and drone pilots to hand-launch
and operate drones beyond visual line of sight(BVLOS), and a second permitting remote operation of
drones from locations separate from the inspection area.
In 2026, Idaho Power anticipates using these drone capabilities in transmission and distribution
inspections in the following ways:
• Drones may be deployed at Idaho Power's discretion to support PSPS patrols in certain locations
by performing aerial inspections of de-energized circuits prior to re-energization.
• Drones may be used at Idaho Power's discretion with outage response following operations of
EPS, allowing patrolmen to quickly identify potential damage or issues requiring corrective
action.
• Drones may be used for routine targeted asset inspections. In 2026, Idaho Power anticipates
using drones to inspect approximately 10,000 poles in wildfire risk zones,with a target of up to
23%. Poles to be inspected by drone will be selected at Idaho Power's discretion.
These applications will be coordinated with existing inspection resources, including ground line,
helicopter standby, and contracted aerial services.
Page 56

Section
LMM kilm
Public
Outreach and
Engagement

Idaho Power Company Wildfire Mitigation Plan 2026
11. Public Outreach and Engagement
11.1. Objective
Communication is an important part of Idaho Power's wildfire mitigation efforts. Idaho Power engages in
community outreach and public awareness efforts before, during, and after wildfire season to inform the
public of wildfire risks and to notify the public of wildfire-related outages. Idaho Power communicates
information about this WMP and wildfire risk in general to employees, customers, government officials,
the public, and other stakeholders.The following objectives guide wildfire-related communications:
1. Educate customers about how to prepare for wildfire-related outages, including where to
find outage and PSPS information and how to update contact information to enhance
communication regarding any potential outage events.
2. Raise awareness about Idaho Power's wildfire mitigation work.
3. Explain how customers can reduce wildfire risk.
11.2. Community Engagement
Idaho Power presents and distributes information on its WMP to a wide variety of stakeholders,
including state and local public safety partners, critical facilities, and customers.
Each year, Idaho Power organizes an education campaign focused on wildfire risk and outage
preparedness.These campaigns promote the company's wildfire mitigation activities and customer
outage communication, provide awareness and education on preparing for wildfire season, and publicize
ways customers can prevent wildfires.The communication is intended to educate stakeholders, whether
they reside in wildfire risk zones or not, about Idaho Power's wildfire mitigation efforts, including when
Idaho Power may need to deploy a PSPS, and how stakeholders will be alerted during these events.
11.2.1. Public Safety Partners
Annually, before wildfire season, communications begin with public safety partners, including the State
of Idaho ESF-12, county emergency managers, LEPCs, other public safety partners, local elected officials,
and health and human service agencies. Through individual conversations, larger presentations, and
public open-house events, Idaho Power provides an overview of its WMP and discusses outage
preparedness, including how to prepare for a PSPS.
11.2.2. Critical Facilities
Idaho Power conducts focused engagement with critical facilities in areas where it has infrastructure and
equipment. Critical facilities are those identified by Idaho Power and include, but are not limited to,
hospitals, police and fire stations, wastewater treatment facilities, and telecommunication providers.
During these interactions, Idaho Power works to update contact information and communication
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Idaho Power Company Wildfire Mitigation Plan 2026
preferences, provides an overview of the communication process during a PSPS, and shares outage
preparedness tips.
11.2.3. Customers
Idaho Power's customer-targeted outreach efforts include Idaho Power-hosted public meetings and open
houses focused on outage preparedness, safety, and wildfire prevention, including PSPS.These efforts
are complemented by participation in coordinated preparedness events led by community-based
organizations,further strengthening local engagement. Outreach includes virtual meeting options in
English and Spanish. Specific topics covered during these events include the following:
• Outage preparedness tips
• Idaho Power's wildfire mitigation efforts
• Tools to prevent wildfires, including PSPS
• Options to help customers manage their accounts and stay informed, including Idaho Power's
app and outage alerts
Access and Functional Needs Customers
To ensure messaging reaches access and functional needs (AFN) customers, Idaho Power collaborates
with community organizations focused on providing services and supplies to AFN individuals as a
strategy to share outage preparedness information.The content includes considerations for older adults
and individuals with disabilities and information about medical equipment considerations during an
outage, emphasizing the importance of battery backups.
11.2.4. Lessons Learned from 2025 Community Engagement Efforts
In 2025, attendance at community engagements varied significantly, with an average of eight customers
per event. Some of the Idaho Power-hosted open houses drew no participants. In contrast, participation
in community-based organized events saw the highest turnout with customer counts at a handful of
these events exceeding 300. Additionally,virtual meetings were offered in both English and Spanish.
Recorded versions of the virtual meetings were also linked on Idaho Power's website for customers to
view at their convenience.
The company's 2025 outreach efforts are summarized in Table 12.
Table 12
Idaho Power community engagement,2025
Date Details Date Details
March 29 Emmett,ID Preparedness Fair May 6 Salmon, ID Open House
April 3 Horseshoe Bend,ID Open House May 7 Virtual Meeting—English
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Idaho Power Company Wildfire Mitigation Plan 2026
Date Details Date Details
April 8 Garden Valley,ID Open House May 8 Virtual Meeting—Spanish
April 9 Gooding, ID Open House May 13 American Falls,ID Open House
April 10 Burley,ID Open House May 15 Blackfoot,ID Open House
April 23 Twin Falls, ID Open House May 17 Boise, ID Preparedness Fair
April 24 Weiser, ID Open House May 17 Pine, ID Presentation
April 26 Caldwell, ID Emergency Preparedness Fair May 22 Council, ID Open House
April 28 Idaho City,ID Open House May 27 Riggins, ID Open House
April 30 Fruitland, ID Open House May 28 McCall, ID Open House
April 30 Hailey,ID Open House May 29 Cascade,ID Open House
May 1 Fairfield, ID Presentation May 29 Pocatello,ID Open House
May 6 Marsing,ID Open House June 26 Virtual Meeting—Unique Medical or Mobility Needs
Idaho Power conducted two surveys to gather feedback and guide future community engagement
strategies.
• The first survey was distributed to attendees of the Outage Preparedness Open-house events.
The feedback from this survey, albeit with very limited participation, validated Idaho Power's
public open-house events with nearly all respondents rating the outage preparedness (92%) and
wildfire prevention (96%) information as helpful.
• The second survey was distributed to a broad group of customers in July 2025 through Idaho
Power's Empowered Community participants,who have volunteered to regularly provide
feedback to Idaho Power on a variety of topics. Insights from the Empowered Community survey
revealed that a majority(62%) of customers prefer virtual events versus in-person events, when
available.
As Idaho Power prepares for the 2026 wildfire season,the insights gathered from both surveys, along
with other anecdotal feedback from customers, serve as a foundation for a strategic shift in outreach
efforts. Rather than continuing the model of hosting in-person events in every Idaho county, Idaho
Power will focus on delivering outage preparedness, wildfire mitigation, and PSPS education through a
combination of virtual meetings and collaborative events with community-based organizations.This
approach reflects customer preferences for more accessible formats and leverages partnerships that
have consistently drawn higher participation. As highlighted above, 62%of customers favor virtual
events when available, and 46% indicated they would be more likely to attend if Idaho Power partnered
with other organizations—highlighting the value of flexibility and collaboration in future
engagement strategies.
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Idaho Power Company Wildfire Mitigation Plan 2026
MIA
Figure 15
Public open house meetings throughout Idaho Power's service area
11.3. Event-Specific Communication
During PSPS and wildfire events, Idaho Power uses communication and event management tools,
including dedicated Idaho Power employees focused on ensuring consistent and accurate
communication,to effectively manage the events and communicate with customers.
11.4. Key Communication Methods
Idaho Power communicates with customers and the public through a variety of channels to help
maximize reach and effectiveness:
• Connections (monthly newsletter to customers)
• Videos
• Email
• News media (news releases, appearances on broadcast TV and radio shows, interviews, etc.)
• Social media
• Printed materials, including flyers and bill inserts
• Idaho Power's website: idahopower.com/wildfire
• Paid advertising (e.g., radio, digital)
At the end of each wildfire season,feedback from customer surveys and campaign metrics from paid
media advertising help inform and refine the approach for the next year.
11.5. Timing of Outreach
Wildfire-related outreach occurs primarily before and during wildfire season.The timing of preseason
wildfire outreach depends on weather conditions. Holding key communications until wildfire is more
prominently on people's minds increases the likelihood people will hear and retain the messages.
Early communications encourage customers to think about wildfire season, how to prepare for outages,
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Idaho Power Company Wildfire Mitigation Plan 2026
their role in preventing wildfires, and steps Idaho Power is taking to mitigate wildfire risk. When the
potential for wildfire increases, the tone and messaging shifts. Messaging urges customers to update
their contact information, prepare for wildfire, and help prevent wildfires while recreating. After wildfire
season and throughout the winter months, Idaho Power's wildfire-related outreach focuses on the
ongoing efforts to reduce risk, including feeder hardening,vegetation management, and asset
inspections.The messaging continues to offer tips for year-round outage preparedness.
11.6. Idaho Power Internal Communications — Employees
Idaho Power communicates wildfire messages to its employees in a variety of ways:
• News Scans (internal newsletter for all employees)
• Emails
• Leader communications
• GIS-based visual communication of risk zones and affected overhead lines
• Online training for employees about the WMP
• In-person, hands-on, training for certain field employees
• Mock events
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Idaho Power Company Wildfire Mitigation Plan 2026
Page 62

llk� Section
Government,
Industry, and
Peer Utility
Outreac
h

Idaho Power Company Wildfire Mitigation Plan 2026
12. Government, Industry, and Peer Utility Outreach
12.1. Objective
Idaho Power's WMP and outage preparedness strategy includes specific activities to engage with key
stakeholders to share information, gain feedback, and incorporate lessons learned. Idaho Power engages
in outreach efforts to coordinate with federal, state,tribal, and local officials and agencies on wildfire
preparedness and emergency response plans.
Idaho Power recognizes the importance of engaging with various levels of government. Idaho Power also
recognizes the importance of engagement and outreach with respect to potential future PSPS events to
minimize customer impact. Peer utility engagement informs the company's efforts by learnings of
its peers.
12.2. Government Engagement
Prior to the start of wildfire season, Idaho Power offers to meet with state and federal land-management
agencies in Idaho and Montana to review the company's approach for wildfire mitigation and discuss
wildfire season operations.Throughout the year, Idaho Power engages with federal, state, and county
agencies to share information, receive feedback on mitigation approaches (including vegetation
management practices), and to identify and work toward activities that are mutually beneficial and may
be considered in subsequent WMPs. For example, in 2024, Idaho Power participated in a wildfire
roundtable hosted by Idaho Governor Brad Little and Lt. Governor Scott Bedke. From this effort,the
Governor's Office produced a report outlining 10 Idaho-specific priorities to reduce the impacts of
wildfire.30 Throughout 2025, Idaho Power worked with state-level partners in support of certain
recommendations. Idaho Power additionally participates in a Drought and Wildfire Technical Working
Group (TWG)through the Idaho Office of Emergency Management(IOEM).The TWG is used to provide
expertise and detail to help inform the State Hazard Mitigation Plan. Beyond the TWG, Idaho Power also
engages with IOEM's area field officers, county emergency managers, LEPCs, local public safety partners,
mayors, county commissioners, and other key local stakeholders.
In 2025, Idaho Power participated in a two-day wildfire summit in Helena, Montana, convened by
Northwestern Energy.The focus of the summit was to bring together federal, state, and local agencies
and organizations to discuss wildfire risk reduction goals and provide insight and perspectives on wildfire
mitigation. Idaho Power presented on company learnings from the 2024 wildfire season at the forum.
Idaho Power engages with its regulators with respect to wildfire mitigation activities.
12.3. Peer Utility Engagement
Idaho Power's WMP is informed by peer benchmarking and utility wildfire-specific forums. Idaho Power
engages with peer utilities from the Pacific Northwest, Rocky Mountain, and California regions, including
but not limited to:Avista Utilities, Rocky Mountain Power, PGE, Pacific Power, Chelan County Public
ao Wildfire Report Recommendations,August 2024.Available at:IOEMADMINCOPIER-20240418092717
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Idaho Power Company Wildfire Mitigation Plan 2026
Utility District, Puget Sound Energy, Excel Energy, NV Energy, BPA, Northwestern Energy, San Diego Gas
and Electric(SDG&E), Southern California Edison, Pacific Gas and Electric (PG&E), Sacramento Municipal
Utility District (SMUD), and Liberty Electric.
Prior to the start of the 2025 Wildfire Season, Idaho Power hosted the Western Energy Institute's annual
Wildfire Conference that brought together many of the utilities listed above for sharing of WMP best
practices, common challenges, and innovative solutions for minimizing wildfire risk. In May of 2025,
members of Idaho Power's Wildfire Mitigation team attended the second annual convening of PG&E's
Near-Term, Risk Informed Wildfire Mitigation Strategies for Utilities conference. More than 150
attendees from utilities across the U.S. came together in California for two days of panel-style
discussions on topics ranging from wildfire mitigation technology, customer engagement, PSPS protocols,
and fire-weather forecasting.
Additionally, Idaho Power is a member of trade-based organizations that offer wildfire-specific forums
and discussions, including the IWRMC, Edison Electric Institute (EEI), and Western Energy Institute (WEI).
These forums facilitate sharing of information. For example, the IWRMC was designed as an
industry-sponsored collaborative forum that facilitates the sharing of wildfire risk mitigation insights and
innovations from across the globe.
Idaho Power also participates in monthly workgroup forums through IWRMC for operations and
protocols, asset management, vegetation management, and risk management.These workgroup forums
inform operational preparedness for wildfire season as well as provide insight into global thinking and
advancements in wildfire mitigation. IWRMC is led by a Utility Executive Steering Group,whose
members work specifically on wildfire/bushfire issues in Australia and the western U.S. Idaho Power's
engagements with IWRMC are focused on operations and protocols, asset management, vegetation
management, and risk management with additional participation from Idaho Power's vice president (VP)
of Planning, Engineering, and Construction in IWRMC's Executive Strategy Forums.
Idaho Power's CEO and president is a member of the EEI Electricity Subsector Coordinating Council
Wildfire Working Group.This working group has been coordinating with the U.S. Department of Energy
(DOE) and other government agencies to collectively address wildfire threats and potential impacts.
Page 64

Section
Ll— —3�
Performance
Monitoring

Idaho Power Company Wildfire Mitigation Plan 2026
13. Performance Monitoring
13.1. WMP Compliance
The company's Chief Operating Officer(COO) is the designated oversight officer for Idaho Power's WMP.
The VP of Planning, Engineering & Construction is responsible for compliance monitoring, necessary
training, and annual review of this WMP.
13.2. Annual Review and Compliance Reporting
Idaho Power conducts an annual review of its WMP and incorporates necessary updates based on the
learnings of the most recent wildfire season. Compliance reports will be submitted to the IPUC on an
annual basis, or on such other basis as the commission may prescribe.
13.3. 2025 Lessons Learned
13.3.1. Community Outreach and Engagement
Throughout 2025, Idaho Power experienced key learnings about community outreach efforts. Between
March and June of 2025, Idaho Power hosted 26 in-person and online events intended to reach
customers regarding outage preparedness,wildfire mitigation, and PSPS education.Attendance at
community engagements varied significantly with an average of eight customers per event,though some
Idaho Power-hosted open houses had no customers attend. In contrast, participation in
community-based organized events saw the highest turnout, with customer counts exceeding 300.
Idaho Power hosted two surveys in the past year that included questions about customer outreach
preferences. Survey results indicated 62%of customers favored virtual events when available, and 46%
indicated they would be more likely to attend if Idaho Power partnered with other organizations —
highlighting the value of flexibility and collaboration in future engagement strategies. Idaho Power is
building from these learnings to improve its overall approach for 2026, which is elaborated on in
Section 11.2.
13.3.2. Fire Weather Station Network
Building on lessons learned during the 2024 wildfire season, Idaho Power installed 85 new fire weather
stations in 2025 intended to enhance weather station coverage. Weather station coverage helps refine
models,forecasts, and operational decision making around powerline safety. Idaho Power's efforts to
improve the weather station network also provides benefit to public partners, including the National
Weather Service.31 The company plans to continue this work throughout 2026.Section 4.5 of the WMP
elaborates on Idaho Power's weather station efforts.
ai Social Media Video on Idaho Power Fire Weather Station Efforts:facebook.com/watch/?v=1469080987564737
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Idaho Power Company Wildfire Mitigation Plan 2026
13.3.3. Aeriai Inspections
In 2025,the company launched its first-year aerial inspections pilot project using unmanned aerial
systems (UAS)to inspect distribution assets.The company completed 5,953 inspections of distribution
poles in wildfire risk zones, exceeding the 5,000-pole target for the year.The pilot project used
contractors for image collection, desktop inspections,and independent quality-assurance checks,
with confirmed issues routed for correction. A key lesson learned is that developing internal data storage
systems for drone imagery will enhance the usability of data.
Building on these results, in 2026,the company will evaluate an enterprise imagery application with a
focus on future integrations to geographic information systems (GIS) or other internal systems to
broaden business use of the images.The pilot project also showed that aerial inspections provide a
complementary vantage point to traditional ground patrols. Based on these lessons, Idaho Power's
intended use of drones in 2026 is described above in Section 10.2.7.
13.3.4. PSPS Event Management Tools and Processes
In 2025,the company began developing an Event Management Software (EMS)to support PSPS
execution.This effort included refreshed customer communications (e.g.,text-to-voice with do-not-
disturb, updated templates and cause codes, and aligned estimated time of restoration).The project also
resulted in outage-map improvements, new critical-facility outreach workflows, and a dashboard
reporting tool that will be used in 2026.
As the company made improvements throughout the year, progress showed that centralizing PSPS data,
decisions, and messaging can help improve operational consistency. In 2026, the Company will continue
maturing event management capabilities and customer communications, focusing on exploring training
and technology.
Page 66

Section
I= 4
WMP
Cost
Summary
tk u
J

Idaho Power Company Wildfire Mitigation Plan 2026
14. WMP Cost Summary
In 2026, Idaho Power estimates investing$53 million in operations and maintenance (O&M) expenses in
Idaho to further wildfire mitigation measures.Table 13 summarizes the company's planned O&M
expenditures associated with executing its 2026 Idaho and Montana WMP. Estimated amounts reflect
the company's best estimates and plans as of October 2025.These estimates will likely change in the
future as the company reviews and refines its WMP and associated mitigation activities.
Idaho Power's wildfire mitigation efforts also include capital investments in system infrastructure,
many of which also provide co-benefits to the company, such as increased safety, reliability,
and resiliency of the system as identified in Section 3.4 (Table 3). Capital investment programs are
summarized in Table 14.
Table 13
Estimated O&M expenses for wildfire mitigation,$000s(2026)*
Wildfire Mitigation Program Description 2026 Forecast
A.Geographical Risk Assessment
Risk Modeling-Risk Maps, Fire Simulation,Probabilistic Model Development and Support $2,236
B.Situational Awareness and Monitoring
Weather Forecasting-System development and support,data services,climatology $72
Weather Forecasting Personnel-FPI and PSPS $202
Weather Forecasting-Weather Station Maintenance $234
Pole Loading Modeling&Assessment(Contract service) $72
Wildfire Detection Cameras $254
C.Workforce Preparedness
Tools/Equipment $34
International Wildfire Risk Mitigation Consortium $38
D.Infrastructure Inspection and Asset Management
0&M Component of Capital Work $391
Annual O&M T&D Patrol Maintenance Repairs $187
Transmission Thermography Inspection Mitigation $48
Distribution Thermography Inspection Mitigation $48
Thermography Technician Personnel $165
Transmission Wood Pole Fire Resistant Wraps $250
Wildfire Mitigation Program Labor $1,194
Patrolmen for Wildfire Pre-Season Inspections in Wildfire Risk Zones $157
Covered Wire Evaluation-Pilot Program in PSPS Zones $14
Drone Beyond Visual Line of Sight Waiver for PSPS Patrols $0
Aerial Drone Inspection Pilot $675
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Idaho Power Company Wildfire Mitigation Plan 2026
Wildfire Mitigation Program Description 2026 Forecast
E.Vegetation Management
Transition to/Maintain 3-year Vegetation Management Cycle(includes Enhanced Practices for $45,282
Distribution Tier 3&Tier 2 Risk Zones)
Internal Tree Trimming Crew $381
Line Clearing Personnel $198
Fuel Reduction Program $72
F.Public Outreach and Engagement
Wildfire/Wildfire Mitigation Education/Communication-Advertisements,Bill Inserts, $164
Meetings,Other&PSPS Customer Education/Communication-Advertisements,Bill Inserts,
Other
Public meetings/event fees for PSPS engagement,maps,flyers $8
Community and Customer Engagement and Outreach $160
G.Line Operations Practices PSPS/Emergency Preparedness and Technology
Communication/Alert Tool development(System set up,outage maps,critical facilities $0
identification)
Communication/Alert Tool for PSPS Customer Alerts/Extended Use $215
Fire Suppression Resources $183
Standby Helicopter Service $536
Community Resource Centers $5
Total $53,473
*As of October 1,2025.These are best-known estimates at the time of this WMP's filing and are subject to change.These numbers are
provided only for the purpose of review and approval of this WMP pursuant to the WSCA.They should not be used for any other purpose.
Table 14
2026 WIMP forecasted capital investments, $000s($)*
Mitigation Program Program Description 2026 Planned in Service
Overhead Primary Replacement and upgrades of $19,500
Hardening Program hardware and equipment
Strategic Undergrounding Select conversion of overhead to $12,000
underground distribution in Tier 3
Risk Zones
Recloser Segmentation and Installation,relocation,and $200
Communication Upgrades expanded communication for
automatic reclosing overcurrent
protection devices
Wildfire Detection Cameras Cameras enabled with artificial $50
intelligence to detect smoke and
notify first responders
Atmospheric Science Installation of weather stations to $1,223
Weather Stations gain situational awareness
*These are estimates only.The costs may increase or decrease due to such factors as inflation or scope changes.These numbers are provided
only for the purpose of review and approval of this WMP pursuant to the WSCA.They should not be used for any other purpose.
Page 68

IDAHO & MONTANA
WILDFIR
MITIGATIO
PLAN1.
1
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Wildland Fire Preparedness
and Prevention Plan ,
NIQAHO POWER.

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Wildland Fire Preparedness
and Prevention Plan
October 2025
0 2025 Idaho Power

Wildland Fire Preparedness and Prevention Plan Idaho Power Company
Table of Contents
1. Plan Overview......................................................................................................................... 1
A. Intent of Plan.................................................................................................................. 1
B. Scope of Plan.................................................................................................................. 1
2. Situational Overview and Applicability.................................................................................... 1
A. Wildfire Season .............................................................................................................. 1
B. Wildfire Risk Zones......................................................................................................... 1
C. Fire Potential Index ........................................................................................................2
D. Decision Making for Field Work Activities......................................................................2
3. Preparedness—Tools and Equipment.....................................................................................4
A. Required Personal Protective Equipment.......................................................................4
B. Required Tools and Equipment ......................................................................................4
C. Land Management Agency Restrictions and Waivers.....................................................5
4. Prevention—Practices of Field Personnel ...............................................................................6
A. General Employee Practices...........................................................................................6
B. Behaviors Relating to Vehicles and Combustion Engine Power Tools ............................8
5. Reporting ..............................................................................................................................10
A. Fire Ignition ..................................................................................................................10
B. Fire Reporting...............................................................................................................10
6. Training.................................................................................................................................10
7. Roles and Responsibilities.....................................................................................................11
8. Audit .....................................................................................................................................12
Page i

Wildland Fire Preparedness and Prevention Plan Idaho Power Company
Page ii

Wildland Fire Preparedness and Prevention Plan Idaho Power Company
1. Plan Overview
A. Intent of Plan
The purpose of this Wildland Fire Preparedness and Prevention Plan (Plan) is to provide
guidance to Idaho Power Company (IPC) employees to help prevent the accidental ignition and
spread of wildland fires (wildfires) associated with employee work activities in locations and
under conditions where there is a heightened risk of wildfire. It is expected for applicable IPC
employees be aware of the provisions of this Plan and operate in accordance with the Plan.
B. Scope of Plan
The scope of this Plan extends to tools, equipment, and field behaviors IPC employees
incorporate when working in locations and under conditions where there is a heightened risk of
wildfire. Other fire mitigation activities, such as operations of Transmission and Distribution
(T&D) lines facilities, vegetation management, and T&D lines programs that mitigate wildfire
risks are not included in this Plan; they are referenced in the separate Wildfire Mitigation Plan
(WMP).
2. Situational Overview and Applicability
A. Wildfire Season
The provisions of this Plan shall be applicable during wildfire season. Idaho's wildfire season is
defined by Idaho Code § 38-115 as extending from May 10 through October 20 each year, or as
otherwise extended by the director of the Idaho Department of Lands (IDL). Montana's wildfire
season is defined by Montana Code § 76-13-102 as the period of each year beginning May 1 and
ending September 30. Oregon's wildfire season is designated by the State Forester each year
pursuant to Oregon Revised Statute § 477.505 and typically begins in June.
Should any local, state, or federal government land management agency (i.e., the Bureau of
Land Management [BLM], U.S. Forest Service, Oregon Department of Forestry, IDL, etc.) issue
any wildfire related order that extends wildfire season beyond that specified above,
that agency's order shall govern.
Many variables—drought conditions, weather, and fuel moisture—can impact fire potential.
Flexibility,judgment, attention to current and forecasted field conditions, and attention to
governmental agency issued wildfire orders are necessary such that operational practices can
be adjusted accordingly.
B. Wildfire Risk Zones
IPC's WMP includes a Wildfire Risk Map of areas where IPC has infrastructure or equipment.
This Wildfire Risk Map may be accessed through geographic information system (GIS)
Page 1

Wildland Fire Preparedness and Prevention Plan Idaho Power Company
applications. All lands in the vicinity of IPC facilities are mapped as Tier 2 (colored yellow on
maps), Tier 3 (colored red on maps), or areas of lesser wildfire risk (i.e., not within a Tier 2 or
Tier 3 zone). Tier 2 and Tier 3 zones are designated as wildfire risk zones (WRZ). The provisions
of this Plan shall apply to work activities taking place during wildfire season in WRZs.
C. Fire Potential Index
IPC's Atmospheric Sciences department has developed a Fire Potential Index (FPI) rating system
that forecasts wildfire potential in WRZs. The FPI consists of a numerical score ranging from 1 to
16. The FPI scores are grouped into the following three index levels:
1. Green: FPI score of 1 through 11
2. Yellow: FPI score of 12 through 14
3. N: FPI score of 15 through 16
During wildfire season, IPC will determine a daily FPI as described in Section 4.2 of the WMP for
each of IPC's WRZs. The FPI information is contained within IPC GIS viewers available to
applicable IPC employees.
D. Decision Making for Field Work Activities
Employees working in the field shall be aware of current and forecasted weather and field
conditions. The following process steps shall apply to Idaho Power employees contemplating
field work during wildfire season.
Planned or Scheduled Work Activities
1. Employees working in the field in a WRZ and not working on transmission or primary
distribution lines should:
1.1. Be aware of the current and forecasted weather and the FPI level for the area where
the work will be performed, through the FPI dashboard.
1.2. Once the FPI level for the work zone is identified, proceed with work but consider using
Prevention—Practices of Field Personnel (see Section 4 of this Plan).
2. Employees working in the field in a WRZ and working on transmission or primary
distribution lines should:
2.1. Be aware of the current and forecasted weather and the FPI level for the area where
the work will be performed.
2.2. Once the FPI level for the WRZ is identified, proceed as follows for each FPI level:
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Wildland Fire Preparedness and Prevention Plan Idaho Power Company
2.2.1. — in All Zones: Proceed with the work. Evaluate need for using
Prevention—Practices of Field Personnel (see Section 4 of this Plan).
2.2.2. Yellow FPI in All Zones: Proceed with the work. Evaluate need for using
Prevention—Practices of Field Personnel (see Section 4 of this plan).
2.2.3.
• In Tier 2 Zone: Proceed with the work. However, it is a requirement to follow
Prevention—Practices of Field Personnel (see Section 4 of this plan).
• In Tier 3 Zone: STOP. No planned work activities shall take place unless
approved by operations level manager. Work consideration will be restoration
of electric service or work deemed critical to providing safe, reliable electric
service. If work is approved to proceed, it is a requirement to follow
Prevention—Practices of Field Personnel (see Section 4 of this plan).
Tier 2 Tier 3
Proceed with Work STOP/NO WORK
Use Prevention—Practices of Field
Personnel
a REQUIRED
LL
x Proceed with Work Proceed with Work
ai 3
c a) Use Prevention—Practices of Field Use Prevention—Practices of Field
> Personnel(evaluate conditions Personnel(evaluate conditions
wN and use as needed) and use as needed)
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3. Land Management Agency Restrictions
3.1. Follow the requirements and restrictions of any wildfire restrictions-related order
issued by local, state, or federal land management agencies.
3.2. As soon as reasonably practicable, upon receiving knowledge of an order,
the Environmental Affairs department will notify, via email, operations leadership
within Power Supply, Customer Operations and Business Development, and T&D
Engineering and Construction of wildfire-related requirements and restrictions orders
issued by local, state, or federal land management agencies.
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Wildland Fire Preparedness and Prevention Plan Idaho Power Company
Emergency Response and Outage Restoration Work Activities
Follow the same steps as identified above for planned work activities. However, it is recognized
that the nature of emergency response and outage restoration situations will often require
exceptions to the above. In these situations, leadership should be consulted, and work will be
undertaken at Idaho Power's discretion given the nature of the emergency or outage at hand.
3. Preparedness—Tools and Equipment
A. Required Personal Protective Equipment
Standard IPC personal protective equipment (PPE) shall be worn in accordance with the IPC
Safety Standards.
When entering a designated fire area being managed by the BLM or the U.S. Forest Service,
additional PPE requirements may be required by those agencies. These typically include:
• Hardhat
• Long sleeve flame-resistant (FIR) shirt and FIR pants
• Leather gloves
• Exterior leather work boots, 8-inch high, lace-type with Vibram type soles
• Fire shelter
B. Required Tools and Equipment
Employees not working on transmission or distribution lines: Standard tools and equipment in
accordance with the IPC Safety Standards and Fleet Services.
Employees working on transmission or distribution lines in situations governed by the wildfire
prevention provisions of the March 2019 Master Agreement between IPC and the State of Idaho
BLM or in any WRZ in Idaho, Nevada, Montana, and Oregon:
• During wildfire season or during any other wildfire season ordered by a local, state,
or federal jurisdiction, IPC will equip at least one on-site vehicle with firefighting
equipment, including, but not limited to:
• Fire-suppression hand tools (i.e., shovels, rakes, Pulaskis, etc.).
• A 16-to 20-pound fire extinguisher.
• A supply of water (30-200 gallons) with a mechanism to effectively spray water,
sufficient for initial attack (i.e., backpack pumps, water sprayer, etc.).
This requirement to carry water is dependent on the vehicle type and weight
restrictions. For example, a mini-excavator would not be required to carry water
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Wildland Fire Preparedness and Prevention Plan Idaho Power Company
since there is no safe way to do so, or a loaded bucket truck may not be required to
carry water because of weight limitations.
• At a minimum, equip each truck that will be driven in the WRZs during wildfire season
with at least:
• One round, pointed shovel at least 8 inches wide, with a handle at least
26 inches long.
• One axe or Pulaski with a 26-inch handle or longer.
• A combination of shovels, axes, or Pulaski available to each person on the crew.
• One fire extinguisher rated no less than 2A:10BV (5 pounds).
• A supply of water, sufficient for initial attack, with an effective spraying mechanism
(e.g., backpack pumps, water sprayer). This requirement to carry water is dependent
on the vehicle type and weight restrictions. For example, a mini-excavator would not
be required to carry water since there is no safe way to do so, or a loaded bucket
truck may not be required to carry water because of weight limitations.
IPC personnel will be trained to use the above tools and equipment to aid in extinguishing a fire
ignition before it gets out of control if the situation warrants such action. In the event of a fire
ignition, IPC personnel present at the time of the ignition will take action consistent with that
person's training and experience to control the fire ignition while still accounting for their own
personal safety; however, Idaho Power is generally not responsible for fighting fires.
This responsibility remains with federal, state, and local firefighting organizations.
C. Land Management Agency Restrictions and Waivers
The Environmental Affairs department will strive to notify operations leadership within Power
Supply, Customer Operations and Business Development, and T&D Engineering and
Construction of any wildfire-related requirements and restrictions orders issued by local, state,
or federal land management agencies. Typical orders issued each fire season include
the following:
• BLM. During BLM's Stage II Fire Restrictions, IPC's Environmental Affairs department will
obtain an appropriate waiver. Field personnel shall take appropriate precautions when
conducting work activities that involve an internal combustion engine, generating a
flame, driving over or parking on dry grass, the possibility of dropping a line to the
ground, or explosives. Precautions include a Fire Prevention Watch person who will
remain in the area for one hour following the cessation of that activity. Also,
IPC personnel will not smoke unless within an enclosed vehicle, building,
designated recreation site, or while stopped in an area at least 3 feet in diameter that is
Page 5

Wildland Fire Preparedness and Prevention Plan Idaho Power Company
barren or cleared of all flammable materials. All smoking materials will be removed from
work sites. No smoking materials are to be discarded.
4. Prevention—Practices of Field Personnel
A. General Employee Practices
The following listing identifies practices and behaviors employees shall incorporate during fire
season.
1. Daily tailboards must include discussion around fire mitigation planning. Discussion topics
may include, but are not limited to, the following:
1.1. Items 2 through 7 below
1.2. Water suppression
1.3. Hand tools
1.4. Welding blankets
1.5. Mowing high brush areas (weed wacker)
1.6. Watering down the worksite before setting up equipment
2. Weather conditions and terrain to be worked shall be considered and evaluated. Items to
be considered may include, but are not limited to, the following:
2.1. Identify the FPI for the area being worked if in a WRZ (see Section 4.2 of the WMP).
2.1.1. Monitor weather forecasts, and wind and humidity conditions.
2.1.2. Identify surroundings (i.e., wildland-urban interface, BLM lands, Forest Service
lands, proximity to any homes and structures, etc.).
2.1.3. Identify local fire departments and locations.
2.1.4. Evaluate the terrain you are working in (steep or flat).
2.1.5. Consider whether the work will occur during the day or at night.
3. Work procedures and tools that have potential to cause a spark or flash shall be
considered and evaluated. Items to be considered may include, but are not limited to,
the following:
3.1. Performing energized work
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Wildland Fire Preparedness and Prevention Plan Idaho Power Company
3.2. Grinding or welding
3.3. Trees contacting electrical conductors
3.4. Hot saws
3.5. Chainsaws
3.6. Weed whackers
3.7. Sawzalls
4. Monitoring the worksite throughout the project.
4.1. All crews and equipment working in a WRZ will monitor and inspect the worksite
throughout the project. This includes prior to leaving the work area for the night or
before moving on to the next structure.
5. Employee cooking stoves.
5.1. If employees bring food to a worksite that needs to be cooked, open flames are not
allowed. Cook stoves may be permitted by leadership but special precautions must be
followed to use them:
5.1.1. The stove or grill must be in good repair and of sturdy construction.
5.1.2. Stoves must be kept clean; grease build up is not allowed.
5.1.3. Fueling of the stove must follow the fueling procedures when liquid fuels
are used.
5.1.4. Cooking must be in areas free of combustible materials.
6. Smoking on the job site.
6.1. The following practices shall be followed:
6.1.1. Do not discard any tobacco products from a moving vehicle.
6.1.2. All employees must smoke only in designated areas, and smoking materials
must be disposed of in half-filled water bottles or coffee containers half-filled
with sand. Smoking materials shall not be discarded on any site.
7. Post job-site inspection.
7.1. Conduct a final inspection or post-check the work site for any ignition hazards that may
remain.
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Wildland Fire Preparedness and Prevention Plan Idaho Power Company
B. Behaviors Relating to Vehicles and Combustion Engine
Power Tools
Employees should follow the vehicle-related processes set out below when working in WRZ
during fire season. Leadership should consider scheduling off-road equipment use in WRZ
during fire season for times of green-level FPI.
1. Additional heat may bring vegetative materials to an easier point of ignition. This includes,
but is not limited to, the following vehicles:
• Pickups
• Crew cabs
• Line-beds
• Bucket trucks (large and small)
• Backhoes
• Excavators and rope trucks
• Any other motorized equipment
2. Vehicle Procedures:
2.1. Inspect engine exhaust, spark arresters, and electrical systems of vehicles used off road
daily for debris, holes, or exposed hot components, and ensure heat shields and
protective components are in place.
2.1.1. Conduct inspections of the vehicle undercarriage before entering or exiting
the project area to clear vegetation that may have accumulated near the
vehicle's exhaust system.
2.1.2. Vehicles shall be parked overnight in areas free from flammable vegetation at
a minimum distance of 10 feet.
2.1.3. Vehicles and equipment will not be stationary or in use in areas where grass,
weeds, or other flammable vegetation will be in contact with the
exhaust system.
2.1.4. If there is no other workable option for the location that doesn't include
weeds, grass, or other flammable vegetation, the vegetation and debris will
need to be removed.
2.1.5. Consider using a fire-resistant material, such as a welding blanket to cover
flammable material to act as a heat shield; fire blankets may be a suitable
option to avoid removal of vegetation.
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Wildland Fire Preparedness and Prevention Plan Idaho Power Company
3. Hot brakes on vehicles and equipment:
3.1. Park vehicles in areas free of combustible materials.
3.1.1. Hot brake emergency parking during times of Yellow or Red FPI shall be
cleared of combustible materials for a distance of at least 10 feet from the
heat source.
4. Fueling procedures:
4.1. Tools or equipment should NOT be fueled while running.
4.1.1. Allow a cool-down period to give equipment time to no longer be considered a
fire risk.
4.1.2. Allow for a 10-foot radius from all ignition sources.
4.1.3. Clear any combustible debris from the immediate area.
4.1.4. Never smoke while fueling.
4.1.5. Designate fueling areas for all gas-powered tools.
5. Combustion engine power tools:
5.1. Poorly maintained or missing spark arrester screens may allow sparks to escape and
cause ignition of vegetation. Ensure proper spark arrester screens are in place for the
following tools:
• Generators
• Pony motors
• Pumps
• Chainsaws
• Hot saws
• Weed whacker
• Brush hog
6. Inspect spark arresters daily; clean or replace when clogged, damaged, or missing or
remove from service until repaired.
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Wildland Fire Preparedness and Prevention Plan Idaho Power Company
5. Reporting
A. Fire Ignition
All fire ignitions shall be reported to IPC regional or system dispatch as soon as practicable.
All work shall immediately stop, and reasonably prudent steps taken to extinguish the fire with
available tools, water, and equipment considering the individual's training and experience,
subject to the safety of personnel. If the fire gets too large to safely contain or extinguish,
ensure all employees are accounted for and get to a safe location.
B. Fire Reporting
When reporting a fire ignition to IPC regional or system dispatch provide the
following information:
• Your name
• Location—Reference points, including an address, road or street name, cross streets,
mountain range, GPS coordinates, as applicable
• Fire information
• Size and behavior of the fire
• Weather conditions
6. Training
Each employee who performs work in WRZs shall be trained on the content of this document
and be required to complete annual refresher courses through the Workday system.
Employees are required to complete fire extinguisher and fire shelter training annually as part
of lineman safety compliance. Documentation of all training shall be retained in Workday.
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Wildland Fire Preparedness and Prevention Plan Idaho Power Company
7. Roles and Responsibilities
Employee 1. Be familiar with the requirements specified in this Plan and operate in accordance
with this Plan.
2. Be aware of daily weather forecast and FPI level.
3. Be aware of whether field work will be performed in a WRZ.
Crew Foreman and 1. Ensure direct report employees are familiar with and follow Plan requirements.
Front-Line Leaders 2. Ensure the crew or team conducts field operations in accordance with this Plan.
3. Be aware of daily weather forecast and FPI level(by viewing the FPI dashboard or
by calling in to dispatch or a leader):
a) Ensure employees are aware of the FPI level.
b) Ensure work practices comply with this Wildland Fire Preparedness and
Prevention Plan.
4. Ensure annual training of employees is completed prior to wildfire season.
5. Ensure required tools and equipment are in place prior to wildfire season.
Manager(Regional 1. Ensure crew foremen and front-line leaders understand they are to operate in
Operations Manager, accordance with Plan requirements.
Area Manager, 2. Support crew foremen and front-line leaders in scheduling training and making
T&D Construction Manager) required tools and equipment available.
3. View daily weather forecast and FPI dashboard:
a) Authorize any exceptions to working when FPI is"Red"and the WRZ is Tier 3.
b) Ensure specified audits are completed in a timely manner.
Atmospheric Sciences 1. Provide daily weather forecast and update the FPI dashboard.
Department
Environmental Services 1. Monitor local,state,and federal land management agencies for any wildfire
Department restriction orders issued.
2. Communicate content of any orders issued to Power Supply,Customer Operations
and Safety,and Planning Engineering and Construction leadership.
Vice President of Planning, 1. Ensure annual review/update of this Plan is conducted following the completion of
Engineering and Construction each wildfire season.
(VP of PEC)
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Wildland Fire Preparedness and Prevention Plan Idaho Power Company
8. Audit
Before the start of wildfire season (May 10), all vehicles associated with work on transmission
and distribution lines will be informally audited by leadership to ensure those required to carry
certain equipment pursuant to this Plan are properly equipped with firefighting equipment. The
following checklist must be completed, dated, and signed by a member of leadership (front-line
supervisor or above) and kept with the crew or individual until fire season has ended. A copy of
each audit checklist shall be sent to the respective manager and senior manager.
Wildland Fire Preparedness Audit Checklist
Inspector
Signature
Date
Crew
Line Crew
At least one vehicle will be equipped with the following:
• Fire suppression hand tools (shovels, Pulaski, axes, etc.) for each member of the crew.
• A 16-to 20-pound fire extinguisher.
• A supply of water, sufficient for initial attack, with an effective spraying mechanism
(i.e., backpack pumps, water sprayer, etc.).
• A 30-to 200-gallon mechanical fire pumper.
Individual Truck
Each truck will be equipped with the following:
• One round, pointed shovel at least 8 inches wide, with a handle at least 26 inches long.
• One axe or Pulaski with a 26-inch handle or longer.
• A combination of shovels, axes, or Pulaskis to each person on the crew.
• One fire extinguisher rated no less than 2A:10BV (5 pounds).
• A supply of water, sufficient for initial attack, with an effective spraying mechanism
(i.e., backpack pumps, water sprayer, etc.). This requirement to carry water is dependent
on the vehicle type and weight restrictions. For example, a mini-excavator would not be
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Wildland Fire Preparedness and Prevention Plan Idaho Power Company
required to carry water since there is no safe way to do so, or a loaded bucket truck may
not be required to carry water because of weight limitations.
PPE: IPC and BLM standards
Each employee performing construction or maintenance activities will be required to have the
following PPE:
• Hard hat
• Safety glasses
• Hearing protection
• Long sleeve FIR shirt and FIR pants
• Leather gloves
• Exterior leather work boots 8-inch-high lace type with Vibram type soles
• Fire shelter
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Wildland Fire Preparedness and Prevention Plan Idaho Power Company
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IDAHO & MONTANAWILDFIR
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MITIGATIO
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Idaho Power Company Wildfire Public Safety Power Shutoff Plan
Table of Contents
1. Public Safety Power Shutoff Overview.................................................................................... 1
2. Definitions............................................................................................................................... 1
3. PSPS Implementation Considerations.....................................................................................2
3.1. Fire Potential Index ........................................................................................................2
3.2. National Weather Service Red Flag Warning..................................................................2
3.3. Publicly Available Weather Models................................................................................3
3.4. Idaho Power Weather Model .........................................................................................3
3.5. Storm Prediction Center Fire Weather Outlooks............................................................3
3.6. Current Weather Observations ......................................................................................3
3.7. GBCC Morning Briefing...................................................................................................4
3.8. GBCC Current and Predicted ERC and F100....................................................................4
3.9. Fire Agency Input............................................................................................................4
3.10. De-Energization Windspeed Considerations ..................................................................5
3.11. Alternative Protective Measures....................................................................................5
4. De-Energization Criteria..........................................................................................................5
5. PSPS Operations and Communication Phases.........................................................................6
5.1. Phase 1 and Incident Team Activation............................................................................6
5.2. Phase 2...........................................................................................................................7
5.3. Phase 3: De-Energization................................................................................................7
5.4. Phase 4: Re-Energization................................................................................................7
6. Post-incident Review.................................................................................................................8
7. Exercises....................................................................................................................................8
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Idaho Power Company Wildfire Public Safety Power Shutoff Plan
1. Public Safety Power Shutoff Overview
A Public Safety Power Shutoff(PSPS) is among the wildfire mitigation practices described in
Idaho Power's Wildfire Mitigation Plan (WMP). Idaho Power may conduct a PSPS for electrical
facilities located within wildfire risk zones if considered appropriate by Idaho Power.
PSPS allows for proactive de-energization of targeted electrical facilities located within wildfire
risk zones during extreme weather to reduce wildfire risk.
Idaho Power developed this Public Safety Power Shutoff Plan (PSPS Plan or Plan) to guide its
use of PSPS. The Plan includes implementation considerations, de-energization criteria, and the
associated community and customer communications protocols. Given the inherently
disruptive nature of power outages, PSPS events are evaluated to balance wildfire risk with
potential PSPS impacts on Idaho Power customers and the communities the company serves.
Idaho Power will only consider performing PSPS events within wildfire risks zones.
The unpredictable nature of wildfire and weather patterns can create challenges with
forecasting when a PSPS event should be implemented. Real-time evaluations and
decision -making are therefore important in making PSPS determinations. Those
determinations may result in a decision not to de-energize or even a proactive de-energization
in areas not originally anticipated to be included in a PSPS event.
Idaho Power only considers implementation of PSPS during wildfire season. Outside of wildfire
season, Idaho Power is not required to consider PSPS events; therefore, this Plan is inactive.
This Plan is reviewed and updated annually, as necessary.
2. Definitions
Critical Facilities—The facilities identified by Idaho Power that, because of their function or
importance, have the potential to threaten life, safety, or disrupt essential socioeconomic
activities if their services are interrupted.
ESF-12 (Emergency Support Function-12)—The Idaho Power liaison from the State Office of
Emergency Management for energy utilities issues during an emergency for both Idaho
and Oregon.'
Exercise—Planned activities and assessments that ensure continuity of operations, provide and
direct resources and capabilities, and gather lessons-learned to develop core capabilities
needed to respond to incidents.
Community—A group of people who share goals, values, and institutions.'
'Federal Emergency Management Institute(FEMA) National Response Framework(NRF) Emergency Support
Functions(ESF) National Response Framework I FEMA.gov.
z FEMA definition under"Communities" (pg. 26) National Response Framework(fema.gov).
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Wildfire Public Safety Power Shutoff Plan Idaho Power Company
Local Emergency Manager—A person assigned a role in a jurisdiction that oversees the day-to-
day emergency management programs and activities.3
Public Safety Partners—ESF-12, local emergency management, and other agencies
as applicable.
3. PSPS Implementation Considerations
Idaho Power will initiate the process that may ultimately result in a PSPS if the company
determines a combination of critical conditions exist that indicate potential significant wildfire
risk associated with Idaho Power's transmission and distribution (T&D) facilities in a wildfire risk
zone under those known conditions. Idaho Power will evaluate as a whole (not relying on one
single factor but a combination of all factors), without limitation, the criteria set forth in this
section in deciding whether to initiate the process that may ultimately result in a PSPS.
The following subsections list the varying data sources Idaho Power may consider in deciding
whether to initiate the PSPS process.
3.1. Fire Potential Index
Idaho Power forecasts wildfire potential in each of Idaho Power's wildfire risk zones during
wildfire season using a tool described as a Fire Potential Index (FPI), described further in
Section 4.2 of the WMP. This tool is designed to support operational decision-making during
fire season. The FPI converts environmental, statistical, and scientific data into a numeric
forecast of the short-term fire threat. As described in Section 4.2 of the WMP, a FPI score of 15
or 16 is classified Red and is considered to indicate higher potential for a large fire to develop
and spread. Idaho Power will consider whether the FPI is Red in determining whether to initiate
the PSPS process.
3.2. National Weather Service Red Flag Warning
A Red Flag Warning (RFW) is a forecast warning issued by the National Weather Service (NWS)
to inform the public, firefighters, and land management agencies that conditions are ideal for
wildland fire combustion and rapid spread. RFWs are often preceded by a Fire Weather Watch
(FWW), which indicates weather conditions that could occur in the next 12 to 72 hours.
The NWS has developed different zones across the nation for providing weather alerts (such as
RFWs) to more discrete areas. These zones are shown on this NWS webpage: Fire Weather.4
RFWs are monitored and factored into Idaho Power's determination of whether to initiate the
PSPS process.
In rare instances, the NWS may issue a Red Flag Warning Particularly Dangerous Situation
(PDS). The PDS designation is reserved for the most critical fire weather conditions,
when forecasters have high confidence that a combination of very strong winds, extremely low
3 FEMA definition under"Local Government" (pg. 29) National Response Framework(fema.gov).
4 National Weather Service, Fire Weather, Idaho, https://www.weather.gov/wrh/fire?wfo=boi.
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Idaho Power Company Wildfire Public Safety Power Shutoff Plan
humidity, and dry fuels will result in rapid ignition and uncontrollable fire spread. Idaho Power
is more likely to initiate the PSPS process if an RFW PDS has been issued for an area in which a
wildfire risk zone is located; however, a RFW PDS does not, alone, dictate that Idaho Power
must initiate the PSPS process.
3.3. Publicly Available Weather Models
Idaho Power's Atmospheric Science department uses the following weather models to predict
weather timing, duration, and intensity:
• Pivotal Weather Link (pivotalweather.com/model.php): Provides numerical weather
data, including an NWS blend of models, European Centre for Medium-Range Weather
Forecasts (ECMWF), United Kingdom Meteorological Office weather service
information, and Geostationary Operational Environmental Satellite (GOES) 16 satellite
information.
• Graphical Weather Link (graphical.weather.gov/sectors/conusFireWeek.php): A NWS
website providing weather, water and climate data, forecasts, and warnings for the
United States for the protection of life and property. The Fire Weather page provides a
daily and weekly view of multiple weather and environmental conditions influencing
wildfire activity.
3.4. Idaho Power Weather Model
Idaho Power maintains its own Weather Research and Forecasting (WRF) model using
high-resolution data from Idaho Power's weather stations across its service area. This model,
along with publicly available weather models, helps develop weather forecasts that include
timing, duration, and intensity of weather systems. An Idaho regional WRF low-resolution map
view is available to the public at atmo.boisestate.edu/view/.
3.5. Storm Prediction Center Fire Weather Outlooks
The Storm Prediction Center's Fire Weather Outlook provides a current, one-day-ahead and
three-to eight-day forecast for wildfires over the contiguous U.S. This forecast accounts for
pre-existing fuel conditions combined with predicted weather conditions that result in a
significant risk of wildfire ignition or spread.
3.6. Current Weather Observations
Monitoring real-time weather conditions assists in determining whether the associated risks
warrant the need for a PSPS event. Resources available for observing current weather
conditions include direct, real-time data from Idaho Power's network of fire weather stations as
well as Remote Automatic Weather Stations, Windy: Wind Map and Weather Forecasts, and
S Windy.com,windy.com/?43.635,-116.202,5
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Wildfire Public Safety Power Shutoff Plan Idaho Power Company
the NWS National Oceanic and Atmospheric Administration's (NOAA) Weather and Hazards
Viewer.6
Additionally, Idaho Power's PSPS program includes employees acting as field observers to
report on site conditions. Idaho Power typically deploys trained field observers to strategic
locations to provide real-time weather observations and circuit conditions before a weather
system is forecasted to arrive at wildfire risk zone. Field observations include—without
limitation—conditional assessments of system impacts from wind and vegetation, flying debris,
and conductor impact.
Field observers are equipped with mobile weather kits that include wind meters, compasses,
and satellite communication devices to report real-time conditions. Information is
communicated to the PSPS Assessment Team for consideration during a PSPS event.
Idaho Power's deployment of field observers is addressed in Section 5.2. Due to the speed at
which weather events can occur and the potential extent of areas in scope, Idaho Power may
not deploy field observers in every event,or to every in-scope area during an event.
3.7. GBCC Morning Briefing
The Great Basin Coordination Center (GBCC) is the focal point for coordinating the mobilization
of resources for wildland fire and other incidents throughout the Great Basin geographic area,
which encompasses Utah, Nevada, Idaho south of the Salmon River, the western Wyoming
mountains, and the Arizona Strip. The GBCC hosts a morning briefing during fire season that
provides situational awareness for Idaho Power's service area.
3.8. GBCC Current and Predicted ERC and F100
The GBCC as described above also provides day-ahead Energy Release Component (ERC),
100-Hour Fuel Moisture (F100) and other fuel condition information that helps Idaho Power
understand wildfire potential in the service area.
3.9. Fire Agency Input
Idaho Power listens to update briefings provided by Boise NWS fire forecasters and National
Interagency Fire Center (NIFC) Predictive Service forecasters as needed, generally regarding
data clarification, to streamline the transfer of data, information, and communications about
wildland fires that may impact wildfire risk zones.
Idaho Power may work with other agencies, including the U.S. Bureau of Land Management
(BLM) and U.S. Forest Service, as wildland fires approach or impact Idaho Power T&D facilities.
6 NOAA,Weather and Hazards Viewer,wrh.noaa.gov/map/?obs=true&wfo=boi
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Idaho Power Company Wildfire Public Safety Power Shutoff Plan
3.10. De-Energization Windspeed Considerations
The environmental conditions in the areas where Idaho Power may consider initiating PSPS vary
drastically from high desert landscape to mountainous terrain. Weather and environmental
conditions also vary greatly within this area and can change in minutes. Regional vegetation
becomes "conditioned" to withstand different environmental conditions, which also influences
de-energization thresholds. To account for the impact these variations have on fire risk
generated by weather conditions, Idaho Power has developed regional windspeed
considerations, which it continues to refine.
3.11. Alternative Protective Measures
Considering the potential impact of a PSPS to customers, prior to implementing a PSPS,
Idaho Power evaluates other potential alternative protective measures for operating its T&D
system both during fire season and in the context of a potential PSPS event. The availability of
alternative protective measures may cause Idaho Power to decide that PSPS is not warranted.
4. De-Energization Criteria
Due to the dynamic and complex nature of wildfire and weather behavior, PSPS decisions are
made in real time using the best available information from meteorological forecasts,
field intelligence, and system conditions. Idaho Power prioritizes a risk-informed approach that
balances wildfire prevention with the need to maintain electric service for safety, emergency
communications, and essential services.
Idaho Power's decision to de-energize will be based on the totality of the circumstances and
thus is not reducible to a formula or definitive triggers. It will involve an evaluation of multiple
risk variables, including wind speed, relative humidity, fuel moisture, and infrastructure type.
Idaho Power's approach, due to the inherent risks and downsides with proactive de-
energization, is to employ de-energization only as a tool of last resort. It is thus Idaho Power's
policy in this WMP, subject to situation-by-situation assessments of all relevant factors as
described above, to employ PSPS de-energization for distribution or transmission lines, or the
segments thereof to the nearest zone of protection segmentation point or end of the line if
none exists, within designated wildfire risk zones if both (1) a fire potential element and (2) a
windspeed element are met for a given wildfire risk zone:
The fire potential element is met for a wildfire risk zone if
• There is an FPI of 15 or higher for that wildfire risk zone for the time period when
the windspeed element is met and
• the National Weather Service has issued either a Red Flag Warning Particularly
Dangerous Situation (PDS) for a location(s) within that wildfire risk zone during
the time that the windspeed element is met or a High Wind Warning (defined as
sustained winds of 40 mph or higher for at least one hour or more and/or gusts
of 58 mph or higher) for that area.
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Wildfire Public Safety Power Shutoff Plan Idaho Power Company
The windspeed element is met if:
• Distribution Circuits: Idaho Power identifies observed winds exceeding 30 mph
sustained for at least one hour combined with wind gusts exceeding thresholds
derived from historical climatology stated in the 2026 Operational Wind Speed
Guidelines for EPS and PSPS by Risk Zone for the applicable wildfire risk zone
location.
• Transmission Circuits: Idaho Power identifies observed winds exceeding 40 mph
sustained for at least one hour and observed or known wind gusts exceeding 70
mph for the wildfire risk zone location. Idaho Power may opt not to de-energize
a transmission segment or circuit if it determines the requested de-energization
may cause grid instability or reliability issues that could impact a large number of
customers (such as a de-energization that could impact 1,000 or more
customers) or impact the bulk electric system, or if Idaho Power believes it poses
a risk to public safety.
Consistent with Idaho Power's case-by-case evaluation of all relevant factors, even when
extreme fire weather is forecasted, a risk evaluation may support maintaining power if other
mitigation measures are in place, such as Enhanced Protection Settings or hardened
infrastructure that lowers the likelihood of ignition.
5. PSPS Operations and Communication Phases
Although the extent of the areas where Idaho Power has infrastructure and equipment,
the geographic and environmental diversity of those locations, and unpredictable nature of
weather make it challenging, Idaho Power is committed to providing as much advance notice as
reasonably possible in preparation for a PSPS event.
5.1. Phase 1 and Incident Team Activation
Once the criteria are met to initiate the process for a potential PSPS event, an internal incident
command team (IC team) will discuss the timing and impact of the event and make
recommendations pertaining to the issuance of preliminary notifications of a potential PSPS
event to customers, public safety partners, utility defined critical facilities operators, and/or the
ESF-12.
The intent of any initial communication is to allow public safety partners and critical facilities to
begin preparing for the PSPS event, which may include identification of back-up generation,
community resource centers, or heightened response for vulnerable populations. This step also
allows for coordinated communications with public safety partners, if deemed necessary by
Idaho Power.
These notifications may include emails, text messages, and/or phone calls. The mode of
communication is based on the preference of each audience as communicated to Idaho Power.
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Idaho Power Company Wildfire Public Safety Power Shutoff Plan
The Idaho Power IC team will continue meeting and providing updated community and
customer communications throughout a PSPS event, if feasible. This could include cancellation
of the event or restoration of the de-energized PSPS circuits and any related storm activity.
Throughout an event, there may be requests to delay proactive de-energization from the public
safety partners or ESF-12. This may occur for several reasons, such as the potential impact to a
customer's or fire response agency's ability to pump water for fire suppression during the
outage. Delay requests will be communicated to the IC team for consideration.
5.2. Phase 2
Phase 2 actions are determined by additional situational awareness activities and timing of
forecasted weather events. Upon transitioning to Phase 2, Idaho Power will discuss timing of
proactive customer communications.
During Phase 2, field observers, described in Section 3.6, may be mobilized and dispatched
to strategic locations, including areas with limited weather and system condition visibility,
to perform field observations for on-the-ground, real-time information to inform PSPS
de-energization decisions. As stated above, Idaho Power does not guarantee that field
observers will be dispatched to all wildfire risk zones under consideration for PSPS in all events.
Idaho Power will strive to provide proactive customer communication as the likelihood of the
PSPS event increases. This may occur several hours or more after the initial public safety
partner and critical facility communication. As reference, Idaho Power strives to follow the
communication timelines set in relevant state regulations, noting the timing of all proactive
communications is tied to the development of weather conditions and therefore subject
to change.
5.3. Phase 3: De-Energization
After the determination to proactively de-energize is made, the assigned representative of the
IC team will inform Idaho Power's Dispatch Operations to confirm the PSPS de-energization.
The criteria for de-energization are discussed in Section 4.
Idaho Power will continue providing community updates as it deems appropriate.
Customer communications may include email, text, and/or phone messages. The outage
notification will include the reason for the de-energization and where to find real-time updates
on outage status.
5.4. Phase 4: Re-Energization
5.4.1. System Inspections
If electrical facilities are de-energized for PSPS, Idaho Power follows a process to restore
service. When conditions are safe, de-energized T&D circuits and other potentially impacted
facilities are patrolled to confirm readiness for re-energization. Repairs may be completed as
necessary, and restoration is carried out in a controlled manner. Each operating region
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Wildfire Public Safety Power Shutoff Plan Idaho Power Company
identifies the resources and procedures to be used during PSPS events, helping restoration to
occur safely, efficiently, and in coordination with the dispatch manager.
5.4.2. Repair and Recovery
Line crews will repair impacted facilities based on internal priority coordination,
replacing damaged equipment, and performing other actions to support safe re-energization
of the affected portion of the T&D system.
5.4.3. Communicate PSPS Event Conclusion
Idaho Power will strive to provide customers with estimated restoration times until any storm
or PSPS repairs are complete, and it is safe to re-energize the system. This may occur in stages
as different feeders or feeder sections are repaired and safe to re-energize. The outage map on
Idaho Power's website will be updated during the event. Idaho Power may also leverage
existing public agency outreach and notification systems as done at other points in the
PSPS process.
6. Post-incident Review
Following the conclusion of a PSPS event, Idaho Power will conduct informal, high-level debriefs
to identify potential modifications to PSPS protocol based on lessons learned during the event.
An assigned representative will consolidate the feedback and file as part of the
incident documentation.
7. Exercises
Idaho Power will exercise this PSPS Plan on an annual basis prior to wildfire season using one or
more different scenarios and testing one or more portions of the Plan. These exercises may
include any of the following:
• Testing text and/or phone alerts with a test group of public safety partners.
• Testing tactical operational plans, such as reporting field observations or
positioning employees at manually operated disconnects to test timing for
de-energization and field inspections of T&D assets.
• Discussing and/or practicing roles and responsibilities of both strategic and tactical
operations, including decision-making handoffs.
• Discussing and/or developing re-energization plans.
• Testing capacity limits on incoming and outgoing communications systems.
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IDAHO & MONTANAWILDFIR
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MITIGATIO
PLAN
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Appendix C.
Wildfire Risk Zone
Map Book
October 2025
© 2025 Idaho Power

Idaho Power Wildfire Risk Zone Map Book
List of Figures
Figure 1
CanyonRegion—North .............................................................................................................. 1
Figure 2
CanyonRegion—South...............................................................................................................2
Figure 3
CapitalRegion—Boise Front.......................................................................................................3
Figure 4
CapitalRegion—Boise South......................................................................................................4
Figure 5
Capital Region—Centerville........................................................................................................5
Figure 6
CapitalRegion—Idaho City.........................................................................................................6
Figure 7
Capital Region—Mountain Home Area ......................................................................................7
Figure 8
Eastern Region—American Falls.................................................................................................8
Figure 9
EasternRegion—Pocatello.........................................................................................................9
Figure 10
Eastern Region—Salmon Area..................................................................................................10
Figure 11
Eastern Region—Salmon North................................................................................................11
Figure 12
Southern Region—Pine Featherville Area ................................................................................12
Figure 13
SouthernRegion—Rock Creek .................................................................................................13
Figure 14
Southern Region—Twin Falls/Buhl...........................................................................................14
Figure 15
Southern Region—Wood River Valley......................................................................................15
Page i

Idaho Power Wildfire Risk Zone Map Book
Figure 16
WesternRegion—Ola...............................................................................................................16
Figure 17
Western Region—Cascade/Donnelly .......................................................................................17
Figure 18
Western Region—Council Area................................................................................................18
Figure 19
Western Region—Emmett/Horseshoe Bend............................................................................19
Figure 20
Western Region—Garden Valley/Crouch.................................................................................20
Figure 21
WesternRegion—Lowman.......................................................................................................21
Figure 22
Western Region—McCall/New Meadows................................................................................22
Figure 23
WesternRegion—Riggins South...............................................................................................23
Figure 24
Western Region—Smiths Ferry................................................................................................24
Figure 25
Western Region—Weiser Payette Area ...................................................................................25
Figure 26
Western Region—Yellow Pine..................................................................................................26
Page ii

Idaho Power Wildfire Risk Zone Map Book
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State
BOR _
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Figure 1
Canyon Region—North
Page 1

Idaho Power Wildfire Risk Zone Map Book
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State
BOR
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Figure 2
Canyon Region—South
Page 2

Idaho Power Wildfire Risk Zone Map Book
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USFS
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Figure 3
Capital Region—Boise Front
Page 3

Idaho Power Wildfire Risk Zone Map Book
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Figure 4
Capital Region—Boise South
Page 4

Idaho Power Wildfire Risk Zone Map Book
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Figure 5
Capital Region—Centerville
Page 5

Idaho Power Wildfire Risk Zone Map Book
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Figure 6
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Page 6

Idaho Power Wildfire Risk Zone Map Book
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Page 7

Idaho Power Wildfire Risk Zone Map Book
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Figure 8
Eastern Region—American Falls
Page 8

Idaho Power Wildfire Risk Zone Map Book
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Figure 9
Eastern Region—Pocatello
Page 9

Idaho Power Wildfire Risk Zone Map Book
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Figure 10
Eastern Region—Salmon Area
Page 10

Idaho Power Wildfire Risk Zone Map Book
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Figure 11
Eastern Region—Salmon North
Page 11

Idaho Power Wildfire Risk Zone Map Book
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City Boundaries
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State
USFS
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Figure 12
Southern Region—Pine Featherville Area
Page 12

Idaho Power Wildfire Risk Zone Map Book
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Figure 13
Southern Region—Rock Creek
Page 13

Idaho Power Wildfire Risk Zone Map Book
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State
DOD/COE
0 2.5 5 10 1040
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Figure 14
Southern Region—Twin Falls/Buhl
Page 14

Idaho Power Wildfire Risk Zone Map Book
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City Boundaries Southern Region - Wood River Valley
BLM
State
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Figure 15
Southern Region—Wood River Valley
Page 15

Idaho Power Wildfire Risk Zone Map Book
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State
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Figure 16
Western Region-01a
Page 16

Idaho Power Wildfire Risk Zone Map Book
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City Boundaries Western Region - Cascade/Donnelly
BLM
State
USFS
BOR 0 2 5 5 M 1040
Miles POMR,v
Figure 17
Western Region—Cascade/Donnelly
Page 17

Idaho Power Wildfire Risk Zone Map Book
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City Boundaries
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State
USFS
BOR 0 2.5 5 1040
fV4iles MR POMR
Figure 18
Western Region—Council Area
Page 18

Idaho Power Wildfire Risk Zone Map Book
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Q
City Boundaries Western Region - Emmett/Horseshoe Bend
BLM
State
USFS
BOR � 0 2.5 5 �
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Figure 19
Western Region—Emmett/Horseshoe Bend
Page 19

Idaho Power Wildfire Risk Zone Map Book
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City Boundaries Western Region - Garden Valley/Crouch
BLM
State
uses BOR 0 2.5 5
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Figure 20
Western Region—Garden Valley/Crouch
Page 20

Idaho Power Wildfire Risk Zone Map Book
Lowman
21
21
Idaho
Boise
Tier 2 Risk Areas Idaho Power Wildfire Risk Area Detail
City Boundaries
USFS Western Region - Lowman
BOR
Miles 1040
Figure 21
Western Region—Lowman
Page21

Idaho Power Wildfire Risk Zone Map Book
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BLM
State
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Figure 22
Western Region—McCall/New Meadows
Page 22

Idaho Power Wildfire Risk Zone Map Book
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BLM Western Region - Riggins South
State
USFS �
0 25 5 ���
Miles � POMR
Figure 23
Western Region—Riggins South
Page 23

Idaho Power Wildfire Risk Zone Map Book
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City Boundaries Western Region - Smiths Ferry
BLM
State
USFS
BOR 0 2 5 5 Miles 1040
� POMR
Figure 24
Western Region—Smiths Ferry
Page 24

Idaho Power Wildfire Risk Zone Map Book
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_ City Boundaries Idaho Power Wildfire Risk Area Detail
BLM Western Region - Weiser Payette Area
State
BOR
DOE
USFWS 0 2.5 5 10 1040
Miles WR POMR
Figure 25
Western Region—Weiser Payette Area
Page 25

Idaho Power Wildfire Risk Zone Map Book
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Figure 26
Western Region—Yellow Pine
Page 26

"lip"►: s \
14
IDAHO & MONTANAWILDFIR
'
MITIGATIO
PLAN
Nll
tt
1.
a.
1
�w
DaP+�
Ida o and Montana
Requirements and ,
Recommendations Crosswalk
NIQAW POWER.

Mq% HIDAHO R®
Appendix D.
Idaho and Montana
Requirements and
Recommendations
October 2025
© 2025 Idaho Power

Idaho Power Company Idaho and Montana Wildfire Requirements and Recommendations
Table of Contents
Idaho Requirements and Recommendations ................................................................................1
Idaho Wildfire Standard of Care Act and IPUC Order No. 36774 Requirements........................2
Other Items to Include in a WMP from Various IPUC Orders ....................................................8
IPUC Order No. 36774, Case No. GNR-E-25-02..........................................................................8
IPUC Order No. 36742, Case No. IPC-E-25-05............................................................................8
IPUC Order No. 36042, Case No. IPC-E-23-11............................................................................9
IPUC Order No. 35717, Case No. IPC-E-22-27..........................................................................10
2026 WMP Major Updates/Changes.......................................................................................10
Montana WMP Requirements.....................................................................................................11

Idaho Power Company Idaho and Montana Wildfire Requirements and Recommendations
Page ii

Idaho Power Company Idaho and Montana Wildfire Requirements and Recommendations
This appendix is intended to aid reviewers in locating content specific to the various statutory
and regulatory requirements and recommendations pertaining to Idaho Power's Idaho and
Montana Wildfire Mitigation Plan 2026 (WMP). This appendix first discusses Idaho
requirements and recommendations and then addresses Montana requirements and
recommendations. The mapping Idaho Power provides in Appendix D is provided for ease of
reference and is non-exhaustive. The WMP is a complex document. There may be content in
sections or appendices not identified in relation to a specific requirement or recommendation
that pertain to that requirement or recommendation.
Idaho Requirements and Recommendations
This appendix provides information specific to WMP requirements, as well as WMP-related
recommendations, in Idaho pursuant to the Idaho Wildfire Standard of Care Act (WSCA) and as
directed by the Idaho Public Utilities Commission (IPUC).
Page 1

Idaho Power Company Idaho and Montana Wildfire Requirements and Recommendations
Idaho Wildfire Standard of Care Act and IPUC Order No. 36774 Requirements
Below is a mapping of WMP requirements set forth in the WSCA and in Order No. 36774 issued by the IPUC in Case No. GNR-E-25-02,
including the IPUC WMP Guidelines (Exhibit B to Order No. 36774), to the applicable section(s) within Idaho Power's WMP.
Idaho Requirement—WSCA 61-1803 WMP Guidelines—IPUC Order No.36774, Exhibit B Corresponding Location in WMP
(3)Each wildfire mitigation plan shall be Not addressed. Section 1. Introduction
developed using approaches and methods that Section 2.Geographical Risk
are designed to protect the public interest and Assessment
are reflective of and commensurate with the
size and complexity of the electric corporation's Section 3.Cost Benefit Approach
operations and of the nature of the fire risk.At Section 4.Situational Awareness and
a minimum,each wildfire mitigation plan shall Monitoring
identify a means for mitigating wildfire risk Section 5. Mitigation Activity:
that reflect a reasonable balancing of Workforce Preparedness
mitigation costs with the resulting reduction of Section 6. Mitigation Activity:Line
wildfire risk.
Operation Practices
Section 7. Infrastructure Inspection
and Asset Management
Section 8. Methods of Line Design
Section 9.Vegetation Management
Section 10.Additional Preventative
Actions and Programs
Section 11. Public Outreach and
Engagement
Section 12.Government,Industry,
and Peer Utility Outreach
Section 13. Performance Monitoring
Section 14.WMP Cost Summary
Appendix A:Wildland Fire
Preparedness and Prevention Plan
Appendix 8:Public Safety Power
Shutoff Plan
Appendix F:Wildfire Mitigation
Activities&Cost Forecast 2026-2030
Page 2

Idaho Power Company Idaho and Montana Wildfire Requirements and Recommendations
Idaho Requirement—WSCA 61-1803 WMP Guidelines—IPUC Order No.36774, Exhibit B Corresponding Location in WMP
(3)(a)Identifying geographical areas where an • The electric corporation must include a description of the wildfire risk Section 2.Geographical Risk
electric corporation has infrastructure or assessment or model used to guide wildfire mitigation activities.The Assessment
equipment that the electric corporation assessment should identify geographic areas with elevated fire risk, Appendix C.Wildfire Risk Zone Map
considers may be subject to a heightened risk considering factors such as vegetation,weather,topography,historical fire Book
of wildfire at the time the wildfire mitigation occurrence,structure density,and asset location.
plan is finalized by the electric corporation. • 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.
(3)(b)Preventative actions and programs that The electric corporation must describe all preventative actions and programs that it will Section 4.Situational Awareness and
the electric corporation will carry out to reduce carry out to reduce the risk of wildfire,in addition to actions and programs specified in Monitoring
the risk of wildfire. statute and by the IPUC. For the three large investor-owned utilities,a WMP's Section 5. Mitigation Activity:
preventative actions and programs must include,but are not limited to,the following: Workforce Preparedness
Situational Awareness Efforts Section 6. Mitigation Activity:Line
• May include use of technology to aid in weather monitoring;fire season Operation Practices
outlook;daily,weekly,and monthly weather and fire modeling risk,etc. Section 7. Infrastructure Inspection
• Consistent with 61-1803(3)(f)and the IPUC WMP Guidelines. and Asset Management
Asset Inspections Section 8. Methods of Line Design
• Must include the frequency and standards of inspections for each type of Section 9.Vegetation Management
electric infrastructure within areas of elevated wildfire risk. Section 10.Additional Preventative
• Consistent with 61-1803(3)(g)(i)and the IPUC WMP Guidelines. Actions and Programs
Enhanced Vegetation Management Practices in Risk Zones Section 11. Public Outreach and
• May include shorter vegetation management cycles than routine cycles,risk Engagement
tree programs,etc. Section 14.WMP Cost Summary
• Consistent with 61-1803(3)(g)(iii)and the IPUC WMP Guidelines. Appendix A:Wildland Fire
Operation Practices During Heightened Wildfire Risk Days or Zones Preparedness and Prevention Plan
• May include restrictions to workforce practices,potential use of proactive Appendix B:Wildfire Public Safety
power Shutoff Plan
de-energization.
Appendix F:Wildfire Mitigation
• Consistent with 61 1803(3)(g)(ii)and the IPUC WMP Guidelines. Activities&Cost Forecast2026-2030
Community Education
• May include public service announcements to create awareness and provide
education of wildfire risks,providing preventative measures,etc.
Page 3

Idaho Power Company Idaho and Montana Wildfire Requirements and Recommendations
Idaho Requirement—WSCA 61-1803 WMP Guidelines—IPUC Order No.36774, Exhibit B Corresponding Location in WMP
• Consistent with 61-1803(3)(c)and 61-1803(3)(d).
A WMP's preventative actions and programs may include,but are not limited to,
the following:
System Hardening Strategies
• May include pole replacements,line rebuilding,or undergrounding
if necessary,strategic fuse or reclosers installations,etc.
Workforce Preparedness
• May include workforce training,equipment provided to employees to reduce
the risk of wildfire,etc.
Pilot Programs
• If applicable.
(3)(c)Community outreach and public This section should include discussion of how each utility maintains community Section 11. Public Outreach and
awareness efforts that the electric corporation outreach and public awareness before,during,and after wildfire season to support Engagement
will use before,during,and after wildfire customer awareness and education of wildfire risks and notify the public of wildfire- Appendix B:Wildfire Public Safety
season to identify and inform the public of related outages.This discussion should include,but is not limited,to the following: Power Shutoff Plan
relevant wildfire risks and notify the public of • Description of customer communication efforts related to wildfire mitigation,
wildfire-related outages. 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 is 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.
(3)(d)Outreach efforts to coordinate with The electric corporation must describe how it engages with and coordinates with Section 4.6 Wildfire Detection
federal,state, tribal,and local officials and federal,state,tribal,and local officials and agencies on wildfire preparedness and Cameras
agencies on wildfire preparedness and emergency response in the plan year.This discussion may include,but is not limited to: Section 10.2.2 Fuels Reduction Shared
emergency response plans. • If applicable,Public Safety Power Shutoff("PSPS")tabletop exercises with Stewardship(Pilot)
interested parties and agencies.
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Idaho Power Company Idaho and Montana Wildfire Requirements and Recommendations
Idaho Requirement—WSCA 61-1803 WMP Guidelines—IPUC Order No.36774, Exhibit B Corresponding Location in WMP
• Communication with the agencies and the ESF-12 coordinator within the Section 11. Public Outreach and
PUC. Engagement
• If applicable,mitigation efforts with the agencies. Section 12.Government,Industry and
The WMP must detail all relationships(such as Bureau of Land Management[BLM]and Peer Utility Engagement
Forest Service)it has established that may benefit the wildfire mitigation program,
contribute to program costs,or provide cost sharing opportunities in its WMP.
(3)(e)Financially prudent and reasonably The electric corporation must describe how its methods of line design for new lines and Section 3.Cost-Benefit Approach
practicable methods of line design for new, planned upgrades reduce wildfire ignition potential in heightened wildfire risk areas. Section 6. Mitigation Activity: Line
planned,and existing lines to mitigate fire risk. This must include evaluation of costs to wildfire risk reductions.Additionally,this must Operation Practices
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 Section 8. Methods of Line Design
following,but is not limited to: Section 10.Additional Preventative
• Line rebuilding within the WMP.
Actions and Programs
• Undergrounding lines within the WMP. Section 14.WMP Cost Summary
Appendix F. Wildfire Mitigation
• Installation of covered conductor. Activities&Cost Forecast 2026-2030
• Installation of non-wooden cross arms.
If any,describe any flexible infrastructure such as automatic reclosers and remote-
controlled devices that support remote operations.
(3)(f)Monitoring of forecasted and current This section should include a description of how the electric corporation monitors Section 2.Geographical Risk
weather data for the purpose of assessing and forecasted and current weather conditions for the purpose of assessing and responding Assessment
responding to current and anticipated fire risk. to current and anticipated wildfire risk.This description must include,but is not limited Section 4.Situational Awareness and
to,the following: Monitoring
• Identification of systems,tools,or external resources used to monitor Section 5. Mitigation Activity:
weather,fire potential,or other situational awareness indicators. Workforce Preparedness
• If applicable,a description of how the utility utilizes weather forecasting, Section 6. Mitigation Activity:Line
fire potential modeling,or similar tools,to inform mitigation activities and Operation Practices
operational decisions.
Section 10.Additional Preventative
• Discussion of how situational awareness capabilities are integrated into daily Actions and Programs
or seasonal wildfire operations. Appendix A:Wildland Fire
• Discussion of how the electric utility becomes aware of another electric Preparedness and Prevention Plan
corporation's de-energization(e.g.,Bonneville Power Administration)and Appendix 8:Wildfire Public Safety
how that is integrated into operations. Power Shutoff Plan
(3)(g)Developing standards,procedures,and This section should provide a summary of an electric corporation's programs for the Section 7. Infrastructure Inspection
schedules,subject to timely approval of access inspection of electric infrastructure,assets,and facilities within areas identified as and Asset Management
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Idaho Power Company Idaho and Montana Wildfire Requirements and Recommendations
Idaho Requirement—WSCA 61-1803 WMP Guidelines—IPUC Order No.36774, Exhibit B Corresponding Location in WMP
to rights-of-way,if necessary,for the following heightened wildfire risk areas to identify and correct conditions that could contribute to Section 9.Vegetation Management
actions: wildfire ignition.This summary must include,but is not limited to,the following: Section 10.Additional Preventative
(i)Inspection of the electric corporation's • Description of inspection standards for each type of infrastructure,assets, Actions and Programs
assets,infrastructure,and facilities within the and facilities. Appendix F:Wildfire Mitigation
areas that are identified as heightened fire risk • Description of schedules for inspections for each type of infrastructure,asset, Activities&Cost Forecast-2026-2030
areas in the wildfire mitigation plan,where and facility.
financially prudent and reasonably practicable.
• 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.)
3(g)(ii)De-energization of the electric If an electric utility plans to use de-energization as part of its wildfire mitigation efforts, Section 6. Mitigation Activity:Line
corporation's power lines,if considered this section must address the standards,criteria,and operational protocols for Operation Practices.
appropriate by the electric corporation; de-energization for encroachment of a wildfire,proactive de-energization(PSPS)to Section 14.WMP Cost Summary
reduce fire risk,and de-energization from third-party energy providers.This discussion
must include,but is not limited to the following: Appendix Power Shutoff
Wildfire Public Safety
off Plan
• 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.
3(g)(iii)Vegetation management within the This section must provide an overview of the utility's vegetation management program Section 9.Vegetation Management
areas that are identified as heightened fire risk aimed at reducing the risk of vegetation-related contact with electric infrastructure in Section 10.Additional Preventative
areas in the wildfire mitigation plan and are areas with heightened wildfire risk within its rights-of-way or lands adjacent thereto. Actions and Programs
within the electric corporation's rights-of-way Elements of this vegetation management section overview should include,but is not
or lands adjacent thereto and that threaten the limited to,the following: Section Government,Industry and
power lines or other electric corporation Peer Utility Outreach
infrastructure.If live marketable timber is Section 14.WMP Cost Summary
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Idaho Power Company Idaho and Montana Wildfire Requirements and Recommendations
Idaho Requirement—WSCA 61-1803 WMP Guidelines—IPUC Order No.36774, Exhibit B Corresponding Location in WMP
identified for removal from timber company • Identification,description,and citation of vegetation management standards Appendix F:Wildfire Mitigation
land adjacent to the rights-of-way, for elevated wildfire risk areas. Activities&Cost Forecast-2026-2030
compensation at fair market value shall be • Explanation of how vegetation management standards,procedures,
made to the landowner for such timber. 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.
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Idaho Power Company Idaho and Montana Wildfire Requirements and Recommendations
Other Items to Include in a WMP from Various IPUC Orders
IPUC Order No. 36774, Case No. GNR-E-25-02
The following contains the IPUC's directives uniquely contained within Order No. 36774 related
to Idaho Power's development of WMP filings and the content to be contained therein.
1. An update of lessons learned from the previously approved WMP within the annual
filings for WMP review and approval.
a. An update of lessons learned is captured in Section 13.4. Lessons Learned.
2. A breakdown of each program category's forecasted costs by year for both capital and
operations and maintenance (O&M) expenditures through the length of the WMP.
a. This information is included in Section 14. WMP Cost Summary and Appendix F:
Wildfire Mitigation Activities& Cost Forecast-2026 to 2030.
3. A section in which Idaho Power describes how it addresses each of the IPUC's orders
and Staff's recommendations.
a. This information is contained within this Appendix D.
4. Rolling WMPs shall be developed with a minimum three-year planning horizon.
a. Idaho Power developed projections for a 5-year planning horizon, as presented
within Appendix F: Wildfire Mitigation Activities& Cost Forecast-2026 to 2030.
5. An explanation how the Company'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 "balance of
mitigation costs with the resulting wildfire reduction in wildfire risk," as required by the
WSCA.
a. This information is addressed within Section 3. Cost-Benefit Approach, Section 8.
Methods of Line Design, and Section 14. WMP Cost Summary.
6. WMPs must include a cost-benefit analysis that justifies the expenditures for risk
mitigation described within.
a. This information is included within Section 3. Cost-Benefit Approach. See also
Section 14. WMP Cost Summary.
IPUC Order No. 36742, Case No. IPC-E-25-05
The following contains the IPUC's directives uniquely contained within Order No. 36742 related
to Idaho Power's development of WMP filings and the content to be contained therein.
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Idaho Power Company Idaho and Montana Wildfire Requirements and Recommendations
(1) List all pilot projects in the WMP, including the status of the pilot and an explanation of how the
Company is evaluating least-cost, least-risk solutions.
Pilot projects, including their status, have been identified in Section 10:Additional
Preventative Actions and Programs.The company's approach to balancing mitigation
costs with the resulting reduction of wildfire risks specific to pilot projects is discussed in
Section 3.4. Idaho Power interprets the IPUC's direction to evaluate "least cost, least
risk" solutions to direct the company to evaluate mitigations with an eye toward
reasonably balancing the lowest cost mitigations against the greatest amount of wildfire
risk reduction for that cost.
(2) Detail how the Company identifies,selects, and evaluates projects as least-cost, least-risk for
line rebuilding, undergrounding, and covered conductor to be consistent with Idaho Code§61-
1803(3)(g), effective July 1, 2025.
Idaho Power interprets the direction to evaluate "least-cost, least-risk" solutions to
direct the company to evaluate mitigations that reasonably balance cost with the
resulting reduction of wildfire risk. Put differently, Idaho Power understands the IPUC to
direct the company to identify the reasonable intersection point between cost and risk
reduction.
See Section: 3.2. Risk-Based Cost and Benefit Analysis of Wildfire Mitigation.
See also Sections 8.3 Transmission Line Rebuild Projects, 8.4.1. Overhead Primary Hardening
Program, 8.4.2. Overhead to Underground Conversion, 8.4.3 New Underground
Construction, and 10.2.4. Covered Conductor(Pilot).
(3) Add a section to the WMP to explain how the Company addressed Staff's recommendations
and discuss other high-level major changes/updates to the WMP since the last filing.
This Appendix D provides a crosswalk of the requirements stated in the WSCA and IPUC
Order No. 36774 in Case No. GNR-E-25-02, as well as how the plan addresses the
requirements contained within Order Nos. 36742, 36042, and 35717 in Case Nos. IPC-E-25-
05, IPC-E-23-11 and IPC-E-22-27, respectively.A high-level discussion of the updates and
changes since Idaho Power's last WMP filing is also contained herein.
IPUC Order No. 36042, Case No. IPC-E-23-11
Within the Company's IPUC-approved settlement stipulation to its 2023 general rate case,
Idaho Power agreed that future iterations of its WMP would break down internal labor
expenses for all WMP programs and to extend the WMP forecast to five years for each version.
The Company also agreed to explore methods to reduce costs with communication and
education regarding wildfire and PSPS.
Idaho Power has incorporated internal labor expense breakdowns for all WMP programs
anticipated in 2026 in the 2026 filing. The company has also provided a five-year cost forecast
in Appendix F: Wildfire Mitigation Activities & Cost Forecast-2026 to 2030. Idaho Power
continues to evaluate opportunities to reduce costs through enhanced communication and
Page 9

Idaho Power Company Idaho and Montana Wildfire Requirements and Recommendations
education related to wildfire and PSPS, in part through the PSPS Event Management work
discussed in Section 13.4.4 of the WMP.
IPUC Order No. 35717, Case No. IPC-E-22-27
The following contains the IPUC's directives contained within Order No. 35717 related to Idaho
Power's development of WMP filings and the content to be contained therein.
(1) Require the Company to detail relationships it has that may benefit the wildfire program,
contribute to program costs, or provide for cost sharing opportunities in the WMP.
This requirement was incorporated in the IPUC WMP Guidelines and is addressed by the
company in various sections of the WMP, including Section 4.6.Wildfire Detection Cameras,
Section 10.2.2. Fuels Reduction Shared Stewardship (Pilot), and Section 12. Government,
Industry and Peer Utility Engagement.
(2) Require the Company to provide details of all funding alternatives and sources pursued within
the WMP.
Idaho Power has pursued grant funding through the Idaho State Office of Energy and
Minerals Resources (OEMR) and Department of Energy for grid modernization and
resilience. Idaho Power continues to investigate and apply for funding opportunities.
Awarding Awarded Amount
Grant Name WMP Project/Initiative Agency ($1,000) Timeline Status
Idaho Energy Resiliency Strategic Overhead to OEMR/DOE $2,000 2025-2027 Active Project
Grant Program Round 1 Undergrounding of overhead
powerlines
Idaho Energy Resiliency Wildfire Situational OEMR/DOE $1,499 2027 Under DOE
Grant Program Round 2 Awareness Equipment-- Review
Weather Stations,Cameras,
line monitors
2026 WMP Major Updates/Changes
Below is a summary of the major updates and changes to Idaho Power's WMP since it was last
filed with the IPUC on February 13, 2025, in Case No. IPC-E-25-05.
• With the passing of the WSCA and Montana Code Section 69-2-XX21, Idaho Power
created this WMP specific to Idaho and Montana addressing the requirements
contained within such newly created state statutes, as well as contemplating the nature
thereof.
1 Montana House Bill 490(2025),Chapter No. 68.Title and codification subject to determination by the Montana
Code Commissioner.
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Idaho Power Company Idaho and Montana Wildfire Requirements and Recommendations
• The content of this WMP is largely consistent with the content of the WMP filed in
February 2025; however, this version has been reorganized and streamlined for ease of
understanding and compliance with the relevant laws and regulatory requirements. The
discussions related to some mitigations have undergone minor alteration and
clarification.
• The 2025 WMP covered Idaho Power's operations in Oregon and Idaho. This WMP is
specific to Idaho Power's operations in Idaho and Montana.
• The cost benefit approach in Section 3 has been updated to more clearly describe Idaho
Power's process for ensuring a reasonable balance of mitigation costs with the resulting
reduction of wildfire risk.
• Idaho Power separated construction-type practices from the inspection and asset
management discussion. Construction-type mitigation practices are now discussed in
Section 8. Methods of Line Design.
• The WMP contains a new Section 10. Additional Preventative Actions and Programs,
which groups certain mitigations previously discussed in various other areas and
presents all Idaho Power pilot programs in one location.
• The addition of a Lessons Learned section to Section 13. Performance Monitoring
and Metrics.
• The addition of a new section—Section 14. WMP Cost Summary.
• The addition of Appendix D, which cross walks the requirements of the WSCA and
Montana Code Section 69-2-XX2, as well as other regulatory requirements with where
Idaho Power addressed such requirements within its WMP.
• The addition of Appendix E: Transmission Line Map Book that highlights the network of
Idaho Power transmission lines.
• The addition of Appendix F: Wildfire Mitigation Activities & Costs Forecast 2026-2030,
which forecasts program activities and costs for 2026 and the following four years.
Montana WMP Requirements
This Appendix D provides additional information specific to wildfire-related requirements in
Montana.
Pursuant to Montana Code Section 69-2-XX2,2 effective May 13, 2025, Idaho Power also filed
this WMP with its statutory "approval authority," as the appropriate body responsible for its
corporate governance. Montana Code Section 69-2-XX2 establishes requirements for the WMP
as to the Montana portion of this plan. The below crosswalk identifies where the plan meets
Montana Code Section 69-2-XX2's requirements.
Z Montana House Bill 490(2025).Title and codification subject to determination by the Montana Code
Commissioner.
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Idaho Power Company Idaho and Montana Wildfire Requirements and Recommendations
Montana Requirement—Montana Code 69-2-XX2 Corresponding Location in WMP
Section 2(2)(a)A wildfire mitigation plan must include description Section 2.Geographical Risk Assessment
of areas in which the electric facilities provider has electric facilities Appendix C:Wildfire Risk Zone Map Book
or electric transmission and distribution activities that may be
Appendix E:Idaho Power Transmission Asset Mapping
subject to a heightened risk of wildfire;
Section 2(2)(b)A wildfire mitigation plan must include a description Section 4.Situational Awareness and Monitoring
of the strategies and programs that the electric facilities provider Section 5.Workforce Preparedness
will use to inspect maintain,repair,and operate its electric
Section 6.Line Operations Practices
facilities;
Section 7.Infrastructure Inspection and Asset
Management
Section 8.Methods of Line Design
Section 10.Additional Preventative Actions and
Programs
Appendix A. Wildland Fire Preparedness and
Prevention Plan
Section 2(2)(c)A wildfire mitigation plan must include a description Section 9.Vegetation Management
of the strategies and programs that the electric facilities provider Section 10.Additional Preventative Actions and
will use to perform vegetation management; Programs
Section 12:Government,Industry and Peer Utility
Outreach
Appendix F.Wildfire Mitigation Activities&Cost
Forecast-2026-2030
Section 2(2)(d)A wildfire mitigation plan must include a description Section 4.Situational Awareness and Monitoring
of the strategies for modifications or upgrades to electric facilities Section 5.Workforce Preparedness
and preventative programs that the electric facilities provider will
employ to reduce the risk of its electric facilities igniting a wildfire; Section 6.Mitigation Activity:Line Operations
Practices
Section 7.Infrastructure Inspection and Asset
Management
Section 8.Methods of Line Design
Section 10.Additional Preventative Actions and
Programs
Appendix A. Wildland Fire Preparedness and
Prevention Plan
Appendix B:Wildfire Public Safety Power Shutoff Plan
Section 2(2)(e)A wildfire mitigation plan must include a description Section 6.Mitigation Activity:Line Operations
of the strategies and methods for de-energizing power lines and Practices.
modifying electric facility operations to mitigate potential wildfires Appendix B:Wildfire Public Safety Power Shutoff Plan
taking into consideration the ability of the electric facilities provider
to reasonably access the proposed electric facility to be de-
energized,the balance of the risk of wildfire with the need for
continued supply of electricity to a community,and any potential
impact to public safety,first responders,and health and
communications infrastructure;
Section 2(2)(f)A wildfire mitigation plan must include a description Section 6.Mitigation Activity:Line Operations
of the methods the electric facilities provider intends to use to Practices
restore its electrical system in the event systems are de-energized Appendix B:Wildfire Public Safety Power Shutoff Plan
for the prevention of a wildfire;
Page 12

Idaho Power Company Idaho and Montana Wildfire Requirements and Recommendations
Montana Requirement—Montana Code 69-2-XX2 Corresponding Location in WMP
Section 2(2)(g)A wildfire mitigation plan must include a description Section 14.Wildfire Mitigation Cost Summary
of the estimated incremental costs associated with implementing Appendix F:Wildfire Mitigation Activities&Cost
the plan,including system improvements and upgrades for a Forecast-2026-2030
regulated utility;
Section 2(2)(h)A wildfire mitigation plan must include a description Section 11.Public Outreach and Engagement
of the community outreach and public awareness efforts before and Appendix e:Wildfire Public Safety Power Shutoff Plan
during a wildfire season;and
Section 2(2)(i)A wildfire mitigation plan must include a description Section 12.Government Engagement,Industry,and
of the potential participation,if applicable, with state or local Peer Utility Engagement
wildland fire protection plans or wildfire mitigation plans.
Page 13

Idaho Power Company Idaho and Montana Wildfire Requirements and Recommendations
Page 14

"lip"►: s \
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IDAHO & MONTANAWILDFIR
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MITIGATIO
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Appendix E.
Idaho Power Transmission
Line Map Book
October 2025
© 2025 Idaho Power

Idaho Power Idaho Power Transmission Line Map Book
List of Figures
Figure 1
Idaho Power transmission lines.................................................................................................. 1
Figure 2
Idaho Power transmission line detail—A. Idaho/Montana ........................................................2
Figure 3
Idaho Power transmission line detail—B. Idaho/Montana.........................................................3
Figure 4
Idaho Power transmission line detail—C. Idaho/Wyoming........................................................4
Figure 5
Idaho Power transmission line detail—D. Idaho/Nevada...........................................................5
Page i

Idaho Power Idaho Power Transmission Line Map Book
Page ii

Idaho Power Idaho Power Transmission Line Map Book
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Page 1

Idaho Power Idaho Power Transmission Line Map Book
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Idaho Power transmission line detail—A. Idaho/Montana
Page 2

Idaho Power Idaho Power Transmission Line Map Book
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Idaho Power transmission line detail—B. Idaho/Montana
Page 3

Idaho Power Idaho Power Transmission Line Map Book
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Idaho Power transmission line detail—C. Idaho/Wyoming
Page 4

Idaho Power Idaho Power Transmission Line Map Book
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Idaho Power transmission line detail—D. Idaho/Nevada
Page 5

Idaho Power Idaho Power Transmission Line Map Book
Page 6

"lip"►: s \
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IDAHO & MONTANAWILDFIR
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Appendix F.
Wildfire Mitigation
Activities and Cost Forecast
2026-2030
October 2025
© 2025 Idaho Power

Idaho Power Wildfire Mitigation Activities and Cost Forecast 2026-2030
List of Tables
Table 1
Estimated O&M expenses for wildfire mitigation, $000s (2026-2030)*..................................... 1
Table 2
Wildfire mitigation forecasted capital investments, $000s, (2026-2030) *................................3
Table 3
Wildfire mitigation plan asset inspection targets (2026-2030)*................................................4
Table 4
Distribution asset management and situational awareness targets (2026-2030)**...................4
Table 5
2026-2030 vegetation management targets* ...........................................................................5
Page i

Idaho Power Wildfire Mitigation Activities and Cost Forecast 2026-2030
Page ii

Idaho Power Wildfire Mitigation Activities and Cost Forecast 2026-2030
Table 1
Estimated O&M expenses for wildfire mitigation, $000s (2026-2030)*
*As of October 1,2025.These are best-known estimates at the time of this Wildfire Mitigation Program(WMP)filing and are subject to change.These numbers are provided only for the purpose of
review and approval of this WMP pursuant to the Idaho Wildfire Standard of Care Act(WSCA).They should not be used for any other purpose.
2026 2027 2028 2029 2030
Wildfire Mitigation Program Description Forecast Forecast Forecast Forecast Forecast
A.Geographical Risk Assessment
Risk Modeling—Risk Maps,Fire Simulation,Probabilistic Model Development and Support $2,236 $2,257 $2,325 $2,325 $2,325
B.Situational Awareness and Monitoring
Weather Forecasting—System development and support,data services,climatology $72 $144 $144 $144 $144
Weather Forecasting Personnel—Fire Potential Index(FPI)and Public Safety Power Shutoff $202 $208 $214 $221 $227
(PSPS)
Weather Forecasting—Weather Station Maintenance $234 $350 $360 $382 $404
Pole Loading Modeling&Assessment(Contract service) $72 $72 $72 $75 $75
Wildfire Detection Cameras $254 $322 $349 $349 $349
C.Workforce Preparedness
Tools/Equipment $34 $10 $10 $5 $5
International Wildfire Risk Mitigation Consortium $38 $40 $40 $42 $42
D.Infrastructure Inspection and Asset Management
O&M Component of Capital Work $391 $460 $552 $607 $667
Annual O&M T&D Patrol Maintenance Repairs $187 $761 $761 $784 $706
Transmission Thermography Inspection Mitigation $48 $48 $48 $48 $48
Distribution Thermography Inspection Mitigation $48 $48 $48 $48 $48
Thermography Technician Personnel $165 $170 $175 $180 $185
Transmission Wood Pole Fire Resistant Wraps $250 $250 $250 $250 $250
Wildfire Mitigation Program Labor $1,194 $1,523 $1,630 $1,679 $1,730
Patrolmen for Wildfire Pre-Season Inspections in Wildfire Risk Zones $157 $161 $166 $171 $176
Covered Wire Evaluation—Pilot Program in PSPS Zones $14 $0 $0 $0 $0
Page 1

Idaho Power Wildfire Mitigation Activities and Cost Forecast 2026-2030
2026 2027 2028 2029 2030
Wildfire Mitigation Program Description Forecast Forecast Forecast Forecast Forecast
Drone Beyond Visual Line of Sight Waiver for PSPS Patrols $0 $0 $115 $0 $0
Aerial Drone Inspection Pilot $675 $869 $895 $922 $950
E.Vegetation Management
Transition to/Maintain 3-year Vegetation Management Cycle(includes Enhanced Practices $45,282 $39,837 $41,231 $45,354 $46,715
for Distribution Tier 3&Tier 2 Risk Zones)
Internal Tree Trimming Crew $381 $335 $347 $382 $393
Line Clearing Personnel $198 $204 $210 $217 $223
Fuel Reduction Program $72 $72 $72 $72 $72
F.Public Outreach and Engagement
Wildfire/Wildfire Mitigation Education/Communication—Advertisements,Bill Inserts, $164 $164 $164 $164 $164
Meetings,Other&PSPS Customer Education/Communication—Advertisements,Bill
Inserts,Other
Public meetings/event fees for PSPS engagement,maps,flyers $8 $10 $10 $10 $10
Community and Customer Engagement and Outreach $160 $171 $176 $181 $187
G.Line Operations Practices PSPS/Emergency Preparedness and Technology
Communication/Alert Tool development(System set up,outage maps,critical facilities $0 $0 $5 $0 $0
identification)
Communication/Alert Tool for PSPS Customer Alerts/Extended Use $215 $225 $200 $200 200
Fire Suppression Resources $183 $188 $194 $200 $206
Standby Helicopter Service $536 $563 $591 $609 $627
Community Resource Centers $5 $5 $5 $5 $5
Total $53,473 $49,220 $51,093 $55,352 $56,853
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Idaho Power Wildfire Mitigation Activities and Cost Forecast 2026-2030
Table 2
Wildfire mitigation forecasted capital investments, $000s, (2026-2030)
2026 Planned 2027 Planned 2028 Planned 2029 Planned 2030 Planned
Mitigation Program Program Description in Service in Service in Service in Service in Service
Overhead Primary Systematic replacement and upgrades of $19,500 $21,700 $24,500 $42,140 $48,035
Hardening Program hardware and equipment
Strategic Select conversion of overhead to underground $12,000 $12,000 $12,000 $18,000 $18,000
Undergrounding distribution in Tier 3 Risk Zones
Recloser Segmentation Installation,relocation,and expanded $200 $1,000 $500 $200 $200
and Communication communication for automatic reclosing
Upgrades overcurrent protection devices
Wildfire Detection Cameras enabled with artificial intelligence to $50 $70 $0 $0 $0
Cameras detect smoke and notify first responders
Atmospheric Science Installation of weather stations to gain situational $1,223 $890 $68 $70 $72
Weather Stations awareness
Total $32,973 $35,660 $37,068 $60,410 $66,307
*These are estimates only.The costs may increase or decrease due to such factors as inflation or scope changes.These numbers are provided only for the purpose of review and approval of this WMP
pursuant to the WSCA.They should not be used for any other purpose.
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Idaho Power Wildfire Mitigation Activities and Cost Forecast 2026-2030
Table 3
Wildfire mitigation plan asset inspection targets (2026-2030)*
Wildfire Mitigation Plan Asset Inspection Initiatives 2026 Goal 2027 Goal 2028 Goal 2029 Goal 2030 Goal
Transmission Inspections
Wildfire Pre-Season Patrol—Tier 3 Risk Zones(Structures) 1,118 1,118 1,118 1,118 1,118
Infrared Thermography Patrol(Structures) 1,118 1,118 1,118 1,118 1,118
Distribution Inspections
Wildfire Pre-Season Patrol—Tier 3 Risk Zones and select Tier 2 Risk Zones(Poles) 19,382 19,382 19,382 19,382 19,382
Infrared Thermography Patrol—Tier 3 Zones(Poles) 4,000 4,000 4,000 4,000 4,000
*The targets shown are based on the current number of poles and structures and on the contents of Idaho Power's 2026 WMP.They are subject to change in future WMPs.
Table 4
Distribution asset management and situational awareness targets (2026-2030)**
Initiative Wildfire Mitigation Plan Activity 2026 Planned 2027 Target 2028 Target 2029 Target 2030 Target
Distribution System System Hardening(miles) 72 75 80 130 140
Hardening* Overhead Line Converted to Underground(miles) 20 20 20 25 25
Feeder Segmentation Installation or Relocation of Automatic Reclosing 5 24 12 4 4
Devices
Wildfire Detection Cameras enabled with artificial intelligence to 2 2 0 0 0
Cameras detect smoke and notify first responders
Atmospheric Science Installation of weather stations to gain situational 55 38 3 3 3
Weather Stations awareness
*Excludes reliability improvement projects outside of wildfire risk zones
* The targets shown are based on the contents of Idaho Power's 2026 WMP.They are subject to change in future WMPs.
Page 4

Idaho Power Wildfire Mitigation Activities and Cost Forecast 2026-2030
Table 5
2026-2030 vegetation management targets*
Wildfire Mitigation Plan Vegetation Management Initiatives 2026 Goal (ID) 2027 Goal(ID) 2028 Goal(ID) 2029 Goal(ID) 2030 Goal (ID)
Transition to a 3-Year Pruning Cycle(Circuits) 213 150 223 213 150
Annual Patrol—Tier 3&Tier 2 Risk Zones(Circuits) 139 139 139 139 139
Annual Mitigation—Tier 3&Tier 2 Risk Zones(Circuits) 139 139 139 139 139
Mid-Cycle Patrols—Tier 3&Tier 2 Risk Zones(Circuits) 15 46 46 15 46
Mid-Cycle Pruning—Tier 3&Tier 2 Risk Zones(Circuits) 15 46 46 15 46
Identified Hazard Trees Pruned 100%of all 100%of all 100%of all 100%of all 100%of all
identified identified identified identified identified
Identified Hazard Trees Removed 100%of all 100%of all 100%of all 100%of all 100%of all
identified identified identified identified identified
Audits of Pruning Activities—Tier 3&Tier 2 Risk Zones(Worksites) 100%of all 100%of all 100%of all 100%of all 100%of all
identified identified identified identified identified
*Idaho Power strives to meet the targets identified herein but may not meet them in all cases.The targets shown are based on the contents of Idaho Power's 2026 WMP.They are subject to change in
future WMPs.
Page 5