20251021Petition for Reconsideration and Clarification.pdf

Kootenai Electric RECEIVED
� OCTOBER 21, 2025
COOPERATIVE
IDAHO PUBLIC
UTILITIES COMMISSION
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October 21,2025
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Via Email Only
Secretary Monica Barrios-Sanchez
Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd. Building 8, Suite 201-A
Boise, ID 83714
Email: [e-mail]
Re: Request for Reconsideration and, in the Alternative, Clarification
Case No. GNR-E-25-02
Dear Secretary Barrios-Sanchez:
Please find attached the Petition for Reconsideration and, in the Alternative, Clarification
of Kootenai Electric Cooperative, Inc., et al. ("Filing Parties") for filing in the above-referenced
proceeding. The Filing Parties respectfully request reconsideration and, in the alternative
clarification, of Idaho Public Utilities Commission Order No. 36774.
Kootenai Electric Cooperative, Inc. is acting as the lead filer of the attached Petition and
is authorized by each of the Filing Parties to file the attached Petition on their behalf. However,
neither Kootenai Electric Cooperative nor its counsel represents any person or entity other than
Kootenai Electric Cooperative, Inc. Therefore, communications regarding this file should (in
addition to the official service list) be directed to each signatory to the Petition. A List of the
Filing Parties, including contact information for each Filing Party, is attached to the Petition as
Attachment A.
Please contact me if you have any questions regarding the attached filing.
Sincerely,
Michael G. Andrea
General Counsel
Attachment
cc: Service List
9014 W. Lancaster Rd. Rathdrum, ID 83858 ff] © Q
TEL [phone] TOLL FREE 800-240-0459 1 FAX [phone]
EMAIL [e-mail] I WEB kec.com

Michael G.Andrea(ISB No. 8308)
General Counsel
Kootenai Electric Cooperative, Inc.
9014 W Lancaster Rd
Rathdrum, ID 83858
Phone: [phone]
Email: [e-mail]
Attorney for Kootenai Electric Cooperative,Inc.
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF COMMISSION }
STAFF'S APPLICATION FOR ) CASE NO. GNR-E-25-02
APPROVAL OF A FILING PROCESS FOR )
WILDFIRE MITIGATION PLANS ) PETITION FOR RECONSIDERATION
} OR,IN THE ALTERNATIVE,REQUEST
} FOR CLARIFICATION OF ORDER NO.
} 36774
Pursuant to the Idaho Public Utilities Commission's("Commission") Rules of Procedure
325, 331, and 332, Kootenai Electric Cooperative,Inc.,Lower Valley Energy,Northern Lights,
Inc., Idaho County Light&Power Cooperative, Inc., Clearwater Power Company, Lost River
Electric Cooperative, Inc.,Raft River Rural Electric Cooperative, Inc.,Fall River Rural Electric
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Cooperative, and United Electric Co-op Inc. (collectively,the"Filing Parties")' respectfully
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petition for reconsideration and, in the alternative, clarification of Order No. 36774 ("September
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Order")issued by the Commission in the above-captioned matter on September 30, 2025.
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'Each of the Filing Parties is an electric corporation(as defined in Idaho Code§61-119)and,therefore,has an
interest in Order No,36774, See September 30 Order at 21,Rule 331.01 (authorizing any person interested in a
final order to petition for reconsideration). A list of the Filing Parties, including contact information for each Filing
Party, is attached hereto as Attachment A.
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Page- 1 PETITION FOR RECONSIDERATION OR, IN THE ALTERNATIVE, REQUEST
FOR CLARIFICATION OF ORDER NO. 36774

As more fully discussed herein,the Filing Parties respectfully requests that the
Commission reconsider the following findings in the September Order:
• "WMPs must explain how an electric corporation's line design methods reduce
the potential for wildfire ignition, including a cost evaluation." September Order
at 20.
• IAIII electric corporations must include a cost-benefit analysis in their proposed
WMPs that justifies the expenditures for risk mitigation described within." Id
The Filing Parties respectfully submit that these requirements unnecessarily exceed the
requirements of the Wildfire Standard of Care Act('WSCA")and,as applied to the Filing
paltieS2,
are unduly burdensome and unreasonable. I.C. §§ 61-1801-61-1808. The Filing Parties
request reconsideration by comments and submit the following comments. See Rule 331.03.
To the extent that the Commission denies the Filing Parties' request for reconsideration,
the Filing Parties request clarification. Specifically, as more fully discussed below, the Filing
Parties request clarification of the Commission's requirements that utilities, including the Filing
Parties:
• Explain how an electric corporation's line design methods reduce the potential for
wildfire ignition,including a cost evaluation. September Order at 15, 20.
• Include a cost-benefit analysis in proposed WMPs that justifies the expenditures for
risk mitigation described within the WMPs. September Order at 20.
As more fully discussed below, it is not clear what costs should be used for the required cost
evaluation and cost-benefit analysis and how the potential for wildfire ignition and any risk
mitigation is to be calculated or quantified. Clarification is necessary to ensure that utilities are
The Filing Parties do not take any position with regard to these requirements as applied to any other entities,
including investor-owned utilities.
Page-2 PETITION FOR RECONSIDERATION OR, IN THE ALTERNATIVE, REQUEST
FOR CLARIFICATION OF ORDER NO. 36774

able to comply with the Commission's requirements. Further, without the requested
clarification, utilities will not be able to provide useful information that the Commission can use
in its review of WMPs.
I. Background
In the 2025 legislative session, the Idaho Legislature enacted the Wildfire Standard of
Care Act. 2025 Idaho Sess. Laws Ch. 249(S.B. 1183). The WSCA allows electric corporations
that are not public utilities, including the Filing Parties,to adopt and file WMPs with the
Commission "at any time permitted by the commission." I.C. § 61-1803(2)(b). The
Commission is required to approve or reject WMPs that are filed with the Commission within six
(6)months of the date such WMPs are filed. I.C. § 61-1804(1).
On June 18, 2025, Commission Staff initiated this proceeding by filing an Application for
a Wildfire Mitigation Plan Filing Process. On July 17,2025, Staff submitted its Supplement to
Application. In its Application and Supplement, Staff proposed a number of requirements and
proposed guidelines for WMPs. A number of the Filing Parties submitted comments on Staffs
Application and Supplement.3 Staff submitted reply comments on August 21, 2025.
On September 30, 2025,the Commission issued Order No. 36774 adopting most of
Staffs proposals, including guidelines regarding the content of WMPs. As discussed below,
requirements to provide cost evaluations and cost-benefit analyses imposed by the Commission
exceed the requirements of the WSCA and, at least as applied to the Filing Parties, are
unreasonable and unduly burdensome. To the extent that utilities are required to provide such
cost evaluations and cost-benefit analyses, the Commission should clarify those requirements so
Kootenai Electric Cooperative,Inc.intervened in this proceeding and submitted comments. In addition to the
Idaho Consumer-Owned Utilities Association,other Filing Parties,including Clearwater Power Company,Lost
River Electric Cooperative,Inc.,Noilhern Lights,Inc.,Raft River Rural Electric Cooperative,Inc.,United Electric
Co-op Inc.,and Idaho County Light and Power submitted public comments.
Page- 3 PETITION FOR RECONSIDERATION OR, IN THE ALTERNATIVE, REQUEST
FOR CLARIFICATION OF ORDER NO. 36774

that the Filing Parties can comply with those requirements. Absent the requested clarifications,
such cost evaluations and cost benefit analyses are burdensome and are unlikely to provide any
usefiil information to the Commission.
II. Request for Reconsideration and,in the Alternative, Clarification
A. The Commission's Requirements to Provide Cost Evaluations and Cost-
Benefit Analysis to Justify their Expenditures for Wildfire Risk Mitigation
Are Unreasonable, Unduly Burdensome, and Exceed the Requirements of the
WSCA.
In the September Order,the Commission stated that"WMPs must explain how an electric
corporation's line design methods reduce the potential for wildfire ignition, including a cost
evaluation." September Order at 15,20. The Commission further ordered that"all electric
corporations must include a cost-benefit analysis in their proposed WMPs that justifies the
expenditures for risk mitigation described within." Id. at 20. These requirements are
unreasonable,unduly burdensome, and exceed the requirements of the WSCA. See Rule 331.01.
As a threshold matter,the Filing Parties recognize that investor-owned utilities that are
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subject to the Commission's jurisdiction are required to justify their costs to the Commission.
Such justification of costs is integral to the Commission's jurisdiction to regulate those investor-
owned utilities' rates. However,all of the Filing Parties are electric corporations that are not
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public utilities and, therefore, are not subject to rate regulation by the Commission. See,e.g.,
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Bollinger v. Fall River Rural Elec. Coop., Inc., 152 Idaho 632, 641 n.7, 272 P.3d 1263, 1272 n.7
(2012) (electric cooperatives are not subject to the Commission's jurisdiction); Clearwater j
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Power Co. v. Washington Water Power Co., 78 Idaho 150, 151, 299 P.2d 484,485 (1956)
(utilities that are not public utilities are not subject to the Commission's jurisdiction);Sutton v.
Hunziker, 75 Idaho 395,401, 272 P.2d 1012, 1015 (1954). Determinations regarding each Filing
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Party's costs and rates are within the exclusive purview of that Filing Party's governing body.
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Page-4 PETITION FOR RECONSIDERATION OR,IN THE ALTERNATIVE, REQUEST
FOR CLARIFICATION OF ORDER NO. 36774

Requiring the Filing Parties to justify their costs to the Commission exceeds the requirements of
the WSCA, undermines the authority of the Filing Parties' governing bodies,and effectively
subjects otherwise non jurisdictional utilities to rate regulation by the Commission.
The WSCA requires WMPs to identify the means for mitigating wildfire risk that reflect
a reasonable balancing of mitigation costs with the resulting reduction of wildfire risk including,
among other things, financially prudent and reasonably practical methods of line design for new,
planned,and existing lines to mitigate fire risk. I.C. § 61-1803(3). In reviewing WMPs,the
Commission is required to ensure that the minimum requirements of the WSCA are satisfied and
to consider certain factors, including the"feasibility of the plan and the cost of its
implementation". I.C. § 61-1804(1). The WSCA does not require utilities to include a cost
evaluation of its methods of line design and does not require utilities to include a cost-benefit
analysis to justify to the Commission its expenditures for risk mitigation. See I.C. §§ 61-
1803(3)(e), 61-1804(1). Requiring otherwise unregulated utilities to justify their costs as
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required by the September Order exceeds the requirements of the WSCA. As the Commission
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acknowledges, "[t]he WSCA grants the Commission authority solely to approve or reject a
proposed WMP, not to regulate the rates an Unregulated Entity charges." September Order at
17.
In the September Order, the Commission requires all electric corporations, including
unregulated utilities, to include a cost evaluation regarding their line design methods and a cost-
benefit analysis to justify their expenditures. September Order at 15, 17, 20. The Commission
asserts that directing electric corporations to include a cost-benefit analysis to justify
expenditures for risk mitigation does not amount to rate regulation because, in the Commission's
view,"[r]ate regulation occurs when a government body sets the prices a company can charge."
Page-5 PETITION FOR RECONSIDERATION OR, IN THE ALTERNATIVE, REQUEST
FOR CLARIFICATION OF ORDER NO. 36774

Id. at 17. This narrow definition of rate regulation fails to recognize that requiring an otherwise
non jurisdictional utility to submit to the Commission's review of its costs—costs that are
reviewed and approved by the governing body of the utility—and further justify those costs to
the Commission undermines the authority of the unregulated utility's governing body. More
fiindamentally,any Commission determination to reject a WMP based on costs associated with a
WMP will likely result in the utility revising its WMP to modify those costs to satisfy the
Commission's requirements. Commission action requiring unregulated utilities to modify the
costs that they incur is effectively rate regulation.
The Commission acknowledges that its review of WMPs may influence unregulated
entities' decisions, including their rates. September 30 Order at 17. Nevertheless,the
Commission dismisses concerns regarding rate regulation of otherwise unregulated utilities by
asserting that subjecting themselves to such rate regulation is"entirely voluntary and subject to
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their own processes only." Id That the process for setting rates is left to the internal processes of
each unregulated utility does not change the fact that the Commission's review of costs and cost
justifications in approving or rejecting WMPs will impact those rates and,therefore, is
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effectively rate regulation. Moreover, unregulated utilities should not be forced to make the
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Hobson's choice to either submit to rate regulation by the Commission or decline the option to !
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seek a Commission-approved WMP and thereby forfeit some of the benefits provided by the I
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WSCA. See id j
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In determining the appropriate method,or level of review, for determining whether a
WMP satisfies the requirements of the WSCA, including whether the WMP(i)identifies a
means for mitigating wildfire risk that reflects a reasonable balancing of mitigation costs with the
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'It is worth noting that some cooperatives comply with the U.S. Department of Agriculture Rural Utility Service's
(RUS)line design standards. See 7 C.R.R. Part 1728.
Page - 6 PETITION FOR RECONSIDERATION OR,IN THE ALTERNATIVE,REQUEST
FOR CLARIFICATION OF ORDER NO. 36774

resulting reduction of wildfire risk,and (ii) includes financially prudent and reasonably
practicable methods of line design for new, planned, and existing lines to mitigate fire risk,the
Commission should consider the nature of the utility. See I.C. § 61-1803(1) (indicating that the
nature of the utility is a factor that should be considered in developing WMPs). Specifically,the
Commission should ensure that it is not undermining or second-guessing the authority of
unregulated utilities' governing bodies and thereby effectively engaging in rate regulation of
those utilities. Where a governing body of an unregulated utility attests(in a resolution or other
declaration submitted to the Commission)that it has reviewed the feasibility of its WMP and the
costs of its implementation and has determined that(i)the WMP reflects a reasonable balancing
of mitigation costs with resulting reduction of wildfire risk,and(ii)the methods of line design
for new,planned, and existing lines to mitigate fire risk are financially prudent and reasonably
practicable,nothing further should be required. See I.C. §§ 61-1803, 61-1804. The Commission
is to consider the feasibility of the plan and the costs of its implementation. I.C. 5 61-
1804(1)(b). Such consideration does not require the Commission to undcrinine or second-guess
determinations made by unregulated utilities' governing bodies.
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B. Request for Clarification of Requirements to Include Cost Evaluations and
Cost-Benefit Analyses in WMPs.
As discussed above, the Commission's September 30 Order requires WMPs to include an j
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explanation of"how an electric corporation's line design methods reduce the potential for
wildfire ignition, including a cost evaluation." September Order at 15. The order further starts
that"this cost evaluation need not be least-cost,least risk, but it must show how the mitigation
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project strikes the necessary `balance of mitigation costs with the resulting reduction in wildfire
risk' required by the WSCA."' Id The Wildfire Mitigation Plan Guidelines attached to the
September Order provides that WMPs "must include evaluation of costs to wildfire risk
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Page - 7 PETITION FOR RECONSIDERATION OR, IN THE ALTERNATIVE, REQUEST
FOR CLARIFICATION OF ORDER NO. 36774

reductions"and"must include how the electric corporation clearly identifies, selects, and
evaluates projects that reflect a balance of mitigation costs with resulting reduction in wildfire
risk"for certain projects including line rebuilding, undergrounding lines, installation of covered
conductor, installation of non-wooden cross arms, and flexible infrastructure. September Order
at Exhibit 1 at 5.
This requirement to provide a cost evaluation to balance wildfire mitigation costs with
wildfire risk reductions appears to be based on one or both of two incorrect premises: (i)that
projects are performed solely for the purpose of reducing wildfire risk and/or(ii)that the costs
associated with wildfire risk reduction for each such project can be easily calculated or otherwise
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determined, In practice,wildfire mitigation is just one of many reasons why a utility may
undertake any given project. Any given project may setve a number of purposes beyond wildfire
mitigation, such as improving reliability,enhancing service, and/or replacing obsolete or
outdated equipment.
Utilities do not evaluate projects based on any single need. Rather, utilities evaluate
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whether, based on all of the needs and benefits associated with a project, the costs of the project
are justified. There simply is noway to accurately allocate the cost of any given project to each }
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purpose for which the project was undertaken.5 Any attempt to allocate a portion of the costs to
such purposes, including wildfire mitigation,would be purely academic and arbitrary and
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ultimately would not reflect any actual cost attributable solely to wildfire mitigation. Simply
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allocating 100 percent of the cost to wildfire mitigation(and explaining that the project serves
s The cost evaluations and cost-benefit analyses that the Commission requires may be useful in decision making
when the inputs for the decision to be made are quantifiable and the decision is quantitative in nature. Here,given
the multitude of purposes for undertaking any project that may also include wildfire mitigation benefits,the analysis
is qualitative,not quantitative,and therefore such evaluations and analyses are not useful for purposes of evaluating
whether a WMP satisfies the requirements of the WSCA.
Page- 8 PETITION FOR RECONSIDERATION OR,IN THE ALTERNATIVE, REQUEST
FOR CLARIFICATION OF ORDER NO. 36774

other purposes)as Staff suggestsb,would significantly overstate the costs associated with any
project that are actually attributable to wildfire mitigation and would effectively result in
Commission regulation of all utility operations.?
Even assuming the costs of any project that are fairly attributable to wildfire mitigation
could be accurately determined,it is unclear how a utility is to quantify the resulting reduction in
wildfire risk or how the utility is to balance the costs attributable to wildfire mitigation with such
resulting reduction in wildfire risk.$ Given that neither the costs attributable to wildfire
mitigation nor the wildfire risk reductions associated with such costs can be accurately
determined, it is unclear what evaluation or other information the Commission requires regarding
how a utility"identifies, selects,and evaluates projects that reflect a balance of mitigation costs
with the resulting reduction in wildfire risk." See September Order at Exhibit I at 5.
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6 In its Reply Comments,Staff states:
Staff understands that wildfire mitigation is only one part of an electric corporation's operations,and many
projects will cross the line from pure wildfire mitigation into other purposes.Staff does not believe
allocation of costs is needed.Instead,it would be better to include the full costs of the project within the
WMP and then mention that there were other criteria beyond just wildfire mitigation for each project with
an explanation of those criteria.Additionally,Staff suggests that if any mitigation effort is done with
extended benefits beyond wildfire mitigation,the electric corporation should describe how its work is either
part of SOP or is incremental to its SOP within the WMP. Staff believes that most,if not all,of this f
information should be available as it would be used in the approval process by the electric corporations'
governing boards.
Reply Comments at 8-9. J
'In addition to overstating the costs associated with any project that are actually attributable to wildfire mitigation, s
including the full costs of any project will result in Commission regulating of not just wildfire mitigation costs,but
also costs associated with reliability and other operating and capital costs of otherwise unregulated utilities. Such
regulation significantly exceeds the scope of the WSCA.
s Idaho Power Company noted in its recently filed Wildfire Mitigation Plan: "Ultimately,Idaho Power found that
obtaining a precise calculation of the potential costs of future wildfires is not possible." Idaho Power Company
Wildfire Mitigation Plan submitted in IPC-E-25-32 at page 15. Instead of providing a cost-benefit analysis,Idaho
Power Company notes the substantial costs associated with recent wildfires. To be sure,the cost of wildfires can,as
Idaho Power notes,be substantial and that substantial cost almost certainly outweighs the costs of mitigation.A
cost-benefit analysis is not only impossible to perform;such analysis is not necessary to demonstrate that costs of
wildfires,while unknown and unquantifiable in advance,are substantial and can outweigh any costs of mitigation.
Page - 9 PETITION FOR RECONSIDERATION OR, IN THE ALTERNATIVE, REQUEST
FOR CLARIFICATION OF ORDER NO. 36774

The September 30 Order further requires all electric corporations to"include a cost
benefit analysis in their proposed WMPs that justifies the expenditures for risk mitigation
described within." September Order at 20. The Commission does not provide any guidance on
how this required cost-benefit analysis is to be performed.
As discussed above,the WSCA does not include any requirement to provide the cost
evaluation or the cost-benefit analysis to justify expenditures for wildfire risk mitigation that the
Commission requires in the September Order. The WSCA merely requires (i)that WMPs
identify a means for mitigating wildfire risk that reflects a reasonable balancing of mitigation
costs with the resulting reduction of wildfire risk, including financially prudent and reasonably
practicable methods of line design for new,planned, and existing lines to mitigate fire risk. I.C.
§§ 61-1803(3)(e). The Commission's review to ensure that WMPs satisfy these requirements j
and its consideration of the feasibility of WMPs and the costs of implementing those plans can,
as discussed above, be satisfied by relying on the Filing Parties' governing bodies' attestations.
Nothing in the WSCA requires the Commission to substitute its judgment for the judgment of the
governing bodies who are charged with regulating their respective utilities.
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To the extent that the Commission requires the Filing Parties to provide cost evaluations
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and cost-benefit analyses,the September Order does not explain how such evaluations and
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analyses are to be performed, including how utilities are to derive the costs attributable to
wildfire mitigation,how to quantify the resulting reduction in wildfire risk, or the time period to
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apply when performing such evaluations and analyses (e.g.,three year rolling period of the
WMP,the useful life of a project,or other time period). Therefore, to the extent that the
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Commission requires a cost evaluation and/or cost-benefit analysis to be included in each WMP,
the Filing Parties respectfirlly request that the Commission clarify how such evaluations and
Page - 10 PETITION FOR RECONSIDERATION OR, IN THE ALTERNATIVE, REQUEST
FOR CLARIFICATION OF ORDER NO. 36774

analyses are to be performed, including the costs that should be included in the cost evaluations
and/or cost-benefit analyses and how utilities should calculate or quantify the resulting reduction
in wildfire risk associated with those costs that are attributable to wildfire risk mitigation,and the
time period to be used in such evaluations and analyses.
For the reasons stated herein, to the extent the Commission requires cost evaluations
and/or cost-benefit analyses,the Filing Parties respectfully request that the Commission clarify
those requirements. Absent clarification and the ability to accurately perform the required cost
evaluations and cost-benefit analyses, such evaluations and analyses will not assist the
Commission in actually ensuring that any WMP"reflect[s] a reasonable balancing of mitigation
costs with the resulting reduction of wildfire risk"and includes"[fJinancially prudent and
reasonably practicable methods of line design for new,planned, and existing lines to mitigate fire
risk." I.C. § 51-1803(e).
III. Conclusion
For the reasons set forth above, the Filing Parties respectfully request reconsideration of
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the September 30 Order. To the extent that the Commission denies reconsideration and requires i
the Filing Parties to provide the cost evaluation and/or cost-benefit analysis required in the j
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September Order,the Filing Parties respectfully request that the Commission clarify those
requirements to ensure that the Filing Parties can comply with the Commission's requirements
and any such evaluations or analyses provide information that is useful in the Commission's j
consideration of the feasibility and costs of implementation of WMPs.
Respectfully submitted this 21 st day of October 2025.
(signature page follows)
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Page- 11 PETITION FOR RECONSIDERATION OR, IN THE ALTERNATIVE,REQUEST
FOR CLARIFICATION OF ORDER NO. 36774

KOOTENAI ELECTRIC COOPERATIVE, NORTHERN LIGHTS, INC.
INC.
Michael G. Andrea
General Counsel Annie Terracciano
General Manager
Northern Lights, Inc.
LOWER VALLEY ENERGY IDAHO COUNTY LIGHT& POWER
COOPERATIVE, INC.
ls/Janies R. TFebb /sl jlfax Bench
James R. Webb Max Beach
President/CEO General Manager
CLEARWATER POWER COMPANY RAFT RIVER RURAL ELECTRIC
COOPERATIVE INC.
lsl Chad Black
Chad Black
General MAnager
Telly Stanger
General Manager/CEO
LOST RIVER ELECTRIC COOPERATIVE, FALL RIVER RURAL ELECTRIC
INC. COOPERATIVE
Brad J. Garnett Biyan L. Case
General Manager CEO/General Manager
UNITED ELECTRIC CO-OP INC.
Michael Darrington
General Manager
Page - 12 PETITION FOR RECONSIDERATION OR, IN THE ALTERNATIVE, REQUEST
FOR CLARIFICATION OF ORDER NO. 36774

ATTACHMENT A
(List of Filing Parties)
KOOTENAI ELECTRIC COOPERATIVE, NORTHERN LIGHTS, INC.
INC.
Claire Babcock
Michael G. Andrea Northern Lights,Inc.
General Counsel PO Box 269
Kootenai Electric Cooperative, Inc. Sagel, ID 83860
9014 W. Lancaster Rd. Email: [e-mail]
Rathdrum, ID 83858
Email: [e-mail]
Thomas Maddalone
Safety Director
Kootenai Electric Cooperative, Inc.
9014 W. Lancaster Rd.
Rathdrum,ID 83858
Email: [e-mail]
LOWER VALLEY ENERGY IDAHO COUNTY LIGHT&POWER
COOPERATIVE, INC.
Jon Hougland
Lower Valley Energy Maas Beach
PO Box 188 General Manager
Afton, WY 83110 ICL&P
Email: jhougland@]venergy.c°rn 1065 Idaho State Highway 13 Scenic
Grangeville, ID 83530
Email: [e-mail]
CLEARWATER POWER COMPANY RAFT RIVER RURAL ELECTRIC
COOPERATIVE INC.
Telly Stanger
General Manager/CEO Chad Black
Clearwater Power Company General Manager
230 Hatwai Rd Raft River Rural Electric Cooperative Inc.
Lewiston, ID 83501 PO Box 617
Email: [e-mail] Malta,ID 83342
Email: [e-mail]
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CERTIFICATE OF SERVICE
I HEREBY CERTIFY that I have this 21 st day of October 2025, served the foregoing
Petition for Reconsideration or, in the Alternative, Request for Clarification of Order No. 36774
upon all parties of record in this proceeding by electronically providing a copy thereof to:
Commission Staff:
Adam Triplett
Deputy Attorney General
Idaho Public Utilities Commission
PO Box 83720
Boise,ID 83702-0074
Email: [e-mail]
Avista Corporation:
Anni Glogovac Elizabeth Andrews
Counsel for Regulatory Affairs Sr. Manager of Revenue Requirements
PO Box 3727 PO Box 3727
1411 E. Mission Ave.,MSC-13 1411 E. Mission Ave.,MSC-27
Spokane, WA 99220-3727 Spokane, WA 99220-3727
Email: [e-mail] Email: [e-mail]
w/copy to:
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[e-mail]
Bennett Lumber Products,Inc.
Idaho Forest Group
Manulife Investment Management,
Molpus Woodlands Group,
Stimson Lumber Company:
Pendrey P. Trammell
Smith+Malek, PLLC J
601 E. Front Ave., Ste, 304
Coeur d'Alene,ID 83814
Email: service@smitltnalek,coin
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CERTIFICATE OF SERVICE j

City of Idaho Fails:
Stephen Boorman Michael A. Kirkham
Interim General Manager City Attorney
City of Idaho Falls, Idaho—Idaho Falls Power City of Idaho Falls,Idaho
PO Box 50220 PO Box 50220
140 S. Capital Ave. 375 "D" Street
Idaho Falls,ID 83402 Idaho Falls, ID 83402
Email: [e-mail] Email: [e-mail]
Idaho Department of Lands:
J.J. Winters Tyre Holfeltz
Attorney for Idaho Department of Lands Wildfire Risk Mitigation Program Manager i
300 N. 6111 Street, Ste. 103 300 N. 61h Street, Ste. 103
Boise, ID 83702 Boise,ID 83702
Email: [e-mail] Email: [e-mail]
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Idaho Power Company: i
Megan Goicoechea Allen Tim Tatum
Donovan E. Walker Riley Maloney
Lisa C. Lance Connie Aschenbremier
Idaho Power Company Idaho Power Company
PO Box 70 PO Box 70
Boise, ID 83707 Boise,ID 83707
Email: mg oicoecheaallen@idaho Email: [e-mail]
[e-mail] [e-mail]
[e-mail] [e-mail]
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w/copy to:
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[e-mail]
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PotlatchDeltic Corporation:
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Michele Tyler, Esq.
Peter J. Richardson Anna Torma I
Richardson Adams,PLLC Wade Semeliss 1
515 N. 2711 St. Brian Schlect, Esq.
Boise, ID 83702 601 W. First Ave. Ste. 1600
Email: [e-mail] Spokane, WA 99201
Email: [e-mail]
[e-mail]
[e-mail]
[e-mail]
potlatchdeltic.com
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CERTIFICATE OF SERVICE

Risch Pisca,PLLC
Attn: Jeremy Pisca
407 W. Jefferson Street
Boise,ID 83702
Email: [e-mail]
Rocky Mountain Power:
Mark Alder Joe Dallas
Idaho Regulatory Affairs Manager Senior Attorney
1407 West North Temple, Suite 330 825 NE Multnomah, Suite 2000
Salt Lake City,Utah 84116 Portland, OR 97232
Email: [e-mail] Email: [e-mail]
ls/Michael G. Andrea
Michael G. Andrea
General Counsel
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CERTIFICATE OF SERVICE