20251030Comments_1.pdf

RECEIVED
American Property Casualty October 30, 2025
IDAHO PUBLIC
10- Insurance Association UTILITIES COMMISSION
INSURING AMERICA apci.org
LYN DARRINGTON ELLIOTT
VICE PRESIDENT,
STATE GOVERNMENT RELATIONS
October 31, 2025
Commissioners Edward Lodge,John R. Hammond,Jr.,
and Dayn Hardie
Idaho Public Utilities Commission
11331 W. Chinden Blvd.
Building 8, Suite A
Boise, ID 83714
Sent electronically via Email to [e-mail]
RE: Consideration of American Property Casualty Insurance Association Wildfire Mitigation Standards in
Utility Wildfire Mitigation Plan Review
Dear Commissioners Lodge, Hammond, and Hardie:
On behalf of the American Property Casualty Insurance Association (APCIA)l, I commend the Idaho Public
Utilities Commission for its leadership in implementing wildfire mitigation standards for utilities, pursuant to
the enactment of Senate Bill 1183(2025),the Wildfire Standard of Care Act.This legislation requires electric
utilities to submit wildfire mitigation plans and authorizes the Commission to review, approve, and enforce
those plans to ensure public safety and infrastructure resilience. As Idaho continues to face increasing
wildfire risks,the Commission's proactive approach to utility oversight is both timely and essential.
As the Commission evaluates utility wildfire mitigation plans under this framework, we respectfully urge
consideration of APCIA's wildfire mitigation plan standards.These standards reflect best practices developed
through extensive research into existing and emerging knowledge and best practices in the utility-
ignited/propagated wildfire space, and are designed to reduce ignition risks, improve infrastructure
resilience, and protect Idaho communities from catastrophic wildfire loss. These principles are consistent
with the requirements outlined in SB 1183 and offer additional detail and best practices to support effective
implementation.
Summary of APCIA Wildfire Mitigation Framework:
APCIA's framework outlines comprehensive standards for utility wildfire mitigation plans, including:
• Risk Assessment& Plan Implementation: Utilities should identify and prioritize wildfire risks across
their service territories, including risks from infrastructure design,topography, and climate. Plans
should include timelines, responsible personnel, and measurable objectives.
1 Representing nearly two thirds of the U.S.property casualty insurance market,APCIA promotes and protects the viability of private
competition for the benefit of consumers and insurers.APCIA represents the broadest cross-section of home,auto,and business
insurers of any national trade association.APCIA members represent all sizes,structures,and regions,protecting families,
communities,and businesses in the U.S.and across the globe.
555 12th Street, NW, Suite 550,Washington, DC 20004 1 202-828-7100
8700 W. Bryn Mawr Avenue,Suite 1200S,Chicago, IL 60631-3512 1847-297-7800

• Infrastructure Hardening&Maintenance: Utilities should harden electricity generation,
transmission, and distribution infrastructure through a continuous process of repair, replacement,
and upgrading of equipment, including appropriate undergrounding, insulating, and covering of
conductors and undertaking other equipment upgrades. Plans must detail compliance with national
safety codes and standards (e.g., IEEE, ANSI, NEMA, RUS).
• Vegetation Management: Utilities must follow rigorous vegetation management protocols and
comply with standards such as FERC FAC-003-4 and ANSI A300.
• Rights-of-Way Access: Procedures should be in place for timely access to federal, state, tribal, and
private lands for wildfire mitigation activities, including emergency protocols.
• Service Interruption &Restoration: Plans should include criteria and technologies for Public Safety
Power Shutoffs (PSPS),fault detection, and rapid restoration procedures.
• Public Outreach &Coordination: Utilities must engage communities,first responders, and critical
infrastructure providers, and educate residents on wildfire preparedness programs.
• Technology&Monitoring: Utilities should deploy weather monitoring,AI-powered sensors, drones,
and satellite imagery to predict and mitigate wildfire risks.
• Coordination with Officials: Plans should include communication protocols with local, state, tribal,
and federal emergency response agencies.
A copy of APCIA's full wildfire mitigation framework is attached for your reference. We welcome the
opportunity to discuss these standards further and explore ways to support Idaho's wildfire resilience
efforts. Feel free to reach out to me at 720-610-9473 or [e-mail] if you have any questions.
Thank you for your continued commitment to public safety and utility accountability.
Sincerely,
Lyn Darrington Elliott
Vice President, State Government Relations
Cc: Director Dean Cameron, Idaho Department of Insurance
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WILDFIRE PREVENTION AND MITIGATIONSTANDARDS
Summary
APCIA advocates for electric utilities and communities to take meaningful steps to prevent
wildfires and to mitigate loss should a wildfire occur so as to prevent or reduce loss of life
and property. This requires purposeful efforts aimed at adopting and implementing
appropriate infrastructure hardening and land management standards, along with utilization
of all available preventive, mitigation, and predictive best practices and technologies. It also
includes focus on and dedication to routine maintenance, repair, and replacement of
infrastructure so as to limit risk and enhance safety. Following is a list of standards APCIA
believes electric utilities, regulatory bodies, and public policymakers should adopt and
implement to protect individuals, businesses, and communities from utility-related wildfire
loss.
Wildfire Mitigation Plan Standards
Electric utilities should be required to adopt Wildfire Mitigation Plans (WMPs), without being
granted any liability protections in exchange for doing so, and which should contain the
following:
General Information; Risk Assessment; Plan Implementation
1) The overall objectives of the plan and the timelines for operational izing each plan
activity.
2) A description of the preventive strategies and programs to be adopted by the electric
utility to minimize the risk of its electrical equipment causing catastrophic wildfires,
including consideration of dynamic climate change risks and risks related to the
wildland-urban interface and a timeline for doing so.
3) A methodology for an ongoing process to identify enterprise-wide wildfire-related
risks and a plan and timeline for developing and implementing the methodology.
4) A list that identifies, describes, and prioritizes all identified wildfire risks, and drivers
for those risks, throughout the electric utility's service territory, including all relevant
wildfire risk and risk mitigation information. The list shall include, but not be limited
to, the following:
a. Risks and risk drivers associated with design, construction, operations, and
maintenance of the electric utility's equipment and facilities.
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WILDFIRE PREVENTION AND MITIGATIONSTANDARDS
b. Particular risks and risk drivers associated with topographic and climatological risk
factors throughout the different parts of the electric utility's service territory.
c. Particular risks and risk drivers associated with the speed with which wildfire risk
mitigation measures can and will be deployed by an electrical corporation within
its service territory.
5) A description of the actions the electrical corporation will take to ensure its system
will achieve the highest level of safety, reliability, and resiliency, taking into account
the cost and time required to achieve those benefits, and to ensure that its system is
prepared for a major event, including hardening and modernizing its infrastructure
with improved engineering, system design, standards, equipment, and facilities,
such as undergrounding, insulating of distribution wires, and replacing poles.
6) A description of the processes and procedures the electric utility will use to do all of
the following:
a. Monitor and audit the implementation of the plan, including a description of the
metrics the electric utility will to use to evaluate the plan's performance and the
assumptions that underlie the use of those metrics.
b. Identify any deficiencies in the plan or the plan's implementation and correct those
deficiencies.
c. Monitor and audit the effectiveness of electrical line and equipment inspections,
including inspections performed by contractors, carried out under the plan and
other applicable statutes and commission rules.
7) A showing that the electric utility has an adequately sized and trained workforce to
promptly restore service after a major event, taking into account employees of other
utilities pursuant to mutual aid agreements and employees of entities that have
entered into contracts with the electrical corporation.
8) A description of areas within the service territory or facility locations of the electric
utility, specifically identifying those areas that may be subject to a heightened risk of
wildfire currently or based on emerging trends.
9) The individual(s) in charge of filing, oversight, implementation, and compliance with
the filed WMP and contact information for each listed individual.
Compliance with Standards and Best Practices: Infrastructure Maintenance, Repair,
Upgrade, and Hardening
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WILDFIRE PREVENTION AND MITIGATIONSTANDARDS
10) A description of the procedures, standards, and timelines that the electric utility will
use to install, regularly inspect, maintain, repair, and operate its generation,
transmission, and distribution infrastructure to reduce the risk of its infrastructure
igniting or facilitating the spread of a wildfire, including a signed certification by the
chief operating officer of the electric utility that the electric utility is in compliance with
National Electrical Safety Code (NESC or ANSI C2).
11) A description of the timeframe during which the electric utility will review and ensure
generation, transmission, and distribution equipment compliance, as applicable, with
the following standards and best practices (including a description of the rationale for
exclusion of compliance with any of the following):
a. Standards and best practices as developed by the Institute of Electrical and
Electronics Engineers' (IEEE) Power Transmission and Distribution Standards.
b. Electrical Commissioning Specifications (ECS) ECS-2024 standard for
commissioning electrical power equipment published by the American National
Standards Institute (ANSI) and International Electrical Testing Association (NETA).
c. Any applicable standards promulgated by National Electrical Manufacturers
Association (NEMA) or Advancing Standards Transforming Markets (ASTM).
d. Rural Utilities Service (RUS) codes and guidelines.
12) A description of proposed modifications or upgrades to facilities and preventative
programs that the electric utility will implement to reduce the risk of its electric
facilities igniting or facilitating the spread of a wildfire, including undergrounding
wires, installing hardware and software needed to implement the existing
technologies, and identifying and adopting emerging and proven technologies. A
timeline for implementation of the proposed modifications, upgrades, and
preventative programs shall be included.
13) Electric utilities shall review and incorporate applicable Department of Energy,
Federal Energy Regulatory Commission, North American Reliability Corporation, and
state public utility commission standards and best practices in all aspects of
electricity generation, transmission, and distribution.
14) An accounting of all transmission facilities, including a list of facilities that are in
service, facilities that are out of service, and permanently abandoned facilities that
are transmission facilities. For permanently abandoned facilities that are
transmission facilities, the plan shall include a process and timeline when each
abandoned facility will be removed and the wildfire mitigation measures that are
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WILDFIRE PREVENTION AND MITIGATIONSTANDARDS
being implemented to prevent hazards related to those facilities prior to removal,
including, but not limited to, induction risks.
15) A description of where and how the electrical corporation considered
undergrounding or insulating electrical power lines within those areas of its service
territory identified to have the highest wildfire risk.
Vegetation Management
16) A description of the procedures, standards, and timelines that the electric utility will
use to perform ongoing vegetation management, including annual patrols of
transmission corridors, hazard tree identification and remediation, vegetation pruning
and removal, right-of-way maintenance, quality assurance and control, notification
and mitigation procedures, and imminent threat response processes.
17) In addition to an individual electric utility's procedures and standards, confirmation
should be made regarding the electric utility's compliance with the following:
a. Federal Energy Regulatory Commission (FERC) Standard FAC-003-4, or
successor standard(s).
b. American National Standards Institute (ANSI) Standard Z133.1 Arboricultural
Operations— Pruning, or successor standard(s).
c. ANSI Standard A300 (Part 1) —Tree, Shrub, and Other Woody Plant Management
— Standard Practices (Pruning); (Part 7) — Integrated Vegetation Management a.
Utility Rights-of-way practices; and (Part 9) —Tree Risk Assessment a. Tree
Structure Assessment, or successor standard(s).
d. National Electrical Safety Code Section 218, or successor standard(s).
e. Rural Utilities Service (RUS) codes and guidelines.
Rights-of-Way Access
18) The electric utility shall describe procedures for accessing rights-of-way (ROWs)
owned by federal, state, and tribal governments. Such procedures shall include the
following:
a. A provision stating that when an electric utility submits a written request for access
to a right-of-way on federal, state, or tribal lands to conduct vegetation
management, infrastructure maintenance, repair, or upgrading, and other wildfire
prevention and mitigation activities consistent with its approved WMP, the relevant
authority shall respond within 30 calendar days of receipt of the written request. If
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WILDFIRE PREVENTION AND MITIGATION PLAN STANDARDS
no written objection or formal denial is issued within that period, the request shall
be deemed approved on the 30th day, authorizing the utility to proceed with the
proposed activities, subject to applicable environmental and safety standards. In
cases of imminent wildfire risk or hazard tree removal, electric utilities may
proceed without prior approval, consistent with federal and state vegetation
management standards and relevant agency protocols.
b. The WMP shall further provide that electric utilities shall coordinate with federal,
state, and tribal governments to ensure timely access to ROWs and may establish
master agreements to streamline routine vegetation management activities.
Where appropriate, memorandums of understanding (MOUs) shall be utilized
between the electric utility and state, tribal, and federal agencies to streamline
processes and promote consistent best vegetation management and
infrastructure hardening practices. At a minimum, Bureau of Land Management
(BLM) and Federal Energy Regulatory Commission (FERC) vegetation
management standards shall be complied with in ROWs.
c. The electric utility shall provide for a notice mechanism to alert impacted federal,
state, and tribal entities of the access protocols.
19) Electric utility shall describe procedures for accessing privately owned ROWs. Such
procedures shall include the following:
a. Electric utilities shall be granted access to private lands where electric utility
infrastructure exists or is adjacent, for the purpose of conducting vegetation
management, infrastructure maintenance, repair, or upgrading, and other wildfire
prevention and mitigation activities consistent with an approved WMP.
b. When an electric utility identifies hazardous vegetation on or adjacent to its
infrastructure located on private property, and such vegetation poses a
demonstrable wildfire risk, the electric utility shall submit a written request to the
landowner for access to perform vegetation management.
c. If the landowner does not respond within 30 calendar days, and no written
objection is received, the request shall be deemed approved, provided the electric
utility:
i. Has documented the risk through inspection or remote sensing.
ii. Limits activities to those outlined in its approved wildfire mitigation plan.
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WILDFIRE PREVENTION AND MITIGATIONSTANDARDS
iii. Provides notice to the local fire authority or relevant jurisdiction.
d. In cases of imminent wildfire risk or hazard tree conditions, electric utilities may
proceed with vegetation mitigation without prior landowner approval, provided:
i. The electric utility notifies the landowner and local fire authority as soon as
practicable.
ii. Activities are limited to emergency hazard reduction and follow-up
restoration.
e. After work is conducted on private land, the electric utility shall:
i. Be responsible for restoring disturbed areas to a safe and stable condition.
ii. Be exempt from liability for damages resulting from delayed or denied
access unless gross negligence is demonstrated.
iii. Comply with applicable environmental, safety, and local land use
regulations.
f. State agencies may establish voluntary agreements or incentive programs to
encourage landowner cooperation. Electric utilities may offer tree replacement
programs or other mitigation support to landowners, modeled after "Right Tree,
Right Place" initiatives.
Prevention and Mitigation Best Practices; Electric Service Interruption and Restoration
20) A description of plans and procedures for de-energizing power lines, utilizing
reclosers and fault detection technology, including the use of Public Safety Power
Shutoffs (PSPS), Protective Equipment and Device Settings (PEDS), Enhanced
Powerline Safety Settings (EPSS), Rapid Earth Fault Current Limiters (REFCL), and
any other available effective technology to mitigate potential wildfires, including
designating the person(s) responsible for determining when the use criteria are met
and implementing such event(s), taking into consideration:
a. The balance of the risk of wildfire with the need for continued supply of electricity
to a community; and
b. Any potential impact on public safety.
21) A description of the procedures, standards, and timelines the electric utility intends to
use to inspect, repair, and re-energize its electrical system in the event of an
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WILDFIRE PREVENTION AND MITIGATION PLAN STANDARDS
interruption of service due to a wildfire or the use of available preventive and
mitigation practices, including but not limited to use of Public Safety Power Shutoffs
(PSPS), Protective Equipment and Device Settings (PEDS), Enhanced Powerline
Safety Settings (EPSS), Rapid Earth Fault Current Limiters (REFCL).
Public Outreach; Service Provider Outreach
22) A description of community outreach and public awareness procedures to be
undertaken by the electric utility related to wildfire prevention and mitigation and the
timeframe for doing so. This shall include the following:
a. A plan for a community outreach program to educate community members of the
need for and benefit of utilizing Public Safety Power Shutoffs (PSPS) and
Protective Equipment and Device Settings (PEDS) and other preventative safety
measures.
b. A plan and timelines for development and use of community warning systems and
other alerts to be implemented in the event of a wildfire or in the event of
implementation of wildfire prevention and mitigation practices, including but not
limited to Public Safety Power Shutoffs (PSPS), Protective Equipment and Device
Settings (PEDS), Enhanced Powerline Safety Settings (EPSS), Rapid Earth Fault
Current Limiters (REFCL). The procedures shall direct notification to all public
safety offices, critical first responders, health care facilities, and operators of
telecommunications infrastructure with premises within the footprint of potential
de-energization for a given event.
c. Processes and timelines for identification of special-needs populations and plans
to accommodate needs for uninterrupted or minimally interrupted service for such
populations.
d. The procedures shall include consideration of enabling residents within a
household who are not the customer of record to subscribe to receive notifications
related to de-energization events.
23) A plan to educate individual property owners and communities located near high-risk
electric utility transmission and distribution lines of the Institute for Business and
Home Safety Wildfire Prepared Home and Wildfire Prepared Neighborhood
programs and to encourage adoption of such standards and programs.
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WILDFIRE PREVENTION AND MITIGATION PLAN STANDARDS
24) The procedures shall include consideration of communications with public safety
partners who have the ability to coordinate with the electric utility to provide broader
messaging to affected communities.
25) A description of plans and timelines for communication and coordination with
potentially impacted critical infrastructure service providers including, but not limited
to, water, broadband, cellular communications, and transportation providers.
Use of Technology
26) A description of the procedures, standards, and timelines that the electric utility will
use to install weather monitoring devices to measure wind speed at the height of
electric equipment in areas most prone to wildfire ignition and other appropriate
technology helpful in predicting weather- or environmentally driven wildfire risk.
27) A description of technologies the electric utility intends to use to prevent and mitigate
damage from wildfires, including AI-powered cameras and sensors, ground-based
sensors, drones, and satellite imagery and timelines for implementation.
Engagement with Local and State Officials
28) A description of planned coordination, if applicable, between the electric utility and
any state or local WMPs and related activities.
29) A description of the processes and procedures that the electric utility uses to
coordinate its communications with local governments within the service area of the
electric corporation, including local, state, tribal, and federal fire officials and
emergency response officials, as part of the preparation of the wildfire mitigation
plan and during a wildfire-related emergencies.
Review, Approval, Implementation, and Enforcement
WMPs are only as good as the review, revision/updating, and enforcement processes that
apply to the environments in which they operate. Any application/approval process must be
robust, transparent, incorporate mechanisms for public participation and input, and be
ongoing. Enforcement must be prompt and meaningful. It is imperative to recognize that
these plans may be all that stand between electric utility-ignited wildfires and protection of
life, property, and wildlands.
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