20251125Comment_1.pdf

From: Michael Niemann <[e-mail]>
Sent:Tuesday, November 25, 2025 2:57 PM
To: secretary<[e-mail]>
Subject:AiDash Comment to IPC-E-25-32
Hello. I just submitted a comment to IPC-E-25-32 indicating we would send the file. Here
is the file for the comment. Please let me know if you need anything or have any questions.
Thanks,
Mike Niemann
Head of Strategic Partnerships
michaelCa)aidash.com
206.288.9049
Creating a
Al.7A*HV*T1.4 planet from space
The following comment was submitted via PUCWeb:
Name: Michael Niemann
Submission Time: Nov 25 2025 2:53PM
Email: michael(a)aidash.com
Telephone: [phone]
Address: 575 High ST, #200
Palo Alto , CA 94301
Name of Utility Company: NA
Case ID: IPC-E-25-32
Comment: "AiDash comments in the matter of Idaho Power Company's application for
approval of its 2026 Wildfire Mitigation Plan. Comment file submitted via email to
secretaryfpuc.idaho.gov. "
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER COMPANY'S
APPLICATION FOR Case Number: IPC-E-25-32
APPROVAL OF THE COMPANY'S 2026
WILDFIRE MITIGATION PLAN
COMMENTS OF AIDASH INC. ON IPC-E-25-32
Michael Niemann
AiDash, Inc.
575 High Street, Suite 200
Pa to Alto, CA 94301
[e-mail]
I. INTRODUCTION
AiDash Inc. ("AiDash") respectfully submits these comments regarding Idaho
Power Company's 2026 Wildfire Mitigation Plan ("WMP"). AiDash commends Idaho
Power and the Idaho Public Utilities Commission ("Commission")for their
Leadership under the Idaho Wildfire Standard of Care Act in advancing wildfire
safety and resilience statewide. Idaho Power has already taken several prudent
steps under the Wildfire Standard of Care Act, including expanded vegetation
management patrols, targeted asset inspections in high-risk areas, and initial
development of data-driven prioritization frameworks.These efforts demonstrate
the Company's commitment to prevention and provide a strong foundation on
which to continue building a risk-informed, outcomes-oriented wildfire mitigation
strategy.
This proceeding marks Idaho's first comprehensive review of a Wildfire Mitigation Plan
under the new statutory framework. It presents an important opportunity to establish a
consistent, data-driven foundation for wildfire risk management—one that prioritizes
prevention, continuous improvement, and measurable outcomes. AiDash's
recommendations are intended to complement and enhance Idaho Power's existing
programs, supporting the Company's transition toward increasingly data-supported
planning and operational decision-making. AiDash supports Idaho Power's commitment to
reducing ignition risks through vegetation management, infrastructure hardening, and
operational controls, and offers these comments to strengthen alignment with national
best practices.
Idaho's diverse terrain, growing wildland-urban interface, and evolving fire weather patterns
create unique challenges for utility operators. The variability in vegetation density and the
scale of Idaho Power's service territory make continuous visibility and dynamic risk
assessment especially valuable. Modern satellite and AI-driven approaches are well suited
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to Idaho's geography, where ground-based inspections alone may not fully capture shifting
vegetation and environmental conditions. Transitioning from traditional risk assessment
methods to proactive, data-driven strategies around vegetation management helps utilities
optimize resource allocation, enhance operational resilience, and support their risk-
mitigation goals. These practices directly align with Idaho Power's emphasis on vegetation
management as a central pillar of its Wildfire Mitigation Plan.
AiDash also participates in the Prevention First Wildfire Mitigation Partnership, a
coordinated ecosystem of wildfire-mitigation solution providers. This partnership has
developed a fully integrated approach to wildfire mitigation best practices. Under this
prevention-first framework, AiDash integrates its vegetation, asset, and ignition intelligence
with complementary capabilities such as fire-spread modeling, camera-based detection,
fuel-reduction technologies, and operational grid-management platforms. Notably, this
includes an integration with Schneider Electric's operational platforms which allows
intelligence generated through AiDash and partner models to be converted directly into
operational actions (e.g., switching strategies, sectionalizing, EPSS, or targeted PSPS). This
ecosystem approach reduces blind spots between planning, modeling, and execution,
providing a more comprehensive prevention strategy that is increasingly valuable as
wildfire mitigation programs mature.
II. THE COMMISSION SHOULD CONSIDER THE IMPLEMENTATION OF INNOVATIVE
TECHNOLOGIES TO ADDRESS WILDFIRE MITIGATION
Vegetation remains a leading driver of wildfire ignition risk and one of the largest ongoing
operations and maintenance expenses for electric utilities. Consistent with the Wildfire
Standard of Care Act's emphasis on prudent, evidence-based practices, AiDash supports
the inclusion of a dedicated "continuous improvement"section in future WMP updates.
This section would outline how Idaho Power evaluates, pilots, and adopts innovative
vegetation management technologies overtime, ensuring that mitigation practices evolve
alongside emerging data, conditions, and proven methods.
Modern satellite and AI-powered vegetation intelligence platforms provide daily visibility
into vegetation conditions across entire service territories. These tools enable utilities to:
• Monitor fuel moisture, connectivity, and encroachment dynamically;
• Identify hazard trees and high-risk corridors proactively; and
• Quantify vegetation-related risk reduction resulting from mitigation activities.
A. Cost Reduction Benefits
Better, more effective vegetation management provides cost savings to utilities by
transitioning from traditional time-based maintenance to risk-based strategies, which
optimize resource allocation. For instance, in Wisconsin, Northern States Power Company
reported achieving the"most bang-for-buck risk reduction"with AiDash's platform, which
allowed the utility to prioritize high-risk areas, reduce unnecessary expenses, and focus
resources where they were most needed.' Similarly, in Washington, Avista leveraged
' Docket No. 9713-FG-2022,Preventing Outages and Enhancing the Resilience of the Electric Grid Formula Grant
funded by The Bipartisan Infrastructure Law Awarded by the US Department of Energy,Application: 685 -Northern
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AiDash's technology in its vegetation management practices to lower operational costs
while maintaining robust wildfire mitigation efforts.2 These financial benefits are especially
vital in wildfire-prone regions, where efficient resource allocation can prevent costly
damages and mitigate operational risks.
B. Reliability Benefits
AiDash partners with utilities to implement programs that enhance grid reliability by
enabling utilities to proactively remove vegetation and decrease outages caused by trees.
In California, Bear Valley Electric Service reported improved reliability metrics through
AiDash's ability to identify and address vegetation-related risks in high-fire-threat districts.'
Similarly, in Colorado, Xcel Energy leveraged AiDash technology to mitigate outages caused
by vegetation encroachments. The partnership resulted in stable energy delivery even in
areas prone to extreme weather and wildfire risks.'
In addition to wildfire mitigation, National Grid in Massachusetts demonstrated the
reliability benefits of AiDash for maintenance pruning.' This initiative underscores the
effectiveness of AiDash's solutions in enhancing grid reliability through condition-based
maintenance strategies for a broader suite of applications, including storm mitigation.
Across these utilities, AiDash's tools have been instrumental in preventing outages caused
by environmental hazards.This proactive approach not only safeguards infrastructure and
protects communities but also ensures grid stability, especially under challenging
circumstances.
C. Flexibility and Scalability Benefits
AiDash's flexibility and scalability make it an ideal solution for utilities with wildfire risk that
are operating in diverse environments. Idaho Power can benefit from a similar evolution by
transitioning from schedule-based vegetation management to risk-based, continuously
informed practices that target resources where they provide the greatest safety and
reliability benefit. These approaches build on Idaho Power's existing vegetation
management and inspection programs by providing continuous, system-wide visibility that
informs more precise work planning and prioritization. As Idaho's wildfire environment
continues to evolve, adopting scalable, continuously informed vegetation strategies will
help ensure the Company's mitigation efforts remain adaptive and forward-looking.
D. Improved Consistencyand Defensibility Through Integrated Ecosystem
States Power Company-WI-Northern States Power Company-Wisconsin_Strategic Vegetation Management NW
Wisconsin at 18.
2 Docket No.UE-240006,Avista Utilities,2023 Wildfire Resiliency Plan at 25.
'Docket No. CA 2023-2025-WMPs,Bear Valley Electric Service,2025 Wildfire Mitigation Plan,Update Revision
2 at12.
°Docket No. 20A-0300E, Public Service Company of Colorado,Wildfire Mitigation Plan,2022 Annual Report at
10.
s Docket No. 23-150,Massachusetts Electric Company d/b/a National Grid,Pre-Filed Direct Testimony of Bertram
H. Stewart,III and Ryan A Moe,at page 13.
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Integration of multiple vendor solutions, as espoused by the Prevention First Wildfire
Mitigation Partnership, can also help Idaho Power strengthen the consistency and
defensibility of its wildfire-risk assessments overtime. By aligning vegetation and asset
intelligence with complementary fire-science and operational-decision tools, this
approach supports a more coherent set of assumptions and inputs—important for a utility
still developing its long-term wildfire-mitigation framework and for demonstrating year-
over-year risk reduction to the Commission.
III. PREVENTION-FIRST, DATA-DRIVEN FRAMEWORK FOR IDAHO
The Wildfire Standard of Care Act underscores the importance of prudent,
reasonable, and preventative measures to reduce ignition risk. AiDash encourages the
Commission and Idaho Power to consider a Prevention First approach—one that connects
vegetation and asset risk identification, hazard modeling, and operational decision-making
into a continuous, integrated mitigation loop. Through the Prevention First Wildfire
Mitigation Partnership, AiDash's intelligence can also be paired with complementary
capabilities such as fire-spread modeling and operational grid-management platforms
(including Schneider Electric's ADMS and distribution-automation systems)to support a
seamless transition from risk identification to preventative action. Embedding these
principles in the Idaho WMP framework can help ensure that the program evolves to
maximize quantifiable, risk-reduction outcomes rather than isolated activities and
outcomes.
AiDash recommends that Idaho Power and the Commission consider the following
practices:
• Continuous Monitoring: Incorporate near real-time vegetation and environmental
intelligence to guide operational and PSPS (Public Safety Power Shutoff) decisions.
• Dynamic Prioritization: Use risk-weighted vegetation and asset data to inform
annual work plans and resource allocation.
• Outcome Tracking: Report annual progress in terms of quantified wildfire risk
reduction, not just activity completion.
• Integrated Data Approach: Combining multiple intelligence layers with
complementary capabilities including operational grid management systems can
help ensure that the program evolves toward quantifiable, risk-reduction outcomes
rather than isolated activities.
Embedding these principles into Idaho's WMP framework will ensure that wildfire risk
mitigation evolves toward measurable outcomes rather than prescriptive actions.
IV: CONCLUSION
AiDash commends Idaho Power and the Commission for the significant progress already
made under the Wildfire Standard of Care Act. The 2026 WMP continues this strong
trajectory by advancing Idaho's commitment to protecting communities, strengthening
system reliability, and promoting a prevention-focused, data-driven approach to wildfire
mitigation.
By integrating continuous improvement, measurable risk reduction metrics, and modern
satellite and AI-based technologies, Idaho Power can enhance safety while ensuring cost-
effectiveness and transparency.
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For the reasons laid out in these comments, AiDash strongly encourages the Commission
to ensure that Idaho Power is seeking continuous improvements within its maturing wildfire
mitigation approach. Utilities should consider the role of innovative technologies like those
provided by AiDash in achieving their goals of cost-effective, risk-informed mitigation. As
outlined in these comments, a prevention-first approach using modern technologies is
already delivering a track record of enabling cost savings, enhancing reliability, and
providing scalable solutions. AIDash and the other Partnership technologies can act as
invaluable assets for utilities addressing wildfire risks and associated vegetation
management challenges. The Commission should ensure that Idaho Power is considering
and adopting such technologies, where appropriate, to ensure safer, more resilient utility
operations for the future.
AiDash further notes that an integrated approach would provide Idaho Power with access
to a coordinated set of complementary wildfire-mitigation tools, including fire-spread
simulation, operational automation, camera-based fire detection and fuel-management
capabilities. Integration with software suites for grid-operations like ADMS, GIS etc
enables Idaho Power to translate AiDash's vegetation, asset, and ignition intelligence into
targeted operational actions such as switching, EPSS deployment, or surgical PSPS.This
integrated workflow helps ensure that Idaho Power's operational responses are aligned
with the same risk insights used for planning and vegetation-mitigation prioritization.
AiDash looks forward to continued engagement with the Commission and stakeholders to
support Idaho's development of innovative, prevention-first wildfire mitigation practice.
Respectfully Submitted,
Randy Lyle
Senior Director,Wildfire Mitigation Practice
AiDash
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