20251219Application.pdf

_ ROCKY MOUNTAIN 1407 W.North Temple,Suite 330
POWER. Salt Lake City,UT 84116
A DIVISION OF PACIFICORP
RECEIVED
December 19, 2025
December 19, 2025 IDAHO PUBLIC
UTILITIES COMMISSION
VIA ELECTRONIC DELIVERY
Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd
Building 8 Suite 201A
Boise, ID 83714
25-RE: CASE NO. PAC-E-25-22
IN THE MATTER OF THE APPLICATION OF ROCKY MOUNTAIN REQUESTING
APPROVAL OF THE 2026-2028 IDAHO WILDFIRE MITIGATION PLAN
Attention: Commission Secretary
Please find Rocky Mountain Power's application in the above-referenced matter.
Informal inquiries may be directed to Mark Alder, Idaho Regulatory Manager at(801) 220-2313.
Very truly yours,
Joe Steward
Senior Vice President, Regulation

Joe Dallas (ISB# 10330)
PacifiCorp, Senior Attorney
825 NE Multnomah Street, Suite 2000
Portland, OR 97232
Email:joseph.dallas(ibpacifico1p.com
Attorney for Rocky Mountain Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION ) CASE NO. PAC-E-25-22
OF ROCKY MOUNTAIN REQUESTING )
APPROVAL OF THE 2026-2028 IDAHO ) APPLICATION OF
WILDFIRE MITIGATION PLAN ) ROCKY MOUNTAIN POWER
Rocky Mountain Power, a division of PacifiCorp ("Company" or"Rocky Mountain
Power"), in accordance with Idaho Code § 61-503, Rule of Procedure 52, and Order No. 36774,'
respectfully submits this application("Application") to the Idaho Public Utilities Commission
("Commission"),requesting that the Commission issue an order approving its 2026-2028 Idaho
Wildfire Mitigation Plan("2026 WMP" or"Plan"), included as Attachment A, in accordance
with the Wildfire Standard of Care Act("WSCA"), Idaho Code § 61- 1801, et seq, and the
guidelines established in Case No. GNR-E-25-02.2
In support of its Application, the Company states as follows:
I. INTRODUCTION
1. Rocky Mountain Power is a division of PacifiCorp, an Oregon corporation, which
provides electric service to retail customers through its Rocky Mountain Power division in the
states of Idaho, Wyoming, and Utah. Rocky Mountain Power is a public utility in the state of
Idaho and is subject to the Commission's jurisdiction with respect to its prices and terms of
1 In 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).
z Id.
APPLICATION OF ROCKY MOUNTAIN POWER Page 1

electric service to retail customers in Idaho pursuant to Idaho Code § 61-129. Rocky Mountain
Power is a"public utility," as defined in Idaho Code, §§ 61-119 and 61-129. Rocky Mountain
Power is authorized to do business in the state of Idaho providing retail electric service to
approximately 91,000 customers in the state.
2. On June 7, 2024, the Company submitted its 2024 Wildfire Mitigation Plan
("2024 WMP"), and on November 26, 2024, the Commission acknowledged the 2024 WMP.'
3. On March 19, 2025, Governor Little signed Idaho Senate Bill (S.B.) 1183 into
law, establishing the WSCA. On June 18, 2025, Staff of the Idaho Public Utilities Commission
("Staff") submitted an application to establish a filing process for wildfire mitigation plans, and
on September 30, 2025, the Commission issued an order adopting Staffs guidelines ("IPUC
WMP Guidelines") for each electric corporation's wildfire mitigation plan filing.4
4. The 2026 WMP is designed to comply with Idaho Code § 61-1803(3) and the
IPUC WMP Guidelines adopted by Order No. 36774, as well as the directives established by
Order No. 36405. The Plan outlines the strategies,practices, and mitigation measures that the
Company will use to address wildfire risk in a manner that reasonably balances mitigation costs
with the resulting reduction in wildfire risk exposure. As described in Section 1 of the 2026
WMP, the Company's risk-informed cost-and-benefit balancing approach guides the selection
and prioritization of wildfire mitigation activities aimed at meaningfully reducing wildfire risk.
5. The Company has detailed its compliance with applicable Commission orders and
the requirements of the WSCA in Appendix A of the 2026 WMP, showing how the Plan satisfies
the statutory and regulatory requirements.
s In the Matter of Rocky Mountain Power's Application for Approval of the 2024 Idaho Wildfire Mitigation Plan,
Case No.PAC-E-24-09,Order No.36405(Nov.26,2024).
4 In Re Commission Staffs Application for Approval of a Filing Process for Wildfire Mitigation Plans, Case No.
GNR-E-25-02,Order No. 36774,Exhibit B(Sep. 30,2025)(hereinafter,"IPUC WMP Guidelines").
APPLICATION OF ROCKY MOUNTAIN POWER Page 2

II. SUMMARY OF THE 2026 WILDFIRE MITIGATION PLAN
6. PacifiCorp's service areas have historically included wildfire risk, including in
Idaho. This risk is inherent to operating an electric utility and is elevated for utilities in the
Western United States where climates are and year-long in some areas or seasonally in others.
However, the frequency, severity, and costs of catastrophic wildfires are increasing across the
West. Recent experiences with catastrophic, and tragic wildfires have resulted in an even greater
focus on wildfire risk mitigation by public utilities in the region. The Company is committed to
making long-term investments to reduce wildfire risk, and the 2026 WMP describes the
investments to construct, maintain, and operate electrical lines and equipment in a manner that
will minimize the risk of wildfire. The 2026 WMP complies with statutory and regulatory
requirements as follows:
A. Identifying Geographical Areas of Heightened Wildfire Risks
7. Rocky Mountain Power's baseline risk analysis framework consists of four main
components: data collection and analysis, risk evaluation, risk treatment, and risk monitoring and
review. The Company's wildfire mitigation risk analysis reviews fire history, the recorded causes
of the fires, the acreage impact of the fires, and when in the year the fires typically occur. Using
that information, the risk analysis identifies the logic for a risk-informed method to strategically
address utility wildfire risks. The Company conducts annual wildfire risk assessments using
models that incorporate vegetation, weather, topography, historical fire occurrence, and asset
location. Risk maps are developed to identify service territories with elevated fire risk,
categorized by severity levels. These maps are reviewed annually to see if updates are needed
and guide prioritization of mitigation activities. Section 1, "Baseline Risk Analysis" (risk
5 See Idaho Code § 61-1803(3)(a);IPUC WMP Guidelines at 2.
APPLICATION OF ROCKY MOUNTAIN POWER Page 3

modeling, monetized risk, prioritization) and Section 11, "Plan Summary, Costs, and Benefits"
(summary of risk reduction outcomes)provide the required information.
B. Preventative Actions and Programs to Reduce Wildfire Risk'
8. The Company implements a suite of preventative programs including asset
inspections and correction (Section 2), vegetation management(Section 3), situational awareness
technologies (Section 5), and operational restrictions during high-risk periods (Section 7). The
following provides a high-level overview of these programs:
9. Rocky Mountain Power performs inspections on a routine basis and also
completes supplemental visual patrols ahead of elevated fire risk conditions. In addition, areas
classified as Fire High Consequence Area("FHCA") are subject to additional inspection
program elements. The risk models used during the baseline risk analysis did not identify any
geographic areas in Idaho for inclusion in an FHCA at this time; however, the Company will
continue to evaluate the Idaho service territory for areas of possible future inclusion into an
FHCA.
10. By reducing vegetation contact with power lines, Rocky Mountain Power's
vegetation management program reduces the potential of an ignition originating from electrical
facilities. The Company has two vegetation management programs: regular cycle maintenance
and enhanced vegetation maintenance. Regular cycle maintenance involves, on a tri-annual basis,
inspecting areas and pruning tall vegetation to maintain safe distances from power lines and
removing identified dead or high-risk trees that pose a threat of falling onto electrical facilities.
The enhanced vegetation management program includes an annual off-cycle inspection to FHCA
territories and may also apply in Idaho to areas even without an FHCA having been identified.
6 See Idaho Code § 61-1803(3)(b);IPUC WMP Guidelines at 2-4.
APPLICATION OF ROCKY MOUNTAIN POWER Page 4

11. Adjustments to power system operations, such as modifying relay settings and re-
energization protocols, can mitigate wildfire risk but may increase outage frequency and
duration. When appropriate, the Company deploys Enhanced Safety Settings, may perform
additional patrols during elevated fire risk periods, and can use fault indicators to expedite
restoration,while continually evaluating and optimizing these strategies to balance wildfire risk
and customer reliability.
12. System strengthening strategies such as pole replacements, conductor upgrades,
and undergrounding are pursued where cost-effective (Section 4). In the context of the
Company's wildfire mitigation efforts, system strengthening is an engineered response to an
identified risk to the electrical system. System strengthening includes retrofitting specific devices
or components within the system to make it more resilient and may also include the wholesale
replacement of legacy equipment when retrofitting is not a viable solution. Rocky Mountain
Power's system strengthening projects focus on reducing the potential that the power system is
the source of ignition by creating a spark during a fault event.
13. Workforce training and pilot programs are also included to ensure continuous
improvement (Section 7). Throughout the year, Rocky Mountain Power takes proactive measures
to minimize wildfire risk, both through modified practices and strategic investments in
equipment. Measures include deferring nonessential work in high-risk areas, imposing necessary
restrictions based on weather conditions, and equipping field personnel with basic firefighting
tools and training, while also employing circuit strengthening upgrades and enhanced
communication devices such as the Starlink satellite devices.
14. Additionally, the Company has a comprehensive Public Safety Power Shutoff
("PSPS") Program (Section 8). During periods of extreme wildfire risk, Rocky Mountain Power
APPLICATION OF ROCKY MOUNTAIN POWER Page 5

employs proactive de-energization, also known as Public Safety Power Shutoff("PSPS"), as a
temporary measure. This practice may be initiated based on factors like high wind speeds, low
humidity, and dry fuels and aims to supplement existing wildfire mitigation strategies. The 2026
WMP describes the PSPS decision making process, communication to partners, notifications to
customers, and critical facilities in the event of a PSPS, as well as the process for re-energization.
15. Finally, as described below, the Company works with communities to collaborate
and prepare for emergencies caused by wildfire (Section 9).
C. Community Outreach and Public Awareness Efforts'
16. The Company's multi-step coordination approach with public safety partners for
wildfire mitigation and PSPS preparedness includes outreach,workshops, tabletop exercises,
Community Resource Center("CRC") demonstrations, and functional exercises culminating in
enhanced communication and strategic planning for emergency situations. In addition to being
important preventative programs to reduce wildfire risk, the Company PSPS Program and
community outreach program are important to provide public awareness. The Company
maintains proactive communication with customers before, during, and after wildfire season.
Outreach includes public service announcements, educational materials, and notifications via
mail, email, text, and web platforms. For PSPS events, protocols ensure advance notice to critical
infrastructure, vulnerable populations, and the general public.
D. Coordination with Federal, State,Tribal, and Local Agencies'
17. The Company collaborates with agencies such as the Forest Service, Bureau of
Land Management, and local emergency managers to align wildfire preparedness and response.
Coordination includes PSPS tabletop exercises,joint mitigation efforts, and communication with
See Idaho Code § 61-1803(3)(c);IPUC WMP Guidelines at 4.
$See Idaho Code § 61-1803(3)(d);IPUC WMP Guidelines at 4-5.
APPLICATION OF ROCKY MOUNTAIN POWER Page 6

ESF-12 coordinators. Partnerships are leveraged for cost-sharing and program effectiveness.
Sections 8 and 9 describe these coordination efforts in the event of a PSPS event and more
generally, respectively.
E. Line Design Methods to Mitigate Fire Risk'
18. New and upgraded line designs incorporate covered conductors, non-wooden
cross arms, and flexible infrastructure such as remote-controlled reclosers. Undergrounding and
line rebuilding are evaluated based on least-cost, least-risk principles. Each project is assessed
for cost-effectiveness relative to wildfire risk reduction. Section 4 describes the Company's
efforts related to system strengthening of this kind and Section 1.3-1.4 describe the monetized
risk and risk treatment that will be considered in selecting and prioritizing programs. There are
no planned system strengthening projects for Idaho; however, there are some planned relay
upgrades that are noted in the Plan in section 4.4.
F. Monitoring Forecasted and Current Weather Data"
19. Rocky Mountain Power's approach to situational awareness includes real-time
daily simulations, forecasting and assessing the risk of potential or active events, and responding
to local conditions. The Company's meteorology department plays a central role in situational
awareness efforts by leveraging advanced numerical weather prediction models to forecast
weather-related system impacts. The Company uses advanced weather monitoring systems, fire
potential modeling, and situational awareness tools to assess current and forecasted wildfire
risks. These capabilities inform daily operational decisions and seasonal planning. Coordination
with other utilities ensures awareness of regional de-energization events. Section 5 describes the
9 See Idaho Code § 61-1803(3)(e);IPUC WMP Guidelines at 5.
10 See Idaho Code§ 61-1803(3)(fl;IPUC WMP Guidelines at 5-6.
APPLICATION OF ROCKY MOUNTAIN POWER Page 7

Company's situational awareness and forecasting efforts, and Section 8 describes the PSPS
Program.
G. Standards, Procedure and Schedules
i. Inspection of Assets in High-Risk Areasit
20. Routine and enhanced inspections are conducted on transmission, distribution,
and substation assets in elevated fire risk zones. Standards and schedules are defined for each
asset type,with defects classified and prioritized for correction. Measurable targets such as miles
inspected and defects corrected are tracked annually. Section 2 describes the Company's
inspection and correction procedures, with Appendix C providing the Company's inspection
policies,procedures, and standards of operation ("SOPs"). Specifically, with regard to Appendix
C, the following policies and procedures are relevant: Detailed Inspections for T&D Lines Asset
Management Policy 009; Clearance Table for Distribution and Transmission Line Inspectors
NESC and GO 95 Grandfathering Matrix Facility Point Inspection NESC and GO 95 Frequently
Asked Questions Condition Code Dropdowns Asset Management Procedure 069; Visual
Assurance InspectionsSafety Patrol of G Transmission and Distribution Lines Asset
Management Policy No 011; Helicopter Standard Operating Procedure for Line Inspections
Facility Inspection Procedure No 203; and Substation inspection Asset Management Policy No
034. Policy 001 Maintenance Intervals for Apparatus, Relays, Meters, Line Patrol/Inspections,
Wires Equipment and Communications Equipment sets measurable targets for the WMP's
inspection program. Finally, Section 11 provides the objectives and measurable costs for the
inspection and correction program.
"See Idaho Code§ 61-1803(3)(g)(i);IPUC WMP Guidelines at 6-7.
APPLICATION OF ROCKY MOUNTAIN POWER Page 8

ii. De-Energization Protocols12
21. The Company maintains protocols for proactive and reactive de-energization to
reduce wildfire risk. Criteria for engagement include encroaching wildfire, agency requests, or
planned mitigation work. Coordination with emergency managers and critical facilities ensures
community support through resource centers, backup power, and clear communication before,
during, and after events. Sections 6 and 8 explain de-energization and PSPS programs. Appendix
C also provides details on the Company's policies and procedures related to de-energization and
PSPS events. Specifically, the PSPS SOPS are provided in the following sections: Operating
Transmission and Distribution Assets During periods of Elevated Wildfire Risk Power Delivery
Policy PAC-1000; SOP 200: Operating Transmission Assets During Identified Wildfire Risk;
SOP 201, which describes operating sub-transmission assets during wildfire; SOP 202 for a
description of operations of distribution assets during identified wildfire risk; and SOP 203,
which describes the Company's wildfire encroachment policy. The Company also follows the
PSPS Execution Playbook and the Emergency Response Plan("ERP"), Sixth edition, dated
April 23, 2025.
iii. Vegetation Management in High-Risk Areas13
22. Vegetation management cycles are shortened in wildfire-prone areas, with risk
tree programs and enhanced clearance standards applied. Practices are aligned with federal, state,
and county recommendations. Measurable targets such as miles cleared and risk trees removed
are tracked, and landowners are compensated for marketable timber removed. Section 2 details
the prioritizations in the Company's vegetation management programs. Section 3 describes the
Company's procedures and its consideration of the removal of live, marketable timber. The
12 See Idaho Code§ 61-1803(3)(g)(ii);IPUC WMP Guidelines at 7.
"See Idaho Code§ 61-1803(3)(g)(iii);IPUC WMP Guidelines at 7-8.
APPLICATION OF ROCKY MOUNTAIN POWER Page 9

Company also follows the following vegetation management SOPS: PacifiCorp's T&D
Vegetation Management Program SOPs, Revision 8, dated 8/29/2024; and Transmission Grid
Operations Operating Procedure PCC-215 Guidelines for Communication of Vegetation
Conditions that Present an Imminent Threat of Transmission Line Outage.
H. Other Required Items14
23. Lessons learned will be incorporated annually into updated WMP filings. And in
2021, Rocky Mountain Power established a Wildfire Safety Department, including a program
delivery team responsible for developing, implementing, and monitoring the Company's wildfire
mitigation strategies across the Company's entire service territory including Idaho. The
Department facilitates coordination across various internal departments, compliance with
regulatory requirements, and securing grant funding for mitigation initiatives.
24. For cost forecasts, capital and O&M expenditures are broken down by program
category and described in Section 11. To implement the investments described above, the
Company is currently forecasting an additional investment of$13.9 million through 2028. This
investment includes $8.1 million of capital expenses. A breakdown of these expenses is provided
in section 11.3 of the 2026 WMP. Finally,this section of the Application describes the
Company's satisfaction of Commission orders and Staff recommendations and is summarized in
Appendix A in the WMP.
III. CORRESPONDENCE OR COMMUNICATIONS
25. Correspondence and communications regarding this Application should be
addressed to:
14 See IPUC WMP Guidelines at 8.
APPLICATION OF ROCKY MOUNTAIN POWER Page 10

Mark Alder
Idaho Regulatory Affairs Manager
Rocky Mountain Power
1407 West North Temple, Suite 330
Salt Lake City, UT 84116
Telephone: [phone]
Email: mark.alder(a�pacificorp.com
Joe Dallas (ISB# 10330)
PacifiCorp, Senior Attorney
825 NE Multnomah Street, Suite 2000
Portland, OR 97232
Email:joseph.dallaskpacificorp.com
In addition, Rocky Mountain Power requests that all data requests regarding this
Application be sent in Microsoft Word to the following:
By email (preferred): datarequestkpacificorp.com
By regular mail: Data Request Response Center
PacifiCorp
825 NE Multnomah Street, Suite 2000
Portland, OR 97232
Informal questions may be directed to Mark Alder, Idaho Regulatory Affairs Manager at
[phone].
26. Included as Attachment B to this Application is a copy of the Notice to Interested
Parties, as required by Idaho Code §61-1804(02). The notice will be sent to parties on the carbon
copy list within 5 business days from the date of this Application.
IV. MODIFIED PROCEDURE
27. The Company believes that consideration of the proposals contained in this
Application do not require an evidentiary proceeding, and accordingly, it requests that this
Application be processed under modified procedure pursuant to Rules 201-204, which allow for
consideration of these issues by written submissions rather than by an evidentiary hearing. Rocky
APPLICATION OF ROCKY MOUNTAIN POWER Page 11

Mountain Power respectfully requests that the Commission issue an Order authorizing that this
proceeding be processed under modified procedure.
V. REQUEST FOR RELIEF
28. WHEREFORE,Rocky Mountain Power respectfully requests that the Commission
issue an order approving the 2026 WMP in accordance with the WSCA.
DATED this 19th day of December, 2025.
Respectfully submitted,
ROCKY MOUNTAIN POWER
c
Joe Dallas (ISB# 10330)
PacifiCorp, Senior Attorney
825 NE Multnomah Street, Suite 2000
Portland, OR 97232
Email: joseph.dallas(aa�pacificorp.com
Attorney for Rocky Mountain Power
APPLICATION OF ROCKY MOUNTAIN POWER Page 12

ATTACHMENT A
2026-2028 Idaho Wildfire Mitigation Plan

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TABLE OF CONTENTS
Introduction .................................................................................................................8
1. Baseline Risk Analysis .........................................................................................9
1.1 Risk Analysis Framework ................................................................................9
1.2 Risk Evaluation and Tools..............................................................................11
1.3 Fire High Consequence Area (FHCA)..............................................................20
1.4 Monetized Risk.............................................................................................22
1.5 RiskTreatment—Program Selection and Prioritization.....................................22
2. Inspection and Correction..................................................................................29
2.1 Inspection and Maintenance Program Overview .............................................29
2.2 Standard Inspection and Correction Programs ...............................................31
2.3 FHCA Inspection and Correction Programs ....................................................32
2.4 Enhanced Inspections ..................................................................................36
3. Vegetation Management....................................................................................36
3.1 Rights-of-Way ..............................................................................................37
3.2 Regular Vegetation Management Program......................................................37
3.3 Enhanced Vegetation Management ...............................................................40
3.4 Quality Control Program ...............................................................................43
4. System Strengthening and Resiliency..................................................................44
4.1 Line Rebuild Program....................................................................................46
4.2 System Resiliency ........................................................................................48
4.3 Advanced System Protection and Control ......................................................49
4.4 Expulsion Fuse Replacement ........................................................................51
4.5 Fault Indicators............................................................................................51
5. Situational Awareness and Forecasting...............................................................51
5.1 Meteorology.................................................................................................52
5.2 Numerical Weather Prediction ......................................................................53
5.3 Ongoing Data Acquisition and Inputs .............................................................55
5.4 Wildfire Risk Models and Tools ......................................................................61
5.5 Application and Use .....................................................................................65
5.6 Wildfire Detection Cameras ..........................................................................69
6. System Operations............................................................................................70
Page 3

6.1 Enhanced Safety Settings..............................................................................70
6.2 Enhanced Safety Settings (ESS) Modes ..........................................................71
6.3 Fault Indicators to Mitigate Impacts...............................................................72
6.4 Re-energization Practices .............................................................................73
6.5 Reliability Impacts of ESS..............................................................................74
6.6 Additional Patrols.........................................................................................75
6.7 Wildfire Encroachment— Emergency De-energization .....................................75
7. Field Operations and Work Practices..................................................................76
8. Public Safety Power Shutoff(PSPS) Program .......................................................82
8.1 Initiation ......................................................................................................83
8.2 Assessing the Potential fora PSPS.................................................................84
8.3 De-energization Watch Protocol....................................................................84
8.4 De-energization Protocol ..............................................................................85
8.5 Active Wildfire De-energization......................................................................86
8.6 Communication Protocol..............................................................................86
8.7 Community Resource Centers ......................................................................90
8.8 Re-energization ............................................................................................91
9. Emergency Preparedness, Community Outreach, and Collaboration....................93
9.1 Public Safety Partner Coordination Strategy...................................................93
9.2 Emergency Preparedness and Exercise Plan ..................................................96
9.3 Community Outreach and Public Awareness..................................................97
9.4 2025 Wildfire Communications and Outreach Plan....................................... 107
9.5 Industry Collaboration ................................................................................ 107
10. Plan Monitoring and Implementation ................................................................ 108
11. Plan Summary and Costs................................................................................. 109
11.1 Program Achievements and Objectives........................................................ 109
11.2 Costs......................................................................................................... 114
Page 4

LIST OF FIGURES
Figure 1-1: Rocky Mountain Power's Baseline Risk Analysis Framework..........................10
Figure 1-2: Historic Ignition Risk Drivers and Wire Down Events During Heightened Fire Risk
Season ............................................................................................................13
Figure 1-3: Historic Ignition Risk Drivers and Wire Down Events During Non-Heightened Fire
RiskSeason .....................................................................................................14
Figure 1-4: Overall FireSight Model for Risk Estimates....................................................17
Figure 1-5: Inputs and Weights for Composite Risk Calculation......................................18
Figure 1-6: Calculation of Composite Risk Score...........................................................18
Figure 1-7: Comparison of Fuel/Terrain-Driven Composite Risk to Wind-Driven Composite
Risk Near Baldy Knoll, ID ...................................................................................19
Figure 1-8: Comparison of Wind-Driven Composite Risk to Fuel/Terrain Composite Risk in
GoshenJunction, ID..........................................................................................19
Figure 1-9: Combined Composite Risk Score Calculation ..............................................19
Figure 1-10: 2025 Areas of Interest ...............................................................................21
Figure 1-11: Program and Project Selection Process......................................................23
Figure 1-12: Current Project Evaluation and Selection Process.......................................25
Figure 1-13: Project Implementation and Monitoring Process.........................................28
Figure 2-1: Fire Threat Condition Identification..............................................................33
Figure 3-1: Hazard Tree Removal..................................................................................38
Figure 3-2: Example Rights-of-Way Clearances for Transmission and Distribution...........40
Figure 3-3: Pole Clearing Strategy.................................................................................42
Figure 3-4: Pole Clearing at Pole Base...........................................................................42
Figure 4-1: Covered Conductor Compared to Bare Conductor .......................................46
Figure 4-2: Distribution Fiberglass Pole.........................................................................49
Figure 4-3: Idaho Planned Relay Upgrade Locations ......................................................50
Figure 5-1: Overview of Situational Awareness ..............................................................52
Figure 5-2: Meteorology Weather/Fire Assessment........................................................53
Figure 5-3: General Weather Station Siting Methodology................................................56
Figure 5-4: Wildfire Acres Burned in States Served by PacifiCorp 1983-2025 ...................57
Figure 5-5: Example Wildfire Operational Flow Diagram Overview ..................................60
Figure 5-6: Publicly Available Situational Awareness Information from a Weather Station
Westof Idaho Falls, ID ......................................................................................61
Page 5

Figure 5-7: Example of FireRisk Output Near Spencer, ID, July 2023................................63
Figure 5-8: FireSim Output Near Spencer, ID, July 2023..................................................64
Figure 5-9: Fire Potential Index Scale............................................................................65
Figure 5-10: Example System Impacts Forecast ............................................................67
Figure 5-11: Fuel and Terrain Polygon Classification......................................................68
Figure 6-1: Example of Distribution Circuit with Protective Relay Devices........................71
Figure 6-2: General Fault Indicator Configuration ..........................................................73
Figure 7-1: Line Workers Performing Work ....................................................................76
Figure 7-2: Rapidly Deployable Cell-on-Wheels (COW)..................................................79
Figure 8-1: PSPS Overview...........................................................................................83
Figure 8-2: PSPS Assessment Methodology ..................................................................84
Figure 8-3: Example of a Temporary CRC ......................................................................91
Figure 8-4: General Re-Energization Process.................................................................91
Figure 8-5: Visual Depiction of Step Restoration............................................................93
Figure 9-1: Public Safety Partner Preparedness Strategy................................................94
Figure 9-2: Sample YouTube Content ...........................................................................98
Figure 9-3: Sample Support Collateral..........................................................................99
Figure 9-4: Sample Email Communication - Modified Operational Settings ................... 100
Figure 9-5: Wildfire Mitigation Program Infographic ..................................................... 102
Figure 9-6: Sample Webpage Content-Spanish.......................................................... 103
Figure 9-7: Wildfire Safety Website Content................................................................ 104
Figure 9-8: Public Safety Power Shutoff Webpage........................................................ 105
Page 6

LIST OF TABLES
Table 1-1: Outage Causes with Possible Correlation to Ignition Potential........................12
Table 1-2: Risk Driver Mapping to Potential Mitigation Program(s)...................................24
Table 2-1: Energy Release Conditions...........................................................................33
Table 2-2: Planned Inspection Frequency .....................................................................35
Table 2-3: Planned Correction Time Frames for Fire Threat Conditions in the FHCA.........35
Table 3-1: Normal Distribution Minimum Post-Work Vegetation Clearance Distances .....38
Table 3-2:Transmission Minimum Vegetation Clearance (in Feet) by Line Voltage ...........39
Table 3-3: Distribution Minimum Post-Work Vegetation Clearance Distances in the FHCA.41
Table 3-4: Post-Work Audit Targets...............................................................................43
Table 4-1: Idaho Idle Line Mitigation Plans and Status....................................................46
Table 5-1: Additional Resources for District Fire Risk Assessment..................................66
Table 6-1: 2025 Reliability Impacts for Circuits Activated in ESS Settings ........................75
Table 7-1:T&D Operations Based on Fire Risk Potential.................................................81
Table 8-1: PSPS Notification Timeline for Customers.....................................................89
Table 9-1:Wildfire Communications and Outreach Plan Timeline ................................ 107
Table 11-1: Summary of 2025 Program Results and 2026-2028 Objectives.................... 110
Table 11-2: Planned Incremental Capital Investment by Category($millions)................ 114
Table 11-3: Planned Incremental Expense by Category($millions)................................ 115
Page 7

INTRODUCTION
Wildfire threats have been growing in the United States, and Rocky Mountain Power has
developed a comprehensive plan describing its wildfire mitigation efforts. This 2026-2028
Wildfire Mitigation Plan (WMP) guides the mitigation strategies that are or may be deployed
in Idaho. These efforts are designed to reduce the risk of utility-related wildfires and
proactively mitigate the damage they cause to our communities and to Rocky Mountain
Power facilities.
Wildfire has long been an issue of notable public concern. Electric utilities have understood
there is a risk of a fire starting because of sparks emitted from an electrical facility, typically
duringfault conditions.The trend toward increased wildfire size and intensity has magnified
these concerns. Increased human development in the wildland-urban interface, the area
where people (and their structures) are intermixed with, or located near, substantial
wildland vegetation, has increased the probability and costs of wildfires in terms of both
harm to people and damage to property. A wildfire in an undeveloped area can have
ecological consequences, some positive, some negative, but typically, it will not directly
affect many people. A wildfire engulfing a developed area, on the other hand, can have
significant consequences for both people and property. Despite the efforts of fire
suppression agencies and increases in suppression budgets, the wildfire threat continues
to grow. For these reasons, Rocky Mountain Power is committed to making long-term
investments to reduce the risk of wildfire.
The measures in this WMP describe the Company's investments to construct, maintain, and
operate electrical lines and equipment in a manner that will minimize the risk of wildfire. In
evaluating which engineering, construction, and operational strategies to deploy, Rocky
Mountain Power was guided by the following core principles:
• Systems that facilitate situational awareness and operational readiness are
important to mitigating fire risk and its impacts.
• When a fault event does occur, the impact can be minimized by using equipment and
personnel to isolate the fault event and shorten its duration.
• The frequency of ignition events related to electric facilities can be reduced by
engineering more resilient systems that experience fewer fault events.
A successful plan also must consider the impact on Idaho customers and communities and
must balance costs, benefits, operational impacts, and risk mitigation to provide safe,
reliable, and affordable electric service.
Page 8

In 2025, the Company deployed the following primary Idaho wildfire mitigation initiatives:
• Expanded situational awareness by installing 10 weather stations and procuring new
risk modelling tools, datasets, and software.
• Implemented modified operational settings and re-energization practices.
• Launched the Wildfire Intelligence Center.
• Fully implemented the Public Safety Partner Portal.
Rocky Mountain Power's 2026-2028 WMP incorporates the Company's experience in
wildfire mitigation as well as feedback and recommendations from stakeholders and Idaho
communities. As a result, in 2026, the Company is forecasting an additional investment of
$13.9 million in Idaho through 2028. Section 11 of this WMP includes a summary of all plan
elements and forecasted cost.
Rocky Mountain Power's wildfire mitigation efforts in Idaho are centered on operating
practices, informed by ongoing wildfire risk analysis. The Company monitors situational
awareness year-round across its entire service territory, enabling the Company to target
specific operational protocols in areas of heightened wildfire risk. These alternative
operating practices include advanced control systems and incremental patrols, which can
Lead to expedited corrections and vegetation clearing.
Manywildfire mitigation efforts, especiallythose driven by long-term, sustained riskfactors,
are focused in areas of highest wildfire risk, known as Fire High Consequence Areas
(FHCAs). To date, Rocky Mountain Power's wildfire risk assessment has not identified any
FHCA in its Idaho service territory. As such, the Company's FHCA programs are not
implemented in Idaho. Nonetheless, baseline risk analysis is re-evaluated regularly, and
Rocky Mountain Power may designate FHCA in Idaho in the future. Therefore, this plan
describes FHCA programs for informational purposes.
i . BASELINE RISK ANALYSIS
1 .1 RISK ANALYSIS FRAMEWORK
Rocky Mountain Power's baseline risk analysis framework consists of four main
components: data collection and analysis, risk evaluation, risk treatment, and risk
monitoring and review.
1. Data Collection and Analysis: Rocky Mountain Power performs enhanced data
collection and analysis to track incidents, analyze trends, and measure mitigation
effectiveness.
Page 9

The Company continuously collects, organizes, and analyzes data, as described in
this section, to develop its risk assessment tools and evaluation, and to inform its
understanding of the wildfire risk and the mitigation programs informed by this risk.
Additional details regarding the specific types of data collected can be found in
Appendix B—Wildfire Risk Modeling Data Inputs.
2. Risk Evaluation includes developing tools and models to support location-specific
risk identification. These risk evaluation tools and models include the delineation of
geographic areas of heightened risk of wildfire designated as the FHCAs, discussed
in detail below, as well as the asset-specific risk modeling tool, FireSight, explained
Later in this section.
3. Risk Treatment involves developing and implementing mitigation programs informed
by the data analysis and risk evaluation.
4. Risk Monitoring and Review includes quantitatively evaluating the effectiveness of
mitigation strategies using a consistent framework and process.
The risk analysis framework is a continuous improvement cycle, depicted in Figure 1-1. For
example, data collection and analysis support inputs to risk evaluation in a repeatable,
transparent way to identify areas of risk. This, in turn, supports the development and
updating of risk evaluation tools, such as mapping the FHCA, to inform risk mitigation
programs such as vegetation management and asset inspections. Finally, risk is monitored,
and programs are evaluated to enable continuous improvement, which informs future data
collection and analysis.
Monitoring • • •
•
Review
Treatmen Risk Risk
At X
Figure 1-1:Rocky Mountain Power's Baseline Risk Analysis Framework
Page 10

1 .2 RISK EVALUATION AND TOOLS
Rocky Mountain Power defines risk as the probability of a specific risk event multiplied by
the consequence of the event. The likelihood (or probability) is an estimate of a particular
event occurring within a given time frame. The consequence is an estimate of the effect on
people and property if an event occurs. When estimating the impact of a risk, Rocky
Mountain Power considers a variety of factors, including consequences to health and safety,
the environment, customer satisfaction, system reliability, the Company's reputation, and
its finances. Rocky Mountain Power uses modeling tools to evaluate both probability and
consequence, which in turn informs risk.
RISK DRIVER ANALYSIS
Rocky Mountain Power analyzes the components of risk associated with utility facilities. In
particular, an understanding of risk drivers informs specific mitigation tactics or strategies
that can be used to reduce the total amount of risk associated with utility operations. For
example, if a risk of utility-related wildfire exists due to the potential of equipment failure,
an increase in inspections or maintenance activities might help mitigate that risk. If a risk
exists due to potential contact between power lines and third-party objects, installing a
covered conductor might help mitigate that risk.
In determining the potential risk drivers, Rocky Mountain Power employs a data-driven
approach that references certain categories of historical outage records as a proxy for risk
events. Outage data is the best available data to correlate an identifiable event on the
electrical network to the risk of a utility-related wildfire. There is a logical physical
relationship: if a fault creates a spark, there is a risk of fire. An unplanned outage, which is
when a line is unintentionally de-energized, is most often rooted in a fault. Accordingly,
outage records are organized into categories to understand the cause of each outage with a
potential ignition, as shown in Table 1-1 below. The outage categories in the table align with
potential correlation to an ignition.'
'These outage categories are not the same as the outage classifications traditionally used for reliability reporting.For
example,certain outage categories,such as loss of upstream transmission supply,planned outage,or not an outage
(misclassification)do not correlate to the potential for an ignition and were excluded from the data set used for risk driver
analysis.
Page 11

Table 1-1: Outage Causes with Possible Correlation to Ignition Potential
Risk Driver to Cause Outages Risk Driver Description
Object Contact Objects make unwanted direct contact with energized assets
Wire-to-Wire Contact Contact between two conductors due to galloping,wind,ice,or
mechanical issues
Contamination Exposure to environmental contamination such as dust, pollution,
rust,or conductive buildup
Failure of energized equipment due to normal deterioration and wear,
Equipment Failure such as a crossarm that has become cracked or the incorrect
operation of a recloser,circuit breaker, relay, or switch
Outage event directly caused by lightning striking either(i)energized
Lightning utility assets or(ii)nearby vegetation or equipment that,as a result,
contacts energized utility assets
Other Outages caused by miscellaneous or nonstandard conditions not
captured by other categories
Unknown Outage event with unknown cause or multiple potential probable
causes identified
Utility Work Outages resulting from planned or unplanned utility operations,
switching,construction,or maintenance work
Vandalism/Theft Outages caused by intentional human actions, including theft of
equipment,vandalism,or tampering
Rocky Mountain Power compiled an outage history from the past 10 years grouped by these
10 outage categories, during both heightened fire risk season(June 1 through October 1)and
non-heightened fire risk season. Because "wire down" events pose an increased risk of
ground fuel ignition, wire down event data is also assessed. The following figures show this
wire down data alongside the cumulative ignition risk drivers in Idaho from 2014 to 2025 for
heightened fire risk season (Figure 1-2) and non-heightened fire risk season (Figure 1-3).
The analysis of risk drivers incorporates outage data collected through the Company's
normal outage response systems. As Rocky Mountain Power's risk modeling efforts evolve,
there may be opportunities to gather more detailed data regarding outages, which may
further refine the analysis of such data, to support the modeling and correlations between
outages, risk events, and ignition probabilities.
Page 12

Idaho Annual Cumulative Ignition Risk Drivers and
Total Period Wire Down Events- During Heightened Fire Risk Season
6,000
5,000
4,000
3,000 ■
2,000 �
1,000 ■
0 � J
Object Equipment Contaminat Vandalism/t Wire-to-
contact failure on Lightning Utilitywork heft wire Unknown Other
Contact
■2025 264 160 8 46 0 0 4 207 185
■2024 325 202 8 90 0 0 10 178 186
■2023 215 216 14 83 0 0 3 194 141
■2022 232 187 7 60 0 0 1 179 155
■2021 198 208 12 89 1 1 3 141 123
■2020 331 233 17 48 0 1 6 139 345
■2019 287 260 27 84 0 0 9 150 61
■2018 322 261 10 49 0 1 26 133 67
■2017 307 293 10 86 0 1 14 151 64
�2016 282 219 11 65 2 0 8 174 49
2015 276 361 16 131 2 0 18 218 117
■ Total Wire 216 173 4 51 2 1 11 167 186
Down Events
Figure 1-2:Historic Ignition Risk Drivers and Wire Down Events During Heightened Fire Risk Season
Page 13

Idaho Annual Cumulative Ignition Risk Drivers and
Total Period Wire Down Events- During Non-Heightened Fire Risk Season
6,000
5,000
4,000
3,000
2,000
1,000
0
Wire-to-
Object Equipment Contaminat Vandalism/
contact failure ion Lightning Utility work theft wire Unknown Other
Contact
is 2025* 125 244 13 10 2 0 10 130 184
■2024 294 300 12 9 4 0 13 169 536
is 2023 223 281 14 32 2 0 8 189 314
■2022 171 315 27 8 2 0 1 7 178 1413
■2021 223 350 30 17 2 0 13 162 416
■2020 241 340 24 15 4 0 17 120 186
■2019 185 376 30 33 0 0 13 164 157
■2018 242 402 29 55 1 0 22 150 178
■2017 246 492 13 16 1 1 24 233 232
■2016 232 447 24 68 0 0 15 225 167
2015 266 526 39 60 1 1 16 216 125
■ Total Wire 216 322 23 16 0 0 22 195 314
Down Events
Figure 1-3:Historic Ignition Risk Drivers and Wire Down Events During Non-Heightened Fire Risk Season
*Values for2025 are year-to-date, November2025.
FIRE INCIDENT HISTORY
Rocky Mountain Power tracks fires potentially originating from Rocky Mountain Power
equipment, as well as other fires that impact Rocky Mountain Power's facilities. An initial
report of a fire can be obtained through a variety of sources. It is common for an initial report
to occur via a call to Rocky Mountain Power's system operations center from an emergency
response agency or local government. Other times, Rocky Mountain Power's field personnel
may observe fire or fire damage while performing work in the field.
After receiving an initial report of a fire incident, Rocky Mountain Power records the incident
in a fire incident tracking database with other gathered information, as available. Data fields
maintained in this database include fire start date and time; location, with a latitude and
Longitude reference; land use in the area; fire size; suppression agency; facility
identification; voltage; associated equipment; outage information; and the suspected
initiating event. Data fields are organized to align with any regulatory reporting requirements.
Page 14

Information is often estimated based on known available information. For example, a
recorded fire start maybe the time the fire is first observed or reported, but the precise time
of ignition may be unknown. Fields are sometimes populated as "unknown" when there is
insufficient information. Information on transmission and distribution equipment, including
type of equipment, location, installation date, and material is captured and used during
analysis, when available.
Fire incident data can be leveraged in various analyses. One such analysis is currently
underway at Rocky Mountain Power to understand the appropriate fire simulation duration
to apply to the wildfire risk model. Technosylva provides wildfire simulations in both eight-
hour and 24-hour durations. Aligning fire history trends with the appropriate simulation
variety is key to allocating cost-efficient mitigations in a responsible way.
FIRESIGHT
Rocky Mountain Power uses FireSight, a commercially available tool from Technosylva, to
model the risk of wildfires igniting in its service territory. The FireSight module is part of a
broader software suite called Wildfire Analyst Enterprise(WFA-E).Technosylva has provided
advanced wildfire products and services to utilities throughout the United States since
1997, and other WFA-E modules are used by state agencies such as the California
Department of Forestry and Fire Protection (Cal Fire).With in-house fire and data scientists,
Technosylva partners with key providers in fire planning, advanced data modeling, and
wildland fire research and development to enhance the models used in their software.
Technosylva has published studies in scientific journals and wildfire industry publications
such as Current Opinion in Environmental Health and Science and International Journal of
Wildland Fire.' Rocky Mountain Power chose to implement FireSight based on
Technosylva's experience with other utilities and their partnerships with experts in wildfire
risk modeling and fire data science.
FireSight associates wildfire hazards with the location of electric overhead assets. The
model simulates the spread of wildfire from an ignition point, which in turn allows for an
estimate of consequence.The FireSight model, depicted in Figure 1-4 below, combines the
risk associated with an ignition from a utility asset with the locational and environmental risk
as described below to provide a composite risk score.
2 Cardil,Adrian,Santiago Monedero,Gavin Schag,Sergio de Miguel,Mario Tapia,Cathelijne R.Stoof,Carlos A.Silva,
Midhun Mohan,Alba Cardil,and Joaquin Ramirez,"Fire behavior modeling for operational decision-making."Current
Opinion in Environmental Health and Science,volume 23.October 2023.
'Cardil,Adrian,Santiago Monedero,Phillip SeLegue,Miguel Angel Navarrete,Sergio de-Miguel,Scott Purdy,Geoff
Marshall,Tim Chavez,Kristen Allison,Raul Quilez,Macarena Ortega,Carlos A.Silva,and Joaquin Ramirez,
"Performance of operational fire spread models in California,"International Journal of Wildland Fire,July7,2023,
Sourced Nov.2,2023.
Page 15

Combining utility asset information with public data, the FireSight model calculates two
independent risk types: Risk Associated with Ignition Location (RAIL) and Risk Associated
with Value Exposure (RAVE).
RAIL, depicted on the left side of Figure 1-4, represents the risk from an asset based on its
characteristics, including age and materials. RAIL assesses the risk by associating the
ignition consequence over an eight-hour and 24-hour period to a specific asset. The eight-
hour period is often used by utilities to model risk, but there is growing interest in how 24-
hour modeling changes the risk profile. Rocky Mountain Power is modeling both to better
understand if there are significant differences in the results that may impact mitigation
efforts.
RAIL inputs include:
• Surface and canopy fuels outlook in 2030, including consideration of climate change
impacts in the modeling.
• Topography.
• Wind speed and direction.
• Historical fire occurrence identifying date, typical weather conditions, and duration.
RAIL outputs include:
• Ignition risk from overhead transmission and distribution assets.
• Potential fire characteristics: fire size, rate of spread, potential for crown fire, flame
Length.
• Population at risk.
• Number of buildings at risk.
RAVE, depicted on the right side of Figure 1-4, assesses the characteristics of the area under
risk of ignition. Community demographics, geography, and the built environment influence
how risky or resilient a community is to wildfire.
RAVE inputs include:
• Population density.
• Socially vulnerable populations such as the elderly, people with a disability, or people
at or below the poverty level.
• Infrastructure: major and minor road density and building density.
• Suppression difficulty: terrain, fuels, and fire station locations all impact how quickly
firefighters can respond to a fire in the initial attack.
• Crown fire acres: the amount the fire can spread through the trees.
Page 16

RAVE outputs include:
• Community impacts: how vulnerable a community is to wildfire and the potential
consequences.
• Fire intensity: how a fire is expected to behave and what area may be impacted from
the point of ignition.
Risk Associated with Ignition Location Risk Associated with Value Exposure
Wildfire risk associated with ignitions from utility Locational risk calculated from all surrounding assets,
assets environmental characteristics,and demographics.
Assets AroliaW: Community
Lines i
Transformers Probability of What are the
Transmission failure causing consequences oth?"N­
Structures an ignition a wildfire
Arrestors
Capacitor Banks
Condu tors
Composite
Risk
f Fire Simulation U�f , (Ignition Risk) Fire Intensity
Fire Growth Ignition Impact of the Fire Behavior Susceptibil
Fire Sevei ity Population and asset to the Area Impacted Fire Growth
i buildings at risk surrounding Flame Length
area Crown Fire
InputsAcres
period
It
Inputs
Asset Data Demographics
Outage History Built
Ignition History Environment
Population Terrain
Built Environment Fuels
Historical Historical
Weather Weather
Figure 1-4:Overall FireSight Model for Risk Estimates
COMPOSITE RISK SCORE
Rocky Mountain Power combines the RAIL and RAVE into a composite risk score to
characterize the wildfire risk along each circuit in its service territory. The composite risk
score captures
• The predicted consequence.This is a measure of the population and buildings likely
to be affected if there is an ignition.
• How destructive the fire could be.This is the expected fire behavior over the forecast
fire area.
• Community resilience.This is a measure of fire suppression difficulty and population
characteristics.
Rocky Mountain Power calculates separate composite risk scores for wind-driven and
fuel/terrain-driven wildfires. This approach accounts for the Company's geographically
Page 17

diverse service territory and the two general types of wildfires, which have different
contributing factors and characteristics.
Figure 1-5 below shows the RAIL and RAVE inputs and weights for the composite risk score,
depicted in Figure 1-6, for wind-driven and fuel/terrain-driven wildfires. The inputs and
percentiles were selected by internal subject matter experts in conjunction with utility best
practices.A sensitivity analysis was performed to validate that the selected percentiles and
weights identified circuits expected to be higher risk based on historical and practical
experience of subject matter experts.
Risk Associated with Ignition Location(RAIL) Risk Associated with Value Exposure(RAVE)
Component:60% Component:40%
RAIL Inputs Percentile Weight RAVE Inputs Percentile Weight
Fuel/Terrain
Fire Behavior Index 95 20% Terrain Difficulty Index N/A 25%
©, Fire Size Potential 95 20% + Fire Station Density N/A 10%
Flame Length 95 20% Fuel Model Majority N/A 5%
Risk Associated with Ignition Location(RAIL) Risk Associated with Value Exposure(RAVE)
Wind Component:80% Component:20%
RAIL Inputs Percentile Weight I[%) RAVE Inputs Percentile Weight(%)
Rate of Spread 95 30% Terrain Difficulty Index N/A 10%
Population Impacted 95 25% + Disability Population N/A 5%
Buildings Destroyed 95 25% Poverty Population N/A 5%
Figure 1-5:Inputs and Weights for Composite Risk Calculation
Risk Associated with Ignition Location(RAIL)Component Risk Associated with Value Exposure(RAVE)Component
(Variable l(Weight;%))+(Variable 2(Weighq%))+(Variable 3(Weight;%)) + (Variable l(Weight;%))+(Variable 2(Weight%))+(Variable 3(Weig
Figure 1-6: Calculation of Composite Risk Score
Figure 1-7 below depicts a circuit with different fuel/terrain-driven and wind-driven
composite risk scores. The selected circuit is in steep terrain with dense vegetation (fuels),
resulting in a higher fuel/terrain-driven composite risk score (0.71) compared with a wind-
driven composite risk score of 0.26.
Page 18

Fuel/Terrain-Driven Risk—Circuit CNY21 Wind-Driven Risk—Circuit CNY21
IN
LUJComposite Score
O.0-0.1 ow
0.1-0.2 Risk
0.2-0.3
0.3-0.4
0.4-0.s CNY21
CNY21 —0.5-0.6
0.6-0.7
\y —0.7-0.8
0.8-0.9
0.9-1.0
0.71 Risk 0.26
IL
Figure 1-7.Comparison of Fuel/Terrain-Driven Composite Risk to Wind-Driven Composite Risk Near
Baldy Knoll, ID
In contrast, Figure 1-8 depicts a circuit in flatter terrain, producing a wind-driven composite
risk score that is higher (0.82)than the fuel/terrain-driven composite risk score (0.59).
Wind-Driven Risk—Circuit GSH12 Fuel/Terrain-Driven Risk—Circuit GSH12
Vq ite Score
0.0-0.1 ow r�
® GSH12 Composite
Risk ® GSH12 V
0. -0.3 i /__ r
0.3-0.4 _0.4-0. L��5.82
—0. -0.6
—0.6-0.7
0.8-0.9
�0.9-1.0
Figure 1-8: Comparison of Wind-Driven Composite Risk to Fuel/Terrain Composite Risk in Goshen
Junction, ID
As seen in Figure 1-7 and Figure 1-8, the composite risk scores can vary along a circuit due
to changes in fuels, terrain, built environment, assets, and community demographics.
COMBINED COMPOSITE RISK SCORE
A combined composite risk score is calculated for each circuit segment by combining the
wind-driven and fuel/terrain-driven composite scores and normalizing by the largest
composite score in the entire dataset(Figure 1-9). Each composite score is on a scale of 0-1.
Wind Driven Composite Risk+Terrain Driven Composite Risk
Largest Composite Score All Circuits
Figure 1-9: Combined Composite Risk Score Calculation
Page 19

These risk scores were used to create two risk outputs. First, Rocky Mountain Power used
the risk scores to inform a risk ranking of circuits for potential prioritization for system
strengthening. Second, the risk scores were used to identify the FHCA, discussed below.
1 .3 FIRE HIGH CONSEQUENCE AREA (FHCA)
Rocky Mountain Power has identified areas of heightened risk of wildfire, with delineated
geographic areas referred to as the Fire High Consequence Area or FHCA. The FHCA sets
geographic boundaries for wildfire mitigation programs, including enhanced asset
inspection and vegetation management programs discussed in Section 2.4 and Section 3.3,
respectively.
Rocky Mountain Power uses the FireSight composite risk scores for wind-driven and
fuel/terrain-driven wildfires to evaluate the FHCA boundaries. Circuit segments with a wind-
driven or fuel/terrain-driven score of 0.85 or above are added to the FHCA boundary. Based
on this approach, Rocky Mountain Power has not identified any geographic areas in Idaho
for inclusion in an FHCA.
AREAS OF INTEREST
Rocky Mountain Power has identified "Areas of Interest"—geographic areas with composite
risk scores of 0.65-0.85 (Areas of Interest 1) and 0.45-0.65 (Areas of Interest 11). The Areas of
Interest are shown in Figure 1-10.
Page 20

JDAHO a
Z
0
o
Fort c.
Hall POCK!
1.R.
Twr n Fart .RupeR
q;K
r� Service Territory
rr� Areas of Interest I
Areas of Interest I I
Figure 1-10:2025 Areas of Interest
Rocky Mountain Power plans to provide information on the risk modeling approach to the
following utilities with assets in close proximity to the Areas of Interest:
• Bonneville Power Administration
• City of Idaho Falls
• City of Soda Springs
• Fall River Rural Electric Cooperative
• Idaho Power Company
Finally, Rocky Mountain Power also intends to continue evaluating the FHCA annually to
incorporate new data, modeling techniques, and stakeholder input.As part of that process,
Rocky Mountain Power plans to confer with state and local agencies, such as Idaho
Department of Lands, and possibly other private stakeholders, such as the Southern Idaho
Timber Association. No FHCA updates are included in the 2026-2028 WMP, but the
Company expects to provide updated FHCA mapping in a future filing.
Page 21

1 .4 MONETIZED RISK
Even though Rocky Mountain Power's current methodology does not yet express wildfire risk
in dollar terms, it still functions as a cost-benefit analysis because it evaluates mitigation
choices through the relationship between risk reduction (benefit)and resource prioritization
(cost). The existing framework, using wind-driven, fuel/terrain-driven, and composite risk
scores, identifies where the system faces the greatest exposure and therefore where
mitigation investments will produce the greatest reduction in risk. By ranking assets
according to risk severity and probability, the Company already weighs the "benefit" of risk
reduction against the implicit "cost" of diverting mitigation resources away from lower-risk
areas. In this way, even a non-monetized scoring system enables the Company to make
decisions that balance limited budgets with the highest potential safety and system-
reliability gains.
At the same time, the Company's ongoing work demonstrates that these foundational risk
scores are the first step toward a more formalized monetized cost-benefit framework.
Throughout 2025, Rocky Mountain Power has been improving its risk quantification
methodology, with a focus on quantifying wildfire mitigation projects in terms of both
monetized risk and risk spend efficiency(RSE). This effort reflects the Company's intention
to present baseline risk and risk reduction in tangible units, including the monetary impact
of acres burned, significant injuries or fatalities, and damaged structures.
Rocky Mountain Power continues to leverage the Technosylva FireSight model to assess
asset-related wildfire risk throughout its service territory. To monetize wildfire risk outputs
from the FireSight model, the Company will be modifying the attribute selection to
accommodate monetizing the consequence of wildfire and then incorporating the
probability of wildfire in the risk equation. This ensures that both the probability of a risk
event and the consequence of a risk event remail available to evaluate possible mitigations.
Rocky Mountain Power expects to have this methodology fully developed and included in
the 2027-2029 Idaho WMP.
1 .5 RISK TREATMENT- PROGRAM SELECTION AND PRIORITIZATION
For the 2026-2028 WMP, Rocky Mountain Power applies a decision-making process within
the FHCA to develop specific projects or incremental programs. The process, represented
by Figure 1-11, includes four key phases: (1) risk modeling and assessment, (2)
program/project identification and planning, (3) evaluation and selection, and (4)
implementation and monitoring.
Page 22

ModelingRisk .•
&Assessment Identification Monitoring
i Project Delivery.
General Step/Task Risk Mitigation
List of Selected &Evaluation of
Impacted by Baseline IZ Mitigation Projects I Effectiveness Assessment Commercially &Programs to
Viable Options) include in Plan
Identification of Id Mitigate X
High-Risk Assets ;Identified Risks
&Risk Drivers to
Mitigate
EDetailed Scoping
Risk
Prioritization
Potential Mitigation
Strategies Cost Construction Planning
Geographic Risk Areas Pilot Projects/ Qualitative Deployment&
(FHCA) Research Assessment
Implementation
Specific Asset Risk
Evaluation&Risk Evaluation of Monitoring&
Commercial Options Technical Assessment
Drivers Effectiveness
Figure 1-11:Program and Project Selection Process
Phase 1 —Risk Modeling and Assessment
The baseline risk mapping section identifies the areas of heightened wildfire risk within
Rocky Mountain Power's service territory. As described in Section 1.2, Rocky Mountain
Power uses FireSight to further identify and prioritize specific circuits that have a heightened
risk of wildfire, like those identified in Figure 1-10 above.
The circuits are prioritized for identification of mitigation options as described in Phase 2 —
Program Identification and Planning and Phase 3—Project Evaluation and Selection below.
Phase 2— Program Identification and Planning
Identifying mitigation options requires evaluating current proven industry practices and
technology. Rocky Mountain Power has relationships with other utilities across multiple
states and discusses industry practices with those utilities, learning from their experiences
and evaluating proven industry solutions for selection as a mitigation program.
Additionally, information from ignition risk drivers helps shape Rocky Mountain Power's
programs,which typicallyfocus on methods,tactics, and technologies that reduce outages
or, more specifically,fault events. For example, if the risk of utility-related wildfire exists due
to equipment failure, increasing inspections or maintenance activities may help mitigate the
Page 23

risk. If the risk exists due to potential contact with third-party objects, constructing a system
more resilient to contact with objects may help to mitigate the risk.
Table 1-2 below generally maps Rocky Mountain Power's key risk drivers to the primary
programs, demonstrating what elements impact a group or groups of risk drivers. It is
important to note that elements may not eliminate a risk driver but are designed to mitigate
the risk associated with that driver. For many risk drivers, risk is mitigated through a
combination of programs, and there is not always a 1:1 relationship between a risk driver
category and a mitigation program. All elements and programs in the plan work together to
collectively mitigate wildfire risk.
Table 1-2: Risk Driver Mapping to Potential Mitigation Program(s)
Significant
Contributor to Wire Potential Mitigation Program Categories
Down Events
Key Risk
Driver
Asset Vegetation System Field System
Inspections Management Strengthening Operations Operations
Object ✓ ✓ ✓ ✓ ✓ ✓
Contact
Other ✓ ✓ ✓ ✓ ✓ ✓
Equipment ✓ ✓ ✓ ✓ ✓ ✓
Failure
Unknown ✓ ✓ ✓ ✓ ✓ ✓
Wire-to-wire ✓ ✓ ✓ ✓ ✓
contact
Contamination ✓ ✓ ✓ ✓
Utility Work ✓ ✓ ✓ ✓
Vandalism/ ✓ ✓ ✓
Theft
Lightning ✓ ✓
As program scoping identifies mitigation options, it is designed to ensure that the ignition
risk driver is addressed and considers existing programs to avoid duplicate efforts or
increased costs.
Page 24

Phase 3— Project Evaluation and Selection
Rocky Mountain Power implements tools and processes to ensure that mitigation projects
are cost-effective and technically feasible. Figure 1-12 below shows the current project
evaluation and selection process.
Evaluation
-------------------------------------------------------------------
UndergroundSpacer Cable($/Mi)
Recommended
-------------------------------------------------------------------
Mitigation
Regulatory Requirements
Qualitative St
Assessment aRisk keholder
mer Impact
--------------------------------------------------------------------
• Constructability
Technical Accessibility
• Vegetation
Assessment Geotechnical
• Environmental
• Permitting
Figure 1-12:Current Project Evaluation and Selection Process
Risk Identification
With the implementation of the composite risk score to identify the specific circuits and
segments of elevated risk, risk identification is shifting its focus. The new approach
identifies the highest-risk circuits by composite risk score, allowing planning teams to
prioritize evaluation based on quantified risk scores.
Cost
Rocky Mountain Power considers project costs when planning, evaluating, and selecting
initiatives. For example, Rocky Mountain Power evaluates the potential to convert overhead
Lines to underground lines for rebuild projects on a project-by-project basis. Through the
Page 25

design process, each individual project is assessed to determine whether sections of the
rebuild should be completed with underground construction. Rocky Mountain Power has
experience that in a more remote, heavily forested location with few customer connections,
undergrounding can be a cost-effective solution when compared to installing a covered
conductor.Another example is partneringwith communication companies fora joint trench,
the costs to the electric utility to underground can be less than overhead rebuild.
Qualitative Assessment
Rocky Mountain Power uses qualitative evaluation of proposed projects. Qualitative
considerations include:
• Regulation and Requirements — Rocky Mountain Power reviews regulations and
requirements for project alignment and compliance. For example, Rocky Mountain
Power projects are built to the approved National Electric Safety Code (NESC)
standards.
• Internal Stakeholder and Customer Input—Initiative identification and evaluation are
coordinated with various stakeholder groups within the Company and departments
that participate in the development and selection of initiatives that align with risk
reduction goals. In addition to internal stakeholder input, Rocky Mountain Power
considers customers' input through webinars that engage local communities and
public safety partners on wildfire safety.
• Wildfire Risk Impact — Mitigation initiatives are evaluated against industry best
practices and programs from other utilities that have demonstrated success in
reducing wildfire risk. Mitigation initiatives are prioritized by known historical causes
of risk.
• Customer Impact—The evaluation and identification of initiatives consider customer
impact in elevated risk areas and location or overlapping of local communities to
determine prioritization and urgency of initiative selection. Customer impact may
include,for example, re-routing an existing line that may interfere with the customers'
ability in the future to construct a facility(barn, shed, etc.).
Technical Assessment
A feasibility analysis is performed as a qualitative input to mitigation selection. Technical
analysis may indicate that the most effective mitigation is not feasible due to other
considerations. Technical feasibility is also used to evaluate mitigation techniques that
currently do not have effective measures of implementation.Tech nicalfeasibility considers
the following:
Page 26

• Constructability — Ease of implementation and constructability are factors in
selecting the final mitigation technique. For example, commercially available
solutions such as covered conductor may be widely implemented as a mitigation
technique, while new and emerging technologies, such as DFA (Distribution Fault
Anticipation) maybe implemented as pilot projects with limited application due to the
constructability.
• Accessibility— Access to the location to perform the work may impact selection of
mitigation technique. For example, undergrounding in a steep terrain may be
inadvisable due to the equipment needed and the ability to safely operate equipment
in the terrain.
• Vegetation— Impacts to vegetation because of the proposed project are considered,
including mitigation efforts during the project and any potential remediation needed
after the project due to removal of vegetation.
• Geotechnical — Identification of the type of earth below ground may affect the
mitigation selected. For example, solid rock or rocky soil may not be conducive to
undergrounding due to technical feasibility or cost, and covered conductor may be a
more cost-effective solution.
• Environmental—Impacts to air,soil,orwater of a proposed mitigation are considered.
• Permitting — The ability to successfully acquire permits as well as the number of
permits required is a consideration. For example, a covered conductor project may
be selected over undergrounding in certain circumstances because permitting can be
completed more quickly with fewer barriers. Conversely, undergrounding may be
moved forward where alignment with other utilities, such as telecom, presents an
opportunity for cost sharing and joint location to a new trench or underground
infrastructure.
Phase 4—Implementation and Monitoring
As projects are selected,they move to the implementation and monitoring stage. Figure 1-13
shows the high-level process described further below.
Page 27

FHCA
Composite Risk
Score Other Projects
PSPS Vulnerability Weather Constraints
Community Impacts Engineering Design
Project Lead Times Schematics
Scope Management
Schedule
Management Inspection
Conditions
Outages
Weather Conditions
Figure 1-13:Project Implementation and Monitoring Process
Prioritization: With the risk data provided by FireSight and the updated FHCA maps, Rocky
Mountain Power will prioritize new work based on the following:
1. Work inside the FHCA, in order from highest fuel/terrain-driven composite risk score
to lowest.
2. Work outside the FHCA, in order from highest fuel/terrain-driven composite risk
score to lowest.
Sequencing: After work is prioritized, it also must be sequenced to execute on the highest
priority work first while understanding that constraints may impact when work can begin.
Examples of constraints that impact sequencing include:
• Other utility work in the area. If proposed work requires electric service to be
temporarily rerouted, other utilitywork in the area may impact when that can happen
to manage service interruptions to customers.
• Weather conditions. For example, if the work is being performed at higher elevations,
the work may need to be scheduled in summer and fall to avoid snowy roads.Summer
work must be mindful of critical fire weather.
• Community impacts.This could range from municipal projects that have priority in a
community to feedback from the local, state, and federal partners about timing to
minimize impacts on residents.
• Project lead times. Examples include ordering and receiving equipment and
permitting.
Page 28

• Design:After the prioritization and sequencing have been determined,the project will
move to the design stage. The design stage can take on many different forms
depending on the project, ranging from schematics and process design to a complete
engineering design. At this point, the project's schedule and costs are finalized.
• Implementation: Once the scope, prioritization, and design are completed, the
project is ready for implementation. As an initial step, prior to implementation, key
performance metrics will be established to enable measurement of results to inform
mitigation effectiveness for future modeling. Key metrics examples include
installation dates, completion dates, conditions, and outages reported.
• Monitoring: As the work is completed, the updated asset information will be updated
annually in FireSight. Over time, the outage history for the asset will inform the
composite risk score for the circuit.This will help identify if the risk has been reduced
and if the risk driver has been mitigated.
2. INSPECTION AND CORRECTION
2.1 INSPECTION AND MAINTENANCE PROGRAM OVERVIEW
Rocky Mountain Power's inspection and maintenance program is structured to align with
industry standards and recognized best practices. Regular and systematic inspection of
power lines is a cornerstone of prudent utility management and sound industry practice.
These inspections enable early detection and correction of issues such as damaged
conductors, deteriorated poles, vegetation encroachments, and hardware defects that
could otherwise contribute to ignition events, equipment failures, or safety hazards. By
maintaining inspection schedules consistent with National Electrical Safety Code (NESC)
requirements, the Company demonstrates due diligence in keeping its facilities in safe
operating condition.Timely inspections and corrective actions can help reduce wildfire and
reliability risks, protect the public and employees, and preserve utility assets.This proactive
approach reflects both a prudent investment in system reliability and a reasonable measure
to help safeguard against foreseeable fire and safety risks inherent to electric infrastructure.
Rocky Mountain Power performs routine inspections as dictated by Company policies
(referenced below)and completes annualvisual assurance patrols across the entire service
territory. Areas classified as FCHA are subject to additional inspection program elements.
At this time, Idaho does not have FHCA, so all assets are subject to the standard inspection
program.When an inspection is performed on an asset, inspectors use a predetermined list
of condition codes and priority levels (defined below) to describe any noteworthy
observations or potential noncompliance discovered during the inspection. Once recorded,
Page 29

the condition codes are used to establish the scope of and timeline for corrective action to
maintain conformance with NESC requirements and Company policies. This process is
designed to correct conditions while reducing impact to normal operations.
Key terms associated with the inspection and correction programs are defined as follows:
• Visual Assurance Inspection: A brief visual inspection performed by viewing each
facility from a vantage point allowing reasonable viewing access. Visual assurance
inspections are intended to identify clearance violations, damage or defects to the
transmission and distribution system, or other potential hazards or right-of-way
encroachments that may endanger the public or adversely affect the integrity of the
electric system, including items that could potentially cause a spark. Special
emphasis is placed on identifying conditions that could result in energy release,
particularly within FHCAs. While there is no FHCA in Idaho, corrective actions for
identified issues in these regions are prioritized and expedited to reduce wildfire risk.
Visual assurance inspections across the service territory are performed annually to
ensure timely identification and resolution of potential hazards (Policy 011).
• Detailed Inspection: A careful visual inspection accomplished by visiting each
structure, as well as inspecting spans between structures.This inspection is intended
to identify potential nonconformance with the NESC or Company standards,
infringement by other utilities or individuals, defects, potential safety hazards, and
deterioration of the facilities that need to be corrected to maintain reliable and safe
service (Policy 009).
• Pole Sound and Bore: An inspection performed by sounding the pole to locate
external and internal decay pockets. The pole is tapped with a metal hammer to
identify potential soft spots or hollow-sounding areas. If decay is suspected,
inspection holes are drilled to determine the extent of the internal decay(Policy 013).
• Pole Test and Treat: An inspection of wooden poles to identify decay, wear, or
damage. Inspections may include pole-sounding, inspection hole drilling, and
excavation to assess the pole condition at groundline to identify the need for any
repair or replacement. When applicable, preservative treatment is also applied as
part of this inspection (Policy 013).
• Enhanced Inspection: A supplemental inspection performed that exceeds the
requirements of normal detailed or visual inspections; typically, a capture of infrared
data, a drone inspection, or an off-cycle inspection performed to support significant
weather events or times of critical wildfire risk(Policy 358 & Policy 371).
• Patrols: Patrols are visual inspections performed in addition to scheduled inspection
cycles. Patrols can be performed prior to or during significant weather events and are
Page 30

usually performed prior to re-energization of lines in FHCA during fire season.
Patrolling can result in conditions being identified and corrected, similarto scheduled
inspections. More details on patrolling activities are described in Section 6.6.
• Condition: As the result of an inspection, a condition reports the state of an asset
regarding appearance, quality, or working order. Conditions may indicate potential
impacts to normal system operation, NESC violation, other utility or private
clearances (Procedure 069).
• Energy Release Risk Condition: A type of condition that, under certain
circumstances, can correlate to increase the risk of a fault event and potential release
of energy at the location of the condition.
• Condition Codes: Predetermined list of codes for use by inspectors to efficiently
capture and communicate observations and inform the scope of and timeline for
potential corrective action.
• Correction: Scope of work required to remove a condition within a specified time
frame.
• Priority Level:The level of risk assigned to the condition observed, as follows:
■ Imminent—imminent risk to safety or reliability
■ Priority A—risk of high potential impact to safety or reliability
■ Priority B—low or moderate risk to safety or reliability
2.2 STANUHRD INSPECT ION AND CORRECTION rKOGRAMS
Rocky Mountain Power's asset inspection programs involve four inspection types: (1)visual
assurance inspection; (2) detailed inspection; (3) pole sound and bore; and (4) pole test and
treat. Inspection cycles, which establish the frequency of inspections, are set by Rocky
Mountain Power's asset management department. In general,visual assurance inspections
are conducted more frequently,to quickly identify any obvious damage or defects that could
affect safety or reliability. Detailed inspections have a more comprehensive scope of work,
so they are performed less frequentlythan visual assurance inspections. Pole test and treat
(including sound and bore inspections) are more intrusive and target finding internal decay.
The frequency of these intrusive inspections is based on the age of wooden poles, and such
inspections are typically scheduled in conjunction with detailed inspections. Regardless of
the inspection type, any identified conditions are entered into Rocky Mountain Power's
facility point inspection system database fortracking purposes. For any condition identified,
the inspector will assign a condition code and the associated priority level. Corrections are
recorded in the facility point inspection mainframe application, with suggested correction
time frames determined by internal Company policies, as discussed below.While the same
Page 31

condition codes are used throughout Rocky Mountain Power's service territory, the time
frame for corrective action varies depending on location, wildfire risk area, and if the
condition has the potential to release energy. In all cases, the timeline for corrections
considers the priority level of any identified condition.
2.3 FHCA INSPECTION AND CORRECTION PROGRAMS
The Company's existing inspection and correction programs are effective at maintaining
regulatory compliance and managing routine operational risk.They also mitigate wildfire risk
by identifying and correcting conditions that, if uncorrected, could potentially ignite a fire.
While Idaho does not have a designated FHCA today, the enhanced FHCA programs
described in this WMPwill be implemented in the future, should FHCA be identified in Idaho.
Recognizing the growing risk of wildfires, Rocky Mountain Power is continuingto supplement
its existing programs within the FHCAs, as defined in Section 1, to further mitigate the
growing wildfire-specific operational risks and create greater resiliency against wildfires.
The Company has implemented three primary elements: (1) created a fire threat
classification system that correlates specific conditions to a heightened risk of fire ignition;
(2) increased the frequency of inspections in the FHCA; and (3) expedited the correction of
anyfire threat conditions identified within the FHCA. These programs are discussed in detail
below.
FIRE THREAT CONDITIONS
Certain conditions are classified as energy release risk conditions. As the name implies,
these are conditions that, under specific circumstances, may increase the likelihood of a
fault event and associated release of energy at the location. If a condition is classified as an
energy release risk and is located within the FHCA, the condition is designated as a fire
threat condition, which means it is generally treated as a type that corresponds to a
heightened risk of fire ignition; see Figure 2-1.
Page 32

Service Territory
. a`00
P��G�� Energy
Release Fire
Risk Threat FHCA
Conditions
Figure 2-1:Fire Threat Condition Identification
For example, damaged or frayed primary conductors are assigned the condition code
CONDFRAY and are energy release risk conditions because the condition could eventually
result in a release of energy under certain circumstances.A CONDFRAY condition identified
within the FHCA is designated as a fire threat condition because, due to escalation and
environmental factors, the condition could eventually result in an ignition. In contrast, a
missing or broken guy marker would be assigned the condition code GUYMARK and would
not be designated as an energy release risk condition or a fire threat condition.Table 2-1
describes the energy release conditions that, if located within the FHCA, Rocky Mountain
Power designates as fire threat conditions.
Fable 2-1: Energy Release Conditions
Condition Type Description
Broken/Missing Grounds Broken or missing ground on a pole or equipment,identified
during visual or detail inspections
Frayed/Damaged Conductor A conductor identified by visual or detailed inspection to have
damage or fraying on conductor strands
Components or equipment that has a temperature rise that
Infrared exceeds thresholds in inspection and correction policies
identified during enhanced inspection
Loose/Broken Anchors and Guys Loose or broken anchor and guying identified on the pole during
visual or detail inspections
Loose/Broken Communication Lashing One or more lashing wires(Telco,CATV, Fiber)that are broken or
Wires loose, identified during visual or detail inspections
Loose/Damaged Equipment Loose or damaged equipment(capacitors, regulators, reclosers,
etc.)identified on the pole during visual or detail inspections
A connection, bolt,or hardware component identified during
Loose Connections/Bolts/Hardware visual or detailed inspections to be loose or missing from
equipment or framing on the pole
Page 33

Condition Type Description
A pole identified for replacement during intrusive testing or visual
Pole Replacement inspection because it does not meet strength requirements or
safety factors
Primary and secondary conductor clearances from the pole,
Primary and Secondary Conductor buildings,or ground that do not meet minimum clearance
Clearances requirements specified in the NESC, identified during visual or
detail inspections
Unstable Soils Soil or backfill on a pole that is unstable or insufficient, identified
during visual or detail inspections
Vegetation clearances from the pole, primary/secondary
Vegetation Clearances conductor,and climbing space that do not meet minimum
clearance requirements specified in the NESC,identified during
visual or detail inspections
INSPECTION FREQUENCY
Consistent with industry best practices, inspections are the Company's preferred
mechanism to identify conditions. Rocky Mountain Power believes that having more
frequent inspections in FHCAs is an important mitigation strategy. More frequent
inspections identify conditions earlier, allowing for timely corrective action. Reducing the
duration that a condition exists on the system may lower the risk of a fault event or release
of energy.
Inspection frequencies for Idaho asset types are summarized in Table 2-2.
Page 34

Table 2-2: Planned Inspection Frequency
Inspection Type* FHCA Inspection Standard Inspection Frequency(Years) Frequency(Years)
Overhead Distribution(Less than 46 kV)
Visual 1 1
Detailed 10 5
Pole Sound and Bore 10 10
Pole Test and Treat** - 10
Overhead Local Transmission(Greater than 46 kV and less than 200 kV)
Visual 1 1
Detailed 10 5
Pole Sound and Bore 10 10
Pole Test and Treat 10 10
Overhead Main Grid(Greater than 200 kV)
Visual 1 1
Detailed 2 2
Pole Sound and Bore 10 10
Pole Test and Treat 10 10
*Inspections with same inspection frequency are performed at the same time.
**Treatment may not be applied if the pole is scheduled for replacement through the line rebuild
program.
EXPEDITED CORRECTION TIME FRAMES
Rocky Mountain Power further mitigates wildfire risk in the areas of greatest risk by reducing
the time for correcting fire threat conditions identified in the FHCA. The expedited time
frames in FHCAs reduce correction times for priority A conditions from 120 days to 60. Any
condition classified as an imminent energy release risk within the FHCA is addressed
immediately. Correction time frames for fire threat conditions are outlined in Table 2-3.
Table 2-3: Planned Correction Time Frames for Fire Threat Conditions in the FHCA
Condition Priority Correction Time Frames
I—Imminent Energy Release Risk in FHCA Immediate
A—Energy Release Risk in FHCA 60 Day
B—Energy Release Risk in FHCA 12 Months
Page 35

2.4 ENHANCED INSPECTIONS
Rocky Mountain Power's enhanced inspection programs use alternate technologies such as
infrared or drone imagery to supplement visual inspections and identify hot spots,
equipment degradation, and potentially substandard connections.
The infrared inspection program can be performed on transmission lines that are
interconnected with the FHCA.The identified lines are grouped by peak loading intervals for
the inspections to be performed. The infrared data are used to identify thermal rises in
equipment, which could be a potential issue not visible through other inspection programs.
Drone inspections are performed using an unmanned aerialvehicle(UAV), or drone.A drone
can provide enhanced imagery, alternate perspectives, and the ability to package new
technology(LiDAR, infrared, detailed imagery)to view assets and assess conditions.
3. VEGETATION MANAGEMENT
Rocky Mountain Power's vegetation management program adheres to its Transmission &
Distribution (T&D) Vegetation Management Program Standard Operating Procedures
(SOPs), which are designed to reduce the potential of vegetation contact with power lines
and risk of ignition originatingfrom electrical facilities. While it is impossible to eliminate all
vegetation contact, at least without radically altering the landscape near power lines, the
primary objective of the vegetation management program is to minimize contact by
addressing both grow-in and fall-in risks. Rocky Mountain Power manages a comprehensive
vegetation management program throughout its service territory. All of the work performed
in the core program provides mitigation against wildfire risk, because the core program is
designed to minimize the risk of vegetation contact. In addition, Rocky Mountain Power may
also supplement the core program with activities both inside and outside the FHCA, further
reducing the potential of vegetation contact in those areas. Rocky Mountain Power will
consider applicable vegetation management recommendations from federal, state, and
Local agencies when establishing and maintaining its standards.
There is currently no FHCA in Idaho, so all routine vegetation management work in Idaho is
performed following the Company's regular vegetation management program detailed
below. Rocky Mountain Power's vegetation management department may perform specific
incremental activities to address wildfire risk in Idaho when a near-term risk is identified
through increased situational awareness efforts, discussed in greater detail in Section 5.
Page 36

3.1 RIGHTS-OF-WAY
On private lands, easements grant the right-of-way across a specific parcel of land. When
right-of-way access is not explicitly granted in terms of an easement, the right to enter upon
the easement to carry out necessary activities—including but not limited to vegetation
management, emergency de-energization, and grid operation—is deemed to be implied.
On public or government-owned lands, property access rights are generally secured through
License agreements with the relevant agencies.
The Company has also established Installation Rules, which explicitly state that any
customerwill allow Rocky Mountain Power safe and unobstructed access to the customer's
premises at reasonable times to trim trees and other vegetation to the extent necessary to
avoid interference with the Company's distribution lines and to protect public safety.
3.2 REGULAR VEGETATION MANAGEMENT PROGRAM
Tall-growing vegetation that is identified during inspections is pruned to maintain a safe
distance between vegetation and power lines. Rocky Mountain Power also removes
identified hazard trees to minimize fall-in risk, depicted in Figure 3-1 below. Hazard trees are
dead, dying, diseased, deformed, or unstable trees that have a high probability of falling and
contacting a substation, distribution conductor, transmission conductor, structure, guy, or
other electric facility. Hazard trees are identified for removal during vegetation inspections.
Like other utilities, Rocky Mountain Power contracts with vegetation management service
providers to perform the pruning and tree removal work for both transmission and
distribution lines. If live marketable timber is identified for removal from timber Company
Land adjacent to the right-of-way, Rocky Mountain Power will compensate the landowner at
fair market value as required by statute.
Page 37

J• r' fax . .Z�'� •
y I
Figure 3-1:Hazard Tree Removal
DISTRIBUTION
Identified vegetation near distribution facilities is pruned to maintain a clearance between
conductors and vegetation. Work is performed on a three-year cycle, with off-cycle
inspections scheduled as needed, typically in conjunction with other wildfire mitigation
activities. When cycle work is planned, the circuit is inspected to identify vegetation that
needs to be pruned because it may grow too close to power lines before the next scheduled
cycle. Vegetation is pruned to achieve minimum post-work clearance distances, designed
to maintain sufficient clearance until the next scheduled cycle. Tree growth rates influence
the minimum post-work clearance distance. For example, fast-growing trees should have a
greater minimum post-work clearance than slow- and moderate-growing trees to maintain
required clearance throughout the cycle.
Rocky Mountain Power also distinguishes between side clearances, under clearances, and
overhang clearances.The distances forthe minimum post-work clearances used for normal
cycle maintenance are listed in Table 3-1.
Table 3-1: Normal Distribution Minimum Post-Work Vegetation Clearance Distances
Slow-Growing Moderate-Growing Fast-Growing
(<1 ft./yr.) (1-3 ft./yr.) (>3 ft./yr.)
Side Clearance 8 ft. 12 ft. 14 ft.
Under Clearance 10 ft. 14 ft. 16 ft.
Overhang Clearance 12 ft. 14 ft. 14 ft.
Page 38

Distribution cycle work also includes work designed to reduce future work volumes.
Volunteer saplings, or small trees that were not intentionally planted, are typically removed
if they could eventually grow into a power line. In the long term, reducing unplanned
vegetation growth helps mitigate wildfire risk by eliminating a potential vegetation contact
Long before it could ever occur.
TRANSMISSION
Vegetation management on transmission lines focuses on removing tall and fast-growing
trees where rights-of-way exist. Where rights-of-way do not exist, identified vegetation is
pruned in an effort to maintain clearances between vegetation and electrical facilities.
These clearances vary according to the transmission line voltage. At all times, Rocky
Mountain Power must maintain the required minimum clearances set forth in FAC-003-05,4
which are referred to as the Minimum Vegetation Clearance Distance (MVCD).To determine
whether work is needed, an action threshold distance is applied; work is required if
vegetation has grown within the action threshold distance. When work is completed,
vegetation is removed or pruned to a minimum post-work clearance distance. The
applicable distances for various transmission line voltages are shown in Table 3-2. Hazard
trees are identified for removal in any vegetation inspection. To identify hazard trees, the
inspector applies the vegetation management best practices set forth in ANSI A300 Tree
Care Standards (Part 9).
Table 3-2:Transmission Minimum Vegetation Clearance(in Feet) by Line Voltage
Minimum 500 kV 345 kV 230 kV 161 kV 138 kV 115 kV 69 kV 45 kV
Clearance Type
Minimum
Vegetation 8.5 5.3 5.0 3.4 2.9 2.4 1.4 N/A
Clearance
Distance(MVCD)
Action 18.5 15.5 15.0 13.5 13.0 12.5 10.5 10
Thresholds
Minimum
Clearances 50 40 30 30 30 30 25 20
Following Work
In some circumstances, when local conditions and property rights-of-way allow, Rocky
Mountain Power may use Integrated Vegetation Management (IVM) practices to prevent
vegetation growth from violating clearances by proactively managing the species of trees
'See Table 21 Over 10,000 ft up to 11,000 ft of FAC-003-05.FAC-003-5.Sourced Nov.10,2025.
Page 39

and other vegetation growing in the rights-of-way. Under such an approach, Rocky Mountain
Power may remove tree species that could potentially threaten clearance requirements,
while encouraging low-growing cover vegetation, which would prevent clearance issues
(see Figure 3-2).
Main grid transmission lines are inspected annually. Other transmission lines ("local"
transmission) are inspected every three years. Vegetation work is scheduled dependent on
several local factors, consistent with industry standards and best management practices.
When transmission lines are overbuilt, meaning they are located on the same poles as
distribution lines, vegetation management work is completed on the normal 3-year
distribution cycle schedule.
TRANSMISSION DISTRIBUTION
S r�
it
I
t
Figure 3-2:Example Rights-of-Way Clearances for Transmission(left)and Distribution(right)
3.3 ENHANCED VEGETATION MANAGEMENT
Vegetation management programs can be targeted to achieve long-term wildfire risk
reduction or can be a rapid response to dynamic situational awareness, which can occur
anywhere in the service territory. In addition to the regular maintenance program discussed
above, Rocky Mountain Powertargets areas of elevated wildfire riskfor enhanced vegetation
management, particularly in the FHCA.
OFF-CYCLE VEGETATION INSPECTIONS
As discussed above, normal vegetation management work on the distribution system is
performed on a three-year cycle. In areas of elevated fire risk, however, Rocky Mountain
Power may schedule an off-cycle vegetation inspection. In the FHCA, an off-cycle vegetation
Page 40

inspection is typically scheduled annually(meaning every year except those years where the
circuit is already scheduled for regular maintenance).
Currently, Idaho does not have an FHCA; however, off-cycle vegetation inspections may still
be scheduled anywhere in the service territory as needed,typically in conjunction with other
wildfire mitigation activities (as discussed in Section 3.2). Off-cycle inspections focus on
identifying any hazard trees that have emerged since the last inspection. An inspector will
also identify vegetation likely to exceed minimum clearance requirements prior to the next
scheduled inspection. After an off-cycle inspection is completed, vegetation management
work is promptly completed as reasonably practicable, including removal of any hazard
trees.
EXTENDED CLEARANCES
Rocky Mountain Power uses increased minimum post-work clearance distances for any
distribution cycle work in the FHCA(Table 3-3). In simple terms, more clearance equates to
decreased likelihood of tree-powerline contact.
Table 3-3: Distribution Minimum Post-Work Vegetation Clearance Distances in the FHCA
Slow Growing Medium Growing Fast Growing
(<1 ft./yr.) (1 to 3 ft./yr.) (>3ft./yr.)
Side Clearance 12 ft. 12 ft. 14 ft.
Under Clearance 12 ft. 14 ft. 16 ft.
Overhang Clearance 12 ft. 14 ft. 14 ft.
POLE CLEARING
In the FHCA, Rocky Mountain Power's vegetation management team performs pole clearing
on subject equipment poles, which are poles that have switches, clamps, fuses, or other
devices that could create a spark. Pole clearing involves removing all vegetation within a 10-
foot radius cylinder (up to eight feet vertically) of clear space around a subject pole and
applying herbicides and/or soil sterilant to prevent any vegetation regrowth (unless
prohibited by law or the property owner). This strategy is illustrated in Figure 3-3 and
Figure 3-4.
Page 41

1 I
I
I I
I I
I I
I I
I I
I I
I I
I I From 0-8 feet above ground level remove
It- I
flammable trash.debris or other materials.
- grass,herbaceous and brush vegetation and
Ground Neel: limbs and foliage of living trees up to a height
remove flenemeble she'... of 8 feet.
Ground Nvel-base of
ryllndricel space Oulee CY Wrilerence of pole or tower
Figure 3-3:Pole Clearing Strategy J
This strategy is distinct from the clearance and removal activities discussed above because
it is not designed to prevent contact between vegetation and a power line. Instead, pole
clearing is designed to remove fuels at the base of equipment poles to reduce the risk of fire
ignition if sparks are emitted from electrical equipment.
_ k
r -
Figure 3-4:Pole Clearing at Pole Base
Page 42

3.4 QUALITY CONTROL PROGRAM
Rocky Mountain Power's quality control program consists of the following:
• Quality Assurance (QA): Review written PacifiCorp T&D Vegetation Management
Program SOPs annually for adherence to NESC standards and regulatory
requirements.
• Quality Control(QC): Audit process to verify that completed vegetation maintenance
meets T&D Vegetation Management Program SOP requirements.
QUALITY ASSURANCE
Rocky Mountain Power achieves QAthrough its T&D Vegetation Management Program SOPs
and requirements therein. These SOPs establish program requirements to achieve desired
objectives.
QUALITY CONTROL
Rocky Mountain Power conducts QC through quality reviews and post-work audits to verify
the effectiveness and adherence of program requirements.
POST-WORK AUDITS
After the Company's vegetation management contractors complete work, Rocky Mountain
Powerforesters, alongwith a third-party contractor, conduct post-work audits to ensure the
work meets Company specifications, including clearances requirements. Post-work audits
are conducted annually on the circuits within the FHCA. Table 3-4 lists post-work audit
targets.
Table 3-4: Post-WnYi.Audit Targets
Maintenance
Sample Size Audit Type(s) Targeted Activities(Work Codes)
Action
Pole Clearing 10%of scheduled Visual ground-based or Distribution Pole Clearing-Fire
poles desktop Mitigation (FDP)
Tree Maintenance- 100%of scheduled Visual ground-based or Fire Mitigation Distribution (FMD)
Distribution line miles aerial
Tree Maintenance- 100%of scheduled Visual ground-based or Fire Mitigation Transmission (FMT)
Transmission miles aerial
Audit findings are used as a communication tool for continuous improvement. When
necessary, exceptions in the audit are assigned back to the contractor for correction. Post-
Page 43

work audits are conducted by internal or contracted International Society of Arboriculture
certified staff.
QUALITY REVIEWS
In addition to post-work audits, Rocky Mountain Power foresters randomly sample work
through quality reviews, which are more limited in scope and serve as spot checks. Unlike
post-work audits, which may cover an entire circuit, quality reviews may examine a single
tree, a property, or a segment of line. Quality reviews are conducted soon after vegetation
management work is completed in a given location. Their purpose is to identify potential
issues before crews leave the area, allowing staffto address deficiencies with the contractor
as soon as possible.
Documentation and corrective actions findings from both post-work audits and quality
reviews are recorded in PacifiCorp's mobile data management software. Any exceptions
defined as inconsistencies with Company specifications or missed work are visible to the
vegetation management contractor through the system. These exceptions are formally
assigned to that contractor, who remains responsible for the work, including any corrective
action.
7 SYSTEM STRENGTHENING AND RESILIENCY
Rocky Mountain Power's electrical infrastructure is engineered, designed, and operated in
a manner consistent with utility best practices, enabling the delivery of safe, reliable power
to all customers. When installing new assets as a part of corrective maintenance or growth
projects, Rocky Mountain Power incorporates the latest technology and engineered
solutions that have been assessed and proven to be effective. When conditions warrant,
Rocky Mountain Power engages in strategic system strengthening, such as replacing or
modifying existing assets and/or using a new design or technology to make the asset more
resilient. With the growing risk of wildfires, the Company supplements existing asset
replacement projects with system strengthening programs designed to mitigate operational
risks associated with wildfire.
System strengthening programs are designed in reference to the equipment on the electrical
network that could be involved in the ignition of a wildfire or be subjectto an existing wildfire
event. In general, system strengthening programs reduce the occurrence of events involving
the emission of sparks (or other forms of heat)from electrical facilities or reduce the impact
of an existing wildfire on utility infrastructure.System strengthening programs represent one
of the best long-term mitigation tools available for use by electric utilities. The phasing and
prioritization of such programs, as described in Section 1 will use risk modeling and
Page 44

assessments for program identification, which will be evaluated for implementation as a
strategic strengthening initiative.
No single system strengthening program mitigates all wildfire risk related to all types of
equipment. Individual programs address several factors, different circumstances, and
different geographic areas. Each program described below shares the common objective of
reducing overall wildfire risk associated with the design and type of equipment used to
construct electrical facilities. In prioritizing particular design or equipment elements, these
programs also consider environmental factors impacting the magnitude of a wildfire.
Extreme weather conditions such as dry and windy conditions present an increased risk of
wildfire ignitions and spread. Consequently, system strengthening programs may
specifically attempt to reduce the potential of an ignition event when conditions are dry and
windy by using equipment that is less likelyto release energy if failure or contact with foreign
objects occurs.
System strengthening cannot prevent all ignitions, no matter how much is invested in the
electrical network. Equipment does not always work perfectly and, even when
manufactured and maintained properly, can fail; in addition, there are external forces and
factors impacting equipment, includingfrom third parties and natural conditions.Therefore,
Rocky Mountain Power cannot guarantee that a spark or heat coming from equipment
owned and operated by the Company will never ignite a wildfire. Instead, the system
strengthening efforts seek to reduce the potential of an ignition associated with any
electrical equipment by making investments with targeted system strengthening programs.
IDLE LINE MITIGATION
Through industry collaboration, the Company has learned that idle lines that are mutually
coupled to an energized line may pose an ignition risk. The Company has removed all idle
transmission lines in Idaho that are not being used as an active backup to an energized line.
For lines that were not removed, a vendor was contracted to run power simulations on idle
Lines to advise mitigation strategies forthese lines.To date, 4.3 miles of idle lines have been
removed in 2025. For each line identified in Idaho, the mitigation plan and status are listed
in Table 4-1.
Page 45

Table 4-1: Idaho Idle Line Mitigation Plans and Status
PL ID State Line Name Length Mitigation Status
(Miles) Strategy
'800060 Idaho McCammon-Inkom 3.9
Remove Complete
46KV-PHASE 1
'800060 Idaho McCammon-Inkom 0.4
Remove Complete
46KV-PHASE 2
'730200 Idaho Ovid-Central Farmers 7.3 Grounding Study- TBD
Line Segmentation
'730100 Idaho Rexburg-Newdale- 5.9 Grounding Study- TBD
Canyon Creek LN Energize
4.1 LINE REBUILD PROGRAM
Circuits within an FHCA constructed with bare overhead wire are evaluated for potential
system strengthening work. As a part of this program, certain overhead lines may either be
moved, removed, retrofitted with more resilient materials (e.g., covered conductor or non-
wooden poles), or converted to underground. After completion of system strengthening,
such lines likely will be more tolerant to incidental contact, thereby reducing the risk of
wildfire. Because the Company currently has no FHCA in Idaho, it has no plans to incur line
rebuild costs in Idaho for 2026.
COVERED CONDUCTOR
Historically, most distribution power lines in the United States, and in Rocky Mountain
Power's service territory, were installed with bare overhead conductor. As the name "bare"
suggests, the wire surface is uninsulated and exposed to the elements. For purposes of
wildfire mitigation, covered conductor, also called tree wire or aerial spacer cable, has been
installed to provide an insulating layer around the conductor.
Covered Conductor Bare Conductor
".r
Figure 4-1: Covered Conductor(left) Compared to Bare Conductor(right)
Images from VW Wire and Cable Product List
Page 46

Covered conductors are manufactured with multiple high-impact—resistant extruded layers
forming an insulation around stranded hard-drawn conductor.The inherent design provides
insulation for the energized metal conductor. To be clear, covered conductor is not
insulated enough for people to directly handle an energized distribution voltage power line
(as discussed below). Rather, the insulating layers reduce the risk of wildfire by minimizing
the potential of vegetation or ground contact with the conductor.
Variations in covered conductor products have been used in the industry for decades. Due
to many operating constraints, however, use of covered conductor has typically been
Limited to locations with extremely dense vegetation where traditional vegetation
management was not feasible or efficient. Recent technological developments have
improved covered conductor products, reducing the operating constraints historically
associated with the design.These advances have improved the durability of the product and
reduced the impact of conductor thermal constraints. There are still logistical challenges
with covered conductor. The wire is heavier, especially during heavy snow/ice loading,
meaning that more and/or stronger poles may be required to support covered conductor.
The wildfire mitigation benefits of covered conductor may be significant.As discussed in the
risk assessment in Section 1, a disruption on the electrical network, a fault, may result in
emission of a spark or heat that could cause an ignition. Covered conductor reduces the
potential of many kinds of faults. Whether it is a tree branch falling into a line and pushing
two phases together or a Mylar balloon carried by the wind drifting into a line, contact with
energized bare conductor can emit sparks. If those same objects contact covered
conductor, the wire is insulated enough to prevent sparks. Likewise, many equipment
failures are a wildfire risk when they allow a bare conductor to contact a grounded object.
For example, if a crossarm breaks, the wire held up by the crossarm may fall to the ground
or come into contact with vegetation or the pole itself. Covered conductor may mitigate
these wildfire risks.
Covered conductors are especially well-suited to reduce the occurrence of faults linked to
wind, the primary driving force behind wildfire spread. Wind can blow objects into lines,
cause equipment failures, and even cause parallel lines to slap together. Taken together,
these benefits make covered conductor an effective mitigation measure in areas with a high
wildfire risk.
UNDERGROUND
Rocky Mountain Power also continues to evaluate the potential to convert overhead lines to
underground lines for the rebuild projects. The potential wildfire mitigation benefits of
converting to underground lines are undeniable. While an underground design does not
Page 47

eliminate every ignition potential (because of above-ground junctions), it is the most
effective design to reduce the risk of a utility-related ignition. Currently, the cost and
operational constraints of underground construction often make it difficult to apply on a
widespread basis.
Currently, the Company is continuing to evaluate the use of underground design as part of
the rebuild program on a project-by-project basis, and it uses underground construction
where practical.Through the design process, every rebuild project is assessed to determine
whether sections of the rebuild should be completed with underground construction. Some
communities and landowners may prefer, for aesthetic reasons, to pursue a higher-cost
underground alternative. Consistent with electric service regulations and Company design
standards, Rocky Mountain Power will collaborate with communities or individual
Landowners who are willing to pay the incremental cost and obtain the necessary legal
entitlements for underground construction.
4.2 SYSTEM RESILIENCY
NON-WOODEN POLES
Traditionally, overhead poles are replaced or reinforced within the service territory
consistent with the NESC, Company policies, and prudent utility practices. When a pole is
identified for replacement, typically through routine inspections and testing, major weather
events, or joint use accommodation projects, a new pole consistent with engineering
specifications suitable for the intended use and design is installed in its place. Engineering
specifications typically reflect the use of wooden poles, which is consistent with prudent
utility practices as they are considered safe and structurally sufficient to support overhead
electrical facilities during standard operating conditions. However,the use of alternate non-
wooden construction, such as steel orfiberglass(pictured in Figure 4-2), provides additional
structural resilience in high-risk locations during wildfire events and therefore aids in
restoration efforts. For example, as a part of covered conductor installation, the strength of
existing poles is evaluated. In many cases, the strength of existing poles may not be
sufficient to accommodate the additional weight of covered conductor. In these instances,
the existing wooden pole is upgraded to support the increased strength requirements and
replaced with a non-wooden solution for added resilience.
Page 48

i
1
r t'
ri1li C
1.
N�A
Figure 4-2:Distribution Fiberglass Pole
POLE WRAP
Depending on the pole configuration and location, Rocky Mountain Power may also install a
fire mesh wrap around both transmission and distribution wooden poles in areas of
heightened wildfire risk. The wrap is applied to protect the poles from fire damage in the
event of a wildfire. Pole wraps also may be applied on poles scoped for replacement with
steel poles as an interim solution.
4.3 ADVANCED SYSTEM PROTECTION AND CONTROL
Rocky Mountain Power is continuing to replace and upgrade electromechanical relays with
microprocessor relays throughout the service territory for operational improvements
system wide. Figure 4-3 shows the planned relay upgrade locations in Idaho.
Microprocessor relays provide multiple wildfire mitigation benefits. They can exercise
programmed functions much faster than an electro-mechanical relay and, most
Page 49

importantly, the faster relay limits the length and magnitude of fault events. After a fault
occurs, energy is released, posing a risk of ignition until the fault is cleared. Reducing the
duration of a fault event reduces the risk that the fault might result in a fire.
Additionally, microprocessor relays allow for greater customization to address
environmental conditions through a variety of settings and are better able to incorporate
complex logic to execute specific operations.These functional features allow the Company
to use more refined settings for application during periods of greater wildfire risk, to be
discussed in Section 6. As part of replacing an electro-mechanical relay, the associated
circuit breaker or other line equipment also may be replaced, as appropriate, to facilitate
the functionality of a microprocessor relay. Finally, as part of this upgrade, Supervisory
Control and Data Acquisition (SCADA) is extended to the relay, allowing remote monitoring
and control of the device. This may include upgrading existing communication assets or
installation of new assets.
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Figure 4-3:Idaho Planned Relay Upgrade Locations
Page 50

4.4 EXPULSION FUSE REPLACEMENT
Overhead expulsion fuses serve as one of the primary system protection devices on the
overhead system. A typical expulsion fuse has a small metal element within the fuse body
that is designed to melt when excessive current passes through the fuse body, interrupting
the flow of electricity to the downstream distribution system. Under certain conditions, the
melting action and interruption technique will expel an arc out of the bottom of the fuse tab.
To reduce the potential for ignition because of fuse operation, Rocky Mountain Power is
evaluating appropriate locations for installation of alternate equipment that does not expel
an arc.
4.5 7-AULT INDICATORS
Fault indicators detect and visually indicate the presence of faults in the distribution
system. These are generally installed on overhead lines and use LEDs, flags, or mechanical
indicators to show fault presence. These devices require manual inspection by crews to
Locate the faults.
Communicating fault circuit indicators (CFCIs) monitor current and voltage levels and are
equipped with wireless or wired communication modules to detect and alert operators to
the presence of faults in the distribution system. This helps reduce outage response time
and improves system reliability. These devices are widely used in smart grids for rapid fault
detection and isolation. The Company strives to balance the benefit of CFCI upgrades with
the increased cost associated with their operation. The focus during 2026-2028 will be on
monitoring the already-installed CFCIs rather than deploying new units at additional
Locations. As the Company continues to understand risk and implement mitigation
programs such as enhanced safety settings (ESS), the Company may install additional
CFCIs as needed and appropriate to continue balancing the impact to customers and
wildfire mitigation.
5. SITUATIONAL AWARENESS AND FORECASTING
As described in Section 1,the Company uses the FHCA as its baseline risk map, layered with
a risk driver analysis to inform long-term strategic investment and modifications to asset
inspections and vegetation maintenance practices. However, as climate and weather
patterns change, extreme weather events are predicted to become more frequent, and the
potential exists for seasonal, dynamic, and/or isolated risk events to occur that compound
or deviate from this baseline risk approach. Therefore, a sophisticated, dynamic risk model
Page 51

grounded in situational awareness is pertinent to ensure electric utilities know when,where,
how, and why to take risk mitigating actions in the short-term.
The Company's approach to situational awareness includes the acquisition of data to
forecast, model, and assess the risk of potential or active events to inform operational
strategies, response to local conditions, and decision-making. These key components, as
illustrated in Figure 5-1 and described below, rely on a core team of utility meteorologists to
continuously evolve the tools and technology, and leverage their expertise to guide action.
Real-time Weather
Conditions System Operations
l
Weather Forecast Work Practices
\ Dynamic 0
y Modeling- 0 0 Risk 0. QD
Q
Assessment
Forecasting \1 0 1/ ®—®
Wildfire Risk(WFA E) PSPS Implementation
o 0 0 0
IUW�W
i
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SITUATIONAL AWARENESS
Figure 5-1: Overview of Situational Awareness
5.1 METEOROLOGY
As described above, the ability to gather, interpret, and translate data into an assessment
of utility-specific risk and informed decision-making is a key component of the Company's
situational awareness capability. To support this effort, the Company developed a
Meteorology Department, which consists of meteorologists who develop forecasts, along
with a data scientist, operations managers, and a director to lead tools, processes, and
strategy. The team's experience includes decades of weather and fire weather forecasting
for various government and private-sector entities.
The objectives of the meteorology department are to supplement the Company's short-term
risk analysis capabilities by:
Page 52

• Utilizing and evolving real-time risk assessment and forecasting tools,
• Identifying and closing any forecasting data gaps,
• Managing day-to-day weather-related system impacts threats and risks, and
• Providing information to internal operation groups to inform and recommend changes
to operational postures during periods of elevated risk, as depicted in Figure 5-2
below.
METEOROLOGY INTERPRETATION
Analyze Rocky
Analyze Public Data Mountain Power Review
Weather Model Data
Observational
Data
Seasonal Fire Risk
0� Model
Meteorology
` I '
Interpretation
1 �
Generate Report
Figure 5-2:Meteorology Weather/Fire Assessment
The meteorology department also coordinates with government agencies that provide
additional weather and fire risk information relevant to the service territory and the
Company's assets. For instance, during high-risk weather events, the Company's
meteorologists participate as a represented partner in coordination calls hosted by the
National Weather Service and/or the Geographic Area Coordination Center. The
meteorology department also participates in these calls to discuss forecasting
discrepancies and seek or provide clarity regarding external messages from a utility or the
National Weather Service. The systems and tools used are summarized below and are
combined with additional real-time data points, along with the experience of the team, to
create actionable short-term forecasts.
5.2 NUMERICAL WEATHER PREDICTION
An impacts-based forecasting system consisting of an operational Weather Research and
Forecasting (WRF) model and a complementary WRF reanalysis across the Company's
Page 53

entire service territory form the foundation of the meteorology program. The Company has
continued to use its WRF reanalysis and other training data to build and train machine
Learning models, which will continue to improve its operational thresholds, and has
converted its weather forecasts into predictions of system impacts. To assess confidence
in the calculated values, forecasts are actively monitored to assess trends and potential
convergences or divergences between forecasts and actuals during periods of elevated risk.
OPERATIONAL WRF MODEL
The meteorology department uses a twice daily, two-kilometer-resolution, hourly WRF
model. The model produces a comprehensive forecast of atmospheric, fire weather, and
National Fire Danger Rating System (NFDRS) parameters out to a timescale of 127 hours.
The model's high resolution gives a much more complete picture of finer-scale atmospheric
features than what is available with most public four-day-ahead timescale models. In
addition,the WRF data is overlayed on overhead distribution circuits and transmission lines,
along with other relevant utility asset data for further analysis.
WFR REANALYSIS
Rocky Mountain Power's meteorology department developed a two-kilometer-resolution,
hourly reanalysis for weather climatology covering the entire service territory. The WRF
reanalysis uses the same configuration and contains the same weather, fire weather, and
NFDRS parameters as the Company's operational WRF to minimize any potential forecast
biases between the two datasets. The only difference is that the reanalysis is downscaled
from a longer time scale weather computer model compared to the operational WRF.These
reanalysis data were correlated with historic outage data and wildfire events using
statistical and machine learning techniques to improve the Company's weather-related
outage and wildfire risk thresholds. Output from Rocky Mountain Power's operational WRF
model is then ingested by the Company's machine-learning models and geographic
information systems (GIS) tools to convert the daily forecast into potential circuit-level
system impacts and to map the intersection of fire weather and outage-related risks across
its service territory. The WRF reanalysis also provides a daily circuit-level view of weather
and fire metrics relative to the past 33 years and, based on these historic data, an
assessment of whether the forecast weather event would historically have resulted in an
outage on that circuit. The historical reanalysis is updated annually so that data are as
accurate as possible when determining climatological thresholds for weather-related
outage percentiles and decision making for public safety power shutoff(PSPS)thresholds.
Page 54

CONTINUAL IMPROVEMENT
The Company's WRF domain covers the entirety of PacifiCorp's six-state service territory.
From 2021 to 2022, PacifiCorp procured two high-performance computing clusters(HPCCs)
to provide the computational resources needed to run an operational WRF and the WRF
reanalysis. The two systems provide a high-resolution forecast of the WRF domain twice
daily through a single, deterministic model. This WRF model has allowed the Company to
take meaningful action in advance of severe weather to reduce restoration times, plan for
resourcing, and increase reliability. However, the model does not account for multiple
weather scenarios, which makes it more difficult to forecast the types of low-probability,
high-impact weather events that are becoming both more common and more impactful.
To address this issue, during 2024-2025 the Company developed a multi-member WRF
ensemble weather model. To support the new ensemble system, the Company purchased
three new HPCCs.These new supercomputers will provide the computing power needed to
implement the new forecasting system and, at the same time, allow for full system
redundancy, which can be critical during severe weather events. The Company also
upgraded the two existing HPCCs, increasing forecasting from 3.5 days to 5 days and shifted
to a 5-day WRF forecast in the second quarter of 2025. The new ensemble system was
completed and became operational in the fourth quarter of 2025. This new forecasting
system enables analysis of multiple weather scenarios simultaneously, thereby improving
the accuracy of the Company's forecasts and its ability to respond to severe weather in
advance.
5.3 ONGOING DATA ACQUISITION AND INPUTS
Ongoing data acquisition and inputs,from both internal and external sources, is another key
component of Rocky Mountain Power's situational awareness model.
WEATHER STATION NETWORK
Public weather data have been available for many years. However, relying only on publicly
available data can have limitations. When using publicly available data, the utility does not
have visibility into the maintenance and calibration records or standards used to maintain
the weather station collecting the data. Additionally, the frequency of data collection may
not match the requisite intervals for performing real-time risk assessments and dynamic
modeling. Finally, publicly available data may have geographic coverage gaps within the
utility's service territory.
When weather stations are owned by the utility,the calibration date and usability of the data
are known, the data reporting intervals can be adjusted to report more frequently, and the
Page 55

data can be used to inform real-time operations. Additionally, weather stations can be
installed and adjusted to pinpoint specific locations needed to inform utility risk
assessment. For all these reasons, the Company is continuing to invest in a utility-owned
and operated weather station network within its service territory. Currently, the Company
has a network of 42 weather stations in Idaho installed directly on utility infrastructure.
Additionally, the Company also has portable weather stations that it can deploy as needed
during extreme weather events.
As shown in Figure 5-3 below, data gaps are a key consideration in where to site weather
stations.These gaps can include areas that lack data granularity or the absence of any data
altogether. Additionally, as part of its weather station siting methodology, the Company
accounts for geographic gaps in publicly available weather data from within its service
territory to include factors such as data resolution and consistency.
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Figure 5-3:General Weather Station Siting Methodology
Weather station data are used to create models of routine weather patterns in specific
areas. The Company leverages this weather data alongside the operational WRF, its
companion WRF reanalysis, and Technosylva's WFA-E software to model potential impacts
to infrastructure associated with forecasted weather events and inform operational
protocols and decision-making, such as when and where to stage resources and how to
Page 56

prioritize restoration times. This improved modeling allows the Company to better
anticipate impactful weather events and is a key component of situational awareness.
To ensure the weather stations are operating appropriately,they are calibrated annually.The
Company's meteorology department will continue to evaluate the benefits of installing
additional weather stations.
In 2025, Rocky Mountain Power installed seven additional weather stations, growing the
weather station fleet to approximately 42 stations by 2026. Rocky Mountain Power's
meteorology department will continue to evaluate the benefits of installing additional
weather stations.
WILDFIRE INTELLIGENCE CENTER AND WILDFIRE AND EMERGENCY RESPONSE
Wildfire threats have been growing in the Western United States over the past several
decades. This trend is depicted in Figure 5-4 below. In 2025, the Company established the
Wildfire Intelligence Center (WIC) to address this growing wildfire risk in the six states
PacifiCorp serves. The WIC provides 24/7 monitoring of all hazards that threaten Company
equipment, with a focus on wildfire.
Annual Acres Burned in 1983-2025 YTD (CA, OR, WA,UT, ID and WY)
1.2 12,000,000.00 Acres —Expon.(Acres)
1 10,000,000.00
0.8 8,000,000.00
0
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U
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YEAR
Figure 5-4: Wildfire Acres Burned in States Served by PacifiCorp 1983-2025
Page 57

Historically,the Company responded to active wildfires after receiving notification from 911
or other agencies. In cases where the first notification was from 911, the Company would
dispatch personnel to the site to provide information on proximity and potential threat to
assets.
Advances in early detection technologies have allowed the Company to take a more
proactive role in threat assessment as an incident evolves. Having dedicated staff with the
skillset and background to monitor and receive alerts from camera networks, fire agency
dispatch, official sources, and social media alerts at the earliest warning better positions
the Company to determine the need for action while prioritizing public safety, protecting
equipment, and maintaining electric service.
PacifiCorp's WIC was modeled after the best practices and insights of other Western state
investor-owned utilities that have integrated similar advanced notification technology and
intelligence gathering to inform decision-making and coordination with fire authorities. The
WIC is composed of individuals who monitor live events and provide situational awareness
and support. The WIC team analyzes information against an incident threat matrix to
determine whether the situation meets a threshold of action. The team is responsible for
providing situational awareness with the goals of early detection, rapid resource
deployment, enhanced public safety partner coordination, and improved customer
notification.
The WIC provides a daily Power Delivery Briefing for all six states,which includes Emergency
Coordination Center (ECC) activation status, weather outlook as provided by Meteorology,
and Significant Outage Impacts. During the wildfire season, the WIC provides the Daily
Wildfire Report, which delivers detailed information on active fires. The report covers fires
greater than 50 acres and provides intelligence on active incidents and associated actions
from Company response to fires that are within six miles of PacifiCorp assets. The
information provided by the WIC, and the actions coordinated by the WIC, cross multiple
stakeholders to align information and action. In circumstances where escalated support is
needed to coordinate response, the Emergency Management team may take over
coordination in conjunction with the Company's 2025 Emergency Response Plan.
By providing rapid, actionable intelligence, the WIC enables quicker response times by
Operations through verified information. Proactive response, when initiated early, allows
customers to receive faster notifications of potential emergency de-energizations that may
affect them, subsequently providing potential for initial emergency alerting as well.
From an inverse perspective, when System Operations is alerted of a wildfire that is
impacting the system, the WIC simultaneously receives those reports and begins aiding
Page 58

incident triage. These wildfires may need to be escalated further due to fire intensity and
spread potential, or may be de-escalated, limiting the extent of customers who are
impacted by emergency de-energization. While PacifiCorp increased wildfire monitoring
capabilities by 607.7% from 2024 to 2025, emergency de-energizations saw a 58.3%
decrease.These percentages are based on the Foundry count of incidents processed during
events that happened in 2024 compared to 2025.
The Wildfire and Emergency Response team was also established in 2025 to provide
operational and wildfire liaison support between the Company and fire agencies on scene.
The team is staffed by Fire and Emergency Response managers, who have a background in
wildland firefighting and, more specifically, are experienced in Complex Incident
Management team leadership and coordination. This on-site support of field crews and fire
agencies during wildland fires and other events improves coordination and communication
and ensures the safety of employees and the public. Fire and Emergency Response
managers will work with the WIC to validate threats, issues, and concerns and are
strategically located in the Company's operational areas to supplement information with
established fire agency relationships in their jurisdiction.
OPERATIONAL FLOW FOR WILDFIRES
For active wildfires,the Company follows a structured operational process, as illustrated in
Figure 5-5 below. Upon identification of a fire, monitoring and response protocols are
initiated. The WIC confirms the fire status with first responders and, if necessary, produces
a fire simulation or predictive analysis. Internal coordination begins by contacting the WIC
to ensure accurate situational awareness.
If the fire poses a significant threat to infrastructure or public safety, the WIC consults the
Wildfire Encroachment System Operations Procedure SOP 203 to evaluate the need for de-
energization. If immediate action is required, the process ensures that de-energization
occurs swiftly to mitigate wildfire risks.
If immediate action is necessary, notifications are sent to internal Operations Management
(executive leadership and appropriate emergency managers) using AlertMedia. AlertMedia
is a web application that pushes notifications to the appropriate stakeholders to inform of
ongoing actions and decisions. Throughout the event, continuous monitoring of the fire
ensures a coordinated and effective response to minimize risks, protect public safety, and
support restoration efforts as needed.
Page 59

Identification of a Near Encroachi Contact on Wildfire Confirm Fire Status With
Wildfire utilits ng on Intelligence Center First Responders
Lquipruen Yes Lqu,p en No
No Ye,
Consult Emergency Is I no I ire
ECC-
Continue to Monitor Energilzabon Table for Activation
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N. Yes
Is De- No To ECC
energizati Continue to Monitor Processes
on quired?
Yes
kuniecliatelV De energize m-ident Closed
Notify Management and
Stakeholders
Figure 5-5:Example Wildfire Operational Flow Diagram Overview
PUBLICLY AVAILABLE SITUATIONALAWARENESs DATA
The Company's weather stations and WRF model generate a considerable amount of data
each day. Rocky Mountain Power makes this data available to its employees, customers,
and public safety partners through a situational awareness website, (English I Spanish)
rockymountainpowerweather.com. The Company presents this data alongside weather
station observations and forecast data from trusted government sources, including the
National Weather Service, allowing the Company to compare real-time weather
observations with forecast data. Further, the wind climatology of each weather station is
considered, with real-time and forecast wind conditions color-coded based on station-
specific statistics like 95th and 99th percentile values. New data are automatically updated
on the website and can be viewed in maps and tables depicting the weather conditions at a
specific location over a period of time.
Figure 5-6 below includes sample material from the situational awareness website, which
will be launched before the 2026 heightened wildfire risk season. The website will highlight
the Company's approach, teams, and tools used to track wildfires. It will also feature
informational videos and links to Rocky Mountain Power's wildfire camera feeds and
weather station feeds.
Page 60

'4FIACFl00W StWMGeo WEATHER AWARENESS SYSTEM All StauOns Map
Filter by State ID Region ll Company All Service Area All Station type All
Station Region Wind Gust Direction Temp Humidity
Spencer ID-North of Pocatello 19 mph 27 mph NNW 28°F 62%
Gem valley Weather Station Stats
Kettle Butte HWY-20 Station Type: W Trans natlon Max Wind Gust:69.6 mph
Kettle Butte HWY-20 Service Territory.Rocky Mountain Power 99 Percentile Wind Gust:53 mph
Service Area:Northern UT11D Wires 95 Percentile Wind Gust:43.7 mph
Soda Spring East Region:ID-North of Pocatello Years Of Data:11.61
Lat:43.5544,Lon:-112.4183 Elevation:5112 h
Ririe Observations WRF EC NBM HRRR Ensemble Map
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- •WW F—cwn —Cl
a Grwts w.
Figure 5-6:Publicly A vailab le Situational Awareness Information from a Weather Station West of Idaho
Falls, ID
These data are also integrated into an internal dashboard used for situational awareness
during periods of elevated risk, for example during a PSPS. The dashboard is customizable
based on the scale of the event and includes station alert speeds and/or other decision
points. In 2024, the Company incorporated additional information into the internal
dashboard to support its situational awareness and implement improved website
functionality.
5.4 WILDFIRE RISK MODELS AND TOOLS
Rocky Mountain Power leverages a variety of models and tools to assess dynamic wildfire
risk. These tools are described in the subsections below. In 2025, PacifiCorp discontinued
the use of the MHDWI to adopt a more accurate method for assessing wildfire potential.The
Company implemented a similar internally developed historical analysis, delivering the
most reliable fire risk metrics across its Idaho service territory while incorporating historical
fire data from 1999 through 2020. This analysis, which provides thresholds for wildfire
mitigation strategies, is comprised of a fuel dryness metric, a measure of vegetation fuel
moisture, and a fire spread variable, or a metric to signify how a fire would spread under
certain conditions.
FIRERISK AND FIRESIM
As discussed in Section 1.2, the Company procured and implemented Wildfire Analyst
Enterprise (WFA-E), the broad suite of wildfire risk modeling tools from Technosylva.WFA-E
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includes two seasonal wildfire models, FireRisk (formally FireCast) and FireSim, which the
Company uses to forecast the risk of wildfire and the potential behavior of a wildfire, should
one occur.As described in Appendix B, the inputs for the various WFA-E models are similar.
They are, however, used for different purposes. FireRisk performs simulations daily to
assess wildfire risk more broadly, while FireSim is used to simulate growth and spread of
specific and unique fire events.
FireRisk: FireRisk performs millions of wildfire simulations daily across the Company's
service territory to provide a 126-hour look ahead that identifies the risk of wildfire (both of
ignition and impact) in particular locations. This output is then combined with overhead
distribution and transmission asset location data to provide location-specific wildfire risk
and consequence forecasts. It is important to note that the asset location data do not
determine the probability of a utility asset causing an ignition but, instead, are used to inform
operational decision-making.
FireRisk outputs include the following information:
• An assessment of the potential for a wildfire, given fuel, weather, and other
conditions.
• A simulation of how a wildfire would behave in the event of an ignition. This would
include, for example, the forecasted rate of spread, size, and flame length.
• Data on the population threatened and potential impact on assets(e.g., identification
of buildings that would be threatened in the event of a wildfire).
Figure 5-7 is an example of FireRisk output from July 2023. It shows the potential acreage
burned should an ignition occur near a circuit. The line graphs to the right depict variables
Like wind speed and fuel moisture for the forecast period. This information is then used to
inform operational practices like whether to de-energize proactively or, if time allows, take
measures to protect utility assets and communities that could be in the path of a wildfire.
This example does not make any assumptions about the effectiveness of the initial or
extended attack that may impact the forecast of acres burned.
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1• r,
AM.
ate-EZ, • ,,, i.
ilk
Figu, -7.Example of Fire Risk Output Near Spencer, ID,July 2023
FireSim: FireSim runs simulations that forecast potentiaIf ire behavior and spread from a 1-
to 126-hour period and assesses the potential impact on populations, buildings, utility
assets, and other resources in the field. FireSim's model assumes no suppression efforts to
slow the fire's spread and considers the following elements:
• Initial Attack Assessment.Assessment of how difficult initial attack could be for first
responders and the probability of stopping the fire within the first operating period.'
• Population at Risk. Projection of the number of people in the path of the fire and the
timing of when the fire is likely to arrive.
• Assets at Risk. Physical assets like utility equipment, residential and commercial
structures, barns, outbuildings, and other structures, and the timing of when the fire
is likely to arrive.
• Places at Risk. These are locations identified on the maps that may not be physical
assets but have other significance. These could include parks, reservoirs, cultural
sites, campgrounds, or other locations.
• Weather and Fuels Conditions.Wind speed, direction, fuel moisture content.
Figure 5-8 is an example of FireSim outputs from a simulated event near Spencer, Idaho, in
July 2023. The shaded area in the graphic shows the forecasted spread of the simulated fire
5 More information on initial attack assessment is available at https://help.wiLdfireanalyst.com/wfae/initial-attack-
assessment-iaa.Sourced Nov.10,2025.
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over a period of 12 hours. This time-based impact analysis illustrates various risk metrics
associated with a simulated ignition under the simulation's specified date and time weather
and fuel conditions.
r• -
o �
Figure 5-8:FireSim Output Near Spencer, ID,July2023
FIRE POTENTIAL INDEX
The Company uses the Technosylva Fire Potential Index (FPI) to accompany other wildfire
metrics for determining wildfire potential across Idaho. The FPI is a supplementary metric
that quantifies the potential for large or consequential wildfires based on weather, fuels,
and terrain.The FPI is used to guide operational decision-making as it relates to wildfire risk
and spread.
The following three inputs contribute to the final FPI score:
• A Complex Fuel Model that assesses the type of fuels and the time elapsed since the
Last fire to quantify how the fuels may affect fire behavior, type, and suppression
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difficulty. The model considers fire history, fuel growth, and fuel dryness over time in
response to weather conditions to support accurate wildfire modeling.
• Weather Conditions that consist of a combination of wind gusts, temperatures, and
fuel conditions. For wind-driven risk events in particular, the Company has identified
some geographically driven patterns that correlate to higher risk.
• Terrain Difficulty Index, which represents the level of geographical complexity to
access an area. For instance, regarding fuels and terrain-driven risk events, large
areas of contiguous complex fuel and terrain in areas of limited or difficult access
present the greatest risk when fuel is dry and weather is hot and dry.
The scores from these inputs are then correlated to a level of fire risk in Figure 5-9 below,
which shows the FPI scoring scale and percentiles. An FPI value or FPI percentile can then
be used to determine the FPI risk level. For instance, FPI values >37.5 or percentiles >99%
indicate that fire risk is extremely high. In contrast, an FPI value <5 or percentile <60%
indicates that fire risk is low.
FPI Category FPI Values FPI Percentiles
Moderate 10-13.5 OR 80-85
High 85-95
Figure 5-9:Fire Potential Index Scale
5.5 APPLICATION AND USE
The Company's meteorology team leverages the various analysis, model outputs, and
indices described above to produce a district-based, weather-related system impact
forecast.
ASSESSING DISTRICT FIRE RISK
Meteorology combines a variety of metrics to produce both a district- and polygon-level,
weather-related system impacts forecast which assigns a risk level at the circuit level and
guides operational decision-making. Additionally, when determining whether to raise the
fire potential risk level to elevated, significant, or extreme, meteorology also performs an
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additional review of fuels and fire weather forecasts and observations using some or all the
resources identified in Table 5-1 below.
Risk Assessment Resources Description
The BI is derived from a combination of Spread and
Energy Release Components expressed as a numeric
Burning Index(BI) value closely related to flame length in feet multiplied
by 10. It is a number related to the contribution of fire
behavior to the effort of containing fire.
ERC is a composite fuel moisture value that measures
the contributions all live and dead fuels have to
Energy Release Component(ERC) potential fire intensity.The ERC is a cumulative or
"build-up"type of index.As live fuels cure and dead
fuels dry,the ERC values get higher,thus providing a
good reflection of conditions.
EDDI identifies anomalous atmospheric evaporative
Evaporative Demand Drought Index(EDDI) demand and provides an early warning of increased
wildfire risk.
Fire Potential Index(FPI) FPI quantifies the potential for large or consequential
wildfires based on weather,fuels, and terrain.
Includes observations of the local fuel conditions
Fuels Conditions(live and dead fuels) including 1, 10, 100,and 1000-hour dead fuel moisture,
herbaceous and woody live fuel moisture,tree
mortality, Energy Release Component,etc.
Geographic Area Coordination Center(GACC) Includes Seven-Day Significant Wildfire Potential, Fuels
products &Fire Behavior Advisories,and other outlooks or
discussion products.
Rocky Mountain Power runs a 2-km WRF model,which
High Resolution Fire Weather Forecasts produces a twice daily territory-wide forecast of fire
weather conditions across a 96-hour time horizon.
Includes Fire Weather Watches, Red Flag Warnings,
National Weather Service Watches or Warnings High Wind Warnings,and other products issued by the
National Weather Service.
Publicly available index that uses two United States
Severe Fire Danger Index National Fire Danger Rating System indices that are
related to fire intensity and spread potential.
Vapor Pressure Deficit(1-month running A measure of the atmospheric demand (thirst)for water.
average)
Values above the 94th percentile have been associated
with large wildfires.
Millions of wildfire simulations are performed daily to
Wildfire Analyst Enterprise(WFA-E)model map out potential wildfire risk and consequence across
the service territory.
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These resources include tools such as wildfire consequence modeling and high-resolution
models to identify localized areas of greatest risk. Additionally, the meteorology team may
collaborate with the local National Weather Service office and/or the regional Geographic
Area Coordination Center (GACC) office if there is significant or extreme wildfire risk. After
evaluatingthese resources,the meteorologyteam determines the risk levelfor each district.
This analysis is then combined with the department's district-based fire risk forecast to
produce a complementary system impacts forecast used to support decision-making
related to implementing operational, short-term risk mitigation programs and measures,
discussed in Sections 6, 7, and 8. An example of a district-based fire risk forecast is shown
in Figure 5-10 below.A written weather summary accompanies the system impacts forecast
matrix to provide key details relevant for decision-making. Some of these factors include
timing, context on historical norms, wind gust values, or precipitation totals.
2/29(Thu) 3/1(Fri) 3/21se) 3/3(Sun) 3/41Mon)
777
w F CIRC COST Response W. F W. F W. F W. F
W W
—W W■
�, W■ W ■ ■
I
Lovell W■ W ■ ■
Dou41.abn D.XI s W WE W ■ W■ WEATHER RELATED OUTAGE POTENTIAL(Wx)
Ewans<an W 0 -0 -0
Evanston Mea x•mm•r•t W E w/s■ w/s�
Lanmi.aea Laramie W■ W ■ ■ OUTAGE POTENTIAL
w;III,., W■ W/s■ .0 Widespread Outages with Extended Restoration
pmwal•a•• pin•4.I• W■ -0 W/s0 Widespread Outages
Ra.Rnsaea aaan. W■ W ■ W■ Scattered Outages
L•ne•r W■ W ■ ■ Few to No Outages
Riwrton M•a
Riverton W■ W ■ .
Rock WtI,sN.. R.c15 1,1 I W■ W ■ -0 WEATHER-RELATED HAZARDS
Gr.vIIuII W W 0 0 _ Thunderstorms ��1
wm Av.. Tnermpaoli: W■ W ■ ■ /r• f (Lightning,Hail,Wind) l.J I I-Freezing Rain
W W 'Y'W and Ice
W- Wind
worl.na
RORrxulx ln�xnMOIGaIaxnRa S-Snow
l.ahopow•rw.. M.ha Pp W w F- Flooding
L.wa.. I.— W/s� w/s 0 s ■
Monep•li.r M•a1—L W/s■ W/S■ s ■ .
Monegli.r W/I w/s■ s ■ ■
05Eenarea 090.1 W■ -■ s ■ ■
M.I.a w/s■ W/s■ 5 ■ I
pretton a•a pre:can w/s■ w/s■ s ■ Extreme Wildfire Risk
Mae Lake w/sE s ■ Significant Wildfire Risk
a..earR a.a
a..w.R w/s■ s ■ ■ Elevated Wildfire Risk
sh.Il.va.. shII W/s■ s ■ 0 Low Wildfire Risk
smalmem ao smienR.I4 W■ w/s■ s ■ Non•Fire Season
Tremont..Nea Trempn W W/5 s
Figure 5-10:Example System Impacts Forecast
WILDFIRE FUEL AND TERRAIN POLYGONS
In 2025, the Company modified its short-term forecasting process by grouping areas of
similar terrain and vegetation height into polygons using a land cover data layer. Various
data sources, including internal pole pictures, satellite views of terrain and vegetation, and
the Multi-Resolution Land Characteristics (MRLC) Consortium data set, were used to
understand the terrain and vegetation for any one location.Subject matter experts reviewing
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the initial Land cover data set categorized vegetation as either "tall" or "short," based on
whether it was tall enough to potentially interfere with poles or Lines.Terrain was categorized
as either"steep" or"flat," based on whether it was steep enough for fire to spread rapidly in
the absence of wind. Following this methodology, the service territory was divided into the
following categories:
• Tall vegetation—steep terrain
• Tall vegetation—flat terrain
• Short vegetation—steep terrain
• Short vegetation—flat terrain
• Low risk
An example polygon map for Idaho is shown below in Figure 5-11.
m
r
Blue= Low Risk
0 Green = Short Vegetation & Flat Terrain
Yellow=Short Vegetation&Steep Terrain , ] w
Orange=Tall Vegetation& Flat Terrain
_ Red =Tall Vegetation&Steep Terrain
� 1..
;Nw� CMM�YA
M1r.r Frw
f
Jww
4V
l^J �
00
T
Figure 5-11:Fuel and Terrain Polygon Classification
These vegetation and terrain polygons are overlaid on all the Company's transmission and
distribution assets. This allows for a wildfire risk forecast, based on the condition of fuels in
the forecast period, at a circuit or portion of circuit level. This is an important maturity step
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as the previously highlighted system impacts matrix only represents the worst-case risk at a
district level. Districts traverse a wide variety of terrain and fuels and may experience
different weather conditions based on this variability. It would cause unnecessary issues for
customers if all circuits and their associated fuels and terrain were treated uniformly. This
approach to forecasting wildfire risk allows for decisions on how to operate the network at a
scale that is necessary for the risk without impacting customers outside the risk area with a
practice like ESS. Additionally, doingthis geospatially in conjunction with an asset database
has allowed for increased efficiency and timing of deploying ESS, and the ability to also
disable when risk subsides.
In summary, the Company's meteorology department leverages a considerable number of
resources to produce its forecast reports.These include internal and external data sources
and metrics, like the Company's WRF model, fuel dryness and fire spread metrics, the FPI,
and publicly available weather trends. The Company recognizes that under certain
conditions, wildfires can occur anywhere there is sufficient wildland vegetation that is dry
and flammable, even in historically low-risk areas. Therefore, the system impacts forecast
covers the Company's entire service territory. Typically, forecast reports are produced on
business days; however, during periods of extreme weather or wildfire risk, a forecast is
generated every day, including weekends and holidays. The forecast produced is integral to
informing internal stakeholders of necessary actions referenced in other parts of the Wildfire
Mitigation Plan.
5.6 WILDFIRE DETECTION CAMERA
Due to the situational awareness benefit of wildfire cameras that PacifiCorp installed and
maintains in Oregon, California, and Utah, PacifiCorp is evaluating camera installation
needs in Idaho during the 2026 year for installations in 2027 and 2028. Rocky Mountain
Power plans to seek input from various state agencies in determining final camera siting
Locations through communications with Idaho Department of Lands. Additionally, Rocky
Mountain Power will look for existing structures (e.g., on fire lookout towers and existing
communication structures)for camera station placement to improve efficiency.
Once the cameras are installed, the Company will work to provide access to fire agencies,
dispatch centers, and other public safety partners who may benefit from access to the
technology.Additionally,these users will have the abilityto receive alerts via email and SMS
when camera systems detect smoke to facilitate early detection and quicker response.The
Company anticipates collecting operational data and end user feedback over time to
evaluate the program for modifications or expansion. Moving forward, Rocky Mountain
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Power will continue to look for opportunities to partner with state agencies and promote the
availability of Company facilities available for camera installation.
SYSTEM OPERATIONS
Adjustments to power system operations can help mitigate wildfire risk. System operations
adjustments may include modifying relay settings for protective devices on distribution lines
or changes to line re-energization testing protocols. However, adjustments beneficial to
wildfire mitigation are not universally applied to power system operations, because there
are certain disadvantages in their use, primarily an increase in outage frequency and
duration experienced by customers. In other words, a balance is required to provide
customers with reliable power while still mitigating wildfire risk. To help balance these
concerns, the Company is deploying technologies such as fault indicators and assessing
outages to inform short-term mitigation practices, which are also discussed in the
subsections below. Rocky Mountain Power has a governing policy, PAC-1000 OperatingT&D
Assets During Periods of Elevated Wildfire Risk, and a number of system operating
procedures (SOPs)that support the operational work practices.
6.1 ENHANCED SAFETY SETTING:
Protective relay devices, such as circuit breakers and line reclosers, are currently deployed
on distribution lines throughout the Company's service territory.When a line trip opens due
to fault activity, reclosers can be programmed to momentarily open, allow the fault to
dissipate, and then reclose to assess whether the fault is temporary.The reclosing function
allows service to be restored on a line that has tripped while maintaining the option to open
again if the fault persists. If the fault is permanent, the recloser will operate and stay open
(known as the "lock out" state) until the line has been deemed ready for re-energization.
Figure 6-1 below depicts one potential configuration of a distribution circuit with protective
relay devices installed.
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Segmentation _
Options — -�
�\
AAdd
= Fault Location
Distribution
Substation
QRecloser
QCircuit Breaker
Figure 6-1:Example of Distribution Circuit with Protective Relay Device
In general, recloser operation is beneficial because it reduces the number of sustained
outages and improves customer reliability. The reclosing function, however, poses some
degree of ignition risk because additional energy can be released if a fault persists. When a
fault is detected on the line, a recloser will trip and reclose to re-energize the line, based on
predetermined settings. If the fault is temporary in nature and is no longer present upon the
reclose operation, the line will re-energize, resulting in limited impact to customers. If the
fault persists, however, reclosing can, depending on the circumstances, potentially result
in arcing or an emission of sparks. Accordingly, a strategic balance between customer
reliability and wildfire mitigation goals is required.
The Company has used reclosing disabling strategies on transmission lines for many years.
In recent years it has employed more frequent reclose disabling on transmission lines to
mitigate the increased wildfire risk. These strategies have had minimal impact on customer
reliability.
With the wildfire risk continuing to increase, the Company has implemented additional
strategies on the distribution network, including the use of modified protection and control
schemes, referred to as enhanced safety settings (ESS). Such applications on the
distribution network, however, can have a greater impact on customer reliability. The
Company is exploring different strategic combinations to find the right balance.
6.2 ENHANCED SAFETY SETTINGS (ESS) MODES
ESS modes of operation are intended to reduce fault clearing times and arc energy expended
during a fault event, to detect and respond to all faults on the system, and to maintain an
acceptable level of customer service reliability.The Company has many different intelligent
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electric devices in operation as protective relay devices on the distribution system. Each
device has a different set of functions and limitations that may be employed to reduce risk
during elevated wildfire risk conditions. At the same time, changes to the reclosing settings
of devices can have significant impacts on customer service reliability, which itself poses
safety concerns.
The primary method to reduce arc energy is to reduce fault interruption time, opening as
quickly as possible when a fault is detected. Enabling ESS with reduction in fault interruption
time is designed to also limit the operation of line fuses. Line fuses operate more slowly, and
the delay increases arc energy and ignitions risk. Limiting their operation is necessary but
has consequences to reliability and fault locating capability.
Settings are also designed to maintain coordination between the different zones of
protection, as necessary. This coordination is intended to interrupt the device directly
seeing the fault to minimize the number of customers impacted. Furthermore, total arc
energy expended during a system event can be reduced by limiting the number of times the
arc may be established. This can be accomplished by adopting a policy, PAC-1000, of
Limited reclosing while in an ESS mode. Recognizing the tradeoff in reliability when mitigating
wildfire risk, leveraging technology to improve fault locating and troubleshooting becomes
an important element of distribution system operations.
6.3 FAULT INDICATORS TO MITIGATE IMPACTS
The time it takes to patrol a line and the impact on customers can be significantly reduced
when a fault can be located. Therefore, as described in Section 4.5 and depicted in
Figure 6-2, the utility has installed fault indicators across its service territory on circuits
where ESS are more likely to be implemented, such as in the FHCA and surrounding areas.
When an outage occurs, regional operators and field personnel use these tools to narrow
down potential fault locations, optimize the deployment of resources, and expedite
restoration.
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Distribution
Substation
fo CFCI
CFCIT tl�
aRecloser
Circuit Breaker
CFCI Fault Indicator
Figure 6-2:General Fault Indicator Configuration
The Company will continue to implement ESS to reduce the wildfire risk associated with
prolonged fault events while being strategic in the ESS implementation to balance the
reliability impacts to customers. Rocky Mountain Power will also continue to assess the
need for and install additional fault indictors as described in Section 4.5.
6.4 RE-ENERGIZATION PRACTICES
In addition to enabling ESS as described above, the Company also modifies re-energization
practices based on risk assessments, balancing customer reliability and wildfire mitigation.
If a breaker or recloser has "locked out," meaning it has opened and no longer conducts
electricity, a system operator or field personnel will test a line if it meets criteria outlined in
PAC-1000 and SOP 203 Wildfire Encroachment.To test the line,the system operator or field
personnel will close the device, thereby allowing the line to be re-energized. If the fault has
Page 73

cleared,the system will run normally. If the fault is not cleared,the device will lock out again.
If the device locks out again, the system operator then knows that additional investigation
orwork will be required before the line can be successfully re-energized. Because faults are
often temporary, line-testing can be an efficient practice to maintain customer reliability,
similarto the use of reclosing described above.Atthe same time, line-testing can potentially
result in arcing or an emission of sparks if a fault has not yet cleared when the line is tested.
If criteria as outlined in PAC-1000 are met, the line can be tested without patrol. After a line
is successfully tested, a mainline patrol is required.
6.5 RELIABILITY IMPACTS OF ESS
Implementing ESS on the distribution network can impact customer reliability, as depicted
in Table 6-1, and Rocky Mountain Power is exploring different strategic combinations to find
the right balance. ESS settings, as discussed, leverage faster isolation schemes to reduce
the amount of energy that may be released during an energy release event, which can lead
to more frequent outages. Each outage correlated to a device with ESS settings enabled is
considered an event where risk was mitigated through refined settings because the settings
Limit the amount of energy released. This correlation, however, does not mean the settings
caused the outage. Outages can be caused by a variety of factors, including planned work
and/or environmental conditions. Based on meteorological conditions related to wildfire
risk, alternative ESS operating modes may be used for risk mitigation, which may lead to a
sustained interruption. For example, if wildfire risk increases, alternative ESS operating
modes may include reducingthe number of reclose attempts or locking open on a single trip
event, resulting in a temporary fault becoming a sustained outage.
To mitigate reliability impacts from ESS, the Company does not reduce the number of
reclose attempts or lock open on a single trip event seasonally. Instead, the Company uses
a daily risk assessment process and situational awareness reports. This allows for the use
of different ESS modes, while minimizing impacts on reliability.
In 2024, the Company initiated an annual evaluation of circuits placed into ESS and their
reliability impactto identify targeted short-term mitigation projects.The goal is to reduce the
total number of outages and outage duration experienced on these circuits. This evaluation
included a review of the number of outages, average outage duration,frequency of outages,
number of customers impacted, and average response time for outages to determine
circuits that had the worst reliability impacts. The evaluation also included an overall
summary of all circuits that were activated in ESS settings in 2024 and associated reliability
impacts. Rocky Mountain Power uses this data to determine where further segmentation is
needed on circuits thatwere impacted by ESS settings.Additional segmentation is achieved
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by upgrading and adding reclosing devices to isolate customers when ESS is triggered. By
adding additional segmentation points, outage durations will decrease because patrols can
be completed more quickly over the shorter distances.
Table 6-1:2025 Reliability Impacts for Circuits Activated in ESS Settings
Metric Number
Number of Outages 239
Average Duration of Outages(minutes) 143.22
Frequency of Outages per Circuit 4.35
Number of Customers Impacts 39,309
Average Response Time for Outages
48.66
(minutes)
6.6 ADDITIONAL PATROLS
When wildfire risk is elevated, a proactive, targeted patrol may be performed. These patrols
target obvious defective equipment and conditions that could lead to increased ignition risk.
Targeted patrols allow for expedited correction of any serious conditions.They also provide
valuable reports of the situation "on the ground" by subject matter expert field personnel.
Additionally, vegetation management may patrol lines, targeting conditions subject to
severe weather, especially hazardous trees.As hazardous vegetation is found, it is promptly
pruned or removed.
Overall, these additional, responsive patrols aim to enhance the Company's situational
awareness of on-the-ground conditions before a weather event and expedited corrections
of targeted equipment conditions and hazardous vegetation. These targeted patrols do not
replace standard programs (as described in Sections 2 and 3 above). Instead, they
supplement them.
b./ WILDFIRE ENCROACHMENT- EMERGENCY DE-ENERGIZATION
The Company has outlined requirements for emergency de-energization of transmission
Lines, distribution lines, and/or substation facilities based on approaching wildfires in
procedure SOP 203.This procedure outlines the actions to betaken byvarious departments
within the organization when a credible wildfire is within specified proximity of an identified
Company asset. Emergency de-energizations aim to minimize additional fire ignitions,
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create a safe environment for firefighting activities, and support the safety of potentially
impacted communities.
. FIELD OPERATIONS AND WORK PRACTICES
During fire season, the Company modifies wires operations and work practices to further
mitigate wildfire risk. Additionally, the Company invests in tools and equipment to mitigate
wildfire risk.
MODIFIED WORK PRACTICES
As a part of the situational awareness reports and briefings prepared by the meteorology
department, the operations department considers the local weather and geographic
conditions that may create an elevated risk of wildfire. These practices are targeted to
reduce the potential of direct or indirect causes of ignition during planned work activities,
fault response, and outage restoration.
Personnel working in the field during fire season mitigate wildfire risk through a variety of
tactics. Routine work, such as condition correction and outage response, poses some
degree of ignition risk, and, in certain circumstances, crews modifytheirwork practices and
equipment to decrease this risk. In the extremely unlikely event that a fire ignition occurs
while field crews or other Company personnel are working in the field (collectively "field
personnel"), such field personnel are equipped with basic tools to extinguish small fires.
arm y v?
I
Figure 7-1:Line Workers Performing Work
Some wildfire risk can be mitigated by managing the way field work is scheduled and
performed. To effectively manage work during fire season, area managers regularly review
Local. fire conditions and the weather forecasts provided to them as part of the situational
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awareness program, as discussed in Section 5 of this document. During fire season,
operations managers are encouraged to defer any nonessential work at locations with
dense and dry wildland vegetation, especially during periods of heightened fire weather
conditions. If essential work needs to be performed in areas with appreciable wildfire risk,
certain restrictions may apply, including:
• Hot Work Restrictions. Evaluating whether field personnel should perform work
during a planned interruption, rather than while a line is energized.
• Time of Day Restrictions. Considering using alternate working hours to
accommodate evening and night work when there may be less risk of ignition.
• Wind Restrictions. Re-evaluating whether work may be deferred when windy
conditions at a particular work site are observed.
• Driving Restrictions. Keeping vehicles on designated roads whenever operationally
feasible.
• Worksite Preparation. Removing wildland vegetation that poses an ignition risk from
a worksite if the work to be performed involves the potential emission of sparks from
electrical equipment and only where it is allowed in accordance with land
management/agency permit requirements. In addition to clearing work, water truck
resources, discussed below, are strategically assigned to accompany field personnel
working in wildland areas during fire season. Depending on local conditions, dry
vegetation in the immediate vicinity may be sprayed with water before conducting
work as a preventive measure.
As noted above, whether to implement these restrictions is evaluated based on the daily
reports and briefings provided by the meteorology department. As the Company is
continuously improving and evolving its plan and programs, the process below is subject to
change and is managed by internal Company policies and procedures.
In general,whenever wildfire risk potential is minimalto none,work may be conducted using
normal operating practices. However, when the meteorology department forecasts
elevated, significant, or extreme wildfire risk conditions, local operations may modify
operating practices. For example, the personal protective equipment and basic firefighting
tools described in the basic personal suppression equipment section below are required for
any field work conducted during periods of elevated fire risk. Local area management will
also evaluate, after considering multiple factors regarding the local circumstances of a
particular circuit, whether any hot work modifications should be made. If wildfire risk is
significant or extreme, local area management will also consider whether any additional
Page 77

work is appropriate. Section 5 provides an in-depth discussion of how the meteorology
department forecasts impact field operations and work practices.
The Company also follows local United States Forest Service work practice requirements,
as outlined in their Industrial Fire Precaution Levels.6These are issued as forest orders and
change depending on the time of year and the forest.
ADDITIONAL RESOURCES
To implement some of the wildfire mitigation programs generally described above,
additional labor resources and field personnel time are often required to (a) support system
operations in assessing localized risk and administering ESS and (b) respond to outages
during heightened fire risk season with additional patrols and coordination.
Under normal operations system operators and field personnel work together daily to
manage the electrical network. In many situations, system operators depend on field
personnel to gather information and assess local conditions.There are a number of system
operations procedures duringwildfire season for implementing ESS and limiting line-testing.
Consequently, system operators need field personnel to gather information and assess
Local conditions during heightened fire risk season more frequently than would otherwise be
required under normal operating procedures.The requests from system operators mayvary,
ranging from a simple phone call to confirm that it is raining in a particular area, to a much
more time-intensive request, such as a full-line patrol on a circuit.
Field personnel may also spend additional time responding to an outage during heightened
fire risk season. Heightened risk exists with traditional restoration practices.To mitigate this
risk,wires operations may perform some line patrols on certain de-energized sections of the
circuit, notably during heightened fire risk season and particularly in the FHCA dependent
on current conditions at the work site and the duration of the restoration work. Depending
on the circumstances, this extra patrol might be done just before or just after re-energizing
the line. Typically, this type of line patrol does not involve a close inspection of a facility;
instead, it is a visual assessment specificallytargeted to identify obvious foreign objects that
may have fallen into the line during restoration work.
ACTIVE WILDFIRE RESPONSE
The Company monitors and may support the response to active wildfires in or near assets
and service territory.While employees may carry small fire suppression equipment,they are
not professionally trained firefighters; therefore, when they encounter a fire of any
appreciable magnitude, they are instructed to call 911. For known active wildfires, the
'United States Forest Service.Industrial Fire Precaution Levels.Sourced Nov.10,2025.
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Company will monitor the situation and may contact the appropriate incident management
team to support efforts needed, which can include de-energization of lines.
FIELD OPERATIONS CIRCUIT STRENGTHENING
As a result of modified work practices, additional patrols performed, and experiences from
times of elevated risk, circuits may be identified on a case-by-case basis for system
strengthening upgrades. System strengthening initiatives include but are not limited to the
strengthening programs identified in Section 4, such as relay or recloser upgrades,
replacement of wooden poles, installation of fault indicators, or replacement of fuses.
EQUIPMENT AND TOOL PURCHASES
In addition to changes in work practices, the Company invests in tools and equipment to
mitigate wildfire risk. These investments include (1) mobile communication devices, (2)
vehicles, (3) personal suppression equipment, and (4)water trucks or trailers.
MOBILE COMMUNICATION DEVICES
The Company serves customers in very rural locations, some of which have limited to no
cellular connectivity to the local district office and/or the control center. During large
disasters, such as wildfire events, field personnel should be able to communicate quickly
and effectively to maintain safe operation of the system and support emergency response
and restoration activities. Therefore, in 2022 the Company procured a compact rapid
deployable cell tower, also known as Cell-On-Wheels (COW). This equipment, shown in
Figure 7-2, generates an area of FirstNet cellular and Wi-Fi coverage, to improve
communication when cell coverage is unavailable.
r e.
7
Figure 7-2:Rapidly Deployable Cell-on-Wheels(COW)
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In addition to the COW device, the Company employs other emergency communication
alternatives, such as Starlink devices, to help mitigate wildfire risk in locations where there
is no cellular coverage. The Starlink devices provide a Wi-Fi hot spot connection to allow
communication with the local district office and the control center. Overall, the
communication equipment should improve emergency restoration activities and mitigate
impacts on customers. Because these devices are deemed useful to other programs within
the Company, the purchase of these devices will be incorporated into normal operational
spending in 2026 and beyond.
These devices are strategically staged at service centers throughout Idaho for use during a
major event, such as a wildfire emergency, to improve communication capabilities into the
control center, base camp, and/or management. This equipment also enables
communication when it is lost due to infrastructure failure for SCADA access, WAN, and
portable radios.
VEHICLES
Vehicles can be a source of ignition. As discussed above, operations personnel are
instructed to stay on designated roads during fire season, as feasible, and to avoid
vegetation that could contact the undercarriage of parked vehicle. To further mitigate any
wildfire risk associated with the use of vehicles, the Company plans to convert, over time,
the vehicle exhaust configuration of work trucks. Long term, when new vehicles are
purchased,the Company plans to purchase trucks with a vehicle exhaust configuration that
minimizes ignition risk.
BASIC PERSONAL SUPPRESSION EQUIPMENT
Personal safety is the Company's priority, and field personnel are encouraged to evacuate
and call 911 if necessary. Field personnel working in fire risk areas maintain the capability
to extinguish a small fire that may ignite while working in the field. Field personnel should
attempt suppression only if the fire is small enough so that one person can effectively
suppress the fire while maintaining their personal safety. All field personnel working in the
FHCA during heightened fire risk season have basic suppression equipment available
onsite, because field utility trucks typically carry the following equipment: (1) fire
extinguisher, (2) shovel, (3) Pulaski, (4) water container, and (5) dust mask. The water
container should hold at least five gallons and may be a pressurized container or a backpack
with a manual pump (or other).
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WATER TRAILER RESOURCES
Rocky Mountain Power has water trucks or trailers that field operations use to mitigate
against wildfire risk. These resources are not dispatched to reported fires. Instead,
resources are strategically assigned to accompanyfield personnel if conditions warrant. For
example, if it is necessary to perform work during a period in which there is a Red Flag
Warning, field operations may schedule a water trailer to join field personnel working in the
field. As discussed above, the water trailer can be used to help prep the site for work. By
watering down dry vegetation in the work area, the chance of an ignition can be minimized.
In the unlikely event that there was an ignition,the water trailer could be used to assist in the
suppression of a smallfire.
If a fire is reported near Company equipment, Rocky Mountain Power will follow the active
wildfire response process described above.
As discussed above,the Company can mitigate some wildfire risk by managingthe wayfield
work is scheduled and performed. To effectively manage work during fire season, area
managers regularly review local fire conditions and weather forecasts provided to them as
part of the Company's monitoring program. As the Company is continuously improving and
evolving its plan and programs, the process below is subject to change and is managed by
internal Company policies and procedures as well as jurisdictional regulations as described
above.
The activities of operations, with respect to a particular category of wildfire risk potential,
are summarized in Table 7-1. For instance, when a circuit is identified as having extreme
wildfire risk or above (RED in Table 7-1), local area management will cancel planned hot
work instead of considering alternatives as part of a hot work evaluation.
Table 7-1:T&D Operations Based on Fire Risk Potential
PotentialFire Risk
Practice
Yellow
PPE Equipment and
Tools
Daily Hot Work
Evaluation
Additional Work
Evaluation
Cancel Hot Work
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WILDFIRE TRAINING
Wildfire mitigation programs include installing modern technologies such as covered
conductor, advanced detection devices, and weather stations, all of which require training
for proper installation and maintenance work.To accommodate this additional training, the
Company built a comprehensive wildfire transmission and distribution training center in
2020.The training center has space to test equipment and conduct analyses and includes a
pole yard, a vital component of operations where personnel can get firsthand training and
practice installing equipment such as covered conductor before going out to the field.
WILDFIRE TRAINING MATERIAL
To prepare crews for ever-changing wildfire conditions, the Company is developing training
materials that will include eBooks and mobile applications available for internal employees.
The goal in developing the training materials is to prepare and train crews before an event
happens to decrease response time and aid in response effectiveness. Training topics
include wildfire protection overview, roles and responsibilities, and PSPS. The application
will also include interactive scenarios for crews to walk through to help inform and guide
actions should an incident occur.
PUBLIC SAFETY POWER SHUTOFF (PSPS) PROGRAM
Rocky Mountain Power may temporarily de-energize power lines during periods of the
greatest wildfire risk to reduce the risk of ignition, limit wildfire spread, and protect first
responders and critical infrastructure during wildfire emergencies. Using de-energization
methods, the Company is able to mitigate wildfire risk, protect communities, and reduce
wildfire losses without the extraordinary increase in spending that would accompany a full
system rebuild.
One such de-energization practice is known as a public safety power shutoff (PSPS). The
decision to implement a PSPS is based on extreme weather and area conditions, including
high wind speeds, low humidity, and critically dry fuels.The Company may also de-energize
power lines in response to an active wildfire that is within a defined distance of the lines
(described in Section 8.4 below). A PSPS event is implemented as a last resort and is
intended to supplement, not replace, existing wildfire mitigation strategies. The general
process is depicted below in Table 8-1.
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Communication 2:ze0
Frecasted
Protocols Risk
.� Reduction
i ECC 4 r h Begin
PSPS Director Restorationr L Restoration
Watch Approves Continuously Restoration Monitor
Monitor Monitor C�{ 'e Conditions
Conditions 01 4��;`r1 through
through Situational
Situational UI preparation \� •- Restoration Awareness
ne
Awaress
Figure 8-1:PSPS Overview
The following subsections describe Rocky Mountain Power's PSPS program in greater detail.
Many of the program elements focus on the successful execution of a PSPS event, while
other elements bolster decision-making, mitigate the potential impact of a PSPS event, or
help to avoid implementing a PSPS altogether.
8.1 INITIATION
As discussed in Section 5, the meteorology department generates situational awareness
reports daily on business days to aid in decision-making during periods of elevated risk.
During periods of extreme risk, such as during PSPS assessment and activation, these daily
reports are also generated on weekends.They identifywhere fuels(dead and live vegetation)
are critically dry, where and when critical fire weather conditions are expected (gustywinds
and low humidity), and where and when the weather is forecast to negatively impact system
performance and reliability. It is the intersection of these triggers that results in the potential
for a PSPS event, as shown below in Figure 8-2.
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Fuel Assessment
1 4 6A4, 01
Increasing
Dryness
PSPS
Negative Fire
System Weather I
Impact Conditions
Figure 8-2:PSPS Assessment Methodology
8.2 ASSESSING THE POTENTIAL FOR A PSPS
As discussed in Section 5, meteorology generates a daily weather briefing that includes a
system impact forecast matrix for Rocky Mountain Power's entire service territory. This
matrix includes a district-level forecast of weather-related outage potential and fire risk.
When the district fire risk is significant or extreme, meteorology will use a combination of its
WRF and outage models, Technosylva's WFA-E software, and subject matter expertise (as
described in Section 5.3) to identify circuits of concern. Emergency management will also
schedule a coordination meeting to discuss circuits of concern and to determine the
appropriate operational response, up to and including PSPS. A PSPS is typically discussed
and/or considered when the forecast matrix indicates a combination of wind-related outage
potential and extreme wildfire risk in the same district.
8.3 DE-ENERGIZATION WATCH PROTOCOL
Rocky Mountain Power actively monitors real-time weather conditions. When real-time
observations and weather forecasts indicate extreme risk, a de-energization watch protocol
is initiated that includes
• activation of an emergency coordination center(ECC),
• communication with local public safety partners, and
• implementation of additional monitoring activities.
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The ECC is staffed by a specialty group of Company representatives who assemble during
the de- energization warning until the event is complete to provide critical support to
operational resources.The ECC makes decisions to maintain the safety and reliability of the
transmission and distribution system and helps facilitate cross-organization coordination.
The ECC is led by an ECC executive and has the support of a safety officer, a joint information
team, emergency management, meteorology, and operational stakeholders representing
field operations, system operations, vegetation management, engineering, and other
specialties.
Upon activation of the ECC, Rocky Mountain Power emergency management gathers input
from public safety partners to properly characterize and consider impacts to local
communities. The ECC also sends advance notifications to the operators of pre-identified
critical facilities, partner utilities, and adjacent local public safety partners. The Company's
customer service team then coordinates through the ECC to confirm customer lists for the
subject area to develop a communication plan for customers who may be impacted.
Local assessments of lines may occur during a PSPS watch by way of various methods
depending on the accessibility of locations, the reliability of the line, area conditions, and
other factors. The ECC reviews various factors and may deploy crews to perform these
assessments in the field or remotely monitor from the ECC.
PSPS is a temporary mitigation measure. Consistent with existing regulations and the
general mandate to operate the electrical system safely, the ECC has discretion to
determine when (or if) a PSPS is appropriate. Given the potential impacts to customers and
communities, the ECC executive will consider all available information, including real-time
feedback and other considerations from other ECC participants, public safety partners, and
field observers, to determine whether a PSPS should be executed. Additionally, the ECC
executive may decide to further refine the PSPS areas identified.
8.4 DE-ENERGIZATION PROTOCOL
When a PSPS event is initiated, an action plan is prepared to include affected location
details, event timing, and projected event duration. Once approved by the ECC executive,
an internal notification is sent to initiate appropriate communications to customers, critical
facilities, public safety partners, regulatory organizations, large industrial customers, and
required field and system operations team members. The Company procedure, per the
PSPS Execution Playbook included as part of Appendix C, is to notifythe ESF-12 Coordinator
within the PUC via the [e-mail] email address. Preparations also begin
for the opening of community resource centers (CRCs), and, if needed, additional field
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resources may be deployed or staged accordingly. Conditions are continually monitored;
when they no longer meet the requirement for a PSPS, the lines are patrolled and assessed
for damage to begin the process of re-energization.
8.5 ACTIVE WILDFIRE DE-ENERGIZATION
Wildfires can spread rapidly and behave unpredictably. Rocky Mountain Power will
sometimes de-energize power lines when there is an active wildfire threateningthe lines, as
described in SOP 203 —Wildfire Encroachment. For example, fire suppression authorities
may request de-energization of lines to protect firefighters working in the area; Rocky
Mountain Power endeavors to accommodate those requests. Additionally, Rocky Mountain
Power may initiate a de-energization after receiving information about advancing wildfire,to
reduce the risk of energized electrical equipment contributing to fire spread or endangering
fire suppression personnel. Consistent with SOP 203, Rocky Mountain Power will de-
energize power lines when a wildfire is within defined distance of the lines, with a sufficient
buffer to guard against the potential spread, as described in SOP 203. To help evaluate a
fire's location and probable spread, Rocky Mountain Power uses fire modelling software and
other situational awareness tools described in Section 5.
8.6 COMMUNICATION PROTOCOL
Rocky Mountain Power recognizes that adequate and clear communication is a key
component to the successful implementation of a PSPS event, and the Company strives to
provide as much notice as practical to impacted parties. Nonetheless, PSPS decisions are
made based on weather forecasts, and weather can change quickly or dramatically with
Little forewarning. This requires balancing communication protocols, and, accordingly,
advanced notice may not always be possible.
PUBLIC SAFETY PARTNERS AND CRITICAL FACILITIES
Public safety partners, such as emergency dispatch centers; state, regional, and local
emergency management; fire agencies; and law enforcement agencies, are an essential
component to any communication plan during an event. They provide essential insight into
the geographic and cultural demographics of affected areas to advise on protocols that
address limited broadband access, languages, medical needs, and vision or hearing
impairment. Rocky Mountain Power's initial communication with local public safety
agencies starts as early as possible when weather forecasts indicate a PSPS event may be
warranted. Proactive communication to public safety partners helps them to prepare for
anticipated operational impacts internally and mitigate any community-wide impacts that
may occur because of de-energization. Collaboration with these agencies also supports
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impact reduction of de-energization and communication of information regarding the
impacted areas and expected event duration.
Rocky Mountain Power recognizes the importance of providing additional geographic details
of affected areas during a PSPS event. The Public Safety Partner (PSP) Portal, described
below in Section 0, was launched in 2024 to facilitate the communication of critical
information through a secured, web-based mapping application. Throughout a PSPS event,
Rocky Mountain Power's emergency management group uses the portal to maintain regular
communication with the Company's public safety partners and other entities as applicable.
The Company will also support efforts to send out emergency alerts and status updates, as
appropriate, until restoration efforts begin.
Critical facilities and infrastructure? are particularly vulnerable to the impact of PSPS
events. Rocky Mountain Power emergency management maintains a list of critical facilities
within its service territory. Upon activation of an ECC, the emergency management team
works to establish and maintain direct contact with these facilities' emergency points of
contact to provide projected PSPS timing, estimated duration, regular status updates, and
restoration notifications. Additionally, Rocky Mountain Power will provide, where possible,
GIS shapefiles to communications facility operators in potentially impacted areas.
Because the electric system is highly interconnected, some facilities are jointly owned or
operated with other utilities, and certain Company assets connect to facilities owned and
operated by other utilities (substations).Any operational adjustments associated with joint-
owned,joint-operated, or interconnected facilities are coordinated and communicated with
all owners/operators.
CUSTOMERS
The Rocky Mountain Power PSPS website8 provides timely and detailed information
regarding potential and actual PSPS events for a specific location. The website has the
bandwidth to manage site traffic under extreme demand.The PSPS website provides visitors
with an interactive map where they can input an address to see if a residence or business
could be affected by a PSPS. When a potential PSPS is announced, the map is updated to
show the geographic boundaries of potentially impacted areas.The boundaries are colored
yellow for "Watch" prior to de-energization, red for "Active" once de-energization occurs,
and green for"Restored" once power has been restored.The website is easily accessible by
Critical facilities and infrastructure are entities that are essential to the public safety and/or that require additional
assistance and advance planningto ensure resiliency during de-energization events.These include,but are not limited
to,medical,public,and private utility,drinking water or wastewater processing,transportation,chemical processing,
food/agriculture,and/or communications facilities.
$See https://www.pacificpower.net/pssps.
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mobile device, and a Rocky Mountain Power mobile app is available that provides
customers with real-time outage updates and information.
Customers with specific language needs can also contact the Company's customer care
number and request to speak with an agent in their preferred language. Rocky Mountain
Power employs Spanish-speaking customer care professionals and contracts with a 24/7
service that provides interpretation in real-time over the phone in multiple languages and
dialects. Customer care agents have received training in wildfire safety and preparedness
and PSPS-related information to facilitate conversations between the customers to ensure
they receive the information they are seeking. Additional information on the Company's
customer wildfire safety and preparedness engagement strategy can be found in Section 9
of this document.
The 2025 Public Safety Power Shutoff Execution Playbook also includes process for
additional notifications to customers who have self-identified as having medical or other
access and functional needs (AFN). Upon activation of the ECC, customer care agents will
attempt — time and circumstances allowing — to make personal outbound calls to known
AFN customers. Customer care agents track if a positive confirmation of contact was made
with medical and other AFN customers. The results of the contact are reported to the ECC
executive. If an AFN customer needs additional assistance, the ECC quickly relays the
information to local public safety partners. Such coordination may lead to a wellness check.
The communication plan allows for informational updates to customers using multiple
methods of communication. Direct customer notifications are made by way of outbound
calls, text messaging, and email notifications. Customers will receive an outbound call,
when possible, according to the PSPS notification timeline defined in Table 8-1.
Additional methods of notification include the use of social media sites like Facebook and X
(formerly Twitter). Upon activation of the ECC, and following appropriate customer
notifications, the public information officer will distribute press releases to news outlets
that serve the affected areas. Regular updates across all available channels are distributed
as they are available, and the public information officer will manage press inquiries as
appropriate.
In making the customer notifications described above, Rocky Mountain Power provides a
statement with
• the impending PSPS execution, with information about the estimated date, time, and
duration of the event;
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• a 24-hour means of contact for customer inquiries and links to pertinent PSPS
websites; and
• event status updates and re-energization expectation notices.
NOTIFICATION TIMING
When a potential PSPS event is forecast, if possible, customers and local government
representatives will be provided with advance notice. If feasible, notifications of a potential
de-energization event will begin 72 hours in advance for public safety partners and 48 hours
in advance for customers. If this is not possible due to rapidly changing weather conditions
or other emerging circumstances, the notification process will begin as soon as possible.
Additional notice will be provided as appropriate, as conditions are monitored and
depending on the circumstances. There is some degree of balance required. Customers
generally want ample advance notice of any actual de-energization. At the same time,
recognizing that weather forecasts are inherently speculative, it is possible to overburden
them with notices of potential PSPS events that never materialize, especially given that the
Company's fundamental business objective is to keep the grid energized except under the
most extreme conditions. Table 8-1 illustrates Rocky Mountain Power's planned PSPS
notification timeline for notifications sent to customers. Notifications to public safety
partners and critical facilities willtake place as appropriate throughout the event.Timelines
may be reduced if rapidly changing conditions do not allowfor advance notification. In these
cases, the Company will make all notifications as promptly as possible.
Table 8-1: PSPS Notification Timeline for Customers
Timeline Summary
48-72 Hours Prior De-energization Warning to Public Safety Partners
&Operators of Critical Facilities
24-48 Hours Prior De-energization Warning
1-4 Hours Prior De-energization Imminent/Begins
Re-energization Begins Re-energization Begins
Re-energization Completed Re-energization Completed
Cancellation of Event De-energization Event Canceled (if needed)
Status Updates Every 24 hours during event(if needed)
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8.7 COMMUNITY RESOURCE CENTERS
Rocky Mountain Power is aware of the potential impacts of PSPS events to all customers,
businesses, and communities and plans to provide support to impacted communities
through activation of community resource centers (CRCs)as appropriate. See Figure 8-3 for
an example. By taking advantage of established relationships with community and public
safety partners, a CRC may be activated in an impacted area to give community members
and businesses access to items that may be affected by interruption of electrical service.
The services, which can vary between CRCs, may include:
• Parking signage and traffic safety equipment
• Potable water and non-perishable snacks
• Accessible shelter from hazardous environment
• Heating and cooling capabilities
• Seating and tables
• Restroom facilities
• Refrigeration and heating for medicine and/or baby needs
• Interior and area lighting
• On-site security
• Communications including internet, Wi-Fi, cellular access, and satellite phone
• Television
• Ice
• On-site medical support(EMT-A at a minimum, Paramedic preferred))
• Charging stations for medical devices, cellular devices, radios, and computers
• Small crates for pets
• AFN/LEP population support
• Personal protective equipment
• Portable ADA ramp
CRCs adhere to all existing local, county, state, orfederal public health orders and will have
personal protective equipment on-site and available to customers if needed. Known local
emergency management and community-based organizations will be notified of CRC
activations as appropriate and with advance notice, generally three days prior to the event,
when possible.
CRC activation timing, protocols, and locations are discussed with area emergency
management and community-based organizations during emergency management
workshops and tabletop exercises.
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Depending on the needs of the Company's public safety partners, CRC locations may be
pre-identified. However, this is not always the case. For instance, in 2023 Rocky Mountain
Power,together with its partners, determined that the need for and location of a CRC should
be dependent on the PSPS area and community needs. As a result, it was decided that a
CRC, if needed, should be activated in close coordination with public safety partners during
a PSPS event. Rocky Mountain Power intends to continue collaborating with public safety
partners to evaluate its approach to CRC activation and adapt its practices accordingly.
1COME WA
Figure 8-3:Example of Temporary CRC
8.8 RE-ENERGIZATION
As described above, local conditions are continually monitored during a PSPS event. Based
on forecasted risk reduction, Rocky Mountain Power may begin staging resources to
expedite restoration. Then, when local conditions subside, consistent with the forecasted
reduction in risk, restoration activities may officially begin. The general steps of restoration
are depicted in Figure 8-4.
Monitor Assess Repair Re-Energize
Figure 8-4:General Re-Energization Process
Once the local and forecasted conditions are favorable to re-energize and no new risks have
been identified, field personnel begin assessing the de-energized circuits through ground or
air patrols. Power lines that have been de-energized during a PSPS event have been exposed
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to strong winds and the potential for damage. In addition, even after the wind has dropped
to levels low enough to support a decision to re-energize, fire weather conditions typically
remain elevated. Therefore, before re-energizing a line post-event, assessments are
completed to determine whether any damage has occurred to the line and/or substation
that needs to be corrected prior to re-energization (e.g., line down, broken crossarms, tree
through line, tree branches or other items blown into the line). Field personnel report any
damage identified to Rocky Mountain Power's facilities to the ECC where it is tracked. If
issues are discovered,the necessary repairs are made within an appropriate corrective time
period.
While all lines and facilities (e.g., substations) that were de-energized as part of a PSPS
event are assessed, a step restoration process is leveraged where possible so that power to
customers may be restored as the assessments progress, instead of waiting for the
assessment of the entire impacted area to complete.While not to scale or representative of
an actual event, this concept is visually depicted in Figure 8-5 below.
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Single Restoration
a�
0
y
QN�
L.L
N
L
Q�
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O
"n
N
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-0 Step Restoration
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E
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U
0
Repair » Re-Energize
® � Repair » Re-Energize
® 10 Repair » Re-Energize
® � Repair » Re-Energize
® 0 Repair y Re-Energize
Figure 8-5: Visual Depiction of Step Restoration
Wherever possible, Rocky Mountain Power also works with emergency and public safety
partners to identify critical customers for prioritization. After the line patrol and facility
inspection is completed, the impacted circuits or portions of circuits are re-energized, and
the date and time of re-energization is logged. Once service is restored to all customers
impacted by the PSPS event, the event concludes.
9. EMERGENCY PREPAREDNESS, COMMUNITY OUTREACH, AND
COLLABORATION
9.1 PUBLIC SAFETY PARTNER COORDINATION STRATEGY
Rocky Mountain Power takes a multi-step approach to coordination with its public safety
partners on wildfire mitigation and PSPS preparedness, as shown in the Figure 9-1 below.
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validateExamine or
Iry Functional coordination,
CommunityExercise(FE) control between various
Center(CRC)
C" on services"Demonstration PSPS
provided
�! Builds upon outreach to
Workshops develop plans and/or
procedures
Informal discussion
Outreach designed to orient
participants to a new
concept or procedure
Figure 9-1:Public Safety Partner Preparedness Strategy
As a part of this strategy, each element builds upon the previous step to increase overall
preparedness. These steps — outreach, workshops, tabletop exercises, CRC
demonstrations, and functional exercises — are described in more detail in the following
subsections.
GENERAL OUTREACH
Rocky Mountain Power actively engages with federal, state, tribal, and local government
agencies through tabletop exercises, workshops, and coordinated planning efforts. The
Company has developed a public safety partner tool, described below,tofacilitate real-time
information sharing and enhance emergency response coordination with these groups.
These outreach and coordination efforts are critical to ensuring community safety and are
considered cost-effective components of the overall mitigation strategy.
Rocky Mountain Power participates in multiple public safety partner meetings and
workshops throughout the calendar year across its service territory. Meetings include
monthly, quarterly, and annual county and state emergency management partner meetings,
in addition to pre-and post-fire season collaboration meetings with local, state, and federal
fire suppression agencies.These informal discussions are designed to orient participants to
a new concept or procedure and continue fostering key working relationships. Participants
at these events vary, and invitations may be extended to but not limited to public safety
partners (local, county, state), public health organizations and hospitals, regional
communications/internet providers, community-based organizations, neighboring utilities,
and community stakeholders. Additionally, Rocky Mountain Power provides an annual
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customer wildfire webinar, described at greater length in Section 9.3, that provides
additional information about PSPS practices, displayed prominently on the wildfire safety
and preparedness website.
In 2025, the Company hosted its annual Idaho Wildfire Webinar and a Wildfire Community
educational event in Rexburg. These events were advertised in a variety of ways including
customer messaging, social media, and on the Companywebsite.These events are open to
the public to increase public awareness of the Company's wildfire mitigation efforts.
WORKSHOPS
Workshops are more local,targeted discussions that build upon general outreach to further
compare and refine plans, streamline processes, and confirm capabilities (such as
customer outreach, critical facilities, and CRC locations and operations) with local public
safety partners.
TABLETOP EXERCISES
Rocky Mountain Power facilitates discussion-based and functional tabletop exercises to
develop awareness of PSPS planning and procedures as it deems appropriate. These
exercises aim to facilitate public and private-sector coordination,validate communications
protocols, and verify capability to support communities during extreme risk events through
mitigation actions such as the deployment of CRCs. Additionally, the exercises include the
collective identification of critical infrastructure at the county level to better inform
restoration planning and notifications. Rocky Mountain Power collects after-action reports
from exercises and real-world events involving wildfire safety and PSPS. The after-action
reports request feedback on areas for improvement, potential corrective actions, and
suggestions for plan or procedure development. The Company considers suggestions for
inclusion in a comprehensive plan that it subsequently shares with the appropriate public
safety partners.
COMMUNITY RESOURCE CENTER DEMONSTRATIONS
Rocky Mountain Power may provide a public demonstration of a CRC prior to the start of
wildfire season.This public event provides an opportunityfor members of the public, as well
as public safety partners, to learn about the type of services offered at a CRC during a PSPS
event.
FUNCTIONAL EXERCISES
Functional exercises are the last step in PSPS preparedness. Rocky Mountain Power
coordinates these exercises to examine or validate coordination, command, and control
between various agencies. Unlike tabletop exercises or workshops, which are discussion-
Page 95

based, functional exercises are larger-scale, last much longer (e.g., multiple days), require
significantly more planning and coordination, and include deployment of resources to
practice protocols and processes. A functional exercise requires that part of the plan be
executed, such as performing customer calls or updating websites during a PSPS event. For
functional exercises to be successful, foundational planning such as workshops and
tabletop exercises must be complete, and formal plans must be in place. Currently, Rocky
Mountain Power is not planning to conduct a functional exercise in Idaho. The Company
does expect to leverage its experience conducting functional exercises in other states with
more mature PSPS programs and incorporate functional exercises in Idaho in the future as
needed.
In addition to executing planned activities, Rocky Mountain Power may also participate in
various other workshops, conferences, and discussions, or it may host other activities to
ensure coordination and preparedness with public safety partners, state agencies, and
other utilities. Rocky Mountain Power will identify general locations and then work with
public safety partners to select the most appropriate location and dates for these activities.
The annual activity plan is subject to change depending on public safety partner input and
availability.
9.2 =MERGENCY PREPAREDNESS AND EXERCISE PLAN
In 2026 and beyond, the Company will build upon previous years' experience to engage and
coordinate with public safety partners. Based on the Company's experience to date,
planning, in collaboration with public safety partners, is most effective when completed
closer to the start of fire season.
PUBLIC SAFETY PARTNER PORTAL
The Company recognizes the importance of providing additional geographical details of
areas that may be affected by a PSPS event. In 2024, the Company implemented the Public
Safety Partner (PSP) Portal. The portal is a secure web-based application that hosts key
information for customers whose facilities or infrastructure has been identified as critical.
This information includes, for example, the location, primary/secondary contact
information, and backup generation capabilities of critical customers. Public safety
partners can access the portal during PSPS events to receive live, real-time PSPS updates
and request support for critical facilities that may be impacted by an outage. In addition to
enhancing coordination with local public safety partners during emergencies,the PSP Portal
also enhances the Company's ability to prioritize power restoration, backup power
Page 96

evaluation, additional communications, and allocation of other resources before and during
PSPS events to critical facility customers.
9.3 COMMUNITY OUTREACH AND PUBLIC AWARENESS
Rocky Mountain Power employs a multifaceted approach to support community
engagement and outreach with the goal of providing clear, actionable, and timely
information to customers, community stakeholders and regulators. Over the past several
years, the Company has engaged customers and the general public throughout its three-
state service area on wildfire safety and preparedness through a variety of tactics including
webinars, targeted paid advertising campaigns, informational videos featuring Company
subject matter experts, press engagement, distributed print materials, infographics, social
media updates, and direct communication through bill messages, emails, and website
content, among other communication channels. The wildfire safety and preparedness
community engagement plan will continue to evolve year-over-year as customer and
stakeholder feedback and regulatory guidance are incorporated. Rocky Mountain Power
maintains an awareness and engagement strategy that is flexible and allows for dynamic
tactics, informed by customer survey data, community stakeholder input, and community
needs. Overall, the Company's plan includes information that can be heard, watched, and
read in a variety of ways with the goal of accessibility and understandability. These efforts
are intended to enhance public awareness. Given the potential severity of wildfire impacts,
the Company deems these expenditures as prudent and proportionate, especially when
weighed against the significant benefits of improved community preparedness and risk
mitigation.
AWARENESS AND ENGAGEMENT CAMPAIGN
For the past several years, the Company has deployed some form of paid media campaign
to raise awareness and action on wildfire safety and preparedness. The wildfire safety and
awareness paid advertising campaign, which launched April 1, 2024, and concluded
September 30, 2024, included social media static and video ads (Facebook, Instagram, and
YouTube). See Figure 9-2 for an example of the Company's YouTube content.
Metropolitan statistical areas in Idaho are targeted through a social media campaign on
Facebook, Instagram, and X (formerly Twitter). The campaign focuses on four main topics:
personal preparedness and safety, PSPS, leadership and vision, and investments the
Company is making to reduce wildfire risk, specifically system strengthening.
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Rocky Mountain Power
Explore
—e— Wildfire Safety and Prevention
IS Y-b-
Yo- Building tile future 10-Y11
Figure 9'2:Sample You7uboContent
The call-to-action in each campaign encourages the audience tovisit Rocky Mountain
Power's wildfire safety and preparedness online resources. Engagingwith locaLand regional
news media outlets is another key component of the awareness and engagement campaign.
In addition to paid and earned (navva media engagement) avvaranaaa and engagement
strategies, Rocky Mountain Power also communicates to ouatonnaru about wildfire safety
and preparedness through channels it owns or manages. Bill messages, website and social
media updates, emaiLs,texts, and automated phone calls are additional ways the Company
reaches customers.
SUPPORT COLLATERAL
Rocky Mountain Power has developed several print and digital wildfire safety and
preparedness collateral pieces, including brochures, infogrophica' and safety checklists.
See Figure 9-3 for on example. These itarna are auoaaaibia through the Company wildfire
safetywebpages and are used at public meetings and community events to describe wildfire
safety for Rocky Mountain Power customers, and to provide general information on
emergency kito/piono and preparation checklists, among other topics.
Pa8o9D

® Enhanced Safety Settings
Wildfire Safety w
>••~ -*�^ and Prevention ��^e,— ow.�as+�r Emergency de energization aw '
•�.='..::�..:r.�. ..".n�.- „.,�..e� ............. .,.,.� ,�.rv:< x,m:�wd,.,,�,ham,.,, „
-� �m,ww wairoa n,.nrwn.w•>a.<.nrv.,.,o,a.,,
.... `moo .ao;.rvw :}r 1 .,Y....o..µ.h.• NTa;`know n,..e.....Menn..b..MkNre
Staying safe during
wildfire season
SUPPORTING ACCESSIBILITY NEEDS
Figure 9-3:Sample Support Collateral
The Rocky Mountain Power communications team updates these materials annually to
ensure the information is relevant, accessible, and actionable. Additionally, the Company
engages customers as needed via direct communications like email. For instance,
beginning in 2023, during periods of elevated risk, enhanced safety settings (described in
greater detail in Section 6) may be implemented in some areas. Customers impacted by
these settings are sent a notification via email or paper letter, depending on their
communication preferences. An example email notification is shown in Figure 9-4.
Page 99

ROCKY MOUNTAIN
POWER
Wildfire safety precautions in place for your area
Due to elevated wildfire risk in your area,we are taking additional
safety precautions. We have turned on enhanced safety settings
and protective devices on our equipment that will automatically de-
energize power lines when debris,wildlife or strong winds contact
the lines.
Unfortunately, we cannot provide advanced notice of
these outages. Power will remain on under normal
conditions, but it will shut off automatically if something
contacts the line for the safety of customers and communities.
Customers should expect more frequent and longer duration
outages when these settings are in place.
These measures help prevent wildfires from starting,and we appre-
ciate your patience.We understand that power outages impact our
customers.
Be prepared and stay informed
• Plan ahead and be prepared year-round.
• Create a plan with your medical provider for appropriate
backup power.
• Review your contact information and sign up for alerts.
• Find outage and restoration information on our outage map.
• Sign up for outage alerts by texting OUT to 759677.
Visit our website for preparedness and wildfire safety information.
Have questions')Contad Us 1 , 0
Q
Update Profft
This mud was rard by Rocky Mountain Poww.1407 W NoiM Twiriple,Soill Lake City,UT 84116
Figure 9-4:Sample Email Communication-Modified Operational Settings
CUSTOMER SERVICE TRAINING
Customer care agents have received training on wildfire safety and preparedness
information to ensure customers receive the information they are requesting. Additionally,
customers with specific language needs can also contact the Company's customer care
number and request to speak with an agent in their preferred language. Rocky Mountain
Page 100

Power employs Spanish-speaking customer care professionals and contracts with a 24/7
service that provides interpretation in real-time over the phone in multiple languages and
dialects.
In 2022, Rocky Mountain Power established a process to track customer calls regarding
wildfire safety, wildfire preparedness, and other wildfire concerns. This process allowed
customer care specialists to select the term `wildfire' from a drop-down menu at the
conclusion of calls.
WILDFIRE SAFETY, PREPAREDNESS,AND PSPS WEBPAGES
The Rocky Mountain Power website provides robust and comprehensive information on
Company wildfire mitigation programs, general wildfire safety, PSPS information, and more.
In 2022,the Company launched updated wildfire safetywebpages to enhance the customer
experience and improve accessibility to wildfire-related information.The new pages include
infographics,videos, and handouts depicted in Figure 9-5 that demonstrate Rocky Mountain
Power's operational practices related to wildfire.
The wildfire safetywebpage updates include 1-to-1 translated Spanish wildfire safety pages
(see Figure 9-6).This includes frequently asked questions sections, links to PSPS maps and
information, and resources such as wildfire preparedness brochures and handouts.
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Wildfire Safety and Prevention
At Rocky Mountain Power,your safety is our top priority. In addition to hardening our system,
we've upgraded our power equipment with settings and devices to help prevent wildfires.
Monitoring conditions and risk in real-time allows us to take action where needed.
Enhanced Safety Settings Public Safety Power Shutoff
Dead,dry vegetation
■
■
■
We may adjust settings on power lines to Windy weather Potential impact on
reduce ignitions. If debris,wildlife or strong conditions surrounding areas
winds contact our lines,they will de-energize PSPS CONDITIONS
within fractions of a second.
We may turn off power to targeted areas
when weather conditions create a
higher risk of wildfires.
Emergency De-Energization
1 When an active wildfire gets too close to
our equipment-we may turn off power
to prevent additional wildfires, protect
first responders and keep our customers
and communities safe.
■
STAY SAFE, ALERT AND INFORMED
ROCKY FACU 1TAIN
•Update your contact information and sin up for alerts at Rockyf1ountanPowernetfAkrts or call 140&221-7070. POWER.
•we wd send important safety clomiation via tent,phone and email based on yov preferences, rO t"4r.roue ueArness
Figure 9-5: Wildfire Mitigation Program Infographic
Page 102

VF ROCKY POWER MOUNTAIN APAGONES SEGURIDAD OPCIONES SIGN IN
Seguridad Seguridad contra incendios forestales
Seguridad y confiabilidad Algunas Areas a las que servimos tienen un mayor riesgo de incendios forestales.Puede ser necesario
apagar ciertas Imeas en Areas que experimentan condiciones climAticas peligrosas para garantizar la
Seguridad contra Incendlos forestales seguridad de su comunidad.Tomamos la decision de cortar la energia con seriedad.y los cortes del
suministro el€ctrico por motivos de seguridad p6blica serAn especificos,precisos a informados por datos
Propietarios o trabajadores rurales s6lidos y en tiempo real sobre la situaci6n en el terreno.
i= Re.w ..
' ra BridgerTelon
P aanoo aus
Search Ma BoN National Forest `° p Observe
'O 'IDAHO
N i Jxkaon RESERVATION PINE RIDGE• Advertenna w rnpe
Pocaldi, WYOMING C.,per ..........._........._ r E.,_.
1 Twln FNla o 0
crams Pesa r o
Figure 9-6:Sample Webpage Content-Spanish
Various resources and tools for community preparedness can be found on the Rocky
Mountain Power wildfire website.9 Prompts for customers to update contact information are
displayed prominently on the page. Guides and checklists for creating an emergency
plan/outage kit are easily accessible. The wildfire safety website also includes links to the
WMP, as well as links to webinars and videos describing key components of the plan.
Overall, site visitors have a variety of ways to consume and engage with wildfire safety and
preparedness information, as shown below in Figure 9-7.
s Rocky Mountain Power wildfire site:http://www.rockymountainpower.net/wildfire.
Page 103

Prepare your home Create an emergency Backup power safety Plan for medical
plan needs
Get simple tips to help Find out more about
protect your home With a simple plan and the generators and how to use If you have medical
by maintaining and right supplies,your family them safely. equipment that requires
reducing vegetation on can be ready for an electricity,we offer
your property. emergency. programs and resources to
help.
SEE STEPS YOU CAN TAKE UPDATE YOUR PLAN BACKUP POWER MEDICAL PROGRAMS
Resources and brochures v
Figure 9-7. Wildfire Safety Website Content
Additionally, the Rocky Mountain Power PSPS website provides educational materials on
PSPS. It describes why a PSPS might happen, including details of conditions monitored prior
to executing a PSPS and how customers can prepare. The website gives information on how
customers will be notified, what to expect during an event, and the service restoration
process. There is also an interactive map of PSPS areas (shown in Figure 9-8) that provides
a visualization of where the Company is considering a PSPS.
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„RONKYRMOUNTAN MYACCOUNT OUTAGES&SAFETY SAVINGS&ENERGY CHOICES Q ` Q SIGN IN
Outages&Safety Public Safety Power Shutoff (PSPS)
Report outage or check status
Streetlight outages
Make sure your contact information on your account is up-to-date to receive outage alerts and
Wildfire safety updates.You can sign in to your account,or call 1-888-221-7070.
Public Safety Power Shutoff Some areas we serve are at an increased risk of wildfire.Turning power off in areas experiencing hazardous
weather,such as extremely hot,dry and windy conditions,may be necessary to ensure the safety of your
Enhanced safety settings
community.We take the decision to turn off power seriously,and Public Safety Power Shutoffs(PSPS)will
Emergency de-energization be targeted,precise and informed by robust,real-time data about the situation on the ground.
Storms&emergencies
Home&work safety
Reliability&tree pruning
Public Safety Power Shutoff map
_nc ary� oSal— '.National Forest '-- - "--' -
Sher don
seareh'Aap :Yellowstone ,cody sp arlish, Stows rl
Nationab Park oRunalo ou tt oswrgis y,,atch 'T
oEogene oeend
S Boise National opapide t
Forest Warning
Ma OREGON Na hpao o6oise Caribou-Targhee
p IDAHO National Forest D Event
PINE Rlo�
Bridger-Teton PINE
Rl t�l T._. Ui National Forest WYOMING ---------a���o
Pocerelloo oCasper
r�
Figure 9-8:Public Safety Power Shutoff Webpage
To serve the Company's non-English—speaking customers, the PSPS website displays the
following message in nine languages10: "A customer care agent can speak with you about
wildfire safety and preparedness. Please call 888-221-7070.”
Additionally, webpages have the capacity to manage site traffic under extreme demand
because the Company has implemented the bandwidth to allow for increased customer
access without compromising site integrity.
WEBINARS AND COMMUNITY EVENTS
Rocky Mountain Power hosts an annualwebinarthat provides an overview of the Company's
wildfire mitigation program and strategies. Among other items, key mitigation topics
addressed in the webinar include situational awareness capabilities, system strengthening
investments, the PSPS process, and general emergency preparedness. The webinar brings
to focus how the Company engages with local communities and public safety partners on
wildfire safety. It also serves as a forum for customers, community stakeholders, and the
0 Chinese traditional,Chinese simplified,Tagalog,Vietnamese,Mixteco,Zapoteco,Hmong,German,and Spanish.
Page 105

public at large to ask questions during the live stream. In 2025, Rocky Mountain Power
hosted a webinar for Idaho in advance of the fire season. The webinar is available on the
Company's YouTube channel.
Rocky Mountain Power hosted a community wildfire event in Rexburg, Idaho, on June 3,
2025. This event was free to attend and was promoted to customers and the community.
Subject matter experts from Rocky Mountain Power's wildfire mitigation and emergency
management teams presented elements of the wildfire mitigation plan, while local
operations teams presented ongoing work and improvements related to wildfire. Rocky
Mountain Power plans to continue these wildfire awareness events, as needed, in 2026 and
beyond.
CAMPAIGN AND ENGAGEMENT EVALUATION
Rocky Mountain Power plans to expand its customer survey program in Idaho. The overall
objective of this research is to measure the public's awareness of messaging related to
wildfire preparedness and safety to inform the development of the following year's
engagement campaign.
Specific research objectives of the surveys include evaluating the following:
• Customer awareness of Rocky Mountain Power messages related to wildfire
preparedness
• Customer recall of specific message topics
• Customer recall of message channels
• Customer recall and understanding of wildfire de-energizations (PSPS, ESS,
encroachment, etc.)
• Sources customers are most likely to turn to for information about wildfire de-
energization
• Customer wildfire de-energization experience
• Actions taken by customers to prepare for wildfire season
• Customer awareness of Rocky Mountain Power's efforts to reduce the risk of wildfires
• Customer perception of wildfire de-energization notification
• Customer recall and understanding of Rocky Mountain Power's wildfire mitigation
programs
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9.4 2025 WILDFIRE COMMUNICATIONS AND OUTREACH PLAN
The Company's overall approach to wildfire communications and its outreach plan remain
the same year over year, as shown in Table 9-1. For example, the Company always runs a
paid advertising, customer email, and initiative-taking news media engagement campaign.
Table 9-1:Wildfire Communications and Outreach Plan Timeline
Q1 Q2 Q3 Q4
Paid media campaign(social,digital)
Proactive media engagement
Customer emails and bill messages
Wildfire community events as appropriate
9.5 INDUSTRY COLLABORATION
Industry collaboration is another component of Rocky Mountain Power's WMP. Through
active participation in workshops, international and national forums, consortiums, and
advisory boards, Rocky Mountain Power maintains an understanding of existing best
practices and collaborates with industry experts regarding emerging technologies and
research.
For example, Rocky Mountain Power is an active member of the International Wildfire Risk
Mitigation Consortium (IWRMC)," an industry-sponsored collaborative designed to
facilitate the sharing of wildfire risk mitigation insights and discovery of innovative and
unique utilitywildfire practices from across the globe.This consortium,with working groups
focused in the areas of asset management, operations and protocols, risk management,
and vegetation management, facilitates a system of working and networking channels
between members of the global utility communityto support the ongoing monthly sharing of
data, information, technology, and practices.
Rocky Mountain Power participated in the three-year Electric Power Research Institute
(EPRI) Climate Resilience and Adaptation Initiative (READi)to develop, in collaboration with
industry stakeholders and other utilities, a common framework or guideline to assess
climate risk, address resiliency, and evaluate investments. This common framework
includes alignment on a consistent approach to understanding climate-related data,
application, and climate trends, applying a common set of climate data to perform asset
" IWRMC website:https://www.esource.com/public/international-wildfire-risk-mitigation-consortium.Sourced Dec.2,
2025.
Page 107

and system vulnerability assessments, and evaluating investments and system
strengthening technologies across power systems. The initiative was completed in July of
2025. EPRI published the result of the initiative, Climate READi Compass,12 the primary tool
for navigating the framework and accessing the related resources and publications, which
are available for Company use. Rocky Mountain Power is still assessing the
recommendations of the framework as of the publication of this WMP.
Rocky Mountain Power's parent Company, PacifiCorp, participated in the Western Wildfire
Communications Workshop to meet with communications teams from Western utilities in
the United States and Canada to discuss wildfire communications. The first event was
hosted by PacifiCorp in November 2024 and included discussions on internal
communications, digital media, paid media, media relations, community engagement,
Lessons learned from the 2024 wildfire season, and discussion on expected 2025
challenges.The 2024 event was attended by nine utilities. Additional events are planned for
2026.
Through these various engagement channels, Rocky Mountain Power aims to maintain
industry networks, understand the evolution of technologies, discover broader applications
for such advancements, freely share data to enable scientists and academics, collaborate
with developers to push the boundaries of existing capabilities, and expand its research
network through support of advisory boards or grant funding. Participation in these industry
networks is continuing to increase Rocky Mountain Power's confidence in its WMP
strategies and program elements.
10. PLAN MONITORING AND IMPLEMENTATION
In a 2025 reorganization,the Wildfire Mitigation Program Delivery(WMPD)team, responsible
for overall plan development, implementation, and monitoring,was included in the Wildfire
Mitigation and Emergency Operations group. This integration strengthens coordination
between strategic planning and field execution, ensuring wildfire mitigation efforts are more
cohesive, responsive, and operationally aligned with the WMP.
While the broader Wildfire Mitigation and Emergency Operations group is tasked with
supporting all types of wildfire mitigation initiatives and strategies across the Company's
entire service territory, the key function of the WMPD team is to develop, implement,
monitor, and improve the Company's WMP in Idaho. The WMPD team is responsible for
coordinating with other internal departments such as asset management, vegetation
12Climate READi Compass:https://apps.epri.com/climate-readi-compass/en/.Sourced Dec.2,2025.
Page 108

management, field operations, and emergency management to ensure all aspects of the
plan are delivered. As needed, WMPD evaluates its plan and provides updates consistent
with statutory and regulatory requirements.
In addition to evaluating the plan elements, Rocky Mountain Power is also monitoring
potential cost sharing and partnership opportunities to secure federal and state grant
funding and offset the potential impacts to customers. Many of the Company's wildfire
mitigation programs, such as system strengthening, which includes investment in
transformational technology, align with the goals and objectives of potential grant funding.
Implementing the plan includes reviewing each initiative's progress toward the established
objectives. Initiative owners are responsible for developing individual project plans to help
the plan objectives be met. The WMPD verifies that the project plans are aligned with the
WMP's objectives and that key performance metrics are in place to monitor progress.
11 . PLAN SUMMARY AND COSTS
11 .1 PROGRAM ACHIEVEMENTS AND OBJECTIVES
The Rocky Mountain Power WMP is designed to provide timely and cost-effective wildfire
mitigation benefits through a range of programs. Table 11-1 summarizes the program
elements, 2025 achievements, and 2026-2028 program objectives.
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Table 11-1:Summary of 2025 Program Results and 2026-2028 ObjertkirP z
Program Category General Program Description 2025 Achievements 2026 Program Objectives 2027-2028 Program
Objectives
➢Implement ignition drivers
✓ Updated risk model ➢Institute model change into risk reduction
Maintain baseline risk maps architecture using Azure Dev tracking and taxonomy methodology
and framework to identify Ops for version control ➢Evaluate cloud-based ➢Develop web application to
Risk Modeling& areas that are subject to a ✓ Implemented monetized risk model development view and use risk model
Drivers heightened risk of wildfire and
methodology environment results
inform longer-term, multiyear
investment and programs ✓ Developed risk aggregation ➢Update methodology for ➢Refine risk model
strategy wildfire likelihood methodology to increase
accuracy and granularity
Perform visual assurance ✓ Completed 100%of visual ➢Continue visual assurance ➢Continue visual assurance
Inspection& patrol inspections annually assurance patrol
Correction across the entire service inspections across service patrol inspections across patrol inspections across
the entire service territory the entire service territory
territory territory
Perform vegetation ✓ Continue with standard ➢Continue with standard ➢Continue with standard
Vegetation vegetation management vegetation management
Management management work based on vegetation management programs(no FHCA in programs(no FHCA in
the standard programs programs(no FHCA in Idaho)
Idaho) Idaho)
➢Plan to replace 4 circuit
Long-term investment to breakers
mitigate wildfire risk,including ➢Plan to install standard Continue monitoring of
line rebuilds,system distribution relay panels in
System ✓ Completed 75 CFCI existing CFCIs. No
protection and control the existing control house
Strengthening equipment upgrades,and installations at 2 circuit breakers additional CFCI
replacement of overhead ➢No additional CFCI installations planned
fuses and adjacent equipment installations planned in
2026
Page 110

Program Category General Program Description 2025 Achievements 2026 Program Objectives 2027-2028 Program
Objectives
✓ Installed 10 weather stations
✓ Implemented an internal fuel
and terrain classification
system for the service ➢Install additional weather
territory to assess wildfire stations based on fuel and
potential terrain characteristics
✓ Extended WRF reanalysis ➢Operationalize WRF
Install and operate a and continued to improve Ensemble model internally ➢Install additional weather
Company-owned weather upon the Technosylva WFA-E ➢Continue to improve WRF stations based on fuel and
Situational station network, implement a software to model potential Deterministic model, terrain characteristics
risk forecasting and impact- impacts based on weather including bias-corrected
Awareness ➢Continue to optimize
based fire weather model,and conditions forecasts internal WRF models
inform key decision-making ✓ Implemented machine ➢Potential new staff to
and protocols learning technologies to support additional ➢Improve forecasting tool
assess with live fuel forecasting for the
moisture analysis and Company
weather station analysis ➢Broaden tools to produce
✓ Completed the more granular forecasting
implementation of WRF
Ensemble forecasting
system
✓ Risk-based implementation ➢Continue risk-based
Continue risk-based
Risk-based implementation of of ESS settings and re- implementation of ESS and ➢
ESS settings and re- energization practices re-energization practices implementation of ESS and
re-energization practices
energization practices in a ✓ Continued implementing 6 ➢Continue implementing 2
System Operations ➢Continue implementing
manner that balances risk
ESS circuit improvement ESS circuit improvement
mitigation with potential projects on top reliability projects on top reliability ESS circuit improvement
projects on top reliability
impacts to customers impacted circuits from ESS impacted circuits from ESS
impacted circuits from ESS
past year past year
Page 111

Program Category General Program Description 2025 Achievements 2026 Program Objectives 2027-2028 Program
Objectives
Acquire and maintain key ➢Continue implementing ➢Continue implementing
equipment(water trucks, ✓ Implemented risk-based risk-based work practices risk-based work practices
remote communication work practices ➢Assess additional ➢Assess additional
Field Operations& devices,and personal ✓ Purchased 5 Starlink devices equipment needs equipment needs
Work Practices suppression equipment)and ✓ Performed system ➢Purchase additional ➢Purchase additional
implement risk-based work strengthening upgrades on Starlink devices under Starlink devices under
practices and resource circuits with ESS normal operational normal operational
adjustments spending spending
✓ Expanded public safety ➢Outreach and train public ➢Outreach and train public
Maintain the ability to actively partners outreach, including safety partners to utilize the safety partners to utilize the
monitor conditions,assess wildfire preparedness, PSP Portal PSP Portal
risk,and implement a PSPS as mitigation and operational ➢Continue outreach to ➢Continue outreach to
a measure of last resort in a practices include wildfire include wildfire
PSPS Program manner that limits the impacts ✓ Developed internal preparedness, mitigation preparedness, mitigation
to customers and situational awareness tools and operational practices and operational practices
communities consistent with ✓ Developed and implement ➢Continue improving real- ➢Continued improving real-
regulatory requirements the Wildfire Intelligence time situational awareness time situational awareness
Center(WIC) tools tools
Develop and implement a
Public Safety public safety partner ✓ Continued regular ➢Continue expanding ➢Continue expanding
Partner engagement strategy to engagement with public engagement with public engagement with public
Coordination enhance coordination and safety partners safety partners safety partners
ensure preparedness
Page 112

Program Category General Program Description 2025 Achievements 2026 Program Objectives 2027-2028 Program
Objectives
✓ Hosted 1 community event
(Rexburg)
✓ Hosted 1 annual webinar
➢Continue customer wildfire ➢Continue customer wildfire
✓ Sent pre-season customer safety and prevention safety and prevention
Manage a multi-pronged email and bill messages messaging before,during messaging before,during
Community approach to engage and ✓ Sent mid-season customer and after wildfire season and after wildfire season
Outreach inform the public and emails ➢Continue paid media ➢Continue paid media
customers regarding wildfire ✓ Ran paid media campaign campaign campaign
safety and preparedness with 1,589,272 impressions
➢Continue multi-state ➢Continue multi-state
and 4%video completion industry collaboration industry collaboration
rate
✓ Participated in multi-state
industry collaboration
✓ Investigated grant funding
Leverage a centralized, opportunities ➢Continue to pursue any
dedicated team to develop, ✓ Continued pursuing any new new grant opportunities. ➢Continue to pursue new
Plan Monitoring& monitor, implement,and grant opportunities ➢Continue reviewing QA/QC grant opportunities in 2026
Implementation continuously improve the ✓ Continued reviewing QA/QC processes for program and beyond
WMP processes for program tracking
tracking
Page 113

11 .2 COSTS
Delivering Rocky Mountain Power's multiyear WMP, as summarized above, requires an
increase in investment across multiple years. Rocky Mountain Power is currently
forecasting an additional investment of $13.9 million through 2028 (across three years), or
$8.1 million capital and $5.8 million expenses. Some programs, as understood today,
require finite investment with a planned end date. Other programs, such as enhanced
inspections or vegetation management, are expected to be ongoing and annual.
Furthermore, not all programs require spending of each type in each year.
The following tables describe Rocky Mountain Power's three-year estimate of these
incremental costs broken down by expenditure type.Additionally,the capital costs included
reflect spending occurring in a given year, which may differ from values included in general
rate case filings or cost recovery mechanism applications, which include costs based on
when assets are placed in service. Furthermore, the costs reflect Rocky Mountain Power
allocated share of associated programs and projects.While the tables only include a three-
yearforecast,these programs and increased expenditures are expected to continue beyond
2028.
Table 11-2: Planned Incremental Capital Investment by Category($millions)
Program Category Total2026 Total2027 Tota12028 3-Year Total
Risk Modeling and Drivers $0.3 $0.3 $2.8 $3.4
Asset Inspections and Corrections $0.0 $0.0 $0.0 $0.0
System Strengthening $1.0 $1.0 $0.3 $2.3
Situational Awareness $0.1 $0.2 $1.5 $1.8
Field Operations and Work Practices
(Starlink Communications and $0.1 $0.1 $0.1 $0.3
Specialized Equipment)
Public Safety Partner Coordination $0.1 $0.1 $0.1 $0.3
Wildfire Safety and Engagement
$0.0 $0.0 $0.0 $0.0
Strategy
Wildfire Mitigation Program Delivery $0.0 $0.0 $0.0 $0.0
Industry Collaboration $0.0 $0.0 $0.0 $0.0
Grand Total $1.6 $1.7 $4.7 $8.0
Page 114

Program Category Total2026 Total2027 Total2028 3-Year Total
Risk Modeling and Drivers $0.2 $0.2 $0.2 $0.7
Asset Inspections&Corrections $0.2 $0.2 $0.2 $0.6
System Strengthening $0.1 $0.1 $0.1 $0.4
Situational Awareness $0.9 $0.9 $1.0 $2.7
Field Operations&Work Practices $0.2 $0.2 $0.2 $0.5
Public Safety Partner Coordination $0.0 $0.0 $0.0 $0.0
Wildfire Safety and Engagement Strategy $0.1 $0.1 $0.1 $0.3
*Wildfire Mitigation Program Delivery $0.2 $0.2 $0.2 $0.6
Industry Collaboration $0.0 $0.0 $0.0 $0.1
Grand Total $1.8 $1.9 $2.0 $5.7
*This line encompasses the internal labor costs for the wildfire mitigation team as required by Order No.
36405.
Rocky Mountain Power anticipates continuously improving its WMP in away that aligns with
community and Idaho Public Utilities Commission expectations. Key takeaways from
collaborations with other utilities, public safety partners, the Idaho Public Utilities
Commission, communities, and customers will be evaluated for incorporation into future
WMPs and may require corresponding changes or updates to these forecasts.
Page 115

Appendix -ADHERENCE TO REQUIREMENTS
Senate Bill (SB) 1183 details legislative requirements for the Wildfire Standard of Care Act.
On September 30, 2025, the Idaho Public Utilities Commission issued order number 36774
regarding SB 1183. Rocky Mountain Power's adherence to these requirements is detailed in
this section.
Page 116

Table A-1: Rocky Mountain Power Compliance with Senate Bill 1183-Chapter 18,Title 61:Wildfire Standard of Care Act
Commission Order No.36774
Code Legislative Requirement Compliance
Case No.GNR-E-25-02
Section 1 "Baseline Risk Analysis"and its
subsections describe the Company's program
selection methodology and balance between
mitigation costs and risk reduction.
See Sections 2 through 9 for a description of
mitigation programs:
Each wildfire mitigation plan shall be Section 2"Inspection and
developed using approaches and Correction"
methods that are designed to protect
the public interest and are reflective Section 3"Vegetation Management"
of and commensurate with the size Section 4"System Strengthening and
and complexity of the electric Resiliency"
Section 3, corporation's operations and of the Section 5"Situational Awareness and
61-1803 nature of the fire risk.At a minimum, Forecasting"
each wildfire mitigation plan shall 0 Section 6"System Operations"
identify a means for mitigating wildfire
Section 7"Field Operations and Work
risk that reflect a reasonable
balancing of mitigation costs with the Practices"
resulting reduction of wildfire risk, Section 8"Public Safety Power
including: Shutoff(PSPS)Program"
• Section 9"Emergency Preparedness,
Collaboration,and Community
Outreach"
See Section 11 "Plan Summary,Costs,and
Benefits"for a summary of costs and benefits
of mitigation programs.
The electric corporation must include a description of the
wildfire risk assessment or model used to guide wildfire
mitigation activities.The assessment should identify geographic
Identifying geographical areas where areas with elevated fire risk,considering factors such as
i n electric corporation has vegetation,weather,topography,historical fire occurrence,
nfrastructure or equipment that the structure density,and asset location.
(a) electric corporation considers may be Section 1 "Baseline Risk Analysis"
subject to a heightened risk of wildfire The electric corporation should provide a map of the identified
at the time the wildfire mitigation plan risk areas within its service territory within this section of its
is finalized by the electric corporation 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.
Page 117

Commission Order No.36774
Code Legislative Requirement Compliance
Case No.GNR-E-25-02
The electric corporation must describe all preventative actions
and programs that it will carry out to reduce the risk of wildfire,in
addition to actions and programs specified in statute and by this
Commission.For the three large investor-owned utilities,Staff
recommends that previous areas of focus of each utility's WMPs
continue to be included within its WMPs.A WMP's preventative
actions and programs may include,but is not limited to:
Situational Awareness efforts
• Which may include use of technology to aid in weather
monitoring,fire season outlook,daily,weekly,and
monthly weather and fire modeling risk,etc.
• Consistent with 61-1803(3)(f)and Staff's proposed Section 2"Inspection and Correction"
requirements within. Section 3"Vegetation Management"
Asset Inspections Section 4"System Strengthening and
• Which must include the frequency and standards of Resiliency"
inspections for each type of electric infrastructure Section 5"Situational Awareness and
within areas of elevated wildfire risk. Forecasting"
Preventative actions and programs
(b) that the electric corporation will carry Consistent with 61-1803(3)(g)(i)and Staffs proposed Section 6"System Operations"
out to reduce the risk of wildfire requirements within. Section 7"Field Operations and Work
Enhanced vegetation management practices in risk zones Practices"
• Which may include shorter vegetation management Section 8"Public Safety Power Shutoff(PSPS)
cycles than routine cycles,risk tree programs,etc. Program"
• Consistent with 61-1803(3)(g)(iii)and Staff's proposed Section 9"Emergency Preparedness,
requirements within. Collaboration,and Community Outreach"
Operation practices during heightened wildfire risk days or
zones.
• Which may include restrictions to workforce practices,
potential use of pro-active de-energization
• Consistent with 61-1803(3)(g)(ii)and Staff's proposed
requirements within.
Community education
• Which 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)
Page 118

Commission Order No.36774
Code Legislative Requirement Compliance
Case No.GNR-E-25-02
A WMP's preventative actions and programs may include,but is
not limited to:
System strengthening strategies13
• Which may include pole replacements,line rebuilding, Section 4"System Strengthening and
Preventative actions and programs or undergrounding if necessary,strategic fuse or Resiliency"
(b)(cont.) that the electric corporation will carry reclosers installations,etc. Section 7"Field Operations and Work
out to reduce the risk of wildfire(cont.) Workforce Preparedness Practices"
• Which may include workforce training,equipment
provided to employees to reduce the risk of wildfire,etc.
Pilot Programs
• If applicable
This section should include discussion of how each utility
maintains community outreach and public awareness before,
during,and after wildfire season to support customer awareness
and education of wildfire risks and notify the public of wildfire-
related outages.This discussion should include,but is not
Limited,to the following:
• Description of customer communication efforts related
to wildfire mitigation,including efforts to increase
awareness and education of the utility's plan,
Community outreach and public explanation of key mitigation activities,and efforts
awareness efforts that the electric supporting public readiness.
Section 8"Public Safety Power Shutoff(PSPS)
corporation will use before,during, If the utility utilizes de-energization,a description of Program"
(c) and after wildfire season to identify public education efforts and communication protocols
and inform the public of relevant for before,during,and after a de-energization event.The Section "Emergency Preparedness,
wildfire risks and notify the public of communication protocols should clearly identify which Collaboration,and Community Outreach"
wildfire-related outages; customers could and will be impacted if a de-
energization event is pursued and identify any advanced
notifications for critical infrastructure or customers,
which may include but not limited to,hospitals and
other medical facilities,schools,police,fire,emergency
operation centers,any jails/prisons,other utilities,and
vulnerable customers.
• Explanation of the communication methods the electric
corporation intends to use,such as mail,flyers,emails,
calls,texts,a notification system,its website,etc.
3 PacifiCorp uses the term system strengthening instead of system hardening.Both terms refer to the same overall strategies.
Page 119

Commission Order No.36774
Code Legislative Requirement Compliance
Case No.GNR-E-25-02
The electric corporation must describe how it engages with and
coordinates with federal,state,tribal,and local officials and
agencies on wildfire preparedness and emergency response in
the plan year.This discussion may include,but is not limited to:
Outreach efforts to coordinate with 0If applicable,Public Safety Power Shutoff("PSPS") Section 8"Public Safety Power Shutoff(PSPS)
federal,state,tribal,and local tabletop exercises with interested parties and agencies Program"
(d) officials and agencies on wildfire 0 Communication with the agencies and the ESF-12 Section 9"Emergency Preparedness,
preparedness and emergency coordinator within the PUC. Collaboration,and Community Outreach"
response plans 0 If applicable,mitigation efforts with the agencies.
The WMP must detail all relationships(such as BLM and Forest
Service)it has established that may benefit the wildfire
mitigation program,contribute to program costs,or provide cost
sharing opportunities in its WMP.
The electric corporation must describe how its methods of line
design for new lines and planned upgrades reduce wildfire
ignition potential in heightened wildfire risk areas.This must
include evaluation of costs to wildfire risk reductions.
Additionally,this must include how the electric corporation
clearly identifies,selects,and evaluates projects that are least- See Section 4"System Strengthening and
Financially prudent and reasonably cost,least-risk for the following,but is not limited to: Resiliency"for details on methods of line
practicable methods of line design for design and grid resilience.
(e) new,planned,and existing lines to Line rebuilding within the WMP. See subsections 1.4-1.5 for details on the
mitigate fire risk Undergrounding lines within the WMP. Company's approach to monetized risk,
• Installation of covered conductor. program selection and prioritization.
• Installation of non-wooden cross arms.
• If any,describe anyflexible infrastructure such as
automatic reclosers and remote-controlled devices that
support remote operations.
Page 120

Commission Order No.36774
Code Legislative Requirement Compliance
Case No.GNR-E-25-02
This section should include a description of how the electric
corporation monitors forecasted and current weather conditions
for the purpose of assessing and responding to current and
anticipated wildfire risk.This description must include,but is not
Limited to,the following:
• Identification of systems,tools,or external resources
used to monitor weather,fire potential,or other
Monitoring forecasted and current situational awareness indicators. Section 5"Situational Awareness and
weather data for the purpose of If applicable,a description of how the utility utilizes Forecasting"
(f) assessing and responding to current weather forecasting,fire potential modeling,or similar Section 8"Public Safety Power Shutoff(PSPS)
and anticipated fire risk tools,to inform mitigation activities and operational Program"
decisions.
• Discussion of how situational awareness capabilities
are integrated into daily or seasonal wildfire operations.
• Discussion of how the electric utility become aware of
another electric corporation's de-energization(e.g.,
Bonneville Power Administration)and how that is
integrated into operations.
Developing standards,procedures,
and schedules,subject to timely
(g) approval of access to rights-of-way,if Appendix C"Policies and Procedures"
necessary,for the following actions
Refer to Section 2"Inspection and
This section should provide a summary of electric corporation's Correction"
programs for the inspection of electric infrastructure,assets,
and facilities within areas identified as heightened wildfire risk Refer to the following asset inspection SOPS:
areas to identify and correct conditions that could contribute to Detailed Inspections for T&D Lines
wildfire ignition.This summary must include,but is not limited Asset Management Policy 009
Inspection of the electric to,the following: Clearance Table for Distribution and
corporation's assets,infrastructure, Description of inspection standards for each type of Transmission Line Inspectors NESC
and facilities within the areas that are infrastructure,assets,and facilities. and GO 95 Grandfathering Matrix
(g)(i) identified as heightened fire risk areas Facility Point Inspection NESC and
in the wildfire mitigation plan,where Description of schedules for inspections for each type
g p of infrastructure,asset,and facility. GO 95 Frequently Asked Questions
financially prudent and reasonably Condition Code Dropdowns Asset
practicable Description of baseline routine inspection methods and Management Procedure 069
enhanced inspection methods for higher fire risk areas,
which may include the use of advanced or pilot Visual Assurance Inspections—
technologies. Safety Patrol of G Transmission and
Distribution Lines Asset Management
• Explanation of how identified defects are classified, policy No 011
prioritized,and corrected.
Page 121

Commission Order No.36774
Code Legislative Requirement Compliance
Case No.GNR-E-25-02
• Measurable targets/goals to be achieved within the Helicopter Standard Operating
WMP.e.g.,miles of lines inspected,corrected identified Procedure for Line Inspections
defects,etc. Facility Inspection Procedure No 203
Inspection of the electric Substation inspection Asset
corporation's assets,infrastructure, Management Policy No 034
and facilities within the areas that are Policy 001 Maintenance Intervals for
(g)(i)(cont.) identified as heightened fire risk areas Apparatus,Relays,Meters,Line
in the wildfire mitigation plan,where Patrol/Inspections,Wires Equipment and
financially prudent and reasonably Communications Equipment
practicable(cont.) See Section 2"Inspection and Correction"
and Section 11 "Plan Summary,Costs,and
Benefits"for objectives and measurable
targets.
If an electric utility plans to use de-energization as part of its
wildfire mitigation efforts,this section must address the
standards,criteria,and operational protocols,for de- Refer to PSPS SOPs:
energization for encroachment of a wildfire,proactive de- Operating Transmission and
energization(PSPS)to reduce fire risk,de-energization if •
requested by a fire agency,de-energization from 3rd party Distribution Assets During periods of
Elevated Wildfire Risk Power Delivery
energy providers,and de-energization for planned utility work for Policy PAC-1000
wildfire mitigation.This discussion must include,but is not
Limited to the following: SOP 200:Operating Transmission
A summary of the conditions underwhich de- Assets During Identified Wildfire Risk
De-energization of the electric energization may be used,if applicable. SOP 201,which describes operating
corporation's power lines,if The criteria or protocols for evaluating its sub-transmission assets during
(9)(ii) wildfire
considered appropriate by the electric appropriateness to engage.
corporation 0 Summary of the electric corporation's operational SOP 202 for a description of
protocols for before,during,and after a de-energization operations of distribution assets
event.
during identified wildfire risk
Description of how the electric corporation will SOP 203,which describes the
• coordinate with local emergency managers,operators Company's wildfire encroachment
of critical facilities,and affected communities before, policy
during,and after a de-energization event. See PSPS Execution Playbook.
• Descriptions of other operations for limiting impact to See Emergency Response Plan(ERP),Sixth
affected communities;which may include community edition,dated April23,2025.
resource centers,emergency generators,backup
batteries,etc.
Page 122

Commission Order No.36774
Code Legislative Requirement Compliance
Case No.GNR-E-25-02
This section must provide an overview of the utility's vegetation
management program aimed at reducing the risk of vegetation-
related contact with electric infrastructure in areas with
heightened wildfire risk within its rights-of-way or lands adjacent
thereto.Elements of this vegetation management section
overview should include,but is not limited to,the following: Refer to the following vegetation management
Vegetation management within the Identification,description,and citation of vegetation sops:
areas that are identified as heightened management standards for elevated wildfire risk areas. PacifiCorp's T&D Vegetation
fire risk areas in the wildfire mitigation Management Program SOPs,Revision
plan and are within the electric Explanation of how vegetation management standards,
corporation's rights-of-way or lands
procedures,and schedules are different or the same as 8,dated 8/29/2024
adjacent thereto and that threaten the routine vegetation management. Transmission Grid Operations
power lines or other electric 0 Description of the current and planned vegetation Operating Procedure PCC-215
(9)(iii) corporation infrastructure. If live management practices used to mitigate wildfire risk, Guidelines for Communication of
marketable timber is identified for including any enhancements in designated wildfire Vegetation Conditions that Present
removal from timber company land areas. an Imminent Threat of Transmission
adjacent to the rights-of-way, Line Outage
• The electric corporation must explain how the electric
compensation at fair market value utility considered vegetation management Also see Section 3"Vegetation Management"
shall be made to the landowner for for a description of vegetation management
recommendations by other federal,state,and county
such timber. agencies into its standards. procedures and the Company's consideration
of the removal of live,marketable timber.
• Must include measurable targets/goals to be achieved
within the WMP.E.g.,miles of lines completed,risk
trees removed,etc.
• Explanation of how identified risk trees are classified,
prioritized,and corrected.
Other Items to Include in the WMP
1)An update of lessons learned from the previously approved Not applicable.No previously approved WMP
WMP within the annual filings for WMP review and approval. to date.
2)A breakdown of each program category's forecasted costs by
year for both capital and O&M expenditures through the length of Section 11 "Plan Summary,Costs,and
Benefits"
the WMP.
3)A section in which it describes how the electric corporation
addresses each of the Commission's orders and Staff's Appendix A"Adherence to Requirements"
recommendations.
Page 123

Commission Order No.36774
Code Legislative Requirement Compliance
Case No.GNR-E-25-02
Within five(5)business days of filing a
wildfire mitigation plan with the
commission for its review and
approval,the electric corporation See the notice included as an attachment to
1804(2) shall provide notice of the filing to the the application.The Company will submit
state forester,cities,counties,fire notice of filing to the appropriate entities
protection districts,fire protection within 5 business days of filing.
associations,and timber protection
associations within the electric
corporation's Idaho service area.
Table A-2: Rocky Mountain Power Compliance with Final Order No.36774
Requirement Compliance
Order No.36774:That WMPs must explain how an electric corporation's line Section 1 "Baseline Risk Analysis"
design methods reduce the potential for wildfire ignition,including a cost
Section 4"System Strengthening and Resiliency"
evaluation.
Order No.36774:That all electric corporations must include a cost-benefit Section 1 "Baseline Risk Analysis"
analysis in their proposed WMPs thatjustifies the expenditures for risk mitigation Subsection 1.4"Monetized Risk"
described within. Subsection 1.5"Risk Treatment—Program Selection and Prioritization"
Table A-3: Rocky Mountain Power r'nmr•';^^^P with Final Order No.36405
Requirement Compliance
Section 1 "Baseline Risk Analysis"
Order No.36405:That the Company develop a least-cost least risk analysis to Subsection 1.4"Monetized Risk"
evaluate its wildfire mitigation projects.
Subsection 1.5"Risk Treatment—Program Selection and Prioritization"
Order No.36405:That the Company include a line item in the cost forecasts
contained in future wildfire mitigation plans disclosing the internal labor costs for Section 11 "Plan Summary,Costs,and Benefits"
its wildfire safety department.
Page 124

Appendix B -WILDFIRE RISK MODELING DATA INPUTS
The following describes the general model inputs, data sources, update frequency, and
update plans for data included in the Company's planning and dynamic, seasonal risk
model described in Sections 1.2 and 5.4. Many of the data sources below are provided and
managed by Technosylva, who owns and maintains WFA-E, which includes the FireSight,
FireRisk, and FireSim models.
Table B-4:Wildfire Risk Modeling Data Inputs
Dataset Spatial Resolution Start of Dataset Dataset Update Source
(Meters) Frequency
Landscape Characteristics
United States
Terrain 10 Yearly Geological Survey
(USGS)
Pre-Fire Season,
Surface Fuels 30/10 2020 Monthly Update in Technosylva
Fire Season, End
of Fire Season
Wildland Urban
Interface(WUI)
and Non-Forest 30/10 2020 Twice a Year Technosylva
Fuels Land Use
Canopy Fuels Pre-Fire Season,
(CBD,CH,CC, 30/10 2020 Monthly Update in Technosylva
CBH) Fire Season, End
of Fire Season
Roads Network 30 Yearly USGS
Hydrography 30 Yearly USGS
Croplands 30 1997 Yearly USDA
Weather and Atmospheric Data
Wind Speed 2000 1990 Hourly/96-Hour Atmospheric Data
Forecast Solutions(ADS)
Wind Direction 2000 1990 Hourly/96-Hour ADS
Forecast
Wind Gust 2000 1990 Hourly/96-Hour ADS
Forecast
Air Temperature 2000 1990 Hourly/96-Hour ADS
Forecast
Page 125

Dataset Spatial Resolution Start of Dataset Dataset Update Source
(Meters) Frequency
Surface Pressure 2000 1990 Hourly/96-Hour ADS
Forecast
Relative Humidity 2000 1990 Hourly/96-Hour Technosylva
Forecast
Precipitation 2000 1990 Hourly/96-Hour ADS
Forecast
Radiation 2000 1990 Hourly/96-Hour ADS
Forecast
Water Vapor
Mixing Ratio 2 2000 1990 Hourly/96-Hour ADS
meter Forecast
Snow National Oceanic
Accumulated— 1000 2008 Daily and Atmospheric
Observed Administration
(N OAA)
Precipitation
Accumulated— 4000 2008 Daily NOAA
Observed
National
Aeronautics and
Space
Burn Scars 10 2000 5 Days Administration
(NASA)/European
Space Agency
(ESA)
Weather
Observations Data Points 1990 10 Min Synoptic
Fuel Moisture
Herbaceous Live 250 2000 Daily/5-Day Technosylva
Fuel Moisture Forecast
Woody Live Fuel 250 2000 Daily/5-Day Technosylva/ADS
Moisture Forecast
1-Hour Dead Fuel 2000 1990 Hourly/124 Hour Technosylva/ADS
Moisture Forecast
10-Hour Dead Fuel 2000 1990 Hourly/124 Hour Technosylva/ADS
Moisture Forecast
100-Hour Dead 2000 1990 Hourly/124 Hour Technosylva/ADS
Fuel Moisture Forecast
Page 126

Dataset Spatial Resolution Start of Dataset Dataset Update Source
(Meters) Frequency
Values at Risk
Buildings Polygon Footprints 2020-21 Yearly Microsoft/
Technosylva
Damage
Inspection (DINS) Points 2014-21 Yearly Cal Fire
LANDSCAN,Oak
Population 90 2019 Yearly Ridge National
Laboratory(ONRL)
Roads Vector Lines 2021 Yearly Caltrans
Social Plexels 2021 Yearly Esri GeoEnrichment
Vulnerability Service
Fire Stations Points 2021 Yearly Esri, USGS
Building Loss Building Footprints 2022 Yearly Technosylva
Factor
Fire Resource
Critical Facilities Points 2021 Yearly Assessment
Program(FRAP)Cal
Fire
Potential Ignition Locations
Distribution&
Transmission Linear Segments 2022 Updated Rocky Mountain
Lines Quarterly Power
Poles&Equipment Points 2022 Updated Rocky Mountain
Quarterly Power
Outage History Points 1989 Annual Rocky Mountain
Power
Ignition History Points 2020 Annual Rocky Mountain
Power
Fire Activity
Hotspots MODIS 1000 2000 Twice a Day NASA
Hotspots VI IRS 375 2014 Twice a Day NASA
Hotspots GOES 3000 2019 10 Minute NASA
16/17
Fireguard Polygons 2020 15 Minute National Guard
Fire Season National Incident
Perimeters
Polygons 2021 Daily Feature Service
(NIFS)
Page 127

Dataset Spatial Resolution Start of Dataset Dataset Update Source
(Meters) Frequency
Historic Fire Polygons 1900 Yearly Cal Fire
Perimeters
Alert Wildfire Alert Wildfire
Live Feeds Real Time 1 Minute
Cameras Consortium
Lightning Strikes 1000 Real Time 1 Minute Earth Networks/
Others
Page 128

Appendix C -POLICIES AND PROCEDURES
Table C-5: List of WMP Policies and Procedures
Procedure/Policy Summary Applicable Section
2025 Emergency Response Plan Assists personnel to support a safe, Section 8"Public Safety
efficient,and coordinated response to Power Shutoff(PSPS)
emergencies and disasters that may Program"
impact the delivery of electric service.
2025 PSPS Execution Playbook Public Safety Power Shutoff—provides Section 8"Public Safety
the minimum guidelines for a planned de- Power Shutoff(PSPS)
energization of energized facilities when Program"
extreme weather or other conditions pose
an imminent safety threat to persons
and/or property.
PAC-1000 OperatingT&D Assets Comprehensive plan for wildfire
During Elevated Fire Risk mitigation efforts designed to reduce the Section 6"System
probability of utility-related wildfire Operations"
ignition and to mitigate damage to
Company assets. Defines the approach Section 8"Public Safety
to monitoring asset health and Power Shutoff(PSPS)
meteorological and fuel conditions
Program"
related to wildfire risk and adjusting daily
operations of transmission and
distribution system assets, including
network restoration,and fire
encroachment during identified periods
of elevated wildfire risk.
T&D Vegetation Management Describes best practices, including Section 2"Inspection
Program SOPs systematic maintenance,scientifically and Correction"
based pruning,tree removal,tree Section 3"Vegetation
replacement,cover type conversion, Management
herbicide and tree growth regulator
applications,and the use of specialized
tools and equipment.The procedure also
describes rights-of-way and easements.
Vegetation management is performed by
qualified independent contractors,and
Company procedures are binding to
third-party contractors performing
vegetation management.
ID Standard Easement Template for"right-of-way easement" Section 3"Vegetation
provided to customers. Management"
SOP-POL-007 PacifiCorp Outlines the detailed Emergency Section 8"Public Safety
Emergency Operating Plan Operating Plan,training,and incident Power Shutoff(PSPS)
command structure when storms,fires Program"
and other transmission system
conditions trigger the need to execute the
Emergency Operating Plan.
Page 129

Procedure/Policy Summary Applicable Section
SOP 200 Operating BES(bulk) Operating-restoration procedures for Appendix A: "Adherence
Transmission Assets During bulk electric system transmission assets to Requirements"
Wildfire during periods of identified wildfire risk.
SOP 201 Operating Sub- Addresses the Company's approach to Section 8"Public Safety
Transmission Assets During adjusting daily operations of sub- Power Shutoff(PSPS)
Identified Wildfire Risk transmission assets, including network Program"
restoration,during identified periods of
elevated wildfire risk.
SOP 202 Operating Distribution Addresses the Company's approach to Section 8"Public Safety
Assets During Identified Wildfire risk mitigation framework for control Power Shutoff(PSPS)
Risk NERC center operators when restoring Program"
distribution assets during identified
wildfire risk conditions.
SOP 203 Wildfire Encroachment Defines the Company's escalation and Section 5"Situational
Systems Operations Procedure response protocols when a wildfire is Awareness and
approaching Company transmission Forecasting"
and/or distribution facilities.This Section 6"System
procedure requires de-energization of Operations"
power lines when wildfire is within
defined distances to Company assets. Section 8"Public Safety
Power Shutoff(PSPS)"
Program
Annex 01: Public Safety Power Provides guidelines on how the Company Section 8"Public Safety
Shutoff Community Resource will activate,staff,and provide resources Power Shutoff(PSPS)"
Center Playbook for Community Resource Centers(CRCs) Program
that can be activated across our service
territory during PSPS(Public Safety Power
Shutoffs).Activated in tandem with PSPS
Execution Playbook.
Policy 009 Detail Inspections T&D Lines Section 2"Inspection
and Correction"
Policy 011 Visual Assurance Inspections T&D Lines Section 2"Inspection
and Correction"
Policy 013 Wood Pole Test&Treatment T&D Lines Section 2"Inspection
and Correction"
Procedure 069 Clearance Table,Grandfathering Matrix, Section 2"Inspection
FAQ and Dropdown Codes and Correction"
Policy 358 Distribution Line Capacitor Inspection Section 2"Inspection
and Correction"
Policy 371 Drone Inspections for T&D Lines Section 2"Inspection
and Correction"
Page 130

Appendix D -DEFINITIONS
Unless otherwise expressly stated,the following words and terms,for the purposes of these
Guidelines, have the meanings shown in this chapter.
Terms Defined in Other Codes
Where terms are not defined in these Guidelines and are defined in the Government Code,
Public Utilities Code, or Public Resources Code, such terms have the meanings ascribed to
them in those codes.
Terms Not Defined
Where terms are not defined through the methods authorized by this section, such terms
have ordinarily accepted meanings such as the context implies.
Term Definition
Individuals, including, but not limited to,those who have
developmental or intellectual disabilities, physical disabilities,
chronic conditions,or injuries;who have limited English
Access and functional needs proficiency or are non-English speaking;who are older adults,
(AFN)populations children,or people living in institutionalized settings;or who are
low income, homeless,or transportation disadvantaged, including,
but not limited to,those who are dependent on public transit or are
pregnant.
Asset(utility) Electric lines,equipment,or supporting hardware.
A specific portion of an electrical circuit that can be separated or
disconnected from the rest of the system without affecting the
Circuit segment operation of other parts of the network.This isolation is typically
achieved using switches,circuit breakers,or other control
mechanisms.
Consequence The adverse effects from an event,considering the hazard
intensity,community exposure,and local vulnerability.
Any individual in the temporary and/or indirect employ of the
Contractor electrical corporation whose limited hours and/or time-bound
term of employment are not considered "full-time"for tax and/or
any other purposes.
Page 131

Term Definition
Facilities and infrastructure that are essential to public safety and
that require additional assistance and advance planningto ensure
resiliency during PSPS events.These include the following:
Emergency Services Sector
• Police stations
• Fire stations
• Emergency operations centers
• Public safety answering points(e.g.,9-1-1 emergency
services)
Government Facilities Sector
• Schools
• Jails and prisons
Healthcare and Public Health Sector
• Public health departments
• Medical facilities, including hospitals,skilled nursing
facilities, nursing homes, blood banks, health care
facilities,dialysis centers and hospice facilities
(excluding doctor offices and other non-essential medical
facilities)
Critical facilities and Energy Sector
infrastructure Public and private utility facilities,vital to maintaining or
restoring normal service, including, but not limited to,
interconnected publicly owned utilities and electric
cooperatives
Water and Wastewater Systems Sector
• Facilities associated with the provision of drinking water
or processing of wastewater,including facilities used to
pump,divert,transport,store,treat and deliver water or
wastewater
Communications Sector
• Communication carrier infrastructure, including selective
routers,central offices, head ends,cellular switches,
remote terminals,cellular switches, remote terminals,
and cellular sites
Chemical Sector
• Facilities associated with the provision of manufacturing,
maintaining,or distributing hazardous materials and
chemicals
Transportation Sector
• Facilities associated with transportation for civilian and
military purposes:automotive, rail, aviation, maritime,or
major public transportation
The moisture content of dead organic fuels,expressed as a
Dead fuel moisture content percentage of the oven dry weight of the sample,which is
controlled entirely by exposure to environmental conditions.
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Term Definition
An inspection where individual pieces of equipment and structures
are carefully examined,visually and through use of routine
Detailed inspection diagnostic test,as appropriate,and (if practical and if useful
information can be gathered)opened, and the condition of each
rated and recorded.
A serious disruption of the functioning of a community or a society
at any scale due to hazardous events interacting with conditions of
exposure,vulnerability,and capacity, leading to one or more of the
following: human, material,economic,and environmental losses
and impacts.The effect of the disaster can be immediate and
Disaster localized but is often widespread and could last a longtime.The
effect may test or exceed the capacity of a community or society to
cope using its own resources.Therefore, it may require assistance
from external sources,which could include neighboring
jurisdictions or those at the national or international levels.
Exercise used to familiarize participants with current plans,
policies,agreements,and procedures or to develop new plans,
Discussion-based exercise policies,agreements,and procedures.Often includes seminars,
workshops,tabletop exercises,and games.
Network of wires, poles,transformers, and related equipment that
Distribution delivers electrical power from substations to homes, businesses,
and other end users at voltages suitable for safe use.
Every corporation or person owning,controlling,operating,or
managing any electric plant for compensation within the state,
Electrical corporation except where the producer generates electricity on or distributes it
through private property solely for its own use or the use of its
tenants and not for sale or transmission to others.
Any incident,whether natural,technological,or human caused,
that requires responsive action to protect life or property but does
Emergency not result in serious disruption of the functioning of a community
or society.
Inspection whose frequency and thoroughness exceeds the
Enhanced inspection requirements of the detailed inspection, particularly if driven by
risk calculations.
An instrument to train for,assess, practice,and improve
Exercise performance in prevention,protection, response,and recovery
capabilities in a risk-free environment.
The presence of people, infrastructure, livelihoods,environmental
Exposure services and resources,and other high-value assets in places that
could be adversely affected by a hazard.
Fire High Consequence Areas
(FHCA) Areas that the Company has deemed at high risk from wildfire.
Fire potential index(FPI)
A supplementary metric that quantifies the potential for large or
consequential wildfires based on weather,fuels, and terrain.
Page 133

Term Definition
The time of year when there is heightened wildfire risk for a given
geographic region due to historical weather conditions,vegetative
Fire season
characteristics,and impacts of climate change. Each electrical
corporation defines the fire season(s)across its service territory
based on a recognized fire agency definition for the specific
region(s)in the state.
Frequency The anticipated number of occurrences of an event or hazard over
time.
Fuel moisture content Amount of moisture in each mass of fuel(vegetation), measured as
a percentage of its dry weight.
A condition,situation,or behavior that presents the potential for
Hazard harm or damage to people,property,the environment,or other
valued resources.
A tree that is,or has portions that are,dead, dying, rotten,
Hazard tree diseased,or otherwise has a structural defect that may fail in
whole or in part and damage utility facilities should it fail.
The number of miles of transmission and/or distribution
Line miles conductors, including the length of each phase and parallel
conductor segment.
Marketable or"merchantable"timber is defined as trees with at
least six-inch diameter at breast height that are recoverable and
have a market in the local area. Merchantable timber belongs to
Marketable timber the property owner unless the easement or permit states
otherwise. If merchantable timber needs to be felled,the property
owner should be contacted regarding timber recovery.After the
merchantable timber is felled, it should be de-limbed and left in
total tree length on the right-of-way for recovery by the owner.
Undertakings to reduce the loss of life and property from natural
Mitigation and/or human-caused disasters by avoiding or lessening the
impact of a disaster.
A systematic, proactive approach to guide all levels of government,
nongovernment organizations,and the private sector to work
together to prevent, protect against, mitigate, respond to,and
National Incident Management recover from the effects of incidents. NIMS provides stakeholders
System(NIMS) across the whole community with the shared vocabulary,systems,
and processes to successfully deliver the capabilities described in
the National Preparedness System. NIMS provides a consistent
foundation for dealing with all incidents, ranging from daily
occurrences to incidents requiring a coordinated federal response.
In accordance with GO 165, a simple visual inspection of
applicable utility equipment and structures that is designed to
Patrol inspection identify obvious structural problems and hazards. Patrol
inspections may be carried out in the course of other Company
business.
Page 134

Term Definition
A quantifiable measurement that is used by an electrical
Performance metric corporation to indicate the extent to which its WMP is driving
performance outcomes.
Population density is calculated using the American Community
Population density Survey(ACS)one-year estimate for the corresponding year or,for
years with no such ACS estimate available,the estimate for the
immediately preceding year.
A continuous cycle of planning,organizing,training,equipping,
exercising,evaluating,and taking corrective action in an effort to
Preparedness ensure effective coordination during incident response.Within the
NIMS, preparedness focuses on planning, procedures and
protocols,training and exercises, personnel qualification and
certification,and equipment certification.
Private and public property,buildings and structures,
Property infrastructure,and other items of value that are destroyed by
wildfire, including both third-party property and utility assets.
PSPS event The period from notification of the first public safety partner of a
PSPS to re-energization of the final customer.
First/emergency responders at the local,state,and federal levels;
water,wastewater,and communication service providers;
Public safety partners community choice aggregators;affected publicly owned electrical
corporations/electrical cooperatives;tribal governments; Energy
Safety;the Idaho Public Utilities Commission;
A measure of the anticipated adverse effects from a hazard
Risk considering the consequences and frequency of the hazard
occurring.
The process of comparing the results of a risk analysis with risk
Risk evaluation criteria to determine whether the risk and/or its magnitude is
acceptable or tolerable.
An event with probability of ignition,such as wire down,contact
with objects, line slap,event with evidence of heat generation, or
other event that causes sparking or has the potential to cause
ignition.The following all qualify as risk events:
• Ignitions
Risk event 0 Outages not caused by vegetation
• Outages caused by vegetation
• Wire-down events
• Faults
• Other events with potential to cause ignition
Systematic application of management policies, procedures,and
Risk management
practices to the tasks of communication,consultation,
establishment of context,and identification,analysis,evaluation,
treatment, monitoring,and review of risk.
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Term Definition
Process used to determine the relationships between the
Sensitivity analysis uncertainty in the independent variables("input")used in an
analysis and the uncertainty in the resultant dependent variables
("output").
An on-going process of gathering information by observation and
Situational awareness by communication with others.This information is integrated to
create an individual's perception of a given situation.
The space between adjacent supporting poles or structures on a
Span circuit consisting of electric lines and equipment."Span level"
refers to asset-scale granularity.
Specialized electric facility within the power system that
Substation
transforms voltage levels, manages power flow,and protects the
electrical grid,acting as an intermediary between generation and
consumption points.
Actions(such as equipment upgrades, maintenance,and planning
for more resilient infrastructure)taken in response to the risk of
System strengthening undesirable events(such as outages)or undesirable conditions of
the electrical system to reduce or mitigate those events and
conditions, informed by an assessment of the relevant risk drivers
or factors.
A discussion-based exercise intended to stimulate discussion of
various issues regarding a hypothetical situation.Tabletop
Tabletop exercise(TTX) exercises can be used to assess plans, policies,and procedures or
to assess types of systems needed to guide the prevention of,
response to,or recovery from a defined incident.
System of conductors designed to carry high-voltage electricity
Transmission over long distances from power plants to substations or
distribution networks.
The amount by which an observed or calculated value might differ
Uncertainty from the true value. For an observed value,the difference is
"experimental uncertainty";for a calculated value, it is"model"or
"parameter uncertainty."
Utility-related ignition
An event that meets the criteria for a reportable event subject to
fire-related reporting requirements.
Utility-related wildfire Wildfire event that was caused on or by the utility's assets or
operations.
The assessment, intervention,and management of vegetation,
Vegetation management
including pruning and removal of trees and othervegetation
around electrical infrastructure for safety, reliability,and risk
reduction.
The propensity or predisposition of a community to be adversely
affected by a hazard, including the characteristics of a person,
Vulnerability group,or service and their situation that influences their capacity
to anticipate,cope with, resist, and recover from the adverse
effects of a hazard.
Page 136

Term Definition
The total anticipated adverse effects from a wildfire on a
Wildfire consequence community that is reached.This considers the wildfire hazard
intensity,the wildfire exposure potential,and the inherent wildfire
vulnerabilities of communities at risk.
The potential intensity of a wildfire at a specific location within the
Wildfire hazard intensity service territory given a probabilistic set of weather profiles,
vegetation,and topography.
The total anticipated annualized number of fires reaching each
spatial location resulting from utility-related ignitions at each
Wildfire likelihood location in the electrical corporation service territory.This
considers the ignition likelihood and the likelihood that an ignition
will transition into a wildfire based on the probabilistic weather
conditions in the area.
Overview of the key mitigation initiatives at enterprise level and
component level across the electrical corporation's service
Wildfire mitigation strategy territory, including interim strategies where long-term mitigation
initiatives have long implementation timelines.This includes a
description of the enterprise-level monitoring and evaluation
strategy for assessing overall effectiveness of the WMP.
The total expected annualized impacts from ignitions at a specific
location.This considers the likelihood that an ignition will occur,
Wildfire risk
the likelihood the ignition will transition into a wildfire,and the
potential consequences—considering hazard intensity,exposure
potential,and vulnerability—the wildfire will have for each
community it reaches.
The line,area,or zone where structures and other human
Wildland-urban interface development meet or intermingle with undeveloped wildland or
vegetation fuels.
Instance where an electric transmission or distribution conductor
Wire down is broken and falls from its intended position to rest on the ground
or a foreign object.
Discussion that resembles a seminar but is employed to build
Workshop specific products,such as a draft plan or policy(e.g.,a multi-year
training and exercise plan).
Page 137

ATTACHMENT B
2026-2028 Idaho Wildfire Mitigation Plan
Notice to Parties

_ ROCKY MOUNTAIN 1407 W.North Temple,Suite 330
POWER. Salt Lake City,UT 84116
A DIVISION OF PACIFICORP
December 19, 2025
VIA ELECTRONIC DELIVERY
RE: Notice of Filing—Rocky Mountain Power's Idaho 2026-2028 Wildfire Mitigation Plan
Attn: Stakeholders and Interested Parties
Rocky Mountain Power, a division of PacifiCorp, is providing notice that it will file its Idaho
2026-2028 Wildfire Mitigation Plan(WMP)with the Idaho Public Utilities Commission(IPUC)
on December 19, 2025.
Rocky Mountain Power filed its first Idaho Wildfire Mitigation Plan in 2024, which was
acknowledged by the IPUC On November 26, 2024. The 2026-2028 WMP continues and
expands on the 2024 WMP. The 2026-2028 Idaho WMP includes enhancements to the baseline
risk section, situational awareness, and incorporates other changes such as a compliance table, a
list of policies and procedures and definitions to comply with the Wildfire Standard of Care Act
(WSCA).
How to Participate:
Rocky Mountain Power's 2026-2028 WMP is available for public review and has been presented
for IPUC approval.
Copies of the filing are available for public inspection during regular business hours at the
IPUC's office located at 11331 W. Chinden Blvd. Building 8, Suite 201-A, Boise, ID 83714, or
the IPUC's website at www.puc.idaho.gov. Click on the "ELECTRIC" icon, select"Open
Cases," and click on Case No. PAC-E-25-22. Interested parties may also subscribe to the IPUC's
RSS feed to receive periodic updates via email about the case.
Written comments regarding Rocky Mountain Power's WMP filing can be filed with the IPUC;
comments are required to be filed through the IPUC's website or by e-mail unless computer
access is not available. To comment electronically, visit puc.idaho.gov and click on the "Case
Comment Form" link on the upper left side of the page. Please use case number PAC-E-25-22
when filling out the form. To comment using e-mail,please send comments to the e-mail
addresses listed below and include case number PAC-E-25-22. Commenters are required to
include their name and address. If computer access is not available, comments can be mailed to
the IPUC secretary and Rocky Mountain Power at the addresses listed below. Commenters are
required to include case number PAC-E-25-22, as well as their name and address.

Page 2
For the Idaho Public Utilities Commission:
Commission Secretary
Idaho Public Utilities Commission
P.O. Box 83720
Boise, ID 83720-0074
Email: secretarykpuc.idaho.gov
For Rocky Mountain Power:
Mark Alder
Idaho Regulatory Affairs Manager
Rocky Mountain Power
1407 West North Temple, Suite 330
Salt Lake City, UT 84116
Email: mark.aldergpacificorp.com
Joe Dallas (ISB# 10330)
PacifiCorp, Senior Attorney
825 NE Multnomah Street, Suite 2000
Portland, OR 97232
Email:joseph.dallaskpacificorp.com
cc:
Idaho Department of Lands, State Forester& Wildfire Risk Mitigation Program Manager
Peter Stegner, Principal -Riley Stegner and Associates
Bannock County, ID, County Clerk
Bear Lake County, ID, County Clerk
Bingham County, ID, County Clerk
Bonneville County, ID, County Clerk
Butte County, ID, County Clerk
Caribou County, ID, County Clerk
Clark County, ID, County Clerk
Franklin County, ID, County Clerk
Fremont County, ID, County Clerk
Jefferson County, ID, County Clerk
Madison County, ID, County Clerk
Oneida County, ID, County Clerk
Power County, ID, County Clerk
Teton County, ID, County Clerk
City of Ammon, ID, City Clerk
City of Arco, ID, City Clerk
City of Arimo, ID, City Clerk
City of Ashton, ID, City Clerk
City of Bancroft, ID, City Clerk
City of Bloomington, ID, City Clerk
City of Clifton, ID, City Clerk
City of Downey, ID, City Clerk

Page 3
City of Driggs, ID, City Clerk
City of Dubois, ID, City Clerk
City of Firth, ID, City Clerk
City of Franklin, ID, City Clerk
City of Georgetown, ID, City Clerk
City of Grace, ID, City Clerk
City of Idaho Falls, ID, City Clerk
City of Iona, ID, City Clerk
City of Lava Hot Springs, ID, City Clerk
City of Lewisville, ID, City Clerk
City of Malad City, ID, City Clerk
City of McCammon, ID, City Clerk
City of Menan, ID, City Clerk
City of Montpelier, ID, City Clerk
City of Mud Lake, ID, City Clerk
City of Newdale, ID, City Clerk
City of Paris, ID, City Clerk
City of Preston, ID, City Clerk
City of Rexburg, ID, City Clerk
City of Rigby, ID, City Clerk
City of Ririe, ID, City Clerk
City of Roberts, ID, City Clerk
City of Shelley, ID, City Clerk
City of Soda Springs, ID, City Clerk
City of Spencer, ID, City Clerk
City of St. Anthony, ID, City Clerk
City of St. Charles, ID, City Clerk
City of Sugar City, ID, City Clerk
City of Teton, ID, City Clerk
City of Tetonia, ID, City Clerk
City of Ucon, ID, City Clerk
City of Victor, ID, City Clerk
City of Weston, ID, City Clerk
Blackfoot Fire Department, ID, Fire Chief
Bonneville County Fire District#1, ID, Fire Chief
Central Fire District, ID, Fire Chief
Chubbuck Fire Department, ID, Fire Chief
Idaho Falls Fire Department, ID, Fire Chief
Madison Fire Department, ID, Fire Chief
North Bannock Fire District, ID, Fire Chief
Pocatello Fire Department, ID, Fire Chief
Shelley-Firth Fire District, ID, Fire Chief
Soda Springs Fire Department, ID, Fire Chief
St. Anthony Fire Department, ID, Fire Chief
Teton County Fire District, ID, Fire Chief
Henry's Creek RFPA, ID, RFPA Chair c/o ID Dept of Lands

Page 4
Black Canyon RFPA, ID, RFPA Chair c/o ID Dept of Lands
Three Creek RFPA, ID, RFPA Chair c/o ID Dept of Lands
Notch Butte RFPA, ID, RFPA Chair c/o ID Dept of Lands