20251231Compliance Filing .pdf

RECEIVED
December 31, 2025
IDAHO PUBLIC
UTILITIES COMMISSION
Idaho Public Utilities Commission Brad Little,Governor
P.O. Box 83720, Boise, ID 83702 Edward Lodge,President
John R.Hammond,Jr.,Commissioner
Dayn Hardie,Commissioner
December 31, 2025
Via E-Mail: secretarykpuc.idaho._og_v
Commission Secretary
Idaho Public Utilities Commission
P.O. Box 83720
Boise, ID 83702
RE: Case No. GNR-E-25-02, Compliance Filing
Dear Commission Secretary,
On September 30, 2025, the Idaho Public Utilities Commission ("Commission") issued
Order No. 36774 directing Commission Staff("Staff') to hold two workshops to determine the
required content of compliance reports. The topics required to be covered in the workshops
included fire reporting, monthly compliance targets, expenditures, filing timelines, and
establishing consistency in language and formatting in all Wildfire Mitigation Plans ("WMP").
Following the workshops,interested parties were ordered to either submit joint proposed standards
by December 31, 2025, or individual proposals if consensus was not reached. Order No. 36774 at
20.
On October 27,2025, Staff held the first virtual workshop with 46 participants representing
14 interested parties.' The first workshop covered a high-level discussion of the topics specified
by the Commission's Order. On November 12, 2025, Staff sent a strawman proposal to all parties
that incorporated items and language that were discussed during the workshop and a document
describing Staff s rationale for each section for the proposed IPUC WMP Compliance Report
Standards. The purpose of the strawman was to encourage discussion during the second workshop.
1 Interested parties in attendance were Avista Corporation,Clearwater Power Company,CTIA—The Wireless
Association,Idaho Consumer Owned Utilities Association,Idaho Department of Lands,City of Idaho Falls,Idaho
Power Company,Kootenai Electric Cooperative,Lost River Electric Cooperative,Lower Valley Energy,Northern
Lights Inc.,PacifiCorp dba Rocky Mountain Power,PotlatchDeltic Corp.,and Raft River Rural Electric Co-Op.
11331 W.Chinden Blvd.,Building 8 Suite 201-A,Boise ID 83714
Telephone:[phone] Facsimile:[phone]

Commission Secretary
Idaho Public Utilities Commission
December 31, 2025
Page 2
On December 1, 2025, Staff held the second virtual workshop with 38 participants
representing 16 interested parties.2 During the workshop, Staff and the interested parties discussed
Staff s strawman proposal of the IPUC WMP Compliance Report Standards.
Incorporating the discussion about proposed language and topics from the workshops, Staff
respectfully submits this filing in compliance with Order No. 36774.
Workshop Discussion
During the workshops, the topic of filing dates for the compliance reports festered
discussion from the three large investor-owned utilities ("IOUs"). The IOUs requested to have a
consistent filing date for compliance reports that provided adequate timing for the electric
corporations to finalize year-end data. Other parties did not provide any input on this topic.
Staff received either no comments or general support from interested parties on the
proposed language for compliance reports for filing dates, the consistency in language, and
consistency in formatting.
The Commission ordered parties to discuss in the workshops"consistency in language and
formatting for all WMPs." Order No. 36774 at 20. As the proposed standards were focused on
compliance reporting, Staff did not include its two recommendations on the topics above for all
WMPs. However, to address these topics, Staff has two recommendations to the Commission, in
which the interested parties during the workshop either did not comment or provided general
support. Therefore, Staff recommends the Commission to order that: (1)each electric corporation
include a glossary within each WMP that defines the utility's terms, and those terms should be
consistent with the Wildfire Standard of Care Act, Idaho Code § 61-1803 and with the IPUC
Guidelines (Commission Order No. 36774, Exhibit B) and (2) the format of the WMP must be
consistent with the Wildfire Standard of Care Act, Idaho Code § 61-1803 and IPUC WMP
Guidelines. Details of the WMPs format will be left to each utility.
2 Interested parties in attendance were Avista Corporation,Clearwater Power Company,CTIA—The Wireless
Association,Idaho Consumer Owned Utilities Association,Idaho County Light and Power,Idaho Department of
Lands,City of Idaho Falls,Idaho Power Company,Kootenai Electric Cooperative,Lost River Electric Cooperative,
Lower Valley Energy,Northern Lights Inc.,PacifiCorp dba Rocky Mountain Power,PotlatchDeltic Corp.,Raft
River Rural Electric Co-Op,and United Electric Cooperative.
11331 W.Chinden Blvd.,Building 8 Suite 201-A,Boise ID 83714
Telephone:[phone] Facsimile:[phone]

Commission Secretary
Idaho Public Utilities Commission
December 31, 2025
Page 3
In the first workshop,parties discussed the reasoning for and against the fire reporting topic
to be included within a compliance report. Parties believed there were other ways to show
implementation and performance of a WMP. Following the input of most of the parties, the fire
reporting topic was not included in the Staff strawman. In the second workshop,the discussion of
not including fire reporting received support from parties. Although it is not included within the
proposed standards, Staff believes fire reporting is a more appropriate topic to ask within a case
while evaluating a WMP through different performance metrics during the Commission's review.3
While agreeing to exclude this topic in compliance reports, two parties encouraged Staff to
consider the size of an electric corporation and encouraged Staff to develop performance metrics
with collaboration of all electric corporations.4
Monthly Compliance Targets and Expenditures
The two topics that had the most discussion were monthly compliance targets and
expenditures. Idaho Code § 61-1803(5) requires the compliance report to include documentation
describing "...wildfire mitigation expenditures, and the work taken to adopt wildfire mitigation
components and measures. " In the first workshop, the electric municipalities and cooperatives
expressed the burden of breaking yearly goals into monthly goals and requested further explanation
how the granular data was necessary. Additionally, a party suggested the language shift from
monthly to seasonal. In Staff s strawman, there was language incorporated for the suggested
seasonal option.
In the second workshop, further discussion of Staffs rationale was requested. Staff
believes it is necessary for the compliance reports to include granular data beyond a yearly
target/goal or annual cost forecast to exemplify the electric corporation's progress made towards
the goals set within the approved-WMP throughout the year. Also, the granular data will aid with
Staff s and other stakeholders'understanding of the feasibility of the approved WMP and will help
inform any changes to the next WMP. Further, Staff believes granular data provided as either
monthly, quarterly, or meteorological season rather than yearly would be a benefit to the electric
'Idaho Code§ 61-1804 requires the Commission to consider the degree to which the plan adequately minimizes
wildfire risk.
4 City of Idaho Falls and Kootenai Electric Cooperative.
11331 W.Chinden Blvd.,Building 8 Suite 201-A,Boise ID 83714
Telephone:[phone] Facsimile:[phone]

Commission Secretary
Idaho Public Utilities Commission
December 31, 2025
Page 4
corporations that wish to file WMPs, as granular data would help with explanations of any
differences between an approved-WMP and actual results.
Idaho Code § 61-1806 provides utilities with an approved WMP with a "rebuttable
presumption that the electric corporation acted without negligence if, with respect to the cause of
the wildfire, the electric corporation reasonably implemented a commission approved wildfire
mitigation plan." To meet the intent of the law, Staff believes it is necessary for electric
corporations to exemplify how its WMP was implemented throughout the year, as compared to
showing only an annual check off. Staff believes the proposed language would also comply with
the legislative requirements of Idaho Code § 61-1803(5).
Proposed Compliance Report Standards
Following the second workshop, on December 4, 2025, Staff sent the interested parties its
proposal of IPUC WMP Compliance Report Standards. Staff requested each party sign the
proposal if they agreed with the proposed standards. Attached as Exhibit No. 1 is the proposed
IPUC WMP Compliance Report Standards that Staff recommends being adopted by the
Commission with the signatures from five of the parties.
As of December 18, 2025, Avista Corp, PacifiCorp, Idaho Power Company, Lost River
Electric Cooperative, and Northern Lights, Inc. have signed the proposed standards, intending to
show support of the proposed IPUC WMP Compliance Report Standards. PotlatchDeltic provided
a letter of agreement with Staff s proposed IPUC WMP Compliance Report Standards; however,
the party did not wish to sign the document at this time. See Exhibit No. 2.
Staff respectfully recommends the Commission adopt the proposed IPUC WMP
Compliance Report Standards in Exhibit No. 1 and order the following:
(1) Each electric corporation include a glossary within each WMP that defines the utility's
terms, and those terms should be consistent with the Wildfire Standard of Care Act,Idaho Code §
61-1803 and with the IPUC WMP Guidelines (Commission Order No. 36774, Exhibit 13); and
11331 W.Chinden Blvd.,Building 8 Suite 201-A,Boise ID 83714
Telephone:[phone] Facsimile:[phone]

Commission Secretary
Idaho Public Utilities Commission
December 31, 2025
Page 5
(2) The format of the WMP must be consistent with the Wildfire Standard of Care Act,
Idaho Code § 61-1803 and IPUC WMP Guidelines. Details of the WMPs format will be left to
each utility.
Sincerely,
Chris Burdin
Deputy Attorney General for Commission Staff
11331 W.Chinden Blvd.,Building 8 Suite 201-A,Boise ID 83714
Telephone:[phone] Facsimile:[phone]

Proposed
IPUC Wildfire Mitigation Plan
Compliance Report Standards
EXHIBIT NO. 1
Proposed - IPUC Wildfire Mitigation Plan Compliance Reports Standards Case No. GNR-E-25-02
12/31/25 Compliance Filing
December 31, 2025

I.C. § 61-1803(5)
"An electric corporation with a commission-approved wildfire mitigation plan shall
submit a report to the commission updating the commission on the electric
corporation's compliance with its wildfire mitigation plan on an annual basis or on
such other basis as the commission may prescribe by rule or order. The report shall
include documentation describing the development and adoption of the wildfire
mitigation plan's components and measures, the wildfire mitigation expenditures,
and the work taken to develop and adopt the plan's components and measures."
Filing Requirements
Beginning in 2027, each electric corporation must file its compliance report of a Commission-
approved Wildfire Mitigation Plan ("WMP") no later than June 1 each calendar year. The
compliance report should be filed under the most recently approved-WMP docket.
Format for the Compliance Report
The format of the Compliance report must be consistent with the Wildfire Standard of
Care Act and IPUC Guidelines.
Additionally, each compliance report should contain the following: (1) a table of
contents, (2) an introduction section, (3) dedicated sections for each category of the WMP, and
(4) any other sections at the discretion of the electric corporation.
The introduction section should include: (1)high-level descriptions of the WMP's
development, adoption, and expenditures and(2) a crosswalk table for each I.C. §§ 61-1803(3)
and 61-1803(5)requirements and IPUC Guidelines is met within the compliance report.
Each dedicated section should include detailed information on categories of the WMP
such as metrics, actual expenses, explanations for any discrepancies between WMP goals and
actuals, and explanations of which I.C. §§ 61-1803(3) and 61-1803(5) requirements and IPUC
Guidelines is met within each section.Any measurable data should be included within each
section.
EXHIBIT NO. 1
Case No. GNR-E-25-02
Proposed -IPUC Wildfire Mitigation Plan Compliance Reports Standards Compliance Filing
12/4/25 December 31, 2025

Laniune for Compliance Reports
• Language to be consistent with:
o The Wildfire Standard of Care Act(I.C. § 61-1803);
o The IPUC Guidelines (Commission Order No. 36774, Exhibit B); and
o The electric corporation's Commission-approved WMP glossary.
Compliance Targets
I.C. § 61-1803(5): "The report shall include...the work taken to adopt wildfire mitigation
components and measures."
The electric corporation must include within its compliance reports actual progress toward
goals set within the approved WMP with explanations for any delays or modifications to electric
corporation-planned and commission-approved goals. The data should be tracked relative to the
WMP category with sufficient granularity to show substantial compliance with the approved WMP
throughout the year. The data could be broken down monthly or quarterly.
Expenditures
Commission Order No. 36774 ordered cost forecasts to be included within WMPs,
included in Exhibit B page 8. Wildfire mitigation expenditures are required to be reported by I.C.
§ 61-1803(5).
The electric corporation must include within its compliance reports actual expenditures
spent towards the approved WMP components. The expenditures should be tracked relative to the
WMP category with sufficient granularity to show substantial compliance with the approved WMP
throughout the year. The data could be broken down monthly or quarterly.
EXHIBIT NO. 1
Proposed - IPUC Wildfire Mitigation Plan Compliance Reports Standards Case No. GNR-E-25-02
12/4/25 Compliance Filing
December 31, 2025

Party Agreement
Atlanta Power Company Avista Corporation
12/09/2025
Date Date
Bennet Lumber, IFG, MIM, Molpus Clearwater Power Company
Woodlands Group, and Stimson Lumber
Date Date
City of Bonners Ferry City of Idaho Falls
Date Date
CTIA—The Wireless Association Idaho County Light and Power
Date Date
Idaho Department of Lands Idaho Power Company
Date Date
EXHIBIT NO. 1
Staff Proposal-IPUC Wildfire Mitigation Plan Compliance Reports Standards Case No. GNR-E-25-02
12/4/25 Compliance Filing
December 31, 2025

Party Agreement
Atlanta Power Company Avista Corporation
Date Date
Bennet Lumber,IFG,MIM,Molpus Clearwater Power Company
Woodlands Group, and Stimson Lumber
Date Date
City of Bonners Ferry City of Idaho Falls
Date Date
CTIA—The Wireless Association Idaho County Light and Power
Date Date
Idaho Department of Lands Id ho Pow r Company
Date Date 12/11/2025
EXHIBIT NO. 1
Staff Proposal-IPUC Wildfire Mitigation Plan Compliance Reports Standards Case No. GNR-E-25-02
12/4/25 Compliance Filing
December 31, 2025

Fall River Rural Electric Cooperative Kootenai Electric Cooperative
Date Date
Lost River Electric Cooperative Lower Valley Energy
Date Date
Northern Lights, Inc. PacifiCorp,dba Rocky Mountain
Power
12/11/25
Date Date
PotlatchDeltic Corp. Raft River Rural Electric Co-Op
Date Date
United Electric Cooperative U.S.Telecom—The Broadband
Association
Date Date
EXHIBIT NO. 1
Staff Proposal-IPUC Wildfire Mitigation Plan Compliance Reports Standards Case No. GNR-E-25-02
12/4/25 Compliance Filing
December 31, 2025

f
R
i,
Fall River Rural Electric Cooperative Kootenai Electric Cooperative
Date Date
Lost River E ectric Cooperative Lower Valley Energy
12 ]CEc— 2U25--
Date Date
Northern Lights, Inc. PacifiCorp, dba Rocky Mountain
Power
Date Date
PotlatchDeltic Corp. Raft River Rural Electric Co-Op
Date Date
United Electric Cooperative U.S.Telecom—The Broadband
Association
Date Date
Staff Proposal-IPUC Wildfire Mitigation Plan Compliance Reports Standards
12/4/25
EXHIBIT NO. 1
Case No. GNR-E-25-02
Compliance Filing
December 31,2025

Fall River Rural Electric Cooperative Kootenai Electric Cooperative
Date Date
Lost River Electric Cooperative Lower Valley Energy
Date Date
Northern 6 ,Inc. PacifiCorp,dba Rocky Mountain
Power
� I �
Date Date
PotlatchDeltic Corp. Raft River Rural Electric Co-Op
Date Date
United Electric Cooperative U.S.Telecom—The Broadband
Association
Date Date
Staff Proposal-IPUC Wildfire Mitigation Plan Compliance Reports Standards EXHIBIT NO. 1
12/4/25 Case No. GNR-E-25-02
Compliance Filing
December 31,2025

Chris Burdin
Commission Staff
December 31, 2025
Date
EXHIBIT NO. 1
Case No. GNR-E-25-02
Staff Proposal - IPUC Wildfire Mitigation Plan Compliance Reports Standards Compliance Filing
12/4/25 December 31, 2025

A T T O R N E Y S A T L A W
515 N.27th Sheet.Boise.ID 83702
Tel-208-398-1900 Fax-'-08-398-7904
richardsonadams.com
December 12, 2025
VIA ELECTRONIC MAIL
Kimberly Loskot
Utilities Analyst
Adam Triplett, Esq.
Deputy Attorney General
Idaho Public Utilities Commission
[e-mail]
[e-mail]
Re: GNR-E-25-02—Staff Proposal for WMP Compliance
Ms. Loskot and Mr. Triplett:
I write on behalf of my client,PotlatchDeltic Corporation, in response to your email dated
December 5, 2025,regarding the above-referenced Staff proposal for establishing standards that are
applicable to electric corporations' WMP compliance reports. The PUC Staff is to be commended
for their tenacity and comprehensive efforts in drafting the proposed WMP Compliance Report
Standards. Your principled adherence to both the intent and the letter of the Wildfire Standard of
Care Act's requirements—particularly with respect to reporting progress and expenditures—is
commendable.
You are authorized to report to the Commission that, as of this writing, PotlatchDeltic
Corporation agrees with Staff s proposed compliance reporting standards referenced above.
However, PotlatchDeltic Corporation specifically reserves its ongoing ability and obligation to
recommend variances or additions to the Standards as new issues and nuances (will inevitability)
arise during implementation of the WMP reporting process—hence we will not be signing onto the
"Proposed IPUC Wildfire Mitigation Plan Compliance Report Standards"report dated 12/4/25.
Please feel free to give me a call if you have any questions or would like to discuss
PotlatchDeltic's position in more detail.
Sincerely,
EXHIBIT NO. 2
Case No. GNR-E-25-02
Compliance Filing
December 31,2025

PotlatichDeltic Corporation
Page 2
Peter J. Richardson
RICHARDSON ADAMS, PLLC
CC: Parties of Record
EXHIBIT NO. 2
Case No. GNR-E-25-02
Compliance Filing
December 31,2025

CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 31' day of December 2025, I served the foregoing
STAFF'S COMPLIANCE FILING, in Case No. GNR-E-25-02, via Electronic Mail to the
following:
Idaho Power Company: PacifiCorp d/b/a Rocky Mountain Power:
Megan Goicoechea Allen maoicoecheaallenkidahopower.com Joe Dallas [e-mail]
Donovan Walker dwalker e,idahopower.com Mark Alder mark.alder(kpacificorp.com
Lisa C. Lance llance e,idahopower.com datarequest(cr�pacificorp.com
Matt Larkin [e-mail]
Connie Aschenbrenner [e-mail]
Tim Tatum ttatum(kidahopower.com
Riley Maloney [e-mail]
docketskidahopower.com
Avista Corporation: Atlanta Power:
Anni Glogovac anni.glo og [e-mail] Nick Jones [e-mail]
Elizabeth Andrews liz.andrews(cr�,avistacorp.com
avistadockets(kavistacorp.com
Raft River: Lower Valley Energy:
Chad Black cblack(krrelectric.com Jim Webb jim( ivenergy.com
City of Bonners Ferry: Idaho County Light& Power:
Mike Klaus mklaus(kbonnersferry.id.gov Max Beach mbeach(kiclp.coop
Fall River Electric: Idaho Falls Power:
Bryan Case bryan.casekfallriverelectric.com Jacob S. Beck jbecknidahofalls.gov
Linden Barney linden.bamey(kfallriverelectric.com Zachary H. Jones zjones e,idahofalls.gov
Randy Wakefield [e-mail] Stephen Boorman sboormankifpower.org
David Peterson dave.petersonkfallriverelectric.com
Northern Lights,Inc.: Kootenai Electric Cooperative:
Annie Terracciano annie.terraccianoknli.coop Michael G.Andrea [e-mail]
Kristin Burge kristin.burge(knli.coop Thomas Maddalone tmaddalone(kkec.com
Trevor Kelly trevor.kelly(knli.coop
Lost River Electric Cooperative: Clearwater Power:
Brad Gamett brad(klrecoop.com Tell Stanger tstanger(kclearwaterpower.com
United Electric: Idaho Consumer-Owned Utilities Association:
Michael Darrington mdarrin ton e,uec.coop Will Hart whart(kicua.coop
Idaho Department of Lands: CTIA—The Wireless Association:
J.J.Winters jwinterskidl.idaho.gov Matthew DeTura [e-mail]
Tyre Holfeltz tholfeltz(kidl.idaho.gov Benjamin Aron Baron e,ctia.org
PAGE 1 OF 2 CERTIFICATE OF SERVICE

PotlatchDeltic Corp: Bennett Lumber Products,Inc.,Idaho Forest
Peter J. Richardson peter ckrichardsonadams.com Group,Manulife Investment Management,
Michele Tyler michele. , lerki2otlatchdeltic.com Molpus Woodlands Group,and Stimson
Anna Torma anna.torma(crpotlatchdeltic.com Lumber Company:
Wade Semeliss wade.semelisskpotlatchdeltic.com Pendrey P.Trammell service(cr�,smithmalek.com
Brian Schlect brian.schlectkpotlatchdeltic.com
Jeremy Pisca jpiscagrischpisca.com
US Telecom—The Broadband Association:
B. Lynn Follansbee lfollansbee(kustelecom.org
Kathleen Slatterly Thompson ksthompson e,ustelecom.org
PATRICIA JORDA , SECRETARY
PAGE 2 OF 2 CERTIFICATE OF SERVICE