20260108Comment_1.pdf

From: David Mangold <[e-mail]>
Sent:Thursday, January 8, 2026 2:23 PM
To: secretary<[e-mail]>
Subject: Case IPC-E-25-32
January 8, 2026
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Building 8, Suite 201-A
Boise, Idaho 83714
RE: Case No. IPC-E-25-32- Public Comment on Idaho Power Company Wildfire
Mitigation Plan
Dear Commissioners:
I submit this comment in support of Idaho Power's Wildfire Mitigation Plan and to
recommend the Commission consider blockchain-based verification infrastructure as a
mechanism to strengthen implementation accountability under SB 1183, the Wildfire
Standard of Care Act.
Yesterday marked the one-year anniversary of the Palisades Fire in California, which killed
12 people and destroyed over 6,800 structures. Congressional investigations by Senators
Rick Scott and Ron Johnson have documented that utilities knew about equipment hazards
but lacked systematic verification that field observations translated into completed
remediation.The resulting liability uncertainty has bankrupted utilities, driven insurance
costs to crisis levels, and left communities unable to rebuild.
Idaho's SB 1183 represents a forward-thinking approach: utilities that reasonably
implement Commission-approved mitigation plans receive a rebuttable presumption of
non-negligence. This framework correctly balances utility accountability with protection
against unfair liability claims. However, the effectiveness of this safe harbor depends
entirely on utilities' ability to prove they"reasonably implemented"their approved plans.
The Verification Gap
Traditional documentation systems create a verification gap that undermines both utility
protection and public accountability:
First, database records can be modified after the fact. In litigation, timestamps can be
disputed, entries altered, and records questioned. This creates years of forensic IT analysis
and expert witness battles, exactly the litigation uncertainty SB 1183 seeks to prevent.
Second, field worker observations are often fragmented across different crews, shifts, and
supervisors. A hazard reported by one crew may not trigger coordinated response, and
there is no systematic way to detect geographic patterns of escalating risk.
Third, when fires do occur, determining whether a utility"reasonably implemented" its
mitigation plan requires months or years of document discovery, during which
communities cannot rebuild and utilities cannot resolve liability exposure.
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Blockchain Verification as Implementation Proof
Blockchain-anchored verification addresses these gaps by creating immutable,
timestamped records of mitigation activities that cannot be altered by any party after the
fact. The technology works as follows:
Anonymous Worker Reporting: Field crews use mobile applications to report both safe
conditions and observed hazards. Reports are cryptographically hashed and anchored to
blockchain within milliseconds, creating tamper-proof timestamps.
Why Anonymity is Essential:The Eaton Fire Evidence
The Eaton Fire provides stark evidence of what happens when workers lack protected
channels to report hazards. Congressional and journalistic investigations have established
that zero utility worker reports existed before the fire ignited at 6:18 PM on January 7,
2025. This was not a gap in released evidence—it was a gap in what was ever collected.
Meanwhile, independent data sources documented extensive electrical failures
throughout that day:
Independent sensors detected transmission line faults at 4:28 AM and 4:36 AM—over 13
hours before the fire. Distribution lines across Los Angeles malfunctioned over 200 times
that day, compared to a typical maximum of 18. Los Angeles County Fire Department
dispatch records show 30 dispatches for"wires down or arcing" in Altadena before 6 PM. At
approximately 4:20 PM, a separate fire ignited from sparking distribution lines in West
Altadena—nearly two hours before the main blaze—yet investigative reporting found this
fire was not listed in the utility's ignition reports.
The utility's explanation for the missing fire report is telling: "Appropriate SCE personnel
must be made aware of the ignition in order for it to be reported:'This reveals the systemic
problem: when workers fear retaliation for reporting hazards, observations never enter
official documentation systems. The utility can claim ignorance because no record exists—
not because no hazard was observed.
Notably, the only documented worker observation from the Eaton Canyon area came
twelve days after the fire, during a January 19 re-energization test when technicians
observed "flashes of white light" on idle transmission lines. When workers were specifically
assigned to observe and report—with institutional backing—they documented exactly what
they saw. Before the fire, no such system existed.
Anonymous reporting addresses this directly. Workers who observe deteriorating
equipment,vegetation encroachment, or fire conditions can document hazards without
fear of termination or career consequences. The blockchain timestamp proves when the
utility received notification, eliminating the "we didn't know" defense while protecting the
worker's identity. Utilities that respond appropriately have cryptographic proof of due
diligence; utilities that ignore verified patterns create documented evidence of negligence.
Pattern Detection:Aggregated reports enable identification of geographic clusters and
escalating risk patterns that individual observers cannot detect. When multiple equipment
degradation reports concentrate in a specific area, the system flags elevated risk requiring
intervention.
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Work Verification Loop:When hazards are identified, work orders are created with
cryptographic signatures. Crews document completion with GPS-verified, timestamped
photo evidence. The entire chain from hazard identification through verified remediation is
blockchain-anchored.
Supporting SB 1183's Framework
Blockchain verification strengthens rather than burdens SB 1183's liability framework:
For utilities: "We identified the risk, deployed crews, and verified completion" becomes
mathematically provable rather than litigatable. The rebuttable presumption becomes
effectively irrebuttable when backed by cryptographic proof.
For ratepayers:Verification infrastructure prevents the reactive bailout spending that
follows catastrophic liability judgments. California ratepayers fund a $21 billion wildfire
Liability fund because utilities could not prove systematic risk management.
For insurers:Verifiable implementation data enables accurate risk pricing rather than
worst-case assumptions. This keeps insurance markets functional in high-risk areas.
For the Commission: Blockchain-verified compliance documentation provides objective
evidence when evaluating whether a utility has met its mitigation plan commitments,
reducing reliance on self-reported metrics.
Recommendation
I respectfully recommend the Commission consider requiring or incentivizing blockchain-
based verification infrastructure as part of approved wildfire mitigation plans. Such
systems are being built today and integrate with existing utility enterprise asset
management platforms. Implementation would strengthen the evidentiary foundation
underlying SB 1183's safe harbor provision while providing the Commission with verifiable
compliance data.
Idaho has the opportunityto lead Western states in implementing verification
infrastructure before a catastrophic fire forces reactive measures. I would welcome the
opportunity to provide technical specifications or demonstration of operational blockchain
verification platforms.
Thankyou forthe opportunityto comment on this important proceeding.
Respectfully submitted,
David Mangold
Founder, GetVer.io
Fenris LLC
Twin Lakes, Wisconsin
[e-mail]
414-233-2670
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