20251219Comment_1.pdf

Idaho Department of Lands State Board of Land Commissioners
General Counsel Brad Little, Governor
300 N. 6th Street, Suite 103 Phil McGrane, Secretary of State
P.O. Box 83720 Raul R. Labrador, Attorney General
Boise, ID 83720-0050 Brandon D Woolf, State Controller
Phone [phone] Debbie Critchfield, Sup't Public Instruction
Fax [phone] Dustin T. Miller, Director
Working Lands, Trusted Stewards RECEIVED
December 19, 2025
December 19, 2025 IDAHO PUBLIC
UTILITIES COMMISSION
Commission Secretary
Idaho Public Utilities Commission
via email: [e-mail]
Re: 2026 Avista Corporation Wildfire Mitigation Plan
Dear Ms. Robles:
The purpose of this letter is to confirm that Idaho Department of Lands received notice of Avista
Corporation's 2026 Wildfire Mitigation Plan dated December 9, 2025, and does not intend to
formally intervene in the matter.
The Wildfire Standard of Care Act, Idaho Code § 61-1804 provides the following:
In reviewing a plan, the commission shall consult with the interested entities listed in
subsection (2) of this section for technical assistance. With respect to elements of the
plan that relate to vegetation management, reduction of wildfire fuels, and other
duties of the state forester under title 38, Idaho Code, it shall be presumed that the
recommendations of the state forester, if any are provided, are reasonable and
appropriate.
I.C. § 61-1804(3). After consultation with IPUC and reviewing guidance from DAG Adam Triplett,
it appears that the statute does not require the State Forester to formally intervene in each WIMP
case. Instead, the statute simply requires the commission to consult with the State Forester for
technical assistance, including recommendations regarding the elements of each plan that relate
to vegetation management and reduction of wildfire fuels. As such, IDL does not intend to file a
petition to intervene in this or other matters, unless IDL determines that intervention is necessary.
Ms. Lauch and Mr. Holfeltz will be available for consultation regarding this and future plans and
look forward to providing technical assistance as needed. Please feel free to reach out to me for
any further questions or discussion.
Very truly yours,
J.J. Winters, Attorney
Idaho Department of Lands
ec: Julia Lauch, jlauch(d)idl.idaho.gov; Tyre Holfeltz, tholfeltz(d)idl.idaho.gov; Anni Glogovac,
anni.glogovacC�avistacorp.com; Elizabeth Andrews, Iiz.andrewsCa)avistacorp.com