Loading...
HomeMy WebLinkAbout20260202Application.pdf C 10-E-26-01 RECEIVED FEBRUARY 2, 2026 C IDAHO PUBLIC UTILITIES COMMISSION 1'he power of local service Northern Lights, Inc. Wildfire Mitigation Plan January 14, 2026 1.0 Executive Summary Northern Lights, Inc. (NLI) operates distribution infrastructure in Washington, Montana and Idaho.This plan is based on the Washington template and has been updated to include requirements within Montana and Idaho as well. The Washington Legislature passed House Bill 1032 in July 2023. By October 31, 2024, and every three years thereafter, each consumer-owned utility and investor-owned utility must review, if appropriate revise, and adopt its wildfire mitigation plan. When reviewing or revising a wildfire mitigation plan, utilities must use the recommended format and elements contained in the Wildfire Mitigation Plan (WMP)format.The plan must be submitted to the Washington utility wildland fire prevention advisory committee created in RCW 76.04.780 to be posted on their website. Under Idaho code section 61-1804, NLI will elect to file a Wildfire Mitigation Plan with the Idaho Public Utilities Commission (IPUC) initially in 2026. Annually NLI will review, update, and file its WMP along with filing a report describing the development and adoption of the wildfire mitigation plan's component and measures,the WMP expenditures, and the work taken to develop and adopt the plan's components and measures. Under Montana HB 490 passed in May of 2025, NLI will submit an initial WMP with Montana no later than December 31, 2025. NLI must seek public comment as part of the process. NLI will resubmit an updated or subsequent WMP for approval to its board every 3 years. 1.1 Definitions Wildfire Mitigation Plan (WMP):This plan. PSPS: Public safety power shutoff.A temporary power outage initiated by an electric utility to reduce the risk of wildfires during extreme fire risk. RCW: Revised Code of Washington state. Recloser: A recloser is an automatic, high-voltage electric switch which de-energizes the affected portion of the power system when a fault, such as a tree falling into an electric power line, occurs. System protection devices: Equipment such as relays, circuit breakers, and fuses that automatically detect abnormal conditions (faults) and isolate the fault to prevent widespread damage or safety issues. SCADA: Supervisory Control and Data Acquisition is a computer-based system for monitoring and controlling electrical components on a power system.This system gathers real-time data from field equipment. WAC: Washington Administrative Code ii Table of Contents Section Page 1.0 Executive Summary............................................................................................................ii 1.1 Definitions...................................................................................................................... ii 2.0 Wildfire Mitigation Plan Overview................................................................................... 1 2.1 Purpose of the Wildfire Mitigation Plan.........................................................................1 2.2 Description of Where WMP Can be Found Online........................................................1 3.0 Utility Overview...................................................................................................................2 3.1 Utility Description and Context Setting Table................................................................2 4.0 Objectives of the Wildfire Mitigation Plan.......................................................................5 4.1 Minimizing likelihood of ignition...................................................................................5 4.2 Resiliency of the electric grid .........................................................................................5 5.0 Roles and Responsibilities ..................................................................................................5 5.1 Utility Roles and Responsibilities...................................................................................6 5.2 Coordination with local utility and infrastructure providers...........................................6 5.3 Coordination with local Tribal entities ...........................................................................6 5.4 Emergency Management/Incident Response Organization..........................................6 6.0 Wildfire Risks and Drivers Associated with Design, Construction, Operation, andMaintenance................................................................................................................. 6 6.1 Risks and risk drivers associated with topographic and climatological risk factors.......9 6.2 Enterprise-wide Safety Risks..........................................................................................9 7.0 Wildfire Preventative Strategies........................................................................................9 7.1 Weather Monitoring........................................................................................................9 7.1.1 Current Strategy Overview....................................................................................9 7.1.2 Planned Updates..................................................................................................10 7.2 Design and Construction Standards..............................................................................10 7.2.1 Current Strategy Overview..................................................................................10 7.2.2 Planned Updates..................................................................................................10 7.3 Fuel & Vegetation Management...................................................................................10 7.3.1 Current Strategy Overview..................................................................................10 7.3.2 Planned Updates..................................................................................................11 7.4 Asset Inspections and Response....................................................................................11 7.4.1 Current Strategy Overview..................................................................................11 7.4.2 Planned Updates..................................................................................................11 7.5 Workforce training........................................................................................................12 7.5.1 Current Strategy Overview..................................................................................12 7.5.2 Planned Updates..................................................................................................12 7.6 Relay and Recloser Practices........................................................................................12 7.6.1 Current Strategy Overview..................................................................................12 7.6.2 Planned Updates..................................................................................................12 7.7 De-energization/Public Safety Power Shutoff............................................................12 7.7.1 Current Strategy Overview..................................................................................12 7.7.2 Planned Updates..................................................................................................12 iii 8.0 Community Outreach and Public Awareness ................................................................ 13 8.1 Current Community Outreach and Public Awareness Program ...................................13 8.2 Planned Updates............................................................................................................13 9.0 Restoration of Service....................................................................................................... 13 10.0 Evaluating the Plan........................................................................................................... 14 10.1 Metrics and Assumptions for Measuring Plan Performance.........................................14 10.2 Identifying and Addressing Areas of Continued Improvement in the Plan..................15 10.3 Monitoring the Performance of Inspections..................................................................15 11.0 Cost Evaluation ................................................................................................................. 16 11.1 Cost vs. Benefit Approach............................................................................................16 iv 2.0 Wildfire Mitigation Plan Overview 2.1 Purpose of the Wildfire Mitigation Plan The purpose of this Wildfire Mitigation Plan(WMP) is to document the strategies, programs, and procedures in place to mitigate the threat of electrical equipment ignited wildfires by Northern Lights, Inc. (NLI). The WMP addresses the unique features of its service territory, such as topography, weather, infrastructure, grid configuration, and areas most prone to wildfire risks. The plan includes the maintenance of its transmission and distribution assets, as well as the management of vegetation in the right-of-way (ROW) areas that contain these assets. The WMP is a living document that will be reassessed routinely as projects and initiatives are proposed and completed. Primary accountability for plan implementation resides with the General Manager. 2.2 Description of Where WMP Can be Found Online The WMP will be made available publicly on the Washington utility wildland fire prevention committee website under RCW 76.04.780. 1 3.0 Utility Overview 3.1 Utility Description and Context Setting Table Table 1. Context-Setting Information Table Utility Name Northern Lights, Inc. Service Territory Size (sq miles) Washington: 20 Idaho: 3,000 Montana: 2,500 TOTAL: 5,520 Service Territory Make-up NLI's Overall Service Area(ID, MT, & WA) (Note: data are from national land cover database from USGS.gov, 3%Urban not all categories represented in this template) 2%Agriculture 1% Barren/Other 78% Conifer Forest 3.5%Herbaceous 10.7% Shrub 1.8%Water Washington ONLY: 0.1%Urban * Sum of Developed 0.2%Agriculture * Hay/Pasture 97% Conifer Forest *Evergreen Forest 0.7%Herbaceous *Herbaceous 2% Shrub * Shrub/Scrub Service Territory Wildland Urban Interface (based on total NA/Not tracked. area) Customers Served Idaho: 18,838 (Note: NLI considers customers as members) Montana: 4,971 2 Washington: 19 (As of August 2024) Account Demographic Washington is 100%residential. [Note: Please provide as a percent of total customers served] NLI overall: Type Count Irrigation 52 0.21 Large Commercial 15 0.06 Large Power 45 0.19 Primary 7 0.03 Residential 23050 94.83 Security and Street Lights 348 1.43 Small Commercial 789 3.25 Utility Equipment Make-up (circuit miles) Overhead Distribution is 7- 34.5 Kv [Line miles are calculated using data from the Engineering Model's Overhead Transmission is > 34.5Kv GIS data length field. GIS uses the NAD 83 State Plane Idaho West Underground Distribution is 7- 34.5 Kv FIPS 1103 coordinate System.] Underground Transmission is > 34.5Kv Washington Overhead Distribution: 5.40 miles Overhead Transmission: 0 3 Underground Distribution: .61 miles Underground Transmission: 0 Total System (WA,ID, MT) 5,280 Overhead Distribution: 1345.93 miles Overhead Transmission: 47.79 miles Underground Distribution: 1266.25 miles Underground Transmission: .50 miles Has developed protocols to pre-emptively shut off electricity in Yes. response to elevated wildfire risks?' See Section 7. No. Has previously pre-emptively shut off electricity in response to elevated wildfire risk? 1 For many utilities this will be a reference to a Public Safety Power Shutoff(PSPS)event.These events,whether through a formally defined PSPS program or not,are recognized as a safety measure of last resort initiated by utilities to pre-emptively de-energize specific powerlines during critical fire weather to reduce the risk of the electric system being involved in an ignition.The decision to either have or not have this type of practice is at the operational discretion of the individual utility. 4 Northern Lights, Inc. Wildfire Mitigation Plan January 14, 2026 4.0 Objectives of the Wildfire Mitigation Plan The objective of the WMP is to minimize the possibility that NLI facilities may be an original or contributing source of ignition and to improve NLI's ability to withstand fire weather conditions and quickly recover services. NLI has evaluated the system improvements, technology, operational procedures, and training that can help to meet this objective. The WMP was developed to be consistent with requirements of Washington, Idaho, and Montana. 4.1 Minimizing likelihood of ignition The WMP describes the range of activities that NLI is taking or considering to mitigate the threat of power-line ignited wildfires, including its various programs, policies, and procedures. The plan will be iterative,promote continuous improvement, and represent NLI's efforts to implement industry best practices in a reasonable manner. This WMP also establishes methods and procedures used to construct, maintain, and operate NLI's electrical system and equipment to minimize the risk of wildfire. 4.2 Resiliency of the electric grid NLI's design and construction of its distribution and transmission systems and equipment is intended to reduce the likelihood of ignition and improve electrical asset survivability. System hardening investments are evaluated on a case-by-case basis. When prudent,NLI utilizes system hardening measures including: • Stronger or metal poles to address engineering standards that exceed code requirement. • Shorter span length and larger spacing between energized conductors to reduce mid-span conductor contact. • Relocate utility poles closer to the road to enhance access. • Strategic undergrounding in areas prone to repeated outages due to tree exposure. 5.0 Roles and Responsibilities NLI utilizes a Board/General Manager governance and reporting hierarchy. Board members are elected by NLI member owners to a rotating four-year term. NLI's Board will be responsible for approving the WMP2. NLI will also submit the plan to the Idaho Public Utilities Commission for approval. NLI staff, including the General Manager and the Engineering & Operations Manager, will be responsible for implementation and updating the WMP. 2 Washington and Montana require the WMP to be board approved.For Idaho,NLI will submit the plan to the Idaho Public Utilities Commission for their approval. 5 Northern Lights, Inc. Wildfire Mitigation Plan January 14, 2026 5.1 Utility Roles and Responsibilities NLI employees have the following responsibilities regarding fire prevention and response: - Conduct work in a manner that will minimize potential fire dangers. - Take reasonable and practical actions to prevent fires caused by NLI electric infrastructure. - Immediately report any observed fires and if possible, extinguish them. - Take corrective action if infrastructure or a ROW becomes a wildfire hazard. - Ensure data related to WMP are appropriately collected and documented. - Provide feedback to management on the WMP and strategies to improve the WMP. - Consider wildfire mitigation costs,benefits and risk to make prudent decisions. 5.2 Coordination with local utility and infrastructure providers NLI will coordinate its WMP with other utilities and infrastructure providers as necessary. In the event of a major wildfire emergency,NLI will lean on the local emergency management or incident command team to coordinate efforts among all entities. See section 8.1 for more details. 5.3 Coordination with local Tribal entities NLI has limited tribal residents and electric services in its service territory. NLI will coordinate as needed with any Tribes impacted due to a wildfire, and if a larger event, NLI will collaborate with the local emergency management team or the incident command team to coordinate among all entities. 5.4 Emergency Management/Incident Response Organization NLI attends coordination meetings with local county emergency management agencies throughout the year. NLI provides electric services in six different counties in three states, including Pend Oreille County in Washington, Bonner, Boundary and Kootenai Counties in Idaho, and Lincoln and Sanders Counties in Montana. NLI receives alerts from local agencies when threatening conditions are possible, imminent, or occurring. Should a large-scale wildfire event occur and coordination with area agencies outside of NLI be necessary,NLI's Engineering & Operations Manager or Operations Superintendent will be assigned to coordinate with the agencies. It is anticipated that NLI would not be a lead agency in a major wildfire event, however, NLI would be involved as necessary. 6.0 Wildfire Risks and Drivers Associated with Design, Construction, Operation, and Maintenance To establish a baseline understanding of the risks and risk drivers involved,NLI regularly evaluates its exposure to wildfire related hazards. NLI has mapped its assets overlayed with 6 Northern Lights, Inc. Wildfire Mitigation Plan January 14, 2026 wildfire risk to provide insight into risk. This section provides an overview of the service area properties and associated risks. NLI considers its entire service territory as having a wildfire risk, however, the eastern portions along the Idaho-Montana border and into Montana are considered higher risk. 7 Northern Lights, Inc. Wildfire Mitigation Plan January 14, 2026 summ't Geston 2 t t m CANADA SA 7713 � coa �e olville e nal Forest / ` r I '�iO i"-1 � • 0 1 sat! t • Mount — o o o e f `^ ° a h � el ]/ � 37 ion I. • \ Ca� Sandpoint � binet r— - Cabine ns M o u n t a i t t a a " 5886 Caniks • tional Forest Selk rk J ` Mount ins 1 I Post Falls Coeur d'Alene National Forest Legend �D 0 5 10 20 Miles County Boundaries � • Ai Landscape Wildfire Risk hena Q1 Data 27� wL Score According to Athena 2025 Q1 Data I 0 0-3.0 ® 3.0-4.0 NORTHERN LIGHTS, INC. Li _—■ 421 Chevy Street,Sagle,Idaho 83860 Phone: 208-263-5141 6.0-8.0 prawn By:WI-argent Protect manager:I(Burge 8.0-lo.oCoeur d'Alene Date:20250513 www.nlLcoop I 8 Northern Lights, Inc. Wildfire Mitigation Plan January 14, 2026 6.1 Risks and risk drivers associated with topographic and climatological risk factors NLI staff evaluates its own, as well as the past experiences of other electric utilities, along with geographical characteristics within the region and field experience to determine the key potential risk drivers. NLI then enhances its existing mitigation approaches and incorporates the best available utility practices. This combination of current and future-implemented strategies is intended to manage or mitigate the following risk drivers: • Drought Conditions • Real-Time Fire Weather o High Winds o High Temperatures o Low Humidity o Poor Moisture Recoveries o Red flag warnings • Vegetation Type & Fuels • Wildland urban interface 6.2 Enterprise-wide Safety Risks NLI evaluated the causes of fires at electric utilities and applied our field experience to determine the potential risk drivers. The following categories were identified as risk drivers: • Foreign contact • Equipment failure • Vehicle impact • Expulsion fuses • Wire to wire contact 7.0 Wildfire Preventative Strategies 7.1 Weather Monitoring 7.1.1 Current Strategy Overview The following resources are used by NLI for weather monitoring: 9 Northern Lights, Inc. Wildfire Mitigation Plan January 14, 2026 • National Weather Service (NWS)—emailed weekly briefings, event-based email notifications, live pre-event briefings, and real-time access to chat and live notifications (Slack messenger). NLI staff monitors weather daily from online NWS sources. • Northern Rockies Geographic Area Coordination Center(NRGACC)—provides fuels, fire weather, fire weather danger outlooks and predictions. • Pyrecast—a near-term fire forecasting support tool. This tool visualizes data from three wildfire related forecasts including active fires, risk forecast, and 8-day fire weather forecast. • Field Observation—During extreme weather,NLI may elect to station field observers to monitor conditions in an area of concern. 7.1.2 Planned Updates NLI has received grant funding to set up our own weather station network. This data will be incorporated into a Daily Situational Awareness Tool (DSAT). This is expected to be set up and functioning by the end of 2026. 7.2 Design and Construction Standards 7.2.1 Current Strategy Overview NLI's construction specifications include Rural Utilities Services (RUS) and National Electric Safety Code (NESC) design recommendations. Current wildfire mitigation design and construction approaches that NLI actively is implementing include: • Overhead to underground power line conversions • System monitoring of substation feeders (SCADA) (partially completed) • Recloser upgrades (partially completed) • Pole replacements and replacing wood poles with steel poles, where appropriate • Installing fiberglass crossarms instead of wood. 7.2.2 Planned Updates No design-standard changes are anticipated in the next 3-year period, however,NLI will continue to evaluate and monitor changes to RUS and NESC and utility best practices. 7.3 Fuel & Vegetation Management 7.3.1 Current Strategy Overview NLI has at least one internal person assigned to oversee the vegetation management contractors and program. Contractors trim vegetation year-round and mower crews are added during the 10 Northern Lights, Inc. Wildfire Mitigation Plan January 14, 2026 warmer weather months along with additional aerial crews. NLI's goal is to have a 7-year trim cycle for all sections of overhead line. Dangerous or hazardous trees are removed, including dead trees at risk of falling into overhead powerlines. Right-of-way mowing is performed in areas after larger trees have been removed or if growth is minimal. A US Forest Service approved regional seed mix is planted in many rights- of-way after a mowing crew has cleared the area. This helps prevent new trees from returning and encourages smaller vegetation to grow in the right-of-way. NLI uses satellite vegetation images to drive an AI machine learning system to provide a risk- based approach to vegetation management to help prioritize areas.NLI has utilized this service for image capture since 2023. Within Idaho, NLI will work with timber company land owners to develop a plan to handle live marketable timber that is identified for removal from timber company land adjacent to the rights- of-way. 7.3.2 Planned Updates NLI received a grant to conduct a drone inspection for a portion of our overhead system in Idaho. This will be done under the grant funding and if beneficial and cost effective may be added as a future planned management strategy to this WMP. 7.4 Asset Inspections and Response 7.4.1 Current Strategy Overview NLI's current inspection strategies are: • NLI started an inspection program in 2024 utilizing mobile tablets with survey forms tied to NLI's mapping system. The goal is to inspect all overhead lines in a 7-year period. Repairs or remediation are performed when issues are noted. • NLI contracts with a pole inspection company to test 8-10% of poles annually. Data from the contract inspectors are input into NLI's mapping system for follow-up. • NLI's meter reader inspects member meters with the goal of a 4-year cycle to inspect each meter. Any issues found are reported to the appropriate department for follow-up. • As mentioned above in section 7.3, Fuel & Vegetation Management,NLI utilizes a satellite vegetation analysis system to provide an aerial survey of NLI's overhead powerline assets. See section 7.3.1 above for more details. 7.4.2 Planned Updates NLI received a grant to conduct a drone inspection for a portion of our overhead system in Idaho. This will be done under the grant funding and if beneficial and cost effective may be added as a future planned management strategy to this WMP. 11 Northern Lights, Inc. Wildfire Mitigation Plan January 14, 2026 7.5 Workforce training 7.5.1 Current Strategy Overview NLI has monthly safety meetings where wildfire and safety topics are covered, including Washington State Department of Labor& Industries Chapter 296-45 WAC safety rules. NLI also coordinates training and other events with local fire departments. 7.5.2 Planned Updates Training needs are evaluated and managed throughout the year and training topics are modified as needed. No major changes are expected within the next 3 years. 7.6 Relay and Recloser Practices 7.6.1 Current Strategy Overview NLI will implement two levels of seasonal settings based on the current area fire restrictions in each of the 6 counties of NLI's service territory. NLI may opt to include or exclude certain line segments based on hazard modeling or on-the-ground experience. Level 1 Settings • Stage 1 fire restrictions in place. • Reclosing is turned off. Level 2 Settings • Stage 2 fire restrictions in place. • System protection devices will be set to trip as quickly as the device allows. Additionally,NLI has seasonal settings in the Yaak area ("Y line"). The seasonal settings provide a more sensitive setting for tripping a fault during summer loads. 7.6.2 Planned Updates NLI updated its recloser practices in 2025, however, the fire restrictions were never elevated to Level 1 during 2025. NLI will adjust this methodology based on lessons learned and other updated industry best practices as needed. 7.7 De-energization/Public Safety Power Shutoff 7.7.1 Current Strategy Overview NLI developed a Public Safety Power Shutoff(PSPS)program in 2025. This program is separate from the WMP and will rely on the weather forecasting and hazard monitoring tools noted in section 7.1.1. NLI does not have bright-line rules for when it will de-energize a circuit but does have numerous inputs that will be monitored to determine if the risk is too high to leave a circuit energized. PSPS is a tool of last resort and will only be used under extreme conditions. 7.7.2 Planned Updates The plan will be evaluated and updated as needed and as there are"lessons learned". 12 Northern Lights, Inc. Wildfire Mitigation Plan January 14, 2026 8.0 Community Outreach and Public Awareness 8.1 Current Community Outreach and Public Awareness Program NLI communicates with its members through multiple means, and wildfire is a topic often covered. The resources NLI uses to communicate with its members include: • Social media platforms. • Website, www.nli.coop • Print magazine and bill stuffers. • Videos are available online and pushed to social media. • Annual meeting and member events • Employee meetings and interactions with members. • In 2025, NLI hosted a public comment period and meeting to seek input on its WMP from members, agencies, and other community organizations.3 NLI also will share this plan with the Idaho state forester, counties, fire protection districts, and associations within its service area.4 NLI utilizes various platforms to communicate during a major storm or other event. Should a wildfire event occur for which NLI needs to communicate with its members, the above (8.1) methods can be utilized, as well as: • Telephonic services using an interactive voice responsive (IVR) platform. • Coordination with local jurisdictions to push county wide messages via text or email. 8.2 Planned Updates NLI is adding additional capabilities for text communication with its members that will be fully implemented in 2026. 9.0 Restoration of Service NLI will patrol de-energized lines should a PSPS event be initiated. Restoration of service due to a wildfire event would be coordinated with local fire chiefs or incident commanders. Lines would be repaired, as needed, and patrolled prior to re-energizing. NLI maintains stocked materials for unforeseen repairs. 3 Montana requires a 45-day public comment period and a public meeting. 4 Idaho requires the plan be filed with several organizations within Idaho within 5 days of filing the WMP with IPUC. 13 Northern Lights, Inc. Wildfire Mitigation Plan January 14, 2026 10.0 Evaluating the Plan 10.1 Metrics and Assumptions for Measuring Plan Performance NLI has selected several metrics (see table below) intended to gauge the effectiveness of the various programs and strategies outlined in the WMP. The annual tracking of these metrics will help identify circuits most susceptible to unexpected outages, time-of-year risks, and the adequacy of the vegetation management and asset inspection schedules. NLI will reassess its operations and identify areas for improvement as more data becomes available, and refine the WMP as needed. In May 2025,NLI started tracking costs incurred in implementing the WMP throughout the year. This will be reported to the NLI Board and other agencies as necessary and as required5. 5 For Montana,no later than June 1 of each year,NLI will submit to its Board a report summarizing NLI's wildfire mitigation efforts and compliance with its currently approved WMP.For Idaho,once the Idaho Public Utilties Commission approves NLI's plan,NLI will submit on an annual basis or on such a basis as the IPUC prescribes by rule or order,a report that includes documentation describing the development and adoption of the WMP's components and measures,the WMP expenditures,and the work taken to develop and adopt the plan's components and measures. 14 Northern Lights, Inc. Wildfire Mitigation Plan January 14, 2026 Performance Metrics Measure of Effectiveness Red Flag Warnings Used to adjust annual Indication of overall in service area variation in criteria threat level for each fire season Number of system Effectiveness of the Reduction or no related ignitions mitigation plan material increase System Average Interruption Assess system Reduction in annual Frequency Index hardening & overall average score SAIFI) reliability System Average Interruption Assess system Reduction in annual Duration Index hardening & overall average score (SAIDI) reliability 10.2 Identifying and Addressing Areas of Continued Improvement in the Plan In 2025, NLI added a PSPS program and updated plans for system protection. These plans will be monitored will be adjusted as needed. The NLI PSPS program was not acted upon in 2025 and has yet to be used for a shutoff event. 10.3 Monitoring the Performance of Inspections NLI's inspections are followed up using various notifications. For internal line inspections, any issues are assigned follow-up, and immediate issues are assigned to a service crew to repair as soon as possible. For pole testing, the contractor provides weekly reports with GIS data. Any immediate issue is provided to NLI's Dispatch or Operations Superintendent to assign a crew to remedy. Other lower priority items are tracked on an internal map dashboard. Vegetation inspections also are tracked on an internal map dashboard. Inspections are considered an important part of NLI's maintenance and fire mitigation goals. Guided by NLI Operations and Engineering employees, the processes to determine and mitigate deficiencies within the electric system will continue to be adjusted. 15 Northern Lights, Inc. Wildfire Mitigation Plan January 14, 2026 11.0 Cost Evaluation 11.1 Cost vs. Benefit Approach When evaluating projects or programs for NLI's systems, all the benefits are evaluated against the cost. Most projects and programs have several system benefits and are not solely a wildfire mitigation cost. The cost of a wildfire can vary greatly, and it is difficult to pinpoint a cost to compare the efforts within NLI's WMP to. As of May 2025,NLI has started tracking costs specific to wildfire mitigation, however, has not incurred adequate data to provide any insight. However, when looking at costs, we can ascertain cost vs. impact to wildfire mitigation benefit at a high level, see table below. Pro ect ro ram A Cost Impact for Wildfire Mitigation PSPS Low High Relay and Recloser Practices Low High Vegetation Management High High Inspections Medium Medium Under grounding High High Replace wood poles with metal High Medium Install fiberglass crossarms Medium Medium Community Outreach Low Low 16