20260211Comments.pdf

John A. Richards #10670
J.J. Winters #10327 RECEIVED
IDAHO DEPARTMENT OF LANDS FEBRUARY 11, 2026
300 N. 61h Street, Ste. 103 IDAHO PUBLIC
Boise, ID 83702 UTILITIES COMMISSION
[phone]
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Attorneys for Idaho Department of Lands
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER CASE NO. IPC-E-25-32
COMPANY'S APPLICATION FOR
APPROVAL OF THE COMPANY'S 2026 INTERVENOR IDAHO
WILDFIRE MITIGATION PLAN DEPARTMENT OF LANDS
COMMENTS
Intervenor Idaho Department of Lands ("IDL") respectfully submits the following
comments in the above-captioned matter pursuant to Idaho Code § 61-1804(3) and Order No.
36835 on behalf of Idaho State Forester, Julia Lauch.
1. IDL has long required our cooperators at the county level who develop and maintain
County Wildfire Preparedness Plans to provide descriptive details about the modeling
inputs that are used to create their products. It is IDL's position that if we don't hold
utilities to the same standard then a"double" standard would be established setting a
precedent that does not"move the needle" on wildfire mitigation efforts. IDL
respectively requests that Idaho Power provide additional descriptive narrative details
about the data utilized to produce their"risk"model.
2. In Section 3 which covers cost-benefit analysis of mitigation, IDL suggests that narrative
discussion be included on diminishing returns as part of cost versus benefits
consideration. Without this discussion, much of the effort would hinge on best
estimation of value versus establishing points in investments to which there is little to no
value. To reduce burden of work, IDL suggests this be done on a practice/project level.
INTERVENOR IDAHO DEPARTMENT OF LANDS COMMENTS-1

3. As written, Section 3 is unclear and IDL respectfully suggests clarification. If Idaho
Power is unable to speak to the economics of efforts, it is suggested that Idaho Power
speak to the value (economic) of the systems served and the impacts (economic)when
electric service is disrupted.
4. In section 9.2.3, Idaho Power has addressed fair market value for industrial lands,
however, due to what IDL believes are shortcomings of the legislation, the concept of fair
market value should be extended at a minimum to state endowment lands and, if possible,
to other large, non-industrial private landowners. It is likely that Idaho Power already has
agreements in place and SOPS for this scenario. It is IDL's position that these SOPS be
highlighted in this section as well, which will build greater confidence in relationships
and the values associated with timbered lands.
5. In the section covering inspection of vegetation, the qualifications appropriately center
around arboriculture standards, which have long been the industry standards. However,
IDL argues that these standards are insufficient at addressing wildland fire related issues
when looking at vegetative mitigation as a mechanism to reduce wildfire risk. The
arboriculture stands address tree/shrub conditions and how to appropriately remove or
prune. Though these standards address vegetation health,they do not consider ignition
potential or fire propagation, both of which should be standard for inspection of
vegetation treatments. When viewed in the context of wildfires, a prime example is
"ladder" fuels. Ladder fuels are vegetative structural components that allow fire to move
rapidly from ground to forest canopies. If ladder fuels are not addressed as part of the
mitigation actions, then the risk of fire propagating to crowns is substantially higher. IDL
respectfully recommends that the inspection qualification standards also include
certification specific to wildland fire.
Respectfully submitted this 1 lth day of February, 2026.
IDAHO DEPARTMENT OF LANDS
J.J.WINTERS
Attorney for Idaho Department of Lands
INTERVENOR IDAHO DEPARTMENT OF LANDS COMMENTS-2

CERTIFICATE OF SERVICE
I hereby certify that on this 1 lth day of February,2026, I caused to be served a true and
correct copy of the foregoing by the method indicated below, and addressed to the following:
Idaho Power Company 0 Email: [e-mail]
Megan Goicochea Allen [e-mail]
Lisa Lance [e-mail]
Tim Tatum [e-mail]
Connie Aschenbrenner [e-mail]
Riley Maloney [e-mail]
Idaho Public Utilities Commission 0 Email: [e-mail]
Adam Triplett [e-mail]
Micron Technology, Inc. 0 Email: [e-mail]
Austin Rueschhoff [e-mail]
Thorvald A Nelson [e-mail]
Kristine A.K. Roach [e-mail]
[e-mail]
Is/Kayla Dawson
Kayla Dawson, Legal Assistant
INTERVENOR IDAHO DEPARTMENT OF LANDS COMMENTS-3