20260212Staff Comments.pdf

RECEIVED
February 12, 2026
ERIKA K. MELANSON IDAHO PUBLIC
DEPUTY ATTORNEY GENERAL UTILITIES COMMISSION
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83702
[phone]
IDAHO BAR NO. 11560
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER )
COMPANY'S APPLICATION FOR ) CASE NO. IPC-E-25-32
APPROVAL OF THE COMPANY'S 2026 )
WILDFIRE MITIGATION PLAN )
COMMENTS OF THE
COMMISSION STAFF
COMMISSION STAFF ("STAFF") OF the Idaho Public Utilities Commission
("Commission"), by and through its attorney of record, Erika K. Melanson, Deputy Attorney
General, submits the following comments.
BACKGROUND
On October 10, 2025, Idaho Power Company ("Company") applied to the Commission
for approval of its 2026 Wildfire Mitigation Plan("Application"). A copy of the proposed 2026
Wildfire Mitigation Plan("WMP") was included with the Application as Attachment 1.
Additionally, the Company requested the Commission to clarify, as part of its order in
this proceeding, whether the most recent WMP-related requirements adopted as part of Order
No. 36774 supersede prior Commission orders, Order Nos. 36042 and 35717. Application at 32.
Further, the Company requested Commission approval for the Company to file its updated WMP
for the Commission's annual review on or about October 1 st of each year going forward. Id.
Lastly, the Company requested the Commission issue an errata to Order No. 36774
aligning the ordering language related to notices under Idaho Code § 61-1804(2) with Staffs
recommendation in Case No. GNR-E-25-02. Notice of Wildfire Mitigation Plan Filing at 2.
STAFF COMMENTS 1 FEBRUARY 12, 2026

On November 6, 2025, the Commission issued a Notice of Application and Notice of
Intervention Deadline, setting a deadline for interested parties to intervene. Order No. 36835.
Micron Technology, Inc. ("Micron") and the Idaho Department of Lands ("IDL") intervened.
Order No. 36865.
On December 22, 2025, the Commission issued an errata to Order No. 36774 in Case No.
GNR-E-25-02 aligning the ordering language to Staff s recommendation about notices.
STAFF ANALYSIS
Staff reviewed the Company's 2026 WMP for compliance with Idaho Code § 61-
1804(1)-(2) and believes it meets the requirements of the Wildfire Standard of Care Act
("WSCA"),Idaho Code § 61-1803 and Commission WMP guidelines. Although Staff believes
that the Company's WMP meets the requirements, Staff recommends the Company include
additional items in future WMPs as discussed below. Staff recommends the Commission issue an
order that(1) approves the Company's 2026 WMP that includes Staff s recommendations; (2)
allows the Company to file its updated WMP on or about October I of each year; (3) requires the
Company to include copies of its quarterly NESC FAC-003-X reports as attachments to future
WMP filings (where X represents the latest version of the standard the Company is using), and
(4)requires the Company to include copies of current Transmission Maintenance and Inspection
plans used for NERC FAC-50 I-WECC-X compliance and any violations noted from the most
recent NERC compliance audit(where X represents the latest version of the standard the
Company is using).
Clarification of WMP-Related Requirements
In Case No. GNR-E-25-02, the Commission ordered the Company to follow the
Commission WMP Guidelines and to provide a copy of the notice to interested parties. Order
No. 36774 and Errata Order No. 36774. In this proceeding, the Company requested clarification
as to whether the most recent WMP-related requirements adopted in Order No. 36774 supersede
prior Commission orders, specifically Order Nos. 36042 and 35717. Application at 32.
The Company identified the following for clarification: (1)the requirement for each
WMP to have a five-year planning horizon; (2) the requirement to separate internal wildfire
mitigation labor in cost forecasts within the WMP; (3)the requirement to explore methods to
STAFF COMMENTS 2 FEBRUARY I2, 2026

reduce costs with communication and education related to wildfire and Public Safety Power
Shutoff ("PSPS"); and(4)the requirement to provide details of all funding alternatives and
sources pursued within the WMP. Staff believes that each requirement should be included in
WMPs, as described below.
In Order No. 36042, the Commission approved the Stipulation and Settlement in Case
No. IPC-E-23-11,under which the Company agreed to extend each version of its WMP to a five
year planning horizon. Order No. 36042 at 10. Subsequently, in Order No. 36774, the
Commission stated that each WMP must include, at a minimum, a 3-year planning horizon.
Order No. 36774 at 15. Staff interprets this language to mean that the Company is no longer
required to include in each WMP a five-year planning horizon, as long as it complies with the
minimum three-year planning horizon requirement.
Also, as part of the Stipulation and Settlement approved in Order No. 36042, the
Company agreed to separate internal wildfire mitigation labor in its cost forecasts and to explore
methods to reduce costs with communication and education regarding wildfire and PSPS within
WMPs. Case No. IPC-E-23-11 Stipulation and Settlement at 16. Staff believes separating
internal wildfire mitigation labor should continue to be included in each WMP as it identifies
dedicated labor expenses to wildfire and allows Staff to track labor costs over time. Also, Staff
believes that it is reasonable to expect the Company to continue seeking cost-effective methods
of communication and community education as community awareness increases.
In Order No. 35717, the Commission ordered the Company to provide details of all
funding alternatives and sources pursued within the WMP. Order No. 35717 at 9. Staff believes
this information is necessary because grant funding may mitigate potential increased wildfire
mitigation costs to ratepayers. Additionally, because the Commission must consider the cost
implementation of WMP expenditures, this information could aid in the Commission's review of
the cost and feasibility of the Company's planned actions. In the Company's Response to Staff
Production Request No. 55, the Company described two grants totaling of$2.65 million for two
undergrounding projects, which are active projects with executed contracts. The Company also
stated it applied for a $1.48 million wildfire smart technology grant and is awaiting final
selection by the U.S. Department of Energy. Id.
Therefore, Staff recommends the Commission clarify that the Company should continue
to: (1) separate internal wildfire mitigation labor in cost forecasts within the WMP; (2) explore
STAFF COMMENTS 3 FEBRUARY 12, 2026

methods to reduce costs with communication and education regarding wildfire and PSPS; and(3)
provide details of all funding alternatives and sources pursued within the WMP.
2026 WMP
The Company requested the Commission to find its WMP is consistent with Idaho Code
§ 61-1802(a) and complies with Order Nos. 36774, 36742, 36042, and 35717, as well as, the
requirements of the WSCA, finding it meets the minimum requirements stated in Idaho Code §
61-1803; is consistent with public health, safety and welfare; is feasibly implemented; and
adequately minimizes wildfire risk and proposes to respond to wildfires that do occur.
Application at 32-33.
For 2026, the Company forecasts $32.9 million in capital investments and$53.5 million
for operations and maintenance ("O&M") expenses. The primary capital expenditures are the
Company's Overhead Primary Hardening Program and the Strategic Undergrounding program,
forecasted to be $19.5 million and $12 million, respectively. 2026 WMP -Appendix F at 3. The
Company's largest O&M expense is the Company's "Transition to/Maintain 3-year Vegetation
Management"Program, estimated to cost$45.3 million. 2026 WMP -Appendix F at 2. In
Table No. 1 below, Staff summarizes the capital and O&M cost forecasts for 2026 through 2030.
Table No. 1: Company's 2026 WMP Cost Forecasts Summary
Forecasts 5-Year
(`OOOs) 2026 2027 2028 2029 2030 Total
O&M $ 53,485 $ 49,467 $ 51,359 $ 55,626 $ 57,070 $ 267,007
Capital $ 32,973 $ 35,660 $ 37,068 $ 60,410 $ 66,307 $ 232,418
Staff details the other categories required by Idaho Code § 61-1803(3)(a)-(g) in the
sections below and provides recommendations within.
Comparison to 2025 WMP
The Company's 2026 WMP capital five-year plan is approximately $94.8 million more
than the Company's 2025 WMP. 2025 WMP—Table 10 at 77. This increase appears to be
primarily attributed to increased investment in Strategic Undergrounding in 2026 through 2030
and investment in Overhead Primary Hardening in 2029 and 2030.
STAFF COMMENTS 4 FFBRUARY 12, 2026

The Company's 2026 WMP forecast is approximately $9 million less than forecasted in
the 2025 WMP. 2025 WMP—Table 8 at 61. This decrease can be attributed to several
categories that were removed, including: removal of an Oregon only program, discontinuance the
vegetation management satellite pilot program, changes in expenses as the Company created an
internal product instead of purchasing third-party software for Encroachment Event Management
Software, and removal of a wildfire mitigation position and related expenses. See Company's
response to Staff Production Request No. 56.
Geographical Risk Assessments
Idaho Code § 61-1803(3)(a) and the Commission WMP Guidelines require all WMPs to
include a description of the Company's wildfire risk assessment and a map. The Company
forecasts an average of$2.3 million in annual expenses for risk modeling updates through 2030.
2026 WMP -Appendix F at 1. Staff believes the Company followed sound quantitative and
qualitative modeling strategies and methods to assess wildland fire risks and to develop and
identify geographical areas with heightened risk. The Company's methodology incorporates
strong and diverse data inputs, a defensible risk calculation framework, and practical wildfire
risk zone ("WRZ") maps that are updated annually. However, the model has several limitations,
including the lack of. (1) explicitly modeled asset-condition level ignition, (2) validation of
modeled results, (3) forward-climate scenarios, and(4)battery storage units as potential ignition
sources.
Based on its assessment, Staff recommends the Company to include the following to its
subsequent WMP as a part of geographical risk modeling and assessment:
1. Address the types of infrastructure left out of risk modeling and, if not included in
the Company's models,provide an explanation as to why;
2. Find ways to include loss of life as a parameter in its future wildfire risk assessments
and at a minimum, include it as a qualitative parameter where loss of life has higher
probabilities;
3. Take necessary steps to integrate asset condition/inspection data and failure modes
into ignition models; and
4. Include quantitative model validation data including, but not limited to, retrospective
analysis of historical fire perimeters and ignition data, hit or miss rates, confidence
intervals or sensitivity study on risk tiers, and calibration to observed fire perimeters.
STAFF COMMENTS 5 FEBRUARY 12, 2026

Key Strengths of the Company's Risk Assessment Methodology
Staff identified the following attributes of the Company risk-assessment methodology as
strengths:
1. Risk calculation formula- In its plan, the Company used a conventional definition of
Risk=Probability X Consequence, which is supported by recognized fire behavior
drivers and spatial consequence modeling. 2026 WMP at 8.
2. Technical inputs - The Company integrated 12-year fire weather climatology from
Weather Research and Forecasting ("WRF"), fuel raster from federal LANDFIRE
program, structure density from US Census data and the Microsoft Building Footprint
database, estimated live fuel moistures from historical observations in its Monte-
Carlo based fire-spread simulations.
3. Asset-proximity ignition sampling -the Company focused on ignitions within 240 in
of its overhead transmission and distribution("T&D") lines to reflect utility-caused
ignition exposure.
4. Pragmatic tiering & calibration- The Company followed a data-driven classification
method, known as Jenks natural break optimization technique, to generate initial risk
zone tiers. Then it incorporated local qualitative factors, such as, ingress/egress,
suppression and response capabilities, feedback from customers, fire agencies, land
managers, etc., to refine and finalize the operational relevance of WRZs (Tiers 2 and
3) that it used for mitigation planning purposes. See Company's response to Staff
Production Request No. 29.
5. Annual refresh - According to the WMP, the Company plans for annual iterative
review updates of the risk zones on an ongoing basis to account for any critical
changes over time, such as changes in vegetation composition due to recent wildfires,
etc.
STAFF COMMENTS 6 FEBRUARY 12, 2026

Gaps in the Compan.Approach and Improvements to Consider
Staff also identified the following gaps in the Company's risk-assessment methodology
that should be addressed in future WMPs.
1. Asset condition-level ignition probability layer- The Company's methodology to
assess risk by using modeled fire volume as the probability proxy does not explicitly
reflect asset condition to determine the likelihood of ignition(including but not
limited to connector failures, vegetation contacts or clearance metrics, fault
signatures, etc.), nor does it factor in potentially defective equipment and operations-
driven ignition risk at the structure level. Staff believes that integrating asset
condition/inspection data and failure modes into ignition models can better reflect
utility-caused ignition likelihood.1,2,3
2. Validation metrics- The WMP does not present quantitative model validation, such
as retrospective analysis of historical fire perimeters and ignition data, hit or miss
rates, confidence intervals, sensitivity study on risk tiers, and calibration to observed
fire perimeters, etc. Published federal reports increasingly emphasize inclusion of
such validation results to enhance transparency of decision-grade fire risk models.2
3. Forward climate or environmental change scenarios -While the Company's plan
embodies WRF climatology, the plan does not explicitly model forward looking
climate scenarios, such as, hotter/drier future, extreme wind return intervals, or
environmental changes, e.g., vegetation growth rates or type changes/migration, tree
growth rates or mortality due to stress/diseases, etc.4,5
4. Generation resources and Battery Energy Storage Systems (`BESS") -The
Company's risk modeling approach only incorporates T&D infrastructure; it does not
consider generation resources and BESS as potential ignition sources. Although
BESS failure rate and hazards have been reduced in recent times due to the adoption
1 hiips://www.energy.gov/sites/default/files/2024-10/UtiliiyResiliencePlannin,gPracticesforHazards-Wildfire.pdf;Accessed:
01/29/2026.
2https://www.pnnl.gov/sites/default/files/media/file/PNNL_lONov2025_Wildfire_Risk_Mitigation_Executive_Order_Best_Practi
ces_FINAL_PNNL-SA-3852811 01.pdf;Accessed:01/29/2026.
3 https:Henergized.edison.com/stories/power-line-temperature-checks-help-prevent-wildfires;Accessed:01/29/2026.
4 hUs://www.nepa.com/wl2-content/uploads/2025/06/NCPA-Wildfire-Mitigation-Plan-2025.pdf,Accessed:01/29/2026.
5 Company's Response to Staff Production Request No.58.
STAFF COMMENTS 7 FEBRUARY 12, 2026

of latest designs and best practices, battery storage units can be severely hazardous
due to several reasons, such as uncontrolled release of heat energy, generation of
toxic and flammable gas, challenges in extinguishing BESS-generated fires, etc. 6,7,8,9
Staff believes the types of infrastructure left out of the risk modeling should be
addressed and, if not included in the Company's models, provide an explanation as to
why.
5. Loss of life as a parameter of consequences to assess risk- The Company's risk
modeling and the mathematical approach does not directly incorporate loss of life
(human and wildlife) because it is hard to quantify and validate. Company's
Response to Staff Production Request No. 57. Staff believes the Company should
find ways to include loss of life as a parameter to include in its future wildfire risk
assessments. Staff believes it could be included qualitatively where loss of life has
higher probabilities.
Preventative Actions and Programs
Idaho Code § 61-1803(3)(b) and the Commission WMP Guidelines require all WMPs to
include discussion of all the electric corporation's preventative actions and programs within the
WMP. The Commission WMP Guidelines list five required preventative actions and programs:
(1) situational awareness efforts, (2) asset inspections, (3) enhanced vegetation management
practices in risk zones, (4) operation practices during heightened wildfire risk days or zones, (5)
and community education. Staff discusses all the required preventative actions and programs, as
well as the Company's additional preventative actions and programs, in the sections below.
Workforce Preparedness
The Commission WMP Guidelines state that a WMP may include Workforce
Preparedness as a preventative program. WMP Guidelines at 3. The Company included its
Workforce Preparedness program as Appendix A of its 2026 WMP. Appendix A also details the
6 https:Hstora eg wiki.epri.com/index.phpBESS_Failure_Incident_Database;Accessed:02/02/2026.
https://www.nfpa.org/education-and-research/electrical/energy-storage=systems;Accessed:02/02/2026.
8 hUs://www.el2a.2ov/electronics-batteries-management/battery-energy-storage-systems-main-considerations-safe;Accessed:
02/02/2026.
9 https://www.sciencedirect.com/science/article/abs/Xii/S095042302200208X;Accessed:02/02/2026.
STAFF COMMENTS 8 FEBRUARY 12, 2026

roles and responsibilities of employees based on positions. Staff believes that the Company's
Workforce Preparedness is reasonable. Staff expects the Company to continue applying and
refining its preparedness plan as needed.
Pilot Programs
The Commission WMP Guidelines state that a WMP may include pilot programs as a
preventative program. WMP Guidelines at 4. Within Section 10.2 of the 2026 WMP, the
Company described its seven pilot programs: (1) Standby Helicopter Services, (2) Fuels
Reduction Shared Stewardship, (3) Line Monitoring Technology, (4) Covered Conductor, (5) 3-
D Pole Loading, (6) High Impedance Relay Protections, (7) and Federal Aviation Administration
Waivers and Aerial Drone Inspections. 2026 WMP at 53-56.
In response to discovery, the Company provided metrics that will be used to evaluate the
success of each pilot program. See Company's response to Staff Production Request No. 5.
Staff believes it is important to track this information in each WMP to explain how the Company
intends to evaluate the success of its pilot programs and to support future WMP actions.
Therefore, Staff recommends the Company list all metrics used to evaluate the success of each
pilot program within the WMP consistent with the Company's response to Staff Production
Request No. 5. Staff also recommends the Company provide the estimated duration and
estimated annual cost of each pilot program within the description for clarity.
In addition, the Company has a new internal vegetation management crew pilot program.
See Company's response to Staff Production Request No. 19. Staff further recommends the
Company to include an internal vegetation management crew description within Section 10.2 of
its WMP.
Public Outreach and Engagement
Idaho Code § 61-1803(3)(c) and the Commission WMP Guidelines require each WMP to
include a discussion of how the utility maintains community outreach and public awareness
before, during, and after wildfire season. Staff believes the Company's WMP has met the public
outreach and engagement requirement.
Section 11 of the WMP details the Company's efforts to educate customers about
wildfire risk and the Company's WMP work. The Company addresses its community
STAFF COMMENTS 9 FFBRUARY 12, 2026

engagement by(1) hosting meetings throughout the year; (2)using a variety of channels and
methods to communicate with the public; (3) focusing the timing of their outreach to occur prior
to and during the wildfire season; and(4) through ongoing training and communication with
their employees. 2026 WMP at 57-61. The Company forecasts $349,000 in annual O&M
expenses for community engagement efforts, and a total of$1.7 million throughout the WMP
planning horizon. See Appendix F at 1-2. Staff believes it is a reasonable expectation for the
Company to seek cost-effective methods of communication and community education as
community awareness increases each year.
Government Outreach
Idaho Code § 61-1803(3)(d) and the Commission WMP Guidelines require each WMP to
include a discussion of outreach and coordination with federal, state, tribal, and local officials
and agencies regarding wildfire preparedness and emergency response planning. Staff believes
that the Company's WMP substantially meets the government outreach requirements.
Throughout the WMP, the Company describes its coordination efforts with state, local,
and federal agencies and working groups. 2026 WMP at 24, 54, and 63. Efforts include
collaboration related to wildfire response planning, fuel reduction activities, and information
sharing. Staff recommends that the Company include descriptions of each of the Fuel Reduction
Shared Stewardship projects, including location, participating entities, and estimated cost. Staff
believes this information would be valuable to understand the work the Company is taking when
collaborating with other entities to address the wildfire risk that is outside its right-of-way.
Method of Line Design and Grid Hardening
Idaho Code § 61-1803(3)(e) and the Commission WMP Guidelines require each WMP to
include a description of the Company's methods of line design for new lines and planned system
upgrades. Overall, Staff believes the Company's line design methods are reasonable.
The Company prioritizes its transmission and distribution("T&D") grid hardening
investments based on the wildfire risk zone ("WRZ") tiers to reduce wildfire risks and to
improve overall system resiliency and reliability. However, Staff believes improvements to
reporting would enhance the Commission's ability to evaluate cost implications.Accordingly,
Staff recommends the Company include the following areas in future WMPs:
STAFF COMMENTS 10 FFBRUARY 12, 2026

1. Disclosure of quantitative targets and effectiveness metrics of all T&D programs and
projects; and
2. Provide a table identifying all T&D rebuild and grid hardening projects. For each
project include the following: project name, project type,primary driver, location,
design standards, anticipated project timeline, estimated costs, and an explanation of
how the wildfire mitigation priority of the project affected the project design, costs,
and timeline.
The Company's methods of line design describe how it will reduce ignition likelihood
and consequence through targeted system grid hardening. The methods include the following:
(1) overhead primary hardening, (2) overhead-to-underground conversion of distribution lines,
(3)use of covered conductors, (4) installation of non-wood and fire resistant crossarms and
poles, (5) recloser segmentation and remote control, (6) selection of steel poles for new>138 kV
transmission where feasible, and(7)targeted transmission line rebuilds. Each grid hardening
project is prioritized in Tier 2 and Tier 3 WRZs using the Company's cost—benefit framework and
the broader WMP risk model as described in the "Geographical Risk Assessment" section above.
2026 WMP at 41.
In general, the Company's plan ties hardening decisions to: (1)the geographical risk
assessment, (2) operational practices, and(3) inspection and asset management programs, so that
design interventions occur where they deliver the most risk reduction per dollar.
Gaps in the Company's Rporting and Improvements to Consider
In its analysis, Staff identified the following gaps in reporting of the Company's line
design and grid hardening programs, that should be improved in future WMPs.
Disclosure Of Quantitative Targets And Effectiveness Metrics
In its plan, the Company provides limited disclosure of quantitative targets for each grid
hardening program such as covered conductor miles per year, undergrounding miles, and specific
Tier 3 feeder scopes. Staff believes that lack of such information makes the program tracking and
quantifiable benchmarking a challenging process. Additionally, the Company did not explicitly
report effectiveness metrics for line design techniques based on industry-leaders'
STAFF COMMENTS 11 FEBRUARY 12, 2026

recommendations (e.g., modeled ignition-risk reduction per mile for covered conductor vs.
undergrounding, etc.). 10 Therefore, Staff recommends the Company include in future WMPs:
1. Annual miles for covered conductor and undergrounding by WRZ tier or feeder, plus
modeled ignition-risk reduction per mile (e.g.,percentage reduction vs. bare wire;
percentage reduction vs. undergrounding, etc.), mirroring some of the industry's best
practices,11,12 and
2. Adopt an effectiveness scorecard for each grid hardening method(including but not
limited to covered conductor, non-wooden poles, non-wooden crossarms,
undergrounding, etc.)based on industry guidance.
T&D Grid Hardening Efforts
The Company's 2026 WMP does not show details regarding its line design and grid
hardening plans when wildfire mitigation is the primary driver for these projects. Although the
Company provided additional project information in responses to Staff Production Request Nos.
6, 7, 8, and 59—62, the WMP does not clearly outline estimated costs for grid hardening
programs, such as T&D line rebuilds, overhead primary hardening, and strategic
undergrounding. Staff could not distinguish how projects were prioritized. Staff believes the
WMP should show how the overall costs were impacted by the need to mitigate wildfires.
Staff believes that some T&D projects may have primary drivers other than wildfire
mitigation, such as reliability, end of life replacement, or load growth. However, based on the
information provided, Staff is unable to quantify the changes in overall project scope, design,
timeline, and total incremental costs when wildfire risk reduction was incorporated as the main
driver in these projects and programs. Staff recommends the Company include a list of all T&D
projects that includes wildfire mitigation as a driver in future WMPs, similar to the information
provided in the Company's response to Staff Production Request Nos. 6, 7, and 8. For each
project, the Company should include the following: the name of the project, project type
(transmission or distribution), primary driver(wildfire, future growth, end of useful life),
io https://www.ppri.com/research/sectors/readi/research-results/3002031834;Accessed:02/02/2026.
ii https://download.newsroom.edison.com/create_memory file/?f id=642le583b3aed3495ld9462a\&content_verified=True;
Accessed:02/02/2026.
12 h t.ps://www.12ge.com/assets/nee/docs/outages-and-safety/safety/undergrounding-benchmarkin2-report.Ddf,Accessed:
02/02/2026.
STAFF COMMENTS 12 FEBRUARY 12, 2026

respective wildfire risk zone tier, and an explanation of how the wildfire mitigation priority of
the project affected the project design, cost, and timeline.
Situational Awareness and Monitoring
Idaho Code § 61-1803(3)(f) and the Commission WMP Guidelines require each WMP to
discuss how the Company monitors weather conditions and wildfire risk. In 2026, the Company
forecasts $834,000 in O&M expenses and $1.3 million in capital expenditures for its Situational
Awareness program. 2026 WMP -Appendix F at 1-3. By 2030, the Company forecasts $5.4
million in O&M expenses and $2.4 million in capital expenditures for this program. Id.
Through its review, Staff believes that the Company has substantially met the situational
awareness and monitoring requirement of Idaho Code § 61-1803(3)(f) and the Commission's
WMP Guidelines.
The Company's custom tool, Fire Potential Index ("FPI"),provides a seven-day forecast
to aid in operational decision making to reduce wildfire threats and risks. 2026 WMP at 21.
During discussions with the Company, Staff understands that it tracks critical changes but
believes there could be improvement. Staff recommends the Company adopt and mature its
implementation of industry best practices in configuration management, requirements
management, test management, and issue and defect tracking for all custom developed models or
software that play a critical role in the Company's WMP. Implementing these practices will help
ensure consistency, traceability, and quality throughout the software development lifecycle,
reduce operational risk, and provide greater confidence in the reliability and accuracy of these
tools.
To support situational awareness, the Company has installed weather stations throughout
its service territory to aid in operations. 2026 WMP at 24. The Company plans to install a total
of 102 weather stations by 2030. 2026 WMP, Appendix F - Table 3 at 4. The Company has
installed seven wildfire detection cameras with ALERTWest in coordination with state agencies
and plans to install four additional cameras in 2026 and 2027. 2026 WMP at 24, 25 and
Appendix F - Table 3 at 4. In addition, the Company has begun integrating Technosylva's
Wildfire Risk Analyst Enterprise to aid in visualizing fire spread if ignition did occur. 2026
WMP at 26.
STAFF COMMENTS 13 FEBRUARY 12, 2026

Infrastructure Inspection and Maintenance
Idaho Code § 61-1803(3)(g)(i) and the Commission WMP Guidelines require each WMP
to include a summary of the utility's inspection programs and targets or goals to be achieved
within the WMP. Section 7 of the 2026 WMP describes the Company's asset inspection cycles.
Staff believes the Company's infrastructure inspection and asset management strategies are
reasonable and the Company's WMP has met the requirement. The key attributes of the
Company's inspection approach are given below.
The Company has a structured inspection portfolio across its T&D assets, including aerial
visual inspections, ground visual inspections, detailed visual inspections using high-resolution
photography, thermal imaging inspections using infrared("IR") technology, transmission wood
pole inspection and treatment, cathodic protection, and fire-resistant mesh wrap. The WMP also
includes 2026 inspection targets and defect prioritization timelines for priority levels 1 through 3.
2026 WMP at 35.
In addition, the Company's WMP includes pre-season inspections in Tier 3 and selected
Tier 2 WRZs, including IR thermography for Tier 3 transmission before July 1, and planned
transmission wood pole mesh wraps installations in 2026 to improve pole survivability. 2026
WMP at 39.
De-Energization and Line Operation Practices
Idaho Code § 61-1803(3)(g)(ii) and the Commission WMP Guidelines require each
WMP to include a discussion of the Company's standards, criteria, and operational protocols for
de-energization as part of the Company's WMP. Based on its review, Staff reached the following
conclusions regarding the Company's line operation practices to mitigate wildfire risk.
First, Staff believes the Company follows a reasonable distribution operational protection
strategy, including enhanced protection settings that can be remotely controlled based on the FPI,
zone-specific wind speeds, and other operational inputs.
Second, Staff believes the Company follows a reasonable transmission line operational
strategy that includes operational strategies for Tier 3 risk zones and coordination with other
electric corporations during de-energization events when the Company is not the operator.
Third, the Company's approach includes emergency de-energization of overhead T&D
lines when wildfires are approaching the Company's infrastructure, as well as the restoration of
electrical service following a wildfire-related de-energization by conducting emergency patrols.
STAFF COMMENTS 14 FFBRUARY 12, 2026

2026 WMP at 29—34. Staff believes that the Company's PSPS process, as described in Section
6 of the WMP and Appendix B, is reasonable. The framework is consistent with industry
practices intended to mitigate wildfire risk while balancing customer impacts.
The Company did not implement a PSPS event in 2025, with the most recent PSPS
occurring in 2024. While the absence of a PSPS event does not,by itself, indicate a deficiency,
Staff is unable to evaluate the effectiveness of recent process updates under current operating
conditions. Staff believes the Company should continue applying and refining best practices as
PSPS events are planned and executed. Ongoing evaluation and improvement of PSPS
procedures will be important to ensure that public safety objectives are met while minimizing
disruption to customers.
In response to Staff Production Request No. 26, the Company described the resources
available to call center agents during a PSPS. Staff believes this information is important to
document within the WMP and recommends the Company include more detail about resources
available to call center agents in Appendix B, similar to the Company's response to Staff
Production Request No. 26.
Vegetation Management
Idaho Code § 61-1803(3)(g)(iii) and the Commission WMP Guidelines require each
WMP to include a discussion of vegetation management and enhanced vegetation management
for heightened fire risk areas.
Staff reviewed the Company's vegetation management and enhanced vegetation
management practices described in the 2026 WMP. The Company estimates an average $44.3
million in annual O&M expenses for this program. 2026 WMP -Appendix F at 1-2. Staff
believes the Company's vegetation management and enhanced vegetation management programs
are critical components of wildfire mitigation and believes the Company has substantially met
the requirements. However, Staff has identified areas of potential improvement in the
Company's future WMP filings.
Through e-mail exchanges, the Company stated its vegetation management is conducted
in accordance with federal, national and industry standards, including ANSI A300;National
Electrical Safety Code ("NESC") Section 21, Part 2, Rule 218; and North American Electric
Reliability Corporation("NERC") Standards FAC-003-5 and FAC-501-WECC-4.
STAFF COMMENTS 15 FEBRUARY 12, 2026

Utilities that own and operate transmission lines are required to submit periodic reports
under NERC FAC-003-5 and FAC-501-WECC-4. Staff believes these standards are essential for
wildfire mitigation and vegetation management because they set clear, consensus-based
guidelines for trimming,pruning, and clearing vegetation to prevent contact with power lines;
thus, reducing outage risk, wildfire ignition, and liability. The data gathered from these reports
supports utilities as it tracks trends in vegetation encroachments, evaluate the effectiveness of
treatment strategies, and proactively target areas at higher risk. Additionally, this information
supports continuous improvement in safety, system reliability, and regulatory compliance. As
such, Staff recommends the Commission to order the Company to include its most recent FAC-
003-X and FAC-501-WECC-X reports for the NERC standards to future WMP filings (where X
represents the most current version of NERC standards).
The NERC FAC standards for metrics and reporting are crucial for vegetation
management. However, these standards primarily apply to specific transmission lines. Staff
believes these standards would also be informative for vegetation management activities on
distribution or transmission lines not covered by NERC standards. Furthermore, including the
WRZ in this information would allow the Company to analyze trends in vegetation-related
outages by circuits, and by risk zones to assess vegetation management effectiveness. Therefore,
Staff recommends the Company expand reporting for future WMP filings to include both
transmission and distribution assets not covered by NERC standards and correlated WRZs to
offer a more comprehensive view of trends and effectiveness across the utility's system.
As described further in the Other WMP Recommendations section, Staff recommends the
Company provide additional metrics. For its vegetation management and enhanced vegetation
management program specifically, additional metrics should include tracking faults or outages
caused by vegetation due to fall-in or grow-in, weather-related, or service-related events.
Monitoring each metric over time may reveal trends and assess program performance.
Other WMP Recommendations
Filing Date
The Company requested to file its annual WMP filing on or about October 1 each year.
Staff has no issues with this request and recommends the Commission issue an order allowing
the Company to file its WMP on or about October 1 of each year.
STAFF COMMENTS 16 FFBRUARY 12, 2026

Cost-Benefit Approach
Idaho Code § 61-1804(1)(b) requires the Commission to consider the feasibility of the
plan and the cost of its implementation. In Order Nos. 36774 and 36882, the Commission
ordered the Company to include a cost-benefit analysis within its WMPs and provided guidance
on the type of necessary information.
The Company provided a company-wide cost-benefit analysis in its 2026 WMP. While a
portfolio-level assessment approach may provide high-level context, Staff believes it is
insufficient to evaluate the prudence of individual wildfire mitigation investments. 2026 WMP -
Section 14 and Appendix F. Staff recommends the Company conduct cost-benefit analysis on a
project-by-project basis to demonstrate that each project reasonably balances costs with a
reduction in wildfire risk.
Staff notes that the benefits associated with individual projects need not be quantified
solely in monetary terms; however, the Company must apply a consistent and transparent
methodology across projects. Consistency is necessary to allow Staff and the Commission to
assess whether proposed projects are being evaluated and prioritized using comparable criteria.
Based on its review, Staff believes the Company did not provide documentation showing
project-by-project cost-benefit calculations or decision analyses. Absent such information, Staff
cannot determine whether individual projects were independently justified or whether the overall
proposal reflects the most reasonable use of ratepayer funds.
Staff believes more specific cost information would improve the cost evaluation of each
wildfire mitigation effort. Staff recommends the Company include in future WMPs average cost
information for projects, such as installation costs of steel poles, fire mesh wraps, wildfire
detection cameras,undergrounding, covered conductor, fiberglass crossarms, wooden crossarms,
and weather stations, etc. Staff suggests that the Company consider assigning a value to projects
to represent the resultant decrease in wildfire risk that the relevant asset represents if said project
was carried out.
Although, Staff reviewed the forecasted capital and O&M expenditures in this WMP,
Commission approval of the WMP does not guarantee cost recovery. The prudence of the WMP
capital and O&M expenses will be evaluated in a future rate proceeding.
STAFF COMMENTS 17 FFBRUARY 12, 2026

Pole Attachments
In response to Staff Production Request No. 17, the Company stated that it did not
include third-party pole attachments in its wildfire risk modeling, but it is investigating ways to
consider pole attachments in future risk evaluations. Staff supports the Company's investigation
and possible inclusion in future wildfire risk models.
Metrics
The WMP does not describe the metrics the Company will use for its wildfire mitigation
efforts, operations, and projects. In response to Production Request Nos. 3, 4, 5, 24, and 46, the
Company provided many of the metrics that will be used.
Staff believes these metrics and the data collected are valuable and should be included
within the WMP for tracking to show progress and to display the feasibility of the WMP and to
the degree it minimizes wildfire risk. Therefore, Staff recommends the Company include all
metrics used for the WMP within each respective sections of future WMPs and provide the data
in a format that can easily be tracked across WMP filings.
Coordination with IDL
Idaho Code § 61-1804(3) requires the Commission to consult with the State Forester at
IDL, specifically in regard to vegetation management, reduction of wildfire fuels, and other
duties of the state forester under Title 38, Idaho Code.
On November 3, 2025, Staff confirmed that IDL received the notification of the
Company's WMP filing. On November 13, 2025, Staff met with IDL to discuss IDL's desired
participation in the case. Staff and IDL agreed to meet multiple times during the review of the
Company's WMP. On December 15, 2025, Staff held a meeting with the Company and IDL to
discuss the Company's wildfire risk model, inputs, and outputs.
On January 29, 2026, Staff and IDL met to discuss recommendations and concerns with
the Company's WMP. IDL expressed concerns with: (1) the descriptions of inputs within in the
risk modeling section, (2) the Company's cost-benefit approach, (3)the Company's address of
fair market value for marketable timber, (4) vegetation management inspection not meeting
wildland fire risk standards, and(5) the lack of thorough descriptions of the Fuel Reduction
Projects that are outside of the right-of-way. IDL stated it would provide comments with
STAFF COMMENTS 18 FFBRUARY 12, 2026

recommendations wherein. Staff considers these concerns valid and supports IDL's
recommendations.
Public Comments
As of February 12, 2026, two public comments were filed. Neither of these comments
are from customers in the Company's service territory. The first comment supported the
Company's WMP and encouraged the Commission to ensure the Company continuously
improves its approach to wildfire mitigation, specifically with regards to technology. The
second comment also supported the Company's WMP and recommended the Commission
consider blockchain-based verification infrastructure to "strengthen implementation
accountability under SB 1183, the Wildfire Standard of Care Act."
STAFF RECOMMENDATION
Staff recommends the Commission issue an order:
1. Approving the 2026 WMP;
2. Approving the Company's request to file its WMP on or about October 1 each year;
3. Requiring the Company include copies of the Company's four most-recent quarterly
NERC FAC-003-X compliance reports as attachments in future WMPs (where X
represents the latest version of the standard the Company is using); and
4. Requiring the Company include copies of current Transmission Maintenance and
Inspection plans used for NERC FAC-501-WECC-X compliance and any violations
noted from the most recent NERC compliance audit(X represents the latest version of the
standard the Company is using).
Additionally, Staff recommends the Company do the following in future WMPs:
1. Continue to separate internal wildfire mitigation labor in cost forecasts;
2. Continue to explore methods to reduce costs with communication and education
regarding wildfire and PSPS;
3. Continue providing details of all funding alternatives and sources pursued within the
WMP;
4. Address the types of infrastructure left out of risk modeling and, if not included in the
Company's models, provide an explanation as to why;
STAFF COMMENTS 19 FFBRUARY 12, 2026

5. Find ways to include loss of life as a parameter in its future wildfire risk assessments and,
at a minimum, include it as a qualitative parameter where loss of life has higher
probabilities;
6. Take necessary steps to integrate asset condition/inspection data and failure modes into
ignition models as a part of geographical risk modeling and assessment;
7. Include quantitative model validation data and analysis as a part of geographical risk
modeling and assessment;
8. Include the estimated cost,planned duration, and evaluation metrics of each pilot
program;
9. Set and publish annual miles for all T&D hardening programs and projects by WRZ Tier
or feeder, plus modeled ignition risk reduction per mile for each category;
10. Adopt an effectiveness scorecard for each grid hardening method(including but not
limited to covered conductor, non-wooden poles, non-wooden crossarms,
undergrounding, etc.)based on industry guidance;
11. Include a table that includes all T&D rebuild and grid hardening projects that includes the
following: project name, project type, primary driver, location, design standards,
anticipated project timeline, and estimated costs within the WMP. Including an
explanation if the wildfire mitigation priority of the project changed any aspects of the
project(i.e., design, costs, and timeline);
12. Include the internal vegetation management crew description within Section 10.2 of the
WMP;
13. Adopt and mature implementation of industry best practices in configuration
management, requirements management, test management, and issue and defect tracking
for all custom models or software developed for the FPI tool, as well as other custom-
developed models or applications that play a critical role in the Company's WMP;
14. Add more detail about the resources available to call center agents during a PSPS within
Appendix B;
15. Expand reporting for future WMPs to include both transmission and distribution assets
not covered by NERC standards to offer a more comprehensive view of trends and
effectiveness across the utility's entire system;
STAFF COMMENTS 20 FEBRUARY 12, 2026

16. Conduct cost-benefit analysis on a project-by-project basis to demonstrate that each
project reasonably balances the costs with the reduction in wildfire risk;
17. Identify the average cost of information for projects, such as installation costs of the
following: steel poles, fire mesh wraps, wildfire detection cameras, undergrounding,
covered conductor, fiberglass cross arms to wooden, and weather stations; and
18. Add all metrics that will be used for the WMP be included within each respective section
of the WMP and provide the data in a format that can be tracked in each version of the
WMP.
Respectfully submitted this 12th day of February 2026.
Erika K. Melanson
Deputy Attorney General
Technical Staff. Kimberly Loskot, Karla Ducharme, Joe Terry, and Shubhra Deb Paul
I:\Utility\UMISC\COMMENTS\IPC-E-25-32 Staff Comments.docx
STAFF COMMENTS 21 FEBRUARY 12, 2026

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 121h DAY OF FEBRUARY 2026,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN CASE
NO. IPC-E-25-32, BY E-MAILING A COPY THEREOF TO THE FOLLOWING:
Idaho Power Company:
MEGAN GOICOECHEA ALLEN TIM TATUM
LISA C. LANCE CONNIE ASCHENBRENNER
REGULATORY DOCKETS RILEY MALONEY
IDAHO POWER COMPANY IDAHO POWER COMPANY
1221 WEST IDAHO STREET (83702) 1221 WEST IDAHO STREET (83702)
P.O. BOX 70 P.O. BOX 70
BOISE, ID 83707 BOISE, ID 83707
E-MAIL: E-MAIL:
mgoicoecheaallengidahopower.com ttatum(kidahopower.com
llance(d),idahopower.com caschenbrenner a,idahopower.com
docketskidahopower.com rmaloney&idahopower.com
Idaho Department of Lands: Micron:
J.J. Winters Austin Rueschhoff
Attorney for IDL Thorvald A. Nelson
300 N. 6th St., Ste 103 Austin W. Jensen
Boise, ID 83702 Kristine A.K. Roach
jwinters a,idl.idaho.gov Holland&Hart, LLP
555 171h St., Ste. 3200
Tyre Holfeltz Denver, CO 80202
Wildfire Risk Management Program Manager E-MAIL:
tholfeltz(c�r�,idl.idaho.gov darueschhoff(c�hollandhart.com
tnels on&hollandhart.com
Julia Lauch aw'enl sen(chollandhart.com
State Forester karoach(khollandhart.com
jlauch a,idl.idaho.gov aclee(a),hollandhart.com
tlfriel(khollandhart.com
PATRICIA JORD , SECRETARY
CERTIFICATE OF SERVICE