20260213Comments_3.pdf

NW Energy Coalition
for a clean and affordable energy future
RECEIVED
February 12, 2026
IDAHO PUBLIC
February 12, 2026 UTILITIES COMMISSION
Northwest Energy Coalition
811 1st Avenue, Suite 305
Seattle, WA 98104
RE: Case No. IPC-E-25-32 -NW Energy Coalition Public Comments on Idaho Power
Company 2025 Wildfire Mitigation Plan
Dear Commissioners,
The NW Energy Coalition(NWEC) appreciates the opportunity to comment on Idaho Power's
2026 Wildfire Mitigation Plan and we thank the Idaho Public Utilities Commission(IPUC, or the
Commission) for its efforts in reviewing and analyzing the plan. NWEC is composed of over 100
organizations focused on environmental, civic, and human services, along with progressive
utilities and businesses. We advocate for clean, equitable, safe, and affordable energy policies
across Washington, Oregon, Idaho, and Montana.
The following perspectives and considerations are informed by NWEC's active engagement in
reviewing investor-owned utility wildfire mitigation plans, rulemakings, and implementation
processes across the region. We offer them in hopes to assist the Commission in its review and
consideration of Idaho Power's plan to better serve Idaho Power customers.
We appreciate Idaho Power's efforts in creating a comprehensive plan with a clear layout for
readability. We also commend the utility for maintaining and leveraging important partnerships
that promote cost savings and enhance coordination, including its role in the Idaho Fire Camera
Interoperability Committee (IFCIC) and collaboration with local public safety partners to benefit
from the wildfire detection camera network. Additionally, we value and support Idaho Power's
collaboration with community-based organizations to support public outreach, education, and
preparedness.
We encourage Idaho Power to expand public education, awareness, and clear protocols related to
Enhanced Protection Settings (EPS). Because EPS-related shutoffs are more likely to occur than
Public Safety Power Shutoffs and are unplanned, they can create confusion, distress, financial
loss, and safety risks for customers and businesses. Proactive communication and preparedness
efforts are essential to mitigate these impacts.

With the passage of the Wildfire Standard of Care Act(SB 1183) last year, a new legal
framework now provides some liability protections for electric utilities that reasonably
implement a Commission-approved wildfire mitigation plan. This heightened protection and the
significant costs of the plan underscores the need for rigorous review and approval process,
including, if feasible, enhanced oversight through IPUC or third-party on-the-ground inspections,
audits, and other verification of utility activities to ensure proposed activities are implemented
effectively.
While capital investments are necessary, it is imperative that expenditures remain reasonable,
particularly because customers ultimately bear these costs. Customers should see tangible
benefits from wildfire mitigation investments. For example, programs supporting vulnerable
customers through battery backup systems or home fire hardening that can deliver more
cost-effective, near-term community benefits and enhance emergency preparedness. Investments
in community preparedness meaningfully reduce harm, lower long-term recovery costs
including rebuilding and insurance impacts—and improve response capabilities. It is important
to balance spending on advanced modeling, situational awareness, and grid hardening with
front-end investments that are proven and supportive of community energy resilience and safety.
Moreover, risk reduction analysis should extend beyond ignition risk from utility assets to
include cumulative community impacts such as wildfire smoke exposure, displacement,power
outages, fire spread and intensity, and economic disruption.
Finally, as wildfire weather conditions have intensified and Wildland and Urban Interface areas
have grown, wildfire risk zones will likely expand. It is therefore essential to support
forward-looking investments by investor-owned utilities that reduce long-term costs,prioritize
co-benefits,promote coordinated planning, and take a holistic approach to risk reduction,
interoperability, land stewardship, grid islanding, and community resilience.
Thank you for your time and consideration.
Respectfully,
Alessandra de la Torre
Policy Associate
NW Energy Coalition

From: Joe Lombardo
To: secretary
Cc: aaonzalez(ftayettecounty.org;Juan Bonilla; Rebecca Squires;Tiffany Westbrook
Subject: Comments on Idaho Power Wildfire Mitigation Plan
Date: Friday,February 13,2026 9:52:41 AM
Attachments: imaae001.Dna
imaoe002.Dna
imaae003.Dna
CAUTION-This email originated outside the State of Idaho network_Verifv links and attachments
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Greetings:
Included please find comments from The Idaho Emergency Management Association (IEMA)
Advocacy and Education Committee on the Idaho& Montana 2026 Wildfire Mitigation Plan
from Idaho Power.
Public safety power shutoffs (PSPS)take place when electric utilities de-energize power lines
during hazardous weather conditions to protect the communications infrastructure and
reduce the risk and impact of wildfires. The Idaho Emergency Management Association (IEMA)
appreciates efforts taken by power providers to keep our community and responders safe,
which includes spreading awareness of wildfire risk zones and the imperative for personal
preparedness,with special attention to medical or mobility needs of our vulnerable
populations when such shutoffs occur.
The 2026 fire season has the potential to be highly active in the State of Idaho.Thus, IEMA
asserts that coordinated planning for the impacts of these PSPS events is critical, particularly
in regard to opening and maintaining Community Resource Centers (CRC).
Power providers cite the importance of establishing CRC for its customers affected by PSPS
outages, as those facilities can provide basic mass care services, such as hydration,
temporary shelter, device-charging, and situational updates. For any power outage of a
significant duration, an all-of-community effort will be needed to address resource gaps
associated with power loss and support CRC operations.This partnership will include assets
from power providers, public safety, and volunteer organizations.
While local emergency managers can be very effective in establishing and coordinating such
partnerships,the logistical challenges for local agencies supporting CRC operations are
important to consider. Local communities are faced with limited capacity,which can be
exacerbated by elevated demands on public safety during extreme weather and fire risk.We
encourage power providers and local emergency management to engage early and
communicate often.
To explore the shared mission space associated with CRC, IEMA recommends that mitigation

or operations plans should result from regionally driven, scenario-based planning
discussions, occurring prior to the start of wildfire season. This will help establish resource
needs, confirm roles and responsibilities, develop shared strategies, and assess the feasibility
of proposed actions.
Please reach out with any questions or follow-on as necessary
Regards
Joe Lombardo, CEM, MEP,ABCP
�1 Director
Ada County Emergency Management
&Community Resilience
7200 Barrister Dr.,Boise,ID 83704
[phone] office
[phone] cell
Email:ilombardo(@adacounty.id. og_v
Visit us online at http://www.adaprepare.id.iiov
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ILPUBLIC WORKS DEPARTMENT RECEIVED
B O I S E MAYOR: Lauren McLean I DIRECTOR:Stephan Burgos February 13, 2026
"T YT IDAHO PUBLIC
MEMOUTILITIES COMMISSION
February 13, 2026
Monica Barrios Sanchez, Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd
Bldg 8, Ste 201-A
Boise, ID 83714
SUBJECT: Case No. IPC-E-25-32- 2026 Wildfire Mitigation Plan
Dear Ms. Barrios Sanchez,
On behalf of the City of Boise City ("City"), we respectfully submit these comments
concerning the 2026 Idaho Power Wildfire Mitigation Plan (WMP). The City appreciates
the opportunity to provide feedback and commends Idaho Power on its continued
work to produce a WMP that is both comprehensive and specific, and which takes into
account the trend of increasing wildfire suppression damages that have occurred
nationally over the last decade'. We also appreciate the continued collaboration to
ensure that Boise is resilient to the ongoing threat of wildfire in our community.
Comments to specific sections of the report, with relevant citations, are provided
below:
Section 6.8: Community Resource Centers (pp. 33-34)
The City notes that the deployment of Community Resource Centers (CRCs) during
Public Safety Power Shutoff (PSPS) events is a new element of the 2026 WMP (Section
6.8, pp. 33-34). The City recognizes this addition as timely, and provides comments
below from an emergency management perspective.
Shared Preparedness Challenges
The City concurs with the following assertions from Idaho Power regarding preparedness
for a PSPS:
• Local jurisdictions should be encouraged to have awareness of wildfire risk zones
and cross-infrastructure dependencies that could be affected by PSPS events
' Wildland Fire Suppression costs,2019-2024.ht!ps://www.nifc.gov/fire-information/statistics/suppression-costs,
February 11,2026
BOISE CITY HALL:150 N.Capitol Boulevard I MAIL:P.O.Box 500,Boise,Idaho 83701-0500 1 P:208-608-7150 1 TTY:711
BOISE CITY COUNCIL:Meredith Stead(President), Kathy Corless(President Pro Tem),Jimmy Hallyburton,Jordan Morales,Colin Nash,Luci Willits
CITYOFBOISE.ORG/PUBLICWORKS

• Households should embrace personal preparedness, considering any medical or
mobility needs
Additionally, it is appreciated that Idaho Power is willing to cooperate with emergency
management and public safety when power lines must be de-energized due to
hazardous weather conditions. However, as the plan cites, those proactive de-
energizations require extensive planning and strategy. Regional power outages of a
significant duration, even with the assistance of Idaho Power's field assets and State,
regional, and volunteer (e.g. Red Cross) organizations could still present a significant
resource and operational challenge for local communities to manage.
Idaho Power's willingness to deploy a response trailer equipped with mobile power
capacity and other amenities to assist with mass care missions is an acknowledgement
of the potential impacts of infrastructure impacts. Local emergency managers
welcome this collaboration, however, also important is a shared understanding of risk
exposure, potential cascading impacts, and the degree of shared resources that would
be needed for response.
Role of Emergency Management
The Idaho Power WMP appropriately cites that local emergency management
agencies provide and coordinate the local response to emergencies and disasters
(p33). However, exclusive management of CRC operations by local agencies during a
PSPS could divert limited emergency response resources away from their core statutory
mission.
Considering the degree of local resourcing available and pre-existing mission space,
local agencies can readily support the utility in a coordination and advisory capacity.
Potential areas of assistance include:
CRC Location Identification (Advisory Support)
• Identifying potential CRC sites such as community centers, libraries, schools, and
other public facilities
• Advising on demographic assumptions to ensure CRC coverage aligns with
impacted neighborhoods and vulnerable populations
• Providing insight into historical evacuation areas, high-risk zones, and
communities with limited mobility or transportation access
• Coordinating introductions with facility owners or jurisdictional partners, where
appropriate
Operational Needs and Site Suitability Guidance
• Advising on site accessibility requirements, including ADA access and proximity
to public transportation
• Identifying locations suitable for individuals with access and functional needs,
including seniors and medically vulnerable populations
• Recommending sites with adequate space, restrooms, parking, and climate-
controlled indoor environments when available
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• Sharing local considerations related to traffic flow, security concerns, and
neighborhood impacts
Coordination and Information Sharing
• Integrating CRC locations and operating hours into emergency communications
and situational awareness products
• Coordinating messaging consistency across local government, emergency
operations centers, and public information channels
• Facilitating alignment with broader emergency response activities without
assuring CRC staffing or operational control
Planning and Pre-Event Collaboration
• Participating in pre-season planning discussions and after-action reviews related
to PSPS events
• Providing feedback on CRC performance, gaps, and community needs
observed during past events
• Supporting continuity of operations planning to ensure CRC activation does not
conflict with emergency response priorities
Clarifying Boundary of Responsibility
Local emergency management agencies apply limited resources to address their
assigned areas of responsibility. Before Idaho Power can assign definitive functional
responsibility for CRC operation to local emergency managers, it is critical to clarify
whether CRC support functions can or should include funding, staffing, managing, or
operating the CRC. Additional review is needed before any binding statement of policy
can be finalized that could transfer risk, responsibility, or liability from a utility to local
government.
To understand allocation of responsibility, it is important to perform a thorough review of
established industry practice for precedent. Electric utilities are regulated entities with
defined duties of care related to service interruptions and approved cost-recovery
mechanisms to fund PSPS mitigations. Investor-owned utilities such as Pacific Gas &
Electric (PG&E), Southern California Edison (SCE), and San Diego Gas & Electric (SDG&E)
explicitly plan, fund, and operate CRCs as part of their PSPS mitigation obligations2.
These utilities maintain formal CRC plans, contract for CRC staffing and equipment, and
activate CRCs when PSPS events occur. This is done by coordinating with, but not
delegating responsibility to, local governments. Regulatory bodies, including the
California Public Utilities Commission, require these utilities to document CRC planning
and activation as part of their PSPS preparedness and reporting requirements.
In Idaho, Rocky Mountain Power, which services over 1.2 million companies across
Idaho, Utah, and Wyoming, plans to provide support to impacted communities through
activation of CRCs when appropriate. Their Wildfire Mitigation Plan describes the
degree of services the company may provide in collaboration with local public safety
2 PG&E CRCs, SCE CRCs, SDG&E CRCs
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agencies3. CRC activation timing, protocols, and locations are discussed prior to
incidents with area emergency management and community-based organizations
during workshop discussions and tabletop exercises.
Avista Utilities, which provides power to customers across 30,000 square miles in eastern
Washington, northern Idaho, and parts of southern and eastern Oregon, cites in its
Wildfire Resiliency Plan & Report, the importance of tabletop exercises to identify
potential locations for CRCs in its service areas prior to PSPS4. These efforts help build
readiness, awareness, and relationships around PSPS. Additionally, the company
partners with a third-party contractor to assist with CRC setup and operation, including
services such as air conditioning, electronic and medical device charging,
snacks/water/ice, and information regarding the outage. Avista Utilities also offers a
battery backup program which shops batteries at no cost to qualified life support
customers.
It is recommended that Idaho Power engage in additional preparedness and
assessment activities with the communities it serves to evaluate its approach to CRC
activation. Through partnership with local public safety agencies, more deliberate and
effective planning and resourcing of CRC can be achieved.
Understanding Planning Factors
When operational roles, responsibilities, and a requisite degree of capacity are
determined in plans - in this case for the response to a utility power outage -there are
questions to be explored that help determine how plans are written and resources are
allocated. In the case of PSPS, discussions are needed to identify agreed-upon findings
to the following questions:
• Where are these outages likely to occur?
• What are the likely worst-case duration(s) for plausible scenarios involving PSPS?
• What is the potential for cascading, cross-infrastructure impact?
• What are partner roles and responsibilities for the mass care mission as it relates
to extended power loss?
Proposed Action
We respectfully request that Idaho Power schedule a regional discussion-based
exercise(s) reviewing plausible PSPS scenarios prior to the start of wildfire season. This will
help establish resource needs, partner expectations, and the feasibility of proposed
actions.
Section 9. Vegetation Management (pp. 47-52)
From a firefighting perspective, the City acknowledges the work done to develop a
vegetation management plan that makes sense for the Boise area. Our fuels are mainly
'Section 8.7 2026-2028 Rocky Mountain Idaho Wildfire Mitigation Plan
4 P.58 AVU-E-25-15 -Avista Corporation's 2026 Wildfire Mitigation Plan
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sagebrush and grass, and the strategy and cadence outlined in Section 9 is reasonable
and consistent with local fire considerations. Of note, City staff commend Idaho Power
staff for their efforts to maintain a vegetation-free radius around wood poles.
Section 11.2-Community Engagement (pp. 57-59)
The City appreciates Idaho Power's ongoing coordination with public safety partners,
local governments, and critical facilities. The City has no additional comments at this
time regarding the community engagement strategies described.
Section 11.3- Event-Specific Communication and PSPS Communications (pp. 60-61)
The City looks forward to the opportunity to continue to engage with Idaho Power on
verifying City of Boise critical infrastructure locations and ensuring appropriate points of
contact are identified in Idaho Power systems for timely alerting of potential PSPS
events.
One recommendation the City (along with other regional emergency-response
partners) has prior to plan adoption is to schedule a regional discussion-based
exercise(s) reviewing plausible PSPS scenarios prior to the start of wildfire season. This will
help establish resource needs, partner expectations, and the feasibility of proposed
actions.
General - Inclusion of climate language
The City is fully supportive of Idaho Power's "Clean by 2045" goal to reduce electricity
emissions5. In 2025, the City provided comments on Idaho Power's 2025 Integrated
Resource Plan ("IRP"), which included content related to the 2025 WMP. In these
comments, the City applauded Idaho Power for its acknowledgement of climate
change as a key driver of increased wildfire and intensity. In the 2026 WMP, all of the
specific references to climate change are no longer included. For example, Section 1 .2
outlines the extended fire risk period, noting that "climate change has contributed to
warmer temperatures, reduced snowpack, and earlier snowmelt" (2025 WMP). This
reference is removed in section 1.2 of the 2026 plan. In Section 4.5.2, the phrase
"increasing climate variability" as a need for enhanced forecasting abilities is removed,
and the 2026 plan merely references "iterative decision making" as a key factor
leading to the need for enhanced forecasting abilities. This trend continues throughout
the document.
The 2025 WMP explicitly modeled escalating wildfire risk driven by climate change,
including hotter, drier summers and more frequent extreme weather. The 2026 plan
references "changing climatic conditions" and emphasizes year-to-year variability.
While the 2026 WMP continues to address wildfire risk through weather monitoring, fuel
conditions, and fire behavior modeling, the City expresses concern that the elimination
of the climate-forward messaging minimizes the heightened risk of wildfire due to
s hgps://www.idahol2ower.com/energy-environment/energy/clean-today-cleaner-tomorrow/
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climate change. The effects of climate change have real impact to the Idaho Power
grid and to future generation choices, as consistently modeled in the IRP's "extreme
weather"scenarios.
We encourage Idaho Power to explicitly model both these risks and the potential
increased costs of wildfire mitigation due to the ongoing threat from climate change.
If you have any questions, please contact the Department of Public Works at (208) 608-
3200.
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