20260219APPLICATION - Updated.pdf

RECEIVED
February 19, 2026
IDAHO PUBLIC
UTILITIES COMMISSION
JAMES .) VERNON & WEEKS , P . A .
ATTORNEYS AT LAW
SUSAN P.WEEKS
February 19, 2026
Via Email to: [e-mail]
Monica Barrios-Sanchez
Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd. Building 8, Suite 201-A
Boise, ID 83714
RE: Northern Lights,Inc.
Updated Application for Approval of 2026-2028 Wildfire Mitigation Plan
Case No. C10-E-26-01
Dear Ms. Barrios-Sanchez:
Please find attached an Updated Application for Approval of the 2026-2028 Wildfire Mitigation Plan
for Norther Lights,Inc.("NLI").Please let me know if you need anything further or have any concerns
regarding the attached updated filing.
Very truly yours,
5uz-'k" �'ZW".&&
Susan P.Weeks
Attachment Transmittal
Cc: Client
1626 LINCOLN WAY,COEUR D'ALENE,ID 83814 TELEPHONE: [phone] FACSIMILE: [phone]

Susan P. Weeks, ISB No. 4255
James,Vernon&Weeks, P.A.
1626 Lincoln Way
Coeur d'Alene, ID 83814
Email: [e-mail]
Attorney for Northern Lights, Inc.
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE CASE NO. C10-E-26-01
APPLICATION OF NORTHERN
LIGHTS,INC. FOR APPROVAL OF UPDATED APPLICATION OF
ITS WILDFIRE MITIGATION PLAN NORTHERN LIGHTS,INC.
Northern Lights, Inc. ("NLI" or"Applicant"), in accordance with Idaho Code § 6-1801, et
seq., including §§ 61-1803 and 61-1804, Rule of Procedure 52, and the Commission's Order No.
36774, respectfully submits this updated application ("Application") to the Idaho Public Utilities
Commission ("Commission"), requesting that the Commission issue an order approving its
updated 2026 Wildfire Mitigation Plan("WMP"), included as Attachment A, in accordance with
the Wildfire Standard of Care Act.
In support of its Application, the Applicant states as follows:
I. INTRODUCTION
1. NLI is a non-profit Idaho corporation meeting the definition of a "cooperative
electrical association" as set forth in Idaho Code § 63-3501. NLI's principal place of business is
Sagle, Idaho. NLI provides electric service in Kootenai and Bonner Counties in Idaho.
Additionally, it serves members in Pend Oreille County, Washington, and in Sanders and Lincoln
Counties, Montana.Additional information about NLI is included the "Need to Know Document"
attached hereto as Attachment B.
2. In the 2025 legislative session,the Idaho Legislature enacted the Wildfire Standard
UPDATED APPLICATION OF NORTHERN LIGHTS, INC.: 1

of Care Act. 2025 Idaho Sess. Laws Ch. 249 (S.B. 1183) ("Act"). The Act allows electric
cooperatives that are not public utilities to adopt and file a Wildfire Mitigation Plan("WMP")with
the Commission. I.C. § 61-1803(2)(b). The Commission is required to approve or reject each
WMP within six(6)months of the date such WMP is filed with the Commission. I.C. § 61-1804(1).
NLI filed its initial WMP on February 2, 2026. This filing constitutes an updated Application.
3. The 2026 WMP is designed to comply with Idaho Code § 61-1803(3), Order No.
36774, and the WMP Guidelines adopted in Case No. GNR-E-25-02. The WMP outlines the
strategies, practices, and mitigation measures NLI will use to address wildfire risk, balancing
mitigation costs with the resulting reduction in wildfire risk exposure.The 2026 WMP is structured
as a rolling three-year plan covering the period 2026-2028. The Plan will be reviewed annually
and updated as appropriate to extend the planning horizon and incorporate lessons learned,updated
risk modeling, evolving mitigation practices, and budget forecasts, consistent with Order No.
36774.
II. SUMMARY OF THE 2026 WILDFIRE MITIGATION PLAN
A. Identifying Geographical Areas of Heightened Wildfire Risk
4. The Act requires each WMP to identify geographical areas where infrastructure
may be subject to heightened wildfire risk. I.C. § 61-1803(3)(a).As described in Section 6 of the
WMP, NLI conducted a baseline wildfire risk assessment using models incorporating vegetation,
weather, topography, historical fire occurrence, and asset location. Risk maps categorize service
territory by severity levels. NLI considers the eastern portion of its service territory along the
Idaho-Montana border, and into Montana, to be higher risk.
5. Elevated wildfire risk areas are categorized using modeled severity levels. These
levels are used to prioritize vegetation management scheduling, inspection frequency, system
UPDATED APPLICATION OF NORTHERN LIGHTS, INC.: 2

hardening investments, relay setting adjustments, and potential Public Safety Power Shutoff
(PSPS) consideration. Risk modeling outputs are reviewed annually and updated as necessary to
reflect changes in vegetation, infrastructure, or climatic conditions.
B. Preventive Actions and Programs to Reduce Wildfire Risk
6. The Act requires inclusion of preventive actions and programs to reduce wildfire
risk. I.C. § 61-1803(3)(b). The Guidelines require situational awareness efforts, asset inspections,
enhanced vegetation management practices, operational practices during heightened wildfire risk,
and community education.
7. NLI's situational awareness efforts are described in Section 7.1 of the WMP. NLI
utilizes National Weather Service data, Northern Rockies Geographic Area Coordination Center
data, Pyrecast fire forecasting tools, and field observations. NLI has received grant funding to
develop its own weather station network, which will integrate into a Daily Situational Awareness
Tool expected to be operational by the end of 2026.
8. Weather and situational awareness data are used to inform operational decisions,
including relay and recloser settings, field observer deployment, inspection prioritization, and
potential PSPS implementation.
9. NLI's asset inspection program is described in Section 7.4.NLI began an inspection
program in 2024, utilizing mobile tablets and GIS-linked survey forms. NLI's goal is to inspect
100% of overhead distribution lines within a seven-year rotation cycle. NLI contracts for pole
testing covering approximately 8-10% of poles annually. Meters are inspected on a four-year
cycle. High-priority deficiencies identified during inspections are assigned corrective action as
soon as practicable.Medium-and low-priority items are scheduled and tracked through NLI's GIS-
based inspection dashboard.
UPDATED APPLICATION OF NORTHERN LIGHTS, INC.: 3

10. NLI's fuel and vegetation management program is described in Section 7.3. The
program operates on a target seven-year trim cycle for overhead line segments. Hazard tree
identification and removal are prioritized in areas with elevated wildfire risk. Satellite imagery and
AI-assisted analysis inform work prioritization. Annual vegetation management mileage and
removal activity are tracked and reviewed internally to assess performance and adjust resource
allocation as necessary.
11. NLI's workforce training is explained in Section 7.5. Monthly safety meetings are
held, covering wildfire and other safety topics.NLI also coordinates training and other events with
local fire departments.
12. Operational practices during heightened wildfire risk are described in Section 7.6.
NLI employs two seasonal protection setting levels based on fire restrictions. NLI also developed
a PSPS program in 2025, described in Section 7.7,which relies on situational awareness inputs to
determine when de-energization may be necessary as a measure of last resort.
C. Community Outreach and Government Coordination
13. The Act requires community outreach and coordination with federal, state, tribal,
and local officials. I.C. § 61-1803(3)(c) and(d).
14. NLI's outreach efforts with its members are described in Section 8 of the WMP.
Communication methods include social media, NLI's website, print publications, bill stuffers,
online videos, annual member meetings, and direct member engagement. During wildfire events,
NLI may utilize interactive voice response systems and coordinate with local jurisdictions to
distribute countywide alerts.
15. Coordination with local tribal entities is discussed in Section 5.3. Section 5.4
discusses emergency management and incident response. Section 8.1 discusses the current
UPDATED APPLICATION OF NORTHERN LIGHTS, INC.: 4

community outreach and public awareness program, including notice to entities per I.C. § 61-
1084(2).
16. NLI conducted workshops prior to finalizing its WMP and will share the Plan with
the Idaho State Forester, counties, fire protection districts, and associations within its service area.
Restoration following wildfire events or PSPS will be coordinated with local fire chiefs or incident
commanders.
17. Pursuant to Idaho Code § 61-1804(3),NLI will provide its WMP to the Idaho State
Forester and will consider any recommendations received. To the extent recommendations are
incorporated, such incorporation shall support the statutory presumption that the Plan complies
with the Act.
D. Cost-Benefit Analysis and Forecasted Program Expenditures
18. Order No. 36774 requires a cost-benefit analysis demonstrating a reasonable
balancing of mitigation costs with wildfire risk reduction.
19. NLI evaluates wildfire mitigation projects and programs using a cost-versus-risk-
reduction framework. Projects are assessed based on:
1. Relative wildfire ignition risk in the affected area;
2. Likelihood of vegetation or equipment-related ignition absent mitigation;
3. Expected reduction in ignition probability or severity;
4. System reliability benefits; and
5. Total capital and operational cost.
20. Vegetation management, inspection programs, system protection adjustments, and
system hardening measures, including undergrounding and steel pole replacement, are prioritized
in elevated wildfire risk zones identified in Section 6.
21. Cost evaluations are reviewed in Section 11 of the WMP.
22. Forecasted expenditures for 2026-2028 are categorized as:
UPDATED APPLICATION OF NORTHERN LIGHTS, INC.: 5

• Capital Improvements (system hardening, pole replacement, undergrounding)
• Operations &Maintenance (inspection,protection settings, operational mitigation
measures)
• Vegetation Management
23. These expenditures are reflected in NLI's approved budget forecasts and represent
a reasonable balancing of wildfire mitigation cost with resulting risk reduction, consistent with
Idaho Code § 61-1803(3)and Order No. 36774.As cost-tracking data accumulates,NLI will refine
quantitative cost-benefit comparisons in future WMP updates.
24. Line design and constructions standards are set forth in Section 7.2 of the WMP.
This section also discusses inspection of assets and goals.
III. COMPLIANCE WITH ORDER NO. 36774
25. NLI has structured its 2026 WMP to comply with Order No. 36774 and the IPUC
Wildfire Mitigation Plan Guidelines. Specifically, the WMP:
• Identifies geographic wildfire risk areas and associated modeling methodologies;
• Describes situational awareness tools and operational integration;
• Establishes inspection and vegetation management cycles with measurable
objectives;
• Describes operational mitigation measures, including relay adjustments and PSPS
protocols;
• Includes community outreach and government coordination procedures;
• Provides a rolling three-year planning horizon; and
• Includes a cost-balancing framework consistent with statutory and Commission
directives.
26. NLI's compliance matrix is attached hereto as Exhibit C.
IV. REQUEST FOR MODIFIED PROCEDURE
27. NLI respectfully submits that its 2026 WMP satisfies all statutory and regulatory
requirements.
UPDATED APPLICATION OF NORTHERN LIGHTS, INC.: 6

28. NLI will provide notice of this filing in accordance with the Act. LC. 61-1803(5).
Pursuant to the errata to Order No. 36774 issued by the Commission on December 22, 2025, NLI
has included a template form of notice as Attachment D to this Application.
29. An evidentiary hearing is not necessary to consider the issues presented in this
Application. Accordingly, NLI respectfully requests that the Commission issue an order
authorizing this Application to be processed under Modified Procedure pursuant to Rules 201-204,
which allow for consideration by written submission rather than by an evidentiary hearing.
V. CORRESPONDENCE OR COMMUNICATIONS
30. Correspondence and communications regarding this Updated Application should
be addressed to:
Kristin Burge
Engineering & Operations Manager
Northern Lights, Inc.
P.O. Box 269
Sagle, ID 83860
[e-mail]
Susan P. Weeks (ISB N o. 4255)
James,Vernon&Weeks, P.A.
1626 Lincoln Way
Coeur d'Alene, ID 83814
sweeks@jvwlaw net
Informal questions may be directed to Kristin Burge, Engineering & Operations Manager
at(208)263-5141.
VI. REQUEST FOR RELIEF
31. Wherefore,NLI respectfully requests that the Commission issue an order approving
UPDATED APPLICATION OF NORTHERN LIGHTS, INC.: 7

the Updated 2026 WMP in accordance with the WSCA.
Respectfully submitted this 19th day of February, 2025.
JAMES, VERNON &WEEKS, P.A.
/s/Susan P. Weeks
Susan P. Weeks
Attorneys for Northern Lights, Inc.
UPDATED APPLICATION OF NORTHERN LIGHTS, INC.: 8

ATTACHMENT A
NORTHERN LIGHTS, INC.
WILDFIRE MITIGATION PLAN

The power of local service
Northern Lights, Inc.
Wildfire Mitigation Plan
February 16, 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.
I.C.: Idaho Code
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.
i

1.2 Three-Year Planning Horizon
This Wildfire Mitigation Plan ("WMP") is structured as a rolling three-year plan covering the period 2026
through 2028.The Plan establishes mitigation programs, operational protocols, inspection cycles,
vegetation management standards, and capital improvement priorities intended to reduce wildfire risk
over this planning horizon.
The WMP is designed to be iterative and adaptive. NLI will conduct an annual review of the Plan to:
• Evaluate wildfire season performance metrics, including ignition incidents, inspection findings,
vegetation management outcomes, and system reliability indices;
• Review updated wildfire risk modeling and mapping;
• Incorporate lessons learned from operational experience, including any PSPS events or elevated
fire weather operations;
• Adjust mitigation strategies, prioritization of projects, and resource allocation as appropriate;
and
• Extend the planning horizon to maintain a rolling three-year outlook.
As part of this annual review process, NLI will assess whether program goals, inspection cycles,
vegetation management targets, and capital investments remain appropriately calibrated to the wildfire
risk profile of its service territory.Where modifications are warranted, updates will be incorporated into
subsequent WMP filings.
By maintaining a rolling three-year planning horizon, NLI ensures that wildfire mitigation efforts remain
forward-looking, data-informed, and aligned with evolving risk conditions and operational best
practices, consistent with Idaho Code § 61-1803 and Order No. 36774.
ii

Table of Contents
Section Page
1.0 Executive Summary .............................................................................................................i
1.1 Definitions....................................................................................................................... i
1.2 Three-Year Planning Horizon........................................................................................ 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
iii

7.7.2 Planned Updates..................................................................................................12
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?
'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
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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 manage 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.
s Montana requires a 45-day public comment period and a public meeting.
a 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
AL AN in
System Average Assess system
Interruption hardening& overall Reduction in annual
Duration Index reliability average score
(SAIDI)
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 and 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, it 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 EH10
ost Impact for Wildfire Mitigation
PSPSw High
Relayand Recloser Practicesow High
Vegetation Management High
Inspections Medium Medium
Under roundin High High
Replace wood poles with metal High Medium
Install fiberglass crossarms Medium Medium
Community Outreach Low Low
16

ATTACHMENT B
NEED TO KNOW DOCUMENTS

Electric Municipality and Cooperative Wildfire
Mitigation Plan Need to Know Document
Pursuant to Idaho Code § 61-1803(3), a Wildfire Mitigation Plan("WMP")
must be reflective and commensurate with the size and complexity of the electric
corporation's operations and of the nature of the fire risk.A WMP must also reflect
a reasonable balancing of mitigation costs with the resulting reduction of wildfire
risk.
The purpose of this document is to collect basic information that will aid in
Staff s review to process a WMP. Please provide the following information and
provide the document along with each respective WMP filing.
1. Name of Utility
Northern Lights, Inc. (NLI)
2. Location of Utility:
NLI Main Office
421 Chevy St
Sagle, ID 83860
a. Located inside of the Wildland Urban Interface?
Yes.
3. Please provide a map of the Company's service territory. Please identify
the Company assets and provide a PDF zoomable.
Files provided in"NLI Service Area Maps.pdf'.
4. Total number of Customers:
a. Residential: 23,050
b. Commercial: 856
c. Other: 400
5. How is energy supplied to the Company?i.e., BPA,utility-owned generation, etc.
Energy supplied to NLI for distribution to members is supplied by BPA and through
PNGC, along with a small portion from NLI's Lake Creek hydroelectric dam.
a. What is the name plate capacity in Megawatts("MW")of utility-
owned generation sources?4.5 MW
b. What is the capacity factor of utility-owned generation sources?
51% at name plate.
NEED TO KNOW DOCUMENT

6. What is the annual amount of energy in Megawatt-hours that the utility serves?
For 2025, NLI served 436,620 Megawatt-hours.
7. What is the peak demand in MW and when does it occur?
January 2024: 120.3 MW
January 2025: 90.6 MW
8. Standard operating procedures ("SOP") for infrastructure management
and vegetation management?
See"NLI Infrastructure &Vegetation Management Procedure.pdf'
a. Annual spend? See below.
b. Annual incremental spend proposed in WMP from SOP? See below.
% Increase Increase
Increase from from
Budgeted for from prior Forecasted for prior Forecasted for prior
2026 year 2027 year Bot2028 year
Capital $ 9,281,000 -3.0% $ 9,652,240 4% $ 10,038,330 4%
0&M $ 8,003,002.00 3.2% $ 8,443,167.11 5.5% $ 8,780,893.79 4%
Vegetation $ 3,195,384.00 3.0% $ 3,355,153.20 5% $ 3,522,910.86 5%
9. Last 3 years of financial statements:
a. Income Statement
b. Cash Flow Statement
c. Balance Sheet
See provided audit statements for past 3 years.
NEED TO KNOW DOCUMENT

Northern Lights, Inc.
Balance Sheets
December 31, 2024 and 2023
2024 2023
ASSETS
NONCURRENT ASSETS
Net utility plant $ 94,891,690 $ 88,320,621
Right-of-use assets 7,074 46,843
Other assets and investments 5,290,191 5,203,436
Total noncurrent assets 100,188,955 93,570,900
CURRENT ASSETS
Cash and cash equivalents 1,566,089 1,137,573
Accounts receivable, net 4,636,097 4,771,947
Materials and supplies inventory 2,845,601 4,015,389
Other current assets 137,755 67,308
Total current assets 9,185,542 9,992,217
Total assets $ 109,374,497 $ 103,563,117
MEMBERS' EQUITY AND LIABILITIES
TOTAL MEMBERS' AND OTHER EQUITY $ 63,688,479 $ 62,624,608
LONG-TERM DEBT, less current maturities 31,429,337 24,610,306
LEASE LIABILITY, less current portion - 6,474
POST-RETIREMENT OBLIGATION 2,329,246 2,175,042
CURRENT LIABILITIES
Long-term debt, due within one year 3,152,393 2,883,677
Lease liability, due within one year 7,074 40,369
Lines of credit 3,500,000 5,000,000
Accounts payable 2,830,554 2,884,624
Consumer deposits 158,198 162,434
Other current and accrued liabilities 2,225,498 3,117,560
Total current liabilities 11,873,717 14,088,664
DEFERRED CREDITS 53,718 58,023
Total members' equity and liabilities $ 109,374,497 $ 103,563,117
See accompanying notes.
4

Northern Lights, Inc.
Statements of Operations and Comprehensive Income
Years Ended December 31, 2024 and 2023
2024 2023
OPERATING REVENUES $ 43,133,377 $ 41,932,825
OPERATING EXPENSES
Cost of power 17,950,206 15,763,614
Power production expense 518,933 564,764
Transmission expense—maintenance 41,976 22,380
Distribution expense—operation 3,203,419 3,192,761
Distribution expense—maintenance 8,214,574 7,418,999
Consumer accounts expense 1,836,232 1,751,391
Sales expense 468,575 435,320
Administration and general expense 4,123,961 4,103,457
Depreciation expense 3,666,782 3,782,344
Tax expense 982,816 1,036,487
Other expense 29,531 25,049
Total operating expenses 41,037,005 38,096,566
Operating margins 2,096,372 3,836,259
FINANCE CHARGES
Interest on long-term debt 1,287,477 1,134,638
Other interest expense 387,938 336,059
Total finance charges 1,675,415 1,470,697
Net operating margins 420,957 2,365,562
NON-OPERATING MARGINS
Investment income 73,088 44,737
Non-operating margins—other 2,012,693 2,245,142
Gain on disposition of property 127,839 73,434
Other capital credits 496,041 437,799
Total non-operating margins 2,709,661 2,801,112
Net margins 3,130,618 5,166,674
OTHER COMPREHENSIVE INCOME
Reclassification adjustment for amounts included in the
computation of net periodic pension cost(See Note 7—
Post-Retirement Benefit Obligation) (211,336) (4,226)
Total comprehensive income $ 2,919,282 $ 5,162,448
See accompanying notes.
5

Northern Lights, Inc.
Statements of Changes in Patronage Capital and Other Equities
Years Ended December 31, 2024 and 2023
2024 2023
Memberships $ 163,377 $ 163,377
Patronage capital
Balance at January 1, 45,359,345 45,449,640
Transfer of current year operating margins 420,957 2,365,562
Retirements and unclaimed capital credits, net (2,127,573) (2,455,857)
Balance at December 31, 43,652,729 45,359,345
Other equities
Balance at January 1, 17,101,886 13,969,519
Retirements and unclaimed capital credits, net 272,162 335,481
Other comprehensive (loss) gain —ASC 715 adjustment (211,336) (4,226)
Current year non-operating margins 2,709,661 2,801,112
Balance at December 31, 19,872,373 17,101,886
Total members' and other equity $ 63,688,479 $ 62,624,608
See accompanying notes.
6

Northern Lights, Inc.
Statements of Cash Flows
Years Ended December 31, 2024 and 2023
2024 2023
CASH FLOWS FROM OPERATING ACTIVITIES
Comprehensive income $ 2,919,282 $ 5,162,448
Adjustments to reconcile comprehensive income to
net cash from operating activities
Depreciation expense 4,529,528 4,589,065
Other capital credits (496,041) (437,799)
Other comprehensive gain —ASC 715 adjustment (211,336) (4,226)
Change in assets and liabilities
Accounts receivable 135,850 622,124
Materials and supplies inventory 1,169,788 (2,174,059)
Other current assets (70,447) (1,814)
Deferred charges - 55,822
Accounts payable (54,070) (336,836)
Consumer deposits (4,236) 11,523
Other current and accrued liabilities (892,062) 1,113,581
Post-retirement benefit obligation 365,540 (43,820)
Deferred credits (4,305) (1,983)
Net cash from operating activities 7,387,491 8,554,026
CASH FLOWS FROM INVESTING ACTIVITIES
Purchases of utility plant (16,699,843) (13,270,455)
Proceeds from aid to construction 5,599,246 6,292,138
Change in other assets and investments 409,286 329,786
Net cash from investing activities (10,691,311) (6,648,531)
CASH FLOWS FROM FINANCING ACTIVITIES
Borrowings under long-term debt 10,000,000 2,015,000
Principal payments on long-term debt (2,912,253) (2,961,545)
Borrowing (payments) under lines of credit, net (1,500,000) 1,500,000
Payment of retired patronage capital credits (2,127,573) (2,455,857)
Changes in other equities 272,162 335,481
Net cash from financing activities 3,732,336 (1,566,921)
NET CHANGE IN CASH AND CASH EQUIVALENTS 428,516 338,574
CASH AND CASH EQUIVALENTS, beginning of year 1,137,573 798,999
CASH AND CASH EQUIVALENTS, end of year $ 1,566,089 $ 1,137,573
SUPPLEMENTAL DISCLOSURE OF CASH FLOW
INFORMATION
Cash paid for interest during the year $ 1,635,032 $ 1,457,054
See accompanying notes.
7

Northern Lights, Inc.
Balance Sheets
December 31, 2023 and 2022
2023 2022
ASSETS
NONCURRENT ASSETS
Net utility plant $ 88,320,621 $ 85,931,369
Right-of-use assets 46,843 55,433
Other assets and investments 5,203,436 5,095,423
Total noncurrent assets 93,570,900 91,082,225
CURRENT ASSETS
Cash and cash equivalents 1,137,573 798,999
Accounts receivable, net 4,771,947 5,394,071
Materials and supplies inventory 4,015,389 1,841,330
Other current assets 67,308 65,494
Total current assets 9,992,217 8,099,894
DEFERRED CHARGES - 55,822
Total assets $ 103,563,117 $ 99,237,941
MEMBERS' EQUITY AND LIABILITIES
TOTAL MEMBERS' AND OTHER EQUITY $ 62,624,608 $ 59,582,536
LONG-TERM DEBT, less current maturities 24,610,306 25,478,983
LEASE LIABILITY, less current portion 6,474 14,225
POST-RETIREMENT OBLIGATION 2,175,042 2,223,088
CURRENT LIABILITIES
Long-term debt, due within one year 2,883,677 2,961,545
Lease liability, due within one year 40,369 41,208
Lines of credit 5,000,000 3,500,000
Accounts payable 2,884,624 3,221,460
Consumer deposits 162,434 150,911
Other current and accrued liabilities 3,117,560 2,003,979
Total current liabilities 14,088,664 11,879,103
DEFERRED CREDITS 58,023 60,006
Total members' equity and liabilities $ 103,563,117 $ 99,237,941
See accompanying notes.
4

Northern Lights, Inc.
Statements of Operations and Comprehensive Income
Years Ended December 31, 2023 and 2022
2023 2022
OPERATING REVENUES $ 41,932,825 $ 42,416,052
OPERATING EXPENSES
Cost of power 15,763,614 16,596,736
Power production expense 564,764 370,025
Transmission expense—maintenance 22,380 42,988
Distribution expense—operation 3,192,761 2,816,540
Distribution expense— maintenance 7,418,999 6,970,339
Consumer accounts expense 1,751,391 1,612,067
Sales expense 435,320 364,215
Administration and general expense 4,103,457 3,828,257
Depreciation expense 3,782,344 3,382,610
Tax expense 1,036,487 956,293
Other expense 25,049 40,445
Total operating expenses 38,096,566 36,980,515
Operating margins 3,836,259 5,435,537
FINANCE CHARGES
Interest on long-term debt 1,134,638 1,209,665
Other interest expense 336,059 78,578
Total finance charges 1,470,697 1,288,243
Net operating margins 2,365,562 4,147,294
NON-OPERATING MARGINS
Investment income 44,737 44,044
Non-operating margins—other 2,245,142 774,939
Gain on disposition of property 73,434 16,834
Other capital credits 437,799 482,869
Total non-operating margins 2,801,112 1,318,686
Net margins 5,166,674 5,465,980
OTHER COMPREHENSIVE INCOME
Reclassification adjustment for amounts included in the
computation of net periodic pension cost(See Note 8—
Post-Retirement Benefit Obligation) (4,226) 726,431
Total comprehensive income $ 5,162,448 $ 6,192,411
See accompanying notes.
5

Northern Lights, Inc.
Statements of Changes in Patronage Capital and Other Equities
Years Ended December 31, 2023 and 2022
2023 2022
Memberships $ 163,377 $ 163,377
Patronage capital
Balance at January 1, 45,449,640 43,234,656
Transfer of current year operating margins 2,365,562 4,147,294
Retirements and unclaimed capital credits, net (2,455,857) (1,932,310)
Balance at December 31, 45,359,345 45,449,640
Other equities
Balance at January 1, 13,969,519 11,650,318
Retirements and unclaimed capital credits, net 335,481 274,084
Other comprehensive (loss)gain—ASC 715 adjustment (4,226) 726,431
Current year non-operating margins 2,801,112 1,318,686
Balance at December 31, 17,101,886 13,969,519
Total members' and other equity $ 62,624,608 $ 59,582,536
See accompanying notes.
6

Northern Lights, Inc.
Statements of Cash Flows
Years Ended December 31, 2023 and 2022
2023 2022
CASH FLOWS FROM OPERATING ACTIVITIES
Comprehensive income $ 5,162,448 $ 6,192,411
Adjustments to reconcile comprehensive income to
net cash from operating activities
Depreciation expense 4,589,065 3,974,689
Other capital credits (437,799) (482,869)
Other comprehensive gain—ASC 715 adjustment (4,226) (726,431)
Change in assets and liabilities
Accounts receivable 622,124 (715,993)
Materials and supplies inventory (2,174,059) (497,391)
Other current assets (1,814) 118,119
Deferred charges 55,822 60,000
Accounts payable (336,836) 269,663
Consumer deposits 11,523 (24,828)
Other current and accrued liabilities 1,113,581 (70,040)
Post-retirement benefit obligation (43,820) (60,941)
Deferred credits (1,983) (8,828)
Net cash from operating activities 8,554,026 8,027,561
CASH FLOWS FROM INVESTING ACTIVITIES
Purchases of utility plant (13,270,455) (12,928,664)
Proceeds from aid to construction 6,292,138 6,545,912
Change in other assets and investments 329,786 347,942
Net cash from investing activities (6,648,531) (6,034,810)
CASH FLOWS FROM FINANCING ACTIVITIES
Borrowings under long-term debt 2,015,000 -
Principal payments on long-term debt (2,961,545) (3,055,349)
Borrowings under lines of credit 1,500,000 1,000,000
Payments on lines of credit - -
Payment of retired patronage capital credits (2,455,857) (1,932,310)
Changes in other equities 335,481 274,084
Net cash from financing activities (1,566,921) (3,713,575)
NET CHANGE IN CASH AND CASH EQUIVALENTS 338,574 (1,720,824)
CASH AND CASH EQUIVALENTS, beginning of year 798,999 2,519,823
CASH AND CASH EQUIVALENTS, end of year $ 1,137,573 $ 798,999
SUPPLEMENTAL DISCLOSURE OF CASH FLOW
INFORMATION
Cash paid for interest during the year $ 1,457,054 $ 1,335,627
See accompanying notes.
7

Northern Lights, Inc.
Balance Sheets
December 31, 2022 and 2021
2022 2021
ASSETS
NONCURRENT ASSETS
Net utility plant $ 85,931,369 $ 83,523,306
Right-of-Use Asset 55,433 -
Other assets and investments 5,095,423 4,960,496
Total noncurrent assets 91,082,225 88,483,802
CURRENT ASSETS
Cash and cash equivalents 798,999 2,519,823
Accounts receivable, net 5,394,071 4,678,078
Materials and supplies inventory 1,841,330 1,343,939
Other current assets 65,494 183,613
Total current assets 8,099,894 8,725,453
DEFERRED CHARGES 55,822 115,822
Total assets $ 99,237,941 $ 97,325,077
See accompanying notes.
3

Northern Lights, Inc.
Balance Sheets
Years Ended December 31, 2022 and 2021
2022 2021
MEMBERS' EQUITY AND LIABILITIES
TOTAL MEMBERS'AND OTHER EQUITY $ 59,582,536 $ 55,048,351
LONG-TERM DEBT, less current maturities 25,478,983 28,440,528
LEASE LIABILITY, less current portion 14,225 -
POST-RETIREMENT OBLIGATION 2,223,088 3,010,460
CURRENT LIABILITIES
Long-term debt, due within one year 2,961,545 3,055,349
Lease liability, due within one year 41,208 -
Lines of credit 3,500,000 2,500,000
Accounts payable 3,221,460 2,951,797
Consumer deposits 150,911 175,739
Other current and accrued liabilities 2,003,979 2,074,019
Total current liabilities 11,879,103 10,756,904
DEFERRED CREDITS 60,006 68,834
Total members' equity and liabilities $ 99,237,941 $ 97,325,077
See accompanying notes.
4

Northern Lights, Inc.
Statements of Operations and Comprehensive Income
Years Ended December 31, 2022 and 2021
2022 2021
OPERATING REVENUES $ 42,416,052 $ 38,072,567
OPERATING EXPENSES
Cost of power 16,596,736 14,716,788
Power production expense 370,025 366,474
Transmission expense—maintenance 42,988 43,216
Distribution expense—operation 2,816,540 2,176,744
Distribution expense— maintenance 6,970,339 7,231,228
Consumer accounts expense 1,612,067 1,392,064
Sales expense 364,215 229,404
Administration and general expense 3,828,257 3,450,696
Depreciation expense 3,382,610 3,353,933
Tax expense 956,293 924,083
Other expense 40,445 57,809
Total operating expenses 36,980,515 33,942,439
Operating margins 5,435,537 4,130,128
FINANCE CHARGES
Interest on long-term debt 1,209,665 1,313,351
Other interest expense 78,578 69,530
Total finance charges 1,288,243 1,382,881
Net operating margins 4,147,294 2,747,247
NON-OPERATING MARGINS
Investment income 44,044 44,044
Non-operating margins—other 774,939 401,653
Gain on disposition of property 16,834 62,733
Other capital credits 482,869 384,905
Total non-operating margins 1,318,686 893,335
Net margins 5,465,980 3,640,582
OTHER COMPREHENSIVE INCOME
Reclassification adjustment for amounts included in the
computation of net periodic pension cost (See Note 8—
Post-retirement Benefit Obligation) 726,431 38,737
Total comprehensive income $ 6,192,411 $ 3,679,319
See accompanying notes.
5

Northern Lights, Inc.
Statements of Changes in Patronage Capital and Other Equities
Years Ended December 31, 2022 and 2021
2022 2021
Memberships $ 163,377 $ 163,377
Patronage capital
Balance at January 1, 43,234,656 42,270,523
Transfer of current year operating margins 4,147,294 2,747,247
Retirements and unclaimed capital credits, net (1,932,310) (1,783,114)
Balance at December 31, 45,449,640 43,234,656
Other equities
Balance at January 1, 11,650,318 10,299,270
Retirements and unclaimed capital credits, net 274,084 418,976
Other comprehensive gain—ASC 715 adjustment 726,431 38,737
Current year non-operating margins 1,318,686 893,335
Balance at December 31, 13,969,519 11,650,318
Total members' and other equity $ 59,582,536 $ 55,048,351
See accompanying notes.
6

Northern Lights, Inc.
Statements of Cash Flows
Years Ended December 31, 2022 and 2021
2022 2021
CASH FLOWS FROM OPERATING ACTIVITIES
Comprehensive income $ 6,192,411 $ 3,679,319
Adjustments to reconcile comprehensive income to
net cash from operating activities
Depreciation expense 3,974,689 3,918,669
Other capital credits (482,869) (384,905)
Other comprehensive gain —ASC 715 adjustment (726,431) (38,737)
Change in assets and liabilities
Accounts receivable (715,993) (113,281)
Materials and supplies inventory (497,391) (359,686)
Other current assets 118,119 (94,749)
Deferred charges 60,000 60,000
Accounts payable 269,663 933,540
Consumer deposits (24,828) (21,687)
Other current and accrued liabilities (70,040) 171,060
Post-retirement benefit obligation (60,941) (35,819)
Deferred credits (81828) 14,864
Net cash from operating activities 8,027,561 7,728,588
CASH FLOWS FROM INVESTING ACTIVITIES
Purchases of utility plant (12,928,664) (11,296,959)
Proceeds from aid to construction 6,545,912 6,811,541
Change in other assets and investments 347,942 1,022,348
Net cash from investing activities (6,034,810) (3,463,070)
CASH FLOWS FROM FINANCING ACTIVITIES
Borrowings under long-term debt - 1,000,000
Principal payments on long-term debt (3,055,349) (2,882,758)
Borrowings under lines of credit 1,000,000 -
Payments on lines of credit - (1,000,000)
Payment of retired patronage capital credits (1,932,310) (1,783,114)
Changes in other equities 274,084 418,976
Net cash from financing activities (3,713,575) (4,246,896)
NET CHANGE IN CASH AND CASH EQUIVALENTS (1,720,824) 18,622
CASH AND CASH EQUIVALENTS, beginning of year 2,519,823 2,501,201
CASH AND CASH EQUIVALENTS, end of year $ 798,999 $ 2,519,823
SUPPLEMENTAL DISCLOSURE OF CASH FLOW
INFORMATION
Cash paid for interest during the year $ 1,335,627 $ 1,388,107
See accompanying notes.
7

NORTHERN LIGHTS, INC.
The power of local service
Infrastructure and Vegetation
Management Procedure
Last Update: February 2026

Infrastructure &Vegetation Management
Purpose:
This document provides clear, concise direction for NLI crews and contractors performing
infrastructure and vegetation inspection and field work. It focuses on wildfire risk
reduction, safety, and required actions in the field.
This document is a companion to NLI's Wildfire Mitigation Plan (WMP).
1 .0 Core Field Principles (Always Apply)
• Work safely and prevent ignitions.
• Maintain required clearances from energized conductors.
• Identify and address wildfire hazards immediately.
• Stop work and notify supervisor and dispatch if conditions are unsafe.
• Document inspections, assessments and as-bunts accurately and timely.
2.0 Infrastructure — Field Inspection Checklist
2.1 Overhead Line Inspections
Overhead line inspections shall be conducted in a manner consistent with the National
Electrical Safety Code(NESC)and generally accepted electric utility inspection
practices. Inspections are intended to identify conditions that may affect public safety,
employee safety, system reliability,wildfire hazards or regulatory compliance.
All inspections shall be documented using the approved Survey123 Line Inspection
application. Each inspection record shall represent a single pole or structure as well as
the attached conductor and shall include sufficient information to support condition
assessment and corrective action planning.
Inspection Scope
Inspectors shall visually assess overhead facilities and associated components for
conditions that may indicate deterioration, damage, improper installation, or unsafe
operation, including conductors and attachments, hardware and assemblies, poles and
structural elements, guying and anchoring systems, grounding components, associated
electrical equipment, right-of-way conditions, and observable signs of abnormal electrical
activity. All inspection findings, including condition assessments, priority classifications,
and photographic documentation where applicable, shall be recorded using the approved
Survey123 application, which serves as the system of record for overhead line inspection
data and supporting documentation.
2

Documentation and Records
Inspection results shall be recorded within the Survey123 application, including:
• Geospatial location data
• Standardized condition assessments
• Priority classification
• Photographic documentation at each pole
The GIS Administrator shall maintain the inspection application and manage inspection
data outputs, including geospatial layers, dashboards, and reports used for operational
tracking and compliance support.
Conditions Not Requiring Immediate Action
Inspection findings shall be assigned a Priority Level at the time of inspection using the
approved Survey123 application. Priority Levels include High-Fix ASAP, Medium-Not
urgent but need scheduled, Low-Maintenance, and NA-All Good, and are used to
indicate the relative urgency of corrective action based on observed conditions. Priority
classifications and supporting documentation are displayed through an operational
dashboard for tracking and oversight. Conditions not identified as high priority are
addressed through the utility's routine maintenance scheduling process and then marked
as work complete as well as the date completed on the original survey form. All inspection
data is recorded in Survey123, which serves as the system of record for inspection data.
Conditions Requiring Prompt Action
Conditions that present an immediate safety concern or heightened risk shall receive
prompt attention. Such conditions may include, but are not limited to:
• Exposed energized components
• Evidence of active electrical stress or overheating
• Clearance issues involving vegetation or other obstructions
• Structural failures or compromised supporting components
Where conditions can be safely addressed at the time of inspection, corrective
action should be taken.
— Where immediate correction is not feasible, appropriate internal notification shall
be made in accordance with established operating procedures.
3

2.2 Pole and Structure Hazards
Poles and supporting structures shall be evaluated by authorized contract personnel for
conditions that may present an immediate or potential safety hazard, including but not
Limited to rot, fire damage, impact damage, or other signs of structural deterioration.
Hazardous conditions identified by contract personnel shall be documented using the
approved inspection application, including photographic evidence and assignment of an
appropriate priority classification, and transmitted to the utility for review and action.
When a condition is identified that may pose an immediate risk to personnel,the public,
or system reliability, the contractor shall notify utility Dispatch or designated supervisory
personnel in accordance with established emergency notification and escalation
procedures.
Where appropriate and authorized, temporary stabilization or protective measures may be
implemented to mitigate risk until permanent corrective action can be completed by the
utility or its designated contractor.
Contractor and Utility Responsibilities
• Contractor Responsibilities:
Contract personnel are responsible for performing inspections, identifying and
documenting observed conditions, capturing photographic evidence, assigning
priority classifications, and providing timely notification of conditions requiring
escalation.
• Utility Responsibilities:
The utility retains responsibility for review, prioritization, response coordination,
and authorization of corrective actions, including permanent repairs, replacements,
or additional mitigation measures.
4

3.0 Vegetation Management— Field Checklist
Vegetation management activities shall be conducted in a manner consistent with
National Electrical Safety Code(NESC) clearance intent and generally accepted utility
vegetation management practices. Activities are intended to reduce the risk of vegetation-
related outages, safety hazards, and access limitations.
All vegetation observations and work activities shall be documented using Field Syte,
which serves as the system used to manage field data, work assignments, and
documentation. The GIS Administrator shall maintain the inspection application and
manage inspection data outputs, including geospatial layers, dashboards, and reports
used for operational tracking and compliance support.
3.1 Clearance Requirements
Vegetation shall be managed to maintain appropriate clearances from overhead
conductors and associated equipment, consistent with NESC intent under normal
operating conditions.
Vegetation that may reasonably be expected to encroach upon or contact conductors due
to wind, sag, or growth shall be identified and addressed.
Vegetation shaping or pruning may be performed as necessary to maintain clearances
while supporting long-term system reliability.
3.2 Hazard Tree Identification
A tree may be considered a hazard tree if it exhibits conditions that could reasonably
result in contact with electrical facilities, including but not limited to:
• Dead or declining condition
• Leaning toward electricalfacilities
• Structural defects or compromised root systems
• Proximity such that failure could impact conductors or equipment
Identified hazard trees shall be marked and documented within Field Syte.
Vegetation-related hazards shall be reviewed by the Vegetation Manager, who is
responsible for prioritization and assignment of mitigation work to authorized contracted
tree crews in accordance with utility policy.
5

3.3 Right-of-Way Clearing and Mowing
Woody vegetation within designated right-of-way limits shall be removed as necessary to
support safe operation, access, and maintenance.
Following tree removal, mowing or mastication may be performed where appropriate, or in
areas where vegetation growth is minimal.
Vegetation work shall be conducted in a manner that avoids leaving slash or debris that
could create access limitations, safety concerns, or increased fire risk.
4.0 Elevated Fire Conditions (Red Flag/ Fire Restrictions)
During elevated fire conditions:
- Increase situational awareness
-Watch for wind, low humidity, and high temperatures
-Avoid activities that could cause sparks
- Have fire tools and extinguishers available.
- Follow any addition restrictions provided by NLI management or the local area
jurisdictions.
If fire restrictions are active:
- Follow applicable work limits or work hour restrictions in place ("hoot owl")
- Recloser and protection settings may be adjusted system-wide
5.0 Ignition or Fire Response
If a fire or ignition occurs:
1. Ensure personal safety first.
2. Call 911 if fire is active, or have NLI Dispatch call 911 if cell phone coverage is not
available.
3. Notify NLI Dispatch immediately.
4. If safe to do so, attempt to extinguish or prevent further spread of the fire until fire crews
arrive onsite.
6

5. De-energize equipment or lines at your discretion or under direction from fire crews.
6.0 Contractor Expectations
All contractors must:
- Follow any fire or road restrictions in place for each county.
- Stop work if unsafe conditions exist.
- Report hazards immediately to NLI contact or NLI dispatch.
- Coordinate with NLI before removing hazard trees.
- Report job location to NLI dispatch or NLI field supervisor.
7.0 When to Stop Work
Stop work and notify supervision if:
-Weather conditions create ignition risk.
- Unsafe clearances cannot be maintained.
- Fire behavior or smoke threatens the work area.
If it looks like a wildfire risk,treat it like one.
7

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Area Boundary 208-263-5141 Drawn By:WLargent

EXHIBIT C
COMPLIANCE MATRIX

NLI Compliance Matrix
Wildfire Standard of Care Act
Requirements and Order No.
36774/WMP Guideline
Requirements NLI WMP Details/Notes
Geographical RiskAssessment(s) 6.0 Wildfire Risks & Risk model, map of risk
I. C. § 61-1803(3)(a) Drivers areas.
Preventative Actions & Programs 7.0 Wildfire Preventative Inspections,vegetation
I. C. § 61-1803(3)(b) Strategies management,
7.3 Fuel&Vegetation technology, operational
Management practices, community
7.4 Asset Inspection & outreach, system
Response hardening, training.
7.5 Workforce Training
7.6 Relay& Recloser
Practices
7.7 De-energization/
PSPS
8.0 Community
Outreach and Public
Awareness
Community Outreach & Public 8.0 Community Member communication,
Awareness Outreach and Public notifications and
I. C. § 61-1803(3)(c) Awareness education.
Government Outreach 5.3 Coordination with Coordination with service
I. C. § 61-1803(3)(d) local Tribal entities area entities such as
5.4 Emergency Tribes and EM agencies.
Management/Incident Provide notice to entities
Response per I. C. § 61-1804(2).
8.1 Current Community
Outreach and Public
Awareness Program
Method of Line Design 7.2 Design and Methods for new/planned
I. C. § 61-1803(3)(e) Construction Standards lines, cost evaluation,
11.0 Cost Evaluations project selection,
materials.
Situational Awareness and 7.1 Weather Monitoring Systems and tools for
Monitoring monitoring integration
I. C. § 61-1803(3)(f) into operations.
Infrastructure Inspection and 7.2 Design and Inspection of assets and
Maintenance Construction Standards goals.
7.3 Fuel&Vegetation
Management

NLI Compliance Matrix
Wildfire Standard of Care Act
Requirements and Order No.
36774/WMP Guideline
Requirements NLI WMP Details/Notes
7.4 Asset Inspection &
Response
De-Energization 7.6 Relay& Recloser Public safety power
I. C. § 61-1803(3)(g)(ii) Practices shutoff.
7.7 De-energization/
PSPS
9.0 Restoration of
Service
Vegetation Management 7.3 Fuel&Vegetation Goals and standards of
I. C. § 61-1803(3)(g)(iii) Management program.

EXHIBIT D
NOTICE TO INTERESTED PARTIES

The power of local service
[Recipient Name] [DATE]
[Address]
[City, State,Zip]
Re: Notice of Filing of Wildfire Mitigation Plan (Idaho Code § 61-1805(2))
To Whom It May Concern:
Northern Lights, Inc.provides this notice that it has filed its Wildfire Mitigation Plan in accordance with the
Idaho Standard of Care Act,Idaho Code§ 61-1805(2),and related Idaho Public Utilities Commission
("Commission")requirements, as applicable. The Wildfire Mitigation Plan describes the Cooperative's
operational practices and risk-reduction measures intended to mitigate wildfire risk associated with electric utility
infrastructure. The filing includes information regarding Northern Lights' approach to wildfire risk identification,
preventive strategies, inspection and maintenance practices, operational protocols,and other measures designed to
support safe and reliable electric service.
Copies of the filing area available for public review during regular business hours at the Commission's office
located at 11331 W. Chinden Blvd. Building 8, Suite 201-A,Boise,ID 83714 or on the Commission's website at
www.puc.idaho.gov. Click on the"ELECTRIC"icon, select"Open Cases,"and click on the relevant case
number.
Written comments regarding NLI's filing can be filed with the Commission; comments are required to be filed
through the Commission's website or by email. To comment electronically,visit www.pub.idaho.gov and click on
the"Case Comment Form"link on the upper left side of the page. Please reference the relevant case number when
filling out the form. To comment using email,please send comments to the email addresses listed below and
include the case number. Commenters are required to include their name and address.
Filing Information
• Date Filed: [ ]
• Filed With: Idaho Public Utilities Commission
• Case Number: [ ]
Sincerely:
Kristin Burge
Engineering&Operations Manager
Northern Lights, Inc.
[e-mail]
Ph: 208-255-5395
PO Box 269 • 421 Chevy Street Sagle, Idaho 83860-0269 • 800-326-9594 • www.nli.coop