20260305Reply Comments.pdf

0IQAHO R®
MEGAN GOICOECHEA ALLEN
Corporate Counsel RECEIVED
mgoicoecheaallen(a)_idahopower.com MARCH 5, 2026
IDAHO PUBLIC
UTILITIES COMMISSION
March 5, 2026
VIA ELECTRONIC FILING
Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg 8,
Suite 201-A (83714)
PO Box 83720
Boise, Idaho 83720-0074
Re: Case No. IPC-E-25-32
Idaho Power Company's 2026 Wildfire Mitigation Plan
Dear Commission Secretary:
Attached for electronic filing please find Idaho Power Company's Reply Comments
in the above-entitled matter.
If you have any questions about the attached documents, please do not hesitate
to contact me.
Very truly yours,
u(� i c 6UA
Megan Goicoechea Allen
MGA:sg
Attachment
1221 W. Idaho St(83702)
P.O. Box 70
Boise, ID 83707

MEGAN GOICOECHEA ALLEN (ISB No. 7623)
LISA C. LANCE (ISB No. 6241)
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
mgoicoecheaallenCaD,idahopower.com
IlanceCc)_idahopower.com
Attorneys for Idaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER )
COMPANY'S 2026 WILDFIRE MITIGATION ) CASE NO. IPC-E-25-32
PLAN. )
IDAHO POWER
COMPANY'S REPLY
COMMENTS
COMES NOW, Idaho Power Company ("Idaho Power" or "Company"),
and, pursuant to Idaho Public Utilities Commission's ("Commission") Rules of Procedure
201-204 and the Notice of Modified Procedure, Order No. 36895, hereby
respectfully submits the following Reply Comments regarding the Company's 2026
Wildfire Mitigation Plan' ("WMP" or "Wildfire Plan").
While the Company's 2026 WMP also encompasses assets and activities within the State of Montana,
because this Application is before the Commission for approval specific to Idaho Power's operations in
Idaho, all discussion in these reply comments is confined to operations and activities occurring within
Idaho.
IDAHO POWER COMPANY'S REPLY COMMENTS - 1

I. INTRODUCTION
The Company's 2026 WMP is the sixth edition of the plan and the first to be
submitted for approval pursuant to the Wildfire Standard of Care Act ("WSCA"), Idaho
Code § 61-1801 et seq. Idaho Power's 2026 WMP is the product of the Company having
conducted a comprehensive, rigorous assessment of wildfire risk across its service area
using approaches and methods that are designed to protect the public interest and are
reflective of and commensurate with the size and complexity of Idaho Power's operations
and the specific fire risks present within the areas in Idaho where the Company has
infrastructure or equipment. The purpose of Idaho Power's 2026 WMP is to guide
mitigation strategies and reduce wildfire risk for the safety of Idaho Power's customers,
the continued and reliable delivery of electricity to approximately 630,000 retail customers
in Southern Idaho, and good stewardship of the beautiful and natural lands within Idaho
Power's service area and beyond. Accordingly, the mitigation measures outlined in the
Company's 2026 WMP are intended to reduce potential risk associated with Idaho
Power's infrastructure or equipment and, in accordance with Idaho Code § 61-1803(3)
and the Commission's directives,2 identify the methods and means for mitigating wildfire
risk that reflect a reasonable balancing of mitigation costs with the reduction of wildfire
risk.
Idaho Power appreciates the opportunity to offer these Reply Comments in
response to Comments on the Company's WMP filed by Commission Staff ("Staff") and
Idaho Department of Lands ("IDL"), as well as public comments submitted by the City of
2 See generally Order No. 36774 issued in GNR-E-25-02 on September 30, 2025.
IDAHO POWER COMPANY'S REPLY COMMENTS - 2

Boise, Idaho Emergency Management Association ("IEMA"), and the Northwest Energy
Coalition ("NWEC") (collectively, the "Stakeholders").
II. REPLY COMMENTS
A. Commission Staff
The Company appreciates Staff's thorough review and assessment of its filing and
determination that Idaho Power's 2026 WMP meets the requirements of the WSCA and
the Commission's WMP guidelines. More specifically, Staff determined that the Company
followed sound quantitative and qualitative modeling strategies and methods to assess
wildland fire risks and to develop and identify geographical areas with heightened risk,
and found reasonable the Company's line design methods, infrastructure inspection and
asset management strategies, workforce preparedness, and line operation and Public
Safety Power Shutoff("PSPS") practices described in its 2026 WMP. Similarly, Staff found
that the Company's 2026 WMP met, or substantially met, the WSCA and Commission's
requirements for public outreach and engagement, government outreach, situational
awareness and monitoring, and vegetation management. As a result, Staff recommends
that the Commission issue an order approving Idaho Power's 2026 WMP and approving
the Company's request to file future WMPs on or about October 1st of each year. Staff
also requested that additional supporting information be provided with future WMP filings
and offered recommendations for additional items to be included or considered as part of
future WMP cycles ("Staff Recommendations").
Idaho Power is largely supportive of many of Staff's Recommendations, either as
presented or in principle, and appreciates the opportunity to offer these Reply Comments
to address Staff Recommendations, including proposing alternative approaches that may
IDAHO POWER COMPANY'S REPLY COMMENTS - 3

better facilitate Staff's objectives, providing additional clarification where necessary, or
explaining why a recommendation is not workable or appropriate.
Staff Recommendation 1:Approving the 2026 WMP
Staff Recommendation 2: Approving the Company's request to file its WMP
on or about October 1 each year.
The Company supports Staff Recommendations 1 and 2.
Staff Recommendation 3: Requiring the Company include copies of the
Company's four most-recent quarterly NERC FAC-003-X compliance reports as
attachments in future WMPs (where X represents the latest version of the standard
the Company is using).
Staff Recommendation 4: Requiring the Company include copies of current
Transmission Maintenance and Inspection plans used for NERC FAC-501-WECC-X
compliance and any violations noted from the most recent NERC compliance audit
(X represents the latest version of the standard the Company is using).
The Company understands Staff's recommendations relating to the provision of
North American Electric Reliability Corporation ("NERC") submissions is based upon the
idea that such submissions will provide greater insight into vegetation-related
performance on the transmission system existing in wildfire risk zones. As a point of
clarity, the Company notes that NERC does not require utilities to prepare or submit
quarterly compliance reports under FAC-003; rather, the standard uses Periodic Data
Submittals ("PDS") which consist primarily of quarterly vegetation outage reporting to the
regional entity when sustained outages on applicable lines are caused by vegetation. If
no sustained vegetation caused outages occur within a given quarter, there may be no
outage data to submit. As such, there are many quarters where Idaho Power does not
submit any information for purposes of NERC PDS compliance. Moreover, the data
submitted as part of a NERC PDS is specific to NERC's review and limited to basic outage
metadata including the date, duration, voltage, cause, and any countermeasures. The
IDAHO POWER COMPANY'S REPLY COMMENTS - 4

submissions are not designed for wildfire mitigation, do not measure vegetation
conditions, and do not provide trend or risk insights into the Company's service area by
wildfire risk zone.
Similarly, Western Electricity Coordinating Council's ("WECC") Regional Reliability
Standard FAC-501-WECC audit results are related to a broad range of transmission
maintenance requirements and not specific to wildfire risk. The audits sample hundreds
of NERC requirements and FAC-501-WECC is just one that may or may not be included
in the audit. Audits of NERC and WECC reliability requirements occur on multi-year
cycles (with the Company's last one that addressed FAC-501-WECC having occurred in
2018) and do not involve wildfire mitigation or ignition-risk reduction. Therefore, FAC-501
audit information would not provide Staff with the wildfire-mitigation insight they are
seeking to assist with trend analysis or evaluation of wildfire conditions.
The Company supports Staff's request for additional metrics relating to its
vegetation management and enhanced vegetation management program to offer a more
comprehensive view of trends and effectiveness across its system, but the specific data
referenced by Staff does not facilitate this objective. The Company believes, however,
that there are alternative options that would provide Staff with data and enable it to
evaluate trends in vegetation-related reliability issues including, for example, the annual
count of vegetation-related outages on transmission and distribution lines, broken out by
wildfire risk zone tier. As such, the Company proposes that it and Staff meet prior to its
next WMP submission to discuss Staff's objectives and coordinate on an approach to
support and streamline Staff's review.
IDAHO POWER COMPANY'S REPLY COMMENTS - 5

Additional Staff Recommendation 1: Continue to separate internal wildfire
mitigation labor in cost forecasts.
Additional Staff Recommendation 2: Continue to explore methods to reduce
costs with communication and education regarding wildfire and PSPS.
Additional Staff Recommendation 3: Continue providing details of all
funding alternatives and sources pursued within the WMP.
The Company believes Additional Staff Recommendations 1 through 3 represent
reasonable measures to support continued sound decision-making by the Company in
mitigating wildfire risk.
Additional Staff Recommendation 4:Address the types of infrastructure left
out of risk modeling and, if not included in the Company's models, provide an
explanation as to why.
As part of subsequent WMP submissions, Staff recommended that the Company
address the types of infrastructure left out of risk modeling and provide an explanation as
to why. Notably, the WSCA requires only geographical areas where an electric corporation
has infrastructure or equipment that it considers may be subject to a "heightened risk of
wildfire" at the time of finalizing its wildfire mitigation plan be identified.3 Though wildfire
is not defined in the WSCA, entities that specialize in firefighting, such as the National
Fire Protection Association, define wildfire in relation to the area in which the fire burns—
specifically the "wildland".4 Because Idaho Power's overhead transmission and
3 See Idaho Code§ 61-1803(3)(a)
4 As of 2024, the National Fire Protection Association defined "wildfire" as "an event dealing with fire in
the wildland, originating from an unplanned ignition, such as lightning, volcanos, unauthorized and
accidental human caused fires, and prescribed fires that are declared wildfires." See also Merriam-
Webster's definition of wildfire, which is a "sweeping and destructive conflagration especially in a
wilderness or rural area," and the Idaho Forestry Act, Title 38, Idaho Code, which defines "forest fire" as
"any fire burning uncontrolled on any land covered wholly or in part by timber and/or other potential forest
products, slash, brush, or other flammable vegetation" and "range fire" as "any fire burning uncontrolled
on any range land,"which in turn is defined as "any land which is not cultivated and which has upon it
native grasses or other forage plants making it best suited for grazing of domestic and wild animals and
which land is adjacent to or intermingled with forest land."
IDAHO POWER COMPANY'S REPLY COMMENTS - 6

distribution ("T&D") assets predominately form the assets and equipment that could be
involved in a fire that burns in the wildland based on their location, rather than buildings
or equipment located in developed areas or in more remote areas with significant
defensible space separating them from the wildland, and because other Company assets
and equipment that might be exposed to wildfire typically have transmission or distribution
lines running to and/or from them and so are effectively considered in geographic risk
modeling of T&D assets, the Company has traditionally focused on T&D assets as part of
its risk modeling. Facilities such as power plants, storage facilities, and office buildings
are managed under separate safety, fire protection, and emergency response programs
to reduce potential fire risk, which are driven by different legal and regulatory compliance
frameworks and standards than the Company's WMP. The Company employs a wildfire
risk modeling approach targeted to facilitate specific objectives consistent with the WSCA
and believes that any changes should be carefully considered within that context. To the
extent the Commission believes it would be helpful to include as part of future WMPs, the
Company can clarify the types of infrastructure not included in its wildfire risk modeling
with an explanation as to why.
Additional Staff Recommendation 5: Find ways to include loss of life as a
parameter in [the Company's] future wildfire risk assessments and, at a minimum,
include it as a qualitative parameter where loss of life has higher probabilities.
Idaho Power agrees that potential harm to people and communities should be a
central consideration in wildfire risk assessment. Indeed, the Company does and has
considered the risk of loss of life in its wildfire risk assessments. Specifically, the
Company's use of modeling that considers impacts on structures also, by default,
captures the risk to community and populations. In addition, the Company also
IDAHO POWER COMPANY'S REPLY COMMENTS - 7

considered qualitative factors when establishing the wildfire risk zones depicted in its
2026 WMP, which included, but were not limited to, ingress/egress considerations; fire
response capabilities; federal, state, and local fire agency input on areas of concern
including home ignition zones; and customer input gained during outreach meetings on
factors such as neighborhood growth in the wildland urban interface and areas of
community concern. In considering these qualitative factors, the Company considered the
risk of loss of life resulting from a wildfire. Looking ahead, the Company plans to
implement an enhanced wildfire risk-modeling platform in its 2027 WMP using
Technosylva's FireSight product, which simulates wildfire behavior and consequences
using historical fires, fuels, topography, and weather, and then evaluates potential impacts
on communities, including where infrastructure-caused wildfire could directly and rapidly
affect nearby populations and communities, further refining the Company's loss of life
analysis.
In advance of its next WMP submission, Idaho Power believes it would be
beneficial to meet with Staff to discuss the abovementioned enhancements and ensure
Staff understands how the Company considers the risk of loss of life in its wildfire risk
assessment.
Additional Staff Recommendation 6: Take necessary steps to integrate asset
condition/inspection data and failure modes into ignition models as part of
geographical risk modeling and assessment.
As an industry best practice, Idaho Power distinguishes between geographic
wildfire risk and asset-level risk. Geographic risk zones are intended to reflect inherent
risk on a landscape by considering relatively stable conditions such as fuels, topography,
wind and climate patterns, and community exposure — conditions that remain present
IDAHO POWER COMPANY'S REPLY COMMENTS - 8

regardless of utility inspection cycles or infrastructure hardening — in order to define where
wildfire impacts would be most severe should an ignition occur. This distinction was
previously emphasized by the independent evaluator ("IF) retained by the Oregon Public
Utility Commission in its review of an Oregon utility's WMP that included removal of
several areas from the prior year's HFRZ due to undergrounding. The IE noted, in
pertinent part, the following concern with that HFRZ determination process:
[The utility] includes the application of mitigation measures such as
undergrounding its lines in making HFRZ determinations. As such, HFRZs
fluctuate and can be removed dependent upon deployed utility mitigations,
which could present significant unintended consequences. This approach
conflates utility mitigations with an overall understanding of ignition
consequence in the area regardless of cause.5
The Company recognizes that asset condition and inspection data are importantly
considered as part of its WMP, but these factors are more appropriately evaluated in the
context of mitigation prioritization rather than assessing geographical risk. Because asset
condition and inspection data are variable, the incorporation of inspection or condition
data directly into the geographic model would result in continually adjusted risk zones to
reflect each time assets are repaired or replaced. However, though the asset condition
may have changed, inherent risk of a given area will not. Other important mitigations,
such as wildfire-informed work practices and construction standards for new
development, would also be lost in an approach that removes risk zones based on
fluctuations in asset condition. These fluctuations would further reduce the stability and
year-over-year comparability of risk zones and potentially confuse communication with
customers and local emergency managers due to continual zone shifts.
5 OPUC Docket UM 2208, Wildfire Mitigation Plan 2024 Independent Evaluator's Report at 8 (Jun. 12,
2024). The utility involved in that docket has subsequently modified its HFRZ determination process.
IDAHO POWER COMPANY'S REPLY COMMENTS - 9

For these reasons, the Company does not currently incorporate asset-condition or
inspection data into its geographic risk modeling. Instead, the Company's risk modeling
process identifies, relative to other areas where Idaho Power has assets and equipment,
where the landscape and communities are most exposed to wildfire consequences.
Conversely, asset-condition data and inspection findings are used by Idaho Power to
prioritize hardening, maintenance, and other mitigation activities within those higher-risk
areas. That said, in advance of preparing its next WMP, Idaho Power would like to work
with Staff to better understand its recommendation and to assess whether improvements
can be implemented to address Staff's concerns.
Additional Staff Recommendation 7: Include quantitative model validation
and analysis as part of geographical risk modeling and assessment.
The Company believes Additional Staff Recommendation 7 represents a
reasonable measure to support continued sound decision-making by the Company in
mitigating wildfire risk.
Additional Staff Recommendation 8: Include the estimated cost, planned
duration, and evaluation metrics of each pilot program.
The Company believes Additional Staff Recommendation 8 represents a
reasonable measure to support continued sound decision-making by the Company in
mitigating wildfire risk.
Additional Staff Recommendation 9: Set and publish annual miles for all T&D
hardening programs and projects by WRZ Tier or feeder, plus modeled ignition risk
reduction per mile for each category.
Additional Staff Recommendation 10: Adopt an effectiveness scorecard for
each grid hardening method (including but not limited to covered conductor, non-
wooden poles, non-wooden crossarms, undergrounding, etc.) based on industry
guidance.
IDAHO POWER COMPANY'S REPLY COMMENTS - 10

The Company appreciates Staff's recommendation to develop ignition risk
reduction figures by mile for T&D hardening projects to inform future WMPs, as well as
adopting an effectiveness scorecard, based on industry feedback, for each grid hardening
method. As Idaho Power's WMPs continue to evolve, the Company is advancing, in
addition to other initiatives, its ignition risk modeling capabilities and a data-validated
understanding of the associated effectiveness of grid-hardening measures. Recognizing
that the data and analysis required to produce meaningful results is a multi-year
endeavor, for which results are likely to evolve as the Company continues to gain
operational experience, as well as the Commission's statement, discussed further below
that the cost-benefit analysis required by the WSCA is not a highly prescriptive, granular
analysis, the Company respectfully requests that these recommendations specific to cost
benefit analysis be interpreted more generally to require only that Idaho Power develop
modeling of ignition risk reduction and mitigation effectiveness and that such modeling
only be required to inform its WMP beginning within its 2028 plan.
Additional Staff Recommendation 11: Include a table that includes all T&D
rebuild and grid hardening projects that includes the following: project name,
project type, primary driver, location, design standards, anticipated project
timeline, and estimated costs within the WMP. Including an explanation if the
wildfire mitigation priority of the project changed any aspects of the project (i.e.,
design, costs, and timeline).
Additional Staff Recommendation 12: Include the internal vegetation
management crew description within Section 10.2 of the WMP.
The Company largely believes Additional Staff Recommendations 11 and 12
represent reasonable measures to support continued sound decision-making by the
Company in mitigating wildfire risk. While not explicit in Staff's recommendation, the
Company interprets Additional Staff Recommendation 11 to only encompass T&D rebuild
IDAHO POWER COMPANY'S REPLY COMMENTS - 11

and grid hardening projects specifically undertaken as part of its wildfire mitigation
strategy, versus all such projects across its system.
Additional Staff Recommendation 13: Adopt and mature implementation of
industry best practices in configuration management, requirements management,
test management, and issue and defect tracking for all custom models or software
developed for the FPI tool, as well as other custom-developed models or
applications that play a critical role in the Company's WMP.
The Company believes Additional Staff Recommendation 13 represents a
reasonable measure to support continued sound decision-making by the Company in
mitigating wildfire risk.
Additional Staff Recommendation 14:Add more detail about the resources
available to call center agents during a PSPS within Appendix B.
The Company believes Additional Staff Recommendation 14 is reasonable.
Additional Staff Recommendation 15: Expand reporting for future WMPs to
include both transmission and distribution assets not covered by NERC Standards
to offer a more comprehensive view of trends and effectiveness across the utility's
entire system.
The Company disagrees with Staff's recommendation to extend the NERC
standards to distribution and transmission lines that are not currently subject to them to
provide additional insight into vegetation management activities performed on such lines.
As previously noted as part of the Company's response to Staff Recommendations 3 and
4, these submissions are tailored exclusively for NERC's review and do not specifically
contemplate wildfire risk. Rather, these NERC reporting frameworks are designed for
transmission reliability and the broader bulk electric system, not wildfire mitigation.
Moreover, applying these requirements to non-NERC facilities would impose a substantial
administrative burden without, from the Company's perspective, providing a
commensurate increase in wildfire risk insight.
IDAHO POWER COMPANY'S REPLY COMMENTS - 12

As discussed above, the Company believes a meeting between the Company and
Staff will help ensure alignment on Staff's objectives and allow the parties to work together
to identify any additional information that would enable Staff to identify vegetation-related
trends and mitigation effectiveness across Idaho Power's system.
Additional Staff Recommendation 16: Conduct cost-benefit analysis on a
project-by-project basis to demonstrate that each project reasonably balances
the costs with the reduction in wildfire risk.
The Company understands that a consistent and transparent methodology can
support clearer communication regarding how projects are selected and how expected
wildfire-risk reductions are balanced with cost. However, the Company also agrees with
the Commission that"[d]emonstrating that a project strikes a reasonable balance between
cost and risk reduction does not require isolating the portion of project costs attributable
solely to wildfire mitigation or conducting a highly granular comparison of those costs to
quantified risk reductions. Rather, financial reasonableness can often be established by
comparing a project's total cost over its useful life to the full range of benefits it provides
to the utility and its customers, including wildfire risk mitigation.116
To ensure that the cost-benefit framework implemented by the Company is
technically sound, feasible to implement, and aligned with the Commission's
expectations, Idaho Power will continue to work on this effort in 2026 and will provide an
update on its progress within the Company's 2027 WMP.
6 In the Matter of Commission Staffs Application for Approval of a Filing Process for Wildfire Mitigation
Plans, Case No. GNR-E-25-02, Order No. 36882 at 3 (Dec. 22, 2025).
IDAHO POWER COMPANY'S REPLY COMMENTS - 13

Additional Staff Recommendation 17: Identify the average cost of
information for projects, such as installation costs of the following:steel poles, fire
mesh wraps, wildfire detection cameras, undergrounding, covered conductor,
fiberglass cross arms to wooden, and weather stations.
Additional Staff Recommendation 18:Add all metrics that will be used for
the WMP be included within each respective section of the WMP and provide the
data in a format that can be tracked in each version of the WMP.
The Company believes Additional Staff Recommendations 17 and 18 represent
reasonable measures to support continued sound decision-making by the Company in
mitigating wildfire risk.
B. Idaho Department of Lands
IDL's Comments include a number of recommendations for Commission
consideration, which the Company addresses in turn as follows.
Within its comments, IDL requests that the Company provide additional descriptive
narrative details about the data utilized to produce its risk model to better align with
requirements of cooperators at the county level who develop and maintain County Wildfire
Preparedness Plans. The Company recognizes the importance of coordinating with local
officials and agencies on wildfire preparedness and emergency response plans and of
"moving the needle" on wildfire mitigation efforts. As noted above, the Company is
working to implement an updated geographical risk analysis approach that includes data
inputs and considerations similar to those used by the State of Idaho in its State Forest
Action Plan risk analysis. Accordingly, in future iterations of the Company's WMP, it will
include details about the modeling inputs used.
IDL also requests that the Company include a discussion regarding any
diminishing returns related mitigation activities considered as well as describe the
economic impact of electric service disruption if an economic value of mitigation efforts is
IDAHO POWER COMPANY'S REPLY COMMENTS - 14

unable to be determined. Idaho Power agrees that it is important to consider both
diminishing returns in the context of mitigation choices, as well as the impact of electrical
service disruption in making mitigation choices, and will consider these factors as part of
developing the cost-benefit framework discussed above.
After acknowledging that Idaho Power's WMP addresses fair market value for
timber on industrial lands, IDL requests that the concept of fair market value ("FMV") be
extended at a minimum to state endowment lands and, if possible, to other large, non-
industrial private landowners. IDL's request in this regard seeks to expand the scope of
Idaho Code § 61-1803(3)(g)(iii) beyond the plain statutory language, which requires that
landowners be compensated at FMV for the removal of live, marketable timber from
timber company land adjacent to a utility right-of-way. While Idaho Power understands
that IDL's recommendation is intended to address what it perceives as shortcomings of
the legislation, Section 9.2.3. of the Company's WMP is targeted to comply with the FMV
compensation requirement for timber removal as set forth in the WSCA, and the Company
does not believe it would be appropriate to incorporate additional elements not
contemplated by the statute.
As noted by the Commission in establishing a procedure and filing schedule for
WMPs submitted for approval under the WSCA, its authority is limited to that granted by
statute.' Specifically addressing the concept of FMV under the WSCA, the Commission
observed that the statute does not define what constitutes FMV, nor does it expressly
grant the Commission the authority to do so.$ As such, the Commission stated that it
Case No. GNR-E-25-02, Order No. 36774 at 18 (Sep. 30, 2025) (citing United States v Utah Power&
Light Co., 98 Idaho 665, 667, 570 P.2d 1353, 135 (1977)).
8 Id.
IDAHO POWER COMPANY'S REPLY COMMENTS - 15

lacked the authority to provide such a definition and it further declined to establish
guidelines for valuation, notice, and dispute resolution related to timber removal.9 The
Commission continued: "Moreover, determining the amount a landowner should receive
for removed timber is akin to fixing damages in a civil case. The power to determine and
award civil damages is the exclusive province of the judicial courts and beyond the
Commission's jurisdiction."10 The Company believes similar reasoning applies to IDL's
request to extend the FMV compensation requirement beyond "timber company land
adjacent to the rights-of-way" as provided by the WSCA and that IDL's recommendation
in this regard is therefore inapposite.
Finally, IDL argues that the arboriculture standards, utilized by the Company for
vegetation management purposes, are insufficient at addressing wildland fire-related
issues because consideration is not given to vegetation ignition potential or fire
propagation. Consistent with the WSCA and regulatory directives, Idaho Power's T&D
Vegetation Management Program ("VMP") addresses public safety, regulatory
compliance, electric reliability, and helps to safeguard lines from trees and other
vegetation that may cause an outage or damage to facilities. What IDL appears to be
referencing in its comments, however, is a desire for a broader landscape-level strategy
aimed at lowering wildfire intensity, reducing fire spread, and mitigating overall fire hazard
across forests and wildlands. While the Company agrees that both utility vegetation
management and fuel reduction are important for managing wildfire risk, they are distinct
strategies differing in scope, intent, drivers, and legal authority.
9 Id. at 17-18.
10 Id. at 17 (citations omitted).
IDAHO POWER COMPANY'S REPLY COMMENTS - 16

Though IDL's recommendation exceeds the scope of legal and regulatory
vegetation management authority and requirements, the Company notes that it is
involved in efforts to reduce the amount of available fuel in certain areas. Separately, and
in addition to its VMP, Idaho Power participates in multiple partner-initiated hazardous
fuel reduction projects within and adjacent to wildfire risk zones. These efforts focus on
reducing fuel loads near Idaho Power infrastructure, creating defensible space, and
improving the resilience of forests and powerline corridors. Idaho Power works with the
landowners and land managers, such as IDL, US Forest Service ("USFS"), Bureau of
Land Management ("BLM"), and stakeholders including local counties and non-
government partners to identify and implement priority projects. Since 2023, Idaho Power
has also supported thinning, pruning, and biomass removal in certain higher-risk areas
through the Southern Idaho All Lands Partnership and other coordinated cross-agency
initiatives in Ada, Boise, Adams, Valley, and Idaho Counties. For example, in 2025 Idaho
Power partnered with IDL and the Salmon—Challis National Forest through IDL and the
USFS Good Neighbor Authority Agreement to support fuels mitigation on approximately
91 acres along a key transmission corridor in the Salmon municipal watershed. This
project resulted in hazardous fuel reduction, and increased protection for both the
watershed and Company's infrastructure.
C. City of Boise
The comments submitted by the City of Boise are generally supportive of the
Company's WMP and appreciative of its continued collaboration to ensure that Boise is
resilient to the ongoing threat of wildfire in our community. In the following discussion, the
IDAHO POWER COMPANY'S REPLY COMMENTS - 17

Company responds to the City of Bosie's concerns and recommendations relating to
certain components of the Company's WMP.
The City of Boise emphasizes the importance of deliberate and effective planning
and resourcing of Community Resource Centers ("CRC") in partnership with local public
safety agencies and raises the need to clarify allocation of responsibility. Accordingly, the
City of Boise recommends that Idaho Power engage in additional preparedness and
assessment activities in the communities it serves to evaluate its approach to CRC
activation. In addition, the City of Boise requests that Idaho Power schedule a regional
discussion-based exercise to review plausible PSPS scenarios prior to the start of wildfire
season.
Idaho Power is committed to ongoing collaboration, training, and engagement
opportunities and regularly engages with emergency managers and Local Emergency
Planning Committees ("LEPCs")with focused outreach prior to each fire season to review
and provide updates on the Company's WMP. The Company also coordinates and
participates in tabletop exercises with public safety partners at reasonable intervals to
enhance knowledge of each other's emergency operations and ensure smooth
interactions during PSPS events, and it continues to seek opportunities to engage public
safety partners through tabletop exercises and similar preparedness activities,
particularly when there is shared interest and readiness to participate. For example, in
May 2026, Idaho Power plans to invite local public safety partners to participate in select
aspects of a PSPS mock event. This approach will allow the Company to test
communication channels and coordination efforts while aligning participation with partner
interest and availability.
IDAHO POWER COMPANY'S REPLY COMMENTS - 18

Finally, the City of Boise expressed concern that the elimination of climate change-
related verbiage from the Company's 2026 WMP minimizes the heightened risk of wildfire
due to climate change. The City of Boise also encouraged Idaho Power to explicitly model
both the risk and potential increase costs of wildfire mitigation due to the ongoing threat
from climate change.
Idaho Power appreciates the City of Boise's interest in how climate variability may
influence wildfire risk. The Company recognizes that changes in temperature, fuel
conditions, drought frequency, and seasonal weather patterns can affect wildfire potential
over time. The Company has incorporated both seasonal climate information and long-
term climate variability into its understanding of wildfire risk and will continue to evaluate
how these factors influence fire-weather conditions in its service area.
Idaho Power's current wildfire risk modeling is based on a 12-year climatology that
includes a wide distribution of severe fire-weather days. This approach captures the types
of extreme conditions that are most relevant to wildfire-spread potential and, as a result,
inherently accounts for a broad range of environmental scenarios. The Company does
not believe that climate variability can be reliably translated into quantifiable, project-level
wildfire-mitigation cost estimates at this time given the high degree of uncertainty in future
climate trajectories and the reliance of wildfire-risk models on historical climatological
inputs that already include severe fire-weather scenarios.
D. Idaho Emergency Management Association
In its comments, IEMA acknowledges the efforts taken by power providers to keep
communities and responders safe, such as by spreading awareness of wildfire risk zones
and the critical importance of personal preparedness. IEMA also notes the importance of
IDAHO POWER COMPANY'S REPLY COMMENTS - 19

coordinated planning with respect to potential PSPS events, particularly as it relates to
opening and maintaining CRCs. To facilitate this work, IEMA encourages early
engagement and frequent communication with local communities and recommends that
WMPs or operations plans result from regionally driven, scenario-based planning
discussions occurring prior to the wildfire season to help develop strategies, establish
resource needs, identify roles and responsibilities, and assess feasibility.
The Company appreciates IEMA's participation in this proceeding and agrees that
coordinated planning and frequent engagement with local communities to prepare for
potential large-scale, extended outages is critically important. Accordingly, the Company
conducts annual meetings with county emergency managers, local public safety partners,
and local emergency planning committees to develop county-specific strategies and
identify the unique needs each county may have during an outage event. A detailed
discussion surrounding this type of work being performed by the Company can be found
within Section 6.8, Community Resource Centers, of Idaho Power's 2026 Idaho WMP.
E. Northwest Energy Coalition
Through its comments submitted, NWEC acknowledges the Company's efforts in
creating a comprehensive plan, leveraging important partnerships that promote cost
savings and enhance coordination, and collaborating with community-based
organizations to support public outreach, education, and preparedness. NWEC also
encourages Idaho Power to proactively communicate to customers about Enhanced
Protection Settings ("EPS"), their associated outages, and how preparation is essential
to limit potential impact. Additionally, NWEC suggests that because the WSCA provides
some liability protections for electric utilities that reasonably implement a Commission-
IDAHO POWER COMPANY'S REPLY COMMENTS - 20

approved WMP, that a rigorous review and verification process is needed to ensure
proposed activities are implemented effectively. Moreover, NWEC discusses the
importance of balancing spending on advanced modeling, situational awareness and grid
hardening with front-end investments that are proven and supportive of community
energy resilience and safety, and that the Company should incorporate a forward-looking
investment approach to reduce long-term costs, prioritize co-benefits, and promote
coordinated planning.
Idaho Power appreciates NWEC's comments and agrees that ongoing
engagement, transparent communication, and coordinated planning are essential
components of an effective wildfire mitigation program. Idaho Power also agrees that
customer awareness is a critical part of preparedness and incorporates EPS information
into community outreach, preparedness fairs, and events led by Community Based
Organizations ("CBO") throughout the year. These engagements focus on how EPS
works, the types of outages customers may experience, and practical steps households
and businesses can take to prepare for wildfire-related or EPS-driven interruptions.
With respect to verification of performance, Idaho Power notes that the WSCA and
Commission require compliance-reporting requirements for utilities" to demonstrate how
they have substantially implemented the commitments in their approved wildfire mitigation
plans. Idaho Power will meet these reporting obligations through annual submissions,
documenting progress on approved wildfire-mitigation activities.
NWEC also highlights the importance of balancing investments in advanced
modeling, situational awareness, and grid hardening with "front-end" measures that
" See Idaho Code§ 61-1803(5) and Commission Order No. 36929.
IDAHO POWER COMPANY'S REPLY COMMENTS - 21

support long-term community resilience and safety. Idaho Power agrees with this
objective and employs a forward-looking approach to wildfire mitigation planning. Many
mitigation projects are scoped years in advance to account for environmental permitting
requirements, co-benefits such as reliability improvements, and long-term risk reduction.
This planning horizon helps ensure that investments are both cost-effective and
coordinated with broader community resilience needs.
Idaho Power appreciates NWEC's feedback and will continue working with public-
safety partners, CBOs, and stakeholders to refine communication strategies, improve
preparedness, and implement wildfire mitigation measures in a transparent and
accountable manner.
III. CONCLUSION
Wildfire mitigation and protection is, unequivocally, one of the most important
issues the Company continues to address at the enterprise level, and it is proud of the
comprehensive work it has undertaken and completed with respect to wildfire mitigation
efforts, PSPS development, customer and community education and engagement,
industry collaboration and learning, and pilot programs. The Company works diligently to
ensure it is able to effectively implement the activities detailed in its WMP, but recognizes
that wildfire mitigation and protection is an evolving practice in a rapidly changing
environment. Accordingly, the Company values Stakeholders' participation in this
proceeding and the proposals put forth to further enhance Idaho Power's subsequent
WMPs. Moreover, the Company appreciates Staff's thorough evaluation of its 2026 WMP
and its recommendation that the Commission issue an order approving the Company's
2026 WMP, as well as its request to file future WMPs on or about October 1st of each
IDAHO POWER COMPANY'S REPLY COMMENTS - 22

year. The Company also values Staff's proposals for future wildfire mitigation plan filings
and largely considers Staff's recommendations to be reasonable courses of action with
thoughtful methods and strategies for improving future WMP processes and analysis,
though in certain instances the Company offers additional suggestions or considerations
related to the recommendations as more fully discussed above and outlined below. In
addition, consistent with Idaho Code § 61-1804(3), the Company identifies below IDL's
recommendations that it believes are reasonable and appropriate within the context of its
WMP and considering the scope of the WSCA.12 More specifically, and based on the
foregoing, Idaho Power respectfully requests the Commission issue an Order:
1) Approving the Company's 2026 WMP (Staff Recommendation 1), finding it
complies with the requirements of the WSCA and Commission directives;
2) Approving the Company's request to file its WMP on or about October 1
each year (Staff Recommendation 2);
3) Clarifying that the most recent WMP-related requirements adopted as part
of Order No. 36774 and any subsequent orders supersede Commission orders issued
prior to the enactment of the WSCA and/or the Commission establishing a filing process
for WMPs submitted under the WSCA;
4) Adopting the following recommendations as proposed by Staff and IDL:
Recommendations Accepted by Idaho Power as Proposed
Additional Staff Recommendation 1 Continue to separate internal wildfire mitigation labor in cost
forecasts.
Additional Staff Recommendation 2 Continue to explore methods to reduce costs with communication
and education regarding wildfire and PSPS.
Additional Staff Recommendation 3 Continue providing details of all funding alternatives and sources
pursued within the WMP.
Additional Staff Recommendation 4 Address the types of infrastructure left out of risk modeling and, if
not included in the Company's models, provide an explanation as to
why.
Additional Staff Recommendation 7 Include quantitative model validation and analysis as part of
geographic I risk modeling and assessment.
Additional Staff Recommendation 8 Include the estimated cost, planned duration, and evaluation metrics
of each pilot program.
12 As discussed more fully above, the Company believes that two of IDL's recommendations exceed the
scope of legal and regulatory authority and requirements under the WSCA and so does not believe it
would be reasonable or appropriate to incorporate those items into the Commission's decision.
IDAHO POWER COMPANY'S REPLY COMMENTS - 23

Additional Staff Recommendation 12 Include the internal vegetation management crew description within
Section 10.2 of the WMP.
Additional Staff Recommendation 13 Adopt and mature implementation of industry best practices in
configuration management, requirements management, test
management, and issue and defect tracking for all custom models or
software developed for the FPI tool, as well as other custom-
developed models or applications that play a critical role in the
Company's WMP.
Additional Staff Recommendation 14 Add more detail about the resources available to call center agents
during a PS PS within Appendix B.
Additional Staff Recommendation 17 Identify the average cost of information for projects, such as
installation costs of the following: steel poles, fire mesh wraps,
wildfire detection cameras, undergrounding, covered conductor,
fiberglass cross arms to wooden, and weather stations.
Additional Staff Recommendation 18 Add all metrics that will be used for the WMP be included within
each respective section of the WMP and provide the data in a format
that can be tracked in each version of the WMP.
IDL Recommendations 1-3 Provide additional descriptive narrative details about the data used
to produce risk model, include narrative discussion on diminishing
returns as part of cost-benefit analysis, as well as the impact of
electrical service disruption in making mitigation choices.
Idaho Power Notes:
Idaho Power will provide details about the modeling inputs used by
the Company in its updated geographical risk analysis and,
consistent with the timeframe proposed regarding Additional Staff
Recommendation 16, will consider economic impact factors as part
of developing the cost-benefit framework to inform future iterations
of the Company's WMP.
5) Adopting the following recommendations by Staff and IDL, modified or
clarified by Idaho Power as outlined below:
Recommendation Accepted by Idaho Power as Modified/Clarified
Additional Staff Recommendation 9 Set and publish annual miles for all T&D hardening programs and
projects by WRZ Tier or feeder, plus modeled ignition risk reduction
per mile for each category.
IPC Modification:
The Company believes the recommendations specific to cost benefit
analysis should be interpreted more generally to require only that
Idaho Power develop modeling of ignition risk reduction and
mitigation effectiveness and that such modeling only be required to
inform its WMP beginning within its 2028 plan.
Additional Staff Recommendation 10 Adopt an effectiveness scorecard for each grid hardening method
(including but not limited to covered conductor, non-wooden poles,
non-wooden crossarms, undergrounding, etc.) based on industry
guidance.
IPC Modification:
The Company believes the recommendations specific to cost benefit
analysis should be interpreted more generally to require only that
Idaho Power develop modeling of ignition risk reduction and
mitigation effectiveness and that such modeling only be required to
inform its WMP beginning within its 2028 plan.
Additional Staff Recommendation 11 Include a table that includes all T&D rebuild and grid hardening
ro ects that includes the following: project name, project type,
IDAHO POWER COMPANY'S REPLY COMMENTS - 24

primary driver, location, design standards, anticipated project
timeline, and estimated costs within the WMP. Including an
explanation if the wildfire mitigation priority of the project changed
any aspects of the project(i.e., design, costs, and timeline).
IPC Clarification:
Apply specifically to T&D rebuild and grid hardening projects
undertaken as part the Company's wildfire mitigation strategy,
versus all such projects across its system.
Additional Staff Recommendation 16 Conduct cost-benefit analysis on a project-by-project basis to
demonstrate that each project reasonably balances the costs with
the reduction in wildfire risk.
IPC Clarification:
Idaho Power will continue to work on this effort in 2026 and will
provide an update on its progress within the Company's 2027 WMP.
6) Directing the Company to work with Staff in advance of finalizing its next
WMP to better understand its objectives and to find appropriate and workable methods
of addressing the following recommendations:
Recommendations for Further Discussion and Collaboration
Staff Recommendation 3 Requiring the Company include copies of the Company's four most-
recent quarterly NERC FAC-003-X compliance reports as
attachments in future WMPs (where X represents the latest version
of the standard the Company is using).
Staff Recommendation 4 Requiring the Company include copies of current Transmission
Maintenance and Inspection plans used for NERC FAC-501-WECC-
X compliance and any violations noted from the most recent NERC
compliance audit (X represents the latest version of the standard the
Company is using).
Additional Staff Recommendation 5 Find ways to include loss of life as a parameter in [the Company's]
future wildfire risk assessments and, at a minimum, include it as a
qualitative parameter where loss of life has higher probabilities.
Additional Staff Recommendation 6 Take necessary steps to integrate asset condition/inspection data
and failure modes into ignition models as part of geographical risk
modeling and assessment.
Additional Staff Recommendation 15 Expand reporting for future WMPs to include both transmission and
distribution assets not covered by NERC Standards to offer a more
comprehensive view of trends and effectiveness across the utility's
entire s stem.
Respectfully submitted this 5th day of March, 2026.
U
MEGAN GOICOECHEA ALLEN
Attorney for Idaho Power Company
IDAHO POWER COMPANY'S REPLY COMMENTS - 25

CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 5th day of March 2026, 1 served a true and correct
copy of Idaho Power Company's Reply Comments upon the following named parties by
the method indicated below, and addressed to the following:
Commission Staff Hand Delivered
Erika Melanson U.S. Mail
Deputy Attorney General Overnight Mail
Idaho Public Utilities Commission FAX
11331 W. Chinden Blvd., Bldg No. 8 FTP Site
Suite 201-A (83714) X Email
PO Box 83720 Erika.Melanson(a-),puc.idaho.gov
Boise, ID 83720-0074
Idaho Department of Lands Hand Delivered
J. J. Winters U.S. Mail
Tyre Holfeltz Overnight Mail
Julia Lauch FAX
Idaho Department of Lands FTP Site
300 N. 6t" Street, Ste. 103 X Email
Boise, Idaho 83702 jwinters(aD-idl.idaho.gov
tholfeltz _idl.idaho.gov
jlauch _idl.idaho.gov
Micron Technology, Inc. Hand Delivered
Austin Rueschhoff U.S. Mail
Thorvald A. Nelson Overnight Mail
Austin W. Jensen FAX
Kristine A.K. Roach FTP Site
Holland & Hart, LLP X Email
555 17t" Street, Suite 3200 tnelson(a)-hollandhart.com
Denver, Colorado 80202 awiensen(d0ollandhart.com
karoach(a)hollandhart.com
aclee(a)-hol land hart.com
tlfriel(a-hol land hart.com
Stacy Gust
Regulatory Administrative Assistant
IDAHO POWER COMPANY'S REPLY COMMENTS - 26