20260313Idaho Department of Lands Comments_1.pdf

John A. Richards #10670
J.J. Winters #10327 RECEIVED
IDAHO DEPARTMENT OF LANDS MARCH 13, 2026
300 N. 61h Street, Ste. 103 IDAHO PUBLIC
Boise, ID 83702 UTILITIES COMMISSION
[phone]
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Attorneys for Idaho Department of Lands
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF AVISTA CASE NO. AVU-E-25-15
CORPORATION'S APPLICATION FOR
APPROVAL OF THE COMPANY'S 2026 IDAHO DEPARTMENT OF
WILDFIRE MITIGATION PLAN LANDS' COMMENTS
Idaho Department of Lands ("IDL")respectfully submits the following comments in the
above-captioned matter pursuant to Idaho Code § 61-1804(3) and Order No. 36927 on behalf of
Idaho State Forester, Julia Lauch.
I. IDL has long required our cooperators at the county level who develop and maintain
County Wildfire Preparedness Plans to provide descriptive details about the modeling inputs that
are used to create their products. It is IDL's position that if we don't hold utilities to the same
standard then a "double" standard would be established setting a precedent that does not "move
the needle"on wildfire mitigation efforts. IDL respectively requests that Avista provide additional
descriptive narrative details in their wildfire mitigation plan about the data utilized and process
that was used to produce their"risk"model.
2. Avista completed a robust cost-benefit analysis for underground services that was
insightful. However, it did not provide a cost-benefit analysis for the other general mitigation
action categories. IDL respectively requests an analysis that compares taking no mitigation
actions—i.e. vegetation management, infrastructure hardening—against the provided details of
IDAHO DEPARTMENT OF LANDS'COMMENTS-1

incurred and plan expenses. This comparison will provide a better understanding of the
ramification of not completing mitigating activities/actions to the utility and surrounding
communities.
3. Generally,throughout the plan the assumption of wildfire risk is addressed from an
internal causality standpoint, whereas external wildfire impact can and often does, impact reliable
service. IDL requests Avista include additional connection of activities to the influence of external
wildfire impinging on the system to clarify which actions are being taken to reduce damage from
external wildfire events on the system.
4. Avista addressed, as required, the fair market value for timber in the Marketable
Timber section narrative, which indicated that a formal process or system has yet to be defined.
IDL requests that Avista add a formal project as an implementation action to address this aspect
of risk mitigation, as it represents a substantive unknown that can be addressed through the
development of a standard operating procedure. It is IDL's position that these SOPS be highlighted
in this section in the next submission of the plane, which will build greater confidence in
relationships and the values associated with timbered lands.
5. In the section covering inspection of vegetation, the qualifications appropriately
center around arboriculture standards, which have long been the industry standards. However,
IDL argues that these standards are insufficient at addressing wildland fire related issues when
looking at vegetative mitigation as a mechanism to reduce wildfire risk. The arboriculture stands
address tree/shrub conditions and how to appropriately remove or prune. Though these standards
address vegetation health,they do not consider ignition potential or fire propagation,both of which
should be standard for inspection of vegetation treatments. When viewed in the context of
wildfires, a prime example is "ladder" fuels. Ladder fuels are vegetative structural components
that allow fire to move rapidly from ground to forest canopies. If ladder fuels are not addressed
as part of the mitigation actions, then the risk of fire propagating to crowns is substantially
higher. IDL respectfully recommends that the inspection qualification standards also include
certification specific to wildland fire.
6. Every county in Idaho has completed a County Wildfire Preparedness Plan and IDL
strongly encourages that Avista integrate through participation in the county "fire planning
groups". This will help to crosswalk efforts between the various planning efforts and allow for
greater leveraging of group resources to address wildfire risk mitigation and wildfire mitigation
IDAHO DEPARTMENT OF LANDS'COMMENTS-2

education across the various county plans and Avista's plan.
7. IDL would like to commend the efforts of Avista to engage with local cooperators
and IDL through agreements to address risk mitigation within the Avista System. IDL has
recommended to several other utilities in Idaho that they develop similar programs of work, as
these efforts have proven to be an effective and efficient way to address wildfire risk reduction,
not just to the utility infrastructure, but to adjoining communities as well.
Respectfully submitted this 13th day of March, 2026.
IDAHO DEPARTMENT OF LANDS
-41k-
J.J.WINTERS
Attorney for Idaho Department of Lands
IDAHO DEPARTMENT OF LANDS'COMMENTS-3

CERTIFICATE OF SERVICE
I hereby certify that on this 13th day of March,2026,I caused to be served a true and correct
copy of the foregoing by the method indicated below, and addressed to the following:
Avista Corporation 0 Email:anni.glo og vac(a avistacorp.com
Anni Glogovac liz.andrewskavistacorp.com
Elizabeth Andrews avistadockets(aavistacorp.com
P.O. Box 3727
1411 E. Mission Avenue, MSC 33
Spokane, WA 99220- 3727
Idaho Public Utilities Commission ❑x Email: secretary_kpuc.idaho._og_v
Commission Secretary ;efj f.loll(&,puc.idaho. og_v
P.O. Box 83720
Boise, ID 83702-0074
Jeff Loll
Deputy Attorney General
11331 W. Chinden Boulevard, Bldg. 8
Suite 201-A (83714)
P.O. Box 83720
Boise, ID 83702-0074
PotlatchDeltic Forest Holdings, Inc. ❑x Email: petergrichardsonadams.com
Peter J. Richardson michele.tyler(&,potlatchdeltic.com
Richardson Adams, PLLC wade.semelisskpotlatchdeltic.com
515 N. 27th Street brian.schlect(&,potlatchdeltic.com
Boise, ID 83702 anna.torma(&,potlatchdeltic.com
Michele Tyler, Esq.
Wade Semeliss
Brian Schlect, Esq.
Anna Torma
601 W. First Avenue, Suite 1600
Spokane, WA 99201
Is/Kayla Dawson
Kayla Dawson
IDAHO DEPARTMENT OF LANDS'COMMENTS-4