20260416Comments.pdf

RECE IVED
April 16, 2026
1 Peter J. Richardson ISB # 3195 IDAHO PL BLIC
515 N. 271h Street UTILITIES COMMISSION
2 Boise, Idaho 83702
3 [phone] DD
[phone] Cell
4 peter-Rxichardsonadams.com
5
6 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
7
8 IN THE MATTER OF AVISTA Case No.: AVU-E-25-15
9 CORPORATION'S 2026 WILDFIRE
MITIGATION PLAN
10 POTLATCHDELTIC FOREST HOLDINGS,
LLC's COMMENTS URGING REJECTION
11 OF AVISTA'S WILDFIRE MITIGATION
12 PLAN
13
14
COMES NOW, POTLATCHDELTIC FOREST HOLDINGS, LLC ("PotlatchDeltic")
15
16 and pursuant to that Notice of Modified Procedure issued in Order No. 36927 by the Idaho
17 Public Utilities Commission("Commission") and pursuant to Rule 203 of the Commission's
18 Rules of Procedure, IDAPA 31.01.01.203, hereby lodges its Comments Urging Rejection of
19
Avista Corporation's ("Avista") Wildfire Mitigation Plan("WMP"). Alternatively,
20
PotlatchDeltic asks that the Commission deny Avista's request to prosecute this matter via
21
22 modified procedure and rather to hold evidentiary hearings as to whether its WMP should be
23 approved or rejected. In support whereof, PotlatchDeltic says as follows:
24
25
26
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1
2
3 I
BACKGROUND
4
1. PotlatchDeltic:
5
6 PotlatchDeltic Forest Holdings, LLC is a private owner of significant timbered acreage in
7 Idaho, including land holdings that are valuable timbered lands that are susceptible to wildfire.
8 Said forested lands are located, in part, in the service territory of and/or adjacent to facilities
9
owned and/or operated by Avista. For PotlatchDeltic, the prevention of wildfire is a constant
10
concern. Adding to that concern is the fact that a substantial portion of PotlatchDeltic's
11
12 valuable commercial timber holdings are traversed by Avista's electric distribution and
13 transmission systems. The Commission's decision process throughout this docket must therefor
14 be constantly instructed by the stark fact that Avista is seeking an order from this Commission
15
granting it immunity for its acts/omissions that cause an inferno in the forest. PotlatchDeltic's
16
property and, indeed,the very lives and livelihoods of PotlatchDeltic's dedicated employees and
17
18 contractors' in Idaho are at risk in such an event. Depending on whether Avista's WMP is
19 blessed by the Commission, liability for untold millions of dollars of valuable timber and the
20 very lives and livelihoods of PotlatchDeltic's employees and contractors is at stake.
21
22
23
24
25
'26 Many of whom are Avista residential and commercial ratepayers.
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I While PotlatchDeltic is confident in the Commission's diligence in reviewing Avista's
2 WMP, it is nevertheless critical that the magnitude of the consequence of its decision in this
3
matter be a constant beacon and guidepost.
4
5 2. The Commission is Severely Limited in its ability to Respond to a WMP
6
Application: The Commission's hands are tied. It can only do one of two things in response
7
to Avista's filing—it may reject the filing in its entirety, or it may approve the filing in its
8
9 entirety.' This is unfamiliar territory for the Idaho PUC. In an, other proceedin the
i o Commission has the authority to easily excise a flaw in a utility application or rate case
11 without the wholesale rejection of the utility's entire application. Here,the Commission does
12
not have that flexibility. A flaw in Avista's case, no matter how significant or trivial, can only
13
be remedied by the Commission's rejection of the WMP Application in total.
14
15 3. Consequences of Approval of a Flawed WMP are Without Remedy.
16
17 Approving a flawed Application has consequences—potentially serious consequences.
18 An approved WMP results in a blanket grant of immunity for Avista's negligence in starting a
19
conflagration that has the potential to cause the loss of life, property and livelihoods - all
20
21 without the ability of the injured to seek recovery or compensation. According to the Act:
22 [T]here is a rebuttable presumption that the electric corporation acted without
negligence if, with respect to the cause of the wildfire, the electric corporation
23 reasonably implemented a commission-approved wildfire mitigation plan. This
24
25
26 2 Wildfire Standard of Care Act(the"Act")at Idaho Code Section 61-1804(1).
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I rebuttable presumption extends to any act or omission taken in reasonable accordance
2 with [the WMP].3
3 As an example, assume the Commission approves a WMP that does not address Fire Safety
4 Measure XYZ. Subsequently, a wildfire is ignited due to the lack of the implementation of Fire
5 Safety Measure XYZ, which safety measure could have easily been implemented and if properly
6
implemented would have prevented the fire's ignition. The utility's omission to implement Fire
7
8 Safety Measure XYZ, regardless of its negligence in its failure to do so, is nevertheless granted
9 immunity from liability under the Act. The failure to implement Fire Safety Measure XYZ
10 would clearly be considered an"omission taken in reasonable accordance with the approved
11 wildfire mitigation plan."4 Note that the utility is granted immunity based on the utility's actions
12
or omissions that are in"reasonable accordance" with its WMP and not based on the
13
14 W
reasonableness (or lack thereof) of the MP itself. Critically, the Act only requires the
15 Commission to determine if a WMP is adequate—not comprehensive or rigorous or prudent—
16 just adequate.5
17 II.
18 AVISTA'S WMP MUST BE REJECTED BY THE COMMISSION
19 1. At Least 90% of Avista's 2026 WMP Efforts are Either(1) Inapplicable to Idaho or
20
(2) Free Rider Measures Masked as WMP Implementation Measures
21
22
23
s Id.at Idaho Code Section 61-1806(1), emphasis provided.
24 a Id. It would be difficult, if not impossible,for an injured person to successfully argue that the omission to act
subjects the utility to liability in light of the express language in the statute to the contrary.
25 s Idaho Code Section 61-1804(1)(c),the test is"the degree to which the plan adequately minimizes
26 wildfire risk...", emphasis provided.
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I Grid hardening is the cornerstone, indeed almost the entirety, of Avista's WMP.
2 According to Avista's WMP:
3
GRID HARDENING & INSPECTIONS
4 Strategies for Line Design, Inspection and Upgrade of
5 Equipment to Reduce Wildfire Risk
Powerline outages can result from uncontrollable events such as storms, high winds,
6 lightning, and vehicle collisions. However, upgrading conductors and equipment can
significantly reduce outage frequency and the risk of spark ignition, offering a cost-
effective mitigation strategy.
8
Grid hardening_represents the largest capital investment in Avista's Wildfire Mitigation
9 Plan—approximately 90%of total wildfire-related expenditures.6
10
11 Thus,the vast majority of Avista WMP efforts (as measured by capital investments)
12 are associated with grid hardening. Yet Idaho-focused grid hardening is largely absent from
13 Avista's WMP. Because, as discussed infra,the vast majority of Avista's 2026 WMP efforts
14
are either unrelated to Idaho or are not legitimate WMP measures, it is incumbent upon the
15
16 Commission to issue its order rejecting Avista's 2026 WMP.
17 While the body of the WMP identifies grid hardening as the backbone of Avista's
18 wildfire mitigation efforts, Appendix B of the plan provides the detailed "Budgets and
19 Targets" for the 2026 WMP. Page 1 of Appendix B of the WMP indicates that there will be
20
zero miles of distribution grid hardening in Idaho in 2026 and also zero miles of distribution
21
22 grid hardening in Idaho in 2027.7 Although there are zero miles of distribution grid hardening
23
24
25 6Avista's WMP at p. 19. Emphasis provided,capitalization in original.
26 Id.,Appendix B p. 1,first row and second and third columns.
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I of any type in Idaho, for the same time period there are 59 "High Risk Mitigated Miles" of
2 distribution grid hardening in Washington State. 8
3
The lack of any distribution grid hardening in Idaho for 2026 or 2027 is not an
4
5 oversight-- it is intentional. When asked to explain why the distribution grid in Washington
6 State is to benefit from grid hardening activities while Idaho's distribution grid is ignored,
7 Avista responded thusly:
8 Miles of mitigation [distribution grid hardening miles] was chosen based on the
9 highest average feeder risk score based on our current Risk Model, of which all
highest risk feeders are in more dense "urban fringe" WUI [Wildland Urban Interface]
10 areas in Spokane County.9
11 The WMP's failure to include forest lands for the benefits of distribution grid hardening is
12
discussed in more detail, infra; however Avista's admission, above, establishes that not only doe
13
Avista's WMP fail to address wildfire risk associated with its distribution system in forested
14
15 lands in Idaho, it fails to address grid hardening in any type of environment in Idaho such as
16 urban, suburban, rural or forested landscapes. Grid hardening is the backbone of Avista's WMP
17 and distribution grid hardening is by far the most important of the two types of grid hardening.
18
While there are only 900 miles of transmission line on Avista's system there are 2,567 miles of
19
distribution lines.lo
20
21
22
23
24 s Id.,Appendix B,p.3,first row and second and third columns.
9Avista Response to PotlatchDeltic Production Request No.6-13. This entire Production Request and Response are
25 attached hereto as Exhibit No. 1.
26 10Avista Application at p. 3.
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I Avista's budget for distribution grid hardening and wood pole management in Idaho
2 reveals that there are no grid hardening activities taking place in Idaho in 2026. Avista is asking
3
the Commission to grant it immunity from liability for its wildfire mitigation plan in Idaho which
4
5 —for practical purposes, simply does not exist. The budget for grid hardening and wood pole
6 management in Idaho for 2026, is limited to engineering work and is only $300,000. The budget
7 (for the same time) for distribution grid hardening and wood pole management in Washington
8 State is, by way of contrast, $26,500,000 or eighty-eight times larger than Idaho's budget.l
9
The other two grid hardening categories are Transmission Grid Hardening and
10
Transmission Remediation. While the budget for Idaho does anticipate 7.1 miles of transmission
11
12 grid hardening in Idaho, Avista's program of transmission grid hardening is a free rider that pre-
13 dates Avista's WMP process. Relative to transmission grid hardening the WMP provides:
14 Since 2006, Avista has systematically replaced wood transmission poles with steel,
15 primarily during rebuilds or when poles are damaged or fail.12
16 Steel transmission pole replacement is business as usual for Avista. According to Avista's pole
17
inspection manual:
18
The Transmission Design group moved to 100% steel designs in 2006, so wood poles are
19 slowly being eliminated from the transmission system at a conversion rate of 1-2%
annually.13
20
21
22
23
24 Avista's WMP at Appendix B. Idaho figures on p. 1,Washington State figures on p.2.
12 Avista's WMP at p.25.
25 13 Response to PotlatchDeltic Production Request No. 5. Attachment entitled,5-622:Specification for the
26 Inspection of Wood and Metal Poles, at p. 1. Attached hereto as PotlatchDeltic Exhibit No.2.
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I While 7.1 miles of transmission grid hardening (a.k.a. replacement of wood poles with steel
2 poles) is a step in the right direction, it is actually fewer annual miles of steel pole conversions
3
than is anticipated under the Transmission Design group's plan which calls for 1-2%conversions
4
5 annually or 9 to 18 miles annually.14 In addition, the transmission grid hardening is focused on
6 WUI lands, and not forested lands—which lands form the basis for PotlatchDeltic' s business
7 operations in Idaho.
8 Avista's failure to conduct any distribution grid hardening in Idaho in 2026 or 2027 and
9
only minimal transmission grid hardening in Idaho (7.1 miles) requires that the Commission
10
11 reject the WMP and send Avista back to the drawing board.
12 2. Avista's Distribution Vegetation Management `Plan' is a Free Rider that Fails to Comply
with the Act
13
14 In a blatant example of Avista's attempt to use its business-as-usual approach to wildfire
15 management, Avista admits that it has not changed its vegetation management efforts or
16 frequency cycles in response to the Idaho Legislature's passage of the Wildfire Standard of Care
17 Act in 2025. In response to PotlatchDeltic's Production Request No. 8 Avista admitted that:
18
REQUEST
19 Please explain and quantify the difference between Avista's vegetation management
efforts and frequency cycles between its most recent wildfire mitigation plan and its
20 proposed 2026 wildfire mitigation plan.
21
22 //
//
23
24
25
'4 26 Avista Application at p.3,"900 miles of overhead transmission lines"multiplied by 1 —2%equals 9 to 18 miles.
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I RESPONSE
Distribution Vegetation Management has not changed inspection frequency cycles since
2 our 2024 Wildfire Resiliency Plan and Report.15
3
The Act requires Avista to develop a WMP that"shall be implemented upon approval by the
4
5 Commission."16 Avista is proposing that it do nothing in response to Act's mandate that it
6 develop a"vegetation management"plan." It is impossible for Avista to comply with the
7 requirement that its vegetation management plan"shall be implemented" if it hasn't developed a
8 plan to be implemented. The mandate ("shall be") is written in the future tense, not the past
9
tense. It is impossible to comply with the requirement that a plan be implemented in the future i
to
11
all Avista is doing is dusting off an old plan that was implemented years ago. Doing nothing in
12 response to the Act is simply not good enough to warrant a blanket grant of immunity for
13 causing a damaging and potentially deadly conflagration. No utility, Avista included, should be
14 rewarded with an extraordinary grant of immunity for a cavalier business-as-usual WMP—it
15
simply does not comply with the mandates in the Act.
16
17 3. Avista's WMP is too Narrowlyy Focused b Excluding Forest and other Non-Urban Land
18 Avista's WMP is Washington State and urban/suburban centric. Largely ignored are the
19 forest lands that help sustain the economy in Avista's Northern Idaho service territory. In
20 response to discovery from PotlatchDeltic, Avista admits that it does not even have a map
21
22
23
24
15 PotlatchDeltic Production Request to Avista No. 8 is attached as PotlatchDeltic Exhibit No 3.
25 i6 Idaho Code Section 61-1803(4).
26 Idaho Code Section 61-1803(3)(g).
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I indicating areas of high fuel levels that are outside of the Wildland Urban Interface (WUI).
2 PotlatchDeltic's Production Request No. 7 requested:
3
Please provide a map showing all areas identified by Avista that exhibit high fuel levels
4 that are also not included as either a tier I or 2 or 3 Risk Level.
5 In response Avista made this admission:
6
Avista does not currently have a map that includes "high fuel levels" outside of the
7 predetermined Wildland Urban Interface Risk Tiers, as that information is used to help
determine the WUI tiers.18
8
9 Avista has not taken the time or effort to identify high-fuel/high-fire risk areas outside of its
10 predetermined Wildland Urban Interface Risk Tiers. It goes without saying that if one does not
11 know where the high fuel risk areas are then one cannot adequately anticipate or obviate the risk
12
of wildfires in those areas. Because PotlatchDeltic's forest land holdings are high4uel-risk/high-
13
14 fire-risk and are not typically in WUIs, its holdings have therefore been systematically excluded
15 from wildland fire mitigation measures implemented by Avista. Thus, Avista's plan, which
16 focuses exclusively on WUI areas, does not comply with Idaho's Wildfire Standard of Care Act.
17 Avista was asked, in PotlatchDeltic Production Request No. 22,to explain why it is fair
18
and just to exclude lands such as PotlatchDeltic's holdings in Idaho from its WMP:
19
H
20
21 H
22 H
23
24
25
26 18 PotlatchDeltic's Production Request to Avista No. 7 is attached as Exhibit 4.
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1
2 REQUEST
3 If areas of high fuel levels and low or negligible housing density do not rise to the level
of even a Tier 1 risk area and hence are in a low priority area for wildfire mitigation
4 measures, please explain why it is fair and just for the Commission to grant Avista
5 entitlement to immunity from liability for starting a wildfire in such areas.19
6 Avista did not deny that it was actively excluding lands such as are owned by PotlatchDeltic in
7 Northern Idaho from its WMP. Rather it tried to explain that fact away:
8 RESPONSE [partial]
9 While Avista's Wildfire Mitigation Plan (WMP)may provide greater focus in specific
areas, Avista's plan does not ignore lower risk Tier Areas where the impacts of wildfire
10 may be less significant.
11 Despite its protestations to the contrary, Avista has ignored the forests of Northern Idaho. It
12
admits, as noted above, that it hasn't even bothered to map the high-fuel, high-risk areas outside
13
14 of designated WUIs. Avista's suggestion that these are areas "where the impacts of wildfire may
15 be less significant" is made without foundation for the same reason. Therefore, Avista cannot
16 speak authoritatively as to the "significance" of the impact of wildfires on those lands - hence its
17 use of the wiggle words "may be less significant." PotlatchDeltic can, however, speak to the
18
significance, or lack thereof, of wildfires on Idaho's forested lands and it hereby avows that
19
wildfires on its forested lands in Northern Idaho are significant events. Idaho's forests are
20
21 deserving of a share of Avista's wildfire mitigation measures and budgets.
22
23
24
25
26 19 Avista's Response to PotlatchDeltic Production Request No.22,attached as PotlatchDeltic Exhibit No. 5.
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I Avista's response to Production Request No. 22 continues, after having made the
2 unsubstantiated assertion that forest fires are events of"less[er] significan[ce]", by stating that it
3 has conducted a balancing of the risks and costs and has decided which of its customers are
4
5 deserving of wildfire mitigation measures and which are not—thereby usurping this
6 Commission's legislatively mandated function:
7 RESPONSE
...[T]he goal of the WMP is to mitigate the risk of wildfire across our service territory,
8 while also being cognizant of the cost pressure that work necessarily places on customer
9 bills.
10 If the Idaho Public Utilities Commission(IPUC) were to exclude lower Risk Tier areas
from Avista's WMP, and by extension from the protections afforded under Idaho law, th
11 natural response would be to spend more on wildfire mitigation in those areas, which
12 would undermine the balance between wildfire mitigation efforts and customer
affordability that both Avista's WMP and Idaho law are intended to protect.20
13
This is not Avista's call to make - it is the Commission's job to balance the wildfire mitigation
14
15 efforts (costs) and customer affordability. According to the Act, "the Commission shall consider
16 ...the feasibility of the plan and the cost of its implementation. "2l Here, Avista has preempted
17 the Commission and presented it with a fait accompli. Because Avista has not explored the costs
18
or the benefits of including Idaho's forests within the reach of its WMP, the Commission is
19
20
without an adequate record upon which to decide on the reasonableness of the plan as a whole.
21
22
23
24
25 20 Id.
21 Idaho Code Section 61-1804.
26
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I Therefore, the Commission must reject the plan as filed and send Avista back to the drawing
2 board to arrive at a plan that encompasses all of its constituencies.
3
The Commission should not bestow immunity from liability on Avista for
4
5
adopting a WMP that ignores forest lands (both private and public) in Idaho. As noted above,
6 PotlatchDeltic owns significant forest lands in Northern Idaho that are traversed by Avista's
7 transmission and distribution lines. Its Idaho operations are dependent on a healthy, and
8 sustainable forest—which is always at risk of wildfire. Avista's WMP, however, fails to
9
provide for wildfire mitigation measures generally for the State of Idaho and specifically for
10
11 W non- UI property such PotlatchDeltic's forest holdings. In other words, Avista's WMP fails
12 as it is not adequately "designed to minimize wildfire risk...[or] respond to wildfires that do
13 occur."22
14 4. The WMP is Fatally Ambiguous and Non-Specific
15
The Wildfire Standard of Care Act is, admittedly, at times vague and lacking in detail
16
17 as to how compliance is to be accomplished. It was, after all, written by committee and
18 displays the traits of having been so crafted. On the other hand, a reasonable, implementable
19 and compliant WMP cannot suffer from ambiguity or vagueness and still be enforceable. An
20 enforceable and reasonable WMP must have specific, objective and quantifiable measures.
21
22
23
24
25
26 22 Idaho Code Section 61-1804(c).
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I Because Avista's WMP fails in this regard it must be rejected by the Commission. Examples
2 of vague non-specific implementation metrics are abundant in the WMP. For example:
3
A. Vague Grid Hardening Metrics:
4
Avista's WMP states at p. 19 that one of its grid hardening strategies includes
5
6 "Rebuilding lines with hardened designs" and that, "Wildfire grid hardening shifts the focus
7 toward reducing spark ignition potential and enhancing system resilience during fire and
8 other environmental stressors. " Unfortunately, for enforcement and verification purposes, the
9
WMP doesn't inform as to what it looks like when a"line" is "rebuilt" with"hardened
10
11 designs." Confronting this ambiguity, PotlatchDeltic asked Avisa in a production request23 to
12 describe the above referenced"hardened designs." Avista's response provided that:
13 Rebuilding lines with hardened designs refers to upgrading overhead existing
14 infrastructure with improved engineering design elements.24
15 The answer is purposefully vague. It does not identify what"improved engineering design
16 elements" are or how they are to be identified, nor does it state when these improved"design
17 elements"must be installed or whether the"failure to install one or more than one of the
18
"improved engineering design elements" satisfies the grid hardening standard—which itself is
19
not defined. Nevertheless, Avista's answer goes on to state:
20
21 H
22
23
24
25 zs PotlatchDeltic Production Request No.4,attached as PotlatchDeltic Exhibit No.6.
26 211d.,at p.2,emphasis in original.
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1
2 Rebuilding lines routinely involves the following work:
3 • Replacing wood cross arms with fiberglass.
• Changing out small copper conductor.
4 • Installing stirrups at hot tap connection.
5 • Converting "open-wire secondary" districts with insulated triples
secondary distribution.
6 • At high-value pole locations—installing fire mesh wrap to existing wood
7 poles25
8 Ambiguities abound. The above five "work" items are described as routine. It is, however,
9 counterintuitive to describe routine maintenance work as meeting the ostensibly higher
10 standard of an"improved engineering design element." It is not clear (ambiguous)whether
11
these five items are either"routine" or"improved engineering design elements." It is not
12
13 clear(ambiguous) whether the installation of one of the five "work" elements constitutes a
14 `rebuilt' line or if all five must be combined to do so, or if some subset of the five will suffice.
15 Next, Avista's response to Production Request No. 4 continues by providing the
16 following wisp of a hardening standard:
17
In addition to overhead infrastructure, wildfire grid hardening strategies refer to
18 many kinds of*improvements that create resiliency and reliability in the system.26
19 And finally, the answer concludes by noting that;
20
Other hardening strategies include:
21 • Undergrounding select distribution segments
22 • Deploying automated protection devices (e.g. reclosers), This work is
performed on overhead infrastructure on a case-by-case basis.
23
24
25 25Id.
26 Id.
26
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1 • Replacing high-value distribution poles with ductile iron, where truck
accessible.
2 • Installing covered conductor.27
3
It is unclear whether one, all, or some subset of these measures are routine measures deployed
4
5 for resilience and reliability purposes or whether they are "improved engineering design
6 elements." Some of these measures will obviously reduce wildfire risk such as
7 undergrounding, but Avista's answer provides no detail as to the magnitude of deployment
8
required nor does it provide objective, measurable metrics as to when Avista believes the grid
9
is sufficiently hardened in its Idaho service territory for the PUC to grant Avista immunity for
10
I I causing wildfires.
12 If one of these five grid hardening measures is not installed, for instance covered
13 conductor, will that mean the grid is not hardened? On the other hand, if one measure is only
14
partially installed, e.g. covered conductor is only installed on 2.5 miles28 out of 2,50029 miles
15
of distribution lines, does that mean the grid is hardened?30 All these ambiguities make it
16
17 impossible to clearly identify that mysterious moment in time when the plan is sufficiently
18 mature, detailed, implemented and enforceable such that Avista is entitled to immunity from
19 liability for causing a destructive and potentially deadly wildfire in Idaho. The covered
20
conductor example is particularly apropos to this issue. Avista's WMP at p. 23 reveals that
21
22
23
24 27Id.
26 Avista's WMP at p.25.
25 29 Avista's Application at p.4.
26 so Avista's WMP at P.25.
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1 (1) covered conductor measures are not being planned for installation in Idaho, (2) only 2.5
2 miles of covered conductor have ever been installed by Avista, and (3) those 2.5 miles of
3
covered conductor miles are in Washington State. Although covered conductors are identified
4
5
as one of Avista's top grid hardening strategies, it is not and cannot be considered a valid
6 component of its 2026 WMP.
7 The assertion by Avista that its non-existent covered conductor program is a valid grid
8 hardening measure31 that entitles it to wildfire liability immunity should be rejected by the
9
Commission. More importantly, however, the fact that Avista includes covered conductors as
10
11 part of its wildfire mitigation plan with no concrete plan to actually install covered conductors
12 and with no covered conductors in or planned for Idaho, should serve as a warning to the
13 Commission that Avista's entire plan is too vague, too non-specific and too lacking in detail
14 to form the basis for the Commission to grant it immunity from liability. The Act restricts the
15
Commission to only approving WMPs that actually "establish the electric corporation's duty
16
17 to...the public. "32 There is simply no "duty" established in Avista's WMP for it to install
18 covered conductor, or in fact, to install any of the other grid hardening measures either,
19 generally in Idaho or specifically on forest lands in Idaho. That failure to establish an
20 affirmative duty to implement grid hardening and other wildfire mitigation measures is fatal to
21
22
23
24
si See,e.g.,Avista's WMP at p.20,"Grid hardening efforts will focus on three key areas." Of the three,covered
25 conductor installation was number two on the list.
12Idaho Code Section 61-1805.
26
POTLATCHDELTIC FOREST HOLDINGS, LLC'S COMMENTS URGING REJECTION OF AVISTA'S
27 WILDFIRE MITIGATION PLAN
AVU-E-25-15
28
PAGE 17

I the Commission's authority to approve Avista's WMP. The Commission's only alternative is
2 to reject Avista's WMP.
3
5. Avista's WMP is Discriminatory and Arbitrary
4
5 It is not fair,just or reasonable for Avista to take advantage of a grant of immunity,
6 conferred by this Commission, without the quid pro quo of it actually engaging in wildfire
7 risk abatement measures on its electrical system in the forests of Northern Idaho. Otherwise,
8 a one-sided and non-compensated transfer of wealth will have occurred—from PotlatchDeltic
9
to Avista. Right now, Avista's balance sheet bears the burden of potential liability for
10
11 wildfires started by Avista's electric plant in Idaho. Should its WMP be approved,that
12 liability does not just disappear. Instead, the liability for wildfires started by Avista will then
13 be transferred from Avista to PotlatchDeltic. PotlatchDeltic will, if Avista's WMP is
14 approved, have to pay for the damages wrongfully caused by Avista's electrical system to
15
PotlatchDeltic's property. Avista's potential liability will have been lifted from its balance
16
17 sheet and that liability will end up on the balance sheets of, not just PotlatchDeltic, but on the
18 balance sheets of everyone in Idaho whose property is potentially destroyed by a wildfire
19 caused by Avista's electric system. Unfortunately, PotlatchDeltic will bear a disproportionate
20 and unfair burden in this exchange because it will not have had the `benefit' of any of Avista's
21
mitigation measures - none of which have been targeted at Idaho forest lands. This
22
23 uncompensated transfer of wealth is not only unfair, unjust and unreasonable, but it
24 discriminates without cause—making it arbitrary and of questionable legality.
25 H
26
POTLATCHDELTIC FOREST HOLDINGS,LLC'S COMMENTS URGING REJECTION OF AVISTA'S
27 WILDFIRE MITIGATION PLAN
AVU-E-25-15
28
PAGE 18

I WHEREFORE, PotlatchDeltic Forest Holdings, LLC respectfully requests the
2 Commission to issue its order rejecting Avista's Wildfire Mitigation Plan without prejudice to
3
file a subsequent, compliant, plan.
4
c
5
By:
6 Peter icilardsc>n
Richardson Adams, PLLC
7 Attorneys for PotlatchDeltic Forest Holdings, LLC
Dated this 16th day of April 2026.
8
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POTLATCHDELTIC FOREST HOLDINGS,LLC'S COMMENTS URGING REJECTION OF AVISTA'S
27 WILDFIRE MITIGATION PLAN
A VU-E-25-15
28
PAGE 19

I CERTIFICATE OF SERVICE
2
3 I HEREBY CERTIFY that on the 16th day of April 2026, a true and correct copy of the within
and foregoing POTLATCHDELTIC FOREST HOLDINGS, LLC'S COMMENTS URGING
4 REJECTION OF AVISTA'S WILDFIRE MITIGATION in Docket No. AVU-E-25-15 was
5 served by electronic copy only, to:
6 Monica Barrios-Sanches Anni Glogovac
Commission Secretary Counsel for Regulatory Affairs
7 Idaho Public Utilities Commission Avista Corporation
PO Box 83720 P.O. Box 3727
8 Bosie, ID 83720-0074 1411 E. Mission Avenue, MSC 33
9 secretarvQ2uc.idaho.gov Spokane, WA 99220-3727
monica.bariossanches,cpuc.idaho.g.ov anni.gloQovac;2avistacorp.com
10
Elizabeth Andrews
11 Senior Manager of Revenue Requirements
12 Avista Corporation
P.O. Box 3727
13 1411 E. Mission Avenue, MSC 27
Spokane, WA 99220-3727
14 lii andrews;'Ravistacorp.com
15 avistadockets r,aavistacorn.com
16
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23 By: Peter J. Richardson ISB # 3195
24
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POTLATCHDELTIC FOREST HOLDINGS, LLC'S COMMENTS URGING REJECTION OF AVISTA'S
27 WILDFIRE MITIGATION PLAN
AVU-E-25-15
28
PAGE 20

I Peter J. Richardson ISB # 3195
515 N. 27th Street
2 Boise, Idaho 83702
3 [phone] DD
[phone] Cell
4 peter iyrichardsonadams.com
5
6 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
7
8 IN THE MATTER OF AVISTA Case No.: AVU-E-25-15
9 CORPORATION'S 2026 WILDFIRE
MITIGATION PLAN
10 POTLATCHDELTIC FOREST HOLDINGS,
11 LLC's COMMENTS URGING REJECTION
OF AVISTA'S WILDFIRE MITIGATION
12 PLAN
13
14
15 POTLATCHDELTIC
16 EXHIBIT NO. 1
17 Avista Response to PotlatchDeltic Production Request No. 6.
18
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26
POTLATCHDELTIC FOREST HOLDINGS,LLC'S COMMENTS URGING REJECTION OF AVISTA'S
27 WILDFIRE MITIGATION PLAN
AVU-E-25-15
28
EXHIBIT NO. 1.

AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION: IDAHO DATE PREPARED: 02/10/2026
CASE NO: AVU-E-25-15 WITNESS: N/A
REQUESTER: Potlatch RESPONDER: Robb Raymond
TYPE: Production Request DEPARTMENT: Energy Delivery
Project
REQUEST NO.: Potlatch-006 TELEPHONE: [phone]
REQUEST:
References Appendix B of the WMP.
6-A Under the Grid Hardening section is a row entitled "High Risk Mitigated Miles." Please
explain what is meant by the phrase "High Risk Mitigated Miles" as this phrase does not appear
elsewhere else in the WMP.
6-B There are zero High Risk Mitigated Miles in Idaho (page 1) for the years 2026 and2027,
while for the same time period there are 42 High Risk Mitigated Miles and 17 High Risk
Mitigated Miles, for 2026 and2027 respectively, in Washington State(page 3). Plc�ise explain
why there are zero High Risk Mitigated Miles in Idaho for the same time period.
6-C Under the Grid Hardening section is a subsection entitled "Grid Hardening Wood Pole
Mgmt" and under that heading is a row entitled "Poles refreshed in High-Risk Areas." Please
explain what a "refreshed" pole is.
6-D There are zero "Poles refreshed in High-Risk Areas" in Idaho for the year 2026 while there
are 2,400 poles refreshed" in High-Risk Areas in Washington State for the same year. Please
explain why there are zero' refreshed' polies in Idaho for the same time period.
6-E Also under the Grid Hardening Section is a row entitled "Transmission Remediation." Please
explain what is meant by the phrase "Transmission Remediation" as the phrase does not appear
elsewhere else in the WMP.
RESPONSE:
A. "High Risk Mitigated Miles" describes the aggregated total miles that have received
treatments to reduce wildfire risk, excluding vegetation management which is tracked
separately. These improvements include hardening strategies such as overhead-to-
underground conversion, covered conductor upgrades, wood pole management, and
overhead Grid Hardening referred in the WMP as "Rebuilding litres with hardened
designs".
B. Miles of mitigation was chosen based on the highest average feederrisk score based on our
current Risk Model,of which all highest risk feeders are in more dense"urban fringe" WUI
areas in Spokane County.
C. The term "Refresh" was chosen to cover the full scope of a potential Wood Pole
Management treatment as stated on page 24 of the WMP.

D. Two feeders in Washington State have been selected for construction for 2026 that are
informed by the Wood Pole Management Program 20-year cycle schedule and are in areas
defined as higher risk according to our risk model.
E. "Transmission Remediation"refers to Crossarm and Equipment repairs identified through
annual inspections as cited on Page 25 of the WMP.
Page 2of2

I Peter J. Richardson ISB # 3195
515 N. 27th Street
2 Boise, Idaho 83702
3 [phone] DD
[phone] Cell
4 peter axichardsonadams.com
5
6 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
7
8 IN THE MATTER OF AVISTA Case No.: AVU-E-25-15
9 CORPORATION'S 2026 WILDFIRE
MITIGATION PLAN
10 POTLATCHDELTIC FOREST HOLDINGS,
LLC's COMMENTS URGING REJECTION
11 OF AVISTA'S WILDFIRE MITIGATION
12 PLAN
13
14
15 POTLATCHDELTIC
16 EXHIBIT NO. 2
17 Avista Response to PotlatchDeltic Production Request No. 5.
18
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25
26
POTLATCHDELTIC FOREST HOLDINGS,LLC'S COMMENTS URGING REJECTION OF AVISTA'S
27 WILDFIRE MITIGATION PLAN
AVU-E-25-15
28
EXHIBIT NO.2.

AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION: IDAHO DATE PREPARED: 02/10/2026
CASE NO: AVU-E-25-15 WITNESS: N/A
REQUESTER: Potlatch RESPONDER: Mark Gabert
TYPE: Production Request DEPARTMENT: Wood Pole
Management
REQUEST NO.: Potlatch-005 TELEPHONE: [phone]
REQUEST:
Beginning on page 23,the WMP begins a discussion of Avista's wood pole inspection process and
methods. On page 24, the WMP asserts that "The program [Wood Pole Inspection Program]
complies with the National Electrical Safety Code(NESC)and Avista's internal standards."Please
provide a copy of the referenced NESC code addressing wood pole inspection procedures and
frequencies referenced. Please also provide a copy of the referenced Avista internal standards
along with the date said standards were first adopted and the dates of subsequent iterations of the
same.
RESPONSE:
The National Electrical Safety Code (NESC) is published and copyrighted by the Institute of
Electrical and Electronics Engineers (IEEE). Avista maintains licensed copies of the NESC but is
not authorized to reproduce or distribute copies of the NESC in discovery.
Below is a list of the specific NESC parts and rules that address wood pole inspection procedures
and inspection intervals on which the Wood Pole Management (WPM) Program relies.
Avista's Wood Pole Management Program complies with the inspection and maintenance
requirements in:
• NESC Part 013 (Application) — establishes the scope and applicability of inspection
obligations for supply and communication lines.
NESC Part 121 (Inspections) — requires utilities to perform inspections of existing
facilities at intervals necessary to ensure safety and compliance.
NESC Rule 214 (Inspection and Tests of Lines and Equipment) — governs inspection
frequency,condition assessment, documentation requirements, and the correction of unsafe
conditions for in service facilities, including wood distribution and transmission poles.
These NESC provisions address inspection expectations at a performance-based level and do not
prescribe detailed inspection methods; utilities are permitted to implement internal standards that
meet or exceed NESC requirements.
Avista Internal Standards Governing Wood Pole Inspection
Avista implements and exceeds NESC inspection requirements through detailed internal standards
and specifications governing wood pole inspection procedures, frequencies, and documentation.
Avista Specification S-622—Specification for the Inspection of Wood and Metal Poles establishes
inspection methods, intrusive testing criteria, inspector qualification requirements, and
documentation standards for Avista's Distribution and Transmission systems.

A current copy of this specification is attached,see Potlatch-PR-005-Attachment A. The revision
dates are documented on the cover sheet.
Our internal standards are applied systemwide within Avista's WPM Program and are used to
determine inspection scope, inspection cycle lengths, intrusive testing requirements, and
replacement criteria. The standards are designed to support system safety,reliability, and wildfire
risk mitigation.
Page 2of2

AVISTA UTILITIES
SPOKANE, WASHINGTON
S-622: SPECIFICATION FOR THE
INSPECTION
OF WOOD AND METAL POLES
MAY 19, 1975
REVISION DATES:
REV. 1 -MARCH 1984
REV. 2 -APRIL 1985
REV. 3 -MAY 1990
REV.4 - FEBRUARY 1997
REV. 5 -OCTOBER 1998
REV. 6 -NOVEMBER 2001
REV. 7 -APRIL 2012
REV. 8 - SEPTEMBER 2013
REV. 9-FEBRUARY 2014
REV. 10-DECEMBER 2014
REV. I t-DECEMBER 2016
REV. 12-JUNE 2018
REV. 13-MAY 2019
REV. 14-FEBRUARY 2020
REV. 15-JANUARY 2023
REV. 16-MAY 2025
Potlatc-PR-005 Attachment A Page 1 of 55

AVISTA UTILITIES
Specification for the Inspection of Poles
A. SCOPE:
S-622 covers Avista's pole inspection process and requirements. Inspection includes a visual
assessment of the above groundline pole and equipment condition. It also includes sounding, boring,
and excavation to profile below groundline internal and external decay. Avista's Wood Pole
Management (WPM) Department manages pole inspections for the entire Distribution and
Transmission network. Distribution poles are inspected on a 20-year cycle, meaning approximately
5% of the 230,000 distribution poles are inspected annually. For Transmission, approximately 7% of
the 35,000 poles in the system are inspected annually which puts them on a 15-year cycle. For
Distribution, the pole inspection data is used to determine what structures and associated hardware
are replaced based on requirements from this document and the Wood Pole Management Design
Criteria Manual (WPM DCM). For Transmission, pole inspection data is sent to Avista's
Transmission Engineering Department who controls decision making for their asset replacements.
Currently Avista installs butt treated cedar poles on its distribution system for most new construction
and existing pole replacements. Distribution may also utilize metal poles in cases where guying is
limited. For Transmission, self-weathering steel poles are used for all new construction and existing
pole replacements. The Transmission Design group moved to 100% steel designs in 2006 so wood
poles are slowly being eliminated from the transmission system at a conversion rate of 1-2%
annually. Avista has installed other pole material types throughout its history including larch, fir,
cement, galvanized, and laminate. Collectively they represent less than 7% of the total pole
population, with larch poles being the highest at 6%.
Avista does not currently add any fumigant treatment during the pole inspection process. To offset
this, distribution poles are rejected if they have any decay at or below groundline. Rejected poles are
either trussed or replaced to address the management of decay and remaining pole strength. One of
the biggest issues with butt treated cedar poles is the propensity for external shell rot above
groundline which can create unsafe climbing conditions for internal and external employees. Pole
top decay can also impact hardware attached to the top of the pole. Both of these issues can impact
the useful life of a butt treated cedar pole.
WPM determines pole replacement based on strength and overall condition. Avista Standard DO
1.007 states poles older than 60 years of age should be replaced as described under the appropriate
work plans. The 60-year pole replacement recommendation was established during Avista's Grid
Modernization Program and documented in the System Wide Distribution Feeder Management Plan
(DFMP). It is also important to note that the Standards language to replace poles older than 60 years
is a"should" not "shall" statement. Additionally, to replace all poles older than 60 years, the WPM
program would require a significant budget increase to fund that additional scope of work.
Avista S-622
RevRM12- eR-005 Attachment A Page 2 of 55

It is important to note that other Avista projects also impact the rate of pole replacements and the age
distribution of poles in the system. Those projects are driven by other Avista departments including
Grid Hardening, Joint Use, Operation Engineers, Road Moves, WSDOT Control Zone Mitigation,
and minor rebuilds. These projects typically involve working in more populated areas due to growth
and fire mitigation strategies. Because of this, the rural portions of the system do not receive the
same proportion of funding to address older facilities.
Overall, the WPM pole inspection process contributes to the integrity and reliability of Avista's
overhead Distribution and Transmissions systems. Pole inspection data is sent to Avista's Editing
Department,who then populate AFM with all missing or miss-aligned facilities identified by the WPM
Pole Inspectors. Inspection data also aids in securing sufficient capital funding to perform all necessary
replacements required to maintain the system at a reliable level.
B. GENERAL
1. Personnel Requirements
a. Determination of remaining pole strength and serviceability is not an exact science.
There can be no substitute for the good judgment of an experienced field Pole Inspector.
All pole inspection Foreman shall be experienced Pole Inspectors, each having a
minimum of 3 years field experience testing poles. Each inspector shall possess and
provide documentation of sufficient training and knowledge to satisfactorily determine
the serviceability of a wood pole. The Foreman is responsible for drilling the pole.
b. Supervisors of pole inspecting personnel shall have a minimum of 3 years of inspection
experience that includes the species of wood poles used by Avista.The Supervisor shall
provide references and credentials upon request.
2. Maps
a. Avista provides e-maps to the Pole Inspector which includes an overview map and
individual detailed line maps. E-maps are useful for providing information such as
pole ownership, age, and height of the pole if the brand cannot be read. The Pole
Inspector shall document the pole number on the maps. Poles that are rejected shall be
circled in red. All good condition poles shall be circled in blue.
3. Guidelines for Inspection of Wood Poles
a. Poles installed or inspected within the last 10 years or less shall only have a 360-degree
visual inspection of the pole with at least .1 Ox binoculars. If any pole is visually rejected
it shall also be bored to help in the evaluation process. If the pole is less than 10 years
old the Pole Inspector can complete a sound and bore inspection on a case-by-case basis
if they feel it's necessary.
2
Avista 5-622 Page 3 of 55
ReviValp -f R-005 Attachment A

b. Poles older than 10 years, and not inspected within the last 10 years, shall be visually
inspected, sounded, and bored at ground line. Refer to Section C.5 At Ground Line
Inspections - Distribution Poles
c. Poles older than 10 years, and previously inspected more than 10 years ago, shall have
all visible plugs removed to complete the inspection process. Refer to Section C.5 At
Ground Line Inspections - Distribution Poles
d. Distribution Poles surrounded by pavement or concrete shall not be excavated. Record
as Reject any pole surrounded by pavement or concrete that shows any internal or
external decay during the At Ground Line (AGL) test.
e. Poles that are already trussed shall have three(3) 7/16"test holes drilled below the low
band (1 in each available quadrant) and 1 test hole at 56" next to the largest check to
determine remaining pole strength. The Inspector can use existing truss test holes if
available to meet these requirements.
f. The effective circumference is based on the measurement taken at the lowest truss
band. Proceed to Section D Evaluation.
g. Poles that have been reinforced as a barrier (truss is not driven into the ground) to
prevent animal damage shall be inspected as though not reinforced.
h. All poles on a feeder or line shall be inspected; this includes idle, marker ball, and
nesting platform poles. Do not inspect meter and customer owned poles unless the pole
has been vacated but Avista is still attached to the pole. Currently there are two (2)
foreign owned phone pole companies in Avista's territory: Lumen and Ziply. We are
also be attached to a few Kootenai, Inland, Modern, and PP&L owned poles.
I. Lumen owned poles shall only be visually inspected. Record if there is a
Lumen reject tag attached to the pole.
ii. Ziply owned poles shall be fully inspected. Refer to section C.5 At Ground
Line Inspections -Distribution Poles
iii. Kootenai, Inland, Modern, and PP&L poles shall be fully inspected. Refer
to section C.5 At Ground Line Inspections—Distribution Poles
Starting in 2017 the AMI Program will be installing some poles for its radio
transmitters in foreign utility areas,which means they are not associated with an Avista
owned feeder. There are approximately 70 poles that AMI installed in foreign owned
areas. These poles shall be fully inspected. Refer to section C.5 At Ground Line
Inspections -Distribution Poles
i. Poles shall be inspected from the substation out. When encountered take the buck as
the first priority. Inspect the lateral from the first pole off the buck to the end of the
lateral. Do not inspect the lateral backwards. This logic applies to all primary and
3
Avista S-622
RevNLg12AeR-005 Attachment A Page 4 of 55

secondary poles. Service poles and light poles shall be inspected immediately after the
pole they are served from is inspected.The only exceptions are locked gates that require
a scheduled time with the landowner to access the property. Drive out all underground
lines to identify pop up poles. For transmission poles start at the lowest mile number
and inspect towards the highest mile number. In addition,all taps off transmission lines
shall also be inspected.
j. Poles treated with fire retardant paint shall be carefully inspected to prevent tearing of
the coating. Avista started using fire mesh wrapping on high value poles in 2021. Do
not remove any wrapping during the pole inspection process. Refer to B.3 Guidelines
for Inspections of Wood Poles
k. Poles set in foam shall be sounded and bored only.
I. Historically, white-tagged poles indicated decay was found in the pole but was not
enough to reject it. This was based on the previous guidelines in effect at the time,
which have since changed to rejecting all distribution poles with decay. If white-tag
poles are encountered, inspect per B.3 Guidelines.for Inspections of Wood Poles
C. INSPECTION/REPORTING
Field Inspection data shall be collected on an Avista provided iPad device which utilizes Survey123
to document wood and metal pole inspections. The data is downloaded and stored in the WPM Access
Data Base, Excel, Designer, and AFM. Data is sent weekly to the pole inspection company for
invoicing.
1. If imminently dangerous structures or equipment are identified,they shall be promptly reported
to Avista's Wood Pole Management Department. This communication should occur the day
of discovery by either phone or email. Include a picture that shows the framing, any damage,
pole number, and location. Examples include, but are not limited to:
a. Poles with less than 3/4" remaining shell thickness in all four(4) quarters
b. Badly split cross arms, particularly cross-grain splits
c. Frayed or stranded conductor
d. Poles with supporting soil washed-out
e. Conductors not attached to the pole or the insulator
f. Poles tied up with ropes
2. Visual/Report Inspection—Above Ground Line
a. A 360-degree visual inspection with at least lOx binoculars of the entire above-ground
portion of the poles shall be conducted.
b. At a minimum, at least three (3) photos shall be included with the Inspection Report:
4
Avista S-622 Page 5 of 55
Revi?pJ1 'R-005 Attachment A

i. Pole framing, showing the terrain in the background
ii. All equipment& stencil numbers
ill. Pole #
iv. If applicable—any visible structural/equipment damage
c. Record the following types of structural/equipment damage in the Inspection Report:
1. Compression wood, ring shake, and excessive spur cuts.
2. Record the measurable strength loss for poles that have been damaged by fire,
insects, animals, woodpeckers, lightning, vehicles, and/or weed eaters.
3. Poles or cross arms that are excessively checked, cracked, split, have excessive
shell rot, or have mushrooms.
4. Spar pole cross arms on Transmission structures.
5. Poles that are leaning(note how many feet in or out of line).
6. Structures that have stolen or missing hardware.
7. Record all loose hardware by equipment type.
8. All foreign contacts such as fiber, cable television (CATV) or telephone (Tel).
9. Record raised ground lines (RGL), poles set shallow (PSS), idle poles, and last off
pole pulls (LOPP's). LOPP's are also referred to as double wood. Record the
number of feet the pole is set too deep or set too shallow.
10. Record previously butt-wrapped poles.
11. Record Reject/Non-Serviceable for any poles that are stubbed with wood so they
can be replaced.
12. Record when re-banding is required on existing steel trusses.
13. Record poles that have unauthorized attachments (UA's). Examples include but
are not limited to: TV dishes, bird houses, large signs, antennas, basketball hoops,
mailboxes, mirrors, etc. Remove UA's if they can be removed in under one minute
of time and are less than 8' from ground line. Legally dispose of UA's that do not
belong to the homeowner, if they have value to the homeowner place it at the base
of the pole. If a UA attachment is removed or left in place an Avista UA attachment
warning sign shall be installed on the pole.
14. Record the following cutouts: butyls with signs of chalking or tracking, Chance,
grasshoppers, QQ's, box, and load break with elephant ears.
15. Record equipment with missing cutouts.
16. Record defective lightning arrestors or terminators.
17. Record any active or inactive bird nests.
5
Avista S-622
Revi,MI2AeR-005 Attachment A Page 6 of 55

18. The pole tag should indicate the pole ownership correctly. Refer to section P
Guidelines for Determining Pole Ownership and Avista Standard DO 2.675
19. Record pole height, class, species, and age. If the brand cannot be read from the
pole, then record the information as designated on the e-maps.
20. Record the address or location of pole.
21. Record frayed or damaged conductor. This includes broken service neutrals.
22. Record any residential 3-wire service drops.This does not include pole to pole open
wire secondaries.
23. Record any leaking equipment.
24. Record any broken, loose, or missing down guys, guy tails extending outside the
guy make-up, broken guy insulators, guy insulators above open wire secondaries,
services attached to down guys, and bad order anchor rods.
25. Record poles where the original backfill has settled to the point that requires a line
crew to provide additional fill.
26. Record any visually obvious vertical or horizontal clearance issues.
27. When probing and measuring any pole holes use a shell indicator. Shell indicators
shall have the markings to determine shell thickness at either 30°, 45°, or 90'
angles. Record a nine (9) if no decay was detected, anything less is the remaining
shell thickness due to decay. Subtract an additional '/2 inch for larch or fir poles.
28. Record if a climbing inspection is requested on the upper portion of the pole and
include the reasons why.
29. Metal poles shall only be visually inspected. Install a Avista pole number with self-
tapping screws. See Avista Overhead Distribution Standards DO 2.650 &
Transmission Standards TR 662 1.1 IOD.
29. Record the Avista pole number and the foreign utility pole number.
30. Record any idle poles, anchors, or transformers.
31. Record if phone steps within 8 feet of ground line were removed. Do not plug these
holes, it does not prevent wood damaging insects from entering the pole. It may
also create new checking because the step hole is smaller than the large plug.
However, plugging drilled holes at Ground Line (GL) and Below Ground Line
(BGL) is critical to prevent water and soil from entering the highest decay zone.
32. Record poles that are in water.
33. Record poles where water has eroded the soil away from the pole.
34. Record poles that have an Avista pole number, but Avista is no longer attached to.
6
Avista S-622 Page 7 of 55
Rev&81 'R-005 Attachment A

35. Record the number of new guy markers the Inspector installed on Avista-owned
down guys. Guy markers shall be zipped tied to the guy makeup.
36. Record poles where vines are growing on them.
37. Record poles where services are attached to trees.
37. Record primary lines that cross over pools or buildings.
3. Soundinp,-Above Ground Line
a. Sound the pole in all four (4) quadrants around the pole from the GL to 8' ABGL to
determine if internal defects such as heart rot or enclosed pockets are present.
b. When sounding gives an audible indication of internal decay, locate where the minimum
shell thickness occurs by additional sounding to determine the best location to bore the
pole.
4. Boring- Above Ground Line
a. Boring to determine the extent of heart rot or enclosed pockets shall be made with a 7/16"
diameter bit. The holes shall be drilled in a horizontal plane to the center of the pole. The
thickness of the shell and depth of the enclosed pocket shall be measured through the bored
hole with a shell indicator. The shell indicator shall be long enough to probe the entire
length of the hole. Shell indicators shall have three (3) different measurement scales to
determine the extent of decay based on the angle the pole is drilled(either 30°,45°, or 90°).
In addition, the tip of shell indicator shall have squared edges (not rounded from use) to
aid in the proper identification of decay. Record the actual measured shell thickness. A
value of nine (9) indicates no decay, anything less indicates the remaining shell thickness.
Record which quarter of the pole was bored. After the inspection is complete,all inspection
holes shall be plugged. The diameter of the plastic plug shall be 1/16" larger than the
diameter of the hole. The plugs are supplied by Avista and are available in the Spokane
Warehouse.
5. At Ground Line Inspections - Distribution Poles
a. Poles installed or inspected within the last 10 years shall only be visually inspected. Refer
to section B.3.a. Guidelines for Inspection of Wood Poles.
b. Poles older than 10 years that have not been inspected in the last 10 years shall be drilled
at groundline with a 30" minimum 13/16"bit AGL next to the largest check.The hole shall
be drilled at a 30-degree angle that utilizes the full length of the bit without drilling through
the pole. Probe the hole wall with a shell indicator that is long enough to probe the entire
length to inspect for decay or voids. If the pole has decay proceed to Section D Evaluation.
If the pole does not have decay, then perform an 8" partial dig under the largest check.
Then, using a 7/16" bit, drill in a horizontal plane to the center of the pole below ground
line(BGL)on the other side of the check(still on the same side of the pole) from the 13/16"
Avista S-622
ReviV,012-1� R-005 Attachment A Page 8 of 55

hole. Any horizontal inspection holes should only extend to the center of the pole and
should not enter or cross any checks to minimize fungi opportunity. The hole-wall will be
probed with a shell indicator to inspect for decay or voids. If decay is found, proceed to
Section D Evaluation. Install a metal tag 1' ABGL to indicate the location of the below
ground 13/16" inspection hole.
At this point if the Inspector determines it is necessary, a 20" partial dig can be completed.
The 20" partial dig utilizes the full length of the 13/16" bit at a 30-degree angle without
drilling through the pole. The hole-wall will be probed with a shell indicator to inspect for
decay or voids. If decay is found, proceed to Section D Evaluation. When this process is
completed plug all holes and backftll per Section J Backfilling& Cleanup. Install a metal
tag 1' ABGL to indicate the location of the below ground 7/16" test hole. This will aid in
locating the hole in future inspections. Proceed to Section D Evaluation. Only bill for one
(1) dig unit.
c. Poles older than 10 years, and previously inspected more than 10 years ago, shall have all
visible plugs pulled. If the wood plugs cannot be removed, then use the 7/16" bit to drill
the plug out and inspect for decay. Note that plastic plugs have head designs which allow
them to be removed by screwing-out instead of drilling out. If the pole was treated with
MITC Fume the vials (glass or aluminum) shall be completely crushed. If the pole was
treated with Ultrafume pull the plugs and re-inspect the fume hole. Be aware that the pole
AGL and BGL may still contain Ultrafume and can be left as is. The hole-wall shall be
probed with a shell indicator to inspect for decay or voids.The shell indicator shall be long
enough to probe the entire length of the hole. Then using the 7/16" bit, drill the pole in a
horizontal plane to the center of the pole AGL next to the largest check and probe the hole-
wall for decay or. voids If the pole has decay plug the holes and proceed to Section D
Evaluation. If the pole does not have decay, then perform an 8" partial under the largest
check. Then, using a 7/16" bit, drill in a horizontal plane to the center of the pole BGL on
the other side of the check (on same side of pole) from the 13/16" hole. Any horizontal
inspection holes should only extend to the center of the pole and should not enter or cross
the check to minimize fungi opportunity. The hole-wall will be probed with a shell
indicator to inspect for decay or voids. If decay is found, proceed to Section D Evaluation.
Install a metal tag 1' ABGL to indicate the location of the below ground 13/16"inspection
hole.
At this point if the Inspector determines it is necessary, a 20" partial dig can be completed.
The 20" partial dig utilizes the full length of the 13/16" bit at a 30-degree angle without
drilling through the pole. The hole-wall will be probed with a shell indicator to inspect for
decay or voids. If decay is found, proceed to Section D Evaluation. When this process is
completed plug all holes and backfill per Section J Backfilling& Cleanup. Install a metal
tag l' ABGL to indicate the location of the below ground 7/16" test hole. This will aid in
s
Avista S-622 Page 9 of 55
Revile°fR-005 Attachment A

locating the hole in future inspections. Proceed to Section D Evaluation. Only bill for one
(1) dig unit
6. At Ground Line Inspections - Transmission Poles
a. Poles installed or inspected within the last 10 years shall only be visually inspected. Refer
to section B.3.a. Guidelines for Inspection of'Wood Poles.
b. Poles older than 10 years that have never been inspected shall be drilled with a 30"
minimum 13/16"bit AGL next to the largest check. The hole shall be drilled at a 30-degree
angle that utilizes the full length of the bit without drilling through the pole. The hole-wall
shall be probed with a shell indicator to inspect for decay or voids. The shell indicator shall
be long enough to probe the entire length of the hole.
If there is a 3"or less shell remaining proceed to Section D Evaluation. If the pole has more
than 3" shell remaining, then perform an 8" partial dig under the largest check. Using a
7/16" bit, drill in a horizontal plane to the center of the pole BGL on the other side of the
check (on the same side of pole) from the 13/16" hole. Any horizontal inspection holes
should only extend to the center of the pole and should not enter or cross any checks to
minimize fungi opportunity. If a 3" or less remaining shell is found 8" BGL then proceed
to Section D Evaluation. Install a metal tag U ABGL to indicate the location of the below
ground 13/16" inspection hole.
If there is more than 3" shell 8" BGL then complete a 20" partial dig. The 20" partial
inspection utilizes the full length of the 13/16" bit at a 30-degree angle without drilling
through the pole. The hole-wall will be probed with a shell indicator to inspect for decay
or voids. Proceed to Section D Evaluation. When this process is completed plug all holes
and backfill per Section J Cleanup & Backfill. Install a metal tag F ABGL to indicate the
location of the below ground 13/16" inspection hole. This will aid in locating the hole in
future inspections. Proceed to Section D Evaluation. Only bill for I dig unit.
c. Poles 10 years or older, and previously inspected more than 10 years ago, shall have all
visible plugs pulled. If the wood plugs cannot be removed, then use the 7/16" bit to drill
the plug out to inspect for decay. Note that plastic plugs have head designs which allow
them to be screwed out instead of drilled out. If the pole was treated with MITC (glass or
aluminum) the vials shall be completely crushed. The hole-wall will be probed with a shell
indicator to inspect for decay or voids. Then using a 7/16" bit drill the pole in a horizontal
place AGL next to the largest check and probe the hole-wall for decay or voids. If there is
a 3" or less shell remaining, proceed to Section D Evaluation.
9
Avista S-622
RevigM%eR-005 Attachment A Page 10 of 55

If there is 3" remaining shell or more, then perform an 8" partial dig under the largest
check. If possible, remove the old plug and probe for decay or if the old plug can't be
removed then use a 7/16" bit to drill in a horizontal plane to the center of the pole BGL on
the other side of the check(on same side of pole) from the 13/16"hole. Any horizontal test
holes should only extend to the center of the pole and should not enter or cross the check
to minimize fungi opportunity. The hole-wall will be probed with a shell indicator to
inspect for decay or voids. If there is 3" or less remaining shell, then proceed to Section D
Evaluation. Install a metal tag 1' ABGL to indicate the location of the below ground 13/16"
inspection hole.
If there is more than a 3" shell remaining, then then complete a 20" partial. The Inspector
can either remove the old plug or use the full length of the 13/16" bit at a 30-degree angle
without drilling through the pole. Probe the hole-wall for decay or voids. Proceed to
Section D Evaluation. When this process is completed plug the holes and backfill per
Section J Backfull & Cleanup. Install a metal tag I' ABGL to indicate the location of the
below ground 7/16"inspection hole. This will aid in locating the hole in future inspections.
Only bill for 1 dig unit. Proceed to Section D Evaluation.
D. EVALUATION
1. All poles shall be evaluated after inspection using the methods described below. All
information obtained during the inspection and evaluation process shall be recorded and
provided to Avista. Poles will be evaluated as either Acceptable, Rejected/Serviceable, or
Rejected/Non-Serviceable. All holes that have been drilled shall be plugged. Drilling through
a check without decay shall not be documented as decay.
2. Acceptable Poles:
a. Distribution: Any pole with no internal decay, no BGL shell rot, and satisfactorily
passes all visual inspections.
b. Transmission: Any pole with a 3" or less remaining shell thickness, no BGL shell
rot, and satisfactorily passes all visual inspections.
3. Rejected/Serviceable Poles: A Rejected/Serviceable pole is a pole that meets the
Acceptable Poles requirements below(sections 2a. Distribution, or 2b. Transmission) and
can be reinforced with a steel truss to bring the pole strength back to a serviceable level.
Poles can be trussed only when there is sufficient shell thickness remaining in the low and
high band locations. Sufficient shell thickness values are listed below. Before designating a
pole for trussing, the Inspector shall confirm the pole exceeds these values. All such poles
shall be tagged with a yellow 4"x6"plastic tag and yellow flagging around the circumference
of the pole. Do not attach reject tags to poles with greater than 67% remaining pole strength.
io
Avista S-622 Page 11 of 55
Revi.M1226 'R-005 Attachment A

a. Distribution: Poles can be reinforced with a steel truss if they meet both requirements
below:
1. Pole has at least 5" of remaining shell in each quadrant 56" ABGL, and
2. Pole has at least a 2" shell of remaining shell in each quadrant at either 6",
12", or 18"ABGL.
If there is less than 2" of shell at 6", 12" and 18" ABGL, the pole shall be
documented as a Reject/Non-Serviceable for replacement. Poles that meet this
requirement shall be tagged with a red 4"x6" plastic tag and yellow ribbon
installed around the pole.
The Inspector shall also document if the truss low bands need to be placed at 12"
or 18" in the inspection Report. All testing shall utilize a 7/16" drill bit. Record
the remaining pole strength % as determined by the Table 2 Nomograph.
b. Transmission: Reject any pole with a 3" or less remaining shell thickness. Poles can
be designated as Reject/Non-Serviceable and reinforced with a steel truss if they
meet both requirements below:
1. Pole has at least 5" of remaining shell in each quadrant at 56" ABGL, and
2. Pole has at least a 3" of remaining shell in each quadrant at either 6", 12", or
18" ABGL.
If there is less than 3" of shell at 6", 12" and 18" ABGL, the pole shall be
documented as a Reject/Non-Serviceable for replacement. Poles that meet this
requirement shall be tagged with a red 4"x6" plastic tag and yellow ribbon
installed around the pole.
The Inspector shall document if the truss low bands need to be placed at 12" or
18" in the inspection Report. All testing shall utilize a 7/16" drill bit. Record the
remaining pole strength % as determined by the Table 2 Nomograph.
4. Rejected/Non-Serviceable Poles: Any of the following poles cannot be brought to a
serviceable level through trussing and shall be replaced. Record the remaining pole strength
% as determined by the Table 2 Nomograph. Tag with a 4" X 6" red plastic tag and yellow
flagging around the circumference of the pole:
a. Distribution
i. Pole has <5" of remaining shell in each quadrant 56" ABGL, and
ii. Pole has <2" shell of sound wood in each quadrant at 6", 12", and 18"
ABGL
b. Transmission: Reject any pole with a 3" or less remaining shell thickness and these
criteria:
II
Avista S-622
Revise,4l2eR-005 Attachment A Page 12 of 55

I. <5" of remaining shell in each quadrant at 56" ABGL, and
ii. <3" of remaining shell in each quadrant 6", 12" and 18" ABGL
c. Any of the following types of support/trusses (considered inadequate and unsafe
for climbing purposes per Avista's Incident Prevention Manual):
i. All wood stubbed poles. Sound and bore the wood stub to determine
remaining pole strength.
ii. Poles set in a Rutherford cement support.
E. DETERMINING POLE STRENGTH
1. Poles may contain one of the following types of defects that reduces the poles' effective
circumference. These types of decay include Heart Rot and/or Decay Pockets. The Inspector
determines the weakest point in the pole and evaluates it to determine its serviceability. If
more than one type of decay is present in the same plane, the combined strength loss shall be
evaluated. Reduced pole strength can be determined by evaluating the defects as described
below.
a. Heart Rot: Poles with a sound shell but severely decayed or void centers. Heart Rot
is usually found at GL to 8" BGL and is most often nearly symmetrical in shape. Use
a shell indicator in the quarter drilled to determine the effective shell thickness. If the
pole is either a Larch or Fir deduct an additional % inch from the effective shell
thickness. This method of determining shell thickness applies to AGL and BGL. The
remaining strength of the inspected poles can be determined by using the pole strength
Nomo graph in Table 2. After determining the effective shell thickness, measure the
pole circumference at that cross section. Draw a straight line between these two points
on the Nomo Graph and read the percentage of strength remaining from the center
scale. Record this as the percentage of strength remaining.
I. Distribution Poles: Poles with any internal decay shall be rejected and designated
as either Reject/Serviceable(truss)or Reject/Non-Serviceable(replace).Evaluate
per Section D—Evaluation.
2. Transmission Poles: Reject all poles that have a 3" or less remaining shell
thickness. Evaluate per Section D Evaluation and Designate as either
Reject/Serviceable (truss) or Reject/Non-Serviceable (replace).
b. Decay Pockets: Decay pockets are small external (Exposed) or internal (Enclosed)
voids with various shapes usually found BGL. The strength of poles containing
Enclosed or Exposed decay pockets can be determined using Tables 1, 3, and 4:
1. Measure the Original Circumference of the pole at the location of the pocket.
2. Measure the pocket:
12
Avisca 5-622 Page 13 of 55
Revi�&t%eR-005 Attachment A

a. For Enclosed pockets, determine the remaining shell thickness and
width diameter of the pocket.
b. For Exposed pockets, determine the width and depth of the pocket.
3. Determine the deduction value:
a. For Enclosed pockets, use Table 3.
b. For Exposed pockets, use Table 4
4. Calculate the Effective Circumference. The Effective Circumference =
(Original Circumference—Deduction Value)
5. Determine the Reject Circumference. Use the Original Circumference and
Table 1.
6. Compare the Reject Circumference, Effective Circumference, and Original
Circumference.
a. If the Effective Circumference is less than the Reject
Circumference, Reject the pole.
b. Exposed decay pockets larger than the values listed in Table 4 shall
be treated as reduced circumference poles. Evaluate these poles per
requirements in section E.6.c Reduced Circumference
c. If the effective circumference at any point in the section of the pole
from 18" AGL to the top is less than the Rejected Circumference in
Table 1, the pole shall be documented as a Reject Non-Serviceable.
c. Reduced Circumference: Poles with sound heart wood, but reduced surface wood
due to weathering or shell rot. Follow the steps below to determine if the pole shall be
rejected due to Reduced Circumference:
i. Measure the original circumference of the pole AGL.
ii. Remove any exterior decay present from the pole surface below ground line
and re-measure the circumference in the area where the most decayed wood
was removed.
iii. Using Table 1, determine the "Reject Circumference" Value based on the
measured Original Circumference.
13
Avista 5-622
Revi,M%eR-005 Attachment A Page 14 of 55

iv. Compare the values: if the re-measured circumference is less than the
"Reject Circumference", Reject the pole.
v. Document the re-measured circumference as the Effective Groundline
circumference.
F. ANCHOR ROD INSPECTION
1. In the Kellogg Superfund area, or when requested, a 20" partial anchor rod dig inspection
shall be conducted to inspect for any degradation of the rod caused by pitting or penciling.
When complete, backfill the hole and document the results. When working in the Kellogg area
a Superfund training class is required prior to any excavation work.
G. POLE CLASSING
1. Gathering pole class information is an integral part of the pole inspection process. The
information is necessary in the design phase of any feeder capitol project. This information is
gathered by the Pole Inspector in one of two ways. The first is to simply read the class from
the existing identifiable branding that is either a wood brand or an aluminum data disc.
Sometimes a light dusting with white marking paint on wood brands helps with visual
interpretation. The brand is usually located 5' AGL but may vary depending on the depth of
the pole set or if ground disturbance has occurred. When the existing branding is not
identifiable on Western Red Ceder or Western Larch, the Inspector can estimate the pole class
using the height and circumference then comparing it to the Tables listed in Avista Utilities
Electric Distribution Overhead Construction Standards DO 2.615
H. SPECIES IDENTIFICATION
1. Identification of pole species (Cedar vs. Larch) can sometimes be visually difficult if the
brand is not identifiable. If the Inspector is uncertain the easiest way to tell is by pounding a
nail into the pole: If the nail goes in easy it is a Cedar, if it goes in hard it is a Larch. Other
things to look for are a spiral twisted grain which is semi-common in Larch. Another
characteristic of Larch is they tend to be smaller in circumference for the same class of pole as
a Cedar. In rare occasions the Inspector may encounter Douglas Fir poles (primary or
secondary construction)which may indicate they are owned by the phone company (Lumen or
Ziply). See Section O: Guidelines for Inspecting Foreign-Owned Poles
I. RAISED GROUND LINES
1. Raised Ground Line (RGL): A condition where the soil line is above the treated portion of
the pole.This condition often accelerates BGL decay advancement due to soil and moisture
contact with untreated wood. These are often found where a grade change has occurred on
roadway/railroad ROW's, and landscaping upgrades.
2. Background: Before 2013 Avista's poles were incised and treated 1' above the ANSI
determined ground line. After 2013, poles were incised and treated 3' above the ANSI
14
Avista S-622 Page 15 of 55
Revi M19M_¢'R-005 Attachment A

determined ground line. This added treatment allows for the pole to be set deeper for slack
spans. In general, the pole is not a RGL if the Inspector can visually see incising on the
pole.
a. If it is determined to be a RGL, there are times it can be remedied by reasonably
removing the soil at least 6" below the top treatment line. This remedy should be
avoided if it creates a sink hole around the pole or requires more than 6"of vertical
digging. If during this process the pole is determined to be severely rotten then the
Inspector shall stop digging and report the pole immediately to the WPM PM.
b. All other RGL poles shall be rejected and inspected for trussing.
c. Poles that have been previously butt wrapped shall be considered RGL if the soil is
above the incised area.
J. BACKFILL AND CLEANUP
1. Backfill
a. The excavated hole shall be generously backfilled and tamped to preclude the
possibility of subsequent settling which would create a depressed area around the pole.
Backfill shall extend 6" ABGL then tamped and shaped to promote water runoff.
Backfill shall not extend above any treated portion of the pole.
2. Cleanup
a. The area surrounding the inspected pole shall be left in a neat,tidy condition. All debris
and garbage shall be removed. For poles located in communities or on private property
all loose rocks and dirt debris from the excavation shall be removed from lawns,
sidewalks, and pavement. Turf,bushes, and plants on private property shall be carefully
replaced if they were temporarily removed during the inspection process.
K. MARKING
1. Pole number tags: Attach pole number tags to the pole where they will be readily visible
from the most practical (usually the nearest road) viewing location. If the existing pole
number tag doesn't face the nearest access, it shall be reattached to meet this standard. It
shall be attached approximately 6' ABGL.
All poles inspected shall be tagged with an Avista supplied pole number if one does not
exist. Existing numbers and tags shall be retightened. Metal poles shall have the pole
number installed by drilling and attaching with self-tapping screws.
Wood Transmission poles also need a yellow mile marker number attached in line at the
beginning of every mile on each side of the pole. Wood transmission poles also require an
aluminum mile structure number to be attached. If there is an existing aluminum mile
structure number but it doesn't face the nearest access install a new number. It is ok to
leave the old number on the pole.
15
Avista S-622
RevDg12 ?R-005 Attachment A Page 16 of 55

2. Down Guys: All Avista-owned down guys that are missing guy markers shall have one
installed. Do not install guy markers on foreign-owned guys; it is their responsibility to
ensure they are attached. Each separate guy is required to have a guy marker even if
multiple guys go to the same anchor. Guy markers shall be zip tied to the anchor head or
guy makeup.
3. Pole Inspection Tags: All poles that are inspected shall be marked with an aluminum tag
that shows the year inspected and the inspecting company name. Inspection tags shall be
installed directly below the pole number. A minimum of a 1 %2 inch galvanized roofing nail
shall be used (do not use aluminum nails) for wood poles. Use a drill and self-tapping
screws for metal poles. Do not cover the pole brand with any tags.
4. Inspected Poles That Are Dug: A tag will be applied directly above the BGL fume or test-
hole at 12" ABGL so it can be found during future inspections.
L. WOODPECKER HOLES (WPH)
1. Pole Inspector Evaluation Guidelines:
The following chart shall be used to describe the WPH condition identified during the pole
inspection process.
Woodpecker Holes
# Of Recommendation
Holes Location Definition
I No further inspection needed
2 Needs closer inspection
3 Previously repaired or screened
2. Calculating remaining strength from WPH damage:
To determine if the pole is a reject due to WPH damage, follow the guidelines in E.l.b:
Decay Pockets to determine if the pole does not meet the minimum allowable effective
circumference.
M. GUIDELINES FOR EXCAVATING POLES WITH RISERS
When excavating poles with an underground riser, the Inspector shall use extra precaution to
prevent damage to underground facilities and more importantly injury to oneself. Underground
risers may have communication, secondary and/or primary cables. For poles that require
excavation, Inspectors shall excavate on the opposite side of the pole from the riser in order to
minimize potential contact with a known underground facility. At any point while excavating
riser poles, the Inspector has the authority to stop, backfill, and continue with a sound and bore
inspection only. In these circumstances, document why the pole was deemed unsafe to
16
Avista S-622 Page 17 of 55
Revic12�R-005 Attachment A

excavate. These guidelines are not intended to supplant any safety precautions provided by the
Inspector's employer, but to help provide options so the pole can be safely inspected. Poles
with risers shall not be dug if the Inspector is working alone.
N. GUIDELINES FOR INSPECTION GRID MODERNIZATION PROGRAM POLES
Larch poles older than 40 years, and cedar poles older than 60 years shall only be visually
inspected, numbered, and GPS'd. Install a visual inspection tag on the pole. There is no need
to sound and bore these poles because they are automatically designated for replacement as
part of the Grid Modernization Program (GMP). Do not install a red reject tag or make any
comments in the notes about being a Reject. Do not select "Replace Pole" under the "Stub
Code" field in Survey 123. This program has been put on hold until further notice.
O. GUIDELINES FOR INSPECTING FOREIGN-OWNED POLES
Lumen and Ziply are the two (2) Foreign-Owned pole companies in Avista's service territory.
Avista has pre-inventoried most of the distribution poles in the system to determine ownership
and"F"tagged the phone-owned poles. Check with Avista's Joint Use Department to confirm
the data for accuracy. Regardless of ownership, if Avista is attached to the pole it shall be
inspected. Follow the guidelines below:
1. Lumen: Lumen is the main communication company in Avista's service territory. When
Inspectors encounter"F" tagged or Lumen-owned poles in the field, they shall be only be
visually inspected. Document the year Lumen inspected the pole and the condition of the
pole based on their tagging. If the pole was inspected by Lumen but Avista is the owner,
then re-inspect the pole as if it was previously inspected. Refer to section C.5 At Ground
Line Inspections - Distribution Poles. If Lumen drilled new fume holes, then pull the
original Avista inspection plugs only.
2. Ziply: Inspectors shall complete a full inspection on Ziply-owned poles. Refer to section
C.5 At Ground Line Inspections - Distribution Poles.
P. GUIDELINES FOR DETERMINING POLE OWNERSHIP
Inspectors shall determine pole ownership from Avista's a-maps, which are updated and
maintained by the Joint Use Department. Never rely on AFM to determine pole ownership
unless the pole has been numbered with a"F" (foreign-owned pole) or "X" (customer-owned
pole)tag. See Avista's Electric Distribution Overhead Construction Standards DO-2.675: Pole
Marking Tags. On the e-maps, if a pole has an "X" inside the circle that is a good indication it
might be foreign owned.
1. Lumen: one indication of a Lumen-owned pole is an old permit code number in Lumen
owned areas as indicated on the e-rnaps. There is a"W" in front of the number, but its logic
was never documented. The numbers are as follows:
17
Avista S-622
Revis412WR-005 Attachment A Page 18 of 55

0-6,000: Lumen on Avista-owned poles
• 6,001 - 20,000: Avista on Lumen-owned poles
• >20,001: Lumen on Avista-owned poles
If the pole meets the 6,001 — 20,000 criteria above, it is safe to assume the pole is owned
by Lumen unless the following conditions apply:
a. If an existing Lumen-owned pole (as determined by the e-maps) was replaced or
trussed by Avista before 2014, then Avista is the owner. Note that Lumen trusses
poles with a C-2 guardrail style truss with an angular cap at the top. The truss is
also treated with a brown rust inhibiting paint as well.
b. If Lumen vacated the pole, then Avista took over ownership at that time.
c. If Avista vacates a pole with a Joint User still attached, then Avista is no longer
the owner of the pole.
2. Ziply- In Ziply's service territory any phone tag that is yellow indicates Avista owns the
pole. If there is an orange phone tag that indicates Ziply is the owner of the pole.
3. Other: Another good indicator that the pole is foreign-owned is if the pole is a fully treated
Douglas Fir. Typically, phone companies prefer fully treated poles, while Avista prefers
butt-treated poles. However, Avista does own a few fully treated poles as well. In 1996
Avista bought the Sandpoint Service Territory from Pacific Power and Light (PP&L).
Although the modem 6-digit white Avista pole tags are used in that office area now,PP&L
pole numbers are still attached to older poles. Knowing the last two numbers of the PP&L
pole number can be used in determining pole ownership: poles with the last two digits
between 40 and 59 are phone owned.
PPL 2S- 18
s6oi_
T9 �ou2 hlu nBERS TowNaN/O 6fAm KE zGGs�
ZI AN6G (E*•+^'Plc �O
'era X, L
I t i
ro
r + ,
9
Laer Two DGra oR�tSA�un.�Ji �EYAmPL�O\�
Oo-rif..39 — r'.,��.a�� 0— Ace
Jn rw,. 59 — rGra w� ow�Go
-Mu ..`7 -�•I��c.r.e TAr.un,as.W P�e
7n fg,u 79 — ..+•ar•+mcR Ow�Fo�`�
80 t7ku 39 — :I•rOa4 G4au}I-•b.ua�t•++tR] f =aa
40 ?'Aeu 99 — SF�ne r`l,w.,6ePs
18
Avista S-622 Page 19 of 55
ReviV42*f R-005 Attachment A

4. Examples of Lumen Tagging:
a. Lumen Reject Tag—B Tag: This tag is an example of a B type"do not climb"reject
tag. It is red with an arrow with an X and is placed on the pole pointing in the
direction of the defect or decay. B type reject tags are placed on poles that do not
require immediate replacement but cannot be climbed until made safe. The arrow
is pointed up or down depending on defect location.
b. Lumen Reject Tag — C Tag: This tag is an example of a C type "do not climb"
priority pole tag. It is red with an "X" in a circle, superimposed over an arrow. The
arrow points in the direction of the decay or defect. C type reject tags are placed on
poles that require immediate replacement due to dangerous or unsafe conditions.
The arrow is pointed up or down depending on defect location.
c. Lumen Number Tag Example
all
Al 193235
� iIIIIlIIIIIIf')
This pole has both an Avista tag, Lumen Pole Inventory tag, and the Pole Inspection tag. Even though Lumen
has their tag on the pole, it is most likely an Avista-owned pole. Confirm ownership with Avista's Joint Use
Department.
19
Avista S-622
Revi�4I2-IK7!FR-005 Attachment A Page 20 of 55

5. Ziply Tagging Examples:
iiVIST4 �
•I II 1
j ZIPLY
1 815193 V Z
596980
Note that Ziply bought out Verizon and Frontier. Their old tags may still be on Ziply poles.
Q. GUIDELINES FOR THE INSPECTION OF METAL POLES
1. The inspection of metal poles entails most of the same inspection logic as wood poles.
Inspectors will encounter the same types of conductors, equipment, and hardware attached to
both wood and metal poles. The main exception is that Avista inspects for corrosion on metal
poles versus decay on wood poles. Inspectors shall use the Steel Pole Inspection Checklist in
Survey 123 to evaluate metal poles.
2. Visual/Report Inspection—Above Ground Line: A 360-degree visual inspection with at least
lOx binoculars of the entire above ground portion of the poles shall be conducted_ Inspectors
shall take enough pictures in the Survey123 Inspection Report to capture the following:
a. Show the structures framing in-line.
b. Show the structures framing from the side.
c. Show where equipment and hardware are attached.
d. Show the structures pole number tag.
e. Show the groundline area along with the background terrain.
f. Show the extent of corrosion or damage (if applicable).
3. Survey 123 guides the Inspector through inspection items to document. The visual
information gathered will help determine which poles require a more intensive inspection.
Additional metal pole inspection items to document, but not limited to:
a. Broken welds
b. Corrosion condition-note that any corrosion is at least a low priority
c. Anchor bolt corrosion
d. Coating condition
e. Compaction settlement
f. Exposed rebar
20
Avista S-622 Page 21 of 55
Revi &I?WR-005 Attachment A

g. Foundation type
h. Grounding wire missing or broken
i. Mastic joint separation
j. Physical hole or dent damage
k. Standing water
1. Vegetation present around the pole
4. Excavation: Poles do not require digging unless it's to correct a RGL condition, or when the
coating is damaged more than two hands at GL. If either of these conditions are encountered,
the Inspector shall perform a partial dig below the defect to inspect for corrosion.
6. Measurements: The following measurements shall only be taken if directed by the WPM
PM:
a. Coating Thickness and Metal Thickness: Use an Ultrasonic thickness (UT)
measurement device. if galvanizing thickness is requested, use a magnetic dry film
thickness device.
b. Soil Resistivity: Use a digital soil resistivity probe at 1', 2', and 3' depths around
the structure. Inspectors should be aware that the lower the resistivity the more
easily current flows, meaning an increased potential for corrosive activity.
c. Soil PH: Use a digital PH probe near the structure after removing the top few inches
of soil. Soils with very low PH are more acidic which creates an environment where
corrosion is more likely.
d. Redox Measurement: Measure the dissolved oxygen content of the soil 3' away
from the structure. This measurement can help indicate the presence of microbial
bacteria and areas with potential Microbial Induced Corrosion.
e. Half Cell Potential Measurement (VDC): Use a digital potential meter to measure
the soil 2' away from the structure.
7. Avista's Engineering Department has additional information regarding the inspection of
Metal poles, found on their SharePoint here
2�
Avista S-622
ReviVL4I2beR-005 Attachment A Page 22 of 55

WOOD POLE STEEL POLE
e
� 1
1 — 4 r
LINE OF TRAVEL(AHEAD SPAN) LINE OF TRAVEL(AHEAD SPAN)
THE GRAPH ABOVE INDICATES THE 4 THE GRAPH ABOVE INDICATES THE 4
QUARTERS OF A WOOD POLE AFTER A QUARTERS OF A STEEL POLE.AND 3 FLATS(A.
WOOD POLE IS INSPECTED.INDICATE WHICH B.&C)IN EACH QUARTER, AFTER A STEEL
QUARTER WAS DRILLED AND THE AMOUNT OF POLE IS INSPECTED.OBTAIN STEEL AND
DECAY PRESENT. A"9"INDICATES NO DECAY COATING THICKNESS AND DOCUMENT THOSE
AND ANYTHING LESS IS THE ACTUAL INCHES MEASUREMENTS. IF FAMAGE IS OBSERVED,
OF REMAINING GOOD WOOD, RECORD THE QUARTER,FLAT AND TYPE OF
DAMAGE THAT OCCURRED IN THE NOTES
PORTION OF THE INSPECTION SHEET.
LATTICE TOWER
2 a
1 INSPECTION ORIENTATION SPECIFICATION
LINE OF TRAVEL(AHEAD SPAN) FOR WOOD AND STEEL POLES
AVISTA CORP
SPOKANE,WA
NTH 2/21/2',017 APPFC'dcC
a cnc `-� --— ^-A—
N t. J — 7�7 3- F T 1
22
Avista S-622 Page 23 of 55
RevivaTu" -005 Attachment A

1 f
4
2
Avista Phone Other
NOTES:
N1 Serialized number marking tags will be used on all poles with Avista Electric facilities
attached to uniquely identify each pale, its associated equipment and owner of record
N2. It is imperative that all Avista Owned and Phone Owned pole numbers be recorded and
entered into the Avista AFM system. Other owned poles such as customer owned
primary meter poles and other utility poles with Avista attachments should be recorded
N3 Only one number marking tag per pole is allowed.
N4 These marking tags shall be attached vertically to the body of the pole approximately 6'
above grade The tag should face the street if possible
N5 The Phone and Other pole marking tags can be obtained from the Avista Joint Use
Administrator
Avista Owned Poles Phone Owned Poles Other Owned Poles
All Primary Lumen Customer
All Secondary/Service Other Utilities
Wood. Steel, Composite ZtPly Subscribers-
Communications
UTA CODE
OR ITEM# DESCRIPTION QTY U/I STOCK NO
SIGN, AVISTA POLE NUMBER MARKING 1 EA 662-3100
SIGN PHONE POLE NUMBER MARKING 1 EA 662-3102
SIGN_ OTHER POLE NUMBER MARKING 1 EA 662.3104
DISTRIBUTION STANDARDS DATE 03-02-16
Pole Marking Tags PAGE 1 of 1
Diu IV/STA SPEC DO-2 675
23
Avista S-622
RevigM1,9*?R-005 Attachment A Page 24 of 55

TABLE I - MINIMUM CIRCUMFERENCE TABLE
Minimum allowable effective pole circumference after deductions have been made for shell rot, enclosed
pockets and exposed pockets (see Table 3 and 4 for deductions). Where defects occur in the same horizontal
plane, the deductions are accumulative.
Original Circumference Reject Circumference Original Circumference Reject Circumference
25.00 22.00 47.00 41.50
25.50 22.25 48.50 42.00
26.00 22.50 49.00 42.50
26.50 23.00 49.50 42.75
27.00 23.50 47.50 43.25
27.50 24.00 50.00 43.50
28.00 24.25 50.50 44.00
28.50 24.75 51.00 44.50
29.00 25.50 51.50 45.00
29.50 25.75 52.00 45.25
30.00 26.00 52.50 45.75
30.50 26.75 53.00 46.25
31.00 27.00 53.50 46.75
31.50 27.50 54.00 47.50
32.00 28.00 54.50 47.75
32.50 28.25 55.00 48.00
33.00 28.75 55.50 48.50
33.50 29.25 56.00 49.00
34.00 29.50 56.50 49.50
34.50 30.00 57.00 49.75
35.00 30.50 57.50 50.00
35.50 31.00 58.00 50.75
36.00 31_50 58.50 51.00
36.50 31.75 59.00 51.50
37.00 32.25 59.50 52.00
37.50 32.75 60.00 52.50
38.00 33.00 60.50 53.00
38.50 33.50 61.00 53.25
39.00 34.00 61.50 53.75
39.50 34.50 62.00 54.25
40.00 35.00 62.50 54.50
40.50 35.25 63.00 55.00
41.00 35.75 63.50 55.50
41.50 36.50 64.00 56.00
42.00 36.75 64.50 56.25
42.50 37.00 65.00 57.00
43.00 37.75 65.50 57.25
43.50 38.00 66.00 57.75
44.00 38.50 66.50 58.00
44.50 38.75 67.00 58.50
45.00 39.25 67.50 59.00
45.50 39.75 68.00 59.50
46.00 40.25 68.50 59.75
46.50 40.50 69.00 60.50
47.00 41.00 69.50 60.75
24
Avista S-622 Page 25 of 55
RevPLO* f -005 Attachment A

TABLE 2
T — -
I 3 3�—
I'J
3 � I
r
3 E
i
i 6
s.e
L a
2 Z r �-
H -I E_ r �^ '5-
r SC
w
a_,—
Pole with Heart Rot Example:A pole with a 45"circumference at GL is determined to have•Heart
Rot and a remaining shell thickness of 1.5". Drawing a line between these two values, the remaining
pole strength is approximately 6l%.
25
Avista S-622
RevM%eR-005 Attachment A Page 26 of 55

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I Peter J. Richardson ISB # 3195
515 N. 271h Street
2 Boise, Idaho 83702
3 [phone] DD
[phone] Cell
4 petersrichardsonadams.com
5
6 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
7
8 IN THE MATTER OF AVISTA Case No.: AVU-E-25-15
9 CORPORATION'S 2026 WILDFIRE
MITIGATION PLAN
10 POTLATCHDELTIC FOREST HOLDINGS,
LLC's COMMENTS URGING REJECTION
11 OF AVISTA'S WILDFIRE MITIGATION
12 PLAN
13
14
15 POTLATCHDELTIC
16 EXHIBIT NO. 3
17 Avista Response to PotlatchDeltic Production Request No. 8,
18
19
20
21
22
23
24
25
26
POTLATCHDELTIC FOREST HOLDINGS,LLC'S COMMENTS URGING REJECTION OF AVISTA'S
27 WILDFIRE MITIGATION PLAN
AVU-E-25-15
28
EXHIBIT NO. 3.

AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION: IDAHO DATE PREPARED: 02/10/2026
CASE NO: AVU-E-25-15 WITNESS: N/A
REQUESTER: Potlatch RESPONDER: Rohan Theobald
TYPE: Production Request DEPARTMENT: Distribution
Vegetation
Management
REQUEST NO.: Potlatch-008 TELEPHONE: [phone]
REQUEST:
Please explain and quantify the difference between Avista's vegetation management efforts and
frequency cycles between its most recent wildfire mitigation plan and its proposed 2026 wildfire
mitigation plan.
RESPONSE:
Distribution Vegetation Management has not changed inspection frequency cycles since our
2024 Wildfire Resiliency Plan and Report.
In 2024, we pruned trees that had encroached to within six inches of conductors under the risk
tree scope of work. In 2025, we expanded that clearance threshold to a minimum of one foot.
Trees are pruned so that they will not encroach within five feet of conductors for a five-year
period.

I Peter J. Richardson ISB # 3195
515 N. 27th Street
2 Boise, Idaho 83702
3 [phone] DD
[phone] Cell
4 peternrichardsonadams.com
5
6 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
7
8 IN THE MATTER OF AVISTA Case No.: AVU-E-25-15
9 CORPORATION'S 2026 WILDFIRE
MITIGATION PLAN
10 POTLATCHDELTIC FOREST HOLDINGS,
LLC's COMMENTS URGING REJECTION
11 OF AVISTA'S WILDFIRE MITIGATION
12 PLAN
13
14
15 POTLATCHDELTIC
16 EXHIBIT NO. 4
17 Avista Response to PotlatchDeltic Production Request No. 7.
18
19
20
21
22
23
24
25
26
POTLATCHDELTIC FOREST HOLDINGS,LLC'S COMMENTS URGING REJECTION OF AVISTA'S
27 WILDFIRE MITIGATION PLAN
AVU-E-25-15
28
EXHIBIT NO.4.

AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION: IDAHO DATE PREPARED: 02/10/2026
CASE NO: AVU-E-25-15 WITNESS: N/A
REQUESTER: Potlatch RESPONDER: Matt Ugaldea
TYPE: Production Request DEPARTMENT: Wildfire Resiliency
REQUEST NO.: Potlatch-007 TELEPHONE: [phone]
REQUEST:
Please provide a map showing all areas identified by Avista that exhibit high fuel levels that are
also not included as either a tier 1 or 2 or 3 Risk Level.
RESPONSE:
Avista does not currently have a map that includes "high fuel levels" outside of the predetermined
Wildland Urban Interface(WUI)Risk Tiers, as that information is used to help determine the WUI
Risk Tiers.

I Peter J. Richardson ISB # 3195
515 N. 271h Street
2 Boise, Idaho 83702
3 [phone] DD
[phone] Cell
4 ,�eteriurichardsonadams.com
5
6 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
7
8 IN THE MATTER OF AVISTA Case No.: AVU-E-25-15
9 CORPORATION'S 2026 WILDFIRE
MITIGATION PLAN
10 POTLATCHDELTIC FOREST HOLDINGS,
11 LLC's COMMENTS URGING REJECTION
OF AVISTA'S WILDFIRE MITIGATION
12 PLAN
13
14
15 POTLATCHDELTIC
16 EXHIBIT NO. 5
17 Avista Response to PotlatchDeltic Production Request No. 22.
18
19
20
21
22
23
24
25
26
POTLATCHDELTIC FOREST HOLDINGS,LLC'S COMMENTS URGING REJECTION OF AVISTA'S
27 WILDFIRE MITIGATION PLAN
AVU-E-25-15
28
EXHIBIT NO. 5.

AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION: IDAHO DATE PREPARED: 02/10/2026
CASE NO: AVU-E-25-15 WITNESS: N/A
REQUESTER: Potlatch RESPONDER: Anni Glogovac
TYPE: Production Request DEPARTMENT: Legal Staff
REQUEST NO.: Potlatch-022 TELEPHONE: [phone]
REQUEST:
If areas of high fuel levels and low or negligible housing density do not rise to the level of even a
Tier 1 risk area and hence are in a low priority area for wildfire mitigation measures, please
explain why it is fair and just for the Commission to grant Avista entitlement to immunity from
liability for starting a wildfire in such areas
RESPONSE:
The liability protections afforded under Idaho law are not intended to give a blanket immunity to
utilities for starting wildfires but instead are intended to appropriately balance the costs of wildfire
mitigation activities with the risks to customers and communities. While Avista's Wildfire
Mitigation Plan (WMP)may provide greater focus in specific areas, Avista's plan does not ignore
lower Risk Tier areas where the impacts of wildfire may be less significant. Instead,the goal of
the WMP is to mitigate the risk of wildfire across our service territory, while also being cognizant
of the cost pressure that work necessarily places on customer bills.
If the Idaho Public Utilities Commission (IPUC) were to exclude lower Risk Tier areas from
Avista's WMP, and by extension from the protections afforded under Idaho law, the natural
response would be to spend more on wildfire mitigation in those areas, which would undermine
the balance between wildfire mitigation efforts and customer affordability that both Avista's WMP
and Idaho law are intended to protect.

I Peter J. Richardson ISB # 3195
515 N. 27th Street
2 Boise, Idaho 83702
3 [phone] DD
[phone] Cell
4 nztergrichardsonadams.com
5
6 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
7
8 IN THE MATTER OF AVISTA Case No.: AVU-E-25-15
9 CORPORATION'S 2026 WILDFIRE
MITIGATION PLAN
10 POTLATCHDELTIC FOREST HOLDINGS,
11 LLC's COMMENTS URGING REJECTION
OF AVISTA'S WILDFIRE MITIGATION
12 PLAN
13
14
15 POTLATCHDELTIC
16 EXHIBIT NO. 6
17 Avista Response to PotlatchDeltic Production Request No. 4.
18
19
20
21
22
23
24
25
26
POTLATCHDELTIC FOREST HOLDINGS,LLC'S COMMENTS URGING REJECTION OF AVISTA'S
27 WILDFIRE MITIGATION PLAN
AVU-E-25-15
28
EXHIBIT NO. 6.

AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION: IDAHO DATE PREPARED: 02/10/2026
CASE NO: AVU-E-25-15 WITNESS: N/A
REQUESTER: Potlatch RESPONDER: James Edwards/Shane
Pacim
TYPE: Production Request DEPARTMENT: Operations Project
Mgmt./ Electric
Distribution Design
REQUEST NO.: Potlatch-004 TELEPHONE: [phone]
REQUEST:
Page 19 of the WMP identifies six of Avista's "wildfire mitigation hardening strategies ... "
which are listed below. Please respond to the question in each subsection.
4-A "Rebuilding lines with hardened designs" Please describe the "hardened designs" that are
referenced and explain whether,and in what way(s), the hardened designs differ from the other
listed "hardening strategies" that are also identified and described in the same paragraph.
Please identify the lines that have been 'hardened' in the 2025 WMP year(2025) and identify the
number of miles, location and relationship to Risk Level for the types of lines that are
encompassed in the description of"hardened designs." Please provide the same information for
lines that are planned to be hardened pursuant to the current WMP (2026).
4-13" Using steel poles on transmission projects and high value distribution pole replacements";
Please separately identify the dates, location, number, and linear miles; of distribution and
transmission poles/line that have been replaced with steel poles in the most recent WMP year
(2025). Please describe what is meant by a"high value distribution pole" and how it relates to
wildfire ignitions. Please identify the Risk Level of the steel pole replacement locations. Please
provide the same information for planned replacements in this WMP year(2026).
4-C "Undergrounding select distribution segments"; Please also refer to page 22,which discusses
"Avista's Undergrounding Project. " That project's 11 miles of underground distribution feeder
"will allow us Avista] to evaluate the feasibility of undergrounding as a wildfire mitigation tool."
Please reconcile the apparent discrepancy between the description on p. 19 that undergrounding is
an included wildfire mitigation hardening strategy with the statement on page 22 that Avista is
still in the process of"evaluating the feasibility of underground ing as a wildfire mitigation tool."
4-D installing covered conductor"; Please refer to page 23, which discusses "Avista's Covered
Conductor Project, " and is described as the installat ion of 2.5 miles of covered conductor near
Springdale, WA., and observes that "the first covered conductor project in Avista's history. "
Please reconcile the apparent discrepancy between the description on p. 19 that "installing
covered conductor" is an included wildfire mitigation hardening strategy with the statement on
page 23 that Avista is in the process of acquiring a"clearer and more informed evaluation of the
cost-benefit relationship of implementing covered conductor solutions ... " Are covered
conductors planned to be installed in this WMP year(2026)? If so, please indicate where and
how many miles are planned for such installations.
4-E "Replacing wood crossarms with fiberglass"; Please identify the locations and their
respective Risk Levels, including the number of replacements, dates of replacements, and line

miles of distribution line and/or transmission lines that have had wood crossarms replaced with
fiberglass in and explain and provide the same information for the Company's planned
installation of fiberglass cross arms in the current WMP year (2026). What is the all in cost of
the installation of a fiberglass cross arm broken down by parts, labor, etc? What savings can be
achieved due to economies of scale for multiple installations?
4-F "Deploying automated protection devices (e.g. reclosers)"; Page 41 discusses installation of
circuit reclosers, providing: "As part of our wildfire Mitigation Plan, we have installed 50
midline circuit reclosers. . . . " Please identify the locations, Risk Level and dates of installation
for each mid line circuit recloser. Please identify the locations and anticipated dates of installation
of new circuit reclosers for this year's WMP (2026). Please explain, in lay terms, the function
and utility as to how a circuit recloser prevents wildfire ignitions. What is the all-in cost of
installation of a circuit recloser broken down by parts, labor, etc? What savings can be achieved
due to economies of scale for multiple installations?
RESPONSE:
A. Rebuilding lines with hardened designs refers to upgrading overhead existing infrastructure
with improved engineering design elements. Rebuilding lines routinely involves the following
work:
• Replacing wood crossarms with fiberglass.
• Changing out small copper conductor.
• Installing stirrups at hot tap connection.
• Converting "open-wire secondary" districts with insulated triplex secondary distribution.
• At high-value pole locations - installing fire mesh wrap to existing wood poles. See
definition of"high-value pole" in B. below.
In addition to overheard infrastructure, wildfire grid hardening strategies refer to many kinds of
improvements that create resiliency and reliability in the system.
Other hardening strategies include:
• Undergrounding select distribution segments.
• Deploying automated protection devices (e.g. reclosers)
o This work is performed on overhead infrastructure on a case-by-case basis.
• Replacing high-value distribution poles with ductile iron, where truck accessible.
• Installing covered conductor.
B. The table below details the dates and work for transmission projects
WMP 2025 2026
Date —July 2025-Se tember 2025 June 2026-September 2026
Nee Perce-Orofino I I5kV Line nearMoscow-Orofino I I5kV Line near
Location Orofino ID rofino ID
Number 63 poles 110 poles
Miles _Approximately 4-miles roximatel 8-miles
Risk
,Level VvrUI Tier 3 WUI Tier 3
Page 2of8

High Value Distribution Pole
A high value distribution pole or high value wood structure is a distribution structure located at a
critical crossing or high-consequence location—such as highway/river/railroad crossings, canyon
long spans, major equipment poles (recloser/regulator/switch/3 phase critical service), or heavily
guyed structures—where failure could create larger impacts, safety hazards or lengthy
outages. These high value poles are prioritized for steel pole replacement when accessible, or fire
mesh wrapping.
While the transmission system converts wooden poles to steel poles across large, continuous
sections of line, the distribution system focuses on replacing individual poles at specific
locations. No linear miles of distribution line have been fully converted to steel poles under any
version of the WMP.
C. Avista is using the undergrounding project in southeast Spokane, Washington, as a test area to
better understand the level of effort, schedule, and cost required to architect,
design, procure, construct, and convert existing overhead primary distribution facilities to
underground service. This project is intended to capture key leamings related to constructability,
customer impacts, permitting, materials, and coordination that can be applied to
future undergrounding efforts. Converting overhead distribution to underground infrastructure is
the most effective method for eliminating the risk of electric spark ignition and is identified as a
primary mitigation measure in Avista's wildfire risk mitigation strategy. At the same time, we
recognize that having a range of mitigation tools allows us to apply the option that delivers the
best cost benefit outcome for our customers and our system in each specific location.
D. Covered conductor remains an important tool in Avista's wildfire mitigation toolbox. Based on
industry and peer utility experience, it is a viable strategy to reduce spark ignitions, which is why
it is included as one of our potential grid hardening approaches. At the same time, we recognize
that having a range of mitigation tools allows us to apply the option that delivers the best cost
benefit outcome for our customers and our system in each specific location.
Avista's Springdale,WA project was our first covered conductor installation and was intentionally
scoped as a learning opportunity. Through that project, we evaluated design considerations,
procurement needs, constructability, postconstruction support, installation costs, and
implementation risks associated with insulated covered conductor.
At this time, we do not have specific 2026 projects planned in which covered conductor is
identified as the sole solution. However, this may evolve as we complete additional analysis,
review the effectiveness of mitigation options, and incorporate insights from the new risk
modeling platform and industry developments.
E. The table below shows materials used forgrid hardening, including cross arms. The number of
cross arms used correlates to the locations that have received grid hardening as listed in
the attachment provided as Potlatch-PR-003-Attachment A. Please see this attachment to view
the feeder list.
Page 3of8

DIWIbution GrId Ha"le"Equipmerd Ir 2021D 2021 2022 2W 2024 2025 Total
599 1,187 382 1,054 469 4?
- -
666 U, 239C 1-1C 9-118
2C.8 550 1.376 1,Ct2 1129 605 4,3713
5 2C1 114 Los 21 0 177
insulator' 3::!_3 4,615 11,132 3,301 9,3d-1 2,539 39.854
Overhead CcnductGr Repl 3,--ed 61 72 202 92 17-1 0 593
Pcie - Metai J t(D 61 2 19 1 100
Wood I is 730 597 537 435 2.596
Yledgp/Bail Irlp 2ce 2,55C 15 095 0._55 5,729 1,193 22.022
�,Vlldiife Guard '
583 1.963 3,'�5C -1.6l) 3,2 71 661 11.552
of the total ry-des hardened, small or Cepricated conductor vj,15 eplared for ail chases on the respective line
tS 1, does not r
segrren .oqet t,,jo, Cr three%vires depending or the Seg.rnerlt�. Thus, d e el)f esent a linear-distance.
Tracking is not available to the individual feeder location or the number of miles.
In 2026, cross arms will be replaced as part of the overhead grid hardening on 29 miles of
GIF34F2 which is located near Inchelium, Washington.
Transmission does not typically use fiberglass crossarms on their structures. There is one framing
that utilizes some I I' fiberglass arms; however, these are not used to programmatically replace
wood crossarms.
Estimated Cost
Phase Tangent Crossarm Accessible Replacement does not include the added costs, when
necessary, Avian Material, Cutouts. Flagging, Inaccessible poles, dead end or buck poles, pole
changeouts, design time, inspection of work, or program management time, or overheads.
Below is a breakdown of estimated costs:
9' Fiberglass crossarm =$220.79
(2) Machine Botts 1/4"xl2" = $7.44
(2) 4"x4" curved washers= $7.76
(1) 1/4" spring washer-- $1.40
(2) Steel Pm* s=$45.58
(3) Vise Top fnsulators= $75.36
(1) Pole PM* = $20.25
(2) 5/8" x 20" Machine Bolt=$ 5.30
(2) 2 1/2" x 2 V2 "Curved Washer= $ $3.00
(2) 5/8" spring washer— $38
Split Bolt 5/8" x 12" =2.65
(2) 2 1/2"x 2 !/2" curved washer-- $3.00
5/8" spring washer-- $39
Page 4 of 8

Total Material Cost= $393.70
Contract Labor Unit Pricing =$863.33
Total Cost= $1,257.03
Contract Labor and cost
Contract labor is competitively bid. Contractor pricing is based on scale. When bidding,
contractors are able to price their units cheaper when there is a larger volume of work by spreading
administration costs.
F. As discussed on page 42 of Avista's Wildfire Mitigation Plan(WMP), Avista has installed and
continues to deploy automated protection devices, including midline circuit reclosers and
associated Fire Safety Mode (FSM) automation, as part of its wildfire risk-reduction strategy.
Installed MidGne Circuit Reclosers
All installed midline circuit reclosers are located on distribution circuits serving elevated wildfire
risk areas, generally corresponding to high-risk Wildland Urban Interface (WUI)tiers identified
in the WMP. A map of individual locations respective to WUI tiers is not available at this time.
To date, Avista has installed a total of 50 midline circuit reclosers. 29 of them are located in
Idaho as part of its Wildfire Mitigation Plan. Please see Staff-PR-046 response.
These installations were prioritized using Avista's wildfire risk assessment framework, which
evaluates factors such as vegetation, terrain, weather exposure, and historical wildfire occurrence.
The majority of these devices were installed between 2020 and 2025, with additional devices
completed or nearing completion in late 2025 and early 2026.
Planned Midline Circuit Recloser Installations (2026)
For the 2026 WMP period, Avista plans to complete remaining midline circuit recloser
installations initiated in 2025 and to install additional midline circuit reclosers. These installations
are targeted for completion in early to mid-2026, subject to system access, outage coordination,
weather conditions, and communications availability. Please refer to Staff-PR-041 for locations
for 2026.
Planned 2026 installations are prioritized using the same wildfire risk-based framework and are
coordinated with broader Wildfire Resiliency automation and substation upgrade efforts.
The number of circuit reclosers and dates of future installations for midline circuit reclosers have
been documented in Staff-PR-041 and Staff-PR-046.
Function of Circuit Reclosers (Lay Explanation)
A circuit recloser is a protection device installed on an electric distribution line. When the device
detects an abnormal electrical condition, also known as a fault, it quickly interrupts power flow,
so it functions similar to a switch. Common causes of faults may include vegetation contact,
lightning, an object blowing into a powerline, or any other abnormality present in the power
system.
Page 5of8

Most problems on power lines are temporary and clear themselves almost immediately. Instead of
shutting off power for hours, a recloser gives the line a quick "time-out" and then automatically
tries turning it back on. If the fault condition is temporary, then the power will be restored. If the
fault condition persists, the device will again interrupt power flow and keep the circuit de-
energized.
By rapidly limiting the duration and energy of fault events, circuit reclosers reduce the likelihood
that the fault will lead to a spark ignition event.
You can think of a circuit recloser like a circuit breaker in your home, but smarter. Your home
breaker trips once and stays off until you flip it manually. A recloser "tries" to restore power
because most outdoor power problems disappear on their own.
Avista can remotely monitor many of the circuit reclosers on the system, with the ability to operate
them(open or close them) and adjust protection settings dynamically, such as changing them based
on fire risk.
The primary purpose of these installations is to reduce outages (by allowing temporary faults to
clear themselves and restore power), improve safety (through isolating problems quickly), and
increase reliability (to keep as many customers online as possible during issues).
Cost of Installation and Economies of Scale
The all-in cost to install or replace a mid line circuit recloser varies depending on site-specific
conditions, including access, communications requirements, and whether installation is
coordinated with other wildfire mitigation or automation projects. Costs generally include the
recloser device, associated hardware, engineering, construction labor, communications
integration, and commissioning In cost-specific conditions, including access, communications
requirements, and whether installation is coordinated with other wildfire mitigation or
automation projects, costs generally include the recloser device, associated hardware,
engineering, construction labor, communications integration, and commissioning.
Avista achieves economies of scale by standardizing equipment and designs, procuring devices
in coordinated batches, and sequencing installations geographically and programmatically. These
efficiencies reduce engineering and construction costs per unit compared to isolated installations.
Below is a summary of estimated cost:
Automation protection device cost estimates
Activity Cost
Design and PM $3,000
Materials $38,000
Protection Settings Config $6,000
CPC Design $3,000
Provisioning $3,000
Construction (installation) $15,000
Construction Support $5,000
Recommissioning $7,500
Subtotal $80,500
Page 6of8

Loadings $2,415
Tax $3,741
Contingency (10%) $8,050
Grand Total $94,706
Locations of Midline circuit reclosers are listed below. No map of exact locations was readily
available at the time of this report.
State •n Feeder Device Year
Con-imissioned
ID CDA APW 113 ZC261 R 2022
ID CDA AVD151 ZC262R 2022
ID CDA BLU321 ZC999R 2024
ID CDA IDR253 ZC355R 2022
ID CDA PF213 ZC263R 2022
ID Grangeville GRV 1271 ZG711 R 2024
ID Grangeville GRV 1273 ZG731 R 2024
ID Grangeville ORO1281 ZG811R 2024
ID Grangeville ORO1281 ZG812R 2024
ID Grangeville ORO1281 ZG813R 2024
ID Grangeville OR01281 ZG82 I R 2022
ID Grangeville ORO1282 ZG822R 2022
ID Kellogg MIS431 ZC432R 2026
ID Kellogg PIN443 ZC450R 2025
ID Kellogg WAL544 ZC507R 2023
ID Lewiston/Clarkston SWT2403 ZL186R 2022
ID Moscow/Pullman DER652 ZP6522R 2022
ID Moscow/Pullman WOR471 ZP471 R 2022
ID Sandpoint OLD721 Z4SI19R 2021
ID Sandpoint PRV752 Z4S215R 2023
ID Sandpoint PRV752 Z4S68R 2022
ID Sandpoint SAG741 Z4S 106R 2023
ID Sandpoint SAG741 Z4S140R 2023
ID Sandpoint SPT4S21 Z4S214R 2023
ID St Maries OGA61 1 ZC613R 2022
ID St Maries OGA611 ZC618R 2021
ID St Maries STM631 ZC627R 2022
ID St Maries STM633 ZC635R 2021
ID St Maries STM633 ZC639R 2025
WA Colville CLV12F4 ZE033R 2023
WA Colville CLV 12F4 ZE034R 2023
WA Colville GIF12F1 ZE072R 2022
WA Colville GIF34F2 ZE074R 2024
WA Colville GIF34F2 ZE075R 2024
WA Colville GIF34172 ZE076R 2024
Page 7of8

RegionState
Commissined
WA Colville GIF34F2 ZE077R 2024'
WA Colville ORI121`1 ZE151R 2023
WA Colville VAL12F1 ZEO11R 2022
WA Colville VAL12F3 ZE251R 2026
WA Davenport FOR12F1 ZR294R 2023
WA Davenport FOR12F2 ZR295R 2022
WA Davenport LTF34F1 ZR020R 2022
WA Deer Park COB12F1 Z90R 2025
WA Deer Park DEP12F1 Z428R 2022
WA Deer Park DEP12F2 Z5383R 2026
WA Deer Park LOO12F1 Z1541R 2024
WA Deer Park LOO 12F2 Z t 542R 2024
WA Lewiston/Clarkston DRY1208 ZL1215R 2025
WA Lewiston/Clarkston DRY1209 ZL187R 2022
WA Spokane GRA12F2 Z160R 2023
Page 8of8