20260424Comment_1.pdf

Subject: PAC-E-25-22 Rocky Mountain Power Wildfire Mitigation Plan 2026-2028 - IDL
Comments
Good morning-Attached for filing and service please find Idaho Department of Lands'
Comments in the matter of Rocky Mountain Power's Application for Approval of the 2026-
2028 Wildfire Mitigation Plan, Case No. PAC-E-25-22.
Kind regards,
Kayla Dawson
Legal Assistant
Idaho Department of Lands
300 N. 6t"Street, Suite 103, Boise, ID 83702
Office: [phone]
Email: kdawsonPidl.idaho.gov
Website: https://www.idL.idaho.gov
NOTICE. This message, including any attachments, is intended only for the individual(s) or
entity(ies) named above and may contain information that is confidential, privileged,
attorney work product, or otherwise exempt from disclosure under applicable law. If you
are not the intended recipient, please reply to the sender that you have received this
transmission in error, and then please delete this email.

John A. Richards #10670
J.J. Winters #10327
IDAHO DEPARTMENT OF LANDS
300 N. 61h Street, Ste. 103
Boise, ID 83702
[phone]
[e-mail]
[e-mail]
Attorneys for Idaho Department of Lands
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF ROCKY MOUNTAIN CASE NO. PAC-E-25-22
POWER'S APPLICATION FOR APPROVAL
OF THE 2026-2028 WILDFIRE MITIGATION IDAHO DEPARTMENT OF
PLAN LANDS' COMMENTS
Idaho Department of Lands ("IDL")respectfully submits the following comments in the
above-captioned matter pursuant to Idaho Code § 61-1804(3) and Order No. 36927 on behalf of
Idaho State Forester, Julia Lauch.
1. IDL has reviewed the risk modeling as provided in the submitted plan by Rocky
Mountain Power("RMP") and presents the following reservations about the process used to
establish the "risk" area associated. Specifically, RMP modeling does not delineate any Fire
High Consequence Areas in Idaho, which is not consistent with other modeling that has been
conducted by IDL and others for the area. Due to the inconsistency associated with industry
products, IDL respectively requests additional details related to the modeling products and
process for the development of risk maps.
2. The cost breakdown provided by RMP was in the form of investment in particular
program categories, but provides no information as to how RMP delineates between investments.
As provided, it is difficult to distinguish the value of one investment over another without a cost-
IDAHO DEPARTMENT OF LANDS'COMMENTS-1

benefit analysis of mitigation activities. Additionally, IDL would encourage RMP to provide an
evaluation of the cost of no mitigation actions to help clarify the impact of investment.
3. Generally, throughout the plan, the assumption of wildfire risk is addressed from
an internal causality standpoint, whereas external wildfire impact can—and often does—impact
reliable service. IDL requests RMP include additional connection of activities to the influence of
external wildfire impinging on the system to clarify which actions are being taken to reduce
damage from external wildfire events on the system.
4. RMP addressed the fair market value as required, but only as far as it is generally
found in Section 3. If RMP has an established procedural process for the compensation of
marketable timber, IDL requests that RMP reference this process in Section 3. If this process
does not exist, IDL requests that RMP adds a formal project as an implementation action to
address this aspect of risk mitigation, as it represents a substantive unknown that can be
addressed through the development of a standard operating procedure. It is IDL's position that
the SOPS, when highlighted, will build greater confidence in relationships and the values
associated with timbered lands.
5. In the section covering inspection of vegetation, the qualifications appropriately
center around arboriculture standards, which have long been the industry standards. However,
IDL argues that these standards are insufficient at addressing wildland fire related issues when
looking at vegetative mitigation as a mechanism to reduce wildfire risk. The arboriculture stands
address tree/shrub conditions and how to appropriately remove or prune. Though these standards
address vegetation health, they do not consider ignition potential or fire propagation,both of
which should be standard for inspection of vegetation treatments. When viewed in the context of
wildfires, a prime example is "ladder" fuels. Ladder fuels are vegetative structural components
that allow fire to move rapidly from ground to forest canopies. If ladder fuels are not addressed
as part of the mitigation actions, then the risk of fire propagating to crowns is substantially
higher. IDL respectfully recommends that the inspection qualification standards also include
certification specific to wildland fire.
6. Every county in Idaho has completed a County Wildfire Preparedness Plan and
IDL strongly encourages that Rocky Mountain integrate through participation in the county"fire
planning groups". This will help to crosswalk efforts between the various planning efforts and
allow for greater leveraging of group resources to address wildfire risk mitigation and wildfire
IDAHO DEPARTMENT OF LANDS'COMMENTS-2

mitigation education across the various county plans and RMP's plan.
7. IDL would like to commend the efforts of RMP to engage with local cooperators
and community members to address risk mitigation within the Rocky Mountain System.
Dated this 241h day of April, 2026.
IDAHO DEPARTMENT OF LANDS
41C�-
J.J.WINTERS
Attorney for Idaho Department of Lands
IDAHO DEPARTMENT OF LANDS'COMMENTS-3

CERTIFICATE OF SERVICE
I hereby certify that on this 20 day of April,2026,I caused to be served a true and correct
copy of the foregoing by the method indicated below, and addressed to the following:
Rocky Mountain Power ❑x Email: [e-mail]
Jana Saba [e-mail]
Joe Dallas [e-mail]
Idaho Public Utilities Commission ❑x Email: [e-mail]
Erika Melanson [e-mail]
Commission Secretary
Bayer ❑x Email: [e-mail]
Thomas J. Budge [e-mail]
Ethan Waltermire [e-mail]
Brian C. Collins [e-mail]
Grey Meyer
Idaho Department of Lands ❑x Email: [e-mail]
Tyre Holfeltz [e-mail]
Julia Lauch [e-mail]
JJ Winters
Is/Kayla Dawson
Kayla Dawson, Legal Assistant
IDAHO DEPARTMENT OF LANDS'COMMENTs-4