20260430Staff Comments.pdf

RECEIVED
April 30, 2026
ERIKA K. MELANSON IDAHO PUBLIC
DEPUTY ATTORNEY GENERAL UTILITIES COMMISSION
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83702
[phone]
IDAHO BAR NO. 11560
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF ROCKY MOUNTAIN )
POWER'S APPLICATION FOR APPROVAL ) CASE NO. PAC-E-25-22
OF THE 2026-2028 IDAHO WILDFIRE )
MITIGATION PLAN )
COMMENTS OF THE
COMMISSION STAFF
COMMISSION STAFF ("STAFF") OF the Idaho Public Utilities Commission
("Commission"), by and through its attorney of record, Erika K. Melanson, Deputy Attorney
General, submits the following comments.
I. BACKGROUND
On December 19, 2025, Rocky Mountain Power, a division of PacifiCorp ("Company")
applied to the Commission requesting approval of its 2026-2028 Idaho Wildfire Mitigation Plan
("2026 WMP"), in accordance with Idaho Code § 61-1801, et seq. Wildfire Standard of Care Act
("WSCA"), and the guidelines established in Exhibit 1 of Order No. 36774 ("Guidelines").
On January 23, 2026, the Commission issued a Notice of Application and Notice of
Intervention Deadline, setting a deadline for interested parties to file a petition to intervene. Order
No. 36912. Ruveon, LLC, an affiliate of Bayer Corporation, was granted intervention. Order No.
36951.
Previously, the Company filed its 2024 Wildfire Mitigation Plan ("2024 WMP") with the
Commission on April 15, 2024, in Case No. PAC-E-24-09. The Commission acknowledged the
2024 WMP in Order No. 36405. Order No. 36045 further ordered the Company to add additional
items in future Idaho WMPs.
II. STAFF ANALYSIS
Pursuant to Idaho Code § 61-1804, Staff reviewed the Company's 2026 WMP for
STAFF COMMENTS 1 APRIL 30, 2026

compliance and believes it meets the requirements of the WSCA, Order No. 36405, and the
Guidelines Staff also reviewed the 2026 WMP to ensure: (1) it is consistent with public health,
safety, and welfare; (2) the feasibility of the plan and the cost of its implementation; and (3) it
adequately minimizes wildfire risk and proposes to respond to wildfires that do occur.
The Guidelines require that the following sections be included: (1) geographical risk
assessment, (2) preventative actions and programs, (3) public outreach and engagement, (4)
government outreach, (5) method of line design, (6) situational awareness and monitoring, (7)
infrastructure inspection and maintenance, (8) de-energization and line operation practices, (9)
vegetation management, consistent with the WSCA. The Guidelines also require an update of
lessons learned from previously approved WMPs, a breakdown of each program category's
forecasted costs by year for both capital and operation and maintenance ("O&M") expenditures,
and a section which describes how the electric corporations address each of the Commission's
orders and Staff's recommendations. Additionally, The WSCA requires each WMP to span a
minimum of 3 years, the filing company to provide notice to specified parties, and for Staff to
coordinate with the state forester. The details of Staff s review of these requirements is discussed
in the respective sections below.
Staff recommends the Commission issue an order that (1) approves the Company's 2026
WMP, and(2) directs the Company to file an updated WMP for the Commission's annual review
on or about December 1st of each year going forward. Although Staff believes that the Company's
2026 WMP meets the requirements, Staff suggests the Company include additional items in future
WMP filings, as discussed.
A. 2026 Wildfire Mitigation Plan Overview and Cross Cutting Elements
The Company requested the Commission to find that its 2026 WMP is consistent with the
WSCA. Application at 12. In this overview section, Staff provides general observations regarding
the Company's 2026 WMP. This is organized into two main areas: (1) Cost Feasibility, and (2)
Cross Cutting Elements. Subsequent sections present comments organized according to the
Guidelines and the WSCA and addresses both(1)the Company's short-term operational activities,
which respond in real-time to current fire risk levels and rapidly changing system conditions, and
(2) its long-term planning activities, which are based on an area's underlying geographical fire
risk.
STAFF COMMENTS 2 APRIL 30, 2026

1. Cost Feasibility
a. Cost Forecasts
The Guidelines require a breakdown of each program category's forecasted costs by year
for both capital and O&M expenditures throughout the time frame of the WMP. Guidelines at 8.
The Company's 2026 WMP only included incremental cost forecast information for 2026-2028
and did not include a comprehensive cost forecast. 2026 WMP at 114-115. It also excluded
vegetation management cost forecast information. Id. The Company subsequently provided a
program-level cost breakdown of its forecast in its 3rd Supplemental Response to Staff Production
Request No. 1. Staff recommends the Commission direct the Company to include a
comprehensive cost forecast that specifies the base capital and O&M budgets, with wildfire costs
separately identified whenever possible. This information should also be broken down by
individual programs within each program category in future WMPs.
Table No. 1 below summarizes the Operations, Maintenance, Accounting, General
("OMAG"), and Capital cost forecasts for the 2026 WMP. Id. Separately,the Company provided
the complete regular vegetation management budget information for 2026-2028, displayed in
Table No. 2. Response to Staff Production Request No. 27. The Company forecasted$4.4 million
in total OMAG, with $1.8 million attributed to wildfire mitigation, with Situational Awareness as
the largest wildfire-specific OMAG incremental expense. The largest capital expenses are
attributed to the renewal of the Technosylva software subscription licenses for risk modeling in
2028 and system strengthening through the addition or upgrade of reclosers, relays, and breakers.
Table No. 1: 2026 WMP Incremental Cost Information
2026 2027 2027 2028 2028
Non- 2026 Non- Non- Non- Non- Non-
Program 2026 Wildfire 2026 Wildfire 2027 Wildfire 2027 Wildfire 2028 Wildfire 2028 Wildfire
Category OMAG OMAG Capital Capital OMAG OMAG Capital Capital OMAG OMAG Capital Capital
Risk Modeling&
Drivers total $ 214,600 $ S 315,120 $ - $ 221,000 $ $ 316,120 S $ 227,600 $ $2,799,600 $
Asset Inspections&
Corrections total $ 204,700 $ 293,894 $ $ $ 210,800 $ 302,701 $ $ $ 217,200 $ 311,782 $ $
System
Strengthening total $ 136,933 $ S 1,000,000 $ $ 137,833 $ $1,000,000 $ S 138,633 $ $ 300,000 $
Situational
Awareness total S SW,035 $ 159,551 $ 117,848 $ $ 912,198 $ 170,273 $ 244,110 S $ 956,30E S 175,421 $1,498,900 $
Field Operations&
Work Practices total S 154,450 $2,098,023 S 57,000 $ $ 158,550 $2,150,664 S 58,700 S $ 162,750 $2,215,1114 $ 60,400 $
Public Safety Partner
Coordination total $ 5,800 $ $ 65,300 S $ 5,800 S S 67,300 S $ 5,900 $ $ 69,300 $
Wildfire Safety
& Engagement
Strategy total S 85,817 $ $ $ $ 98,391 $ $ $ $ 91,043 $ $ $
Industry
Collaboration total $ 20,100 S $ $ $ 20,700 $ - S $ $ 21,300 $ $ $
Plan Monitoring&
Implementation total S 163.200 S $ 3 $ 168.100 S S S $ 173.100 S S $
GRAND
STAFF COMMENTS 3 APRIL 30, 2026

Table No. 2: 2026 Comprehensive Regular Vegetation Management Cost Budget
Regular Vegetation
Management Asset Class 2026 2027 2028
Distribution $3,592,141.00 $3.522.147.00 $2,919,337.00
Transmission $ 240,633.00 $ 223,109.00 $ 230,567.00
Prograrn Total $3,832,773.00 $3.745.256.00 $3,149,904.00
b. Internal Wildfire Mitigation Labor
The Commission directed the Company to include a line item for internal labor costs for
its Wildfire Safety Department in its cost forecasts in future WMPs. Order No. 36405 at 7. The
Company included this as a line item labeled "Wildfire Mitigation Program Delivery" within the
2026 WMP;however,no costs were included. 2026 WMP at 115. The Company provided a more
detailed cost forecast of$163,200 in Attachment 1 in its response to Staff Production Request No.
1. Consistent with Order No. 36405, Staff recommends the Commission direct the Company to
continue inclusion of a separate line item for the total Idaho-allocated internal labor needed for
wildfire mitigation in each WMP, which allows Staff to track labor costs over time and compare
those costs to Idaho's other investor-owned utilities.
c. Cost Benefit Approach
Pursuant to Idaho Code § 61-1804(1)(b) the Commission is required to consider the
feasibility of the plan and the cost of its implementation. In Order Nos. 36045, 36774, and 36882,
the Commission directed the Company to include a cost-benefit analysis within its WMPs and
provided guidance on the information necessary to support its analysis. Staff believes that the
Company has met these requirements. However, Staff has additional recommendations for future
WMP filings for added clarity, as discussed below.
Order No. 36045 requires the Company to provide an analysis and comparison of
alternatives considered in relation to each wildfire mitigation project. Although the approach was
described in Sections 1, 1.4, and 1.5 of the WMP,the Company did not provide the actual analysis
of any project for Idaho. The Company stated that none were provided because Idaho has no
identified Fire High Consequence Areas ("FHCA") and the Company only targets the top 15% of
areas within its FHCAs for system hardening. Response to Staff Production Request No. 33. Staff
believes that projects, such as upgrading or adding conductors, reclosers, relays, breakers, and
weather stations, should qualify under the Commission's Order. Accordingly, Staff recommends
that the Company perform the analysis for these types of mitigation projects within areas identified
STAFF COMMENTS 4 APRIL 30, 2026

as Areas of Interest ("AOI") in Idaho, at a minimum.
The Company also shared that it is developing a new Risk Spend Efficiency evaluation
capability to be described in its next WMP to support future cost-benefit analysis. Response to
Staff Production Request No. 33. The tool is intended to be applied to overhead covered
conductor, undergrounding projects, and enhanced vegetation management activities. Staff notes
that benefits may not always be quantified solely in monetary terms; nonetheless, the Company
should apply a consistent, transparent, and repeatable methodology across projects. Such
consistency is necessary for Staff and the Commission to evaluate whether projects are prioritized
using comparable criteria. Additionally, when qualitative benefits are applied, the Company
should define them and include how they relate to mitigating wildfire risk.
When describing wildfire mitigation strategies and comparing alternatives, Staff believes
the Company should include the estimated cost of each strategy. Including this information would
aid in the cost-benefit analysis of feasible alternatives. For example, the Company may wish to
install non-wooden poles, such as steel or ductile iron poles. By including the estimated cost of
each alternative, Staff can better evaluate the relative costs and benefits of those strategies.
Although Staff reviewed the forecasted capital and OMAG expenditures provided in the
WMP, approval of the WMP does not guarantee approval of cost recovery. The prudence and
recovery of WMP-related capital and O&M expenses will be evaluated in a future rate proceeding.
d. Grants
The 2026 WMP did not discuss grants that the Company has applied for or been awarded.
In its response to Staff Production Request No. 2, the Company provided information on three
grants the Company applied for as part of its wildfire mitigation efforts. The Company was
awarded $650,000 by the Idaho State Energy Resiliency Grant Program for a project in Madison
County, ID in December 2025. Id. The Company was also awarded $50 million by the U.S.
Department of Energy in 2024,under which the Company may deploy substation control advanced
network technology in Goshen and other communicating fault circuit indicator sensors across
Idaho. Id. The Company applied for a third grant from the Office of Energy and Mineral
Resources; however, it was not awarded. Id.
Staff believes this information should be included in the WMP because grant funding may
mitigate potential increases in wildfire mitigation costs to ratepayers. Additionally, the
Commission must consider the cost of implementing WMP expenditures, this information would
STAFF COMMENTS 5 APRIL 30, 2026

aid in the Commission's review of the cost and feasibility of the Company's planned actions.
Accordingly, in future WMP filings, Staff recommends the Commission direct the Company to
provide details of all funding alternatives and sources pursued within the WMP, including project
level details and current status.
e. Cost Comparison to 2024 WMP
The Company's 2026 WMP identifies approximately $13.7 million total additional
investment, $8 million in capital and$5.7 million in O&M for 2026 through 2028. 2026 WMP at
114-115. The Company's 2024 WMP identified $31.4 million of additional investment for 2024
through 2026, $22.6 million in capital and$9.14 million in O&M. 2024 WMP at 90. The decrease
in incremental investment between the 2026 WMP compared to the 2024 WMP are attributed
primarily to decreases in planned system hardening and operations and work practices.
Table No. 3 below summarizes the comparison between the 2024 WMP and the 2026
WMP.
Table No. 3: Company's 2024 WMP Forecast Compared to Company's 2026 WMP Forecast
Category 2024-2026 WMP 2026-2028 WMP Delta
Capital Costs S22.26M S8.OM S14.26M decrease
Expense (O&M) S9.14M S5.7M S3.44M decrease
Costs
Total S31 .40M S13.7M S17.7M decrease
2. Cross Cutting Elements
a. Referenced Policies and Procedures
Throughout the 2026 WMP, the Company refers to various procedures, policies, and
documents which the Company summarized in Appendix C of the 2026 WMP. However,
Appendix C did not include copies of these documents. The Company provided these documents
in its Response to Staff Production Request No. 42. Staff requests the Company include copies of
all referenced Company policies, procedures, standards, and documents as attachments in future
WMP filings.
b. Targets and Goals
The Company provides a summary of 2025 Program Results and 2026-2028 Objectives in
Table 11-1 on pages 110-113. Staff appreciates the Company's work to identify objectives for
each program because it aids in evaluating the feasibility of the proposed 2026 WMP. However,
STAFF COMMENTS 6 APRIL 30, 2026

most of the objectives are not quantitative. Staff suggests the Company consider adding
measurable targets to future year objectives where possible.
c. Metrics
Idaho Code § 61-1804(1)(b)-(c) requires the Commission to evaluate the feasibility of the
WMP and the degree to which it minimizes wildfire risk. The 2026 WMP does not describe the
metrics the Company will use for its wildfire mitigation efforts, operations, and projects. In
response to Staff Production Request Nos. 3, 5, and 32, the Company provided specific metrics
that will be used to evaluate the effectiveness of the WMP programs.
Additionally, there are industry-standard metrics that may be beneficial to track reliability
as the Company implements its WMP. These include the System Average Interruption Duration
Index ("SAIDI"),1 System Average Interruption Frequency Index ("SAIFI"),2 Customer Average
Interruption Duration Index ("CAIDI"),3 and Momentary Average Interruption Frequency Index
("MAIFI"). a These metrics allow utilities to benchmark reliability performance over time;
identify poor-performing circuits to prioritize investment; and assess the effectiveness of
vegetation management,protection schemes, and system maintenance and hardening.
Staff believes metrics and the data collected should be included within the WMP as they
demonstrate measurable targets for the Company to implement. Therefore, for future WMP
filings, Staff recommends the Commission direct the Company include all metrics used within
each respective section and provide the data in a format that can easily be tracked across WMP
filings, similar to the table provided in the Company's response to Staff Production Request No.
3. Additionally, where feasible, the Company should include three or more years of metric data
in future WMP filings to allow for trends to be identified.
d. Future WMP Filing Date
Idaho Code § 61-1803(2)(a) gives the Commission the authority to stagger the filing dates
of the WMPs. Order No. 36774 directed electric corporations to file their updated WMPs for
annual review one year after the filing date of the previously approved WMP. Order No. 36774
at 20. However,through communication with the Company,it stated that it would prefer an annual
1 SAIDI represents the total number of minutes of interruption the average customer experiences.
2 SAIFI represents the average number of times a customer experiences an outage during the year.
3 CAIDI is the average number of minutes it takes to restore non-momentary electric interruptions.
a MAIFI is the average number of momentary interruptions that a customer would experience during a given period
(typically a year).
STAFF COMMENTS 7 APRIL 30, 2026

WMP filing on or about December Ist each year. Staff has no concerns with this preferred filing
date because it staggers the filing dates of Idaho's other two investor-owned electric utilities.5
Therefore, Staff recommends the Commission issue an order allowing the Company to file its
updated WMP on or about December I"of each year.
B. Geographical Risk Assessment
Idaho Code§ 61-1803(3)(a) and the Guidelines require all WMPs to identify infrastructure
or equipment that the electric corporation considers may be subject to a heightened risk of wildfire.
Identifying these areas allows utilities to clearly show where their systems pose elevated ignition
risks and where their infrastructure is vulnerable to wildfire damage, enabling regulators and the
public to assess whether mitigation measures are properly targeted to the highest risk locations.
In this section, Staff provides: (1) summarized description of the Company's wildfire risk
analysis method used to identify varying levels of risk within the Idaho service territory; (2) the
results produced by the method; (3) the key strengths of the Company's method; and (4) the key
areas of improvement the Company should consider in future WMPs.
1. Description of Wildfire Risk Analysis Methodology
The Company's methodology incorporates a mathematically coherent framework for
composite wildfire risk score calculations, multi-source data integration, model validation by the
vendor and the Company's internal experts,and development of wildfire risk zone maps with clear
thresholds. Staff believes the Company has followed sound quantitative and qualitative modeling
approaches to assess wildland fire risks, to identify geographical areas with heightened risks, and
has met the requirements.
The Company's wildfire risk model defines wildfire risk as likelihood multiplied by
consequence, and it is operationalized through a structured four-stage framework including: (1)
data collection and analysis; (2) risk evaluation and tools (centered on Technosylva's FireSight
Wildfire Analyst Enterprise or "WFA-E" suite); (3) risk treatment (program selection and
prioritization); and(4)risk monitoring&review(continuous improvement). 2026 WMP at 21-29.
The Company computes circuit-segment risk scores using FireSight's two independent risk
types: (1) Risk Association with Ignition Location ("RAIL") that captures the fire characteristics
(e.g., fire size, rate of spread, flame length, etc.) and impacts on structures from any potential
5 In IPC-E-25-32, Idaho Power requested an annual filing date on or about October 1 each year. In AVU-E-25-15,
Avista requested an annual filing date on or about November 1 each year.
STAFF COMMENTS 8 APRIL 30, 2026

ignition at an asset location, and (2) Risk Association with Value Exposure ("RAVE"), which
calculates the community impacts from a potential ignition location. Id. Both RAIL are RAVE
values are calculated using wind-driven and fuel/terrain-driven risks factors and are then combined
to produce a composite risk score ("CRS") for each ignition location along a circuit. Id. These
CRSs are then utilized to categorize the Company's service area into three different geographical
risk tiers with heightened wildfire risks. Id. These tiers are based on thresholds applied to I-mile
by I-mile spatial grids or segments. Id. Thresholds include: (1) FHCA when CRSs are greater
than 0.85, (2) Areas of Interest I ("AOI I") for CSRs between 0.65 and 0.85, and (3) Areas of
Interest II ("AOI II") for CSRs between 0.45 and 0.65. Id.
2. Results of the Company's Risk Analysis
Based on the risk modeling results,the Company did not identify any FHCAs; only AOI Is
and AOI Its are identified within the Company's Idaho service area. Thus,the Company's wildfire
mitigation efforts in Idaho primarily rely on situational awareness and operations. Response to
Staff Production Request No. 53. The Company plans to continue to improve and mature its risk
quantification methodology,which focuses on potential wildfire mitigation projects,incorporating
both monetized risk and risk spend efficiency. 2026 WMP at 22. However, Staff is concerned that
the AOIs may present heightened wildfire fire risk that could reasonably and proportionally be
mitigated. Accordingly, Staff suggests the Company consider potential options and discuss them
in its next WMP filing.
3. Key Strengths of the Company's Risk Modeling Methodology
Through its review of the Company's risk modeling and analysis methodology, Staff
identified several strengths:
The model's RAIL and RAVE architecture incorporates deterministic fire spread
simulations and community exposure features both fire behavior and population or
asset vulnerability — a design that is consistent with how specialized wildfire platforms such as
Technosylva FireSight WFA-E are used by other utilities and agencies.6,7,8
The risk model separates wind-driven vs. fuel/terrain driven risks and applies transparent
variable weighting (e.g., rate of spread, buildings destroyed, terrain difficulty, etc.). Response to
6 https://helpcenter.technosylva.com/wfa-firesight(last visited April 14,2026).
7 https://www.latitudemedia.com/news/utilities-are-beginning-to-embrace-firetechs-old-guard/(last visited April 16,
2026).
8 https://technosylva.com/customers/(last visited April 16,2026).
STAFF COMMENTS 9 APRIL 30, 2026

Staff Production Request No. 49. Staff believes this approach aligns with differing fire regimes,
wind events and steep, fuel rich terrain can drive different hazard profiles and reduces bias toward
a single risk driver.
The model translates segment level risk scores to mapped zones via 1-mile by 1-mile grids,
giving the mitigation programs actionable footprints (FHCA,AOI I or AOI I1)rather than isolated
line fragments. Staff believes that such a structured approach based on clear geographical
distinction should provide useful insights for inspection and vegetation management workflows
and partner coordination.
The methodology incorporates multiple data integration such as, outages, inspections,
fuelscape, operational Weather Research and Forecasting or"WRF"ensemble,FireSight seasonal
outputs, etc. to quantify wildfire risks. 2026 WMP at 125. Staff believes that using diverse data
inputs facilitates the FireSight modeling tool in identifying specific circuits that have a heightened
risk of wildfire within the Company's service territory.
The Company performed model verification and validation through a combination of
vendor and internal expert review. Response to Staff Production Request No. 49. The vendor
validation included comparison of the predicted rate of fire spread ("ROS") with the observed
ROS, while the Company's internal validation comprised of sensitivity analysis to improve
confidence in relative rankings of the modeled risk tiers. Id. Staff believes the Company's efforts
in validating the modeling results is consistent with the published literature related to current
industry-wide practices and standards on wildfire mitigation plans.9,10
4. Key Areas for Improvement in the Company's Risk Modeling Methodology
Staff identified six areas for improvement in the Company's risk modeling methodology:
(1) generation resources are not modeled; (2) Company ignition data is not used; (3) lack of direct
correlation between fault and probability of ignition; (4) grid sizing lacks adequate resolution; (5)
"Loss of Life" is not modeled; and (6) lack of benchmarking of publicly available maps. Each is
discussed below.
9
https://www.pnnl.aov/sites/default/files/media/file/PNNL_lONov2025 Wildfire_Risk_Mitigation_Executive_Order
Best_Practices_FINAL PNNL-SA-3852811_Ol.pdf(last visited April 20,2026).
10 https://www.nerc.com/globalassets/who-we-are/standing-
committees/rstc/wildfire_mitigation_ref guide iu1y2025.pdf(last visited April 20,2026).
STAFF COMMENTS 10 APRIL 30, 2026

a. Generation Resources are Not Modeled
The Company's fire spread modeling framework in Technosylva FireSight incorporates
transmission and distribution line assets but does not consider generation resources,battery energy
storage systems("BESS"),or other non-line assets as potential ignition sources. Response to Staff
Production Request No. 49. Although BESS failure rate and hazards have been reduced in recent
times due to the adoption of latest designs and best practices, battery storage units can still be
severely hazardous due to several reasons such as uncontrolled release of heat energy, generation
of toxic and flammable gas, challenges in extinguishing BESS-generated fires, etc. 11,12,13,14 Staff
believes the types of infrastructure excluded from the risk modeling should be addressed and, if
not included, the Company should provide an explanation.
b. Company-Specific Ignition Data is Not Used
The Company's has not utilized Company-specific ignition data in its risk model, as it is
still being cleaned and validated. Response to Staff Production Request No.47. Instead,the model
utilizes the probability of ignition ("POI"), which relies on a proxy from National Fire Danger
Rating System Ignition Component, and it is expressed as the probability of a wildfire requiring
suppression will develop when there is a burning materials (such as ember or spark) present."
Response to Staff Production Request No. 49. Staff believes that by not using Company-specific
ignition data it may under- or over-estimate grid-level ignition probability for each region. The
Company should consider replacing the probability of ignition proxy with the Company's asset-
specific ignition data in the risk modeling.
c. Lack of Direct Correlation Between Fault and Probability of Ignition
In its model, the Company calculates the asset-specific expected risk or likelihood value
by multiplying the probability of failure ("POF") by the POI. Response to Staff Production
Request No. 47 and 1" Supplemental Response to Staff Production No. 47. However, in a
teleconference between the Company and Staff, the Company acknowledged that POF and POI
are calculated independently in the FireSight model and there exists no direct link or correlation
11 h!Ws:Hstoragewiki.epri.com/index.php/BESS Failure_Incident_Database(last visited April 15,2026).
12 https://www.nfpa.org/education-and-research/electrical/energ -serge ssystems(last visited April 15,2026).
"https://www.epa.gov/electronics-batteries-management/batte .rig_ -serge ssystems-main-considerations-safe
(last visited April 15,2026).
14 https://www.sciencedirect.com/science/article/abs/pii/S095042302200208X(last visited April 15,2026).
15 https://www.nwcg•gov/publications/pms437/fire-danger/nfdrs-system-inputs-and-outputs;Accessed: 04/28/2026.
STAFF COMMENTS 11 APRIL 30, 2026

between POF and POI.16 In the discussion, the Company stated that FireSight calculates POF
based on outage history, and in this process, FireSight uses a conservative assumption, where all
faults can start a fire. Staff believes that although a spark or ignition could potentially result from
a fault or failure of an asset, each of the simulated fault events might not have enough energy
release to start an ignition.l',ls Staff believes that without establishing a concrete relationship
between the POF and POI, it may bias the estimation of overall risks in the modeling approach.
The Company should consider addressing issues related to statistical correlation between the POF
and the POI.
d. Grid Sizing Lacks Adequate Resolution
The Company uses 1-mile by 1-mile spatial grids or segments to compute geographical
wildfire risks. Response to Staff Production Request No. 49. In comparison, some other major
electric utilities in Idaho, such as Idaho Power Company (Case No. IPC-E-25-32) and Avista
Utilities(Case No. AVU-E-25-15)used 240-meter and 200-meter as unit cell sizes respectively in
their individual wildfire mitigation plans for 2026. Staff believes that compared to these above-
mentioned utilities, the Company's grid sizing may lack adequate resolution and by using larger
unit cell sizes, this may mask micro-hotspots in certain geographic regions, which could result in
under or overestimation of consequences in different areas within the Company's service territory.
The Company should consider incorporating smaller and more appropriate grid sizes ('/2-mile or
variable by terrain and fuel) in its spatial fire spread simulations.
e. "Loss of Life" is Not Explicitly Modeled
The modeling framework does not explicitly model or quantify loss of life (human and
wildlife), or natural resource (timber, habitat, ecosystem, etc.) impacts as separate monetized
categories. Response to Staff Production Request No. 49. FireSight's modeling indirectly proxies
these elements via consequence and exposure variables as a part of composite risk scores. Id.
Staff believes not incorporating loss of life as a separate input parameter to risk modeling might
underrepresent values of non-structural elements that are important to the public. The Company
should consider expanding consequence parameters (e.g., loss of life, wildlife habitat, timber,
ecosystem, etc.) in its future wildfire risk assessments, and at a minimum, include them as a
16 The teleconference between the Company and the Staff took place on March 9,2026.
"https:Hencyclopedia.pub/entry/39869#:-:text=An%20electrical%20arc%20exhibits%20extremely,heated%20to%2
Oits%20ignition%20temperature(last visited April 15,2026).
18 https://www.mdpi.com/2571-6255/5/6/201 (last visited April 15,2026).
STAFF COMMENTS 12 APRIL 30, 2026

qualitative parameter where parameters have higher probabilities.
f. Public Map Benchmarking is Pending
The Company did not perform a comparative analysis of the currently modeled wildfire
risk areas in Idaho against publicly available risk maps, such as United States Forest Service's
("USFS") Wildfire Hazard Potential ("WHP"), Federal Emergency Management Agency's
("FEMA") National Risk Index ("NRI"), etc. 19,20 Response to Staff Production Request No. 51.
The Company is expecting to perform comparison and validation with public maps as a part of its
new risk map development. Id. Staff believes that a comparison of the modeled risk map with the
nationally consistent datasets should provide an independent cross-check to identify any potential
blind spots in wildfire consequence estimates. The Company should include the detailed results
of the external benchmarking of the modeled geographical risk maps in Idaho against nationally
consistent and publicly available maps, such as USFS WHP,FEMA NRI, etc.,in its future WMPs.
C. Other Preventative Actions and Programs
Idaho Code § 61-1803(3)(b) and the Guidelines also state optional preventative action and
programs that may include, but are not limited, to three additional topics: (1) system hardening
strategies, (2) workforce preparedness, and (3) pilot programs. System hardening strategies are
included in a later section "Methods of Line Design and System Hardening." Staff discusses the
remaining two listed optional strategies and programs below.
1. Workforce Training and Preparedness
The Guidelines state that a WMP may include discussion of workforce training and
preparedness. Guidelines at 3. A trained workforce supports the safe and effective implementation
of wildfire mitigation measures, including situational awareness, emergency response, and line
operations. This not only fulfills regulatory obligations but also strengthens operational resilience,
reduces the likelihood of safety incidents during wildfire season, and supports timely, coordinated
responses when conditions escalate.
The Company provided a brief description of its workforce training activities on page 82
of the 2026 WMP. In response to Staff s Production Request No. 17, the Company also supplied
copies of training materials and descriptions of its e-book and electronic training modules.
19 https://research.fs.usda.,gov/firelab/products/dataandtools/wildfire-hazard-potential(last visited April 15,2026).
20 https://www.fema.gov/sites/default/files/documents/fema national-risk-index technical-documentation.pdf (last
visited April 15,2026).
STAFF COMMENTS 13 APRIL 30, 2026

Additionally, the Company provided summary information on training participation in response
to Staff Production Request No. 18. This supplemental information was necessary for Staff to
fully assess the Company's training program.
Based on its review, Staff concludes that the Company has met the training requirements
outlined in the Guidelines. However, because additional information was required for a complete
analysis, Staff suggests the Company include sufficient detail in future WMP filings to describe
training program, including high-level metrics such as employee participation,training frequency,
and types of training completed. Staff also suggests the Company maintain supporting training
materials and make them available upon request or through audit, as needed.
2. Pilot Programs
The Guidelines state that a WMP may include pilot programs as a preventative program.
Guidelines at 4. The Company's 2026 WMP did not include any pilot programs, however the
Company is conducting a few pilot programs in other states as part of its 2026 WMP efforts.
Response to Staff Production Request No. 4. The pilot programs include (1) early fault detection
line sensors by Intelligent Network Diagnostic Technology, (2) Gridscope line sensors by
Gridware, and (3) a drone inspection in FHCAs. Id. The Company's response also includes
descriptions and metrics used to evaluate each pilot. Id.
Although these pilot projects are being conducted outside Idaho, the Company may apply
insights gained to future efforts in Idaho. Staff suggests the Company include a summary of all
pilot programs in future WMPs,including a description,estimated duration, estimated annual cost,
and high-level metrics used to evaluate performance, to improve clarity and transparency.
D. Public Outreach, Engagement, and Community Education
Idaho Code § 61-1803(3)(c) and the Guidelines require each WMP to describe how the
utility maintains community outreach and public awareness before, during, and after wildfire
season. Staff believes the Company's 2026 WMP meets the public outreach and engagement
requirement.
The 2026 WMP describes the Company's community outreach efforts to educate
customers about wildfire risk and mitigation activities. The Company's community engagement
includes: (1)webinars, (2)targeted paid advertising campaigns, (3) informational videos, (4)press
engagement, (5) distributed print materials, (6) infographics, (7) social media updates, and (8)
direct communication (e.g. billing inserts, e-mails, and website content). 2026 WMP at 97. Staff
STAFF COMMENTS 14 APRIL 30, 2026

believes the Company's public outreach efforts are reasonable.
E. Government Outreach
Idaho Code § 61-1803(3)(d) and the Guidelines require each WMP to include a discussion
of outreach and coordination with federal, state, tribal, and local officials and agencies regarding
wildfire preparedness and emergency response planning. Staff believes the Company's 2026
WMP satisfies these requirements.
The Company describes its coordination efforts with federal, state, tribal, and local
governments. Efforts include tabletop exercises, workshops, and coordinated planning activities.
2026 WMP at 93. Staff suggests the Company consider specifying the federal, state, local, and
tribal organizations with which it coordinates, preferably in a table or appendix. Staff notes that
public participation appears to increase when the Company partners with these organizations.
1. Partnerships
The Company stated that partnerships are leveraged for cost-sharing and program
effectiveness. Application at 7. However,the Company did not identify any specific partnerships.
Staff recommends the Commission direct the Company to include additional detailed descriptions
of current or planned partnerships,including any cost-sharing arrangements within Idaho,in future
WMPs.
F. Method of Line Design and System Hardening
Idaho Code § 61-1803(3)(b), § 61-1803(3)(e), and the Guidelines require the Company to
include a description of the Company's methods of line design for new lines and planned system
upgrades. As discussed above, the Company's Idaho service territory does not have any FHCAs;
only AOI I and II areas are identified. Thus,the Company does not have any planned line-rebuild
projects (e.g., covered conductor and overhead to underground conversion) in Idaho. 2026 WMP
at 46. Idaho's only planned system-strengthening work noted in the WMP is breaker and relay
replacements at Rexburg,Ashton,and Shelley substations.2026 WMP at 49-50; Response to Staff
Production Request No. 53. As Idaho does not have any FHCAs, Staff believes the Company's
approach is reasonable and has met the requirements. However, Staff has additional
recommendations for future WMP filings as discussed below.
1. Measurable Targets
The 2026 WMP does not provide sufficient detail on measurable targets for planned
breaker and relay upgrades, including short-term goals (i.e., 3-5 years), projected timelines,
STAFF COMMENTS 15 APRIL 30, 2026

selection criteria, reasonableness of costs, primary drivers of each project, and expected ignition
risk reduction. Accordingly, Staff recommends the Company to provide this information in future
WMP filings so that progress can be measured against the plan. This may include providing details
on measurable targets for system strengthening strategies(such as breaker and relay replacements)
in Idaho, including but not limited to, short-term goals (3-5 years), projected timelines, selection
criteria or reasonableness of costs, primary drivers for these projects, and ignition reduction.
2. Breaker and Relay Replacements
The Company utilizes advanced system protection and control ("ASPC") as one of the
components of its System strengthening and resiliency program. ASPC focuses on upgrading
protection schemes to reduce fault energy and duration (e.g., relay modernization, faster fault
clearing, sectionalization) and is complemented by operational Enhanced Safety Settings ("ESS")
to temporarily harden protection during elevated fire weather. As a part of the ASPC,the Company
states it plans to conduct breaker and relay replacements at Rexburg, Ashton, and Shelley
substations in Idaho. 2026 WMP at 49-50;Response to Staff Production Request No. 53. As Idaho
currently does not have any FHCAs, Staff believes the Company's approach is reasonable.
However, the 2026 WMP lacks the details and quantifiable targets for the anticipated planned
breaker and relay upgrades, short-term goals, anticipated timelines, selection criteria or
reasonableness of costs, primary drivers for each project, and ignition risk reduction per mile.
Without this information, Staff cannot assess the Company's progress against the proposed plan.
Thus, Staff recommends the Company provides this information in its future WMPs.
3. Pole Wraps
The Company states within its 2026 WMP that fire mesh wraps may be installed on poles
in heightened wildfire risk areas. 2026 WMP at 49. However, the Company does not have a
programmatic approach for installing pole wraps in Idaho because Idaho does not have any
FHCAs. Company Responses to Staff Production Request Nos. 14 and 46. In its responses, the
Company explained its policy to opportunistically install fire mesh wraps on poles in Idaho as part
of normal operations and provided the number of poles that have been wrapped prior to 2026. Id.
Staff believes that these pole wraps are part of wildfire mitigation and recommends the
Commission direct the Company include a description of the Company's approach to pole wrap
installations in Idaho within future WMPs,including the estimated cost per pole and an explanation
of how these activities are accounted for within the Company's operations or budgets.
STAFF COMMENTS 16 APRIL 30, 2026

G. Situational Awareness and Monitoring
Idaho Code § 61-1803(3)(f) and the Guidelines require each WMP to discuss how the
Company monitors weather conditions and wildfire risk. In 2026, the Company forecasts
$117,048 in capital expenditures and approximately$1 million in OMAG expenses. Attachement
to 3rd Supplemental Response to Staff Production Request No. 1. Over the three-year plan, the
Company forecasts a total of $1.9 million in capital expenditures and $3.2 million in OMAG
expenses. Id.
Through its review, Staff believes that the Company has met the situational awareness and
monitoring requirements of Idaho Code § 61-1803(3)(f) and the Guidelines. However, Staff has
additional recommendations for future WMP filings for added clarity, as discussed below.
1. Weather Stations
The Guidelines require the Company to identify the systems, tools, or external resources
used to monitor weather, fire potential, or other situational awareness indicators. Guidelines at 6.
Staff believes the Company has met this requirement; however some details regarding external
resources are not included in the 2026 WMP.
The 2026 WMP does not include sufficient detail on the external data it used from weather
stations in its situational awareness efforts. As it explains in its response to Staff Production
Request No. 7, the Company utilizes external data from the department of transportation, remote
automated weather stations, and airport weather stations. Staff recommends the Commission
direct the Company to include a description of the publicly available data sources the Company
relies on in future WMP filings for completeness and transparency.
Additionally,the Company did not include targets for its Company-owned weather station
network in the 2026 WMP. The Company plans to install two weather stations in 2026 and 2027
in Idaho, with an average cost of$17,500. Response to Staff Production Request No. 44. For
transparency, Staff suggests the Company include planned installation targets in future WMP
filings, including locations of focus, estimated costs, and alternatives considered.
2. Wildfire Detection Cameras
For situational awareness,the Company has installed wildfire detection cameras in Oregon,
California,and Utah. 2026 WMP at 69. Within Section 5.6 of the 2026 WMP,the Company states
it will be evaluating the installation of wildfire detection cameras in Idaho. Id. The Company
estimates $140,000 in capital cost per camera and $10,000 in annual OMAG expenses. Response
STAFF COMMENTS 17 APRIL 30, 2026

to Staff Production Request No. 43.
As the Company plans to expand its camera network, Staff suggests the Company include
additional details into Section 5.6 of future WMP filings, such as locations of focus, average cost
of installation, timeframe of installations, cost-benefit analysis, and alternatives considered.
Additionally, Staff suggests the Company consider including information or metrics that reflect
the effectiveness of detection cameras (e.g. number of ignitions detected per total number of
ignitions).
H. Infrastructure Inspections and Maintenance
Idaho Code § 61-1803(3)(b), § 61-1803(3)(g)(i), and the Guidelines require a discussion
of inspection frequency and standards of each type of electric infrastructure within areas of
elevated wildfire risk and associated targets or goals. Clear inspection guidelines help enable
timely inspections, maintenance, and emergency repairs, reducing reliability and safety risks
during high fire danger conditions and in heightened wildfire risk zones.
Based on its review of the 2026 WMP, Staff believes the Company has met the WSCA and
Guidelines requirements. However, Staff has identified areas for improvement in future WMP
filings.
1. Deficiency Backlog Monitoring
The Company will identify deficiencies through its inspections and other related activities.
Monitoring and correcting inspection deficiencies according to their respective priority is essential
to protect safety and system reliability because a growing backlog signals that additional resources
or process changes are needed to keep risks from escalating. Staff suggests the Company include
the following data, for the prior three years in future WMP filings for deficiencies related to
infrastructure in Idaho AOIs; (1) Number of deficiencies identified by priority category (e.g., P1,
P2, etc.); (2)Number or percentage of deficiencies repaired by priority category; (3)Remediation
targets by category; (3) Average time to repair by category type; and (4) Pending repairs at year-
end by category.
2. Quality Assurance
A Quality Assurance ("QA") program for infrastructure maintenance is essential because
it verifies that corrective work resolves identified issues, ensuring safety, reliability, and
accountability in the maintenance practices. The Company describes its QA for vegetation
management in Section 3.4 of the 2026 WMP. However,Staff suggests the Company also describe
STAFF COMMENTS 18 APRIL 30, 2026

its QA processes for inspection programs in a similar manner. This may include the scope of
audits (e.g., 100% review in high fire risk areas, or a 20%minimum sample of work across the
service area), audit frequency (e.g., weekly or monthly), and the process for addressing
deficiencies that do not meet the Company standards.
I. De-Energization and Operational Practices During Heightened Wildfire Risk Days
and Zones
Idaho Code § 61-1803(3)(b), § 61-1803(3)(g)(ii), and the Guidelines require a discussion
of operational changes during heightened wildfire risk days or within high wildfire risk zones
including line settings and restrictions to workforce practices. This is important because
operational changes during heightened wildfire risk days reduce the likelihood of ignition not only
from electrical infrastructure but also from activities performed on that infrastructure, such as
routine maintenance or emergency repairs. Although Staff believes the Company's 2026 WMP
meets these requirements, Staff has identified areas for improvement in future WMP filings.
1. Operational Practices During Heightened Wildfire Risk Days and Zones
The Guidelines require the Company to provide a description of operational practices
during heightened wildfire risk days or zones. Guidelines at 3. The Company's 2026 WMP
provides only a high-level description of how transmission and distribution operations change in
response to varying Fire Risk Potential, as shown in 2026 WMP Table 7-1 on page 81. However,
the WMP does not include a comparable description of changes in workforce practices as fire risk
increases. Staff believes the description lacks the level of detail necessary to understand how
operational practices change as fire risk increases. Id.
Staff recommends the Company include more specific information,preferably in a tabular
format, describing how workforce practices change as Fire Risk Potential increases, such as; (1)
Changes in tailboard meeting protocols; (2) Required equipment for crews and vehicles under
elevated fire risk; (3) Mandatory activities, including dedicated fire watches; and (4) Any
restrictions or prohibitions on work hours or field activities.
2. De-Energization with a Public Safety Power Shutoff
Staff believes the Company's Public Safety Power Shutoff("PSPS")process,as described,
is reasonable and appears consistent with industry practices intended to reduce wildfire risk while
balancing customer impacts. 2026 WMP at 82. The Company executed a single PSPS event
during 2025 in Utah. While this event did not immediately affect Idaho customers, it provides
experience that can inform future PSPS execution in Idaho.
STAFF COMMENTS 19 APRIL 30, 2026

Staff suggests the Company continue refining its PSPS protocols based on planned and
executed events. Ongoing evaluation and improvement of PSPS procedures will help ensure that
public safety objectives are met while minimizing customer disruption.
J. Vegetation Management
Idaho Code § 61-1803(3)(b) and § 61-1803(3)(g)(iii) and the Guidelines require each
WMP to include a discussion of vegetation management and enhanced vegetation management for
areas of heightened wildfire risk. Staff reviewed the Company's routine and enhanced vegetation
management practices described in the 2026 WMP and believes the Company has met the WSCA
and Guidelines requirements. However, Staff has identified areas for improvement in future WMP
filings.
1. Wildfire Risk Reduction
The Company shared in discovery discussions that its vegetation management is done
according to federal,national, and industry standards that include ANSI A300,National Electrical
Safety Code Section 21, Part 2, Rule 218, and North American Electric Reliability Corporation
Standards FAC-003-5 and FAC-501-WECC-4. These standards address clearances, tree/shrub
conditions, how to safely and appropriately prune or remove vegetation, and vegetation health.
However, during discussions with the Company, IDL, and Staff, the IDL mentioned that these
standards do not cover the ignition potential or fire propagation perspectives of vegetation from a
wildfire perspective. Specifically, these standards do not address "ladder" fuels, which allow
wildfires to progress from the ground to the canopy. Accordingly, Staff suggests the Company
consider adding standards specific to wildland fire, such as the International Society of
Arboriculture's Wildfire Risk Reduction Qualification, into the qualification standards for
personnel performing vegetation management.
2. Vegetation Management Metrics
The Company's current metrics for measuring the effectiveness of vegetation management
are primarily completion based, such as miles completed. Response to Staff Production Request
No. 5. The Company plans to expand beyond completion metrics to measure effectiveness by
analyzing vegetation-related outage and ignition efficacy. Id. This analysis will consider both
general and enhanced vegetation management activities, where applicable. Id. As part of
determining which new metrics to implement, Staff recommends (1) the Company evaluate
incorporating vegetation management metrics consistent with those identified in the Pacific
STAFF COMMENTS 20 APRIL 30, 2026

Northwest National Laboratory's Metrics in Wildfire Mitigation Plans (May 2025); (2) the
Company consider tracking vegetation-related fault, outage, and ignition data for both
transmission and distribution systems; and that this data be reported at the system level and the
circuit or feeder level.
Additionally, Table 11-1 in the 2026 WMP identifies past achievements and 2026-2028
objectives. However, it does not include measurable targets for vegetation management as
required by the Guidelines (at 8). For future WMP filings, Staff recommends the Commission
direct the Company to include measurable targets and completion data(e.g., miles treated) where
relevant.
3. Enhanced Vegetation Management
As stated above, the Company has identified no FHCAs in Idaho and, as a result, does not
perform enhanced vegetation management in Idaho. 2026 WMP at 36. However, the Company
also states that it may perform incremental vegetation management activities to address wildfire
risk in Idaho when near-term risks are identified. 2026 WMP at 36. Staff suggests the Company
describe any such work in future WMP filings when they occur. Staff is concerned that AOIs in
Idaho may have increased wildfire risk under certain conditions that could reasonably be mitigated,
and incremental vegetation management may be one approach to addressing those risks in AOIs.
K. Notice of WMP Filing
Idaho Code § 61-1803(2) requires the Company to provide notice, within five business
days of filing a wildfire mitigation plan, to the state forester, cities, counties, fire protection
districts, fire protection associations, and timber protection associations within its Idaho service
area. Staff believes the Company has met this requirement. 2026 WMP at Attachment B.
L. Lessons Learned
The Guidelines require the Company to provide an update of lessons learned from a
previously approved WMP in annual filings. Guidelines at 8. In the 2026 WMP, the Company
states there was no prior year approved WMP and, therefore, did not include lessons learned but
intends to provide them in future WMP filings. Application at 10. However, the Company
provided detailed lessons learned about inspections in its response to Staff Production Request No.
13. Accordingly, Staff believes the Company has met this requirement.
M. Mapping of WMP to WSCA and the Commission Orders
The Guidelines require the Company to include a section describing how it addresses each
STAFF COMMENTS 21 APRIL 30, 2026

of the Commission's orders and Staff s recommendations. Guidelines at 8. The Company detailed
its adherence to these requirements in Appendix A . Staff believes the Company has met this
requirement.
N. WMP Planning Horizon
Order No. 36774 requires the Company's WMP to be developed with a minimum three-
year planning horizon. Staff believes the Company has met this requirement because its 2026
WMP covers the period from 2026 through 2028. Application at 1.
O. Coordination with IDL
Idaho Code § 61-1804(3) requires the Commission to consult with the State Forester at
IDL, specifically regarding vegetation management, reduction of wildfire fuels, and other duties
of the State Forester under Title 38, Idaho Code.
On January 13,2026, Staff met with the Company and IDL to discuss the Company's 2026
WMP, specifically to discuss its wildfire risk model and vegetation management practices.
On January 29, 2026, Staff met with IDL to discuss its desired participation in the case.
Staff and IDL agreed to continue including IDL in meetings with the Company to attend as their
schedule allows.
On January 30, 2026, the Commission Secretary notified IDL of the Company's
application and supporting documents and provided access to this content through a shared
OneDrive location.
On March 9, 2026, Staff met with the Company and IDL to clarify the Company's
responses to Staff Production Requests.
On April 17, 2026, Staff and IDL met to discuss their concerns and recommendations
regarding the Company's WMP.
III. STAFF RECOMMENDATIONS
Staff recommends the Commission issue an order:
1. Approving the Company's 2026 WMP; and
2. Requiring the Company to file future WMPs on or about December I"of each year.
For future WMP filings, Staff recommends the Commission direct the Company to:
1. Include a comprehensive cost forecast that specifies the base capital and O&M budgets
in addition to the incremental wildfire-related costs, with these elements separately
STAFF COMMENTS 22 APRIL 30, 2026

identified where possible and broken down by program within each category;
2. Provide details of all funding alternatives and sources pursued, including project
information and current status;
3. Include metrics used to evaluate WMP performance within each respective sections
and present data in a format that can be tracked across WMP filings;
4. Include detailed descriptions of each current or planned partnered projects and any
partnerships based on cost-sharing opportunities within Idaho;
5. Include a description of the Company's informal process of pole wrap installations in
Idaho within the WMP, including the estimated cost per pole and an explanation why
it is not included within the wildfire mitigation budgets;
6. Include a description of the publicly available data the Company uses for situational
awareness; and
7. Include measurable targets and associated completion data (e.g., miles treated) where
applicable.
Respectfully submitted this 30th day of April 2026.
Erika K. Melanson
Deputy Attorney General
Technical Staff. Kimberly Loskot, Karla Ducharme, Shubhra Deb Paul, Ray McArthur
STAFF COMMENTS 23 APRIL 30, 2026

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 301h DAY OF APRIL 2026,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN
CASE NO. PAC-E-25-22, BY E-MAILING A COPY THEREOF, TO THE
FOLLOWING:
Rocky Mountain Power:
JANA SABA
JOE DALLAS
ROCKY MOUNTAIN POWER
1407 WEST NORTH TEMPLE STE 330
SALT LAKE CITY UT 84116
E-MAIL: jana.saba(4pacificorp.com
joseph.dallas(d),pacificorp.com
datarequestgpacificorp.com
Intervenor
Bayer:
Brian C. Collins
Thomas J. Budge Greg Meyer
Racine Olson, PLLP Brubaker& Associates
P.O. Box 1391; 201 E. Center 16690 Swingley Ridge Rd., #140
Pocatello, ID 83204-1391 Chesterfield, MO 63017
ti&racineolson.com bcollins&consultbai.com
tessa(d),racineolson.com gmeyer(d),consultbai.com
Ethan Waltermire
P4 Production, L.L.C.
P.O. Box 816
Soda Springs, ID 83276
ethan.waltermire&bayer.com
PATRICIA JORDA , SECRETARY
CERTIFICATE OF SERVICE