20260430Reply Comments.pdf

I 1,
RECEIVED
April 30, 2026
Avista Corp. IDAHO PUBLIC
1411 East Mission P.O. Box 3727 UTILITIES COMMISSION
Spokane, Washington 99220-0500
Telephone [phone]
Toll Free 800-727-9170
April 30, 2026
Monica Barrios-Sanchez
Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd
Building 8, Suite 201-A
Boise, ID 83714
RE: Case No. AVU-E-25-15 —Avista Corporaiton's 2026 Wildfire Mitigation Plan
Dear Commission Secretary:
Enclosed for electronic filing with the Commission is Avista's Reply Comments in Case No.AVU-
E-25-15.
Please direct any questions regarding these comments to Liz Andrews at 509-495-8601 or
liz.andrews navistacorp.com.
Sincerely,
l sl ,5*Cleat ,4w*eW
Elizabeth Andrews
Sr. Manager of Revenue Requirements
liz.andrews@avistaco!p.com
509-495-8601

ANNI GLOGOVAC, ISB #13010
COUNSEL FOR REGULATORY AFFAIRS
AVISTA CORPORATION
1411 E. MISSION AVENUE
P.O. BOX 3727
SPOKANE, WASHINGTON 99220
PHONE: [phone]
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF AVISTA ) CASE NO. AVU-E-25-15
CORPORATION'S 2026 WILDFIRE )
MITIGATION PLAN ) AVISTA CORPORATION
REPLY COMMENTS
COMES NOW, Avista Corporation ("Avista" or "Company"), in accordance with the
Idaho Public Utilities Commission("Commission" or"IPUC")Rule of Procedure' ("RP") 52 and
the Notice of Modified Procedure, Order No. 36927, respectively submits the following Reply
Comments regarding Avista's 2026 Wildfire Mitigation Plan("WMP","Wildfire Plan"or"Plan").
I. INTRODUCTION
The Company's 2026 WMP is its fifth edition of the plan and the first filed for approval
pursuant to the Wildfire Standard of Care Act("WSCA"), Idaho Code § 61-1801, et seq. Pursuant
to the WMP Filing Schedule adopted by the Commission, Avista's WMP was filed with the
Commission in an Application for review on December 9, 2025 ("Application")'.
Avista's WMP was the product of the Company's continued efforts to reduce wildfire risk
for the safety of Avista's customers, the continued and reliable delivery of electricity to
' Idaho Administrative Procedures Act(IDAPA)31.01.01.
2 Exhibit A to Order No. 36774.
3 See IPUC Case No.AVU-E-25-15.
AVISTA REPLY COMMENTS Page 1

approximately 150,000 retail electric customers in Idaho, and good stewardship of the beautiful
and natural lands within Avista's service area and beyond. Accordingly, the mitigation measures
outlined in the Company's 2026 WMP are also intended to reduce potential risk associated with
the Company's infrastructure or equipment, such as the operation of its 180 substations (system)
as well as approximately 900 miles of overhead transmission lines and 2,567 miles of overhead
distribution lines within the state of Idaho. These overhead assets represent about 40 percent of
Avista's total overhead transmission line assets and 33 percent of its total overhead distribution
line assets.
The 2026 WMP is built around a geographical risk assessment, which utilizes a risk-
informed approach that considers wildfire probability and consequence to identify areas that may
be subject to potential heightened wildfire risk in locations where Avista has infrastructure or
equipment. Additionally, the Company employs a risk-informed approach to select and prioritize
various wildfire mitigations carried out to reduce the risk of wildfire while balancing wildfire risk
and cost of mitigation. As more thoroughly discussed in the Company's 2026 Wildfire Plan, and
summarized within Avista's WMP Application, Avista's WMP identifies the methods and means
for mitigating wildfire risk that reflect a reasonable balancing of mitigation costs with the resulting
reduction of wildfire risk, complying with the requirements of Idaho Code §61-1803(3) and the
additional directives from the Commission set forth in Order No. 36774 issued in GNR-E-25-02
on September 30, 2025, including the IPUC WMP Guidelines provided as Exhibit B to that order.
Avista appreciates the opportunity to offer these Reply Comments in response to
Comments on the Company's WMP filed by Commission Staff("Staff'), Idaho Department of
Lands ("IDL"), and PotlatchDeltic Forest Holdings, LLC ("PotlatchDeltic") (collectively, the
"Stakeholders").
AVISTA REPLY COMMENTS Page 2

II. REPLY COMMENTS
Avista's Response to the Comments of Commission Staff
The Company appreciates Staff s thorough review and assessment of its filing and
determination that Avista's 2026 WMP meets the requirements of the WSCA4, Order No. 36774,
the Commission's WMP Guidelines ("Guidelines"), and Staff s recommendation that the
Commission approve the WMP.Avista also supports Staff s recommendation to clarify that future
WMP filings may be submitted on or about November 1 of each year. Avista also recognizes the
suggested improvements and constructive recommendations offered by Staff. Provided below are
responses directly to the nine (9) recommendations made by Staff as detailed on p. 24 of its April
16, 2026 Comments.
Staff Recommendation #1 - The Company appreciates Staff s review and
recommendation regarding the presentation of internal labor costs associated with wildfire
mitigation. The Company supports the inclusion of a separate line item in future WMP cost
forecasts to identify internal labor dedicated to wildfire mitigation activities.
Staff Recommendation #2 - Staff concluded that Avista substantially meets Guidelines
related to workforce preparedness and training, while recommending additional
documentation in future filings. Avista agrees that providing clearer summaries can aid
regulatory review and is supportive of including wildfire specific training summaries as
well as a table, including identifying the role, number of people, training date, and type of
training completed.
Staff Recommendation #3 - Staff (and IDL) recommends that Avista include a more
detailed narrative description of wildfire risk modeling methodology within future WMP
filings, rather than relying on discovery responses. Avista agrees. While the 2026 WMP
reflects outputs from its then-current modeling framework, Avista is actively transitioning
to its new wildfire risk model developed with Aerospace Technical Services("ATS"). This
ATS model is designed to:
a Idaho Code§ 61-1803.
AVISTA REPLY COMMENTS Page 3

• evaluate wildfire risk using ignition probability and consequence analysis,
• support asset level and scenario-based assessments, and
• inform comparative evaluation of mitigation strategies.
As this model becomes operational and validated, Avista intends to include a clearer
methodology description in future WMP filings, including data sources, assumptions, and
model structure, while maintaining flexibility to refine inputs as wildfire science and data
availability evolve.
Staff Recommendation #4 - Avista acknowledges Staff s observation that transmission
and distribution (T&D) projects often serve multiple objectives, including reliability,
end-of-life replacement, load growth, and wildfire mitigation. The Company agrees that
additional transparency regarding the role of wildfire mitigation in capital projects would
be reasonable.Accordingly,in future WMP filings,Avista will include a summary of T&D
projects for which wildfire mitigation is a documented driver, including, as appropriate,
the project name, project type, primary driver(s), associated wildfire risk zone tier, and a
description of how wildfire risk considerations influenced project design, cost, or timeline.
Staff Recommendation#5-Avista agrees that additional detail regarding the weather data
sources used for situational awareness would improve transparency and completeness. The
Company utilizes a combination of Company-owned and publicly available weather station
networks. Avista will include a description of these publicly available data sources, along
with Company-owned weather infrastructure, in future WMP filings.
Staff Recommendation#6-Avista acknowledges Staff s comment regarding the level of
inspection detail provided in the 2026 WMP. The Company will consider providing
supplemental detail, such as a summary table describing inspections in more detail, where
doing so adds value and improves transparency in future WMP filings.
Staff Recommendation #7 - Avista appreciates Staff s review of the vegetation related
fault, outage, and ignition data included in the 2026 WMP. The Company will continue to
provide system level transmission and distribution vegetation related fault, outage, and
ignition summary data consistent with the approach presented in the 2026 WMP,including
the information provided in Appendix E in compliance with Order No. 52980. Further,
Avista acknowledges Staff s suggestion regarding additional data granularity and will
AVISTA REPLY COMMENTS Page 4

continue to evaluate opportunities to enhance data presentation in future WMP filings,
including the feasibility of providing line or feeder level summaries based on the data
currently captured, where practicable.
Staff Recommendation #8 - Avista agrees to keep Staff and the Commission informed
regarding wildfire-related grant applications and outcomes.The Company has no objection
to providing additional details in future WMP filings regarding grants that are actively
being pursued or awarded, as applicable.
Staff Recommendation #9 - Avista appreciates Staff s review and recommendations
regarding the use of metrics to evaluate the effectiveness of the WMP. The Company
agrees that clear and trackable metrics are important to demonstrate progress, plan
feasibility, and wildfire risk reduction. In future WMP filings, Avista will include the
metrics used to evaluate WMP programs within the applicable Plan sections and will
present the information in a format that allows for comparison across WMP filings over
time. Avista also acknowledges Staffs recommendation to consider incorporating
reliability metrics, such as SAIDI, SAIFI, CAIDI, and MAIM, particularly for inspection
and vegetation management programs. The Company will evaluate the use of these
industry-standard reliability metrics as supplemental information in future WMP filings,
where appropriate, while continuing to emphasize metrics that directly measure wildfire
risk reduction outcomes consistent with the primary purpose of the WMP.
In addition to the 9 recommendations noted above, Staff in its comments also provides a
number of suggested improvements. Generally, those improvements are in the areas related to
geographic risk assessments, drivers of ignitions, exposure bias to populated areas, confidence
bands, material failure analysis and feedback to modeling, public and government outreach,
method of line design and grid hardening, situational awareness and monitoring, infrastructure
inspection and maintenance,de-energization and line operation practices,vegetation management,
cost-benefit and risk reduction framework, and Idaho requirements and crosswalk. To not overly
burden these Reply Comments and otherwise address each of these items in detail, Avista agrees
that it will integrate Staffs suggested improvements in future WMPs.
AVISTA REPLY COMMENTS Page 5

Avista's Response to the Comments of Idaho Department of Lands
Avista appreciates the comments submitted by IDL regarding Avista's 2026 WMP. Avista
values IDL's constructive feedback and its leadership role in wildfire preparedness, mitigation,
and coordination across the State of Idaho, and agrees with the importance of collaboration among
utilities, state agencies, and local partners to advance shared wildfire mitigation objectives. IDL's
comments include a number of recommendations for Commission consideration, which the
Company addresses in turn below. Avista provides the following responses to describe how the
Plan supports coordination, alignment,and continued engagement consistent with Idaho's WSCA.
IDL Recommendation #1 - In its comments, IDL requests that the Company provide
additional descriptive narrative regarding the data used to develop its risk model to
maintain consistency of county-level cooperators responsible for developing and
maintaining County Wildfire Preparedness Plans.The Company recognizes the importance
of close coordination with local officials and agencies in support of wildfire preparedness
and emergency response, as well as the shared objective of advancing effective wildfire
mitigation efforts. The Company is in the process of implementing an updated geographic
risk analysis approach that incorporates data inputs and considerations complimentary to
those used by the State of Idaho in its State Forest Action Plan risk analysis. Accordingly,
future iterations of the Company's WMP will include additional detail describing the
modeling inputs used.
IDL Recommendation #2 - Avista appreciates IDL's comments regarding cost-benefit
analysis within the 2026 WMP. As noted, the Company completed a robust and detailed
cost-benefit analysis for undergrounding distribution facilities to better understand the
feasibility, risk-reduction value, and customer cost implications of that mitigation option.
Other wildfire mitigation measures, including vegetation management and grid hardening,
will be evaluated using the risk model going forward, with investments focused on areas
identified as having elevated wildfire ignition risk. In these higher-risk areas, Avista
believes that a"no action"alternative in the wildfire mitigation context represents the least
favorable approach. However,to illustrate the potential consequences and wildfire impacts
AVISTA REPLY COMMENTS Page 6

that could occur in the absence of mitigation measures, Avista will continue to evaluate
opportunities to enhance its analytical framework and presentation of decision-making
information in future WMP filings, consistent with data availability, methodological
limitations, and the intent of the WSCA.
IDL Recommendation #3 - As to IDL's comment regarding the influence of external
wildfire impingement and the resulting effects on system reliability, Avista believes the
WMP identifies multiple strategies intended to enhance the resilience of Company facilities
when exposed to wildfire conditions. These strategies include, but are not limited to, the
installation of fire-resistant mesh around critical infrastructure, targeted grid hardening
measures, de-energization protocols implemented in the event of wildfire encroachment,
and participation in fuel-reduction partnerships with land management agencies.
Collectively,these actions are designed to reduce damage to facilities and support safe and
reliable operation during wildfire events, regardless of ignition source. While Avista
believes the 2026 WMP addresses both internal ignition risk and system resilience during
external wildfire events, the Company will seek to enhance future WMP filings to more
clearly articulate how specific mitigation measures reduce impacts to the electric system
from external wildfires, consistent with IDL's comment.
IDL Recommendation #4 - Avista will continue to refine its standard operating
procedures, consistent with recommendations from the IDL, regarding the treatment of
marketable timber when trees or other vegetation must be removed from industrial lands.
This includes coordination with state and federal land management agencies or large
private industrial landowners, as applicable, in circumstances where fair market valuation,
appraisal, and permitting requirements may apply.5
IDL Recommendation #5 -At this time, Avista is not recommending any changes to the
certifications required for its Vegetation Management staff or contractors. The Company's
vegetation management practices are conducted in conformance with established industry
standards, including ANSI A300, the National Electrical Safety Code (NESC), and
5 Avista does not intend to establish procedures requiring the application of fair market timber valuation when
vegetation management activities are conducted within existing easements or other rights-of-way that the Company
has previously acquired and which secure the Company's right to trim or remove vegetation;vegetation management
within these areas is performed pursuant to the Company's established property rights or other prior agreements and
is necessary to maintain system safety,reliability,and wildfire risk reduction objectives.
AVISTA REPLY COMMENTS Page 7

applicable NERC vegetation management standards. These standards provide
comprehensive requirements related to vegetation clearance,pruning practices, and system
safety.
IDL Recommendation #6 - Avista recognizes the importance of county-level wildfire
preparedness planning and the value of coordination through established county fire
planning groups. The Company currently engages in local wildfire planning efforts and has
participated in recent Community Wildfire Protection Plan(CWPP)development activities
in Latah County through attendance at planning meetings and coordination with local
partners. Avista agrees that continued collaboration with county planning groups supports
alignment among wildfire mitigation efforts, improves information sharing, and enhances
the effective use of available resources. The Company intends to continue participating in
these collaborative forums and to pursue additional opportunities,as appropriate,to support
coordination with county wildfire preparedness and planning efforts across its Idaho
service territory.
In the end, the Company will continue to support fuel reduction efforts moving forward, as the
Company shares the same philosophy as the Idaho Department of Lands that reducing hazardous
fuels is a proven strategy to lessen the adverse impacts of wildfire on the customers and
communities we serve. Avista looks forward to continuing the work already underway in Bonner
and Latah Counties and, in the near future, advancing new fuel reduction projects in Shoshone
County.
Avista's Response to the Comments of PotlatchDeltic Forest Holdings,LLC
Avista appreciates the comments submitted by PotlatchDeltic regarding Avista's 2026
WMP. Avista recognizes PotlatchDeltic's stated interest in wildfire prevention and values the
opportunity to consider stakeholder perspectives as part of the Commission's review process.
However, Avista disagrees with PotlatchDeltic's recommendation that the Plan be rejected, and
provides the following responses to address the issues raised and to clarify how the Plan satisfies
the requirements of Idaho's WSCA.
AVISTA REPLY COMMENTS Page 8

1. Assertion that the Commission is Severely Limited in its Ability to Respond to a WMP
Application-PotlatchDeltic argues that the Commission can only approve or reject the WMP "in
its entirety,"' and therefore any purported flaw requires Commission rejection. While the WSCA
does direct the Commission to "approve or reject" a WMP after notice and comment, the statute
also provides robust review criteria: the Commission must ensure minimum requirements are met
and must consider public health/safety/welfare, feasibility and cost, as well as whether the plan
adequately minimizes risk and proposes to respond to fires that occur.7
The WSCA establishes a defined, substantive approval standard; it does not support
PotlatchDeltic's suggestion that the Commission is compelled to reject based on disagreement with
the weight Avista assigns to individual mitigation measures or on PotlatchDeltic's preferred
allocation of utility investments. While the Commission must decide whether the Plan meets the
statutory criteria, it retains broad authority to condition approval and oversee the implementation
of the Plan.
2. Assertion that Approval of WMP Grants "Blanket Immunity" to Avista Without
Remedy - PotlatchDeltic asserts that approval of Avista's WMP would result in "a blanket grant
of immunity for Avista's negligence...all without the ability of the injured to seek recovery or
compensation."8 To the contrary, and as identified by PotlatchDeltic, the WSCA provides a
rebuttable presumption only when the utility "reasonably implemented" the Commission-
approved plan with respect to the cause of the wildfire.' That is not blanket immunity, but rather,
a conditional, rebuttable presumption.
6 See PotlatchDeltic's Comments at p. 3.
Idaho Code§ 61-1804(1)(a)-(c).
s See PotlatchDeltic's Comments at p. 3.
9 Idaho Code§ 61-1806(1).
AVISTA REPLY COMMENTS Page 9

The WSCA expressly anticipates that a utility may be found liable and provides the
framework applicable in that circumstance.10 PotlatchDeltic's assertion seemingly ignores the
statutory function of the WSCA,which the Commission has also addressed in recent orders." The
statutory"duty"language underscores that the WSCA is a standard-of-care framework,not a grant
of immunity.
3. Assertion that Avista's WMP Is Idaho-Inapplicable or "Free Rider" in Nature -
PotlatchDeltic asserts that Avista's WMP largely reflects non-Idaho or "business-as-usual"
activities and should therefore be rejected!2 PotlatchDeltic also contends that because certain
programs (e.g., vegetation management practices) existed prior to the WSCA, Avista cannot
satisfy the WSCA's requirements. These assertions mischaracterize both the scope and purpose of
the Plan.
The WSCA does not require that every plan element be newly invented post-enactment; it
requires that each plan identify means of mitigating risk, including "preventative actions and
programs" the utility "will carry out," and that the plan be commensurate with risk and
operations.13 Avista's WMP addresses wildfire risk across its Idaho service territory using a
risk-based, data-driven framework that prioritizes mitigation measures where electric-related
wildfire ignition risk is highest.As explained in Avista's Production Request responses,mitigation
investments, including grid hardening, wood pole management, protection automation, and
vegetation management, are targeted based on feeder level wildfire risk scores derived from
Avista's current risk model. That approach is consistent with Avista's obligations under the
11 Idaho Code§61-1806(2).
11 See,e.g.,Order No. 37004(Case No.IPC-E-25-32)(summarizing Idaho Code§§ 61-1803,61-1804,61-1805,and
61-1806, and explaining that an approved WMP establishes measures and duties, while the litigation benefit is a
rebuttable presumption, which again, is available only when a utility reasonably implements the Commission-
approved WMP with respect to the cause of a wildfire.)
12 See PotlatchDeltic's Comments at p. 8.
13 See,Idaho Code§ 61-1803(3).
AVISTA REPLY COMMENTS Page 10

WSCA, which directs utilities to adequately minimize wildfire risk, not to apply mitigation
measures uniformly or without regard to relative risk.
To reiterate, the WSCA does not require that every mitigation tool be newly created or
expanded in response to the statute.Rather,it contemplates that utilities will implement reasonable
wildfire mitigation measures, many of which may build on existing programs, provided they are
reasonably implemented and responsive to identified wildfire risk. Avista's WMP does exactly
that: it describes the Company's wildfire program elements and how those elements are
implemented to protect public safety while being mindful of cost,and it states the plan incorporates
both enhanced existing programs (e.g.,vegetation management and grid hardening)and new tools
(e.g., LiDAR, satellite imaging, and WUI mapping)to assess and manage risk.
4. Concerns Res!ardin2 Distribution Grid Hardening - PotlatchDeltic argues that the absence
of planned distribution grid hardening miles in Idaho for 2026 and 2027 renders the WMP
defective. This argument ignores Avista's articulated risk-based prioritization methodology, as
required by the WSCA.
Avista explained that "High Risk Mitigated Miles" are selected based on the highest
average feeder wildfire risk scores,and that the feeders with the highest scores during this planning
period are located in dense WUI areas in Spokane County. Based on that analysis, no Idaho
distribution feeders ranked among the highest-risk feeders warranting concentration of distribution
hardening during this planning cycle. That outcome does not reflect an omission or disregard of
Idaho wildfire risk, but rather the application of a consistent, quantitative risk model across
Avista's system. The WSCA does not require that each service area receive a predetermined share
of each mitigation tool,nor does it prohibit utilities from sequencing mitigation investments based
on relative risk. Importantly, Avista's Idaho system continues to benefit from other wildfire
mitigation measures, including wood pole management, inspection and remediation, protection
AVISTA REPLY COMMENTS Page 11

automation, and vegetation management, all of which reduce wildfire ignition risk regardless of
whether linear grid hardening miles are added in a given year.
5. Concerns Regarding Transmission Grid Hardening -PotlatchDeltic characterizes Avista's
transmission grid hardening as a"free rider" activity that predates the WMP and should therefore
be disregarded. That characterization is incorrect.
Avista's WMP explicitly identifies transmission grid hardening, including steel pole
replacement and remediation identified through inspections as part of its wildfire mitigation
strategy. While Avista has historically converted transmission structures to steel over time, that
does not preclude those actions from serving wildfire mitigation objectives or being appropriately
included in the WMP. The WSCA does not exclude existing programs from qualifying as wildfire
mitigation measures, nor does it require utilities to abandon or restart long-standing safety
programs in order for those activities to "count" under a WMP. The relevant legal inquiry is
whether the measures reduce wildfire risk and are reasonably implemented, which Avista's
transmission hardening activities demonstrably do.
6. Concerns Regarding Vegetation Management - PotlatchDeltic argues that Avista's
vegetation management program is defective because Avista's approach is too narrowly focused
on WUI areas, ignores forest lands and "non-urban" areas, and inspection cycle lengths have not
changed since prior plans. This argument mischaracterizes both the WSCA and Avista's
implementation.
As explained in prior Production Request responses, Avista has enhanced vegetation
management practices within existing cycles,including expanding clearance distances and refining
risk tree treatment criteria. The WSCA requires utilities to develop and implement a vegetation
management plan as part of a WMP; it does not mandate that inspection frequencies must change,
nor does it prohibit utilities from relying on established, NESC-compliant programs that are
AVISTA REPLY COMMENTS Page 12

adjusted to address wildfire risk. Avista's vegetation management program is implemented
systemwide, complies with applicable standards, and directly supports wildfire risk reduction, all
of which satisfy the statutory requirement.
7. Concerns Regarding WUI and Treatment of Forested Lands - PotlatchDeltic asserts that
Avista's WMP improperly focuses on WUI areas and excludes forested lands. This assertion
misunderstands the Plan.
Avista's WMP addresses wildfire risk across its entire service territory,including non-WUI
areas, through system-wide measures such as pole inspection and remediation, vegetation
management, operational practices, situational awareness, and protection automation. While
certain tools,such as distribution grid hardening,are prioritized in WUI areas due to higher ignition
consequence and exposure to life and property, prioritization is consistent with the risk-based
framework contemplated by the WSCA. The WSCA does not require utilities to map or classify
all high fuel lands outside the WUI, nor does it require identical mitigation strategies for forested
areas with low population density. The WSCA requires the WMP to be developed using methods
commensurate with "the nature of the fire risk" and to identify "geographical areas" the utility
considers may be subject to heightened risk at the time of plan finalization.14 It further requires an
adequate plan to minimize wildfire risk, which Avista has provided.
8. Assertions of Vagueness or Lack of Enforceability - PotlatchDeltic contends that Avista's
WMP is impermissibly vague and lacks "specific, objective and quantifiable measures."15 To the
contrary, the WMP includes detailed descriptions of mitigation strategies, annual budgets,targets,
inspection programs, and implementation practices, supplemented by extensive discovery
responses describing how those strategies are executed in practice. The WSCA does not require
14 Idaho Code§61-1803(3)(a).
15 See PotlatchDeltic's Comments at p. 13.
AVISTA REPLY COMMENTS Page 13

rigid thresholds, prescriptive mileage requirements, or exhaustive specifications for each
mitigation tool. It requires a plan that reasonably establishes the utility's duty, which can be
evaluated for adequacy by the Commission. Avista's WMP meets that requirement and provides
program descriptions, cycles, and prioritization criteria as concrete guidance for implementation
for Commission review under the WSCA's adequacy standard.
9. Assertions of Arbitrary or Discriminatory Treatment-PotlatchDeltic argues that approving
Avista's WMP would result in an unfair or discriminatory transfer of wildfire risk. This argument
improperly reframes the statutory framework of the WSCA.
PotlatchDeltic characterizes the Plan as "discriminatory and arbitrary"because it believes
forest landowners receive fewer grid-hardening benefits than other areas, framing it as an
"uncompensated transfer of wealth. ,16 The WSCA establishes a planning-and-review framework
that is expressly risk- and cost-based, requiring a "reasonable balancing of mitigation costs with
the resulting reduction of wildfire risk" and requiring the Commission to consider feasibility and
Cost.17
PotlatchDeltic's disagreement with Avista's prioritization in the Plan is not evidence of
unlawful discrimination; the governing question under the WSCA is whether the plan meets the
minimum requirements and whether, considering feasibility and cost, it adequately minimizes
wildfire risk and proposes to respond to wildfires that occur.18 The Commission's role, not
PotlatchDeltic's, is to determine whether the Plan meets these requirements. Avista respectfully
submits that its WMP satisfies the statutory standard and, thus, should be approved.
16 Id. at p. 18.
17 Idaho Code§§61-1803(3)and 61-1804(1)(b).
18 Idaho Code§61-1804(1).
AVISTA REPLY COMMENTS Page 14

10. Modified Procedure is Appropriate - PotlatchDeltic requests evidentiary hearings rather
than Modified Procedure. Subject to IDAPA 31.01.01.203 and RP 201-204, et. seq., the
Commission has already issued its Notice of Modified Procedure, providing a mechanism for any
interested person to file written comments and, if a hearing is desired, to specifically request one
and explain why written comments alone are insufficient. PotlatchDeltic has not shown that the
statutory issues cannot be addressed through written submissions, particularly where the WSCA
itself contemplates a notice-and-comment process for Commission review.19 As such, Avista
agrees with the Commission's determination that this matter be adjudicated through Modified
Procedure.
III. CONCLUSION
Avista continues to take proactive measures to adjust to increasing wildfire risk, assessing
the magnitude of damage and loss of life. Taking actions to reduce the risk of wildfires is critical
for Avista's customers, the communities in which the Company operates, and to investors who
provide capital to the Company.
Consistent with Idaho Code §61-1803(2)(a), Avista's WMP is the product of the
Company's comprehensive assessment of wildfire risk across its service area, using approaches
and methods that are commensurate with the size and complexity of the Company's operations
and specific fire risks present within its Idaho service territory. In its 2026 WMP, the Company
has identified several actions necessary to mitigate wildfire risk and protect the public interest that
reflect a reasonable balancing of mitigation costs. With its 2026 WMP filing, Avista believes it
has met all statutory requirements of the WSCA, including demonstrating the Plan's adequacy.As
such, Avista respectfully urges the Commission to approve its 2026 WMP.
19 Idaho Code§61-1804(1).
AVISTA REPLY COMMENTS Page 15

Respectfully submitted this 30th day of April, 2026.
A�ni�
i Glogovac, ISB #13010
Counsel for Regulatory Affairs
AVISTA REPLY COMMENTS Page 16

CERTIFICATE OF SERVICE
I HEREBY CERTIFY that I have this 301h day of April, 2026, served the foregoing Comments
upon all parties to Case No. AVU-E-25-15, through electronic mail:
Commission Staff: Potlatch:
Jeff Loll Peter J. Richardson
Deputy Attorney General Richardson Adams, PLLC
Idaho Public Utilities Commission 515 N. 27th Street
P.O. Box 83720 Boise, ID 83702
Boise, ID 83702-0074 petergrichardsonadams.com
Jeff.lolla,puc.idaho.gov
Michele Tyler, Esq.
Monica Barrios-Sanchez Wade Semeliss
Idaho Public Utilities Commission Brian Schlect, Esq.
11331 W. Chinden Blvd Anna Torma
Building 8, Suite 201-A michele.t lerkpotlatchdeltic.com
Boise, ID 83714 wade.semeliss(kpotlatchdeltic.com
secretgakpuc.idaho.gov brian.schlect(kpotlatchdeltic.com
anna.torma(kpotlatchdeltic.com
Is/Athena Allen
Athena Allen
Regulatory Affairs Analyst