20260514Reply Comments.pdf

_ROCKY MOUNTAIN 1407 West North Temple, Suite 330
POWER, Salt Lake City, Utah 84116
A DIVISION OF PACIFICORP RECEIVED
May 14, 2026
May 14, 2026 IDAHO PUBLIC
UTILITIES COMMISSION
VIA ELECTRONIC FILING
Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd.
Building 8 Suite 201A
Boise, Idaho 83714
RE: CASE NO. PAC-E-25-22
IN THE MATTER OF ROCKY MOUNTAIN POWER'S APPLICATION FOR
APPROVAL OF THE 2026-2028 IDAHO WILDFIRE MITIGATION PLAN
Attention: Commission Secretary
Pursuant to Commission Order No. 36955—Notice of Application and Notice of Modified
Procedure, issued March 5, 2026, in the above referenced matter, PacifiCorp submits reply
comments to written comments filed by Commission Staff and a member of the public.
Informal inquiries may be directed to Jana Saba, Director of Regulation, at(801) 220-2823.
Sincerely,
)A a�"'D
Joelle Steward
Senior Vice President of Regulation

CERTIFICATE OF SERVICE
I hereby certify that on this day, I caused to be served, via email, a true and correct copy
of Reply Comments in Case No. PAC-E-25-22 to the following:
Commission Staff
Erika Melanson
Deputy Attorney General
Idaho Public Utilities Commission
11331 W. Chinden Blvd.
Bldg No. 8 Suite 201-A
Boise, ID 83720-0074
erika.melansongpuc.Idaho.gov
Bayer Corporation
Thomas J. Budge Brian C. Collins
Racine, Olson PLLP Greg Meyer
201 E. Center Brubaker&Associates
Pocatello, ID 83204-1391 16690 Swingley Ridge Rd., #140
tinracineolson.com Chesterfield, MO 63017
tessa&racineolson.com bcollins(kconsultbai.com
gmeyer(d),,consultbai.com
Ethan Waltermire
P4 Production LLC
PO Box 816
Soda Springs, ID 83276
Ethan.waltermire(kbayer.com
Rocky Mountain Power
Jana Saba Joe Dallas
Rocky Mountain Power Rocky Mountain Power
1407 West North Temple, Suite 330 825 NE Multnomah Street, Suite 2000
Salt Lake City, UT 84116 Portland, OR 97232
jana.saba(&,pacificorp.com joseph.dallas(&,pacificorp.com
Data Request Response Center
PacifiCorp
datare uest acifico .com
Dated this 141h day of May, 2026. ,�
/ &U
Carrie Meyer
Manager, Discovery& Regulatory Operations
Page 1

Joe Dallas (ISB# 10330)
Tiffanie A. Ellis-Burke
825 NE Multnomah, Suite 2000
Portland, OR 97232
Telephone: [phone]
Email: joseph.dallas(d),pacificorp.com
Tiffanie.ellis-burke(kpacificorp.com
Attorneys for Rocky Mountain Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE Case No. PAC-E-25-22
APPLICATION OF ROCKY MOUNTAIN
POWER FOR APPROVAL OF ITS ROCKY MOUNTAIN POWER'S
IDAHO WILDFIRE MITIGATION COMMENTS IN RESPONSE TO
PLAN 2026-2028 COMMISSION STAFF, IDAHO
DEPARTMENT OF LANDS,AND
RUVEON,LLC
On December 19, 2025, PacifiCorp d/b/a Rocky Mountain Power ("Rocky Mountain
Power" or the "Company") submitted an application to the Idaho Public Utilities Commission
("Commission") requesting approval of its 2026-2028 Wildfire Mitigation Plan ("WMP") in the
above-referenced matter. Commission Staff("Staff'), Idaho Department of Lands ("IDL"), and
Ruveon, LLC, an affiliate of Bayer Corporation (`Bayer"), filed comments on the WMP. The
Company respectfully submits the following comments in response.
I. INTRODUCTION
Wildfire risk has intensified nationwide, posing growing threats to public safety,
communities, and electric infrastructure. In response, Rocky Mountain Power filed its 2026-2028
Wildfire Mitigation Plan for approval from the Commission on December 19,2025, in accordance
with Idaho Code § 61-1801, et seq., the Wildfire Standard of Care Act ("WSCA"), and the
guidelines established in Exhibit I of Order No. 36774 ("Guidelines"). The WMP was developed
to help guide targeted,risk-informed mitigation efforts in Idaho.The WMP reflects the Company's
commitment to working to proactively reduce wildfire risk associated with electric operations
while minimizing the impacts of wildfires—whether utility-related or external—on customers and
communities. As wildfire conditions have worsened, Rocky Mountain Power has made and
I

continues to make prudent, long-term investments to strengthen system resilience and protect
public safety in Idaho and throughout its service territories.
The WMP builds on the Company's recent operational experience and stakeholder
engagement and prioritizes situational awareness, operational readiness, and system performance
to reduce ignition risk and limit the consequences of fault events. In 2025 alone, the Company
expanded weather monitoring, enhanced risk modeling, implemented modified operating
practices, launched the Wildfire Intelligence Center, and strengthened coordination with public
safety partners. Looking forward, Rocky Mountain Power forecasts approximately $13.9 million
in additional Idaho-specific wildfire mitigation investments through 2028.1 Although no Fire High
Consequence Areas("FHCA")have been identified in Idaho to date,the WMP nonetheless reflects
continuous risk evaluation and deploys statewide operational mitigation measures and
demonstrates a balanced and prudent approach tailored to Idaho's wildfire risk profile.
IL RESPONSE TO STAFF'S COMMENTS AND RECOMMENDATIONS
In comments, Staff concludes that Rocky Mountain Power's WMP satisfies the
requirements of the WSCA,prior Commission orders, and established guidelines.2 Staff states that
the WMP is generally consistent with public safety objectives, operational feasibility, and wildfire
risk reduction, particularly given Idaho's lack of designated FHCA.3 Staff recommends that the
Commission issue an order that approves the WMP and that directs the Company to file an updated
WMP annually on or about December 1, which would appropriately stagger filings among Idaho
utilities.4
A. Areas of Interest in Idaho
Staff believes that certain infrastructure upgrades should qualify under Order No. 36045 as
an item for which the Company should analyze these mitigation projects within Areas of Interest
("AOI") in Idaho.' Staff expresses concern that AOIs may have elevated wildfire risk that can be
reasonably and proportionally mitigated and encourages the Company to evaluate and discuss
mitigation options in its next WMP.6 Staff proposes incremental vegetation management as one
potential approach to addressing wildfire risk in A0Is.7
The Company acknowledges Staff's recommendations and is in the process of updating its
wildfire risk mapping methodologies, which will transition away from AOIs and establish new
' Rocky Mountain Power 2026-2028 Idaho Wildfire Mitigation Plan("WMP"), 114.
'In re Rocky Mountain Power's Application forApproval of the 2026-2028Idaho Wildfire Mitigation Plan,Comments
of the Commission Staff,2(Apr. 30,2026)(hereinafter,"Staff Comments").
' Staff Comments,2.
4 Id.
' Staff Comments,4-5.
6 Staff Comments,9.
Staff Comments,21.
2

FHCA boundaries in Idaho. Within the FHCA, enhanced vegetation and asset management
activities will be applied where appropriate.
The Company plans to present these model updates during the pre-fire season meeting.The
Company believes this transition away from the legacy AOIs to the new FHCA will address Staff's
concerns by more clearly aligning mitigation strategies in Idaho with the locations of higher
wildfire risk.
B. Cost-Benefit Approach
While acknowledging that benefits may not always be fully quantifiable in monetary terms,
Staff believes that the Company should employ "a consistent, transparent, and repeatable
methodology across projects."g Staff believes this is necessary to evaluate whether projects are
prioritized using comparable criteria.9 Staff also recommends that estimated costs be included
when describing wildfire mitigation strategies and comparing alternatives.10
The Company agrees with Staff's recommendation and is currently developing a monetized
cost-benefit analysis to allow for consistent, repeatable comparisons between mitigation projects
where the benefits can be reasonably quantified. Included in this analysis will be a set of
assumptions regarding the economic costs associated with wildfire impact on lives, property, and
acres burned.These assumptions will be provided with the updated cost-benefit analysis to support
transparency in plan review.Assumptions regarding project costs used in this cost-benefit analysis
also will be provided. The Company provides further discussion on this topic in response to IDL
below.
C. Referenced Policies and Procedures
Staff requests the Company include copies of all referenced Company policies,procedures,
standards, and documents as attachments in future WMP filings."
The Company recognizes the importance of transparency and wants to ensure that Staff
and appropriate stakeholders have access to the information necessary to understand the
Company's wildfire mitigation practices. Many of the referenced policies,procedures, and internal
standards are dynamic documents that are reviewed and updated regularly. Including static copies
in WMP filings runs the risk that Staff or stakeholders interpret policies and procedures that may
be out of date, depending on timing. The Company's preference is to maintain a narrative
description and table of all referenced policies and procedures in the WMP, while providing the
current versions of policies and procedures upon request.
a Staff Comments, 5.
9 Id.
io Id.
" Staff Comments,6.
3

D. Measurable Targets
Staff recommends that the Company include metrics and data in the WMP to establish
measurable targets for wildfire mitigation efforts, operations, and projects. Staff recommends that
the Commission direct the Company to present this data in a trackable format across WMP filings
and include at least three years of data where feasible to enable trend analysis.12 Staff asserts the
WMP lacks sufficient detail on measurable targets for planned breaker and relay upgrades,
including goals, timelines, selection criteria, cost reasonableness, primary drivers, and expected
ignition risk reduction.13 Accordingly, Staff recommends that future WMP filings provide this
information to allow progress to be measured against the plan.14
The Company appreciates Staff's comments regarding metrics and measurable targets.The
Company agrees that metrics are important for tracking performance and will include them in
future WMP filings where available and supported by Company data or industry best practices,
along with historical data where available. However, some mitigation measures are relatively new
or evolving and do not yet have sufficient data to support reliable metrics. The Company will
continue to refine and evaluate expanded metrics as additional data becomes available. As
discussed above,model advancements are planned to include relays and breakers,including details
on selection criteria, cost reasonableness, and other listed values.
E. Key Areas for Improvement in the Company's Risk Modeling Methodology
Staff notes six issues in the Company's risk modeling methodology: (1) generation
resources are not modeled; (2) Company ignition data is not used; (3) a direct correlation between
probability of fault ("POF") and probability of ignition ("POI") is lacking; (4) grid sizing lacks
adequate resolution; (5) "loss of life" is not explicitly modeled; and (6)publicly available maps
are not yet benchmarked.15
The Company has taken action regarding improvement areas 4, 5, and 6 above as part of
its ongoing risk mapping and cost-benefit analysis updates. For improvement area 4, the updated
risk analysis used for mapping uses 270 meter grid cells, providing finer spatial resolution. For
improvement area 5, the cost-benefit analysis will include an estimation for loss of life and
significant injuries, including a monetized economic impact based on the value of statistical life
from the United States Department of Transportation. For improvement area 6,updated risk maps
are being benchmarked against publicly available datasets, including the United States Forest
Service ("USFS") Wildfire Hazard Potential, historical wildfire perimeters, and state-developed
risk maps where available.
12 Staff Comments,7.
13Id., 15-16.
14 Id.
15 Staff Comments, 10-13.
4

Improvement areas 2 and 3 are related to limited utility-caused ignition data to inform an analysis
linking faults and outages to ignition probabilities. As part of its 2027-2028 program objectives,
the Company will explore alternative data sources or modeling techniques to incorporate
underlying ignition risk drivers into the calculation of ignition probability.
With regard to the Company's lack of generation resource modeling, the Company's modeling on
wildfire risk is associated with transmission and distribution assets but does not include generation
facilities. The Company is uncertain what "generation resources" include based on the Staff
comment. At this time, the Company has not planned to add generation resources to its wildfire
risk modeling but remains committed to working with Staff to better understand the desired
outcome and potential solutions.
F. Workforce Training and Preparedness
Staff concludes that the Company has met the training requirements outlined in the
Guidelines but suggests that the Company include additional detail in future WMP filings to
describe its training program,including high-level metrics such as employee participation,training
frequency, and types of training completed.16
The Company agrees to incorporate a description of training programs and associated
metrics such as employee participation, training frequency, and the types of training completed.
The Company also retains records of training materials and attendance to be made available upon
request or audit.
G. Pilot Programs
Staff suggests that the Company include a summary of all pilot programs in future WMPs,
regardless of the state within which the Company is deploying the project. Staff recommends that
the Company include a description, estimated duration, estimated annual cost, and high-level
metrics used to evaluate performance.17
The Company agrees with Staff's recommendation to include all pilot programs,regardless
of the state in which the Company is evaluating the pilot program. The Company also
acknowledges that pilot programs should have key elements, such as descriptions and/or goals,
estimated duration, costs, and metrics.
H. Government Outreach
Staff suggests the Company consider specifying the federal, state, local, and tribal
organizations with which it coordinates,preferably in a table or appendix. Staff asserts that public
participation appears to increase when the Company partners with these organizations.
16 Staff Comments, 14.
17 Id.
5

The Company acknowledges Staff's suggestion and will incorporate a list of federal, state,
local, and tribal organizations with which we coordinate into future WMPs.
I. Weather Stations
Staff suggests the Company include planned weather station installation targets in future
WMP filings, including locations of focus, estimated costs, and alternatives considered.18
When there are weather station installations planned for the future WMP period, the
Company will include the planned weather station installation targets, locations, costs, and any
alternatives it considered.
J. Wildfire Detection Cameras
Staff recommends that future WMP filings include additional details on planned
expansions to the Company's camera network, such as locations of focus, average cost of
installation, installation timeframe, cost-benefit analysis, and alternatives considered. Staff also
recommends that the Company include information or metrics that reflect the effectiveness of
detection cameras (e.g., number of ignitions detected per total number of ignitions).19
The Company agrees to include the recommended details on planned expansions to the
camera network and available metrics if camera installations are identified for future WMP periods
in Idaho.
K. Infrastructure Inspections and Maintenance: Deficiency Backlog Monitoring
Staff suggests the Company include,in future WMP filings,the following prior three years
of data for deficiencies related to infrastructure in Idaho AOIs: (1) number of deficiencies
identified by priority category(e.g., P 1, P2); (2) number or percentage of deficiencies repaired by
priority category; (3)remediation targets by category; (4) average time to repair by category type;
and(5)pending repairs at year-end by category.20
The Company acknowledges Staff's suggestion and will be able to provide this data
relative to the newly defined FHCA in Idaho after the risk methodologies have been updated.AOIs
will become a legacy term and will not be available to report these metrics against.
L. Infrastructure Inspections and Maintenance: Ouality Assurance
Staff suggests the Company describe its quality assurance process for inspection programs,
similar to how it describes its quality assurance for vegetation management in section 3.4 of the
is Staff Comments, 17.
i9 Staff Comments, 18.
zo Id.
6

WMP. This may include the scope of audits, audit frequency, and the process for addressing
deficiencies that do not meet Company standards.21
The Company agrees with Staff's suggestion and can describe asset inspection program
quality assurance processes, scopes, and frequency, along with the processes for addressing
deficiencies.
M. Operational Practices During Heightened Wildfire Risk Days and Zones
Staff recommends that the Company include more specific information, preferably in a
tabular form,describing how workforce practices change as fire risk potential increases. Staff gives
examples, 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 of field activities.22
The Company acknowledges Staff's recommendation. There is often a measurable
difference in work practice between elevated, significant, and extreme risk and associated change
in work practice. Although there are often local agency restrictions that could result in more
restrictive application and there are certain circumstances where documented exceptions may be
supported, the Company can elaborate on the differences in work practice as risk changes.
N. Refining PSPS Protocols
Staff suggests that the Company continue refining its PSPS protocols based on planned and
executed events. Staff asserts that ongoing evaluation and improvement of PSPS procedures will
help ensure that public safety objectives are met while minimizing customer disruption.23
The Company acknowledges Staff's recommendation and is committed to continuous
improvement through established after action reports and modifications of procedures through
lessons learned. The Company has had a limited number of PSPS events but continues to perform
internal PSPS exercises. Rocky Mountain Power will refine procedures and processes as they
relate to PSPS through actual and exercised events.
O. Consideration of Pacific Northwest National Laboratory's Metrics in Wildfire
Mitigation Plans
As part of determining which new metrics to implement, Staff recommends (1)the
Company evaluate incorporating vegetation management metrics consistent with those identified
in Pacific Northwest National Laboratory's ("PNNL")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 (3) the Company report this data at the system
2i Staff Comments, 18-19.
22 Staff Comments, 19.
zs Staff Comments,20.
7

level and the circuit or feeder level.
The Company acknowledges Staff's recommendation and will evaluate the PNNL
vegetation management metrics.The Company tracks vegetation-related fault,outage,and ignition
data for both transmission and distribution systems. Rocky Mountain Power will report the data it
currently tracks in future WMPs.
P. International Society of Arboriculture's Wildfire Risk Reduction
Qualification
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.24 IDL provides similar
comment regarding vegetation inspection standards,which the Company addresses in its response
to IDL 13below.
The Company's vegetation management program is aware of and will evaluate
International Society of Arboriculture credentialing opportunities in Idaho.
Q. Staff Recommendations
In addition to the above suggestions, Staff identified areas where future WMP filings could
provide additional detail, metrics, or clarity.21 Staff suggests the Company include the following
additional items in future WMPs,26 which the Company agrees to:
1. For future filings, the Company will revise the WMP narrative to include cost
forecasts at the program level from each category, including costs for planned
projects as applicable.
2. For future filings,the Company will revise the WMP narrative to include additional
details of all funding alternatives and funding sources pursued, including the status
of those pursued opportunities.
3. For future filings, the Company will revise the WMP narrative to include metrics
to evaluate the effectiveness of each program in the WMP. The Company is
currently in the process of implementing a wildfire portfolio optimization to support
this effort.
4. For future filings, the Company will revise the WMP narrative to include
measurable targets and associated completion data where applicable.
2a Id.
21 Staff Comments,22-23.
26 Id.
8

5. For future filings,the Company will revise the narrative to include additional details
of cost-sharing opportunities pursued, as well as the status of those pursued
opportunities.
6. For future filings,the Company will revise the narrative to clarify the informal pole
wrap installations that occur outside of the wildfire mitigation budget.
7. For future filings, the Company will include a description of the publicly available
weather station data sources that the Company relies on for decision making.
III. RESPONSE TO IDL COMMENTS AND RECOMMENDATIONS
The IDL, on behalf of the Idaho State Forester, raises technical and coordination-related
concerns with the WMP.27 IDL's concerns included the topics of risk modeling, cost-benefit
analysis,assumption of wildfire risk,marketable timber compensation,vegetation inspections,and
the Company's engagement with county wildfire preparedness planning groups. The Company
responds to each concern below.
A. Wildfire Risk Modeling
IDL states it reviewed the WMP's wildfire risk modeling results. IDL expresses
reservations regarding the absence of any identified FHCA in Idaho, which IDL states is
inconsistent with its own modeling and other available analyses.28 IDL requests additional details
regarding the modeling tools, assumptions, and processes used to develop the Company's wildfire
risk maps.29
At this time, the Company has not identified wildfire risk areas in the state of Idaho and
has not completed a comparative analysis of risk areas using publicly available risk maps.
However, Rocky Mountain Power is currently updating its methodology for identifying high-risk
areas. The new methodology will incorporate publicly available data, such as the USFS Wildfire
Hazard Potential geospatial data, as inputs to the new maps for future WMP filings.As part of the
new risk map development,validation will include comparing the Company's results with publicly
available risk maps. This may include additional review of the USFS Wildfire Hazard Potential
map, the Federal Emergency Management Agency National Risk Index, and similar state-created
datasets, where such data are available and current.
The risk modeling detailed in the WMP evaluates wildfire risk at the level of individual
transmission and distribution line segments using Technosylva's FireSight wildfire risk modeling
platform. FireSight uses deterministic wildfire spread simulation models to estimate fire behavior
and propagation from potential ignition points along utility infrastructure. Model outputs include
27 In re Rocky Mountain Power's Application for Approval of the 2026-2028 Wildfire Mitigation Plan, Idaho
Department of Lands'Comments(Apr.24,2026)(hereinafter"IDL Comments").
28 IDL Comments, 1.
29 Id.
9

acres burned, buildings threatened, buildings destroyed, flame length, rate of spread, population
impacted,and fire behavior index.Each risk calculation includes three components: (1)probability
of failure, (2)probability of ignition, and(3) consequence.
Probability of fault ("POF") represents the likelihood that an asset will experience an
outage event. The model uses hierarchical logistic regression, calibrated against observed
Company outage data.Although the model does not explicitly include asset-level attributes, these
factors are implicitly captured through both the hierarchical structure and the historical outage
patterns used during calibration. Assets with characteristics associated with higher historical
failure rates (e.g., older equipment or lines in heavily vegetated areas) therefore exhibit higher
POF values.
Probability of ignition("POI")is based on the National Fire Danger Rating System Ignition
Component, which estimates the probability that a wildfire requiring suppression will develop,
given the presence burning material(such as an ember or a spark).POI reflects weather conditions,
fuel availability, and other environmental factors for a specific historical date. For example, POI
is higher on hot, dry, windy days in the middle of fire season than on cool, wet days in winter.
Consequence represents the potential damage if a fire were to occur. For each power line
segment,the model evaluates nearby ignition points and estimates the maximum potential impacts:
how many acres could burn, how many buildings could be threatened, how many people could be
affected, etc.
POF and POI are multiplied to calculate the overall likelihood:
POF POI[asset, date] = POF[asset, date] X POI[asset, date]
The product of POI and POF is then multiplied by consequence to obtain the expected risk:
Expected Risk[asset, date]= Consequence[asset, date] X POF POI[asset, date]
FireSight generates a distribution of expected risk values by running hundreds of
simulations for each asset ignition point, with each simulation using a different historical weather
scenario. The result is a matrix consisting of expected risk values for assets, dates in the analysis
range, and consequence types (acres affected, buildings destroyed, buildings threatened,
population affected, rate of spread flame length, fire behavior index). For each output, FireSight
provides a range of simulation percentiles (e.g.,p0, p50, p95, p100).
Rocky Mountain Power combines these FireSight outputs into composite risk scores
representing two primary drivers of wildfire spread and damage potential: (1)wind-driven fire risk
and (2) fuel/terrain-driven fire risk. These scores represent the relative likelihood and severity of
wildfire outcomes based on historical wind patterns, vegetation, topography, and fuel conditions.
10

Figure 1-5 of the WMP shows the specific FireSight outputs and weightings used to calculate the
wind-driven and fuel/terrain-driven risk scores, using the equation in Figure 1-6 of the WMP.
Rocky Mountain Power uses these wind-driven and fuel/terrain-driven scores to identify
FHCA. Line segments with a wind or fuel/terrain score of 0.85 or greater are designated as FHCA
segments. Lower thresholds (0.65 and 0.45) identify AOI I and AOI II segments, respectively.
Qualifying line segments are overlaid on a grid of one-by-one-mile cells; any grid cell containing
at least one line segment meeting the applicable risk threshold is included in the corresponding
FHCA or AOI zone. Using this approach,Rocky Mountain Power identified no FHCA in its Idaho
service territory because all line segment risk scores were below the 0.85 threshold.
Model verification and validation are performed through a combination of vendor model
development and internal expert review. The Technosylva model is evaluated for how accurately
it predicts real-world wildfire behavior by comparing model outputs with observed fire events.30
Internal validation involves sensitivity analyses of selected inputs and weightings used in
the wind-driven and fuel/terrain-driven risk scores. This process validates that the selected
percentiles and weightings identify circuits expected to be higher risk for wind- or fuel/terrain-
driven wildfires based on subject matter expertise.
B. Cost-Benefit Analysis of Mitigation Activities
IDL states that, although the WMP includes cost information by program category, it does
not provide sufficient cost-benefit detail to evaluate the relative effectiveness of different
mitigation investments.3 1 As discussed in Staff Response B above, a cost-benefit analysis is
currently under development and will be included in the Company's next Idaho WMP filing later
this year. This analysis will take the form of a risk-spend efficiency ("RSE") evaluation. At this
time, Idaho has no identified FHCA, and therefore, the Company has not identified any projects
that would qualify for or be evaluated through an RSE cost-benefit analysis.
C. Assumption of Wildfire Risk
IDL notes that wildfire can impact reliability and requests that the Company "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."32
The WMP includes several activities specifically intended to reduce the potential for
damage to Company assets from external wildfires on the system. The plan identifies pole
wrapping as a targeted mitigation measure to improve asset survivability during wildfire exposure.
Pole wrap may be applied in areas of elevated wildfire risk and, in some cases, installed on poles
30 This is discussed in more detail in IPUC 49.
31 IDL Comments, 1-2.
32 IDL Comments,2.
11

that are planned for future replacement with steel to provide interim protection. Pole wrapping is
designed to reduce the effects of radiant heat, direct flame contact, and ember intrusion at the base
of the pole, which are common mechanisms of damage during external wildfire events. This
protection reduces the likelihood of pole failure,downed wire events,and secondary ignition when
a wildfire burns through an area containing Company facilities.
The Company's vegetation management program provides an important layer of defense
against external wildfire impacts. While the core program is designed to minimize ignition risk by
addressing grow-in and fall-in conditions, it also reduces fuel loading adjacent to electrical
infrastructure,which can lessen wildfire intensity as it approaches the system. In higher-risk areas,
the Company implements enhanced vegetation management practices, including additional
inspections, trimming, and pole clearing, which further improve defensible spaces around assets
and reduce the potential for damage from encroaching wildfires. Should the Company identify an
FHCA in Idaho in the future, these enhanced measures would be applied accordingly.
Inspection and maintenance programs support system resilience under wildfire exposure.
The Company's inspection program is structured in alignment with industry best practices and is
designed to identify and correct conditions that could make assets more susceptible to failure
during external events. This includes identifying deteriorated poles, structural deficiencies,
missing or damaged hardware, and degraded pole wrap. By proactively addressing these issues,
the Company improves overall system integrity and reduces the likelihood that assets will fail
when subjected to the stresses associated with wildfire conditions.
Finally, the Company's emergency de-energization strategy provides an operational
response when wildfires are actively encroaching on electrical infrastructure. While de-
energization may not prevent physical damage to assets directly exposed to fire, it is an important
tool to reduce overall risk during an active wildfire event. Specifically,de-energization reduces the
likelihood of additional ignition events caused by damaged or compromised equipment, which
could otherwise exacerbate an existing fire and further threaten Company assets. It also enhances
safety for first responders and supports more effective wildfire suppression activities in areas
where electrical infrastructure is present.
A Marketable Timber Compensation Process
IDL believes that the Company should have an established process for the compensation
of marketable timber, which it states will build relationships and values associated with timbered
land.33 The Company agrees and is currently developing a procedure for compensation for
marketable timber,which it will complete by and include in the next WMP filing. In the meantime,
the Company issued a memorandum to the state forester to notify them of this requirement in the
state of Idaho.
33 Id.
12

E. Vegetation Inspections
IDL asserts that, within the vegetation inspection section, although the Company
appropriately centers its qualifications around arboriculture standards, those "standards are
insufficient at addressing wildland fire related issues when looking at vegetative mitigation as a
mechanism to reduce wildfire risk. ,34 The Company's vegetation management program is aware
of the updated International Society of Arboriculture credentialing opportunities in Idaho and is
evaluating whether these opportunities offer additional capabilities. The Company is also open to
further discussions with Staff and IDL on how it can continue to develop its vegetation inspection
section. See also the Company's response to Staff feedback regarding vegetation management
qualification standards in Staff Response P.
F. County Wildfire Preparedness Plan and Fire Planning Groups
IDL emphasizes the importance of coordinating with county wildfire preparedness
planning efforts and encourages the Company to engage more fully with local fire planning
groups.35 The Company's emergency management program is looking into the county wildfire
preparedness planning meetings to evaluate whether these meetings include any information that
the Company is not already receiving through other public safety partner coordination efforts.
IV. RESPONSE TO BAYER'S COMMENTS AND RECOMMENDATIONS
In comments,Bayer acknowledges the importance of wildfire mitigation planning. Bayer's
comments attempt to limit their scope to the statutory purpose of the WMP process under the
WSCA and to preserve Bayer's right to address cost recovery, allocation, and liability issues in a
future proceeding.
A. Purpose of WMP Proceeding
Bayer asserts that Commission approval of the WMP should be confined to prospective
planning and standard-of-care considerations and should not bear on determinations regarding the
prudence, cost recovery, or cost allocation of wildfire mitigation program costs on Idaho
customers.36 Bayer requests that any approval order expressly state it is without prejudice to future
challenges related to cost recovery and allocation.37
As an initial matter,Rocky Mountain Power is not seeking rate recovery in this proceeding.
PacifiCorp filed its application for approval of its WMP pursuant to the WSCA, codified in Idaho
Code § 61-1803. The request in this docket is for the Commission to determine that the WMP
34 Id.
35 Id.
36 In re Rocky Mountain Power's Application for Approval of the 2026-2028 Idaho Wildfire Mitigation Plan,
Comments of Bayer, 1-2(Apr. 30,2026)(hereinafter,"Bayer Comments").
37 Bayer Comments,2-3.
13

complies with the statutory requirements of the WSCA. Once approved, the WSCA states:
"Commission-approved wildfire mitigation plans shall be implemented upon approval by the
commission and shall be reviewed and updated annually."38
In response to Bayer, PacifiCorp's position is that Commission approval of a WMP has
evidentiary value in assessing whether later compliance costs with the plan are prudently incurred.
Bayer's attempt to characterize WMP approval as "mitigation planning and standard of care
compliance only" improperly limits the statute and the Commission's standard of approval for a
WMP 39 The WSCA addresses utility reasonableness in expenditures for wildfire mitigation
programs. Specifically, the legislative intent states that it is "essential" that wildfire risks are
addressed "as needed and within appropriate cost parameters so that electric power is kept
affordable to the public. ,40 The statute goes on: "This chapter is designed to direct the prudent use
of resources by electric utilities to mitigate and respond to wildfire risk within the costs that can
be justified as just and reasonable in order to keep rates affordable to utility customers and protect
Idaho residents and their property. ,41
Indeed, in approving a wildfire mitigation plan, the Commission must ensure compliance
with Idaho Code§ 61-1803,which requires,among other matters,that a WMP"reflect a reasonable
balancing of mitigation costs with the resulting reduction of wildfire risk, including: [f]inancially
prudent and reasonably practicable methods of line design for new, planned, and existing lines to
mitigate fire risk," and the Commission must consider"[t]he feasibility of the plan and the cost of
its implementation. ,42 Accordingly, approval of the Company's WMP necessarily carries
evidentiary value and regulatory significance when assessing whether the utility later acted
reasonably and prudently in implementing the approved mitigation measures it is statutorily
required to undertake.
Commission Staff's recommendations underscore why Bayer's concerns do not warrant
limiting or conditioning approval of the WMP. Staff concluded that the WMP meets all statutory
and guideline requirements and recommended approval.43 Staff noted that approval of the WMP
does not equate to approval of cost recovery and that prudence and ratemaking issues will be
addressed, as appropriate, in future proceedings.44 Rocky Mountain Power agrees with Staff, and
the record supports approval of the WMP as filed,without qualifiers that could improperly conflate
planning review with ratemaking determinations.
38 I.C.A. § 61-1803(4).
39 Bayer Comments,3.
40I.C.A. § 61-1802.
41 Id.
42I.C.A. §§ 61-1803(3)(e),61-1804(1).
43 Staff Comments,2.
44 Staff Comments,5.
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B. Compliance and Cost Recovery
Bayer states the WMP assumes costs associated with wildfire mitigation will be allocated
using traditional systemwide allocation methodologies, without demonstrating cost causation or a
state-by-state comparison of costs, risk levels and mitigation activity.45 Bayer claims systemwide
wildfire mitigation spending may be influenced by policy choices in other states served by the
Company, including standards of liability and damage claims.According to Bayer, this drives the
need for cost-causation support before wildfire-related costs are assigned to Idaho customers, a
distinction Bayer claims is necessary because"utilities sometimes cite compliance with mitigation
plans as evidence supporting later requests for cost recovery."46 Bayer asserts that while
compliance with an approved WMP may be relevant to evaluating whether actions were consistent
with the Company's asserted standard of care,it is not dispositive and should not be conflated with
whether the amount spent to implement the mitigation measures in the plan were reasonable and
if the costs should be allocated to Idaho.47 Bayer lists six factors that it claims affect cost allocation
that are not resolved by approval of the WMP in this proceeding.48
The Company disagrees with Bayer's assertion that policies in other states drive wildfire
mitigation efforts and associated costs in Idaho. The vast majority of wildfire mitigation costs are
not systemwide costs but are distribution costs that are paid for by the specific state where the
work is performed. The Company acknowledges the WMP contains some systemwide costs for
mitigation work performed on transmission lines and other items such as software modeling costs
that are shared by all of the Company's states. However it is imperative to note that the
transmission costs represented in a WMP pertain to transmission assets that are physically located
in Idaho. Idaho's WMP does not contain costs for mitigation work being performed in other states.
Cost allocation for wildfire mitigation work performed on transmission assets located in other
states will be addressed in the appropriate rate proceedings. The Company addresses each of
Bayer's six factors below.
C. Fire High Consequence Areas in Idaho
Bayer states that the absence of FHCAs in Idaho means that some mitigation measures
associated with FHCA designation are not being implemented in Idaho.49 Bayer provides examples
of increased inspection frequency, enhanced vegetation clearance, and system hardening as
potential mitigation measures that are not being implemented in Idaho.
The Company notes that while the presence of an FHCA within a state can drive mitigation
costs, it is not the only driver, and inspections and vegetation management programs are still best
practices to monitor for and mitigate wildfire risk. Costs associated with mitigation measures tied
4s Bayer Comments,2.
46 Id.
47 Id.
48 Bayer Comments,2-3.
49 Bayer Comments,2.
15

to FHCA designation in other states are not incurred in states that are not receiving those mitigation
measures. FHCA designation does not affect costs of increased inspection frequency, enhanced
vegetation clearance, and system hardening.
D. State-by-State Comparisons of Wildfire Activity and Exposure Metrics
Bayer states that the WMP does not provide state-by-state comparisons of actual wildfire
activity and exposure metrics to assist parties in evaluating relative exposure and any asserted basis
for allocating systemwide costs.50 The Company's asset risk group has actual wildfire activity and
exposure metrics per circuit embedded in its current maps for this WMP and for future WMP
filings. However, it is not a statutory requirement for the Company to include state-by-state
comparisons of wildfire activity and exposure metrics; as such, Rocky Mountain Power does not
include these in its WMPs.
E. Distribution/Transmission-Level Mitigation
Bayer notes that some mitigation efforts appear to be aimed at the distribution level instead
of the transmission level, suggesting that a transmission-level customer, such as Bayer should not
be required to pay for these costs.51
The Company disagrees with Bayer's suggestion that a transmission-level customer should
be allocated fewer costs because it does not take service at the distribution level. Wildfire
mitigation is fundamentally a public safety measure because it reduces the risk of loss of life,
protects homes,businesses, and critical infrastructure, and improves the ability of communities to
respond when fires occur.Mitigations on distribution assets benefit all of the Company's customers
as those mitigations protect the public safety as well as the critical assets needed to provide service
to all Rocky Mountain Power customers.
F. Least-Cost/Least-Risk Comparisons of Alternatives
Additionally, Bayer is incorrect when it states that the WMP must show a "robust least-
cost/least-risk comparison of alternative for each major mitigation category."52 Bayer cites no
rules, laws, or Commission orders for this position. Indeed, the Company has been unable to find
such requirements. Rather, in Order No. 36774, the Commission specifically acknowledged and
accepted Staff's decision to remove "least-cost, least-risk"requirements in its WMP Guidelines.53
Accordingly, no such requirement exists, and it would be inappropriate to direct the Company to
complete and provide such an analysis.
50 Id.
51 Id.
5'Bayer Comments,3.
51 Order No.36774, 10-11.
16

G. Idaho-Specific Needs and Cost-Causation
Bayer notes that the WMP includes changes and additions that may materially affect costs
but which Bayer believes "should not be assumed to be reasonable for Idaho absent a clearer
showing of Idaho-specific need, alternatives considered, and cost-causation-based assignment to
Idaho customers.',54
Bayer lists as examples, increased overhead visual inspections, increased minimum
vegetation clearance distances, and new initiatives such as the Wildfire Intelligence Center
("WIC"), idle line mitigation, and wildfire detection cameras.
The increase in overhead visual inspections to an annual frequency reflects a risk-informed,
operationally justified enhancement to improve reliability and reduce ignition potential across all
voltage classifications and varying risk areas.Although there is currently no designated FHCA in
Idaho, this does not mean there is no wildfire risk. Increasing inspection frequency also
standardizes inspection practices across the entire system,which improves clarity and consistency
in how Rocky Mountain Power manages transmission and distribution equipment regardless of
voltage. It also reduces confusion among field employees by clearly establishing when inspections
must be performed, independent of FHCA designation.
Concerns regarding additional costs associated with increased minimum vegetation
clearance distances are not applicable to Idaho under the current plan because the state does not
presently have an FHCA. Accordingly, the enhanced clearance standards tied to FHCA
designations are not being implemented in Idaho.
PacifiCorp established the WIC to address the increasing risk of wildfire across its six-state
service territory, including Idaho, through centralized, 24/7 situational awareness and risk
monitoring. The WIC continuously monitors a range of hazards that may threaten electric system
assets, regardless of whether those assets are located within a designated FHCA. This capability
enhances the Company's ability to make informed, real-time operational decisions, particularly
during wildfire events, by providing more precise, data-driven insights into fire behavior,
proximity to infrastructure, and evolving risk conditions. The WIC supports a more targeted
response to actions, including determining whether emergency de-energization is needed or
whether continued monitoring is sufficient, thus improving both system reliability, by avoiding
unnecessary outages resulting in customer impacts, and public safety.
As discussed in the WMP,the Company has learned that idle lines that are mutually coupled
to an energized line may become an ignition risk. Therefore, the Company has removed all idle
lines that are not currently being used as a backup for other lines that may need to be de-energized
for various reasons.
54 Bayer Comments,3.
17

Rocky Mountain Power does not currently have a wildfire camera program in Idaho. As
described in the WMP,the Company is evaluating camera installation needs in Idaho during 2026,
with potential installations in 2027 and 2028. Rocky Mountain Power plans to seek input from
various state agencies in determining final camera siting locations, including through coordination
with the Idaho Department of Lands.Additionally,the Company will prioritize existing structures
(e.g., fire lookout towers) for camera placement to improve efficiency.55 Any costs incurred for
installing cameras in Idaho's service territory will be reflected in future WMP filings.
V. CONCLUSION
The Company's wildfire risk modeling is robust, transparent, and appropriately scaled to
Idaho conditions. Nonetheless, the Company will incorporate additional publicly available data
and validation in future filings and will develop a formal marketable timber compensation process
as requested by IDL. Although Rocky Mountain Power's mitigation measures—including
vegetation management, inspections, pole wrapping, and emergency de-energization—address
both utility-caused ignitions and external wildfire threats, the Company will continue evaluating
enhanced coordination with county fire planning groups and relevant credentialing opportunities.
Additionally, the absence of designated Fire High Consequence Areas in Idaho reflects model
results rather than inaction, and state-by-state cost comparisons and least-cost/least-risk analyses
are not required. Rather, systemwide tools and centralized programs are statutorily appropriate
given the size and complexity of the Company's operations. Finally, Commission approval of the
WMP may properly inform—but does not predetermine—future prudence determinations, and
Bayer's requested limitations and disclaimers are unsupported by statute or Commission
precedent. For these reasons, Rocky Mountain Power recommends Commission approval of the
WMP as filed and demonstrates that it reasonably addresses wildfire risk in Idaho while remaining
consistent with statutory, operational, and cost-feasibility requirements.
DATED: May 14, 2026
Joseph Dallas
Attorney for Rocky Mountain Power
ss WMP,69.
18