20260514Staff Comments.pdf

RECEIVED
May 14, 2026
KELSEA E. ROSS IDAHO PUBLIC
DEPUTY ATTORNEY GENERAL UTILITIES COMMISSION
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83702
[phone]
IDAHO BAR NO. 12050
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF KOOTENAI )
ELECTRIC COOPERATIVE,INC.'S ) CASE NO. C07-E-25-01
APPLICATION FOR APPROVAL OF ITS )
2026-2028 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,Kelsea E. Ross, Deputy Attorney General,
submits the following comments.
BACKGROUND
On December 31, 2025, Kootenai Electric Cooperative, Inc. ("Company") applied to the
Commission requesting approval of its 2026-2028 Wildfire Mitigation Plan ("2026 WMP"), in
accordance with Idaho Code § 61-1801, et seq. Wildfire Standard of Care Act ("WSCA").
Under Idaho Code § 61-1803(2)(b), the Company has opted to file its 2026 WMP for
Commission approval. As the Company is an unregulated utility, the Company is not required to
file a wildfire mitigation plan("WMP") for Commission approval.
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. 36911. No petitions to intervene were filed.
STAFF COMMENTS 1 MAY 14, 2026

STAFF ANALYSIS
Pursuant to Idaho Code § 61-1804, Staff reviewed the 2026 WMP and believes it meets
the requirements of the WSCA, Order No. 36774, and the Commission WMP Guidelines, detailed
in Order No. 36774 Exhibit No. 1 and Order No. 36929 ("Guidelines"). Staff also reviewed the
2026 WMP to ensure: (1)it is consistent with public health, safety,and welfare; (2)it was feasible
and provided the cost of its implementation; and(3)whether it adequately minimizes wildfire risk
and proposes to respond to wildfires that do occur.
The Guidelines require the WMP to include the following sections consistent with the
WSCA: (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. Order No. 36774. Additionally, the
Guidelines require an update of lessons learned from previously approved WMPs, and a
breakdown of each program category's forecasted costs by year for both capital and operation and
maintenance ("O&M")expenditures. Id. Staff s review of these requirements are discussed in the
respective sections below.
Additionally, Order No. 36774 required the Company to file a Need to Know Document as
part of this WMP filing, provide a copy of its notice to interested parties of this WMP filing, and
create its WMP using a three-year planning horizon that includes a section that describes how the
electric corporations addresses each of the Commission's Orders and Staffs recommendations.
Staff reviewed each of these items and believes the Company has met these requirements.
Staff recommends the Commission issue an order that (1) approves the Company's 2026
WMP, (2) clarifies that the Company may file its updated WMP for the Commission's annual
review on or about December 31s' each year, and (3) directs the Company to include additional
information in future WMP filings, if the Company opts to file again for Commission approval.
Although Staff believes that the Company's 2026 WMP meets the requirements, Staff offers
suggestions for additional items to be included in future WMP filings as discussed below.
Commission Authority
Throughout the discovery process with Staff in this case,the Company claimed on multiple
occasions that Staffs requests for information went beyond the scope of this proceeding. See
STAFF COMMENTS 2 MAY 14, 2026

Response to Staff Production Request Nos. 1, 2, 5, 6, and 13a. For instance, in Staff Production
Request No. 5, Staff requested the Company provide any lessons learned from the Company's
inspection process and an explanation of how those lessons have influenced revisions or updates
to inspection criteria, as part of Staffs analysis of Idaho Code § 61-1803(3)(g)(i) and the
Guidelines. As this information was not included within the 2026 WMP, Staff could not evaluate
whether the Company had been adapting its inspection procedures based on past inspections.
Although the Company objected due to the Company's assumption that information prior to the
Company's implementation of its 2026 WMP was not relevant, the Company provided a high-
level response to Staffs request.
Under the WSCA,the Commission is tasked with approving or rejecting WMPs filed with
the Commission. Idaho Code § 61-1801, et seq. This means the Commission has jurisdiction to
review WMPs submitted with the Commission for approval. Id. The Commission must confirm
that a WMP meets the minimum requirements set forth in Idaho Code§61-1803 and must consider
the factors outlined in Idaho Code § 61-1804(1)(a)-(c). Idaho Code § 61-1804(l). The WSCA
requires the Commission to ensure that a WMP is "developed using approaches and methods that
are designed to protect the public interest and are reflective of and commensurate with the size and
complexity of the electric cooperation's operations and of the nature of the fire risk." Idaho Code
§ 61-1803(3).
The WSCA states that
[a]n electric corporation that is not a public utility, including but not limited to a
cooperative association distributing electric power to its members or a municipal electric
distribution system under section 50-342, Idaho Code, may adopt and file a wildfire
mitigation plan with the commission for its review at any time permitted by the
commission.
Idaho Code § 61-1803(2)(b) (emphasis added). Staff interprets this language to mean that
it is optional for a cooperative association to submit a WMP for Commission-approval. Idaho
Code § 61-1803(2)(b). The Guidelines established a filing schedule and set forth guidelines and
essential components for WMPs. Staff believes that once a cooperative association files a WMP
with the Commission, review of the cooperative's WMP is subject to the requirements set forth in
Idaho law, the Guidelines, essential elements of WMPs adopted in the Guidelines, and additional
requirements based in the Commission's authority. Without responding to Commission direction
in future filings, Staff may be unable to recommend the Commission approve a future WMP.
STAFF COMMENTS 3 MAY 14, 2026

2026 Wildfire Mitigation Plan Overview and Cross Cutting Elements
The Company requested the Commission approve its 2026 WMP and find that its WMP is
consistent with Idaho Code § 61-1804(1). Application at 1 and 12. In this overview section, Staff
provides general observations regarding the Company's 2026 WMP. This overview is organized
into three main areas: (1) Cost Feasibility, (2) Cross Cutting Elements, and(3) Comparison to the
Company's 2024 WMP. 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.
Cost Feasibility
Cost Forecasts. Idaho Code§ 61-1804(1)(b)requires the Commission to consider the cost
of the WMP implementation and the Guidelines require the Company to provide a breakdown of
each program category's forecasted costs by year for both capital and O&M expenditures across
the horizon of the WMP. Guidelines at 8. The Company provided cost forecasts for the following:
Vegetation Management Implementation Plan ("VMIP"), Construction Work Implementation
Plan ("CWIP"), and System Inspection Implementation Plan ("SIIP") (collectively the "Cost
Forecasts"). 2026 WMP at Appendix A-1,Appendix B,and Appendix C. Staff notes that the Cost
Forecasts do not clearly specify wildfire-related expenses.
In 2026, the Company forecasts $5.7 million for vegetation management, $219,981 for
system inspections, and $66.3 million for CWIP. Id. The primary capital investment categories
are substation upgrades with an estimated cost of$7.74 million,conversion and line upgrades with
an estimated cost of$7.72 million, and transmission line projects with an estimated cost of$7.57
million. 2026 WMP Appendix B. Table No. 1 below summarizes the Cost Forecasts from the
2026 WMP.
STAFF COMMENTS 4 MAY 14, 2026

Table No. 1: Cost Forecasts Summary
$in (`000s) =2026 2027 2028 3-Year Total
VMIP $ 5,686,609 $ 5,857,207 $ 6,032,923 $ 17,576,739
SIIP $ 219,981 $ 233,180 $ 247,170 $ 700,331
CWIP $ 52,130,155 $ 40,711,820 $ 31,812,692 $ 124,654,667
TOTAL $ 58,036,745 $ 46,802,207 $ 38,092,785 $ 142,931,737
Identifying Wildfire Expenditures. Wildfire-related projects are not clearly identified in
the provided Cost Forecasts. 2026 WMP Appendix A-1, Appendix B, and Appendix C. In a
meeting with Staff,' the Company represented that due to its service territory,it considers wildfire
mitigation in all aspects of its daily operations and therefore could not isolate costs for only wildfire
mitigation. Staff recognizes the challenge of separating the costs for wildfire-related projects from
a company's daily operations; however, Staff believes the Company has demonstrated that it is
able to narrow down the projects that are related to wildfire mitigation in its CWIP. Response to
Staff Production Request No. 1 Item I-Exhibit A.
For example, in the CWIP, Project 300-2026-16 is to convert an existing overhead line to
underground line, with the identified benefit to increase capacity,mitigate downed conductor, and
mitigate fire risk. Id. (emphasis added). Another example is Project 603-2026-07 that is
replacing older reclosers with new Gear and Willams Electric Viper reclosers, with an identified
benefit of providing better functionality for outage management and fire mitigation.Id. Not every
project listed in the CWIP involves work for mitigating wildfire risk. Id. Thus, Staff believes the
Company has demonstrated it can identify which of its projects are related to wildfire mitigation,
and which are not, and therefore can then determine the costs associated with wild-fire related
projects. For these reasons, Staff recommends the Commission direct the Company to provide
detailed,wildfire-related project-level cost forecasts for each year as part of all future WMP filings.
1 Staff met with the Company on February 5,2026.
STAFF COMMENTS 5 MAY 14, 2026

Grants. The Commission must consider the cost of implementing WMP expenditures.
Idaho Code § 61-1804(1)(b). Thus, information on funding alternatives and sources is necessary
to evaluate the cost and feasibility of the Company's planned actions. This information is
necessary because grant funding may impact the cost feasibility of wildfire projects and informs
the Commission on the Company's cost of implementing WMP expenditures. The 2026 WMP
did not discuss any grants that the Company was awarded or applied for. However, in its response
to Staff Production Request Nos. 15 and 16, the Company provided some information on grants
the Company applied for as part of its wildfire mitigation efforts. Id. As the Company was able
to provide grant information in discovery, Staff believes the Company provided the required
information on cost of implementing WMP expenditures. Therefore, Staff recommends the
Commission direct the Company to provide details of all funding alternatives and sources pursued
within future WMPs.
Cost-Benefit Approach. Idaho Code § 61-1804(1)(b) requires the Commission to
consider the feasibility of a WMP and the cost of its implementation. In Order Nos. 36774 and
36882, the Commission directed electric cooperations to include a cost-benefit analysis within its
WMPs and provided guidance on the information necessary to support its analysis.
Staff believes the 2026 WMP meets the requirements of Idaho Code § 61-1804(1)(b) and
the Guidelines because the Company provided some risk mitigation information in meetings with
Staff and in responses to Staff s production requests. See Response to Staff Production Request
No. 1. However, the 2026 WMP does not include the wildfire risk mitigation benefits within the
plan. Staff believes this information should be incorporated in the 2026 WMP itself because it is
required under Idaho Code § 61-1804(1)(b) and Order Nos. 36774 and 36882. Staff recommends
the Commission direct the Company to include wildfire risk mitigation benefits in future WMP
filings,while applying a consistent,transparent,and repeatable methodology across projects. Such
consistency is necessary to evaluate whether projects are prioritized using comparable criteria.
Additionally, if qualitative benefits are applied, the Company should define them, provide the
efficacy of mitigating wildfire risk, and consider quantifying the risk reduction associated with
specific infrastructure mitigation measures.
STAFF COMMENTS 6 MAY 14, 2026

Cross Cutting Elements
Targets and Goals within WMP. Appendix A-1 and Appendix B to the Application
identify targets(i.e., objectives)for vegetation management and system inspections. Additionally,
in response to Staff Production Request No. 1 Item 1-Exhibit A, the Company provided a list of
specific targets for the Company's CWIP projects. Staff appreciates the Company's work to
identify some objectives for each identified project because it helped Staff review the feasibility
of the proposed 2026 WMP. However, targets were only provided for some wildfire mitigation
efforts, for instance vegetation management, system inspections, and CWIP projects, but not for
the remaining categories of its WMP. Specifically, the Company did not provide targets for its
risk assessment, situational awareness, outreach and communications categories in its WMP. See
2026 WMP at 21 and 49-50. Only providing targets for some efforts but not across all categories
of the WMP,hinders the Commission's ability to review and evaluate the feasibility of an electric
corporation's wildfire mitigation efforts. Staff suggests that the Company add measurable targets
to future year objectives for each category of a WMP in future filings,where possible,to aid in the
Commission's review of feasibility of mitigation efforts.
Metrics. Idaho Code § 61-1804(1)(b)-(c) requires the Commission to evaluate the
feasibility of the WMP and to what degree it minimizes wildfire risk. Staff believes the Company
provided sufficient detail through discovery with Staff to what is required by Idaho Code § 61-
1804(1)(b)-(c) because it supplied information on the Company's metrics for measuring and
tracking the efficacy of its grid hardening efforts. Response to Staff Production Request No. 11.
Although the Company provided some targets, Staff believes that the 2026 WMP lacks sufficient
metrics to track efficacy of all the Company's wildfire mitigation efforts and thus there is room
for improvement in for future WMP filings. One way Company's future WMP filings can support
this analysis is through providing information on metrics that can be used to describe or quantify
the impacts of its WMP.
Additionally, Staff believes industry-standard metrics, including, System Average
Interruption Duration Index ("SAIDI"), a System Average Interruption Frequency Index
2 SAIDI represents the total number of minutes of interruption the average customer experiences.
STAFF COMMENTS 7 MAY 14, 2026

("SAIFI"),3 Customer Average Interruption Duration Index("CAIDI"),4 and Momentary Average
Interruption Frequency Index("MAIFI")may help the Company track reliability as it implements
its 2026 WMP. 5 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.
Accordingly, Staff believes the Company should consider tracking and reporting on three years of
these metrics at the system and circuit levels in future WMP filings.
Staff believes these metrics and the data collected are necessary to be included within the
WMP as they display the feasible measurable targets for the Company to implement. In the
Company's 2024 WMP,the Company identified different metrics that could be used to help show
the efficacy of its WMP. Therefore, if the Company chooses to file future WMP filings, Staff
recommends the Commission direct the Company include all metrics used within each respective
section of future WMPs and provide the data in a format that can easily be tracked across WMP
filings. Additionally, where feasible, Staff suggests the Company include three or more years of
metric data in future WMP filings to allow trends to be identified.
Filing Date. Idaho Code § 61-1803(2)(a) gives the Commission the authority to stagger
the filing dates of electric corporation's WMPs. Further, Order No. 36774 directed electric
corporations to file updated WMPs for annual review one year after the filing date of the previously
approved WMP. Through communication with Staff,the Company stated it would prefer to keep
its annual WMP filing on December 31 of each year.
Staff has no concerns with this filing date as it staggers the filing dates from the other two
large IOUs filing date requests.6 Staff recommends the Commission issue an order that clarifies
the Company's annual update WMP filing must be submitted on or about December 31 of each
year.
3 SAIFI represents the average number of times a customer experiences an outage during the year.
a CAIDI is the average number of minutes it takes to restore non-momentary electric interruptions.
5 MAIFI is the average number of momentary interruptions that a customer would experience during a given period
(typically a year).
6 In Case No.IPC-E-25-32,Idaho Power requested an annual filing date on or about October 1 each year. In Case
No.AVU-E-25-15,Avista requested an annual filing date on or about November 1 each year.In Case No. PAC-E-
25-22, Staff recommended Rocky Mountain Power have an annual filing date on or about December 1 each year.
STAFF COMMENTS 8 MAY 14, 2026

Comparison to the 2024 WMP
Prior to filing the 2026 WMP with the Commission, the Company had previously created
and filed its 2024 WMP in Washington.7 Although the 2024 WMP did not include any cost
forecasts, it did include limited descriptions of the Company's then-current process for mitigating
wildfire risk throughout the WMP. 2024 WMP at 5-8. Additionally,the Company represented in
its 2024 WMP that it planned to: (1) assess the WMP after fire season and prior to the start of fire
season; (2) install additional line reclosers with high-impedance fault detection; (3) work with
Overstory to identify hazard areas to assign target trimming and inspections; (4) enhance its
inspection program with a new approach to right-of-way clearing; (5)continue improvement based
on staff performance; and (6) partner with local Office of Emergency Management and Fire
Districts.2024 WMP at 6-10. In the 2026 WMP,the Company included more detailed descriptions
of its current processes for mitigating wildfire risk throughout the WMP and showed
implementation of its planned updates identified in the 2024 WMP. 2026 WMP at 6-20.
The 2024 WMP also included metric tables for: (1) external risk metrics; (2)performance
metrics; and (3) outcome metrics. 2024 WMP Appendix A. These 2024 WMP tables were not
included within the 2026 WMP. Staff believes each table includes metrics that may be useful to
include in future WMPs due to the reasoning discussed in the "Metrics" section of Staff s
Comments.
Geographical Risk Assessments
Idaho Code § 61-1803(3)(a) and the Guidelines require all WMPs to include a description
of the Company's wildfire risk assessment and a map of identified risk areas. Staff believes the
Company has followed a reasonable modeling approach to assess the wildfire risk in its service
territory and has met these requirements, based on information provided in a meeting with Staff
and in its 2026 WMP. 2026 WMP at 3-6. However,Staff believes there are areas for improvement
due to: (1) limitations to the Company's risk modeling; and(2) a lack of a detailed description on
how the Company's model distinguishes the levels of wildfire risk in its Heightened Risk Area
Map, as discussed below.
Kootenai Electric Cooperative 2024 WMP.https:Hdnr.wa.gov/sites/default/files/2025-05/rp_uwfpac plan kec.pdf.
(last visited April 21,2026).
STAFF COMMENTS 9 MAY 14, 2026

Limitations of Risk Modeling
In Section 2.1 of the 2026 WMP, the Company briefly describes how it modeled wildfire
risk in its service territory. 2026 WMP at 5-6. The Company's current process utilizes the United
States Forest Service's Wildfire Risk to Communities data set layered with the Company's service
territory's vegetation fuels mapped by the Company's third-party vendor, Overstory.8 2026 WMP
at 5-6. Both data sets use similar vegetation data of the same area as an input. Staff is concerned
that the Company's current process may be overweighting the vegetation risk in the Company's
service territory. However, given the size and complexity of the Company as a cooperative, Staff
believes this risk modeling approach appears to be reasonable so long as this limitation is
acknowledged.
Separately, Staff believes that the Company's approach to risk modeling considers the
existing wildfire risk due to external factors;however, Staff believes the Company's risk modeling
is limited by not considering the risk of ignition. The Company's risk assessment process does
not consider the Company's infrastructure risk to creating wildfire. Understanding and modeling
the infrastructure risk would enable the Company to identify where to focus investments in its
system, in addition to risk from external factors such as vegetation. Staff recommends the
Commission direct the Company to narratively explain how certain mitigation activities (such as
grid hardening efforts)are reducing wildfire risk, as the Company's model for the 2026 WMP will
not show any reduction of risk based on investments in the system.
Heightened Risk Area Map
As required by the Guidelines, Figure 3 of the 2026 WMP depicted the Company's
heightened wildfire risk areas. 2026 WMP at 6. However,there are limitations with this map and
its description in the 2026 WMP. Firstly,the map does not clearly identify the heightened wildfire
risk areas within the Company's service territory, as the service territory boundaries are not
included. Id. Secondly, the description within the 2026 WMP does not clearly explain how each
of the wildfire risk zones are determined(i.e., there are no risk scores distinguishing the levels of
risk or explanation of how each level was determined). For clarity, Staff recommends the
s The Wildfire Risk to Communities data set is a public data, one of the inputs is the vegetation fuel risk as provided
by LANDFIRE data.htips://wildfirerisk.org/wp-
content/uploads/2024/05/WildfireRiskToCommunities_V2_Methods_Landscape-wideRisk.pd£ (last visited April
21,2026).
STAFF COMMENTS 10 MAY 14, 2026

Commission direct the Company to overlay its service territory boundaries on the heightened
wildfire risk map and provide a more detailed explanation of how each risk zone is determined in
future WMP filings.
Additionally, in a meeting with Staff, the Company described how it divides its territory
and how each section is prioritized; however, this was not described within the 2026 WMP. This
information would be beneficial to include within WMPs, as it describes how the Company is
prioritizing its wildfire-related investments in its service territory. Therefore, Staff recommends
the Commission direct the Company to narratively explain how the Company divides its territory
and explain how it prioritizes wildfire-related projects within each section in future WMP filings.
Optional Preventative Actions and Programs
In addition to the required elements for a WMP, the Guidelines state that an electric
corporation may include other actions or programs,such as system hardening strategies,workforce
preparedness, and pilot programs. Guidelines at 3-4. In a meeting with Staff, the Company
represented that it does not have any pilot programs at this time. Staff believes system hardening
strategies correlate with the required information under Idaho Code § 61-1803(3)(e), therefore,
Staff discusses system hardening in the "Method of Line Design and Grid Hardening" section
below. The Company incorporated workforce preparedness in its WMP efforts.
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. Within the 2026 WMP, the Company did not provide much detail on its
workforce preparedness. However, the Company provided details and descriptions on its
workforce preparedness in its response to Staff Production Request No. 6. Staff believes the
Company's response to Production Request No. 6 sufficiently meets the Guidelines'
recommendations. Staff believes the Company should consider including a table identifying
employee roles,number of personnel trained,training frequency(i.e.,date,month, or quarter),and
topics or focus areas of the completed training in future WMP filings.
STAFF COMMENTS 11 MAY 14, 2026

Public Outreach, Engagement, and Community Education
Idaho Code § 61-1803(3)(c) and the Guidelines require each WMP to include how the
utility maintains community outreach and public awareness before, during, and after wildfire
season. Staff believes the Company's 2026 WMP meets the requirements of Idaho Code § 61-
1803(3)(c) and the Guidelines. The Company communicated about its WMP, including its Public
Safety Power Shutoff("PSPS") program, through members, employees, the public, media, and
other stakeholders. 2026 WMP at 17. The Company should continue refining and updating its
public outreach, engagement,and community education as necessary for inclusion in future WMP
filings.
Government Outreach
Idaho Code § 61-1803(3)(d) and the Guidelines require each WMP 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 2026 WMP satisfies
these requirements because prior to May 1 of each calendar year, the Company has an Annual
Coordination Meeting on wildlife preparedness and emergency response plans where federal,state,
tribal, and local officials and agencies coordinate on wildfire preparedness. 2026 WMP at 18.
Staff believes the Company should identify coordination with specific federal, state, local, and
tribal organizations, preferably in a table or appendix within the WMP. While none were
mentioned in the WMP, if there are any current and planned partnered projects with entities, Staff
suggests providing a detailed description of each current and planned partnered project in future
WMP filings.
Method of Line Design and Grid 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. Specifically,this description must include a cost-benefit evaluation and how the utility
identifies, selects, and evaluates projects.Id.
As stated earlier, the Company provided its CWIP cost forecast, which was developed to
implement its Construction Work Plan.Response to Staff Production Request No. 1 Item 1-Exhibit
A. The CWIP outlines a multi-year grid modernization strategy that incorporates wildfire
STAFF COMMENTS 12 MAY 14, 2026

mitigation as one dimension of its decision-making, along with system reliability, safety, capacity
expansion, and meeting new service needs. 2026 WMP at 26. Staff believes the cost forecast
summary provided in the 2026 WMP was insufficient to satisfy the requirements.
However, the Company provided a more detailed list of projects in its response to Staff
Production Request No. 1 Item 1-Exhibit A. The detailed plan includes targeted infrastructure
upgrades, advanced protection technologies, system hardening, and enhanced operational
capabilities to support both long-term reliability and reduced wildfire risk. Id. Additionally, it
includes targets, an explanation of benefits, and alternatives considered for each project category.
Id. With the additional information provided by the Company, Staff believes the Company has
met the requirements to provide a description of the Company's methods of line design for new
lines and planned system upgrades. Because said information is required under WSCA and the
Guidelines, Staff recommends the Commission direct the Company to include similar project-level
details including the targets, explanation of the benefits, and alternatives considered for each
project in future WMP filings.
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. The Guidelines specifically 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. Section 4.1 and 4.3.1 of the
2026 WMP describe the Company's current weather monitoring process. Staff believes the
Company has met the requirements based on the information within the 2026 WMP and in its
response to Staff Production Request 13(b); however, Staff believes there are areas for
improvement in future WMP filings as described below.
Tempest Daily Situational Awareness Tool
The Company utilizes the Tempest Daily Situational Awareness Tool to monitor daily
weather. 2026 WMP at 8. Figures 4, 5, and 6 within the 2026 WMP depict the tool, provide a
summary of the outputs, and operational changes based on the model. 2026 WMP at 9-11.
However, the Company does not robustly describe the tool in its 2026 WMP or provide details of
the inputs for the model. Providing a clear description of the tool and its inputs would enable a
STAFF COMMENTS 13 MAY 14, 2026

more thorough review to ensure that the tool is producing data that reflects accurate weather
conditions. For transparency and clarity, Staff suggests the Company include additional details of
the inputs for the Tempest Daily Tool within future WMP filings.
Tempest One- Weather Stations
The Company's 2026 WMP does not include a narrative describing its weather station
network, nor does it provide the current status of its network or any planned installations.
However, in response to Staff Production Request No. 14, the Company stated it plans to install
additional weather stations at local fire stations within its service territory. Without this
information in the 2026 WMP, Staff believes the Company is excluding a portion of its efforts to
reduce wildfire mitigation from its 2026 WMP which hinders the Commission's ability to review
the 2026 WMP's feasibility. To adequately evaluate this program in a future WMP filing, Staff
recommends the Commission direct the Company to include additional details about its weather
station network, including areas of focus, average cost, and any metrics it will use to evaluate
success of the network. Additionally, Staff suggests the Company include the targeted amount of
weather station installations in future WMPs for transparency and to aid in the Commission's
review of the WMP's feasibility.
Infrastructure Inspection and Maintenance
Idaho Code §§ 61-1803(3)(b), 61-1803(3)(g)(i), and the Guidelines require discussion of
the frequency and standards for inspections of each type of electric infrastructure within areas of
elevated wildfire risk and targets or goals to be achieved within the WMP. 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 and based on the Company's responses to Staff Production
Request Nos. 7, 11, 12, and 13(a), Staff believes the 2026 WMP meets the WSCA and Guidelines
requirements for electric infrastructure inspection standards and frequency. However, Staff has
identified areas for improvement in future WMP filings described below.
STAFF COMMENTS 14 MAY 14, 2026

Deficiency Monitoring
The Company stated that it assigns a priority to identified deficiencies but currently lacks
the capability to generate reports showing the time elapsed from creation to remediation. Response
to Staff Production Request No. 13. Staff believes that correcting inspection deficiencies in a
timely manner according to respective priorities is essential to protect safety and system reliability.
However, without the ability to measure how long a deficiency has been open, Staff believes the
Company cannot determine whether issues are being addressed within the appropriate timeframes,
whether certain priority levels are falling behind, and prevents the Company from effectively
monitoring overdue deficiency trends. Staff believes that a growing number of overdue
deficiencies that remain open for extended periods is a key indicator that additional resources or
process adjustments may be needed to prevent risks from escalating. Because the Company cannot
currently track or report deficiency age, Staff believes it is unable to identify overdue deficiencies
or confirm that remediation activities are keeping pace with identified issues. Staff recommends
the Company evaluate options to enhance its processes so that it can generate reports capable of
identifying backlog trends and supporting timely remediation.
Quality Assurance
Staff believes a Quality Assurance ("QA") program for infrastructure maintenance is
essential because it verifies that completed corrective work truly resolves identified issues,
ensuring safety,reliability,and accountability in the utility's maintenance practices. The Company
described its QA for vegetation management on page 25 in Appendix A of its 2026 WMP.
However, Staff believes the Company should also describe the QA process for each of its
inspection programs in a similar manner,including the scope of QA audits(e.g., 100% in high fire
risk areas, or 20% sample of all-service-area work), the frequency of audits (e.g., weekly,
monthly), and the process for addressing any items that failed to meet the Company's standards in
future WMP filings.
De-Enemization and Line Operation Practices
Idaho Code §§ 61-1803(3)(b), 61-1803(3)(g)(ii), and the Guidelines require each WMP to
include descriptions of de-energization protocols and line operation practices. Idaho Code § 61-
1803(3)(g)(ii) and the Guidelines specifically require the Company to describe its standards,
STAFF COMMENTS 15 MAY 14, 2026

criteria, and operational protocols for de-energization, including PSPS. Staff believes the 2026
WMP PSPS process meets the requirements of Idaho Code § 61-1803(3)(g)(ii) and the Guidelines
because the Company provided clear criteria that is considered within the different stages of a
PSPS 2026 WMP at 12-17. The Company should continue to evaluate and improve PSPS
procedures to ensure public safety objectives are met while minimizing disruption to customers.
Vegetation Management
Idaho Code § 61-1803(3)(g)(iii) and the Guidelines require each WMP to include a
discussion of vegetation management and enhanced vegetation management for heightened fire
risk areas. In a meeting with Staff, the Company shared that most of its service area is classified
as a heightened risk area; thus, it applies enhanced vegetation management to all areas. 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 of potential improvement in the Company's future WMP filings as
described below.
Vegetation Management Training
The Company stated that its vegetation management is done according to standards that
include ANSI A300 and the International Society of Arboriculture ("ISA") guidelines.
Application at 7. These standards address clearances, tree/shrub conditions, how to safely and
appropriately prune or remove vegetation, and vegetation health.
In a meeting with the Company, the Idaho Department of Lands ("IDL"), and Staff, IDL
mentioned the Company's vegetation management standards do not cover the ignition potential or
fire propagation perspectives of vegetation. IDL specifically mentioned the standards do not
address "ladder" fuels, which allow wildfires to progress from the ground to the canopy. The
Company represented it will evaluate if ISA's Wildfire Risk Reduction Qualification is applicable
and a useful way of addressing the standard gaps identified by IDL. Response to Staff Production
Request No. 9.
STAFF COMMENTS 16 MAY 14, 2026

Hazard Trees
The Company stated that it started tracking hazard trees in November 2025 and shared that
it had identified 1,110 hazard trees, had removed 89, and had 1,021 remaining to be mitigated.
Response to Staff Production Request No. 2. The Company's service territory is highly forested,
where both drought and insect infestations impact tree health and can have a pronounced effect on
wildfire risk. Staff recommends the Company continue to provide updated hazard tree data in
future WMP filings as it becomes available to monitor and establish trends to see if additional
resources may be needed to address the number of trees that are identified on an ongoing basis.
Wind Event Prioritization.During Staff s discussions with IDL regarding the Company's
2026 WMP, IDL noted that the Company's service territory experiences extreme wind events that
frequently compromise certain tree species, particularly in specific soil types. IDL explained that
trees lacking a tap root—such as lodgepole pine, grand fir, spruce, and some alpine fir—are
especially prone to becoming hazard trees after high-wind events due to weakened root structures.
Based on this information, Staff recommends the Company consider increasing the frequency of
hazard-tree inspections for a period of time in service areas affected by recent extreme wind events,
particularly in areas where the more vulnerable tree species are present.
Vegetation Management Metrics
The Company stated that its current metrics for evaluating the effectiveness of vegetation
management include the number of miles trimmed and fault and outage data attributed to
vegetation. Response to Staff Production Request Nos. 10 and 12. While the Company provided
crew vegetation management assignments by feeder in its 2026 WMP, it did not provide target
mileage for those feeders. 2026 WMP Appendix A-1 at 24. Staff recommends that the Company
include the total miles planned for vegetation management and fault and outage data for the
previous three or more years to illustrate historical trends in future WMPs. Staff believes these
metrics would allow for tracking of planned versus completed miles and establish trends that
reflect the impact of these efforts.
STAFF COMMENTS 17 MAY 14, 2026

Marketable Timber on Timber Company Land
Idaho Code § 61-1803(3)(g)(iii) requires each company to describe its process providing
timber companies compensation at fair market value for live, marketable timber identified for
removal from timber company land adjacent to the Company's Right of Way("ROW"). The 2026
WMP did not include the required information. However, the Company represented that it: (1)
works with land owners to determine fair market value compensation for any marketable timber
that needs to be removed from timber company land adjacent to the Company's ROW; and(2)that
the Company does not compensate marketable timber removed from its ROW and instead cuts
the trees appropriately so they can be used by the respective landowner. Response to Staff s
Production Request No. 4. Staff recommends the Commission direct the Company to include the
Company's process for compensating timber companies for marketable timber marked for removal
on land adjacent to Company's ROW in future WMP filings.
Quality Assurance
The Company stated that it uses drone-based Light Detection and Ranging ("LiDAR") to
audit whether vegetation management work has been completed in accordance with its
specifications, standards, and ROW requirements. 2026 WMP Appendix A-1 at 25. However,
the 2026 WMP did not specify the percentage of vegetation management work that is selected for
a LiDAR audit. Staff recommends that the Company clarify whether these audits cover 100
percent of the completed vegetation management work, or identify the sample size used (for
example, whether 25 percent of the work is audited) in future WMPs.
Coordination with Idaho Department of Lands
Idaho Code § 61-1804(3) requires the Commission to consult with the State Forester at
IDL regarding vegetation management, reduction of wildfire fuels, and other duties of the State
Forester under Title 38, Idaho Code.
On February 5, 2026, Staff met with IDL and the Company to discuss the Company's
wildfire risk assessment process, inspection process, vegetation management practices, identified
projects and cost-benefit process.
STAFF COMMENTS 18 MAY 14, 2026

On April 17, 2026, Staff met with IDL to discuss any concerns with the Company's filing
and current practices pertaining to its 2026 WMP. IDL suggested another meeting after further
review of the 2026 WMP.
On May 1, 2026, Staff and IDL met and discussed remaining concerns and
recommendations for the 2026 WMP. Staff believes it has sufficiently consulted with IDL during
its review of the 2026 WMP.
Public Comments
As of May 14, 2026, there have been no public comments filed.
STAFF RECOMMENDATION
Staff recommends the Commission issue an order that:
1. Approves the Company's 2026 Wildfire Mitigation Plan; and
2. Clarifies the Company may file its future annual Wildfire Mitigation Plan's on or about
December 31 of each year.
For future WMP filings, Staff recommends the Commission direct the Company to:
1. Provide detailed, wildfire-related project-level cost forecasts for each year;
2. Provide details of all funding alternatives and sources pursued;
3. Include wildfire risk mitigation benefits, applying a consistent, transparent, and
repeatable methodology across projects;
4. Include all metrics used within each respective section and provide the data in a format
that can easily be tracked across WMP filings;
5. Provide an explanation of how certain mitigation activities (such as grid hardening
efforts) are reducing wildfire risk;
6. Overlay its service territory boundaries on the Heightened Wildfire Risk Map;
7. Include a more detailed explanation of how each heightened wildfire risk zone was
determined;
8. Narratively explain how the Company divides its territory and explain how it prioritizes
wildfire-related projects in each section;
STAFF COMMENTS 19 MAY 14, 2026

9. Include wildfire-related project-level details that includes targets, expected wildfire
mitigation benefits, and alternatives considered within the respective sections of the
WMP;
10. Include Company's process for compensating timber companies for marketable timber
marked for removal on land adjacent to Company's ROW; and
11. Include additional details about the Company's weather station network, including
areas of focus, average cost, and any metrics it will use to evaluate success of the
network.
Respectfully submitted this 14th day of May 2026.
X�� -1
Kelsea E. Ross
Deputy Attorney General
Technical Staff. Kimberly Loskot, Karla Ducharme, and Ray McArthur
I:\Utility\UMISC\COMMENTS\CO7-E-25-01 Comments.docx
STAFF COMMENTS 20 MAY 14, 2026

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 14th DAY OF MAY 2026, SERVED
THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN CASE NO. C07-
E-25-01, BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
COMPANY.•
Thomas Maddalone
Safety Director
Kootenai Electric Cooperative, Inc.
9014 W. Lancaster Rd.
Rathdrum, ID 83858
E-mail: [e-mail]
Michael G. Andrea
General Counsel
Kootenai Electric Cooperative, Inc.
9014 W. Lancaster Rd.
Rathdrum, ID 83858
E-mail: mandreaAkec.com
PATRICIA JORDA.9, SECRETARY
CERTIFICATE OF SERVICE