20260520Supplemental Comments.pdf

RECEIVED
MAY 20, 2026
IDAHO PUBLIC
UTILITIES COMMISSION
John A. Richards #10670
J.J. Winters #10327
IDAHO DEPARTMENT OF LANDS
300 N. 6th Street, Ste. 103
Boise, ID 83702
[phone]
[e-mail]
[e-mail]
Attorneys for Idaho Department of Lands
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER CASE NO. IPC-E-25-32
COMPANY'S APPLICATION FOR
APPROVAL OF THE COMPANY'S 2026 INTERVENOR IDAHO
WILDFIRE MITIGATION PLAN DEPARTMENT OF LANDS'
SUPPLEMENTAL
COMMENTS
Intervenor Idaho Department of Lands ("IDL") respectfully submits the following
supplemental comments in the above-captioned matter pursuant to Idaho Code § 61-1804(3) and
Order No. 36835 on behalf of Idaho State Forester, Julia Lauch.
1. In conjunction with risk modeling, IDL strongly encourages the following data inputs to be
included in future evaluations of wildfire risk:
1. System components. Type, condition, and age of system components should be
included as these elements can significantly increase or decrease the risks associated
with wildfire ignitions or impacts from wildfire on the system.
2. Vegetative height lam. The plan should include data regarding the vegetative layer
that includes information where the surrounding tree canopy is taller than the
'The data associated with vegetative and soil layers can be publicly obtained,thus reducing the burden of data that is
needed to be developed or acquired through purchase.
INTERVENOR IDAHO DEPARTMENT OF LANDS SUPPLEMENTAL COMMENTS—1

adjacent system. Trees provide a significant strike risk to above-ground systems that
occur outside of the managed rights-of-way. The inclusion of this data will help to
significantly improve the understanding of external risk from vegetation to systems,
thus allowing for a more informed decision process related to system management
and mitigation options.
3. Soils lay. It is well-established science that certain soil types are more prone to
trees tipping or blowing over during wind events when saturated. Again, the
inclusion of this data will help to inform the decision process of management and
mitigation actions.
2. Damaging wind events occur often enough within the footprint of the service area that IDL
feels it would be prudent for future iterations of the wildfire mitigation plan to address these
exceptional events through the lens of wildfire. Specifically, how these wind events impact
the risk ratings and implementation of wildfire risk mitigation.
Respectfully submitted this 20t" day of May, 2026.
IDAHO DEPARTMENT OF LANDS
-44k'
J.J.WINTERS
Attorney for Idaho Department of Lands
INTERVENOR IDAHO DEPARTMENT OF LANDS SUPPLEMENTAL COMMENTS-2

CERTIFICATE OF SERVICE
I hereby certify that on this 20t'day of May,2026,I caused to be served a true and correct
copy of the foregoing by the method indicated below, and addressed to the following:
Idaho Power Company
Megan Goicochea Allen ❑x Email: mgoicocheaallengidahopower.com
Lisa lance llanceAidahopower.com
Tim Tatum dockets(&,,idahopower.com
Connie Aschenbrenner ttatumkidahopower.com
Riley Maloney caschenbrenner(a�idahopower.com
rmaloney(a,idahopower.com
Idaho Public Utilities Commission ❑x Email: adam.triplett(&,puc.idaho.gov
Adam Triplett secretga(d),puc.idaho.gov
Micron Technology, Inc. 0 Email: tnelson(a hollandhart.com
Austin Rueschhoff awje� nsen(d),hollandhart.com
Thorvald A Nelson karoachkhollandhart.com
Kristine A.K. Roach aclee(ahollandhart.com
tlfrielnhollandhart.com
Is/Kayla Dawson
Kayla Dawson, Legal Assistant
INTERVENOR IDAHO DEPARTMENT OF LANDS SUPPLEMENTAL COMMENTS-3