20260520Comment_1.pdf

Good morning-Attached for filing and service please find Idaho Department of Lands'
Supplemental Comments in the matter of Avista Corporation's Application for Approval of
the Company's 2026 Wildfire Mitigation Plan, Case No. AVU-E-25-15.
Kind regards,
Kayla Dawson
Legal Assistant
Idaho Department of Lands
300 N. 6t"Street, Suite 103, Boise, ID 83702
Office: [phone]
Email: kdawson(a)idl.idaho.gov
Website: https://www.idl.idaho.gov
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John A. Richards #10670
J.J. Winters #10327
IDAHO DEPARTMENT OF LANDS
300 N. 61h 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 AVISTA CASE NO. AVU-E-25-15
CORPORATION'S APPLICATION FOR
APPROVAL OF THE COMPANY'S 2026 IDAHO DEPARTMENT OF
WILDFIRE MITIGATION PLAN LANDS' SUPPLEMENTAL
COMMENTS
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.
36927 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:
a. 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.
b. Vegetative height layer'. The plan should include data regarding the vegetative
layer that includes information where the surrounding tree canopy is taller than
the 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
'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.
IDAHO DEPARTMENT OF LANDS'SUPPLEMENTAL COMMENTS—I

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.
c. 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 20th day of May, 2026.
IDAHO DEPARTMENT OF LANDS
-4ik_
J.J.WINTERS
Attorney for Idaho Department of Lands
IDAHO DEPARTMENT OF LANDS'SUPPLEMENTAL COMMENTS-2

CERTIFICATE OF SERVICE
I hereby certify that on this 20th 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:
Avista Corporation 0 Email:anni.glo og vac(a avistacorp.com
Anni Glogovac liz.andrewskavistacorp.com
Elizabeth Andrews avistadockets(aavistacorp.com
P.O. Box 3727
1411 E. Mission Avenue, MSC 33
Spokane, WA 99220- 3727
Idaho Public Utilities Commission ❑x Email: secretary_kpuc.idaho._og_v
Commission Secretary ;efj f.loll(&,puc.idaho. og_v
P.O. Box 83720
Boise, ID 83702-0074
Jeff Loll
Deputy Attorney General
11331 W. Chinden Boulevard, Bldg. 8
Suite 201-A (83714)
P.O. Box 83720
Boise, ID 83702-0074
PotlatchDeltic Forest Holdings, Inc. ❑x Email: petergrichardsonadams.com
Peter J. Richardson michele.tyler(&,potlatchdeltic.com
Richardson Adams, PLLC wade.semelisskpotlatchdeltic.com
515 N. 27th Street brian.schlect(&,potlatchdeltic.com
Boise, ID 83702 anna.torma(&,potlatchdeltic.com
Michele Tyler, Esq.
Wade Semeliss
Brian Schlect, Esq.
Anna Torma
601 W. First Avenue, Suite 1600
Spokane, WA 99201
Is/Kayla Dawson
Kayla Dawson, Legal Assistant
IDAHO DEPARTMENT OF LANDS'SUPPLEMENTAL COMMENTS-3