20260520Comment_1.pdf

Good morning-Attached for filing and service please find Idaho Department of Lands'
Supplemental Comments in the matter of Rocky Mountain Power's Application for
Approval of the 2026-2028 Wildfire Mitigation Plan, Case No. PAC-E-25-22.
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 ROCKY MOUNTAIN CASE NO. PAC-E-25-22
POWER'S APPLICATION FOR APPROVAL
OF THE 2026-2028 WILDFIRE MITIGATION IDAHO DEPARTMENT OF
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:
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 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—1

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
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.
Dated this 201h day of May, 2026.
IDAHO DEPARTMENT OF LANDS
_0(�<_
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 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:
Rocky Mountain Power ❑X Email: jana.saba(ibpacificorp.com
Jana Saba joseph.dallas&pacificorp.com
Joe Dallas datarequest(&,pacificorp.com
Idaho Public Utilities Commission ❑x Email: Erika.melansonkpuc.idaho.gov
Erika Melanson secretary�a),puc.idaho.gov
Bayer ❑x Email: tjnracineolson.com
Thomas J. Budge Ethan.waltermireAbayer.com
Ethan Waltermire bcollins(a,consultbai.com
Brian C. Collins gme er&consultbail.com
Grey Meyer
Idaho Department of Lands ❑x Email: tholfeltz(2idl.idaho.gov
Tyre Holfeltz ;lal uch(cidl.idaho.goy
Julia Lauch jrichards c&idl.idaho._og_v
John Richards jwinterskidl.idaho.gov
JJ Winters
Is/Kayla Dawson
Kayla Dawson, Legal Assistant
IDAHO DEPARTMENT OF LANDS'SUPPLEMENTAL COMMENTS-3