20260526Comment_1.pdf

Good morning-Attached for filing and service please find Idaho Department of Lands'
Comments in the matter of Kootenai Electric Cooperative, Incas Application for Approval of
its 2026-2028 Wildfire Mitigation Plan, Case No. CO7-E-25-01.
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 KOOTENAI CASE NO. C07-E-25-01
ELECTRIC COOPERATIVE, INC.'S
APPLICATION FOR APPROVAL OF ITS IDAHO DEPARTMENT OF
2026-2028 WILDFIRE MITIGATION PLAN LANDS' COMMENTS
Idaho Department of Lands ("IDL")respectfully submits the following 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. IDL has reviewed the risk modeling as provided in the submitted plan by
Kootenai Electric and presents the following reservations. Specifically, the risk products are not
presented with any overlays of the Kootenai Electric system, making it difficult at best to
understand the consequences associated with wildfire for or from the infrastructure. IDL
respectively requests that all future modeling products include a system overlay to help qualify
the associated wildfire risks to and from Kootenai Electric's system.
2. Additionally, in conjunction with the 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.
IDAHO DEPARTMENT OF LANDS'COMMENTS- 1

b. Height vegetative lam. 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
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 for Kootenai Electric's system.
3. Damaging wind events occur often enough within the footprint of the Kootenai
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 for Kootenai
Electric.
4. The efforts to address wildland fire through planning efforts has a long history in
Idaho. In 2003, Idaho began the implementation of the federal 2002 Healthy Forest Restoration
Law. This law required state forestry agencies throughout the U.S. to establish criteria and
support the development of Community Wildfire Protection Plans (CWPP). This effort
continues today with IDL supporting the maintenance of CWPPs for every county in Idaho. IDL
strongly believes there is significant opportunity for cross integration of the county level CWPPs
and utility mitigation plans and encourages Kootenai Electric to actively seek partnerships with
the various counties in which their systems exist. IDL believes that doing so will strengthen
relationships, enhance community protection, and leverage resources for greater efficiency in
delivery of services and programs related to wildfire response, education, and mitigation.
5. The cost breakdown provided by Kootenai Electric was very general in scope and
would benefit from more localized examples and application. Additionally, IDL would
encourage Kootenai Electric to provide an evaluation of the cost of no mitigation actions to help
'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 by Kootenai Electric.
IDAHO DEPARTMENT OF LANDS'COMMENTS—2

clarify the impact of expenditure investment.
6. Kootenai Electric has indicated through discovery that they utilize a process when
working on industrial lands, but the formalization of that process is not formalized for referenced
in the current submission. If this process does not currently exist, IDL requests that Kootenai
Electric add it as a project for implementation to address this aspect of risk mitigation, as it
represents a substantive unknown that can be addressed through the development of a standard
operating procedure. It is IDL's position that the SOPS, when highlighted, will build greater
confidence in relationships and the values associated with timbered lands.
7. In the section covering inspection of vegetation, the qualifications appropriately
center around arboriculture standards, which have long been the industry standards. However,
IDL argues that these standards are insufficient at addressing wildland fire related issues when
looking at vegetative mitigation as a mechanism to reduce wildfire risk. The arboriculture stands
address tree/shrub conditions and how to appropriately remove or prune. Though these standards
address vegetation health, they do not consider ignition potential or fire propagation,both of
which should be standard for inspection of vegetation treatments. When viewed in the context of
wildfires, a prime example is "ladder" fuels. Ladder fuels are vegetative structural components
that allow fire to move rapidly from ground to forest canopies. If ladder fuels are not addressed
as part of the mitigation actions, then the risk of fire propagating to crowns is substantially
higher. IDL respectfully recommends that the inspection qualification standards also include
certification specific to wildland fire.
8. IDL would like to commend the efforts of Kootenai Electric to engage with local
cooperators and community members to address risk mitigation within their System.
Respectfully submitted this 26rh day of May 2026.
IDAHO DEPARTMENT OF LANDS
-4ik'
J.J.WINTERS
Attorney for Idaho Department of Lands
IDAHO DEPARTMENT OF LANDS'COMMENTS-3

CERTIFICATE OF SERVICE
I hereby certify that on this 26 h 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:
Kootenai Electric ❑x Email:tmaddalone(akec.com
Thomas Maddalone mandreakkec.com
Michael G. Andrea
9014 W. Lancaster Road
Rathdrum, ID 83858
Idaho Public Utilities Commission ❑x Email: secretary(apuc.idaho.gov
Commission Secretary erika.melanson(&,puc.idaho.gov
P.O. Box 83720
Boise, ID 83702-0074
Erika Melanson
Deputy Attorney General
11331 W. Chinden Boulevard, Bldg. 8
Suite 201-A (83714)
P.O. Box 83720
Boise, ID 83702-0074
Is/Kayla Dawson
Kayla Dawson
IDAHO DEPARTMENT OF LANDS'COMMENTS-4