20260528Reply Comments.pdf

' Kootenai Electric
COOPERATIVE RECEIVED
May 28, 2026
IDAHO PUBLIC
UTILITIES COMMISSION
May 28, 2026
Via Email Only
Secretary Monica Barrios-Sanchez
Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd. Building 8, Suite 201-A
Boise, ID 83714
Email: [e-mail]
Re: Reply Comments of Kootenai Electric Cooperative, Inc.
Case No. C07-E-25-01
Dear Secretary Barrios-Sanchez:
Please find attached for filing in the above referenced proceeding the Reply Comments of Kootenai
Electric Cooperative, Inc. to the Comments of Commission Staff. Please let me know if you have any questions
regarding the attached responses.
Sincerely,
lsl Michael G. Andrea
Michael G. Andrea
General Counsel
Attachment
9014 W. Lancaster Rd. I Rathdrum, ID 83858 ff] © 0 n
TEL [phone] TOLL FREE 800-240-0459 1 FAX [phone]
EMAIL [e-mail] I WEB kec.conl

Michael G. Andrea(ISB No. 8308)
General Counsel
Kootenai Electric Cooperative, Inc.
9014 W Lancaster Rd
Rathdrum, ID 83858
Phone: [phone]
Email: [e-mail]
Attorney for Kootenai Electric Cooperative, Inc.
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 WIDLFIRE MITIGATION ) REPLY COMMENTS OF KOOTENAI
PLAN ) ELECTRIC COOPERATIVE, INC. TO
COMMENTS OF COMMISSION STAFF
On May 14, 2026, the Idaho Public Utilities Commission ("Commission") Staff
submitted comments ("Staff Comments") in this proceeding (i) recommending approval of
Kootenai Electric Cooperative, Inc.'s ("KEC") 2026-2028 Wildfire Mitigation Plan ("Plan"), (ii)
clarifying that KEC may file its future annual wildfire mitigation plans on or about December 31
of each year, and(iii) recommending that the Commission direct KEC include certain additional
information in future wildfire mitigation plan filings. Staff Comments at 19-20. Pursuant to the
Notice of Modified Procedure issued by the Commission in this Proceeding in Order No. 36939,
KEC respectfully submits these reply comments in response to the Staff Comments.'
' On May 26,2026,Idaho Department of Lands("IDL")also submitted comments. IDL did not intervene in this
proceeding,and,in any event,any comments were due by May 14,2026. Order No. 36939 at 3. IDL provides no
explanation for its untimely submission,nor does it seek leave to submit its untimely comments. Given the late
submission of IDL's comments,KEC has not had sufficient time to fully review IDL's recommendations and,
therefore,these reply comments do not provide a response to IDL's comments. Notwithstanding the foregoing,
KEC will carefully consider IDL's recommendations and,to the extent that such recommendations are helpful and
consistent with the WSCA,KEC will incorporate IDL's recommendations in future wildfire mitigation filings.
Page - 1 COMMENTS OF KOOTENAI ELECTRIC COOPERATIVE, INC.

I. Background
In the 2025 legislative session, the Idaho Legislature enacted the Wildfire Standard of
Care Act("WSCA"). 2025 Idaho Sess. Laws Ch. 249 (S.B. 1183). The WSCA allows electric
corporations that are not public utilities, including KEC, to adopt and file a WMP with the
Commission"at any time permitted by the commission." Idaho Code § 61-1803(2)(b).
In response to the WSCA, Commission Staff initiated a generic proceeding, Cased No.
GNR-E-25-02, to establish a regulatory process to follow to comply with the WSCA. On
September 30, 2025, the Commission issued Order No. 367742 in which the Commission, among
other things, established a regulatory process, including a schedule for electric corporations to
file their wildfire mitigation plans, and adopted Staff s proposed guidelines for electric
corporations' wildfire mitigation plan filings.
On December 31, 2025, KEC submitted its Plan to the Commission for approval in this
proceeding. On May 14, 2026, Staff filed its comments recommending approval of KEC's Plan.
No other comments were submitted on KEC's Plan. KEC respectfully submits these comments
in response to the Staff Comments.
2 Order No.36774,reconsideration denied,Order No.36849,clarified,Order No. 36882.
Page - 2 COMMENTS OF KOOTENAI ELECTRIC COOPERATIVE, INC.

II. Reply to Staff Comments
As discussed above, KEC submitted its Plan to the Commission for review and approval
pursuant to the WSCA. In reviewing KEC's Plan, the Commission:
. . . shall ensure that it meets the minimum requirements stated in section 61-1803, Idaho
Code, and shall consider the following factors:
(a) The consistency of the plan with the public health, safety, and welfare;
(b) The feasibility of the plan and the cost of its implementation; and
(c) The degree to which the plan adequately minimizes wildfire risk and proposes
to respond to wildfires that do occur.
I.C. § 61-1804 (emphasis added).
In the Staff Comments, Staff states that it reviewed KEC's Plan and found that KEC's
Plan "meets the requirements of the WSCA[.]" Staff Comments at 2. In addition to satisfying
the requirements of the WSCA, Staff further found that KEC's Plan satisfies "Order No. 36774,
and the Commission's WMP Guidelines, detailed in Order No. 36774 Exhibit 1 and Order No.
36929 (`Guidelines')." Id. Staff recommends that the Commission issue an order approving
KEC's Plan and clarifying that KEC may file its updated wildfire mitigation plan for the
Commission's annual review on or about December 31 st each year. Id. at 19. Finally, Staff
requests that the Commission direct KEC to include certain additional information in future
WMP filings. Id. at 19-20.
KEC carefully developed its Plan to comply with all requirements of the WSCA and,
more importantly, to provide a wildfire mitigation plan that provides meaningful wildfire
mitigation measures and procedures to mitigate and respond to wildfire risk. KEC worked
closely with its operations, communications, and other employees to ensure that its Plan is both
meaningful and useful to those employees who are charged with implementing the Plan. In
Page - 3 COMMENTS OF KOOTENAI ELECTRIC COOPERATIVE, INC.

short, KEC's Plan is designed with the goals of providing a useful and meaningful Plan to
mitigate and respond to wildfire risk and to comply with the WSCA.
KEC appreciates Staff s review of its Plan and its thoughtful comments. KEC expects its
wildfire mitigation plans to evolve and improve over time. Accordingly, KEC appreciates
Staff s recommendations for additional items to be included in future WMP filings. KEC will
incorporate in its future wildfire mitigation plans additional information that, consistent with the
WSCA, is reasonably required by the Commission.
KEC has approximately 120 total employees and serves roughly 30,000 members.' The
WSCA expressly recognizes that Plans should be designed to be reflective of and commensurate
with the size and complexity of the electric corporation's operations and the nature of the fire
risk. I.C. § 61-1803(3). Consistent with the WSCA, KEC respectfully requests that, in
evaluating Staffs recommendations to require KEC to provide additional information in future
wildfire mitigation plan filings, the Commission consider the WSCA requirements, KEC's size
and limited resources, the additional burden on KEC's staff, and the efficacy of requiring such
additional information.
III. Conclusion
KEC agrees with, and appreciates, Staffs finding that KEC's Plan meets the
requirements of the WSCA and the Commission's requirements. See Staff Comments at 2. KEC
further appreciates Staffs suggestions for additional information in future wildfire mitigation
filings and, as noted above, KEC is willing to provide additional information that is reasonably
required by the Commission. KEC does respectfully request that, in reviewing Staffs
recommendations for additional information, the Commission consider, among other things,
s See KEC's Response to Request No.6 of Staff s First Production Request;KEC's Need to Know Document.
Page - 4 COMMENTS OF KOOTENAI ELECTRIC COOPERATIVE, INC.

KEC's size and limited resources to ensure that any additional requirements imposed by the
Commission do not create an undue burden on KEC Staff.
As noted by Staff, KEC's Plan satisfies the requirements of the WSCA and the
Commission's requirements. Accordingly, KEC respectfully requests that the Commission issue
an order approving its Plan.
Respectfully submitted this 28th day of May 2026.
KOOTENAI ELECTRIC COOPERATIVE, INC.
lsl Michael G. Andrea
Michael G. Andrea
General Counsel
Page - 5 COMMENTS OF KOOTENAI ELECTRIC COOPERATIVE, INC.

CERTIFICATE OF SERVICE
I HEREBY CERTIFY that I have this 28th day of May 2026, served the foregoing
Comments of Kootenai Electric Cooperative, Inc. upon all parties of record in this proceeding by
electronically providing a copy thereof to:
Commission Staff:
Monica Barrios-Sanchez Kelsea E. Ross
Commission Secretary Deputy Attorney General
Idaho Public Utilities Commission Idaho Public Utilities Commission
11331 W. Chinden Blvd. Building 8, PO Box 83720
Suite 201-A Boise, ID 83702-0074
Boise, ID 83714 Email: [e-mail]
Email: [e-mail]
lsl Michael G. Andrea
Michael G. Andrea
General Counsel
CERTIFICATE OF SERVICE