20260529Comment_1.pdf

Good morning-Attached for filing and service please find Idaho Department of Lands'
Comments in the matter of Clearwater Power Company's Application for Approval of the
Company's 2026 Wildfire Mitigation Plan, Case No. C01-E-26-01.
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 CLEARWATER CASE NO. COI-E-26-01
POWER COMPANY'S APPLICATION FOR
APPROVAL OF THE COMPANY'S 2026 IDAHO DEPARTMENT OF
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 Wildfire
Mitigation Plan by Clearwater Power and presents the following as considerable shortcomings
that IDL recommends must be addressed before plan approval.
a. Section 4.1.2 defines Wildland Urban Interface (WUI) that is not
consistent with current industry standards. Not utilizing current data and
methodologies results in a significant under-representation of the WUI in
Idaho. The resultant impact is a gross under-representation of the impact
of wildfire on communities and developments throughout Clearwater
Power's system. If assistance is needed to refine the WUI area for
Clearwater Power, IDL can provide state-level data that is consistent with
adopted county plans and meets federal law intent.
IDAHO DEPARTMENT OF LANDS'COMMENTS-1

b. The modeling described in section 4.1.3 is based on antiquated fire
modeling from 2016 and 2012. Each of the referenced data products has
been updated several times to reflect changes in science and integration of
current data sets. As a result of the outdated nature of the modeling
exercise, the wildfire threat assessment is significantly skewing the
wildfire risk within the Clearwater Power system as substantially lower
than shown in all other current industry standard products. If assistance is
needed to update the modeling, IDL maintains current modeling that is
publicly available and informed by current data inputs and modeling
process that are congruent with industry standards.
2. 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 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 lam. 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 Clearwater Power's system.
'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 Clearwater Power.
IDAHO DEPARTMENT OF LANDS'COMMENTS—2

3. Damaging wind events occur often enough within the footprint of the Clearwater
Power 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
Clearwater Power.
4. The efforts to address wildland fire through planning has a long history in Idaho.
In 2003, Idaho began the implementation of the federal 2002 Healthy Forest Restoration Act.
This act 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 Clearwater Power 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 references were associated with the impacts of fires instead
of the value of the mitigation actions. If Clearwater Power is unable to speak to the economics
of efforts, it is suggested that Clearwater Power speaks to the value (economic) of the systems
served and the impacts (economic)when electric service is disrupted. Additionally, IDL would
encourage Clearwater Power to provide an evaluation of the cost of no mitigation actions to help
clarify the impact of expenditure investment.
6. Clearwater Power's plan does not include a process for cost recovery when trees
on forest industry ownerships are required to be removed. IDL requests that Clearwater Power
add the development of a process as a project for implementation within the plan to address this
aspect of risk mitigation, as it represents a substantive unknown that can be addressed through
the development of a SOP. It is IDL's position that the SOPs, when highlighted in the plan, 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
IDAHO DEPARTMENT OF LANDS'COMMENTS-3

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. The plan contains several editorial items that warrant updating to reflect current
information. For example, 5.1.2 in Idaho IDL does not"declare fire season".
Respectfully submitted this 20 day of May, 2026.
IDAHO DEPARTMENT OF LANDS
-4ik_
J.J.WINTERS
Attorney for Idaho Department of Lands
IDAHO DEPARTMENT OF LANDS'COMMENTS-4

CERTIFICATE OF SERVICE
I hereby certify that on this 29 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:
Clearwater Power Company ❑x Email:sweeks(a(a�jvwlaw.net
Susan P. Weeks rdpiercekclearwaterpower.net
Bob Pierce
Idaho Public Utilities Commission ❑x Email: secretarykpuc.idaho.gov
Commission Secretary erika.melanson(d),puc.idaho.gov
P.O. Box 83720
Boise, ID 83702-0074
Erika Melanson
Deputy Attorney General
PotlatchDeltic Forest Holdings, Inc. 0 Email: peter(d),richardsonadams.com
Peter J. Richardson michele. . lerkpotlatchdeltic.com
Richardson Adams, PLLC wade.semeliss(&,potlatchdeltic.com
515 N. 27t' Street brian.schlectkpotlatchdeltic.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'COMMENTS-5