20260602Staff Comments.pdf

RECEIVED
June 02, 2026
ERIKA K. MELANSON IDAHO PUBLIC
DEPUTY ATTORNEY GENERAL UTILITIES COMMISSION
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83702
[phone]
IDAHO BAR NO. 11560
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF CLEARWATER )
POWER COMPANY'S APPLICATION FOR ) CASE NO. C01-E-26-01
APPROVAL OF THE COMPANY'S 2026 )
IDAHO WILDFIRE MITIGATION PLAN )
COMMENTS OF THE
COMMISSION STAFF
COMMISSION STAFF ("STAFF") OF the Idaho Public Utilities Commission
("Commission"), by and through its attorney of record, Erika K. Melanson, Deputy Attorney
General, submits the following comments.
BACKGROUND
On January 20, 2026, Clearwater Power Company ("Company") applied to the
Commission requesting approval of its 2026 Idaho Wildfire Mitigation Plan ("2026 WMP"), in
accordance with the Wildfire Standard of Care Act("WSCA"),Idaho Code § 61-1801,et seq.,and
the guidelines established in Case No. GNR-E-25-02.
After initial review Staff identified that a few required components of the 2026 WMP were
omitted. Staff reached out to the Company about the missing components and the Company filed
these items subsequent to the initial filing.
Under Idaho Code § 61-1803(2)(b),the Company has opted to file a WMP for Commission
approval. As the Company is an unregulated utility, the Company is not required to file a WMP
for Commission approval.
STAFF COMMENTS 1 JUNE 2, 2026

On February 13, 2026, the Commission issued a Notice of Application and Notice of
Intervention Deadline, setting a deadline for interested parties to file a petition to intervene. Order
No. 36934. Intervention was granted to Potlatch Forest Holdings, LLC ("PotlatchDeltic"). Order
No. 36938.
On March 23, 2026, the Commission issued a Notice of Modified Procedure. Order No.
36977.
STAFF ANALYSIS
Pursuant to Idaho Code § 61-1804, Staff reviewed the Company's 2026 WMP for
compliance and believes it meets the requirements of the WSCA, Order No. 36774, and the
Commission WMP Guidelines, detailed in Exhibit No. B to that Order("Guidelines"). Staff also
reviewed the 2026 WMP to determine: (1) whether it is consistent with public health, safety, and
welfare; (2) the feasibility of the plan and the cost of its implementation; and (3) whether it
adequately minimizes wildfire risk and proposes to respond to wildfires that do occur.
The Guidelines require the WMP to include the following sections consistent with the
WSCA: (1) geographical risk assessment, (2) preventative actions and programs, (3) public
outreach and engagement, (4) government outreach, (5) method of line design, (6) situational
awareness and monitoring, (7) infrastructure inspection and maintenance, (8) de-energization and
line operation practices, and(9) vegetation management. Order No. 36774. The Guidelines also
require an update of lessons learned from previously approved WMPs, and a breakdown of each
program category's forecasted costs by year for both capital and operation and maintenance
("O&M") expenditures. Id. Staff s review of these requirements is discussed in the respective
sections below.
Additionally, Order No. 36774 required the Company to file a Need to Know Document as
part of this WMP filing, provide a copy of its notice to interested parties of this WMP filing, and
create its WMP using a three-year planning horizon that includes a section which describes how
the electric utility addresses each of the Commission's Orders and Staffs recommendations. Staff
reviewed each of these items and believes the Company has met these requirements.
Accordingly, Staff recommends the Commission issue an order that (1) approves the
Company's 2026 WMP, (2) clarifies that the Company may file its updated WMP for the
Commission's annual review on or about January 20 of each year going forward, and (3) directs
STAFF COMMENTS 2 JUNE 2, 2026

the Company to include additional items in future WMPs, if the Company opts to file in future
years. Although Staff believes the Company's 2026 WMP meets the applicable requirements,
Staff believes the Company should include additional items in future WMP filings, as discussed
below.
Additionally, while Staff is recommending approval of the Company's 2026 WMP, Staff
is aware that the Idaho Department of Lands("IDL")has expressed significant concerns regarding
certain elements of the Company's data sources and related assumptions. IDL has indicated it
intends to file public comments outlining its concerns. Staff respectfully recommends that the
Commission consider and weigh IDL's comments alongside Staff s analysis during its
deliberations and decision-making.
Commission Authority
Under the WSCA,the Commission is tasked with approving or rejecting WMPs filed with
the Commission. Idaho Code § 61-1801,et seq. Accordingly,the Commission has jurisdiction to
review WMPs submitted for Commission approval. Id. The Commission must confirm that a
WMP meets the minimum requirements set forth in Idaho Code § 61-1803 and must consider the
factors outlined in Idaho Code § 61-1804(1)(a)-(c). Idaho Code § 61-1804(1). The WSCA
requires the Commission to ensure that a WMP is "developed using approaches and methods that
are designed to protect the public interest and are reflective of and commensurate with the size and
complexity of the electric cooperation's operations and of the nature of the fire risk." Idaho Code
§ 61-1803(3).
The WSCA states that
[a]n electric corporation that is not a public utility, including but not limited to a
cooperative association distributing electric power to its members or a municipal
electric distribution system under section 50-342, Idaho Code, may adopt and file
a wildfire mitigation plan with the commission for its review at any time permitted
by the commission.Idaho Code § 61-1803(2)(b) (emphasis added).
Staff interprets this language to mean that it is optional for a cooperative association to
submit a WMP for Commission approval. Idaho Code § 61-1803(2)(b). The Guidelines
established a filing schedule and set forth guidelines and essential components for WMPs. Staff
concludes that once a cooperative association files a WMP with the Commission, review of the
cooperative's WMP is subject to the requirements set forth in Idaho law, the Guidelines, the
STAFF COMMENTS 3 JUNE 2, 2026

essential elements of WMPs adopted in the Guidelines, and additional requirements within the
Commission's authority. Absent responses to Commission direction in future filings, Staff may be
unable to recommend approval of future WMPs.
2026 Wildfire Mitigation Plan-Wide Considerations
In this overview section, Staff s Provides general observations regarding the Company's
2026 WMP. This section is organized into two main areas: (1) Cost Feasibility, and (2) Cross-
Cutting Elements. Subsequent sections present comments organized according to the Guidelines.
Cost Feasibility
This section addresses several cost-related components of the Company's 2026 WMP that
Staff considered in its review but are not captured within any specific programmatic requirement
of the Guidelines. Here, Staff provides its analysis of the Company's cost forecasts for planned
mitigation activities,the cost-benefit approach used to evaluate and prioritize those activities, and
the extent to which the Company has pursued or incorporated grant funding. Together,these topics
inform Staff s assessment of the overall feasibility and financial reasonableness of the Company's
proposed wildfire mitigation strategies.
Cost Forecasts. Idaho Code § 61-1804(1)(b) requires the Commission to consider the
cost of the WMP implementation,and the Guidelines require the Company to provide a breakdown
of each program category's forecasted costs by year for both capital and O&M expenditures
through the planning horizon of the WMP. Guidelines at 8. The Company provided a detailed
Construction Work Plan Improvement List, a summary Vegetation Management Budget, and a
Line Inspection Cost Budget. CPC Construction Workplan Cost Breakdown spreadsheet; Need
To Know document at 2. Each budget is comprehensive and not specific to wildfire-related
spending.
In 2026,the Company forecasts$2.58 million in vegetation management and$3.57 million
in capital projects. Id. The vegetation management budget is categorized as O&M. The primary
capital investment category is "Total Equipment- Miscellaneous"which includes $1.1 million for
pole replacements and$0.5 million for deploying reclosers to sectionalize the Company's electric
system.Id. The Line Inspection Budget includes O&M spending for the annual patrolling,before
STAFF COMMENTS 4 JUNE 2, 2026

June 1, of all lines in high Ere risk areas, standard cycle-based line inspections, and contractor
labor for cycle-based pole inspections.
Table Nos. 1, 2 and 3 below provide summaries of these budget items for the Company's
2026 WMP. Need to Know Document at 2; CPC Construction Workplan Cost Breakdown
spreadsheet.
Table No. 1: 2026-2029 Capital Construction Budget
n Imp
Imp.
Number Loc4W and Description 2026 2027 2028 2029 Four Year Total
Total Trans miss ion Improvements S 525,000 S 600.000 S S S 1,125.000
Total Substation improvements S - S 650.000 S 863.500 S S 1,513.500
Total Primary System Improvements S 87.400 S 170.500 S 143.000 S 340.000 S 740.900
Total Member Service Extensions S 460.000 S 460.000 S 460.000 S 460.000 S 1,840.000
Total Equipment-Miscellaneous S 2.443.250 S 2.515.250 S 2.674,250 S 2,674.250 S 10,307.000
Total Other Distribution Items S 60.000 S 60,000 S 60.000 S 60.000 S 240.000
S 4—j 5.750 S 3.534,250 S 15,766.400
Table No. 2: 2026-2028 Comprehensive Vegetation Management Budget
2026 $ 1,770,808 S 808.363 $ 2,579,171
2027 $ 1,793,890 S 666,667 $ 2,460,557
2028 $ 1,871,085 S - $ 1,871,085
Table No. 3: 2026-2028 Line Inspection BudgeLine Inspection Cost
ira'r ' CPC Labor Pole Inspect AnnualTotat
2026 c 224,500 S 82,986 S 307,486
2027 235,725 S 851.476 S 321,201
2028 S 247,511 $ 88,040 S 335,551
707,736 $ 256,5011PS
Cost-Benefit Approach. Idaho Code § 61-1804(1)(b) requires the Commission to
consider the feasibility of the plan and the cost of its implementation. Further,in Order Nos. 36774
STAFF COMMENTS 5 JUNE 2, 2026

and 36882, the Commission directed the Company to include a cost-benefit analysis within its
WMPs and provided guidance on the information necessary to support its analysis. Staff believes
the Company met these requirements;however, Staff has identified areas of potential improvement
to be included in future WMPs.
The WMP does not include wildfire risk mitigation benefits within the plan. While the
Company provided some qualitative risk mitigation information during a teleconference on April
23, 2026, Staff believes this information should be incorporated in future WMPs and that the
Company should also consider including wildfire risk mitigation and benefit information by
applying a consistent, transparent, and repeatable methodology across projects. Such consistency
is necessary to evaluate whether projects are prioritized using comparable criteria. Additionally,
if qualitative benefits are applied, the Company should define them, explain the efficacy of
mitigating wildfire risk, and consider quantifying risk reduction associated with specific
infrastructure mitigation measures.
Grants. The Commission must consider the cost of implementing the WMP. Information
on funding alternatives and funding sources is necessary to evaluate the cost and feasibility of the
Company's planned actions. Although the 2026 WMP did not discuss any grants that the
Company was awarded or applied for, the Company provided details of a grant to install
approximately 1,375 existing poles per year in 2026 and 2027 awarded through the Idaho Office
of Energy and Mineral Resources ("OEMR") in Responses to Staff s Production Request Nos. 3
and 10. With a cost match of$250,000,the Company received$650,000 from the grant. Response
to Staff s Production Request No. 13. Additionally, the Company was awarded three other grants
from the OEMR for (1) contracting with an Al satellite company to determine vegetation
conditions of$2 million, (2) purchasing protective relays, unmanned aircraft systems for aerial
inspections, and technology to enhance reliability of the Ahsahka substation of$349,864, and (3)
replacing 50 aging reclosers, upgrading its operation center with new reclosers, and installing a
redundant automation controller of$820,000.1
Grant information is necessary to evaluate the cost implementation of the WMP, because
grant funding may impact the cost feasibility of wildfire projects. Therefore, Staff recommends
1 OEMR Energy Resiliency Grant Program Awarded Projects. https:Hoemr.idaho.goy/programs/idaho-
energy-resiliency rg ant-pro rg am/(last accessed May 6,2026).
STAFF COMMENTS 6 JUNE 2, 2026

the Commission direct the Company to provide details of all funding alternatives and sources
pursued within future WMPs.
Cross Cutting Elements
This section addresses several integral components of the Company's 2026 WMP that Staff
considered in its review but do not fit neatly within a specific Guidelines requirement. Here, Staff
provides its analysis of the Company's targets and goals, the metrics used to monitor progress,the
anticipated filing date for future WMPs, lessons learned from prior implementation, and Staff s
coordination efforts with the State Forester. Together, these topics inform Staffs assessment of
the Company's overall approach to wildfire mitigation planning and continuous improvement.
Targets and Goals. The Guidelines require the Company to include measurable targets
and goals in its WMP. Guidelines at 7 and 8. In the 2026 WMP, the Company provides cycle-
based targets for many of its programs. For example, the Company states that vegetation
management in forested areas is performed on a 10-year cycle,equating to approximately 90 miles
of right-of-way clearing each year. 2026 WMP at 30. Table 7 of the 2026 WMP Infrastructure
provides inspection cycles for overhead transmission, overhead distribution, underground
distribution, and substations. However, having both numeric targets and cycle-based targets
allows for more effective year-to-year compliance verification. The Company supplied numeric
targets for certain programs in Response to Staff s Production Request No. 3. Therefore, Staff
recommends that the Company incorporate all applicable targets into the WMP, including both
cycle-based and quantitative measures where feasible.
Metrics. Idaho Code § 61-1804(l)(b)(c) requires the Commission to evaluate both the
feasibility of the WMP and the extent it minimizes wildfire risk. The Company has identified
some metrics it plans to use to assess the effectiveness of various WMP programs. 2026 WMP
Table 8. However, the Company also provided additional detail on measuring WMP program
effectiveness in Response to Staffs Production Request Nos. 9 and 11. Staff believes these
metrics—and the underlying data—should be included in the WMP, as they function as practical
indicators that support the Company's ongoing evaluation of system conditions. Therefore, for
future WMP filings, Staff recommends that the Company include all metrics used within each
STAFF COMMENTS 7 JUNE 2, 2026

respective program area and provide the associated data in a format that allows for easy
comparisons across WMP cycles. Where available, Staff further recommends providing at least
three years of historical system- and circuit-level data to support trend analysis.
Future WMP Filing Date. Idaho Code § 61-1803(2)(a) gives the Commission the
authority to stagger the filing dates of the WMPs. Order No. 36774 directed electric corporations
to file its updated WMPs for annual review one year after the filing date of the previously approved
WMP. Order No. 36774 at 20. Through communication with the Company, the Company stated
that it would prefer an annual WMP filing on or about January 20th each year. Staff has no concerns
with this preferred filing date. Therefore, Staff recommends the Commission issue an order
clarifying that the Company's annual update WMP filing should be submitted on or about January
20ffi of each year.
Lessons Learned. The Guidelines require the Company to provide an update of lessons
learned from the previously approved WMP within WMP annual filings for review and approval
The Company has no prior Idaho Commission-approved WMPs filed, this requirement does not
apply to the 2026 WMP and, accordingly, the Company's 2026 WMP did not include a section
discussing lessons learned. However, the Company provided some lessons learned from the last
five years,such as adapting its operations by adding new electronic reclosers,setting the electronic
reclosers to non-reclose in fire season, adding ten drones for line patrol with 18 licensed pilots,
using a proprietary service for 31) satellite imagery to inform vegetation management, and
installing fused cut-outs on all new transformer installations. Response to Staff s Production
Request No. 2. Staff suggests the Company add these details within the next WMP to exemplify
its efforts to reduce wildfire risk and to help demonstrate its implementation of WMP practices.
State Forester Collaboration. Idaho Code § 61-1804(3) requires the Commission to
consult with the State Forester at IDL regarding vegetation management, reduction of wildfire
fuels, and other duties of the State Forester under Title 38,Idaho Code.
On January 29, 2026, Staff informed IDL of the Company's 2026 WMP and provided
access to the Company's application and associated documents.
STAFF COMMENTS 8 JUNE 2, 2026

On February 23,2026, Staff met with the Company and IDL to discuss the Company's risk
modeling and other areas of the 2026 WMP.
On May 15, 2026, Staff and IDL met to discuss IDL's concerns and recommendations
regarding the Company's WMP. During this meeting, IDL outlined significant concerns related
to data accuracy,the currency of certain datasets, and other aspects of the Company's wildfire risk
assessment. Staff understands that IDL intends to file these concerns as public comments. Staff
recommends that the Commission consider IDL's comments alongside Staff s analysis when
evaluating the Company's WMP.
Geographical Risk Assessment
Idaho Code § 61-1803(3)(a) and the Guidelines require all WMPs to include a description
of the Company's wildfire risk assessment and a map of identified risk areas. Staff believes the
Company has followed a reasonable modeling approach to assess wildfire risk in its service
territory and has met these requirements. However, Staff believes there are areas for improvement,
including: (1) providing a risk model description, (2) addressing the limitations of the risk
modeling process, and (3) addressing changes to risk areas based on a changed risk methodology
in its Wildfire Hazard Potential ("WHP")map.
Risk Model Description
In Section 4 of its 2026 WMP, the Company describes wildfire risk within its service
territory by providing two maps that depict fire history and the Wildland Urban Interface("WUI")
within its service area. 2026 WMP at 11 and 13. The vendor,Vantage Point Solutions—formerly
known as BKI Engineering—was used to update the Company's 2026 WHP from previous WMPs
filed outside of Idaho. Response to Staffs Production Request No. 4. The description of the
modeling process and the inputs were not included within the 2026 WMP. In Response to Staff s
Production Request No. 4, the Company provided additional details about the modeling inputs.
The WHP map is produced by the Fire Modeling Institute,based on spatial vegetation and wildfire
fuels data from LANDFIRE 2020, spatial datasets of wildfire likelihood and intensity from Large
Fire Simulator, and point locations of past fire occurrence from 1992 through 2020. Response to
Staff s Production Request No.4 Exhibit A. For clarity of the risk modeling process,the Company
should consider including a narrative explaining the vendor's modeling process and the inputs
STAFF COMMENTS 9 JUNE 2, 2026

used in the model. This narrative would assist in Staff s analysis of the Company's adherence to
Idaho Code § 61-1803(3)(a) and the Guidelines by providing context for the risk model and its
inputs.
Risk Model Limitations
Staff believes there are four limitations with the Company's modeling approach. First,
Staff consulted with IDL about the Company's risk modeling on May 15, 2026. IDL expressed
significant concerns with the out-of-date risk model inputs Vantage Point Solutions used in this
2026 WMP and that the vendor does not use an adequate WUI dataset to establish accurate areas
of heightened wildfire risk,which may result in the risk model underrepresenting the true wildfire
risk. IDL stated that Vantage Point Solutions used the Silvis Lab WUI dataset which, according
to IDL,underrepresents Idaho WUI areas by 60 to70 percent. Based on these concerns,IDL stated
it believes the current risk modeling approach has created an inaccurate representation of wildfire
risk in the Company's service territory. Staff recommends the Commission consider IDL's
recommendations regarding this issue in conjunction with Staffs other concerns regarding risk
modeling. Further, Staff recommends the Commission direct the Company to meet with IDL and
its consultant to identify and correct issues with the risk modeling prior to filing its next WMP
with the Commission.
Second, the Guidelines state risk assessment should consider factors including asset
location. Guidelines at 2. Staff believes that the Company's approach to risk modeling reasonably
considers the existing wildfire risk due to external factors; however,the Company's risk modeling
is limited by not considering the risk of ignition from its infrastructure. The Company overlaid its
assets onto the WHP map as seen in Figure 4. 2026 WMP at 16. However, the overlaid asset
information doesn't contain condition or ignition potential from its infrastructure such as the age
of the asset, mitigations applied, or line spans between poles. Understanding infrastructure risk
would enable the Company to identify where to focus system investments. As the Company
continues to refine its modeling process, Staff suggests the Company should consider adding risk
from its infrastructure as an input into its risk modeling.
Third, Idaho Code § 61-1804(1)(c) requires the Commission to consider the degree the
plan adequately minimizes wildfire risk. Without infrastructure risk considered in the modeling,
the model will not show any reduction of risk based on investments in the system. Staff believes
STAFF COMMENTS 10 JUNE 2, 2026

that risk modeling is one potential area where the Company can explain how it is minimizing
wildfire risk by improving its infrastructure. The Company was able to provide some qualitative
benefits of its wildfire mitigation plans in Response to Staff s Production Request No. 1 and in
discussion with Staff. However, the 2026 WMP does not clearly explain how specific mitigation
activities reduce wildfire risk or how those activities improve system resiliency. Therefore, Staff
recommends the Commission direct the Company to narratively explain how certain mitigation
activities (such as grid hardening efforts) are reducing wildfire risk within future WMP filings.
Finally, in a meeting with Staff, the Company stated that it also had not consulted with
local fire experts on the results of the model. Staff believes it is an industry best practice to consult
with local experts as another facet to validate the model's results. Therefore,the Company should
consult with local fire experts, such as the local fire warden, to further refine the risk modeling
output.
Risk Areas Updates
As required by the Guidelines,the Company provided Figure 4 of its service area and WHP
Overview. 2026 WMP at 16. Based on this map,the Company also provided Table 5 that provides
an overview of transmission and distribution assets within the low,moderate,and high WHP tiers.
2026 WMP at 15. The provided map and table are different from the maps and tables included in
the Company's previous WMP; however, the 2026 WMP does not address this change. The
Company explained that the 2026 WMP used updated WHP maps to determine wildfire risk areas,
which recategorized a large portion of the overhead assets as being located in high WHP areas
compared to those in the 2022 WMP. Response to PotlatchDeltic's Production Request No. 17.
For clarity between WMPs, Staff suggests the Company describe any changes or updates to risk
areas based on updated risk modeling within future WMPs.
Optional Preventative Actions and Programs
In addition to required discussions, the Guidelines state that an electric corporation may
include other actions or programs, such as system hardening strategies, workforce preparedness,
and pilot programs. Guidelines at 3-4. Staff believes system hardening strategies correlate with
Idaho Code § 61-1803(3)(e); therefore, Staff discusses system hardening in the "Method of Line
STAFF COMMENTS 11 JUNE 2, 2026

Design and System Hardening" section. The Company does include a discussion of its workforce
preparedness and pilot programs in its 2026 WMP, as discussed below.
Workforce Training and Preparedness
The Guidelines state that a WMP may include discussion of workforce training and
preparedness. Guidelines at 3. A robust workforce demonstrates that personnel are equipped with
the skills and readiness to safely and effectively execute wildfire risk-reduction measures, such as
situational awareness, emergency response actions, and safe line operations. This not only fulfills
regulatory obligations but also strengthens operational resilience, reduces the likelihood of safety
incidents during wildfire season, and supports timely and coordinated responses when conditions
escalate.
The Company provided a brief description of its workforce training activities on page 39
of its 2026 WMP. The Company also provided additional workforce training information that
included specific training delivered on January 26, 2026, including: (1) a detailed review of
updated WHP maps; (2)a detailed review of Enhanced Line Patrol lists,which were revised based
on the new WHP maps; (3) and a review of which reclosers would be set to not automatically
reclose based on the new WHP maps. Response to Staff s Production Request No. 8 (see materials
and employee list included in Exhibit D). The Company also provided examples of practical
workforce training exercises conducted as part of its wildfire preparedness efforts. One example
provided is that the Company conducted a live demonstration of fire wrap on three poles sets. Id.
Based on its review of the 2026 WMP and the Company's responses to Staffs production
requests, Staff concludes that the Company provided sufficient detail for Staff to evaluate this
optional training component of the Guidelines. Staff recommends the Company include its
training plan and the extent it executed this plan in future WMP filings.
Pilot Programs
Within the 2026 WMP, the Company describes its five pilot programs: (1) Electronic
Reclosers with Remote Adjustability, (2)Non-expulsion Fuses, (3)Drone Inspection Program, (4)
Satellite Imaging Program, and (5) Weather Stations. In Response to Staffs Production Request
No. 1, the Company provided more details regarding each of its current pilot programs and
STAFF COMMENTS 12 JUNE 2, 2026

explained that the Non-Expulsion Fuses and the Weather Stations pilots have not yet been
implemented.
The Company's Electronic Reclosers pilot started with Siemens CMR reclosers but has
switched to G&W Vipers with SEL relay controls with instantaneous trip functionality and remote
capability to adjust trip settings. Id. The Company plans to install 13 single-phase and 10 three-
phase reclosers over the next four years, subject to existing lead times. Id. A single-phase and a
three-phase recloser costs $22,000 and $40,000, respectively, with no annual O&M expense. Id.
The Company also provided three metrics to evaluate this project.
The Drone Inspection Program was a three-year pilot that reduced line patrol, outage
investigation, and vegetation management inspections by roughly 33 percent. Id. The Company
plans to move this program from the pilot stage into standard practice after it determined it was
successful. Id. The pilot included $65,000 in capital expenditures and $10,000 in annual O&M
expenses.Id.
The Satellite Imaging Program is in its third year of the planned three-year pilot. Id. The
program is forecasted at $46,000 per year plus $20,000 for the first-year setup. Id. The targets of
the pilot include: (1) scanning 1,000 miles of line per year, (2) trimming 130 miles of line in
Clearwater County, (3) trimming 84 miles of line outside of Clearwater County, and (4) cutting
hazard trees in 300 locations. The Company also provided two metrics to evaluate this program.
Id.
As the Company continues to implement pilot programs, it is best practice to include this
information as they provide targets and metrics that can be used to measure the program's success.
Should any pilot be promoted to a regular program, Staff believes that the information provided in
discovery may be necessary to include within future WMPs. Therefore, for each pilot program,
Staff suggests the Company include the metrics used to evaluate each pilot program, total
estimated capital and annual O&M, annual targets, timeline, and the descriptions of any benefits
realized to date in future WMPs.
Public Outreach, Engagement and Community Education
Idaho Code § 61-1803(3)(c) and the Guidelines require each WMP to describe how the
utility maintains community outreach and public awareness before, during, and after wildfire
season. Staff believes the Company's WMP meets the requirements of Idaho Code § 61-
STAFF COMMENTS 13 JUNE 2, 2026

1803(3)(c) and the Commission's Guidelines. The Company communicates its WMP with its
members and the community via Ruralite Magazine, its website, bill stuffer publications, and
social media. 2026 WMP at 46. The Company should continue refining and updating its public
outreach, engagement, and community education as necessary for inclusion in future WMPs.
Government Outreach
Idaho Code § 61-1803(3)(d)and the Guidelines require each WMP to include a discussion
of outreach and coordination with federal, state, tribal, and local officials and agencies regarding
wildfire preparedness and emergency response planning. The Company's 2026 WMP meets the
requirements of Idaho Code § 61-1803(3)(d) and the Commission's Guidelines. The Company
developed an Emergency Restoration Plan ("ERP") to prepare and plan for the most efficient
means by which to restore service to customers. Response to Staff s Production Request No. 6,
Exhibit C at 117. The plan includes roles for emergency restoration, a list of government agencies
and tribal partners,key contacts,and mutual aid agreements. 2026 WMP at 40. Federal regulation
requires the Company to exercise its ERP at least annually to ensure operability.Id. at 41.
Method of Line Design and System Hardening
Idaho Code §§ 61-1803(3)(b), 61-1803(3)(e) and the Guidelines require the Company to
include a description of the Company's methods of line design for new lines and planned system
upgrades. The Company identified five design and construction programs for wildfire mitigation:
Undergrounding, Animal Guards, Reduced Span Length in High Wind Areas, Avian Protection,
Increased Phase Spacing, and Fire-Resistant coatings or wraps for high-risk wood poles. 2026
WMP Table 1 at 5; 2026 WMP at 34-37. However, the sections on these topics did not contain
sufficient details for Staff s analysis. Additionally, the 2026 WMP did not include measurable
targets for each Wildfire Mitigation Program. 2026 WMP Table 1 at 5. Additional details such
as costs, projected timelines, alternatives considered, selection criteria, cost reasonableness, and
primary drivers for each project were also omitted. The Company was able to provide costs,
measurable targets,project timelines, and a discussion of benefits and alternatives in Response to
Staff s Production Request Nos. 3 and 5. Table No. 4 below provides a screenshot of some of the
targets provided. Due to needing additional details for Staff s analysis, Staff recommends the
STAFF COMMENTS 14 JUNE 2, 2026

Commission direct the Company to include similar project-level details, including targets,
explanations of the benefits, and alternatives considered for each project in future WMPs.
Table No. 4: 2026-2028 Targets by WMP Category and Year
Request 43:Targets by WMP Category and year
WMP Year
Target Description 1%`--NIP Category- 2026 2027 2 u S
Fire Wrap Design&Construction 1650poles* 1650poles* 300 poles
Under rounding Design&Construction .7 miles 2.9 nines 1.5 nu lc
IR Inspections of Inspection&
Substations Maintenance
Inspection&
Satellite Iniageiy of ROW Maintenance 1000 Miles 1000 Miley 1000 Mile,
Pole Testing and Inspection&
Treatment Maintenance 2800 Poles 2800 poles 2800 poles
' 2026& 2027 n unbers are increased due to receipt of a grant
Staff believes the Company's 2026 WMP met these requirements based on its review of
the 2026 WMP and the additional material provided in discovery. However, Staff has the
following recommendation for future WMP filings.
Reclosers
Response to Staff s Production Request No. 1 states that 92 electronic reclosers are planned
for installation throughout the Company's system over the next four years. Given the scale of the
planned installations, Staff suggests the Company consider at what point this mitigation measure
should move from a pilot project to inclusion within the set of standard wildfire mitigation
programs listed in Table 1 of the 2026 WMP.
Situational Awareness and Monitoring
Idaho Code § 61-1803(3)(f) and the Guidelines require each WMP to discuss how the
Company monitors weather conditions and wildfire risk. The Guidelines specifically require the
Company to identify the systems, tools, or external resources used to monitor weather, fire
potential, or other situational awareness indicators. Guidelines at 6. Sections 2, 5.1.1, and 5.1.2
of the 2026 WMP clearly describe each of the public sources and explain that the Company was
STAFF COMMENTS 15 JUNE 2, 2026

evaluating its own weather station network as a pilot. 2026 WMP at 23-24. Staff believes the
Company has met the requirements; however, Staff identified an area for improvement in future
WMP filings regarding the weather station pilot program.
As detailed in the Pilot Program section,the Company is evaluating its own weather station
network. 2026 WMP at 23 and 38. In Response to Staff s Production Request No. 1,the Company
stated the pilot program was suggested by Vantage Point Solutions; however,it is unclear how the
information from the weather stations would be different from the public source data. The
Company stated that further research was needed before providing more information. Id. Staff
suggests the Company update the status of this pilot program in its next WMP.
Infrastructure Inspections and Maintenance
Idaho Code §§ 61-1803(b), 61-1803(g)(i), and the Guidelines require discussion of the
frequency and standards for inspections of each type of electric infrastructure within areas of
elevated wildfire risk and targets or goals to be achieved within the WMP. Clear inspection
guidelines help enable timely inspections, maintenance, and emergency repairs, reducing
reliability and safety risks during high fire danger conditions and in heightened wildfire risk zones.
The Company's 2026 WMP identifies enhanced inspections for wildfire high potential areas that
include annual patrols before fire season and enhanced inspection intervals. 2026 WMP (Section
5.2.3 and Table 6). Based on its review of the 2026 WMP, Staff believes the Company has met
requirements of the WSCA and Guidelines. However, Staff has identified areas for improvement
in the Company's future WMP filings, as described below.
Quality Assurance
A Quality Assurance ("QA") program for infrastructure maintenance is essential because
it verifies that completed corrective actions have resolved specific issues ensuring safety,
reliability, and accountability in the utility's maintenance practices. The Company described its
QA for inspections in its 2026 WMP at Section 7.4.1. This description did not include what would
be selected for a QA audit (i.e. 100 percent in high fire risk areas, or a 20 percent sample of all-
service-area work), the frequency of the audits (i.e., weekly or monthly), and the process for
addressing any items that failed to meet the Company's standards. Staff requests the Company
consider adding these details to future WMPs.
STAFF COMMENTS 16 JUNE 2, 2026

Deficiency Backlog Monitoring
The Company will identify deficiencies through its inspections and other related activities.
Monitoring the timely correction of these deficiencies relative to their assigned priority is
important for safety and system reliability. A sustained or increasing backlog of overdue repairs
may indicate the need for additional resources or process improvements. Staff suggests the
Company include the following data,for each priority category(e.g.,P 1,P2,etc.),and for the prior
three years, in future WMP filings: (1) the number of deficiencies identified; (2) the number or
percentage of deficiencies repaired within the applicable target timeframe; and (3)the number of
pending deficiencies at year-end,separated into those that are overdue and those that remain within
their target timeframe.
De-Enemization and Operational Practices During Heightened Wildfire Risk Days and Zones
Idaho Code §§ 61-1803(3)(b), 61-1803(3)(g)(ii), and the Guidelines require discussion of
operational changes during heightened wildfire risk days or in high wildfire risk zones, which
includes line settings and restrictions of workforce practices. This is important because operational
changes during heightened wildfire risk days reduce the likelihood of ignition not only from
electrical infrastructure but also from activities performed on that infrastructure, such as routine
maintenance or emergency repairs. The Company states it operates under two seasonal periods:
the Fire Precautionary Period (June 1 — October 1) and the Low Fire Potential Period (Oct. 2 —
May 31). See 2026 WMP at 24. Although Staff believes the Company's 2026 WMP has met the
requirements, Staff has recommendations for improvement for future WMPs.
Operational Practices During Heightened Wildfire Risk Days and Zones
The Company tracks National Weather Service Red Flag Warning ("RFW") days but
doesn't specify how operational practices change when a RFW is in effect. 2026 WMP at 23. The
Company did provide a table describing operational changes as the Company moves from the Low
Fire Potential period to the Fire Precautionary period. Response to Staff s Production Request
No. 12. The table also identified operational changes when a RFW is in effect. Id. As a result of
operational changes occurring when a RFW is in effect, Staff suggests the Company include these
operational changes in future WMPs.
STAFF COMMENTS 17 JUNE 2, 2026

De-Energization with a Public Safety Power Shutoff
The Company outlines its de-energization and re-energization policy in Sections 5.1.5 and
5.1.6 of its 2026 WMP. In a meeting with Staff,the Company explained that,rather than adopting
a formal PSPS program, it intends to rely on configuring reclosers to instantaneously trip without
automatically reclosing, while retaining the option to implement a proactive de-energization if
necessary. A recloser trip automatically de-energizes the affected line segment during a fault and
reduces the amount of line that must be patrolled before service can be restored. In contrast, a
proactive de-energization may impact a larger service area due to current system segmentation and
automated controls.
Staff suggests that the Company evaluate its current system segmentation and consider
modifications that would allow any Company-initiated de-energization to be limited to affected
segments,rather than impacting a broader customer population or larger system areas due to less-
granular segmentation.
Vegetation Management
Idaho Code § 61-1803(3)(g)(iii) and the Guidelines require each WMP to include a
discussion of vegetation management and enhanced vegetation management for heightened fire
risk areas. Staff reviewed the Company's routine and enhanced vegetation management practices
described in the 2026 WMP and believes the Company has met the WSCA and Guidelines
requirements. However, Staff has identified areas of potential improvement in the Company's
future WMP filings.
Quality Assurance
A QA program for vegetation management is essential because it verifies that work is
completed in accordance with its specifications, standards, and right-of-way requirements to
prevent outages and reduce risk. The Company described its QA for vegetation management in
Section 7.4.2 of the 2026 WMP. This description did not include what would be selected for a QA
audit (i.e. 100 percent in high fire risk areas, or a 20 percent sample of all-service-area work), or
the frequency of the audits(i.e.,weekly or monthly). Staff suggests the Company consider adding
these details in future WMPs.
STAFF COMMENTS 18 JUNE 2, 2026

Vegetation Management Training
The Company shared that its vegetation management is done according to standards that
include ANSI A300 and the International Society of Arboriculture ("ISA") guidelines.
Application at 7. These standards address clearances, tree/shrub conditions, how to safely and
appropriately prune or remove vegetation, and vegetation health.
During a meeting held on April 23, 2026,with IDL and the Company, IDL mentioned that
the above standards do not cover the ignition potential or fire propagation perspectives of
vegetation. IDL specifically mentioned that the above standards do not address "ladder" fuels,
which allow wildfires to progress from the ground to the tree canopy. The Company said it will
evaluate whether ISA's Wildfire Risk Reduction Qualification is applicable and useful as a way
of addressing the standard gaps identified by IDL. Response to Staff s Production Request No. 9.
Hazard Trees
The Company stated that it identifies and documents hazard trees during its bi-annual
inspections and that remediation of hazard trees occurs outside of normal vegetation management
cycles. 2026 WMP at 27, 33. The Company also noted that it is piloting the use of drones to
expedite hazard-tree identification. 2026 WMP at 38. However, the WMP does not provide data
on the number of hazard trees identified each year, the number removed or otherwise addressed,
or the number remaining at year-end. Tracking these metrics would help determine whether
additional resources are needed to manage growth in the backlog of hazard trees requiring
remediation.
The Company shared that approximately 30 percent of its system is in wooded areas. 2026
WMP at 2. Staff is concerned that ongoing drought conditions and insect infestations in Idaho
forests may increase tree mortality, accelerating the emergence of hazard trees within the
Company's service territory. Staff recommends that the Company include these hazard-tree
metrics in future WMPs to better monitor, anticipate, and manage potential backlog growth.
Wind Event Prioritization.
During discussions with IDL regarding the Company's 2026 WMP, IDL noted that the
Company's service territory experiences extreme wind events that frequently compromise certain
tree species, particularly in specific soil types. IDL explained that trees lacking a tap root—such
STAFF COMMENTS 19 JUNE 2, 2026

as lodgepole pine, grand fir, spruce, and some alpine fir—are especially prone to becoming hazard
trees after high-wind events due to weakened root structures. Based on this information, Staff
recommends the Company consider increasing the frequency of hazard-tree inspections for a
period of time in service areas affected by recent extreme wind events,particularly in areas where
these more vulnerable tree species are present.
Marketable Timber on Timber Company Land
The WSCA requires each Company to describe its process for providing timber companies
compensation at fair market value for live marketable timber identified for removal from timber
company land adjacent to the Company's Right-of-Way ("ROW"). The Company's 2026 WMP
did not include the required information. However, the Company stated it would provide
compensation in Response to Staffs Production Request No. 7:
The Company will operate in accordance with the Wildfire Standards of
Care Act, which states: "If live marketable timber is identified for removal from
timber company land adjacent to the rights-of-way, compensation at fair market
value shall be made to the landowner for such timber." Regarding timber upon the
Company's rights-of-way, the Company's practice is to attempt to notify all
landowners of the Company's intent to remove live trees prior to removal. No
compensation is paid because the timber is within the Company's right-of-way.The
timber belongs to the private landowner, and the Company's practice is to cut and
leave it in whole tree lengths along the right-of-way.Id.
Staff recommends the Commission direct the Company to include a section documenting
its process for providing timber companies compensation at fair market value for live marketable
timber identified for removal from timber company land adjacent to the Company's ROW in future
WMPs.
STAFF RECOMMENDATIONS
Staff recommends the Commission issue an order to:
1. Approve the 2026 WMP;
2. Clarify that the Company may file its future annual updated Wildfire Mitigation Plan
on or about January 20t' each year; and
3. Meet with IDL and its consultant to identify and correct issues with Company's risk
modeling prior to filing future WMPs.
STAFF COMMENTS 20 JUNE 2, 2026

For future WMPs, Staff recommends the Commission direct the Company to:
1. Provide details of all funding alternatives and sources pursued;
2. Include a narrative explaining how certain mitigation activities, such as grid hardening
efforts, are reducing wildfire risk, as the model will not show any reduction of risk
based on investments in the system;
3. Include project-level details, including the targets, explanation of the benefits, and
alternatives considered for each project; and
4. Include a description of its process for providing timber companies fair market
compensation for live marketable timber identified for removal from timber company
land adjacent to the Company's ROW.
Respectfully submitted this 2nd day of June 2026.
Erika K. Melanson
Deputy Attorney General
Technical Staff: Karla Ducharme, Ray McArthur, Kimberly Loskot
I:\Utility\UMISC\COMMENTS\COI-E-26-01 Comments.docx
STAFF COMMENTS 21 JUNE 2, 2026

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 2nd DAY OF JUKE 2026, SERVED
THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN CASE NO. COI-E-
26-01, BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
Clearwater Power Company:
Susan P. Weeks
JAMES, VERNON & WEEKS, P.A.
1626 Lincoln Way
Coeur d'Alene, ID 83814
EMAIL: sweeksAjvwlaw.net
Bob Pierce
Chief Operating Officer
4230 Hatwai Road
Lewiston, ID 83501
EMAIL: [e-mail]
Intervenor,Potlatch Deltic Forest Holdings, LLC:
Peter J. Richardson
RICHARDSON ADAMS, PLLC
515 N. 27th Street
Boise, ID 83702
EMAIL: [e-mail]
Michele Tyler,Esq.
Wade Semeliss
Brian Schlect, Esq.
Anna Torma
PotlatchDeltic Forest Holdings, LLC
601 W. First Ave, Suite 1600
Spokane, WA 99201
EMAIL:
[e-mail]
wade.semeliss&,potlatchdeltic.com
brian.schlect(,potlatchdeltic.com
anna.torma(&,potlatchdeltic.com
PATRICIA JORD , SECRETARY
CERTIFICATE OF SERVICE