20260604Staff Comments.pdf

RECEIVED
June 04, 2026
KELSEA E. ROSS IDAHO PUBLIC
DEPUTY ATTORNEY GENERAL UTILITIES COMMISSION
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83702
[phone]
IDAHO BAR NO. 12050
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF RAFT RIVER RURAL )
ELECTRIC CO-OP INC.'S APPLICATION ) CASE NO. C11-E-26-01
FOR APPROVAL OF ITS 2026-2028 )
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,Kelsea E. Ross, Deputy Attorney General,
submits the following comments.
BACKGROUND
On January 29, 2026, Raft River Rural Electric Co-op Inc. ("Company") applied to the
Commission requesting approval of its Wildfire Mitigation Plan ("2026 WMP"), in accordance
with Idaho Code § 61-1801, et seq. Wildfire Standard of Care Act ("WSCA") and the Wildfire
Mitigation Plan ("WMP") guidelines established in Commission Order No. 36774 ("Guidelines")
and additional requirements detailed in Order No. 36929.
Under Idaho Code § 61-1803(2)(b), the Company has opted to file its 2026 WMP for
Commission approval. As the Company is an unregulated utility, the Company is not required to
file a WMP for Commission approval.
On March 3, 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. 36952. No petitions to intervene were filed.
STAFF COMMENTS I JUNE 4, 2026

STAFF ANALYSIS
Pursuant to Idaho Code § 61-1804, Staff reviewed the 2026 WMP and believes that the
Company has met all the requirements of the WSCA and the Guidelines. Staff also reviewed the
2026 WMP to ensure: (1)it is consistent with public health, safety, and welfare; (2)it was feasible
and provided the cost of implementation; and (3) 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, (9) vegetation management. Additionally, the Guidelines 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 corporation addresses each of the Commission's Orders and Staffs recommendations.
Staff reviewed each of these items and believes the Company has met these requirements.
Based on its review, Staff recommends the Commission issue an order that: (1) approves
the Company's 2026 WMP; (2) clarifies the Company may file its future annual updated Wildfire
Mitigation Plan on or about January 29th of each year; and (3) directs the Company to include
additional information in future WMP filings, if the Company opts to file again for Commission
approval. Additionally, Staff encourages the Company to include additional items in future WMP
filings, which is discussed below.
While Staff recommends approval of the Company's 2026 WMP, based on Staff s
communications and work with the Idaho Department of Lands ("IDL") on the 2026 WMP, it is
Staff s understanding that IDL has concerns regarding certain elements of the Company's data
sources and related assumptions used to develop the 2026 WMP. IDL has indicated to Staff that
STAFF COMMENTS 2 JUNE 4, 2026

it intends to file public comments outlining its concerns with the 2026 WMP. Staff respectfully
recommends that the Commission consider and weigh IDL's comments alongside Staff s analysis.
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, Staff believes the Commission has
jurisdiction to review WMPs submitted for 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 corporation'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 believes 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, essential elements of WMPs adopted in the Guidelines, and additional
requirements based in the Commission's statutory authority. Without providing information
requested by Staff and responding to Commission direction in future filings, Staff may be unable
to recommend the Commission approve a future WMP.
2026 Wildfire Mitigation Plan Overview and Cross Cutting Elements
In this overview section, Staff provides general observations regarding the 2026 WMP.
This is organized into three main areas: (1) Cost Feasibility, (2) Cross-Cutting Elements, and (3)
STAFF COMMENTS 3 JUNE 4, 2026

Lessons Learned from Previous WMPs. Subsequent sections present comments organized
according to the Guidelines and the WSCA.
Cost Feasibility
Idaho Code § 61-1804(1)(b) requires the Commission to consider the cost of the WMP
implementation. As part of Staff's analysis of cost feasibility, Staff reviewed the Company's cost
forecasts, identified wildfire-related expenditures and grants, and the Company's cost-benefit
approach, as discussed below.
Cost Forecasts. 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 across the
plan horizon of the WMP. Guidelines at 8. The Company provided cost forecasts for its wildfire-
related vegetation management and system hardening programs. 2026 WMP at 52; See also
Response to Staff Production Request No. 25. Staff believes the cost forecasts supplied by the
Company satisfy this requirement. Below in Table No. 1, Staff summarizes the cost forecasts from
the 2026 WMP:
Table No. 1: Cost Forecasts Summary
Expense 2026 2027 2028 2029 Four-Year
Type Total
Vegetation O&M $ 120,000 $ 120,000 $ 120,000 $ 120,000 $ 480,000
Management
System O&M $ 35,000 $ 35,000 $ 35,000 $ 35,000 $ 140,000
Hardening
Capital $ 1,110,000 $1,310,000 $1,310,000 $1,310,000 $5,040,000
Total $ 1,265,000 $1,465,000 $1,465,000 $1,465,000 $5,660,000
Identifying Wildfire Expenditures. Because the WSCA requires the Commission to
consider the cost implementation of a WMP, Staff reviewed the 2026 WMP for wildfire-related
projects. Idaho Code § 61-1804(1)(b). Individual wildfire-related projects are not clearly
identified in the cost forecasts provided in the 2026 WMP nor in discovery responses to Staff. See
2026 WMP Table 8 at 52; See also Response to Staff Production Request No. 25. However, in its
Response to Staff Production Request No. 17,the Company did provide a project breakdown with
STAFF COMMENTS 4 JUNE 4, 2026

the estimated costs associated with its System Improvement Schedule. Staff recognizes the
challenge of separating wildfire-related projects; however, Staff believes the Company has
demonstrated that it is able to narrow down the projects that are related to wildfire mitigation. For
these reasons, Staff recommends the Commission direct the Company to provide detailed,
wildfire-related, project-level cost forecasts for each year as part of all future WMP filings.
Grants. The Commission must consider the cost of implementing WMP. Idaho Code §
61-1804(1)(b). Thus, information on funding alternatives and funding sources is necessary to
evaluate the cost and feasibility of the Company's planned actions. The 2026 WMP did not discuss
any grants that the Company was awarded or applied for. However, in its Response to Staff
Production Request No. 17, the Company stated it had received three grants: (1) the Kelton
Overcurrent Protection Grant for$107,901; (2)the Curlew to Kelton Tie Line Grant for$620,420;
and (3) a grant, without disclosing the amount, for updating reclosers in Cassia County from the
Office of Energy and Mineral Resources. Staff believes information on funding alternatives and
sources, as well as grant amounts, should be provided in a WMP. Further, Staff believes
information on the amounts for each grant need to be included because grant funding may impact
the cost feasibility of wildfire mitigation projects. Therefore, Staff recommends the Commission
direct the Company to provide details, including grant amounts, of all funding alternatives and
sources pursued within future WMPs.
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. In Order Nos. 36774 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. The Company did not
provide wildfire risk mitigation benefits within the 2026 WMP; however, Staff believes the
Company complied with the requirements of the Guidelines because it supplied wildfire risk
mitigation benefits in discovery with Staff. Specifically, in its Supplemental Response to Staff
Production Request No. 20, the Company provided qualitative wildfire risk mitigation benefits.
While benefits may not always be quantified solely in monetary terms, Staff believes the
Company should apply a consistent, transparent, and repeatable methodology across projects.
Such consistency is necessary for Staff and the Commission to evaluate whether projects are
STAFF COMMENTS 5 JUNE 4, 2026

prioritized using comparable criteria. Additionally, when qualitative benefits are applied, the
Company should define those benefits and explain the efficacy in mitigating wildfire risk. Staff
recommends the Commission direct the Company to include wildfire risk mitigation benefits,
whether qualitative or quantitative,in future WMPs.
Cross Cutting Elements
This section addresses several integral components that Staff considered in its review and
analysis of the 2026 WMP, and whether it satisfies Idaho Code §§ 61-1803(2)(a), 61-1804(1)(b)-
(c), and 61-1804(3). Here, Staff provides its analysis of the Company's targets and goals, the
metrics used to monitor progress, the Staff s coordination efforts with the State Forester, and the
anticipated filing date for future WMPs. Together, these topics inform Staffs assessment of the
Company's overall approach to wildfire mitigation planning and continuous improvement.
Targets and Goals within the WMP. Idaho Code § 61-1804(1)(b)-(c) requires the
Commission to evaluate the feasibility of the WMP and the degree it minimizes wildfire risk. Staff
believes that one way for the Company's WMP to support this analysis is through identifying
targets or goals as part of the Company's plan to implement its WMP. The 2026 WMP does not
identify targets or goals of the Company's wildfire mitigation categories. Specifically, the
Company did not provide targets for its risk assessment, system hardening, situational awareness,
outreach and communications,inspection,and vegetation management categories in its WMP. See
2026 WMP at 35 and 49-50. The lack of targets within the WMP hinders Staffs ability to review
and evaluate the feasibility of an electric corporation's wildfire mitigation efforts. In this case,
Staff was able to evaluate the feasibility of the 2026 through other identified system hardening
projects anticipated to be completed supplied by the Company in discovery. Response to Staff
Production Request No. 17. To aid in Staff s analysis of feasibility in future WMPs,Staff suggests
that the Company add measurable targets,where possible, for each WMP category.
Metrics within the WMP. As stated previously,Idaho Code § 61-1804(1)(b)-(c)requires
the Commission to evaluate the feasibility of the WMP and the degree it minimizes wildfire risk.
Another option for the 2026 WMP to support this analysis is through providing metrics that reflect
success factors of its WMP. The 2026 WMP does not describe the metrics the Company will use
STAFF COMMENTS 6 JUNE 4, 2026

to evaluate its wildfire mitigation efforts, operations, and projects. However, the Company
provided some detail in discovery with Staff on how it measures and tracks the efficacy of its
mitigation efforts, such as using "Form 7A" which provides the System Average
Interruption Duration Index ("SAIDI")1. Responses to Staff Production Request Nos. 23 and 24.
Staff believes that metrics—and the underlying data—should be included within a WMP because
they function as practical indicators that support the Company's ongoing evaluation of system
conditions. Therefore, for future WMP filings, Staff recommends that the Commission direct the
Company to include all metrics used within each respective program area and provide the
associated data in a format that allows for easy comparison across WMP cycles. Where available,
Staff further recommends that the Company provide at least three years of historical system- and
circuit-level data to support trend analysis.
Coordination with Idaho Department of Lands. Idaho Code § 61-1804(3) requires the
Commission to consult with the State Forester at IDL, specifically regarding vegetation
management, reduction of wildfire fuels, and other duties of the State Forester under Title 38,
Idaho Code.
On March 18, 2026, Staff met with IDL and the Company to discuss the Company's
wildfire risk assessment process, inspection process, vegetation management practices, identified
projects, situational awareness and cost-benefit process.
On May 15, 2026, Staff met with IDL to discuss concerns with the Company's filing and
current practices pertaining to its WMP. During this meeting, IDL outlined concerns related to
data accuracy within the 2026 WMP and other aspects of the 2026 WMP. Staff understands that
IDL intends to file these concerns as public comments,and Staff recommends that the Commission
consider IDL's comments alongside Staffs analysis when evaluating the 2026 WMP.
Filing Date. Idaho Code § 61-1803(2)(a) gives the Commission authority to stagger the
filing dates of the WMPs. Order No. 36774 directed electric corporations to file updated WMPs
for annual review one year after the filing date of the previously approved WMP. Through
communication with Staff, the Company stated it prefers to keep its annual WMP filing date of
January 29th each year. Staff has no concerns with this filing date since it staggers WMP filings
1 SAIDI represents the total number of minutes of interruption the average customer experiences.
STAFF COMMENTS 7 JUNE 4, 2026

from the other electric utility's filing date requests.2 Staff recommends the Commission issue an
order clarifying that the Company's annual update WMP filing should be submitted on or about
January 29th of each year.
Lessons Learned from Previous WMPs
The Guidelines require the Company to provide an update of lessons learned from the
previously approved WMP filings submitted for Commission review and approval. Guidelines at
8. The Company has not previously filed an Idaho Commission approved WMP, therefore, Staff
believes this requirement does not apply to the 2026 WMP.
However,the Company provided in discovery with Staff some of the lessons it has learned
through previous WMPs developed by the Company. The Company had previously developed a
2020 and 2022 WMP for its service areas in Idaho, Utah, and Nevada.3 In its Response to Staff
Production Request No. 3, the Company stated that after its implementation of new inspection
processes in its 2020 and 2022 WMPs, it resulted in refined inspections criteria and shifted
inspections toward a more proactive approach. The Company stated these changes improved
reliability and safety in both line and substation operations. Id. In Response to Staff Production
Request No. 19, the Company stated that experiences from the past five fire seasons resulted in
operational changes, including: (1) adding alternative profile settings to overcurrent protective
devices to easily adjust them throughout the year; and (2) using raptor framing between
conductors, which has reduced overall power interruptions. In future WMP filings, Staff will
review the lessons learned from the Company's Commission approved WMPs.
Geographical Risk Assessments
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. To meet these
2 In Case No.IPC-E-25-32,Idaho Power requested an annual filing date on or about October 1 each year.In Case No.
AVU-E-25-15,Avista requested an annual filing date on or about November 1 each year.In Case No.PAC-E-25-22,
Staff recommended Rocky Mountain Power have an annual filing date on or about December 1 each year. In Case
No.C07-E-25-01,Staff recommended Kootenai Electric Cooperative have an annual filing date on or about December
31 each year.
s Pacific Northwest National Lab, Wildfire Mitigation Plan Database,
https://wildfire.pnnl. ova /mitigationPlans/pages/documents?stateAndUtility=Idaho-
Raft+River+Rural+Electric+Cooperative&selectedPlan=2e70a2e9-dd20-481a-bbda-f927bed79abI (last accessed
May 8,2026).
STAFF COMMENTS 8 JUNE 4, 2026

requirements, the Company provided a description within Section 3 of the 2026 WMP, as well as
inputs and maps in Appendix A, Appendix B, and Appendix C to its 2026 WMP. Staff believes
the Company followed a reasonable modeling approach to assess the wildfire risk in its territory
and has met the requirements of the WSCA and the Guidelines. However, Staff believes there are
areas for improvement,including: (1)addressing limitations to the risk modeling;and(2)including
a high-level wildfire Risk Analysis Map, as discussed below.
Risk Model Limitations
Within Section 3 of the 2026 WMP and in Appendix B of the 2026 WMP, the Company
described how its third-party vendor, Steven W. Carothers & Associates ("SWCA")
Environmental Consultants, modeled wildfire risk in its service territory. 2026 WMP at 21-36
and Appendix B at B-1. SWCA Environmental Consultants' current risk analysis process for
Idaho utilizes multiple sources of well-established fire behavior models, including Fire Area
Simulator ("FARSITE"), FlamMap, BehavePlus, FireFamily Plus, and Landscape Fire and
Resource Management Planning Tools ("LANDFIRE"). 2026 WMP Appendix B at B-1. SWCA
Environmental Consultants' wildfire risk analysis identifies areas within the Company's service
area that are particularly susceptible to high-intensity and severe wildfire behavior. 2026 WMP at
21. However, Staff has several concerns regarding the current risk modeling approach.
First, Staff consulted with the IDL about the Company' risk modeling on May 15, 2026.
In that meeting, IDL expressed concerns about the lack of detail within the 2026 WMP regarding
whether SWCA Environmental Consultants included a Wildland Urban Interface("WUI")dataset
as an input to the risk model to establish accurate areas of heightened wildfire risk. IDL
represented that without the inclusion of WUI data into the risk model the current risk modeling
approach may have created an inaccurate representation of wildfire risk in the Company's service
territory. Staff believes the Commission should consider IDL's recommendations in its comments
for this issue in conjunction with Staff s other concerns detailed below. As such, Staff
recommends the Commission direct the Company to meet with IDL and SWCA Environmental
Consultants to identify and correct issues with its risk modeling prior to filing its next WMP with
the Commission.
Second, the Guidelines state that risk assessment should consider factors including asset
location. Guidelines at 2. Staff believes SWCA Environmental Consultants' approach to risk
STAFF COMMENTS 9 JUNE 4, 2026

modeling considers the existing wildfire risk due to external factors based on the inputs used to
create the risk analysis. However, Staff believes that its risk modeling is limited by not considering
the risk of ignition from the Company's infrastructure. Understanding infrastructure risk would
enable the Company to identify where to focus investments in its system,in addition to addressing
external wildfire risks such as vegetation. As the Company and SWCA Environmental
Consultants continue to refine the modeling process, Staff suggests the Company consider adding
risk from its infrastructure as an input into the risk model.
Lastly, Idaho Code § 61-1804(1)(c) requires the Commission to consider the degree to
which the plan adequately minimizes wildfire risk. Staff believes that the risk model developed
by SWCA Environmental Consultants is one potential area where the Company can explain how
it is adequately minimizing wildfire risk from its infrastructure. Without infrastructure risk
considered in the model, the model will not show any reduction of risk based on investments in
the system. The Company was able to provide some qualitative benefits of its mitigation efforts
in its Supplemental Response to Staff Production Request No. 1 and in discussions with Staff.
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.
Risk Analysis Map
As required by the Guidelines, the Company included Appendix C within its WMP,which
depicts the Company's heightened wildfire risk areas within its Idaho service territory. 2026 WMP
Appendix C at C 13—C28. For Idaho,there are 15 separate maps of risk areas. Id. Although Staff
believes the Company has met the requirements with the maps provided in Appendix C,the WMP
does not include one map that depicts the entire wildfire risk for the Company's whole service
territory. To provide a high-level overview of the Company's wildfire risk, Staff suggests the
Company consider including a figure that provides a high-level overview of wildfire risk that
encompasses the Company's entire service territory in future WMP filings.
Optional Preventative Actions and Programs
In addition to required material, the Guidelines state that an electric corporation may
include other actions or programs, such as system hardening strategies, workforce preparedness,
STAFF COMMENTS 10 JUNE 4, 2026

and pilot programs in its WMP. Guidelines at 3-4. Regarding pilot programs, in its initial
discussions with Staff,the Company represented that it does not have any at this time. Regarding
system hardening strategies, Staff believes said strategies correlate with the requirements under
Idaho Code § 61-1803(3)(e), and therefore, Staff will discuss system hardening in the"Method of
Line Design and System Hardening" section of Staff s comments.
Regarding workforce preparedness, Staff believes a trained workforce supports the safe
and effective implementation of wildfire mitigation measures, including situational awareness,
emergency response, and line operations. Staff also believes a trained workforce not only fulfills
regulatory obligations but also strengthens operational resilience, reduces the likelihood of safety
incidents during wildfire season, and supports timely, coordinated responses when conditions
escalate. The Company did not include workforce training or preparedness information in its 2026
WMP. However, the Company provided information regarding wildfire mitigation training in
Response to Staff Production Request No. 15. For future WMPs, the Company should consider
including its training plan and the extent it executed its plan in a table or appendix.
Public Outreach, Engagement, and Community Education
Idaho Code § 61-1803(3)(c)and the Guidelines require each WMP to include a description
of how the utility maintains community outreach and public awareness before, during, and after
wildfire season. Staff believes the 2026 WMP meets the requirements of the WSCA and the
Guidelines. The Company communicates information regarding its WMP with its members and
the community through social media and its website. 2026 WMP at 51. Staff encourages the
Company to continue refining and updating its public outreach, engagement, and community
education efforts 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. Staff believes the 2026 WMP satisfies
these requirements. Before the annual fire season, the Company coordinates inspections,
maintenance, repair, and reconstruction activities with federal agencies. 2026 WMP at 50. The
STAFF COMMENTS 11 JUNE 4, 2026

Company also relies on information from the Bureau of Indian Affairs and local tribal mitigation
plans for wildfire preparedness and emergency response planning. Id. at 14.
The Company further coordinates with county emergency managers to discuss the fire
season outlook, and potential red flag periods. Id. at 51. The WMP includes roles for emergency
restoration, a listing of government agency and tribal partners, key contacts, and mutual aid
agreements. Id. Staff encourages the Company to continue refining and updating its government
outreach efforts as necessary for inclusion in future WMP filings.
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. Further, the Guidelines require an explanation of how the Company clearly identifies,
selects, and evaluates projects that reflect a balance of mitigation costs with resulting reduction of
wildfire risk. Guidelines at 5. The Company described its procedures and approach to system
hardening in Sections 4.4 and 7 of its 2026 WMP. 2026 WMP at 43-45, 51. These sections list
projects that include: (1)hazard tree remediation; (2)right-of-way("ROW")maintenance; (3)bird
and raptor design and mitigation measures; (4) advanced protection and control measures; and(5)
reconstruction of aging lines with shorter spans to reduce conductor contact. Id.
However, Staff believes the 2026 WMP did not contain sufficient detail to explain how the
Company identifies evaluates and selects projects such as expected benefits, measurable targets,
alternatives considered, and selection criteria or reasonableness of costs for each project necessary
to inform Staff s analysis. In discovery with Staff, the Company provided this information in its
Responses to Staff Production Request Nos. 17 and 25. Staff recommends the Commission direct
the Company to provide information on how the Company identifies, evaluates, and selects
wildfire-related projects, at the project-level and include the details described above, in future
WMP filings. Based on its review of the 2026 WMP and the additional material provided in
discovery, Staff believes the 2026 WMP meets the requirements of the WSCA and the Guidelines.
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
STAFF COMMENTS 12 JUNE 4, 2026

Company to identify the systems, tools, and external resources used to monitor weather, fire
potential, or other situational awareness indicators. Guidelines at 6. Section 5 of the 2026 WMP
describes the Company's current weather monitoring process at a high level. 2026 WMP at 49.
In its initial meeting with Staff, the Company further explained it uses public weather sources to
monitor weather and wildfire risk, such as local weather applications and the United States Forest
Service red flag warnings. Additionally, the Company stated it has daily meetings with its staff,
monthly safety meetings, and seasonal meetings with federal agencies to maintain its situational
awareness of wildfire risk.
Based on the material in the 2026 WMP on weather monitoring,and additional information
provided by the Company in meetings with Staff, Staff believes the Company has met the
requirements of the WSCA and the Guidelines. However, because necessary information on
weather monitoring was supplied to Staff through discovery, and not in the 2026 WMP as Staff
believes is required, Staff recommends the Commission direct the Company to include a
description of each external weather source and include additional information of the situational
awareness meetings within future WMPs.
Infrastructure Inspection and Maintenance
Idaho Code §§ 61-1803(3)(b), 61-1803(3)(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.
Based on its review of the 2026 WMP, Staff believes the Company has met the WSCA and
Guidelines requirements. However, Staff has identified areas for improvement in the Company's
future WMP filings, as described below.
Enhanced Inspection Details
The Company identifies and ranks specific high-risk line segments and outlines
corresponding action plans, including areas that require more frequent line inspections. 2026
WMP Appendix C at 1-15. However, the Company does not provide any numerical detail (e.g.
yearly instead of every five years) or explanation regarding the extent of this increased frequency.
STAFF COMMENTS 13 JUNE 4, 2026

To provide a clear mitigation strategy, Staff suggests the Company consider including additional
information specifying the schedule of the increased line inspection frequency in future WMPs.
Quality Assurance
Staff believes a Quality Assurance ("QA") program for infrastructure maintenance is
beneficial because it verifies that completed corrective actions have resolved specific issues,
ensuring safety, reliability, and accountability in the utility's maintenance practices. In Section
4.1.4 of the 2026 WMP, the Company describes its process for reviewing inspection records;
however, this description did not include any details regarding actual field audits of completed
work. 2026 WMP at 37. In discovery with Staff, the Company provided more details of its QA
approach and described that there is no formal process for QA, but that the Line Superintendent
was responsible for making sure work was completed appropriately. Response to Staff Production
Request No. 9. Staff suggests that the Company consider including the information regarding how
it performs QA reviews of infrastructure maintenance work in future WMPs.
Deficiency Backlog Monitoring
Staff believes that as the Company identifies deficiencies through its inspections and other
related activities, the Company should monitor its progress in correcting those deficiencies. Staff
also believes monitoring and correcting inspection deficiencies according to respective priority
categories is beneficial to protect safety and system reliability because a growing backlog signals
that additional resources or process changes are needed to keep risks from escalating. The
Company provided a list of deficiencies related to infrastructure in its Response to Staff Production
Request Nos. 1 and 2. Staff suggests the Company include data in future WMP filings for
deficiencies related to infrastructure for the prior three years similar to what the Company provided
in Response to Staff Production Request Nos. 1 and 2, which includes: (1) the number of
deficiencies identified by priority category (Major, Moderate, Minor); (2) the number or
percentage of deficiencies repaired by priority category; (3) remediation targets by category; (4)
average time to repair by category type; and(5)pending repairs at year-end by category.
STAFF COMMENTS 14 JUNE 4, 2026

De-Energization and Line Operation Practices
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 including
line settings and restrictions to workforce practices. Staff believes 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 that it monitors local and regional
weather events to identify periods of increased fire risk. 2026 WMP at 49. The Company
describes its de-energization, line recloser settings, and restoration of service practices in Sections
4.5 and 4.6 of its 2026 WMP. In discovery with Staff, the Company provided information on its
operational changes during increased fire risk periods, which included details such as increased
emphasis on wildfire awareness and ignition prevention measures in safety tailboard meetings.
Response to Staff Production Request No. 10.
Even though Staff believes what was provided in the 2026 WMP as it relates the
Company's operations during heightened wildfire risk days and in high wildfire risk zones met the
requirements of the WSCA and the Guidelines, Staff suggests the Company include the
supplemental information provided in discovery on its operational changes in future WMPs
because that material offers better insight into the Company's operational changes during
heightened wildfire risk days.
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. See 2026 WMP at 37-42. However, Staff identified areas of potential improvement
in the Company's future WMP filings, as described below.
Quality Assurance
Staff believes a QA program for vegetation management is beneficial because it verifies
that work is completed in accordance with applicable specifications, standards, and right-of-way
STAFF COMMENTS 15 JUNE 4, 2026

requirements to prevent outages and reduces wildfire risk. The 2026 WMP did not include any
information on vegetation management program's QA process. However, in Response to Staff
Production Request No. 8, the Company described its QA for vegetation management. As this
additional information exists,but is not recognized in the 2026 WMP, Staff suggests the Company
consider including these details in future WMPs to improve clarity and transparency.
Enhanced Inspection Details
The Company identifies and ranks specific high-risk line segments and outlines
corresponding action plans, including increasing the frequency of vegetation management
inspections. 2026 WMP Appendix C at 1-15. However, the Company does not provide any
numerical detail or explanation regarding the extent of this increased frequency, similar to
inspection frequency of line segments described above. To provide a clear mitigation strategy,
Staff suggests the Company consider including additional information regarding schedule changes
and the need for more frequent vegetation management inspections in future WMPs.
Vegetation Management Training
In a meeting on March 18, 2026, with IDL and Staff, the Company shared that its
vegetation management is done according to standards that include the American National
Standards Institute("ANSI")A300. These standards address clearances,tree and shrub conditions,
methods for safely and appropriately pruning or removing vegetation while maintaining vegetation
health. IDL mentioned that ANSI standards do not cover the ignition potential or fire propagation
of vegetation. Specifically, the standards do not address "ladder" fuels, which allow wildfires to
progress from the ground to tree canopies. In a meeting with Staff on May 15, 2025, IDL further
stated that the sage brush and juniper trees in the Company's territory are examples of vegetation
that can promote this ladder-fuel behavior, where ignition can transfer from sagebrush to juniper.
Because of this, Staff suggests the Company evaluate if the Internation Society of Arboriculture's
Wildfire Risk Reduction Qualification is applicable and useful as a way of addressing the ANSI
A300 standard gaps identified by IDL.
STAFF COMMENTS 16 JUNE 4, 2026

Marketable Timber on Timber Company Land
Idaho Code § 61-1803(3)(g)(iii) 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 power line ROWs.
The 2026 WMP did not include this required information. However in discovery with Staff, the
Company stated it has no current process for compensating timber landowners for marketable
timber and that its service territory has very few trees in general. Response to Staff Production
Request No. 16. In further communication with Staff,the Company clarified that there is no timber
company land within its service territory or adjacent to its ROWS. Accordingly, Staff believes
Idaho Code § 61-1803(3)(g)(iii) is not currently applicable to the Company's operations. If
circumstances change in the future, the Company should include a section addressing this
requirement in future WMP filings.
Public Comments
As of June 4, 2026, there have been no public comments filed.
STAFF RECOMMENDATION
Staff recommends the Commission issue an order that:
1. Approves the Company's 2026 Wildfire Mitigation Plan;
2. Clarifies the Company may file its future annual updated Wildfire Mitigation Plan on
or about January 29th of each year; and
3. Directs the Company to meet with IDL and its consultants to correct the Company's
wildfire risk assessment prior to filing its next WMP.
For future WMP filings, Staff recommends the Commission direct the Company to:
1. Provide detailed, wildfire-related project-level cost forecasts for each year;
2. Provide details of all funding alternatives and funding sources pursued;
3. Include wildfire risk mitigation benefits, whether qualitative or quantitative, as part of
its cost-benefit analysis;
STAFF COMMENTS 17 JUNE 4, 2026

4. Include all metrics used within each respective section and provide the data in a format
that can easily be tracked across WMP filings,with at a minimum of three years of data
if available;
5. Provide an explanation of how certain mitigation activities, such as grid hardening
efforts, are reducing wildfire risk;
6. Include an explanation of how the Company identifies, evaluates, and selects wildfire-
related projects;
7. Include the wildfire-related project-level details that include targets, expected wildfire
mitigation benefits, and alternatives considered within the respective sections of the
WMP;
8. Include a description of each external weather source and include additional
information of the situational awareness meetings; and
9. Include additional details about the Company's weather station network, including
areas of focus, average cost, and any metrics it will use to evaluate success of the
network.
Respectfully submitted this 4th day of June 2026.
Kelsea E. Ross
Deputy Attorney General
Technical Staff. Kimberly Loskot, Karla Ducharme, and Ray McArthur
I:\Utility\UMISC\COMMENTS\C11-E-26-01 Comments.docx
STAFF COMMENTS 18 JUNE 4, 2026

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 4TH DAY OF DUNE 2026, SERVED
THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN CASE NO. C11-
E-26-01, BY E-MAILING A COPY THEREOF TO THE FOLLOWING:
Raft River Rural Electric Co-op
David F. Shirley
Attorney
Parsons, Loveland, Shirley& Miller LLP
137 West 13'h Street
P.O. Box 910
Burley, ID 83318
EMAIL: dshirleygma icg valley
Mike Christensen
Operations Superintendent
155 North Main
P.O. Box 617
Malta, ID 83342
EMAIL: mchristensengrrelectric.com
PATRICIA JORDAfT, SECRETARY
CERTIFICATE OF SERVICE