20260609Final_Order_No_37063.pdf

Office of the Secretary
Service Date
June 9,2026
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF ROCKY MOUNTAIN ) CASE NO. PAC-E-25-22
POWER'S APPLICATION FOR APPROVAL )
OF THE 2026-2028 IDAHO WILDFIRE ) ORDER NO. 37063
MITIGATION PLAN )
On December 19, 2025, Rocky Mountain Power, a division of PacifiCorp ("Company")
applied to the Idaho Public Utilities Commission("Commission")requesting that the Commission
approve its 2026-2028 Idaho Wildfire Mitigation Plan ("WMP"), in accordance with Idaho Code
§ 61-1801, et seq., the Wildfire Standard of Care Act("WSCA"), and the Commission Guidelines
established in Order No. 36774 (Commission Guidelines").
On January 23, 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. 36912. Intervention was granted to Ruveon,LLC, an affiliate of Bayer Corporation("Bayer").
Order No. 36951.
On March 5, 2026, the Commission issued a Notice of Modified Procedure, establishing
deadlines for public comments and Company reply comments. Order No. 36955.
Based on our review of the record,the Commission now issues this Final Order approving
the Company's 2026 WMP.
BACKGROUND
On July 1, 2025, the WSCA, Idaho Code §§ 61-1801 et seq., became effective. Through
enactment of the WSCA, the Idaho Legislature established a framework intended to support the
continued delivery of safe, reliable, and cost-effective electric service while addressing the
growing risks associated with wildfires. Idaho Code § 61-1802. The Legislature recognized that
wildfire preparedness and response have become increasingly significant components of utility
system planning and operations, particularly for electric utilities responsible for transmission and
distribution infrastructure throughout the state.Id.
The Legislature further acknowledged the Commission's role in overseeing electric utility
compliance with applicable statutes, regulations, and safety standards. Id. In adopting the WSCA,
ORDER NO. 37063 1

the Legislature emphasized that utilities should proactively identify, mitigate, and respond to
wildfire risk in a manner that protects public safety and property while also ensuring that utility
expenditures remain prudent and rates remain affordable for customers.Id.
Under the WSCA, electric corporations regulated as public utilities under Idaho Code
§§ 61-119 and 61-129 are required to "adopt and file" WMPs with the Commission for review.
Idaho Code § 61-1803(2)(a). The statute also permits municipal and cooperative utilities to
voluntarily submit WMPs for Commission consideration.Idaho Code § 61-1803(2)(b). If a WMP
is filed by a municipal or cooperative utility the Commission can assess reasonable fees to such
entity which"may not exceed the actual reasonable cost incurred by the Commission for the review
and consideration of a plan submitted to it."Id.
Commission-approved WMPs shall be implemented upon approval and be reviewed and
updated annually. Idaho Code 61-1803(4). A Commission-approved WMP establishes the
operational and risk-mitigation measures the utility will undertake to prepare for and respond to
wildfire-related threats and helps define the utility's responsibilities to the public and its customers.
Idaho Code § 61-1805.
The WSCA also creates a rebuttable presumption in wildfire-related litigation that an
electric corporation acted without negligence if it reasonably implemented a Commission-
approved WMP.Idaho Code § 61-1806(1). To ensure ongoing oversight and continued adaptation
to changing conditions,the statute requires utilities to review and update their WMPs annually and
to submit periodic compliance reporting as directed by the Commission. Idaho Code §§ 61-
1803(4), 61-1804.
Consistent with the WSCA, on September 30, 2025, the Commission issued Order No.
36774 establishing a procedural schedule for WMP filings. The Order directed utilities to submit
its initial WMP no earlier than October 1, 2025, and to file annual updates one year following
approval of each preceding WMP. Order No. 36774 at Exhibit A.
THE APPLICATION
The Company stated that its WMP was developed to comply with Idaho Code § 61-
1803(3), the Commission Guidelines, and the directives established in Order No. 36405.
Application at 2. The WMP described the strategies, practices, and mitigation measures the
Company intends to use to address wildfire risk while balancing mitigation costs against reductions
ORDER NO. 37063 2

in wildfire risk exposure. Id. The Company explained that its risk-informed cost-and-benefit
framework guided the selection and prioritization of mitigation activities designed to meaningfully
reduce wildfire risk. Id. Appendix A of the WMP detailed the Company's compliance with
applicable Commission orders and the requirements of the WSCA and demonstrated how the
WMP satisfied statutory and regulatory requirements. Id.
The Company acknowledged that wildfire risk had historically existed throughout its
service territory, including Idaho, and recognized that such risk was inherent to operating an
electric utility in the western United States. Id. at 3. The Company noted that the frequency,
severity, and costs of catastrophic wildfires had increased significantly across the region,
prompting utilities to place greater emphasis on wildfire mitigation. Id. The Company stated that
it remained committed to long-term investments intended to reduce wildfire risk and described
efforts to construct, maintain, and operate electrical infrastructure in a manner designed to
minimize wildfire ignition potential.Id.
The Company's baseline risk analysis framework consisted of data collection and analysis,
risk evaluation, risk treatment, and risk monitoring and review. Id. The Company reviewed fire
history, causes, acreage impacts, and seasonal occurrence patterns to identify and prioritize
wildfire risks.Id. Annual wildfire risk assessments incorporated models using vegetation,weather,
topography, historical fire occurrence, and asset location data. Id. Risk maps identified areas with
elevated wildfire risk and are reviewed annually to determine whether updates or changes in
mitigation priorities were necessary.Id.
The Company implemented a variety of preventative programs, including inspection and
correction activities, vegetation management, situational awareness technologies, and operational
restrictions during periods of elevated wildfire risk.Id. at 4. Routine inspections and supplemental
visual patrols are conducted ahead of high-risk conditions, while areas designated as Fire High
Consequence Areas("FHCAs") are subject to enhanced inspection requirements.Id. Although the
Company's risk models had not identified any Idaho geographic areas for FHCA designation at
the time of filing, the Company stated that it would continue evaluating Idaho service territory
conditions for potential future inclusion.Id.
Vegetation management efforts were intended to reduce the likelihood of vegetation
contacting power lines and causing ignitions. Id. The Company maintained both regular cycle
ORDER NO. 37063 3

maintenance and enhanced vegetation management programs. Id. Regular cycle maintenance
included tri-annual inspections, vegetation pruning, and removal of dead or hazardous trees near
electrical facilities. Id. Enhanced vegetation management involved annual off-cycle inspections
within FHCA territories and could also be applied in Idaho even in the absence of a formally
designated FHCA. Id. The Company also shortened vegetation management cycles in wildfire-
prone areas, implemented risk tree programs,and tracked measurable targets such as miles cleared
and hazardous trees removed.Id.
The WMP described operational adjustments designed to reduce wildfire risk, including
modified relay settings, altered re-energization protocols, enhanced safety settings, additional
patrols during elevated risk periods, and deployment of fault indicators to expedite restoration
activities. Id. at 5. The Company recognized that such measures could increase outage frequency
and duration but stated that it continually evaluated these strategies to balance wildfire mitigation
objectives with customer reliability needs.Id.
System strengthening initiatives included pole replacements, conductor upgrades,
undergrounding projects, and retrofitting or replacing legacy equipment where cost-effective. Id.
These efforts were intended to improve system resilience and reduce the likelihood that electrical
infrastructure would create ignition sources during fault events. Id.
The Company also emphasized workforce training, pilot programs, and continuous
improvement efforts.Id. Throughout the year,the Company defers nonessential work in high-risk
areas, imposed operational restrictions based on weather conditions, equipped field personnel with
firefighting tools and training, and deployed enhanced communication technologies such as
Starlink satellite devices.Id.
The Company further described its Public Safety Power Shutoff("PSPS")Program, which
authorizes proactive de-energization during periods of extreme wildfire risk. Id. at 6. The
Company explained that PSPS events could be initiated based on factors such as high winds, low
humidity, and dry fuel conditions and were intended to supplement other wildfire mitigation
measures.Id. The Company's WMP detailed PSPS decision-making processes, coordination with
public safety partners, customer notification procedures, support for critical facilities, and re-
energization protocols. Id.
ORDER NO. 37063 4

The Company outlined a coordination and outreach strategy involving public safety
agencies, emergency managers, the Forest Service, the Bureau of Land Management, and local
stakeholders. Id. at 6-7. Activities included workshops, tabletop exercises, Community Resource
Center demonstrations, functional exercises, and collaborative mitigation planning. Id. Customer
outreach efforts included public service announcements, educational materials, and notifications
delivered through mail, email, text messaging, and web platforms. Id. at 6. The Company stated
that it maintained proactive communication before, during, and after wildfire season and ensured
that vulnerable populations and critical infrastructure received advance notice during PSPS events.
Id.
The Company also described its situational awareness capabilities, including real-time
simulations, advanced weather forecasting, wildfire modeling, and daily operational assessments.
Id. at 7. The Company's meteorology department uses advanced numerical weather prediction
models to forecast weather-related impacts to the electrical system. Id. Coordination with
neighboring utilities and regional partners facilitated awareness of broader wildfire and de-
energization conditions throughout the region.Id.
Inspection and correction programs covered transmission, distribution, and substation
assets located in elevated wildfire risk zones. Id. at 8. The Company established standards and
schedules for inspections and classified defects according to priority levels for correction. Id.
Numerous policies,procedures,and standard operating practices governing inspections,vegetation
management, de-energization, and wildfire operations were identified in Appendix C of the WMP.
Id. at 8-9.
Finally, the Company provided cost forecasts for wildfire mitigation investments and
operations and maintenance ("O&M") expenditures through 2028. Id. at 10. The WMP projected
approximately $13.9 million in additional investments, including $8.1 million in capital
expenditures, to implement the mitigation activities described in the WMP.Id.
STAFF COMMENTS
Staff reviewed the Company's WMP pursuant to Idaho Code § 61-1804 and believed that
the plan complied with the requirements of the WSCA, Commission Order No. 36405, and the
Commission Guidelines. Staff Comments at 1-2. Staff evaluated whether the WMP protected
public health, safety, and welfare; whether the proposed mitigation measures and associated
ORDER NO. 37063 5

expenditures were feasible;and whether the plan adequately minimized wildfire risk and addressed
wildfire response capabilities.Id. at 2. Staff believed that the Company had satisfied the required
WMP components, including geographical risk assessments, preventative actions and programs,
public outreach and government coordination, methods of line design, situational awareness and
monitoring, infrastructure inspection and maintenance, de-energization practices, vegetation
management, lessons learned, cost forecasts, and compliance with Commission directives. Id.
Accordingly, Staff recommended that the Commission approve the Company's WMP and require
the Company to continue filing updated WMPs annually on or about December 1 of each year.Id.
Although Staff found the WMP compliant overall, it also identified numerous areas where future
filings could include additional information, greater transparency, and more measurable
performance metrics.Id.
Staff's review focused on the feasibility and cost effectiveness of the Company's wildfire
mitigation activities. Id. at 3. Staff observed that the Company's WMP filing only provided
incremental wildfire mitigation costs for 2026 through 2028 and omitted comprehensive baseline
budget information as well as vegetation management forecasts. Id. Although the Company later
supplied supplemental program-level cost information through discovery responses, Staff
recommended that future WMP filings include complete capital and O&M forecasts broken down
by individual programs and categories, with wildfire-related costs separately identified whenever
possible. Id. Staff noted that the Company forecast approximately $13.7 million in incremental
wildfire mitigation investments between 2026 and 2028, consisting of approximately $8 million
in capital expenditures and $5.7 million in O&M expenses. Id. at 6. This represented a decrease
from the Company's 2024 WMP forecast of approximately$31.4 million in total investments.Id.
Staff explained that the reduction primarily resulted from lower projected spending on system
hardening activities and operational work practices. Id.
Staff also reviewed the Company's wildfire mitigation labor forecasts and believed that,
although the Company included a "Wildfire Mitigation Program Delivery" line item as required
by prior Commission orders, the WMP itself did not identify any associated labor costs. Id. at 4.
Supplemental discovery responses revealed approximately $163,200 in Idaho-allocated internal
labor costs. Id. Staff therefore recommended that the Commission continue requiring separate
ORDER NO. 37063 6

labor cost reporting in future WMPs to allow comparisons across Idaho's investor-owned utilities
and to track changes in labor expenditures over time.Id.
In evaluating the Company's cost-benefit analysis efforts, Staff believed that the Company
generally complied with prior Commission directives requiring analyses of wildfire mitigation
alternatives. Id. However, Staff expressed concern that the Company had not provided actual
project-level analyses for Idaho because the Company identified no FHCAs within its Idaho
service territory.Id. The Company stated that system hardening investments were prioritized only
within FHCAs and therefore did not perform detailed alternative analyses for Idaho projects. Id.
Staff disagreed with this interpretation and recommended that projects such as conductor upgrades,
relay replacements, weather station installations, and other mitigation investments within Idaho
Areas of Interest("AOIs") should also be evaluated through formal cost-benefit analyses.Id. at 4-
5. Staff additionally recommended that future WMPs include estimated costs for mitigation
alternatives such as non-wooden poles, undergrounding, and covered conductors in to allow the
Commission to better evaluate the relative effectiveness and reasonableness of proposed wildfire
mitigation strategies. Id. at 5. Staff also noted that the Company was developing a "Risk Spend
Efficiency" evaluation tool intended to improve future cost-benefit analysis efforts.Id.
Staff reviewed the Company's use of grants and alternative funding sources and believed
that this information should be more prominently included within future WMPs. Id. Through
discovery responses, the Company disclosed that it had received a $650,000 Idaho State Energy
Resiliency Grant for a Madison County project and a separate $50 million award from the U.S.
Department of Energy to support advanced network technology and fault circuit indicators.Id. The
Company also disclosed that it had unsuccessfully applied for an additional grant through the
Office of Energy and Mineral Resources. Id. Staff recommended that future WMPs identify all
pursued funding opportunities, grant awards, and associated project details because such funding
could reduce wildfire mitigation costs borne by ratepayers and assist the Commission in evaluating
the feasibility of planned mitigation activities.Id. at 5-6.
Staff reviewed the Company's wildfire risk modeling methodology and believed that it
generally reflected sound industry practices. Id. at 8. The Company utilized Technosylva's
FireSight Wildfire Analyst Enterprise platform to evaluate wildfire risk through a framework that
incorporated data collection, risk evaluation, risk treatment, and continuous monitoring. Id. The
ORDER NO. 37063 7

model calculated wildfire risk as the product of ignition likelihood and consequence severity and
used two primary metrics: Risk Association with Ignition Location and Risk Association with
Value Exposure. Id. at 8-9. These metrics incorporated variables such as fire spread potential,
terrain, fuels, structures at risk, and community impacts to produce composite risk scores across
one-mile by one-mile grid cells.Id. at 9. Based on those scores,the Company categorized wildfire
risk areas into FHCAs, AOI I, and AOI II.Id. Staff noted that the Company identified no FHCAs
in Idaho and therefore relied primarily on operational controls and situational awareness rather
than extensive infrastructure hardening.Id.
Although Staff found the overall modeling framework reasonable, it identified six major
areas for improvement. Id. at 9-10. First, Staff observed that the Company excluded generation
facilities,battery energy storage systems,and other non-line assets from wildfire ignition modeling
despite the potential fire risks associated with those facilities. Id. at 11. Second, Staff noted that
the Company did not use Company-specific ignition data because the data remained under review
and validation; instead, the Company relied on generalized ignition probability proxies. Id. Staff
warned that this approach could either understate or overstate actual ignition risk. Id. Third, Staff
expressed concern that the model failed to establish a direct statistical relationship between
probability of failure and probability of ignition, potentially biasing overall risk calculations. Id.
Fourth, Staff questioned the adequacy of the Company's one-mile grid resolution because larger
grid sizes could obscure smaller wildfire "hot spots" and reduce modeling precision compared to
other Idaho utilities that used significantly smaller grid cells. Id. at 12. Fifth, Staff observed that
the Company's model did not separately quantify potential loss of life,wildlife impacts,ecosystem
damage, or timber losses as distinct consequence categories.Id. Sixth, Staff criticized the absence
of benchmarking against publicly available wildfire risk maps such as the U.S. Forest Service
Wildfire Hazard Potential maps and FEMA's National Risk Index. Id. at 13. Staff recommended
that future WMPs address each of these modeling concerns and provide additional transparency
regarding validation efforts.Id. at 10.
Staff also reviewed the Company's workforce preparedness, pilot programs, public
outreach efforts, and governmental coordination activities. Id. at 13-15. Staff believed that the
Company met applicable outreach and preparedness requirements through employee training
programs, webinars, public information campaigns, informational videos, social media
ORDER NO. 37063 8

communications,billing inserts, and coordination with federal, state,tribal, and local agencies.Id.
at 13. However, Staff recommended that future WMPs provide additional detail regarding training
participation rates, training frequency, specific partner organizations, and cost-sharing
arrangements. Id. at 13-14. Staff further noted that the Company operated several pilot programs
outside Idaho, including fault detection sensors, Gridware line sensors, and drone inspections, and
recommended that future WMPs include summaries of all pilot programs, estimated costs,
durations, and performance metrics even if those programs were not currently deployed within
Idaho.Id. at 14.
Staff reviewed the Company's methods of line design and system hardening and believed
that the Company's overall approach is reasonable given the absence of FHCAs in Idaho. Id. at
15. The Company planned limited system-strengthening projects in Idaho, including breaker and
relay replacements at substations in Rexburg, Ashton, and Shelley. Id. Staff recommended that
future WMPs include measurable project goals, timelines, cost justifications, project selection
criteria, and estimated wildfire risk reduction benefits associated with those upgrades. Id. at 15-
16. Staff also addressed the Company's use of fire mesh pole wraps and recommended that future
WMPs describe the Company's installation practices, estimated per-pole costs, and accounting
treatment for those mitigation activities.Id. at 16.
In reviewing situational awareness and monitoring activities, Staff believed that the
Company satisfied statutory and Commission requirements. Id. at 17. The Company forecast
approximately $1.9 million in capital expenditures and $3.2 million in O&M expenses over the
three-year WMP period for weather monitoring, fire detection, and operational awareness
activities. Id. Staff believed the Company's use of weather forecasting systems, weather stations,
and wildfire detection technologies is generally appropriate but recommended additional detail
regarding publicly available weather data sources, installation targets for new weather stations,
deployment plans for wildfire detection cameras, and metrics used to evaluate camera
effectiveness. Id. Staff also encouraged the Company to provide more transparent cost-benefit
analyses for future situational awareness investments.Id. at 18.
Staff s review of infrastructure inspection and maintenance practices similarly concluded
that the Company generally complied with WSCA and Guideline requirements.Id. However, Staff
recommended that future WMPs provide additional data concerning inspection deficiencies,repair
ORDER NO. 37063 9

priorities, remediation timelines, and pending corrective work. Id. Staff also encouraged the
Company to establish and describe formal quality assurance ("QA") procedures for inspection
programs similar to those already used for vegetation management activities. Id. at 18-19. Staff
explained that improved QA processes would enhance accountability,safety,and system reliability
in wildfire-prone areas. Id. at 19.
With respect to operational practices and PSPS procedures, Staff believed that the
Company's WMP generally satisfied applicable requirements but lacked sufficient detail regarding
changes in workforce practices during elevated wildfire conditions. Id. at 19-20. Staff
recommended that future WMPs include detailed tables describing operational restrictions, fire
watch requirements, vehicle equipment requirements, and changes to field activities based on
increasing fire risk levels.Id. at 20. Staff also noted that the Company had conducted a PSPS event
in Utah during 2025 and encouraged the Company to continue refining its PSPS protocols using
lessons learned from planned and executed events.Id. at 19-20.
Staff also reviewed the Company's vegetation management practices and believed them to
be generally compliant with statutory and guideline requirements.Id. at 20. The Company utilized
vegetation management standards such as ANSI A300, National Electrical Safety Code
requirements, and North American Electric Reliability Corporation standards. Id. However, Staff
observed that these standards primarily addressed vegetation clearances and reliability rather than
wildfire ignition and propagation risks, particularly "ladder fuels" that allow fires to spread
vertically into tree canopies. Id. at 20. Staff therefore recommended that the Company consider
incorporating wildfire-specific vegetation management qualifications and standards into future
programs. Id. at 20-21. Staff also encouraged the Company to move beyond simple completion
metrics, such as miles treated, and develop more outcome-based metrics tied to vegetation-related
outages, faults, and ignitions. Id. at 21. Staff further recommended that future WMPs include
measurable vegetation management targets and discuss any incremental vegetation management
activities conducted within Idaho AOIs.Id.
Finally, Staff confirmed that the Company complied with all procedural requirements
related to WMP notice, annual filing obligations, lessons learned, and coordination with the Idaho
Department of Lands ("IDL"). Id. at 21-22. Staff documented multiple meetings between Staff,
IDL, and the Company during early 2026 to discuss wildfire risk modeling, vegetation
ORDER NO. 37063 10

management practices, and responses to Staff discovery requests.Id. at 22. Staff believed that the
Company met the required three-year planning horizon and properly addressed Commission orders
and Staff recommendations within its appendices and supplemental responses. Id. Overall, Staff
believed that the Company's 2026 WMP satisfied the applicable statutory and regulatory
requirements while also identifying numerous recommendations intended to improve the detail,
transparency, consistency, and effectiveness of future wildfire mitigation plan filings.Id. at 22-23.
BAYER COMMENTS
Bayer stated that its comments were intentionally limited in scope and were submitted to
acknowledge the statutory purpose of the WSCA wildfire mitigation planning process while
preserving Bayer's rights to address cost recovery, allocation, and liability issues in future
proceedings. Bayer Comments at 1. Bayer explained that the WSCA directed the Commission's
review toward prospective mitigation measures and whether the proposed WMP satisfied Idaho
Code§ 61-1803 and the Commission Guidelines,including whether the WMP reasonably balanced
mitigation costs with risk reduction and identified appropriate preventative actions. Id. Bayer
emphasized that the proceeding did not adjudicate wildfire liability or determine the recoverability
or allocation of wildfire-related costs among the multiple jurisdictions in which the Company
operated. Id. Bayer noted that Commission approval of the WMP did not constitute a finding that
any specific mitigation expenditure was prudent or recoverable from Idaho ratepayers, and that
such issues would instead arise in future rate cases, cost recovery proceedings, or allocation
dockets.Id. at 1-2.
Bayer explained that the Company operated as a division of PacifiCorp, which managed
operations on an integrated multi-state basis, and that the WMP relied on systemwide tools,
programs, and operational capabilities that were developed and implemented across PacifiCorp's
broader service territory. Id. at 2. Bayer argued that the WMP appeared to assume traditional
systemwide allocation methodologies for wildfire mitigation costs without adequately
demonstrating Idaho-specific cost causation or providing transparent state-by-state comparisons
of wildfire risks,mitigation activities,and expected costs.Id. Bayer further contended that wildfire
mitigation spending and related costs could be influenced by differing legal standards and policy
decisions in other jurisdictions, underscoring the need for greater transparency before assigning
such costs to Idaho customers.Id.
ORDER NO. 37063 11

Bayer also maintained that compliance with an approved WMP should not be conflated
with a determination that wildfire mitigation expenditures were reasonable or appropriately
allocated to Idaho ratepayers. Id. Bayer identified several unresolved issues related to cost
allocation, including the absence of designated FHCA in Idaho, the lack of state-specific wildfire
risk and cost comparisons, and concerns that some mitigation measures primarily addressed
distribution-level public safety risks rather than transmission-level reliability. Id. at 2-3. Bayer
further argued that the WMP did not sufficiently demonstrate least-cost or least-risk alternatives
for major mitigation categories and lacked detailed state-by-state wildfire exposure metrics
necessary to evaluate the reasonableness of allocating systemwide costs to Idaho customers.Id. at
3. Bayer also raised concerns regarding increased inspection frequencies, expanded vegetation
clearance requirements, and new wildfire initiatives that could materially increase costs without
adequately demonstrating Idaho-specific need or cost causation.Id.
Although Bayer acknowledged and appreciated the Company's efforts to develop the
WMP and the Commission's oversight of wildfire mitigation planning under the WSCA, Bayer
asserted that Idaho's comparatively lower wildfire exposure should result in demonstrable cost
savings relative to other PacifiCorp states. Id. Bayer believed that the WMP lacked sufficient
information to evaluate whether the wildfire mitigation program would be successful or whether
its costs were reasonable. Id. Accordingly, Bayer argued that approval of the 2026-2028 WMP
should be limited to mitigation planning and standard-of-care compliance and should not be
interpreted as a determination regarding cost recovery, cost allocation, or liability for wildfire
losses incurred in other jurisdictions. Id. Bayer therefore requested that any Commission order
approving the WMP expressly preserve the parties' ability to challenge future wildfire-related cost
recovery, jurisdictional cost allocation, and customer-class allocation issues in subsequent
proceedings.Id. at 3-4.
IDAHO DEPARTMENT OF LANDS COMMENTS
IDL reviewed the Company's wildfire risk modeling and expressed several reservations
regarding the process used to identify wildfire risk areas. IDL Comments at 1. IDL noted that the
Company's modeling did not designate any FHCA in Idaho, which IDL stated was inconsistent
with wildfire risk modeling conducted by IDL and other entities. Id. As a result, IDL requested
ORDER NO. 37063 12

additional information regarding the modeling products and methodologies used to develop the
wildfire risk maps.Id.
IDL also observed that the Company's cost breakdown categorized investments by
program area but did not clearly explain how investment decisions were differentiated or
prioritized. Id. IDL stated that, without a cost-benefit analysis of mitigation activities, it was
difficult to assess the relative value of individual investments, and it encouraged the Company to
evaluate the potential costs of taking no mitigation action to better illustrate the benefits of the
proposed investments.Id. at 1-2.
IDL further commented that the WMP primarily addressed wildfire risk from an internal
causation perspective,while external wildfires could also significantly affect system reliability.Id.
at 2. IDL requested that the Company provide additional discussion regarding measures intended
to reduce damage from external wildfire events affecting the system.Id. With respect to fair market
value considerations, IDL acknowledged that the Company addressed the issue generally in
Section 3 of the WMP but requested that the Company either reference any existing procedures
for compensating marketable timber or, if no such procedures existed, develop a formal
implementation project and standard operating procedure addressing compensation for timbered
lands. Id. IDL stated that clearly defined standard operating procedures would strengthen
stakeholder confidence regarding wildfire mitigation activities affecting timber resources.Id.
IDL also raised concerns regarding vegetation inspection standards contained in the WMP.
Id. Although IDL acknowledged that the qualifications relied on established arboriculture
standards,it argued that those standards did not adequately address wildfire-specific concerns such
as ignition potential and fire propagation. Id. IDL specifically referenced the importance of
addressing "ladder fuels," which can allow fires to spread rapidly from the ground into forest
canopies, thereby increasing wildfire severity. Id. IDL recommended that vegetation inspection
qualification standards also include certifications specific to wildland fire mitigation. Id. In
addition, IDL encouraged the Company to participate in Idaho county wildfire planning groups,
noting that every Idaho county had completed a County Wildfire Preparedness Plan and that
greater coordination could improve resource sharing, wildfire mitigation planning, and public
education efforts.Id. at 2-3.
ORDER NO. 37063 13

COMPANY REPLY
In its Reply Comments, the Company stated that its WMP built upon recent operational
experience and stakeholder engagement efforts and focused on improving situational awareness,
operational readiness, and system performance to reduce ignition risk and limit the consequences
of wildfire-related fault events. Company Reply Comments at 2. The Company explained that
during 2025 it expanded weather monitoring capabilities, enhanced wildfire risk modeling,
implemented modified operating practices, launched the Wildfire Intelligence Center, and
strengthened coordination with public safety partners. Id. The Company also forecasted
approximately $13.9 million in additional Idaho-specific wildfire mitigation investments through
2028.Id. Although no FHCA had been identified in Idaho,the Company maintained that the WMP
reflected ongoing risk evaluation and statewide mitigation efforts tailored to Idaho's wildfire risk
profile. Id.
The Company responded to Staff s comments and recommendations. Id. The Company
noted that Staff believed the WMP satisfied the requirements of the WSCA, prior Commission
orders and applicable guidelines, and recommended Commission approval of the WMP with
annual filing updates. Id. In response to Staff s concerns regarding AOI, the Company stated that
it was updating its wildfire risk mapping methodology to transition away from AOIs and establish
new FHCA boundaries in Idaho. Id. at 2-3. The Company further agreed with Staff s
recommendation to develop a transparent and repeatable cost-benefit methodology and explained
that it was creating a monetized cost-benefit analysis framework that would evaluate wildfire
mitigation investments using assumptions regarding the economic impacts of wildfire damage,
including impacts to life,property, and acres burned. Id. at 3.
The Company also addressed Staffs recommendations regarding transparency, metrics,
and future reporting requirements. Id. at 4. The Company agreed to include additional metrics,
measurable targets, training information, pilot program details, weather station plans, camera
network information, vegetation management metrics, infrastructure deficiency tracking, quality
assurance processes, and workforce safety practice descriptions in future WMP filings where data
were available. Id. at 4-6. The Company stated that it would continue refining PSPS procedures
through exercises and operational experience and would evaluate industry wildfire-specific
vegetation management qualifications. Id. at 7. While the Company acknowledged Staffs
ORDER NO. 37063 14

recommendations for increased detail and reporting, it explained that some metrics and mitigation
programs were still evolving and therefore lacked sufficient historical data for meaningful trend
analysis.Id. at 7-8.
The Company also responded to IDL's concerns regarding wildfire risk modeling.Id. at 9.
The Company explained that its modeling used Technosylva's FireSight platform to evaluate
wildfire risk at the transmission and distribution line segment level by analyzing probability of
fault, probability of ignition, and wildfire consequences. Id. at 9-10. The Company described
ongoing improvements to grid resolution, risk validation processes, and cost-benefit analyses,
including the incorporation of publicly available wildfire datasets and monetized assessments of
loss-of-life impacts.Id. at 10-11. The Company also acknowledged that while it has not identified
wildfire risk areas in the State of Idaho or completed a comparative analysis using public risk
maps, the Company was currently updating its methodology for identifying high risk areas. Id. at
9.
The Company addressed concerns regarding wildfire risk mapping, vegetation
management, cost-benefit analysis, timber compensation procedures, and coordination with local
wildfire planning groups. Id. at 11-13. The Company stated that it was updating its risk mapping
methodology to incorporate publicly available wildfire hazard data and to benchmark future
wildfire risk maps against other available datasets. Id. at 11. The Company also explained that its
wildfire mitigation measures, including vegetation management, inspections, pole wrapping, and
emergency de-energization procedures,were designed to address both utility-caused ignitions and
external wildfire threats. Id. at 11-12. Additionally, the Company agreed to develop a formal
procedure regarding compensation for marketable timber and stated that it would continue
evaluating wildfire-specific vegetation management credentials and coordination with county
wildfire preparedness planning groups.Id. at 12-13.
The Company also responded to Bayer's comments regarding cost recovery, allocation,
and the legal significance of WMP approval.Id. at 13.Bayer had argued that approval of the WMP
should be limited to mitigation planning and standard-of-care considerations and should not affect
future determinations regarding prudence, cost recovery, or cost allocation. Id. The Company
disagreed, asserting that approval of the WMP carried evidentiary value regarding whether future
mitigation expenditures were reasonably and prudently incurred under the WSCA. Id. at 14. The
ORDER NO. 37063 15

Company argued that the WSCA expressly required the Commission to consider the feasibility
and cost reasonableness of wildfire mitigation plans and therefore WMP approval could properly
inform future prudence evaluations, even though it did not predetermine future ratemaking
outcomes.Id.
The Company further rejected Bayer's assertions regarding systemwide cost allocation and
Idaho-specific mitigation costs. Id. at 15. The Company maintained that most wildfire mitigation
costs were state-specific rather than systemwide and that Idaho's WMP did not include costs
associated with mitigation work performed in other states. Id. at 15-16. The Company also
disagreed with Bayer's arguments regarding the need for state-by-state wildfire comparisons and
"least-cost, least-risk" analyses, asserting that such requirements were not mandated by statute or
Commission order. Id. at 16. The Company emphasized that many wildfire mitigation efforts,
including inspections, vegetation management, the Wildfire Intelligence Center, idle line
mitigation, and emergency de-energization strategies, were appropriate and necessary even in the
absence of designated FHCA areas in Idaho. Id. at 16-17. The Company believed that the WMP
appropriately addressed wildfire risk in Idaho, satisfied statutory and regulatory requirements, and
should be approved as filed without the limitations or disclaimers requested by Bayer. Id. at 17-
18.
IDAHO DEPARTMENT OF LANDS SUPPLEMENTAL COMMENTS
IDL filed Supplemental Comments to encourage additional data inputs in future wildfire
risk evaluations. IDL Supplemental Comments at 1. IDL encouraged the Company to include
system components, vegetative height layer, and soil layer. Id. at 1-2. IDL also requested that the
Company address wind events in the Company service territory when evaluating wildfire risk. Id.
at 2.
COMMISSION FINDINGS AND DECISION
The Commission has jurisdiction over the Company's Application and the issues in this
case under Title 61 of the Idaho Code including, Idaho Code §§ 61-501, -502, and -503. The
Commission is empowered to investigate rates, charges,rules,regulations,practices, and contracts
of all public utilities and to determine whether they are just, reasonable, preferential,
discriminatory, or in violation of any provisions of law, and to fix the same by order.Idaho Code
§§ 61-501, -502, and-503.
ORDER NO. 37063 16

The Commission is required to review a utility's WMP to ensure it satisfies the minimum
requirements of the WSCA. Idaho Code § 61-1804(1). In conducting its review, the Commission
considers the protection of public health, safety, and welfare; the feasibility of the WMP and the
cost of its implementation; and the extent to which the WMP minimizes wildfire risk and provides
for an effective response to potential wildfire events.Idaho Code § 61-1804(1)(a)-(c).
2026 WMP
The Commission has reviewed the Company's 2026 WMP in accordance with the
requirements of the WSCA, including Idaho Code §§ 61-1803 and 61-1804. Based on the record,
we find that the Company's WMP satisfies the minimum statutory requirements set forth in Idaho
Code § 61-1803(3)(a)-(g). Specifically,the Commission finds that the WMP adequately addresses
wildfire risk identification and assessment,preventative and corrective mitigation measures,public
outreach and governmental coordination, infrastructure inspection and maintenance, operational
practices, vegetation management, situational awareness and monitoring, emergency response
planning, and public communication protocols.
The Commission further finds that the WMP is consistent with the public interest when
considering the protection of public health, safety, and welfare; the feasibility of the proposed
mitigation measures; and the anticipated costs of implementation.The Company has demonstrated
a continued commitment to evaluating and reducing wildfire risk through enhanced situational
awareness, operational preparedness, vegetation management, infrastructure maintenance, and
coordination with public safety partners. The Commission also recognizes that the Company
forecasts approximately $13.9 million in Idaho-specific wildfire mitigation investments through
2028 and has committed to continuing annual updates to its wildfire mitigation efforts.
Accordingly, the Commission approves the Company's 2026 WMP as filed, subject to
ongoing review and future updates as required by the WSCA and Commission order.
Additional Public and Party Comments
The Commission appreciates the participation of Staff, IDL, Bayer, and the Company
throughout this proceeding. The comments submitted by the parties contributed to a thorough
review of the Company's WMP and identified opportunities to improve future wildfire mitigation
planning efforts.
ORDER NO. 37063 17

The Commission acknowledges Bayer's comments regarding cost recovery,jurisdictional
allocation, and liability issues. We agree that approval of a WMP under the WSCA does not
predetermine future ratemaking outcomes, cost allocation decisions, or prudence determinations
that may arise in future proceedings. Those matters remain subject to review in the appropriate
docket. At the same time, the Commission recognizes that the WSCA requires consideration of
the feasibility and cost of proposed wildfire mitigation measures as part of the WMP review
process. Accordingly, our approval of the WMP reflects compliance with the statutory
requirements governing wildfire mitigation planning and should not be interpreted as a
determination regarding the recoverability or allocation of any future expenditure.
The Commission also appreciates IDL's continued participation and expertise regarding
wildfire risk, vegetation management, and land management practices. We encourage the
Company to continue coordinating with IDL, county wildfire preparedness planning groups,
emergency management organizations, and other stakeholders as it refines future iterations of its
WMP.
Staff Recommendations
Staff recommended that the Company continue to provide greater transparency regarding
wildfire mitigation costs, including separate identification of wildfire-related labor expenditures
and more detailed capital and operation and maintenance forecasts by program category. The
Company agreed to continue improving its reporting and disclosure practices. The Commission
finds these recommendations to be reasonable and in the public interest.
Staff recommended that future WMPs provide additional information regarding grants,
alternative funding sources, and other opportunities to offset wildfire mitigation costs. The
Company agreed to expand its reporting of grant applications, funding awards, and associated
projects. The Commission finds these recommendations to be reasonable and in the public interest.
Staff also recommended that the Company further develop its cost-benefit analysis
framework and apply that framework to wildfire mitigation investments undertaken within Idaho
AOIs. The Company stated that it is developing a monetized cost-benefit methodology that will
evaluate wildfire mitigation investments using assumptions related to wildfire impacts, including
impacts to life, property, and acres burned. The Commission finds these recommendations to be
ORDER NO. 37063 18

reasonable and in the public interest. We expect the Company to continue developing and refining
this framework and to report on its progress in future WMP filings.
Staff identified several opportunities to improve the Company's wildfire risk modeling,
including additional transparency regarding model inputs, validation processes, asset coverage,
benchmarking against publicly available wildfire datasets, and incorporation of Company-specific
operating experience. The Company indicated that it is updating its risk mapping methodology,
improving model validation efforts,and incorporating additional publicly available wildfire hazard
data. The Commission finds these recommendations to be reasonable and in the public interest and
encourages the Company to continue refining its modeling processes and providing additional
information regarding those efforts in future WMPs.
Staff further recommended that future WMPs include additional detail regarding workforce
training, pilot programs, weather monitoring, wildfire detection technologies, infrastructure
inspections, quality assurance procedures, operational practices, Public Safety Power Shutoff
protocols, vegetation management activities, and measurable performance metrics. The Company
generally agreed with these recommendations and committed to providing additional information
where data is available. The Commission finds these recommendations to be reasonable and in the
public interest. The Commission encourages the Company to continue developing meaningful
performance measures that allow stakeholders to evaluate the effectiveness of wildfire mitigation
activities over time.
IDL Recommendations
IDL recommended that the Company provide additional information regarding its wildfire
risk modeling methodology and continue refining its identification of high wildfire risk areas. IDL
also encouraged the Company to incorporate additional data inputs into future risk assessments
and to benchmark its results against publicly available wildfire hazard datasets. The Company
stated that it is updating its risk mapping methodology and intends to incorporate additional public
wildfire hazard information into future analyses. The Commission finds these recommendations
to be reasonable and in the public interest.
IDL further recommended that the Company continue developing its cost-benefit analysis
framework, provide additional discussion regarding external wildfire threats to utility facilities,
develop procedures addressing compensation for marketable timber where appropriate, evaluate
ORDER NO. 37063 19

wildfire-specific vegetation management qualifications, and coordinate with county wildfire
preparedness planning groups. The Company generally agreed with these recommendations and
committed to evaluating or implementing these measures in future planning cycles. The
Commission finds these recommendations to be reasonable and in the public interest.
The Commission commends the Company, Staff, IDL, and participating stakeholders for
their collaborative efforts throughout this proceeding. Wildfire mitigation planning remains an
evolving process under the WSCA, and continuous improvement is essential to reducing wildfire
risk and protecting Idaho communities,infrastructure,natural resources,and utility customers. The
Commission encourages the Company to continue working closely with Staff, IDL, and other
stakeholders as it develops future WMPs and implements wildfire mitigation measures throughout
its Idaho service territory.
ORDER
IT IS HEREBY ORDERED that the Company's 2026 WMP is approved, as filed.
THIS IS A FINAL ORDER. Any person interested in this Order may petition for
reconsideration within 21 days of the service date of this Order regarding any matter decided in
this Order.Within 7 days after any person has petitioned for reconsideration, any other person may
cross-petition for reconsideration.Idaho Code § 61-626.
ORDER NO. 37063 20

DONE by Order of the Idaho Public Utilities Commission at Boise, Idaho this 9th day of
June 2026.
G
EDWARD LODGE, PRF,,SIDENT
1-2�—- xf�
J R. HAMMOND JR., COMMISSIONER
DAYN HA IE, COMMISSIONER
ATTEST:
do i a a n c h e z
Commission Secretary
IALegaRELECTRIC\PAC-E-25-22_WMP\orders\PACE2522_fina1_em.docx
ORDER NO. 37063 21