20260609Final_Order_No_37064.pdf

Office of the Secretary
Service Date
June 9,2026
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF AVISTA ) CASE NO.AVU-E-25-15
CORPORATION'S APPLICATION FOR )
APPROVAL OF THE 2026 WILDFIRE )
MITIGATION PLAN ) ORDER NO. 37064
On December 9, 2025, Avista Corporation ("Company") applied to the Idaho Public
Utilities Commission("Commission")requesting an order approving its 2026 Wildfire Mitigation
Plan("WMP") ("Application").
On January 6, 2026, the Commission issued a Notice of Application and Notice of
Intervention Deadline. Order No. 36901. The Commission granted intervention to PotlatchDeltic
Forest Holdings, LLC ("PotlatchDeltic"). Order No. 36888.
On February 4, 2026, the Commission provided notice that the Application would be
processed under Modified Procedure and set comment deadlines. Order No. 36927. Commission
Staff ("Staff') and PotlatchDeltic filed comments, to which the Company replied. The
Commission also received two public comments from the Idaho Department of Lands ("IDL"),
one filed timely and the other filed after the deadline.
This matter is now fully submitted.
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,
the Legislature emphasized that utilities should proactively identify, mitigate, and respond to
ORDER NO. 37064 1

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
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 submitted its 2026 WMP to the Commission for approval pursuant to the
WSCA. Application at 1. The Company represented that its 2026 WMP complied with all
requirements of the WSCA—including the notice requirements set forth in Idaho Code § 61-
1804(2)—and with all Commission directives set forth in Order No. 36774 ("Guidelines"),which
was issued in Case No. GNR-E-25-02 on September 30, 2025.Id. at 34, 6.
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According to the Company, its 2026 WMP was the result of a comprehensive assessment
of wildfire risk specific to its service territory, which included input from internal experts and
industry peers. Id. at 4, 7. The Company stated that its proposed wildfire mitigation measures
reflected a reasonable balance between mitigation costs and a reduction of wildfire risk. Id. at 3-
4.
The Company requested a Commission order finding that the 2026 WMP: meets the
minimum requirements of the WSCA and the Guidelines; is consistent with public health, safety,
and welfare;can be feasibly implemented;reasonably minimizes the risk of wildfires;and provides
standard operating procedures for responding to wildfires that do occur. Id. at 8. Additionally, the
Company sought clarification allowing it to file its future annual WMPs for the Commission's
review on or about November 1 of each year.Id.
PUBLIC COMMENTS
On March 13, 2026, IDL, on behalf of Idaho State Forester, Julia Lauch, filed comments
identifying several items it believed the Company should include in WMP filings, including: (1) a
narrative description of the modeling inputs; (2) a cost-benefit analysis for each general mitigation
action category; (3)clarification regarding actions to reduce damage from external wildfire events;
(4) a defined formal process for determining the fair market value of timber; (5) worker
qualification standards and vegetation inspection practices designed to identify and address
conditions specific to wildfire risks; and (6) input from county fire planning groups. IDL
Comments at 1-3.
On May 20,2026,IDL filed supplemental comments with additional recommendations for
future WMP filings. IDL believed risk modeling inputs should address Company infrastructure
details (type, condition, and age); vegetative layer height; soil type; and damaging wind events.
IDL Supplemental Comments at 1-2. Because IDL filed its supplemental comments after both the
public comment deadline and the Company's reply comment deadline, no party has had an
opportunity to respond to the recommendations contained in those comments.
STAFF COMMENTS
Following review of the Company's Application, 2026 WMP, and discovery responses,
Staff recommended that the Commission issue an order approving the WMP and clarifying that
the Company may file updated annual WMPs on or about November 1 of each year. Staff
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Comments at 2. Though Staff believed the 2026 WMP met the relevant requirements, it also
suggested improvements for future WMP filings. Id.
According to Staff, the Company's WMP should provide additional details about the cost
and quality of the Company's wildfire mitigation workforce preparedness. Id. at 3-4, 9. Staff
recommended that the Commission require the Company to specifically identify internal wildfire
mitigation labor in its cost forecasts.Id. at 3-4.According to Staff,the Commission has previously
ordered other regulated utilities to include a separate line item for internal labor in their WMP cost
forecasts.Id. at 4 citing Order Nos. 37004 and 36405. Staff also contended that such a requirement
would allow tracking of labor costs overtime and assist Staff in its review.Id. at 4. Relatedly, Staff
recommended that the Commission direct the Company to proactively provide workforce training
materials and participation information in future WMP filings.Id. at 9.
While noting several strengths of the Company's geographical risk assessment
methodology, Staff identified limitations and areas for improvement.Id. at 5-7. Staff believed that
the Company should use a name other than"wildland urban interface"("WUI")to avoid confusion
with differing, industry-standard WUI maps. Id. at 5. Staff also recommended that the Company
consider adjusting inputs used to determine geographical risk areas to align with existing literature
and include a detailed description of the risk modeling methodology in its WMP.Id. at 5-8.
Though Staff stated that the Company's public and government outreach efforts met the
minimum requirements of the WSCA and the Guidelines, it also believed there were opportunities
for improvement.Id. at 10. Staff suggested that the Company specify the federal, state, local, and
tribal organizations with which it coordinates during wildfire mitigation planning. Id. Staff also
believed that the Company should discuss methods to expand participation in the planning process.
Id.
Staff further recommended that the Company provide additional details regarding its
approach to grid hardening and line rebuilding in future WMPs.Id. at 11. Specifically, Staff stated
that the Company should consider including information regarding asset-level ignition likelihood
and a stochastic scenario optimization in wildfire consequence modeling in the description of its
grid hardening approach.Id. at 12. As Staff believed some transmission and distribution("T&D")
projects might be driven by factors unrelated to wildfire mitigation, it also recommended that the
Commission instruct the Company to provide a detailed list of all T&D projects driven by wildfire
mitigation in future WMP submissions. Id. Additionally, Staff believed that the Company could
ORDER NO. 37064 4

improve the overhead to underground conversion study by including tables demonstrating
potential mitigation effectiveness and a cost-benefit analysis comparing alternative grid hardening
strategies.Id. at 11-12. Staff also recommended reconsideration of certain premises and modeling
inputs used in the undergrounding study. Id. at 13-14. Finally, Staff suggested improving the
covered conductor pilot study by providing short-term measurable targets and project selection
criteria. Id. at 14.
Staff also believed that the WMP met the situational awareness and monitoring
requirements of the WSCA and the Guidelines. Id. at 14-15. However, Staff recommended that
the Commission direct the Company to improve the level of detail provided for weather station
sources and wildfire detection cameras in future WMP submissions. Id. at 15. Staff first thought
that the Company should add a description of the publicly available data used in situational
awareness efforts. Id. Staff believed that the Company should include specific detail surrounding
the plans to expand the use of its camera network, including: "locations of focus, average cost of
installation, timeframe for installation of cameras, cost-benefit analysis, and other alternatives
considered."Id. at 16. Staff further suggested that the Company consider providing metrics for the
number of ignitions detected; ignition response time; Company responses; and involvement of
Company infrastructure.Id.
Similarly, Staff stated that the Company had satisfied WSCA and Guideline requirements
regarding discussion of infrastructure inspection and maintenance but again had recommendations
for improvement to future WMPs. Id. According to Staff, the Commission should instruct the
Company to provide details of all inspections. Id. at 16-17. Staff also believed that the WMP
should include documentation of deficiencies identified through inspection and information
regarding corrections.Id. at 17.
Despite asserting that the Company had adequately detailed its de-energization protocols,
Staff believed future WMPs could benefit from additional description of workforce practices
during times of heightened wildfire risk. Id. at 17-18. Staff also suggested that the Company
continue refining its public safety power shut-off protocols.Id. at 18.
Staff recommended that the Company describe its vegetation management quality
assurance program in future WMP filings.Id. at 19. Staff also agreed with IDL's recommendation
that the Company add"standards specific to wildland fire to training and certification required for
personnel doing vegetation management work." Id. at 20. According to Staff, the Commission
ORDER NO. 37064 5

should require the Company to continue providing summaries of T&D fault, outage, and ignition
data. Id. Staff further suggested that the Company consider including such data at the line and
feeder level, if possible.Id.
Staff noted that during discovery, the Company provided information regarding grants to
which it had unsuccessfully (as of January 2026) applied as part of its wildfire mitigation efforts.
Id. at 21. Staff recommended that the Commission direct the Company to provide details
concerning potential alternative funding sources in future WMPs.Id.
Staff recommended that the Commission require the Company to include all metrics used
within each respective section of future WMPs and to provide the data in a format allowing for
easy tracking across WMP filings. Id. at 22. According to Staff, these metrics and the associated
data allow for tracking and evaluating the Company's plan over time.Id.
Finally, Staff supported each of the recommendations that IDL offered in its initial
comments.Id. at 23.
INTERVENOR COMMENTS
PotlatchDeltic,the private owner of timbered acreage within and near the Company's Idaho
service territory and traversed by the Company's T&D systems, urged the Commission to reject
the Company's 2026 WMP or alternatively,to hold a technical hearing prior to making a decision
on the Company's Application. PotlatchDeltic Comments at 1-2. The intervenor claimed that
"[d]epending on whether[the Company's]WMP is blessed by the Commission,liability for untold
millions of dollars of valuable timber and the very lives and livelihoods of PotlatchDeltic's
employees and contractors is at stake."Id. at 2. According to PotlatchDeltic, the WSCA requires
the Commission to either entirely approve of or reject the Company's WMP. Id. at 3. The
intervenor argued that the Commission can only properly address any flaw in the WMP by
rejecting the Application. Id. PotlatchDeltic argued that if the Commission were to approve a
flawed WMP,under the WSCA,the Company would receive"a blanket grant of immunity"for its
negligence.Id.
PotlatchDeltic first contended that the Company's grid hardening efforts, which account
for approximately 90 percent of the Company's total wildfire-related expenditures, are either
inapplicable to Idaho or merely free rider measures disguised as WMP measures. Id. at 4.
According to the intervenor,the Company plans to conduct all distribution grid hardening projects
scheduled for 2026 and 2027 in Washington State, with no such work planned in Idaho. Id. at 5—
ORDER NO. 37064 6

6. PotlatchDeltic alleged that this planning was intentional, as the Company's risk modeling was
designed to prioritize denser "urban fringe" areas near Spokane while ignoring risks in high-fuel
forested lands in Idaho. Id. at 6, 9-13. PotlatchDeltic also contended that all transmission grid
hardening efforts planned for Idaho are part of a free rider effort of steel transmission pole
replacement that predates the WMP process.Id. at 7.
Similarly, the intervenor argued that the Company could not comply with the WSCA's
requirement of developing a vegetation management plan because the vegetation management plan
contained in the 2026 WMP was a free rider that was developed prior to the WSCA. Id. at 8-9.
PotlatchDeltic believed that repurposing pre-WSCA plans could not satisfy the act's mandates.Id.
at 9.
PotlatchDeltic further argued that the WMP is too ambiguous to satisfy the requirements
of the WSCA.Id. at 13. According to PotlatchDeltic, the Company's grid hardening plans contain
unverifiable, unenforceable phrases such as "[r]ebuilding lines with hardened designs," that the
Company failed to sufficiently define through its discovery responses. Id. at 14. PotlatchDeltic
also noted that despite listing the covered conductor program as one of its top grid hardening
strategies, the Company, which allegedly has no plans to install covered conductors in Idaho,
provided no standard by which successful implementation of the measure would be demonstrated.
Id. at 16-17. PotlatchDeltic contended that such ambiguities throughout the plan prevent a clear
determination of when the WMP has been reasonably implemented.Id. at 16.
Finally, PotlatchDeltic stated that Commission approval of the Company's flawed plan
would shift liability for wildfires started by the Company to Idaho property owners without any
obligation for the Company to implement risk mitigation measures in Idaho. Id. at 18.
PotlatchDeltic characterized potential approval of the WMP as an "unfair, unjust and
unreasonable"transfer of wealth"of questionable legality."Id.
COMPANY REPLY COMMENTS
In its reply comments,the Company separately responded to recommendations from Staff,
IDL, and PotlatchDeltic.
Response to Staff
In addition to supporting Staff s recommendation that the Commission approve its 2026
WMP, the Company expressed agreement with several of Staffs recommendations to improve
future WMP filings. Company Reply Comments at 3. The Company agreed that it should include
ORDER NO. 37064 7

a distinct line item for internal labor costs for wildfire mitigation activities.Id. The Company also
agreed that it should provide the additional workforce preparedness and training documentation
and information Staff recommended for inclusion.Id. In response to Staff s recommendation that
the Company provide a detailed description of the risk modeling methodology and inputs used to
determine geographical risk areas, the Company stated its intention "to include a clearer
methodology description in future WMP filings...."Id. at 3-4. The Company also committed to
adopting Staffs recommendation of providing summaries of T&D projects for which wildfire
mitigation is a documented driver. Id. at 4. Additionally, the Company agreed to include more
details concerning the weather data sources it uses for situational awareness. Id. The Company
stated that it had no objection to providing details concerning additional sources of funding.Id. at
5. Finally, the Company agreed that future WMPs would include program evaluation metrics in
each applicable section in a format that allows for comparisons over time.Id.
The Company was non-committal in response to Staff s recommendation that it provide
the details of all inspections in future WMP filings. The Company stated that it would "consider
providing supplemental detail, such as a summary table describing inspections in more detail,
where doing so adds value and improves transparency in future WMP filings."Id. at 4.
Response to IDL
Generally,the Company indicated that it would incorporate changes to future WMP filings
based on the IDL's recommendations. In response to IDL's recommendation that future WMPs
include narratives describing inputs used for risk modeling, the Company represented that it is
currently implementing an updated risk analysis methodology comparable to that used by Idaho's
State Forest Action Plan, which will include additional details regarding the modeling inputs. Id.
at 6.As to IDL's recommendation that it perform a cost-benefit analysis for each general mitigation
action category, the Company stated that it will continue to assess measures using the risk model
while continuing "to evaluate opportunities to enhance its analytical framework and presentation
of decision-making information in future WMP filings, consistent with data availability,
methodological limitations, and the intent of the WSCA." Id. at 6-7. In response to IDL's
recommendation that the Company clarify actions designed to reduce damage from external
wildfire events, the Company stated that the 2026 WMP already identifies strategies to reduce the
effects of facilities exposed to wildfire that are applicable to both internal and external ignition
risks but also indicated that it would seek to more clearly address how certain mitigation measures
ORDER NO. 37064 8

reduce risks from external fires in future plans.Id. at 7. As to IDL's recommendation that it define
a formal process for determining the fair market value of timber, the Company responded that it
would continue to refine its standard operating procedures regarding the treatment of marketable
timber.Id. Finally, in response to IDL's recommendation that it incorporate input from county fire
planning groups,the Company expressed its intention to continue participating in county planning
groups and to seek additional opportunities. Id. at 8.
The Company objected entirely to only one of IDL's recommendations. The Company
stated that it was not currently planning any changes to the certification requirements for its
vegetation management workers, despite IDL's belief that it should establish worker qualification
standards and conduct vegetation inspections designed to address specific conditions that increase
the risk of wildland fire.Id. at 7. According to the Company, its vegetation management practices
conform to established industry standards.Id.
Response to PotlatchDeltic
The Company disagreed with PotlatchDeltic's position that the 2026 WMP failed to meet
the requirements of the WSCA. Id. at 9. In response to PotlatchDeltic's contention that the
Commission must reject any flawed WMP, the Company argued that the Commission possesses
broad authority under the statute to condition its approval and oversee implementation of the
WMP. Id. The Company also opposed PotlatchDeltic's characterization of WMP approval as "a
blanket grant of immunity."Id. Rather,the Company contended that WMP approval would merely
create a conditional, rebuttable presumption that the utility acted without negligence with respect
to the cause of a damage-causing wildfire. Id. Additionally, the Company contended that
PotlatchDeltic mischaracterized the requirements of the WSCA when it argued that the
Commission should reject the 2026 WMP on the basis that many mitigation efforts pre-dated the
WSCA. Id. at 10. According to the Company, there is no requirement that each plan element be
created following enactment of the statute.Id.
As to PotlatchDeltic's contention that the 2026 WMP is largely inapplicable to Idaho, the
Company defended its risk modeling framework as a location-neutral assessment of the
Company's service territory.Id. According to the Company, its mitigation measures are informed
by the resulting risk scores and mitigation measures are prioritized in the areas where electric-
related wildfire risk is the highest.Id. The Company stated that the highest scores in this planning
period were in Spokane County, justifying concentration of grid hardening and vegetation
ORDER NO. 37064 9

management efforts. Id. The Company argued that the WSCA does not prevent utilities from
prioritizing areas for mitigation investments based on relative risk. Id. The Company added that
though the 2026 WMP prioritized WUI areas for certain measures, such as distribution hardening,
other measures, including pole inspections, vegetation management, operational practices and
situational awareness, and protection automation were implemented on a system-wide basis.Id. at
13.
The Company also disputed PotlatchDeltic's argument that the 2026 WMP is
impermissibly vague. Id. According to the Company, the 2026 WMP reasonably established the
utility's duties regarding mitigation strategies by providing "annual budgets, targets, inspection
programs, and implementation practices...."Id. The Company contended that the WSCA does not
require each mitigation measure to include rigid thresholds by which successful implementation
can be determined.Id. at 13-14.
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.
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). The
Commission is obligated to incorporate any recommendations submitted by the State Forester in
the order approving or rejecting the WMP absent a determination that "they are not just,
reasonable, and in the public interest...."Idaho Code § 61-1804(3).
Under the Commission's Rules of Procedure, it may find that technical hearing is
unnecessary to serve the public interest and may decide a case "through written filings in which
persons views are expressed through written comments rather than by hearing." IDAPA
3 1.01.01.20 1. Once the Commission notifies interested persons that it may process a case through
ORDER NO. 37064 10

this modified procedure, the burden rests on a party requesting a technical hearing to demonstrate
"why written comments alone are insufficient." IDAPA 31.01.01.202.O1.c.
The Company's 2026 WMP
The Commission has reviewed the Company's 2026 WMP for compliance with the
requirements of the WSCA. 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, when reasonably weighing cost mitigation, the 2026 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. Additionally,we
find that the Company's 2026 WMP is consistent with protection of public health, safety, and
welfare; is reasonably implemented; and adequately minimizes wildfire risk.
The 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.
However, as the Commission values the perspectives of the participants to this proceeding
and endeavors to facilitate continual improvements to annual WMP filings through an iterative
process, we also direct the Company to make revisions to future WMP submissions addressing
some of the concerns expressed in the written submissions—most of which the Company
committed to implement in its reply comments. Namely, we instruct the Company to integrate
feedback by including: (1) a specific cost forecast for internal wildfire mitigation labor; (2) copies
of all wildfire-related training and a table with wildfire mitigation personnel training information;
(3) a detailed description of the risk modeling methodology and inputs used to determine
geographical risk areas; (4) information for all T&D projects driven by wildfire mitigation efforts;
(5)a description of the publicly available data the Company uses as part of its situational awareness
ORDER NO. 37064 11

efforts; (6) a description of all wildfire mitigation inspections that the Company performs; (7)
continued summaries of the Company's T&D fault, outage, and ignition data; (8) details
concerning potential alternative wildfire mitigation funding sources; (9) all metrics used for the
WMP within each respective section in a format allowing for easy tracking across WMP filings;
(10) a cost-benefit analysis for each general mitigation action category; (11) a description of
actions designed to reduce damage from external wildfire events; (12) establish a formal process
for determining the fair market value of timber; and(13) input from county fire planning groups.
We note that the Company had no opportunity to respond to the recommendations
contained in IDL's supplemental comments, filed on May 20, 2026. Accordingly, we will not
expressly require the Company to incorporate those recommendations in future WMPs.
Nevertheless, in recognition of the statutory deference afforded the State Forester, we expect the
Company to implement the recommendations concerning risk modeling inputs unless it can
articulate substantial justification for failing to do so. The recommendations include accounting
for Company infrastructure details (type, condition, and age); vegetative layer height; soil type;
and damaging wind events.
While the Commission is unopposed to IDL's position that vegetation inspection practices
and certification standards should address conditions specific to wildfire risks, without further
elaboration of the additional requirements envisioned by IDL, we lack the basis to impose rigid
obligations on the Company in excess of, and possibly contrary to, what IDL acknowledges are
established industry standards. However, we strongly encourage the Company to explore
opportunities to address IDL's concerns about vegetation inspections overlooking fire ignition and
propagation potential.
Though the Commission understands PotlatchDeltic's discomfort with a plan that largely
focuses on mitigation efforts outside of Idaho, we do not find that rejecting the Company's 2026
WMP on that basis would serve the intent of the WSCA or the public interest. The WSCA
unambiguously tasks utilities with conducting"a reasonable balancing of mitigation costs with the
resulting reduction of wildfire risk."Idaho Code§ 61-1803(1).To that end,the Company subjected
its entire service territory to a risk model assessment for purposes of prioritizing areas for
mitigation activities.PotlatchDeltic suggested that the Company's risk modeling was intentionally
designed to prioritize Washington territory by giving more weight urban fringe areas, but it made
no showing that the model's sensitivity to higher density resulted in an inaccurate ranking of areas
ORDER NO. 37064 12

in terms of wildfire risk faced by the Company. We decline to dictate the risk modeling input
values employed for the Company's WMPs at this time. However, we can revisit the deference
given to the Company later should the Commission sense a pattern of the Company's WMPs
disproportionately prioritizing out-of-state areas.
We disagree with PotlatchDeltic's argument that mitigation measures pre-dating the
WSCA should be disregarded when assessing satisfaction of the statutory requirements. The fact
that certain measures were implemented as standard practice prior to the effective date of the
WSCA does not invalidate the effectiveness of those measures, either in fact or according to the
statutory text.
Finally, the Commission emphasizes that all directives from prior Order Nos. 35909 and
36741 that are not superseded or otherwise addressed by the WSCA or Order No. 36774 remain
in full force and effect. The Company is expected to continue complying with those requirements
unless the Commission orders otherwise.
PotlatchDeldc's Request for a Technical Hearin
The Commission finds that a technical hearing is unnecessary to render a decision in this
matter. PotlatchDeltic has had sufficient opportunity to examine the Company's positions related
to this case through discovery. PotlatchDeltic made no showing, and in fact, did not expressly
contend that written comments alone were insufficient to develop a full evidentiary record in this
proceeding. Setting a technical hearing would not contribute meaningfully to a resolution of the
case.
ORDER
IT IS HEREBY ORDERED that the Company's 2026 WMP is approved.
IT IS FURTHER ORDERED that the Company shall revise future WMPs in a manner
consistent with the directives of this Order.
IT IS FURTHER ORDERED that the Company may file its updated annual WMP on or
about November 1 of each year.
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 seven days after any person has petitioned for reconsideration, any other person
may cross-petition for reconsideration.Idaho Code § 61-626.
ORDER NO. 37064 13

DONE by Order of the Idaho Public Utilities Commission at Boise, Idaho this 9th day of
June 2026.
G
EDWARD LODGE, PR IDENT
J 7
R. HAMMOND JR., COMMISSIONER
DAYN HA IE, COMMISSIONER
ATTEST:
Monica I3af'ri Sanchez
Commission Secretary
L\Legal\ELEC TRIC\A W-E-25-15_W MP\orders\A V UE2515_FO j 1.docx
ORDER NO. 37064 14