20260609Comment_1.pdf

From: Kayla Dawson <[e-mail]>
Sent:Tuesday, June 9, 2026 8:40 AM
To: secretary<[e-mail]
Subject: C11-E-26-01 Raft River Rural Electric Co-op Wildfire Mitigation Plan 2026-2028 -
Amended IDL Comments
Good morning-Attached for filing and service please find Amended Idaho Department of
Lands'Comments in the matter of Raft River Rural Electric Co-op, Incas Application for
Approval of its 2026-2028 Wildfire Mitigation Plan, Case No. C11-E-26-01.
Kind regards,
Kayla Dawson
Legal Assistant
Idaho Department of Lands
300 N. 6t"Street, Suite 103, Boise, ID 83702
Office: [phone]
Email: kdawson(abidl.idaho.gov
Website: https://www.idi.idaho.gov
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John A. Richards #10670
J.J. Winters #10327
IDAHO DEPARTMENT OF LANDS
300 N. 61h Street, Ste. 103
Boise, ID 83702
[phone]
[e-mail]
[e-mail]
Attorneys for Idaho Department of Lands
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF RAFT RIVER RURAL CASE NO. C11-E-26-01
ELECTRIC CO-OP INC.'S APPLICATION
FOR APPROVAL OF ITS 2026-2028 AMENDED IDAHO
WILDFIRE MITIGATION PLAN DEPARTMENT OF LANDS'
COMMENTS
In accordance with Idaho Code § 61-1804, the Idaho Department of Lands ("IDL")by
and through undersigned counsel, submits the following amended 'comments in the above-
referenced matter:
1. IDL has reviewed the risk modeling as provided in the submitted Wildfire
Mitigation Plan by Raft River and presents the following:
a. The modeling described in section 3.4 lacks critical details on data inputs
and methodology to adequately determine the validity of the outputs
presented in the plan. IDL respectfully requests that additional narrative
descriptive details be included for the purposes of process and product
evaluation.
b. When conducting risk modeling, two key elements are necessary for a
model to accurately represent risk—probability of occurrence and
'Amended to include comment Lb.
AMENDED IDAHO DEPARTMENT OF LANDS'COMMENTS— 1

consequence to values. The modeling provided by Raft River does not
include the latter as it lacks clearly identifiable wildland urban interface
(WUI) or other comparable data in the modeling as a data input or as a
mask 2. As a result of this exclusion, the consequence of utility ignited
fires cannot be accurately reflected, and brings into question the validity of
the modeling. In light of this omission, IDL recommends to PUC staff that
the plan be rejected by the Commission.
2. In conjunction with risk modeling, IDL strongly encourages the following data
inputs to be included in future evaluations of wildfire risk:
a. System components. Type, condition, and age of system components
should be included as these elements can significantly increase or decrease
the risks associated with wildfire ignitions or impacts from wildfire on the
system.
b. Vegetative height lam. The plan should include data regarding the
vegetative layer that includes information where the surrounding tree
canopy is taller than the adjacent system. Trees provide a significant strike
risk to above-ground systems that occur outside of the managed rights-of-
way. The inclusion of this data will help to significantly improve the
understanding of external risk from vegetation to systems, thus allowing
for a more informed decision process related to system management and
mitigation options.
C. Soils layer. It is well-established science that certain soil types are more
prone to trees tipping or blowing over during wind events when saturated.
Again, the inclusion of this data will help to inform the decision process of
management and mitigation actions for Raft River's system.
2 IDL maintains a current state-level WUI layer and invites Raft River to contact Tyre Holfeltz for access to the data
and instruction on how to integrate that data into their modeling.
3 The data associated with vegetative and soil layers can be publicly obtained,thus reducing the burden of data that
is needed to be developed or acquired through purchase by Raft River.
AMENDED IDAHO DEPARTMENT OF LANDS'COMMENTS—2

3. Significant straight line wind events regularly occur within the footprint of the
Raft River service area. IDL feels it would be prudent for future iterations of the wildfire
mitigation plan to address these events through the lens of wildfire. Specifically, how these wind
events impact the risk ratings and implementation of wildfire risk mitigation for Raft River with
emphasis on the Idaho service area.
4. The efforts to address wildland fire through planning has a long history in Idaho.
In 2003, Idaho began the implementation of the federal 2002 Healthy Forest Restoration Act.
This act required state forestry agencies throughout the U.S. to establish criteria and support the
development of Community Wildfire Protection Plans (CWPP). This effort continues today with
IDL supporting the maintenance of CWPPs for every county in Idaho. IDL strongly believes
there is significant opportunity for cross integration of the county level CWPPs and utility
mitigation plans and encourages Raft River to actively seek partnerships with the various
counties in which their systems exist. IDL believes that doing so will strengthen relationships,
enhance community protection, and leverage resources for greater efficiency in delivery of
services and programs related to wildfire response, education, and mitigation.
5. In section 4.3.3 covering inspection of vegetation, the qualifications appropriately
center around arboriculture standards, which have long been the industry standards. However,
IDL argues that these standards are insufficient at addressing wildland fire-related issues when
looking at vegetative mitigation as a mechanism to reduce wildfire risk. The arboriculture stands
address tree/shrub conditions and how to appropriately remove or prune. Though these standards
address vegetation health, they do not consider ignition potential or fire propagation,both of
which should be standard for inspection of vegetation treatments. When viewed in the context of
wildfires, a prime example is "ladder" fuels. Ladder fuels are vegetative structural components
that allow fire to move rapidly from ground to forest canopies. If ladder fuels are not addressed
as part of the mitigation actions, then the risk of fire propagating to crowns is substantially
higher. IDL respectfully recommends that the inspection qualification standards also include
certification specific to wildland fire.
6. IDL respectfully requests Raft River include additional narrative details on how
inspections are prioritized or how a change in frequency of inspections occurs related to areas of
the Raft River system that are shown by the wildfire risk modeling to be at elevated risk.
AMENDED IDAHO DEPARTMENT OF LANDS'COMMENTS-3

7. Situational awareness is critical to effectively manage and react to environmental
or system functional changes. Raft River's plan lacks sufficient details on how they obtain and
utilize situational awareness data, making it difficult to evaluate the appropriateness and
adequacy of Raft River's situational awareness related to wildfire.
8. The plan contains several editorial items that warrant updating to reflect current
information:
• Section 2.1.1 should reflect policy directing the mitigation plan elements,
• Section 2.5.2.1.1 -the Owyhee County Plan Hazard Mitigation Plan has
been updated and approved since 2018.
• Section 2.5.4.1 - the Idaho Forest Action Plan was initially penned in 2010
and updated in 2020.
• Section 2.5.5.1 - the Bureau of Land Management now includes the
National Wildland Fire Service.
• Section 3.1.1.1 is not an accurate trend reflection for Idaho based on data
maintained by IDL.
Respectfully submitted this 9th day of June 2026.
IDAHO DEPARTMENT OF LANDS
41k-
J.J.WINTERS
Attorney for Idaho Department of Lands
AMENDED IDAHO DEPARTMENT OF LANDS'COMMENTS-4

CERTIFICATE OF SERVICE
I hereby certify that on this 9t'day of June,2026, I caused to be served a true and correct
copy of the foregoing by the method indicated below, and addressed to the following:
Raft River Rural Electric Co-op, Inc. ❑x Email:dshirley(abma icg valley
David F. Shirley mchristensenkrrelectric.com
Attorney
Parsons, Loveland, Shirley& Miller LLP
137 West 13t' Street
P.O. Box 910
Burley, ID 83318
Mike Christensen
Operations Superintendent
155 North Main
P.O. Box 617
Malta, ID 83342
Idaho Public Utilities Commission ❑x Email: secretary(apuc.idaho.gov
Commission Secretary kelsea.ross(kpuc.idaho.gov
P.O. Box 83720
Boise, ID 83702-0074
Kelsea E. Ross
Deputy Attorney General
P.O. Box 83720
Boise, ID 83702-0074
Is/Kayla Dawson
Kayla Dawson
AMENDED IDAHO DEPARTMENT OF LANDS'COMMENTS-5