20260610Staff Comments.pdf

RECEIVED
June 10, 2026
KELSEA E. ROSS IDAHO PUBLIC
DEPUTY ATTORNEY GENERAL UTILITIES COMMISSION
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83702
[phone]
IDAHO BAR NO. 12050
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF NORTHERN LIGHTS, )
INC.'S APPLICATION FOR APPROVAL OF ) CASE NO. C10-E-26-01
ITS 2026-2028 WILDFIRE MITIGATION )
PLAN )
COMMENTS OF THE
COMMISSION STAFF
COMMISSION STAFF ("STAFF") OF the Idaho Public Utilities Commission
("Commission"),by and through its attorney of record,Kelsea E. Ross, Deputy Attorney General,
submits the following comments.
BACKGROUND
On February 2, 2026, Northern Lights Inc. ("Company") filed its 2026-2028 Wildfire
Mitigation Plan("2026 WMP")with the Commission. On February 19, 2026,the Company filed
an updated application("Application"),requesting approval of the 2026 WMP,in accordance with
Idaho Code § 61-1801, et seq., the Wildfire Standard of Care Act ("WSCA") and the Wildfire
Mitigation Plan("WMP") guidelines established in Commission Order No. 36774 ("Guidelines")
and additional requirements detailed in Order No. 36929.
Under Idaho Code § 61-1803(2)(b), the Company has opted to file the 2026 WMP for
Commission approval. As the Company is an unregulated utility, the Company is not required to
file a WMP for Commission approval.
STAFF COMMENTS 1 JUNE 10, 2026

On March 19, 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. 36963. No petitions to intervene were filed.
On April 30, 2026, the Commission issued a Notice of Modified Procedure. Order No.
36977.
STAFF ANALYSIS
Pursuant to Idaho Code § 61-1804, Staff reviewed the 2026 WMP and believes it meets
the requirements of the WSCA and the Guidelines. Staff also reviewed the 2026 WMP to ensure:
(1) it is consistent with public health, safety, and welfare; (2) it was feasible and provided the cost
of implementation; and (3) it adequately minimizes wildfire risk and proposes to respond to
wildfires that do occur.
The Guidelines require the WMP to include the following sections consistent with the
WSCA: (1) geographical risk assessment; (2) preventative actions and programs; (3) public
outreach and engagement; (4) government outreach; (5) method of line design; (6) situational
awareness and monitoring; (7)infrastructure inspection and maintenance; (8) de-energization and
line operation practices; and(9)vegetation management. The Guidelines also require an update of
lessons learned from previously approved WMPs, and a breakdown of each program category's
forecasted costs by year for both capital and operation and maintenance ("O&M") expenditures.
Id. Staff s review of these requirements is discussed in the respective sections below.
Additionally,the Guidelines require the Company to file a Need to Know Document as part
of this WMP filing,provide a copy of its notice to interested parties of this WMP filing,and create
its WMP using a three-year planning horizon that includes a section that describes how the electric
corporation addresses each of the Commission's Orders and Staffs recommendations. Staff
reviewed each of these items and believes the Company has met these requirements.
Based on its review, Staff recommends the Commission issue an order that: (1) approves
the 2026 WMP; (2) clarifies that the Company may file its future updated WMP for the
Commission's annual review on or about February 2nd of each year; and (3) directs the Company
to include additional items in future WMP filings, if it opts to file again for Commission approval.
Additionally, Staff encourages the Company to include additional items in future WMP filings,
which are discussed below.
STAFF COMMENTS 2 JUNE 10, 2026

Commission Authority
Under the WSCA,the Commission is tasked with approving or rejecting WMPs filed with
the Commission.Idaho Code § 61-1801, et seq. Accordingly, Staff believes the Commission has
jurisdiction to review WMPs submitted for approval. Id. The Commission must confirm that a
WMP meets the minimum requirements set forth in Idaho Code § 61-1803 and must consider the
factors outlined in Idaho Code § 61-1804(1)(a)-(c). Idaho Code § 61-1804(1). The WSCA
requires the Commission to ensure that a WMP is "developed using approaches and methods that
are designed to protect the public interest and are reflective of and commensurate with the size and
complexity of the electric cooperation's operations and of the nature of the fire risk."Idaho Code
§ 61-1803(3).
The WSCA states that
[a]n electric corporation that is not a public utility, including but not limited to a
cooperative association distributing electric power to its members or a municipal
electric distribution system under section 50-342, Idaho Code, may adopt and file
a wildfire mitigation plan with the commission for its review at any time permitted
by the commission.Idaho Code § 61-1803(2)(b) (emphasis added).
Staff interprets this language to mean that it is optional for a cooperative association to
submit a WMP for Commission-approval. The Guidelines established a filing schedule and set
forth guidelines and essential components for WMPs. Staff believes that once a cooperative
association files a WMP with the Commission, review of the cooperative's WMP is subject to the
requirements set forth in Idaho law, the Guidelines, essential elements of WMPs adopted in the
Guidelines, and additional requirements based on the Commission's statutory authority. Without
providing information requested by Staff and responding to Commission direction in future filings,
Staff may be unable to recommend the Commission approve a future WMP.
2026 Wildfire Mitigation Plan-Wide Considerations
In this overview section, Staff provides general observations regarding the 2026 WMP.
Staff s review is organized into two main areas: (1) Cost Feasibility, and (2) Cross Cutting
Elements. Subsequent sections present comments organized according to the Guidelines and the
WSCA.
STAFF COMMENTS 3 JUNE 10, 2026

Cost Feasibility
This section addresses several cost-related components of the 2026 WMP that relate to
multiple programmatic areas of the Guidelines that Staff considered in its review. Here Staff
provides its analysis of the Company's cost forecasts for planned mitigation activities, the
cost-benefit approach used to evaluate and prioritize those activities, and the extent to which the
Company has pursued or incorporated grant funding. Together, these topics inform Staff s
assessment of the overall feasibility and financial reasonableness of the Company's proposed
wildfire mitigation strategies.
Cost Forecasts. The Guidelines require the Commission to consider the cost of the WMP
implementation and require the Company to provide a breakdown of each program category's
forecasted by year for both capital and operations and maintenance ("O&M") expenditures across
the plan horizon of the WMP. Guidelines at 8. The Company provided a summary of its capital,
O&M, and vegetation management budgets for 2026 through 2028. 2026 WMP Need to Know
Document at 2. However,the summary did not break down the costs by category or project level.
Id. In Response to Staff Production Request No. 20, the Company provided a project-level
narrative that included short project descriptions,benefits,timespans,and budgets for each project,
which Staff believes satisfies the requirement to provide a breakdown of program category's O&M
expenditures. Staff believes each budget is comprehensive but not specific to wildfire-related
spending.
In 2026, the Company forecasts expenditures of $9.28 million in capital, $8 million in
O&M, and $3.19 million in vegetation management. 2026 WMP Need to Know Document at 2.
Although vegetation management is classified as O&M spending, it is reported as a separate
budget category. Id. The capital budget includes several major projects, most notably multiple
substation construction and rebuild efforts. See Response to Staff Production Request No. 20. It
also includes $1.15 million to replace 50 wood poles with ductile iron poles and to install
Gridscope devices on 225 poles near Priest Lake.Id.
Table No. 1 below provides the Company's budget summary for the 2026 WMP. Need to
Know Document at 2.
STAFF COMMENTS 4 JUNE 10, 2026

Table No. 1: 2026-2028 Budget Summary
°o increase °'o increase %increase
Budget Budgeted for from prior Forecast for from prior Forecast for from prior
Category 2026 year 2027 year 2023 year 3 year Total
Capital S 9.281.000 3.0°o S 9,652,240 4.Vo S 10,038,330 4.0°o S 23,971,570
OR-Nd S 8.003.002 3?0o S 8,443,167 5.5% S 8.780,894 4.0°'o S 25,227,063
Vegetation S 3.195.384 3.00o S 3.355.153 5.0% S 3,522,911 5.0% S 10,073,44E
Total S 20,479,3E6 S 21.450.560 S 22,342,135 S 64,272,081
Cost Benefit Approach. Idaho Code § 61-1804(1)(b) requires the Commission to
consider the feasibility of the plan and the cost of its implementation. In the Guidelines and Order
No. 36882,the Commission directed companies to include a cost-benefit analysis within its WMPs
and provided guidance on the information necessary to support its analysis. Staff believes the
2026 WMP meets the requirements of Idaho Code § 61-1804(1)(b),the Guidelines,and Order No.
36882. The Company provided a table that identifies wildfire-mitigation programs as high,
medium, or low in terms of cost and effectiveness. 2026 WMP at 16. While the table classifies
each program,it does not explain the underlying rationale for those designations. Id. For example,
relays are categorized as low cost but highly effective for wildfire mitigation; however, the
Company does not describe how it determined the cost rating (such as cost per mile, cost per
device,or another metric)or why the program was assigned its specific mitigation value. Id. Staff
encourages the Company to consider including a narrative to accompany the table that applies a
consistent, transparent, and repeatable methodology across projects. Staff believes that such
consistency is necessary to evaluate whether projects are prioritized using comparable criteria.
Additionally, Staff encourages the Company to define any qualitative benefits included in the
analysis, explain the efficacy in mitigating wildfire risk, and consider quantifying the risk
reduction associated with specific infrastructure mitigation measures.
Grants. Idaho Code § 61-1803(4)(b) requires the Commission to consider the cost of
implementation of WMP expenditures. Thus, Staff believes information on funding alternatives
and funding sources are necessary to evaluate the cost and feasibility of the Company's planned
actions. The 2026 WMP briefly discussed that the Company had been awarded two grants for
wildfire-related projects but did not provide additional information on the details of the grants.
2026 WMP at 10-11. In its Response to Staff Production Request No. 7, the Company provided
STAFF COMMENTS 5 JUNE 10, 2026

information regarding the Idaho Office of Energy and Mineral Resources ("OEMR") grant of
$452,772 to install weather stations and of$375,000 to conduct drone inspections. Response to
Staff Production Request No. 7 Bates Nos. NLI0001-25. In addition, Staff learned that the
Company has been awarded another three OEMR grants that were not mentioned in the 2026
WMP. See Response to Staff Production Request No. 20 and OEMR Energy Resiliency Grant
Program Awarded Projects. 1 These grants are for the following: (1) Priest Lake area projects to
replace 50 wood poles with ductile iron poles and to install Gridscope devices on 225 pole
locations of$1,159,162; (2) installing satellite imaging technology for vegetation management to
enable targeting of reduction areas needed to reduce wildfire hazards around powerlines of
$48,240; and (3) undergrounding overhead distribution power lines and underground services to
homes in Bonners Ferry of$1,543,542. Id.
Given that the majority of the Company's awarded grant information was omitted from the
2026 WMP and was instead provided in discovery, Staff recommends the Commission direct the
Company to provide details of all funding alternatives and funding sources pursued for wildfire-
related mitigation efforts in future WMP filings.
Cross Cutting Elements
This section addresses several integral components of the 2026 WMP that Staff considered
in its review that relate to multiple programmatic areas of the Guidelines. Here Staff provides its
analysis of the Company's targets and goals, the metrics used to monitor progress, the anticipated
filing date for future WMP filings, lessons learned from prior implementation, and Staff s
coordination efforts with the State Forester at the Idaho Department of Lands ("IDL"). Together,
these topics inform Staff s assessment of the Company's overall approach to wildfire mitigation
planning and continuous improvement.
Targets and Goals. The Guidelines require the Company to include measurable targets
and goals in its WMP. Guidelines at 7-8. Staff believes that the Company provides cycle-based
targets for many of its programs in the 2026 WMP. For example, the Company states that
vegetation management is performed on a 7-year cycle; overhead lines are inspected on a 7-year
1 OEMR Energy Resiliency Grant Program Awarded Projects. https:Hoemr.idaho.goy/programs/idaho-
energy-resiliency rg ant-pro rg am/(last visited May 12,2026).
STAFF COMMENTS 6 JUNE 10, 2026

cycle, and meters are inspected on a 4-year cycle. 2026 WMP at 11. However, the Company
provided additional numeric targets in Response to Staff Production Request No. 20, including
replacement of 50 wood poles with ductile iron poles and installation of Gridscope devices on 225
poles. Staff believes that having both numeric targets and cycle-based targets allows for more
effective year-to-year compliance verification. Therefore, Staff suggests that the Company
provide both cycle-based and numeric targets, such as poles or underground cable to be replaced,
for each program area and project where feasible in future WMP filings.
Metrics. As stated previously, Idaho Code § 61-1804(1)(b)(c) requires the Commission
to evaluate both the feasibility of the WMP and the extent to which it minimizes wildfire risk. The
Company identified some metrics it plans to use to assess the effectiveness of various WMP
programs. 2026 WMP at 15. However, the Company also provided additional details on
measuring WMP program effectiveness in its Response to Staff Production Request Nos. 9 and
11. Staff believes these metrics and the supporting data should be included in future WMP filings
because they provide practical indicators that support the Company's ongoing evaluation of system
conditions. Therefore, Staff recommends that the Company include all metrics used within each
respective program area and provide the associated data in a format that allows for easy
comparison across WMP cycles in future WMP filings. Where available, Staff further
recommends that the Company provide at least three years of historical system- and circuit-level
data to support trend analysis in future WMP filings.
Future WMP Filing Date. Idaho Code § 61-1803(2)(a) gives the Commission the
authority to stagger the filing dates of the WMPs. The Guidelines directed electric corporations
to file their updated WMPs for annual review one year after the filing date of the previously
approved WMP. Guidelines at 20. Through communication with Staff, the Company stated it
would prefer an annual WMP filing date on or about February 2"d. Staff has no concerns with this
preferred filing date.2 Therefore, Staff recommends the Commission issue an order clarifying that
2 In Case No.IPC-E-25-32,Idaho Power requested an annual filing date on or about October 1 each year.In Case No.
AVU-E-25-15,Avista requested an annual filing date on or about November 1 each year.In Case No.PAC-E-25-22,
Staff recommended Rocky Mountain Power have an annual filing date on or about December 1 each year. In Case
No.C07-E-25-01,Staff recommended Kootenai Electric Cooperative have an annual filing date on or about December
31 each year.
STAFF COMMENTS 7 JUNE 10, 2026

the Company's annual filing on an updated WMP should be submitted on or about February 2"d
of each year.
Lessons Learned. The Guidelines require the Company to provide an update of lessons
learned from the previously approved WMP filings submitted for Commission review and
approval. Guidelines at 8. The Company has not previously filed an Idaho Commission approved
WMP, so this requirement does not apply to the 2026 WMP.
However, the Company explained that in 2024 it developed its first WMP, implemented a
formal overhead inspections program, and applied seasonal protection settings to portions of its
system during peak wildfire conditions. Response to Staff Production Request No. 1. In 2025,the
Company expanded its wildfire mitigation efforts by developing its public power safety shutoff
("PSPS") plan and began formal wildfire risk modeling using Athena Intelligence. Id. Staff
suggests the Company include these details in future WMP filings to better demonstrate its efforts
to reduce wildfire risk and to demonstrate its implementation efforts.
State Forester Collaboration. Idaho Code § 61-1804(3) requires the Commission to
consult with the State Forester at the IDL regarding vegetation management,reduction of wildfire
fuels, and other duties of the State Forester under Title 38, Idaho Code. On January 29, 2026,
Staff informed the IDL of the 2026 WMP and provided access to the Company Application and
associated documents. On February 23,2026, Staff met with the Company and the IDL to discuss
the Company's wildfire risk modeling and other areas of the 2026 WMP.
On May 20, 2026, Staff and the IDL met to discuss the IDL's concerns and
recommendations for the 2026 WMP. Staff understands that the IDL intends to file public
comments, and Staff recommends that the Commission consider IDL's comments alongside
Staff s analysis when evaluating the 2026 WMP.
Geographical Risk Assessment
Idaho Code § 61-1803(3)(a) and the Guidelines require all WMPs to include a description
of the Company's wildfire risk assessment and a map of identified risk areas. In Section 6 of the
2026 WMP, the Company provided its Landscape Wildfire Risk map and provided a list of high-
level risk drivers. 2026 WMP at 8-9. Staff believes the Company has followed a reasonable
STAFF COMMENTS 8 JUNE 10, 2026

modeling approach to assess wildfire risk in its service territory and has met the requirements of
Idaho Code § 61-1803(3)(a) and the Guidelines. However, Staff believes there are areas for
improvement, including: (1) the wildfire risk model description; (2) addressing limitations of the
risk modeling process; and(3) addressing the different risk scores on its Landscape Wildfire Risk
map.
Risk Model Description
The description of the Company's modeling process and the inputs used were not included
within the 2026 WMP. In Section 6 of the 2026 WMP, the Company provides a brief description
of the wildfire risk model that states the Company has mapped its assets onto the risk model to
provide insight into risk. 2026 WMP at 6-7. However, in discovery with Staff the Company
explained that a third-party vendor, Athena Intelligence, was used to create the Company's
Landscape Wildfire Risk map. Response to Production Request No. 5. Also, the Company
provided details about the risk modeling inputs used by Athena Intelligence, which included: (1)
the United States Department of Agriculture Forest Service's ("USDA Forest Service") Wildfire
Risk to Communities 2024; (2)USDA Forest Service Landscape Fire and Resource Management
Planning Tools ("LANDFIRE") 2023; (3) National Interagency Fire Center Wildland Fire
Interagency Geospatial Services ("WFIGS"); (4) University of Wisconsin's SILVIS Lab; and(5)
other datasets.Id. Further in its Response to Staff Production Request No. 6, the Company stated
Athena Intelligence's Landscape Wildfire Risk was produced by the combination of two models,
Conditional Risk and Probability Risk models.
As most of the information needed to meet the requirements was provided in discovery,
Staff recommends the Commission direct the Company to include a narrative describing the
Athena Intelligence's modeling process and model inputs in future WMP filings. Staff believes
this narrative would assist in Staffs analysis of the Company's adherence to Idaho Code § 61-
1803(3)(a) and the Guidelines by providing context for the risk model and its inputs.
Risk Model Limitations
Staff believes there are multiple limitations with the Company's current risk model process.
First, the Guidelines state that the geographical risk assessment should consider factors including
asset location. Guidelines at 2. The Company explained that Athena Intelligence's approach to
STAFF COMMENTS 9 JUNE 10, 2026

risk modeling considers the existing wildfire risk due to external factors. Response to Production
Request Nos. 5 and 6. Staff believes Athena Intelligence's approach satisfies the requirements of
the Guidelines. However, Staff believes the risk modeling does not consider the risk of ignition
from the Company's infrastructure and that by not considering the risk of that ignition source, the
risk modeling is limited.
The Company stated it has overlayed its assets onto the Landscape Wildfire Risk map,but
this image is not included within the 2026 WMP. 2026 WMP at 6. Further, Staff believes that
simply overlaying assets on the risk map only indicates their physical location and does not provide
key details and attributes—such as equipment condition or type—that would be relevant in a
comprehensive wildfire mitigation plan, where utilities should consider both the presence of
equipment in high-fire-risk areas and the condition of that equipment to inform investments and
mitigations. Based on this, Staff believes that the Company's risk assessment process does not
consider the Company's infrastructure risk of causing wildfire as an input into the risk model.
Using its infrastructure risk as an input into the risk modeling may create a different
wildfire risk profile for the Company as it would consider the risk of ignition from its
infrastructure. Understanding the infrastructure risk would enable the Company to identify where
to focus system investments, in addition to understanding risk from external factors such as
vegetation. As the Company and Athena Intelligence continue to refine the modeling process,
Staff suggests the Company consider adding infrastructure ignition risk as an input into the risk
model.
Second, Idaho Code § 61-1804(l)(c) requires the Commission to consider the degree to
which the plan adequately minimizes wildfire risk. The Company provided qualitative
explanations regarding the benefits of its wildfire mitigation plans in its Response to Staff
Production Request No. 2 and in discussions with Staff. Thus, Staff believes the Company
satisfied the requirements of the WSCA. However, Staff believes that this information should be
included in the 2026 WMP.
Further, Staff believes that the risk model is one potential area where the Company can
explain how it is adequately minimizing wildfire risk from its infrastructure. Staff believes that
without infrastructure risk considered in the model,the model will not show any reduction of risk
based on investments in the system. Therefore, Staff recommends the Commission direct the
STAFF COMMENTS 10 JUNE 10, 2026

Company to narratively explain how specific mitigation activities, such as grid hardening efforts,
reduce wildfire risk in future WMP filings.
Lastly, in a meeting with Staff, the Company stated that it also had not directly consulted
with local fire experts on the results of the risk model. Staff believes it is an industry best practice
to consult with local experts as another facet to validate the risk model's results. Therefore, Staff
suggests the Company consult with local fire experts, such as the local fire warden,to further refine
the risk modeling output.
Risk Scores
The Guidelines require the Company to provide a map of its service area and provide an
explanation of what determines each level of wildfire risk. Guidelines at 2. The Company
provided the Landscape Wildfire Risk map produced by Athena in the 2026 WMP. 2026 WMP
at 8. Included in this map, there was a legend that depicts the five risk score categories based on
color and risk score; however,there was no explanation provided on how each risk score category
was determined. Id. In its Response to Staff Production Request No. 6, the Company stated that
the wildfire risk levels reflect a combination of likelihood of ignition, fuel characteristics, fire
intensity potential, and exposure of structures and infrastructure. The Landscape Wildfire Risk
map is produced by two models, which result in a geospatial-based, quantitative risk profile. Id.
The Company provided an illustration to depict the different colors of each risk category, which
is included herein as Figure No. 1 below. Id. The Company also provided an illustration that
showed how the colors on the map correlate to Figure No. 1 of the Risk Profile,which is included
as Table No. 2 below. Id. Athena's Risk Scores of 2 through 10 were created by combining the
Conditional Risk Class and Probability Risk Class. Id.
Figure No. 1 —Risk Profile
Very Low or High Very High
Moderate
STAFF COMMENTS 11 JUNE 10, 2026

Table No. 2—Athena's Risk Score
Probability Risk
Low Moderate Elevated High V*ryH
N
Very High 8
= High 5 5 7
0
Moderate 4 4 6 6 7 8
o Low 5 6 7
`j Very Low 4
Staff believes this information was necessary to evaluate the Company's adherence to the
risk assessment requirements. Because the information was not included within the 2026 WMP,
Staff recommends the Commission direct the Company to include an explanation of how risk
scores are derived and include any illustrations needed in future WMP filings, similar to what it
provided in its Response to Staff Production Request No. 6.
Preventative Actions and Programs
In addition to required material, the Guidelines state that an electric corporation may
include other actions or programs, such as system hardening strategies, workforce preparedness,
and pilot programs in tis WMP. Guidelines at 3-4. Staff believes system hardening strategies
correlate with Idaho Code § 61-1803(3)(e), therefore, Staff discusses system hardening in the
"Method of Line Design and System Hardening" section. The Company included a discussion of
its workforce preparedness and pilot programs in the 2026 WMP and those topics are discussed
below.
Workforce Training and Preparedness
Idaho Code § 61-1803(3)(c) and the Guidelines state that an electric corporation's WMP
may include other actions or programs, such as workforce preparedness. Guidelines at 3-4. The
Company included a workforce preparedness section within the 2026 WMP. 2026 WMP at 12.
Staff believes a trained workforce supports the safe and effective implementation of wildfire
mitigation measures, including situational awareness, emergency response, and line operations.
Staff also believes a trained workforce not only fulfills regulatory obligations but also strengthens
operational resilience, reduces the likelihood of safety incidents during wildfire season, and
supports timely, coordinated responses when conditions escalate.
STAFF COMMENTS 12 JUNE 10, 2026

Within the 2026 WMP, the Company stated that it conducts monthly wildfire and safety
training meetings and coordinates training and other events with local fire departments. 2026
WMP at 12. The Company also provided a summary of training provided during 2024 and 2025.
Response to Staff Production Request No. 18. Examples of additional training information
provided included attendance at a full-day Fire Mitigation and Advanced Distribution Protection
Control seminar and internal training on wildfire settings for reclosers. Id. Staff recommends the
Company provide a table identifying the planned training, the role of who should attend,
designation of whether training is required or optional, and training dates (i.e., date, month, or
quarter) in future WMP filings.
Pilot Programs
The Guidelines state that a WMP may include pilot programs as a preventative program.
Guidelines at 4. As discussed in the Grant section above, the Company was awarded a grant to
conduct a drone inspection on a portion of its overhead system. Response to Staff Production
Request No. 7 Bates Nos.NLI0001-25. In 2026,the Company plans to use drones to inspect 450-
500 miles of overhead line in Idaho. Response to Staff Production Request No. 9. Within the
2026 WMP, the Company stated that if it determines drone inspections are beneficial and cost
effective,it may add drone inspection as a future planned management strategy to its WMP. 2026
WMP at 11. In a meeting with Staff, the Company explained that this is a one-time inspection
funded by the OEMR grant, and that the Company planned to issue a request for proposal for a
contractor in Spring 2026, with the inspection to be performed in Summer 2026. As most of the
details regarding drone inspections were not included within the 2026 WMP, and the Company is
already conducting this work, Staff suggests the Company include additional details about the
Company's current or planned pilot programs,including areas of focus,total estimated capital and
annual O&M, and any metrics it will use to evaluate the success of each program. Additionally,
Staff suggests the Company include any targets in future WMP filings for transparency and to
support Staff s evaluation of the WMP's feasibility.
Public Outreach, Engagement and Community Education
Idaho Code § 61-1803(3)(c)and the Guidelines require each WMP to include a description
of how the electric corporation maintains community outreach and public awareness before,
STAFF COMMENTS 13 JUNE 10, 2026

during, and after wildfire season. Staff believes the 2026 WMP meets these requirements. For
example, the Company communicates its WMP with its members and the community via public
notices, public open houses, demonstrations, and information tables. 2026 WMP at 13.
Furthermore, the Company's Tree Foreman communicates daily with members while working in
the field. 2026 WMP at 6 and Response to Staff Production Request No. 3. Staff encourages the
Company to continue refining and updating its public outreach, engagement, and community
education efforts as necessary for inclusion in future WMP filings.
Government Outreach
Idaho Code § 61-1803(3)(d) and the Guidelines require a WMP to include a discussion of
outreach and coordination with federal, state, tribal, and local officials and agencies regarding
wildfire preparedness and emergency response planning. Staff believes the 2026 WMP satisfies
these requirements. For instance,the Company explained that it has limited interaction with tribal
residents and therefore coordinates with Tribes as necessary. 2026 WMP at 6. For large-scale
wildfires, the Company stated its Engineering & Operations Manager coordinates with local
emergency management agencies and any other agency as necessary. Id. The Company also
explained that it attends county coordination meetings,and the Company's Tree Foreman regularly
works with the United Stated Forest Service and the Idaho Department of Lands. Response to
Staff Production Request No. 3. Staff encourages the Company to continue refining and updating
its government outreach efforts as necessary for inclusion in future WMP filings.
Method of Line Design and System Hardening
Idaho Code §§ 61-1803(3)(b), 61-1803(3)(e), and the Guidelines require the Company to
include a description of the Company's methods of line design for new lines and planned system
upgrades. The Company identified five design and construction programs for wildfire mitigation:
(1) overhead to underground power line conversions; (2) system monitoring of substation feeders
via SCADA; (3) recloser upgrades; (4) pole replacements and replacing wood poles with steel
poles; and(5) installing fiberglass crossarms. 2026 WMP at 10. Based on its review of the 2026
WMP and the additional material provided by the Company in discovery, Staff believes the
requirements of Idaho Code §§ 61-1803(3)(b), 61-1803(3)(e), and the Guidelines have been met.
However, Staff has identified areas for improvement in future WMP filings described below.
STAFF COMMENTS 14 JUNE 10, 2026

Project Level Details
The 2026 WMP did not contain sufficient details, such as projected timelines, targets,
alternatives considered, selection criteria, reasonableness of costs, or primary drivers for each
project needed for Staffs analysis. The Company provided additional details in its Response to
Staff Production Request No. 20. Examples of details provided include:
Idaho Governor's Office of Energy and Mineral Resources, Preventing Outages
and Enhancing the Resilience of the Electric Grid grant—Priest Lake area projects,
including replacing 50 wood poles with ductile iron poles and installing Gridscope
devices at 225 pole locations. Total grant $1,159,162, NLI's cost share is 19%.
NLI's budget includes cost share. This project will span 2026 and 2027.
Lamb Creek Substation—This is a complete rebuild of an existing substation. This
will have modernized system protection,monitoring& control. Budget for 2026 is
$1,875,000 and includes site prep, final engineering design, construction and
commissioning.
I...I
Weather Stations & DSAT — Grant project that will install 60 weather stations in
Idaho and set up a DSAT for situational awareness during wildfire season. A grant
in the amount of$103,696 through the Idaho Energy Resiliency Grant Program,
has been awarded, and NLI's cost match is $25,924.
Response to Staff Production Request No. 20. Staff believed the additional information provided
in discovery was needed for, and did help with, Staffs analysis on whether the requirements of
Idaho Code §§ 61-1803(3)(b), 61-1803(3)(e), and the Guidelines were met. Thus, Staff
recommends the Commission direct the Company to include similar project-level details,
including targets, explanation of the benefits, project timelines, and alternatives considered for
each project in future WMP filings.
General Maintenance and Upgrade as a Project
The Company represented it prioritizes project selection using factors such as reliability
and continuity of service, replacement of aging infrastructure, capacity to meet load growth, and
reduction of operational and wildfire-related risk. Response to Staff Production Request No. 2.
The Company also stated that replacement of aging infrastructure inherently reduces wildfire risk
by lowering the likelihood of equipment failure. Id.
The North American Electric Reliability Corporation ("NERC") identifies that the risks
from a utility's infrastructure depend on several factors that include age, condition, and type of
STAFF COMMENTS 15 JUNE 10, 2026

construction.3 Staff believes incorporating a prioritized and enhanced maintenance program
focused on aging or high-risk equipment in elevated wildfire risk areas in a utility's WMP reduces
the probability of utility-caused ignitions while improving infrastructure resilience. Thus, Staff
suggests the Company consider adding prioritized inspection and maintenance based on an area's
fire risk and infrastructure condition as a wildfire mitigation strategy,similar to the strategies listed
in the 2026 WMP at Section 7.2.1.
Include Avian and Animal Projects
In a conversation between Staff and the Company on March 25, 2026,the Company stated
that it maintains an Avian Protection Plan. Staff believes that avian and animal protection is
important to an electric utility because it prevents wildlife-caused contacts that can lead to outages
and ignition risks, thereby improving system reliability while also safeguarding animals. As the
Company has an Avian Protection Plan that is otherwise not detailed in the 2026 WMP, Staff
suggests the Company include these details in future WMP filings.
Situational Awareness and Monitoring
Idaho Code § 61-1803(3)(f) and the Guidelines require each WMP to discuss how the
Company monitors weather conditions and wildfire risk. The Guidelines specifically require the
Company to identify the systems, tools, or external resources used to monitor weather, fire
potential,or other situational awareness indicators. Guidelines at 6. Section 7.1 of the 2026 WMP
describes each of the public sources the Company uses to monitor weather conditions and wildfire
risk,and explains that the Company has received a grant to set up its own weather station network.
2026 WMP at 10. Staff believes the Company has met the requirements of Idaho Code § 61-
1803(3)(f) and the Guidelines; however, Staff believes there is room for improvement regarding
the weather station network.
As mentioned in the Grants section above,the Company is creating its own weather station
network as a result of an OEMR grant. Response to Staff Production Request No. 7 Bates Nos.
NLI0001-25. In Response to Staff Production Request No. 7, the Company stated its plans to
install 60 weather stations in 2026 and incorporate the data into a new Daily Situational Awareness
s NERC Wildfire Mitigation Reference Guide July 2025 at 3. Wildfire Mitigation Reference Guide - July
2025 (last visited May 20,2026).
STAFF COMMENTS 16 JUNE 10, 2026

Tool ("DSAT"). The Company stated it intends to use the Tempest software as its DSAT, which
will integrate real-time weather data, alert thresholds, and decision-support tools to assist in
wildfire risk monitoring. Id. Staff believes this information is necessary to include within WMPs,
and not through discovery with Staff, as it describes a program that will benefit the Company's
situational awareness. Therefore, even though Staff believes that the information provided in the
2026 WMP satisfies Idaho Code § 61-1803(3)(f) and the Guidelines, Staff recommends the
Commission direct the Company to include the details of the weather station program status, areas
of focus,annual cost,any applicable targets,and any metrics used to evaluate the program in future
WMP filings. Additionally, Staff recommends the Commission direct the Company to include a
more detailed description of the DSAT tool, including the outputs of the tool, in future WMP
filings. Staff suggests the Company include a narrative describing how the Company uses the data
from the DSAT tool to inform its operations.
Infrastructure Inspections and Maintenance
Idaho Code §§ 61-1803(3)(b), 61-1803(3)(g)(i), and the Guidelines require discussion of
the frequency and standards for inspections of each type of electric infrastructure within areas of
elevated wildfire risk and targets or goals to be achieved within the WMP. Staff believes clear
inspection guidelines help enable timely inspections, maintenance, and emergency repairs,
reducing reliability and safety risks during high fire danger conditions and in heightened wildfire
risk zones. The Company described its asset inspection strategy in 2026 WMP sections 7.4, 10.3,
and in the Infrastructure and Vegetation Management Procedure attached to the 2026 WMP("2026
WMP Infrastructure and Vegetation Management Procedure"). The Company also provided
additional details in its Response to Staff Production Request No. 10. This response included a
description of the inspection form content that includes tasks such as: (1)checking connection and
grounds for proper installation and system integrity; (2) evaluation of equipment condition
(including transformers, breakers, etc.); and (3) evaluating wire condition to identify issues such
as sag, excessive splicing, or improper tie-ins. Based on its review of the 2026 WMP, Staff
believes the Company has met these requirements. However, Staff has identified areas for
improvement in future WMP filings, described below.
STAFF COMMENTS 17 JUNE 10, 2026

Enhanced Inspections for Elevated Fire Risk Areas
The Company states that it has a 7-year inspection cycle for all overhead lines. 2026 WMP
at 11. The Company has also identified certain areas of its service territory that have elevated fire
risks. 2026 WMP at 6-8. The NERC's recent wildfire report recommends electric utilities adopt
risk-based asset management programs that"target equipment"within the high fire risk areas,that
consider "factors such as failure-mode history and age-based performance curves," and that
prioritize at-risk equipment"within inspection and maintenance regimes."4 Based on the NERC's
recommendation in its recent wildfire report, Staff recommends the Company consider adopting
enhanced inspection schedules for elevated fire risk areas that also considers equipment condition.
Quality Assurance
Staff believes a Quality Assurance ("QA") program for infrastructure maintenance is
essential because it verifies that completed corrective work truly resolves the identified issue,
ensuring safety, reliability, and accountability in the utility's maintenance practices. The 2026
WMP did not describe the Company's QA process for inspections. In discovery with Staff, the
Company stated that it"utilizes [geographic information system] GIS and engineering systems to
monitor and track deficiencies and repairs, which functions as an ongoing quality control process
in lieu of a formal audit program." Response to Staff Production Request No. 14. Staff suggests
the Company consider adopting a more formal QA process that uses a statistically valid sample of
completed work to provide reliable assurance that issues are being properly corrected.
Deficiency Backlog Monitoring
Staff believes that through the course of its inspections and related activities,the Company
will naturally identify deficiencies. The Company represented in discovery with Staff that each
identified deficiency is assigned to one of the following categories that include defined priorities
and target timelines for remediation:
1. High—requires immediate attention;
2. Medium—requires scheduled work;
4 North American Electric Reliability Corporation Docket No. RD25-9-000(2026)Attachment A at 6,
hitps://www.nerc.com/globalassets/who-we-are/le ag 1--regulatory/filings--orders/nerc-filings-to-ferc... (last visited
May 21,2026).
STAFF COMMENTS 18 JUNE 10, 2026

3. Low—routine maintenance; and
4. NA—no action required.
Response to Staff Production Request No. 10. Staff notes that a backlog represents the
accumulation of deficiencies that remain unresolved beyond the target timeline. Monitoring how
long deficiencies remain open is essential for understanding whether remediation is occurring
within appropriate priority-based target timelines and for identifying trends that may indicate
emerging risks. An increasing number of overdue deficiencies, particularly those remaining open
for extended durations, signals that additional resources or process adjustments may be needed to
maintain safety and system reliability.
The Company provided deficiency backlog data in its Response to Staff Production
Request No. 11. To further support transparency and long-term monitoring of deficiency trends,
Staff recommends that the Company include the following Idaho infrastructure-related deficiency
information for the prior three years in future WMP filings: (1) the number of deficiencies
identified by category; (2) the number or percentage of deficiencies repaired by priority category;
and(3)pending repairs at year-end by category.
De-Enemization and Operational Practices During Heightened Wildfire Risk Days and
Zones
Idaho Code §§ 61-1803(3)(b), 61-1803(3)(g)(ii), and the Guidelines require discussion of
operational changes during heightened wildfire risk days or in high wildfire risk zones, which
includes system and line settings, restrictions to workforce practices, and other system processes.
Staff believes this information is important because operational changes during heightened
wildfire risk days reduce the likelihood of ignition not only from electrical infrastructure but also
from activities performed on that infrastructure,such as routine maintenance or emergency repairs.
The Company stated it operates under two levels of seasonal settings based on current area fire
restrictions in each of the six counties it serves:
1. Level 1 Settings: Stage 1 Fire Restrictions (Reclosing is turned off for system
protection devices); and
2. Level 2 Settings: Stage 2 Fire Restrictions (System protection devices are set to trip as
quickly as the device allows).
STAFF COMMENTS 19 JUNE 10, 2026

2026 WMP at 12. Although Staff believes the 2026 WMP has met the requirements, Staff has
recommendations for improvement in future WMP filings.
Operational Practices During Heightened Wildfire Risk Days and Zones
The Company tracks multiple sources of real-time and near-term weather for situational
awareness and also tracks Red Flag Warnings ("RFW") and area fire restrictions. 2026 WMP at
9-10; See also 2026 WMP Infrastructure and Vegetation Management Procedure at 6. The
Company described how relays and reclosers settings change as fire risk escalates. 2026 WMP at
12. The Company described how infrastructure and vegetation management work may change
during elevated fire conditions. 2026 WMP at 9-10; See also 2026 WMP Infrastructure and
Vegetation Management Procedure at 6. Staff believes that the information provided in the 2026
WMP satisfies Idaho Code §§ 61-1803(3)(b), 61-1803(3)(g)(ii), and the Guidelines.
However, the descriptions of infrastructure and vegetation management work were
presented at a high level and did not distinguish how specific operational practices change as
conditions escalate from Level 1 to Level 2 and ultimately to a RFW. Id. Instead of identifying
what actions apply at each individual risk level,the information is grouped,making it unclear how
incremental changes occur as wildfire risk increases. Id. Staff requested from the Company
documentation outlining how operational practices, such as fieldwork procedures and required fire
and safety equipment, vary across different risk levels, but the documents provided by the
Company were not responsive to Staffs request. Response to Staff Production Request No. 16.
Staff believes that operational adjustments are likely to differ as wildfire risk levels change. Staff
recommends that the Company include in future WMP filings a table or narrative that clearly
identifies how practices evolve at each designated risk level. Staff believes that providing this
level-specific detail will improve transparency and allow for a clearer understanding of how the
Company scales its operational response as wildfire risks escalate.
De-Energization with a Public Safety Power Shutoff
The 2026 WMP briefly describes the Company's de-energization and re-energization
policy. 2026 WMP at 12-13. The Company stated that it developed a PSPS program in 2025. Id.
The Company provided a copy of its PSPS plan in its Supplemental Response to Staff Production
Request No. 17. The Company represents it will utilize a variety of tools to make PSPS decisions
STAFF COMMENTS 20 JUNE 10, 2026

based on current conditions and with public safety as a priority rather than having a specific
formula or checklist for enacting a PSPS. Id. The Company's PSPS plan describes that it also
configures reclosers to instantaneous trip with no reclosing while retaining the option to implement
a proactive de-energization,if necessary.Id. Staff notes that it is a common industry understanding
that a recloser trips automatically and de-energizes the affected line segment during a fault and
reduces the amount of line that must be patrolled before service can be restored. The Company's
PSPS plan also describes member communication before, during, and after an event, as well as its
re-energization processes. Id. Staff suggests that the Company include a copy of its current PSPS
plan in future WMP filings.
Vegetation Management
Idaho Code § 61-1803(3)(g)(iii) and the Guidelines require each WMP to include a
discussion of vegetation management and enhanced vegetation management for heightened fire
risk areas. Staff reviewed the Company's routine and enhanced vegetation management practices
described in the 2026 WMP and believes the Company has met the WSCA and Guidelines
requirements. However, Staff has identified areas of potential improvement in future WMP
filings.
Enhanced Inspection for Elevated Fire Risk Areas.
The Company states that it uses satellite-based vegetation imagery to support a risk-based
approach to vegetation management and to help prioritize work areas. 2026 WMP at 11. Staff
requests that, in future WMP filings,the Company provide additional detail on the criteria used to
determine this prioritization (e.g., vegetation clearance measurements, identification of hazard
trees, designation of elevated fire-risk areas, or other relevant factors).
Quality Assurance
Staff believes that a QA program for vegetation management is essential because it verifies
that work is completed in accordance with the Company's specifications, standards, and
right-of-way requirements to prevent outages and reduce risk. The Company did not describe its
QA process in the 2026 WMP. However, through discovery with Staff the Company stated that
QA is performed through supervisory review by the Company's Tree Foreman rather than a formal
STAFF COMMENTS 21 JUNE 10, 2026

audit program. Response to Staff Production Request No. 13. Staff suggests the Company
consider adopting a more formal approach to QA that uses statistically valid sampling because
only a sufficiently large and properly selected sample can provide reliable confidence in contractor
performance and prevent decisions from being based on incomplete or misleading data.
Vegetation Management Training
The Company shared that its vegetation management is done according to standards that
include American National Standards Institute ("ANSI") A300 and Occupational Safety and
Health Administration("OSHA") 1910.269. Response to Staff Production Request No. 22. These
standards address clearances, tree/shrub conditions, how to safely and appropriately prune or
remove vegetation, and vegetation health. However, in a meeting on March 25, 2026, with the
Company, the IDL, and Staff, the IDL mentioned that the standards the Company used do not
cover the ignition potential or fire propagation perspectives of vegetation. The IDL specifically
mentioned the above standards do not address "ladder" fuels, which allow wildfires to progress
from the ground to the canopy and are applicable to the Company's territory. In the March 25,
2026, meeting, the Company stated it does not currently require the International Society of
Arboriculture's Wildfire Risk Reduction Qualification and has not considered doing so. Staff
suggests the Company consider adding this training and certification as a requirement for
personnel or contractors doing vegetation management as it addresses ladder fuels, which are
applicable to the Company's territory.
Hazard Trees
The Company stated that it identifies and documents hazard trees during its vegetation
management inspections and schedules mitigation work in accordance with its internal policies.
2026 WMP Infrastructure and Vegetation Management Procedure at 5. The 2026 WMP does not
provide data on the number of hazard trees identified each year, the number removed or otherwise
addressed, or the number remaining at year-end. However, the Company did provide the number
of trees removed and trimmed each year from 2022 through discovery with Staff. Response to
Staff Production Request No. 3. Staff believes tracking these metrics would help determine
whether additional resources are needed to manage any growth in the backlog of hazard trees
requiring remediation. The Company's territory includes wooded areas, and Staff is concerned
STAFF COMMENTS 22 JUNE 10, 2026

that ongoing drought conditions and insect infestations in Idaho forests may increase tree
mortality,accelerating the emergence of hazard trees within the Company's service territory. Staff
recommends that the Company include these hazard-tree metrics in future WMP filings to better
monitor, anticipate, and manage potential backlog growth.
Wind Event Prioritization.
During discussions with IDL regarding the 2026 WMP, IDL noted that the Company's
service territory experiences extreme wind events that frequently compromise certain tree species,
particularly in specific soil types. IDL explained that trees lacking a tap root—such as lodgepole
pine, grand fir, spruce, and some alpine fir—are especially prone to becoming hazard trees after
high-wind events due to weakened root structures. Based on this information, Staff recommends
the Company consider increasing the frequency of hazard-tree inspections for a period in service
areas affected by recent extreme wind events, particularly in areas where these more vulnerable
tree species are present.
Marketable Timber on Timber Company Land
Idaho Code § 61-1803(3)(g)(iii) requires each Company to describe its process providing
timber companies compensation at fair market value for live marketable timber identified for
removal from timber company land adjacent to the Company's Right of Way ("ROW"). The
Company stated it"will work with timber company land owners to develop a plan to manage live
marketable timber that is identified for removal from timber company land adjacent to the rights-
of-way". 2026 WMP at 11. Staff believes the Company has met this requirement. However, Staff
suggests the company include more details on this process in future WMP filings.
STAFF RECOMMENDATIONS
Staff recommends the Commission issue an order:
1. Approving the 2026 WMP; and
2. Clarifies the Company may file its future annual updated Wildfire Mitigation Plan on
or about February 2nd each year.
Staff recommends the Commission issue an order directing the Company to:
STAFF COMMENTS 23 JUNE 10, 2026

1. Provide details of all funding alternatives and sources pursued in future WMP filings;
2. Include a narrative explaining the vendor's modeling process, including the inputs of
the modeling it is using in future WMP filings;
3. Include a narrative that explains how mitigation activities are reducing wildfire risk in
future WMP filings;
4. Include the explanation of how risk scores are derived and include any illustrations
needed, similar to its Response to Staff Production Request No. 6, in future WMP
filings;
5. Include project-level details including the targets, explanation of the benefits, and
alternatives considered for each project in future WMP filings;
6. Include the details of the weather station program status, areas of focus, annual cost,
any targets,if applicable,and any metrics used to evaluate the program inf future WMP
filings; and
7. Include a more detailed description of the DSAT tool — including the outputs of the
tool in future WMP filings.
Respectfully submitted this 10th day of June 2026.
Kelsea E. Ross
Deputy Attorney General
Technical Staff. Karla Ducharme, Kimberly Loskot, Ray McArthur
I:\Utility\UMISC\COMMENTS\COI-E-26-01 Comments.docx
STAFF COMMENTS 24 JUNE 10, 2026

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 1 Oth DAY OF JUNE 2026, SERVED
THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN CASE NO. C10-
E-26-01, BY E-MAILING A COPY THEREOF TO THE FOLLOWING:
Northern Lights,Inc.
KRISTIN BURGE
ENGINEERING& OPERATIONS MGR.
NORTHERN LIGHTS, INC.
P.O. BOX 269
SAGLE, ID 83860
EMAIL: kristin.burge(a h.coop
SUSAN P. WEEKS
JAMES, VERNON& WEEKS, P.A.
1626 LINCOLN WAY
COEUR D'ALENE, ID 83814
E-MAIL: [e-mail]
PATRICIA JORDAf4, SECRETARY
CERTIFICATE OF SERVICE