20260610Comment_1.pdf

From: Kayla Dawson <[e-mail]>
Sent:Wednesday, June 10, 2026 3:44 PM
To: secretary<[e-mail]
Subject: C10-E-26-01 Northern Lights, Inc.Wildfire Mitigation Plan 2026-2028 - IDL
Comments
Good afternoon -Attached for filing and service please find Idaho Department of Lands'
Comments in the matter of Northern Lights, Incas Application for Approval of its 2026-2028
Wildfire Mitigation Plan, Case No. C10-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(c-bidl.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 NORTHERN LIGHTS, CASE NO. C10-E-26-01
INC'S APPLICATION FOR APPROVAL OF
ITS 2026-2028 WILDFIRE MITIGATION IDAHO DEPARTMENT OF
PLAN LANDS' COMMENTS
Idaho Department of Lands ("IDL")respectfully submits the following comments in the
above-captioned matter pursuant to Idaho Code § 61-1804(3) and Order No. 36927 on behalf of
Idaho State Forester, Julia Lauch.
1. IDL has long required our cooperators at the county level who develop and maintain
County Wildfire Preparedness Plans to provide descriptive details about the modeling
inputs that are used to create their products. It is IDL's position that if we don't hold
utilities to the same standard then a"double" standard would be established setting a
precedent that does not"move the needle" on wildfire mitigation efforts. IDL
respectively requests that Idaho Northern Lights provide additional descriptive narrative
details about the data utilized to produce their"risk"model.
a. When conducting risk modeling, two key elements are necessary for a model to
accurately represent risk—probability of occurrence and consequence to values.
The modeling provided by Northern Lights does not include the latter as it lacks
clearly identifiable wildland urban interface (WUI) or other comparable data in
IDAHO DEPARTMENT OF LANDS'COMMENTS-1

the modeling as a data input or as a mask'. 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. Veizetative 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 lay. 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 Northern Lights' system.
3. 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 Northern Lights to
actively seek partnerships with the various counties in which their systems exist. IDL
1 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.
2 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.
IDAHO DEPARTMENT OF LANDS'COMMENTS—2

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.
4. Northern Lights' plan mentions a process for cost recovery when trees on forest industry
ownerships are required to be removed. However, due to a lack of details associated with
that process IDL requests that Northern Lights add narrative details about the process in
future iteration of the plan. It is IDL's position that the SOPS, when highlighted in the
plan,will build greater confidence in relationships and the values associated with
timbered lands.
5. IDL cannot make a reasonable determination of how vegetation management differs in
the areas within Northern Lights systems designated as high fire risk. Specifically, how
the frequency of inspection changes and how prioritization of mitigation is made when
high wildfire risk is considered.
a. Additionally, in the section 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. Generally, the level of detail included in the plan makes it difficult to determine what will
be done and how the measure of success of implementation of the plan mitigation actions
will be captured. This is most strongly evident in the cost evaluation provided which
should include measurable details so success can be weighed. If Northern Lights is
IDAHO DEPARTMENT OF LANDS'COMMENTS-3

unable to speak to the economics of efforts, it is suggested that Northern Lights speaks to
the value (economic) of the systems served and the impacts (economic)when electric
service is disrupted. Additionally, IDL would encourage Northern Lights to provide an
evaluation of the cost of no mitigation actions to help clarify the impact of expenditure
investment.
Respectfully submitted this 10th day of June, 2026
IDAHO DEPARTMENT OF LANDS
-4i*`
J.J.WINTERS
Attorney for Idaho Department of Lands
IDAHO DEPARTMENT OF LANDS'COMMENTS-4

CERTIFICATE OF SERVICE
I hereby certify that on this 10t'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:
Northern Lights, Inc. ❑X Email:Kristin.burge(d),,nli.com
Kristin Burge sweeksgjvwlaw.net
Susan P. Weeks
Idaho Public Utilities Commission ❑x Email: secretarygpuc.idaho.gov
Commission Secretary erika.melanson(&,puc.idaho.gov
P.O. Box 83720 Kelsea.ross(&,puc.idaho.gov
Boise, ID 83702-0074
Erika Melanson
Kelsea Ross
Deputy Attorney General
11331 W. Chinden Boulevard, Bldg. 8
Suite 201-A (83714)
P.O. Box 83720
Boise, ID 83702-0074
Is/Kayla Dawson
Kayla Dawson
IDAHO DEPARTMENT OF LANDS'COMMENTS-5