20260623Reply Comments.pdf

RECEIVED
June 23, 2026
SUSAN P. WEEKS, ISB NO. 4255 IDAHO PUBLIC
JAMES, VERNON& WEEKS, P.A. UTILITIES COMMISSION
1626 Lincoln Way
Coeur d'Alene, ID 83814
Telephone: [phone]
Facsimile: [phone]
[e-mail]
Attorneys for Clearwater Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF CASE NO. COI-E-26-01
CLEARWATER POWER
COMPANY'S APPLICATION FOR CLEARWATER POWER COMPANY'S
APPROVAL OF THE COMPANY'S REPLY TO COMMENTS
2026 IDAHO WILDFIRE
MITIGATION PLAN
Clearwater Power Company ("Clearwater" or "Company"), by and through counsel,
respectfully submits these Reply Comments regarding the comments filed by Commission Staff
("Staff'), the Idaho Department of Lands ("IDL"), and PotlatchDeltic Forest Holdings, LLC
("PotlatchDeltic") concerning Clearwater's 2026 Wildfire Mitigation Plan("WMP").
I. INTRODUCTION
Clearwater appreciates the review conducted by Staff, IDL, and PotlatchDeltic and shares
their commitment to reducing wildfire risk throughout Idaho. Staff concludes that Clearwater's
WMP satisfies the requirements of the Wildfire Standard of Care Act ("WSCA"), the
Commission's Wildfire Mitigation Plan Guidelines, and applicable Commission Orders, and
recommends approval of the WMR Clearwater agrees and urges the Commission to approve its
WMP.
Clearwater further appreciates the recommendations offered by IDL and PotlatchDeltic.
Many of those recommendations concern additional information, enhanced analysis, or future
refinements that may be considered as Clearwater continues to update and improve its wildfire
CLEARWATER POWER COMPANY'S REPLY TO COMMENTS: 1

mitigation planning efforts. Clearwater intends to evaluate those recommendations as part of future
WMP development.
The fundamental question before the Commission is not whether additional information,
alternative methodologies, or enhanced mitigation measures could be incorporated into future
wildfire mitigation plans. Any wildfire mitigation plan can be refined as technology advances,
wildfire science evolves, and operational experience grows. Rather, the question before the
Commission is whether Clearwater's 2026 WMP satisfies the requirements established by the
Legislature and the Commission. The record demonstrates that it does.
II. RESPONSE TO STAFF COMMENTS
Clearwater appreciates Staff's thorough review of the WMP and Staff's recommendation
that the Commission approve the Plan. Staff identifies several areas where future WMP filings
may benefit from additional discussion, including wildfire risk modeling, project-level
information, mitigation metrics, quality assurance procedures, funding opportunities, and related
topics. Clearwater agrees future WMPs may include additional information regarding these
subjects.As wildfire mitigation planning continues to mature, Clearwater expects future plans to
incorporate additional analysis, data, operational experience, and lessons learned.
Importantly, however, Staff does not conclude that the absence of such additional
information renders the current WMP deficient. To the contrary, Staff expressly concludes that
Clearwater's WMP satisfies applicable requirements and recommends approval.
III. RESPONSE TO COMMENTS REGARDING
WILDFIRE RISK ASSESSMENT
IDL and PotlatchDeltic recommend that Clearwater consider additional datasets,
infrastructure information,vegetation-related information, and alternative modeling approaches in
future wildfire risk assessments. Clearwater appreciates these recommendations and agrees that
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wildfire risk assessment methodologies continue to evolve. As new information becomes
available, Clearwater intends to evaluate whether additional datasets, analytical tools, and
assessment techniques may improve future wildfire risk analysis. The commenters'preference for
alternative methodologies,however,does not establish that Clearwater's current WMP is deficient.
The WSCA does not prescribe a specific wildfire risk model. It does not require utilities to
utilize a particular dataset, weighting methodology, mapping platform, or analytical framework.
Instead, the statute requires utilities to identify wildfire risks and develop plans to mitigate them.
That is precisely what Clearwater's WMP accomplishes.
The Company's wildfire risk assessment evaluates conditions within Clearwater's service
territory and provides the foundation for the mitigation strategies described throughout the Plan.
While reasonable stakeholders may disagree regarding the optimal methodology for conducting
such assessments, those differences of opinion do not establish noncompliance with the WSCA.
Nor should the Commission lose sight of the context in which Clearwater operates.
Clearwater is a rural electric cooperative serving approximately 11,900 meters across a service
territory spanning portions of Idaho,Washington,and Oregon.The Company operates nearly 3,000
miles of electric facilities across approximately 5,000 square miles of largely rural terrain. The
WSCA expressly contemplates that wildfire mitigation planning should reflect the size,
complexity, and circumstances of the utility involved. Clearwater's risk assessment methodology
and mitigation planning efforts are appropriately tailored to those circumstances.
IV. RESPONSE TO COMMENTS REGARDING VEGETATION MANAGEMENT
AND STAKEHOLDER COORDINATION
IDL and PotlatchDeltic also raise issues relating to vegetation management, hazard tree
identification, contractor practices, forest land impacts, and coordination with industrial forest
landowners. Clearwater recognizes the critical role vegetation management plays in reducing
CLEARWATER POWER COMPANY'S REPLY TO COMMENTS: 3

wildfire risk and maintaining safe and reliable electric service. As discussed in the WMP,
Clearwater maintains ongoing vegetation management, inspection, maintenance, and system
improvement programs intended to reduce wildfire risks associated with electric operations.
Clearwater values its longstanding relationships with governmental agencies and fire management
organizations throughout its service territory and intends to continue coordinating with these
stakeholders on wildfire risk reduction activities. The Company also agrees that future WMP
filings may include additional discussion of hazard tree management, contractor qualifications,
vegetation management practices, and stakeholder coordination efforts.
The commenters' desire for additional detail, however, does not establish that the current
WMP is deficient. The WMP identifies existing vegetation management activities, describes
wildfire mitigation programs, and provides a framework for continued risk reduction. The WSCA
does not require a utility to include every operational procedure or management practice in
exhaustive detail as a condition of plan approval.
V. TIMBER COMPENSATION
IDL and Staff recommend that future WMP filings contain additional discussion regarding
the process for compensating timber companies for live marketable timber removed from timber
company lands adjacent to utility rights-of-way. Clearwater appreciates these comments and
agrees that additional explanation of such procedures may be beneficial in future WMP filings.
As Clearwater explained in discovery, if live marketable timber is identified for removal
from timber company land adjacent to Clearwater's rights-of-way, compensation at fair market
value will be provided where required by the WSCA. Clearwater will evaluate whether future
WMP filings should include additional discussion regarding notice procedures, coordination
efforts, valuation practices, or related processes. However, the absence of such procedural detail
CLEARWATER POWER COMPANY'S REPLY TO COMMENTS: 4

in the current WMP does not relieve Clearwater of any statutory obligation, nor does it render the
Plan noncompliant.
VI. RESPONSE TO POTLATCHDELTIC'S REQUEST
THAT THE WMP BE REJECTED
PotlatchDeltic urges the Commission to reject Clearwater's WMP and require the
Company to address alleged deficiencies before approval. Clearwater respectfully disagrees.
The issue before the Commission is not whether commenters can identify additional
information, alternative methodologies, or potential modifications that could be incorporated into
future WMPs. Wildfire mitigation planning is necessarily an evolving process, and reasonable
stakeholders may disagree regarding the relative merits of particular analytical approaches,
mitigation strategies, operational practices, or reporting formats.
Rather, the question before the Commission is whether Clearwater's 2026 WMP satisfies
the requirements established by the WSCA and the Commission's Wildfire Mitigation Plan
Guidelines. The record demonstrates that it does.
The principal criticisms advanced by PotlatchDeltic concern wildfire risk modeling,
vegetation management practices, weather monitoring strategies, mitigation priorities, and the
level of detail contained in the WMP. Those criticisms largely reflect disagreements over
methodologies, priorities, or the extent of information to include in future filings. Such
disagreements do not establish noncompliance.
The WSCA does not require utilities to adopt a particular wildfire-risk model, utilize
specific datasets, implement particular mitigation measures, deploy specific technologies, or
allocate mitigation resources in any prescribed manner. Nor does the statute require utilities to
adopt recommendations advanced by commenters in a Commission proceeding.
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Instead, the statute requires utilities to identify wildfire risks and develop plans to mitigate
those risks in a manner that reflects the utility's circumstances and operations. Clearwater's WMP
satisfies that standard. The Plan identifies wildfire risks within the Company's service territory,
describes existing and planned mitigation activities, addresses vegetation management,
inspections, operations, emergency response, and public communications, and provides a
framework for continued wildfire risk mitigation planning.
PotlatchDeltic identifies several areas in which it believes additional information, different
methodologies, or alternative mitigation approaches should be considered. Clearwater
acknowledges those recommendations and may take them into account, together with other
available information and operational considerations,in developing future WMPs,as the Company
deems appropriate. However, the existence of potential enhancements or alternative approaches
does not establish that the current WMP is deficient.
Many of the mitigation measures described in the WMP build upon programs and
operational practices that Clearwater has maintained as part of its longstanding commitment to
providing safe and reliable electric service. The fact that certain programs predate the enactment
of the WSCA does not diminish their effectiveness as wildfire-mitigation measures. The WSCA
does not require utilities to discontinue effective programs merely because those programs existed
before the adoption of the statute.
Ultimately, PotlatchDeltic's comments identify issues on which reasonable parties may
hold differing views. They do not demonstrate that Clearwater's WMP fails to satisfy applicable
statutory requirements.
Most importantly, Staff reviewed Clearwater's WMP, discovery responses, and the
comments filed in this proceeding and nevertheless concluded that the WMP satisfies applicable
CLEARWATER POWER COMPANY'S REPLY TO COMMENTS: 6

statutory and regulatory requirements and should be approved. Clearwater respectfully submits
that the Commission should adopt Staff's recommendation.
VII. CONCLUSION
Clearwater appreciates the participation of Staff, IDL, and PotlatchDeltic in this
proceeding. The comments submitted by IDL and PotlatchDeltic identify various matters that may
be considered in connection with future wildfire mitigation planning efforts. The existence of such
recommendations, however, does not establish that Clearwater's 2026 WMP fails to satisfy the
requirements of the WSCA or the Commission's Wildfire Mitigation Plan Guidelines.
The Commission's task in this proceeding is to determine whether the submitted WMP
complies with applicable requirements. Staff reviewed the WMP, discovery responses, and
comments filed in this proceeding and concluded that the Plan satisfies those requirements and
should be approved. The record supports that conclusion.
Accordingly, Clearwater respectfully requests that the Commission approve Clearwater
Power Company's 2026 Wildfire Mitigation Plan.
DATED this 23FD day of June, 2026.
JAMES, VERNON& WEEKS, P.A.
l sl.Sudan P. Wee&
SUSAN P. WEEKS
Attorneys for Respondent
CLEARWATER POWER COMPANY'S REPLY TO COMMENTS: 7

CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing was served by email on the
following persons this 26th day of June, 2026:
Idaho Public Utility Commission Staff
Erika K. Melanson, Deputy Attorney General
EMAIL: [e-mail]
Intervenor, Potlatch Deltic Forest Holdings,LLC:
Peter J. Richardson RICHARDSON ADAMS, PLLC
515 N. 27th Street Boise, ID 83702
EMAIL:[e-mail]
Michele Tyler, Esq.
Wade Semeliss
Brian Schlect, Esq.
Anna Torma
PotlatchDeltic Forest Holdings, LLC
601 W. First Ave, Suite 1600
Spokane, WA 99201
EMAIL:
[e-mail]
[e-mail]
[e-mail]
[e-mail]
lsl5ad4a P. ZpeedQ
SUSAN P. WEEKS
CLEARWATER POWER COMPANY'S REPLY TO COMMENTS: 8