20260701Reply Comments.pdf

SUSAN P. WEEKS, ISB NO. 4255 RECEIVED
JAMES, VERNON& WEEKS, P.A. JULY 1, 2026
1626 Lincoln Way IDAHO PUBLIC
Coeur d'Alene, ID 83814 UTILITIES COMMISSION
Telephone: [phone]
Facsimile: [phone]
[e-mail]
Attorneys for Clearwater Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF NORTHERN CASE NO. C 10-E-26-01
LIGHTS, INC.'S APPLICATION
FOR APPROVAL OF THE NORTHERN LIGHT INC.'S REPLY TO
COMPANY'S 2026 IDAHO COMMENTS
WILDFIRE MITIGATION PLAN
Northern Lights,Inc. ("NLI"or"Company"),by and through counsel,respectfully submits
these Reply Comments regarding the comments filed by Commission Staff("Staff") and the Idaho
Department of Lands ("IDL") concerning NLI's 2026 Wildfire Mitigation Plan("WMP").
I. INTRODUCTION
As a rural electric cooperative voluntarily submitting its first Wildfire Mitigation Plan for
Commission review under the Wildfire Standard of Care Act ("WSCA"), NLI appreciates the
professionalism and constructive approach taken by Staff throughout this proceeding. Staff's
review, discovery requests, and recommendations have provided valuable guidance regarding the
information that will assist the Commission in evaluating future annual WMP filings. NLI views
this proceeding as the beginning of the iterative planning process established by the WSCA and
intends to continue refining future WMPs as operational experience, technology, and wildfire
science evolve.
II. RESPONSE TO STAFF'S COMMENTS
NLI appreciates Staff's careful and comprehensive review of the WMP. Staff's review
included written discovery, discussions with NLI, and consultation with the IDL as contemplated
NORTHERN LIGHT INC.'S REPLY TO COMMENTS: 1

by the WSCA.The approval standard established by the WSCA is not whether a WMP incorporates
every available analytical methodology or evolving best practice, but whether it satisfies the
statutory requirements enacted by the Legislature and the Commission's existing Guidelines.
Following a thorough review, Staff concluded that NLI's WMP should be approved.
Specifically, Staff concluded the WMP meets the requirements of the WSCA and the Commission's
Guidelines, is consistent with public health, safety, and welfare, is feasible, provides
implementation costs, and adequately minimizes wildfire risk. Staff therefore recommends
approval.
The comments filed in this proceeding reflect the continuing development of wildfire
mitigation planning under the WSCA. As utilities, Staff, and technical experts gain additional
experience implementing the Act, future annual WMPs will naturally continue to evolve through
additional operational experience, technological advances, and refinements in wildfire science.
The Commission's review of multiple WMP filings demonstrates that this iterative process is
functioning as the Legislature intended.
The Commission's responsibility in this proceeding, however, is to determine whether
NLI's 2026 WMP satisfies the requirements presently established by the WSCA and the
Commission's Wildfire Mitigation Plan Guidelines. Staff concluded that it does. The record
supports that conclusion.
A.Wildfire Risk Assessment
Staff recommends that future WMP filings contain additional narrative describing the
Company's modeling methodology and supporting datasets. While IDL believes additional
analytical inputs should be incorporated before approval, Staff considered those technical concerns
NORTHERN LIGHT INC.'S REPLY TO COMMENTS: 2

during its review and nevertheless concluded that the current WMP satisfies the WSCA and
recommended approval.
NLI appreciates these recommendations.Wildfire risk assessment is an evolving discipline
that continues to benefit from additional data sources, analytical techniques, operational
experience, and collaboration among utilities, regulators, and wildfire professionals. NLI expects
that future annual WMP updates will continue to reflect that evolution.
At the same time, neither the WSCA nor the Commission's existing Guidelines prescribe
a particular wildfire risk model, require a specific analytical methodology, or mandate the use of
any particular dataset. Rather, the statutory framework requires electric corporations to identify
wildfire risks within their systems and develop reasonable measures to mitigate those risks.
Accordingly, the approval determination turns on whether the submitted WMP satisfies those
statutory requirements, and not whether additional analytical approaches may be developed in
future annual WMP updates. After reviewing the WMP, conducting discovery, consulting with
IDL, and evaluating the information developed during this proceeding, Staff concluded that NLI's
methodology satisfies the statutory requirements and recommended approval.
NLI welcomes continued dialogue on wildfire risk assessment as the annual review process
established by the WSCA matures. The existence of additional approaches that may further refine
future risk assessments, however, does not establish that the current WMP fails to satisfy the
applicable approval standard.
B. Mitigation Planning, Cost Information, and Project Reporting
Staff recommends that future WMP filings include additional project-level information
regarding mitigation activities, implementation costs, funding sources, and project-specific
reporting. NLI appreciates these recommendations.
NORTHERN LIGHT INC.'S REPLY TO COMMENTS: 3

During discovery, NLI promptly provided the additional information requested by Staff
regarding project descriptions, grant funding, implementation activities, and related matters. That
information enabled Staff to complete its review and conclude that the WMP satisfies the WSCA
requirements and should be approved.
NLI recognizes that incorporating additional portions of this information directly into
future annual WMP filings may facilitate Commission review. As implementation of the WMP
continues and additional historical information becomes available, future annual filings are
expected to include progressively more detailed operational information regarding mitigation
activities, project implementation, expenditures, and available grant funding.
These recommendations concern the level of detail that may assist the Commission's future
review. They do not alter Staff's conclusion that the current WMP satisfies the statutory
requirements for approval.
C. Performance Metrics and Future Reporting
Staff recommends that future WMP filings include additional performance metrics,
historical trend information, and enhanced reporting regarding program effectiveness. NLI
appreciates these recommendations. Because this filing represents NLI's initial WMP submitted
to the Commission for review under the WSCA, the amount of historical implementation data
available for inclusion is necessarily limited.
As additional years of implementation experience are accumulated, future annual WMP
filings will naturally contain more robust historical information, trend analysis, and performance
reporting. NLI agrees that such information may further assist the Commission's future review,
while recognizing that the current record already supports Staff's conclusion that the WMP
satisfies the applicable statutory and regulatory requirements.
NORTHERN LIGHT INC.'S REPLY TO COMMENTS: 4

D.Vegetation Management and Coordination
Staff recognizes the importance of vegetation management as a principal component of
wildfire mitigation. As such, Staff recommends additional discussion concerning vegetation
management in future filings and notes IDL's technical recommendations in this area. NLI
appreciates those observations. Vegetation management practices continue to evolve as additional
operational experience is gained and industry practices develop. NLI expects to continue
evaluating technical guidance, operational experience, and evolving industry practices as it
prepares future annual WMP updates.
Similarly, NLI appreciates the recommendations concerning additional discussion of
coordination with local entities, including Community Wildfire Protection Plans. NLI values its
ongoing relationships with local governments, emergency responders, and wildfire professionals
throughout its service territory and will continue to evaluate opportunities to further describe those
efforts in future WMP filings.
These recommendations identify opportunities to provide additional information regarding
existing and evolving operational practices. They do not diminish Staff's conclusion that NLI's
vegetation management program satisfies the requirements of the current statutory framework.
E. Timber Management and Related Operational Practices
Staff recommends additional discussion of procedures applicable to timber removal and
references similar observations raised during the review process. NLI appreciates Staff's
recommendation that additional discussion of existing operational practices may be beneficial in
future annual filings.The annual review process established by the WSCA provides an opportunity
for NLI to include additional discussion of these practices to assist future Commission review.
NORTHERN LIGHT INC.'S REPLY TO COMMENTS: 5

III. CONCLUSION
NLI appreciates the thoughtful participation of Staff throughout this proceeding. Staff
conducted an extensive review of the WMP, engaged in discovery, evaluated the information
developed during this proceeding, and concluded that NLI's 2026 WMP satisfies the requirements
of the WSCA,the Commission's Wildfire Mitigation Plan Guidelines, and applicable Commission
Orders. Staff therefore recommends approval. The record supports Staff's recommendation of
approval for NLI's 2025 Wildfire Mitigation Plan. The record supports Staff's recommendation.
Accordingly,NLI respectfully requests that the Commission approve its 2026 Wildfire Mitigation
Plan.
DATED this Pt day of July, 2026.
JAMES, VERNON& WEEKS, P.A.
lsl.Sudan P. 2Uce&
SUSAN P. WEEKS
Attorneys for Respondent
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing was served by email on the
following persons this 1st day of July, 2026:
Idaho Public Utility Commission Staff
Erika K. Melanson, Deputy Attorney General
Kelsea E. Ross, Deputy Attorney General
EMAIL: [e-mail]
l s/S6d " ;V. Vice&
SUSAN P. WEEKS
NORTHERN LIGHT INC.'S REPLY TO COMMENTS: 6