20260709Compliance Filing.pdf

AN
Kootenai Electric RECEIVED
� COOPERATIVE July 09, 2026
IDAHO PUBLIC
UTILITIES COMMISSION
July 9, 2026
Via Email Only
Secretary Monica Barrios-Sanchez
Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd. Building 8, Suite 201-A
Boise, ID 83714
Email: [e-mail]
Re: Kootenai Electric Cooperative, Inc.'s Order No. 37081 Compliance Filing
Case No. C07-E-25-01
Dear Secretary Barrios-Sanchez:
On June 29, 2026, the Idaho Public Utilities Commission("Commission") issued Order No. 37081
("June 29 Order") conditionally approving Kootenai Electric Cooperative, Inc.'s ("KEC") 2026-2028 Wildfire
Mitigation Plan ("Plan"). KEC is required to file a compliance filing within fourteen(14) days of the June 29
Order. Pursuant to the June 29 Order, KEC submits the attached First Amended 2026-2028 Wildfire Mitigation
Plan("Amended Plan"). A redline version of the Amended Plan showing the changes to KEC's Plan is
attached for information only.
The Amended Plan incorporates the 2026 WMP Update Materials that the Commission requires KEC to
provide in its compliance filing. Specifically,the Commission requests that KEC incorporate in its wildfire
mitigation plan information consistent with a number of KEC's responses to Staff s discovery requests,
including responses to:
• Staff First Production Request at No. 1, including Item 1-Exhibit A(June 29 Order at 12, items 1, iii,vii);
• Staffs Second Production Request at Nos. 15 and 16(id. at item ii);
• Staffs First Production Request at No. 11 (id. at item iv);
• Staff First Production Request at No.4(id. at item viii); and
• Staff First Production Request at No. 14(id. at Item ix).
KEC is also required to provide (a)the Heightened Wildfire Risk Map overlayed with KEC's service territory
boundaries, and (b) a narrative explanation on how KEC divides its territory and how it prioritizes wildfire-
related projects in each section, consistent with the explanation KEC provided in a meeting with Staff. Id.
(items v and vi).
9014 W. Lancaster Rd. I Rathdrum, ID 83858
TEL [phone] TOLL FREE 800-240-0459 1 FAX [phone] 911309
EMAIL [e-mail] I WEB kec.cOm

Secretary Monica Barrios-Sanchez
Commission Secretary
Idaho Public Utilities Commission
KEC's Order No.37081 Compliance Filing
July 9,2026
Page 2 of 2
To ensure that the information that KEC provides is consistent with the information provided in
response to Staff s discovery requests, KEC incorporates those responses in full in its Amended Plan as follows:
• KEC's response to Staff s First Production Request at No. 1, including Item 1-Exhibit A, is attached to,
and incorporated into,KEC's 2026-2028 Construction Work Implementation Plan as Exhibit 1 to
Appendix B of KEC's Amended Plan;
• KEC's response to Staff s Second Production Request Nos. 15 and 16 are attached to,and incorporated
into,KEC's 2026-2028 Construction Work Implementation Plan as Exhibit 3 to Appendix B of KEC's
Amended Plan;
• KEC's response to Staff s First Production Request No. 11 is attached to, and incorporated into,KEC's
2026-2028 Construction Work Implementation Plan as Exhibit 2 to Appendix B of KEC's Amended
Plan;
• KEC's response to Staff s First Production Request No.4 is attached to, and incorporated into,KEC's
Vegetation Management Plan as Exhibit I to Appendix A of KEC's Amended Plan; and
• KEC's response to Staff s First Production Request No. 14 is attached to, and incorporated into,KEC's
Amended Plan as Appendix G(Amended Plan at 15 n.10).
KEC has also incorporated into Section 2.1 of its Amended Plan a Heightened Wildfire Risk Map overlayed
with KEC's service territory boundaries (Amended Plan at 6 and Appendix F). Finally, KEC has added a
narrative explanation in Section 2.1 of its Amended Plan describing how KEC divides its territory and how it
prioritizes wildfire-related projects, consistent with the explanation KEC provided in a meeting with Staff
(Amended Plan at 6).
KEC submits the attached Amended Plan as the compliance filing required by the June 29 Order and
respectfully requests that the Commission issue an order approving its Amended Plan. Please let me know if
you have any questions or need any additional information regarding anything contained in this compliance
filing.
Sincerely,
ls/Michael G. Andrea
Michael G. Andrea
General Counsel
Attachments

® Kootenai Electric
COOPERATIVE
02 -
First Amended 2026-2028
WILDFIRE MITIGATION PLAN
July 9, 2026
9014 W.Lancaster Road I Rathdrum,ID 83858 © Q
TEL [phone] TOLL FREE 800-240-0459 1 FAX [phone]
EMAIL [e-mail] I WEB kec.corn

Table of Contents:
1. Introduction...........................................................................................................................................1
1.1 Purpose of the Wildfire Mitigation Plan ......................................................................................2
1.2 Definitions....................................................................................................................................2
2. Geographical Area Served by KEC and Areas that May Be Subject to Heightened Risk of Wildfire......3
2.1 Identification of Geographical Areas that May be Subject to Heightened Risk of Wildfire.........5
3. Preventive Actions and Programs to Reduce Risk of Wildfire...............................................................7
3.1 Grid Modernization......................................................................................................................7
3.2 Methods of Line Design for New, Planned, and Existing Lines to Mitigate Fire Risk...................7
3.3 Vegetation Management.............................................................................................................7
3.4 Development of Standards, Procedures, and Schedules for Inspection of KEC's Assets,
Infrastructure, and Facilities Within Heightened Fire Risk Areas..............................................................8
4. Fire Season Operational Guide..............................................................................................................8
4.1 Daily Situational Awareness.........................................................................................................8
4.2 Public Safety Power Shutoff(PSPS) Procedure..........................................................................12
4.3 Operational Action Index with Fire Danger Linkage ..................................................................13
4.3.1 Risk Monitoring and Forecasting...........................................................................................14
4.3.2 Risk Assessment and Initial Decision-Making........................................................................15
4.3.3 Notification & Coordination (Pre-Activation Phase: 72-24 Hours Out) ................................15
4.3.4 Final Decision and Activation (24-0 Hours Out)....................................................................16
4.3.5 Monitoring During a PSPS......................................................................................................17
4.3.6 Restoration Process After a PSPS...........................................................................................17
4.3.7 Post-Event Review..................................................................................................................17
5. Outreach and Communication............................................................................................................17
5.1 KEC Internal Processes to Guide Wildfire-Related Communication ..........................................17
5.2 Coordination with Federal,State,Tribal, and Local Agencies....................................................18
5.3 Member Communications.........................................................................................................18

Table of Figures:
Figure 1: Service Area Across Counties ........................................................................................................4
Figure 2: Service Area Within the State of Idaho..........................................................................................5
Figure3 Heightened Risk Areas.....................................................................................................................6
Figure 4 Tempest System Daily Fire Risk Example (for Illustrative Purposes Only).......................................9
Figure 5 Daily Situational Awareness Table.................................................................................................10
Figure6 DSAT Mitigation Levels ..................................................................................................................11
Figure 7 Fire Danger/Operational Index......................................................................................................13
Figure 8 Fire Season PSPS Decision Making Process/Operational Table.....................................................14
Figure 9 National Weather Service Red Flag Weather Matrix, Eastern Washington and North Idaho.......16
Appendices:
Appendix A:Vegetation Management Plan ................................................................................................21
Appendix A-1:Vegetation Management Implementation Plan ..................................................................21
Appendix B: 2026-2028 Construction Work Implementation Plan.............................................................26
Appendix C: 2026-2028 System Inspection Implementation Plan..............................................................27
AppendixD: Resolution # 10-25..................................................................................................................28
Appendix E: Compliance Matrix .................................................................................................................28
Appendix F: Heightened Wildfire Risk Map Overlayed with Boundaries for Areas Served by KEC
Appendix G: KEC's Response to Commission Staff's First Product Request, Request No. 14
KOOTENAI ELECTRIC COOPERATIVE INC.WILDFIRE MITIGATION PLAN-PAGE 1 DECEMBER 31,2025

1. Introduction
Kootenai Electric Cooperative, Inc. (KEC), founded in 1938, is the largest of ten not-for-profit, member-
owned cooperative utilities in Idaho in terms of load and total customers served. With its main office in
Rathdrum, Idaho, KEC provides electric utility service to its members primarily in Kootenai County. It also
serves portions of Bonner and Benewah counties in Idaho, and Spokane County in Washington. KEC's
service territory is quasi-urban in nature with over half of its power lines being underground. While the
largest cooperative in the state in terms of load and customers served, other cooperatives are larger in
terms of miles of lines. KEC's mission is to provide its members with exceptional service and dependable
power at competitive rates.
1.1 Purpose of the Wildfire Mitigation Plan
The primary objective of KEC's Wildfire Mitigation Plan ("Plan") is to provide direction to staff with
regard to (i)the design, inspection, operation and maintenance of KEC's electrical system to mitigate
wildfire risk; (ii) coordination with federal, state, tribal, and local officials and agencies on wildfire
preparedness and emergency response plans; and (iii) outreach and public awareness efforts to be used
before, during, and after wildfire season to identify and inform the public of relevant wildfire risks and to
notify the public of wildfire-related outages. KEC's Plan utilizes a three-year planning horizon.
Specifically, KEC's Plan includes a rolling three-year Vegetation Management Implementation Plan,
Construction Work Implementation Plan, and System Inspection Implementation Plan that, respectively,
forecast the vegetation management, construction, and system inspection work for the next three
calendar years.
In March 2025,the State of Idaho enacted the Wildfire Standard of Care Act, Idaho Code§§ 61-1801 to
61-1808 (Act). Among other things, the Act affords electric cooperatives, like KEC, the ability to adopt
and file a wildfire mitigation plan with the Idaho Public Utilities Commission ("Commission") for review
and approval. KEC's Plan is designed to comply with the requirements of the Act.
Effective Date: Upon acceptance by the KEC board, KEC will take steps to implement this Plan and this
Plan shall remain in effect until such time as this Plan is superseded by a Commission-approved wildfire
mitigation plan or is superseded or rescinded by board action.
1.2 Definitions
Below are definitions of some frequently used terms.
Act:The Wildfire Standard of Care Act, Idaho Code §§ 61-1801 to 61-1808, as such Act may be
amended or superseded.
Commission:The Idaho Public Utilities Commission.
Construction Work Implementation Plan (CWIP): KEC's three-year rolling Construction Work
Implementation Plan referred to in Section 3.1 and attached as Appendix B to this Plan.
Construction Work Plan: KEC's Construction Work Plan referred to in Section 3.1 of this Plan.
Energy Release Component(ERQ The Energy Release Component is a number related to the
available energy(BTU) per unit area (square foot)within the flaming front at the head of a fire.
Daily variations in ERC are due to changes in moisture content of the various fuels present, both
live and dead, or Fire Potential Index model to assess local wildfire risks.
KOOTENAI ELECTRIC COOPERATIVE INC.WILDFIRE MITIGATION PLAN-PAGE 2 DECEMBER 31,2025

Heightened Risk Areas: Heightened Risk Areas are those areas identified in Section 2 of this
Plan that KEC considers may be subject to heightened risk of wildfire at the time this Plan is
finalized and may change due to changes in circumstances, including changes in weather.
Hot Line Tag:A setting in a recloser control that,when enabled, opens the recloser without
intentional delay when an overcurrent situation on the power line is detected by the control.
Incident Command Team (ICT):The Incident Command Team (ICT) is a key group of KEC staff
responsible for responding to the emergency and restoring service to KEC's members.
Non-Reclose: A setting in a recloser control that,when enabled, opens the recloser and prevents
the recloser from automatically closing, attempting to re-energize or restore power on the
power line.
OEM: Kootenai County Office of Emergency Management.
Particularly Dangerous Situations (PDS) Red Flag Warning: Issued by the National Weather
Service, indicating critically dangerous fire weather including high or gusty winds, high
temperatures, and low humidity.
Plan: This Wildfire Mitigation Plan.
Public Safety Power Shutoff(PSPS): A temporary power outage initiated by an electric utility to
reduce the risk of wildfires during extreme fire risk.
Recloser: A recloser is an automatic, high-voltage electric switch which de-energizes the
affected portion of the power system when a fault, such as a tree falling into an electric power
line, occurs.
Red Flag Warning: A Red Flag warning is issued by the National Weather Service,generally
indicating critical fire weather with sustained surface winds exceeding a 10-minute average of 15
mph combined with relative humidity(RH) less than 25%.
Supervisory Control and Data Acquisition (SCADA): A system combining hardware and
software elements to allow electrical utilities to control and monitor power system devices
remotely.
Vegetation Management Implementation Plan (VMIP): KEC's Vegetation Management
Implementation Plan referred to in Section 3.3 and attached as Appendix A-1 to this Plan.
Vegetation Management Plan (VMP): KEC's Vegetation Management Plan referred to in Section
3.3 and attached as Appendix A to this Plan.
2. Geographical Area Served by KEC and Areas that May Be Subject to Heightened Risk of
Wildfire
KEC serves approximately 38,000 meters across three counties in North Idaho and Eastern Washington.
To provide electric service to its members, KEC owns and operates approximately 940 line-miles of
overhead electric line and 1,500 line-miles of underground electric line. Figure 1 illustrates the areas that
are served by KEC in these four counties'and Figure 2 illustrates the general area that KEC serves within
the State of Idaho.
'Idaho does not have defined geographical service areas. The area shown in Figure 1 generally depicts the area
where KEC has infrastructure to serve its members;however, other electric utilities also serve their customers
within that same general area.
KOOTENAI ELECTRIC COOPERATIVE INC.WILDFIRE MITIGATION PLAN-PAGE 3 DECEMBER 31,2025

Kootenai Electric Cooperative Service Terfitga
Bonner
Countyt. '�
d
1"
rs r ♦; O
Spokane .. .
County
Kootenai
County --
doe
l'o­ —
Benewah{
.
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E1 tC Sa�rcss Esn USGS td'JAd fiw�cas sn.Gar no
• R1ye _ U9G5:NPti
Figure 1: Service Area Across Counties
KOOTENAI ELECTRIC COOPERATIVE INC.WILDFIRE MITIGATION PLAN-PAGE 4 DECEMBER 31,2025

Kootenai Electric Cooperative Service Territo
Bonner
••County
Spokane
County
Kootenai
County
Bejiewah
Couory r. ty;s n<u a
Figure 2:Service Area Within the State of Idaho
2.1 Identification of Geographical Areas that May be Subject to Heightened Risk of Wildfire
KEC uses a combination of resources and data to determine specific geographical areas that are
considered to have a heightened risk of wildfire. First, as shown in Figure 3, KEC utilizes data from
Wildfire Risk to Communities? This data rates the areas from very low to very high, based on techniques
developed to create various simulations factoring in weather, topography, ignitions and vegetation.This
data is then overlayed with proprietary vegetation management software that produces further insight
into how those areas overlap within the KEC service area and infrastructure.This allows KEC to better
understand how the identified wildfire risk zones align with vegetation encroachments and hazard trees
and develop vegetation management goals to prioritize heightened risk zones. Areas with denser
z Wildfire Risk to Communities:Spatial datasets of landscape-wide wildfire risk components for the United States.
2nd Edition. Fort Collins,CO: Forest Service Research Data Archive available at: https://doi.org/10.2737/RDS-
2020-0016-2.
KOOTENAI ELECTRIC COOPERATIVE INC.WILDFIRE MITIGATION PLAN-PAGE 5 DECEMBER 31,2025

vegetation are denoted on Figure 3 as"Medium;' "High," and "Very High" Wildfire Risk Zones, which are
areas that KEC considers may be subject to a heightened risk of wildfire (Heightened Risk Areas). KEC
uses the information depicted in Figure 3 to prioritize vegetation management practices and other work
in Heightened Risk Areas.
Athol
t�
a
Hayden
Post falls ,� � A,-1 "
Coeur d'AJe w
y�
,. +y A J
y ;
° Wildfire risk zones 0
Plummer ,� ' ��,_ ■ ■
Figure 3 Heightened Risk Areas
A Heightened Wildfire Risk Map overlayed with the boundaries of the areas that KEC serves is attached
hereto as Appendix F. Order No. 37081 at 12 (item v).
As indicated in Figure 3 above,virtually all of the areas served by KEC are medium, high, or very high
wildfire risk zones and therefore, as noted above, are considered Heightened Risk Areas. KEC prioritizes
capital projects, including projects that serve to mitigate the risk of wildfire, based on need considering
factors such as reliability, expansion to serve KEC's members, and the need to replace aging
infrastructure. Order No. 37081 at 12 (item vi).
KOOTENAI ELECTRIC COOPERATIVE INC.WILDFIRE MITIGATION PLAN-PAGE 6 DECEMBER 31,2025

3. Preventive Actions and Programs to Reduce Risk of Wildfire
3.1 Grid Modernization
KEC has developed its 2025-2029 Construction Work Plan Wildfire risk zones A
(Construction Work Plan)to modernize its electric system. The
Construction Work Plan includes reasonably practical methods
for new, planned, and existing lines to, among other things,
mitigate fire risk. The Construction Work Plan, is a five-year plan that includes projects to ensure that
power system has the capacity to meet the growing demands of the members served, and to modernize
the grid by replacing end of life equipment, enhancing reliability, and mitigating fire risk. Projects
included in the Construction Work Plan include:
• Replacing end of life oil circuit reclosers(OCR)and other strategically located reclosers with solid
dielectric,vacuum interrupted reclosers equipped with solid-state controls and advanced
protection schemes;
• Installing new solid dielectric,vacuum interrupted reclosers on KEC feeders originating from non-
KEC owned substations to provide advanced protection schemes;
• Installing, in strategic locations, solid dielectric insulated pad-mounted switchgear equipped with
operators and solid-state controls connected to the SCADA system to provide remote indication,
monitoring, and control; and
• Installing new protective feeder relays equipped with Arc Sense Technology(AST) in KEC owned
substations for high-impedance fault detection on distribution feeders.
The Construction Work Plan also includes finalizing the integration of a new SCADA system with an
existing Geographic Information System (GIS).This integration will set up the framework required to
deploy SCADA to feeder-level devices and perform Advanced Distribution Management System (ADMS)
functions. The additional ADMS functions include, among other things,the ability to remotely control
feeder level reclosers outside of substations, remotely adjust protection settings, and automatically
detect and isolate sections of the power system through Fault Location Isolation and System Restoration
(FLISR).
To implement its Construction Work Plan, each calendar year, KEC develops a Construction Work
Implementation Plan ("CWIP"). The CWIP provides a forecast of the work in the Construction Work Plan
that KEC intends to perform in each of the next three calendar years. KEC's CWIP is incorporated into
this Plan and is attached hereto as Appendix B.
3.2 Methods of Line Design for New, Planned, and Existing Lines to Mitigate Fire Risk
In addition to modernization discussed in Section 3.1 above,the Construction Work Plan includes steps
to harden KEC's electrical system with upgrades and design changes.These designs stem from
engineering experience and the adoption of emerging technologies. The Construction Work Plan
includes:
• The use of ductile iron poles for fire-resiliency construction of overhead distribution lines;
• The undergrounding of overhead distribution lines to improve reliability and eliminate the
impact of wind and tree related outages,which provides effective wildfire mitigation strategies;
and
• The replacement of traditional expulsion fuses with current limiting fuses,when possible, in
strategic high-risk wildfire zones to reduce the energy and potential ignition source for wildfires.
3.3 Vegetation Management
KOOTENAI ELECTRIC COOPERATIVE INC.WILDFIRE MITIGATION PLAN-PAGE 7 DECEMBER 31,2025

KEC has adopted a Vegetation Management Plan (VMP) to identify and control or eliminate vegetation
that threatens the integrity, reliability,or safety of the electrical facilities that are part of KEC's electrical
system. The VMP calls for the assessment of KEC's service territory every two (2)years and provides
wildfire risk analysis, hazard tree identification,tree segmentation, height and health analysis, 3D
vegetation risk scoring, and recommended work. Pursuant to the VMP,vegetation management is
performed in accordance with applicable federal, state, or local laws, regulations, or ordinances. KEC's
VMP is incorporated herein and is attached hereto as Appendix A.
To implement its VMP, each year KEC prepares a Vegetation Management Implementation Plan (VMIP).
The VMIP that is developed each year is a three-year rolling plan. That is, the VMIP that is developed in
each calendar year sets out the strategy, resources, and schedule for vegetation management to be
performed in the next calendar year as well as a projected schedule for the following two calendar years.
Each VMIP establishes the specific sections of KEC's electrical system (identified by specific feeders) that
are targeted for vegetation management in each calendar year. The VMIP is developed using
information available to KEC at the time the Implementation Plan is prepared. KEC will monitor
conditions and needs and may modify the implementation of its VMP in response to changes in
circumstances to the extent KEC deems necessary to provide for the safe, efficient, and reliable
distribution of electric power to KEC's members. KEC's 2026-2028 VMIP is attached hereto as Appendix
A-1.
3.4 Development of Standards, Procedures,and Schedules for Inspection of KEC's Assets,
Infrastructure,and Facilities Within Heightened Fire Risk Areas
In addition to the assessments performed in accordance with KEC's VMP (discussed in Section 3.3
above), KEC also performs inspections of its system in accordance with its System Inspection
Implementation Plan,which is attached hereto as Appendix C.
All inspection data is electronically recorded and tied to specific map locations. Recording this data
provides a centralized and accessible record of asset condition over time.This electronic system supports
maintenance and tracking of repairs.
KEC follows a time-based inspection cycle for system assets:
• Overhead and Underground Line Assets: Inspected on a 12-year cycle.
• Switchgear: Inspected on a 1-to 4-year cycle depending on asset type and location.
• Substations: Inspected monthly.
All defects identified during inspections are documented and routed to Operations for timely repair or
replacement.
4. Fire Season Operational Guide
4.1 Daily Situational Awareness
During periods when the National Fire Danager Rating is elevated to a level of High or greater(as defined
in Figure 7), daily morning briefings will be held (on normally scheduled workdays) by the Operations
Superintendents with the line crews and Operations staff to review the daily fire risk in the areas served
by KEC as indicated by the Tempest system. An example of the information provided by the Tempest
system is seen below in Figure 4.
KOOTENAI ELECTRIC COOPERATIVE INC.WILDFIRE MITIGATION PLAN-PAGE 8 DECEMBER 31,2025

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Figure 4 Tempest System Daily Fire Risk Example (for Illustrative Purposes Only)
Based on the Tempest information, Operations Superintendents will review the Daily Situational
Awareness Tool (Figure 5) and its associated mitigation strategies(Figure 6), below.
KOOTENAI ELECTRIC COOPERATIVE INC.WILDFIRE MITIGATION PLAN-PAGE 9 DECEMBER 31,2025

TEMPEST DAILY SITUATIONAL AWARENESS TOOL(DSAT)
KEC Operating Mitigation Condition'
General Activity Specific Description Normal Elevated
Vehicle travel on &off road. With A A A
no vehicle/vegetation contact
Vehicle
Operations Travel off-road or on unmaintained A Special
road with vehicle/vegetation A No parking Circumstances/Stage 2
contact. on dry grass Fire Restrictions
C
Heavy Dozers, graders, skid steers, Water Trailer or Water
Equipment Use/ trenchers, etc. All road A B Truck
Ground maintenance, water bars, pole hole Special
Disturbing Work drilling, etc. Includes all blasting. Circumstances/Stage 2
Fire Restrictions
C
Equipment maintenance or
Water Trailer or Water
Construction and replacement. (Cross arms, pole Truck
maintenance of replacement, reconductor, A B Special
electric facilities substation,transformers, relays, Circumstances/Stage 2
meter maint/replacement, etc.)
Fire Restrictions
C
Vegetation
Vegetation clearing. A B Special
Management
Circumstances/Stage 2
Fire Restrictions
C
Cutting, All types of spark-producing
Grinding, A B Special
Welding cutting, grinding, or welding work.
g Circumstances/Stage 2
Fire Restrictions
Internal
Use of equipment with combustion B
Combustion engines not covered elsewhere. A B
Engine Use Includes ATV, chainsaw, generator, Special
compressor, etc. Circumstances/Stage 2
Fire Restrictions
Figure 5 Daily Situational Awareness Table
'The Operating Mitigation Condition is established by the Tempest DSAT.
KOOTENAI ELECTRIC COOPERATIVE INC.WILDFIRE MITIGATION PLAN-PAGE 10 DECEMBER 31,2025

MITIGATION LEVELS FOR DSAT
Mitigation Level A Mitigation Level B Mitigation Level C Special Circumstances/
Stage 2 Fire Restrictions
Apply
1. Documented Safety 1. Work will stop until a 1. Work will stop until a Essential work only.
Tailboard prior to new Safety Tailboard is new Safety Tailboard Essential work is work
performing any work. completed any time fire is completed anytime that is approved by a
■ At minimum. one fire risk increases. fire risk increases. supervisor as essential
suppression hand tool 2. At minimum,two fire 2. At a minimum, one fire work. Except for
shall be within 100 suppression hand tools suppression hand-tool essential work that
feet of job site or shall be within 25 feet per crew member shall cannot be deferred,all
immediately available of job site for a crew be present at job site. other work will be
deferred to days with
when the work is not with multiple persons. 3. At a minimum,two KEC less critical fire risk.
stationary. 3. At a minimum, one KEC approved fire
2. Designated person to approved fire extinguishers shall be 1. Mitigations will be
call 911 in the event of extinguisher shall be available at the job site determined b aasis.
an ignition. available at the job site and every crew vehicle case-by-case b
and every crew vehicle shall have a filled 5- Fire risk mitigation
shall have a filled 5- gallon backpack water practices may not be
gallon backpack water pump at the job site or possible for some
pump within 25 feet of readily accessible on work activities,and
job site or immediately work that is not their continuance
available when work is stationary, i.e., access should be restricted.
not stationary. road maintenance.
■ Documented Fire 4. Designate a working
Watch person(s) as Fire Watch.
appropriate on Safety Check all work sites for
Tailboard. hot spots or
4. Designated person to smoldering embers for
call 911 in the event of 45 minutes after work
an ignition. activities have ceased.
■ Designated person to
call 911 in the event of
an ignition.
Figure 6 DSAT Mitigation Levels
KOOTENAI ELECTRIC COOPERATIVE INC.WILDFIRE MITIGATION PLAN-PAGE 11 DECEMBER 31,2025

Fire Restriction Stages:
KEC will comply with all fire restrictions in accordance with applicable law, including Idaho Code §§ 38-115, 38-
121, Idaho Admin. Code 20.04.01.080. Stage 1 and Stage 2 Fire Restrictions are posted on Idaho Department of
Lands' website and are available at: www.idl.gov/fire-management/fire-restrictions-finder.
4.2 Public Safety Power Shutoff(PSPS) Procedure
A Public Safety Power Shutoff is a temporary power outage initiated to reduce the risk of wildfires during extreme
fire risk.The two charts below(Figures 7 and 8) illustrate the PSPS decision making process and the operational
actions to be taken in each situation.4
4 In addition to decisions to initiate a PSPS in accordance with this Plan, KEC will coordinate with applicable public agencies to
accommodate,where appropriate, requests from such public agencies to energize or deenergize KEC' s electrical system for
public safety.
KOOTENAI ELECTRIC COOPERATIVE INC.WILDFIRE MITIGATION PLAN-PAGE 12 DECEMBER 31,2025

4.3 Operational Action Index with Fire Danger Linkage
FIRE DANGER/OPERATIONAL INDEX
National Fire Danger Very High w/Red
Ratings High Very High Flag Warning
Weather and fuel Weather and fuel Potential for large
conditions indicate conditions indicate Red Flag Warning
Fires spread rapidly fires exists. Fires
Weather and fuel some potential for some potential for and fires spread
Fire Danger/ and show erratic spread rapidly.
indicators show the fire occurrence. fire occurrence. rapidly and show
Operational Index behavior. Extreme fire
probability of fire Expect predictable Expect predictable erratic behavior.
Definition Dangerous burning behavior is
occurrence is low. fire behavior with fire behavior with Dangerous burning
moderate rate of moderate rate of conditions exist. conditions exist. probable.Critical
conditions exist.
spread. spread.
Substation Circuit Automatic Reclose
Breaker Settings Automatic Reclose Non-Reclose on Red Non-Reclose Non-reclose Hot Line Tag Hot Line Tag
Flag Warning days
Normal until fault
Line Crew Patrol Normal until fault condition identified. All Outaged Lines Between Non-Reclose All Outaged Lines
Following Circuit Outage condition identified. On Red Flag Set Devices
Warning days all
outaged lines.
Non-Reclose
(to be Non-Reclose
Line Reclosers in accomplished as Non-Reclose Non-Reclose (potential for PSPS
Predetermined Hazard Automatic Reclose Automatic Reclose soon as reasonably (potential for PSPS at select locations
Areas at select locations) during Red Flag
practical after the
change in NFDRS). Warning).
No
Increased Number of (with the exception of Red Flag
No Yes Yes Yes Yes
'On Call'Personnel
Warning days)
Pre-positioning of
Personnel During High
Wind or Fire Weather No No Yes
Events
Figure 7 Fire Danger/Operational Index
s For purposes of this Plan,the National Fire Danger Rating( "NFDR" )shall be the applicable National Fire Danger Rating provided by the Coeur d' Alene
Interagency Dispatch Center posted at: https://gacc.nifc.gov/nrcc/dc/idcdc/.
KOOTENAI ELECTRIC COOPERATIVE INC.WILDFIRE MITIGATION PLAN-PAGE 13 DECEMBER 31,202S

PSPS Decision Making Process during Fire Season/Operational Table
Level NFDR Conditions Description Utility/Public Actions
ffimm.. -
0 � No elevated fire risk. Norma operations. No action
0 M. Conditio needed.
Conditions are drying, mild
1 Moderate Elevated sustained winds forecasted. Situational awareness.
Fire weather being Internal utility monitoring.
monitored.'
High winds+ low humidity
2 High Watch forecast.' Fire weather is Notify agencies. Early public
likely. awareness messaging.
Weather event8 likely. PSPS
3 Very High Warning/Advisory under consideration in high- Public alerts.
risk areas.
Very High PSPS Event PSPS highly likely in next 24— Final prep. Staging crews.
4 w/Red Flag Likely 48 hours if weather persists. Community readiness.
Warning
PSPS may be activated due Active outage.
• Communication + restoration
to imminent wildfire risk.
planning.
Figure 8 Fire Season PSPS Decision Making Process/Operational Table'
4.3.1 Risk Monitoring and Forecasting
During periods where conditions are at Level 0 or Level 1 as set forth in Figure 8,Operations will
monitor:
• Weather forecasts and information, including:
o National Weather Service Regional Weather at:
https://www.weather.gov/otx/firedashboard.
o Tempest One weather stations with wind alert configuration via email and text.
o Tempest One Daily Situational Awareness Tool to determine best operational practices.
o Windy.com with Mapping Overlay to determine time and duration of wind events.
e Fire weather refers to weather conditions that create a higher risk of fire generally due to higher temperatures,
lower relative humidity, and/or high winds.
'High wind means generally sustained winds over 20 mph and/or wind gusts exceeding 30 mph. Low humidity is
generally when the relative humidity is below 20%,which creates drier fuels and increased fire potential.
8 Weather events are extreme weather conditions,such as high temperature and low humidity combined with high
winds,create or exacerbate the potential for wildfires.
9 This Figure 8 is intended to be used solely as a tool to aid the decision-making process to determine whether and
when to activate a PSPS. Decisions whether and when to activate a PSPS will be made by Incident Command
pursuant to Section 4.3.4 of this Plan.
KOOTENAI ELECTRIC COOPERATIVE INC.WILDFIRE MITIGATION PLAN-PAGE 14 DECEMBER 31,2025

• Remote sensing, weather stations, and satellite imagery to identify high-risk areas.lo
• Fuel moisture levels, including Dry Vegetation/Fuel Moisture Criticality: Dry grasses, shrubs,and
trees, based on local fuel moisture readings.Typically,when the moisture level of 1000-hour
fuels are at or below 11%, 100-hour fuels are at or below 8%and live fuels at or below 120%.
• Northern Rockies Coordination Center 1000-hour Fuel moisture graphs and the 100-hour Fuel
moisture.
• The Burning Index at : https://gacc.nifc.gov/nrcc/predictive/fuels fire-danger/fuels fire-
danger.htm.
4.3.2 Risk Assessment and Initial Decision-Making
During periods where conditions are at Level 2 or Level 3 as set forth in Figure 8,the PSPS Planning
Committee (Operations, Safety, Legal, Communications) will conduct impact analysis regarding a
potential PSPS, including analysis of:
• The number of members who may be affected, and
• Whether any critical infrastructure (hospitals, emergency services,water systems) may be
affected.
Grid Operations will also evaluate:
• Any Fire Weather Watch issued by the National Weather Service A Fire Weather Watch is issued
when there is a high potential for the development of a Red Flag Warning due to:
o Abundant lightning and dry fuels,
o Sustained surface winds exceeding 15 MPH and relative humidity(RH) less than 20% in
the valleys, RH less than 25%in the mountains,
o low RH of 15%or less, and/or
o an unusually unstable atmosphere.
• Alternatives to PSPS (e.g.,grid rerouting,temporary barriers)
• Potential duration of any PSPS and restoration times
• Whether and when to make initial recommendations to proceed to pre-activation phase (See
Section 4.3.3).
4.3.3 Notification &Coordination (Pre-Activation Phase: 72-24 Hours Out)
During periods where conditions are at Level 3 or above as set forth in Figure 8, in addition to the
activities set forth in Section 4.3.2 above, ICT will notify OEM who will notify the following, as applicable:
• Local, county, and state emergency agencies
• Tribal governments and public safety partners
• Hospitals and critical infrastructure
The Incident Command Team (ICT) will also begin public outreach, including:
• Notifying the media and public via website,text, email, automated calls, and social media and,
as applicable:
o Explaining potential PSPS zones
o Providing resources and preparation tips
10 Details about KEC's weather station network are provided in KEC's response to Commission Staff's First
Product Request, Request No. 14,which is attached hereto and incorporated herein as Appendix G. Order No.
37081 at 13 (item(ix).
KOOTENAI ELECTRIC COOPERATIVE INC.WILDFIRE MITIGATION PLAN-PAGE 15 DECEMBER 31,2025

• Contacting Kootenai County Office of Emergency Management (OEM)to coordinate the set-up
of public resource centers (if needed)
4.3.4 Final Decision and Activation (24-0 Hours Out)
During periods where conditions are at Level 4 and Level 5 as set forth in Figure 8, the Incident
Command Team (ICT)will reassess conditions in real-time, including:
• Fire Weather Watch conditions,
• Red Flag Warning: Issued by the National Weather Service 24 hours in advance, indicating critical
fire weather(high winds+ low humidity). Sustained surface winds exceeding a 10-minute
average of 15 mph combined with relative humidity less than 25%, and
• Red Flag Warning Particularly Dangerous Situation (PDS): Issued by the National Weather
Service, indicating critical fire weather(high winds+ low humidity) (See Figure 9):
o Conditions last 3+ hours, 1000-hour fuels 10%or less
o Energy Release Component(ERC) in the 90th percentile or higher(see 4.3.8 below)
o Little to no rain past 30-90 days with less than .10 inches
o Wind speeds 30 mph or greater
o Wind gusts over 40 mph
o Exception will be made when relative humidity is less than 10%.
For Eastern WA and North Idaho .
Red Flag Weather Matrix
Dry Fuels with(Low RH+Winds)for at least 2 hours
Relative unaldity wNess Record dirY I ww aeaft'60�
teas RH<3Sk
RH:80-40% RH:25-30% RH:20-25% RH:15-20% RM 10-15% RR 10%or
less
10-75 mph commer C-Sk .,. Minimum PDS Prerequisites
G>20 mph RPW RFW #:
Cionclitions last 3+hours
Ccnsider
15-20 mph btoumain Caranler R
CL G>25 mph aFw RFN 00 HR 10%or less
1 0
H -— ERCs 90th percentile or higher
v
C 20J0 mph Consder Crmsida
G>30 mph A bun�t+ain qFW riFn NfW NFw - L�to no rain pest 30-90 days(<.10')
>30 mph Consider ;tiW H-W RFW Wind speed 30 mph Or greater
c>40.,ph RFw Wind gusts>40 mph
(exception when RH less than 10%)
>30 mph laptl
G>50 mph Fes++my RH<30%
Low-Nv*al:00•eWer Low- Marg,-- '-
(2 hum1dityilue1I00ja"` C._ IHeadliM HeaJlme
0 RL .Saml
Figure 9 National Weather Service Red Flag Weather Matrix, Eastern Washington and North Idaho
• Confirm weather severity and fire risk
• Make final decision to activate PSPS and de-energize circuits.
The General Manager, or designee, will make the final decision to initiate a PSPS based on the
recommendation of the ICT.
If a PSPS is initiated,the ICT:
• Will direct the opening of devices to de-energize affected lines, and
KOOTENAI ELECTRIC COOPERATIVE INC.WILDFIRE MITIGATION PLAN-PAGE 16 DECEMBER 31,2025

• Confirm with field teams that de-energization has occurred safely.
4.3.5 Monitoring During a PSPS
During any PSPS,the ICT will take, or will direct,the following steps until restoration is complete:
• Patrol and monitor de-energized lines for safety hazards,
• Coordinate with emergency services for any incidents,
• Take reasonable steps to identify and provide on-site support for critical members, and
• Provide public regular updates, including estimated restoration times(if available).
4.3.6 Restoration Process After a PSPS
After the ICT determines that a PSPS is no longer necessary, Operations will begin the re-energization
protocol. Under the re-energization protocol, Operations will:
• Conduct line inspections,
• Clear vegetation and hazards,
• Verify system integrity and readiness, and
• Restore power.
Communications will take steps to notify customers of restoration progress.
4.3.7 Post-Event Review
As promptly as reasonably practical after a PSPS has occurred and restoration is complete,the PSPS
Review Management Team (which will include representatives from all teams involved in the PSPS event)
will conduct an internal after-action review. The internal after-action review will include a review of the
following:
• Response timeline,
• Communication effectiveness,
• System and personnel performance, and
• Public and agency feedback.
Upon completion of the internal after-action review,the PSPS Review Management Team will create an
after-action report and, if necessary, will update the PSPS process/procedures in this Plan based on
lessons learned.
5. Outreach and Communication
5.1 KEC Internal Processes to Guide Wildfire-Related Communication
KEC will adhere to established internal processes for wildfire-related communication. KEC will share
information about its Wildfire Mitigation Plan, including details on PSPS,with members,employees, the
public,the media, and other stakeholders(including federal, state, tribal, and local agencies).
KEC will,to the extent practical, communicate any anticipated or actual PSPS with any neighboring utility
that may be impacted by the PSPS. KEC anticipates that neighboring utilities will similarly share
information regarding any anticipated or actual de-energization that will impact KEC. To the extent that
KOOTENAI ELECTRIC COOPERATIVE INC.WILDFIRE MITIGATION PLAN-PAGE 17 DECEMBER 31,2025

KEC obtains information from another utility regarding any de-energization that will impact KEC, KEC will
integrate such information in its operational planning."
5.2 Coordination with Federal,State,Tribal, and Local Agencies
5.2.1 Annual Coordination Meeting
Prior to May 1 of each calendar year, KEC will schedule and host (or if a similar meeting is scheduled and
hosted by another entity, participate in) a meeting ("Annual Coordination Meeting") with, as applicable,
federal, state,tribal,and local officials and agencies to coordinate on wildfire preparedness and
emergency response plans. To the extent that KEC schedules and hosts the Annual Coordination
Meeting, KEC will invite applicable federal, state, tribal and local officials and agencies, including without
limitation, the OEM, Kootenai County Fire Chiefs, Coeur d'Alene Tribe Police Chief, and the Idaho
Department of Lands to the Annual Coordination Meeting. The Annual Coordination Meeting may be
held in person or virtually or both.
5.2.2 Communication of Changes in Operating Condition
Whenever the NFDRS rises to "High" or above (or a Red Flag Warning Day), KEC will notify OEM,the
Coeur d'Alene Tribe Polce Chief, and Idaho Department of Lands of a potential of a change in operating
condition.
5.2.3 Communications with OEM Regarding PSPS
With regard to PSPS, KEC will notify OEM as follows:
• At any time that KEC determines whether a PSPS is likely or imminent, KEC will notify OEM of
the potential of a PSPS and the potential areas on KEC's electrical system that may be
affected by a PSPS.
• When there is a PSPS, KEC will notify OEM that a PSPS has occurred,the areas on KEC's
electrical system that are impacted by the PSPS and, if available, an estimate of how long the
PSPS will be in effect.
• When the event requiring a PSPS has passed and KEC begins the restoration process, KEC will
notify OEM that it has commenced restoration and, if available, will provide an estimate of
how long it will take for KEC to restore its electrical system.
• Upon completion of the restoration process after a PSPS, KEC will notify OEM that
restoration is complete.
Upon notification from KEC, OEM will notify other state and local agencies.
5.3 Member Communications
KEC's wildfire-related communication goals are as follows:
• Educate members about KEC's approach to wildfire prevention and mitigation.
• Inform members about the current wildfire conditions and any actions that KEC may take to
mitigate wildfire risk, including any operational conditions/limitations on KEC's system and any
PSPS.
• Prepare members for PSPS or other wildfire-related outages, including reminders to update
their contact information, report outages, access updates on system conditions/outages, and
access safety/preparedness tips.
11 The only other utility in the area that is likely to impact KEC's operations is Avista Corporation.
KOOTENAI ELECTRIC COOPERATIVE INC.WILDFIRE MITIGATION PLAN-PAGE 18 DECEMBER 31,2025

Before the wildfire season begins, KEC will communicate broad messages about safety and preparedness
to KEC's membership. As weather events or system changes occur, KEC will direct more targeted
messages to members affected by the changes. Below are the communications channels used to share
wildfire and outage related messages to KEC's members:
• Powerl-ines monthly member newsletter,which is included in member billing statements (an e-
version is also sent to all member email addresses).
• KEC's website: www.kec.com.This is a source of information and education about wildfire,
safety, and outages for members. It is updated regularly.
• Social media: KEC regularly updates its Facebook and Instagram pages with timely information
and updates about outages, safety and wildfire.
• News releases are used as needed to provide information to local media outlets.
• KEC sends an annual wildfire email to all members. KEC also sends targeted emails and/or
text/SMS to members affected by outages.These methods will also be used to communicate
with members that may be affected by a fire mitigation mode adjustment or a PSPS.
Due to KEC's rate structure, members with needs or infrastructure that they deem to be critical are
expected to provide their own redundancy and/or backup to provide power in the event of de-
energization. Therefore, KEC currently does not identify any critical infrastructure and/or members. To
the extent KEC identifies any critical infrastructure and/or members in the future, KEC shall maintain a
list of such critical infrastructure and/or members and shall provide targeted communications to such
critical infrastructure and/or members via email, text/SMS, or other appropriate communication
method.
6. Cost Evaluation; Cost-Benefit Approach
The Wildfire Standard of Care Act requires wildfire mitigation plans to identify a means for mitigating
wildfire risk that reflects a reasonable balancing of mitigation costs with the resulting reduction of
wildfire risk. This includes financially prudent and reasonably practicable methods of line design for new,
planned, and existing lines to mitigate fire risk.12
In Order No. 36774, the Commission ordered that electric corporations must (i) explain how an electric
corporation's line design methods reduce the potential for wildfire ignition, including a cost evaluation,
and (ii) include a cost benefit analysis in their proposed wildfire mitigation plans that justifies the
expenditures for risk mitigation described in such wildfire mitigation plans.13 The costs incurred by KEC,
including costs incurred pursuant to its construction work plan,vegetation management plan, and
inspection plan, are incurred for multiple purposes. Those purposes include, among other things,
extending service to members, enhancing reliability, replacing outdated infrastructure, and wildfire
mitigation. It is not possible to determine the amount of each expenditure that is properly allocated to
wildfire mitigation as opposed to some other purpose. Accordingly, in evaluating any project, KEC
evaluates all of the needs and benefits associated with the project to determine whether the costs of
the project are justified.
12 Idaho Code§61-1803(3).
t3 Order No.36774 at 20.
KOOTENAI ELECTRIC COOPERATIVE INC.WILDFIRE MITIGATION PLAN-PAGE 19 DECEMBER 31,2025

It is also not possible to obtain a precise calculation of the potential costs of future wildfires.14 As noted
by Idaho Power:
publicly available analyses of recent wildfires illustrate the magnitude of potential avoided costs
when prudent mitigation reduces the likelihood or consequences of catastrophic events. For
example, in Idaho,the Moose Fire in 2022—which grew to approximately 130,000 acres— cost
approximately$ 100 million to suppress, as did the Pioneer Fire in 2016. The Charlotte Fire in
Pocatello ( 2012) destroyed 66 homes, burned approximately 1,038 acres, and estimates at the
time gauged damages at$12 million,though officials noted that timely response helped protect
approximately$472 million in property value. In eastern Washington in 2023,the Gray and
Oregon fires together destroyed over 350 homes and caused multiple fatalities. Costs and
damages associated with the 2020 Idaho wildfire season alone are estimated between $100 to
$250 million.
In more catastrophic events outside of Idaho, the costs are exponentially higher.The recovery
costs of the Maui wildfires in 2023 are expected to exceed $ 2 billion, and in California, costs and
damages associated with the 2025 Los Angeles wildfires are estimated between$28. 0 billion
and $53. 8 billion."
This data supports the conclusion that the costs of KEC's wildfire mitigation efforts set forth in this Plan
are reasonable expenditures to avoid the potential costs associated with a wildfire.
KEC is a member-owned non-profit corporation. KEC is not a public utility subject to rate regulation by
the Idaho Public Utilities Commission. Rather, KEC is governed by its board of directors. KEC's board of
directors has reviewed this Plan and its costs of implementation and has determined that the Plan (i)
includes financially prudent and reasonably practicable methods of line design for new, planned, and
existing lines to mitigate fire risk; (ii) is feasible; and (iii) reflects a reasonable balancing of mitigation
costs with the resulting reduction of wildfire risk. KEC Resolution#10-25 is attached hereto as Appendix
D.
"See Idaho Power Company's 2026 Wildfire Mitigation Plan,filed in Case No. IPC-E-25-32,at page 15
(stating: "Ultimately, Idaho Power found that obtaining a precise calculation of the potential costs of future
wildfires is not possible.").
15 Id. (internal footnotes omitted).
KOOTENAI ELECTRIC COOPERATIVE INC.WILDFIRE MITIGATION PLAN-PAGE 20 DECEMBER 31,2025

Appendix A
Vegetation Management Plan
Incorporation in Wildfire Mitigation Plan. This Vegetation Management Plan (VMP) is incorporated in,
and is part of, Kootenai Electric Cooperative, Inc's ("KEC") Wildfire Mitigation Plan.
Purpose. The purpose of vegetation management performed by KEC is to identify and control or
eliminate vegetation that threatens the integrity, reliability, or safety of the electrical facilities that are
part of KEC's electrical system ("KEC Facilities"). This VMP provides the general standards and guidelines
for KEC's performance of vegetation management.
VMP Implementation Schedule. Vegetation management includes pruning and removing tree and
brush species in the areas around KEC Facilities, the proper disposal of debris created by those activities,
and other steps necessary to identify and control or eliminate vegetation that threatens the integrity,
reliability, or safety of KEC Facilities. Each calendar year, KEC shall develop a VMP Implementation Plan
for the next calendar year. Each VMP Implementation Plan shall (i) identify the KEC Facilities (or
portions of the KEC electrical system) where vegetation management is scheduled to be performed in
the applicable calendar year; (ii)the resources that will be required to perform the scheduled vegetation
management (including the anticipated KEC personnel,total number of personnel hours, KEC
contractors, and equipment necessary to perform the scheduled vegetation management activities);
and (iii)the steps to be taken to document and report the work that is performed pursuant to the VMP
Implementation Plan Each VMP Implementation Plan will also include projected VMP Implementation
Plan for the calendar year immediately following the first calendar year. For example,the VMP
Implementation Plan that is developed in 2025, will include the VMP Implementation Plan for 2026 and
a projected VMP Implementation Plan for 2027.
Right-of-Way Clearing and Trimming. KEC's standard
practice is to maintain a 30-foot area around its overhead and
above-ground electric facilities operating at distribution
voltages. KEC's standard practice is to clear everything within 15' 15' r
fifteen (15)feet of the centerline of its overhead and above-
ground electric facilities operating at distribution voltages as
illustrated in the graphic below. KEC will perform vegetation
management in accordance with its standard practice of a
clearing everything within fifteen (15) feet of the centerline
of the KEC Facilities, except as otherwise required by
applicable federal,state, or local laws, regulations, or
ordinances("Applicable Laws"). In addition to clearing
everything within 15 feet of the centerline of the KEC
Facilities, KEC will also remove any hazard trees as discussed
herein.
Figure 1 ROW Clearances
In those circumstances where clearing in
accordance with the standard practice stated above is either not permitted or is impractical, pruning will
be performed in a manner that is consistent with best management practices as published by the
International Society of Arboriculture (ISA) guidelines, including ANSI A300, applicable OSHA
KOOTENAI ELECTRIC COOPERATIVE INC.WILDFIRE MITIGATION PLAN-PAGE 21 DECEMBER 31,2025

requirements, and all Applicable Laws. Such pruning will be performed to remove dead/dying branches
and other parts overhanging, encroaching, or otherwise threatening any KEC Facilities.
Vegetation Management Practices
• Residential:Vegetation that is cleared or pruned will be masticated. Debris will not obstruct
roads, ditches,or drains.To the extent practical, KEC will discuss any pruning or clearing of
ornamental plantings with landowners before work begins.Topping is not an accepted practice.
• Rural and Undeveloped Areas:Vegetation that is cleared or pruned will be masticated, and
scattered. Live and dead trees will be felled and arranged parallel to power lines without
blocking roads, streams, or ditches.
System-Wide Assessment Using Al &Satellite Imaging. KEC will assess its electrical system every two
(2)years using an AI-powered vegetation intelligence system, which provides wildfire risk analysis,
hazard tree identification, tree segmentation, height and health analysis, 3D vegetation risk scoring, and
recommended work prioritization.
The Encroachment Risk Rating system classifies vegetation risks as:
1. High (0-3 feet from conductor)
2. Medium (3-6 feet)
3. Low (6-10 feet)
4. Minor
5. Clear
Vegetation Management Schedule and Prioritization.
KEC performs vegetation management on a seven (7)year cycle in accordance with its VMP
Implementation Plan. Vegetation management to be performed in each year of the cycle shall be
included in the VMP Implementation Plan for such year and will be organized by feeder and prioritized
based on historical outage frequency and duration.Vegetation management that is required to be
performed in a calendar year that is not included in the VMP Implementation Plan for that year
(including, service order work) is prioritized based on an assessment of the Encroachment Risk Rating as
follows:
• Priority 1 (High Encroachment Risk):Addressed within the year identified.
• Priority 2 (Medium Encroachment Risk):Addressed after Priority 1 within two (2)years after
identified.
• Priority 3& 4 (Low and Very Low Encroachment Risk):Addressed in the normal course within the
seven (7)year cycle.
Hazard Tree Mitigation. Hazard trees are trees that are identified as dead,dying, or structurally
damaged that pose a risk to KEC Facilities. Hazard trees outside a right-of-way that present a fall risk
are continuously evaluated and prioritized for removal. Priority is assigned based on U.S. Forest Service
wildfire zone data. KEC's field planners will assess the Encroachment Risk Rating of each hazard tree that
is identified and will assign work accordingly. KEC will, in accordance with KEC's Vegetation
Management Policy, remove any hazard tree that is outside the right-of-way(or outside of the 30-foot
KOOTENAI ELECTRIC COOPERATIVE INC.WILDFIRE MITIGATION PLAN-PAGE 22 DECEMBER 31,2025

area cleared of vegetation in accordance with KEC's standard practice) if such hazard tree reasonably
threatens KEC's facilities.
Member-Reported Service Orders& Emergency Response. Member-reported concerns will be assessed
by a KEC representative. If the request involves vegetation that is encroaching on any KEC Facilities,
work will be performed per specifications and this Vegetation Management Plan.
Underground Structures. KEC's crews must be able to inspect utility equipment at all times. Any
obstruction that impedes access to KEC facilities will be removed to allow immediate access.
Cleanup. Logs that are left after performing vegetation management will be cut into tree lengths, unless
the member/landowner requests that such logs be cut into firewood lengths. Stumps will be cut as
close to ground level as practical. Stump removal is not performed by KEC. All wood is left for property
owners. Brush and limbs from live trees will be chipped or lopped and scattered,while those from dead
trees will be left for the property owner.
Secondary Line Trimming. Members are responsible for vegetation management for secondary service
lines. KEC does not generally perform vegetation management for secondary service lines, but KEC may,
in its sole discretion, perform such vegetation management. KEC will provide line drops free of charge
for members to trim trees affecting secondary service lines.
Member Communication. Members will be notified before circuit trimming begins. KEC will make
reasonable efforts to notify other(non-member) landowners. In the event that any landowner(member
or non-member) denies KEC access to perform vegetation management in accordance with this
Vegetation Management Plan, KEC will provide such landowner notice in accordance with the Wildfire
Standard of Care Act of its intent to access and perform vegetation management.
Compensation for Live Marketable Timber on Timber Company Land. Pursuant to the Act,
"[i]f live marketable timber is identified for removal from timber company land adjacent to the
right-of-way, compensation at fair market value shall be made to the landowner for such
timber." I.C. § 61-1803(3)(g)(i). With regard to KEC's determination of such fair market value,
KEC incorporates its response to Commission Staffs First Product Request, Request No. 4,
which is attached hereto as Exhibit 1 to this VMIP. Order No. 37081 at 13 (item viii).
Conclusion.This document serves as KEC's official Vegetation Management Plan. This Vegetation
Management Plan is supported by KEC's Vegetation Management Policy,Vegetation Management
Procedure,which reference and guide vegetation management activities.
KOOTENAI ELECTRIC COOPERATIVE INC.WILDFIRE MITIGATION PLAN-PAGE 23 DECEMBER 31,2025

Exhibit 1
Vegetation Management Plan
KEU S Response to Staff s First Production Request, Request No. 4

Exhibit 1 to Vegetation Management Plan
KEC'S Response to Staff s First Production Request, Request No. 4
IPUC Case No. CO7-E-25-01
First Production Request of Commission Staff
Request No. 4
Person Preparing Response: Julie Turbin, VP of Operations& Operational Services
Record Holder: Kootenai Electric Cooperative, Inc. ("KEC")
KEC Contact: Michael G. Andrea, General Counsel, [phone]
Request No. 4: Please describe the Company's process for compensating timber land owners for
the marketable timber. In your response, indicate whether compensation is also provided to
private owners, Idaho state agencies, tribal entities, or other entities, and explain any differences
in treatment.
KEC Response: The Wildfire Standard of Care Act("Act")requires compensation for
marketable timber identified for removal from timber company land adjacent to rights-of-way.
I.C. § 61-1803(3)(g)(iii). The Act does not require a process for compensating landowners and
does not address compensation to any other landowners and,therefore,to the extent that this
request seeks information regarding a process for compensation and/or compensation to other
landowners, the requested information is beyond the scope of this proceeding. Notwithstanding
the foregoing, KEC provides the following information in response to Staff s request:
To KEC's knowledge, KEC does not have any facilities on timber company land that will require
removal of marketable timber and does not contemplate the need to remove any live marketable
timber from timber company land adjacent to any rights-of-way. In the unlikely event that KEC
does need to remove marketable timber from timber company land adjacent to its rights-of-way
in the future, KEC will, if appropriate, work collaboratively with the landowner to determine fair
compensation.
KEC does not provide compensation for marketable timber removed from its rights-of-way
(ROW). When timber removal is necessary, KEC makes reasonable efforts to cut the trees into
log lengths and leave them on site for the landowner's use or disposal. See KEC's Wildfire
Mitigation Plan at Appendix A(stating: "Logs that are left after performing vegetation
management will be cut into tree lengths, unless the member/landowner requests that such logs
be cut into firewood lengths."). This practice is applied consistently regardless of whether the
landowner is a private individual, a state agency, a tribal entity, or another type of landowner.

Appendix A-1
2026-2028 Vegetation Management Implementation Plan
Vegetation Management Implementation Plan 2026-2028
Overview This Vegetation Management Implementation Plan (VMIP) outlines how Kootenai Electric
Cooperative, Inc. (KEC) will operationalize its Vegetation Management Plan (VMP) over a three-year
period. This plan reflects KEC's commitment to safety, reliability, mitigation, regulatory compliance, and
stewardship of its rights-of-way through best practices.
Staffing Structure
• Planners: 3
o Planners will inspect circuits prior to crew mobilization. Using Overstory satellite data,
planners will assess hazard trees, identify high-risk wildfire zones, and engage with
members and landowners to communicate the scope of work.
• Crews: 9 total
0 1 Crew for system-wide Hazard Tree mitigation
0 1 Crew for member-requested vegetation work (tree tickets)
0 7 Crews dedicated to circuit-based vegetation management
Vegetation Management Strategy For each circuit:
1. Planners will evaluate Overstory data to prioritize hazard tree removal.
2. Work will begin in high wildfire risk areas with encroachment.
3. One crew will begin at the substation and proceed downline; the second crew will begin at the
identified priority locations.Then start circuit trimming at designated location.
Crew Assignments by Year
• Crew 1: Hazard trees (system-wide, ongoing)
• Crew 2: Member tree tickets (ongoing)
• Crew 3:
o Julia Street:Jan 2026—Dec 2026
o Scarcello: 2027—2028+
• Crew 4:
o Pleasant View:Jan 2026—Dec 2027
o Scarcello: 2028+
• Crew 5:
o Pleasant View:Jan 2026—Dec 2027
o Scarcello:Jan 2027—Dec 2028
• Crew 6:
o Athol:Jan 2026—Oct 2026
o Beck Road: Nov 2026—Oct 2027
o Hayden: Nov 2027—Dec 2028
• Crew 7:
o Athol:Jan 2026—Oct 2026
o Beck Road: Nov 2026—Nov 2027
o Hayden: Dec 2027—Dec 2028
KOOTENAI ELECTRIC COOPERATIVE INC.WILDFIRE MITIGATION PLAN-PAGE 24 DECEMBER 31,2025

• Crew 8:
o Plummer:Jan 2026—Jul 2026
o Setters: Aug 2026—Dec 2027
o Rathdrum: 2028+
• Crew 9:
o Plummer:Jan 2026—Jul 2026
o Setters: Aug 2026—Dec 2027
o Ogara: 2028+
Documentation & Reporting KEC will use Inspection software to document all vegetation management
activities in the field.This includes:
• Tree work progress (pruning, removals, hazard tree mitigation)
• Location-specific data, including GPS coordinates and condition assessments
• Real-time status updates and digital checklists for crew accountability
Work completed will be audited using drone-based LiDAR data, which will be analyzed to ensure
compliance with KEC specifications, clearance standards, and right-of-way maintenance requirements.
These audits will support continuous quality assurance and help validate contractor performance and cycle
effectiveness.
Resource Planning KEC will estimate the number of personnel and labor hours required to complete each
year's scheduled work and will staff crews accordingly. These estimates will be informed by historical
workload and circuit characteristics. Every two years, following receipt of updated Overstory Al and
satellite vegetation data, resource requirements will be re-evaluated and adjusted as needed to ensure
alignment with vegetation growth patterns, encroachment risk trends and hazard tree counts.
Projected expenditures for right-of-way(ROW) clearing are as follows:
• 2026:$5,686,609
• 2027:$5,857,207
• 2028:$6,032,923
Review Cycle This Implementation Plan will be reviewed and updated annually in conjunction with the
VMP and will include projections for the subsequent three calendar years. Adjustments will be based on
Overstory assessments, work audits, member requests, and unplanned events such as storm response or
wildfire emergencies.
This document supports and aligns with KEC's Vegetation Management Plan and associated policies and
procedures.
KOOTENAI ELECTRIC COOPERATIVE INC.WILDFIRE MITIGATION PLAN-PAGE 25 DECEMBER 31,2025

Appendix B
2026-2028 Construction Work Implementation Plan
This Construction Work Implementation Plan ("CWIP") includes the estimated annual budgets for
construction projects for calendar years 2026-2028.The projects included in this CWIP will mitigate
wildfire risk. These system improvement projects are also planned for reasons other than wildfire
mitigation including to support KEC's forecasted growth, to enhance the reliability of KEC's electrical
system,to improve grid resiliency, and to replace end-of-life equipment.
i
Project Type Estimate Estimate Estimate Estimate
New Consumers - Underground $4,208,013 $4,397,374 $4,595,256 $13,200,643
New Consumers -Overhead $87,372 $91,304 $95,413 $274,089
New Tie Lines $0 $1,275,048 $2,643,929 $3,918,977
Conversion & Line Upgrades $20,240,767 $7,483,515 $5,178,511 $32,902,793
New Substations $176,655 $6,879,758 $4,564,665 $11,621,078
Substation Upgrades, Inside Sub Fence $3,747,242 $2,500,370 $3,594,673 $9,842,285
Meters $1,153,149 $1,205,041 $1,259,268 $3,617,458
Sectionalizing $2,217,142 $1,904,128 $1,929,332 $6,050,602
Voltage Regulators and Controls $3,239,500 $3,385,278 $798,816 $7,423,594
Capacitor Banks and Controls $104,500 $109,203 $114,117 $327,820
Pole Replacements $836,000 $873,620 $912,933 $2,622,553
Miscellaneous Replacements $2,296,910 $1,493,890 $1,561,115 $5,351,915
Road Moves $522,500 $546,013 $570,583 $1,639,096
Transmission Lines $9,642,905 $4,745,190 $0 $14,388,095
Security Lights $156,750 $163,804 $171,175 $491,729
Transmission Pole Replacements $52,250 $54,601 $57,058 $163,909
Minor Projects $3,448,5001 $3,603,6831 $3,765,8481 $10,818,031
Total Budget Estimate $52,130,155 $40,711,820
Pursuant to Commission Order No. 37081,the following responses to Commission Staff's requests for
production are attached hereto and incorporated herein:
• KEC's response to Commission Staff's First Product Request, Request No. 1, including the
detailed list of known projects used by KEC to refine its 2026-2028 budget estimates and
information is attached to this Appendix B as Exhibit 1. Order No. 37081 at 12 (items i, iii, and
vii).
• KEC's response to Commission Staff's First Production Request, Request No. 11, regarding
metrics used by KEC for measuring efficacy of its grid hardening is attached to this Appendix B as
Exhibit 2. Order No. 37081 at 12 (item iv).
• KEC's responses to Commission Staff's Second Production Request, Request Nos. 15 and 16,
regarding grants awarded to KEC are attached to this Appendix B as Exhibit 3. Order No. 37081
at 12 (item ii).
KOOTENAI ELECTRIC COOPERATIVE INC.WILDFIRE MITIGATION PLAN-PAGE 26 DECEMBER 31,2025

Exhibit 1
2026-2028 Construction Work Implementation Plan
KEC's Response to Staff s First Production Request, Request No. 1
(including Exhibit A)

Exhibit 1 to 2026-2028 Construction Work Implementation Plan
KEC'S Response to Staff s First Production Request, Request No. 1 (including Exhibit A)
IPUC Case No. CO7-E-25-01
First Production Request of Commission Staff
Request No. 1
Person Preparing Response: Scott Davis,VP Engineering
Record Holder: Kootenai Electric Cooperative, Inc. ("KEC")
KEC Contact: Michael G.Andrea, General Counsel, [phone]
Request No. 1: Idaho Code § 61-1803(3), § 61-1803(3)(b), and § 61-1803(3)(e)address preventative
actions and programs, as well as methods of line design. The Commission's WMP Guidelines for
Idaho Code § 61-1803 (3)(e), Method of Line Design, states: "Financially prudent and reasonably
practicable methods of line design for new,planned, and existing lines to mitigate fire risk."
The Guidelines further state: "The electric corporation must describe how its methods of line design
for new lines and planned upgrades reduce wildfire ignition potential in heightened wildfire risk
areas. This must include evaluation of costs to wildfire risk reductions. Additionally, this must
include how the electric corporation clearly identifies, selects, and evaluates projects that reflect a
balance of mitigation costs with resulting reduction in wildfire risk."
Appendix B of the Company's Wildfire Mitigation Plan("WMP")provides project types and
budgets for 2026-2028. Further, Sections 3.1 and 3.2 describes the potential Grid Modernization and
Methods of Line Design initiatives. For each project type in Appendix B,please identify specific
known projects used to develop the 2026-2028 budget estimates and provide the following
information for each project:
a. Project type;
b. Project name;
c. Brief description of the project;
d. Estimated cost of the project(could be a range);
e. Targets of the project(e.g.,miles, number of assets installed/replaced);
f. Explanations of the benefits of this project;
g.Alternatives considered and explain why this was chosen as the best alternative;
h. Costibenefit considerations; and
i. Estimated completion date.
KEC Response:
The Wildfire Standards of Care Act("Act")requires wildfire mitigation plans to identify a means for
mitigating wildfire risk that reflect a reasonable balancing of mitigation costs with the resulting
reduction of wildfire risk and requires the Commission to consider the feasibility of the plan and the
cost of its implementation. See I.C. § 61-1803(3), 61-1804(1). The Act does not provide the
Commission with authority to regulate cooperatives', like KEC's,projects and/or costs and provides
no authority over costs to the extent that such projects,project benefits and/or project costs are not
related to wildfire mitigation. Therefore,to the extent that this request seeks information regarding
projects,project benefits, and/or project costs not related to wildfire mitigation,the requested
information is not relevant and is beyond the scope of this proceeding. Notwithstanding the
foregoing,KEC provides the following response.

The Construction Work Implementation Plan as presented in Appendix B of the WMP is a
snapshot of the financial work plan at the time of the WMP filing with IPUC. The detailed list of
known projects used to refine the 2026-2028 budget estimates and information as requested in
this response item are tabulated in Item 1 - Exhibit A.
With regard to subparts f and h of this request, KEC notes that KEC considers the benefits of all
projects, including, but not limited to, benefits associated with reliability, extending service to
members, replacing outdated infrastructure, and wildfire mitigation. Projects are rarely, if ever,
solely performed for any single reason, including wildfire mitigation. Rather, KEC considers all
attributes of any project. Furthermore, it is not clear what is needed for subpart h of this request
and how that is differentiated from the response that is provided in subpart f.
It is impossible to quantify the amount of any given project that should be attributed to wildfire
mitigation as opposed to any other benefit(s) of the project. More fundamentally, it is impossible
to predict or quantify the costs of a future wildfire.' However, even assuming that 100 percent of
KEC's projects and costs and benefits were solely attributable to wildfire mitigation(which they
are not), given the extremely high cost of wildfires as evidenced by recent wildfires,the benefits
of those projects would almost certainly always outweigh the costs.2
Note that the sum of cost values for the known projects in Item 1 - Exhibit A has been further
refined since the tabulation was provided in Appendix B of the WMP.
'See Idaho Power Company's Wildfire Mitigation Plan filed in IPC-E-25-32 at page 15(stating: "Ultimately,Idaho
Power found that obtaining a precise calculation of the potential costs of future wildfires is not possible.").
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Exhibit 2
2026-2028 Construction Work Implementation Plan
KEC S Response to Staff s First Production Request, Request No. 11

Exhibit 2 to 2026-2028 Construction Work Implementation Plan
KEC'S Response to Staff s First Production Request, Request No. 11
IPUC Case No. CO7-E-25-01
First Production Request of Commission Staff
Request No. 11
Person Preparing Response: Scott Davis, VP Engineering
Record Holder: Kootenai Electric Cooperative, Inc. ("KEC")
KEC Contact: Michael G. Andrea, General Counsel, [phone]
Request No. 11: Please list and describe the Company's metrics for measuring the efficacy of its
grid hardening. In addition,please explain if the Company currently or plans to measure the
effect of its grid hardening efforts relative to System Average Interruption Duration Index,
System Average Interruption Frequency Index, Customer Average Interruption Duration Index,
and/or Momentary Average Interruption Frequency Index.
KEC Response: KEC follows the IEEE 1366 standard for tracking SAIDI, SAIFI, CAIDI, and
CEMI reliability metrics for all outages. These metrics are tabulated and graphed on a quarterly
basis for a rolling 12-month dataset that includes major event days and then for another rolling
12-month dataset that does not. The tabulation and graphical information also illustrate the
system reliability performance by sub and by feeder level which allows measurements to be
made on reliability improvement for grid hardening projects complete on each substation and
feeder level.
KEC currently targets substation feeders with the worst reliability metrics for grid hardening
projects. KEC measures effect of its grid hardening efforts relative to System Average
Interruption Duration Index, System Average Interruption Frequency Index, Customer Average
Interruption Duration Index, and/or Momentary Average Interruption Frequency Index on a
quarterly basis, using a rolling 12-month dataset.

Exhibit 3
2026-2028 Construction Work Implementation Plan
KEU S Response to Staff s Second Production Request, Request Nos.
15 and 16

Exhibit 3 to 2026-2028 Construction Work Implementation Plan
KEC'S Response to Staff s Second Production Request, Request Nos. 15 and 16
IPUC Case No. CO7-E-25-01
Second Production Request of Commission Staff
Request No. 15
Person Preparing Response: Reed Christensen, Chief Operating and Financial Officer
Record Holder: Kootenai Electric Cooperative, Inc. ("KEC")
KEC Contact: Michael G. Andrea, General Counsel, [phone]
Request No. 1: In the Response to Staffs First Production Request at No. 1, Project Name"603-
2026-09" on Line 53 in"Item I —Exhibit A"is described as"WRIP Grant VIPER Recloser
Installations, 8 locations."Please answer the following:
a. Please provide the awarded grant documents (i.e.,Notice of Award, approved proposal, etc.);
b. Please provide the number of VIPER reclosers planned to be installed in 2026, 2027, 2028;
c. Please provide the locations that the Company is focusing on using the grant;
d. Please provide the metrics that will be used to evaluate the VIPER reclosers;
e. Please explain if the Company has to financially match the grant; and
f. Please provide the timeline of the grant.
KEC Response:
The purpose of the cited WRIP Grant, as set forth in the WRIP Subaward Agreement(attached
to KEC's response to subpart a below), "is to increase grid resilience, reduce wildfire risk,
enhance fault detection and isolation, and improve reliability."To the extent that this request
seeks information regarding KEC's costs and projects for purposes other than the purposes set
forth in the Wildfire Standard of Care Act, I.C. §§ 61-1803(3), 61-1804,this request seeks
information that is not relevant to the Commission's review or approval of KEC's 2026-2028
Wildfire Mitigation Plan. Notwithstanding the foregoing, KEC provides the following response:
a. Please provide the awarded grant documents (i.e.,Notice of Award, approved proposal, etc.);
The following awarded grant documents are attached:
"WRIP Conditional Award Letter"
"WRIP Subaward Agreement KEC"
b. Please provide the number of VIPER reclosers planned to be installed in 2026, 2027, 2028;
Eight VIPER reclosers are planned to be physically installed in 2026 with further
telecommunications and commissioning work performed in early 2027.No work is
expected in 2028.

c. Please provide the locations that the Company is focusing on using the grant;
At this time, the precise locations have not yet been decided. However, as mentioned in
the grant application, these advanced reclosers will be strategically placed in high-risk
areas most susceptible to wildfire to improve the reliability and safety of our electric
distribution system.
d. Please provide the metrics that will be used to evaluate the VIPER reclosers;
KEC does not understand this request. Once installed,the VIPER reclosers will be
incorporated into KEC's electrical system and monitored and inspected as part of that
system.
e. Please explain if the Company has to financially match the grant; and
As set forth in the WRIP Subaward Agreement attached in response to subpart a of this
request, the company is required to match the grant funding up to $117,008 of the total
project cost of$468,031.
f. Please provide the timeline of the grant.
Eight VIPER reclosers are planned to be physically installed in 2026 with further
telecommunications and commissioning work performed in early 2027.No work is
expected in 2028. Once work is fully completed, funding will be provided to KEC to
reimburse KEC for the construction work.

IPUC Case No. CO7-E-25-01
Second Production Request of Commission Staff
Request No. 16
Person Preparing Response: Reed Christensen, Chief Operating and Financial Officer
Record Holder: Kootenai Electric Cooperative, Inc. ("KEC")
KEC Contact: Michael G. Andrea, General Counsel, [phone]
Request No. 16: Please explain if the Company has been awarded any other grants for wildfire
mitigation projects in 2026-2028. If so,please answer the following:
a. Please provide the name of the grant;
b. Please provide the status of the grant;
c. Please provide the grant amount and any Company match;
d. Please provide the timeframe of the grant; and
e. Please describe what the grant will be used for.
KEC Response:
To the extent that this request seeks information for purposes other than those purposes set forth
in the Wildfire Standard of Care Act, I.C. §§ 61-1803(3), 61-1804,this request seeks information
that is not relevant to the Commission's review or approval of KEC's 2026-2028 Wildfire
Mitigation Plan. Notwithstanding the foregoing, KEC provides the following response:
a. Please provide the name of the grant;
Idaho Energy Resilience Grant Program (ERGP)
b. Please provide the status of the grant;
The grant agreement between KEC and the State of Idaho's Office of Energy and Mineral
Resources was executed on May 4, 2026.
c. Please provide the grant amount and any Company match;
The total cost of the project is estimated to be $745,340. KEC is to match $141,010 of the total
project costs.
d. Please provide the timeframe of the grant; and
The project related expenditures will commence in July 2026 and continue through July 2027.
e. Please describe what the grant will be used for.
The project will entail two main endeavors. The first activity entails a satellite scan of the
vegetation on our distribution system to identify and prioritize vegetation risks and identify dead
or dying trees outside of the right-of-way that are considered hazardous. Using the information

produced from the satellite scan, KEC would then deploy an additional vegetation crew to
conduct hazardous-tree removal for those trees identified outside of the right-of-way.

Appendix C
2026-2028 System Inspection Implementation Plan
This System Inspection Implementation Plan includes the estimated power line feeders, lengths,
and budgets for inspection in calendar years 2026-2028. The inspections of the feeders included in
this System Inspection Implementation Plan are targeted to mitigate wildfire risk and improve system
reliability.
Substation Feeder Year Length(mites) Budgeted Cost
Dower East 2026 60.6
Setters North 2026 113.8
Setters South 2026 116.8
2026 Total 291.2 $219,981
Rathdrum 2027 53
15th Street 2027 57.7
2027 Total 110.7 $233,180
Rathdrum 2028 54.6
Pleasantview 2028 82.3
2028 Total 136.9 $247,170
Grand Total 538.8 $700,331
KOOTENAI ELECTRIC COOPERATIVE INC.WILDFIRE MITIGATION PLAN-PAGE 27 DECEMBER 31,2025

Appendix D
Resolution # 10-25
Kootenai Electric
,,m COOPERATIVE
KOOTENAI ELECTRIC COOPERATIVE,INC.
Resolution#10-25
Review and Acceptance of Wildfire Mitigation Plan
WHEREAS,in the 2025 legislative session,the Idaho Legislature enacted the Wildfire Standard of Care Act. 2025
Idaho Sess.Laws Ch.249(S.B.1183),codified at Idaho Code§§61-1801,et seq.("Act");and
WHEREAS,the Act provides that electric corporations that are not public utilities,including the Cooperative, may
adopt and file a wildfire mitigation plan("Plan")with the Idaho Public Utilities Commission("Commission");and
WHEREAS,the Act requires Plans submitted to the Commission to identify a means for mitigating wildfire risk
that reflects a reasonable balancing of mitigation costs with the resulting reduction of wildfire risk;and
WHEREAS,in reviewing and approving a Plan,the Act requires the Commission to(i)ensure that the Plan meets
the minimum requirements stated in the Plan,including that the Plan includes financially prudent and reasonably
practical methods of line design for new,planned,and existing lines to mitigate fire risk;and(ii)consider certain factors,
including the feasibility of the Plan and the cost of its implementation;and
WHEREAS,determinations regarding(i)financial prudency and practicability of the Cooperative's methods of
line design for new,planned,and existing lines;(ii)whether the Cooperative's Plan reflects a reasonable balancing of
mitigation costs with the resulting reduction of wildfire risk;and(iii)matters regarding the feasibility of the Plan and the
cost of its implementation are within the purview of the Cooperative's board of directors;and
WHEREAS,management has reviewed the Cooperative's Plan and has presented it to the Cooperative's board of
directors for review;and
WHEREAS,the board of directors has reviewed the Cooperative's Plan and its costs of implementation and has
determined that the Plan(i)includes financially prudent and reasonably practicable methods of line design for new,
planned,and existing lines to mitigate fire risk;(ii)is feasible;and(iii)reflects a reasonable balancing of mitigation costs
with the resulting reduction of wildfire risk.
KOOTENAI ELECTRIC COOPERATIVE INC.WILDFIRE MITIGATION PLAN-PAGE 28 DECEMBER 31,2025

Resolution#10-25
Signature Page
NOW,THEREFORE,BE IT RESOLVED that the board hereby accepts the Cooperative's 2026-2028 Plan as presented by
management and authorizes management to make such revisions to such Plan as management deems necessary or
advisable to file the Plan with the Idaho Public Utilities Commission for approval pursuant to the Act;provided that any
substantial changes to the costs associated with the Plan shall be submitted to the board for its review and approval.
Approved this 20`h day of November,2025
411 William R.Swick,Chair
I,Roger Tinkey,Secretary of the Board of Directors of Kootenai Electric Cooperative,Inc.,do hereby certify that
the above Resolution#10-25 was presented to and approved by the Board of Directors this 2011 day of November 2025
and that none of the above Resolution has been altered or rescinded.
Roger Tinke ,Sec ry
KOOTENAI ELECTRIC COOPERATIVE INC.WILDFIRE MITIGATION PLAN-PAGE 29 DECEMBER 31,2025

Appendix E
Wildfire Standard of Care Act and Order No. 36774 WMP Guideline Compliance Matrix
The WMP Guidelines adopted by the Idaho Public Utilities Commission in Order No. 36774 indicate that WMPs should include a
section that describes how the electric corporation addresses each of the Commission's orders and Staff's recommendations. This
Wildfire Standard of Care Act and Order No. 36774 WMP Guideline Compliance Matrix describes the section(s) of KEC's Wildfire
Mitigation Plan ("Plan")that address each such requirement.
Wildfire Standard of Care Act Requirements and Order No.36774/WMP Guideline Requirements KEC Wildfire Mitigation Plan Compliance
Each wildfire mitigation plan("WMP")shall be developed using approaches and methods that are All sections of KEC's Plan.
designed to protect the public interest and are reflective of and commensurate with the size and KEC's Plan was developed using approaches and methods that are designed to
complexity of the electric corporation's operations and the nature of the fire risk. I.C.§61- protect the public interest and are reflective of and commensurate with the size
1803(3). and complexity of KEC's operations and the nature of the fire risk.
Section 6—Cost Evaluation;Cost-Benefit Approach
Appendix D—KEC Resolution#10-25
Each WMP shall identify a means for mitigating wildfire risk that reflect a reasonable balancing of All sections of KEC's Plan identify means for mitigating wildfire risk that reflect a
mitigation costs with the resulting reduction of wildfire risk. I.C. §61-1803(3). reasonable balancing of mitigation costs with the resulting reduction of wildfire
risk.
Section 6—Cost Evaluation;Cost-Benefit Approach
Appendix D—KEC Resolution#10-25
Each WMP is to identify geographical areas where an electric corporation has infrastructure or Section 2.1—Identification of Geographical Areas that May be Subject to
equipment that the electric corporation considers may be subject to a heightened risk of wildfire Heightened Risk of Wildfire.
at the time the WMP is finalized by the electric corporation. I.C. §61-1803(a). Figure 3—Heightened Risk Areas
• The electric corporation must include a description of the wildfire risk assessment or model
used to guide wildfire mitigation activities.The assessment should identify geographic areas
with elevated fire risk,considering factors such as vegetation,weather,topography,historical
fire occurrence,structure density,and asset location.
• The electric corporation should provide a map of the identified risk areas within its service
territory within this section of its WMP.The identified risk areas should be defined with
different level of fire risks to the utility.There must be an explanation of what determines
each level of risk and risk assessments of each service territory should be updated annually in
the WMP.
Order No.36774,Exhibit 1 at 2.
KOOTENAI ELECTRIC COOPERATIVE INC.WILDFIRE MITIGATION PLAN-PAGE 29 DECEMBER 31,2025

Each WMP is to include preventive actions and programs that the electric corporation will carry
out to reduce the risk of wildfire. I.C.§61-1803(3)(b).
• The electric corporation must describe all preventative actions and programs that it will carry
out to reduce the risk of wildfire,in addition to actions and programs specified in statute and
by this Commission.
• WMP's preventative actions and programs must include,but is not limited to:
Situational Awareness efforts Section 4—Fire Season Operational Guide
o Which may include use of technology to aid in weather monitoring,fire season outlook, Section 4.1—Daily Situational Awareness
daily,weekly,and monthly weather and fire modeling risk,etc. Consistent with 61-1803(3)(f) Figure 4—Tempest System Daily Fire Risk Example (for Illustrative Purposes
and Staff's proposed requirements within. Only)
Figure 5—Daily Situational Awareness Table
_._._._.A .
Asset Inspections p_._._._._._ .................................................._._._._._._._._._._._._._._._._._._._._._._._._.-._._._._._._._._._._._._._._._._._._._._._._._._._._._._._._._._._._._._._._._._._._._._._.__.__._._._._._._._._._._._._._._._._._._.__._. -Section 3.4—Development ment of Standards Procedures and Schedules for.......................................
o Which must include the frequency and standards of inspections for each type of electric Inspection of KEC's Assets, Infrastructure,and Facilities Within Heightened Fire
infrastructure within areas of elevated wildfire risk. Risk Areas
Consistent with 61-1803(3)(g)(i)and Staffs proposed requirements within. Appendix A—Vegetation Management Plan
Appendix A-1—Vegetation Management Implementation Plan
Appendix C—System Inspection& Maintenance Plan
- _ _ _ _._._________ -------------_.............................................................
Enhanced vegetation management practices in risk zones Section 3.3—Vegetation etation Management
o Which may include shorter vegetation management cycles than routine cycles, risk tree Appendix A—Vegetation Management Plan
programs,etc. Appendix A-1-2026-2028 Vegetation Management Implementation Plan
Consistent with 61-1803(3)(g)(iii)and Staffs proposed requirements within.
........................-----------------------------------------------------------------------------------------------------------------------------------------._._._._._._._.__._._._._._._._._._._.-._._.-._._._._._._._._._._._._._._._._._._._._._._._._._._._._._. ._Section 4.3-0 p g erational Action Index with Fire Danger Linkag._.e_._._._._._.___.._._._._._._._._._._._._._
Operation practices during heightened wildfire risk days or zones Figure 7—Fire Danger/Operational Index
o Which may include restrictions to workforce practices, potential use of proactive de- Figure 8—Fire Season PSPS Decision Making Process/Operational Table
energization Section 4.3.1—Risk Monitoring and Forecasting
Consistent with 61-1803(3)(g)(ii)and Staffs proposed requirements within. Section 4.3.2—Risk Assessment and Initial Decision-Making
Section 4.3.3—Notification and Coordination(Pre-Activation Phase: 72-24
Hours Out)
Section 4.4—Final Decision and Activation(24-0 Hours Out)
Figure 9—National Weather Service Red Flag Weather Matrix,Eastern
Washington and North Idaho
4.3.5—Monitoring During a PSPS
4.3.6 Restoration Process After a PSPS
KOOTENAI ELECTRIC COOPERATIVE INC.WILDFIRE MITIGATION PLAN-PAGE 30 DECEMBER 31,2025

-----------
Community education---------------...... ----------------------...............................---------------------------...... -------- ---- ........................................_.....-------.........-_...--.................................--...............----------------------------
Section 5-Outreach and Communication
o Which may include public service announcements to create awareness and provide Section 5.1—KEC Internal Processes to Guide Wildfire-Related Communication
education of wildfire risks,providing preventative measures,etc. Section 5.2—Coordination with Federal,State,Tribal,and Local Agencies
Consistent with 61-1803(3)(c)and 61-1803(3)(d) Section 5.2.1—Annual Coordination Meeting
Section 5.2.1—Communication of Changes in Operating Condition
Section 5.2.3—Communications with OEM Regarding PSPS
....... .......... .................
And an
Section 5.3—Member Communications
any additional requirements ordered by the Commission Section 3.1—Grid Modernization
Section 3.2—Methods of Line Design for New, Planned,and Existing Lines to
WMPs may include: Mitigate Fire Risk
System hardening strategies:Which may include pole replacements,line rebuilding,or Appendix B-2026-2028 Construction Work Implementation Plan
undergrounding if necessary,strategic fuse or reclosers installations,etc.
Figure 5—Daily Situational Awareness Table
Workforce Preparedness:Which may include workforce training,equipment provided to
employees to reduce the risk of wildfire,etc.
N/A
Pilot Programs:If applicable.
Order No.36774,Exhibit 1 at 2-4.
Each WMP is to include community outreach and public awareness efforts that the electric corporation will use before,during, Section 5—Outreach and Communication
and after wildfire season to identify and inform the public of relevant wildfire risks and notify the public of wildfire-related Section 5.1—KEC Internal Processes to Guid
outages. I.C.§61-1803(c). Wildfire-Related Communication
Section 5.2—Coordination with Federal,State,
This section should include discussion of how each utility maintains community outreach and public awareness before, Tribal,and Local Agencies
during,and after wildfire season to support customer awareness and education of wildfire risks and notify the public of Section 5.2.1—Annual Coordination Meeting
wildfire-related outages.This discussion should include,but is not limited,to the following: Section 5.2.1—Communication of Changes in
• Description of customer communication efforts related to wildfire mitigation,including efforts to increase awareness Operating Condition
and education of the utility's plan,explanation of key mitigation activities,and efforts supporting public readiness. Section 5.2.3—Communications with OEM
• If the utility utilizes de-energization,a description of public education efforts and communication protocols for before, Regarding PSPS
during,and after a de-energization event.The communication protocols should clearly identify which customers could Section 5.3—Member Communications
and will be impacted if a de-energization event is pursued and identify any advanced notifications for critical
infrastructure or customers,which may include but not limited to,hospitals and other medical facilities,schools,police,
fire,emergency operation centers,any jails/prisons,other utilities,and vulnerable customers.
• Explanation of the communication methods the electric corporation intends to use,such as mail,flyers,emails,calls,
texts,a notification system,its website,etc.
Order No.36774,Exhibit 1 at 4.
KOOTENAI ELECTRIC COOPERATIVE INC.WILDFIRE MITIGATION PLAN-PAGE 31 DECEMBER 31,2025

Each WMP is to include outreach efforts to coordinate with federal,state,tribal,and local officials and Section 5.2—Coordination with Federal,State,Tribal,and Local
agencies on wildfire preparedness and emergency response plans. I.C.61-1803(3)(d). Agencies
Section 5.2.1—Annual Coordination Meeting
The electric corporation must describe how it engages with and coordinates with federal,state,tribal,and Section 5.2.1—Communication of Changes in Operating Condition
local officials and agencies on wildfire preparedness and emergency response in the plan year.This Section 5.2.3—Communications with OEM Regarding PSPS
discussion may include,but is not limited to:
• If applicable,Public Safety Power Shutoff("PSPS")tabletop exercises with interested parties and
agencies
• Communication with the agencies and the ESF-12 coordinator within the PUC.
• If applicable,mitigation efforts with the agencies.
The WMP must detail all relationships(such as BLM and Forest Service)it has established that may benefit
the wildfire mitigation program,contribute to program costs,or provide cost sharing opportunities in its
WMP.
Order No.36774,Exhibit 1 at 4-5.
Each WMP is to include financially prudent and reasonably practicable methods of line design for new, Section 3.1—Grid Modernization
planned,and existing lines to mitigate fire risk. I.C. §61-1803(e). Section 3.2—Methods of Line Design for New,Planned,and
Existing Lines to Mitigate Fire Risk
The electric corporation must describe how its methods of line design for new lines and planned upgrades Appendix B-2026-2028 Construction Work Implementation Plan
reduce wildfire ignition potential in heightened wildfire risk areas.This must include evaluation of costs to Section 6—Cost Evaluation;Cost-Benefit Approach
wildfire risk reductions.Additionally,this must include how the electric corporation clearly identifies, Appendix D—KEC Resolution#10-25
selects,and evaluates projects that reflect a balance of mitigation costs with resulting reduction in wildfire
risk for the following,but is not limited to:
• Line rebuilding within the WMP.
• Undergrounding lines within the WMP.
• Installation of covered conductor.
• Installation of non-wooden cross arms.
• If any,describe any flexible infrastructure such as automatic reclosers and remote-controlled devices
that support remote operations
Order No.36774,Exhibit 1 at S.
KOOTENAI ELECTRIC COOPERATIVE INC.WILDFIRE MITIGATION PLAN-PAGE 32 DECEMBER 31,2025

Each WMP is to include monitoring of forecasted and current weather data for the purpose of assessing and Section 4—Fire Season Operational Guide
responding to current and anticipated fire risk. I.C.§61-1803(f). Section 4.1—Daily Situational Awareness
Figure 4—Tempest System Daily Fire Risk Example(for Illustrative
This section should include a description of how the electric corporation monitors forecasted and current Purposes Only)
weather conditions for the purpose of assessing and responding to current and anticipated wildfire risk. Figure 5—Daily Situational Awareness Table
This description must include,but is not limited to,the following: Section 4.3—Operational Action Index with Fire Danger Linkage
• Identification of systems,tools,or external resources used to monitor weather,fire potential,or other Figure 7—Fire Danger/Operational Index
situational awareness indicators. Figure 8—Fire Season PSPS Decision Making Process/Operational
• If applicable,a description of how the utility utilizes weather forecasting,fire potential modeling,or Table
similar tools,to inform mitigation activities and operational decisions. Section 4.3.1—Risk Monitoring and Forecasting
• Discussion of how situational awareness capabilities are integrated into daily or seasonal wildfire Section 4.3.2—Risk Assessment and Initial Decision-Making
operations. Figure 9—National Weather Service Red Flag Weather Matrix,
• Discussion of how the electric utility becomes aware of another electric corporation's de-energization Eastern Washington and North Idaho
(e.g.,Bonneville Power Administration)and how that is integrated into operations.
Order No.36774,Exhibit 1 at 5-6.
Each WMP is to include standards, procedures,and schedules,subject to timely approval of access to rights-
of-way, if necessary for the following actions:
i Inspection of the electric corporation's assets infrastructure and facilities within the areas that Section 3.4—Development of Standards Procedures and
are identified as heightened fire risk areas in the wildfire mitigation plan,where financially Schedules for Inspection of KEC's Assets, Infrastructure,and
prudent and reasonably practicable. Facilities Within Heightened Fire Risk Areas
Appendix A—Vegetation Management Plan
This section should provide a summary of electric corporation's programs for the inspection of electric Appendix A-1—Vegetation Management Implementation Plan
infrastructure,assets,and facilities within areas identified as heightened wildfire risk areas to identify and Appendix C—System Inspection& Maintenance Plan
correct conditions that could contribute to wildfire ignition.This summary must include,but is not limited
to,the following:
• Description of inspection standards for each type of infrastructure,assets,and facilities.
• Description of schedules for inspections for each type of infrastructure,asset,and facility.
• Description of baseline routine inspection methods and enhanced inspection methods for higher fire
risk areas,which may include the use of advanced or pilot technologies.
• Explanation of how identified defects are classified,prioritized,and corrected.
• Measurable targets/goals to be achieved within the WMP.E.g.,miles of lines inspected,corrected
identified defects,etc.
Order No.36774,Exhibit 1 at 6.
KOOTENAI ELECTRIC COOPERATIVE INC.WILDFIRE MITIGATION PLAN-PAGE 33 DECEMBER 31,2025

----------- -................................... -- --- ------- -------- -- -- --- - - .. ---------------------- -- --- -- ... _-_-................................ ------- ... . . . ----- -- . . ------
(ii) De-energization of the electric corporation's power lines,if considered appropriate by the Section 4.2—Public Safety Power Shutoff(PSPS)Procedure
electric corporation;and Section 4.3—Operational Action Index with Fire Danger Linkage
Figure 7—Fire Danger/Operational Index
If an electric utility plans to use de-energization as part of its wildfire mitigation efforts,this section must Figure 8—Fire Season PSPS Decision Making Process/Operational
address the standards,criteria,and operational protocols,for de-energization for encroachment of a Table
wildfire,proactive de-energization(PSPS)to reduce fire risk,and deenergization from 3rd party energy Section 4.3.1—Risk Monitoring and Forecasting
providers.This discussion must include,but is not limited to the following: Section 4.3.2—Risk Assessment and Initial Decision-Making
Section 4.3.3—Notification and Coordination(Pre-Activation
• A summary of the conditions under which de-energization may be used,if applicable. Phase: 72-24 Hours Out)
• The criteria or protocols for evaluating its appropriateness to engage. Section 4.4—Final Decision and Activation(24-0 Hours Out)
• Summary of the electric corporation's operational protocols for before,during,and after a de- Figure 9—National Weather Service Red Flag Weather Matrix,
energization event. Eastern Washington and North Idaho
• Description of how the electric corporation will coordinate with local emergency managers,operators 4.3.5—Monitoring During a PSPS
of critical facilities,and affected communities before,during,and after a de-energization event. 4.3.6 Restoration Process After a PSPS
• Descriptions of other operations for limiting impact to affected communities;which may include Section 5—Outreach and Communications
community resource centers,emergency generators,backup batteries,etc. Section 5.1—KEC Internal Processes to Guide Wildfire-Related
Communication
Order No.36774,Exhibit 1 at 7. Section 5.2—Coordination with Federal,State,Tribal,and Local
Agencies
Section 5.2.1—Annual Coordination Meeting
Section 5.2.1—Communication of Changes in Operating Condition
Section 5.2.3—Communications with OEM Regarding PSPS
Section 5.3—Member Communications
KOOTENAI ELECTRIC COOPERATIVE INC.WILDFIRE MITIGATION PLAN-PAGE 34 DECEMBER 31,2025

-----_-III----------- --- ---------- - . _-................................................... ------ ---- -- - . - - ------- ................................. -- - -- - - -................-..........._ _ _........-...........-.........-- ..........._.................-----------------------------..............
-
( ) Vegetation management within the areas that are identified as heightened fire risk areas in the Section 3.3 Vegetation Management
wildfire mitigation plan and are within the electric corporation's rights-of-way or lands adjacent Appendix A—Vegetation Management Plan
thereto and that threaten the power lines or other electric corporation infrastructure. If live Appendix A-1-2026-2028 Vegetation Management
marketable timber is identified for removal from timber company land adjacent to the rights- Implementation Plan
of-way,compensation at fair market value shall be made to the landowner for such timber.
This section must provide an overview of the utility's vegetation management program aimed at reducing
the risk of vegetation-related contact with electric infrastructure in areas with heightened wildfire risk
within its rights-of-way or lands adjacent thereto. Elements of this vegetation management section
overview should include,but is not limited to,the following:
• Identification,description,and citation of vegetation management standards for elevated wildfire
risk areas.
• Explanation of how vegetation management standards,procedures,and schedules are different
or the same as routine vegetation management.
• Description of the current and planned vegetation management practices used to mitigate
wildfire risk,including any enhancements in designated wildfire areas.
• The electric corporation must explain how the electric utility considered vegetation management
recommendations by other federal,state,and county agencies into its standards.
• Must include measurable targets/goals to be achieved within the WMP.E.g.,miles of lines
completed,risk trees removed,etc.
• Explanation of how identified risk trees are classified,prioritized,and corrected.
Order No.36774,Exhibit 1 at 7-8.
An update of lessons learned from the previously approved WIMP within the annual filings for WMP N/A
review and approval.
Order No.36774,Exhibit 1 at 8.
A breakdown of each program category's forecasted costs by year for both capital and O&M expenditures Appendix A-1-2026-2028 Vegetation Management
through the length of the WMP. Implementation Plan
Appendix B-2026-2028 Construction Work Implementation Plan
Order No.36774,Exhibit 1 at 8.
A section in which it describes how the electric corporation addresses each of the Commission's orders Appendix E—Wildfire Standard of Care Act and Order No.36774
and Staffs recommendations. WMP Guideline Compliance Matrix
Order No.36774,Exhibit 1 at 8.
Electric corporations shall develop rolling WMPs with a minimum three-year planning horizon. Section 1.1—Purpose of the Wildfire Mitigation Plan
KOOTENAI ELECTRIC COOPERATIVE INC.WILDFIRE MITIGATION PLAN-PAGE 35 DECEMBER 31,2025

Order No.36774 at 20. Appendix A-1-2026-2028 Vegetation Management
Implementation Plan
Appendix B-2026-2028 Construction Work Implementation Plan
WMPs must explain how an electric corporation's line design methods reduce the potential for wildfire Section 6—Cost Evaluation;Cost-Benefit Approach
ignition,including a cost evaluation. Appendix B-2026-2028 Construction Work Implementation Plan
Order No.36774 at 20.
All electric corporations must include a cost-benefit analysis in their proposed WMPs that justifies the Section 6—Cost Evaluation;Cost-Benefit Approach
expenditures for risk mitigation described within.
Order No.36774 at 20.
Unregulated Entities shall submit a completed copy of Staffs proposed"Need to Know"document with See Application of Kootenai Electric Cooperative, Inc.for Approval
their initial WMP filings to aid Staff in its review of the plan. of its Wildfire Mitigation Plan at page 1 and Attachment 2.
Order No.36774 at 20.
KOOTENAI ELECTRIC COOPERATIVE INC.WILDFIRE MITIGATION PLAN-PAGE 36 DECEMBER 31,2025

APPENDIX F
Heightened Wildfire Risk Map Overlayed with Boundaries for Areas Served by KEC
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APPENDIX G
KEC'S Response to Staff s First Production Request, Request No. 14
CIPUC Case No. C07-E-25-01
First Production Request of Commission Staff
Request No. 14
Person Preparing Response: Julie Turbin, VP of Operations& Operational Services
Record Holder: Kootenai Electric Cooperative, Inc. ("KEC")
KEC Contact: Michael G. Andrea, General Counsel, [phone]
Request No. 14: Regarding the Company's risk assessment of its service territory,please
explain how the Company determined each level of risk identified as medium, high, or very high,
including the criteria and thresholds used to distinguish between each level of risk.
KEC Response: As stated in Section 2.1 of KEC's Wildfire Mitigation Plan:
KEC uses a combination of resources and data to determine specific geographical areas
that are considered to have a heightened risk of wildfire. First, as shown in Figure 3,
KEC utilizes data from Wildfire Risk to Communities.' This data rates the areas from
very low to very high, based on techniques developed to create various simulations
factoring in weather, topography, ignitions and vegetation. This data is then overlayed
with proprietary vegetation management software that produces further insight into how
those areas overlap within the KEC service area and infrastructure. This allows KEC to
better understand how the identified wildfire risk zones align with vegetation
encroachments and hazard trees and develop vegetation management goals to prioritize
heightened risk zones. Areas with denser vegetation are denoted on Figure 3 as
"Medium," "High,"and"Very High"Wildfire Risk Zones,which are areas that KEC
considers may be subject to a heightened risk of wildfire (Heightened Risk Areas). KEC
uses the information depicted in Figure 3 to prioritize vegetation management practices
and other work in Heightened Risk Areas.
' Wildfire Risk to Communities: Spatial datasets of landscape-wide wildfire risk components for the United States.
2nd Edition.Fort Collins,CO:Forest Service Research Data Archive available at: https://doi.orp-/10.2737/RDS-
2020-0016-2.

REDLINE
(for information only)

Kootenai Electric
COOPERATIVE
n,.
First Amended 2026-2028
WILDFIRE MITIGATION PLAN
December 31 202SOuly 9, 2026
9014 W.Lancaster Road I Rathdrum,ID 83858 © O
TEL [phone] TOLL FREE 800-240-0459 1 Fax [phone]
EMAIL [e-mail] I WEB kec.com

Table of Contents:
1. Introduction...........................................................................................................................................1
1.1 Purpose of the Wildfire Mitigation Plan ......................................................................................2
1.2 Definitions....................................................................................................................................2
2. Geographical Area Served by KEC and Areas that May Be Subject to Heightened Risk of Wildfire......3
2.1 Identification of Geographical Areas that May be Subject to Heightened Risk of Wildfire.........5
3. Preventive Actions and Programs to Reduce Risk of Wildfire.............................................................76
3.1 Grid Modernization....................................................................................................................745
3.2 Methods of Line Design for New, Planned, and Existing Lines to Mitigate Fire Risk...................7
3.3 Vegetation Management.............................................................................................................7
3.4 Development of Standards, Procedures, and Schedules for Inspection of KEC's Assets,
Infrastructure, and Facilities Within Heightened Fire Risk Areas..............................................................8
4. Fire Season Operational Guide..............................................................................................................8
4.1 Daily Situational Awareness.........................................................................................................8
4.2 Public Safety Power Shutoff(PSPS) Procedure..........................................................................12
4.3 Operational Action Index with Fire Danger Linkage ..................................................................13
4.3.1 Risk Monitoring and Forecasting...........................................................................................14
4.3.2 Risk Assessment and Initial Decision-Making........................................................................15
4.3.3 Notification &Coordination (Pre-Activation Phase: 72-24 Hours Out) ................................15
4.3.4 Final Decision and Activation (24-0 Hours Out)....................................................................16
4.3.5 Monitoring During a PSPS......................................................................................................17
4.3.6 Restoration Process After a PSPS...........................................................................................17
4.3.7 Post-Event Review..................................................................................................................17
5. Outreach and Communication............................................................................................................17
5.1 KEC Internal Processes to Guide Wildfire-Related Communication ..........................................17
5.2 Coordination with Federal, State,Tribal, and Local Agencies....................................................18
5.3 Member Communications.........................................................................................................18

Table of Figures:
Figure 1: Service Area Across Counties........................................................................................................4
Figure 2: Service Area Within the State of Idaho..........................................................................................5
Figure3 Heightened Risk Areas.....................................................................................................................6
Figure 4 Tempest System Daily Fire Risk Example (for Illustrative Purposes Only).......................................9
Figure 5 Daily Situational Awareness Table.................................................................................................10
Figure 6 DSAT Mitigation Levels..................................................................................................................11
Figure 7 Fire Danger/Operational Index......................................................................................................13
Figure 8 Fire Season PSPS Decision Making Process/Operational Table.....................................................14
Figure 9 National Weather Service Red Flag Weather Matrix, Eastern Washington and North Idaho.......16
Appendices:
Appendix A: Vegetation Management Plan ................................................................................................21
Appendix A-1:Vegetation Management Implementation Plan ..................................................................21
Appendix B: 2026-2028 Construction Work Implementation Plan.............................................................26
Appendix C: 2026-2028 System Inspection Implementation Plan..............................................................27
AppendixD: Resolution# 10-25..................................................................................................................28
AppendixE: Compliance Matrix .................................................................................................................28
Appendix F: Heightened Wildfire Risk Map Overlayed with Boundaries for Areas Served by KEC
Appendix G: KEC's Response to Commission Staff's First Product Request, Request No. 14
KOOTENAI ELECTRIC COOPERATIVE INC.WILDFIRE MITIGATION PLAN-PAGE 1 DECEMBER 31,2025

1. Introduction
Kootenai Electric Cooperative, Inc. (KEC), founded in 1938, is the largest of ten not-for-profit, member-
owned cooperative utilities in Idaho in terms of load and total customers served. With its main office in
Rathdrum, Idaho, KEC provides electric utility service to its members primarily in Kootenai County. It also
serves portions of Bonner and Benewah counties in Idaho, and Spokane County in Washington. KEC's
service territory is quasi-urban in nature with over half of its power lines being underground. While the
largest cooperative in the state in terms of load and customers served, other cooperatives are larger in
terms of miles of lines. KEC's mission is to provide its members with exceptional service and dependable
power at competitive rates.
1.1 Purpose of the Wildfire Mitigation Plan
The primary objective of KEC's Wildfire Mitigation Plan ("Plan") is to provide direction to staff with
regard to (i)the design, inspection, operation and maintenance of KEC's electrical system to mitigate
wildfire risk; (ii) coordination with federal, state,tribal, and local officials and agencies on wildfire
preparedness and emergency response plans; and (iii)outreach and public awareness efforts to be used
before, during, and after wildfire season to identify and inform the public of relevant wildfire risks and to
notify the public of wildfire-related outages. KEC's Plan utilizes a three-year planning horizon.
Specifically, KEC's Plan includes a rolling three-year Vegetation Management Implementation Plan,
Construction Work Implementation Plan, and System Inspection Implementation Plan that, respectively,
forecast the vegetation management, construction, and system inspection work for the next three
calendar years.
In March 2025,the State of Idaho enacted the Wildfire Standard of Care Act, Idaho Code§§ 61-1801 to
61-1808 (Act). Among other things, the Act affords electric cooperatives, like KEC, the ability to adopt
and file a wildfire mitigation plan with the Idaho Public Utilities Commission ("Commission")for review
and approval. KEC's Plan is designed to comply with the requirements of the Act.
Effective Date: Upon acceptance by the KEC board, KEC will take steps to implement this Plan and this
Plan shall remain in effect until such time as this Plan is superseded by a Commission-approved wildfire
mitigation plan or is superseded or rescinded by board action.
1.2 Definitions
Below are definitions of some frequently used terms.
Act:The Wildfire Standard of Care Act, Idaho Code §§ 61-1801 to 61-1808, as such Act may be
amended or superseded.
Commission:The Idaho Public Utilities Commission.
Construction Work Implementation Plan (CWIP): KEC's three-year rolling Construction Work
Implementation Plan referred to in Section 3.1 and attached as Appendix B to this Plan.
Construction Work Plan: KEC's Construction Work Plan referred to in Section 3.1 of this Plan.
Energy Release Component(ERC):The Energy Release Component is a number related to the
available energy(BTU) per unit area (square foot)within the flaming front at the head of a fire.
Daily variations in ERC are due to changes in moisture content of the various fuels present, both
live and dead, or Fire Potential Index model to assess local wildfire risks.
KOOTENAI ELECTRIC COOPERATIVE INC.WILDFIRE MITIGATION PLAN-PAGE 2 DECEMBER 31,2025

Heightened Risk Areas: Heightened Risk Areas are those areas identified in Section 2 of this
Plan that KEC considers may be subject to heightened risk of wildfire at the time this Plan is
finalized and may change due to changes in circumstances, including changes in weather.
Hot Line Tag:A setting in a recloser control that, when enabled, opens the recloser without
intentional delay when an overcurrent situation on the power line is detected by the control.
Incident Command Team (ICT):The Incident Command Team (ICT) is a key group of KEC staff
responsible for responding to the emergency and restoring service to KEC's members.
Non-Reclose:A setting in a recloser control that, when enabled, opens the recloser and prevents
the recloser from automatically closing, attempting to re-energize or restore power on the
power line.
OEM: Kootenai County Office of Emergency Management.
Particularly Dangerous Situations(PDS) Red Flag Warning: Issued by the National Weather
Service, indicating critically dangerous fire weather including high or gusty winds, high
temperatures, and low humidity.
Plan: This Wildfire Mitigation Plan.
Public Safety Power Shutoff(PSPS): A temporary power outage initiated by an electric utility to
reduce the risk of wildfires during extreme fire risk.
Recloser: A recloser is an automatic, high-voltage electric switch which de-energizes the
affected portion of the power system when a fault, such as a tree falling into an electric power
line, occurs.
Red Flag Warning: A Red Flag warning is issued by the National Weather Service,generally
indicating critical fire weather with sustained surface winds exceeding a 10-minute average of 15
mph combined with relative humidity (RH) less than 25%.
Supervisory Control and Data Acquisition (SCADA): A system combining hardware and
software elements to allow electrical utilities to control and monitor power system devices
remotely.
Vegetation Management Implementation Plan (VMIP): KEC's Vegetation Management
Implementation Plan referred to in Section 3.3 and attached as Appendix A-1 to this Plan.
Vegetation Management Plan (VMP): KEC's Vegetation Management Plan referred to in Section
3.3 and attached as Appendix A to this Plan.
2. Geographical Area Served by KEC and Areas that May Be Subject to Heightened Risk of
Wildfire
KEC serves approximately 38,000 meters across three counties in North Idaho and Eastern Washington.
To provide electric service to its members, KEC owns and operates approximately 940 line-miles of
overhead electric line and 1,500 line-miles of underground electric line. Figure 1 illustrates the areas that
are served by KEC in these four counties'and Figure 2 illustrates the general area that KEC serves within
the State of Idaho.
' Idaho does not have defined geographical service areas. The area shown in Figure 1 generally depicts the area
where KEC has infrastructure to serve its members; however,other electric utilities also serve their customers
within that same general area.
KOOTENAI ELECTRIC COOPERATIVE INC.WILDFIRE MITIGATION PLAN-PAGE 3 DECEMBER 31,2025

Kootenai Electric Coo erative Service TerTitga
Bonner
-�' County .---
`Spokane .:
Coun
tY �.
Kootenai
County
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-0j v'
-:... rj
Benewah
County
.Swmes Esn USGS.MOA.L �u,-�e.REsn,Garnr,
uacs_rrRs
Figure 1: Service Area Across Counties
KOOTENAI ELECTRIC COOPERATIVE INC.WILDFIRE MITIGATION PLAN-PAGE 4 DECEMBER 31,2025

Kootenai Electric Cooperative Service Territo
Bonner
County
Spokane 7'
County
Kootenai
County
BgnNe1waa'h
Idah
Figure 2:Service Area Within the State of Idaho
2.1 Identification of Geographical Areas that May be Subject to Heightened Risk of Wildfire
KEC uses a combination of resources and data to determine specific geographical areas that are
considered to have a heightened risk of wildfire. First, as shown in Figure 3, KEC utilizes data from
Wildfire Risk to Communities.z This data rates the areas from very low to very high, based on techniques
developed to create various simulations factoring in weather,topography, ignitions and vegetation.This
data is then overlayed with proprietary vegetation management software that produces further insight
into how those areas overlap within the KEC service area and infrastructure.This allows KEC to better
understand how the identified wildfire risk zones align with vegetation encroachments and hazard trees
and develop vegetation management goals to prioritize heightened risk zones. Areas with denser
z Wildfire Risk to Communities:Spatial datasets of landscape-wide wildfire risk components for the United States.
2nd Edition. Fort Collins,CO: Forest Service Research Data Archive available at: https://doi.org/10.2737/RDS-
2020-0016-2.
KOOTENAI ELECTRIC COOPERATIVE INC.WILDFIRE MITIGATION PLAN-PAGE 5 DECEMBER 31,2025

vegetation are denoted on Figure 3 as"Medium;' "High," and "Very High" Wildfire Risk Zones, which are
areas that KEC considers may be subject to a heightened risk of wildfire (Heightened Risk Areas). KEC
uses the information depicted in Figure 3 to prioritize vegetation management practices and other work
in Heightened Risk Areas.
ti E Athol '
Hayden i
Post Falls
Coeur d'Ale ,A
`3 Wildfire risk zones Plummer
Figure u u
r r �
Figure 3 Heightened Risk Areas
A Heightened Wildfire Risk Map overlayed with the boundaries of the areas that KEC serves is attached
hereto as Appendix F. Order No. 37081 at 12 (item v).
As indicated in Figure 3 above, virtually all of the areas served by KEC are medium, high, or very high
wildfire risk zones and therefore, as noted above, are considered Heightened Risk Areas. KEC prioritizes
capital protects, including protects that serve to mitigate the risk of wildfire, based on need considering
factors such as reliability, expansion to serve KEC's members, and the need to replace aging
infrastructure. Order No. 37081 at 12 (item vi).
KOOTENAI ELECTRIC COOPERATIVE INC.WILDFIRE MITIGATION PLAN-PAGE 6 DECEMBER 31,2025

3. Preventive Actions and Programs to Reduce Risk of Wildfire
3.1 Grid Modernization
KEC has developed its 2025-2029 Construction Work Plan Wildfire risk zones 0
(Construction Work Plan)to modernize its electric system. The
Construction Work Plan includes reasonably practical methods
for new, planned, and existing lines to, among other things, -
mitigate fire risk. The Construction Work Plan, is a five-year plan that includes projects to ensure that
power system has the capacity to meet the growing demands of the members served, and to modernize
the grid by replacing end of life equipment, enhancing reliability, and mitigating fire risk. Projects
included in the Construction Work Plan include:
• Replacing end of life oil circuit reclosers (OCR) and other strategically located reclosers with solid
dielectric,vacuum interrupted reclosers equipped with solid-state controls and advanced
protection schemes;
• Installing new solid dielectric, vacuum interrupted reclosers on KEC feeders originating from non-
KEC owned substations to provide advanced protection schemes;
• Installing, in strategic locations, solid dielectric insulated pad-mounted switchgear equipped with
operators and solid-state controls connected to the SCADA system to provide remote indication,
monitoring, and control; and
• Installing new protective feeder relays equipped with Arc Sense Technology(AST) in KEC owned
substations for high-impedance fault detection on distribution feeders.
The Construction Work Plan also includes finalizing the integration of a new SCADA system with an
existing Geographic Information System (GIS).This integration will set up the framework required to
deploy SCADA to feeder-level devices and perform Advanced Distribution Management System (ADMS)
functions. The additional ADMS functions include, among other things,the ability to remotely control
feeder level reclosers outside of substations, remotely adjust protection settings, and automatically
detect and isolate sections of the power system through Fault Location Isolation and System Restoration
(FLISR).
To implement its Construction Work Plan,each calendar year, KEC develops a Construction Work
Implementation Plan ("CWIP"). The CWIP provides a forecast of the work in the Construction Work Plan
that KEC intends to perform in each of the next three calendar years. KEC's CWIP is incorporated into
this Plan and is attached hereto as Appendix B.
3.2 Methods of Line Design for New, Planned,and Existing Lines to Mitigate Fire Risk
In addition to modernization discussed in Section 3.1 above, the Construction Work Plan includes steps
to harden KEC's electrical system with upgrades and design changes.These designs stem from
engineering experience and the adoption of emerging technologies. The Construction Work Plan
includes:
• The use of ductile iron poles for fire-resiliency construction of overhead distribution lines;
• The undergrounding of overhead distribution lines to improve reliability and eliminate the
impact of wind and tree related outages, which provides effective wildfire mitigation strategies;
and
• The replacement of traditional expulsion fuses with current limiting fuses,when possible, in
strategic high-risk wildfire zones to reduce the energy and potential ignition source for wildfires.
3.3 Vegetation Management
KOOTENAI ELECTRIC COOPERATIVE INC.WILDFIRE MITIGATION PLAN-PAGE 7 DECEMBER 31,2025

KEC has adopted a Vegetation Management Plan (VMP)to identify and control or eliminate vegetation
that threatens the integrity, reliability,or safety of the electrical facilities that are part of KEC's electrical
system. The VMP calls for the assessment of KEC's service territory every two (2)years and provides
wildfire risk analysis, hazard tree identification,tree segmentation, height and health analysis, 3D
vegetation risk scoring, and recommended work. Pursuant to the VMP,vegetation management is
performed in accordance with applicable federal, state, or local laws, regulations, or ordinances. KEC's
VMP is incorporated herein and is attached hereto as Appendix A.
To implement its VMP, each year KEC prepares a Vegetation Management Implementation Plan (VMIP).
The VMIP that is developed each year is a three-year rolling plan. That is,the VMIP that is developed in
each calendar year sets out the strategy, resources, and schedule for vegetation management to be
performed in the next calendar year as well as a projected schedule for the following two calendar years.
Each VMIP establishes the specific sections of KEC's electrical system (identified by specific feeders)that
are targeted for vegetation management in each calendar year. The VMIP is developed using
information available to KEC at the time the Implementation Plan is prepared. KEC will monitor
conditions and needs and may modify the implementation of its VMP in response to changes in
circumstances to the extent KEC deems necessary to provide for the safe, efficient, and reliable
distribution of electric power to KEC's members. KEC's 2026-2028 VMIP is attached hereto as Appendix
A-1.
3.4 Development of Standards, Procedures,and Schedules for Inspection of KEC's Assets,
Infrastructure,and Facilities Within Heightened Fire Risk Areas
In addition to the assessments performed in accordance with KEC's VMP (discussed in Section 3.3
above), KEC also performs inspections of its system in accordance with its System Inspection
Implementation Plan, which is attached hereto as Appendix C.
All inspection data is electronically recorded and tied to specific map locations. Recording this data
provides a centralized and accessible record of asset condition over time.This electronic system supports
maintenance and tracking of repairs.
KEC follows a time-based inspection cycle for system assets:
• Overhead and Underground Line Assets: Inspected on a 12-year cycle.
• Switchgear: Inspected on a 1-to 4-year cycle depending on asset type and location.
• Substations: Inspected monthly.
All defects identified during inspections are documented and routed to Operations for timely repair or
replacement.
4. Fire Season Operational Guide
4.1 Daily Situational Awareness
During periods when the National Fire Danager Rating is elevated to a level of High or greater(as defined
in Figure 7),daily morning briefings will be held (on normally scheduled workdays) by the Operations
Superintendents with the line crews and Operations staff to review the daily fire risk in the areas served
by KEC as indicated by the Tempest system. An example of the information provided by the Tempest
system is seen below in Figure 4.
KOOTENAI ELECTRIC COOPERATIVE INC.WILDFIRE MITIGATION PLAN-PAGE 8 DECEMBER 31,2025

ye
2 2
A 63 -,
4.
Figure 4Tempest System Doily Fire Risk Example(for Illustrative Purposes Only)
Based on the Tempest information, Operations Superintendents will review the Daily Situational
Awareness Tool (Figure S) and its associated mitigation strategies (Figure 6)' be|ovu
woorswm ELECTRIC COOPERATIVE INC.WILDFIRE MITIGATION PLAN PAGE oscsmama1,aoa

TEMPEST DAILY SITUATIONAL AWARENESS TOOL(DSAT)
KEC Operating Mitigation Condition'
General Activity Specific Description Normal Elevated
Vehicle travel on &off road. With A A A
no vehicle/vegetation contact
Vehicle
Operations Travel off-road or on unmaintained A Special
road with vehicle/vegetation A No parking Circumstances/Stage 2
contact. on dry grass Fire Restrictions
C
Heavy Dozers, graders, skid steers, Water Trailer or Water
Equipment Use/ trenchers, etc. All road A B Truck
Ground maintenance, water bars, pole hole Special
Disturbing Work drilling, etc. Includes all blasting. Circumstances/Stage 2
Fire Restrictions
C
Equipment maintenance or Water Trailer or Water
Construction and replacement. (Cross arms, pole Truck
maintenance of replacement, reconductor, A B Special
electric facilities substation, transformers, relays, Circumstances/Stage 2
meter maint/replacement, etc.)
Fire Restrictions
C
Vegetation
Vegetation clearing. A B Special
Management
Circumstances/Stage 2
Fire Restrictions
C
Cutting, All types of spark-producing
Grinding, cutting, grinding, or welding work. A B Special
Welding Circumstances/Stage 2
Fire Restrictions
Internal Use of equipment with combustion B
Combustion engines not covered elsewhere. A B
Engine Use Includes AN chainsaw, generator, Special
compressor, etc. Circumstances/Stage 2
Fire Restrictions
Figure 5 Daily Situational Awareness Table
'The Operating Mitigation Condition is established by the Tempest DSAT.
KOOTENAI ELECTRIC COOPERATIVE INC.WILDFIRE MITIGATION PLAN-PAGE 10 DECEMBER 31,2025

MITIGATION LEVELS FOR DSAT
Mitigation Level A Mitigation Level B Mitigation Level C Special Circumstances/
Stage 2 Fire Restrictions
Apply
1. Documented Safety 1. Work will stop until a 1. Work will stop until a Essential work only.
Tailboard prior to new Safety Tailboard is new Safety Tailboard Essential work is work
performing any work. completed any time fire is completed anytime that is approved by a
At minimum. one fire risk increases. fire risk increases. supervisor as essential
■ suppression hand tool 2. At minimum,two fire 2. At a minimum,one fire work. Except for
shall be within 100 suppression hand tools suppression hand-tool essential work that
feet of job site or shall be within 25 feet per crew member shall cannot be deferred,all
immediately available of job site for a crew be present at job site. other work will be
deferred to days with
when the work is not with multiple persons. 3. At a minimum,two KEC less critical fire risk.
stationary. 3. At a minimum,one KEC approved fire
2. Designated person to approved fire extinguishers shall be 1. Mitigations will be
call 911 in the event of extinguisher shall be available at the job site determined a
basis.
an ignition. available at the job site and every crew vehicle case-by-case b
and every crew vehicle shall have a filled 5- Fire risk mitigation
shall have a filled 5- gallon backpack water practices may not be
gallon backpack water pump at the job site or possible for some
pump within 25 feet of readily accessible on work activities,and
job site or immediately work that is not their continuance
available when work is stationary, i.e., access should be restricted.
not stationary. road maintenance.
■ Documented Fire 4. Designate a working
Watch person(s)as Fire Watch.
appropriate on Safety Check all work sites for
Tailboard. hot spots or
4. Designated person to smoldering embers for
call 911 in the event of 45 minutes after work
an ignition. activities have ceased.
■ Designated person to
call 911 in the event of
an ignition.
Figure 6 DSAT Mitigation Levels
KOOTENAI ELECTRIC COOPERATIVE INC.WILDFIRE MITIGATION PLAN-PAGE 11 DECEMBER 31,2025

Fire Restriction Stages:
KEC will comply with all fire restrictions in accordance with applicable law, including Idaho Code §§ 38-115, 38-
121, Idaho Admin. Code 20.04.01.080. Stage 1 and Stage 2 Fire Restrictions are posted on Idaho Department of
Lands' website and are available at: www.idi.gov/fire-management/fire-restrictions-finder.
4.2 Public Safety Power Shutoff(PSPS) Procedure
A Public Safety Power Shutoff is a temporary power outage initiated to reduce the risk of wildfires during extreme
fire risk.The two charts below (Figures 7 and 8) illustrate the PSPS decision making process and the operational
actions to be taken in each situation.4
a In addition to decisions to initiate a PSPS in accordance with this Plan, KEC will coordinate with applicable public agencies to
accommodate,where appropriate, requests from such public agencies to energize or deenergize KEC' s electrical system for
public safety.
KOOTENAI ELECTRIC COOPERATIVE INC.WILDFIRE MITIGATION PLAN-PAGE 12 DECEMBER 31,2025

4.3 Operational Action Index with Fire Danger Linkage
FIRE DANGER/OPERATIONAL INDEX
National Fire Danger Very High w/Red
s Modera ' High Very High - -
Rating �- _ Flag Warning
Weather and fuel Weather and fuel
Potential for large
conditions indicate conditions indicate Red Flag Warning
Fires spread rapidly fires exists. Fires
Weather and fuel some potential for some potential for and fires spread
Fire Danger/ and show erratic spread rapidly.
indicators show the fire occurrence. fire occurrence. rapidly and show
Operational Index behavior. Extreme fire
Definition probability of fire Expect predictable Expect predictable Dangerous burning erratic behavior. behavior is
occurrence is low. fire behavior with fire behavior with Dangerous burning
moderate rate of moderate rate of conditions exist. conditions exist. probable.Critical
conditions exist.
spread. spread.
Substation Circuit Automatic Reclose
Breaker Settings Automatic Reclose Non-Reclose on Red Non-Reclose Non-reclose Hot Line Tag Hot Line Tag
Flag Warning days
Normal until fault
Line Crew Patrol Normal until fault condition identified. All Outaged Lines Between Non-Reclose All Outaged Lines
Following Circuit Outage condition identified. On Red Flag Set Devices
Warning days all
outaged lines.
Non-Reclose
(to be Non-Reclose
Line Reclosers in accomplished as Non-Reclose Non-Reclose (potential for PSPS
Predetermined Hazard Automatic Reclose Automatic Reclose soon as reasonably (potential for PSPS at select locations
Areas at select locations) during Red Flag
practical after the
change in NFDRS). Warning).
No
Increased Number of
NO (with the exception of Red Flag yes Yes Yes Yes
'On Call' Personnel Warning days)
Pre-positioning of
Personnel During High
Wind or Fire Weather No No Yes
Events
Figure 7 Fire Danger/Operational Index
5 For purposes of this Plan,the National Fire Danger Rating( "NFDR" )shall be the applicable National Fire Danger Rating provided by the Coeur d' Alene
Interagency Dispatch Center posted at: https://gacc.nifc.gov/nrcc/dc/idcdc/.
KOOTENAI ELECTRIC COOPERATIVE INC.WILDFIRE MITIGATION PLAN-PAGE 13 DECEMBER 31,2025

PSPS Decision Making Process during Fire Season/Operational Table
Level NFDR Conditions Description Utility/Public Actions
0 No elevated fire risk. Normal operations. No action
Low Conditions needed.
Conditions are drying, mild
1 Moderate Elevated sustained winds forecasted. Situational awareness.
Fire weather being Internal utility monitoring.
monitored.'
High winds+ low humidity
2 High Watch forecast.' Fire weather is Notify agencies. Early public
awareness messaging.
likely.
Warning/
Weather event' likely. PSPS
3 Very High Advisory under consideration in high- Public alerts.
risk areas.
Very High PSPS Event PSPS highly likely in next 24— Final prep. Staging crews.
4 w/Red Flag Likely 48 hours if weather persists. Community readiness.
Warning
PSPS may be activated due Active outage.
- • • to imminent wildfire risk.
Communication+ restoration
-- planning.
Figure 8 Fire Season PSPS Decision Making Process/Operational Table9
4.3.1 Risk Monitoring and Forecasting
During periods where conditions are at Level 0 or Level 1 as set forth in Figure 8,Operations will
monitor:
• Weather forecasts and information, including:
o National Weather Service Regional Weather at:
https://www.weather.gov/otx/firedashboard.
o Tempest One weather stations with wind alert configuration via email and text.
o Tempest One Daily Situational Awareness Tool to determine best operational practices.
o Windy.com with Mapping Overlay to determine time and duration of wind events.
e Fire weather refers to weather conditions that create a higher risk of fire generally due to higher temperatures,
lower relative humidity,and/or high winds.
'High wind means generally sustained winds over 20 mph and/or wind gusts exceeding 30 mph. Low humidity is
generally when the relative humidity is below 20%,which creates drier fuels and increased fire potential.
8 Weather events are extreme weather conditions, such as high temperature and low humidity combined with high
winds,create or exacerbate the potential for wildfires.
9 This Figure 8 is intended to be used solely as a tool to aid the decision-making process to determine whether and
when to activate a PSPS. Decisions whether and when to activate a PSPS will be made by Incident Command
pursuant to Section 4.3.4 of this Plan.
KOOTENAI ELECTRIC COOPERATIVE INC.WILDFIRE MITIGATION PLAN-PAGE 14 DECEMBER 31,2025

• Remote sensing, weather stations, and satellite imagery to identify high-risk areas.t'
• Fuel moisture levels, including Dry Vegetation/Fuel Moisture Criticality: Dry grasses, shrubs, and
trees, based on local fuel moisture readings.Typically,when the moisture level of 1000-hour
fuels are at or below 11%, 100-hour fuels are at or below 8%and live fuels at or below 120%.
• Northern Rockies Coordination Center 1000-hour Fuel moisture graphs and the 100-hour Fuel
moisture.
• The Burning Index at : https://gacc.nifc.gov/nrcc/predictive/fuels fire-danger/fuels fire-
danger.htm.
4.3.2 Risk Assessment and Initial Decision-Making
During periods where conditions are at Level 2 or Level 3 as set forth in Figure 8,the PSPS Planning
Committee (Operations, Safety, Legal,Communications) will conduct impact analysis regarding a
potential PSPS, including analysis of:
• The number of members who may be affected, and
• Whether any critical infrastructure (hospitals, emergency services, water systems) may be
affected.
Grid Operations will also evaluate:
• Any Fire Weather Watch issued by the National Weather Service A Fire Weather Watch is issued
when there is a high potential for the development of a Red Flag Warning due to:
o Abundant lightning and dry fuels,
o Sustained surface winds exceeding 15 MPH and relative humidity (RH) less than 20%in
the valleys, RH less than 25% in the mountains,
o low RH of 15%or less, and/or
o an unusually unstable atmosphere.
• Alternatives to PSPS(e.g.,grid rerouting,temporary barriers)
• Potential duration of any PSPS and restoration times
• Whether and when to make initial recommendations to proceed to pre-activation phase (See
Section 4.3.3).
4.3.3 Notification &Coordination (Pre-Activation Phase:72-24 Hours Out)
During periods where conditions are at Level 3 or above as set forth in Figure 8, in addition to the
activities set forth in Section 4.3.2 above, ICT will notify OEM who will notify the following, as applicable:
• Local, county,and state emergency agencies
• Tribal governments and public safety partners
• Hospitals and critical infrastructure
The Incident Command Team (ICT)will also begin public outreach, including:
• Notifying the media and public via website, text, email, automated calls, and social media and,
as applicable:
o Explaining potential PSPS zones
o Providing resources and preparation tips
0 Details about KEC's weather station network are provided in KEC's response to Commission Staff's First
Product Request, Request No. 14,which is attached hereto and incorporated herein as Appendix G. Order No.
37081 at 13 (item(ix).
KOOTENAI ELECTRIC COOPERATIVE INC.WILDFIRE MITIGATION PLAN-PAGE 15 DECEMBER 31,2025

• Contacting Kootenai County Office of Emergency Management(OEM)to coordinate the set-up
of public resource centers(if needed)
4.3.4 Final Decision and Activation (24-0 Hours Out)
During periods where conditions are at Level 4 and Level 5 as set forth in Figure 8,the Incident
Command Team (ICT) will reassess conditions in real-time, including:
• Fire Weather Watch conditions,
• Red Flag Warning: Issued by the National Weather Service 24 hours in advance, indicating critical
fire weather(high winds+ low humidity). Sustained surface winds exceeding a 10-minute
average of 15 mph combined with relative humidity less than 25%, and
Red Flag Warning Particularly Dangerous Situation (PDS): Issued by the National Weather
Service, indicating critical fire weather(high winds+ low humidity) (See Figure 9):
o Conditions last 3+ hours, 1000-hour fuels 10%or less
o Energy Release Component(ERC) in the 90th percentile or higher(see 4.3.8 below)
o Little to no rain past 30-90 days with less than .10 inches
o Wind speeds 30 mph or greater
o Wind gusts over 40 mph
o Exception will be made when relative humidity is less than 10%.
For Eastern WA and North Idaho
Red Flag Weather Matrix
Dry Fuels with(Low RH+Winds)for at least 2 hours
--� Relative Humidity ARMW Racmd dy Wind Onts'
tars fU•I s 36%
RH:30-40% RH:25.30% RH:20-25% RH:15-20% RH.10-15% RH:less
-ruider ConsiUer a " Minimum PDS Prerequisites
Co ',. v- .,.
G>70 mph RFYI RFW
Conditions last 3+hours
N G>25 moh NO mmussin pFWer t4 R(W Rr
to " -.' -`<..- 1000 HR 10%or less
o
ERCs 90th percentile or higher
C Con ide
20-30 mph Hlountai❑ Ccnsltlrr M -
G>30 mph RFN r Rrw Little to no rain past 30-90 days(<.10')
>30 mph Co"sidn ;;vw - Wind speed 30 mph or greater
G>40 mph R=++ 1Mind gusts>40 mph
--— (exception when RH Was then 10%)
>30 mph ePN 4 N
G>50 mph - ?lie F•xe:r,b its Ma.ru.w pn11 RH<30%
Low-Maro nal:consider Ir Low- Marginal
mountain(25%)vsvaley C_ Headline Headline ROD4gWamL.
(20%)humidity&fuel status
Figure 9 National Weather Service Red Flag Weather Matrix, Eastern Washington and North Idaho
• Confirm weather severity and fire risk
• Make final decision to activate PSPS and de-energize circuits.
The General Manager, or designee, will make the final decision to initiate a PSPS based on the
recommendation of the ICT.
If a PSPS is initiated, the ICT:
• Will direct the opening of devices to de-energize affected lines, and
KOOTENAI ELECTRIC COOPERATIVE INC.WILDFIRE MITIGATION PLAN-PAGE 16 DECEMBER 31,2025

• Confirm with field teams that de-energization has occurred safely.
4.3.5 Monitoring During a PSPS
During any PSPS,the ICT will take, or will direct,the following steps until restoration is complete:
• Patrol and monitor de-energized lines for safety hazards,
• Coordinate with emergency services for any incidents,
• Take reasonable steps to identify and provide on-site support for critical members, and
• Provide public regular updates, including estimated restoration times (if available).
4.3.6 Restoration Process After a PSPS
After the ICT determines that a PSPS is no longer necessary,Operations will begin the re-energization
protocol. Under the re-energization protocol, Operations will:
• Conduct line inspections,
• Clear vegetation and hazards,
• Verify system integrity and readiness, and
• Restore power.
Communications will take steps to notify customers of restoration progress.
4.3.7 Post-Event Review
As promptly as reasonably practical after a PSPS has occurred and restoration is complete, the PSPS
Review Management Team (which will include representatives from all teams involved in the PSPS event)
will conduct an internal after-action review. The internal after-action review will include a review of the
following:
• Response timeline,
• Communication effectiveness,
• System and personnel performance, and
• Public and agency feedback.
Upon completion of the internal after-action review, the PSPS Review Management Team will create an
after-action report and, if necessary, will update the PSPS process/procedures in this Plan based on
lessons learned.
5. Outreach and Communication
5.1 KEC Internal Processes to Guide Wildfire-Related Communication
KEC will adhere to established internal processes for wildfire-related communication. KEC will share
information about its Wildfire Mitigation Plan, including details on PSPS,with members, employees,the
public, the media, and other stakeholders (including federal, state, tribal, and local agencies).
KEC will,to the extent practical, communicate any anticipated or actual PSPS with any neighboring utility
that may be impacted by the PSPS. KEC anticipates that neighboring utilities will similarly share
information regarding any anticipated or actual de-energization that will impact KEC. To the extent that
KOOTENAI ELECTRIC COOPERATIVE INC.WILDFIRE MITIGATION PLAN-PAGE 17 DECEMBER 31,2025

KEC obtains information from another utility regarding any de-energization that will impact KEC, KEC will
integrate such information in its operational planning."
5.2 Coordination with Federal,State,Tribal,and Local Agencies
5.2.1 Annual Coordination Meeting
Prior to May 1 of each calendar year, KEC will schedule and host (or if a similar meeting is scheduled and
hosted by another entity, participate in) a meeting ("Annual Coordination Meeting") with, as applicable,
federal, state, tribal, and local officials and agencies to coordinate on wildfire preparedness and
emergency response plans. To the extent that KEC schedules and hosts the Annual Coordination
Meeting, KEC will invite applicable federal, state, tribal and local officials and agencies, including without
limitation, the OEM, Kootenai County Fire Chiefs, Coeur d'Alene Tribe Police Chief, and the Idaho
Department of Lands to the Annual Coordination Meeting. The Annual Coordination Meeting may be
held in person or virtually or both.
5.2.2 Communication of Changes in Operating Condition
Whenever the NFDRS rises to "High" or above (or a Red Flag Warning Day), KEC will notify OEM,the
Coeur d'Alene Tribe Polce Chief, and Idaho Department of Lands of a potential of a change in operating
condition.
5.2.3 Communications with OEM Regarding PSPS
With regard to PSPS, KEC will notify OEM as follows:
• At any time that KEC determines whether a PSPS is likely or imminent, KEC will notify OEM of
the potential of a PSPS and the potential areas on KEC's electrical system that may be
affected by a PSPS.
• When there is a PSPS, KEC will notify OEM that a PSPS has occurred,the areas on KEC's
electrical system that are impacted by the PSPS and, if available, an estimate of how long the
PSPS will be in effect.
• When the event requiring a PSPS has passed and KEC begins the restoration process, KEC will
notify OEM that it has commenced restoration and, if available,will provide an estimate of
how long it will take for KEC to restore its electrical system.
• Upon completion of the restoration process after a PSPS, KEC will notify OEM that
restoration is complete.
Upon notification from KEC, OEM will notify other state and local agencies.
5.3 Member Communications
KEC's wildfire-related communication goals are as follows:
• Educate members about KEC's approach to wildfire prevention and mitigation.
• Inform members about the current wildfire conditions and any actions that KEC may take to
mitigate wildfire risk, including any operational conditions/limitations on KEC's system and any
PSPS.
• Prepare members for PSPS or other wildfire-related outages, including reminders to update
their contact information, report outages, access updates on system conditions/outages, and
access safety/preparedness tips.
li The only other utility in the area that is likely to impact KEC's operations is Avista Corporation.
KOOTENAI ELECTRIC COOPERATIVE INC.WILDFIRE MITIGATION PLAN-PAGE 18 DECEMBER 31,2025

Before the wildfire season begins, KEC will communicate broad messages about safety and preparedness
to KEC's membership.As weather events or system changes occur, KEC will direct more targeted
messages to members affected by the changes. Below are the communications channels used to share
wildfire and outage related messages to KEC's members:
• Powerl-ines monthly member newsletter, which is included in member billing statements (an e-
version is also sent to all member email addresses).
• KEC's website: www.kec.com.This is a source of information and education about wildfire,
safety, and outages for members. It is updated regularly.
• Social media: KEC regularly updates its Facebook and Instagram pages with timely information
and updates about outages, safety and wildfire.
• News releases are used as needed to provide information to local media outlets.
• KEC sends an annual wildfire email to all members. KEC also sends targeted emails and/or
text/SMS to members affected by outages.These methods will also be used to communicate
with members that may be affected by a fire mitigation mode adjustment or a PSPS.
Due to KEC's rate structure, members with needs or infrastructure that they deem to be critical are
expected to provide their own redundancy and/or backup to provide power in the event of de-
energization. Therefore, KEC currently does not identify any critical infrastructure and/or members. To
the extent KEC identifies any critical infrastructure and/or members in the future, KEC shall maintain a
list of such critical infrastructure and/or members and shall provide targeted communications to such
critical infrastructure and/or members via email,text/SMS, or other appropriate communication
method.
6. Cost Evaluation; Cost-Benefit Approach
The Wildfire Standard of Care Act requires wildfire mitigation plans to identify a means for mitigating
wildfire risk that reflects a reasonable balancing of mitigation costs with the resulting reduction of
wildfire risk. This includes financially prudent and reasonably practicable methods of line design for new,
planned, and existing lines to mitigate fire risk.12
In Order No. 36774, the Commission ordered that electric corporations must(i) explain how an electric
corporation's line design methods reduce the potential for wildfire ignition, including a cost evaluation,
and (ii) include a cost benefit analysis in their proposed wildfire mitigation plans that justifies the
expenditures for risk mitigation described in such wildfire mitigation plans.13 The costs incurred by KEC,
including costs incurred pursuant to its construction work plan,vegetation management plan, and
inspection plan, are incurred for multiple purposes. Those purposes include, among other things,
extending service to members, enhancing reliability, replacing outdated infrastructure, and wildfire
mitigation. It is not possible to determine the amount of each expenditure that is properly allocated to
wildfire mitigation as opposed to some other purpose. Accordingly, in evaluating any project, KEC
evaluates a//of the needs and benefits associated with the project to determine whether the costs of
the project are justified.
12 Idaho Code§61-1803(3).
13 Order No.36774 at 20.
KOOTENAI ELECTRIC COOPERATIVE INC.WILDFIRE MITIGATION PLAN-PAGE 19 DECEMBER 31,2025

It is also not possible to obtain a precise calculation of the potential costs of future wildfires.14 As noted
by Idaho Power:
publicly available analyses of recent wildfires illustrate the magnitude of potential avoided costs
when prudent mitigation reduces the likelihood or consequences of catastrophic events. For
example, in Idaho, the Moose Fire in 2022— which grew to approximately 130,000 acres— cost
approximately$ 100 million to suppress, as did the Pioneer Fire in 2016.The Charlotte Fire in
Pocatello ( 2012) destroyed 66 homes, burned approximately 1,038 acres, and estimates at the
time gauged damages at$12 million,though officials noted that timely response helped protect
approximately$472 million in property value. In eastern Washington in 2023,the Gray and
Oregon fires together destroyed over 350 homes and caused multiple fatalities. Costs and
damages associated with the 2020 Idaho wildfire season alone are estimated between$100 to
$250 million.
In more catastrophic events outside of Idaho, the costs are exponentially higher.The recovery
costs of the Maui wildfires in 2023 are expected to exceed $ 2 billion, and in California, costs and
damages associated with the 2025 Los Angeles wildfires are estimated between$28. 0 billion
and $53. 8 billion."
This data supports the conclusion that the costs of KEC's wildfire mitigation efforts set forth in this Plan
are reasonable expenditures to avoid the potential costs associated with a wildfire.
KEC is a member-owned non-profit corporation. KEC is not a public utility subject to rate regulation by
the Idaho Public Utilities Commission. Rather, KEC is governed by its board of directors. KEC's board of
directors has reviewed this Plan and its costs of implementation and has determined that the Plan (i)
includes financially prudent and reasonably practicable methods of line design for new, planned, and
existing lines to mitigate fire risk; (ii) is feasible; and (iii) reflects a reasonable balancing of mitigation
costs with the resulting reduction of wildfire risk. KEC Resolution#10-25 is attached hereto as Appendix
D.
14 See Idaho Power Company's 2026 Wildfire Mitigation Plan,filed in Case No. IPC-E-25-32,at page 15
(stating: "Ultimately, Idaho Power found that obtaining a precise calculation of the potential costs of future
wildfires is not possible.").
15 Id. (internal footnotes omitted).
KOOTENAI ELECTRIC COOPERATIVE INC.WILDFIRE MITIGATION PLAN-PAGE 20 DECEMBER 31,2025

Appendix A
Vegetation Management Plan
Incorporation in Wildfire Mitigation Plan. This Vegetation Management Plan (VMP) is incorporated in,
and is part of, Kootenai Electric Cooperative, Inc's ("KEC")Wildfire Mitigation Plan.
Purpose. The purpose of vegetation management performed by KEC is to identify and control or
eliminate vegetation that threatens the integrity, reliability, or safety of the electrical facilities that are
part of KEC's electrical system ("KEC Facilities"). This VMP provides the general standards and guidelines
for KEC's performance of vegetation management.
VMP Implementation Schedule. Vegetation management includes pruning and removing tree and
brush species in the areas around KEC Facilities,the proper disposal of debris created by those activities,
and other steps necessary to identify and control or eliminate vegetation that threatens the integrity,
reliability, or safety of KEC Facilities. Each calendar year, KEC shall develop a VMP Implementation Plan
for the next calendar year. Each VMP Implementation Plan shall (i) identify the KEC Facilities (or
portions of the KEC electrical system)where vegetation management is scheduled to be performed in
the applicable calendar year; (ii)the resources that will be required to perform the scheduled vegetation
management(including the anticipated KEC personnel,total number of personnel hours, KEC
contractors, and equipment necessary to perform the scheduled vegetation management activities);
and (iii)the steps to be taken to document and report the work that is performed pursuant to the VMP
Implementation Plan Each VMP Implementation Plan will also include projected VMP Implementation
Plan for the calendar year immediately following the first calendar year. For example,the VMP
Implementation Plan that is developed in 2025, will include the VMP Implementation Plan for 2026 and
a projected VMP Implementation Plan for 2027.
Right-of-Way Clearing and Trimming. KEC's standard
practice is to maintain a 30-foot area around its overhead and
above-ground electric facilities operating at distribution
voltages. KEC's standard practice is to clear everything within ts' is,
fifteen (15)feet of the centerline of its overhead and above-
ground electric facilities operating at distribution voltages as
illustrated in the graphic below. KEC will perform vegetation
management in accordance with its standard practice of
clearing everything within fifteen (15)feet of the centerline
of the KEC Facilities, except as otherwise required by ,
applicable federal, state, or local laws, regulations, or
ordinances ("Applicable Laws"). In addition to clearing
everything within 15 feet of the centerline of the KEC
Facilities, KEC will also remove any hazard trees as discussed
herein.
Figure 1 ROW Clearances
In those circumstances where clearing in
accordance with the standard practice stated above is either not permitted or is impractical, pruning will
be performed in a manner that is consistent with best management practices as published by the
International Society of Arboriculture (ISA)guidelines, including ANSI A300, applicable OSHA
KOOTENAI ELECTRIC COOPERATIVE INC.WILDFIRE MITIGATION PLAN-PAGE 21 DECEMBER 31,2025

requirements, and all Applicable Laws. Such pruning will be performed to remove dead/dying branches
and other parts overhanging, encroaching, or otherwise threatening any KEC Facilities.
Vegetation Management Practices
• Residential:Vegetation that is cleared or pruned will be masticated. Debris will not obstruct
roads, ditches, or drains.To the extent practical, KEC will discuss any pruning or clearing of
ornamental plantings with landowners before work begins.Topping is not an accepted practice.
• Rural and Undeveloped Areas:Vegetation that is cleared or pruned will be masticated, and
scattered. Live and dead trees will be felled and arranged parallel to power lines without
blocking roads, streams, or ditches.
System-Wide Assessment Using Al &Satellite Imaging. KEC will assess its electrical system every two
(2)years using an AI-powered vegetation intelligence system,which provides wildfire risk analysis,
hazard tree identification, tree segmentation, height and health analysis, 3D vegetation risk scoring, and
recommended work prioritization.
The Encroachment Risk Rating system classifies vegetation risks as:
1. High (0-3 feet from conductor)
2. Medium (3-6 feet)
3. Low(6-10 feet)
4. Minor
5. Clear
Vegetation Management Schedule and Prioritization.
KEC performs vegetation management on a seven (7)year cycle in accordance with its VMP
Implementation Plan. Vegetation management to be performed in each year of the cycle shall be
included in the VMP Implementation Plan for such year and will be organized by feeder and prioritized
based on historical outage frequency and duration. Vegetation management that is required to be
performed in a calendar year that is not included in the VMP Implementation Plan for that year
(including, service order work) is prioritized based on an assessment of the Encroachment Risk Rating as
follows:
• Priority 1 (High Encroachment Risk):Addressed within the year identified.
• Priority 2 (Medium Encroachment Risk):Addressed after Priority 1 within two (2)years after
identified.
• Priority 3& 4 (Low and Very Low Encroachment Risk):Addressed in the normal course within the
seven (7)year cycle.
Hazard Tree Mitigation. Hazard trees are trees that are identified as dead,dying, or structurally
damaged that pose a risk to KEC Facilities. Hazard trees outside a right-of-way that present a fall risk
are continuously evaluated and prioritized for removal. Priority is assigned based on U.S. Forest Service
wildfire zone data. KEC's field planners will assess the Encroachment Risk Rating of each hazard tree that
is identified and will assign work accordingly. KEC will, in accordance with KEC's Vegetation
Management Policy, remove any hazard tree that is outside the right-of-way(or outside of the 30-foot
KOOTENAI ELECTRIC COOPERATIVE INC.WILDFIRE MITIGATION PLAN-PAGE 22 DECEMBER 31,2025

area cleared of vegetation in accordance with KEC's standard practice) if such hazard tree reasonably
threatens KEC's facilities.
Member-Reported Service Orders&Emergency Response. Member-reported concerns will be assessed
by a KEC representative. If the request involves vegetation that is encroaching on any KEC Facilities,
work will be performed per specifications and this Vegetation Management Plan.
Underground Structures. KEC's crews must be able to inspect utility equipment at all times. Any
obstruction that impedes access to KEC facilities will be removed to allow immediate access.
Cleanup. Logs that are left after performing vegetation management will be cut into tree lengths, unless
the member/landowner requests that such logs be cut into firewood lengths. Stumps will be cut as
close to ground level as practical.Stump removal is not performed by KEC.All wood is left for property
owners. Brush and limbs from live trees will be chipped or lopped and scattered,while those from dead
trees will be left for the property owner.
Secondary Line Trimming. Members are responsible for vegetation management for secondary service
lines. KEC does not generally perform vegetation management for secondary service lines, but KEC may,
in its sole discretion, perform such vegetation management. KEC will provide line drops free of charge
for members to trim trees affecting secondary service lines.
Member Communication. Members will be notified before circuit trimming begins. KEC will make
reasonable efforts to notify other(non-member) landowners. In the event that any landowner(member
or non-member) denies KEC access to perform vegetation management in accordance with this
Vegetation Management Plan, KEC will provide such landowner notice in accordance with the Wildfire
Standard of Care Act of its intent to access and perform vegetation management.
Compensation for Live Marketable Timber on Timber Company Land. Pursuant to the Act, "(ilf live
marketable timber is identified for removal from timber company land adiacent to the right-of-way,
compensation at fair market value shall be made to the landowner for such timber." I.C.§61-1803(3)(00).
With regard to KEC's determination of such fair market value, KEC incorporates its response to Commission
Staff's First Product Request, Request No.4, which is attached hereto as Exhibit 1 to this VMIP. Order No.
37081 at 13 (item viii).
Conclusion.This document serves as KEC's official Vegetation Management Plan. This Vegetation
Management Plan is supported by KEC's Vegetation Management Policy,Vegetation Management
Procedure,which reference and guide vegetation management activities.
KOOTENAI ELECTRIC COOPERATIVE INC.WILDFIRE MITIGATION PLAN-PAGE 23 DECEMBER 31,2025

Exhibit 1
Vegetation Management Plan
KEU S Response to Staff s First Production Request, Request No. 4

Exhibit 1 to Vegetation Management Plan
KEC'S Response to Staffs First Production Request. Request No. 4
IPUC Case No. CO7-E-25-01
First Production Request of Commission Staff
Request No. 4
Person Preparing Response: Julie Turbin, VP of Operations& Operational Services
Record Holder: Kootenai Electric Cooperative, Inc. ("KEC")
KEC Contact: Michael G. Andrea, General Counsel, [phone]
Request No. 4: Please describe the Company's process for compensating timber land owners for
the marketable timber. In your response, indicate whether compensation is also provided to
private owners, Idaho state agencies,tribal entities, or other entities, and explain any differences
in treatment.
KEC Response: The Wildfire Standard of Care Act("Act")requires compensation for
marketable timber identified for removal from timber company land adjacent to rights-of-way.
I.C. § 61-1803(3)(g)(iii). The Act does not require a process for compensating landowners and
does not address compensation to any other landowners and, therefore, to the extent that this
request seeks information regarding a process for compensation and/or compensation to other
landowners, the requested information is beyond the scope of this proceeding. Notwithstanding
the foregoing, KEC provides the following information in response to Staff s request:
To KEC's knowledge, KEC does not have any facilities on timber company land that will require
removal of marketable timber and does not contemplate the need to remove any live marketable
timber from timber company land adjacent to any rights-of-way. In the unlikely event that KEC
does need to remove marketable timber from timber company land adjacent to its rights-of-way
in the future, KEC will, if appropriate,work collaboratively with the landowner to determine fair
compensation.
KEC does not provide compensation for marketable timber removed from its rights-of-way
(ROW). When timber removal is necessary, KEC makes reasonable efforts to cut the trees into
log lengths and leave them on site for the landowner's use or disposal. See KEC's Wildfire
Mitigation Plan at Appendix A(stating: "Logs that are left after performing vegetation
management will be cut into tree lengths, unless the member/landowner requests that such logs
be cut into firewood lengths."). This practice is applied consistently regardless of whether the
landowner is a private individual, a state agency, a tribal entity, or another type of landowner.

Appendix A-1
2026-2028 Vegetation Management Implementation Plan
Vegetation Management Implementation Plan 2026-2028
Overview This Vegetation Management Implementation Plan (VMIP) outlines how Kootenai Electric
Cooperative, Inc. (KEC) will operationalize its Vegetation Management Plan (VMP) over a three-year
period. This plan reflects KEC's commitment to safety, reliability, mitigation, regulatory compliance, and
stewardship of its rights-of-way through best practices.
Staffing Structure
• Planners: 3
o Planners will inspect circuits prior to crew mobilization. Using Overstory satellite data,
planners will assess hazard trees, identify high-risk wildfire zones, and engage with
members and landowners to communicate the scope of work.
• Crews: 9 total
0 1 Crew for system-wide Hazard Tree mitigation
0 1 Crew for member-requested vegetation work(tree tickets)
0 7 Crews dedicated to circuit-based vegetation management
Vegetation Management Strategy For each circuit:
1. Planners will evaluate Overstory data to prioritize hazard tree removal.
2. Work will begin in high wildfire risk areas with encroachment.
3. One crew will begin at the substation and proceed downline; the second crew will begin at the
identified priority locations.Then start circuit trimming at designated location.
Crew Assignments by Year
• Crew 1: Hazard trees(system-wide, ongoing)
• Crew 2: Member tree tickets (ongoing)
• Crew 3:
o Julia Street:Jan 2026—Dec 2026
o Scarcello: 2027—2028+
• Crew 4:
o Pleasant View:Jan 2026—Dec 2027
o Scarcello: 2028+
• Crew 5:
o Pleasant View:Jan 2026—Dec 2027
o Scarcello:Jan 2027—Dec 2028
• Crew 6:
o Athol:Jan 2026—Oct 2026
o Beck Road: Nov 2026—Oct 2027
o Hayden: Nov 2027—Dec 2028
• Crew 7:
o Athol:Jan 2026—Oct 2026
o Beck Road: Nov 2026—Nov 2027
o Hayden: Dec 2027—Dec 2028
KOOTENAI ELECTRIC COOPERATIVE INC.WILDFIRE MITIGATION PLAN-PAGE 24 DECEMBER 31,2025

• Crew 8:
o Plummer:Jan 2026—Jul 2026
o Setters: Aug 2026—Dec 2027
o Rathdrum: 2028+
• Crew 9:
o Plummer:Jan 2026—Jul 2026
o Setters: Aug 2026—Dec 2027
o Ogara: 2028+
Documentation & Reporting KEC will use Inspection software to document all vegetation management
activities in the field.This includes:
• Tree work progress (pruning, removals, hazard tree mitigation)
• Location-specific data, including GPS coordinates and condition assessments
• Real-time status updates and digital checklists for crew accountability
Work completed will be audited using drone-based LiDAR data, which will be analyzed to ensure
compliance with KEC specifications, clearance standards, and right-of-way maintenance requirements.
These audits will support continuous quality assurance and help validate contractor performance and cycle
effectiveness.
Resource Planning KEC will estimate the number of personnel and labor hours required to complete each
year's scheduled work and will staff crews accordingly. These estimates will be informed by historical
workload and circuit characteristics. Every two years, following receipt of updated Overstory Al and
satellite vegetation data, resource requirements will be re-evaluated and adjusted as needed to ensure
alignment with vegetation growth patterns, encroachment risk trends and hazard tree counts.
Projected expenditures for right-of-way(ROW) clearing are as follows:
• 2026:$5,686,609
• 2027:$5,857,207
• 2028: $6,032,923
Review Cycle This Implementation Plan will be reviewed and updated annually in conjunction with the
VMP and will include projections for the subsequent three calendar years. Adjustments will be based on
Overstory assessments, work audits, member requests, and unplanned events such as storm response or
wildfire emergencies.
This document supports and aligns with KEC's Vegetation Management Plan and associated policies and
procedures.
KOOTENAI ELECTRIC COOPERATIVE INC.WILDFIRE MITIGATION PLAN-PAGE 25 DECEMBER 31,2025

Appendix B
2026-2028 Construction Work Implementation Plan
This Construction Work Implementation Plan ("CWIP") includes the estimated annual budgets for
construction projects for calendar years 2026-2028.The projects included in this CWIP will mitigate
wildfire risk. These system improvement projects are also planned for reasons other than wildfire
mitigation including to support KEC's forecasted growth, to enhance the reliability of KEC's electrical
system, to improve grid resiliency, and to replace end-of-life equipment.
Project Type Estimate Estimate Estimate Estimate
New Consumers - Underground $4,208,013 $4,397,374 $4,595,256 $13,200,643
New Consumers -Overhead $87,372 $91,304 $95,413 $274,089
New Tie Lines $0 $1,275,048 $2,643,929 $3,918,977
Conversion& Line Upgrades $20,240,767 $7,483,515 $5,178,511 $32,902,793
New Substations $176,655 $6,879,758 $4,564,665 $11,621,078
Substation Upgrades, Inside Sub Fence $3,747,242 $2,500,370 $3,594,673 $9,842,285
Meters $1,153,149 $1,205,041 $1,259,268 $3,617,458
Sectionalizing $2,217,142 $1,904,128 $1,929,332 $6,050,602
Voltage Regulators and Controls $3,239,500 $3,385,278 $798,816 $7,423,594
Capacitor Banks and Controls $104,500 $109,203 $114,117 $327,820
Pole Replacements $836,000 $873,620 $912,933 $2,622,553
Miscellaneous Replacements $2,296,910 $1,493,890 $1,561,115 $5,351,915
Road Moves $522,500 $546,013 $570,583 $1,639,096
Transmission Lines $9,642,905 $4,745,190 $0 $14,388,095
Security Lights $156,750 $163,804 $171,175 $491,729
Transmission Pole Replacements $52,250 $54,601 $57,058 $163,909
Minor Projects $3,448,500 $3,603,6831 $3,765,8481 $10,818,031
Pursuant to Commission Order No. 37081,the following responses to Commission Staff's requests for
production are attached hereto and incorporated herein:
• KEC's response to Commission Staff's First Product Request, Request No. 1, including the
detailed list of known projects used by KEC to refine its 2026-2028 budget estimates and
information is attached to this Appendix B as Exhibit 1. Order No. 37081 at 12 (items i, iii, and
vii .
• KEC's response to Commission Staff's First Production Request, Request No. 11, regarding
metrics used by KEC for measuring efficacy of its grid hardening is attached to this Appendix B as
Exhibit 2. Order No. 37081 at 12 (item iv).
• KEC's responses to Commission Staff's Second Production Request, Request Nos. 15 and 16,
regarding grants awarded to KEC are attached to this Appendix B as Exhibit 3. Order No. 37081
at 12 (item ii).
KOOTENAI ELECTRIC COOPERATIVE INC.WILDFIRE MITIGATION PLAN-PAGE 26 DECEMBER 31,2025

Exhibit 1
2026-2028 Construction Work Implementation Plan
KEC's Response to Staff s First Production Request, Request No. 1
(including Exhibit A)

Exhibit 1 to 2026-2028 Constriction Work Implementation Plan
KEC'S Response to Staff s First Production Request. Request No. 1 (including Exhibit A)
IPUC Case No. CO7-E-25-01
First Production Request of Commission Staff
Request No. 1
Person Preparing Response: Scott Davis,VP Engineering
Record Holder: Kootenai Electric Cooperative, Inc. ("KEC")
KEC Contact: Michael G.Andrea, General Counsel, [phone]
Request No. 1: Idaho Code § 61-1803(3), § 61-1803(3)(b), and § 61-1803(3)(e)address preventative
actions and programs, as well as methods of line design. The Commission's WMP Guidelines for
Idaho Code § 61-1803 (3)(e), Method of Line Design, states: "Financially prudent and reasonably
practicable methods of line design for new,planned, and existing lines to mitigate fire risk."
The Guidelines further state: "The electric corporation must describe how its methods of line design
for new lines and planned upgrades reduce wildfire ignition potential in heightened wildfire risk
areas. This must include evaluation of costs to wildfire risk reductions.Additionally,this must
include how the electric corporation clearly identifies, selects, and evaluates projects that reflect a
balance of mitigation costs with resulting reduction in wildfire risk."
Appendix B of the Company's Wildfire Mitigation Plan("WMP")provides project types and
budgets for 2026-2028.Further, Sections 3.1 and 3.2 describes the potential Grid Modernization and
Methods of Line Design initiatives. For each project type in Appendix B,please identify specific
known projects used to develop the 2026-2028 budget estimates and provide the following
information for each project:
a.Project type;
b. Project name;
c. Brief description of the project;
d. Estimated cost of the project(could be a range);
e. Targets of the project(e.g.,miles, number of assets installed/replaced);
f. Explanations of the benefits of this project;
g.Alternatives considered and explain why this was chosen as the best alternative;
h. Cost/benefit considerations; and
i. Estimated completion date.
KEC Response:
The Wildfire Standards of Care Act("Act") requires wildfire mitigation plans to identify a means for
mitigating wildfire risk that reflect a reasonable balancing of mitigation costs with the resulting
reduction of wildfire risk and requires the Commission to consider the feasibility of the plan and the
cost of its implementation. See I.C. § 61-1803(3), 61-1804(l). The Act does not provide the
Commission with authority to regulate cooperatives', like KEC's,projects and/or costs and provides
no authority over costs to the extent that such projects,project benefits and/or project costs are not
related to wildfire mitigation. Therefore,to the extent that this request seeks information regarding
projects,project benefits, and/or project costs not related to wildfire mitigation,the requested
information is not relevant and is beyond the scope of this proceeding. Notwithstanding the
foregoing,KEC provides the following response.

The Construction Work Implementation Plan as presented in Appendix B of the WMP is a
snapshot of the financial work plan at the time of the WMP filing with IPUC. The detailed list of
known projects used to refine the 2026-2028 budget estimates and information as requested in
this response item are tabulated in Item 1 - Exhibit A.
With regard to subparts f and h of this request, KEC notes that KEC considers the benefits of all
projects, including,but not limited to, benefits associated with reliability, extending service to
members,replacing outdated infrastructure, and wildfire mitigation. Projects are rarely, if ever,
solely performed for any single reason, including wildfire mitigation. Rather, KEC considers all
attributes of any project. Furthermore, it is not clear what is needed for subpart h of this request
and how that is differentiated from the response that is provided in subpart f.
It is impossible to quantify the amount of any given project that should be attributed to wildfire
mitigation as opposed to any other benefit(s) of the project. More fundamentally, it is impossible
to predict or quantify the costs of a future wildfire.' However, even assuming that 100 percent of
KEC's projects and costs and benefits were solely attributable to wildfire mitigation(which they
are not), given the extremely high cost of wildfires as evidenced by recent wildfires, the benefits
of those projects would almost certainly always outweigh the costs.2
Note that the sum of cost values for the known projects in Item 1 -Exhibit A has been further
refined since the tabulation was provided in Appendix B of the WMP.
'See Idaho Power Company's Wildfire Mitigation Plan filed in IPC-E-25-32 at page 15 (stating: "Ultimately,Idaho
Power found that obtaining a precise calculation of the potential costs of future wildfires is not possible.").
2 See id. (noting costs of recent wildfires).

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Exhibit 2
2026-2028 Construction Work Implementation Plan
KEU S Response to Staff s First Production Request, Request No. 11

Exhibit 2 to 2026-2028 Construction Work Implementation Plan
KEC'S Response to Staff s First Production Request, Request No. 11
IPUC Case No. CO7-E-25-01
First Production Request of Commission Staff
Request No. 11
Person Preparing Response: Scott Davis, VP Engineering
Record Holder: Kootenai Electric Cooperative, Inc. ("KEC")
KEC Contact: Michael G. Andrea, General Counsel, [phone]
Request No. 11: Please list and describe the Company's metrics for measuring the efficacy of its
grid hardening. In addition,please explain if the Company currently or plans to measure the
effect of its grid hardening efforts relative to System Average Interruption Duration Index,
System Average Interruption Frequency Index, Customer Average Interruption Duration Index,
and/or Momentary Average Interruption Frequency Index.
KEC Response: KEC follows the IEEE 1366 standard for tracking SAIDI, SAIFI, CAIDI, and
CEMI reliability metrics for all outages. These metrics are tabulated and graphed on a quarterly
basis for a rolling 12-month dataset that includes major event days and then for another rolling
12-month dataset that does not. The tabulation and graphical information also illustrate the
system reliability performance by sub and by feeder level which allows measurements to be
made on reliability improvement for grid hardening projects complete on each substation and
feeder level.
KEC currently targets substation feeders with the worst reliability metrics for grid hardening
projects. KEC measures effect of its grid hardening efforts relative to System Average
Interruption Duration Index, System Average Interruption Frequency Index, Customer Average
Interruption Duration Index, and/or Momentary Average Interruption Frequency Index on a
quarterly basis,using a rolling 12-month dataset.

Exhibit 3
2026-2028 Construction Work Implementation Plan
KEU S Response to Staff s Second Production Request, Request Nos.
15 and 16

Exhibit 3 to 2026-2028 Construction Work Implementation Plan
KEC'S Response to Staffs Second Production Request, Request Nos. 15 and 16
IPUC Case No. CO7-E-25-01
Second Production Request of Commission Staff
Request No. 15
Person Preparing Response: Reed Christensen, Chief Operating and Financial Officer
Record Holder: Kootenai Electric Cooperative, Inc. ("KEC")
KEC Contact: Michael G. Andrea, General Counsel, [phone]
Request No. 1: In the Response to Staff s First Production Request at No. 1, Project Name"603-
2026-09"on Line 53 in"Item 1 —Exhibit A" is described as "WRIP Grant VIPER Recloser
Installations, 8 locations."Please answer the following:
a. Please provide the awarded grant documents(i.e.,Notice of Award, approved proposal, etc.);
b. Please provide the number of VIPER reclosers planned to be installed in 2026, 2027, 2028;
c. Please provide the locations that the Company is focusing on using the grant;
d. Please provide the metrics that will be used to evaluate the VIPER reclosers;
e. Please explain if the Company has to financially match the grant; and
f. Please provide the timeline of the grant.
KEC Response:
The purpose of the cited WRIP Grant, as set forth in the WRIP Subaward Agreement(attached
to KEC's response to subpart a below), "is to increase grid resilience,reduce wildfire risk,
enhance fault detection and isolation, and improve reliability."To the extent that this request
seeks information regarding KEC's costs and projects for purposes other than the purposes set
forth in the Wildfire Standard of Care Act, I.C. §§ 61-1803(3), 61-1804,this request seeks
information that is not relevant to the Commission's review or approval of KEC's 2026-2028
Wildfire Mitigation Plan. Notwithstanding the foregoing, KEC provides the following response:
a. Please provide the awarded grant documents (i.e.,Notice of Award, approved proposal, etc.);
The following awarded grant documents are attached:
"WRIP Conditional Award Letter"
"WRIP Subaward Agreement KEC"
b. Please provide the number of VIPER reclosers planned to be installed in 2026,2027, 2028;
Eight VIPER reclosers are planned to be physically installed in 2026 with further
telecommunications and commissioning work performed in early 2027.No work is
expected in 2028.

c. Please provide the locations that the Company is focusing on using the grant;
At this time, the precise locations have not yet been decided. However, as mentioned in
the grant application, these advanced reclosers will be strategically placed in high-risk
areas most susceptible to wildfire to improve the reliability and safety of our electric
distribution system.
d. Please provide the metrics that will be used to evaluate the VIPER reclosers;
KEC does not understand this request. Once installed, the VIPER reclosers will be
incorporated into KEC's electrical system and monitored and inspected as part of that
system.
e. Please explain if the Company has to financially match the grant; and
As set forth in the WRIP Subaward Agreement attached in response to subpart a of this
request, the company is required to match the grant funding up to $117,008 of the total
project cost of$468,031.
f. Please provide the timeline of the grant.
Eight VIPER reclosers are planned to be physically installed in 2026 with further
telecommunications and commissioning work performed in early 2027.No work is
expected in 2028. Once work is fully completed, funding will be provided to KEC to
reimburse KEC for the construction work.

IPUC Case No. CO7-E-25-01
Second Production Request of Commission Staff
Request No. 16
Person Preparing Response: Reed Christensen, Chief Operating and Financial Officer
Record Holder: Kootenai Electric Cooperative, Inc. ("KEC")
KEC Contact: Michael G. Andrea, General Counsel, [phone]
Request No. 16: Please explain if the Company has been awarded any other grants for wildfire
mitigation projects in 2026-2028. If so,please answer the following:
a. Please provide the name of the grant;
b. Please provide the status of the grant;
c. Please provide the grant amount and any Company match;
d. Please provide the timeframe of the grant; and
e. Please describe what the grant will be used for.
KEC Response:
To the extent that this request seeks information for purposes other than those purposes set forth
in the Wildfire Standard of Care Act, I.C. §§ 61-1803(3), 61-1804, this request seeks information
that is not relevant to the Commission's review or approval of KEC's 2026-2028 Wildfire
Mitigation Plan. Notwithstanding the foregoing, KEC provides the following response:
a. Please provide the name of the grant;
Idaho Energy Resilience Grant Program(ERGP)
b. Please provide the status of the grant;
The grant agreement between KEC and the State of Idaho's Office of Energy and Mineral
Resources was executed on May 4,2026.
c. Please provide the grant amount and any Company match;
The total cost of the project is estimated to be $745,340. KEC is to match $141,010 of the total
project costs.
d. Please provide the timeframe of the grant; and
The project related expenditures will commence in July 2026 and continue through July 2027.
e.Please describe what the grant will be used for.
The project will entail two main endeavors. The first activity entails a satellite scan of the
vegetation on our distribution system to identify and prioritize vegetation risks and identify dead
or dying trees outside of the right-of-way that are considered hazardous. Using the information

produced from the satellite scan, KEC would then deploy an additional vegetation crew to
conduct hazardous-tree removal for those trees identified outside of the right-of-way.

Appendix C
2026-2028 System Inspection Implementation Plan
This System Inspection Implementation Plan includes the estimated power line feeders, lengths,
and budgets for inspection in calendar years 2026-2028. The inspections of the feeders included in
this System Inspection Implementation Plan are targeted to mitigate wildfire risk and improve system
reliability.
Substation Feeder Year Length(mites) Budgeted Cost
Dower East 2026 60.6
Setters North 2026 113.8
Setters South 2026 116.8
2026 Total 291.2 $219,981
Rathdrum 2027 53
15th Street 2027 57.7
2027 Total 110.7 $233,180
Rathdrum 2028 54.6
Pleasantview 2028 82.3
2028 Total 136.9 $247,170
Grand Total 538.8 $700,331
KOOTENAI ELECTRIC COOPERATIVE INC.WILDFIRE MITIGATION PLAN-PAGE 27 DECEMBER 31,2025

Appendix D
Resolution # 10-25
Kootenai Electric
COOPERATIVE
KOOTENAI ELECTRIC COOPERATIVE,INC.
Resolution#10-25
Review and Acceptance of Wildfire Mitigation Plan
WHEREAS,in the 2025 legislative session,the Idaho Legislature enacted the Wildfire Standard of Care Act. 2025
Idaho Sess.Laws Ch.249(S.B.1183),codified at Idaho Code§§61-1801,et seq.("Act");and
WHEREAS,the Act provides that electric corporations that are not public utilities,including the Cooperative, may
adopt and file a wildfire mitigation plan("Plan")with the Idaho Public Utilities Commission("Commission");and
WHEREAS,the Act requires Plans submitted to the Commission to identify a means for mitigating wildfire risk
that reflects a reasonable balancing of mitigation costs with the resulting reduction of wildfire risk;and
WHEREAS,in reviewing and approving a Plan,the Act requires the Commission to(i)ensure that the Plan meets
the minimum requirements stated in the Plan,including that the Plan includes financially prudent and reasonably
practical methods of line design for new,planned,and existing lines to mitigate fire risk;and(ii)consider certain factors,
including the feasibility of the Plan and the cost of its implementation;and
WHEREAS,determinations regarding(i)financial prudency and practicability of the Cooperative's methods of
line design for new,planned,and existing lines;(ii)whether the Cooperative's Plan reflects a reasonable balancing of
mitigation costs with the resulting reduction of wildfire risk;and(iii)matters regarding the feasibility of the Plan and the
cost of its implementation are within the purview of the Cooperative's board of directors;and
WHEREAS,management has reviewed the Cooperative's Plan and has presented it to the Cooperative's board of
directors for review;and
WHEREAS,the board of directors has reviewed the Cooperative's Plan and its costs of implementation and has
determined that the Plan(i)includes financially prudent and reasonably practicable methods of line design for new,
planned,and existing lines to mitigate fire risk;(ii)is feasible;and(iii)reflects a reasonable balancing of mitigation costs
with the resulting reduction of wildfire risk.
KOOTENAI ELECTRIC COOPERATIVE INC.WILDFIRE MITIGATION PLAN-PAGE 28 DECEMBER 31,2025

Resolution#10-25
Signature Page
NOW,THEREFORE,BE IT RESOLVED that the board hereby accepts the Cooperative's 2026-2028 Plan as presented by
management and authorizes management to make such revisions to such Plan as management deems necessary or
advisable to file the Plan with the Idaho Public Utilities Commission for approval pursuant to the Act;provided that any
substantial changes to the costs associated with the Plan shall be submitted to the board for its review and approval.
Approved this 201 day of November,2025
410 5
William R.R.Swick,Chair
I,Roger Tinkey,Secretary of the Board of Directors of Kootenai Electric Cooperative,Inc.,do hereby certify that
the above Resolution#10-25 was presented to and approved by the Board of Directors this 2011 day of November 2025
and that none of the above Resolution has been altered or rescinded.
1 11 1�—Z�— �k—",
Roger Tinke ,Sec ry
KOOTENAI ELECTRIC COOPERATIVE INC.WILDFIRE MITIGATION PLAN-PAGE 29 DECEMBER 31,2025

Appendix E
Wildfire Standard of Care Act and Order No. 36774 WMP Guideline Compliance Matrix
The WMP Guidelines adopted by the Idaho Public Utilities Commission in Order No. 36774 indicate that WMPs should include a
section that describes how the electric corporation addresses each of the Commission's orders and Staff's recommendations. This
Wildfire Standard of Care Act and Order No. 36774 WMP Guideline Compliance Matrix describes the section(s) of KEC's Wildfire
Mitigation Plan ("Plan")that address each such requirement.
Wildfire Standard of Care Act Requirements and Order No.36774/WMP Guideline Requirements KEC Wildfire Mitigation Plan Compliance
Each wildfire mitigation plan("WMP")shall be developed using approaches and methods that are All sections of KEC's Plan.
designed to protect the public interest and are reflective of and commensurate with the size and KEC's Plan was developed using approaches and methods that are designed to
complexity of the electric corporation's operations and the nature of the fire risk. I.C.§61- protect the public interest and are reflective of and commensurate with the size
1803(3). and complexity of KEC's operations and the nature of the fire risk.
Section 6—Cost Evaluation;Cost-Benefit Approach
Appendix D—KEC Resolution#10-25
Each WMP shall identify a means for mitigating wildfire risk that reflect a reasonable balancing of All sections of KEC's Plan identify means for mitigating wildfire risk that reflect a
mitigation costs with the resulting reduction of wildfire risk. I.C. §61-1803(3). reasonable balancing of mitigation costs with the resulting reduction of wildfire
risk.
Section 6—Cost Evaluation;Cost-Benefit Approach
Appendix D—KEC Resolution#10-25
Each WIMP is to identify geographical areas where an electric corporation has infrastructure or Section 2.1—Identification of Geographical Areas that May be Subject to
equipment that the electric corporation considers may be subject to a heightened risk of wildfire Heightened Risk of Wildfire.
at the time the WMP is finalized by the electric corporation. I.C. §61-1803(a). Figure 3—Heightened Risk Areas
• The electric corporation must include a description of the wildfire risk assessment or model
used to guide wildfire mitigation activities.The assessment should identify geographic areas
with elevated fire risk,considering factors such as vegetation,weather,topography,historical
fire occurrence,structure density,and asset location.
• The electric corporation should provide a map of the identified risk areas within its service
territory within this section of its WMP.The identified risk areas should be defined with
different level of fire risks to the utility.There must be an explanation of what determines
each level of risk and risk assessments of each service territory should be updated annually in
the WMP.
Order No.36774,Exhibit 1 at 2.
KOOTENAI ELECTRIC COOPERATIVE INC.WILDFIRE MITIGATION PLAN-PAGE 29 DECEMBER 31,2025

Each WMP is to include preventive actions and programs that the electric corporation will carry
out to reduce the risk of wildfire. I.C. §61-1803(3)(b).
• The electric corporation must describe all preventative actions and programs that it will carry
out to reduce the risk of wildfire,in addition to actions and programs specified in statute and
by this Commission.
• WMP's preventative actions and programs must include,but is not limited to:
Situational Awareness efforts Section 4—Fire Season Operational Guide
o Which may include use of technology to aid in weather monitoring,fire season outlook, Section 4.1—Daily Situational Awareness
daily,weekly,and monthly weather and fire modeling risk,etc. Consistent with 61-1803(3)(f) Figure 4—Tempest System Daily Fire Risk Example(for Illustrative Purposes
and Staff's proposed requirements within. Only)
Figure 5—Daily Situational Awareness Table
Asset Inspections_._._._._ ........................._._. _._._._._._._._._._._._._._._._._._._._._._._._._._..............._._._._._._._._._._._._._._._._._._._._._._._._._._._._._._._._._._._._._._._._._._._._._._._.__. -Section 3.4—Development ment of Standards Procedures and Schedules for...........................................
p P
o Which must include the frequency and standards of inspections for each type of electric Inspection of KEC's Assets, Infrastructure,and Facilities Within Heightened Fire
infrastructure within areas of elevated wildfire risk. Risk Areas
Consistent with 61-1803(3)(g)(i)and Staff's proposed requirements within. Appendix A—Vegetation Management Plan
Appendix A-1—Vegetation Management Implementation Plan
Appen..............................................ix C—System Inspection_& Maintenance Plan
Enhanced vegetation management practices in risk zone _._._..............................................._._._._._._._._._._._._._._._._._._._._._._._._.__. Section 3.3Vegetation etation Management
g � p s s s g g
o Which may include shorter vegetation management cycles than routine cycles, risk tree Appendix A—Vegetation Management Plan
programs,etc. Appendix A-1-2026-2028 Vegetation Management Implementation Plan
Consistent with 61-1803(3)(g)(iii)and Staffs proposed requirements within.
.................._._._._......................................................................................................................................................................................................._._._._._._._._._._._._._._._._. ._ erational Action Index with Fire Danger Linka--e---------- -----Section 4.3-0
P g g
Operation practices during heightened wildfire risk days or zones Figure 7—Fire Danger/Operational Index
o Which may include restrictions to workforce practices, potential use of proactive de- Figure 8—Fire Season PSPS Decision Making Process/Operational Table
energization Section 4.3.1—Risk Monitoring and Forecasting
Consistent with 61-1803(3)(g)(ii)and Staff's proposed requirements within. Section 4.3.2—Risk Assessment and Initial Decision-Making
Section 4.3.3—Notification and Coordination(Pre-Activation Phase: 72-24
Hours Out)
Section 4.4—Final Decision and Activation(24-0 Hours Out)
Figure 9—National Weather Service Red Flag Weather Matrix, Eastern
Washington and North Idaho
4.3.5—Monitoring During a PSPS
4.3.6 Restoration Process After a PSPS
KOOTENAI ELECTRIC COOPERATIVE INC.WILDFIRE MITIGATION PLAN-PAGE 30 DECEMBER 31,2025

-_---Communit education ----------------------- ------------------------------------------- -------------_---- - ---
y Section 5 Outreach and Communication
o Which may include public service announcements to create awareness and provide Section 5.1—KEC Internal Processes to Guide Wildfire-Related Communication
education of wildfire risks,providing preventative measures,etc. Section 5.2—Coordination with Federal,State,Tribal,and Local Agencies
Consistent with 61-1803(3)(c)and 61-1803(3)(d) Section 5.2.1—Annual Coordination Meeting
Section 5.2.1—Communication of Changes in Operating Condition
Section 5.2.3—Communications with OEM Regarding PSPS
Section 5.3—Member Communications
And an additional. ._._._._._._.__._._._._._.___._._.-._... .-- --- ------------------------------------------------------------- ------- ------...I— ___ _____________________________________________------------------------------
v requirements ordered by the Commission Section 3.1—Grid Modernization
Section 3.2—Methods of Line Design for New, Planned,and Existing Lines to
WMPs may include: Mitigate Fire Risk
System hardening strategies:Which may include pole replacements,line rebuilding,or Appendix B-2026-2028 Construction Work Implementation Plan
undergrounding if necessary,strategic fuse or reclosers installations,etc.
Figure 5—Daily Situational Awareness Table
Workforce Preparedness:Which may include workforce training,equipment provided to
employees to reduce the risk of wildfire,etc.
N/A
Pilot Programs:If applicable.
Order No.36774,Exhibit 1 at 2-4.
Each WMP is to include community outreach and public awareness efforts that the electric corporation will use before,during, Section 5—Outreach and Communication
and after wildfire season to identify and inform the public of relevant wildfire risks and notify the public of wildfire-related Section 5.1—KEC Internal Processes to Guid
outages. I.C. §61-1803(c). Wildfire-Related Communication
Section 5.2—Coordination with Federal,State,
This section should include discussion of how each utility maintains community outreach and public awareness before, Tribal,and Local Agencies
during,and after wildfire season to support customer awareness and education of wildfire risks and notify the public of Section 5.2.1—Annual Coordination Meeting
wildfire-related outages.This discussion should include,but is not limited,to the following: Section 5.2.1—Communication of Changes in
• Description of customer communication efforts related to wildfire mitigation,including efforts to increase awareness Operating Condition
and education of the utility's plan,explanation of key mitigation activities,and efforts supporting public readiness. Section 5.2.3—Communications with OEM
• If the utility utilizes de-energization,a description of public education efforts and communication protocols for before, Regarding PSPS
during,and after a de-energization event.The communication protocols should clearly identify which customers could Section 5.3—Member Communications
and will be impacted if a de-energization event is pursued and identify any advanced notifications for critical
infrastructure or customers,which may include but not limited to,hospitals and other medical facilities,schools,police,
fire,emergency operation centers,any jails/prisons,other utilities,and vulnerable customers.
• Explanation of the communication methods the electric corporation intends to use,such as mail,flyers,emails,calls,
texts,a notification system,its website,etc.
Order No.36774,Exhibit 1 at 4.
KOOTENAI ELECTRIC COOPERATIVE INC.WILDFIRE MITIGATION PLAN-PAGE 31 DECEMBER 31,2025

Each WMP is to include outreach efforts to coordinate with federal,state,tribal,and local officials and Section 5.2—Coo rdination with Federal,State,Tribal,and Local
agencies on wildfire preparedness and emergency response plans. I.C.61-1803(3)(d). Agencies
Section 5.2.1—Annual Coordination Meeting
The electric corporation must describe how it engages with and coordinates with federal,state,tribal,and Section 5.2.1—Communication of Changes in Operating Condition
local officials and agencies on wildfire preparedness and emergency response in the plan year.This Section 5.2.3—Communications with OEM Regarding PSPS
discussion may include,but is not limited to:
• If applicable,Public Safety Power Shutoff("PSPS")tabletop exercises with interested parties and
agencies
• Communication with the agencies and the ESF-12 coordinator within the PUC.
• If applicable,mitigation efforts with the agencies.
The WMP must detail all relationships(such as BLM and Forest Service)it has established that may benefit
the wildfire mitigation program,contribute to program costs,or provide cost sharing opportunities in its
WMP.
Order No.36774,Exhibit 1 at 4-5.
Each WMP is to include financially prudent and reasonably practicable methods of line design for new, Section 3.1—Grid Modernization
planned,and existing lines to mitigate fire risk. I.C.§61-1803(e). Section 3.2—Methods of Line Design for New, Planned,and
Existing Lines to Mitigate Fire Risk
The electric corporation must describe how its methods of line design for new lines and planned upgrades Appendix B-2026-2028 Construction Work Implementation Plan
reduce wildfire ignition potential in heightened wildfire risk areas.This must include evaluation of costs to Section 6—Cost Evaluation;Cost-Benefit Approach
wildfire risk reductions.Additionally,this must include how the electric corporation clearly identifies, Appendix D—KEC Resolution#10-25
selects,and evaluates projects that reflect a balance of mitigation costs with resulting reduction in wildfire
risk for the following,but is not limited to:
• Line rebuilding within the WMP.
• Undergrounding lines within the WMP.
• Installation of covered conductor.
• Installation of non-wooden cross arms.
• If any,describe any flexible infrastructure such as automatic reclosers and remote-controlled devices
that support remote operations
Order No.36774,Exhibit 1 at S.
KOOTENAI ELECTRIC COOPERATIVE INC.WILDFIRE MITIGATION PLAN-PAGE 32 DECEMBER 31,2025

Each WMP is to include monitoring of forecasted and current weather data for the purpose of assessing and Section 4—Fire Season Operational Guide
responding to current and anticipated fire risk. I.C. §61-1803(f). Section 4.1—Daily Situational Awareness
Figure 4—Tempest System Daily Fire Risk Example(for Illustrative
This section should include a description of how the electric corporation monitors forecasted and current Purposes Only)
weather conditions for the purpose of assessing and responding to current and anticipated wildfire risk. Figure 5—Daily Situational Awareness Table
This description must include,but is not limited to,the following: Section 4.3—Operational Action Index with Fire Danger Linkage
• Identification of systems,tools,or external resources used to monitor weather,fire potential,or other Figure 7—Fire Danger/Operational Index
situational awareness indicators. Figure 8—Fire Season PSPS Decision Making Process/Operational
• If applicable,a description of how the utility utilizes weather forecasting,fire potential modeling,or Table
similar tools,to inform mitigation activities and operational decisions. Section 4.3.1—Risk Monitoring and Forecasting
• Discussion of how situational awareness capabilities are integrated into daily or seasonal wildfire Section 4.3.2—Risk Assessment and Initial Decision-Making
operations. Figure 9—National Weather Service Red Flag Weather Matrix,
• Discussion of how the electric utility becomes aware of another electric corporation's de-energization Eastern Washington and North Idaho
(e.g.,Bonneville Power Administration)and how that is integrated into operations.
Order No.36774,Exhibit 1 at 5-6.
Each WMP is to include standards, procedures,and schedules,subject to timely approval of access to rights-
of-way,if necessary for the following actions:
(i) Inspection of the electric corporation's assets, infrastructure,and facilities within the areas that Section 3.4—Development of Standards Procedures,and
are identified as heightened fire risk areas in the wildfire mitigation plan,where financially Schedules for Inspection of KEC's Assets, Infrastructure,and
prudent and reasonably practicable. Facilities Within Heightened Fire Risk Areas
Appendix A—Vegetation Management Plan
This section should provide a summary of electric corporation's programs for the inspection of electric Appendix A-1—Vegetation Management Implementation Plan
infrastructure,assets,and facilities within areas identified as heightened wildfire risk areas to identify and Appendix C—System Inspection&Maintenance Plan
correct conditions that could contribute to wildfire ignition.This summary must include,but is not limited
to,the following:
• Description of inspection standards for each type of infrastructure,assets,and facilities.
• Description of schedules for inspections for each type of infrastructure,asset,and facility.
• Description of baseline routine inspection methods and enhanced inspection methods for higher fire
risk areas,which may include the use of advanced or pilot technologies.
• Explanation of how identified defects are classified,prioritized,and corrected.
• Measurable targets/goals to be achieved within the WMP. E.g.,miles of lines inspected,corrected
identified defects,etc.
Order No.36774,Exhibit 1 at 6.
KOOTENAI ELECTRIC COOPERATIVE INC.WILDFIRE MITIGATION PLAN-PAGE 33 DECEMBER 31,2025

................I.......--.... -De-en ergs... --- --- --------- . ------ ------- ---- --------..................................................... -------------------- ---.............................................................--- -------- --------------
( ) atlon of the electric corporation's power lines, if considered appropriate by the Section 4.2—Public Safety Power Shutoff(PSPS) Procedure
electric corporation;and Section 4.3—Operational Action Index with Fire Danger Linkage
Figure 7—Fire Danger/Operational Index
If an electric utility plans to use de-energization as part of its wildfire mitigation efforts,this section must Figure 8—Fire Season PSPS Decision Making Process/Operational
address the standards,criteria,and operational protocols,for de-energization for encroachment of a Table
wildfire,proactive de-energization(PSPS)to reduce fire risk,and deenergization from 3rd party energy Section 4.3.1—Risk Monitoring and Forecasting
providers.This discussion must include,but is not limited to the following: Section 4.3.2—Risk Assessment and Initial Decision-Making
Section 4.3.3—Notification and Coordination(Pre-Activation
• A summary of the conditions under which de-energization may be used,if applicable. Phase: 72-24 Hours Out)
• The criteria or protocols for evaluating its appropriateness to engage. Section 4.4—Final Decision and Activation(24-0 Hours Out)
• Summary of the electric corporation's operational protocols for before,during,and after a de- Figure 9—National Weather Service Red Flag Weather Matrix,
energization event. Eastern Washington and North Idaho
• Description of how the electric corporation will coordinate with local emergency managers,operators 4.3.5—Monitoring During a PSPS
of critical facilities,and affected communities before,during,and after a de-energization event. 4.3.6 Restoration Process After a PSPS
• Descriptions of other operations for limiting impact to affected communities;which may include Section 5—Outreach and Communications
community resource centers,emergency generators,backup batteries,etc. Section 5.1—KEC Internal Processes to Guide Wildfire-Related
Communication
Order No.36774,Exhibit 1 at 7. Section 5.2—Coordination with Federal,State,Tribal,and Local
Agencies
Section 5.2.1—Annual Coordination Meeting
Section 5.2.1—Communication of Changes in Operating Condition
Section 5.2.3—Comm unications with OEM Regarding PSPS
Section 5.3—Member Communications
KOOTENAI ELECTRIC COOPERATIVE INC.WILDFIRE MITIGATION PLAN-PAGE 34 DECEMBER 31,2025

- _ - - ------
._._._._._._._._._._._._._._._._._._. - .-..-- ----...............---- _- ----.__-.-... ... - --- -- - -------- -- --------- ----- ---._._.------- ------ ------ - — .......................--
(III) Vegetation management within the areas that are identified as heightened fire risk areas in the Section 3.3 Vegetation Management
wildfire mitigation plan and are within the electric corporation's rights-of-way or lands adjacent Appendix A—Vegetation Management Plan
thereto and that threaten the power lines or other electric corporation infrastructure. If live Appendix A-1-2026-2028 Vegetation Management
marketable timber is identified for removal from timber company land adjacent to the rights- Implementation Plan
of-way,compensation at fair market value shall be made to the landowner for such timber.
This section must provide an overview of the utility's vegetation management program aimed at reducing
the risk of vegetation-related contact with electric infrastructure in areas with heightened wildfire risk
within its rights-of-way or lands adjacent thereto.Elements of this vegetation management section
overview should include,but is not limited to,the following:
• Identification,description,and citation of vegetation management standards for elevated wildfire
risk areas.
• Explanation of how vegetation management standards,procedures,and schedules are different
or the same as routine vegetation management.
• Description of the current and planned vegetation management practices used to mitigate
wildfire risk,including any enhancements in designated wildfire areas.
• The electric corporation must explain how the electric utility considered vegetation management
recommendations by other federal,state,and county agencies into its standards.
• Must include measurable targets/goals to be achieved within the WMP.E.g.,miles of lines
completed,risk trees removed,etc.
• Explanation of how identified risk trees are classified,prioritized,and corrected.
Order No.36774,Exhibit 1 at 7-8.
An update of lessons learned from the previously approved WMP within the annual filings for WMP N/A
review and approval.
Order No.36774,Exhibit 1 at 8.
A breakdown of each program category's forecasted costs by year for both capital and O&M expenditures Appendix A-1-2026-2028 Vegetation Management
through the length of the WMP. Implementation Plan
Appendix B-2026-2028 Construction Work Implementation Plan
Order No.36774,Exhibit 1 at 8.
A section in which it describes how the electric corporation addresses each of the Commission's orders Appendix E—Wildfire Standard of Care Act and Order No.36774
and Staff's recommendations. WMP Guideline Compliance Matrix
Order No.36774,Exhibit 1 at 8.
Electric corporations shall develop rolling WMPs with a minimum three-year planning horizon. Section 1.1—Purpose of the Wildfire Mitigation Plan
KOOTENAI ELECTRIC COOPERATIVE INC.WILDFIRE MITIGATION PLAN-PAGE 35 DECEMBER 31,2025

Order No.36774 at 20. Appendix A-1-2026-2028 Vegetation Management
Implementation Plan
Appendix B-2026-2028 Construction Work Implementation Plan
WMPs must explain how an electric corporation's line design methods reduce the potential for wildfire Section 6—Cost Evaluation;Cost-Benefit Approach
ignition,including a cost evaluation. Appendix B-2026-2028 Construction Work Implementation Plan
Order No.36774 at 20.
All electric corporations must include a cost-benefit analysis in their proposed WMPs that justifies the Section 6—Cost Evaluation;Cost-Benefit Approach
expenditures for risk mitigation described within.
Order No.36774 at 20.
Unregulated Entities shall submit a completed copy of Staff's proposed"Need to Know"document with See Application of Kootenai Electric Cooperative, Inc.for Approval
their initial WMP filings to aid Staff in its review of the plan. of its Wildfire Mitigation Plan at page 1 and Attachment 2.
Order No.36774 at 20.
KOOTENAI ELECTRIC COOPERATIVE INC.WILDFIRE MITIGATION PLAN-PAGE 36 DECEMBER 31,2025

APPENDIX F
Heightened Wildfire Risk Map Overlaved with Boundaries for Areas Served by KEC
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APPENDIX G
KEC'S Response to Staff s First Production Request, Request No. 14
CIPUC Case No. C07-E-25-01
First Production Request of Commission Staff
Request No. 14
Person Preparing Response: Julie Turbin, VP of Operations& Operational Services
Record Holder: Kootenai Electric Cooperative, Inc. ("KEC")
KEC Contact: Michael G. Andrea, General Counsel, [phone]
Request No. 14: Regarding the Company's risk assessment of its service territory,please
explain how the Company determined each level of risk identified as medium, high, or very high,
including the criteria and thresholds used to distinguish between each level of risk.
KEC Response: As stated in Section 2.1 of KEC's Wildfire Mitigation Plan:
KEC uses a combination of resources and data to determine specific geographical areas
that are considered to have a heightened risk of wildfire. First, as shown in Figure 3,
KEC utilizes data from Wildfire Risk to Communities.I This data rates the areas from
very low to very high, based on techniques developed to create various simulations
factoring in weather, topography, ignitions and vegetation. This data is then overlayed
with proprietary vegetation management software that produces further insight into how
those areas overlap within the KEC service area and infrastructure. This allows KEC to
better understand how the identified wildfire risk zones align with vegetation
encroachments and hazard trees and develop vegetation management goals to prioritize
heightened risk zones. Areas with denser vegetation are denoted on Figure 3 as
"Medium,""High," and"Very High"Wildfire Risk Zones, which are areas that KEC
considers may be subject to a heightened risk of wildfire (Heightened Risk Areas). KEC
uses the information depicted in Figure 3 to prioritize vegetation management practices
and other work in Heightened Risk Areas.
' Wildfire Risk to Communities: Spatial datasets of landscape-wide wildfire risk components for the United States.
2nd Edition.Fort Collins,CO: Forest Service Research Data Archive available at: https://doi.org/10.2737/RDS-
2020-0016-2.