20260731Final_Order_No_37120.pdf

Office of the Secretary
Service Date
July 31,2026
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF NORTHERN LIGHTS, ) CASE NO. C10-E-26-01
INC.'S APPLICATION FOR APPROVAL OF )
ITS 2026-2028 WILDFIRE MITIGATION ) ORDER NO. 37120
PLAN )
On February 2, 2026, Northern Lights Inc. ("Company") filed its 2026-2028 Wildfire
Mitigation Plan("2026 WMP") with the Idaho Public Utilities Commission ("Commission"). On
February 19,2026,the Company filed an updated application("Application"),requesting approval
of its 2026 WMP, in accordance with the Wildfire Standard of Care Act Idaho Code § 61-1801, et
seq. ("WSCA").
On March 19, 2026, the Commission issued a Notice of Application and Notice of
Intervention Deadline, setting a deadline for interested parties to file a petition to intervene. Order
No. 36963. No petitions to intervene were filed. On April 30, 2026, the Commission issued a
Notice of Modified Procedure, establishing comment deadlines. Order No. 37023. Commission
Staff("Staff') and the Idaho Department of Lands ("IDL")filed comments to which the Company
replied. No other comments were received.
Based on our review of the record, we issue this Final Order denying approval of the
Company's 2026 WMP.
BACKGROUND
On July 1,2025,the WSCA became effective.Through enactment of the WSCA,the Idaho
Legislature established a framework intended to support the continued delivery of safe, reliable,
and cost-effective electric service while addressing the growing risks associated with wildfires.
Idaho Code § 61-1802. The Legislature recognized that wildfire preparedness and response have
become increasingly significant components of utilities system planning and operations,
particularly for electric corporations responsible for transmission and distribution infrastructure
throughout the state.Id.
The Legislature further acknowledged the Commission's role in overseeing electric utility
compliance with applicable statutes,regulations, and safety standards.Id. In adopting the WSCA,
the Legislature emphasized that electric corporations should proactively identify, mitigate, and
ORDER NO. 37120 1

respond to wildfire risk in a manner that protects public safety and property while also ensuring
that utility expenditures remain prudent and rates remain affordable for customers.Id.
The WSCA allows municipal and cooperative electric corporations to voluntarily submit
WMPs for review by the Commission. Idaho Code § 61-1803(2)(b). The WSCA does not treat a
municipal or cooperative utility's WMP differently than a Commission-regulated public utility's
WMP. Order No. 36774 at 14. If a municipal or cooperative electric corporation elects to file a
WMP,the Commission can assess reasonable fees to such entity,which"may not exceed the actual
reasonable cost incurred by the Commission for the review and consideration of a plan submitted
to it."Idaho Code § 61-1803(2)(b).
The WSCA requires the Commission to consult with the IDL state forester ("State
Forester") on an electric corporation's WMP. Idaho Code § 61-1804(3). Recommendations from
the State Forester for a WMP are presumed to be reasonable and appropriate under the WSCA.Id.
The presumption of reasonableness regarding the State Forester's recommendations on a WMP
can only be overcome by a showing that said recommendations are "not just, reasonable, and in
the public interest."Id. Recommendations on a WMP from the State Forester that the Commission
does not deem unreasonable, unjust, or not in public interest must be incorporated in the
Commission's decision on a WMP.Id.
Commission-approved WMPs shall be implemented upon approval and reviewed and
updated annually. Idaho Code § 61-1803(4). A Commission-approved WMP establishes the
operational and risk-mitigation measures the electric corporation will undertake to prepare for and
respond to wildfire-related threats and helps define the electric corporation's responsibilities to the
public and its customers.Idaho Code § 61-1805.
The WSCA also creates a rebuttable presumption in wildfire-related litigation that an
electric corporation acted without negligence if it reasonably implemented a Commission-
approved WMP. Idaho Code § 61-1806(1). If an electric corporation, like a municipal or
cooperative utility, elects to file any future WMP filings, to ensure continued adaptation to
changing conditions, the statute requires electric corporations to review and update their WMPs
annually and to submit periodic compliance reporting as directed by the Commission.Idaho Code
§§ 61-1803(4), 61-1804.
Consistent with the WSCA, on September 30, 2025, the Commission issued Order No.
36774 that established a filing schedule, guidelines, and essential components for WMPs filed for
ORDER NO. 37120 2

Commission review and approval. Order No. 36774 at Exhibit A. Each WMP filed with the
Commission, whether it is a Commission-regulated utility's WMP or a municipal or cooperative
electric corporation's WMP,is subject to the requirements for WMPs under the Commission WMP
guidelines detailed in Order No. 36774 ("Guidelines") and Order No. 36929.
In conducting its review, the Commission considers: (1) the protection of public health,
safety, and welfare; (2) the feasibility of the WMP and the cost of its implementation; and (3)the
extent to which the WMP minimizes wildfire risk and provides for an effective response to
potential wildfire events. Idaho Code § 61-1804(1)(a)-(c). The Commission also considers its
Guidelines, which require a WMP to include the following sections: (1) geographical risk
assessment; (2) preventative actions and programs; (3) public outreach and engagement; (4)
government outreach; (5) method of line design; (6) situational awareness and monitoring; (7)
infrastructure inspection and maintenance; (8) de-energization and line operation practices; (9)
vegetation management.
THE APPLICATION
The 2026 WMP is a rolling three-year plan covering 2026-2028 that the Company
represented will be reviewed and updated annually to incorporate lessons learned, updated risk
modeling, evolving mitigation practices, and revised budget forecasts in accordance with the
Guidelines. Application at 2. The Company represented that consistent with Idaho Code § 61-
1803(3)(a), it conducted a baseline wildfire risk assessment using models that incorporated
vegetation, weather, topography, historical fire occurrence, and asset location to identify areas of
heightened wildfire risk.Id.
The Company's risk mapping indicated the eastern portion of its service territory along the
Idaho—Montana border and into Montana presented higher wildfire risk. Id. The Company
represented that the modeled severity levels guide its prioritization of mitigation actions,including
vegetation management, inspection frequency, system hardening investments, relay setting
adjustments, and potential Public Safety Power Shutoff("PSPS") consideration.Id. at 2-3.
The Company represented that in accordance with Idaho Code § 61-1803(3)(b), the 2026
WMP outlines preventive programs to reduce wildfire risk, including situational awareness, asset
inspections, vegetation management, operational practices during heightened wildfire risk,
workforce training,and community outreach.Id. at 3. The Company stated it uses weather and fire
data sources,including National Weather Service data and fire forecasting tools,and is developing
ORDER NO. 37120 3

a proprietary weather station network that will integrate into a Daily Situational Awareness Tool
("DSAT") expected by the end of 2026.Id.
The Company's inspection program proposes to inspect all overhead distribution lines on
a seven-year cycle and includes annual pole testing and meter inspections, with deficiencies
tracked through a GIS-based system.Id. The Company represented that its vegetation management
follows a seven-year trim cycle, prioritizes hazard tree removal in elevated risk areas, and uses
satellite imagery and artificial intelligence ("Al") assisted analysis to guide work planning. Id. at
4. Further, the Company stated its operational practices include seasonal protection settings and a
PSPS program implemented as a measure of last resort. Id. The 2026 WMP emphasizes
stakeholder coordination, public communication, and emergency response planning, including
outreach to members,coordination with local jurisdictions and tribal entities,and consultation with
the Idaho State Forester.Id. at 4-5.
STAFF COMMENTS
Staff reviewed the 2026 WMP for compliance with the requirements of the WSCA, the
Guidelines, and Order No. 36929. Staff Comments at 2. Based on its review, Staff believed that
the 2026 WMP, and additional information provided by the Company through discovery, satisfied
the applicable statutory and regulatory requirements.Id. Staff recommended that the Commission
approve the 2026 WMP and direct the Company to include the following information in future
filings, should the Company seek Commission approval of another WMP:
I. Provide details of all funding alternatives and sources pursued;
2. Include a narrative explaining the modeling process, including the inputs of the modeling
used, by the Company's third-party vendor, Athena Intelligence;
3. Include a narrative that explains how mitigation activities are reducing wildfire risk;
4. Include the explanation of how risk scores are derived and include any illustrations needed,
similar to its Response to Staff s First Production Request at No. 6;
5. Include project-level details including the targets, explanation of the benefits, and
alternatives considered for each project;
6. Include the details of the weather station program status, areas of focus, annual cost, any
targets, if applicable, and any metrics used to evaluate the program; and
7. Include a more detailed description of the DSAT—including the outputs of the tool.
Id. at 23-24. Staff also recommended the Commission clarify that the Company could file an
updated WMP annually on or about February 2 of each year for Commission review and approval.
Id. at 7.
ORDER NO. 37120 4

I. 2026 WMP-Wide Considerations
a. Staff's Recommendations for Commission
i. Cost Feasibility: Grants
Staff noted that the 2026 WMP briefly described that the Company had been awarded two
grants for projects related to wildfire.Id. at 5. In discovery,the Company supplied information on
an Idaho Office of Energy and Mineral Resources ("OEMR") grant the Company received for
installing weather stations and completing drone inspections. Id. at 5-6. The Company also
brought up three other OEMR grants that the Company received but that were not discussed in the
2026 WMP.Id. at 6.
Staff believed information on funding alternatives helps inform the Commission on an
electric corporation's cost of implementing its WMP, which the Commission is required to
consider under the WSCA (Idaho Code § 61-1804(1)(b)). Id. Thus, Staff believed funding
alternative information must be included in an electric corporation's WMP, and not through
discovery. Id. at 6. Because most of the Company's information on funding alternatives was
provided through discovery, Staff recommended the Commission direct the Company to include
alternative funding sources the Company is pursuing, if any, and the amount of funds received, to
help fund its wildfire mitigation efforts in any future WMP filings.Id.
ii. Cross Cutting Elements: Metrics & State Forester Recommendation
Staff stated that the 2026 WMP identified some metrics the Company plans on using to
assess the effectiveness of the 2026 WMP programs.Id. In discovery,the Company provided more
details on the metrics it uses.Id. Thus, Staff believed the Company provided sufficient information
on material the Commission must consider under the WSCA(Idaho Code § 61-1804(1)(b)(c)).Id.
at 7. However, Staff believed information on metrics used to track the effectiveness of wildfire
mitigation efforts are required to be included in an electric corporation's WMP and not provided
through discovery. Id. Thus, Staff recommended the Commission direct the Company to include
information on the metrics it uses to track the feasibility of wildfire mitigation efforts in any future
WMP filings.Id.
Additionally, in a meeting between Staff and IDL, IDL shared concerns it had with the
2026 WMP. Id. IDL indicated to Staff that it intended to file its concerns as public comments.Id.
Staff recommended the Commission consider IDL's comments in conjunction with Staff s
comments.Id.
ORDER NO. 37120 5

b. Staffs Suggestions for Company
i. Cost Feasibility: Cost Forecasts & Cost Benefit Approach
Staff commented that the 2026 WMP included a summary of the Company's capital,
operation and maintenance ("O&M") expenses, and budget for managing vegetation for 2026
through 2028. Id. at 4. However, Staff noted that the summary "did not break down the costs by
category or project level." Id. In discovery the Company expanded its summary by providing
project-level narratives on the work being done, the benefits, timelines, and budgets for the
projects. Id. Staff believed that the Company's project-level narratives on the projects, and the
2026 WMP budget summary, satisfied the requirements under the Guidelines to provide a cost
forecast for program categories and capital and O&M expenditures.Id.
Staff believed that by outlining the Company's programs for wildfire mitigation as either
high,medium,or low for cost and effectiveness,that the Company satisfied the requirements under
the WSCA (Idaho Code § 1-1804(1)(b)), the Guidelines, and Order No. 36882 to provide
information that would allow the Commission to consider the feasibility of a WMP.Id. at 5. Staff
encouraged the Company to further detail the rationale for the high,medium,and low designations,
to provide information on the qualitative benefits identified by the Company, to detail the
successfulness in wildfire mitigation, and to quantify the risk reduction associated with mitigation
actions.Id.
ii. Cross Cutting Elements: Targets, Goals, and Lessons Learned
Staff believed the Company satisfied the requirement in the Guidelines to include targets
and goals that can be measured in a WMP by providing cycle-based targets for many of the
programs in the 2026 WMP.Id. However, Staff encouraged the Company to include numeric and
cycle-based targets in any future WMP filing to assist in verifying compliance year-to-year.Id. at
7.
Staff believed that the Guidelines' requirement that electric corporations supply
information on the lessons it has learned from its previously approved WMPs was inapplicable to
the Company's proposed WMP because the Company was not a utility regulated by the
Commission and had not previously filed a WMP. Id. at 8. However, in discovery the Company
detailed that in 2024 it: (1) created its first WMP; (2) put into action an overhead inspection
program; and(3)used seasonal protection settings on parts of its system when wildfire conditions
were high. Id. Additionally, in 2025 the Company further advanced its wildfire mitigation efforts
ORDER NO. 37120 6

by developing its PSPS and using formal wildfire risk modeling.Id. Staff encouraged the Company
to include the additional information the Company supplied on its prior wildfire mitigation efforts
in any future WMP filings.Id.
II. Geographical Risk Assessment
a. Staffs Recommendations for Commission
Staff believed that the Landscape Wildfire Risk map included in the 2026 WMP, and
additional information supplied in discovery, showed that the Company used a reasonable
approach to evaluate wildfire risk in its service territory and thus was sufficient to satisfy what was
required under the WSCA (Idaho Code § 61-1803(3)(a)) and the Guidelines, which requires a
WMP to include an explanation of the Company's assessment and identification of wildfire risk
areas. Id. at 8-9. However, Staff believed there were limitations with the Company's approach
primarily concerning the description of the modeling process, inputs used in the modeling,
identifying and describing qualitative benefits, narratives on specific mitigation efforts, and
coordination with local fire experts.Id. at 10-11.
i. Risk Model Description
Staff noted that the 2026 WMP did not include a description of the modeling process or
the data inputs used to create the Landscape Wildfire Risk map, and instead most of the
information Staff reviewed to confirm compliance with the WSCA and the Guidelines was
provided in discovery.Id. at 9. Staff believed information on the third-party vendor used to create
the risk model, the model inputs utilized, and the fact that the map was created from two models,
would provide context on how the risk model was created and would demonstrate that the
Company was supplying information the Commission must consider under the WSCA and the
Guidelines. Id. Thus, Staff felt that the information should be included in the WMP, and not
through discovery. Id. Accordingly, Staff recommended the Commission direct the Company to
include a narrative describing the modeling process in any future WMP filings. Id.
ii. Risk Model Limitations
Staff also believed the modeling process was limited because it did not consider the risk of
wildfire ignition from the Company's infrastructure.Id. at 10. Staff explained that only overlaying
the Company's assets on the Landscape Wildfire Risk map, which is what the Company's third-
party vendor did when creating the map, made it so the risk assessment process did not consider
the risk of wildfire ignition from the Company's infrastructure as an input in the risk model. Id.
ORDER NO. 37120 7

Staff believed inputting the risk of ignition from the Company's infrastructure would
enable the Company to more adequately plan and focus its investments on its systems as part of
its wildfire mitigation efforts. Id. Further, Staff believed that because infrastructure ignition risk
was not considered in the model, the model would also not document the reduction of risk due to
the Company's investments in its system. Id. As a result, Staff encouraged the Company to add
risk from infrastructure ignition as an input in its modeling process moving forward and
recommended the Commission direct the Company to explain how its mitigation activities were
reducing wildfire risk in any future WMP filings.Id. at 10-11.
Additionally, Staff noted that the Company provided information on the qualitative
benefits of its plans to mitigate wildfire risk in discovery. Id. at 10. Staff believed material on the
qualitative benefits of wildfire mitigation efforts should be included in a WMP, and not through
discovery. Id. Accordingly, Staff recommended the Commission direct the Company to include
descriptions of the qualitative benefits of its mitigation efforts in any future WMP filings. Id.
Lastly, Staff encouraged the Company to consult with local fire experts to validate a risk model's
results. Id. at 11.
iii. Risk Scores
Staff noted the Company's Landscape Wildfire Risk map detailed "five risk score
categories."Id. at 11. Staff explained that there was no explanation in the 2026 WMP of how the
risk categories were determined. Id. Staff stated that the Company supplied information in
discovery on how the risk categories were developed and thus made it possible for Staff to analyze
whether the Company provided sufficient information on how levels of wildfire risk in the
Company's service territory was developed, as required by the Guidelines. Id. at 11-12. Staff
believed information on how wildfire risk levels are determined must be included in a WMP, and
not through discovery. Id. at 13. Thus, Staff recommended the Commission direct the Company
to include the information it provided in discovery on how the risk categories were developed in
any future WMP filings.Id.
III. Preventative Actions and Programs
a. Staffs Suggestions for Company
Regarding optional preventative actions and programs that were suggested in the
Guidelines, Staff outlined various recommendations for the Company on information and/or
practices Staff believed the Company should consider implementing and including in any future
ORDER NO. 37120 8

WMP filings. For instance, Staff encouraged the Company to include in any future WMP filings a
table that outlined the workforce training the Company planned to conduct, the roles of the
individuals attending, information on whether the training was required or optional, and the dates
of the training.Id. at 12-13.
Further, Staff suggested that the Company include details and information on program
pilots it was already conducting, or planning on, like what it supplied in discovery, in any future
WMP filings.Id. at 13. Staff also recommended the Company detail its targets for pilot programs
in future filings to provide transparency and to help Staff evaluate a WMP's feasibility.Id.
IV. Method of Line Design and System Hardening
a. Staffs Recommendations for Commission
While the Company provided information on its system hardening process in the 2026
WMP, Staff believed the 2026 WMP did not sufficiently explain the timelines, goals, alternatives
considered, criteria for selection, costs, or main drivers of its system hardening projects.Id. at 14-
15. Staff stated that because the Company provided project-level details, and discussed goals,
benefits,timelines, and alternatives for system hardening projects in discovery, Staff believed that
the Company provided sufficient information on material the Commission must consider under
the WSCA (Idaho Code §§ 61-1803(3)(b) and 61-1803(3)(e)) and the Guidelines. Id. at 15.
However, Staff believed project-level details on system hardening projects must be included in an
electric corporation's WMP, and not through discovery. Id. Thus, Staff recommended the
Commission direct the Company to include project-level details on system hardening projects in
any future WMP filings.Id.
V. Situational Awareness and Monitoring
a. Staff's Recommendations for Commission
Staff explained that because the 2026 WMP included information on the Company's
method for monitoring weather conditions and wildfire risk and explained that the Company would
be using an OEMR grant to develop a weather station network, Staff believed the Company
provided sufficient information on how the Company assesses wildfire risk and weather conditions
that the Commission must consider under the WSCA (Idaho Code § 61-1803(3)(f)) and the
Guidelines.Id. at 16-17.
Staff stated that in discovery, the Company supplied additional information on its weather
station network plans and explained how the Company intends to incorporate the data from the
ORDER NO. 37120 9

weather stations into a DSAT. Id. Because the additional information provided in discovery
expanded on the Company's work for situational awareness, Staff believed it should be included
in the 2026 WMP, and not through discovery.Id. at 17. Thus, Staff recommended the Commission
direct the Company to include the information on its weather station network and use of the DSAT
that it provided in discovery in any future WMP filings. Id. Staff also suggested the Company
further describe the DSAT in any future WMP filings.Id.
VI. Infrastructure Inspection and Maintenance
a. Staffs Suggestions for Company
Regarding infrastructure inspection and maintenance, Staff believed the information the
Company supplied in the 2026 WMP and in discovery sufficiently discussed the frequency of, and
standards for, electric infrastructure inspections that the Commission must consider under the
WSCA (Idaho Code §§ 61-1803(3)(b), 61-1803(3)(g)(i)) and the Guidelines. However, Staff
encouraged the Company to implement more robust inspection schedules for areas of higher
wildfire risk and to consider the condition of equipment in those inspections.Id. at 17-18.
On the matter of quality assurance ("QA") for inspections and maintenance of
infrastructure, Staff suggested the Company adopt a more formal QA process and to use
"statistically valid sample of completed work" to track whether infrastructure issues were being
corrected properly.Id. at 18.
Regarding monitoring deficiency backlog for infrastructure inspections and maintenance,
Staff encouraged the Company to provide deficiency priority categories,the amount of deficiency
repairs completed, repair objectives, time to repair, and remaining repairs for the prior three years
in any future WMP filing.Id. at 18-19.
VII. De-Enemization and Operation for Heightened Wildfire Risk
a. Staffs Suggestions for Company
Regarding the Company's operations during heightened wildfire risk or in high-risk areas,
Staff noted that the 2026 WMP described the Company's infrastructure and vegetation
management during heightened wildfire risk at a high level rather than detailing what occurs at
each risk level. Id. at 20. Staff stated that the Company's response to Staff s request for more
information did not yield satisfactory additional information. Id. Staff encouraged the Company
to include a table or a narrative on what operational changes the Company makes during those
ORDER NO. 37120 10

times and/or in those areas so there can be a better understanding on how the Company determines
its operational response as wildfire risks increases in any future WMP filings.Id.
VIII. Vegetation management
a. Staffs Suggestions for Company
Staff requested the Company provide more details on the criteria the Company uses to
prioritize vegetation management work areas in any future WMP filings. Id. at 21. Additionally,
Staff encouraged the Company to adopt a formal QA process for managing vegetation to ensure
decisions are not being based on data that is incomplete or misleading.Id. at 21-22. On vegetation
management training, Staff suggested the Company consider adding the training and certification
for the International Society of Arboriculture's Wildfire Risk Reduction Qualification as a
requirement because the qualification addressed ladder fuels, which Staff believes present a risk
in the Company's service territory.Id. at 22.
Staff encouraged the Company to include its metrics for hazard tree management in any
future WMP filings to monitor and manage hazard trees.Id. at 22-23.Additionally,based on IDL's
comments regarding certain tree's developing into hazard trees after a high wind event, Staff
encouraged the Company to increase hazard tree inspections in areas of its service territory that
are affected by high wind events, and where the tree's identified by IDL are present.Id. at 23.
IX. Marketable Timber on Timber Company Land
a. Staffs Suggestions for Company
While Staff believed the 2026 WMP supplied sufficient information on how the Company
compensates timber companies for live marketable timber, Staff encouraged the Company to
expand on its process in any future WMP filings.Id.
IDL COMMENTS
IDL was concerned with the Company's risk modeling believing that there was insufficient
information on the data used to develop the modeling. IDL Comments at 1. IDL explained that it
requires cooperators that develop and implement County Wildfire Preparedness Plans to include
information on the modeling inputs utilized to create those plans. Id. IDL stated it must hold
utilities to the same standard to ensure consistent wildfire mitigation efforts throughout the state.
Id.
IDL believed that the Company's wildfire risk modeling did not include "clearly
identifiable wildland urban interface (WUI) or other comparable data in the modeling...." Id. at
ORDER NO. 37120 11

1-2. IDL explained that the consequence of not including that information was that a fire ignited
by a utility was not accurately reflected in the modeling and caused IDL to question the validity
of the risk modeling. Id. at 2. Due to the questionable validity of the risk modeling, IDL
recommended the 2026 WMP be denied.Id.
For the Company's future assessments of wildfire risk, IDL strongly recommended the
Company include data on: (1)the Company's system components; (2)where trees surrounding the
Company's system are taller than said system; and(3) information on soil types.Id. IDL believed
there was an opportunity for "cross integration" between county level Community Wildfire
Protection Plans and a utility's wildfire mitigation plan and thus encouraged the Company to work
with Idaho counties where the Company's system is located to improve wildfire response and
mitigation efforts.Id. at 2-3.
IDL requested that the Company add a narrative for its process "for cost recovery when
trees on forest industry ownerships are required to be removed."Id. at 3. IDL noted that it could
not determine how vegetation management was differentiated in areas of the Company's service
territory that were considered high fire risk. Id. IDL recommended the Company's inspection
qualification standards include wildland fire certification.Id.
IDL commented that the level of detail in the 2026 WMP made it difficult for IDL to
ascertain what work will be done by the Company and how the Company will measure its
successful implementation. Id. To weigh the success of mitigation efforts, IDL suggested that the
Company detail the economic value of its system, the economic impact of a disruption in service,
and to share an evaluation of the costs if no mitigation actions were implemented.Id. at 3-4.
COMPANY REPLY
The Company stated that even through Staff recommended the Company include a
narrative describing the Company's modeling method and data used in the modeling, and IDL
requested more information on the analytical inputs used in the modeling prior to Commission
approval, the Company argued that Staff considered the technical concerns with the modeling
during its review and nevertheless recommended approval of the WMP. Company Reply at 2-3.
The Company stated that neither the WSCA nor the Guidelines mandate a specific wildfire
risk model,a particular model method,or require certain data inputs.Id. at 3. The Company argued
that the Commission's approval of a WMP is based on whether an electric corporation identified
wildfire risk in its system and if an electric corporation developed reasonable measures to mitigate
ORDER NO. 37120 12

the wildfire risk. Id. The Company was open to additional dialogue regarding wildfire risk
assessment but argued that just because there were other approaches that could improve risk
assessments, that did not mean that the 2026 WMP failed to satisfy what was required under the
WSCA and the Guidelines.Id.
The Company argued that Staff s requests regarding more project-level information,which
the Company represented it supplied in discovery, did not change Staff s recommendation that the
2026 WMP be approved. Id. at 4. The Company stated that as it implements the 2026 WMP, it
expects to have, and supply to the Commission, more historical information and analysis.Id.
The Company represented it plans to evaluate vegetation management technical guidance,
operational knowledge, and changing industry practices as it develops WMP updates.Id. at 5. The
Company represented it is committed to community and government engagement throughout its
service territory and argued that any recommendations from Staff and/or IDL related to the same
do not diminish Staffs recommendation that the 2026 WMP be approved. Id. The Company
believed the annual review process for WMPs would provide it with the opportunity to add more
details on its procedure for timber removal and compensation.Id.
COMMISSION FINDINGS AND DECISION
An electric corporation like the Company can elect to file a WMP with the Commission
for review and approval. Idaho Code § 61-1803(2)(b). Once an electric corporation files a WMP
with the Commission for review, the WMP is subject to the authority and jurisdiction of the
Commission. Id. When reviewing a WMP, the Commission must ensure the WMP satisfies the
minimum requirements of the WSCA (Idaho Code § 61-1804(1)) and the requirements set forth
in the Commission's Guidelines.
The Commission has reviewed the record in this case. Based on our review, we find the
2026 WMP does not adequately provide information on the Company's assessment of wildfire
risk that the Commission must consider under the WSCA, specifically Idaho Code § 61-
1803(3)(a), and the Guidelines. The Commission acknowledges and appreciates the Company's
cooperation throughout Staff s review of the 2026 WMP in its responses to discovery requests and
providing additional or supplemental information for the 2026 WMP where Staff sought clarity or
supporting documentation.While the additional information provided by the Company was helpful
and demonstrates the Company's willingness to engage in the Commission's review process, we
find that the information provided did not fully resolve the material omissions or limitations with
ORDER NO. 37120 13

the 2026 WMP. Thus, additional development of the 2026 WMP is necessary before the 2026
WMP can be approved.
The Commission recognizes that the 2026 WMP is the Company's first WMP submitted
for review and approval under the WSCA. The Commission also recognizes that wildfire
mitigation planning is an evolving process. As utilities gain operational experience, incorporate
new technologies, collect additional data, and evaluate the effectiveness of mitigation activities,
future WMPs will continue to develop and improve. Thus, we understand that subsequent WMPs
will look different from a utility's first WMP.
I. Wildfire Risk Assessment and Modeling
The Commission finds that the Company's wildfire risk model requires further
development before approval can be granted. While the Commission recognizes that the WSCA
does not require a specific wildfire risk model or prescribe a particular analytical framework, we
find that the risk assessment used in a WMP must include identifiable WUI, infrastructure, and
other comparable data. Said information helps the Commission analyze whether a WMP is
implementing "approaches and methods that are designed to protect the public interest...."Idaho
Code §§ 61-1803(3); 61-1803(3)(a). Further, including that information in a wildfire risk model
would facilitate the Commission's consideration of"the consistency of the plan with the public
health, safety, and welfare," and "the degree to which the plan adequately minimizes wildfire
risk..."Idaho Code §§ 61-1804(1)(a); 61-1804(1)(c).
The Commission finds that IDLs recommendations that identifiable WUI, data on the
Company's infrastructure, and other related data must be included in a wildfire risk model to
conduct an accurate risk assessment is reasonable due to the risk of wildfire from infrastructure.
We find that not including said data does not fully demonstrate where and how wildfire risk could
arise from.
Further, while Staff believed that the Company's wildfire risk modeling approach was
reasonable, it also noted several limitations. Staff Comments at 8-9. For instance, Staff noted that
the Company's risk modeling approach did not consider the risk of wildfire ignition from its
infrastructure. Id. at 9. Staff explained that "simply overlaying assets on the risk map" only
indicated the infrastructure's physical location but did "not provide key details and attributes,"
such as the type and condition of equipment, that could help the Company "consider both the
presence of equipment in high-fire risk areas and the condition of that equipment to inform
ORDER NO. 37120 14

investments and mitigation."Id. This led Staff to believe that the risk model did not consider the
risk of the Company's infrastructure causing a wildfire. Id.
Without considering the risk of a wildfire from the Company's infrastructure, the
Commission finds that the 2026 WMP does not adequately demonstrate how the Company will
avoid and minimize wildfire risk or how it is utilizing approaches and methods that are meant to
protect the public good, which the Commission is required to consider under the WSCA.
Accordingly, the Commission finds that Company's wildfire risk model is insufficient and that
adjustments must be made to the Company's risk modeling approach before the Commission can
approve the WMP.We strongly encourage the Company to work with IDL and Staff on its wildfire
risk modeling approach and to include in future WMP filings wildfire risk modeling that
incorporates WUI, infrastructure, and similar data to accurately model and reflect the
consequences of a wildfire ignited by its infrastructure.
II. Incorporating Additional Information in the 2026 WMP
We find that supplemental information that was provided by the Company in discovery
regarding: (1) funding alternatives and sources; (2) wildfire risk mitigation benefits; (3) the
Company's risk scores; (4)wildfire-related project-level details; (5) weather station network; and
(6) use of the DSAT (collectively "Supplemental Information") was consistent with the
requirements of the WSCA and the Guidelines. However, the Supplemental Information was not
in the 2026 WMP. The Commission finds that the Supplemental Information must be included in
future WMP filings to ensure a WMP comprehensively describes the Company's operational and
mitigation measures for wildfire mitigation.
Accordingly, the Commission finds that the Company must include the following
information(collectively"WMP Update Material") in any future WMP filings:
1. Details of all funding alternatives and sources pursued, consistent with, but further
developed from, the information that was supplied in the Company's Response to Staff s
First Production Request at No. 7 and the Company's Response to Staff s First Production
Request at No. 20;
2. A narrative explaining the modeling process, including the inputs of the modeling used,by
the Company's third-party vendor, Athena Intelligence, consistent with, but further
developed from, the information that was supplied in the Company's Response to Staffs
First Production Request at No. 5 and the Company's Response to Staffs First Production
Request at No. 6;
3. A narrative that explains how mitigation activities are reducing wildfire risk and the
qualitative benefits of its mitigation efforts, consistent with, but further developed from,
ORDER NO. 37120 15

the information that was supplied in the Company's Response to Staff s First Production
Request at No. 2, the Company's Response to Staffs First Production Request at No. 5,
and the Company's Response to Staff s First Production Request at No. 6;
4. The explanation of how the Company's risk scores are derived and include any illustrations
needed, consistent with, but further developed from, the information that was supplied in
the Company's Response to Staff s First Production Request at No. 6;
5. Project-level details including the targets, explanation of the benefits, and alternatives
considered for each project, consistent with, but further developed from, the information
that was supplied in the Company's Response to Staffs First Production Request at No.
20;
6. Include the details of the weather station program status, areas of focus, annual cost, any
targets, if applicable, and any metrics used to evaluate the program, consistent with, but
further developed from, the information that was supplied in the Company's Response to
Staff s First Production Request at No. 7; and
7. Include a more detailed description of the DSAT—including the outputs of the tool,
consistent with, but further developed from, the information that was supplied in the
Company's Response to Staff s First Production Request at No. 7.
Additionally, as outlined above, the WSCA requires the Commission to consult with the
State Forester on an electric corporation's WMP and any recommendations made by the State
Forester are presumed reasonable and appropriate under the WSCA. Idaho Code § 61-1804(3).
Recommendations on a WMP from the State Forester that the Commission does not deem
unreasonable, unjust, or not in public interest must be incorporated in the Commission's decision
on a WMP. Id. The Commission finds that most of IDL's recommendations in this case are
reasonable and thus the Company must incorporate the following recommendations from IDL
(collectively the "IDL Recommendations") in any future WMP filing:
1. Include more descriptive details on the Company's risk modeling data and method, and
include clearly identifiable WUI or other comparable data in the risk modeling;
2. Include the following data inputs in future evaluations of wildfire risk:
a. Type, condition, and age of system components;
b. Data regarding the vegetative layer that includes information where the surrounding
tree canopy is taller than the adjacent system; and
c. Soil layer data.
3. Work with counties where the Company's system is located to improve wildfire response
and mitigation efforts;
4. Additional narrative details on the Company's process for cost recovery when trees on
forest industry ownerships must be removed;
ORDER NO. 37120 16

5. Description of how or if the Company's vegetation management practices differ in areas
the Company has designated as high fire risk; and
6. How the Company will measure the success of its implementation of a WMP.
While the Commission is unopposed to IDL's position that vegetation inspection practices
and certification standards should address conditions specific to wildfire risks, without further
elaboration of the additional requirements envisioned by IDL, we lack the basis to impose rigid
obligations on the Company in excess of, and possibly contrary to, what IDL acknowledges are
established industry standards. Thus, without additional information from IDL regarding why the
Company should shift away from the established industry standards, we find that its
recommendation that the Company include wildland fire specific inspection standards in its
vegetation inspection as unreasonable. However, we strongly encourage the Company to explore
opportunities to understand and address IDL's concerns about vegetation inspections overlooking
fire ignition and propagation potential. In any future WMP filing, the Company must describe
what effort it has taken to address this recommendation, or if no attempt has been made to address
the recommendation,the Company must explain why it was unaddressed.
III. Conclusion
The Commission recognizes the significant work undertaken by the Company in preparing
the 2026 WMP and appreciates the Company's cooperation throughout the process. The
Commission also recognizes that wildfire mitigation planning will continue to evolve as utilities
gain experience and additional information becomes available. At the same time,the Commission
has a responsibility to the people of Idaho to ensure that any WMP approved under the WSCA
satisfies the minimum requirements established by the Legislature. The Commission must balance
this responsibility with its obligation to provide utilities with a fair and reasonable regulatory
process and to recognize the practical challenges associated with wildfire mitigation planning.
Based on our review of the record, the Commission finds that the Company's 2026 WMP
provides a foundation for its wildfire mitigation efforts but does not contain sufficient wildfire risk
modeling that is needed for the Commission to make the findings necessary for approval under the
WSCA. Accordingly, the Commission denies the Application for approval of the 2026 WMP
without prejudice. The Commission encourages the Company to continue working with Staff and
IDL as it develops its next WMP. The Commission expects that future filings will address the
concerns and recommendations identified and outlined in this Order. A future WMP, which can
ORDER NO. 37120 17

be filed at any time following the issuance of this Order, that incorporates the risk modeling
improvements, the 2026 WMP Update Material, and IDL Recommendations will allow the
Commission to conduct the thorough review required by the WSCA and determine whether
approval is appropriate.
ORDER
IT IS HEREBY ORDERED that the Application for approval of the 2026 WMP is denied.
IT IS FURTHER ORDERED that in any future WMP filing the Company shall incorporate
the WMP Update Materials outlined in this Order, provided that such material may be reasonably
adjusted to account for change in facts, circumstances, available data, applicable assumptions, and
other relevant factors with sufficient justification.
IT IS FURTHER ORDERED that in any future WMP filing the Company shall incorporate
the IDL Recommendations outlined in this Order.
THIS IS A FINAL ORDER. Any person interested in this Order may petition for
reconsideration within 21 days of the service date of this Order regarding any matter decided in
this Order.Within seven days after any person has petitioned for reconsideration, any other person
may cross-petition for reconsideration.Idaho Code § 61-626.
ORDER NO. 37120 18

DONE by Order of the Idaho Public Utilities Commission at Boise, Idaho this 31st day of
July 2026.
YDDGE /RE ENT
;4�
T HN R. HAMMOND JR., COMMISSIONER
DAYN HARDI , COMMISSIONER
ATTEST:
Monica Barrios-Sanchez
Commission Secretary
I:\Legal\ELECTRIC\C10-E-26-01_NLI WMP\orders\C10E2601_FO_kr.docx
ORDER NO. 37120 19