20260824Motion to Admit Records.pdf

SUSAN P. WEEKS, ISB NO. 4255
JAMES, VERNON& WEEKS, P.A. RECEIVED
1626 Lincoln Way AUGUST 24, 2026
Coeur d'Alene, ID 83814 IDAHO PUBLIC
UTILITIES COMMISSION
Telephone: [phone]
Facsimile: [phone]
[e-mail]
Attorneys for Northern Lights, Inc.
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF NORTHERN CASE NO. C 10-E-26-01
LIGHTS, INC.'S APPLICATION
FOR APPROVAL OF THE NORTHERN LIGHTS INC.'S MOTION
COMPANY'S 2026 IDAHO TO ADMIT RECORDS FROM
WILDFIRE MITIGATION PLAN RELATED COMMISSION
PROCEEDINGS AND REQUEST FOR
OFFICIAL NOTICE
COMES NOW Northern Lights,Inc. ("NLI"),by and through its undersigned counsel,and,
pursuant IDAPA 31.01.01.262 ("Rule 262"), respectfully moves that the Idaho Public Utilities
Commission("Commission")admit into the record the Idaho Department of Land Comments filed
in Case No. C07-E-25-01, Kootenai Electric Cooperative, attached hereto as Exhibits 1, and the
Idaho Department of Land Comments filed in Case No. C11-E-26-01, Raft River Rural Electric
Cooperative, Inc., attached hereto as Exhibits 2 and 3.
NLI further requests pursuant to IDAPA 31.01.01.263 ("Rule 263") that the Commission
take official notice of its Order No. 36774 attached hereto as Exhibit 4. Additionally, NLI
requests the Commission take official notice of its Order No. 37081, attached hereto as Exhibit 5.
DATED this 21 st day of August, 2026.
JAMES, VERNON& WEEKS, P.A.
SUSAN P. WEEKS
Attorneys for Petitioner
NORTHERN LIGHTS INC.'S MOTION TO ADMIT RECORDS FROM RELATED
COMMISSION PROCEEDINGS AND REQUEST FOR OFFICIAL NOTICE: 1

CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing was served by email on the
following persons this 21St day of August, 2026:
Idaho Public Utility Commission Staff
Erika K. Melanson, Deputy Attorney General
Kelsea E. Ross, Deputy Attorney General
EMAIL: [e-mail]
.Sw" ;V, Wee&
SUSAN P. WEEKS
NORTHERN LIGHTS INC.'S MOTION TO ADMIT RECORDS FROM RELATED
COMMISSION PROCEEDINGS AND REQUEST FOR OFFICIAL NOTICE: 2

John A. Richards#10670
J.J. Winters#10327
IDAHO DEPARTMENT OF LANDS
300 N. 61h Street, Ste. 103
Boise, ID 8370;
(208)334-0.2,00
[e-mail]
[e-mail]
Attorneys for Idaho Department of Lands
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF KOOTENAI CASE NO. C07-E-25-01
ELECTRIC COOPERATIVE, INC.'S
APPLICATION FOR APPROVAL OF ITS IDAHO DEPARTMENT OF
2026-2028 WILDFIRE MITIGATION PLAN LANDS' COMMENTS
Idaho Department of Lands("IDL")respectfully submits the following comments in the
above-captioned matter pursuant to Idaho Code § 61-1804(3) and Order No. 36927 on behalf of
Idaho State Forester, Julia Lauch.
1. IDL has reviewed the risk modeling as provided in the submitted plan by
Kootenai Electric and presents the following reservations. Specifically, the risk products are not
presented with any overlays of the Kootenai Electric system, making it difficult at best to
understand the consequences associated with wildfire for or from the infrastructure. IDL
respectively requests that all future modeling product include a system overlay to help qualify
the associated wildfire risks to and from Kootenai Electric's system.
2. Additionally, in conjunction with the modeling, IDL strongly encourages the
following loll?.-axputs to be included in future evaluations of wildfire risk:
a. System components. Type, condition, and age,of system components should be
included as these elements can significantly increase or decrease the risks
associated with wildfire ignitions or impacts from wildfire on the system.
E
BIT 1
IDAHO DEPARTMENT OF LANDS'COMMENTS- I

b. Height vegetative layer'. The plan should inclul A ,,"`*ding the vegetative
layer that includes information where the surrat ie't�<�anopy is taller than
the adjacent system. Trees provide a significant+'s-,&,�44, ' above-ground
systems that occur outside of the managed rights-of-way. The inclusion of this
data will help to significantly improve the understanding of external risk from
vegetation to systems, thus allowing for a more informed decision process related
to system management and mitigation options.
c. Soils layer. It is well-established science that certain soil types are more prone to
trees tipping or blowing over during wind events when saturated . Again, the
inclusion of this data will help to inform the decision process of management and
mitigation actions for Kootenai Electric's systd ¢_
3. Damaging wind events occur often enough withit'i=tfte footprint of the Kootenai
service area that IDL feels it would be prudent for future iterations of the wildfire mitigation plan
to address these exceptional events through the lens of wildfire. Specifically, how these wind
events impact the risk ratings and implementation of wildfire risk mitigation for Kootenai
Electric.
4. The efforts to address wildland fire through planning efforts has a long history in
Idaho. In 2003, Idaho began the implementation of the federal 2002 Healthy Forest Restoration
Law. This law required state forestry agencies throughout the U.S. to establish criteria and
support the development of Community Wildfire Protection Plans(CWPP). This effort
continues today with IDL supporting the maintenance of CWPPs for every county in Idaho. IDL
strongly believes there is significant opportunity for cross integration of the county level CWPPs
and utility mitigation plans and encourages Kootenai Electric to actively seek partnerships with
the various counties in which their systems exist. IDL believes that doing so will strengthen
relationships, enhance community protection, and leverage resources for greater efficiency in
delivery of services and programs related to wildfire response, education, and mitigation.
5. The cost breakdown provided by Kootenai Electric was very general in scope and
would benefit from more localized examples and application. Additionally, IDL would
encourage Kootenai Electric to provide an evaluation of the cost of no mitigation actions to help
' The data associated with vegetative and soil layers can be publicly obtained,thus reducing the burden of data that
is needed to be developed or acquired through purchase by Kootenai Electric.
IDAHO DEPARTMENT OF LANDS'COMMENTS—2

clarify the impact of expenditure.investment.
6. Kootenai Electric has indicated through discovery that they utilize a process when
working on industrial lands,but the formalization of that process is not formalized for referenced
in the current submission. If this process does not currently exist, IDL requests that Kootenai
Electric add it as a project for implementation to address this aspect of risk mitigation, as it
represents a substantive unknown that can be addressed through the development of a standard
operating procedure. It is IDL's position that the SOPs, when highlighted,will build greater
confidence in relationships and the values associated with timbered lands.
;?�> In the section covering inspection of vegetation, the qualifications appropriately
nd arboriculture standards, which have long been the industry standards. However,
IT c=.g*that these standards are insufficient at addressing wildland fire related issues when
looking at vegetative mitigation as a mechanism to reduce wildfire risk. The arboriculture stands
address tree/shrub conditions and how to appropriately remove or prune. Though these standards
address vegetation health,they do not consider ignition potential or fire propagation,both of
which should be standard for inspection of vegetation treatments. When viewed in the context of
wildfires, a prime example is "ladder"fuels. Ladder fuels are vegetative structural components
that allow fire to move rapidly from ground to forest canopies. If ladder fuels are not addressed
as part of the mitigation actions, then the risk of fire propagating to crowns is substantially
higher. IDL respectfully recommends that the inspection qualification standards also include
certification specific to wildland fire.
8. IDL would like to commend the efforts of Kootenai Electric to engage with local
cooperators and community members to address risk mitigation within their System.
Respectfully submitted this 261h day of May 2026.
IDAHO DEPARTMENT OF LANDS
411(A-C
J:J.WINTERS
Attorney for Idaho Department of Lands
IDAHO DEPARTMENT OF LANDS'COMMENTS—3

CERTIFICATE OF SERVICE
I hereby certify that on this 260'day of May, 2026, I caused to be served a true and cOrred
copy of the foregoing by the method indicated below. and addressed to the following:
Kootenai Electric l] Email:tmaddalone(d*ec.com
Thomas Maddalone mandrea(a-kec.com
Michael G. Andrea
9014 W. Lancaster Road
Rathdrum, ID 83858
Idaho Public Utilities Commission ❑x Email: secretaiyCeypuc.idaho.gov
Commission Secretary erika.melanson(ri),puc.idaho.gov
P.O. Box 83720
Boise, ID 83702-0074
Erika Melanson
Deputy Attorney General
11331 W. Chinden Boulevard, Bldg. 8
Suite 201-A (83714)
P.O. Box 83720
Boise, ID 83702-0074
Is/Kmvla Dawson
Kay]a Dawson
IDAHO DEPARTMENT OF LANDS'COMMENTS-4

John A. Richards#10670
J.J. Winters#10327
IDAHO DEPARTMENT OF LANDS
300 N. 61h Street, Ste. 103
Boise, ID 83702
[phone]
[e-mail]
[e-mail]
Attorneys for Idaho Department of Lands
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF RAFT RIVER RURAL CASE NO. C11-E-26-01
ELECTRIC CO-OP INC.'S APPLICATION
FOR APPROVAL OF ITS 2026-2028 IDAHO DEPARTMENT OF
WILDFIRE MITIGATION PLAN LANDS' COMMENTS
In accordance with Idaho Code § 61-1804, the Idaho Department of Lands ("IDL")by
and through undersigned counsel, submits the following comments in the above-referenced
matter:
1. IDL has reviewed the risk modeling as provided in the submitted Wildfire
Mitigation Plan by Raft River and presents the following:
a. The modeling described in section 3.4 lacks critical details on data inputs
and methodology to adequately determine the validity of the outputs
presented in the plan. IDL respectfully requests that additional narrative
descriptive details be included for the purposes of process and product
evaluation.
2. In conjunction with risk modeling, IDL strongly encourages the following data
inputs to be included in future evaluations of wildfire risk:
a. System components. Type, condition, and age of system components
should be included as these elements can significantly increase or decrease
E
IBIT 2
[DAHO DEPARTMENT OF LANDS'COMMENTS- 1

the risks associated with wildfire ignitions or impacts from wildfire on the
system.
b. Vegetative height lam. The plan should include data regarding the
vegetative layer that includes information where the surrounding tree
canopy is taller than the adjacent system. Trees provide a significant strike
risk to above-ground systems that occur outside of the managed rights-of-
way. The inclusion of this data will help to significantly improve the
understanding of external risk from vegetation to systems,thus allowing
for a more informed decision process related to system management.and
mitigation options.
C. Soils layer. It is well-established science that certain soil types are more
prone to trees tipping or blowing over during wind events when saturated.
Again, the inclusion of this data will help to inform the decision process of
management and mitigation actions for Raft River's system.
3. Significant straight line wind events regularly occur within the footprint of the
Raft River service area. IDL feels it would be prudent for future iterations of the wildfire
mitigation plan to address these events through the lens of wildfire. Specifically, how these wind
events impact the risk ratings and implementation of wildfire risk mitigation for Raft River with
emphasis on the Idaho service area.
4. The efforts to address wildland fire through planning has a long history in Idaho.
In 2003, Idaho began the implementation of the federal 2002 Healthy Forest Restoration Act.
This act required state forestry agencies throughout the U.S. to establish criteria and support the
development of Community Wildfire Protection Plans(CWPP). This effort continues today with
IDL supporting the maintenance of CWPPs for every county in Idaho. IDL strongly believes
there is significant opportunity for cross integration of the county level CWPPs and utility
mitigation plans and encourages Raft River to actively seek partnerships with the various
counties in which their systems exist. IDL believes that doing so will strengthen relationships,
The data associated with vegetative and soil layers can be publicly obtained,thus reducing the burden of data that
is needed to be developed or acquired through purchase by Raft River.
IDAHO DEPARTMENT OF LANDS'COMMENTS—2

enhance community protection, and leverage resources for greater efficiency in delivery of
services and programs related to wildfire response, education, and mitigation.
5. In section 4.3.3 covering inspection of vegetation, the qualifications appropriately
center around arboriculture standards, which have long been the industry standards. However,
IDL argues that these standards are insufficient at addressing wildland fire-related issues when
looking at vegetative mitigation as a mechanism to reduce wildfire risk. The arboriculture stands
address tree/shrub conditions and how to appropriately remove or prune. Though these standards
address vegetation health,they do not consider ignition potential or fire propagation,both of
which should be standard for inspection of vegetation treatments. When viewed in the context of
wildfires, a prime example is"ladder"fuels. Ladder fuels are vegetative structural components
that allow fire to move rapidly from ground to forest canopies. If ladder fuels are not addressed
as part of the mitigation actions, then the risk of fire propagating to crowns is substantially
higher. IDL respectfully recommends that the inspection qualification standards also include
certification specific to wildland fire.
6. IDL respectfully requests Raft River include additional narrative details on how
inspections are prioritized or how a change in frequency of inspections occurs related to areas of
the Raft River system that are shown by the wildfire risk modeling to be at elevated risk.
7. Situational awareness is critical to effectively manage and react to environmental
or system functional changes. Raft River's plan lacks sufficient details on how they obtain and
utilize situational awareness data, making it difficult to evaluate the appropriateness and
adequacy of Raft River's situational awareness related to wildfire.
8. The plan contains several editorial items that warrant updating to reflect current
information:
• Section 2.1.1 should reflect policy directing the mitigation plan elements,
• Section 2.5.2.1.1 - the Owyhee County Plan Hazard Mitigation Plan has
been updated and approved since 2018.
• Section 2.5.4.1 -the Idaho Forest Action Plan was initially penned in 2010
and updated in 2020.
IDAHO DEPARTMENT OF LANDS'COMMENTS-3

• Section 2.5.5.1 - the Bureau of Land Management now includes the
National Wildland Fire Service.
• Section 3.1.1.1 is not an accurate trend reflection for Idaho based on data
maintained by IDL.
Respectfully submitted this 5°i day of June 2026.
IDAHO DEPARTMENT OF LANDS
JOHN RICHARDS
Attorney for Idaho Department of Lands
IDAHO DEPARTMENT OF LANDS'COMMENTS-4

CERTIFICATE OF SERVICE
I hereby certify that on this 5'h day of June, 2026, I caused to be served a true and correct
copy of the foregoing by the method indicated below, and addressed to the following:
Raft River Rural Electric Co-op, Inc. ❑x Email:dshirley(doa►ic�valle.
David F. Shirley mchristensen(a,)rrelectric.com
Attorney
Parsons, Loveland, Shirley& Miller LLP
137 West 13`h Street
P.O. Box 910
Burley, ID 83318
Mike Christensen
Operations Superintendent
155 North Main
P.O. Box 617
Malta, ID 83342
Idaho Public Utilities Commission O Email: secretaryCc),puc.idaho.gov
Commission Secretary kelsea.ross0Vpuc.idaho.gov
P.O. Box 83720
Boise, ID 83702-0074
Kelsea E. Ross
Deputy Attorney General
P.O. Box 83720
Boise, ID 83702-0074
Is/Kavla Dawson
Kayla Dawson
IDAHO DEPARTMENT OF LANDS'COMMENTS-5

From: Kayla Dawson <[e-mail]>
Sent: Tuesday, June 9, 2026 8:40 AM
To: secretary<[e-mail]
Subject: C11-E-26-01 Raft River Rural Electric Co-op Wildfire Mitigation Plan 2026-2028 -
Amended IDL Comments
Good morning- Attached for filing and service please find Amended Idaho Department of
Lands' Comments in the matter of Raft River Rural Electric Co-op, Inc.'s Application for
Approval of its 2026-2028 Wildfire Mitigation Plan, Case No. C11-E-26-01.
Kind regards,
Kayla Dawson
Legal Assistant
Idaho Department of Lands
300 N. 61"Street, Suite 103, Boise, ID 83702
Office: [phone]
Email: I<[e-mail]
Website: https://www.idt.idaho.go,i
NOTICE: This message, including any attachments, is intended only for the individual(s) or
entity(ies)named above and may contain information that is confidential, privileged,
attorney work product, or otherwise exempt from disclosure under applicable law. If you
are not the intended recipient, please reply to the sender that you have received this
transmission in error, and then please delete this email.
E
IBIT 3

John A. Richards#10670
J.J. Winters#10327
IDAHO DEPARTMENT OF LANDS
300 N. 61h Street, Ste. 103
Boise, ID 83702
[phone]
[e-mail]
[e-mail]
Attorneys for Idaho Department of Lands
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF RAFT RIVER RURAL CASE NO. C11-E-26-01
ELECTRIC CO-OP INC.'S APPLICATION
FOR APPROVAL OF ITS 2026-2028 AMENDED IDAHO
WILDFIRE MITIGATION PLAN DEPARTMENT OF LANDS'
COMMENTS
In accordance with Idaho Code § 61-1804, the Idaho Department of Lands ("IDL")by
and through undersigned counsel, submits the following amended 'comments in the above-
referenced matter:
1. IDL has reviewed the risk modeling as provided in the submitted Wildfire
Mitigation Plan by Raft River and presents the following:
a. The modeling described in section 3.4 lacks critical details on data inputs
and methodology to adequately determine the validity of the outputs
presented in the plan. IDL respectfully requests that additional narrative
descriptive details be included for the purposes of process and product
evaluation.
b. When conducting risk modeling, two key elements are necessary for a
model to accurately represent risk—probability of occurrence and
Amendcd to include comment 1.b.
AMENDED IDAHO DEPARTMENT OF LANDS'COMMENTS— 1

consequence to values. provided by Raft River does not
include the latter as it lacks -1�Pul i� tifiable wildland urban interface
(WUI)or other comparable da n I'h modeling as a data input or as a
mask 2. As a result of this exclusion,the consequence of utility ignited
fires cannot be accurately reflected, and brings into question the validity of
the modeling. In light of this omission, IDL recommends to PUC staff that
the plan be rejected by the Commission.
2. In conjunction with risk modeling, IDL strongly encourages the following data
inputs to be included in future evaluations of wildfire risk:
a. System components. Type, condition, and age of system components
should be included as these elements can significantly increase or decrease
the risks associated with wildfire ignitions or impacts from wildfire on the
system.
b. Vegetative height lam. The plan should include data regarding the
vegetative layer that includes information where the surrounding try-,
canopy is taller than the adjacent system. Trees provide a significike
risk to above-ground systems that occur outside of the managed rights-of-
way. The inclusion of this data will help to significantly improve the
understanding of external risk from vegetation to systems,thus allowing
for a more informed decision process related to system management and
mitigation options.
C. Soils laver. It is well-established science that certain soil types are more
prone to trees tipping or blowing over during wind events when saturated.
Again,the inclusion of this data will help to inform the decision process of
management and mitigation actions for Raft River's system.
z IDL maintains a current state-level WUI layer and invites Raft River to contact Tyre Holfeltz for access to the data
and instruction on how to integrate that data into their modeling.
3 The data associated with vegetative and soil layers can be publicly obtained,thus reducing the burden of data that
is needed to be developed or acquired through purchase by Raft River.
AMENDED IDAHO DEPARTMENT OF LANDS'COMMENTS—2

3. Significant straight line wind events regularly occur within the footprint of the
Raft River service area. IDL feels it would be prudent for future iterations of the wildfire
mitigation plan to address these events through the lens of wildfire. Specifically, how these wind
events impact the risk ratings and implementation of wildfire risk mitigation for Raft River with
emphasis on the Idaho service area.
4. The efforts to address wildland fire through planning has a long history in Idaho.
In 2003, Idaho began the implementation of the federal 2002 Healthy Forest Restoration Act.
This act required state forestry agencies throughout the U.S. to establish criteria and support the
development of Community Wildfire Protection Plans(CWPP). This effort continues tod.u',V`L ft
IDL supporting the.%aintenance of CWPPs for every county in Idaho. IDL strongly belrt v y-�:
there is significant rtunity for cross integration of the county level CWPPs and utility
mitigation plans and encourages Raft River to actively seek partnerships with the various
counties in which their systems exist. IDL believes that doing so will strengthen relationships,
enhance community protection, and leverage resources for greater efficiency in delivery of
services and programs related to wildfire response, education, and mitigation.
5. In section 4.3.3 covering inspection of vegetation, the qualifications appropriately
center around arboriculture standards, which have long been the industry standards. However,
IDL argues that these standards are insufficient at addressing wildland fire-related issues when
looking at gItive mitigation as a mechanism to reduce wildfire risk. The arboriculture stands
address treehhrdb conditions and how to appropriately remove or prune. Though these standards
address vegetation health,they do not consider ignition potential or fire propagation,both of
which should be standard for inspection of vegetation treatments. When viewed in the context of
wildfires, a prime example is gadder"fuels. Ladder fuels are vegetative structural components
that allow fire to move rapidly from ground to forest canopies. If ladder fuels are not addressed
as part of the mitigation actions,then the risk of fire propagating to crowns is substantially
higher. IDL respectfully recommends that the inspection qualification standards also include
certification specific to wildland fire.
6. IDL respectfully requests Raft River include additional narrative details on how
inspections are prioritized or how a change in frequency of inspections occurs related to areas of
the Raft River system that are shown by the wildfire risk modeling to be at elevated risk.
AMENDED IDAHO DEPARTMENT OF LANDS'COMMENrrs—3

7. Situational awareness is critical to effectively manage and react to environmental
or system functional changes. Raft River's plan lacks sufficient details on how they obtain and
utilize situational awareness data, making it difficult to evaluate the appropriateness and
adequacy of Raft River's situational awareness related to wildfire.
8. The plan contains several editorial items that warrant updating to reflect current
infotn:
• Section 2.1.1 should reflect policy directing the mitigation plan elements,
• Section 2.5.2.1.1 -the Owyhee County Plan Hazard Mitigation Plan has
been updated and approved since 2018.
a Section 2.5.4.1 -the Idaho Forest Action Plan was initially penned in 2010
and updated in 2020.
a Section 2.5.5.1 -the Bureau of Land Management now includes the
National Wildland Fire Service.
a Section 3.1.1.1 is not an accurate trend reflection for Idaho based on data
maintained by IDL.
Respectfully submitted this 91h day of June 2026.
IDAHO DEPARTMENT OF LANDS
-44k'
J.J.WINTERS
Attorney for Idaho Department of Lands
AMENDED IDAHO DEPARTMENT OF LANDS'COMMENTS-4

CERTIFICATE OF SERVICE
I hereby certify that on this 9'h day of June, 2026, I caused to be served a true and correct
copy of the foregoing by the method indicated below, and addressed to the following:
Raft River Rural Electric Co-op, Inc. ❑x Email:dshirley(doa►ic�valle.
David F. Shirley mchristensen(a,)rrelectric.com
Attorney
Parsons, Loveland, Shirley& Miller LLP
137 West 13'h Street
P.O. Box 910
Burley, ID 83318
Mike Christensen
Operations Superintendent
155 North Main
P.O. Box 617
Malta, ID 83342
Idaho Public Utilities Commission O Email: secretaryCc),puc.idaho.gov
Commission Secretary kelsea.ross0Vpuc.idaho.gov
P.O. Box 83720
Boise, ID 83702-0074
Kelsea E. Ross
Deputy Attorney General
P.O. Box 83720
Boise, ID 83702-0074
Is/Kavla Dawson
Kayla Dawson
AMENDED IDAHO DEPARTMENT OF LANDS'COMMENTS-5

Off 9F� e'Seczoary
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF COMMISSION ) CASE NO. GNR-E-25-02
STAFF'S APPLICATION FOR APPROVAL )
OF A FILING PROCESS FOR WILDFIRE ) ORDER NO. 36774
MITIGATION PLANS )
On June 18,2025,Staff("Staff')of the Idaho Public Utilities Commission("Commission")
applied to establish a filing process for Wildfire Mitigation Plans ("WMPs") submitted under the
Wildfire Standard of Care Act ("WSCA"). See Idaho Code § 61-1801 et seq. Staff requested the
matter be processed by Modified Procedure, and that the Commission issue an order adopting a
WMP filing process no later than September 5, 2025.
On June 18, 2025, Staff moved for a Commission order setting initial temporary filing
for WMPs.
.... On June 30, 2025, the Commission issued a Note Application and Notice of
Intervention Deadline, establishing a deadline for interested pr'. o petition to intervene. Order
No. 36660. The Commission granted intervention to PotlatchDeltic Corporation ("Potlatch"),
Idaho Power Company,Avista Corporation,d/b/a Avista Utilities,Kootenai Electric Cooperative,
Inc. ("KEC"), Rocky Mountain Power, a Division of PacifiCorp, the Idaho Department of Lands
("IDL"), the City of Idaho Falls ("Idaho Falls"), Bennett Lumber Products, Inc., Idaho Forest
Group, Manulife Investment Management, Molpus Woodlands Group, and Stimson Lumber
Company. Order Nos. 36673, 36692, 36697, and 36699.
On July 10,2025,Staff filed its Supplemental Application which included Staff's proposed
guidelines outlining additional requirements to be included within WMPs, Staff's proposed"Need
to Know Document," and some alternative proposals from the original Application ("Original
Application").
On July 16, 2025, the Commission issued an interlocutory order s-uspe ding the filing of
WMPs before a final order issued in this case. Order No. 36674 at 2. The Order-also allowed for
interested parties to propose schedules for the filing of WMPs in their cominetlu filed in this case.
Id.
ORDER NO. 36774 I EXHIBIT 4

On August 7.,2025,interested parties and utilities submitted comments on Staff's proposals
within its Original Application and Supplemental Application.
On August 21, 2025, Staff filed reply comments.
Having reviewed the record, the Commission now issues this Order establishing a
procedure and filing schedule for WMPs submitted for approval under the WSCA.
BACKGROUND
On February 21, 2025, the first version, Senate Bill 1124a, of the WSCA was introduced
In:the Idaho Senate State Affairs Committee. After several amendments,that version failed to pass
in the '-hate. Subsequently, a revised version of the WSCA, Senate Bill 1183, was enacted and
took effect on July 1, 2025. The law requires the Commission to annually approve WMPs for
investor-owned utilities ("IOUs"). Idaho Code § 61-1803(2)(a), -1803(4). Municipal and
cooperative utilities ("Unregulated Entities") may also submit WMPs for the Commission's
review. Id. at § 61-1803(2)(b), -1803(4). The Commission can determine filing deadlines for
WMPs, staggering them as needed. Id. at § 61-1803(2)(a)—(b), -1803(4), -1803(5). Under the
WSCA, if a wildfire results in a lawsuit against an electric corporation, "there is a rebuttable
presumption that the electric corporation acted without negligence if, with respect to the cause of
the wildfire, the electric corporation reasonably implemented a commission-approved wildfire
mitigation plan."Idaho Code § 61-1806.
` 7RE APPLICATION
Staff seeks to establish a clear regulatory process for all IOUs, municipalities, and
cooperatives to follow and that satisfies the requirements of the WSCA. To accomplish this, Staff
proposes filing procedures, guidelines for WMPs, recommended filing dates, and the key
components that should be included in WMPs. Staff also requests that the Commission clearly
define the necessary elements of a WMP and associated compliance reports, as required by Idaho
Code §§ 61-1803(3) and 61-1803(5). Staff further requests direction on any other information the
Commission believes should be included in these filings.
' On August 20,2025,Potlach filed comments responding to comments from interested parties filed by the August 7,
2025, public comment deadline. Under IDAPA 31.01.01.202.01(d), a Notice of Modified Procedure establishing a
comment deadline and a deadline for replies by the moving party. The Notice of Modified Procedure issued in this
case established an August 7,2025,comment deadline and an August 21,2025,reply deadline.Potlach is not the party
who filed the Application, which initiated this proceeding. Thus, Potlatch is not the moving party authorized to file
comments by the August 21,2025,reply comment deadline. Instead,Potlatch had to file all its comments by August
7,2025.Accordingly,Potlatch's comments filed on August 20,2025,are untimely and will not be considered.
ORDER NO. 36774 2

PARTY AND PUBLIC COMMENTS
Fifteen IOUs, municipalities, cooperatives, and electric customers filed comments. While
some concerns expressed were unique to individual parties, multiple entities shared many of the
same issues.
I. Filing Timeline
Several intervenors raised concerns about the timeline for submitting WMPs. Because the
Commission has six months to approve or reject a proposed plan, these commentors worry that
some WMPs will not be approved before the next wildfire season. Accordingly,these commenters
argued that Staff's proposed schedule unfairly affects Unregulated Entities—such as
municipalities and cooperatives—by leaving them insufficient time to get their WMPs approved.
Instead of Staff's proposed filing schedule,they recommended a more flexible timeline that would
let these entities submit their WMPs earlier to ensure timely approval.For example,one suggestion
was for IOUs to fide their plans immediately after the Commission issues its final order in this case,
with Unregulated Entities subn itthig by November 1,2025. However, one commenter, an electric
customer, felt the proposed schedule was too rushed and suggested that no plans be submitted
before January 1, 2026.
II. Justification of Costs
Many intervenors were concerned about having to justify the costs of complying with a
WMP. Idaho Falls and KEC argued that requiring them to explain their spending could lead to a
review of tes and internal operations. They are worried that such financial scrutiny could
interfere w* die authority of their own governing bodies. As a result,they urged the Commission
to limit its inquiries into the costs related to their WMPs.
Some commenters—mainly smaller municipalities and cooperatives—argued that cost
justification is either unnecessary or should not apply to Unregulated Entities. Others pointed out
that wildfire mitigation costs are often hard to separate from routine operational expenses.Because
of this,they felt that Staffs proposal>is overly burdensome.
These commenters suggested that, instead of detailed cost breakdowns, signed attestations
or formal resolutions from their governing bodies should be enough to meet the minimum
requirements of the WSCA. These documents could show that the entities have reasonably
weighed wildfire mitigation costs and considered cost-effective, practical approaches—like
responsible line design for both new and existing infrastructure. Alternatively, Idaho Falls
ORDER NO. 36774 3

proposed using a system like the North American Electric Reliability Corporation's ("NERC")
periodic spot checks and audits to review costs.
III.Fire Reporting
Fire reporting requirements were another key concern for intervenors. Idaho Falls argued
that Staff s proposal to report fires within a quarter mile of utility infrastructure goes beyond what
the WSCA requires and is overly burdensome due to the high number of fires in its service area.
Instead, it suggested that Staff rely on the U.S. Department of the Interior's Wildland Application
Information Portal for fire data.
Other intervenors said they lack the resources to report all fires within a,q I rter Anile of
their infrastructure. They recommended that this information be gathered from �
instead. Those who did not entirely oppose fire reporting still supported a more limited
They generally suggestpd,oplyze rting the occurrence and general location of fires that directly`
affect their systems. ti J
Idaho's three l roposed a narrower requirement: report only those fires that
are over one acre in si known to the utility or reported by the National Interagency
Fire Center ("NIFC"), occur within a high wildfire risk area and within a quarter mile of utility
infrastructure during the compliance year, and include only causes that are publicly available
through NIFC at the time the compliance report is.-prepared.
IV.Compliance Reports
The intervenors generally asserted that the compliance reporting rules proposed by Staff
were too burdensome and went beyond. t1ac WS i~itended. The IOUs argued that setting
monthly progress targets could create g fidgO imprcw a,-n dfAt they are not complying with their
WMPs. According to the IOUs, platy ustWlly h vc that guide actions throughout the
year.
The IOUs suggested that cor-plz we rqp, `e, :s Itted on a staggered schedule: Idaho
Power on April 1,Rocky Mountain Pow== ka r ,azrdr lasta Coiporgdon on June 1 each year.
These reports would include results from the previous calendar year and should be limited to
clearly known and measurable outcomes identified at the time each WMP is prepared.
The Unregulated Entities recommended that the Commission reject Staffs proposed
compliance reporting process. They argued that reporting requirements should differentiate
between regulated IOUs and Unregulated Entities,with the latter facing less strict rules.As a result,
ORDER NO. 36774 4

they called for further discussions and workshops with Staff to create a reporting process that
aligns with their interpretation of the WSCA.
V. Proposed Requirements for WMP
Intervenors were generally concerned about being required to develop rolling WMPs with
a three-year pl � . horizon. The IOUs believed such plans would impose a significant
administrative bu: = Instead, they supported static three-year plans without the inclusion of
least-cost, least risk evaluations of line design. KEC expressed similar concerns, urging more
flexibility in the guidelines governing WMPs from Unregulated Entities.
Idaho Falls also urged flexibility in the requirements for WMPs. Specifically, Idaho Falls
argued that Staff's proposed process would require it to submit extensive and detailed information
to the Commission—including monthly targets, cost-benefit analyses, goals, metrics, and specific
data for each part of its WMP. According to Idaho Falls, this would be overwhelmingly
burdensome. As noted above, Idaho Falls recommended adoption of NERC's process for
evaluating system reliability. This process involves regular confirmation of compliance by an
electric municipality's governing board,along with occasional spot checks and audits. Idaho Falls
asserted that this method is cheap, streamlined, and familiar to municipalities, making it a more
practical way for municipal utilities to show compliance.
Customer comments on this issue sought stricter requirements for WMPs. For example,
one customer commenter asserted that the non-exhaustive list of "Preventative Actions and
Programs" that Staff indicated may be included in a WMP is required under Idaho Code § 61-
1803(3)(b). Another commenter recommended that each WMP include detailed descriptions of
every wildfire-related damage claim the electric corporation paid over the last two decades,
regardless of whether the company admitted liability,paid voluntarily,or because of a court order
or arbitration.
VI.Coordination with the Idaho Department of Lands
The IOUs generally supported Staff s proposed WMP requirements, with a few minor
adjustments and reform_
eform ifically, they requested that discussions of de-energization exclude
circumstances where paok `o terminated at the request of first responders or for planned activities
like maintenance or circuit hardening. Although such shut offs may be part of broader wildfire
mitigation efforts,the IOUs characterized them as routine operational procedures.
ORDER NO. 36774 5

Many commentors, including the IOUs, recommended that the Commission clarify how it
will evaluate recommendations from other governmental agencies, like the Idaho Department of
.l..,a C LAL'). When describing how input from federal,state,and local agencies was considered
v' ing vegetation management standards, the IOUs emphasized that they must operate
v*W ; cific easements or rights-of-way and comply with the National Electrical Safety Code.
",I`'limfore, they recommended that the Commission limit its explanation to how agency
recommendations directly relating to surface fuels, fuel reduction, or vegetation near utility
infrastructure were considered. Comments from IDL itself echoed some of these concerns.
VII. Timber Protections
A group of commentors expressed concern over the lack of what they believed were
adequate protections for marketable timber in Staff s proposed WMP guidelines. Idaho Code §
61-1803(3)(g)(iii) requires that landowners be compensated at fair market value ("FMV") for the
removal of live,marketable timber. However,these commentors noted that neither the WSCA nor
Staff's proposed guidelines outlined a process for valuid*Aotice, or dispute resolution.
To address this, these commentors proposed that the Commission require each WMP
include a written inventory of all proposed tree removals, identification of an independent third-
party timber appraiser if marketable timber is involved, and a procedure allowing landowners to
object or seek expedited mediation prior to any timber removal. Inclusion of these requirements
would reduce the likelihood of post hoc legal disputes.
The IOUs agreed that clarifying how FMV will be determined could reduce confusion and
landowner frustration when timber removal is necessary. Additionally, they also believed that
collaborating with all stakeholders to develop a list of timber companies or a centralized map of
timber lands would support compliance with the FMV compensation requirement for any timber
that is removed.
VIII. Retroactivity
The IOUs disagreed with Staffs proposed prohibition of retroactive amendments to
WMPs. They argue that this limitation does not reflect the practical challenges of implementing a
WMP or the required flexibility and innovation during the plan year, while still complying with
the WSCA and maintaining eligibility for its liability protections. Accordingly, the IOUs believe
they should be allowed—even encouraged—to respond#d(i kly to changing conditions and adopt
more efficient or cost-effective wildfire mitiptio1q, strategies, even after a WMP has been
ORDER NO :W774 6.

approved. According to the IOUs, without the ability to amend a WMp mid-year (subject to
Commission review and approval), the WSCA may unintentionally discourage innovation and
efficiency by forcing utilities to follow outdated plans strictly,just to preserve liability protections.
STAFF REPLY COMMENTS
Staffs reply comments responded to the key concerns raised by the intervenors, clarifying
that any issues not specifically addressed should not be interpreted as agreement or approval. Staff
also incorporated some concerns that were originally brought up in public comments.Additionally,
a proposed set of WMP guidelines was included as an exhibit with the reply comments. Staff s
responses to individual issues are discussed in the sections below.
I. Filing Schedule
Staff indicated that many electric municipalities and cooperatives, in addition to Idaho's
three largest IOUs, are ready to file their WMPs with the Commission. Accordingly, Staff stated
that it expects up to 15 W-N4Ps to be submitted, in addition to the Commission's usual caseload.
Staff stated that reviewing and approving all 15 WMPs before the 2026 fire season is unrealistic
and would not allow sufficient time for proper review and stakeholder input.
To address this, Staff has proposed alternative filing schedules, aiming to avoid
overwhelming the review process while still ensuring fairness to Unregulated Entities. Staffs two
proposed schedules account for each utility's size, complexity, and expressed preferences.
Although the proposed schedules may not allow every utility to receive an order approving its
WMP before the start of the 2026 fire season, the few that do not should receive one shortly
thereafter. The following two tables reflect Staffs two proposed filing schedule options:
Option No. I:Staff's Preferred Schedule
Electric Corporation Permitted To File
Month Large Utility Medium Utility small Utility
No earlier than Idaho Power Kootenai Electric Raft River
October 1
No earlier than pvista Northern Lights Idaho County Light
November I and Power
No earlier than Pacificorp City of Idaho Falls United Electric
December 1
No earlier than Atlanta Power' Clearwater Power Lost River Electric*
Januar I
No earlier than Lower Valley Fall River' City of Banners
Fehruan I Lner • Fe
Vo earlier than
ilarch 1 Any other electric corporation that wishes to file
ORDER NO. 36774 7

Option No.2
Month Electric Corporation Permitted To File
No earlier than Idaho Power Kootenai Electric City of Idaho Falls
October 1
No earlier than Avista Norlhern Lights Clearwater Power
No%cmber 1
No earlier than Idaho County Light
December 1 pacitiCorp Raft River and Power
No earlier than Atlanta Power' United Electric Lost River Electric'
Januar t
No earlier than Lower Vallev Fall River' City of Bonrrers
February 1 Energy' Ferry`
No earlier than Anv other electric corporation that wishes to rile
March 1
*These utilities did not request an expedited filing timeline.
Staff Reply Comments at 4. Staff preferred Option 1, believing it offered a balanced and
manageable review schedule. Under this option, one large, one medium, and one small utility
(based on Idaho customer count)would have the opportunity to file a WMP each month,beginning
October 1, 2025. Electric corporations who requested expedited filing would file before those that
did not.
Option 2 schedules filings from the largest to the smallest utility, followed by those not
requesting expedited review. Although this approach uses a clear and consistent method, Staff
noted it front-loads the workload and may not allow sufficient time for thorough review. Under
both options, the comment period for each WMP will be set when the plan is filed, in accordance
with the Commission's Rules of Procedure 31.01.01 et. seq. Staff requested that the Commission
adopt a filing schedule that reasonably balances expedited requests. Staff also stated that if it later
determines it can manage additional filings sooner than expected, it will formally ask the
Commission to allow certain utilities to file their WMPs ahead of schedule.
II. Annual Filings
Staffs original application requested that the Commission require electric corporations to
file their annual WMP reviews one year after the approval date of their previous plan, with set
dates for the IOUs. However, since Staff is now proposing alternative filing schedules, the timing
for annual reviews may shift. Instead of the schedule proposed in the Original Application, Staff
requested that the Commission direct each electric corporation to file its annual review one year
after the approved filing date, consistent with whatever WMP schedule the Commission adopts.
Although alternative annual filing dates may be proposed in the initial WMP submissions, Staff
believed this is a reasonable starting point for annual review filings.
ORDER NO. 36774 8

III.WMP Forecast and Planning Horizon
Staff disagreed with the IOUs' proposed static,three-year WMPs. Staff believed the IOUs
proposal for static plans does not align with prior orders or the Commission's planning standards.
As noted in Staff's Supplemental Application, Order No. 36042 requires Idaho Power to extend
the forecast of its WMP to five years. Idaho Power has followed this approach, submitting rolling
plans for 2024 and 2025 that build on prior versions and extend the forecast accordingly. Rocky
Mountain Power also develops its WMP with a three-year planning cycle, consistent with its
schedules in Utah and Wyoming.See Order No.36405.Accordingly,Staff recommended that each
WMP include, at minimum, a three-year forecast.
IV.WMP Requirements for IOUs and Unregulated Entities
Staff believed its proposed WMP guidelines are reasonable, not overly burdensome, and
account for the varying size and complexity of each electric corporation. The purpose of the
guidelines is to help the Commission clearly define what must be included in a WMP under Idaho
Code §§ 61-1803(3)(a)—(g), and to establish consistent expectations for all electric corporations
choosing to file with the Commission.
Staff asserted that the only difference between IOUs and Unregulated Entities corporation's
under the WSCA is that IOUs are required to file WMPs, while Unregulated Entities buave the
option to do so. However,to receive the liability protections offered under Idaho Code§6:1-1806,
Unregulated Entities must have a Commission-approved WMP. Consequently, Staff does Uot
support applying different standards and believes all filers seeking these protections mustrsieet the
same statutory requirements.
The WSCA contains standards,procedures,and schedules for infrastructure inspection and
maintenance, de-energization practices, and vegetation management. These may be subject to the
availability of access to rights-of-way. Staff s proposed guidelines request measurable targets and
goals for the sections on infrastructure inspection and maintenance and vegetation management.
Staff viewed this information as critical to understanding how a utility plans to carry out its WMP
within the designated planning cycle. This information can also aid the Commission's evaluation
of whether the plan is feasible, cost-effective,and sufficient to reduce wildfire risk,as required by
Idaho Code §§ 61-1804(b) and (c). Accordingly, Staff recommended that the Commission adopt
its proposed WMP gui0 as minimum requirements forcI11':°° addition to those listed
under Idaho Code §§ 61;,.1*.. (3)(aHg).
ORDER NO. 36774 9

V, Standard Operating Procedures in WMPs
Staff believed it was unnecessary for WMPs to include detailed standards, criteria, or
operational protocols for de-energization. Dr-energizations carried out at the request of fire
agencies or for planned utility work are already covered under each utility's Standard Operating
Procedures ("SOPs"). Consequently, Staff proposed. removing these two situations from the
minimum WMP requirements.
In response to concerns about separating wildfire mitigation activities from routine SOPs,
Staff maintained that the WMP should serve as the utility's comprehensive wildfire mitigation
strategy. Staff acknowledged that wildfire mitigation is just one aspect of a utility's broader
t a 3~s and that many projects may serve multiple purposes. Rather than trying to split or
,Mlocate costs,however, Staff recommended including the full project cost in the WMP,along with
an expsation if the project also addresses goals beyond wildfire mitigation. Furthermore, if a
initigatit+n activity provides benefits beyond wildfire risk reduction, Staff recommended that
electric:corporations explain in their WMPs whether the effort is part of normal ons or goes
beyond what is covered in their SOPS. Staff believed most of this information alriidoxists, as it
would be developed during internal approvals by each electric corporation's governing board.
VI."Least Cost,Least Risk"Line Design Requirements
Staff did not believe that including line design methods in a WMP infringes on the authority
of the governing boards of Unregulated Entities over costs or rates. Rather, this requirement is
clearly outlined in the WSCA and applies to all electric corporations that submit a WMP. To
support the contention, Staff noted that Idaho Co s > 1-1803(3)(e)r+xpdres all WMPs to include,
at a minimum, "financially prudent and reasonacticable method :of line design for new,
planned, and existing lines to mitigate fire risk."
In response to other comments, Staff revised the language in its proposed guidelines to
better align with the WSCA. Specifically, Staff removed the phrase "least-cost, least-risk" and
replaced it with language that reflects "a balance of mitigation costs with the resulting reduction
in wildfire risk,"which more accurately reflects the text.of:,. ho Code § 61-1803(3).
Staff s updated proposed guidelines now state:
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 wildfi1*t. for the following, but not limited to...
ORDER NO. 36774 10

Staff s Reply Comments- Exhibit 1 at 6.
Staff believed this level of detail is important for h,-Commission's review of WMPs under Idaho
Code § 61-1803(3)(e). Staff requested that the Commission adopt the revised language described
above as part of the minimum requirements for all WMPs.
VII. WMP Amendments
Staff opposed the retroactive application of WMPs without the express approval of the
Commission. Idaho Code § 61-1803(4) states that Commission-approved WMPs must be
implemented upon approval. Staff interpreted this to mean that a WMP becomes effective on the
date of the Commission's approval and remains so until approval of a new WMP. Staff requested
clarification of the effective period for each approved WMP. If no such clarification is provided,
Staff will propose effective dates in each individual WMP filing.
Although Staff is not opposed to utilities filing amendments to approved or pending
WMPs, it noted that significant updates or modifications could affect the entire plan. Under Idaho
Code § 61-1804, the Commission must approve or deny amended plans within six months.
The : Staff requested the Commission clarify whether it will accept amendments to filed or
appro a&WMPs, and whether any such amendments could be approved retroactively.
VIII. IDL Participation
Neither Staffs Original nor Supplemental Application addressed the requirement under
Idaho Code § 61-1804(3) which requires the Commission to consult with interested p~arti ,
including the state forester,as identified in Idaho Code§ 61-1804(2). During informal discussions,
with the state forester and IDL wildfire risk mitigation program director, IDL expressed its intent
to intervene in all future WMP Flings to review each plan and provide recommendations. Under
Idaho Code § 61-1804(3), the state forester's recommendations—particularly those related to
vegetation management, fuel reduction, and responsibilities under Title 38 Idaho Code—are
presumed reasonable and appropriate. If the Commission finds any recommendation unjust,
unreasonable, or not in the public interest, however, it must explain its reasoning in the order
approving or rejecting the WMP. Idaho Code § 61-1804(3).
IX.Cost Justification
In response to comments suggesting that its proposed process could constitute rate
regulation regarding Unregulated Entities, Staff asserted that its proposals are solely intended to
satisfy the requirements of Idaho Code§ 61-1803(3),which calls for balancing wildfire mitigation
ORDER NO. 36774 11

costs with the resulting risk reduction. Staff disclaimed any intent to evaluate whether any project
or actions prudent for cost recovery from ratepayers of Unregulated Entities in the WMP.Rather,
the poise of collecting cost and financial information is to create a complete record to determine
whether each WMP meets the statutory requirements. Neither the WSCA nor Staffs proposal
gives the Commission authority to set rates or judge cost recovery. Therefore, Staff believed its
recommendations do not constitute rate regulation and that requesting financial information is
reasonable and appropriate.
X. Cost-Benefit Analysis
Staff proposed requiring elecurio rporations to submit WMPs with cost estimates for their
planned projects and operations. Ac lo, pmposed requirement is not intended to
override the authority of the utility's od re is 65ar .o determine whether costs are prudent
for rate recovery. Rather, its purpose] o'mwv° tar cmirmake informed recommendations with
a record sufficient to support a Comi ski dodsib o -_
To support this proposed requimm .4,,Staffndfe th t Idaho Code § 61-1803(3) requires
each WMP to include strategies that reftecfz rMwiab"le balance between mitigation costs and
wildfire risk reduction. Additionally, Idaho Code § 61-1804 directs the Commission to consider
the feasibility and cost of implementing each plan. Staff also observed that the WSCA does not
distinguish between IOUs and Unregulated Entities regarding WMP content or approval standards.
Therefore, Staff did not support altering the statutory requirements to allow more flexibility for
Unregulated Entities.
However,Staff acknowledged that each WMP should be tailored to the size and complexity
of the utility, as required by Idaho Code§ 61-1803(3),and therefore does not expect all utilities to
provide the same level of detail in their cost or risk analyses. Larger companies like Idaho Power,
Avista or Rocky Mountain Power may submit more detailed financial analyses, while smaller
utilities, such as Atlanta Power,may provide simpler submissions.
XI.Co-nn liance Reports
In expressed about the proposed compliance reporting requirements,
Staff agreed,V, bk*.;Ashops to determine what information should be included in these reports.
Staff belie r11 • ' e monthly targets and expenditure tracking can be resolved collaboratively
in workshops. To that end, Staff requested that the Commission direct it to hold two workshops
with interested parties and submit a joint proposal for standard compliance report requirements by
ORDER NO. 36774 12

December 31,2025. If consensus cannot be reached,each party would submit its own proposal by
that same date.
Staff also indicated its openness to discussing potential compliance report filing deadlines
during the workshops. Therefore, at this time, Staff does not recommend the Commission set
specific filing dates or timeframes for the required compliance reports. Ultimately, Staff expected
each electric corporation to provide the same type of information their governing boards would
use to evaluate whether their WMP appropriately balances cost and wildftre Brisk,as required by
the WSCA.
XII. Fair Market Value of Timber
Staff observed that the term"fair market value"is not defined in the WSCA. Staff believed
electric corporations should outline how they will determine or achieve fair market value in
relevant situations within their WMPs. Staff encouraged electric corporations to collaborate with
interested parties to establish a fair and consistent approach to determining fair market value.
XIII. Timber Company Contacts or Maps
Staff generally supported the proposed collaboration among stakeholders to create a
working list of timber companies or a centralized map of timber-owned lands. However, Staff
indicated that IDL may be the more appropriate agency to host such information.
XIV. Late Filed Comments
Due to the compressed timeline of this case, Staff recommended that the Commission
consider any late filed comments.
COMMISSION DISCUSSION AND FINDINGS
The Commission has jurisdicitrrt over this matter pursuant to the authority and power
granted it under Title 61 of the Idaho Code, including the WSCA. The purpose of WSCA is to
provide electric service that is safe, reliable, and affordable, while minimizing risk to the public.
See Idaho Code § 61-1802. Addressing wildfire risk is a growing priority for electric utilities, and
proper planning is essential to both prevent wildfires and respond effectively when they occur. To
foster this planning, the WSCA provides liability protections to electric corporations that comply
with a Commission-approved WMP. See Idaho Code § 61-1806. The Commission's experience
and expertise in regulating electric utilities led the Idaho Legislature to assign it the responsibility
of reviewing and approving required and voluntarily filed WMPs.To ensure a timely and thorough
ORDER NO. 36774 13

review of proposed WMPs, the Commission establishes the following filing schedule, guidelines,
and K; tial components for WMPs.
I. Piling Schedule
Idaho Code § 61-1803 authorizes the Commission to set the filink�� r WMPs.
Staff anticipates the filing of as many as 15 WMPs before the 2026 wild&.";-- *0it 'o avoid a
flood of filings and promote orderly, efficient review of WMPs, we find 4 a t e to adopt
Staff s proposed Option 1 filing schedule. This schedule allows one large, one medium, and one
small utility (based on its number of Idaho customers) to submit its proposed WMP for approval
each month. Additionally, we find it reasonable to allow electric corporations that requested
expedited filing to submit their WMPs before those that did not; In sum, we find Staffs proposed
Option No. 1 to be a balanced and manageable initial review schedule.
We acknowledge that the approved filing schedule may not allow every electric
corporation to obtain a Commission-approved WMP before the 2026 wildfire season. However,
we anticipate that those that do not are likely to receive one shortly thereafter. Furthermore, we
find it reasonable to ensure some flexibility in the filing schedule. Specifically, should Staff
subsequently determine that it can handle more WMP filings, we direct Staff to formally request
Commission approval to update the approved filing schedule and allow certain electric
corporations to file WMP ahead of schedule.
11. A n n u a l Reviews and WMP Updates
Commission-approved WMPs must be reviewed and updated annually. Idaho Code § 61-
1803(4). To maintain a balanced and manageable review schedule going forward, we find it
reasonable to direct electric corporations to file updated WMPs one year after the approval date of
their previously approved WMP.
IILWMP %ts for IOUs and Unregulated Entities
Several i ated Entities argued that they should be treated differently from IOUs,
suggesting fewer requirements or more flexibility than IOUs is appropriate. Other than permitting,
rather than requiring, Unregulated Entities to submit WMPs, the WSCA does not expressly treat
Unregulated Entities differently than IOUs. Compare Idaho Code § 61-1803(2)(a) with Idaho
Code § 61-1803(2)(b). Instead, the WSCA addresses differences among electric corporations by
requiring that each WMP be tailored to the scope and complexity of the corporation's operations.
Idaho Code § 61-1803(3). Acknowledging this minor discrepancy does not otherwise authorize
ORDER NO. 36774 14

different treatment of Unregulated Entities.Therefore we will not impose fewer requirements upon
Unregulated Entities solely based on their regulatory status.
IV.WMP Projections and Planning Horizon
We next consider the planning timeframe for WMPs. Consistent with established practice,
we find it reasonable to require electric corporations to develop rolling WMPs with a minimum
three-year planning horizon. As stated in prior proceedings, WMPs must incorporate long-term
planning while maintaining the flexibility to address emerging risks as they arise. See Order No.
36405.Requiring each iteration of a WMP to roll the planning and forecast horizon forward serves
the need for long-term planning while still allowing flexibility t., ,-odoress emergent threats.
-:n
Although this approach may place a greater burden on electric corpo O " ;than a static three-year
plan, we find that the improved wildfire risk reduction provided by a rolling plan justifies the
additional burden.
V. Exclusion of Standard Operating Procedures in WMPs
We concur with Staff s view that WMPs need not contain exhaustive standards or
procedures for every possible instance of live de-energization. Standards and protocols for de-
energization requested by fire agencies or for planned work that are included in an electric
corporation's SOPs may not be part of its wildfire mitigation strategy. Accordingly, standards and
protocols for these kinds of de-energizations need not be duplicated in a WMP.
However,a WMP should be a comprehensive plan to address wildfire risk.Although many
of an electric corporation's projects may support multiple objectives beyond wildfire mitigation,
it is not necessary to separate the costs among those different purposes. Rather, a WMP should
include the full cost of the project with an explanation of any additional objectives the project
serves beyond wildfire mitigation. If a project provides benefits beyond wildfire risk mitigation,
the WMP should explain whether the effort is part of its SOPS or exceeds them.
VI.Line Design Requirements
Idaho Code § 61-1803(3)(e) requires WMPs to include line design methods for new,
planned,and existing lines that are both financially prudent and reasonably practicable for wildfire
risk mitigation. Accordingly, WMPs must explain how an electric corporation's line design
methods reduce the potential for wildfire ignition,including a cost evaluation. This cost evaluation
need not be least-cost, least risk,but-.l ; t show how the mitigation project strikes the necessary
ORDER NO. 36774 15

"balance of mitigation costs with the resulting reduction in wildfire risk"required by the WSCA.
See Idaho Code § 61-1803(3)(e).
VII. WMP Amendments and Retroactivity
Idaho Code § 61-1806(1) creates a rebuttable presumption that an electric corporation
acted without negligence if, with respect to the cause of the wildfire, the electric corporation
reasonably implemented a commission-approved WMP. This rebuttable presumption applies to
any action or omission reasonably consistent with an approved WMP in effect when the fire began.
This rebuttable presumption applies only to actions or omissions reasonably consistent with the
approved WMP in effect when the fire began.Idaho Code§61-1806(1). Stated differently,a WMP
must be approved to provide liability protection to electric corporations. More importantly, this
liability protection applies only to fires ignited while the approved WMP is effective. A plain,
ordinary reading of the statutory text indicates a WMP is effective upon Commission approval,
and that this approval cannot be retroactive to cover prior fires.
With respect to mid-year amendments to approved plans, we find it reasonable to permit
their filing. However, to avoid disrupting the review of other WMPs, electric corporations must
first consult with Staff to discuss the proposed amendment and coordi#* a filing date that
supports efficient review of all plans. Once filed, proposed amendments will be processed in
accordance with the Commission's Rules of Procedure.
VIII. IDL and State Forester Recommendations
Under Idaho Code § 61-1804(3), the state forester's recommendations, particularly those
related to vegetation management,fuel reduction,and responsibilities under Title 38,are presumed
reasonable and appropriate. We will apply frds statutory presumption when reviewing WMPs.
However, we decline to set a definitive framework for how IDL's recommendations will be
considered at this time,as each WMP is expected to differ.As a result,the relevance and persuasive
force of IDL's comments and recommendations may vary from case to case.
IX.Cost Justification
One of the most contested aspects of this case is Staff 5 proposal to require a cost-benefit
analysis in WMPs to justify spending on projects related to WMPs. To support this proposed
requirement, Staff argued that such an analysis was necessary to determine whether planned
expenditures were justified relative to anticipated wildfire risk reduction benefits. However, some
Unregulated Entities were concerned that explaining their expenditures could result in review of
ORDER NO. 36774 16

their rates and internal management,potentially undermining the authority of their own governing
authorities.
Under Idaho Code § 61-1803(3),WMPs must reasonably balance anticipated wildfire risk
reductions against the anticipated mitigation costs. Assessing whether the WMP has achieved this
balance requires a review of the cost-benefit analysis underlying the expenditures outlined therein.
Additionally, Idaho Code § 61-1804 requires the Commission to consider the feasibility and cost
of implementing each WMP when deciding whether or not to approve a WMP.Review of the cost-
benefit analysis supporting WMP expenditures can inform the Commission's consideration of
those costs.Finally,the WSCA is intended to guide the prudent use of resources to address wildfire
risks with justifiable costs,keeping utility rates affordable and protecting Idaho residents and their
property. Idaho Code § 61-1802. Including a cost-benefit analysis in WMPs supports this goal by
requiring electric corporations to perform a balancing test that assesses whether expenses are
prudent.
Accordingly, we find it reasonable to direct all electric corporations to include a cost-
benefit analysis in their proposed WMPs that justifies the expenditures for risk mitigation
described within. This directive does not amount to rate regulation. Rate regulation occurs when a
government body sets the prices a company can charge. The WSCA grants the Commission
authority solely to approve or reject a proposed WMP, not to regulate the rates an Unregulated
Entity charges. The Commission has no authority other than that given to it by the legislature. It
exercises a limited jurisdiction, and nothing is presumed in favor of its jurisdiction. See United
States v Utah Power& : a+ > Idaho 665, 667, 570 P.2d 1353, 1355 (1977).
Furthermore,u:' r 'Unregulated Entities are not obligated to obtain a Commission-
,,. ..,
approved WMP and may s not, �p, r.sue one. Seeking Commission approval of a WMP may
influence an Unregulated Entity's decisions,including those related to service rates.However,any
rate changes made to obtain approval of a WMP for an Unregulated Entity would be entirely
voluntary and subject to their own processes only. This is not rate regulation.
X. Timber Protections
Idaho Code § 61-1803(3)(g)(iii) requires that landowners be compensated at FMV for the
removal of live, marketable timber from timber company land adjacent to a utility right-of-way.
Some commenters recommended establishing guidelines for valuation, notice, and dispute
resolution related to timber removal to help prevent future legal conflicts. We decline to do so.
ORDER NO. 36774 17

The WSCA does not define what constitutes FMV. Nor does the WSCA expressly grant the
Commission authority do provide such a definition. Accordingly, we lack the authority to do so.
See United States v Utah Power& Light Co., 98,Idaho at 667, 570 P.2d at 1355 (holding that the
Commission's jurisdiction is limited to that grantlby statute).
Moreover,determining the amount a landowner should receive for removed timber is akin
to fixing damages in a civil case. The power to determine and award civil damages is the exclusive
province of the judicial courts and beyond the Commission's jurisdiction. See Pounds v. Denison,
115 Idaho 381, 384, 766 P.2d 1262, 1265 (Ct. App. 1988) (holding that awarding civil damages is
the exclusive province of judicial courts;McNeal v. Idaho Pub. Utilities Comm'n, 142 Idaho 685,
691, 132 P.3d 442,448 (2006) (observing that the Commission is not a judicial court), abrogated
on other grounds by Verska v. Saint Alphonsus Reg 7 Med. Ctr., 151 Idaho 889, 265 P.3d 502
(2011). We do, however, encourage electric corporations to collaborate with interested parties to
establish a fair and consistent approach to determining fair market value. Similarly,we encourage
the electric corporations to develop a list of timber companies or a centralized map of timber lands
to support compliance with the FMV compensation requirement for any timber that is removed.
XI.Compliance Reports
Finally, under Idaho Code § 61-1803(5), electric corporations with an approved WMP
must submit an annual compliance report to the Commission, unless directed otherwise by
Commission rule or order. Such reports must provide documentation detailing how the
components and measures of the WMP were developed and adopted,the related expenditures,and
the actions taken to implement the plan.
Given the substantial number of comments on Staff's proposed compliance report
requirements, we find it reasonable to direct Staff to conduct two workshops to determine the
necessary report content. These workshops should address topics such as fire reporting
requirements, monthly compliance targets and expenditures, filing dates, and achieving
consistency in language and formatting across all WMPs. Following the workshops, interested
parties may submit joint proposed standard compliance report requirements by December 31,
2025. If conse -us is not reached, individual proposals may be submitted by the same date.
XII. Staffs Proposed WMP Guidelines
Attached to Staff s reply comments as Exhibit No. 1 is a revised set of proposed guidelines
for electric corporations to follow for the WMP filings. Considering our decisions above general
ORDER NO. 36774 18

lack of objection to Staffs Exhibit No. 1, we find it reasonable to accept and approve it as
guidelines for each electric corporation's WMP filing. Each electric corporation must comply with
these guidelines for its WMP to satisfy the requirements for approval going forward.
XIII.Staffs Proposed "Need to Know"Document
Attached to Staffs Supplemental Application as Exhibit No. 2, is a proposed "Need to
Know" document. The purpose of this document is to gather essential information to support
Staff s review and processing of a WMP from an Unregulated Entity. As previously stated,Idaho
Code § 61-1803(3) requires WMPs to be reflective and commensurate with the size and
complexity of the electric corporation's operations and of the nature of the fire risk it faces. We
find it reasonable to direct Unregulated Entities to submit a completed copy of Staffs proposed
"Need to Know"document with their initial WMP filings to aid Staff in its review of the plan.
XIV.Annual Wildfire Update Meetings
Before the WSCA was enacted, the Commission held annual meetings with Idaho's three
largest IOUs to receive updates on wildfire conditions and their mitigation efforts. We will
continue to hold these meetings. To avoid having them overlap with WMP annual reviews, these
meetings shall occur annually during the third week in May, or as close thereto as reasonably
possible. Additionally, as Unregulated Entities may now submit WMPs, we find it reasonable to
offer them the opportunity to participate in these meetings, should they choose to do so.
XV. Review Fees for WMP from Unregulated Entities
Idaho Code § 61-1803(2)(b) authorizes the Commission to assess Unregulated Entities a
reasonable fee for reviewing their WMPs.This is necessary because,unlike IOUs that are assessed
special regulatory fees annually,Unregulated Entities generally do not pay fees that cover the cost
of their supervision and regulation. Accordingly, we find it reasonable to direct Staff to issue
q rterly invoices to each Unregulated Entity based on time and expense principles to review its
"V°WMP pursuant to Idaho Code § 61-1004. If a Unregulated Entity has no outstanding balance
during a quarter,the issuance of an invoice is unnecessary.
XVI.Notices to Interested Parties
Idaho Code § 61-1804(2) requires electric corporations to provide notice to certain
interested parties within five days of filing a WMP for review and approval. To facilitate the
participation of those interested parties in the review process,we find it reasonable to direct electric
corporations to include the information Staff proposed in these notices. Specifically, this notice
ORDER NO. 36774 19

must include a copy of the notice to the Commission of the filing of the WMP, the case number
for the case in which the WMP will be review—rd, and information about how to particiP a the
proceeding.
ORDER
IT IS HEREBY ORDERED that electric corporations shall file their WMPs with the
Commission for review according to the schedule reflected in Option No. 1 from Staff s reply
comments and reproduced in Exhibit A attached to this Order.
IT IS FURTHER ORDERED that electric corporations shall file updated WMPs for their
annual review one year after the filing date of their previously approved WMP.
IT IS FURTHER ORDERED that electric corporations shall develop rolling WMPs with
a minimum three-year planning horizon.
IT IS FURTHER ORDERED that WMPs need not contain exhaustive standards or
procedures for de-energization requested by fire agencies or for planned work that are included in
an electric corporation's Standard Operating Procedures.
IT IS FURTHER ORDERED that WMPs must explain how an electric corporation's line
design methods reduce the potential for wildfire ignition, including a cost evaluation.
IT IS FURTHER ORDERED that, before filing a mid-year amendment to an approved
WMP, electric corporations must consult with Staff to discuss the proposed amendment and
coordinate a filing date that supports efficient review of all plans.
IT IS FURTHER ORDERED that all electric corporations must include a cost-benefit
analysis in their proposed WMPs that justifies the expcnditures for risk mitigation described
within.
IT IS FURTHER ORDERED that Staff shall hold two workshops to determine the required
content of compliance reports. Topics covered in these workshops should include fire reporting,
monthly compliance targets, expenditures, filing timelines, and establishing consistency in
language and formatting of all WMPs. Following the workshops, interested parties may submit
joint proposed ,standards by December 31, 2025, or individual proposals if consensus is not
reached.
IT IS FURTHER ORDERED that Staffs proposed WMP guidelines reflected in Staffs
Exhibit No. 1 attached to its reply comments are accepted and approved guidelines for each electric
corporation's WMP filing. A copy of Staff's Exhibit 1 is attached to this Order as Exhibit B.
ORDER NO. 36774 20

IT IS FURTHER ORDERED that Unregulated Entities shall submit a completed copy of
Staff s proposed"Need to Know"document with their initial WMP filings to aid Staff in its review
of the plan. A copy of Staff "Need to Know"document is attached to this Order as Exhibit C.
IT IS FURTHER ORDERED that anw.41 meetings to update the Commission on wildfire
conditions in Idaho and the IOUs m1figyat on offorts shall occur annually during the third week in
May, or as close thereto as reasonably possible. Unregulated Entities may participate in these
meetings.
IT IS FURTHER ORDERED that Staff shall issue quarterly invoices to each Unregulated
Entity based on time and expense principles pursuant to Idaho Code§ 61-1004 to review its WMP
unless the Unregulated Entity has no outstanding balance for such costs.
IT IS FURTHER ORDERED that the notice to interested E mrfiws required under Idaho
Code§ 61-1804(2)shall include a copy of the notice to the Commission of the filing of the WMP,
the case number for the case in which the WMP will be reviewed, and information about how to
participate in the prodding.
THIS IS A FINAL ORDER. Any person interested in this Order may petition for
reconsideration within twenty-one (21) days of the service date upon this Order regarding any
matter decided in this Order. Within seven (7) days after any person has petitioned for
reconsideration, any other person may cross-petition for reconsideration. See Idaho Code § 61-
626.
ORDER NO. 36774 21

DONE by Order of the Idaho Public Utilities Commission at Boise, Idaho this 301h day of
September 2025.
G
G,cx'
DWARD LODGE, RE 1 ENT
HN R. HAMMOND JR., COMMISSIONER
DAMN HARDI , COMMISSIONER
ATTEST;
?c
Laura Calderon Robles
Interim Commission Secretary
1:\LcplTLFCTRIC+GNR-F-25-02_WMP Processlnrders\GNRF.2502_final_aGdocx
ORDER NO. 36774

Exhibit A
Case No. GNR-E-25-02
Order No. 36774
Exhibit A—WMP Filing Schedule
Electric Corporation Permitted To File
Month Large Utility Medium Utility Small Utility
No earlier than
October I Idaho Power htx)tcnai Electric Raft River
No earlier than Avista Northern Lights Idaho County Light
November 1 and Power
No earlier than PacifiCorp City of Idaho Falls Unitcd Electric
December 1
No earlier than Atlanta Power Clearaatcr Poker Lost River Electric
.lanuar� 1
No earlier than Lower Valley }all Kip er City of Bonners
Februan- 1 Encrgy Ferry
No earlier than Any other electric corporation that wishes to file
March 1

Exhibit B
Case No. GNR-E-25-112
Order No. 36774
1 of H
EXHIBIT NO. 1
Idaho Public Utilities Commission
Wildfire Mitigation Plan Guidelines

Exhibit 8
Case No. GNR-E-25-02
Order No. 36774
2of8
Intention of the Wildfire Mitigation Plan Guidelines
The intention of this document is to serve as guidelines for creating a Wildfire Mitigation
Plan ("WMP") for approval by the Commission.
As required by I.C. § 61-1803(3),a WMP at a minimum must include the elements outlined
in I.C. § 61-1803(3)(a)-(g). Staff recommends the Commission consider the areas detailed in each
section below to be included in the utilities WMP filing as written. Staff will review this
information in each WMP fifing for approval by the Commission.
I.C. § 61-1803(3)(a) - Geographical Risk Assessments
"Identifying geographical areas where an electric corporation has infrastructure or
equipment that the electric corporation considers may be subject to a heightened
risk of wildfire at the time the wildfire mitigation plan is finalized by the electric
corporation"
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.
I.C. § 61-1803(3)(b)- Preventative Actions and Programs
"Preventative actions and programs that the electric corporation will carry out to
reduce the risk of wildfire."
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. For the three large investor-owned utilities,' Staff recommends that previous
Avista Corp., Idaho Power,and Rocky Mountain Power.
WMP GUIDELINES 2 UPDATED EXHIBIT NO. 1

Exhibit B
Case No. GNR-E-25-02
Order No. 36774
3 of 8
areas of focus of each utility's WMPs continue to be included within its WMPs. A WMP's
preventative actions and programs must include, but is not limited to:
• Situational Awareness efforts
o Which may include use of technology to aid in weather monitoring, fire season
outlook, daily, weekly, and monthly weather and fire modeling risk, etc.
o Consistent with 61-1803(3)(f) and Staff's proposed requirements within.
• Asset Inspections
o Which must include the frequency and standards of inspections for each type of
electric infrastructure within areas of elevated wildfire risk.
o Consistent with 61-1803(3)(g)(i) and Staff's proposed requirements within.
• Enhanced vegetation management practices in risk zones
o Which may include shorter vegetation management cycles than routine cycles,
risk tree programs, etc.
o Consistent with 61-1803(3)(g)(iii) and Staff's proposed requirements within.
• Operation practices during heightened wildfire risk days or zones.
o Which may include restrictions to workforce practices, potential use of pro-
active de-energization
o Consistent with 61-1803(3)(g)(ii) and Staff's proposed requirements within.
• Community education
o Which may include public service announcements to create awareness and
provide education of wildfire risks, providing preventative measures, etc.
o Consistent with 61-1803(3)(c) and 61-1803(3)(d)
• And any additional requirements ordered by the Commission.
A WMP's preventative actions and programs may include, but is not limited to:
• System hardeningstrategies
ttategies
Which may include pole replacements, line rebuilding, or undergrounding if
necessary, strategic fuse or reclosers installations, etc.
• Workforce Preparedness
o Which may include workforce training, equipment provided to employees to
reduce the risk of wildfire, etc.
WMP GUIDELINES 3 UPDATED EXHIBIT NO. I

Exhibit B
Case No. GNR-E-25-02
Order No. 36774
4 of H
• Pilot Programs
o If applicable.
I.C. § 61-1803(3)(c) - Public Outreach and Engagement
"Community outreach and public awareness efforts that the electric corporation
will use before, during, and after wildfire season to identify and inform the public
of relevant wildfire risks and notify the public of wildfire-related outages."
This section should include discussion of how each utility maintains community outreach
and public awareness before, during, and after wildfire season to support customer awareness and
education of wildfire risks and notify the public of wildfire-related outages. This discussion should
include, but is not limited, to the following:
• Description of customer communication efforts related to wildfire mitigation, including
efforts to increase awareness and education of the utility's plan, explanation of key
mitigation activities, and efforts supporting public readiness.
• If the titility utilizes de-energization, a description of public education efforts and
communication protocols for before, during, and after a de-energization event. The
communication protocols should clearly identify which customers could 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.
I.C. § 61-1803(3)(d) -Government Outreach
"Outreach efforts to coordinate with federal, state, tribal, and local officials and
agencies on wildfire preparedness and emergency response plans."
The electric corporation must describe how it engages with and coordinates with federal,
state, tribal, and local officials and agencies on wildfire preparedness and emergency response in
the plan year. This discussion may include, but is not limited to:
WMP GUIDELINES 4 UPDATED EXHIBIT NO. 1

Exhibit B
Case No. GNR-E-25-02
Order No. 36774
5of8
• 1f 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.
I.C. § 61-1803(3)(e)- Method of Line Design
"Financially prudent and reasonably practicable 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 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 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.
I.C. § 61-1803(3)(f)- Situational Awareness and Monitoring
"Monitoring of forecasted and current weather data for the purpose of assessing and
responding to current and anticipated fire risk."
This section should include a description of how the electric corporation monitors
forecasted and current weather conditions for the purpose of assessing and responding to current
and anticipated wildfire risk. This description must include, but is not limited to, the following:
WMP GUIDELINES 5 UPDATED EXHIBIT NO. 1

Exhibit 8
Case No. GNR-E-25-02
Order No. 36774
6of8
• Identification of systems, tools, or external resources used to monitor weather, fire
potential, or other situational awareness indicators.
• If applicable, a description of how the utility utilizes weather forecasting, fire potential
modeling, or similar tools, to inform mitigation activities and operational decisions.
• Discussion of how situational awareness capabilities are integrated into daily or seasonal
wildfire operations.
• Discussion of how the electric utility become aware of another electric corporation's de-
energization (e.g., Bonneville Power Administration) and how that is integrated into
operations.
Developing Standards, Procedure, and Schedules
Idaho Code 61-1803(3)(g) requires each electric corporation to "[develop] standards,
procedures, and schedules, subject to timely approval of access to rights-of-way, if necessary..."
for the 1) Infrastructure Inspection and Maintenance, 2) De-Energization, and 3) Vegetation
Management.
I.C. § 61-1803(3)(g)(i)- Infrastructure Inspection and Maintenance
"Inspection of the electric corporation's assets, infrastructure, and facilities within
the areas that are identified as heightened fire risk areas in the wildfire mitigation
plan, were financially prudent and reasonably practicable."
This section should provide a suminaly of electric corporation's programs for the
inspection of electric infrastructure, assets, and facilities within areas identified as heightened
wildfire risk areas to identify and 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.
WMP GUIDELINES 6 UPDATED EXHIBIT NO. I

Exhibit 8
Case No. GNR-E-25-02
Order No.36774
7 of 8
• Measurable targets/goals to be achieved within the WMP. E.g., miles of lines inspected,
corrected identified defects, etc.
I.C. § 61-1803(3)(g)(ii)-De-Energization
"De-energization of the electric corporation's power lines, if considered appropriate
by the electric corporation."
If an electric utility plans to use de-energization as part of its wildfire mitigation efforts,
this section must address the standards, criteria, and operational protocols, for de-energization for
encroachment of a wildfire, proactive de-energization (PSPS) to reduce fire risk, and de-
energization from Yd party energy providers. This discussion must include, but is not limited to
the following:
• A summary of the conditions under which de-energization may be used, if applicable.
• The criteria or protocols for evaluating its appropriateness to engage.
• Summary of the electric corporation's operational protocols for before, during, and after a
de-energization event.
• Description of how the electric corporation will coordinate with local emergency
managers,operators of critical facilities,and affected communities before,during,and after
a de-energization event.
• Descriptions of other operations for limiting impact to affected communities; which may
include community resource centers, emergency generators, backup batteries, etc.
I.C. § 61-1803(3)(g)(iii)-Vegetation Management
"Vegetation management within the areas that are identified as heightened fire risk
areas in the wildfire mitigation plan and are within the electric corporation's rights-
of-way or lands adjacent thereto and that threaten the power lines or other electric
corporation infrastructure. If live marketable timber is identified for removal from
timber company land adjacent to the rights-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
WMP GUIDELINES 7 UPDATED EXHIBIT NO. I

Exhibit 8
Case No. GNR-E-25-02
Order No. 36774
8of8
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.
Other Items to Include in a WMP
l) An update of lessons learned from the previously approved WMP within the annual filin0s
for WMP review and approval.
2) A breakdown of each program category's forecasted costs by year for both capital and
O&M expenditures through the length of the WMP.
3) A section in which it describes how the electric corporation addresses each of the
Commission's orders and Staff's recommendations.
WMP GUIDELINES 8 UPDATED EXHIBIT NO. 1

Exhibit C
Case No. GNR-E-25-02
Order No. 36774
1 of 2
EXHIBIT NO. 2
ELECTRIC MUNIPALITIES AND COOPERATIVES
"NEED TO KNOW" DOCUMENT

Exhibit C
Case No. GNR-E-25-02
Order No. 36774
2 of 2
Electric Municipality and Cooperative Wildfire Mitigation Plan
Need to Know Document
Pursuant to Idaho Code § 61-1803(3), a Wildfire Mitigation Plan ("WMP") must be
reflective and commensurate with the size and complexity of the electric corporation's operations
and of the nature of the fire risk. A WMP must also reflect a reasonable balancing of mitigation
costs with the resulting reduction of wildfire risk.
The purpose of this document is to collect basic information that will aid in Staff's review
to process a WMP. Please provide the following information and provide the document along with
each respective WMP filing.
1. Name of Utility
2. Location of Utility:
a. Located inside of the Wildland Urban Interface?
3. Please provide a map of the Company's service territory. Please identify the Company
assets and provide a PDF zoomable.
4. Total number of Customers:
a. Residential
b. Commercial
c. Other
5. How is energy supplied to the Company? i.e., BPA, utility-owned generation, etc.
a. What is the name plate capacity in Megawatts("MW")of utility-owned generation
sources?
b. What is the capacity factor of utility-owned generation sources?
6. What is the annual amount of energy in Megawatt-hours that the utility serves?
7. What is the peak demand in MW and when does it occur?
8. Standard operating procedures ("SOP") for infrastructure management and vegetation
management?
a. Annual spend?
b. Annual incremental spend proposed in WMP from SOP?
9. Last 3 years of financial statements:
a. Income Statement
b. Cash Flow Statement
c. Balance Sheet
NEED TO KNOW DOCUMENT I EXHIBIT NO. 2

Office of the Secretary
Service Date
June 29,2026
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF KOOTENAI ELECTRIC ) CASE NO. C07-E-25-01
COOPERATIVE, INC.'S APPLICATION FOR )
APPROVAL OF ITS 2026-2028 WILDFIRE ) ORDER NO. 37081
MITIGATION PLAN )
On December 31, 2025, Kootenai Electric Cooperative, Inc. ("Company") applied to the
Idaho Public Utilities Commission("Commission")requesting approval of its 2026-2028 Wildfire
Mitigation Plan("2026 WMP")("Application"),in accordance with Wildfire Standard of Care Act
("WSCA")Idaho Code § 61-1801,et seq. ("Application").Application at 1.
On January 23, 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. 36911. No petitions to intervene were filed. On February 19, 2026, the Commission issued a
Notice of Modified Procedure, establishing public comment and Company reply deadlines. Order
No. 36939. Idaho Department of Lands ("IDL") filed public comments after the public comment
de ad'ti ke:.
Based on our review of the record, we issue this Final Order conditionally approving the
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 corporationQ r"ponsible 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 ele .c corporations should proactively identify, mitigate, and
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.
ORDER NO. 37081 1
E
XHIBIT 5

The WSCA allows electric corporations that are municipal and cooperative utilities 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 utility's WMP. Order No. 36774 at 14. If a municipal or cooperative utility 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
suba,riated 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. Recom-a r-dations 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 be 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 deff'ir.e the electric corporation's responsibilities to the
public and its customers. Idaho Code§ 61-1801,.
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
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
ORDER NO. 37081 2

utility's WMP, is subject to the requirements,f6r WMPs under the Commission WMP guidelines
detailed in Order No. 36774("Guidelines )and'Order No. 36929.
In conducting its review, the Commu.ssion 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 Company attached a full copy of its 2026 WMP as Attachment 1 to the Application.
The Company stated that its WMP was structured to comply with the Guidelines and the WSCA
by utilizing a :telling three-year planning horizon and incorporating detailed implementation plans
for vegetation management, construction work, and system inspections for the 2026-2028 period.
Application at 3. The Company represented that its 2026 WMP identified geographic areas in the
Companv's service territory that are subject to heightened wildfire risk using a multi-factor risk
�s:s.-moot. Id. at 4. The Company explained that the multi-factor risk assessment considered
voget.� ic--n, weather, topography, historical fire activity, and asset location, with most of the
r +wpa ,'s service territory being classified as medium to very high risk. Id. at 3-4.
The Company represented that its 2026 WHIP outlined comprehensive preventive
programs, including situational awareness supported by weather and fire-risk modeling tools,
systematic asset inspections, enhanced vegetation management practices, operational protocols
during elevated fire risk conditions, and the potential use of Public Safety Power Shutoffs. Id. at
4-8. The Company's 2026 WMP also outlined the Company's community outreach and
coordination with federal, state, tribal, and local agencies to ensure there was effective wildfire
preparedness,communication,and emergency response.Id. at 8-9. The Company represented that
its board of directors reviewed the 2026 WMP and that the board of directors formally accepted
the 2026 WMP and determined that the 2026 WMP was feasible, financially prudent, and
reasonably balanced mitigation costs with wildfire risk reduction. Id. at 11.
ORDER NO. 37081 3

STAFF COMMENTS
Staff reviewed the 2026 WMP for compliance with the roquiremet.7I.s of the WS+,:,'A and the
Guidelines. Staff Comments at 2. Based on its review, Staff bebi ved the' 2026 WMP, and
additional information provided by the Company through discovery, satisfied the applicable
statutory and regulatory requirements, and Staff recommended that the Commission approve the
2026 WMP and direct the Company to include the following additional information in future
filings, should the Company seek Commission approval of another WMP:
1. Provide detailed, wildfire-related project-level cost forecasts for each year;
2. Provide details of all funding alternatives and sources pursued;
3. Include wildfire risk mitigation benefits, applying a consistent, transparent, and repeatable
methodology across projects;
4. Include all metrics used within each respective section and provide the data in a format that
can easily be tracked across WMP filings;
5. Provide an explanation of how certain mitigation activities(such as grid hardening efforts)
are reducing wildfire risk;
6. Overlay its service territory boundaries on the Heightened Wildfire Risk Map;
7. Include a more detailed explanation of how each heightened wildfire risk zone was
determined;
8. Narratively explain how the Company divides its territory and explain how it prioritizes
wildfire-related projects in each section;
9. Include wildfire-related project-level details that includes targets, expected wildfire
mitigation benefits,and alternatives considered within the respective sections of the WMP;
10. Include the Company' s process for compensating timber companies for marketable timber
marked for removal on land adjacent to Company's ROW; and
11. Include additional details about the Company's weather station network, including areas
of focus, average cost, and any metrics it will use to evaluate success of the network.
Id. Staff also recommended the Commission clarify that the Company can file an updated WMP
annually on or about December 31 of each year for Commission review and approval.Id.
I. 2026 WMP Overview& Cross Cutting Elements
a. Cost Feasibility
Staff noted that the Company's cost forecasts for its: (1) Vegetation Management
Implementation Plan; (2) Construction Work Implementation Plan; and (3) System Inspection
Implementation Plan (collectively the "Cost Forecasts") did not include specific wildfire-related
expenses. Id. at 4. In a meeting with Staff, the Company represented that it considered wildfire
mitigation"in all aspects of its daily operations"due to the Company's service territory and that it
ORDER NO. 37081 4

could not "isolate costs for only wildfire mitigation." Id. at 5. However, based on Staff s review
of material the Company supplied to Staff in discovery, Staff believed the Company could isolate
costs for wildfire-related projects.Id.
Because the Company was able to provide information on costs for work related to wildfire
in a response to Staff production request, Staff believed the Company sufficiently provided
information on the costs to implement the 2026 WMP. Id. However, Staff believed WMP
implementation costs must be included in an electric corporations WMP under the WSCA (Idaho
Code § 61-1804(1)(b)), and not through discovery.Id. Thus, Staff recommended the Commission
direct the Company to include detailed project-level costs forecasts for projects that are wildfire
related in any future WMP filings. Id.
i. Grants
Staff noted the 2026 WMP did not include information on funding alternatives, such as
grant funds, in its information on the cost of implementing the 2026 WMP.Id. at 6. In response to
Staff s discovery requests, the Company supplied information on grants it applied for related to
wildfire mitigation. Id. Because the Company was able to provide information on alternative
funding in responses to Staff s production requests, Staff believed the Company sufficiently
provided information on the costs to implement the 2026 WMP.Id.
However, 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
evaluate under the WSCA (Idaho Code § 61-1804(1)(b)). Id. Thus, Staff recommended the
Commission direct the Company to include alternative funding sources the Company is pursuing,
if any, to help fund its wildfire mitigation efforts in any future WMP filings.Id.
ii. Cost-Benefit Approach
Staff explained that because the Company provided some information on the feasibility of
the 2026 WMP and a cost-benefit analysis of the 2026 WMP in meetings with Staff and in
responses to Staff s production requests, Staff believed the Company satisfied the requirements
under the WSCA (Idaho Code § 61-1804(1)(b)) and the Guidelines to provide information on
wildfire risk mitigation benefits in the 2026 WMP. Id.
However, Staff believed information on wildfire risk mitigation benefits must be included
in an electric corporation's WMP under the WSCA and Order Nos. 36774 and 36882, and not
through discovery. Id. Thus, Staff recommended the Commission direct the Company to include
information on wildfire risk mitigation benefits in any future WMP filings. Id. Further, Staff
ORDER NO. 37081 5

recommended the Commission direct the Company to apply "a consistent, transparent, and
repeatable methodology" on all projects for wildfire mitigation. Id. Additionally, if the Company
identifies qualitative benefits, Staff recommends the Company define the benefits, explain how
the benefits help mitigate wildfire frisk, and to quantify the reduction of risk for particular
infrastructure mitigation measures.Id.
b. Cross Cutting Elements
i. Targets and goals within WMP
Staff believed the Company provided sufficient information on its objectives for managing
vegetation and inspecting the Company's system in the 2026 WMP and through discovery. Id. at
7. Thus, Staff thought the Company provided enough information for the Commission to evaluate
the 2026 WMP's feasibility and to what extent the 2026 WMP minimized risk of wildfire, as
required under the WSCA(Idaho Code§ 61-1804(1)(c)).Id. While Staff believed the information
provided was sufficient, Staff encouraged the Company to include additional information on
objectives in future WMP filings. Id.
ii. Metrics
Staff believed the Company provided enough information on the metrics the Company uses
to measure and track the effectiveness of the Company's grid hardening efforts.Id. However,Staff
argued information on metrics used to track the effectiveness of wildfire mitigation efforts must
be included in the WMP and not 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.
While Staff believed the Company provided sufficient information through discovery on
the metrics it uses in the 2026 WMP, Staff encouraged the Company to use industry-standard
metrics including System Average Interruption Duration Index, System Average Interruption
Frequency Index, Customer Average Interruption Duration Index, and Monetary Average
Interruption Frequency Index for a period of three years to track and assess the performance and
success of vegetation management and maintaining the Company's system. Id. at 7-8.
II. Geographical Risk Assessments
a. Limitations of Risk Modeling
Staff explained that even though it thought the Company's use of data from the United
States Forest Service Wildfire Risk to Communities combined with Overstory mapped data of the
ORDER NO.37081 6

vegetation in the Company's service territory to model wildfire risk in its territory was reasonable
due to the size and complexity of the Company, Staff believed the Company may have been
overweighing the vegetation risk in its territory. Id. at 10. Thus, Staff argued that so long as the
Company 400owledged the limitation of the type of vegetation data used in the Company's
process to m6del'wildfire risk in its territory,it would be appropriate for the Company to continue
to utilize its current process. Id.
However,while Staff stated the Company's model did consider risk due to external factors,
it believed the Company's model did not factor in the risk of ignition from the Company's
infrastructure, which Staff believed would help the Company make decisions on where to invest
in its system. Id. Thus, Staff recommended the Commission direct the Company to include
narratives on how the Company's investments in its system have reduced wildfire risk in any future
WMP filings. Id.
b. Heightened Risk Area Map
Staff explained that because the Company provided a map of its heightened wildfire risk
areas,and provided information in meetings with Staff on how the Company divides and prioritizes
sections of its service territory, Staff believed the Company satisfied the requirement under the
Guidelines to depict risk areas in its service territory.Id. at 10-11.
However, Staff opined that overlaying the boundaries of the Company's service territory
on-its heightened wildfire risk area map tmald help the Commission review the heightened
wildfire risk area in the Company's service territory. Id. at 10. Further, Staff believed that
information on how the Company divides and prioritizes sections of its service territory must be
included in an electric corporation's WMP under the Guidelines,and not through drs ;mvery.Id. at
11. Thus, Staff recommended the Commission direct the Company to: (1) overlay its service
boundary on the Company's heightened wildfire risk area map; and (2) include information on
how the Company divides and prioritizes sections of its service territory in any future WMP filings.
Id.
III. Optional Preventative Actions & Programs
Staff believed the information the Company supplied regarding its workforce's
preparedness in discovery met the Guidelines' recommendations on including optional
preventative actions in a WMP. Id. Staff encouraged the Company to include in future WMP
filings information on: (1)frequency of training;(2)roles of employees;(3)topics and focus areas;
and(4)the number of employees trained. Id.
ORDER NO. 37081 7

IV. Method of Line Design & Grid Hardening
Staff believed the initial cost forecast provided on Page 26 of the WMP was insufficient to
satisfy the requirements of the WSCA (Idaho Code §§ 61-1803(3)(b), 61-1803(3)(e)) and the
Guidelines. Id. at 12-13. However, Staff explained that because the Company supplied additional
information on: (1) the Company's line design methods for planned system upgrades; (2) a cost-
benefit evaluation of the Company's projects; and (3) the Company's selection method for its
projects in discovery, Staff believed that the Company satisfied the requirements of the WSCA
and the Guidelines.Id. at 13. Staff believed sufficient cost forecasts must be included in an electric
corporation's WMP under the WSCA and the Guidelines, and not through discovery. Id. Thus,
Staff recommended the Commission direct the Company to include said information in future
WMP filings. Id.
V. Situational Awareness & Monitoring
Staff explained that because the 2026 WMP inelbaded information on the Company's
current method for monitoring weather,and because the Company supplied additional information
on weather monitoring to Staff through discovery,Staff believed the Company satisfied the WSCA
(Idaho Code § 61-1803(3)(f)) and the Guidelines that require a WMP to detail how a utility
assesses wildfire risk and weather conditions.Id. Even though Staff considered the i xformation on
the Company's weather monitoring in the 2026 WMP sufficient, Staff encouraged the Company
to: (1) include more information related to the Tempest Daily Awareness Tool; (2) narratively
describe the work the Company is already doing as it is related to its weather station network; and
(3) provide more detail on the Company's planned future weather station installations in future
WMP filings. Id. 14.
VI. Infrastructure Inspection & Maintenance
Staff believed that the material on standards and frequency of electric infrastructure
inspections included in the 2026 WMP, and supplied to Staff through discovery, satisfied the
WSCA (Idaho Code §§ 61-1803(3)(b), 61-1803(3)(g)(i)) and the Guidelines that require a WMP
to describe a utility's standards, efforts, and goals to inspect its electric infrastructure in areas of
heightened wildfire risk.Id. at 14.Even though Staff considered the information on the Company's
standards and frequency of electric infrastructure inspections in the 2026 WMP sufficient, S <':.
encouraged the Company to: (1) further develop its inspection and remediation process to supO *:-
tracking the length of a deficiency and timely repairs/resolutions of a deficiency; and (2) include
OR110. 37081 8

in future WMP filings more descriptions on the Company's quality assurance process for
infrastructure inspections and maintenance. Id. at 15.
VII. Vegetation Management
Staff believed the information in the 2026 WMP on the Company's process for vegetation
management was insufficient to satisfy the requirements of the WSCA (Idaho Code § 61-
1803(3)(g)(iii))and the Guidelines. Id. at 16. Staff explained this was because the 2026 WMP did
not include information on compensating timber companies foie Kid marketable timber identified
for removal from a timber company adjacent to the Company's"Right of Way...," which Staff
believed must be included in a WMP. Id. at 18 (citing Idaho Code § 61-1803(3)(g)(iii)).
However, Staff explained that because the Company provided information on the
Company's process for "compensating timber companies for marketable timber..." through
discovery,Staff believed the Company satisfied the requirements under the WSCA and Guidelines
to supply such information. Id. at 18. Staff stated the information on compensation to timber
companies must be included in an electric corporation's WMP under the WSCA and the
Guidelines, and not through discovery. Id. Staff recommended the Commission direct the
Company to include material on timber compensation to timber companies in any future WMP
filings.Id.
Even though Staff believed the information provided in the 2026 WMP, and through
discovery, met the requirements for vegetation management, Staff encouraged the Company to
improve: (1) vegetation management training; (2) tracking and inspecting hazard trees; (3) the
metrics used to assess the effectiveness of the Company's vegetation management;and(4)quality
assurance determinations of vegetation management practices.Id. 16-18.
PUBLIC COMMENTS
I. IDL Comments
IDL expressed concerns with the Company's risk modeling. IDL Comments at 1.
Specifically, IDL argued that because information on the Company's system was not included, it
was difficult to determine the risks wildfire posed to the Company's infrastructure, and the risks
the Company's infrastructure posed for wildfire ignition. Id. IDL requested that the Company's
future modeling include information on the Company's system to qualify the risks of wildfire to
and from the Company's system. Id. For the Company's future assessments of wildfire risk, IDL
stron:gly recommended the Company include data on: (1)the Company's system components; (2)
ORDER NO. 37081 9

where trees wurrotmdirg the Company's system aiv,WleM than the system infrastructure; and (3)
information on soif lypes,14'..V,Y"-? -
IDL.t&ommendc-,d. the; Company includo ihf6nnadon on the risks associated with, and
mitigation efforts for, damaging wind events that IDL believe occur frequently in the Company's
service territory. Id. at 2. IDL believed there is an opportunity for "cross integration" between
county level Community Wildfire Protection Plans("CWPP")and the utility's wildfire mitigation
plan and thus encouraged the Company to work with counties where the Company's system is
located to improve wildfire response and mitigation efforts.Id.
IDL believed the Company's cost breakdown was general and recommended the Company
provide more localized examples.Id. IDL also encouraged the Company to evaluate the cost of no
mitigation efforts to provide more information on the impacts of expenditure investment.Id. at 2-
3. IDL questioned whether a standard operating procedure ("SOP") existed for the Company's
work on industrial lands,and if the Cbtn
poy didnot have a SOP for that work,IDL recommended
the Company develop one. Id. at . Regarding the Company's vegetation management, IDL
recommended the Company's ins.p abon qualification standards include wildland fire
certification.Id.
COMPANY REPLY
The Company filed reply comments in response to Staff's comments but noted that because
IDL submitted comments on May 26, 2026, after the public comment deadline, the Company did
not have sufficient time to review and respond to IDL's comments. Company Reply at 1. Thus,
the Company's reply was limited to responding only to Staffs comments.Id. The Company stated
that it would consider IDL's comments and to the extent the comments were in line with the
WSCA,the Company would implement IDL's recommendations in its next WMP filing.Id.
The Company represented it has approximately 120 employees and serves about 30,000
members.Id. at 4.The Company requested the Commission approve the 2026 WMP and indicated
it is willing to supply additional information "reasonably required by the Commission."Id. at 4-
5. The Company asked that when reviewing Staffs recommendations that the Company include
additional information in future filings, that the Commission consider the Company's size and
available resources so that any additional requirements do not create an undue burden for the
Company. Id. at 5.
ORDER NO. 37081 10

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 that
the 2026 WMP, and the information the Company supplied in discovery, satisfies the minimum
statutory requirements set forth in Idaho Code § 61-1803 3}s A)-(g) and the Guidelines.
Specifically,the Commission finds that the 2026 WMP and the suppleire ntal information provided
in discovery regarding: (1) wildfire-related project-level forecasts; ('):funding alternatives and
sources; (3) wildfire risk mitigation benefits; (4) metrics used in components of the 2026 WMP;
(5) wildfire-related project-level details; (6) how the Company compensates timber companies;
and (7) information on the Company's weather station network (collectively "Supplemental
Information") is consistent with what is required under the WSCA and the Guidelines.
However, because the Supplemental Information was provided by the Company through
discovery, and not in the 2026 WMP, the Commission approves the 2026 WMP on the condition
that the Company file an updated 2026 WMP with the `'2!026 WMP Update Materials (defined
below)included,within 14 days from the date of the Commission's order it this case.Further,due
to die Commission's obligation under the WSCA to consider I.DL's recommendations, and the
presumption of their reasonableness under the WSCA, because we find that the IDL
Recommendations (defined below) are reasonable,just, and in the gointerest, the Company
must incorporate the IDL Recommendations in any future WMP filing .
I. 2026 WMP
The Commission finds that the 2026 WMP and Supplemental Information adequately
address the Company's wildfire risk identification and assessment, preventative and corrective
mitigation measures,public outreach and governmental coordination,infrastructure inspection and
maintenance, operational practices, vegetation management, situational awareness and
monitoring, emergency response planning, and public communication protocols. In making this
finding,the Commission considered: (1)the public interest, specifically,public health, safety,and
ORDER NO. 37081 11

welfare; (2) the feasibility of the proposed mitigation measures; and (3) the anticipated costs of
implementation.
a. Updated 2026 WMP Filing
While the Commission finds that the 2026 WMP and Supplemental Information satisfies
the requirements under WSCA and the Guidelines, the Commission finds that the Supplemental
Information must be included in the 2026 WMP and in future WMP filings, should the Company
file again for Commission review and approval. Our finding is based on the fact that the WSCA
imposes a rebuttable presumption that the Company acted without negligence if it reasonably
implemented its Commission-approved WMP. Thus, the Commission must ensure a WMP
comprehensively describes the Company's operational and mitigation measures for wildfire
mitigation.
Accordingly, the 2026 WMP is approved on the condition that the Company make a
compliance filing with the following information(collectively the"2026 WMP Update Materials")
incorporated into the 2026 WMP within 14 days of the date this Order:
Detailed, wildfire-related project-level cost forecasts for each year, consistent with the
information that was supplied in the Company's Response to Staff's First Production
Request at No. 1 Item 1-Exhibit A;
ii. Details of all funding alternatives and sources the Company pursued, consistent with the
information that was supplied in the Company's Response to Staff s Second Production
Request at No. 15 and the Company's Response to Staffs Second Production Request at
No. 16;
iii. Wildfire risk mitigatiop benefits, consistent with the information that was supplied in the
Company's Respdhsp,to Stuff s First Production Request at No. 1;
iv. All metrics used within each respective section of the WMP and provided in a format that
can easily be tracked across WMP filings,consistent with the information that was supplied
in the Company's Response to Staff s First Production Request at No. 11;
V. The Heightened Wildfire Risk Map overlayed with the Company's service territory
boundaries;
vi. A narrative explanation on how the Company divides its territory and how it prioritizes
wildfire-related projects in each section, consistent with the explanation the Company
provided in a meeting with Staff;
vii. Wildfire-related projeol4e el details that include targets, expected wildfire mitigation
benefits,and alternatives considered within the respective sections of the WMP,consistent
with the information that was supplied in the Company's Response to Staffs First
Production Request 4 No. 1 Item 1-Exhibit A;
ORDER NO. 37081 12

viii. The Company's process for compensating timber companies for marketable timber marked
for removal on land adjacent to Company's ROW,consistent with the information that was
supplied in the Company's Response to Staff s First Production Request at No. 4; and
ix. Details about the Company's weather station network, including areas of focus, average
cost, and any metrics it will use to evaluate success of said network, consistent with the
information that was supplied in the Company's Response to Staffs First Production
Request at No. 14.
The 2026 WMP Update Materials must be included in any future WMP filings submitted by the
Company. Due to the requirements established for WMPs under the WSCA and the Guidelines,
the Company must also include the following info_�tion in any future WMP filings:
i. Information on wildfire risk mitigation beh6f-its that shows the Company is applying a
consistent,trar+sparent; and repeatable methodology across projects;
ii. An explawtion of how certain mitigation activities (such as grid hardening efforts) are
reducing wildfire risk; and
iii. A more:detailed'explanation of how each heightened wildfire risk zone was determined.
Shor►ld the C'oznpany fail to file with the Commission an updated 2026 WMP with the 2026
WMP Update Matra ',.a incorporated within 14 days of this Order, the Commission will by its
order revoke its approval of the 2026 WMP.If the Company files with the Commission an updated
2026 WMP with the 2026 WMP Update Materials incorporated within 14 days of the
Commission's order in this case, then we find that the Company may file an updated WMP
annually on of about December 31 of each year for Commission review and approval.
We find that incorporating the 2026 WMP Update Material in the 2026 WMP will ensure
that the 2026 WMP comprehensively describes the Company's operational and mitigation
measures, in accordance with the WSCA.Further, we find it reasonable to require the Company
to incorporate the 2026 WMP Update Materials in the 2026 WMP because the 2026 WMP Update
Material was supplied by the Company in discovery and meetings with Staff.
II. IDL Recommendations
The Commission acknowledges the timing of IDL's comments limited the Company's
opportunity to respond to IDL's recommendations. However, the Commission's procedural rules
must be"liberally construed to secure just, e*,and economical determination of all issues..."
IDAPA 31.01.01.013.Thus,"[u]nless prohbt by statute,the Commission may permit deviation
from these rules when it finds compliance with them is impracticable, unnecessary, or not in the
public interest." Id. Due to the Commission's statutory obligation to consider IDL's
recommendations,the Commission has considered IDL's late filed comments in this case.
ORDER NO. 37081 13

Accordingly, 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"):
i. Include information on the Company's system in the Company's future modeling to qualify
the risks of wildfire to and from the Company's system;
ii. For the Company's future assessments of wildfire risk, include data on:
a. The Company's system components;
b. Where trees surrounding the Company's system are taller than the Company's
surrounding infrastructure; and
c. Information on soil types.
iii. Include information on the risks associated with,and mitigation efforts for,damaging wind
events;
iv. Work with counties where the Company's infrastructure is located to improve wildfire
response and mitigation efforts;
V. Provide more localized examples of the Company's cost breakdown;
vi. Evaluate the cost of no mitigation efforts to provide more information on the impacts of
the Company's expenditures; and
vii. Develop a SOP for the Company's work on industrial lands, if one does not exist already.
While the Commission is unopposed to IDL's position that vegetation inspection practices
and certification standards should address conditions specific to wildfire risks (IDL
Recommendation No. 7),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 addit oual
information from IDL, 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 address IDL's concerns about vegetation
inspections overlooking fire ignition and propagation potential. In the Company's next WMP, it
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.
ORDER
IT IS HEREBY ORDERED that the 2026 WMP is approved subject to the condition that
the Company must file with the Commission as a compliance filing an updated 2026 WMP with
the 2026 WMP Update Materials incorporated within 14 days of this Order.
ORDER NO. 37081 14

IT IS FURTHER ORDERED that the Company shall incorporate the 2026 WIMP Update
Materials outlined in this order in future WMP filings, 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 the Company shall incorporate in future WMP filings
the IDL Recommendations outlined in this Order.
IT IS FURTHER ORDERED that the Company shall incorporate in future WMP filings:
(1) information on wildfire risk mitigation benefits that shows the Company is applying a
consistent, transparent, and repeatable methodology across projects; (2) an explanation of how
certain mitigation activities (such as grid hardening efforts) are reducing wildfire risk; and (3) a
more detailed explanation of how each heightened wildfire risk zone was determined, provided
that such material may be reasonably adjusted to account for change in facts, circumstances,
available data, applicable assumptions, and other relevant factors.
IT IS FURTHER ORDERED that should the Company satisfy the condition that the
Company must file with the Commission as a compliance filing an updated 2026 WMP with the
2026 WMP Update Materials incorporated within 14 days of this Order, then the Company may
file its future annual WMP on or about December 31 of each year.
IT IS FURTHER ORDERED that should the Company fail to file with the Commission an
updated 2026 WMP with the 2026 WMP Update Materials incorporated within 14 days of this
Order,the Commission will by its order revoke its approval of the 2026 WMP.
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. 37081 15

DONE by Order of the Idaho Public Utilities Commission at Boise, Idaho this 291h day of
June 2026.
EDWARD LODGE, PR IDENT
11t - xf�
J R. HAMMOND JR., COMMISSIONER
DAYN HA IE, COMMISSIONER
ATTEST:
o 1 a anchez
Commission Secretary
1:1LepPELECTR10C07•E•25.01_KEC WMPorder%C07E2501_F0_kr_.docx
ORDER NO. 37081 16