20260831Reconsideration Reply Comments.pdf

' 11.
RECEIVED
August 31, 2026
Avista Corp. IDAHO PUBLIC
1411 East Mission P.O. Box 3727 UTILITIES COMMISSION
Spokane, Washington 99220-0500
Telephone [phone]
Toll Free 800-727-9170
August 31, 2026
Monica Barrios-Sanchez
Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd
Building 8, Suite 201-A
Boise, ID 83714
RE: Case No. AVU-E-25-15 —Avista Corporaiton's 2026 Wildfire Mitigation Plan
Dear Commission Secretary:
Enclosed for electronic filing with the Commission is Avista's Reconsideration Reply Comments
in Case No. AVU-E-25-15.
Please direct any questions regarding these comments to Liz Andrews at 509-495-8601 or
liz.andrews@avistaco!p.com.
Sincerely,
l sl 'F*k'ai '4W*ew
Elizabeth Andrews
Sr. Manager of Revenue Requirements
[e-mail]
509-495-8601

ANNI GLOGOVAC, ISB #13010
COUNSEL FOR REGULATORY AFFAIRS
AVISTA CORPORATION
1411 E. MISSION AVENUE
P.O. BOX 3727
SPOKANE, WASHINGTON 99220
PHONE: [phone]
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF AVISTA ) CASE NO. AVU-E-25-15
CORPORATION'S APPLICATION FOR )
APPROVAL OF THE 2026 WILDFIRE ) AVISTA CORPORATION
MITIGATION PLAN ) REPLY COMMENTS TO
RECONSIDERATION ORDER NO.
37106
COMES NOW, Avista Corporation ("Avista" or "Company"), in accordance with the
Idaho Public Utilities Commission("Commission" or"IPUC")Rule of Procedure' ("RP") 52 and
the Commission's order granting reconsideration of Order No. 36927, dated July 28, 2026
("Reconsideration Order No. 37106"), respectively, submits the following Reply Comments
regarding Avista's Application for Approval of the 2026 Wildfire Mitigation Plan ("WMP",
"Wildfire Plan" or"Plan").
I. INTRODUCTION
On December 9, 2026, Avista Corporation ("Avista" or the "Company") filed for
Commission approval its 2026 WMP (the "Application").2 The 2026 WMP is Avista's fifth
'Idaho Administrative Procedures Act(IDAPA)31.01.01.
2 See IPUC Case No.AVU-E-25-15.
AVISTA REPLY COMMENTS Page 1

edition of the Plan, though, its Application was the first filed pursuant to the Wildfire Standard of
Care Act ("WSCA"), Idaho Code § 61-1801, et seq. PotlatchDeltic Forest Holdings, LLC
("PotlatchDeltic") filed, and the Commission granted on December 31, 2025, a Petition to
Intervene in Avista's Application 3. Bennett Lumber Products, Inc. ("Bennett Lumber"), Manulife
Investment Management, Molpus Woodlands Group, and Stimson Lumber Company (together
with PotlatchDeltic, the "Petitioners") did not intervene in Avista's Application, nor did they
provide comments under the Notice of Modified Procedure Order No. 36927 issued by the
Commission on February 4, 2026.
On June 9,2026,the Commission issued Final Order No. 37064,approving the Company's
2026 WMP, and on June 30, 2026, PotlatchDeltic and Bennett Lumber, et. al. (together the
"Petitioners") filed petitions for reconsideration. Reconsideration was granted by the Commission
on July 28, 2026, in Reconsideration Order No. 37106. Avista appreciates the opportunity to
provide these comments in response to Reconsideration Order No. 37106 and the response
comments filed by the Petitioners.
As noted in the Commission's Reconsideration Order No. 37106,the Idaho Department of
Lands("IDL")submitted public comments on Avista's Application,"one filed timely and the other
filed after the deadline. ,4 Given that IDL's May 20, 2026, comments were filed after the deadline,
Avista was not afforded the opportunity to address the Idaho State Forester's recommendations
through IDL's additional comments on the record. The basis of Bennett Lumber's response
comments that, "the Company's 2026 WMP failed to meaningfully consider the recommendations
of the Idaho State Forester" through the IDL is not entirely accurate and fails to account for the
Commission's responsibility to make determinations based on evidence in the record before it.
3 IPUC Intervention Order No.36888.
4 IPUC Reconsideration Order No. 37106,at p. 1.
AVISTA REPLY COMMENTS Page 2

Presumptively, the purpose of the supplemental comment process established in
Reconsideration Order No. 37106 is to promote a complete and balanced record upon which the
Commission can conduct its independent review.' Although one of IDL's comments was filed
after the original deadline, Avista uses this opportunity to address the recommendations raised in
that filing, so that the Commission may evaluate them thoroughly. Such an approach is consistent
with the Commission's obligation to reach its decision based on a full and fair consideration of all
relevant arguments rather than on unrebutted assertions. Avista encourages the Commission to
consider both the recommendations themselves and Avista's response herein to evaluate whether
Petitioners have met their burden to demonstrate that Final Order No. 37064 is unreasonable,
unlawful, erroneous, or not in conformity with law. We believe they have not.
II. BACKGROUND
As noted in its Application,Avista's WMP is the product of the Company's ongoing efforts
to reduce wildfire risk for the safety of Avista's customers and communities, and the continued
delivery of reliable electricity to approximately 150,000 retail electric customers in Idaho. In line
with WSCA requirements, Avista employs a risk-informed approach to select and prioritize
various wildfire mitigations carried out to reduce the risk of wildfire while balancing wildfire risk
and cost of mitigation. As more thoroughly discussed in the Plan, and summarized within Avista's
Application, Avista's WMP identifies the methods and means for mitigating wildfire risk that
reflect a reasonable balancing of mitigation costs with the resulting reduction of wildfire risk,while
complying with the requirements of Idaho Code § 61-1801 et. seq., and the additional directives
5 See also, Bennett Lumber's response comments at p. 3, "Furthermore, IDAPA 31.01.01.013 provides that
Commission rules are to be liberally construed to secure a just determination of issues....".
AVISTA REPLY COMMENTS Page 3

from the Commission as set forth in Order No. 36774, issued in Case No. GNR-E-25-02 on
September 30, 2025.
III. LEGAL STANDARDS
A. PotlatchDeltic's Procedural Argument
PotlatchDeltic asserts that its Petition for Reconsideration("Petition") is "uncontested and
unchallenged"because neither Avista nor Commission Staff filed an answer within seven(7)days
of filing its Petition. That argument both misinterprets the Commission's Rules of Procedure and
misstates the Commission's order granting reconsideration.6
Rule 331 governs petitions for reconsideration, cross-petitions, and answers thereto.
Nothing in Rule 331 provides that a party waives its right to participate in reconsideration
proceedings by not filing an answer within the time contemplated by the rule, nor does the rule
provide that a petition for reconsideration is deemed admitted if no answer is filed. Further,
pursuant to Rule 57(b), "The complainant or petitioner must offer evidence of its allegations
regardless of whether the complaint or petition is answered or denied." Seemingly,
PotlatchDeltic's position is that this is merely a procedural dispute, which is inconsistent with the
Commission's role on reconsideration and is contrary to the Commission's chosen reconsideration
procedure in Reconsideration Order No. 37106.
The Commission retains discretion to determine how reconsideration will proceed. Rule
332 expressly provides that, after reconsideration is granted, the Commission may consider the
matter through "briefs, memoranda, written interrogatories or written statements, or otherwise."
Importantly,the Commission exercised that authority in its Reconsideration Order No. 37106. The
Commission not only granted reconsideration for the limited purpose of supplementing the record,
6 See,PotlachDeltic's Response to Reconsideration Order No. 37106,at p.4.
AVISTA REPLY COMMENTS Page 4

but as PotlatchDeltic also identified in its Response Comments, the Commission expressly found
it reasonable to grant Avista"an opportunity to file responsive comments."
In its Petition, PotlatchDeltic declines to provide additional information or arguments in
support of its position, instead relying on the existing record.' Consistent with the Commission's
authority cited above,while the Commission has the discretion to reconsider matters based on the
record before it,"[g]rounds for,or issues,on reconsideration not supported by specific explanation
may be dismissed."RP 332.
Ultimately,PotlatchDeltic's contention that its reconsideration arguments are"uncontested
and unchallenged" on its face provides no legal basis for denying Avista's WMP, and should be
disregarded. Rule 332 expressly authorizes the Commission, after granting reconsideration, to
determine the procedure to be followed, including consideration of the matter through briefs,
memoranda,written comments,written statements, or other submissions.Avista now properly and
timely submits these responsive comments pursuant to the procedure established by the
Commission in Reconsideration Order No. 37106.
B. Bennett Lumber's Statutory Liability Argument
Bennett Lumber, et. al., requests that the Commission reverse its determination in Final
Order No. 37064, and require the Company to "fully incorporate[] the Idaho State Forester's
recommendations as a condition to its [WMP] approval."9 Without such recommendations
incorporated into the WMP, Bennett Lumber asserts that Avista enjoys "significant statutory
protection against liability".10 Avista addressed a similar argument on page 21 of its Reply
Comments to PotlatchDeltic filed on April 30, 2026:
7 Id.at pp. 3-4(quoting Reconsideration Order No. 37106).
$Id.at p.4.
9 Bennett Lumber,et. al.,Response Comments at 7.
10 Id. at 3.
AVISTA REPLY COMMENTS Page 5

...[T]he WSCA provides a rebuttable presumption only when the utility
"reasonably implemented" the Commission-approved plan with respect to the
cause of the wildfire. That is not blanket immunity, but rather, a conditional,
rebuttable presumption.
The WSCA expressly anticipates that a utility may be found liable and provides
the framework applicable in that circumstance." (emphasis added, footnotes
omitted)
Further, Bennett Lumber appears to take the position that any recommendation advanced
by IDL must be incorporated into Avista's WMP to satisfy the WSCA requirements. That is not
the standard established by Idaho Code § 61-1803, which requires a utility to develop and
implement a wildfire mitigation plan that balances wildfire risk reduction with customer costs and
system reliability. The statute does not require adoption of every recommendation offered by
interested stakeholders, nor does it establish that a plan is legally deficient whenever a
recommendation is not incorporated. Rather, the Commission must evaluate whether the Plan,
taken as a whole, reasonably satisfies the statutory objectives. As determined by the Commission
in Final Order No. 37064, Avista's 2026 WMP does so. The mere existence of alternative
recommendations, including recommendations not adopted by Avista, does not demonstrate that
the Plan is unreasonable, unlawful, or otherwise inconsistent with Idaho law.
The Commission's task is not to determine whether additional wildfire mitigation measures
could be adopted, but whether Avista's proposed Plan satisfies the requirements of Idaho Code §
61-1803. Wildfire mitigation planning inherently involves choices regarding the appropriate
balance between incremental risk reduction and the costs borne by customers. A
recommendation's absence from an approved WMP is not evidence that the plan is legally
deficient or inadequate. To the contrary,the statute contemplates utility judgment and Commission
oversight in determining which mitigation measures are reasonable and cost-effective under the
circumstances. Accordingly, Avista believes its 2026 WMP has met its statutory obligations.
AVISTA REPLY COMMENTS Page 6

Notwithstanding the foregoing, Avista does not contend that the Idaho State Forester's
recommendations are unreasonable or inappropriate,nor does Avista contend that IDL's late-filed
recommendations should be disregarded altogether. The Company reasons that fundamental
procedural fairness requires that parties be afforded a meaningful opportunity to respond to
arguments and recommendations before they form the basis for Commission action. By granting
reconsideration and establishing a responsive comment schedule, the Commission has provided
the process necessary to ensure that all relevant viewpoints are considered on an equal footing.
Thus, Avista addresses IDL's recommendations herein, so that the Commission may evaluate
those recommendations in light of the complete record.
IV. AVISTA'S RESPONSES TO PETITIONERS AND IDL'S
RECOMMENDATIONS
On May 20, 2026, IDL provided supplemental comments related to "data inputs to be
included in future evaluations of wildfire risk."11 On August 11, 2026, Bennett Lumber Products,
Inc.12, Manulife Investment Management, Molpus Woodlands Group, and Stimson Lumber
Company ("Bennett Lumber, et. al.") submitted response comments to supplement the record
following the Commission's grant of reconsideration in Order No. 37106, including sworn
declarations of Andrew Stockwell(Stimson Lumber Company), Patrick Morolla(Manulife Forest
Management), and Halli Hemingway (Bennett Lumber Products, Inc.).13 Consolidated issues
raised by these parties relate to risk modeling inputs, formal timber valuation procedures, cost-
benefit analysis of mitigation measures, wildfire-specific worker qualifications and vegetation
" See Idaho Department of Lands Supplemental Comments "2026.05.20 AVU-E-25-15 IDL Supplemental
Comments-Avista Wildfire Mitigation Plan 2026"filed on May 20,2026.
12 See Bennett Lumber,et. al.,Response Comments at 1.
13 See"20260811 Declaration of A. Stockwell ISO Response","20260811 Declaration of P.Marolla ISO Response"
and"20260811 Declaration of H.Hemingway ISO Response",filed on August 11,2026.
AVISTA REPLY COMMENTS Page 7

inspection practices, activities intended to reduce damage from wildfire events, and county fire
planning group input.14 Avista addresses these issues as follows:
A. Risk Modeling
The Bennett Lumber, et. al. response comments contend that Avista's Plan lacks detail
regarding modeling inputs, such as fuel loads, vegetation density, and terrain, and that although
Avista had previously addressed a future updated risk analysis approach that compliments that
used by the State of Idaho, no further detail or clarification was provided as to the current model
which the Company is currently using.15
Avista recognizes the importance of transparent wildfire risk assessment. As described in
Avista's April 30, 2026 reply comments in Case No.AVU-E-25-15,the Company is implementing
an updated geographic risk analysis that uses multiple data inputs, including information
complementary to data used by the State of Idaho in its State Forest Action Plan risk analysis.
Future Avista Wildfire Mitigation Plan filings will provide such additional detail on the model and
its inputs.
Avista's new ATS Wildfire Risk Analysis and Management (AWRAM) model has now
been implemented and is currently live. The Company is in the process of evaluating this new
model,understanding its overall functions,determining the required processes and procedures,and
verifying outputs that will result in required actions.
The new AWRAM model includes the following inputs in its analysis:
14 Ibid.
15 Bennett Lumber,et.al.,Response Comments at 4-5.
AVISTA REPLY COMMENTS Page 8

�Category ModelInputs
Weather Wind speed and direction, temperature, humidity, precipitation, weather
forecasts, and real-time weather observations
Fuels ANDFIRE fuel models, vegetation type and condition, and live and dead
fuel moisture
Topography Digital elevation models
Barriers Roads,rivers, lakes, and other natural or constructed features that affect fire
spread
Ignition source Utility asset locations used as starting points for simulated ignitions
Fire propagation ire spread across 20-meter hexagons using weather,fuels,topography,an
barriers to estimate fire growth potential
utility Asset locations, system topology, outages, asset condition and mitigations
For its 2026 WMP, Avista used a static risk model in its legacy Fire Weather Dashboard.
That model considered the following factors:
• Fuel types, including shrubs, grasses, and trees
• Topography
• Community risk
• Historical summer outage performance
• Severe Fire Danger Index (SFDI)
• Fire Preparedness Level
• Percentage of overhead spans in treed areas
The factors assessed through Avista's legacy risk model established baseline circuit wildfire risk.
Avista then combined the baseline risk with forecast and real-time wind, temperature, and
humidity data to calculate the dynamic Fire Risk Index used to assess operational decisions.
During the review of the 2026 WMP, Avista discussed its modeling approach with both
Commission Staff and an IDL representative.Avista also described the model inputs used to assess
wildfire risk associated with overhead electrical equipment in response to Staff Production
Requests and as provided to the parties in this case. As noted, future Avista Wildfire Mitigation
Plan filings will provide additional detail on the AWRAM model, which includes factors above
AVISTA REPLY COMMENTS Page 9

and beyond its legacy risk model. Regardless of the risk model used, Avista's current Plan and
associated model inputs are compliant with the current legislative and regulatory requirements.
B. Fair Market Value of Timber
The response comments from Bennett Lumber, et. al. indicate that Avista's Plan lacks a
formal, consistent procedure for compensating landowners for the removal of merchantable
timber.16 As described in the Company's April 30, 2026 reply comments, Avista will continue to
refine its standard operating procedures,consistent with recommendations from the IDL,regarding
the treatment of marketable timber when trees or other vegetation must be removed from industrial
lands. This includes coordination with state and federal land management agencies or large private
industrial landowners, as applicable, in circumstances where fair market valuation, appraisal, and
permitting requirements may apply." Furthermore, Avista has taken steps to address concerns
regarding payment for merchantable timber and is continuing to formalize its procedures. Avista
will continue to refine a more formal process to ensure landowners receive appropriate
payment when wildfire mitigation activities require tree removal.
C. Cost-Benefit Analysis and Mitigation Prioritization
The response comments from Bennett Lumber, et. al. note concern that without a clear
cost-benefit analysis for mitigation categories, there is a risk that Avista is failing to prioritize the
most effective mitigation work in the highest-risk locations."As described in the Company's April
30, 2026 reply comments, the Company completed a robust and detailed cost-benefit analysis for
16 Bennett Lumber,et.al.,Response Comments at 5.
11 As previously stated,Avista does not intend to establish procedures requiring the application of fair market timber
valuation when vegetation management activities are conducted within existing easements or other rights-of-way that
the Company has previously acquired and which secure the Company's right to trim or remove vegetation;vegetation
management within these areas is performed pursuant to the Company's established property rights or other prior
agreements and is necessary to maintain system safety,reliability,and wildfire risk reduction objectives.
18 Bennett Lumber,et.al.,Response Comments at 6.
AVISTA REPLY COMMENTS Page 10

undergrounding distribution facilities to better understand the feasibility,risk-reduction value,and
customer cost implications of that mitigation option. Other wildfire mitigation measures,including
vegetation management and grid hardening,will be evaluated using Avista's new risk model going
forward, with investments focused on areas identified as having elevated wildfire ignition risk.
This model will support risk-based budgeting and mitigation planning by identifying spending
efficiency, comparing risk before and after treatment, and simulating potential fire spread under
pre-treatment and post-treatment conditions. Avista expects to apply these capabilities across
multiple mitigation options and provide additional details in future annual WMP updates.
D. Worker Qualifications and Vegetation Management
Bennett Lumber, et. al., argues that Avista's Plan is missing critical worker qualification
requirements, and that vegetation inspections must be conducted by individuals with specific
training in wildfire risk, ladder fuels, and site-specific terrain.19 As described in the Company's
April 30, 2026 reply comments, Avista is not recommending any changes to the certifications
required for its Vegetation Management staff or contractors at this time. Avista's vegetation
management contractor qualifications conform to applicable industry standards, including
American National Standards Institute(ANSI)A300,the National Electrical Safety Code(NESC),
and North American Electric Reliability Corporation (NERC) vegetation management
requirements. These standards provide comprehensive requirements related to vegetation
clearance, pruning practices, and system safety, and appropriately address the Company's
objective to reduce tree-to-wire conflicts and the potential for overhead electrical equipment to
cause an ignition.
19 Ibid.
AVISTA REPLY COMMENTS Page I I

Avista supports hazardous fuels reduction and funds priority projects through its
Vegetation Management program. Landscape-scale hazardous fuels treatments, however, are
outside the primary scope of utility vegetation management. Therefore, requiring additional
qualifications designed for landscape-scale fuels treatment would not materially improve Avista's
execution of utility vegetation-management activities, as those activities have a different scope,
purpose, and governing standards. Imposing unrelated qualification requirements could reduce
contractor availability and increase costs without a corresponding reduction in utility-related
wildfire risk.
E. Local Coordination
Bennett Lumber, et. al. argues that obtaining input from county fire planning groups is
important because these groups often have practical, specific local knowledge regarding fire
history, access routes, suppression constraints, seasonal fuel conditions, and community
vulnerabilities.20 Avista agrees. As described in the Company's April 30, 2026 reply comments,
Avista recognizes the importance of county-level wildfire preparedness planning and the value of
coordination through established county fire planning groups. The Company currently engages in
local wildfire planning efforts and has participated in recent Community Wildfire Protection Plan
(CWPP) development activities in Latah County through attendance at planning meetings and
coordination with local partners. Avista values local expertise and agrees that continued
collaboration with county planning groups supports alignment among wildfire mitigation efforts,
improves information sharing,and enhances the effective use of available resources.The Company
intends to continue participating in these collaborative forums and to pursue additional
20 Bennett Lumber,et.al.(Stimson Lumber),Response Comments at 5.
AVISTA REPLY COMMENTS Page 12

opportunities to support coordination with Ere agencies, local governments, landowners, and
community stakeholders, where appropriate. The Company also works with Latah, Bonner, and
Nez Perce Counties to support fuels-reduction treatments near overhead electrical facilities.
Additionally, Avista has an agreement with IDL to coordinate on broader statewide fuels-
reduction priorities and is currently supporting a hazardous fuels-reduction project in Shoshone
County. These activities demonstrate that local and county-level input is already incorporated into
Avista's wildfire mitigation efforts, even though the WMP does not prescribe a separate formal
consultation process for every county in Idaho.
F. External Wildfire Considerations and Coordination
The Petitioners suggest that Avista's Wildfire Mitigation Plan does not clearly identify
activities intended to reduce damage from external wildfire events. However, Avista's wildfire
mitigation program addresses both utility-related ignition risk and the impacts of wildfires
originating outside utility corridors, rights-of-way, or Company facilities. Through wildfire
situational awareness, emergency response planning,vegetation management, grid hardening, and
infrastructure resiliency investments, the Company works to reduce wildfire risk and improve
system resilience regardless of ignition source.
These measures include monitoring wildfire conditions throughout the fire season,
coordinating with fire agencies and emergency management organizations, supporting fuels
reduction activities near electrical facilities, and implementing infrastructure improvements
intended to withstand wildfire exposure. As described throughout the Wildfire Mitigation Plan,
Avista's resiliency investments include measures such as installation of fire-resistant steel poles,
fire mesh, and other system hardening improvements designed to reduce infrastructure damage
from external wildfire events and support more rapid restoration when fire impacts occur.
AVISTA REPLY COMMENTS Page 13

Avista also collaborates with county fire planning groups (as noted above), the IDL, and
other local stakeholders to improve coordination, information sharing, and overall wildfire
preparedness. These partnerships help identify emerging wildfire threats and support coordinated
response efforts when wildfires threaten utility facilities or surrounding communities.
Accordingly, Avista does not agree that external wildfire threats are omitted from the
Company's wildfire mitigation program simply because they are not identified under a separate
standalone section of the Plan. Rather, as discussed extensively in Avista's comments in this case,
external wildfire considerations are incorporated throughout the Company's wildfire preparedness,
operational response, vegetation management, and resiliency strategies.
V. CONCLUSION
Avista remains committed to engaging with stakeholders, considering constructive feedback,
and continually improving its wildfire mitigation efforts while maintaining safe, reliable, and
affordable service.In approving Avista's 2026 Wildfire Mitigation Plan,the Commission carefully
considered the record and exercised its discretion in determining that Avista's Plan meets the
statutory requirements. Upon reconsideration, the Petitioners have failed to meet their burden of
demonstrating that Final Order No. 37064 is unreasonable, unlawful, erroneous, or otherwise not
in conformity with the law. Accordingly, the Commission should reject the Petitioners'
contentions, and affirm Final Order No. 37064 in all respects.
Respectfully submitted this 3Pt day of August, 2026.
( Wt �9�,
ni Glogovac, ISB #13010
Counsel for Regulatory Affairs
AVISTA REPLY COMMENTS Page 14

CERTIFICATE OF SERVICE
I HEREBY CERTIFY that I have this 31st day of August, 2026, served the foregoing
Reconsideration Reply Comments upon all parties to Case No. AVU-E-25-15, through
electronic mail:
Commission Staff: Potlatch:
Jeff Loll Peter J. Richardson
Deputy Attorney General Richardson Adams, PLLC
Idaho Public Utilities Commission 515 N. 27th Street
P.O. Box 83720 Boise, ID 83702
Boise, ID 83702-0074 peter(a),richardsonadams.com
Jeff.lollkpuc.idaho.gov
Michele Tyler, Esq.
Monica Barrios-Sanchez Wade Semeliss
Idaho Public Utilities Commission Brian Schlect, Esq.
11331 W. Chinden Blvd Anna Torma
Building 8, Suite 201-A michele.tyler(a),potlatchdeltic.com
Boise, ID 83714 wade.semeliss&potlatchdeltic.com
secretary�a,puc.idaho.gov brian.schlect(&,potlatchdeltic.com
anna.tonnagpotlatchdeltic.com
Idaho Department of Lands: Bennett Lumber, et al.:
J.J. Winters Tara Malek
John A. Richards Smith+Malek, PLLC
300 N. 6th St., Ste. 103 601 E. Front Ave., Ste. 304
Boise, ID 83702 Coeur d' Alene, ID 83814
jwinterskidl.idaho.gov servicegmalekattome. s
'richards idl.idaho. ov
Is/Athena Allen
Athena Allen
Regulatory Affairs Analyst