20260914Amended Application.pdf

RECEIVED
September 14, 2026
IDAHO PUBLIC
UTILITIES COMMISSION
ATLANTA
POWER
Atlanta Power Company
Wildfire Mitigation Plan
Page 1

Table of Contents
ExecutiveSummary............................................................................................................................3
Purpose of the Wildfire Mitigation Plan...................................................................................................3
Section1 —Utility Overview..............................................................................................................4
Section 2—Geographical Risk Assessments..................................................................................5
2.1 —General Description of Service Territory and Risk Factors....................................................5
2.2—Risk Tier Methodology and Map............................................................................................5
2.3—Consideration of the Wildland-Urban Interface (WUI)................................................................7
Section 3—Preventative Actions and Programs..........................................................................7
3.1 —Current Status of Preventative Actions and Programs............................................................7
3.2—Additional System Hardening Equipment...............................................................................8
3.3—Deficiency Classification and Prioritization...................................................................................9
Section 4—Public Outreach and Engagement.............................................................................9
4.1 —General Communication Channels and Wildfire Outreach.....................................................9
4.2—Customer Communication Regarding De-Energization.............................................................10
Section 5—Government Outreach................................................................................................10
Section 6—Method of Line Design................................................................................................10
6.1 —General Line Design and Construction Standards ................................................................ 10
6.2—Construction Standards for Heightened Risk Areas....................................................................1 1
Section 7—Situational Awareness and Monitoring..................................................................11
7.1 —Weather and Fire Danger Monitoring Systems.....................................................................11
7.2—Integration into Operations ................................................................................................... 11
7.3—Enhanced Monitoring Frequency During Heightened Risk.......................................................12
Section 8—Infrastructure Inspections,De-Energization, and Vegetation Management............12
8.1 —Applicable Inspection and Vegetation Management Standards............................................ 12
8.2—De-Energization: Scope, Standards, and Restoration Protocol.............................................13
8.3—Heightened Fire Risk Area,Vegetation Management and Risk Tree Program.......................13
Section 9—WMP Expenditures and Cost-Benefit Analysis....................................................14
9.1 —Three-Year Expenditures Summary......................................................................................14
9.2—Cost-Benefit Analysis......................................................................................................................14
Additional Filing Requirements.....................................................................................................17
Attachment 1 -Notice of WMP Filing(WSCA § 61-1804(2))...........................................................17
Attachment 2—Compliance Crosswalk, I.C. § 61-1803(3).................................................................18
Page 2

Executive Summary
Atlanta Power Company is a small, investor-owned electric distribution utility serving the isolated
mountain community of Atlanta,Idaho, in Elmore County. The Company's entire 3.0-square-mile service
territory is surrounded by the Boise National Forest and falls entirely within the Wildland-Urban
Interface.Atlanta Power's system consists of approximately 6.0 miles of overhead distribution line
operating at 2.4 W.
Atlanta Power is committed to proactive wildfire risk reduction. The utility is currently undertaking three
significant infrastructure initiatives that constitute its primary mitigation strategy: (1)the ongoing
relocation of Atlanta Power's distribution lines from forested areas to roadways, (2) a systematic
replacement of aged poles and conductors with new infrastructure throughout the 6-mile system, and(3)a
yearly system-wide vegetation management program.
Purpose of the Wildfire Mitigation Plan
This Plan explains how Atlanta Power designs, inspects, operates, and maintains its electrical system to
reduce wildfire risk. It also covers how the Company coordinates with agencies like the U.S.Forest
Service and the Atlanta Fire District on wildfire preparedness and emergency response, and how it keeps
customers informed of wildfire risks and outages before, during,and after fire season. Sections 3 and 8
address system hardening, construction,inspections, and vegetation management.A crosswalk of this
Plan to each requirement of I.C. § 61-1803(3) is provided in Attachment 2.
Page 3

Section 1 — Utility Overview
Utility Name Atlanta Power Company
Service Territory Size (sq TOTAL: 3.0
miles)
Service Territory Make-up <1%Urban
(Note:data are from the 5%Barren/Other
national land cover database at 85%Evergreen and Mixed Forests
USGS.gov;not all categories 9% Shrub
are represented in this
template) 1%Water
Service Territory Wildland- TOTAL: 100%of the Company's service territory falls within the WUI
Urban Interface(based on boundary, consistent with the WUI methodology described in Section
total area) 2.3 of this plan.
Utility Equipment Make-up Overhead Distribution: 6 miles of 2.4 kV
(circuit miles)
Have protocols been No
developed to pre-emptively
shut off electricity in
response to elevated wildfire
risks?
Has electricity previously No
been pre-emptively shut off
in response to elevated
wildfire risk?
Page 4

Section 2 — Geographical Risk Assessments
2.1 — General Description of Service Territory and Risk Factors
Atlanta, Idaho,is an isolated mountain community surrounded by the Boise National Forest, at roughly
5,400 feet elevation near the headwaters of the Middle Fork of the Boise River. The terrain is steep
canyon country with dense surrounding timber,matching the 85%evergreen and mixed forest land cover
reported in Section I. During fire season,more than one route provides access into and out of the
community;however, all these routes remain unimproved dirt roads that continue to limit access,a factor
relevant to both wildfire risk and emergency response. Together,these conditions place the Company's
entire service territory within a Wildland-Urban Interface intermix zone, described further in Section 2.3.
2.2 — Risk Tier Methodology and Map
Atlanta Power sorts all overhead electric facilities in its Idaho service territory into four risk tiers,based
on a composite score covering vegetation, fuel load and type,historical fire occurrence,terrain and slope,
sustained wind exposure, and structure density. As Section 2.3 explains, 100%of the Company's service
territory sits within the Wildland-Urban Interface(WWI), so WUI status alone doesn't differentiate risk
here the factors above do that work instead. Tier assignments also shift with the season: because
wildfire risk rises during fire season, each area's baseline classification moves up one tier during that
period,matching the enhanced monitoring and inspection practices in Sections 4.3 and 7.3. Each tier's
baseline(non-fire-season)and fire-season classification is defined below:
• Tier 1 —Extreme: The Company's 1.5-mile Heightened Fire Risk Area(see Section 8.3)during
fire season, subject to the heightened inspection,vegetation management, and operational
practices in Sections 6 through 8. Outside fire season,this same 1.5-mile area is Tier 2(see
below).
• Tier 2—Elevated: (a)the Company's 1.5-mile Heightened Fire Risk Area outside fire season(its
baseline classification, see Tier 1 above); and(b)the remainder of the system(approximately 4.5
miles)during fire season,when its baseline Tier 3 classification(see below)moves up one tier.
• Tier 3—Moderate: The remainder of the system(approximately 4.5 miles)outside fire season.
This is the baseline,non-fire-season tier for this portion of the system, and the floor tier for the
system overall(see Tier 4 below). It moves up to Tier 2 during fire season(see above).
• Tier 4—Low:Not applicable, due to the Company's entire 3.0-square-mile service territory sits
within the WUI and is immediately adjacent to forested terrain(see Sections 1 and 2.3);no part of
the system qualifies for the lowest risk tier. Tier 3 is therefore the lowest risk classification
present on the system.
Page 5

Figure 2-1,below, shows these risk tiers geographically across the Company's Idaho service territory,
color-coded by tier and cross-referenced to the mileage figures cited elsewhere in this Plan(e.g.,the 1.5-
mile Heightened Fire Risk Area boundary discussed in Section 8.3).
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Figure 2-1 shows the Company's full system, color-coded per the map's legend.Red segments mark the
Company's 1.5-mile Heightened Fire Risk Area(Tier 1 &2, see Sections 2.2 and 8.3), combined across
multiple segments of the system. Blue segments mark the three completed line relocation projects,labeled
on the map: Main Line Project(Main Line into Town),Pine Street Project, and Mine Hill Project(Mine
Hill Rebuild), each described in Section 3.2. The orange segment marks the planned future line relocation
connecting the community school to Mine Hill junction, currently in the planning stage(see Section 3.1).
Areas not marked in red are standard Tier 3 baseline(see Section 2.2).
This risk assessment is reviewed and updated annually with each WMP filing to reflect updated fire
history,vegetation conditions, and any changes to the Company's facilities.
Page 6

2.3 — Consideration of the Wildland-Urban Interface (WUI)
Section 1 reports that 100%of Atlanta Power's service territory falls within the Wildland-Urban
Interface. Given the Company's small footprint(3.0 square miles)and land cover dominated by evergreen
and mixed forest(85%), structures throughout the territory are intermixed with wildland vegetation rather
than simply bordering it. That matches the WUI Intermix pattern in national WUI mapping
methodologies(e.g.,the U.S. Forest Service SILVIS Lab classification),where development is
interspersed within wildland vegetation with no clear dividing line,unlike the WUI Interface pattern of a
development edge bordering a larger, contiguous block of wildland. Because the entire service territory is
uniformly WUI,that status alone doesn't further differentiate risk within the Company's tier approach in
Section 2.2: every foot of the system already reflects the elevated consequence of structures embedded in
wildland vegetation. Instead,the Company differentiates risk tiers using the factors in Section 2.2
(vegetation fuel load,historical fire occurrence,terrain and slope, sustained wind exposure, and structure
density), each of which varies across the territory even though WUI classification does not. The 100%
WUI figure comes from the Company's review of the ArcGIS WUI Viewer, a GIs mapping tool built on
the federal WUI dataset(U.S. Census housing density combined with USGS National Land Cover Data,
following the Federal Register definition of WUI). That tool shows the town of Atlanta and the
surrounding service territory entirely within a mapped WUI zone, confirming the Intermix
characterization above.
Section 3 — Preventative Actions and Programs
3.1 — Current Status of Preventative Actions and Programs
This section covers preventative-action and program activity currently underway or completed,before
turning to planned equipment upgrades (Section 3.2)and the Company's deficiency prioritization
standards(Section 3.3).
To date,the Company has completed three system hardening projects, addressing a combined 3,400 feet
of aging line (since replaced with a combined 4,000 feet of new line,reflecting the longer road-following
alignments used for the two relocation projects)with deficiencies matching the priority classifications in
Section 3.3: rotted poles,mechanical connectors, deteriorated wooden cross arms,and leaning poles. Two
projects relocated line segments out of forest canopy(in one case,out from over buildings)into road
right-of-way;the third rebuilt an aging segment in place within the forest right-of-way. These are the Pine
Street and Main Line into Town line replacement and relocation projects and the Mine Hill Rebuild, all
described in Section 3.2.
Beyond these three completed projects,the Company is planning a line extension connecting the
community school to Mine Hill junction. The existing 900-foot segment runs through meadow and forest
vegetation and shows rotted poles,mechanical connectors, and aging cross arms,the same deficiency
criteria from Section 3.3 found in the Company's completed relocation projects, and forms part of the
approximately 1 mile of system-wide aging infrastructure described in Section 6.1. This project will move
the line to the adjacent road right-of-way, following the realignment strategy in Section 3.2,replacing the
existing 900 feet with approximately 600 feet of new line. The Company anticipates beginning this
Page 7

project in approximately November 2026; the completion date has not yet been determined. Capital and
labor cost estimates are not yet available because the project is still in the early stage of planning.
3.2 —Additional System Hardening Equipment
Line Realignment Out of Forested Rights-of-Way: Several of the Company's existing distribution lines
were originally built on a direct, cross-country path through forested terrain,chosen at the time to
minimize span length and construction cost.Where feasible,the Company is now relocating these legacy
segments to follow existing road rights-of-way instead. This cuts the line's exposure to dense timber fuel
loads and overhanging or leaning trees, gives crews year-round vehicle access for inspection,
maintenance, and fire suppression, and shrinks the vegetation-management corridor that would otherwise
need to be maintained through forest canopy.
Completed Project—Pine Street Line Replacement and Relocation: The Company has completed
relocation of the Pine Street line segment,previously routed on a direct,roughly 700-foot alignment
through open meadow and forest canopy,with rotted poles,mechanical connectors, and deteriorated
wooden cross arms with wooden pins. It's now been replaced and relocated with approximately 1,100 feet
of new,upgraded powerline(new poles,new conductor, and pressed connectors)within the adjacent road
right-of-way. The segment is about 400 feet longer than before but moving it out of continuous meadow
and forest-canopy exposure and into the road right-of-way, combined with the equipment upgrades,
meaningfully cuts vegetation-contact ignition risk and improves year-round vehicle access for inspection,
maintenance, and fire suppression.
Completed Project—Main Line into Town: The Company has completed replacement of the Main Line
serving the town,previously routed on an approximately 1,700-foot alignment through forest canopy and
built directly over buildings,with rotted poles,mechanical connectors,and deteriorated wooden cross
arms with wooden pins. It's been replaced with approximately 1,900 feet of new,upgraded powerline
(new poles,new conductor,pressed connectors) along the road right-of-way, feeding the main
intersection of town. Moving this segment out of the forest canopy and away from directly over
structures, combined with the equipment upgrades,reduces vegetation-contact ignition risk,removes the
hazard of an energized line running directly above occupied buildings,and improves year-round vehicle
access for inspection,maintenance, and fire suppression.
Completed Project—Mine Hill Rebuild: Unlike the two relocation projects above,this one addresses an
aging segment that stays within the forest right-of-way rather than moving to a road right-of-way. The
Company completed replacement of an approximately 1,000-foot segment of aging powerline meeting the
Priority 1 deficiency criteria in Section 3.3. The segment was rebuilt in place with new poles,new
conductors, and pressed connectors,plus bi-directional guying at the poles on each end to improve
structural stability and reduce the risk of pole lean or failure.
Beyond line realignment,the Company's system hardening program includes replacing or installing the
following equipment,where routine inspection or aging asset management identifies it as a wildfire risk
mitigation measure:
• Polymer(non-ceramic)insulators,rated 12 kV, in place of porcelain insulators subject to
flashover or contamination-related failure
Page 8

• Current-limiting fuse upgrades to reduce fault energy and arc duration in heightened risk areas
• Pressed(compression)connectors in place of mechanicalfbolted connectors,reducing the risk of
loosening, arcing, and heating at conductor connection points
• Bi-directional guying at poles on either side of forest right of way,to improve structural stability
and reduce the risk of pole lean or failure
3.3 — Deficiency Classification and Prioritization
Deficiencies identified during inspection(see Section 8.1) are classified and corrected under the following
three-tier system, applied consistently across all infrastructure types:
PriorityDefinition Correction
Condition poses an imminent risk of ignition,
Priority 1 — electrocution, or other immediate public safety Corrected Immediately
Emergency hazard(e.g.,broken/downed conductor,broken
pole,tree through powerline)
Condition presents an elevated but non-imminent
Priority 2— risk(e.g., significant equipment wear, Corrected within 3 to 6 months
Priority encroaching vegetation not yet in contact with
conductor).
Condition does not present a near-term wildfire
Priority 3— or safety risk but should be corrected as part of Next scheduled maintenance
Routine normal maintenance(e.g.,minor hardware wear, cycle or within 12 to 18 months
routine wood pole treatment).
Deficiencies in Tier 1 or Tier 2 risk areas(Section 2.2)are corrected within the shorter end of the
applicable timeline above,reflecting the heightened consequence of ignition in those areas.
Section 4 — Public Outreach and Engagement
4.1 — General Communication Channels and Wildfire Outreach
Atlanta Power communicates with its customers through multiple channels.Wildfire mitigation has not
historically been a regular topic in that communication,but going forward the Company will fold wildfire
mitigation education and outreach into its ongoing customer communications,as described in this Plan.
• Direct contact
• Social media
• Phone services
• Bill inserts
The Company hasn't yet decided whether to hold a dedicated public comment period or meeting on this
WMP for customers, agencies,and other community organizations, and will consider this for future
updates. The Company will also share this Plan with the Idaho State Forester, fire protection districts, and
Page 9

fire protection associations within its service area, as described in the Notice of WMP Filing later in this
document.
4.2 — Customer Communication Regarding De-Energization
Because the Company has decided against proactive de-energization(PSPS) as a wildfire mitigation
strategy(see Section 3.2),this Plan doesn't include a dedicated de-energization customer communication
protocol. If the Company adopts proactive de-energization in a future WMP update,this subsection will
be revised to describe the customer notification protocol at that time.
Section 5 — Government Outreach
Atlanta Power maintains an ongoing working relationship with the Atlanta Fire District for emergency
response coordination and coordinates closely with the U.S. Forest Service on wildfire preparedness
matters affecting the Company's service territory. This includes daily information sharing between the
Atlanta Fire District and Atlanta Power, and joint training between the two organizations.
Section 6 — Method of Line Design
6.1 — General Line Design and Construction Standards
Outside the heightened wildfire risk areas addressed in Section 6.2,the Company's line design and
construction practices follow National Electrical Safety Code (NESC)minimum requirements together
with industry-standard practice for a system of this size and voltage class;the Company does not maintain
a separate internal engineering or design manual. The Company's distribution system runs at 2.4 kV(see
Section 1),and system-wide baseline construction typically uses Class 3 or 4 wood poles,#4 ACSR
conductor,and 8-foot wood or fiberglass cross arms with standard porcelain insulators, each meeting or
exceeding NESC minimum requirements as described in Section 6.2. These baseline standards are the
Company's"Standard Practice"referenced in Table 6-1 of Section 6.2, against which the enhanced
construction standards for heightened wildfire risk areas are compared. The Company is transitioning
from porcelain to polymer(non-ceramic)insulators,rated at 12 kV, system-wide,matching the equipment
upgrade described in Section 3.2.
Approximately 1 mile of the Company's system outside the completed projects in Section 3.2 is more
than 30 years old,and approximately 28%remains routed through forested areas. This aging
infrastructure shows the same kind of conditions corrected in the Pine Street,Main Line into Town, and
Mine Hill Rebuild projects: rotted or weathered poles,mechanical(bolted) conductor connectors,
deteriorated wooden cross arms secured with wooden pins,and,in some locations, leaning poles. About
16%of the system currently meets the Company's replacement criteria in Section 3.3. The Company
identifies and addresses these conditions through the deficiency classification and prioritization process in
Section 3.3, and it expects to continue identifying and correcting additional segments through the system
hardening program in Section 3.2 as resources allow.
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6.2 — Construction Standards for Heightened Risk Areas
New construction,rebuilds, and planned upgrades within the Company's service territory are designed
and built to the NESC,2023 Edition, along with the construction, clearance, and vegetation requirements
under the Company's U.S.Forest Service special use permit(s)for rights-of-way on National Forest
lands.
Under the permit's"Applicable Reliability and Safety Standards"provision,the Company's facilities are
subject to the NESC and standards issued by the Occupational Safety and Health Administration(OSHA).
Section 8.1 covers NESC construction standards,and Company personnel follow applicable OSHA
standards for electric power generation,transmission, and distribution work(29 CFR Part 1910.269).
Table 6-1
Component Standard Practice Heightened Risk Area Practice
Pole Type Class 3 or 4 wood pole Full-treat poles used to replace all poles within
heightened risk areas
Conductor #4 ACSR conductor 12 kV-rated insulators with increased conductor
spacing
Cross Arms Wood or fiberglass, 8 ft Fiberglass cross arms,utilized in heavily wooded areas
where access may be a challenge—see Section 3.2
Hardware/Insulators Porcelain Polymer/non-ceramic, 12 kV—see Section III.B
F
Section 7 — Situational Awareness and Monitoring
7.1 — Weather and Fire Danger Monitoring Systems
The Atlanta Fire District handles weather and fire danger monitoring for the Company's service territory,
and the Company relies on it to track forecasts, current weather conditions, and fire danger. This matches
the daily information-sharing relationship between the Atlanta Fire District and Atlanta Power described
in Section 5. The Fire District's monitoring tools include NOAA weather data,the Watch Duty wildfire
tracking app, and resources from the Western Fire Chiefs Association.
7.2 — Integration into Operations
One of the Company's owners' reviews weather and fire-danger information from the Atlanta Fire
District daily during fire season.When that review shows elevated wildfire risk,the Company responds
with a weekly visual inspection of its system,matching the enhanced monitoring practices in Section 7.3.
Because Atlanta Power's service territory is a small, standalone system with no other utility operating
nearby,the Company doesn't currently need to monitor for de-energization events from other entities.
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7.3 — Enhanced Monitoring Frequency During Heightened Risk
Table 7-1 below defines,numerically,what counts as"increased"or"enhanced"monitoring and
inspection frequency in both Section 6.3 (fire season) and Section 7.3 (operational practices during
heightened risk), covering both in one place.
Table 7-1
Activity Baseline Routine Enhanced(Fire Season Tier I-
2 Areas)
Weather/fire-danger monitoring Weekly Daily during fire season(see
Section 7.2)
Line patrol/visual inspection Monthly Weekly during periods of elevated
wildfire risk(see Section 7.2)
Not applicable—given the size of
the Company's system,a separate
Detailed Pole Inspections Annually enhanced Detailed Pole Inspection
cycle for heightened risk areas is
not maintained beyond the annual
baseline cycle
Fire weather index/outlook review Same as"Weather/fire-danger Same as"Weather/fire-danger
monitoring"row above monitoring"row above
None currently in place—the
Workforce operating restrictions Standard operating procedures Company does not have formal
operating restrictions specific to
high-risk days currently
Section 8 — Infrastructure Inspections, De-Energization, and Vegetation
Management
8.1 —Applicable Inspection and Vegetation Management Standards
Infrastructure inspections follow the National Electrical Safety Code(NESC),2023 Edition.Vegetation
management activities in Section 8.3 follow ANSI A300 Parts 1 (Pruning)and 7(Integrated Vegetation
Management),most current edition.No additional inspection or construction standards apply.
Beyond the standards above,vegetation management within the Company's U.S.Forest Service special
use permit area(see Section 6.2)is governed by that permit's Operating Plan(Section 7,Vegetation
Management). Following the Operating Plan,the Company's vegetation management program aims to(1)
maintain reliability, address public safety,and eliminate the risk of vegetation-caused outages; (2)
minimize the spread of invasive plant species within the permit area; (3)maintain and enhance vegetation
conditions for fish,wildlife,plant,water, and soil resources; and(4) encourage low-growing vegetation
where feasible.
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Best management practices under the Operating Plan include compliance with Forest Service National
Core BMPs(per the Forest Service's BMP Technical Guide), applicable standards and guidelines in the
governing national forest land management plan,and NESC clearance factors under NESC Section 218:
line voltage class, species growth rates,vegetation location relative to conductors,and potential conductor
sag or movement. The Operating Plan also requires Integrated Vegetation Management(IVM)under
ANSI A300,Part 7,matching the citation above; IVM aims to convert right-of-way vegetation to low-
growing,non-invasive plant communities.
Under the Operating Plan's routine vegetation management provisions,the Company may control
vegetation within approximately 30 feet(9 meters) of powerline facilities in the permit area, or a larger
perimeter where reliability,electrical, or safety standards require it,with prior written notice to and
approval from the Forest Service. In practice,the Company's actual clearance perimeter,described in
Section 8.3,is 15 feet,narrower than and within the 30-foot maximum the Operating Plan allows. The
Company also follows the Operating Plan's emergency vegetation management provisions,notifying the
Forest Service within 24 hours of starting an emergency response and filing a written report within 30
days of completion.
8.2 — De-Energization: Scope, Standards, and Restoration Protocol
The Company evaluated proactive de-energization(Public Safety Power Shutoff,or PSPS)as a wildfire
mitigation strategy and decided not to adopt it in this Plan. Given the small size and limited customer
count of the service territory, along with the operational and reliability tradeoffs of proactive shutoffs
compared with the system hardening and vegetation management measures already underway elsewhere
in this Plan,the Company concluded those measures offer a more effective approach to wildfire risk
reduction for its system right now.
This decision doesn't affect the Company's existing automatic protective equipment,which will de-
energize a line automatically when it detects a fault condition,as a standard part of the Company's
overcurrent protection plan and normal utility practice. That automatic function isn't a discretionary
wildfire mitigation tool and operates independently of this decision. After any such automatic protective
operation, Company personnel visually inspect the entire system before re-energizing to confirm there's
no downed conductor,vegetation contact, or other hazard, and that no fire has ignited. The Company will
keep evaluating whether proactive de-energization makes sense to adopt in a future WMP update as
conditions,technology, or system configuration change.
8.3 — Heightened Fire Risk Area Vegetation Management and Risk Tree Program
Within the Company's designated 1.5-mile Heightened Fire Risk Area described in Section 2.2,
vegetation management follows an enhanced cycle relative to the Company's routine, system-wide
vegetation management program:
• Enhanced clearance cycle: Annual trimming happens March through April within the Heightened
Fire Risk Area,timed ahead of fire season, clearing vegetation to about 15 feet from powerline
facilities,matching the clearance perimeter in Section 8.1. The Company's routine, system-wide
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vegetation management cycle is also annual,but isn't tied to a specific season and is less
intensive. The Heightened Fire Risk Area cycle is enhanced in two ways: (1)timing, since
clearing is deliberately scheduled for March through April rather than any time during the year;
and(2) scope and intensity, since trimming within the Heightened Fire Risk Area is more
thorough than the routine cycle,matching the area's elevated risk classification.
• Supplemental as-needed trimming: Vegetation conditions identified during any inspection
(routine or enhanced)within the Heightened Fire Risk Area are addressed within 30 to 60 days
regardless of the annual cycle.
Risk trees—trees identified as dead, dying,diseased,or structurally compromised such that they pose a
risk of falling into Company facilities—are classified and addressed as follows:
• Imminent Hazard: Tree presents an immediate risk of falling into energized facilities. After
identification,the Company contacts the customer and plans removal.
• Elevated Risk: Tree presents a risk of falling into facilities but is not imminent—scheduled for
removal within 60-90 days.
The Company considers vegetation management recommendations from the U.S.Forest Service in
developing and updating these standards. The Company follows the Operating Plan's general
requirements(see Section 8.1)without additional case-specific input beyond those requirements.
Measurable Targets: The Company's measurable vegetation management targets for the WMP term are
currently under development, and a timeline for establishing them has not yet been determined.
Section 9 — WMP Expenditures and Cost-Benefit Analysis
9.1 — Three-Year Expenditures Summary
This section provides a full cost breakdown by year for both capital and O&M expenditures, covering the
required minimum three-year rolling planning horizon.
Table 9-3 in Section 9.2 sets out the Company's planned wildfire mitigation expenditures by year 2026
through 2029, covering the required three-year rolling planning horizon.
9.2 — Cost-Benefit Analysis
Atlanta Power weighs each project's total cost, capital and labor,against its expected wildfire risk
reduction,using the same method for every project.Where the benefit can be measured, such as
conductor removed from forest-canopy exposure or Priority 1 deficiencies corrected,the Company
reports that figure.Where it cannot,the Company describes the risk reduction in narrative form.
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The costs in Table 9-1 include labor and materials, shown separately so that the full cost of each project is
visible.
Table 9-1
'roject/Segment Units Capital Labor Cost Total Cost Risk Reduction
(miles) Cost
Pine Street line Removed line from
replacement and 0.21 mi continuous meadow/forest-
relocation(Section 3.2) (1,100 ft) $10,285.00 $8,415.00 $18,700.00 canopy exposure into road
—completed ROW; reduces vegetation-
contact ignition risk
Removed line from forest-
Main Line Into Town canopy exposure and over top
replacement and 0.36 mi $15,675.00 $12 825.00 $28 500.00 of buildings into road ROW;
relocation(Section 3.2) (1,900 ft) reduces vegetation-contact
—completed and structure-overbuild
ignition risk
Replaced leaning poles and
mechanical connectors with
Mine Hill Rebuild 0.19 mi new poles, conductor,pressed
(Section 3.2)— 000 ft) $7,650.00 $9,350.00 $17,000.00 connectors, and bi-directional
completed (1, guying; addresses Priority 1
deficiency criteria
(Section 3.3)
Beyond the project-specific analysis, Table 9-2 rates each program on cost and wildfire-mitigation
impact. Ratings are relative to the Company's scale of operations: "High" cost means a program that
represents a major share of the Company's annual mitigation spending, and"High" impact means a
program that directly reduces the likelihood of a utility-caused ignition in the Heightened Fire Risk Area.
Table 9-2
Program
Line realignment out of forested ROW High High
Pole replacement(system hardening) High Medium
Non-wooden cross arms&hardware upgrades Medium Medium
Infrastructure inspections Medium Medium
Vegetation management High High
Public&government outreach Low Low
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Table 9-3 shows the Company's planned wildfire mitigation expenditures over the four-year period 2026
through 2029. Spending is front-loaded toward system hardening in 2026 and 2027 to complete the Mine
Hill Rebuild and the Main Street Extension, after which the Company shifts to a steady annual program
of aging pole and hardware replacement. Vegetation management and replacement budgets increase
approximately 10 percent per year to reflect anticipated growth in material and labor costs.
Table 9-3
Vegetation Tree Trimming& $2,700.00 $2,970.00 $3,267.00
Management Tree Removal
Mine Hill Rebuild
System Hardening (Completed) $8,500.00
Main Street
System Hardening Extension $4,883.00 $4,883.00 $7,682.89
Aging Pole&
System Hardening Hardware —(a) $6,349.50 $6,984.45
Replacements
(a)In 2026, the Company's replacement effort was directed to the Mine Hill Rebuild and Main Street Extension
projects rather than to a separate replacement program.
This expenditure profile reflects the balance required by I.C. § 61-1803(3)and the feasibility and cost
considerations of I.C. § 61-1804. The two programs rated"High" impact in Table 9-2, line realignment
and vegetation management,receive the largest share of planned spending,while lower-impact activities
are funded at levels proportional to their benefit. The Company funds all mitigation work from its
operating revenue and owner contributions and does not anticipate that this level of spending will require
a rate increase for its customers.
Page 16

ATLANTA
POWER
Attachment 1
Template Notice
August 27,2026
Via Email or Certified Mail
Subject: Notice of Filing—Atlanta Power Wildfire Mitigation Plan
Dear
In accordance with Idaho Code 61-1804(2),Atlanta Power Company hereby notifies you that on
August 27,2026,Atlanta Power filed its Wildfire Mitigation Plan with the Idaho Public Utilities
Commission for initial review. The Plan outlines Atlanta Power's operational plan to reduce wildfire risks
associated with electrical infrastructure and vegetation management.
How to Participate:
Atlanta Power's Plan has been filed with the Commission. Copies of the filing are available for public
inspection during regular business hours at the Commission's office located at 11331 W. Chinden Blvd.
Building 8, Suite 201-A,Boise,ID 83714, or the Commission's website at https://puc.idaho.gov/. Click
the "ELECTRIC" icon, select"Open Cases," and click Case No. ATL-E-26-01.
Interested parties may also subscribe to the Commission's RSS feed to receive periodic email updates
about the case. Written comments regarding Atlanta Power's filing can be filed with the Commission;
comments must be filed through the Commission's website or by email. To comment electronically,visit
www.pub.idaho.gov and click on the "Case Comment Form" link on the upper left side of the page.
Please use the case number when filling out the form. To comment using email,please send comments to
the email addresses listed below and include the case number. Comments are required to include the
commenter's name and address.
For the Idaho Public Utilities Commission:
Commission Secretary If sending express mail:
Idaho Public Utilities Commission 11331 W. Chinden Blvd. Building 8, Suite 201A
P. O. Box 83720,Boise,ID 83720-0074 Boise, ID 83714
[e-mail]
Respectfully,
Nicholas Jones
Owner/Operator
[phone]
Page 17

Attachment 2
ATLANTA POWER COMPANY
Wildfire Mitigation Plan
Compliance Crosswalk—Idaho Code§ 61-1803(3)
Requirement Atlanta Power WMP WMP SectionSection Summary
Section
1. C. § 61-1803(3)(a) Section 2 Section 2.1: General Description of Service •Service territory location(3.0 sq mi,surrounded by Boise
Geographical Risk Assessment Territory and Risk Factors National Forest)
Section 2.2:Risk Tier Methodology and •Four-tier risk classification system(Tier 1-Extreme,Tier
Map 2-Elevated,Tier 3-Moderate,Tier 4-not applicable)
Section 2.3:Wildland-Urban Interface •Identification of 1.5-mile Heightened Fire Risk Area
(WUI)Consideration (Tier 1 in fire season,Tier 2 otherwise)
Figure 2-1:Risk Map • 100%WUI classification and terrain analysis
•Color-coded risk map identifying line segments by tier
and completed/planned projects
1. C. § 61-1803(3)(b) Section 3 Section 3.1: Current Status of Preventative •Three completed line relocation/replacement projects
Preventative Actions&Programs Actions and Programs (Pine Street Project,Main Line into Town,Mine Hill
Section 3.2:Additional System Hardening Rebuild)
Equipment •One planned project: school-to-Mine-Hill line extension
Section 3.3:Deficiency Classification and •Line realignment strategy moving lines from forested
Prioritization terrain to road right-of-way
•System-wide vegetation management program
•Deficiency prioritization framework(rotted poles,
mechanical connectors,deteriorated crossarms,leaning
poles)
Page 18

Requirement Atlanta Power WNIP WNIP SectionSection
Section
I. C.§ 61-1803(3)(c) Section 4 Section 4.1: General Communication •Communication channels: direct contact,social media,
Public Outreach and Engagement: Channels and Wildfire Outreach phone,bill inserts
Section 4.2: Customer Communication •Wildfire mitigation education to be folded into ongoing
Regarding De-Energization customer communications
•Plan shared with State Forester,Atlanta Rural Fire
District,Elmore County Board of Commissioners and
courtesy notice to USDA Forest Service,Boise National
Forest
•No PSPS customer protocol;Section 4.2 to be revised if
PSPS is adopted in a future update
I.C. § 61-1803(3)(d) Section 5 Government Outreach •U.S.Forest Service coordination
Government Outreach •Atlanta Fire District partnership for wildfire preparedness
and emergency response
•Daily information sharing and joint training with the
Atlanta Rural Fire District
I. C. § 61-1803(3)(e) Section 6 Section 6.1: General Line Design and •Road-aligned line placement strategy(relocating legacy
Method of Line Design Construction Standards cross-country forested paths to road right-of-way)
Section 6.2: Construction Standards for •New construction standards for poles,conductors,and
Heightened Risk Areas hardware
Section 3: Preventative Actions(practical •Enhanced construction standards for heightened fire risk
implementation) areas
•Deficiency-based replacement prioritization
•Practical implementation through ongoing line relocation
and replacement projects
Page 19

Requirement Atlanta Power WNIP WNIP SectionSection
Section
I.C. § 61-1803(3)(f) Section 7 Section 7.1:Weather and Fire Danger •Weather data sources(fire danger indices,forecasts,
Situational Awareness and Monitoring Systems alerts)
Monitoring Section 7.2:Integration into Operations •Real-time fire risk assessment systems
Section 7.3:Enhanced Monitoring •Integration into operational decision-making
Frequency During Heightened Risk •Escalation protocols during fire season and Red Flag
conditions
•Enhanced monitoring frequency in heightened risk areas
during fire season
I. C. § 61- Section 8 Section 8.1:Applicable Inspection and •Inspections per NESC 2023;enhanced inspection
1803(3)(g)(i)—(iii) Infrastructure Inspections,De- Vegetation Management Standards frequency in the 1.5-mile Heightened Fire Risk Area
Energization,and Vegetation Section 8.2:De-Energization: Scope, defined in Table 7-1
Management Standards,and Restoration Protocol •Proactive de-energization(PSPS)evaluated and not
Section 8.3:Heightened Fire Risk Area, adopted;automatic protective de-energization on fault
Vegetation Management and Risk Tree retained,with post-event inspection before restoration
Program •Vegetation management per ANSI A300 and USFS
Section 3:Preventative Actions and special use permit Operating Plan;—15-foot clearance
Programs •Heightened Fire Risk Area: annual March April trimming
ahead of fire season;as-needed trimming within 30-60 days
•Risk tree program(Imminent Hazard/Elevated Risk
classification,60-90 day removal)
I.C. § 61-1803(3) Section 9 Section 9.1:Three-Year Expenditures •Three-year investment summary for line relocation,
I.C. § 61-1804 WMP Expenditures and Cost- Summary infrastructure replacement,and vegetation management
Benefit Analysis Section 9.2: Cost-Benefit Analysis •Ratio of expenditures to wildfire risk reduction
Scaling costs to Company size and operational complexity
•Financing plan and rate impact analysis
Page 20