APPLICATION

CERTIFICATE OF ATTORNEY

ASSERTION THAT INFORMATION CONTAINED IN AN IDAHO PUBLIC UTILITIES
COMMISSION FILING IS PROTECTED FROM PUBLIC INSPECTION

Idaho Power Company’s 2027 Wildfire Mitigation Plan

Case No. IPC-E-26-28

The undersigned attorney, in accordance with Commission Rules of Procedure 67,
believes that Appendix H of Attachment No. 1 to Idaho Power Company’s Application,
dated October 1, 2026, contains information that Idaho Power and/or a third party claim
constitutes trade secrets or other confidential business data exempt from disclosure
under Idaho Code § 74-101, et seq., and/or § 48-801, et seq. As such, it is protected from
public disclosure, inspection, examination, or copying.

DATED this 1st day of October 2026.

Megan Goicoechea Allen
Counsel for Idaho Power Company

APPLICATION - 1
MEGAN GOICOECHEA ALLEN (ISB No. 7623)
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: (208) 388- 6936
[e-mail]

Attorney for Idaho Power Company

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF IDAHO POWER
COMPANY’S 2027 WILDFIRE
MITIGATION PLAN
)
)
)
)
)

CASE NO. IPC-E-26-28

APPLICATION

COMES NOW, Idaho Power Company (“Idaho Power” or “Company”), and in
accordance with Idaho Public Utilities Commission (“Commission” or “IPUC”) Rule of
Procedure1 52 and Order Nos. 367742 and 37004,3 respectfully submits its 2027 Wildfire
Mitigation Plan (“WMP”), included as Attachment 1, and requests the Commission issue
an order approving such plan. Idaho Power’s 2027 WMP is being filed for approval
pursuant to the Wildfire Standard of Care Act (“WSCA”), Idaho Code § 61-1801 et seq,
and in accordance with the WMP Filing Schedule4 and the WMP Guidelines5 adopted by

1 Idaho Administrative Procedures Act (IDAPA) 31.01.01.
2 In the Matter of Commission Staff’s Application for Approval of a Filing Process for Wildfire Mitigation
Plans, Case No. GNR-E-25-02, Order No. 36774 (Sep. 30, 2025).
3 In the Matter of Idaho Power Company’s 2026 Wildfire Mitigation Plan, Case No. IPC-E-25-32, Order
No. 37004 (Apr. 14, 2026).
4 Case No. GNR-E-25-02, Exhibit A to Order No. 36774.
5 Case No. GNR-E-25-02, Exhibit B to Order No. 36774.
APPLICATION - 2
the Commission in Case No. GNR-E-25-02.6
In support of this Application, Idaho Power states the following:
I. INTRODUCTION
1. In recent years, the Western United States (“U.S.”) has experienced an
increase in the frequency and intensity of wildland fires (“wildfires”). A variety of factors
have contributed to this trend, including changing climatic conditions, increased human
encroachment in wildland areas, historical land management practices, and changes in
wildland and forest health.
2. While Idaho has not experienced wildfires of the same magnitude as some
other western states,7 warmer temperatures, reduced snowpack, and earlier snowmelt
contribute to drier conditions, impacting the period of heightened wildfire risk.8
3. Idaho Power is focused on the safety of its customers and communities and
the reliable, affordable delivery of energy. The purpose of Idaho Power’s WMP is to guide
mitigation strategies and reduce risk. Over the past six years under its WMPs, Idaho
Power has worked to reduce wildfire risk through practices such as, but not limited to,
hardening its electrical system, expanding situational awareness capabilities, and
enhancing operational practices and vegetation management programs.
4. This Application is submitted in accordance with Idaho Code § 61-
1803(2)(a) and is premised on the Company’s continued efforts to reduce wildfire risk for
the safety of Idaho Power’s customers, the continued and reliable delivery of electricity to

6 The WMP Filing Schedule provides that Idaho Power’s WMP shall be filed no earlier than October 1st,
with updated WMPs filed annually, one year after filing the previously approved WMP. Although Idaho
Power’s approved 2026 WMP was filed on October 10, 2025, the Commission affirmed through Order No.
37004 that the Company may file its updated WMP with the Commission on or about October 1st of each
year going forward.
7 Wildland Fire Summaries 2019-2025. https://www.nifc.gov/fire-information/statistics
8 Western Fire Chiefs Association. Idaho Fire Season: In-Depth Guide | WFCA
APPLICATION - 3
approximately 640,000 retail customers in Idaho, and good stewardship of the beautiful
and natural lands within Idaho Power’s service area and beyond. Accordingly, the
mitigation measures outlined in the Company’s 2027 WMP are also intended to reduce
potential risk associated with the Company’s infrastructure or equipment, such as its
operation of approximately 3,715 miles of overhead transmission lines and 17,199 miles
of overhead distribution lines within the state of Idaho.9 These overhead assets represent
about 80 percent of Idaho Power’s total overhead transmission line assets and roughly
89 percent of its total overhead distribution line assets.
5. The 2027 WMP is built around a geographical risk assessment, which
utilizes a risk-informed approach that considers wildfire probability and consequence to
identify zones that may be subject to potential heightened wildfire risk in areas where
Idaho Power has infrastructure or equipment. Additionally, the Company employs a risk-
informed cost and benefit balancing approach to select and prioritize the wildfire
mitigations identified in the 2027 WMP.
6. As more thoroughly discussed below, the Company’s 2027 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, complying with the
requirements of Idaho Code § 61-1803(3) and the IPUC WMP Guidelines approved by
the Commission in Order No. 3677410 issued in GNR-E-25-02 on September 30, 2025.
The Company’s 2027 WMP also complies with the other directives pertaining to its WMP

9 While the Company’s 2027 WMP also encompasses assets and activities within the State of Montana,
because this Application is before the IPUC for approval specific to Idaho Power’s operations in Idaho, all
discussion in this Application is confined to operations and activities occurring within Idaho.
10 Case No. GNR-E-25-02, Exhibit B to Order No. 36774.
APPLICATION - 4
issued in various Commission orders, including those contained in Order No. 37004,11
which approved the Company’s 2026 WMP.
II. IDAHO POWER’S 2027 WILDFIRE MITIGATION PLAN
7. To assist the Commission’s review of its 2027 WMP, the Company provides
the following high-level overview of the 2027 WMP’s conformity with the various
statutory and regulatory requirements and recommendations, including identifying
where content specific to the various statutory and regulatory requirements and
recommendations can be found.12 The Company is providing this information for ease
of reference and it should not be considered exhaustive. In the event of any conflict or
inconsistency between this Application and the 2027 WMP, the latter shall govern.
A. Compliance with WSCA Requirements and IPUC WMP Guidelines.

(1) WMP Element – Cost-Benefit Approach

Idaho Code § 61-1803(3) IPUC WMP Guidelines
(Order No. 36774)
Corresponding Location
in WMP
Each wildfire mitigation plan
shall be developed using
approaches and methods that
are designed to protect the
public interest and are reflective
of and commensurate with the
size and complexity of the
electric corporation's operations
and of the nature of the fire risk.
At a minimum, each wildfire
mitigation plan shall identify a
means for mitigating wildfire risk
that reflect a reasonable
balancing of mitigation costs
with the resulting reduction of
wildfire risk, including the
elements outlined below.

WMPs must include a cost-benefit
analysis that justifies the
expenditures for risk mitigation
described within.

Section 1. Introduction
Section 2. Geographical
Risk Assessment
Section 3. Cost-Benefit
Approach
Section 4. Situational
Awareness and Monitoring
Section 5. Mitigation Activity:
Workforce Preparedness
Section 6. Mitigation Activity:
Line Operation Practices
Section 7. Infrastructure
Inspection and Asset
Management
Section 8. Methods of Line
Design

11 Case No, IPC-E-25-32.
12 See also Appendix D to the Company’s 2027 WMP, which further details the various statutory and
regulatory requirements and recommendations pertaining to Idaho Power’s WMP, including those that
have been directed through IPUC Orders, and delineates the 2027 WMP’s compliance with those
requirements.
APPLICATION - 5
Section 9. Vegetation
Management
Section 10. Additional
Preventative Actions and
Programs
Section 11. Public Outreach
and Engagement
Section 12. Government,
Industry, and Peer Utility
Outreach
Section 13. Performance
Monitoring
Section 14. WMP Cost
Summary
Appendix A: Wildland Fire
Preparedness and
Prevention Plan
Appendix B: Wildfire Public
Safety Power Shutoff Plan
Appendix F: Wildfire
Mitigation Activities and Cost
Forecast 2027-2029
Appendix G: Grid Hardening
List

8. The Company’s approach to mitigating wildfire risk is designed to protect
the public interest, reflect the size and complexity of Idaho Power’s operations, and
consider the specific wildfire risks present within the areas in Idaho where the Company
has infrastructure or equipment. Idaho Power’s risk-based cost and benefit approach to
selecting wildfire mitigations is designed to reasonably balance the costs of mitigation
activities with the resulting reduction in wildfire risk. This starts with understanding the
potential costs of wildfires, assessing drivers of potential wildfire risk and, finally, using a
variety of strategies to select cost-effective mitigations to reduce wildfire risk.
9. Potential Costs. In assessing the potential consequence of wildfire risk,
Idaho Power considered several sources of data on the costs of major wildfires, though
ultimately determined that obtaining a precise calculation of the potential costs of future
wildfires is not feasible; precise quantification of potential wildfire costs is inherently
APPLICATION - 6
uncertain due to the variability in factors such as jurisdictional differences, weather, fuel
conditions, topography, location, population density, and exposure. Litigation outcomes
and community impacts can also differ widely from event to event. Additionally, while fire
suppression costs can be roughly estimated on a per-acre basis, the actual cost of fire
suppression can vary greatly depending on a similar variety of factors. Nonetheless,
publicly available analyses of recent wildfires illustrate the magnitude of potential avoided
costs when prudent mitigation reduces the likelihood or consequences of catastrophic
events.
10. Risk Analysis and Drivers. The next step in the Company’s selection of
cost-effective mitigations is to understand potential wildfire risk drivers. Idaho Power’s
WMP risk management evaluation provides the Company with a structured approach to
wildfire mitigation planning by enabling systematic identification, assessment, and
management of wildfire risk. While not all risk can be eliminated, Idaho Power’s goal with
its 2027 WMP is to proactively prepare and enhance its infrastructure and operational
practices to prepare for and address wildfire risk.
11. Using its WMP risk management evaluation, Idaho Power gathered
information from internal subject-matter experts regarding potential ignition risk drivers
and developed the below risk bow-tie diagram as a visual representation of equipment-
specific wildfire ignition risks, including key drivers, scenarios, likelihood, and potential
impacts.

APPLICATION - 7
Figure 1
Risk bow-tie diagram

12. Mitigation Selection. Idaho Power’s mitigation selection is informed by its
risk driver identification and its identification of wildfire risk zones. This approach allows
Idaho Power to direct its mitigations toward the geographic areas and infrastructure that
may be subject to heightened wildfire risk and to employ mitigations that are most likely
to achieve a reduction in wildfire risk. Each type of mitigation employed by Idaho Power
is designed to reduce one or more of the risk driver frequencies and/or minimize the
potential impacts or outcomes. In addition, while mitigations are primarily intended to
reduce the risk of wildfire, co-benefits, such as increased safety, reliability, and resiliency
of the system may also be achieved.
13. Idaho Power’s approach to selecting mitigations for wildfire risk
encompasses a variety of factors and considers various strategies to identify mitigations
that reflect a reasonable balancing of mitigation costs with the resulting reduction of
APPLICATION - 8
wildfire risk, as presented in the 2027 WMP. Specific to infrastructure projects described
in Section 8 of the 2027 WMP, and consistent with IPUC Order No. 37004, Idaho Power
began developing a Risk-Informed Mitigation Evaluation Framework (“Framework”) in
2026 to support the planning-level evaluation of both costs and benefits associated with
these infrastructure projects primarily driven by wildfire risk reduction. The Framework is
intended to reflect a per-project cost-benefit analysis demonstrating that each project
reasonably balances costs with reductions in wildfire risk and other project benefits to
Idaho Power and its customers. Included as Attachment 213 to this Application is a table
summarizing the Company’s implementation of the Framework with respect to grid
hardening projects planned to be undertaken in 2027 as part of Idaho Power’s wildfire
mitigation strategy.14 Of note, the Framework intends to supplement existing Idaho Power
project assessment processes; it does not replace those processes or establish a single
determinant for project selection.
(2) WMP Element - Geographical Risk Assessments

Idaho Code § 61-1803(3)(a) IPUC WMP Guidelines
(Order No. 36774)
Corresponding Location
in WMP
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.
Section 2. Geographical
Risk Assessment
Appendix C: Wildfire Risk
Zone Map Book

13 Idaho Power’s goal is to complete 100 percent of the work identified in this attachment; however,
emergencies, operational issues, access issues, permitting delays or other unplanned events can occur
and disrupt the planned work. All work is completed in accordance with safety and applicable
requirements. Inclusion of a project in this attachment reflects Idaho Power’s good faith representation of
its construction plans for 2027; it is not a guarantee that a project will be constructed exactly as described
or even at all.
14 Consistent with IPUC Order No. 37004, Idaho Power intends to continue maturing its project-specific
cost-benefit analysis in 2027 based on learnings obtained from the implementation of the Framework, as
well as other sources of data and information.
APPLICATION - 9

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.

14. Idaho Power’s approach to mitigating wildfire risk starts by assessing
wildland fire risk using qualitative and quantitative strategies to identify geographic areas
where Idaho Power has infrastructure or equipment that the Company considers may be
subject to a heightened risk of wildfire (referred to as wildfire risk zones). To accomplish
this, Idaho Power works with external consultants that specialize in assessing and
quantifying the threat of wildfire in different geographic areas using a risk-based
methodology for wildfire spread modeling.
15. Idaho Power’s understanding of wildfire risk is consistent with conventional
definitions of risk – an event’s probability is multiplied by its potential negative
consequences or impacts should that event occur. This formula is shown in Figure 2.
Figure 2
Wildfire risk-based methodology

APPLICATION - 10
The components of the formula shown in Figure 2 are defined as follows:
 Wildfire Probability. Wildfire probability evaluates whether the landscape is
conducive to ignition and spread (i.e., whether the landscape can support an ignition).
For purposes of Idaho Power's wildfire risk assessment, modeled wildfire volume (i.e.,
spatial integral of wildfire area and flame length) serves as a proxy measure for wildfire
probability and potential growth. Data inputs used in the fire spread model to
determine the wildfire volume include historical weather, historical wildfire occurrence,
topography, fuel type, and fuel moisture content.
 Consequence. Estimation of potential wildfire impacts under fire spread simulations
to specific resources (natural) and assets (human-made), such as residences,
population, and acreage.
 Wildfire Risk. Wildfire risk is wildfire probability multiplied by the consequence. The
highest wildfire risk areas are those where both the wildfire probability and
consequence are elevated. Combinations of low wildfire probability and elevated
consequence, or elevated wildfire probability and low consequence, typically indicate
lower wildfire risk.

16. As more fully discussed in Section 2.2 of the 2027 WMP, beginning in 2026,
Idaho Power began the transition process of updating its identification of geographical
areas of heightened wildfire risk from those identified using a prior geospatial wildfire risk
model to those identified using a new geospatial wildfire risk model — Technosylva. This
transition maintains consistency with the company’s overall wildfire risk framework while
using the data and analytics available through Technosylva. Idaho Power intends this
transition to be iterative. Thus, for 2027, Idaho Power has maintained its existing
geographic identifications of areas of heightened wildfire risk (its existing wildfire risk
zones) and added certain additional areas of identified heightened wildfire risk.
17. Based on Idaho Power’s modeling and assessment process, the Company
has identified wildfire risk zones that may be subject to heightened wildfire risk: Tier 3 and
Tier 2 zones. Relative to Tier 2 zones, Tier 3 zones are generally assessed as having
greater possible wildfire risk. To aid in customer and public understanding, Idaho Power
color-codes these tiers on maps – yellow for Tier 2 and red for Tier 3. Of note, Idaho
APPLICATION - 11
Power’s wildfire risk zones reflect risk relative to the areas modeled by Idaho Power only
and not absolute geographic/landscape risk.
18. Idaho Power intends to utilize the data and analytics available through
Technosylva to continue refining its identification of geographic areas of heightened
wildfire risk in areas where it has assets and equipment, which may result in changes to
Idaho Power’s wildfire risk zones in the future. A full and up-to-date risk zone map can
be viewed in detail on Idaho Power’s website, and individual addresses can be entered
on the map to determine proximity to identified risk zones.15
(3) WMP Element - Preventative Actions and Programs

Idaho Code § 61-
1803(3)(b)
IPUC WMP Guidelines
(Order No. 36774)
Corresponding Location
in WMP
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 it will carry
out to reduce the risk of wildfire, in addition to
actions and programs specified in statute and by
the IPUC. For the three large investor-owned
utilities, Staff recommends that previous areas of
focus of each utility’s WMPs continue to be
included. A WMP's preventative actions and
programs must include, but is not limited to, the
following:

Situational Awareness Efforts
 May include use of technology to aid in
weather monitoring; wildfire season outlook;
daily, weekly, and monthly weather and fire
modeling risk, etc.
 Consistent with 61-1803(3)(f) and the IPUC
WMP Guidelines.

Asset Inspections
 Must include the frequency and standards of
inspections for each type of electric
infrastructure within areas of elevated wildfire
risk.
 Consistent with 61-1803(3)(g)(i) and the
IPUC WMP Guidelines.

Enhanced Vegetation Management Practices in
Risk Zones
 May include shorter vegetation management
Section 4. Situational
Awareness and
Monitoring
Section 5. Mitigation
Activity: Workforce
Preparedness
Section 6. Mitigation
Activity: Line Operation
Practices
Section 7. Infrastructure
Inspection and Asset
Management
Section 8. Methods of
Line Design
Section 9. Vegetation
Management
Section 10. Additional
Preventative Actions and
Programs
Section 11. Public
Outreach and
Engagement
Section 14. WMP Cost
Summary
Appendix A: Wildland
Fire Preparedness and
Prevention Plan

15 Protecting the Grid-Wildfire Risk Zones, idahopower.com/outages-safety/wildfire-safety/protecting-grid/.
APPLICATION - 12
cycles than routine cycles, risk tree
programs, etc.
 Consistent with 61-1803(3)(g)(iii) and the
IPUC WMP Guidelines.

Operation Practices during Heightened Wildfire
Risk Days or Zones
 May include restrictions to workforce
practices, potential use of proactive de-
energization.
 Consistent with 61-1803(3)(g)(ii) and the
IPUC WMP Guidelines.

Community Education
 May include public service announcements
to create awareness and provide education
of wildfire risks, providing preventative
measures, etc.
 Consistent with 61-1803(3)(c) and 61-
1803(3)(d).

A WMP's preventative actions and programs
may include, but is not limited to, the following:

System Hardening Strategies
 May include pole replacements, line
rebuilding, or undergrounding if necessary,
strategic fuse or reclosers installations, etc.

Workforce Preparedness
 May include workforce training, equipment
provided to employees to reduce the risk of
wildfire, etc.

Pilot Programs
 If applicable
Appendix B: Wildfire
Public Safety Power
Shutoff Plan
Appendix F: Wildfire
Mitigation Activities and
Cost Forecast 2027-
2029
Appendix G: Grid
Hardening List
19. Idaho Power carries out numerous preventative actions and programs to
reduce the risk of wildfire in compliance with the requirements of the WSCA as well as
the IPUC WMP Guidelines. The Company notes that, relative to preventative actions and
programs required by Idaho Code § 61-1803(3)(b), the IPUC WMP Guidelines address a
number of different mitigation efforts that are also separately identified in other
subsections of the WSCA. For ease of review and in order to avoid duplication, in those
instances where the IPUC WMP Guidelines identify a preventive action/program that is
also encompassed by another subsection of Idaho Code § 61-1803(3), the Company
APPLICATION - 13
discusses its compliance with both provisions in the discussion of the corresponding
statutory requirement as noted below.
20. Situational Awareness efforts. See discussion of Idaho Code § 61-
1803(3)(f).
21. Asset Inspections. See discussion of Idaho Code § 61-1803(3)(g)(i).
22. Enhanced vegetation management practices in risk zones. See discussion
of Idaho Code § 61-1803(3)(g)(iii).
23. Operation practices during heightened wildfire risk days or zones. See
discussion of Idaho Code § 61-1803(3)(g)(ii).
24. Community education. See discussion of Idaho Code § 61-1803(3)(c)-(d).
25. System hardening strategies. See discussion of Idaho Code § 61-
1803(3)(e).
26. Workforce Preparedness. Idaho Power’s wildfire mitigation strategy
includes procedural personnel measures to reduce potential ignition risk and the spread
of wildfires. Idaho Power developed a Wildland Fire Preparedness and Prevention Plan
(the “Plan”), included as Appendix A to the Company’s 2027 WMP, to provide guidance
to Idaho Power employees to help prevent the accidental ignition and spread of wildland
fires associated with employee work activities in locations and under conditions where
there is a heightened risk of wildfire. The Plan includes information on wildfire season
tools and equipment required to be available when on the job site; expected wildfire
ignition prevention practices while working and reporting instructions in the event of fire
ignition; and training and compliance requirements for employees in situations covered
by the Plan.
APPLICATION - 14
27. Pilot Programs. As part of its 2027 WMP, Idaho Power may use pilot
projects to evaluate emerging technologies, operational practices, and mitigation
approaches that may reduce wildfire risk, improve system reliability, or enhance
operational effectiveness. Pilot projects provide an opportunity to assess implementation
requirements, operational performance, costs, and potential risk reduction benefits before
broader deployment. These projects support learning with respect to cost, labor, and time
requirements and inform risk-based decisions when comparing, selecting, and prioritizing
mitigation strategies for the future. Currently, the following projects are in pilot status:
 Standby helicopter services for pre- and post-event inspections
 Wildfire resilience partnerships and fuels reduction shared stewardship
 Line monitoring technology
 Covered conductor
 3-D pole loading
 High impedance relay protections
 Unmanned aircraft system aerial inspection

(4) WMP Element – Public Outreach and Engagement

Idaho Code § 61-
1803(3)(c)
IPUC WMP Guidelines
(Order No. 36774)
Corresponding Location
in WMP
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 utility utilizes de-energization, a
Section 11. Public Outreach
and Engagement
Appendix B: Wildfire Public
Safety Power Shutoff Plan
APPLICATION - 15
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 is 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.

28. Communication is an important part of Idaho Power’s wildfire mitigation
efforts. Idaho Power engages in community outreach and public awareness efforts
before, during, and after wildfire season to inform the public of wildfire risks and to notify
the public of wildfire-related outages. The Company’s wildfire-related communications are
guided by the following objectives: educate customers about how to prepare for wildfire-
related outages, including where to find outage and Public Safety Power Shutoff (“PSPS”)
information, and how to update contact information to enhance communication regarding
any potential outage events; raise awareness about Idaho Power’s wildfire mitigation
work; and explain how customers can reduce wildfire risk.
29. Each year, Idaho Power organizes an education campaign focused on
wildfire risk and outage preparedness. This campaign promotes the Company’s wildfire
mitigation activities and customer outage communication, provides awareness and
education on preparing for wildfire season, and publicizes ways customers can prevent
wildfires.
APPLICATION - 16
30. To help maximize reach and effectiveness, Idaho Power communicates
with customers and the public through a variety of channels including, but not limited to,
social media, news media, customer newsletters, printed materials including flyers and
bill inserts, videos, the Company’s website, paid advertising, and email. The Company
also hosts public events focused on outage preparedness, safety, and wildfire prevention,
including PSPS. These efforts are complemented by participation in coordinated
preparedness events led by community-based organizations.
(5) WMP Element – Government Outreach

Idaho Code § 61-1803(3)(d) IPUC WMP Guidelines
(Order No. 36774)
Corresponding Location
in WMP
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:
 If applicable, 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 Bureau of Land Management
[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.
Section 4.6 Wildfire
Detection Cameras
Section 10.3.2 Wildfire
Resilience Partnerships
and Fuels Reduction
Shared Stewardship (Pilot)
Section 11. Public
Outreach and
Engagement
Section 12. Government,
Industry, and Peer Utility
Outreach

31. Idaho Power recognizes the importance of engaging with various levels of
government — federal, tribal, state, and local — as an integral part of wildfire
preparedness and emergency response plans. Prior to the start of wildfire season, Idaho
Power meets with interested state and federal land-management agencies in Idaho to
review the Company’s approach for wildfire mitigation and discuss wildfire season
APPLICATION - 17
operations. Additionally, throughout the year Idaho Power offers to engage with federal,
tribal, state, and county agencies to share information, receive feedback on mitigation
approaches (including vegetation management practices), and identify and work toward
mutually beneficial activities that may be considered in subsequent WMPs.
(6) WMP Element – Method of Line Design

Idaho Code § 61-
1803(3)(e)
IPUC WMP Guidelines
(Order No. 36774)
Corresponding Location
in WMP
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.
Section 3. Cost-Benefit
Approach
Section 6. Mitigation Activity:
Line Operation Practices
Section 8. Methods of Line
Design
Section 10. Additional
Preventative Actions and
Programs
Section 14. WMP Cost
Summary
Appendix F. Wildfire
Mitigation Activities and Cost
Forecast 2027-2029
Appendix G: Grid Hardening
List

32. The Company’s wildfire mitigation strategy includes financially prudent and
reasonably practicable methods of line design for new, planned, and existing lines to
mitigate wildfire risk. As explained above, in considering mitigation measures, including
line design methods, to reduce wildfire risk, Idaho Power uses a cost-benefit approach
and applies various strategies to achieve risk reduction that reasonably balances
mitigation costs against mitigation effectiveness.
33. In the context of line design methods, Idaho Power’s wildfire mitigation
efforts include design and system hardening activities such as line rebuilding, line
APPLICATION - 18
relocation, strategic undergrounding of distribution circuits, and systematic replacement
of hardware, equipment, and materials that provide for additional wildfire protection, as
well as use of automatic reclosers and remote-controlled devices that support remote
operations. As discussed more fully in Section 3 of the 2027 WMP, many of these
activities may also provide co-benefits including improved safety, reliability, and resiliency
of the system.
34. The Company’s 2027 WMP includes a detailed description of how its design
methods for new lines and planned upgrades reduce wildfire ignition potential in
heightened wildfire risk areas, including an evaluation of costs, and explains the process
and strategies used by the Company to identify, select, and evaluate projects that reflect
a balance of mitigation costs with resulting reduction in wildfire risk. By way of example,
the Company may use strategic undergrounding as an alternative to conducting overhead
circuit hardening upgrades as a mitigation approach in select areas where risks justify the
costs. While underground conversion of overhead distribution lines can provide benefits,
including reduced wildfire ignition risk, improved reliability, and lower long-term vegetation
maintenance needs, they often have higher up-front costs compared to carrying out
overhead hardening work. In general, overhead hardening efforts provide the benefit of
being able to impact a greater number of circuit miles and customers in a shorter time
horizon with less up-front investment than undergrounding. However, there may be
certain risk, reliability, ongoing cost savings, and other benefits of underground
infrastructure relative to overhead. Using the Framework, Idaho Power evaluates these
alternatives as it selects line infrastructure projects.

APPLICATION - 19
(7) WMP Element – Situational Awareness and Monitoring

Idaho Code § 61-
1803(3)(f)
IPUC WMP Guidelines
(Order No. 36774)
Corresponding Location
in WMP
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:
 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
becomes aware of another electric
corporation's de-energization (e.g.,
Bonneville Power Administration) and
how that is integrated into operations.
Section 2. Geographical
Risk Assessment
Section 4. Situational
Awareness and Monitoring
Section 5. Mitigation
Activity: Workforce
Preparedness
Section 6. Mitigation
Activity: Line Operation
Practices
Section 10. Additional
Preventative Actions and
Programs
Appendix A: Wildland Fire
Preparedness and
Prevention Plan
Appendix B: Wildfire
Public Safety Power
Shutoff Plan

35. Consideration of current and forecasted meteorological conditions, fuel
conditions, and information about fire behavior is an aspect of Idaho Power’s wildfire
mitigation strategy. Idaho Power leverages its internal Atmospheric Science group’s
modeling/forecasting capabilities, its fire weather stations, and publicly available
weather/fuel data to develop projections of current and future wildfire potential in wildfire
risk zones. This wildfire potential information is factored into operational decision-making.
36. In 2020, Idaho Power developed a Fire Potential Index (“FPI”) to support
operational decision-making to reduce wildfire threats and risks. The FPI is issued during
wildfire season, for a seven-day period, and converts data on weather and fuel conditions
(i.e., trees, shrubs, grasses) into a numeric forecast of the short-term fire threat for each
of Idaho Power’s wildfire risk zones. Based on its variables, which are assigned a numeric
APPLICATION - 20
value, the FPI produces fire potential value from 0 to 16, which expresses the degree of
fire potential expected for each of the seven days included in the forecast. FPI scores of
0 through 11 are grouped into the Green category, indicating lower potential for a fire to
develop and spread. FPI scores of 12 through 14 are grouped into the Yellow category,
indicating an elevated potential for a fire to develop and spread, and FPI scores of 15
through 16 are grouped into the Red category, indicating a higher potential for a fire to
develop and spread.
37. To further enhance Idaho Power’s situational awareness, the Company
partnered with the National Center for Atmospheric Research in 2024 to develop a system
that produces multiple custom, high-resolution weather forecast models throughout the
day, referred to in the 2027 WMP as the Ensemble Forecast System. Following this
system’s initial development, Idaho Power created data pipelines that combined the
output of these models with a range of publicly available weather forecast model output.
This method allows Idaho Power forecasters to compare different custom and public
model outputs to predict a range of possible weather scenarios. Through an interactive
data viewer, Idaho Power forecasters can calculate probabilities of the timing, location,
and intensity of various weather events, helping them communicate potential outcomes.
38. Idaho Power’s Atmospheric Science group utilizes both publicly available
and Company-owned weather stations to gather information on conditions in wildfire risk
zones. Over the next three years, with locations informed by coordinating with
the National Weather Service, Idaho Power plans to install additional weather stations,
adding to the 154 stations that have already been installed in Idaho.
39. In addition, Idaho Power contracts with ALERTWest, which installs AI-
enabled wildfire detection camera sites. This network of cameras and the associated
APPLICATION - 21
software solution is used by first responders, emergency management personnel, and
Idaho Power to detect wildfire, track real-time weather and fuel conditions, and allow first
responders, as well as Idaho Power, to allocate the appropriate resources in the event of
a fire. To date, the Company, through ALERTWest, has installed nine wildfire detection
cameras in Idaho in areas where they provide visibility of overhead assets or surrounding
terrain in certain wildfire risk zones. These cameras are part of an artificial intelligence-
enabled wildfire detection camera network that totals more than 30 cameras across Idaho
owned by various members of the Idaho Fire Camera Interoperability Committee.
40. Idaho Power continues to explore the use of on-demand capabilities of
Technosylva’s Wildfire Risk Analyst Enterprise (WFA-E) software FireSim and FireRisk
in conjunction with the Company’s internal FPI tool to support operational decisions that
reduce wildfire threats and risks. Specifically, FireSim provides an on-demand capability
within WFA-E to generate fire spread predictions based on forecast weather conditions,
and FireRisk integrates Idaho Power’s Weather Research Forecasting model outputs with
FireSim to generate current and near-term wildfire risk forecasts.
(8) WMP Element – Infrastructure Inspection and Asset Management

Idaho Code § 61-
1803(3)(g)(i)
IPUC WMP Guidelines
(Order No. 36774)
Corresponding Location
in WMP
Developing standards,
procedures, and schedules,
subject to timely approval of
access to rights-of-way, if
necessary, for the following
actions:

(i) Inspection of the electric
corporation’s assets,
infrastructure, and
facilities within the areas
that are identified as
heightened fire risk
areas in the wildfire
mitigation plan, where
financially prudent and
This section should provide a summary of
an 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.
Section 7. Infrastructure
Inspection and Asset
Management
Section 9. Vegetation
Management
Section 10. Additional
Preventative Actions and
Programs
Appendix F: Wildfire
Mitigation Activities and
Cost Forecast 2027-2029
APPLICATION - 22
reasonably practicable.

.

 Description of baseline routine
inspection methods and enhanced
inspection methods for higher fire-risk
areas, which may include the use of
advanced or pilot technologies.
 Explanation of how identified defects
are classified, prioritized, and
corrected.
 Measurable targets/ goals to be
achieved within the WMP. (e.g., miles
of lines inspected, corrected identified
defects, etc.)

41. The Company’s wildfire mitigation strategy relies in part on its various asset
management programs, including inspections and maintenance activities. To reduce
wildfire risk and continue to safely operate the grid, Idaho Power evaluates and
implements a robust set of transmission and distribution (“T&D”) asset inspection
programs, as shown below in Table 1.
Table 1
Overview of T&D inspection programs
Inspection Type 2027 WMP
Section
Transmission Distribution
Outside
Wildfire
Risk Zone
Tier 2
Zones
Tier 3
Zones
Outside
Wildfire
Risk Zone
Tier 2
Zones
Tier 3
Zones
Visual Inspections
Programs
(Aerial/Ground)
Sections 7.4.1 (T)
& 7.5.1 (D) Annually Annually Annually None Annually
Selected Annually
Line Equipment
Inspection Program Section 7.5.2 N/A N/A N/A N/A Annually Annually
Detailed Visual
(Aerial/Ground)
Inspections
Section 7.4.2 (T)
&7.5.3 (D) 10 years* 10 years* 10 years* 3 Years 3 Years 3 Years
Thermal Imaging
(Infra-Red)
Sections 7.4.3 (T)
& 7.5.4 (D) N/A Annually
Selected Annually N/A Annually
Selected
Annually
Selected
Wood Pole Inspection
and Treatment
Program
Sections 7.3 10 years 10 years 10 years 10 years 10 years 10 years
Cathodic Protection
Inspection Program Sections 7.4.4 Annually
Selected
Annually
Selected
Annually
Selected N/A N/A N/A
* Western Electricity Coordinating Council (WECC) Lines Only

APPLICATION - 23
(9) WMP Element - Line Operation Practices

Idaho Code § 61-
1803(3)(g)(ii)
IPUC WMP Guidelines
(Order No. 36774)
Corresponding Location
in WMP
Developing standards,
procedures, and schedules,
subject to timely approval of
access to rights-of-way, if
necessary, for the following
actions:

(ii) 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 third-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.
Section 6. Mitigation
Activity: Line Operation
Practices
Section 11. Public Outreach
and Engagement
Section 14. WMP Cost
Summary
Appendix B: Wildfire Public
Safety Power Shutoff Plan

42. To reduce wildfire risk in a way that balances mitigation costs, Idaho Power
implements line operational practices during heightened wildfire risk days and/or in areas
with potential heightened wildfire risk. Wildfire mitigation operational practices fall in the
following categories: temporary operating procedures for distribution lines in wildfire risk
zones during wildfire season; temporary operating procedures for transmission lines
during wildfire season; Idaho Power’s emergency de-energization operational strategy for
T&D lines related to wildfire during the wildfire season; and a PSPS strategy.
APPLICATION - 24
43. The Company’s operational protection strategy utilizes Enhanced
Powerline Safety Settings (“EPSS”), sometimes referred to as sensitive powerline
settings, to reduce the probability of ignition during fault events on Idaho Power’s
distribution system. EPSS are generally enabled, based on various criteria, in automatic
reclosing protective devices where the zone of protection overlaps with, or is located
within, Tier 2 or Tier 3 wildfire risk zones. While EPSS help reduce wildfire risk by
operating more sensitively to fault conditions, they also increase the likelihood of
customer outages. For this reason, Idaho Power only enables EPSS when the conditions
and protocols defined within the 2027 WMP are met.
44. The Company’s transmission line operational strategy varies based on the
line’s voltage and location. During wildfire season, Idaho Power temporarily modifies its
operating procedures for transmission lines 115 kilovolts (“kV”) and above to include
procedures for “testing”16 and closing in on “locked out”17 transmission lines. Depending
upon the transmission line’s designation and location, among other criteria that may be
applicable, a patrol is typically required prior to re-energization. Transmission lines
located in Tier 3 zones and operating at 69 kV and below are operated in normal settings
mode but with no “testing” of a line that may have “locked out” during the time of a red
FPI. If the line locks out, it will be patrolled in the area where Idaho Power has evidence
suggesting the fault occurred before re-energization. Alternatively, the Company may
choose to wait until the FPI level drops out of the red category and re-energize without a
patrol.

16 Transmission line “testing” refers to the human act of re-energizing a line without completing a physical
field patrol or observation of a line.
17 “Locked out” in this context refers to the condition in which a protection device has operated and
remains de-energized until it is manually or remotely reset. Depending on the protection scheme and
settings, lockout may occur following one or more trip/reclose attempts or after a single trip.
APPLICATION - 25
45. In the event of a wildfire near or approaching Idaho Power infrastructure,
the Company will conduct an emergency de-energization of overhead transmission or
distribution lines only if requested by the lead firefighting agency, including the designated
incident commander for that wildfire or those operating at the local, state, or federal level,
and if Idaho Power can determine to its satisfaction the identity of the line for which de-
energization is requested. Because the lead firefighting agency is generally in the best
position to analyze the wildfire risk and water needs in any situation, Idaho Power relies
on their determination, subject to the Company’s ability to identify the line in question and
Idaho Power’s evaluation of potential impacts to overall grid reliability and system stability,
as discussed more fully in the 2027 WMP.
46. When deemed appropriate by Idaho Power, the Company may implement
a PSPS, which is the proactive de-energization of electric transmission and/or distribution
facilities during extreme weather events to reduce wildfire risk. Idaho Power will conduct
a PSPS only when Idaho Power facilities located within wildfire risk zones may be
impacted by extreme weather. To guide its implementation of a PSPS, Idaho Power has
developed its Wildfire Public Safety Power Shutoff Plan, which is included as Appendix B
to the 2027 WMP.
(10) WMP Element – Vegetation Management

Idaho Code § 61-
1803(3)(g)(iii)
IPUC WMP Guidelines
(Order No. 36774)
Corresponding Location
in WMP
Developing standards,
procedures, and schedules,
subject to timely approval of
access to rights-of-way, if
necessary, for the following
actions:

(iii) Vegetation management
within the areas that are
identified as heightened
fire risk areas in the
This section must provide an
overview of the utility's vegetation
management program aimed at
reducing the risk of vegetation-related
contact with electric infrastructure in
areas with heightened wildfire risk
within its rights-of-way or lands
adjacent thereto. Elements of this
vegetation management section
overview should include, but is not
limited to, the following:
Section 9. Vegetation
Management
Section 10. Additional
Preventative Actions and
Programs
Section 12. Government,
Industry, and Peer Utility
Outreach
APPLICATION - 26
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.

.

 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.
Section 14. WMP Cost
Summary
Appendix F: Wildfire
Mitigation Activities and Cost
Forecast 2027-2029

47. Vegetation management remains an important mitigation strategy for Idaho
Power. Idaho Power’s vegetation management activities addresses public safety,
regulatory compliance, electric reliability and helps safeguard transmission and
distribution lines from trees and other vegetation that may cause an outage or damage to
facilities. These activities encompass planning, scheduling, performing, and quality
control related to the management of trees and vegetation that could impact lines, as well
as the clearing of vegetation from the base of certain poles and line structures. In addition
to routine vegetation management activities, which are performed throughout Idaho
Power's transmission and distribution system to maintain vegetation clearances, support
system reliability, comply with applicable regulatory requirements, and address
vegetation conditions that could affect the operation of electric facilities, the Company
APPLICATION - 27
also employs enhanced vegetation management activities. Enhanced vegetation
management activities supplement Idaho Power’s routine vegetation management
program within designated wildfire risk zones and are intended to further reduce
vegetation-related wildfire ignition potential and wildfire risk.
48. The Company ensures adherence with its vegetation management
standards and specifications through quality control and assurance audits,18 which are
performed on certain pruning worksites in non-wildfire risk zones and on 100 percent of
pruning work performed in wildfire risk zones. Auditors check if pruning cuts meet
specification and proper clearance was achieved. When necessary, circuits are re-pruned
to achieve satisfactory results.
B. Compliance with Order Nos. 36774 and 36929
49. In GNR-E-25-02 Commission Staff (“Staff”) applied to the Commission for
approval of a filing process for Wildfire Mitigation Plans. As an outcome of that case, the
Commission issued several Orders with specific content requirements that pertain to
Idaho Power’s WMP. Incorporation of these directives in the Company’s 2027 WMP is
highlighted below.
Commission Order No. 36774, Case No. GNR-E-25-02 Corresponding Location
in WMP
An update of lessons learned from the previously approved
WMP within the annual filings for WMP review and approval.

Section 13.3. 2026 Lessons Learned

A breakdown of each program category’s forecasted costs by
year for both capital and O&M expenditures through the length
of the WMP.

Section 14. WMP Cost Summary
Appendix F: Wildfire Mitigation Activities
and Cost Forecast 2027-2029

A section in which Idaho Power describes how it addresses
each of the IPUC’s orders and Staff’s recommendations.

Appendix D: Idaho and Montana
Requirements and Recommendations
Crosswalk

18 Within this context, the term “audit” is used in an informal context and does not mean a formal audit
conducted by the Company’s Audit Services Department or by an outside auditing firm.
APPLICATION - 28
Rolling WMPs shall be developed with a minimum three-year
planning horizon.

Appendix F: Wildfire Mitigation Activities
and Cost Forecast 2027-2029

An explanation of how the company’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 it must show how the mitigation project strikes the
necessary “balance of mitigation costs with the resulting wildfire
reduction in wildfire risk,” as required by the WSCA.

Section 3. Cost-Benefit Approach
Section 8. Methods of Line Design
Section 14. WMP Cost Summary
Attachment 2 to this Application

WMPs must include a cost-benefit analysis that justifies the
expenditures for risk mitigation described within.

Section 3. Cost-Benefit Approach
Section 14. WMP Cost Summary
Attachment 2 to this Application

Commission Order No. 36929, Case No. GNR-E-25-02 Corresponding Location
in WMP
All electric corporations shall include a glossary within each
WMP that defines each utility’s terms, and that those terms
should be consistent with the WSCA and with the Commission
WMP Guidelines (issued through Order No. 36774).
Appendix I: Glossary of Terms
C. Compliance with Order No. 37004
50. In IPC-E-25-32 Idaho Power filed its 2026 WMP, which was its first version
of the plan filed for Commission approval pursuant to the WSCA. Within this case, Staff
determined that Idaho Power's 2026 WMP met the requirements of the WSCA and the
Commission's WMP Guidelines and therefore recommended that the Commission
approve the same. In addition, Staff requested that certain additional supporting
information be provided with the Company’s future WMP filings and offered
recommendations for additional items to be included or considered as part of future WMP
cycles (collectively referred to as "Staff’s Recommendations").19 In Order No. 37004
issued on April 14, 2026, the Commission approved the Company’s 2026 WMP and also

19 Staff’s Comments conclude with a numeric list summarizing the various recommendations, including
recommendations 1-4 and additional recommendations 1-18. See Case No. IPC-E-25-32, Staff Comments
at 19-21 (Feb. 12, 2026). For ease of reference, this Application uses the same numeric references in
discussing the various recommendations.
APPLICATION - 29
adopted many of Staff’s Recommendations.20 Idaho Power’s incorporation of new
recommendations beginning with its 2027 WMP filling are highlighted below.
Commission Order No. 37004, Case No. IPC-E-25-32
Adopted Staff Recommendations21

Corresponding Location
in WMP
Additional Staff Recommendation 4: Address the types of
infrastructure left out of risk modeling and provide an
explanation for its exclusion.

Section 2.2. Identifying Areas of
Heightened Wildfire Risk

Additional Staff Recommendation 7: Incorporate quantitative
model validation and analysis into its geographic risk modeling
and assessment.

Section 2.2.2.2. Model Validation
Section 2.2.3. 2027 Wildfire Risk Zone
Modification Process

Additional Staff Recommendation 8: Provide the estimated
cost, planned duration, and evaluation metrics for each pilot
program.

Section 10.3. Pilot Projects
Additional Staff Recommendation 9: Establish and publish
annual mileage targets for all transmission and distribution
(“T&D”) hardening programs and projects by wildfire risk zone
tier or feeder, along with modeled ignition risk reduction per
mile for each category.

Appendix F: Wildfire Mitigation
Activities and Cost Forecast 2027-2029
Appendix G: Grid Hardening List
Modeled ignition risk reduction not due
until 2028

Additional Staff Recommendation 10: Adopt an effectiveness
scorecard for each grid hardening method— including, but not
limited to, covered conductor, non-wooden poles, non-wooden
crossarms, and undergrounding— based on industry guidance.
This information is not due until 2028

Additional Staff Recommendation 11: Include a table in the
WMP identifying all T&D rebuild and grid hardening projects
undertaken as part of Idaho Power’s wildfire mitigation strategy,
including the project name, type, primary driver, location,
design standards, anticipated timeline, and estimated costs, as
well as an explanation of whether wildfire mitigation priorities
affected any aspect of the project, such as design, cost, or
schedule.

Appendix G: Grid Hardening List
Additional Staff Recommendation 12: Include the internal
vegetation management crew description within Section 10. of
the WMP.
Discussion of the Internal Vegetation
Management Crew is no longer relevant
under Section 10’s Pilot Projects.
Instead, the requested description has
been included under Section 13.3.4.

20Additional Staff Recommendations 1-3 involved recommendations for the Company to continue
undertaking certain activities. Additional Staff Recommendations 4, 7-8, 12-14, and 17-18 were adopted as
proposed and Additional Staff Recommendations 9-11 and 16 were adopted as modified/clarified by Idaho
Power. The Commission did not adopt Additional Staff Recommendation 5, which requested the Company
to identify ways to incorporate loss of life as a parameter in future wildfire risk assessments. With respect
to Staff’s remaining recommendations, the Commission ordered Staff and the Company to work
collaboratively to address them. See Case No. IPC-E-25-32, Order No. 37004 at 17-19.
21 Including Staff’s Recommendations that were adopted as proposed (i.e., Additional Staff
Recommendations 4, 7-8, 12-14, and 17-18) and those that were adopted as modified/clarified by Idaho
Power (i.e., Additional Staff Recommendations 9-11 and 16).
APPLICATION - 30
Internal Vegetation Management Crew

Additional Staff Recommendation 13: Adopt and further
develop industry best practices in configuration management,
requirements management, test management, and issue and
defect tracking for all custom models or software developed for
the FPI tool, as well as other custom developed models or
applications that play a critical role in the Company's WMP.

Section 4.3. FPI Review and Evaluation
Section 4.4 Ensemble Forecast System

Additional Staff Recommendation 14: Expand the description of
resources available to call center agents during a PSPS event
within Appendix B.

Section 5.2 of the 2027 WMP’s
Appendix B: Wildfire Public Safety
Power Shutoff Plan.

Additional Staff Recommendation 16: Conduct cost-benefit
analyses on a project-by-project basis to demonstrate that each
project reasonably balances costs with reductions in wildfire
risk.
Section 3.5. Risk Informed Mitigation
Evaluation Framework
Attachment 2 to this Application

Additional Staff Recommendation 17: Identify average project
costs, including installation costs for steel poles, fire mesh
wraps, wildfire detection cameras, undergrounding, covered
conductors, fiberglass cross-arms for wooden poles, and
weather stations.

Appendix H: Average Mitigation Project
Costs (Confidential)
Additional Staff Recommendation 18: Add all metrics that will
be used for the WMP be included within each respective
section of the WMP and provide the data in a format that can
be tracked in each version of the WMP.

Appendix F: Wildfire Mitigation
Activities and Cost Forecast 2027-2029

51. While the Company largely supported many of Staff’s Recommendations,
either as presented or in principle, there were certain proposals, as shown in the below
table, that were not well-suited to achieve Staff’s objectives or were otherwise
inappropriate. Accordingly, the Company requested that the Commission direct it to work
with Staff in advance of finalizing its next WMP to find appropriate and workable methods,
which the Commission ultimately directed as part of Order No. 37004.
Staff Recommendations for Further Discussion and Collaboration
Staff Recommendation 3 Requiring the Company to include copies of the Company’s four
most-recent quarterly NERC FAC-003-X compliance reports as
attachments in future WMPs (where X represents the latest version
of the standard the Company is using).
Staff Recommendation 4 Requiring the Company include copies of current Transmission
Maintenance and Inspection plans used for NERC FAC-501-WECC-
X compliance and any violations noted from the most recent NERC
compliance audit (X represents the latest version of the standard the
Company is using).
Additional Staff Recommendation 6 Take necessary steps to integrate asset condition/inspection data
APPLICATION - 31
and failure modes into ignition models as part of geographical risk
modeling and assessment.
Additional Staff Recommendation 15 Expand reporting for future WMPs to include both transmission and
distribution assets not covered by NERC Standards to offer a more
comprehensive view of trends and effectiveness across the utility’s
entire system.

52. Idaho Power met with Staff on July 9, 2026, to discuss Staff’s outstanding
recommendations. With respect to Staff Recommendation’s 3 and 4 and Additional Staff
Recommendation 15, the Company understands Staff to be seeking information
regarding the performance of the Company’s system following implementation of wildfire
mitigation activities, which the requested NERC compliance reports would not provide.
That said, Idaho Power has historically looked to sustained outage data and associated
cause codes when seeking insights related to wildfire risk, both for insights into potential
drivers of wildfire ignition risk, as discussed in Section 3 of the 2027 WMP, and to gain
insights into wildfire mitigation efficacy.22 With regard to the latter, Idaho Power considers
trends in reduction in sustained outages associated with key ignition drivers as an
indicator, or proxy, for reduced ignition potential. As such, Idaho Power considers this
data in evaluating whether mitigation programs are reducing conditions that could
potentially lead to ignitions. Tables 2 and 3, included below, represent year-over-year
outage trends compared to the reference period (2019 to 2021), which occurs prior to the
majority of the Company’s wildfire mitigation activities being implemented. It must be
noted that, in addition to the limitations in outage data in reflecting the effectiveness of
wildfire mitigation measures in driving down ignition risk, the use of this data to provide

22 Idaho Power acknowledges the limitations in this data. There is no guarantee that an outage will
necessarily lead to an ignition, regardless of the cause of the outage. In fact, most outage events do not
result in ignitions, and outcomes are often influenced by external factors beyond the Company’s control,
most particularly fuel and weather conditions at the time of the outage. Ignitions can also occur in the
absence of an outage. For these reasons, Idaho Power considers outage data to be a rough proxy by which
to gain insight into potential ignition risk drivers. However, this data remains the best data available to Idaho
Power at this time from which to assess system performance relative to wildfire risk.
APPLICATION - 32
year over year comparisons also has limitations. Idaho Power‘s system is not static, nor
is its system solely impacted by wildfire mitigation efforts. For example, subsequent to the
reference period, Idaho Power has engaged in certain reliability-focused initiatives,
including circuit segmentation projects that install or upgrade automatic reclosing devices,
that improve reliability by reducing the number of customers affected by individual outage
events. Conversely, EPSS are intended to reduce wildfire risk during elevated fire-
weather conditions. Because EPSS limits automatic re-energization following a fault,
some interruptions that might otherwise be momentary may instead be recorded as
sustained outages. As additional years of data become available, the Company expects
a broader understanding of long-term trends and the relationship between wildfire
mitigation activities and outage performance.
Table 2
Year-over-year WMP sustained outage performance compared to the reference period’s average
Period
EPSS
Implemented
Reported
Outages
Compared to
2019-2021
Reference Period
Average
2019-2021 average No 931 n/a
2023 No 766 18% below
2024 Yes 984 6% above
2025 Yes 871 6% below
2026* Yes 640 31% below
* 2026 results are through 9/28/2026.

APPLICATION - 33
Table 3
Interim 2026 sustained outage results listed by cause code
Cause Code
2019-2021
Reference Period
Average 2026*
Change From
Reference Period
Average
Environmental 131 48 63% below
Contamination 5 1 81% below
Public Contact 80 43 46% below
Vegetation 300 170 43% below
Equipment Failure 190 113 41% below
Corrosion 57 43 24% below
Animal 125 109 13% below
Other 43 43 No Change
* 2026 results are through 9/28/2026.

53. Regarding Additional Staff Recommendation 6, Idaho Power understands,
based on its July 9, 2026, conversation with Staff, the recommendation to require the
Company to consider asset condition and inspection data, as well as failure modes, when
selecting mitigations. Accordingly, discussion of how these factors are considered by
Idaho Power when evaluating mitigations has been included under Section 3.5 of the
2027 WMP.
54. The Commission also found through Order No. 37004 that Idaho
Department of Lands’ (“IDL”) recommendations relating to Idaho Power’s provision of
additional descriptive narrative regarding the data used to develop its risk model,
including a discussion of diminishing returns within its cost benefit analysis and the impact
of electrical service disruptions when making mitigation decisions, to be reasonable and
in the public interest. Idaho Power has met with IDL on multiple occasions to discuss
these recommendations, including the Company’s risk modeling approach and model
inputs. Additionally, the Company has added additional details under Section 2.2.2. of the
2027 WMP regarding the modeling inputs used within its updated risk analysis. As the
Company continues to develop its infrastructure project cost-benefit framework, which
APPLICATION - 34
must begin informing future iterations of Idaho Power’s WMPs beginning in 2028 pursuant
to Order No. 37004, the Company will discuss diminishing returns and the impact of
electrical service disruptions when making mitigation decisions.
55. On May 20, 2026, following the Commission’s approval of Idaho Power’s
2026 WMP through Order No. 37004, IDL submitted supplemental comments in IPC-E-
25-32 strongly encouraging that data inputs relating to the type, condition and age of
system components be included by the Company when evaluating wildfire risk given such
elements have the ability to significantly increase or decrease the risks associated with
wildfire ignitions or impacts from wildfire on Idaho Power’s system. Idaho Power notes
that its Risk Informed Mitigation Evaluation Framework, discussed in Section 3.5 of the
2027 WMP, utilizes a variety of information to inform the Company’s mitigation strategy.
This information includes but is not limited to: location within a wildfire risk zone, modeling
outputs based on historical outage rates, inspection findings, asset management
information, system planning information, operational experience, and other planning
inputs.
56. Additionally, IDL requested that Idaho Power’s WMP include data to
account for instances where the surrounding tree canopy is taller than the adjacent
system to consider above-ground system strike risk, as well as include soil layer
saturation data to reflect tree tipping or blow-over risk. IDL also requested that damaging
wind events be considered by the Company when determining risk ratings and
implementation of wildfire risk mitigations. While Section 2.2.3 of the Company’s 2027
WMP discusses the datasets evaluated for concurrence as part of its 2027 wildfire risk
zone modification process, Idaho Power plans to continue evaluating additional data
APPLICATION - 35
sources and datasets that may be of benefit to future iterations of the Company’s
geographical risk assessment process.
D. Compliance with Other Prior Commission Directives
57. Since 2021, Idaho Power has submitted WMPs annually for the
Commission’s visibility and review.23 The Orders issued by the Commission in most of
those cases set forth certain requirements, in addition to those listed above, for Idaho
Power to incorporate in the development of its ongoing WMPs. The Company’s 2027
WMP fully incorporates these directives as detailed in Appendix D to such plan.
III. PROGRESS ON 2026 WILDFIRE MITIGATION TARGETS
58. To aid the Commission and Staff in their review of the Company’s 2027
WMP, Table 4 provides an update on Idaho Power’s progress toward its 2026 wildfire
mitigation targets. Because of the timing associated with this submission, the values
presented in Table 4 reflect work completed through September 15th, 2026, and should
therefore be considered a progress update rather than final, year-end results.
59. Idaho Power’s objective is to complete all planned wildfire mitigation
activities each year; however, emergencies or other unplanned events can occur and
disrupt planned work. Final 2026 metric results will be reported in Idaho Power’s 2026
WMP Compliance Report, to be filed no later than June 1, 2027, consistent with the
schedule and standards adopted in Commission Order No. 36929. Additionally, Idaho

23In the Matter of Idaho Power Company’s Application for an Accounting Order Authorizing the Deferral of
Incremental Wildfire Mitigation and Insurance Costs, Case No. IPC-E-21-02, Application (Jan. 22, 2021);
In the Matter of Idaho Power Company’s Application for Review of the Company’s Current Wildfire
Mitigation Plan and Authorization to Defer Newly Identified Incremental Wildfire Mitigation Costs, Case
No. IPC-E-22-27, Application (Oct. 20, 2022) (which encompassed the Company’s 2022, 2023 and 2024
WMPs); In the Matter of the Application of Idaho Power Company for Review of the Company’s Current
Wildfire Mitigation Plan and Authorization to Defer Newly Identified Incremental Wildfire Mitigation Costs,
Case No. IPC-E-25-05, Application (Feb. 13, 2025).
APPLICATION - 36
Power’s 2026 WMP Compliance Report may include additional target information not
contained in Table 4.
Table 4
2026 WMP Target Progress
Metric
2026
WMP
Target
Progress as of
September 15th, 2026
(% complete)
Situational Awareness
Wildfire detection cameras installed 2 100%
Weather stations installed 55 100%
Asset Inspections/
Corrections
(Transmission) Wildfire Pre-Season
Patrol—Tier 3 Risk Zones (Structures) 1,118 100%
(Transmission) Infrared Thermography
(Structures) 1,118 100%
(Distribution) Wildfire Pre-Season
Patrol—Tier 3 Risk Zones and select Tier
2 Risk Zones (Poles) 19,382 100%
(Distribution) Infrared Thermography
Patrol—Tier 3 Zones (Poles) 4,000 100%
Pole Mesh Wrap – No. of Poles 750 ~60%
Line Design/System
Hardening
System Hardening (miles) 72 ~45%
Overhead Line Converted to
Underground (miles) 20 ~30%
Feeder Segmentation (installation or
relocation of automatic reclosing devices) 5 100%
Vegetation
Management
Wildfire Mitigation Vegetation Inspection
Patrol/Mitigation (No. of T&D Circuits) 139 100%
Line Clearing Cycle Patrol /Mitigation (No.
of T&D Circuits) 213 ~96%
Mid-cycle Patrol/Mitigation (Cycle
Busters) of T&D Circuits 15 100%

IV. REQUIRED STAKEHOLDER COMMUNICATION
60. 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.
Additionally, to facilitate the participation of those interested parties in the review process,
the Commission adopted Staff’s recommendation to include certain information in these
notices: “Specifically, each electric corporation’s notice to interested entities must include
APPLICATION - 37
information about how to participate in the Commission’s proceeding and the case
number for the proceeding in which the WMP will be reviewed. Electric corporations must
provide a copy of this notice to the Commission in its filing.”24
61. Accordingly, and as required by Idaho Code § 61-1804(2) and pursuant to
the additional directive in Order No. 36774, Idaho Power is providing notice of its 2027
WMP filing to the state forester, cities, counties, fire protection districts, fire protection
associations, and timber protection associations within the Company’s Idaho service
area, which includes the case number for this proceeding and information about how to
participate in the Commission's proceeding; a copy of the Company’s letter, including a
list of entities to which it is being provided,25 is provided as Attachment 3 to this
Application.
V. MODIFIED PROCEDURE
62. Idaho Power believes that a technical hearing is not necessary to consider
the issues presented herein and respectfully requests that this Application be processed
under Modified Procedure, i.e., by written submission rather than by hearing. Procedural
Rule 201, et. seq. However, the Company stands ready to present testimony supporting
this Application in a technical hearing if the Commission determines such a hearing is
required.
VI. COMMUNICATIONS AND SERVICE OF PLEADINGS
63. Communications and service of pleadings, with reference to this Application
should be sent to the following:

24 Case No. GNR-E-25-02, Errata to Order No. 36774 (Dec. 22, 2025).
25 This list includes both entities that were provided notice pursuant to the WSCA and other stakeholders
or parties having expressed interest or identified by the Company.
APPLICATION - 38
Megan Goicoechea Allen
Regulatory Dockets
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
[e-mail]
[e-mail]
Tim Tatum
Connie Aschenbrenner
Riley Maloney
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
[e-mail]
[e-mail]
[e-mail]
VII. CONCLUSION

64. Wildfire risk in the West is increasing, and Idaho Power continues to take
proactive measures to adjust to that increasing risk, particularly considering the
magnitude of damage and loss of life associated with events outside of Idaho in recent
years. Taking actions to reduce the risk of wildfires is critical for Idaho Power’s customers,
the communities in which the Company operates, and investors who provide capital to
the Company.
65. To that end, and consistent with Idaho Code § 61-1803(2)(a), the
Company’s seventh WMP being submitted herein is the product of the Company having
conducted a comprehensive, rigorous assessment of wildfire risk across its service area
using approaches and methods that are designed to protect the public interest and are
reflective of and commensurate with the size and complexity of the Company’s operations
and the specific fire risks present within the areas in Idaho where the Company has
infrastructure or equipment that it considers may be subject to a heightened risk of
wildfire. From the 2027 WMP, the Company has identified several actions necessary to
mitigate wildfire risk that reflect a reasonable balancing of mitigation costs with the
resulting reduction of wildfire risk. Idaho Power currently estimates spending
approximately $51 million during 2027 in O&M expenses in Idaho to further wildfire
APPLICATION - 39
mitigation measures; however, this amount will likely change in the future as the Company
reviews and refines its 2027 WMP and associated mitigation activities, as well as due to
factors beyond the Company’s control. In addition to 2027’s estimated $51 million in O&M
expenses, Idaho Power’s wildfire mitigation efforts also include capital investments in
system infrastructure, many of which may also provide co-benefits such as increased
safety, reliability and resiliency of the system.
66. Accordingly, the Company requests the Commission review and issue an
order approving its 2027 WMP, finding it complies with the requirements of the WSCA,
meets the minimum requirements stated in Idaho Code § 61-1803; is consistent with
public health, safety and welfare; is feasibly implemented; and adequately minimizes
wildfire risk and proposes to respond to wildfires that do occur, as well as the additional
directives contained in Commission Order Nos. 37004, 36929, 36774, 36742, 36042, and
35717.
Respectfully submitted this 1st day of October, 2026.

MEGAN GOICOECHEA ALLEN
Attorney for Idaho Power Company
BEFORE THE

IDAHO PUBLIC UTILITIES COMMISSION

CASE NO. IPC-E-26-28

IDAHO POWER COMPANY

ATTACHMENT NO. 1

©2026 Idaho Power
2027
& WILDFIREMITIGATIONPLAN
IDAHO & MONTANA
Idaho and Montana 2027
Wildfire Mitigation Plan
Updated October 1, 2026
©2026 Idaho Power
Idaho Power Company Wildfire Mitigation Plan 2027
Page i
Table of Contents
Table of Contents ........................................................................................................................... i
List of Tables ................................................................................................................................ vi
List of Figures ............................................................................................................................... vi
List of Appendices .......................................................................................................................viii
1.Introduction ............................................................................................................................ 1
1.1. Overview ........................................................................................................................ 1
1.2. Background .................................................................................................................... 1
1.3. Idaho Power Profile and Service Area ............................................................................ 1
1.4. Asset Overview ............................................................................................................... 4
1.5. Legal and Regulatory Context ......................................................................................... 6
1.6. Summary of Idaho Power’s Plan for Mitigating Wildfire Risk ......................................... 6
2.Geographical Risk Assessment ................................................................................................ 9
2.1. Objective ........................................................................................................................ 9
2.2. Identifying Areas of Heightened Wildfire Risk ................................................................ 9
2.2.1. Wildfire Risk Model Processes ............................................................................. 10
2.2.2. 2027 Wildfire Risk Zone Modeling and Validation ............................................... 13
2.2.3. 2027 Wildfire Risk Zone Modification Process ..................................................... 15
2.3. Idaho Power’s Wildfire Risk Zones................................................................................ 17
3.Cost-Benefit Approach .......................................................................................................... 19
3.1. Objective ...................................................................................................................... 19
3.2. Risk-Based Cost and Benefit Analysis of Wildfire Mitigation ........................................ 19
3.3. Risk Analysis and Drivers .............................................................................................. 20
3.4. Mitigation Selection ..................................................................................................... 23
3.5. Risk Informed Mitigation Evaluation Framework ......................................................... 25
3.5.1. Purpose ............................................................................................................... 25
Idaho Power Company Wildfire Mitigation Plan 2027
Page ii
3.5.2. Relationship to Idaho Power's Wildfire Mitigation Strategy ................................ 26
3.5.3. Framework Overview .......................................................................................... 26
3.5.4. Identify Candidate Locations ............................................................................... 26
3.5.5. Evaluate Mitigation Alternatives ......................................................................... 27
3.5.6. Select Mitigation and Document Rationale ......................................................... 27
3.5.7. Future Development ........................................................................................... 29
4.Situational Awareness and Monitoring ................................................................................. 31
4.1. Overview ...................................................................................................................... 31
4.2. Fire Potential Index ...................................................................................................... 31
4.2.1. FPI Components .................................................................................................. 31
4.3. FPI Review and Evaluation ............................................................................................ 34
4.4. Ensemble Forecast System ........................................................................................... 34
4.5. Fire Weather Stations ................................................................................................... 35
4.6. Wildfire Detection Cameras ......................................................................................... 37
4.7. Fire Spread Predictive Tools ......................................................................................... 39
4.7.1. FireSim ................................................................................................................. 39
4.7.2. FireRisk ................................................................................................................ 39
5.Mitigation Activity: Workforce Preparedness ....................................................................... 41
5.1. Overview ...................................................................................................................... 41
5.2. Wildland Fire Preparedness and Prevention Plan ......................................................... 41
6.Mitigation Activity: Line Operation Practices ........................................................................ 43
6.1. Overview ...................................................................................................................... 43
6.2. Distribution Operational Protection Strategy ............................................................... 43
6.3. Transmission Line Operational Strategy ....................................................................... 44
6.3.1. Wildfire Season Temporary Operating Procedure for Transmission Lines
115 kilovolt (kV) and Above ................................................................................. 44
6.3.2. Tier 3 Zone Transmission Operational Strategy 69 kV & Below ........................... 45
6.3.3. Transmission Lines Where Idaho Power Is Not the Operator .............................. 46
Idaho Power Company Wildfire Mitigation Plan 2027
Page iii
6.3.4. De-energization by Other Electric Corporations .................................................. 46
6.4. Emergency De-energization When Wildfire is Approaching ......................................... 46
6.5. Restoration of Electrical Service After a Wildfire De-Energization ............................... 47
6.6. Mutual Assistance ........................................................................................................ 47
6.7. Public Safety Power Shutoff ......................................................................................... 47
6.7.1. PSPS Plan ............................................................................................................. 48
6.8. Community Resource Centers ...................................................................................... 48
7.Infrastructure Inspection and Asset Management ................................................................ 51
7.1. Overview ...................................................................................................................... 51
7.2. T&D Inspection Overview and Correction Timeframes ................................................ 51
7.3. Wood Pole Inspection and Treatment Program ........................................................... 52
7.4. Transmission Inspection and Asset Management Programs ........................................ 53
7.4.1. Transmission Visual (Ground/Aerial) Inspection Program ................................... 53
7.4.2. Transmission Detailed Visual Inspection Program ............................................... 53
7.4.3. Transmission Thermal Imaging (Infrared) Inspections ......................................... 54
7.4.4. Transmission Cathodic Protection and Inspection Program ................................ 54
7.5. Distribution Inspection and Asset Management Programs .......................................... 54
7.5.1. Visual Inspection ................................................................................................. 54
7.5.2. Line Equipment Inspection Program ................................................................... 55
7.5.3. Detailed Inspection Program ............................................................................... 55
7.5.4. Thermal Imaging (Infrared) Inspections ............................................................... 55
7.5.5. Pole Attachments ................................................................................................ 56
8.Methods of Line Design ......................................................................................................... 57
8.1. Overview ...................................................................................................................... 57
8.2. Siting and Design of New Transmission Lines ............................................................... 57
8.2.1. Transmission Steel Poles ..................................................................................... 57
8.3. Transmission Line Rebuild Projects .............................................................................. 58
Idaho Power Company Wildfire Mitigation Plan 2027
Page iv
8.3.1. Targeted Structural Reinforcement ..................................................................... 58
8.4. Distribution Investments .............................................................................................. 58
8.4.1. Overhead Primary Hardening Program ............................................................... 59
8.4.2. Overhead to Underground Conversion ............................................................... 61
8.4.3. New Underground Construction ......................................................................... 62
8.4.4. Feeder Segmentation .......................................................................................... 62
9.Vegetation Management ...................................................................................................... 65
9.1. Overview ...................................................................................................................... 65
9.2. Program Components .................................................................................................. 66
9.2.1. Vegetation Risk Identification .............................................................................. 66
9.2.2. Vegetation Mitigation .......................................................................................... 66
9.2.3. Vegetation Mitigation Activity Schedule ............................................................. 67
9.2.4. Fair Market Value of Timber ................................................................................ 69
9.3. Transmission Vegetation Inspection and Management ............................................... 69
9.3.1. Transmission Vegetation Wildfire Mitigation Patrol and
NERC/WECC Patrol .............................................................................................. 69
9.3.2. Transmission Line Clearing Cycles ....................................................................... 69
9.3.3. Transmission Line Clearing Quality Control and Assurance ................................. 70
9.4. Distribution Vegetation Inspection and Management ................................................. 70
9.4.1. Distribution Vegetation Inspections: Wildfire Mitigation Patrol/Pruning ............ 70
9.4.2. Distribution Line Clearing Cycles ......................................................................... 70
9.4.3. Distribution Line Clearance Distances ................................................................. 71
9.4.4. Distribution Line Quality Control and Assurance ................................................. 71
9.5. Pole Clearing of Vegetation .......................................................................................... 71
10. Additional Preventative Actions and Programs ..................................................................... 73
10.1. Wildfire Suppression and Response ............................................................................. 73
10.2. Wood Pole Mesh Wrap ................................................................................................ 73
10.3. Pilot Projects ................................................................................................................ 74
Idaho Power Company Wildfire Mitigation Plan 2027
Page v
10.3.1. Standby Helicopter Services: Pre- and Post-Event Inspections (Pilot) ................. 74
10.3.2. Wildfire Resilience Partnerships and Fuels Reduction Shared
Stewardship (Pilot) .............................................................................................. 74
10.3.3. Line Monitoring Technology (Pilot) ..................................................................... 75
10.3.4. Covered Conductor (Pilot) ................................................................................... 75
10.3.5. 3-D Pole Loading (Pilot) ....................................................................................... 75
10.3.6. High Impedance Relay Protections (Pilot) ........................................................... 76
10.3.7. UAS Aerial Inspection (Pilot) ................................................................................ 76
11. Public Outreach and Engagement ......................................................................................... 77
11.1. Objective ...................................................................................................................... 77
11.2. Community Engagement .............................................................................................. 77
11.2.1. Public Safety Partners .......................................................................................... 77
11.2.2. Critical Facilities ................................................................................................... 78
11.2.3. Customers ........................................................................................................... 78
11.3. Event-Specific Communication ..................................................................................... 79
11.4. Key Communication Methods ...................................................................................... 79
11.5. Timing of Outreach ....................................................................................................... 79
11.6. Idaho Power Internal Communications—Employees ................................................... 80
12. Government, Industry, and Peer Utility Outreach ................................................................. 81
12.1. Objective ...................................................................................................................... 81
12.2. Government Engagement ............................................................................................ 81
12.3. Industry and Peer Utility Engagement .......................................................................... 81
13. Performance Monitoring ....................................................................................................... 83
13.1. WMP Compliance ......................................................................................................... 83
13.2. Annual Review and Compliance Reporting ................................................................... 83
13.3. 2026 Lessons Learned .................................................................................................. 83
13.3.1. Community Outreach and Engagement .............................................................. 83
13.3.2. Aerial Inspections ................................................................................................ 86
Idaho Power Company Wildfire Mitigation Plan 2027
Page vi
13.3.3. PSPS Event Management Tools and Exercise ...................................................... 86
13.3.4. Internal Vegetation Management Crew .............................................................. 87
13.3.5. Wildfire Operational Response Team .................................................................. 87
13.3.6. Helicopter Standby Pilot ...................................................................................... 87
14. WMP Cost Summary ............................................................................................................. 89
List of Tables
Table 1
Overhead transmission and distribution line mileage and substations by state* ...................... 5
Table 2
Idaho Power’s overhead transmission and distribution lines by risk zone in Idaho and
Montana ................................................................................................................................... 17
Table 3
Safety, reliability, and resilience co-benefits of wildfire mitigation initiatives ......................... 25
Table 4
Typical reasons for selection by mitigation alternative ............................................................ 28
Table 5
Overview of T&D inspection programs .................................................................................... 51
Table 6
Idaho Power overhead distribution primary hardening program methods .............................. 60
Table 7
Vegetation Management Program initiatives and schedules ................................................... 68
Table 8
Idaho Power’s 2026 WMP outreach efforts ............................................................................. 84
Table 9
Estimated O&M expenses for wildfire mitigation, $000s ......................................................... 89
Table 10
2026 WMP forecasted capital investments, $000s* ................................................................ 90
List of Figures
Figure 1
Idaho Power service area ........................................................................................................... 3
Idaho Power Company Wildfire Mitigation Plan 2027
Page vii
Figure 2
Wildfire risk-based methodology ............................................................................................... 9
Figure 3
Risk zone evaluation and determination process prior to 2027 ............................................... 13
Figure 4
Risk zone evaluation and determination process ..................................................................... 16
Figure 5
Idaho Power wildfire risk zones within Idaho ........................................................................... 18
Figure 6
Idaho Power WMP risk management framework .................................................................... 21
Figure 7
Risk bow-tie diagram ................................................................................................................ 22
Figure 8
Potential mitigation selection benefits .................................................................................... 28
Figure 9
FPI categories ........................................................................................................................... 32
Figure 10
Green-Up component of FPI .................................................................................................... 32
Figure 11
Fuels Component of FPI ........................................................................................................... 33
Figure 12
Weather Component of FPI ...................................................................................................... 34
Figure 13
Pole-mounted fire weather station .......................................................................................... 35
Figure 14
Idaho fire weather station map. Idaho Power does not have any company-owned
weather stations in Montana, as it does not have any wildfire risk zones located in
Montana. Idaho Power utilizes third-party weather stations for situational awareness
in Montana. .............................................................................................................................. 36
Figure 15
Idaho wildfire detection camera interoperability ..................................................................... 38
Figure 16
Idaho Power crews working to replace poles damaged by a wildfire during 2026
wildfire season. ........................................................................................................................ 73
Idaho Power Company Wildfire Mitigation Plan 2027
Page viii
List of Appendices
Appendix A
Wildland Fire Preparedness and Prevention Plan
Appendix B
Wildfire Public Safety Power Shutoff Plan
Appendix C
Wildfire Risk Zone Map Book
Appendix D
Idaho and Montana Requirements and Recommendations Crosswalk
Appendix E
Idaho Power Transmission Line Map Book
Appendix F
Wildfire Mitigation Activities and Cost Forecast 2027–2029
Appendix G
Grid Hardening List
Appendix H
Average Mitigation Project Costs (Confidential)
Appendix I
Glossary of Terms

1Introduction
Section
Idaho Power Company Wildfire Mitigation Plan 2027
Page 1
1. Introduction
1.1. Overview
Idaho Power is focused on the safety of its customers and communities and safely delivering
reliable, affordable energy. The purpose of Idaho Power’s Wildfire Mitigation Plan (WMP) is to
guide mitigation strategies and reduce risk. The company’s WMP identifies methods and means
for mitigating wildfire risk that reflect a reasonable balancing of mitigation costs with the
resulting reduction of wildfire risk.
1.2. Background
In recent years, the western United States has experienced an increase in the frequency and
intensity of wildland fires (wildfires). A variety of factors have contributed to this trend,
including changing climatic conditions, increased human encroachment in wildland areas,
historical land management practices, and changes in wildland and forest health. While Idaho
has not experienced wildfires of the same magnitude as some other western states, 1
warmer temperatures, reduced snowpack, and earlier snowmelt contribute to drier conditions,
impacting the period of heightened wildfire risk.2
Idaho’s wildfire season is defined by Idaho Code § 38-115 as extending from May 10 through
October 20 each year, or as otherwise extended by the director of the Idaho Department of
Lands (IDL). For example, in 2024, the director extended wildfire season to November 1, 2024.3
Montana’s wildfire season is defined by Montana Code § 76-13-102 as the period of each year
beginning May 1 and ending September 30. Similarly, Montana’s wildfire season can be
extended by the Montana Department of Natural Resources and Conservation pursuant to
Montana Code § 76-13-203.
1.3. Idaho Power Profile and Service Area
Idaho Power, headquartered in Boise, Idaho, is an investor-owned utility engaged in the
generation, transmission, and distribution of electricity. Idaho Power is regulated by the Federal
Energy Regulatory Commission (FERC) and the state public utility commissions of Idaho and
Oregon. Idaho Power’s service area includes 24,000 square miles across southern Idaho and
eastern Oregon, with approximately 19,255 square miles of that service area in Idaho (Figure 1).
1 Wildland Fire Summaries 2019-2025. https://www.nifc.gov/fire-information/statistics Accessed May 28, 2026.
2 Western Fire Chiefs Association. Idaho Fire Season: In-Depth Guide | WFCA Accessed May 28, 2026.
3 News Release: Idaho Department of Lands Extends Closed Fire Season Due to Persistent Wildfire Risks/News
Release: Idaho Department of Lands Extends Closed Fire Season Due to Persistent Wildfire Risks
Idaho Power Company Wildfire Mitigation Plan 2027
Page 2
The company serves more than 660,000 customers, approximately 640,000 of which reside
in Idaho. 4
4 On June 30, 2026, Idaho Power applied to the Idaho Public Utilities Commission for an order approving a proposed sale and transfer of Idaho
Power’s Oregon retail service territory to Oregon Trail Electric Consumers Cooperative (OTEC). At the time of this WMP’s submission to the
Idaho Public Utilities Commission, the proceeding concerning the transaction between Idaho Power and OTEC remains ongoing in Case No.
IPC-E-26-21.
Idaho Power Company Wildfire Mitigation Plan 2027
Page 3

Figure 1
Idaho Power service area
Idaho Power Company Wildfire Mitigation Plan 2027
Page 4
1.4. Asset Overview
Idaho Power delivers electricity to customers via 258 substations, approximately 4,661 miles of
overhead transmission5 lines, and approximately 19,295 miles of overhead distribution lines.
Approximately 80% of Idaho Power’s transmission line assets are in Idaho and approximately
1% are in Montana. Roughly 89% of Idaho Power’s distribution line assets are in Idaho. Table 1
summarizes the overhead powerline asset information by state.
5 Refers to all lines at or above 46kV unless otherwise noted.
Idaho Power Company Wildfire Mitigation Plan 2027
Page 5
Table 1
Overhead transmission and distribution line mileage and substations by state*
Asset—OH** Line Miles
Total Idaho Oregon Montana Nevada Wyoming
Line Miles Line Miles % Line Miles % Line Miles % Line Miles % Line Miles %
46 kV Transmission Lines 368 368 100.0% 0.00%
69 kV Transmission Lines 1,022 670 65.5% 303 29.6% 49 4.8%
115 kV Transmission Lines 3 3 100.0%
138 kV Transmission Lines 1,452 1,245 85.7% 142 9.8% 65 4.5%
161 kV Transmission Lines 85 85 100.0% 0.00%
230 kV Transmission Lines 1,148 933 81.3% 215 18.7%
345 kV Transmission Lines 472 362 76.7% 0.00% 110 23.30%
500 kV Transmission Lines 100 52 52.0% 48 48.0%
Total OH Transmission
Lines 4,650 3,715 79.9% 711 15.3% 49 1.10% 65 1.40% 110 2.40%
Total OH Distribution Lines 19,288 17,199 89.2% 2,089 10.8%
Total OH Line Miles 23,938 20,914 87.4% 2800 11.7% 49 0.20% 65 0.30% 110 0.50%
Asset—Substations
Total Idaho Oregon Montana Nevada Wyoming
Substations Substation
s % Substations % Substations % Substations % Substations %
Total # Substations 258 227 88.00% 29 11.2% 1 0.4% 1 0.4% 0 0
*OH line miles contained in this table are approximate and encompass Idaho Power-owned lines. Further, the total number of substations includes Idaho Power-owned facilities and excludes
cogen, interconnects, and generation facilities.
** OH refers to overhead lines.
Idaho Power Company Wildfire Mitigation Plan 2027
Page 6
1.5. Legal and Regulatory Context
As required by the Wildfire Standard of Care Act (WSCA), Idaho Code § 61-1801 et seq.,
with respect to the Idaho portion of the plan, Idaho Power has filed for approval of this Idaho
and Montana 2027 WMP with the Idaho Public Utilities Commission (IPUC). Idaho Code
§ 61-1803 codifies the specific elements required to be documented within a WMP. The IPUC
has also issued orders governing filing requirements for Idaho Power’s WMP as detailed in
Appendix D. This WMP complies with all applicable requirements.
Further, pursuant to Montana Code Section 69-2-302, Idaho Power intends to file this WMP
with its statutory “approval authority,” as the appropriate body responsible for its corporate
governance. Montana Code Section 69-2-302 establishes requirements for the WMP as to the
Montana portion of this plan.
While Idaho Power’s inaugural WMP, covering the company’s Idaho and Oregon service areas,
was submitted to the IPUC in 2021, Idaho Power filed its first Idaho and Montana 2026 WMP
pursuant to the WSCA with the IPUC on October 10, 2025. With respect to the Idaho portion of
this plan, Idaho Power’s Idaho and Montana 2026 WMP was approved by the IPUC on April 14,
2026, through Order No. 37004. Additionally, Idaho Power’s Idaho and Montana 2026 WMP
was submitted and approved in accordance with Montana Code Section 69-2-302, with final
approval occurring on May 20, 2026.
1.6. Summary of Idaho Power’s Plan for Mitigating Wildfire Risk
Idaho Power’s approach to mitigating wildfire risk is designed to protect the public interest,
reflect the size and complexity of Idaho Power’s operations, and consider the specific wildfire
risks present within the areas in Idaho and Montana where Idaho Power has infrastructure or
equipment. The WMP is built around the following key components, which are detailed in
subsequent sections.
• Geographical Risk Assessment. Idaho Power uses a risk-informed approach that
considers wildfire probability and consequence to identify zones that may be subject to
potential heightened wildfire risk in areas where Idaho Power has infrastructure
and equipment.
• Mitigation Approach. The company employs a risk-informed cost and benefit balancing
approach to select and prioritize wildfire mitigations carried out to reduce the risk of
wildfire, such as the following:
• Situational awareness capabilities;
• Workforce preparedness;
• Operational practices, including Enhanced Powerline Safety Settings (EPSS);
Idaho Power Company Wildfire Mitigation Plan 2027
Page 7
• Asset management and inspection programs;
• System hardening and other line design strategies;
• Vegetation management around electric infrastructure;
• Additional preventative actions and programs;
• Customer and stakeholder communication and outreach; and
• Coordination with government agencies, industry groups, and peer utilities
• Performance Monitoring. Idaho Power monitors program performance and compliance.
In this document, Idaho Power lays out its intended wildfire mitigation efforts for 2027.
All plans identified by Idaho Power are subject to change due to operational experience or
factors beyond Idaho Power’s control, including emergencies, adverse weather,
unplanned events, permitting or contracting delays, supply chain issues, or acts of God.
This plan covers Idaho Power’s WMP efforts in both Idaho and Montana during 2027. A new
plan will be filed annually that contains requirements for the corresponding year.

Idaho Power Company Wildfire Mitigation Plan 2027
Page 8

2Geographical Risk Assessment
Section
Idaho Power Company Wildfire Mitigation Plan 2027
Page 9
2. Geographical Risk Assessment
2.1. Objective
Idaho Power’s approach to wildfire risk mitigation begins with assessing geographic wildfire risk
through both quantitative and qualitative methods. These assessments identify geographic
areas where Idaho Power has infrastructure or equipment the company considers may be
subject to a heightened risk of wildfire. These areas are identified as wildfire risk zones,
and mitigation programs and actions are prioritized for those areas.
2.2. Identifying Areas of Heightened Wildfire Risk
Idaho Power’s identification of heightened areas of wildfire risk begins with its understanding
of the concepts underlying the assessment.
Wildfire risk is the potential for wildfire hazard to impact values within a geographic area.
Values are resources (natural) and assets (human-made). Wildfire risk exists only when wildfire
hazard has the potential to impact values. Therefore, Idaho Power’s understanding of wildfire
risk is consistent with conventional definitions of risk—an event’s probability multiplied by its
potential negative consequences or impacts should that event occur as illustrated in Figure 2.
Conversely, wildfire hazard refers to the likelihood and potential intensity of wildfire,
regardless of the presence of values at risk. Idaho Power's geographic risk assessment considers
wildfire risk and wildfire hazard in developing its wildfire risk zones.

Figure 2
Wildfire risk-based methodology

Idaho Power Company Wildfire Mitigation Plan 2027
Page 10
Each component is defined as follows:
• Wildfire Probability. Wildfire probability evaluates whether the landscape is conducive
to ignition and spread (i.e., whether the landscape can support an ignition).
For purposes of Idaho Power's wildfire risk assessment, modeled wildfire volume
(i.e., spatial integral of wildfire area and flame length) serves as a proxy measure for
wildfire probability and potential growth. Data inputs used in the fire spread model to
determine the wildfire volume include historical weather, historical wildfire occurrence,
topography, fuel type, and fuel moisture content.
• Consequence. Estimation of potential wildfire impacts under fire spread simulations to
specific values, such as residences, population, and acreage.
• Wildfire Risk. As discussed above, wildfire risk is wildfire probability multiplied by the
consequence. The highest wildfire risk areas are those where both the wildfire
probability and consequence are elevated. Combinations of low wildfire probability and
elevated consequence, or elevated wildfire probability and low consequence,
typically indicate lower wildfire risk.
The company’s geographic risk modeling focuses on overhead transmission and distribution
(T&D) facilities. Consistent with the WSCA, these facilities are infrastructure or equipment the
company considers may be subject to a heightened risk of wildfire given their location in areas
where underlying vegetation and landscape conditions may influence wildfire ignition and
spread.6 Utility facilities such as power plants, substations, power storage facilities, and office
buildings do not have the same locational considerations and therefore are not specifically
analyzed in Idaho Power’s geographic modeling process. However, power plants, power storage
facilities, and substations are typically interconnected with transmission and distribution lines.
This means that, when the interconnection point is located over areas that the risk modeling
software perceives as susceptible to wildfire ignition and spread, they are indirectly reflected in
Idaho Power’s geographic risk assessment.
Recognizing that wildfire risk is inherently dynamic, Idaho Power evaluates, and, where
appropriate based on its analysis, updates its geographic risk assessment annually to reflect
changing conditions and emerging information.
2.2.1. Wildfire Risk Model Processes
As part of its wildfire risk-modeling process, Idaho Power works with external consultants that
specialize in assessing and quantifying utility-related wildfire risk.
Beginning in 2026, Idaho Power began the transition process of updating its identification of
geographical areas of heightened wildfire risk from those identified using a prior geospatial

6 Though “wildfire” is not defined in the WSCA, entities that specialize in firefighting typically define wildfire in relation to the area in which the
fire burns—specifically the “wildland”.
Idaho Power Company Wildfire Mitigation Plan 2027
Page 11
wildfire risk model to those identified using a new geospatial wildfire risk model—Technosylva.
This transition maintains consistency with the company’s overall wildfire risk framework while
using the data and analytics available through Technosylva. Idaho Power intends this transition
to be iterative. Thus, for 2027, Idaho Power has maintained its existing geographic
identifications of areas of heightened wildfire risk (its existing wildfire risk zones) and added
certain additional areas of identified heightened wildfire risk. Idaho Power intends to utilize the
data and analytics available through Technosylva to continue refining its identification of
geographic areas of heightened wildfire risk in areas where it has assets and equipment,
which may result in changes to Idaho Power’s wildfire risk zones in future WMPs.
2.2.1.1. Wildfire Risk Zone Development Process
The processes by which Idaho Power arrived at 1) the development of its existing wildfire risk
zones and 2) the 2027 wildfire risk zone modifications are described in detail below.
2.2.1.2. Wildfire Risk Modeling Process Prior to 2027
The geospatial wildfire risk model outputs originally received by Idaho Power that form the
basis for Idaho Power’s continued wildfire risk zones were developed using the following
major steps:
1. A 12-year fire weather climatology was developed using the Weather Research and
Forecasting (WRF) model to recreate historical days of fire weather significance in
geographic areas where Idaho Power has infrastructure and equipment.
This analysis generated high-resolution hourly gridded fields of relative humidity,
temperature, dead fuel moisture, and wind speed/direction that was used as input
to a Monte Carlo-based fire modeling analysis.
2. Estimates of seasonal variation in live fuel moisture across areas where Idaho Power
has infrastructure and equipment were developed. This was accomplished by
analyzing historical fuel measurements and/or weather station observations.
This step was necessary because live fuel moisture data is needed for fire spread
modeling, but the WRF weather model does not provide live fuel moistures.
3. The federal LANDFIRE program was used to provide high-resolution (30 meter/
approximately 100 feet) fuel rasters for use in fire spread modeling.7
4. The data developed above (WRF climatology, live fuel moisture, and LANDFIRE data)
was used to drive a Monte Carlo8 fire spread modeling analysis. This Monte Carlo
simulation was accomplished by randomly selecting an ignition location and a day
from the fire weather climatology developed in step 1 above. Ignition locations were
limited in the model to be within a 240-meter (m) buffer surrounding Idaho Power’s
overhead T&D lines (i.e., 120 m on either side). The model used equal ignition

7 Lautenberger, C.W., “Mapping areas at elevated risk of large-scale structure loss using Monte Carlo simulation and wildland fire modeling,”
Fire Safety Journal 91: 768–775 (2017). https://doi.org/10.1016/j.firesaf.2017.04.014
8 Ibid.
Idaho Power Company Wildfire Mitigation Plan 2027
Page 12
probability for all overhead distribution and transmission asset types.9
Urbanized areas having underground circuitry were not included in the model due to
a low probability of wildfire associated with underground electrical equipment.
For each combination of ignition location and time of ignition, fire progression was
then modeled for 12 hours. For each modeled fire, potential fire impacts to
structures were quantified using structural location data. This was repeated for
millions of combinations of ignition location and time of ignition.
5. The Monte Carlo results were processed, and geographic information system
(GIS)based data depicting wildfire risk was developed. This risk was then illustrated
using GIS-based wildfire risk maps.
2.2.1.3. Wildfire Risk Zone Establishment Process Prior to 2027
Based on the previously described modeling processes, draft risk tiers were generated using the
Jenks optimization method to bin the resulting risk model data, reflecting risk relative to the
modeled areas. Jenks optimization is a data classification method commonly used to determine
the best arrangement of values into different classes while seeking to minimize each class’s
average deviation from the class mean and maximizing each class’s deviation from the means
of the other groups. The draft tiers were then considered by Idaho Power in conjunction with
qualitative factors in establishing Idaho Power’s wildfire risk zones depicted in the 2026 WMP.
This consideration process is detailed in Figure 3.

9 All transmission and distribution lines owned and operated by Idaho Power and jointly owned assets were included in the analysis.
Furthermore, the proposed Boardman to Hemingway (B2H) 500-kV line route was also included in this analysis.
Idaho Power Company Wildfire Mitigation Plan 2027
Page 13
Figure 3
Risk zone evaluation and determination process prior to 2027
Idaho Power also considered learnings gained from attending Local Emergency Planning
Committee meetings related to suppression capabilities, ingress/egress routes, and localized
factors that may influence fire regime, as well as learnings from peer utilities in developing its
continued wildfire risk zones.
2.2.2. 2027 Wildfire Risk Zone Modeling and Validation
2.2.2.1. New Geospatial Risk Model
Idaho Power has begun the process of transitioning to Technosylva’s Wildfire Risk Analyst
Enterprise (WFA-E) platform using Technosylva’s FireSight consequence model output for its
new geospatial wildfire risk model.
FireSight performs millions of wildfire simulations under a broad range of historical weather
and fuel conditions to estimate potential wildfire behavior and consequences.
These simulations estimate the potential impacts associated with an ignition occurring at
specific utility assets at the feeder, sub-feeder, and segment level. The FireSight consequence
model outputs received by Idaho Power are developed using the following major steps:
1.A 20-year historical fire weather climatology was developed using the 600 most
significant fire weather days occurring between 2004 and 2024 to represent the
Idaho Power Company Wildfire Mitigation Plan 2027
Page 14
range and frequency of wildfire-conducive weather conditions across Idaho Power’s
service area. Weather conditions were modeled at a 2 kilometer (km)
spatial resolution.
2. Projected future vegetation and fuel conditions representing the year 2030 were
incorporated using LANDFIRE-derived fuel datasets at a 30 m spatial resolution.
3. Exposure modeling included supplemented Microsoft Buildings footprint data and
OpenStreetMap (OSM) data to represent estimates of potential structure impacts.
4. Fire spread potential was modeled for overhead transmission and distribution
infrastructure using ignition locations placed at approximately 100-m intervals along
utility assets.
5. Fire behavior simulations were conducted using an eight-hour fire duration.
Each simulation represents a unique combination of specific input conditions,
including wind speed, wind direction, fuel moisture, temperature, and relative
humidity. Simulations were initiated at 2 p.m. Mountain Time to approximate the
period of the day when fire behavior is often most active within Idaho Power’s
service area.
6. Hundreds of fire spread simulations were performed for each ignition location to
characterize the range of potential wildfire outcomes. This approach captures the
variability associated with weather conditions and landscape characteristics.
7. FireSight outputs and risk metrics were processed, both as normalized composite
risk indices and underlying raw values associated with various weather percentiles.
Composite risk scores were based on the 90th percentile weather scenarios based on
a 20-year climatology, representing, on average, approximately 11 annually
significant fire weather days per year.
8. The resulting analysis produces metrics that provides estimated quantification of the
potential consequences of a wildfire, assuming an ignition occurs at a specific
location with an equal probability of ignition across all assets. These metrics serve as
a function of fire spread potential (deterministic fire spread model) and
consequence and thus help to answer the question: “If a wildfire starts at this
location, what could happen?”
Because these metrics focus on wildfire impacts independent of asset condition or ignition
likelihood, they provide a consistent and stable measure of wildfire risk associated with a
geographic area. These factors largely remain consistent over time and give a sense of the
potential consequences of wildfire for long-term planning purposes.10 This allows Idaho Power
to avoid the constant fluctuations that would result from incorporating asset condition,
which changes as assets are repaired, replaced, or hardened, when assessing geographic
wildfire risk.
Idaho Power then used the Immediate Impacts Composite, a metric created by Technosylva and
derived from the above processes that aggregates buildings threatened, population impacted,

10 While asset condition, inspection results, and equipment performance are important inputs to Idaho Power's WMP, the company considers
these factors more appropriately within mitigation prioritization and investment decision-making rather than geographic risk identification.
See Sections 3, 7, and 8 for discussions that address these factors.
Idaho Power Company Wildfire Mitigation Plan 2027
Page 15
and acres burned in a given fire spread simulation, to identify possible areas for further review.
More specifically, areas identified as exceeding the 95th percentile of the Immediate Impacts
Composite were identified for further evaluation and possible zone modifications via the
process described below.
2.2.2.2. Model Validation
Model validation and quality assessment completed by Reax Engineering11 and Technosylva12
involves assessing the performance of fire spread models.
2.2.3. 2027 Wildfire Risk Zone Modification Process
Using the modeling processes described in section 2.2.2, Idaho Power identified possible areas
of zone modifications for further review.
The possible areas for modification were then reviewed for concurrence with nationally
available fire history datasets, including the National Interagency Fire Center (NIFC) Wildland
Fire Interagency Geospatial Services (WFGIS) Incident Points and Perimeters13 and Monitoring
Trends in Burn Severity.14 Wildfire risk characterization was further validated through
comparison with existing federal, state, and local risk assessments, including the United States
Department of Agriculture (USDA) Forest Service Wildfire Risk to Communities15 products,
the Idaho Forest Action Plan16 Fire Hazard Assessment17, and local county-wide Community
Wildfire Protection Plans (CWPP), such as those developed for Elmore18 and Valley19 counties.
The resulting output was used to identify areas for targeted ground review. As with the
development of wildfire risk zones through 2026, Idaho Power relied on ground review and

11 Lautenberger, Chris. 2013. Wildland fire modeling with an Eulerian level set method and automated calibration. Fire Safety Journal, Volume
62, Part C, 2013, Pages 289-298, ISSN 0379-7112, https://doi.org/10.1016/j.firesaf.2013.08.014.
12 Cardil A, Monedero S, SeLegue P, Navarrete MÁ, de-Miguel S, Purdy S, Marshall G, Chavez T, Allison K, Quilez R, Ortega M, Silva CA, Ramirez J.
2023. Performance of operational fire spread models in California. International Journal of Wildland Fire 32, 1492 –1502 .
13 National Interagency Fire Center. WFIGS Fire History Location and Perimeter Services. ArcGIS HUB, WFIGS Fire History | Wildland Fire
Interagency Geospatial Services.
14 USGS EROS and the United States Department of Agriculture, Forest Service GTAC. Monitoring Trends in Burn Severity (MTBS).
https://www.mtbs.gov/ .
15 Scott, Joe H.; Dillon, Gregory K.; Jaffe, Melissa R.; Vogler, Kevin C.; Olszewski, Julia H.; Callahan, Michael N.; Karau, Eva C.; Lazarz, Mitchell T.;
Short, Karen C.; Riley, Karin L.; Finney, Mark A.; Grenfell, Isaac C. 2024. Wildfire Risk to Communities: Spatial datasets of landscape-wide
wildfire risk components for the United States. 2nd Edition. Fort Collins, CO: Forest Service Research Data Archive.
https://doi.org/10.2737/RDS-2020-0016-2
16 Idaho Forest Action Plan: Resource Assessment – July 2020. FINAL_2020-FAP-Resource-Assessment_09-03-20.pdf.
https://www.idl.idaho.gov/about-forestry/shared-stewardship/forest-action-plan/
17 Idaho Department of Lands. Fire Hazard 2025 | No Boundaries Forestry. ArcGIS online.
https://gis1.idl.idaho.gov/portal/apps/sites/#/ssdata/maps/e43a616a03994d4c802f6c05cf6394a7/explore?location=45.192191%2C-
114.630074%2C7.05&path=
18 Elmore County. Elmore County Hazard Mitigation Plan, 2020. https://elmorecounty.org/wp-content/uploads/2022/02/elmore-county-hmp-
cwpp-2020-2021-update-final-draft.pdf
19 Valley County. Valley County Community Wildfire Protection Plan 2025.
https://www.valleycountyid.gov/departments/Wildfire/CommunityWildfireProtectionPlan
Idaho Power Company Wildfire Mitigation Plan 2027
Page 16
subject-matter expert feedback to further refine and identify targeted modifications to Idaho
Power’s existing wildfire risk zones.
Figure 4 summarizes the processes used to establish Idaho Power’s 2027 wildfire risk
zone modifications.
Figure 4
Risk zone evaluation and determination process
Idaho Power Company Wildfire Mitigation Plan 2027
Page 17
2.3. Idaho Power’s Wildfire Risk Zones
Based on the process described above, Idaho Power has identified wildfire risk zones that may
be subject to heightened wildfire risk: Tier 3 and Tier 2 zones. Relative to Tier 2 zones, Tier 3
zones are generally assessed under the process described above as having greater possible
wildfire risk.
Idaho Power’s wildfire risk zones reflect risk relative to the areas modeled by Idaho Power only,
and not absolute geographic/landscape risk.
To aid in customer and public understanding, Idaho Power color-codes the tiers on maps—
yellow for Tier 2 and red for Tier 3. The following two-tier wildfire risk map in Figure 5 is
illustrative of Idaho Power’s Tier 2 and Tier 3 wildfire risk zones (the continuing wildfire risk
zones with the 2027 modifications) that will be utilized in 2027 located in Idaho. Both of Idaho
Power’s geographic risk assessment processes described above determined no wildfire risk
zones near its infrastructure and equipment located in Montana. Table 2 depicts total line miles
of overhead transmission and distribution lines by risk zone in Idaho and Montana.
An illustrative map book of all zones, including 2027 modifications located in Idaho, is included
in Appendix C. Appendix E illustrates the extent of Idaho Power’s transmission system,
including transmission line assets in Montana. A full and up-to-date risk zone map can be
viewed in detail on Idaho Power’s website, and individual addresses can be entered on the map
to determine proximity to identified risk zones.20
Table 2
Idaho Power’s overhead transmission and distribution lines by risk zone in Idaho and Montana
Idaho Power’s overhead transmission and distribution lines by risk zone in Idaho & Montana
Asset Total line
miles
Total line
miles in
wildfire risk
zones
% of total lines
in wildfire risk
zones
Tier 2* Tier 3*
Total line
miles
% All
Lines
Total line
miles
% All
Lines
Transmission Lines (ID) 3,715 363 10% 279 8% 84 2%
Transmission Lines (MT) 49 0 0% 0 0% 0 0%
Distribution Lines (ID) 17,199 1,716 10% 997 6% 719 4%
Distribution Lines (MT) - - - - - - -
Total Line Miles 20,963 2,079 10% 1,276 6% 803 4%
*Except when otherwise indicated, total line mile counts in this WMP encompass Idaho Power-owned lines located in Idaho and Montana
only. The data reviewed by Idaho Power did not support the establishment of any risk zones in Montana in 2027.

20 Idaho Power. Protecting the Grid-Wildfire Risk Zones, accessed August 29, 2025, idahopower.com/outages-safety/wildfire-safety/protecting-
grid/.
Idaho Power Company Wildfire Mitigation Plan 2027
Page 18

Figure 5
Idaho Power wildfire risk zones within Idaho
3Cost Benefi t Approach
Section
Idaho Power Company Wildfire Mitigation Plan 2027
Page 19
3. Cost-Benefit Approach
3.1. Objective
The WSCA requires that Idaho Power perform a reasonable balancing of the costs of mitigation
with reduction of wildfire risk. This section details Idaho Power’s risk-based cost and benefit
approach to selecting wildfire mitigations. Idaho Power’s WMP is designed to reasonably
balance the costs of mitigation activities with the resulting reduction in wildfire risk.
3.2. Risk-Based Cost and Benefit Analysis of Wildfire Mitigation
Idaho Power’s cost-benefit approach to selecting wildfire mitigations starts with understanding
the potential costs of wildfires, assessing drivers of potential wildfire risk, and, finally, using a
variety of strategies to select cost-effective mitigations to reduce wildfire risk.
The recoverable damages in wildfire litigation in Idaho are identified in Idaho Code
§ 61-1806(2). The recoverable damages in wildfire litigation against an electric utility in
Montana are similar and are set out in Montana Code § 69-2-303(5). Wildfire costs can also
include the cost of restoring Idaho Power property.
In assessing the potential consequence of wildfire risk, Idaho Power considered several sources
of data on the costs of major wildfires. Ultimately, Idaho Power found that obtaining a precise
calculation of the potential costs of future wildfires is not possible. Quantifying the precise
costs of wildfires is inherently uncertain because outcomes vary by jurisdiction, weather, fuels,
topography, location, population density, and exposure. Litigation outcomes and community
impacts can also differ widely from event to event. Additionally, while fire suppression costs
can be roughly estimated on a per-acre basis, the actual cost of fire suppression can vary
greatly depending on the same variety of factors.
Nonetheless, publicly available analyses of recent wildfires illustrate the magnitude of potential
avoided costs when prudent mitigation reduces the likelihood or consequences of catastrophic
events. For example, in Idaho, the Moose Fire in 2022—which grew to approximately
130,000 acres—cost approximately $100 million to suppress,21 as did the Pioneer Fire in 2016.22
The Charlotte Fire in Pocatello (2012) destroyed 66 homes; burned approximately 1,038 acres;
and estimates at the time gauged damages at $12 million, though officials noted that timely
response helped protect approximately $472 million in property value.23 In eastern Washington

21 Idaho Rangeland Resource Commission, Steve Stueber, Careless Camper Ignites Moose Wildfire, idrange.org/range-stories/central-
idaho/human-caused-moose-fire-causes-widespread-
impacts/#:~:text=The%20Moose%20Creek%20fire%20ended,fires%20five%20miles%20away%2C%20downwind.
22 Fire Research and Management Exchange System, frames.gov/documents/catalog/calkin_et_al_2016_PioneerFireInquiry.pdf.
23 Debbie Bryce, 3 Years Later – Survivors remember the devastating 2012 Charlotte Fire, Idaho State Journal, June 28, 2015,
idahostatejournal.com/members/3-years-later-survivors-remember-the-devastating-2012-charlotte-fire/article_04fd7bd8-1d64-11e5-bd2f-
ab6d571a8626.html.
Idaho Power Company Wildfire Mitigation Plan 2027
Page 20
in 2023, the Gray and Oregon fires together destroyed over 350 homes and caused
multiple fatalities.24
In more catastrophic events, the costs are exponentially higher. The recovery costs of the Maui
wildfires in 2023 are expected to exceed $12 billion,25 and in California, costs and damages
associated with the 2025 Los Angeles wildfires are estimated between $28 billion and
$53.8 billion.26 The recent Spokane Complex fires of 2026 in Spokane, Washington
destroyed over 800 homes and are estimated to have caused more than $1 billion in damage. 27
This data supports the conclusion that the costs of Idaho Power’s wildfire mitigation efforts,
summarized in Section 14 below, are reasonable investments to avoid the potential costs
associated with wildfire.
3.3. Risk Analysis and Drivers
Idaho Power’s next step in selecting cost-effective mitigations is to understand potential
wildfire risk drivers. Idaho Power’s risk management framework is reflected in the six distinct
steps summarized in Figure 6.

24 ArcGIS StoryMaps, Gray and Oregon Wildfires, storymaps.arcgis.com/stories/9a77e2ece6d6421ebc9c6a60635742c8.
25 Kevin Knodell, Overall costs for the Maui wildfires are expected to top $12 billion, The Star Advertiser, November 21, 2024,
staradvertiser.com/2024/08/10/hawaii-news/overall-costs-for-maui-wildfires-are-expected-to-top-12-billion.
26 Matt Horton et al., Impact of 2025 Los Angeles Wildfires and Comparative Study, Institute for Applied Economics, February 2025,
LAEDC_2025-LA-Wildfires-Study_090525-UPDATE.pdf
27 Thomas Clouse, Spokane fire damages will exceed $1 billion, The Spokesman Review,
https://www.spokesman.com/stories/2026/aug/21/spokane-fire-damages-will-exceed-1-billion/
Idaho Power Company Wildfire Mitigation Plan 2027
Page 21

Figure 6
Idaho Power WMP risk management framework
The risk management framework provides Idaho Power with a structured approach to wildfire
mitigation planning by enabling systematic identification, assessment, and management of
wildfire risk. While not all risk can be eliminated, Idaho Power’s goal with its WMP is to
proactively prepare and enhance its infrastructure and operational practices to prepare for and
address wildfire risk. The company continues to work to identify, analyze, evaluate, mitigate,
and monitor risks associated with wildfire.
Using this risk management framework, Idaho Power gathered information from internal
subject-matter experts regarding potential ignition risk drivers and developed a risk bow-tie
diagram, shown in Figure 7, as a visual representation of equipment-specific wildfire ignition
risks, including key drivers, scenarios, likelihood, and potential impacts.
Idaho Power Company Wildfire Mitigation Plan 2027
Page 22
Figure 7
Risk bow-tie diagram
The bow-tie analysis considers the risk exposure across all Idaho Power-owned and operated
overhead T&D facilities. The bow-tie is constructed using the following three components.
•The Triggering Event: The event Idaho Power aims to avoid that could
impact the company’s ability to meet its objectives of providing safe, reliable,
and affordable energy.
•Risk Drivers: Factors that may potentially lead to an ignition are listed on the left side of
the bow tie. Actual conditions play a key role in whether a wildfire occurs because of an
ignition, and it is important to note the risk drivers shown are only an indication a risk
event may occur.
•Contact from a foreign object—Contact with foreign objects, including vegetation,
animals, balloons, and other wind-blown objects.
•Equipment failure—The unexpected failure of line equipment due to discrete
(internal) or destructive (external) conditional changes.
•Environmental—Extreme weather conditions that include high wind, low humidity,
and drought, which contribute to increasing risk of wildfire.
Idaho Power Company Wildfire Mitigation Plan 2027
Page 23
• Other—Overhead powerlines may be at risk of vandalism or physical attack.
Construction activities, including activities performed by sub-contractors,
near overhead power lines may be a risk driver if proper safety precautions are not
taken to eliminate inadvertent equipment contact.
• Risk Impacts: While most wildfires are extinguished quickly, the right side of the bow-tie
describes the range of possible outcomes associated with the risk event. Impacts vary
largely based on where and when the event occurs and actual conditions. The impacts
shown are worst-case scenarios.
Based on the results of this consultation, Idaho Power has identified the risk drivers shown in
the risk bow-tie. Of these, Idaho Power focuses its efforts on selecting cost-effective mitigations
to address key risk drivers. Additionally, the company annually assesses information gathered
by the wildfire mitigation team pertaining to risk drivers, including information from ignition
tracking efforts and operational experience, and evaluates chosen mitigations.
3.4. Mitigation Selection
Idaho Power’s mitigation selection is informed by its risk driver identification and its
identification of wildfire risk zones. This approach allows Idaho Power to direct its mitigations
toward the geographic areas and infrastructure that may be subject to heightened wildfire risk
and to employ mitigations that are most likely to achieve a reduction in wildfire risk. Each type
of mitigation employed by Idaho Power is designed to reduce one or more of the risk driver
frequencies and/or minimize the potential impacts or outcomes.
Idaho Power’s approach to selecting mitigations for wildfire risk encompasses a variety of
factors, including geographical risk assessment; reasonable balancing of cost and efficacy;
benchmarking and discussions with peer utilities; consultation with government entities and
agencies; and consideration of potential alternatives.
To achieve risk reduction that reasonably balances mitigation costs against mitigation
effectiveness, the company typically applies one or more of the following strategies, as it
deems appropriate, in selecting mitigations to reduce wildfire risk drivers:
1. Risk-informed planning and prioritization. Mitigation is generally prioritized to
circuits and segments with the highest wildfire consequence and exposure;
sequencing work where potential safety and reliability benefits are expected to
be greatest.
2. Alternatives analysis. For each mitigation, when reasonable and possible,
Idaho Power evaluates feasible alternatives, including materials, configurations,
and operating practices, and selects the mitigation that reflects a reasonable
balancing of cost with risk reduction.
3. Vendor and delivery evaluation. For technology enablement, the company
evaluates vendor platforms against internal/contracted builds and chooses the
Idaho Power Company Wildfire Mitigation Plan 2027
Page 24
cost-effective delivery path that provides required functionality and integration
while minimizing ongoing lifecycle costs.
4. Procurement discipline. Competitive sourcing, phasing, and scrutiny are used to
validate performance and cost.
5. Strategic reliance on pilot projects. Pilot projects are used to calibrate benefits
relative to cost, labor, and time. This allows Idaho Power to assess the learnings
associated with each pilot project and, when Idaho Power deems appropriate,
make a case-by-case determination as to whether to scale up that program,
which will be determined in future WMPs.
6. Performance monitoring and adaptive management. Idaho Power tracks
implementation performance outcomes, such as outage and ignition metrics,
customer outage impacts, and operational lessons learned; results inform future
scope to maintain cost-effectiveness over time.
7. Targeted deployment of operational mitigations. Operational mitigations are
deployed to reduce duration and extent of customer impacts while reducing
wildfire risk.
8. Leveraging existing operations to reduce wildfire risk. Idaho Power works to build
on existing processes, systems, and personnel, when possible, to deploy wildfire
mitigation strategies, including by augmenting existing processes with
new technology.
9. Leveraging partnership access and dollars to reduce wildfire risk. Idaho Power
partners with other entities on wildfire mitigation strategies, such as fuels
management and wildfire detection camera deployment, to achieve risk mitigation
benefits at reasonable costs for customers.
By generally using the process and strategies described above when selecting mitigation
measures to reduce wildfire risk, Idaho Power believes the mitigations identified in this
2027 WMP reflect a reasonable balancing of mitigation costs with the resulting reduction of
wildfire risk.
Idaho Power applies these principles across the wildfire mitigation programs described
throughout this WMP. For infrastructure mitigation projects primarily driven by wildfire risk
reduction, Idaho Power further applies the Risk-Informed Mitigation Evaluation Framework
described in Section 3.5 to support project-specific evaluation and selection.
In this WMP, Idaho Power introduces and discusses its wildfire mitigations in detail as follows:
• Situational awareness and monitoring efforts (Section 4)
• Workforce preparedness (Section 5)
• Line operation practices (Section 6)
• Infrastructure inspection and asset management (Section 7)
Idaho Power Company Wildfire Mitigation Plan 2027
Page 25
•Methods of line design, including system hardening strategies (Section 8)
•Vegetation management efforts (Section 9)
•Additional preventative actions and programs (Section 10)
•Public outreach and engagement (Section 11)
•Government, industry, and peer utility outreach (Section 12)
•Performance monitoring (Section 13)
Notably, while mitigations are primarily intended to reduce the risk of wildfire, co-benefits—
such as increased safety, reliability, and resiliency of the system—may also be achieved
(Table 3).
Table 3
Safety, reliability, and resilience co-benefits of wildfire mitigation initiatives
Wildfire Mitigation Safety Reliability Resiliency
Defined as the potential to
pose a danger, risk, or
injury to life or property
Defined as the ability of
the power system to
withstand instability,
uncontrolled events,
cascading failures, or
unanticipated loss of
system components
Defined as the ability for
the grid system to adapt
to, withstand, and quickly
recover from disruptive
events or changes within
the surrounding
environment
Situational Awareness and Monitoring X X X
Operational Practices X
Asset Inspections X X
System Hardening—Overhead X X X
System Hardening—Underground X X X
Vegetation Management X X
Geographic Risk Assessment X
Public Outreach and Engagement X
3.5. Risk Informed Mitigation Evaluation Framework
3.5.1. Purpose
In 2026, consistent with IPUC Order No. 37004, Idaho Power began developing a Risk-Informed
Mitigation Evaluation Framework (Framework) to support the planning-level evaluation of both
costs and benefits associated with the infrastructure projects primarily driven by wildfire risk
reduction described in Section 8 of this WMP. The Framework is intended to reflect a per-
project cost-benefit analysis demonstrating that each project reasonably balances costs with
Idaho Power Company Wildfire Mitigation Plan 2027
Page 26
reductions in wildfire risk, while also considering other project benefits to Idaho Power and its
customers. The Framework supplements existing Idaho Power project assessment processes; it
does not replace those processes or establish a single determinant for project selection.
The Framework is a generally applicable planning approach rather than a mandatory sequence,
scoring protocol, or representation that every factor or alternative applies to every project.
3.5.2. Relationship to Idaho Power's Wildfire Mitigation Strategy
Idaho Power's wildfire mitigation strategy incorporates multiple layers of mitigations. Thus,
the mitigations described throughout this WMP form the broader context for the application of
the Framework to Section 8’s infrastructure projects.
3.5.3. Framework Overview
The Framework generally consists of three steps: 1) Identify Candidate Locations, 2) Evaluate
Mitigation Alternatives, and 3) Select Mitigation and Document Rationale.
3.5.4. Identify Candidate Locations
Under the first step of the Framework, Idaho Power utilizes a variety of information to identify
candidate locations for further evaluation, such as location within a wildfire risk zone,
modeling outputs based on historical outage rates,28 inspection findings, asset management
information, system planning information, operational experience, and other planning inputs.
Together, these inputs help Idaho Power evaluate potential relative wildfire risk, co-benefits
that might be obtained from a project, and potential mitigation opportunities.
Candidate locations identified may consist of line segments, circuit sections, or other
infrastructure locations exhibiting similar characteristics within a geographic area. Identification
of a candidate location does not require implementation of a project; rather, it identifies
locations that may warrant further evaluation for potential selection. These inputs help inform
project evaluation but do not independently determine project selection.

28 Idaho Power considers outage information as a rough proxy from which to gain a sense of potential equipment-specific ignition risk because
it is the best available data for identifying locations that may warrant further wildfire mitigation evaluation. While Idaho Power does not
have a developed body of ignition data, Idaho Power does have a historical body of equipment-specific outage data that records initial causal
impressions. Idaho Power therefore uses this historical outage data to gain a sense of potential ignition risk at the asset level. However,
Idaho Power recognizes that an outage does not necessarily mean an ignition will occur, as ignitions require both the release of fault energy,
which does not necessarily occur in an outage, and that the released fault energy is sufficient to ignite available fuels under receptive fuel
and weather conditions. Idaho Power, therefore, uses outage information in conjunction with other risk factors when evaluating candidate
project locations.
Idaho Power Company Wildfire Mitigation Plan 2027
Page 27
3.5.5. Evaluate Mitigation Alternatives
For each candidate location identified, Idaho Power evaluates feasible mitigation alternatives.
At this stage, Idaho Power focuses on engineering feasibility. Generally, Idaho Power considers
the following to be available mitigation alternatives for the assessment for feasibility:29
• Overhead hardening
and/or
• Undergrounding
and/or
• Line relocation
Notably, not all alternatives are feasible, necessary, or appropriate in every location.
3.5.6. Select Mitigation and Document Rationale
Mitigation selection is based on project-specific circumstances and a comparison of the benefits
provided by each alternative, as well as potential cost. Idaho Power considers the benefits
listed below in Figure 8 that might be obtained from each alternative. When assessing project
cost, Idaho Power considers the project’s estimated total cost over its expected useful life.

29 Line segmentation is another hardening strategy that Idaho Power employs as a Section 8 distribution mitigation; however, it is not
considered a viable alternative to the above mitigations in the majority of cases.
Idaho Power Company Wildfire Mitigation Plan 2027
Page 28
Figure 8
Potential mitigation selection benefits
Different mitigation alternatives may be appropriate depending on location characteristics,
expected project benefits, implementation requirements, and estimated cost. The purpose of
the evaluation at this stage is to identify the mitigation that provides the most appropriate
combination of benefits relative to cost for the location being evaluated, in Idaho
Power’s determination.
Table 4 summarizes common illustrative reasons why Idaho Power may select a particular
mitigation alternative. The considerations shown are examples only and may vary depending on
project-specific circumstances.
Table 4
Typical reasons for selection by mitigation alternative
Mitigation Alternative Typical Reasons for Selection
Overhead Hardening Wildfire risk reduction, reliability improvements, asset replacement opportunities,
rebuild opportunities, constructability, lower cost, and implementation timeline.
Underground Conversion Enhanced wildfire risk reduction, cost-competitive rebuild opportunities,
constructability, operational benefits, community benefits, critical facility benefits,
evacuation-route considerations, and PSPS reduction.
Idaho Power Company Wildfire Mitigation Plan 2027
Page 29
Mitigation Alternative Typical Reasons for Selection
Line Relocation May be implemented as a stand-alone mitigation or in combination with other
mitigation measures to reduce wildfire risk, improve access, support operational
objectives, address environmental considerations, or provide other location-specific
benefits.
Idaho Power documents the selected mitigation, the primary benefits supporting the project,
the estimated cost, and the reason for the selection.
3.5.7. Future Development
Consistent with IPUC Order No. 37004, Idaho Power intends to continue maturing its project-
specific cost-benefit analysis in 2027 based on learnings obtained from the implementation of
the Framework, as well as other sources of data and information.
Idaho Power Company Wildfire Mitigation Plan 2027
Page 30
4Situational Awareness and Monitoring
Section
Idaho Power Company Wildfire Mitigation Plan 2027
Page 31
4. Situational Awareness and Monitoring
4.1. Overview
Consideration of current and forecasted meteorological conditions, fuel conditions,
and information about wildfire behavior is an aspect of Idaho Power’s wildfire mitigation
strategy. Meteorological and fuel conditions can vary across the locations where Idaho Power
has infrastructure or equipment. Idaho Power monitors forecasted and observed weather data
for the purpose of assessing and responding to current and anticipated wildfire risk. Idaho
Power leverages its internal Atmospheric Science group’s modeling/forecasting capabilities, its
fire weather stations, and publicly available weather/fuel data to develop projections of current
and future wildfire potential in wildfire risk zones. This wildfire potential information is then
available to relevant operations personnel to factor into operational decision-making,
as discussed further below.
4.2. Fire Potential Index
In 2020, Idaho Power developed a Fire Potential Index (FPI) to support operational
decision-making to reduce wildfire threats and risks. The index incorporates data on weather
and fuel conditions (i.e., trees, shrubs, grasses), then converts that data into a numeric forecast
of the short-term fire threat for each of Idaho Power’s wildfire risk zones. The FPI is issued
during wildfire season, for a seven-day period, to provide an operational planning horizon that
informs decision-making based on current and forecasted daily fire potential.
Idaho Power’s FPI is based on original work completed by San Diego Gas and Electric (SDG&E),
the United States Forest Service, and NIFC, and has been modified for Idaho Power’s climate.
Since the original development of the FPI, Idaho Power has continued to enhance its
meteorological data and forecasting capabilities to refine FPI accuracy.
The benefits of developing an internal FPI and enhancing the company’s meteorological
forecasting capabilities include greater situational awareness of Idaho Power’s system during
critical peak summer months. Idaho Power’s situational awareness activities are evaluated
annually, as necessary, to support the company’s wildfire preparedness.
4.2.1. FPI Components
The FPI reflects key variables as follows: the state of grasses and fine fuels (green-up),
woody fuels (ratio of dead fuel moisture to live fuel moisture), and weather (sustained wind
speed and dew point depression). Each of these variables is assigned a numeric value,
and those individual numeric values are summed to generate a fire potential value from 0 to
Idaho Power Company Wildfire Mitigation Plan 2027
Page 32
16, which expresses the degree of fire potential expected for each of the seven days included in
the forecast. The FPI scores are grouped into the following index levels (shown in Figure 9):
•Green: FPI score of 0 through 11 indicates lower potential for a fire to develop and
spread, based on the variable components described below.
•Yellow: FPI score of 12 through 14 indicates an elevated potential for a fire to develop
and spread, based on the variable components described below.
•Red: FPI score of 15 through 16 indicates a higher potential for a fire to develop and
spread, based on the variable components described below.
FPI Categories
Lower Elevated Higher
FPI Range 0 to 11 12 to 14 15 to 16
Figure 9
FPI categories
The state of grasses and fine fuels, or the Green-Up Component, of the FPI is determined using
satellite data for locations within wildfire risk zones. This component is rated on a 0-to-5 scale
ranging from very wet (lush) to very dry (cured). The rating is based on the Normalized
Difference Vegetation Index (NDVI), a satellite‑derived measure of vegetation greenness and
health that ranges from 0 to 1. Lower NDVI values indicate sparse or dry vegetation, and higher
values indicate dense, actively growing vegetation. The inverse relationship between NDVI and
the Green-Up scale is shown in Figure 10.
Figure 10
Green-Up component of FPI
The Fuels Component (FC) of the FPI represents the condition of dead and live woody fuels that
can potentially support wildfire, and is calculated as the ratio of dead fuel moisture to live fuel
moisture using the following relationship:
FC = FD / LFM
In the equation above, FD is the 100-hour dead fuel moisture, and LFM is the live fuel moisture
(expressed as a percentage).
NDVI
Very
Wet/Lush:
1.00 to 0.65
0.64 to 0.60 0.59 to 0.55 0.54 to 0.50 0.49 to 0.40
Very
Dry/Cured
0.39 to 0.00
Score 0 1 2 3 4 5
Green-Up Component
Idaho Power Company Wildfire Mitigation Plan 2027
Page 33
Dead fuel moisture is sourced from GridMET30 (observational data). For 100-hour dead fuel
moisture, current conditions are used directly from GridMET data. Forecasted values are then
calculated using the Nelson31 time-lag model with weather inputs from the Idaho Power
ensemble forecast system discussed further below in Section 4.4, creating a continuous dataset
of observed and forecast dead fuel moisture. These values are scaled to a 1–3 range as the
numerator in the equation above.
Live fuel moisture is derived from indicators of vegetation health based on temperature,
atmospheric dryness, and day length from both GridMET and the Idaho Power ensemble
forecast system. These factors are combined into a daily Growing Season Index (GSI)32 and
averaged over several weeks to represent recent growing conditions. The result is then
converted to a live fuel moisture percentage. This process is applied to both observed and
forecast inputs to capture short- to medium-term changes in live fuels.
The ratio of FD to LFM in the equation above is scaled from 0 to 5 to represent the FC, as shown
in Figure 11.

Figure 11
Fuels Component of FPI
The Weather Component of the FPI is a matrix of sustained wind speed and dew-point
depression using the scale shown in Figure 12. These data are sourced from the WRF products
produced by Idaho Power using its High-Performance Computing (HPC) system as well as other
publicly available national models.

30 Abatzoglou, J. T. (2013), Development of gridded surface meteorological data for ecological applications and modelling. Int. J. Climatol., 33:
121–131. Available at: https://rmets.onlinelibrary.wiley.com/doi/abs/10.1002/joc.3413
31 Nelson, R.M. Jr. (2000). Prediction of diurnal change in 10-h fuel stick moisture content. Canadian Journal of Forest Research, 30(7), 1071–
1087. Available at: https://columbiaweather.com/RPViewDoc.pdf
32 Jolly, W.M., R. Nemani, and S.W. Running (2005). A generalized, bioclimatic index to predict foliar phenology in response to climate. Global
Change Biology, 11(4), 619–632. Available at: https://www.frames.gov/documents/catalog/spa/jolly_nemani_running_2005.pdf
Very Wet Very Dry
0 1 2 3 4 5
Idaho Power Company Wildfire Mitigation Plan 2027
Page 34
Figure 12
Weather Component of FPI
4.3. FPI Review and Evaluation
Idaho Power tracks FPI data year over year. The FPI process is reviewed annually after
completion of the wildfire season. Evaluation of the FPI process is used to assess and validate
Idaho Power’s wildfire preparedness approach.
For the 2026 wildfire season, key refinements focused on the FC of the FPI, specifically fuel
moisture inputs. Previously, this component relied solely on observed GridMET data
(Section 4.2.1). As discussed above, the FC now incorporates forecast-derived fuel moisture
alongside GridMET observations (Section 4.2.1), intending to provide a more dynamic FC.
4.4. Ensemble Forecast System
In 2024, Idaho Power partnered with the National Center for Atmospheric Research (NCAR) to
develop a system that produces multiple custom, high-resolution weather forecast models
throughout the day, referred to herein as the Ensemble Forecast System. After initial
development, Idaho Power created data pipelines that combined the output of these models
with a range of publicly available weather forecast model output. This method allows Idaho
Power forecasters to compare different custom and public model outputs to predict a range of
possible weather scenarios. Through an interactive data viewer, Idaho Power forecasters can
calculate probabilities of the timing, location, and intensity of various weather events,
helping them communicate potential outcomes. For 2027, Idaho Power intends to use the
Ensemble Forecast System as part of its FC calculations for the FPI. Idaho Power may also, at its
discretion, use the Ensemble Forecast System for additional situational awareness purposes.
Dewpoint
Depression/Wind ≤5 mph 6 to 11 mph 12 to 18 mph 19 to 25 mph 26 to 32 mph ≥33 mph
≥50ºF 4 4 4 5 5 6
40ºF to 49ºF 3 3 4 4 5 5
30ºF to 39ºF 3 3 3 4 4 5
20ºF to 29ºF 3 3 3 3 3 4
10ºF to 19ºF 2 2 2 2 2 3
˂10ºF 0 1 1 1 1 2
Idaho Power Company Wildfire Mitigation Plan 2027
Page 35
Idaho Power intends to continue evaluating additional use cases for the Ensemble
Forecast System.
4.5. Fire Weather Stations
Idaho Power’s Atmospheric Science group utilizes both publicly available and company-owned
weather stations to monitor conditions in wildfire risk zones. Due to the limited temporal and
spatial density of public weather station networks, the company has installed additional
stations within and proximal to its wildfire risk
zones.33 Fire weather station placement is on
existing power line poles to reflect real-time
wind conditions at power line height and
provide representative coverage for a given
wildfire risk zone (Figure 13). To date,
154 stations have been installed in Idaho,
providing reasonable coverage across all of
Idaho Power’s wildfire risk zones (Figure 14).
Data from these stations are shared through a
public feed accessible to the National Weather
Service (NWS), public safety agencies,
and customers in real-time. Idaho Power plans
to install additional weather stations over the
next three years as shown in Appendix F,
with locations informed by coordinating with
the NWS.

33 Weather stations may be installed outside of wildfire risk zones in areas proximal to the wildfire risk zone when a suitable pole within the
wildfire risk zone is not available for weather station installation.
Figure 13
Pole-mounted fire weather station
Idaho Power Company Wildfire Mitigation Plan 2027
Page 36

Figure 14
Idaho fire weather station map. Idaho Power does not have any company-owned weather stations in
Montana, as it does not have any wildfire risk zones located in Montana. Idaho Power utilizes third-party
weather stations for situational awareness in Montana.

Idaho Power Company Wildfire Mitigation Plan 2027
Page 37
4.6. Wildfire Detection Cameras
Idaho Power contracts with ALERTWest, which installs AI-enabled wildfire detection camera
sites. The network of cameras and the associated software solution is used by first responders,
emergency management personnel, and Idaho Power to detect wildfire; track real-time
weather and fuel conditions; and allow first responders, as well as Idaho Power, to allocate the
appropriate resources in the event of a fire. Idaho Power’s detection cameras are placed in
locations that provide viewsheds of wildfire risk zones or company infrastructure.
While informal coordination for wildfire detection camera siting and interoperability has been
occurring for the past three years between the IDL, Idaho Power, and the Bureau of Land
Management (BLM), a formal recommendation was put forth by the Idaho governor’s office in
202434 recommending the state formalize a working group process. The recommendation
included directions to the IDL, Idaho Office of Emergency Management, Office of Energy and
Mineral Resources, and the Idaho Department of Transportation to establish an interoperability
system that included engagement with entities participating in or interested in wildfire
detection camera operations. The Idaho Fire Camera Interoperability Committee (IFCIC) was
established in early 2025, with the official charter finalized in early 2026, to deliver on the
governor’s recommendation.
To date, Idaho Power, through ALERTWest, has installed nine wildfire detection cameras in
Idaho in areas where they provide visibility of overhead assets or surrounding terrain in certain
wildfire risk zones. These cameras are part of an artificial intelligence (AI)-enabled wildfire
detection camera network that totals more than 30 cameras across Idaho owned by various
members of the IFCIC. By working closely with the IFCIC and local public safety partners, Idaho
Power achieves efficiency in siting locations and cost savings for its installed sites. In some
cases, local partners have provided tower space at no cost, or installations were collectively
designed to eliminate the need for towers all together.
Idaho Power plans to continue to collaborate with the IFCIC to identify future camera locations,
focusing on opportunities that deliver mutual benefits and cost efficiencies while reducing
wildfire risk. Current camera locations are identified in Figure 15.

34 Wildfire Report Recommendations, August 2024. Available at: IOEMADMINCOPIER-20240418092717
Idaho Power Company Wildfire Mitigation Plan 2027
Page 38

Figure 15
Idaho wildfire detection camera interoperability
Idaho Power Company Wildfire Mitigation Plan 2027
Page 39
4.7. Fire Spread Predictive Tools
Idaho Power continues to explore the use of on-demand capabilities of Technosylva’s WFA-E
software FireSim and FireRisk in conjunction with the company’s internal FPI tool to support
operational decisions that reduce wildfire threats and risks. Each daily operational risk product
is described in greater detail below.
4.7.1. FireSim
FireSim provides an on-demand capability within WFA-E to generate fire spread predictions
based on forecast weather conditions. Idaho Power uses this tool at its discretion for situational
awareness and to support decision making during wildfire incidents.
4.7.2. FireRisk
FireRisk integrates Idaho Power’s WRF model outputs with FireSim to generate current and
near-term wildfire risk forecasts. Idaho Power continues to determine how best to integrate
FireRisk outputs in its decision making.

Idaho Power Company Wildfire Mitigation Plan 2027
Page 40

5Mitigation Activity: Workforce Preparedness
Section
Idaho Power Company Wildfire Mitigation Plan 2027
Page 41
5. Mitigation Activity: Workforce Preparedness
5.1. Overview
The nature of Idaho Power’s operations can mean employees and contractors perform work in
the field during wildfire season. For this reason, Idaho Power considers wildfire risk associated
with employee and contractor actions in this WMP, as described further below.
5.2. Wildland Fire Preparedness and Prevention Plan
The Wildland Fire Preparedness and Prevention Plan (the Plan), included as Appendix A to this
WMP, informs Idaho Power personnel about the following:
• Annual wildfire season tools and equipment required to be available when on the
job site
• Expected wildfire ignition prevention actions while working, and reporting instructions
in the event of fire ignition
• Training and compliance requirements for employees in situations covered by the Plan
Idaho Power employees in situations covered by the Plan should conform to the Plan as
detailed therein. Idaho Power’s contractors bear responsibility for their own actions and should
ensure they take adequate wildfire mitigation measures. Idaho Power may require that
contractors performing field work abide by wildfire mitigation terms as part of their contract.
These terms require contractors to ensure they follow practices intended to mitigate against
wildfire risk.

Idaho Power Company Wildfire Mitigation Plan 2027
Page 42
6Mitigation Activity: Line Operation Practices
Section
Idaho Power Company Wildfire Mitigation Plan 2027
Page 43
6. Mitigation Activity: Line Operation Practices
6.1. Overview
To reduce wildfire risk in a way that balances mitigation costs, Idaho Power implements line
operational practices during heightened wildfire risk days and/or in areas with potential
heightened wildfire risk. Wildfire mitigation operational practices fall in the
following categories:
• Temporary operating procedures for distribution lines in wildfire risk zones during
wildfire season
• Temporary operating procedures for transmission lines during wildfire season
• Idaho Power’s emergency de-energization operational strategy for T&D lines related to
wildfire during the wildfire season
• A public safety power shutoff (PSPS) strategy
6.2. Distribution Operational Protection Strategy
Sometimes called sensitive power line settings, Enhanced Powerline Safety Settings (EPSS) are
used to reduce the probability of ignition during fault events on Idaho Power’s distribution
system. EPSS are generally enabled, based on the criteria described below, in automatic
reclosing (AR) protective devices where the zone of protection overlaps with, or is located
within, Tier 2 or Tier 3 wildfire risk zones (i.e., on lines located in wildfire risk zones and/or lines
that traverse a zone and extend beyond the zone’s boundaries to any point of segmentation,
or the end of the line). EPSS help reduce wildfire risk by operating more sensitively to fault
conditions, but they also increase the likelihood of customer outages. For this reason,
Idaho Power enables EPSS only under the conditions and protocols defined in this WMP.35
AR protective devices include feeder relays (at head end of feeder) and reclosers.
• EPSS Mode 1: Auto-reclose turned off. This allows only a single trip, which eliminates
traditional re-energizations to test whether the fault has cleared on the line.

EPSS Mode 1 is operated as a seasonal setting. It is typically enabled by wildfire risk zone
grouping36 only during declared wildfire season but no later than July 1. Mode 1 remains
in effect until the end of declared wildfire season.

35 Similar protection philosophies are applied in line work contexts to ensure worker safety.
36 Groupings of wildfire risk zones are based on zones that have geographic areas with similar terrain, elevation, and vegetation characteristics.
Idaho Power Company Wildfire Mitigation Plan 2027
Page 44
• EPSS Mode 2: Auto-reclose turned off and trip settings set to instantaneous lock out37.
This is a more sensitive setting that will cause the AR device to lock out prior to most
fuses. Mode 2 is designed to minimize the energy of a fault to reduce ignition risk.

EPSS Mode 2 is enabled for a wildfire risk zone when the forecasted FPI is 15 or higher
(red) and the forecast predicts wind speeds meeting or exceeding zone-specific wind
criteria established for that zone by Idaho Power based on historic climatology.
EPSS Mode 2 will remain in effect until Idaho Power determines forecasted conditions
no longer warrant the setting. Idaho Power’s zone-specific wind speed criteria are set
out in the 2027 Operational Wind Speed Guidelines for EPSS and PSPS by Risk Zone.

Mode 2 applies only to AR devices that have fast trip or instantaneous trip capability.
Not all AR devices protecting wildfire risk zones currently have this capability.
EPSS settings are activated remotely from Idaho Power’s Distribution Control Center when
remote control is available through Supervisory Control and Data Acquisition (SCADA).
When SCADA control is not available on an AR device, qualified company personnel enable the
EPSS modes manually at the AR device, which requires additional time to implement once the
decision to do so is made.
In the case of a Mode 1 outage, Idaho Power will typically patrol38 to the next zone of
protection on the affected line. In the event of a Mode 2 outage, Idaho Power generally patrols
a line to the end of the line. In either case, Idaho Power may limit the patrol to a targeted area
in instances where Idaho Power determines it has identified the cause of the outage with
reasonable certainty.
Idaho Power tracks outage events occurring under EPSS Mode 1 and Mode 2 conditions.
6.3. Transmission Line Operational Strategy
6.3.1. Wildfire Season Temporary Operating Procedure for Transmission Lines
115 kilovolt (kV) and Above
During wildfire season, Idaho Power temporarily modifies its operating procedures for
transmission lines. Those modifications are, generally, as follows.
For transmission lines rated up to 230 kV, a patrol is generally performed prior to
re-energization following a sustained outage, also described in this section as a lock out,39

37 “Lock out” refers to the condition in which a protection device has operated and remains de-energized until it is manually or remotely reset.
Depending on the protection scheme and settings, lockout may occur following one or more trip/reclose attempts or after a single trip.
38 For the purposes of a patrol described in Section 6, the lines patrolled are limited to transmission, sub-transmission, or primary voltage level
distribution lines (i.e., 12.5 kV to 34.5 kV).

Idaho Power Company Wildfire Mitigation Plan 2027
Page 45
except in cases of planned outages or maintenance activities. The patrol is typically focused on
the area where available system information, relay data, field observations, or other tools
indicate the fault or outage condition likely occurred and does not involve patrolling the entire
line. Unlike normal operating conditions, operators do not routinely test40 or re-energize
transmission lines after they lock out to identify the faulted section before a patrol
is completed.
However, for certain 161-kV and 230-kV lines identified in Idaho Power’s Energy Management
System as serving highly populated areas, when relay fault data and GIS tools allow operators
to identify the fault location with—in their opinion—a high degree of confidence, operators
may sectionalize the faulted segment and re-energize the unaffected portion of the line to
restore service to customers without first conducting a patrol. This exception is intended to
facilitate the restoration of unaffected line sections while isolating the suspected faulted area
for inspection.
For 345-kV and 500-kV transmission lines, operators may exercise discretion to test the line to
maintain grid reliability and stability if one of the following criteria is met:
• The outage de-rates a rated path or forces curtailments.
• The outage directly impacts customers or Idaho Power’s ability to serve load.
• The outage strands or islands generation that is required for load service or
system reliability.
If none of these criteria apply, testing will not be performed, and the line will be patrolled as
described for transmission lines rated up to 230 kV prior to re-energization.
6.3.2. Tier 3 Zone Transmission Operational Strategy 69 kV & Below
During wildfire season, Idaho Power determines a daily FPI as described in Section 4 of this
WMP. The FPI informs the transmission line operational strategy for those lines owned and
operated by Idaho Power located in Tier 3 zones. These lines will be operated in normal settings
mode but with no testing of a line that may have locked out during the time of a red FPI. If the
line locks out, it will be patrolled in the area where Idaho Power has evidence suggesting the
fault occurred, consistent with the description in Section 6.3.1, before re-energization.
Alternatively, Idaho Power may choose to wait until the FPI level drops out of the red category
and re-energize without a patrol.

40 A transmission line “test” or transmission line “testing” refers to the human act of re-energizing a line without completing a physical field
patrol or observation of a line.
Idaho Power Company Wildfire Mitigation Plan 2027
Page 46
6.3.3. Transmission Lines Where Idaho Power Is Not the Operator
Idaho Power both fully owns and co-owns transmission lines in Idaho for which Idaho Power is
not the FERC-registered transmission operator (TOP) responsible for the safe and reliable
monitoring and operation according to North American Electric Reliability Corporation (NERC)
standards governing transmission lines. The FERC-registered TOP for all Idaho Power full and
co-owned transmission lines is responsible for determining and implementing any and all
transmission line operational strategies intended to mitigate against wildfire risk. Idaho Power
is not responsible for implementation of wildfire mitigations for lines operated by a
different party.
6.3.4. De-energization by Other Electric Corporations
Idaho Power may be notified by other electric corporations in advance of de-energization if
they intend to de-energize a transmission line that may impact one or more transmission lines
operated by Idaho Power. Idaho Power considers the impact of potential de-energization on
the bulk electric system, which includes the status of transmission lines operated by other
electric corporations, when deciding whether to de-energize under Sections 6.4 and 6.7.
6.4. Emergency De-energization When Wildfire is Approaching
In the event of a wildfire near or approaching Idaho Power infrastructure, the company will
conduct an emergency de-energization of overhead transmission or distribution lines only if
requested by the lead firefighting agency, including the designated incident commander for
that wildfire or those operating at the local, state, or federal level, and if Idaho Power can
determine to its satisfaction the identity of the line for which de-energization is requested.
Because the lead firefighting agency is generally in the best position to analyze the wildfire risk
and water needs in any situation, Idaho Power relies on their determination, subject to the
company’s ability to identify the line in question and Idaho Power’s bulk electric considerations
noted below, as applicable.
Upon a request to de-energize transmission circuits, Idaho Power will also evaluate potential
impacts to overall grid reliability and system stability. Idaho Power may opt not to de-energize a
transmission segment or circuit if it determines the requested de-energization may cause grid
instability or reliability issues that could impact a large number of customers (such as a
de-energization that could impact 1,000 or more customers), impact the bulk electric system,
or if Idaho Power believes it poses a risk to public safety.
Idaho Power will de-energize upon a request for emergency de-energization that meets the
above criteria as soon as reasonably possible. Idaho Power strives to de-energize in response to
such a request within one hour of the request being validated, though in some instances the
de-energization may take longer than one hour.
If Idaho Power learns of a fire located in a wildfire risk zone through a report to Dispatch,
Idaho Power will enable EPSS Mode 2 (when configured) on distribution lines located within
Idaho Power Company Wildfire Mitigation Plan 2027
Page 47
that wildfire risk zone or intersecting the wildfire risk zone to the nearest zone of protection
segmentation point if the following are met: 1) the FPI is 15 or higher (red), and 2) the weather
forecast predicts wind speeds meeting or exceeding the zone-specific wind criteria established
through the 2027 Operational Wind Speed Guidelines for EPSS and PSPS by Risk Zone.
EPSS Mode 2 will remain in effect until the lead firefighting agency communicates to Idaho
Power that the fire is no longer a threat to Idaho Power infrastructure or equipment, or until
either the FPI or wind speed no longer justify Mode 2 enablement.
6.5. Restoration of Electrical Service After a Wildfire De-Energization
Idaho Power personnel restore electrical service when it is safe to do so following a wildfire.
Following an emergency or unplanned de-energization of lines as set forth in Section 6.4,
Idaho Power will use qualified line personnel to patrol the known portion(s) of the de-energized
lines impacted by the fire, unless Idaho Power determines a patrol is unnecessary.
These patrols identify outage causes, damaged facilities, and restoration requirements
(number of crews, crew sizes, and necessary materials).
If damage is detected, trained field crews report to the site where damage has occurred with
equipment and new materials and develop a plan to remove and rebuild or repair damaged
facilities. Depending on the situation, contracted field crews—such as line crews and vegetation
management crews—are also deployed to assist in restoration efforts. Restoration work may
take hours or—in some cases, days—to complete.
6.6. Mutual Assistance
Idaho Power is a member of the Western Region Mutual Assistance Group (WRMAG), of which
most western U.S. electric utilities are also members. Member utilities provide emergency
repair and restoration assistance to other member utilities requesting assistance when dealing
with damaged electric facilities following a significant wildfire or weather event. In the event of
a wildfire that causes widespread damage to Idaho Power’s system, Idaho Power may request
restoration assistance via the WRMAG.
6.7. Public Safety Power Shutoff
A PSPS, as used in this WMP, is defined as the proactive de-energization, when deemed
appropriate by Idaho Power, of electric transmission and/or distribution facilities during
extreme weather events to reduce wildfire risk. A PSPS event involves planning and strategy
leading up to, during, and after the event to minimize the impact of the PSPS event on
stakeholders. Idaho Power tracks data relating to PSPS events.
PSPS is not the practice of de-energizing lines in the following types of situations:
• Unplanned de-energization of lines required for emergencies and during outage
restoration situations
Idaho Power Company Wildfire Mitigation Plan 2027
Page 48
• Planned line or station work activities that require a planned outage (Idaho Power
currently has a planned outage customer notification process in place for
these situations.)
• Reactive de-energization of electric transmission and/or distribution facilities in
response to wildfire threatening to burn into such facilities, as set forth in Section 6.4
• Automated de-energization of electric transmission and/or distribution facilities caused
by faults on the line
6.7.1. PSPS Plan
Idaho Power developed its Wildfire Public Safety Power Shutoff Plan (Appendix B) to guide its
implementation of this wildfire mitigation strategy. Idaho Power will conduct PSPS only when
Idaho Power facilities located within wildfire risk zones may be impacted by extreme weather,
as described further in the PSPS Plan. To safely isolate electrical facilities serving the affected
wildfire risk zone, this may also require de-energization of certain facilities located outside of
wildfire risk zones. The decision regarding PSPS is based on several dynamic factors, and each
weather event is unique.
6.8. Community Resource Centers
Each county has unique needs during outage events, requiring a customized, flexible approach.
Through annual meetings with county emergency managers, local public safety partners,
and local emergency planning committees (LEPC), Idaho Power refines county-specific
strategies in preparation for potential large-scale, extended outages. These strategies include
working with emergency managers to identify community resource center (CRC) locations for
potential activation during a PSPS event.
Idaho Power has a mobile CRC trailer available that may be used in large-scale,
extended outages, when operationally feasible. This unit can be staged where needed in
response to extended outages of Idaho Power equipment. The trailer is equipped with a
generator, climate control, charging stations for durable medical equipment and personal
devices, canopy tents for additional shade, and a monitor system to provide real-time updates
about the emergency event.
Idaho Power is not responsible for providing a local emergency response or coordinating local
emergency response resources; that is the role of the local emergency managers. However, if a
PSPS event is forecasted, Idaho Power will strive to collaborate with public safety partners to
identify and meet the needs of the community. Services provided in collaboration with
Idaho Power Company Wildfire Mitigation Plan 2027
Page 49
emergency managers could include the following, as appropriate and depending on
the situation:
• Deployment of a CRC
• CRC location(s) and logistics included in community outreach/outage notifications
• Resources, including food and water (as needed)
• Charging stations for durable medical equipment and personal devices
• Potential coordination of auxiliary services, which may be used for medical services,
housing assistance, family reunification, etc.
Idaho Power recognizes the challenges faced by vulnerable populations. The company also
recognizes that local communities and emergency managers are specially equipped for the care
of vulnerable populations in PSPS situations and defers to their expertise and abilities.
Idaho Power may, however, take measures to support emergency managers and vulnerable
customers during PSPS outages.
Outreach efforts also emphasize the importance of personal preparedness, particularly for
customers with medical or mobility needs. Idaho Power encourages individuals to understand
their unique needs and develop a plan before an outage. This includes identifying back-up
power options for life-support equipment or refrigerated medications, updating contact
information and outage notification preferences, and knowing where to go if power is lost.
Customers are also advised to coordinate with medical supply companies or caregivers and to
be aware of locations of emergency shelters with power.

Idaho Power Company Wildfire Mitigation Plan 2027
Page 50

7Mitigation Activity:
Infrastructure Inspection and Asset Management
Section
Idaho Power Company Wildfire Mitigation Plan 2027
Page 51
7. Infrastructure Inspection and Asset Management
7.1. Overview
Idaho Power’s wildfire mitigation strategy relies in part on its various asset management
programs, including inspection and maintenance activities. Table 5 provides a summary of
Idaho Power’s T&D asset inspection programs, which will be discussed in greater detail
throughout this section. The work described herein may be completed by Idaho Power
employees or contractors, at Idaho Power’s election.
Table 5
Overview of T&D inspection programs
Inspection Type Section
Transmission Distribution
Outside
Wildfire
Risk Zone
Tier 2
Zones
Tier 3
Zones
Outside
Wildfire
Risk Zone
Tier 2
Zones
Tier 3
Zones
Visual Inspections
Programs
(Aerial/Ground)
Sections 7.4.1 (T)
& 7.5.1 (D) Annually Annually Annually None Annually
Selected Annually
Line Equipment
Inspection Program Section 7.5.2 N/A N/A N/A N/A Annually Annually
Detailed Visual
(Aerial/Ground)
Inspections
Section 7.4.2 (T)
& 7.5.3 (D) 10 years* 10 years* 10 years* 3 Years 3 Years 3 Years
Thermal Imaging
(Infra-Red)
Sections 7.4.3 (T)
& 7.5.4 (D) N/A Annually
Selected Annually N/A Annually
Selected
Annually
Selected
Wood Pole Inspection
and Treatment
Program
Section 7.3 10 years 10 years 10 years 10 years 10 years 10 years
Cathodic Protection
Inspection Program Section 7.4.4 Annually
Selected
Annually
Selected
Annually
Selected N/A N/A N/A
* Western Electricity Coordinating Council (WECC) Lines Only
7.2. T&D Inspection Overview and Correction Timeframes
The WSCA requires that Idaho Power develop standards, procedures, and schedules—
subject to timely approval of access to rights-of-way—if necessary, for the inspection of its
assets, infrastructure, and facilities within the areas identified as wildfire risk zones. To meet
that requirement, Idaho Power sets out the following.
Idaho Power Company Wildfire Mitigation Plan 2027
Page 52
Idaho Power employees or contractors inspect Idaho Power equipment for potential defects.
Defects are categorized as Priority 1, Priority 2, or Priority 3 based on the following criteria:
• Priority 1: Defects that, depending on the circumstances, require repair as soon as
reasonably possible, generally within 30 days upon identification by Idaho Power.
Timeframes can be extended as a result of conditions such as access issues, weather,
and/or materials lead time.
• Priority 2: Defects that, depending on the circumstances, generally require correction
within 24 months of identification by Idaho Power. The correction of these defects is
scheduled during crews’ normal work schedules. Timeframes can be extended beyond
24 months due to conditions such as materials lead time, including the correction as
part of a broader project, and access issues.
• Priority 3: Defined as potential issues that may need correction over time and should be
monitored, but do not pose a threat to the system. A Priority 3 designation may also be
used by Idaho Power personnel for tracking certain line construction practices.
Correction of Priority 3 issues may be deferred until the next major work activity on the
circuit generally or included in the next 10-year corrective action plan for the
transmission line. On distribution facilities, Priority 3 issues may be monitored until
qualifying as Priority 1 or Priority 2 defects.
Idaho Power line patrol employees receive training on defect classification. Idaho Power relies
on its contractors to supply qualified electrical workers able to identify defects in accordance
with the above-described defect classification.
7.3. Wood Pole Inspection and Treatment Program
Idaho Power strives to visually inspect, sound, and bore wood poles on transmission and
distribution systems for defects and decay on a 10-year cycle. Poles are categorized according
to the following:
• Reported: Any wood pole inspected and found to be installed within 10 years of the
manufactured date or last inspection date.
• Treated: Any wood pole inspected and found to be installed 11 years or more prior
to the inspection date and determined to be in sound enough condition to
warrant treatment.
• Rejected: Any wood pole determined to fit any of the following criteria:
• Has less than 4 inches of shell at 48 inches above the ground line; or
• Less than 2 inches of shell at 15 inches above the ground line; or
• Less than 2 inches of shell at the ground line; or
Idaho Power Company Wildfire Mitigation Plan 2027
Page 53
• Is deteriorated and does not meet minimum strength criteria; or
• Fails a visual inspection
Rejected poles are classified as Priority or Non-Priority, which determines the replacement or
remediation timeframe. Priority rejected poles are those with an effective circumference of less
than 50% of the original circumference or 13% or less of the original strength. These poles are
scheduled for replacement or reinforcement as soon as reasonably possible, generally within
30 days of being classified as rejected. Non-Priority rejected poles include all other rejected
poles and are scheduled for replacement or reinforcement within two years of being classified
as rejected. Both Priority and Non-Priority replacements may be subject to delays related to
permitting, access, or construction constraints.
7.4. Transmission Inspection and Asset Management Programs41
Idaho Power’s transmission inspection and asset management programs include
condition-based aerial and ground visual inspections, detailed visual inspections,
thermal imaging inspections, transmission wood pole inspection and treatment, and cathodic
protection.
Idaho Power’s goal is to complete 100% of this work each year; however, emergencies,
operational issues, or other unplanned events can occur and disrupt the annual work plan.
All work is completed in accordance with safety and applicable requirements.
7.4.1. Transmission Visual (Ground/Aerial) Inspection Program
Idaho Power conducts annual visual inspections of all transmission lines using ground-based
and aerial inspection methods.42 Idaho Power strives to complete Tier 3 and selected Tier 2
wildfire risk zone inspections prior to the start of wildfire season; however, spring weather
conditions and snow accumulation may limit access in some areas and delay completion until
July 1 or later. Other transmission lines may be inspected at any time in the calendar year.
Inspections are performed by qualified personnel and may utilize vehicles, helicopters, and/or
unmanned aerial vehicles (UAVs). Potential defects identified by inspectors during inspections
are documented and scheduled for repair based on their classification.
7.4.2. Transmission Detailed Visual Inspection Program
Idaho Power conducts detailed visual inspections of Western Electricity Coordinating Council
(WECC) transmission lines on a 10-year cycle. Detailed inspections generally provide a more

41 Idaho Power owns and co-owns transmission lines in Idaho for which another entity is the Operator. The Operator performs maintenance and
inspection of those transmission lines. Idaho Power does not perform wildfire mitigation activities for transmission lines for which it is not
the Operator.
42 When Idaho Power conducts a detailed visual inspection on a line as described in Section 7.4.2, the detailed inspection is performed in lieu of
the annual visual inspection.
Idaho Power Company Wildfire Mitigation Plan 2027
Page 54
comprehensive evaluation of facility condition through a closer examination of poles,
structures, conductors, hardware, insulators, and associated equipment. These inspections are
performed by qualified personnel and may utilize helicopters, UAVs, and/or hand-held
high-definition imaging. Potential defects identified during detailed inspections are
documented and prioritized for corrective action in accordance with the defect classification
process described in Section 7.2.
7.4.3. Transmission Thermal Imaging (Infrared) Inspections
Idaho Power annually inspects select transmission line connectors and splices within Tier 3 and
select Tier 2 zones using thermal imaging (infrared) cameras. Idaho Power strives to complete
these inspections before July 1 generally; however, inspections may be performed later in the
year based on load conditions to ensure effective inspections. These inspections are conducted
using hand-held, helicopter-mounted, and/or drone-mounted cameras with thermal-sensing
technology and can help identify defects associated with overheating equipment.
As part of the thermography inspections, temperature gradients are analyzed to detect
potential problems, and repairs of issues found are prioritized based on their severity
consistent with defect classifications. A combination of Idaho Power personnel and contracted
resources are used to perform thermography inspections. Idaho Power’s thermography
technicians coordinate repair activities found by internal and contracted resources.
7.4.4. Transmission Cathodic Protection and Inspection Program
Cathodic protection systems are installed on select steel transmission towers and utilize either
Impressed Current Cathodic Protection (ICCP) systems or direct-buried sacrificial magnesium
anodes. Structure-to-soil potential testing is performed periodically on selected cathodically
protected towers located in wildfire risk zones, at intervals established by Idaho Power.
For ICCP systems, rectifiers and ground-beds are checked annually for proper operation,
and test results are measured and recorded. Based on these inspection and testing results,
Idaho Power performs any necessary repairs and/or system adjustments as determined by
Idaho Power.
7.5. Distribution Inspection and Asset Management Programs
Idaho Power’s distribution inspection and asset management programs include annual
condition-based visual inspections; detailed visual inspections, thermal-imaging inspections;
wood pole inspection and treatment; and line equipment inspections, as described
further below.
7.5.1. Visual Inspection
Annually, qualified line patrol personnel (trained in distribution line inspection procedures and
experienced in distribution line construction) complete visual wildfire mitigation inspections of
the distribution lines located in Tier 3 and select Tier 2 zones. The inspections are conducted to
Idaho Power Company Wildfire Mitigation Plan 2027
Page 55
identify Priority 1 defects (defined in Section 7.2) based on the inspector’s judgment
and experience.
Patrols are performed using four-wheel-drive vehicles, all-terrain vehicles (ATVs), utility terrain
vehicles (UTVs), or on foot. Inspectors use visual observation, binoculars, and/or UAVs, as the
inspector deems appropriate, to conduct the inspection. While helicopters are generally not
practical for distribution line inspections in areas with higher population density and greater
concentrations of structures and vegetation, Idaho Power may utilize helicopters on a case-by-
case basis when warranted.
Inspectors strive to inspect the line through to the service transformer only; they do not inspect
beyond the service transformer as part of annual visual inspections in order to allow the
inspections to be completed generally before July 1. The identified defects are then
documented, prioritized, and scheduled for repair consistent with defect classification,
as discussed in Section 7.2.
Idaho Power strives to complete inspections under this Section 7.5.1 before the start of each
wildfire season. However, access constraints may delay completion in some areas until July 1
or later.
7.5.2. Line Equipment Inspection Program
Idaho Power strives to inspect line equipment in and immediately feeding all wildfire risk zones,
including capacitor banks, AR devices, and regulators, annually prior to July 1 using line
operations technicians. The inspection is a visual inspection. When electronic controls are
present, control data is also analyzed.
7.5.3. Detailed Inspection Program
Idaho Power performs detailed patrol inspections of all distribution lines on a three-year cycle.
Detailed inspections generally provide a more comprehensive evaluation of facility condition
through a closer examination of poles, structures, conductors, hardware, insulators,
and associated equipment. Inspections are performed using four-wheel-drive vehicles, ATVs,
UTVs, or on foot. Inspectors use visual observation, binoculars, and/or UAVs, as appropriate to
identify any defects consistent with Section 7.2. While inspectors strive to inspect the line up to
the point of delivery, circumstances, such as access issues, physical obstacles, and customer
objections, may prevent inspectors from inspecting to this point. Inspections document
identified defects and prioritize corrections according to priority level, as described in
Section 7.2.
7.5.4. Thermal Imaging (Infrared) Inspections
At its discretion, Idaho Power annually inspects selected distribution lines and equipment
within Tier 3 zones using thermal imaging (infrared) cameras. Identified risks are prioritized and
mitigated consistent with the defect classification system set out in Section 7.2.
Idaho Power Company Wildfire Mitigation Plan 2027
Page 56
7.5.5. Pole Attachments
Idaho Power is obligated by Idaho Code § 61-538 and associated regulations to
allow attachments owned by third-party attaching entities (i.e., cable, broadband,
or telecommunications providers) on its poles. The attaching entity is solely responsible for
performing its work according to industry standards, maintaining its equipment in good
working order, and taking steps to prevent wildfire caused by their equipment and actions.

8Methods of Line Design
Section
Idaho Power Company Wildfire Mitigation Plan 2027
Page 57
8. Methods of Line Design
8.1. Overview
Idaho Power’s wildfire mitigation strategy includes financially prudent and reasonably
practicable methods of line design for new, planned, and existing lines to mitigate wildfire risk.
On an annual basis, Idaho Power assesses potential construction (rebuild, hardening, and/or
upgrade) work for its transmission and distribution lines. Candidate projects are identified
through inspection and maintenance programs, wildfire risk evaluations, operational needs,
reliability considerations, and other planning activities. Following project identification,
Idaho Power develops project scopes, evaluates engineering requirements, establishes cost
estimates, obtains necessary permits and approvals, and other applicable requirements. Each of
these activities can impact the timeline and feasibility of the project. Some candidate projects
identified may be deferred or even removed from the project pipeline based on considerations
identified through the project development process.
Idaho Power generally plans and develops projects over a multi-year horizon to support
efficient engineering, permitting, resource planning, and construction scheduling.
Projects advance through planning, engineering, and construction phases and are prioritized
based on system needs and benefits, including wildfire risk reduction, and available resources.
Final project selections intended to be completed in a given calendar year are reviewed and
approved by leadership.
Idaho Power’s goal is to complete 100% of the planned project work for that year; however,
emergencies, operational issues, or other unplanned events can occur and disrupt the planned
work. All work is completed in accordance with safety and applicable requirements.
Specific wildfire mitigation design and construction practices are discussed further below.
8.2. Siting and Design of New Transmission Lines
Idaho Power uses financially prudent and reasonably practicable methods of line design for its
new lines, and Idaho Power will apply this WMP to new transmission lines located in Idaho and
Montana, once constructed.
8.2.1. Transmission Steel Poles
Idaho Power has existing wood transmission poles on its system, which is allowed under this
WMP. However, when building new 138-kV lines and above, Idaho Power will use steel poles or
structures unless, in Idaho Power’s discretion, the use of wood poles is more feasible than steel
poles based on factors such as limited supply or availability of steel poles, engineering
specifications, right-of-way constraints, permitting requirements, and project timelines. This
approach is designed to enhance wildfire mitigation, improve transmission line resiliency,
Idaho Power Company Wildfire Mitigation Plan 2027
Page 58
reduce future rebuilding costs after wildfire events, and provide greater reliability
for customers.
8.3. Transmission Line Rebuild Projects
Idaho Power takes steps to repair or replace transmission line components on an ongoing basis.
Idaho Power prioritizes transmission line rebuild projects through a planning process that
considers asset condition, inspection results, maintenance history, system reliability,
operational needs, facility criticality, load growth, transmission planning requirements,
stakeholder input, and wildfire risk. Although many transmission line rebuild projects are
initiated to address broader system needs, Idaho Power considers wildfire risk and
opportunities to improve system resiliency as part of project evaluation and prioritization. As a
result, transmission line rebuild projects often provide multiple benefits, including improved
system reliability and increased wildfire resiliency.
8.3.1. Targeted Structural Reinforcement
In addition to transmission line rebuild projects, Idaho Power may implement targeted
structural reinforcement measures on existing transmission facilities to enhance structural
resiliency. These measures are intended to address site-specific conditions identified by Idaho
Power through inspections, engineering evaluations, maintenance history, operational
experience, and/or wildfire risk considerations.
Potential structural reinforcements may include the installation of supplemental crossarm
bracing or guying components, reinforcement clamps, replacement of hold-down assemblies on
H-frame structures, and other modifications designed to enhance the structural performance of
existing facilities.
Targeted structural reinforcements are not implemented through a system-wide replacement
program and Idaho Power does not apply them across the transmission system. Instead,
Idaho Power evaluates these opportunities on a case-by-case basis as part of its ongoing asset
management, inspection, maintenance, and engineering processes. Where engineering review
by Idaho Power determines that a reinforcement measure provides a practical and
cost-effective means of enhancing facility condition, reliability, or wildfire resiliency,
the reinforcement may be incorporated into a given planned maintenance activity,
corrective work, or capital project.
8.4. Distribution Investments
Distribution hardening is an ongoing component of the WMP. This work reflects a reasonable
balancing of mitigation costs with wildfire risk reduction. Overhead distribution infrastructure
located in wildfire risk zones is analyzed, inspected, and hardened as Idaho Power deems
appropriate using the strategies and analytical framework discussed below.
Idaho Power Company Wildfire Mitigation Plan 2027
Page 59
Idaho Power deploys hardening efforts utilizing the Framework described in Section 3.5. The
timing of work activities and selection of structures and equipment for hardening are
determined at the discretion of Idaho Power. Idaho Power strives to schedule projects
efficiently utilizing both internal construction crews and external contractors, allowing work to
proceed concurrently across multiple locations. Distribution hardening activities are
implemented on a rolling basis over the course of multiple years, consistent with internal
prioritization analysis and scheduling.
In certain circumstances, Idaho Power may relocate or reroute electrical facilities as part of its
hardening efforts. Line relocation may be implemented as a stand-alone mitigation or in
combination with other mitigation measures, such as overhead hardening or underground
conversion. Relocation may be utilized to address permitting requirements, land use
constraints, construction considerations, maintenance access needs, environmental factors,
or identified wildfire risk drivers. Line relocation may be incorporated into hardening projects
discussed in this section when it supports the project’s overall objectives and provides
operational and/or wildfire risk reduction benefits.
8.4.1. Overhead Primary Hardening Program
Overhead primary hardening includes upgrading overhead power lines to reduce wildfire risk
and improve safety. In 2027, Idaho Power’s overhead primary hardening is focused on certain
Tier 3 and Tier 2 zones43 or portions thereof using the strategies discussed below. Idaho Power
will strive to meet the 2027 targets identified in Appendix F.
Idaho Power’s overhead primary hardening program strategies and equipment are evaluated by
patrolmen, troublemen, reliability engineers, and the company’s Methods and Materials
department to determine cost-effective solutions that balance overall costs with expected
risk reduction. Prior to developing its WMP, Idaho Power successfully implemented many of the
same hardening measures as part of the company’s reliability program. On average,
outage data and analytics showed customer outages were reduced by approximately 38% in
areas where hardening projects were carried out. With the success of reducing outages,
many of these same activities used to increase reliability were chosen to be part of the WMP.
Table 6 describes methods that may be used as part of the company’s overhead primary
hardening program in a given overhead hardening project. Not all these strategies are
employed in all scenarios. At their discretion, Idaho Power personnel select the appropriate
hardening methods for a given project on a case-by-case basis. Idaho Power’s team researches
and evaluates emerging technologies relative to primary hardening to determine if any should
be adopted in the future.
43 If circumstances impact the ability to perform overhead hardening in selected Tier 3 zones, Idaho Power may, at its discretion, assess whether to
perform hardening in additional Tier 2 zones.
Idaho Power Company Wildfire Mitigation Plan 2027
Page 60
Table 6
Idaho Power overhead distribution primary hardening program methods
Overhead Distribution Primary Hardening Program Methods*
• Replace “small conductor” with new 4 ACSR or larger conductor.
• Replace or repair damaged conductor.
• Re-tension loose conductors, including slack spans as required.
• Replace wood-stubbed poles with new wood poles.
• Replace rejected poles with new wood poles.
• Replace wood crossarms with new fiberglass crossarms.
• Replace steel insulator brackets with new steel pins/fiberglass crossarms.
• Replace wedge dead ends on primary taps with new polymer dead end strain insulators.
• Replace aluminum dead end strain insulators with new polymer dead end strain insulators.
• Replace porcelain switches with new polymer switches.
• Install bird/animal guarding.
• Replace hot line clamps:
• Replace aluminum stirrups.
• Install avian switch cover.
• Relocate arresters below the fuse.
• Update the following capacitor banks:
• Replace swelling capacitors.
• Replace oil-filled switches with vacuum style.
• Replace porcelain switches with polymer switches.
• Install disconnect switches on CSP transformers.
• Install avian switch cover.
• Update down guys.
• Replace/Install down-guy insulators with fiberglass insulators.
• Re-tension down guys.
• Tighten hardware.
• Replace all arresters with non-expulsion arresters.
• Replace all expulsion fuses with energy-limiting or SMU Power fuses.
* Design is informed by inspection findings and other factors considered as part of the mitigation selection process.

These methods represent a toolkit of options rather than a prescriptive set of actions to be
applied in every case. Not all measures will be implemented on each project; for example,
newer construction may already include avian covers and/or polymer switches, and recently
installed poles may not require replacement. Instead, Idaho Power applies a risk-based
approach in which Idaho Power designers evaluate each project in the field to determine the
specific hardening needs for that location.
Idaho Power Company Wildfire Mitigation Plan 2027
Page 61
8.4.2. Overhead to Underground Conversion
As an alternative to conducting overhead circuit hardening upgrades, the company considers
converting overhead distribution circuits to underground and does so by reasonably balancing
mitigation costs of undergrounding with the resulting reduction in wildfire risk and comparing
mitigation alternatives using its mitigation-selection framework. Idaho Power will strive to meet
the overhead to underground conversion targets in 2027, as identified in Appendix F.
Underground conversion of overhead distribution lines can provide benefits, including reduced
wildfire ignition risk, improved reliability, and lower long-term vegetation maintenance needs.
In certain locations, undergrounding also enhances community safety by reducing outage
exposure for critical facilities and improving system resilience in areas with limited access or
evacuation routes.
While underground conversions of the distribution system are used in certain circumstances,
the up-front cost can vary based on voltage level, configuration, equipment requirements,
permitting, and ground suitability. Underground costs are generally estimated to be higher than
the cost of carrying out overhead hardening work. In general, overhead hardening efforts
provide the benefit of being able to impact a greater number of circuit miles and customers in a
shorter time horizon with less up-front investment than undergrounding. However, there may
be certain risk, reliability, ongoing cost savings, and other benefits of underground
infrastructure relative to overhead. Idaho Power evaluates these alternatives annually in the
development of its WMPs using the Framework and is not required to undertake
undergrounding or hardening measures beyond what is reasonably planned and approved by
Idaho Power leadership for a given year.
The company uses the Framework described in Section 3.5 to select locations for underground
conversion by reasonably balancing the following areas to assess costs and potential for wildfire
risk mitigation:
• Wildfire risk modeling and quantification, showing areas with elevated risk of wildfire
spread and impacts to people and property.
• Wildfire history where overhead power lines may be susceptible to repeated wildfire
events over their lifetime (i.e., fire return interval).
• Community safety risks, including areas with limited egress or evacuation routes and
constrained access for fire suppression resources.
• Outage exposure for critical facilities, including but not limited to hospitals,
water suppliers, and nursing homes.
• Vegetation exposure, including areas with dense fuels or elevated likelihood of
vegetation-related faults, such as falling trees.
• Weather vulnerability, such as locations subject to frequent lightning or high winds.
Idaho Power Company Wildfire Mitigation Plan 2027
Page 62
• Accessibility constraints, such as steep terrain, remote locations, or right-of-way
limitations.
• Feedback from local officials or fire agencies on topography and fuels in areas conducive
to rapid wildfire spread that may impact highly valued resources, watersheds, or critical
facilities.
• Overall number of customers that may benefit from a particular project.
• Condition and age of existing infrastructure, especially where age or type of original
construction would otherwise require upgrades.
• Long-term operational savings, such as reduced vegetation maintenance,
outage response, or wildfire-related restoration costs.
8.4.3. New Underground Construction
Customer growth and new developments in wildland-urban interface (WUI) areas present
challenges for Idaho Power when working to decrease wildfire risk. As people increasingly move
into areas with more wildfire risk, the company expands its infrastructure to serve customers
while simultaneously balancing cost and mitigating for wildfire risk. Idaho Power evaluates new
developments to determine if near-term risk levels warrant underground construction at the
onset of a project; specifically, the company may consider a new development’s location,
wildland fuels, suppression and response capabilities, and egress/ingress routes when
determining if underground construction is warranted. The risk reduction benefits, cost of
underground construction, potential long-term cost savings, and potential reliability benefits,
as well as other potential benefits, are typically explored in each instance.
8.4.4. Feeder Segmentation
Idaho Power has expanded the use of overcurrent protection devices (i.e., reclosers) to isolate
areas of higher wildfire risk from areas with lower risk—a practice called segmentation.
Feeder segmentation may include installation of new devices, relocation of existing devices,
and/or upgrading remote communication capabilities (i.e., SCADA).
Reclosers provide a point of de-energization for PSPS and are also used to implement EPSS,
resulting in the ability for Idaho Power to minimize impacts from de-energization and
unplanned EPSS outages, particularly for customers outside wildfire risk zones. Segmentation is
also used to break up longer circuits in wildfire risk zones which, in the event of an outage,
expedites restoration by reducing patrol time and cost by limiting the line miles patrolled prior
to re-energization.
Segmentation is most efficiently accomplished through remote-controlled devices.
Remote communications allow for real-time setting changes and de-energization,
Idaho Power Company Wildfire Mitigation Plan 2027
Page 63
providing significant time savings and avoiding costs that would otherwise be incurred if
devices are manually adjusted in the field.
Idaho Power prioritizes new recloser installations and upgrades based on the following criteria:
• SCADA Operability: The first consideration is whether an existing recloser or circuit
breaker can be remotely operated via Idaho Power’s SCADA system. Remote operability
is key for timely and safe execution of PSPS events and eliminates the need for manual
field switching during wildfire conditions.
• EPSS Compatibility: The second criterion is the device’s ability to support EPSS.
Existing equipment is assessed for compatibility with Mode 1 and Mode 2
configurations, and upgrades are implemented where necessary to promote reliable
operation under elevated wildfire risk conditions.
• Minimizing Customer Impacts: A third factor involves identifying areas where
customers are located outside wildfire risk zones but are served by circuits that extend
into them. In such cases, reclosers may be strategically installed near the boundary of
wildfire risk zones to isolate high-risk segments and minimize patrol times during PSPS
events and help avoid unnecessary outages for customers located in lower-risk areas.

Idaho Power Company Wildfire Mitigation Plan 2027
Page 64

9Vegetation Management
Section
Idaho Power Company Wildfire Mitigation Plan 2027
Page 65
9. Vegetation Management
9.1. Overview
Idaho Power’s vegetation management activities address public safety, regulatory compliance,
electric reliability, and help safeguard primary distribution and transmission lines from trees
and other vegetation that may cause an outage or damage to facilities. As more fully described
throughout this section, these activities encompass planning, scheduling, performing,
and quality control related to the management of trees and vegetation that could impact lines,
as well as the clearing of vegetation from the base of certain poles and line structures.
Idaho Power's vegetation management program consists of both routine vegetation
management activities and enhanced vegetation management activities. Routine vegetation
management activities are performed throughout Idaho Power's transmission and distribution
system to maintain vegetation clearances, support system reliability, comply with applicable
regulatory requirements, and address vegetation conditions that could affect the operation of
electric facilities.
Idaho Power has also developed standards, procedures, and schedules—subject to timely
approval of access to rights-of-way, if necessary—for vegetation management within areas
identified as wildfire risk zones within Idaho Power’s rights-of-way or lands adjacent thereto to
address potential vegetation risk to Idaho Power’s power lines or other infrastructure.
Enhanced vegetation management activities supplement Idaho Power's routine vegetation
management program within designated wildfire risk zones. These activities are intended to
further reduce vegetation-related wildfire ignition potential and wildfire risk.
Table 7 summarizes Idaho Power’s vegetation management activities and schedules with
respect to both routine vegetation management activities and enhanced vegetation
management activities.
Idaho Power’s vegetation management activities and schedules are designed to comply with
applicable National Electric Safety Code (NESC), federal, and state requirements and occur
year-round.
Idaho Power faces challenges that impact its ability to complete its vegetation management
goals. These include, but are not limited to, landowners who refuse pruning or removal of
trees, shortage of qualified labor resources in the vegetation line clearing industry,
inclement weather and terrain limiting access to overhead electric facilities during some
seasons, urban growth that increases the number of trees near overhead electric facilities,
and cycle-buster trees that grow back after pruning more rapidly than other trees. Idaho Power
adheres to the vegetation management activities and cadences stated below to the
extent practicable given these obstacles.
Idaho Power Company Wildfire Mitigation Plan 2027
Page 66
9.2. Program Components
Idaho Power employs a variety of inspection, patrol, mitigation, and quality assurance activities
to identify and address vegetation-related risks and to maintain clearances around its lines.
9.2.1. Vegetation Risk Identification
Idaho Power conducts a variety of vegetation management patrols, described further below,
to identify vegetation risk relative to its lines, beyond maintaining vegetation clearances around
its lines. These patrols are performed by Idaho Power-employed arborists and qualified
vegetation management contractors (collectively referred to herein as Utility Arborists) who
evaluate vegetation conditions through field observations, established procedures,
and professional judgment.
Utility Arborists generally evaluate for the following types of vegetation risk visible at the time
of patrol:
• Cycle Busters: Vegetation identified by the Utility Arborist as exhibiting growth rates
that may result in encroachment into line clearances before the next scheduled
pruning cycle.
• Hazard Trees: Trees identified by the Utility Arborist as showing signs of mortality at the
time of patrol or have one or more structural defects that could make the tree likely to
fail and fall into or onto power lines.
• High-Priority Vegetation: Any vegetation condition identified by the Utility Arborist as
likely to cause a line outage with a high risk of failure in the next few days or weeks.
These are normally tall Hazard Trees that have one or more defects that could cause the
tree to fail and fall into or onto power lines. High-Priority Vegetation could also be
vegetation that is in good condition but has grown so close to the line that it presents a
high risk of coming into contact with the line through a combination of conductor sag
and/or wind-induced movement of the conductor or the vegetation.
• Vegetation Encroachments: Vegetation identified by the Utility Arborist as growing into
the clearance envelope of the line. Because of Idaho Power’s cycle pruning efforts,
Idaho Power generally expects that Vegetation Encroachments found on vegetation
management patrols will be Cycle Busters.
9.2.2. Vegetation Mitigation
Idaho Power, through the actions of its employees or contractors, completes appropriate
mitigations to address the issues identified by Utility Arborists. Throughout the vegetation
management section, the term Vegetation Mitigation is used to refer to the appropriate action
required either to address vegetation risk or on-cycle pruning. A Vegetation Mitigation is
generally the pruning and/or removal of vegetation.
Idaho Power Company Wildfire Mitigation Plan 2027
Page 67
Idaho Power mitigates vegetation risk categorized as a High-Priority Vegetation on an expedited
basis upon identification and reporting. High-Priority Vegetation is expected to be reported to
an Idaho Power internal arborist following identification without intentional time delay.
Other vegetation risks are addressed as scheduled work. Vegetation Mitigation methods
include crews using hand saws, chainsaws, pruners, specialized machinery, and herbicides.
Trees are pruned using a pruning procedure called directional or natural pruning, a method
recommended by the International Society of Arboriculture, and the American National
Standards Institute (ANSI) A300 standards.
When appropriate, tree-growth regulators and spot herbicide treatments are applied in
compliance with federal or state requirements. These treatments are effective for reducing
regrowth of sprouting deciduous shrubs and trees and extending maintenance cycles.
Vegetation Mitigation in relation to a service44 wire is not part of Idaho Power’s vegetation
management activities, except on a case-by-case basis upon customer45 or their agent’s
request. Customers are responsible for keeping trees and other vegetation located on or
growing into the customer’s property from potentially interfering with Idaho Power equipment,
including an overhead service line. Idaho Power encourages customers to take care when
pruning vegetation near power equipment and utilize trained professionals to prune around
service wires. Customers may reach out to Idaho Power to request de-energization to support
pruning around a service wire.
When pruning or removing trees, Idaho Power generally leaves wood in place to biodegrade
when the wood is dead or when the wood is in non-landscaped areas. In landscaped areas,
all wood greater than 4 inches in diameter is cut to manageable lengths and left for the
property owner’s use; live wood smaller than 4 inches in diameter is chipped and removed
from the property.
9.2.3. Vegetation Mitigation Activity Schedule
Table 7 summarizes vegetation management activities performed on Idaho Power's
transmission and distribution system, including applicable inspection and maintenance
frequencies within and outside wildfire risk zones.

44 The service wire is the conductors (wires or cables) that connect Idaho Power’s facilities to customer equipment.
45 In this context, customer is defined as the individual, partnership, association, organization, public or private corporation, government,
or governmental agency receiving or contracting with Idaho Power for electric service.

Idaho Power Company Wildfire Mitigation Plan 2027
Page 68
Table 7
Vegetation Management Program initiatives and schedules
Vegetation Management Program Initiatives and Inspection Schedule*
Inspection Type & Section Transmission Distribution
Outside WRZ Tier 2 Zones Tier 3 Zones Outside WRZ Tier 2 Zones Tier 3 Zones
Wildfire Mitigation Patrol**
Sections 9.3.1
& 9.4.2 None None Annually None Annually Annually
NERC/WECC Line Patrol*** Section 9.3.1 Annually Annually Annually N/A N/A N/A
Line Clearing Cycles Patrol
Sections 9.3.2
& 9.4.2
3 years (Valley
Locations)/6 years
(Mountain Locations)
3 years (Valley
Locations)/6 years
(Mountain
Locations)
3 years (Valley
Locations/6 years
(Mountain
Locations) 3 years 3 years 3 years
Mid Cycle Patrol (Cycle Busters)
Sections 9.3.2
& 9.4.2 18 Months 18 Months 18 Months None
2 years after
Cycle Prune
2 years after
Cycle Prune
Quality assurance (QA)/Quality
Control (QC) Audit Patrols
Sections 9.3.3
& 9.4.4 Sampling 100% 100% Sampling 100% 100%
Targeted Pole Clearing Section 9.5 Annually Selected Annually Selected Annually Selected
Annually
Selected Annually Selected
Annually
Selected
*Idaho Power strives to maintain the cycles identified herein. Idaho Power anticipates achieving the 3-year cycles identified in this table by the end of 2026 but may not meet them in all instances.
**Wildfire Mitigation Patrols are typically performed prior to July 1, unless inclement weather causes access issues, which may result in a delay.
*** NERC/WECC are inspected annually. If a NERC/WECC line is located within a wildfire risk zone, the line is inspected once that year and not inspected again with another type of inspection.
Idaho Power Company Wildfire Mitigation Plan 2027
Page 69
9.2.4. Fair Market Value of Timber
If live marketable timber is identified for removal from timber company land adjacent to
Idaho Power’s rights-of-way, compensation at fair market price will be made available to the
landowner for such timber. The process utilized to determine how fair market value was
achieved will be documented and consistent with the WSCA, Idaho Code § ̛61-1803(3)(g)(iii).
9.3. Transmission Vegetation Inspection and Management
Maintaining a vegetation-free clearance zone near transmission lines has long been a priority
for Idaho Power. The clearance zone is voltage-level dependent and defined by federal and
state regulations.
9.3.1. Transmission Vegetation Wildfire Mitigation Patrol and
NERC/WECC Patrol
Utility Arborists annually conduct aerial and/or ground patrols of all transmission lines located
in Tier 3 zones and all NERC- and WECC-regulated transmission lines to identify vegetation risk
that could cause, in the opinion of the inspecting Utility Arborist, an outage during that
calendar year. Vegetation risk found is mitigated as described in Section 9.2.2.
9.3.2. Transmission Line Clearing Cycles
Idaho Power performs cycle pruning of vegetation around transmission lines on a general cycle
of every three years for urban and rural valley areas and six years for mountain areas.
During cycle pruning, the Utility Arborist both identifies and mitigates vegetation risk as
described above and removes enough vegetation such that, in the judgment of the Utility
Arborist, the vegetation is unlikely to grow into the line clearance envelope before the next
cycle pruning.
The duration of pruning cycles is influenced by vegetation type. Areas dominated by
slower-growing coniferous species, such as pine and fir, can often sustain longer maintenance
cycles due to slower crown expansion and reduced encroachment risk. In contrast, areas with
fast-growing deciduous species, such as cottonwood, willow, or aspen, generally require more
frequent pruning to maintain clearances and reduce the likelihood of contact with energized
conductors. The pruning cycle in mountain areas is longer than the cycle in valley locations
because the trees in mountain areas are almost entirely slower growing conifer species.
When deemed appropriate by Idaho Power and allowed by property owners/land managers,
tree-growth regulators and spot herbicide treatments are also applied in compliance with
federal or state requirements as part of the cycle pruning activity. These treatments are
effective for reducing regrowth of sprouting deciduous shrubs and trees and extending
maintenance cycles.
Idaho Power Company Wildfire Mitigation Plan 2027
Page 70
Idaho Power also conducts mid-cycle vegetation management patrols of documented Cycle
Busters on transmission lines every 18 months to identify vegetation risk,
particularly encroaching vegetation. Idaho Power mitigates vegetation risk identified on
mid-cycle patrols as described in section 9.2.2.
9.3.3. Transmission Line Clearing Quality Control and Assurance
Outside of wildfire risk zones, audits46 are performed on a sample of pruning worksites selected
by an Idaho Power contractor. These audits are performed through a combination of the
contracted arborists that planned the work and Idaho Power’s internal arborists. In wildfire risk
zones, audits are performed on 100% of pruning work. Auditors check if pruning cuts meet
specification and proper clearance was achieved. This quality control and assurance program
has proven valuable by discovering trees that were not properly pruned. As a result,
Idaho Power requested the pruning contractor re-prune these circuits to achieve
satisfactory results.
9.4. Distribution Vegetation Inspection and Management
The following sections describe Idaho Power’s distribution line cycle pruning and vegetation
management patrol processes.
9.4.1. Distribution Vegetation Inspections: Wildfire Mitigation Patrol/Pruning
Utility Arborists annually conduct vegetation management patrols of the portion of each
distribution circuit located in a wildfire risk zone to identify vegetation risk. These patrols are
generally performed prior to wildfire season, but no later than July 1. Vegetation risk found is
mitigated in accordance with Section 9.2.2.
9.4.2. Distribution Line Clearing Cycles
Idaho Power strives to cycle prune distribution lines, regardless of location, on a three-year
cycle. As with transmission line cycle pruning, the Utility Arborist both identifies and mitigates
vegetation risk and removes enough vegetation such that, in the judgment of the Utility
Arborist, the vegetation is unlikely to grow into the line clearance envelope before the next
cycle pruning.
In wildfire risk zones, Idaho Power strives to perform mid-cycle pruning in the second year to
identify and remove Cycle Busters that, in the judgment of the Utility Arborist, should be
removed to prevent vegetation from encroaching into the line clearance envelope for the full
pruning cycle. In addition, Idaho Power performs vegetation mitigation on lines on an

46 Throughout the WMP, the term ‘audit’ is used in an informal context and does not mean a formal audit conducted by the company’s Audit
Services Department or by an outside auditing firm.
Idaho Power Company Wildfire Mitigation Plan 2027
Page 71
“as-needed basis” in situations where fast, unexpected growth occurs and is reported by an
employee or customer. Vegetation risk found is mitigated in accordance with Section 9.2.2.
9.4.3. Distribution Line Clearance Distances
Idaho Power has a target to maintain clearance distance between vegetation and conductors,
where practicable, as follows:
• Five feet for conductors energized at 600 through 50,000 volts.
• Clearances may be reduced to 3 feet if the vegetation is not considered to be readily
climbable because the lowest branch is greater than 8 feet above ground level.
• New tree growth no larger than ½ inch in diameter may intrude into this minimum
clearance area, provided it does not come closer than 6 inches to the conductor.
This new growth is identified during line patrols and removed, as necessary.
• For conductors energized below 600 volts, subject to the service wire-related exceptions
discussed in Section 9.2.2, vegetation is pruned to prevent the vegetation from causing
unreasonable strain on electric conductors.
Idaho Power strives to maintain these clearance distances throughout the full pruning cycle
through the activities described above.
9.4.4. Distribution Line Quality Control and Assurance
Similar to Idaho Power’s vegetation audit process for transmission lines in non-wildfire risk
zones, audits are performed on a sample of Vegetation Mitigation worksites for distribution
lines. Audits are performed through a combination of contracted arborists and Idaho Power’s
internal arborists. In wildfire risk zones, audits are performed on all pruning work for
distribution lines. Auditors check if pruning cuts meet specification and proper clearance was
achieved. If an audit indicates unsatisfactory results, such as improper pruning, Idaho Power
requests the pruning contractor re-prune circuits to achieve satisfactory results.
9.5. Pole Clearing of Vegetation
Idaho Power clears vegetation from the base of certain transmission wood poles and a limited
number of distribution wood poles in Idaho. These vegetation clearing practices help mitigate
wildfire damage to existing wood poles and, at the same time, help to reduce the ignition
potential at the base of the pole. Where acceptable and permissible, Idaho Power clears
existing vegetation to the ground in a general 20-foot radius surrounding selected wood poles
and applies an herbicide in a general 15-foot radius that remains effective for several years.

Idaho Power Company Wildfire Mitigation Plan 2027
Page 72

10Additional Preventative Actions and Programs
Section
Idaho Power Company Wildfire Mitigation Plan 2027
Page 73
10.Additional Preventative Actions and Programs
10.1. Wildfire Suppression and Response
Idaho Power field crews carry
certain fire suppression
equipment in accordance with
the Wildland Fire
Preparedness and Prevention
Plan. However, they are not
professionally trained
firefighters and are instructed
not to place themselves in
hazardous situations when
responding to wildfires.
During wildfire incidents,
Idaho Power personnel take
appropriate directions from
the incident commander (IC)
or other authorized fire
response officials having
jurisdiction over the incident.
In addition, beginning in 2026, Idaho Power began employing internal seasonal wildfire
operations specialists during wildfire season to support critical infrastructure protection,
enhance situational awareness, and coordinate with wildfire incident command. In certain
situations, Idaho Power may also utilize contracted personnel to help protect its critical
infrastructure. Idaho Power deploys these resources on a case-by-case basis at its discretion.
10.2. Wood Pole Mesh Wrap
Idaho Power installs pole mesh wrap on selected wood transmission structures as an asset
hardening measure designed to improve wildfire resilience. The non-combustible mesh barrier
is installed around the lower portion of the pole to help protect the structure from direct flame
exposure and reduce the likelihood of pole loss during wildfire events. By enhancing pole
survivability, mesh wrap supports system reliability and may reduce wildfire-related repair and
replacement costs.
Installation efforts are primarily focused within wildfire risk zones; however, Idaho Power, at its
discretion, may utilize mesh wrap in other areas based on operational needs, infrastructure
risk, wildfire history, and system reliability considerations. Costs and targets associated with
mesh wrap deployment are provided in Appendix F.
Figure 16
Idaho Power crews working to replace poles damaged by a wildfire
during 2026 wildfire season.
Idaho Power Company Wildfire Mitigation Plan 2027
Page 74
10.3. Pilot Projects
Idaho Power uses pilot projects to evaluate emerging technologies, operational practices,
and mitigation approaches that may reduce wildfire risk, improve system reliability, or enhance
operational effectiveness. Pilot projects provide an opportunity to assess implementation
requirements, operational performance, costs, and potential risk reduction benefits before
broader deployment. These projects support learning with respect to cost, labor, and time
requirements and inform risk-based decisions when comparing, selecting, and prioritizing
mitigation strategies for the future.
10.3.1. Standby Helicopter Services: Pre- and Post-Event Inspections (Pilot)
Pilot Description
Evaluate dedicated helicopter availability during wildfire season for
outage response, patrols, construction, restoration, and situational
awareness.
Evaluation Metrics
Utilization hours, supported events, restoration performance,
operational flexibility, situational awareness benefits, and annual
cost-benefit review.
Estimated Duration 2024–2029
Estimated Annual
Cost Approximately $287,000
10.3.2. Wildfire Resilience Partnerships and Fuels Reduction Shared
Stewardship (Pilot)
Pilot Description Evaluate collaborative fuels reduction projects and landscape-scale
wildfire resilience efforts.
Evaluation Metrics Acres treated, stakeholders engaged, funding leveraged,
infrastructure benefits, and partnership outcomes.
Estimated Duration 2023–2029
Estimated Annual
Cost
Approximately $72,000

Idaho Power Company Wildfire Mitigation Plan 2027
Page 75
10.3.3. Line Monitoring Technology (Pilot)
Pilot Description Evaluate advanced line monitors and their ability to enhance
situational awareness and fault analysis.
Evaluation Metrics Detection accuracy, transitory fault identification, post-event analysis
value, and workflow integration.
Estimated Duration 2025–2029
Estimated Annual
Cost
Approximately $200,000
10.3.4. Covered Conductor (Pilot)
Pilot Description Evaluate constructability, maintenance requirements,
operational performance, and applicability of covered conductor,
including 12.5-kV and 34.5-kV distribution installations.
Evaluation Metrics Construction performance, operational experience, tooling
requirements, maintenance observations, reliability performance,
and installation costs.
Estimated Duration 2023–2028
Estimated Annual
Cost
Approximately $2,000
10.3.5. 3-D Pole Loading (Pilot)
Pilot Description Evaluate pole-loading analytics and structural
assessment methodologies.
Evaluation Metrics Engineering usefulness, deficiencies identified, model accuracy,
and decision-support value.
Estimated Duration 2023–2027
Estimated Annual
Cost
Approximately $72,000

Idaho Power Company Wildfire Mitigation Plan 2027
Page 76
10.3.6. High Impedance Relay Protections (Pilot)
Pilot Description Evaluate high impedance fault detection capabilities and reduction of
false positives.
Evaluation Metrics Detection accuracy, false-positive rates, validated events,
and operational effectiveness.
Estimated Duration 2025–2029
Estimated Annual
Cost
N/A

10.3.7. UAS Aerial Inspection (Pilot)
Pilot Description Evaluate UAS-based inspections, imagery management, and AI-assisted
image review.
Evaluation Metrics Poles inspected, defects identified, review efficiency, data quality,
and workflow integration.
Estimated Duration 2025–2027
Estimated Annual
Cost
Approximately $867,000

11Public Outreach and Engagement
Section
Idaho Power Company Wildfire Mitigation Plan 2027
Page 77
11. Public Outreach and Engagement
11.1. Objective
Communication is an important part of Idaho Power’s wildfire mitigation efforts. Idaho Power
engages in community outreach and public awareness efforts before, during, and after wildfire
season to inform the public of wildfire risks and to notify the public of wildfire-related outages.
Idaho Power communicates information about this WMP and wildfire risk in general
to employees, customers, government officials, the public, and other stakeholders.
The following objectives guide wildfire-related communications:
• Educate customers about how to prepare for wildfire-related outages, including where
to find outage and PSPS information and how to update contact information to enhance
communication regarding any potential outage events.
• Raise awareness about Idaho Power’s wildfire mitigation work.
• Explain how customers can reduce wildfire risk.
11.2. Community Engagement
Idaho Power presents and distributes information on its WMP to a wide variety of stakeholders,
including state and local public safety partners, critical facilities, and customers.
Each year, Idaho Power organizes an education campaign focused on wildfire risk and outage
preparedness. This campaign promotes the company’s wildfire mitigation activities and
customer outage communication, provides awareness and education on preparing for wildfire
season, and publicizes ways customers can prevent wildfires. The communication is intended to
educate stakeholders, whether they reside in wildfire risk zones or not, about Idaho Power’s
wildfire mitigation efforts, including when Idaho Power may need to deploy a PSPS, and how
stakeholders will be alerted during these events.
11.2.1. Public Safety Partners
Annually, before wildfire season, communications begin with public safety partners, such as:
• State of Idaho Emergency Support Function 12 (ESF-12)
• County emergency managers
• LEPCs
• Other public safety partners
Idaho Power Company Wildfire Mitigation Plan 2027
Page 78
• Local elected officials
• Health and human service agencies
Through individual conversations, larger presentations, and public events, Idaho Power
communicates about its wildfire mitigation efforts and discusses outage preparedness,
including how to prepare for a PSPS.
11.2.2. Critical Facilities
Idaho Power conducts focused engagement with critical facilities in areas where it has
infrastructure and equipment. Critical facilities are those identified by Idaho Power and include,
but are not limited to, hospitals, police and fire stations, wastewater treatment facilities,
and telecommunication providers. During these interactions, Idaho Power works to update
contact information and communication preferences, provides an overview of the
communication process during a PSPS, and shares outage preparedness tips.
11.2.3. Customers
Idaho Power’s customer-targeted outreach efforts include Idaho Power-hosted public events
focused on outage preparedness, safety, and wildfire prevention, including PSPS. These efforts
are complemented by participation in coordinated preparedness events led by
community-based organizations, further strengthening local engagement. Outreach includes
virtual meeting options in English and Spanish. Specific topics covered during these events
include the following:
• Outage preparedness tips, including PSPS
• Idaho Power’s wildfire mitigation efforts
• Strategies to prevent wildfires
• Options to help customers manage their Idaho Power account(s) and stay informed,
including Idaho Power’s app and outage alerts
11.2.3.1. Vulnerable Customers
To ensure messaging reaches vulnerable customers, Idaho Power collaborates with community
organizations focused on providing services and supplies to vulnerable customers as a strategy
to share outage preparedness information. The content includes considerations for older adults
and individuals with disabilities and information about medical equipment considerations
during an outage, emphasizing the importance of battery backups.
Idaho Power Company Wildfire Mitigation Plan 2027
Page 79
11.3. Event-Specific Communication
During PSPS events, Idaho Power uses communication and event management tools,
including dedicated Idaho Power employees focused on ensuring consistent and accurate
communication, to effectively manage the events and communicate with customers.
11.4. Key Communication Methods
Idaho Power communicates with customers and the public through a variety of channels to
help maximize reach and effectiveness:
• Connections (monthly newsletter to customers)
• Videos
• Email
• News media (news releases, appearances on TV and radio shows, interviews, etc.)
• Social media
• Printed materials, including flyers and bill inserts
• Idaho Power’s website: idahopower.com/wildfire
• Paid advertising (e.g., radio, digital)
At the end of each wildfire season, feedback from customer surveys and campaign metrics from
paid media advertising help inform and refine Idaho Power’s approach for the next year.
11.5. Timing of Outreach
Wildfire-related outreach occurs primarily before and during wildfire season. Holding key
communications until wildfire is more prominent on people’s minds increases the likelihood
people will hear and retain the messages. Early communications encourage customers to think
about wildfire season, how to prepare for outages, their role in preventing wildfires, and steps
Idaho Power is taking to mitigate wildfire risk. As the potential for wildfire increases, the tone
and messaging shifts. Messaging urges customers to update their contact information,
prepare for wildfire, and help prevent wildfires while recreating. After wildfire season and
throughout the winter months, Idaho Power’s wildfire-related outreach focuses on the
company’s ongoing efforts to reduce risk, including feeder hardening, vegetation management,
and asset inspections. The messaging continues to offer tips for year-round
outage preparedness.
Idaho Power Company Wildfire Mitigation Plan 2027
Page 80
11.6. Idaho Power Internal Communications—Employees
Idaho Power communicates wildfire mitigation-related content to employees in a variety
of ways:
• News Scans (internal newsletter for all employees)
• Emails
• Leader communications
• Online training for employees about the WMP
• Required In-person and virtual training for certain field employees
• Mock events

12Government, Industry, and Peer Utility Outreach
Section
Idaho Power Company Wildfire Mitigation Plan 2027
Page 81
12. Government, Industry, and Peer Utility Outreach
12.1. Objective
Idaho Power’s WMP includes specific activities intended to engage with key stakeholders to
share information, gain feedback, and incorporate lessons learned. Idaho Power engages in
outreach efforts to coordinate with federal, state, tribal, and local officials and agencies on
wildfire preparedness and response plans.
Idaho Power recognizes the importance of engaging with various levels of government.
Idaho Power also recognizes the importance of engagement and outreach to government and
industry with respect to potential future PSPS events to minimize customer impact. Peer utility
engagement informs the company’s efforts through the learnings of its peers.
12.2. Government Engagement
Prior to the start of wildfire season, Idaho Power meets with interested state and federal
land-management agencies in Idaho and Montana to review the company’s approach for
wildfire mitigation and discuss wildfire season operations. Throughout the year, Idaho Power
engages with federal, state, and county agencies to share information, receive feedback on
mitigation approaches (including vegetation management practices), and identify and work
toward mutually beneficial activities that may be considered in subsequent WMPs.
In 2026, Idaho Power continued to serve as a co-chair for the Southwest Idaho All-Lands
Partnership. This group is a coalition of federal and state land-management agencies, counties,
cities, businesses, nonprofits, and community members working together to pool expertise and
resources to collaboratively plan and implement landscape-scale wildfire mitigation work
across private and public lands.
The company also remains an engaged participant in the IFCIC, supporting statewide
coordination and integration of wildfire detection technologies. Idaho Power further
participates in the Idaho Office of Emergency Management's Drought and Wildfire Technical
Working Group, providing technical expertise to support wildfire planning and risk assessment
efforts, including development of the State Hazard Mitigation Plan. In addition, Idaho Power
maintains regular engagement with county emergency managers, LEPCs, public safety agencies,
elected officials, and other key stakeholders to strengthen coordination, information sharing,
and emergency preparedness before and during wildfire season.
12.3. Industry and Peer Utility Engagement
Idaho Power’s WMP is informed by peer benchmarking and utility wildfire-specific forums.
Idaho Power engages with peer utilities from the Pacific Northwest, Rocky Mountain,
and California regions, including but not limited to: Avista Utilities, Rocky Mountain Power,
Portland General Electric (PGE), Pacific Power, Chelan County Public Utility District (Chelan
Idaho Power Company Wildfire Mitigation Plan 2027
Page 82
PUD), Puget Sound Energy (PSE), Xcel Energy, NV Energy, Bonneville Power Administration
(BPA), Northwestern Energy, SDG&E, Southern California Edison (SCE), Pacific Gas and Electric
(PG&E), Sacramento Municipal Utility District (SMUD), and Liberty Electric.
Prior to the start of the 2026 wildfire season, Idaho Power attended multiple conferences,
workshops, and meetings where it engaged many of the utilities listed above in the sharing of
WMP learnings, common challenges, and innovative solutions for minimizing wildfire risk.
In the spring of 2026, Idaho Power’s Wildfire Mitigation Team attended industry conferences
hosted by Western Energy Institute (WEI) and Northwestern Energy in Bozeman, Montana,
as well as the Edison Electric Institute (EEI) and PG&E Utility Wildfire Mitigation Conference in
Concord, California. Leadership from Idaho Power’s wildfire team also participated in a wildfire
mitigation focused panel with SDG&E, SCE, and PG&E during the Western Underground
Committee Conference.
Additionally, Idaho Power continues to be a member of trade-based organizations that offer
wildfire-specific forums and discussions, including the International Wildfire Risk Management
Consortium (IWRMC), EEI, and WEI. These forums facilitate sharing of information.
For example, the IWRMC was designed as an industry-sponsored collaborative forum that
facilitates the sharing of wildfire risk mitigation insights and innovations from across the globe.
Idaho Power also participates in monthly workgroup forums through IWRMC for operations and
protocols, asset management, vegetation management, and risk management.
These workgroup forums inform operational preparedness for wildfire season as well as
provide insight into global thinking and advancements in wildfire mitigation. IWRMC is led by a
Utility Executive Steering Group, whose members work specifically on wildfire/bushfire issues
in Australia and the western U.S. Idaho Power’s engagements with IWRMC are focused on
operations and protocols, asset management, vegetation management, and risk management
with additional participation from Idaho Power’s vice president (VP) of Planning, Engineering
& Construction in IWRMC’s Executive Strategy Forums.
Idaho Power’s chief executive officer (CEO) and president is a member of the EEI Electricity
Subsector Coordinating Council Wildfire Working Group. This working group has been
coordinating with the U.S. Department of Energy (DOE) and other government agencies to
collectively address wildfire threats and potential impacts.

13Performance Monitoring and Metrics
Section
Idaho Power Company Wildfire Mitigation Plan 2027
Page 83
13. Performance Monitoring
13.1. WMP Compliance
The company’s chief operating officer (COO) is the designated oversight officer for
Idaho Power’s WMP. The VP of Planning, Engineering & Construction is responsible for
compliance monitoring, necessary training, and annual review of this WMP.
13.2. Annual Review and Compliance Reporting
Idaho Power conducts an annual review of its WMP and incorporates necessary updates based
on the learnings of the most recent wildfire season. Additionally, Idaho Power will annually
submit a compliance report regarding its most recently approved WMP to the IPUC,
consistent with the schedule and standards adopted in Order No. 36929, unless the IPUC
directs otherwise.
13.3. 2026 Lessons Learned
13.3.1. Community Outreach and Engagement
In 2026, Idaho Power refined its community outreach strategy based on lessons learned from
prior outreach efforts. During 2025, Idaho Power hosted 26 in-person and virtual outreach
events focused on outage preparedness, wildfire mitigation, and PSPS education.
Attendance data showed that Idaho Power-hosted open houses averaged approximately eight
participants per event, while community-partner-led events often attracted more than
300 attendees. To better understand customer preferences, Idaho Power conducted two
surveys: one distributed to open-house attendees and a second distributed through the
company’s Empowered Community customer feedback panel. Survey results indicated that 62%
of customers preferred virtual engagement opportunities when available, and 46% reported
they would be more likely to participate if Idaho Power partnered with local organizations.
These findings reinforced the value of accessible, flexible engagement formats and trusted
community partnerships, leading Idaho Power to shift its 2026 outreach approach toward a
combination of virtual meetings and collaborative community-based events to expand
customer reach and participation.
Between January and August of 2026, Idaho Power participated in over 20 in-person and virtual
outreach events across its service area. While community participation levels varied by event,
Idaho Power estimates it may have reached as many as 10,000 individuals through its
participation in these events.
Between May and June, Idaho Power also hosted virtual meetings in English and Spanish,
including specialized outreach opportunities for customers with medical and/or mobility needs.
Idaho Power Company Wildfire Mitigation Plan 2027
Page 84
Recorded or online resources were made available through Idaho Power's website and
customer communication channels to help extend outreach beyond live events.
Idaho Power continued to gather customer feedback during the 2026 outreach season through
surveys and direct conversations at community events. Feedback generally reinforced the value
of partnering with established community organizations and providing flexible engagement
options. Customers also expressed appreciation for receiving practical information on wildfire
mitigation, outage preparedness, emergency planning, and PSPS operations in settings that
were convenient and accessible.
The company’s 2026 outreach efforts in Idaho are summarized in Table 8.
Table 8
Idaho Power’s 2026 WMP outreach efforts

Date Time County City Event & Location
March 7 9 a.m.–1 p.m. Ada Meridian
Family Preparedness Fair
Church of Jesus Christ Latter-
day Saints 4505 N, Linder Rd.,
Meridian, ID
March 26–28 12 p.m.–9 p.m. Thu/Fri
10 a.m.–7 p.m. Sat Bannock Pocatello
Pocatello Spring Fair Idaho
State University ICCU Dome
550 Memorial Dr., Pocatello, ID
April 11 10 a.m.–2 p.m. Gem Emmett
Gem County Emergency
Preparedness Fair 980 West
Central Rd., Emmett, ID
April 18 11 a.m.–3 p.m. Bannock Pocatello
Portneuf Valley Environmental
Fair Lookout Point 426 West
Lewis St., Pocatello, ID
May 2 11 a.m.–2 p.m. Valley McCall
Valley County Wildfire
Preparedness Day Donnelly Fire
Department 244 W Roseberry
Rd., Donnelly, ID
May 12–14 8 a.m.–5 p.m. each day Bannock Pocatello
Safety Fest of the Great
Northwest Pocatello ISU
Rendezvous Complex 111
Martin Luther King Jr Wy.,
Pocatello, ID
May 13 6 p.m.–7 p.m. Southern-Eastern: Virtual Event—Outage Preparedness—Our Wildfire
Prevention Efforts—Public Safety Power Shutoffs
May 14 6 p.m.–8 p.m. Boise Garden Valley Garden Valley Wildfire
Preparedness Event
May 16 10 a.m.–2 p.m. Ada Boise
Idaho Firewise Garden Open
House Preparedness Fair Old
Penitentiary Ave., Boise, ID
Idaho Power Company Wildfire Mitigation Plan 2027
Page 85
Date Time County City Event & Location
May 16–17 9 a.m.–5 p.m. Elmore Mountain Home
Mountain Home Air Show at
the Mountain Home Air Force
Base
May 19 5:30 p.m.–8:30 p.m. Twin Falls Twin Falls
Outage Preparedness and
Wildfire Mitigation Town Hall—
Twin Falls & Jerome counties
Canyon Ridge High School 300
N College Rd W, Twin Falls, ID
May 20 6 p.m.–7 p.m. Capital Canyon-West: Virtual Event—Outage Preparedness—Our Wildfire
Prevention Efforts—Public Safety Power Shutoffs
May 23 9 a.m.–1 p.m. Lemhi Salmon
Lemhi County Farmers Market,
Veterans Memorial Park—
corner of Main and Water
Streets Downtown Salmon, ID
June 3 6 p.m.–7 p.m. Spanish Virtual Event—Outage Preparedness—Our Wildfire Prevention
Efforts—Public Safety Power Shutoffs
June 4 4 p.m.–7 p.m. Ada Meridian
Meridian Public Works
Preparedness Event Meridian
City Hall Plaza 33 E Broadway
Ave., Meridian, ID
June 6 10 a.m.–2 p.m. Blaine Hailey
Hailey Farmers Market Outage
Preparedness Booth—Roberta
McKercher Park, Hailey, ID
83333
June 6–7 8 a.m.–5 p.m. Sat.
10:30 a.m.–4 p.m. Sun Owyhee County Outpost Days—17085 Basey St. Murphy, ID
June 10 12 p.m.–1p.m. Virtual Event (Idaho) for Vulnerable Populations
June 10 12 p.m.–4 p.m. Blaine Ketchum
Ketchum Farmers Market
Outage Preparedness Booth
Forest Service Park 131 River St
E, Ketchum, ID
June 13 10 a.m.– 12 p.m. Ada Eagle
“Plan, Prepare, Protect”-
Hidden Springs/Cartwright
Ranch Residents 5876 W.
Hidden Springs Dr., Boise, ID
June 16 12 p.m.–2 p.m. Elmore Pine
Red Cross Wildfire Workshop
Pine Senior Center 350 N Pine–
Featherville Rd., Pine, ID
June–August Saturdays 9 a.m.–2 p.m. Nampa Farmer’s Market—Lloyd Square Park, Nampa, ID
June–August Tuesdays 5 p.m.–8 p.m. Caldwell Farm to Fork Farmer’s Market—Indian Creek Plaza, Caldwell, ID
July 25 10 a.m.–2 p.m. Boise |Wilderness Ranch| Community Event—Southeast Boise County
Emergency Services, Infrastructure, Evacuation Event

Idaho Power Company Wildfire Mitigation Plan 2027
Page 86
As Idaho Power prepares for the 2027 wildfire season, insights gathered through customer
surveys, event participation, and direct community feedback will be used to inform the
company's 2027 outreach strategy.
13.3.2. Aerial Inspections
In 2025, the company launched its first-year aerial inspections pilot project using UAS to inspect
distribution assets. The company completed 5,953 inspections of distribution poles in wildfire
risk zones, exceeding the 5,000-pole target for the year. The 2025 pilot project utilized
contractors to perform image collection, desktop inspections, and independent QA checks,
with confirmed issues routed to Idaho Power for correction.
As aerial inspection activities expanded in 2026, Idaho Power gained additional insights
regarding implementation of the program. Idaho Power continues to see value in continuing
and expanding its UAS pilot based on its experiences in 2026. Further, Idaho Power recognized
the importance of standardized image capture requirements to support consistent and efficient
asset evaluations. In 2026, Idaho Power refined inspection protocols and developed
standardized shot sheets that define required image angles and asset views to aid with image
quality, review efficiency, and consistency. Idaho Power will continue this work in 2027.
As part of the pilot, Idaho Power is currently working with vendors to evaluate AI and
machine-learning technologies that analyze inspection imagery and assist in the identification
and classification of potential equipment deficiencies. Preliminary results suggest AI review may
add value in this process. In 2027, Idaho Power will continue to compare AI-identified results
with traditional review methods to better understand the technology’s capabilities, limitations,
and potential applications.
Based on lessons learned from the pilot and subsequent program expansion, Idaho Power
increased its aerial inspection target from approximately 10,000 distribution poles in 2026 and
plans to inspect approximately 15,000 distribution or transmission poles in wildfire risk zones
during 2027.
13.3.3. PSPS Event Management Tools and Exercise
Based on learnings from 2025, Idaho Power implemented several enhancements to its Event
Management Software (EMS) to strengthen PSPS readiness and execution capabilities for 2026.
These enhancements focused on data management, information verification,
and communications processes, including the addition of a weather ensemble viewer to
enhance situational awareness and support decision-making during potential PSPS events.
Prior to the 2026 wildfire season, Idaho Power conducted a three-day PSPS mock event.
The exercise provided an opportunity to test and train on the tools, processes,
and communication protocols that would be used during an actual PSPS event,
strengthening readiness and validating operational workflows. The exercise included
engagement with public safety partners and interested critical facilities, who, following the
Idaho Power Company Wildfire Mitigation Plan 2027
Page 87
mock exercise, highlighted the value of the Public Safety Partner Portal and associated
data-sharing capabilities. Partners noted that the ability to visualize potentially impacted areas
through the portal enhanced their situational awareness before, during, and after an event,
while the inclusion of critical facility information supports effective emergency planning
and coordination.
13.3.4. Internal Vegetation Management Crew
Beginning in 2024, Idaho Power began piloting an internal vegetation management crew for
tree trimming and pruning activities. Idaho Power’s internal vegetation management crew
worked to develop local customer relationships and leverage access to the company’s
operational and customer systems in planning and execution. Investments in specialized
equipment, including a large chipper with a winch for whole-tree processing, have increased
productivity and enabled more efficient vegetation removal methods. Based on these
successes, Idaho Power transitioned the pilot crew to a full-time, permanent program in 2026.
13.3.5. Wildfire Operational Response Team
In 2026, Idaho Power began utilizing internal seasonal wildfire operations specialists to support
active wildfire events. The program demonstrated the value of proactive infrastructure
protection and coordination with fire agencies and the respective incident command structure.
During the 2026 wildfire season, the internal wildfire operational response team responded to
approximately 32 wildfire incidents and helped save approximately 189 poles and structures
through pre-suppression actions such as vegetation removal; grubbing; and application of
water, foam, or retardant. One lesson learned by the company was that on-site coordination
with the respective incident command structure can enhance asset protection outcomes.
This initiative has underscored the effectiveness of early mitigation work, employees with
former wildfire experience, and partnerships with incident management teams.
13.3.6. Helicopter Standby Pilot
Idaho Power continued its helicopter standby pilot program during the 2026 wildfire season,
building on lessons learned from previous years. A lesson learned by the company has been
aligning helicopter availability with wildfire conditions, considering the increasing competition
for aviation resources. During 2026, Idaho Power observed that wildfire conditions and
associated demand for aviation resources began emerging earlier in the season than
anticipated. The company experienced instances where access to helicopter resources was
limited prior to the commencement of the standby contract period. As a result, Idaho Power
will continue evaluating the timing and duration of future standby contracts to better align with
evolving wildfire conditions.
In 2026, Idaho Power utilized the standby helicopter on multiple occasions to support aerial
patrols of distribution facilities located in remote areas, which, in those instances, reduced the
time required to inspect lines and supported restoration efforts following outages. The
helicopter was also utilized to support patrol and restoration of transmission facilities following
Idaho Power Company Wildfire Mitigation Plan 2027
Page 88
wildfire-related system impacts, as well as other construction activities during the standby
period. The company has also learned the importance of maintaining operational flexibility
when utilizing contracted aviation resources. Although the standby contract provides dedicated
access to aerial resources, flight operations may occasionally be affected by maintenance
requirements, weather conditions, or other operational considerations, such as temporary
flight restrictions in active wildfire areas.
Based on lessons learned from the pilot, Idaho Power plans to continue utilizing a helicopter
standby contract during the 2027 wildfire season and will evaluate whether adjustments to the
timing of the standby period are warranted to better align with changing wildfire conditions.
In 2027, the company anticipates continuing to use helicopter resources, when available and
practical, to support outage response, post-event patrols, system restoration activities,
and other operational needs where rapid aerial access can aid situational awareness and
reduce restoration times.

14Wildfi re Mitigation Plan Cost Summary
Section
Idaho Power Company Wildfire Mitigation Plan 2027
Page 89
14. WMP Cost Summary
In 2027, Idaho Power estimates spending approximately $51 million in operations and
maintenance (O&M) expenses in Idaho to further wildfire mitigation measures. Table 9
summarizes the company’s planned O&M expenditures associated with executing its 2027
Idaho and Montana WMP. Estimated amounts reflect the company’s best estimates.
These estimates will likely change in the future as the company reviews and refines its WMP
and associated mitigation activities.
Idaho Power’s wildfire mitigation efforts also include capital investments in system
infrastructure, many of which also provide co-benefits to the company, such as increased
safety, reliability, and resiliency of the system, as identified in Section 3 (Table 3).
Capital investment programs are summarized in Table 10.
Table 9
Estimated O&M expenses for wildfire mitigation, $000s

Wildfire Mitigation Program Description
2027
Forecast
A. Geographical Risk Assessment
Risk Modeling—Risk maps, fire simulation, probabilistic model development, and support $2,273
B. Situational Awareness and Monitoring

Weather forecasting—System development and support, data services, climatology $96
Weather forecasting personnel—FPI and PSPS $172
Weather forecasting—Weather station maintenance $219
Pole loading modeling & assessment (Contract service) $72
Wildfire detection cameras $288
C. Workforce Preparedness

Tools/Equipment $19
IWRMC $40
D. Transmission & Distribution Programs

O&M component of capital work $493
Annual O&M T&D patrol maintenance repairs $125
Transmission thermography inspection mitigation $48
Distribution thermography inspection mitigation $48
Thermography technician personnel $164
Transmission wood pole fire-resistant wraps $239
Wildfire Mitigation Program labor $1,242
Patrolmen for wildfire pre-season inspections in wildfire risk zones $431
Covered wire evaluation—Pilot program $2
Idaho Power Company Wildfire Mitigation Plan 2027
Page 90
Wildfire Mitigation Program Description
2027
Forecast
Drone Beyond Visual Line of Sight Waiver for PSPS Patrols $0
UAS (drone) Inspection Pilot $867
E. Vegetation Management

Transition to/maintain 3-year Vegetation Management Cycle (includes Enhanced Practices for
Distribution Tier 3 & Tier 2 Risk Zones) $42,134
Internal tree trimming crews $769
Line clearing personnel $197
Fuel Reduction Program $72
F. Public Outreach and Engagement

Wildfire/wildfire mitigation education/communication—Advertisements, bill inserts, meetings, other
& PSPS customer education/communication—Advertisements, bill inserts, other $164
Public meetings/event fees for PSPS engagement, maps, flyers $8
Community and customer engagement and outreach $180
G. Line Operations Practices PSPS/Emergency Preparedness and Technology

Communication/alert tool for PSPS customer alerts/extended use $216
Fire suppression resources $180
Standby helicopter service $287
CRCs $5
Total $51,050
These are best-known estimates at the time of this WMP’s filing and are subject to change. These numbers are provided only for the purpose of
review and approval of this WMP pursuant to the WSCA. They should not be used for any other purpose.

Table 10
2026 WMP forecasted capital investments, $000s*
Mitigation Program Program Description 2027 Planned in Service
Overhead Primary Hardening Program Replacement and upgrades of hardware and equipment $21,000
Strategic Undergrounding Select conversion of overhead to underground
distribution
$12,000
Recloser Segmentation and
Communication Upgrades
Installation, relocation, and expanded communication for
automatic reclosing overcurrent protection devices
$350
Wildfire Detection Cameras Cameras enabled with AI to detect smoke and notify
first responders
$35
Atmospheric Science Weather Stations Installation of weather stations to gain situational
awareness
$100
*These are estimates only. The costs may increase or decrease due to such factors as inflation or scope changes. These numbers are provided
only for the purpose of review and approval of this WMP pursuant to the WSCA. They should not be used for any other purpose.

Appendix A: Wildland Fire
Preparedness and
Prevention Plan

October 2026
© 2026 Idaho Power
Idaho Power Company Wildland Fire Preparedness and Prevention Plan
Page i
Table of Contents
1. Plan Overview ........................................................................................................................... 1
A. Intent of Plan .................................................................................................................... 1
B. Scope of Plan .................................................................................................................... 1
2. Situational Overview and Applicability ..................................................................................... 1
A. Wildfire Season ................................................................................................................ 1
B. Wildfire Risk Zones ........................................................................................................... 1
C. Fire Potential Index .......................................................................................................... 2
D. Decision Making for Field Work Activities ....................................................................... 2
3. Preparedness—Tools and Equipment ...................................................................................... 4
A. Required Tools and Equipment ........................................................................................ 4
B. Required Personal Protective Equipment ........................................................................ 5
C. Land Management Agency Restrictions and Waivers ..................................................... 5
4. Prevention—Practices of Field Personnel ................................................................................ 5
A. General Employee Practices ............................................................................................ 5
B. Behaviors Relating to Vehicles and Combustion Engine Power Tools ............................ 7
5. Reporting................................................................................................................................... 8
A. Fire Ignition ...................................................................................................................... 8
B. Fire Reporting ................................................................................................................... 9
6. Training ..................................................................................................................................... 9
7. Roles and Responsibilities ......................................................................................................... 9
8. Audit ........................................................................................................................................ 10

Idaho Power Company Wildland Fire Preparedness and Prevention Plan
Page ii

Idaho Power Company Wildland Fire Preparedness and Prevention Plan
Page 1
1. Plan Overview
A. Intent of Plan
The purpose of this Wildland Fire Preparedness and Prevention Plan (Plan) is to provide
guidance to Idaho Power Company (IPC) employees to help prevent the accidental ignition and
spread of wildland fires (wildfires) associated with employee work activities in locations and
under conditions where there is a heightened risk of wildfire. It is expected for applicable IPC
employees be aware of the provisions of this Plan and operate in accordance with the Plan.
B. Scope of Plan
The scope of this Plan extends to tools, equipment, and field behaviors IPC employees
incorporate during wildfire season to mitigate the risk of wildfire resulting from general work
practices. Other fire mitigation activities, such as operations of Transmission and Distribution
(T&D) lines facilities, vegetation management, and T&D lines programs that mitigate wildfire
risks are not included in this Plan; they are referenced in the separate Wildfire Mitigation Plan
(WMP).
2. Situational Overview and Applicability
A. Wildfire Season
The provisions of this Plan shall be applicable during wildfire season. Idaho’s wildfire season is
defined by Idaho Code § 38-115 as extending from May 10 through October 20 each year, or as
otherwise extended by the director of the Idaho Department of Lands (IDL). Montana’s wildfire
season is defined by Montana Code § 76-13-102 as the period of each year beginning May 1 and
ending September 30. Oregon’s wildfire season is designated by the State Forester each year
pursuant to Oregon Revised Statute § 477.505 and typically begins in June.
Should any local, state, or federal government land management agency (i.e., the Bureau of
Land Management [BLM], U.S. Forest Service, Oregon Department of Forestry, IDL, etc.) issue
any wildfire related order that extends wildfire season beyond that specified above,
that agency’s order shall govern.
Many variables—drought conditions, weather, and fuel moisture—can impact fire potential.
Flexibility, judgment, attention to current and forecasted field conditions, and attention to
governmental agency issued wildfire orders are necessary such that operational practices can
be adjusted accordingly.
B. Wildfire Risk Zones
IPC’s WMP includes a Wildfire Risk Map of geographic areas where IPC has infrastructure or
equipment that IPC considers may be subject to a heightened risk of wildfire. This Wildfire Risk
Idaho Power Company Wildland Fire Preparedness and Prevention Plan
Page 2
Map may be accessed through geographic information system (GIS) applications. All lands in the
vicinity of IPC facilities are mapped as Tier 2 (colored yellow on maps), Tier 3 (colored red on
maps), or areas of lesser wildfire risk (i.e., not within a Tier 2 or Tier 3 zone). Tier 2 and Tier 3
zones are designated as wildfire risk zones (WRZ). The provisions of this Plan shall apply to work
activities taking place during wildfire season in WRZs.
C. Fire Potential Index
IPC’s Atmospheric Sciences department has developed a Fire Potential Index (FPI) that forecasts
the short-term fire threat in WRZs. The FPI consists of a numerical score ranging from 1 to 16.
The FPI scores are grouped into the following three index levels:
1. Green: FPI score of 1 through 11
2. Yellow: FPI score of 12 through 14
3. Red: FPI score of 15 through 16
During wildfire season, IPC will determine a daily FPI as described in Section 4.2 of the WMP for
each of IPC’s WRZs. The FPI information is contained within IPC GIS viewers available to
applicable IPC employees.
D. Decision Making for Field Work Activities
Employees working in the field should generally be aware of current and forecasted weather
and field conditions. The following process steps shall apply to IPC employees contemplating
field work during wildfire season.
Planned or Scheduled Work Activities
1. Employees working in the field in a WRZ and not working on transmission or primary
distribution lines should:
• Be aware of the current and forecasted weather and the FPI level for the area where
the work will be performed, through the FPI dashboard.
• Once the FPI level for the work zone is identified, employ Prevention—Practices of
Field Personnel (see Section 4 of this Plan).
2. Employees working in the field in a WRZ and working on transmission or primary
distribution lines should:
• Be aware of the current and forecasted weather and the FPI level for the area where
the work will be performed.
• Once the FPI level for the WRZ is identified, proceed as follows for each FPI level:
Idaho Power Company Wildland Fire Preparedness and Prevention Plan
Page 3
• Green FPI in All Zones: Proceed with the work. Follow Prevention—Practices
of Field Personnel (see Section 4 of this Plan).
• Yellow FPI in All Zones: Proceed with the work. Follow Prevention—Practices
of Field Personnel (see Section 4 of this plan).
• Red FPI
• In Tier 2 Zone: Proceed with the work. Follow Prevention—Practices of
Field Personnel (see Section 4 of this plan).
• In Tier 3 Zone: STOP. No planned work activities shall take place unless
approved by operations level manager. Work consideration will be
restoration of electric service or work deemed critical to providing safe,
reliable electric service. If work is approved to proceed, follow
Prevention—Practices of Field Personnel (see Section 4 of this plan).

Tier 2 Tier 3 Fire Potential Index (FPI) Higher 15–16 (Red) Use Prevention—Practices of Field Personnel STOP/NO WORK (unless exception authorized) Elevated 12–14 (Yellow) Use Prevention—Practices of Field Personnel Use Prevention—Practices of Field Personnel Normal 1–11 (Green) Use Prevention—Practices of Field Personnel Use Prevention—Practices of Field Personnel

3. Land Management Agency Restrictions
• Follow the requirements and restrictions of any wildfire restrictions-related order
issued by local, state, or federal land management agencies.
Emergency Response and Outage Restoration Work Activities
Follow the same steps as identified above for planned work activities. However, it is recognized
that the nature of emergency response and outage restoration situations will often require
Idaho Power Company Wildland Fire Preparedness and Prevention Plan
Page 4
exceptions to the above. In these situations, leadership should be consulted, and work will be
undertaken at IPC’s discretion given the nature of the emergency or outage at hand.
3. Preparedness—Tools and Equipment
A. Required Tools and Equipment
Outside of wildfire season, all employees are required to carry standard tools and equipment in
accordance with the IPC Safety Standards and Fleet Services.
During wildfire season, employees who are working in a WRZ are required to carry the tools and
equipment listed below:
• One round, pointed shovel at least 8 inches wide, with a handle at least
26 inches long.
• One axe or Pulaski with a 26-inch handle or longer.
• A combination of shovels, axes, or Pulaski available to each person on the crew.
• One fire extinguisher rated no less than 2A:10BV (5 pounds).
• A supply of water, sufficient for the initial attack, with an effective spraying
mechanism (i.e., backpack pumps, water sprayer, etc.).
During wildfire season, employees working on construction or maintenance of transmission or
distribution lines in situations governed by the wildfire prevention provisions of the March 2019
Master Agreement between IPC and the State of Idaho BLM, or in any WRZ, are additionally
obligated to have at least one-on-site vehicle equipped with at least the following fire
equipment
• Fire-suppression hand tools (i.e., shovels, rakes, Pulaskis, etc.).
• A 16- to 20-pound fire extinguisher.
• A 30- to 200-gallon mechanical fire pumper
IPC personnel will be trained to use the above tools and equipment to aid in extinguishing a fire
ignition before it gets out of control if the situation warrants such action. In the event of a fire
ignition, IPC personnel present at the time of the ignition will take action consistent with that
person’s training and experience to control the fire ignition while still accounting for their own
personal safety; however, IPC is generally not responsible for fighting fires. This responsibility
remains with federal, state, and local firefighting organizations.
Idaho Power Company Wildland Fire Preparedness and Prevention Plan
Page 5
B. Required Personal Protective Equipment
Standard IPC personal protective equipment (PPE) shall be worn in accordance with the IPC
Safety Standards.
In addition, IPC personnel are expected to comply with the requirements of the fire suppression
agency managing a designated fire area. Regardless of the requirements of the fire suppression
entity, IPC personnel entering a designated fire area will carry at least the following:
• Hardhat
• Long sleeve flame-resistant (FR) shirt and FR pants
• Leather gloves
• Exterior leather work boots, 8-inch high, lace-type with Vibram type soles
• Fire shelter
C. Land Management Agency Restrictions and Waivers
The Wildfire Mitigation department will strive to notify operations leadership within Power
Supply, Customer Operations and Business Development, and T&D Engineering and
Construction of any wildfire-related requirements and restrictions orders issued by local, state,
or federal land management agencies. Typical orders issued each wildfire season include
the following:
• BLM, USFS, and IDL Stage I or II Fire Restrictions: Field personnel shall take appropriate
precautions when conducting work activities that involve an internal combustion engine,
generating a flame, driving over or parking on dry grass, the possibility of dropping a line
to the ground, or explosives. Precautions include a Fire Prevention Watch person who
will remain in the area for one hour following the cessation of that activity. Also,
IPC personnel will not smoke unless within an enclosed vehicle, building,
designated recreation site, or while stopped in an area at least 3 feet in diameter that is
barren or cleared of all flammable materials. All smoking materials will be removed from
work sites. No smoking materials are to be discarded. During Stage II Fire Restrictions,
IPC’s Environmental Affairs department will obtain an appropriate waiver.
4. Prevention—Practices of Field Personnel
A. General Employee Practices
The following list identifies practices and behaviors employees shall employ while working in
WRZs during wildfire season.
Idaho Power Company Wildland Fire Preparedness and Prevention Plan
Page 6
1. Participate in daily tailboards that include discussion around fire mitigation planning.
Discussion topics may include, but are not limited to, the following:
• Items 2 through 7 below
• Water suppression
• Hand tools
• Welding blankets
• Mowing high brush areas (weed whacker)
• Watering down the worksite before setting up equipment
2. Consider and evaluate weather conditions and terrain to be worked. Items to be
considered must include, but are not limited to, the following:
• Identify the FPI for the area being worked.
• Monitor weather forecasts and wind and humidity conditions.
• Identify surroundings (i.e., wildland-urban interface, BLM lands, Forest Service lands,
proximity to any homes and structures, etc.).
• Identify local fire departments and locations.
• Evaluate the terrain being worked in (steep or flat).
• Consider whether the work will take place during the day or at night.
3. Consider and evaluate work procedures and tools that have potential to cause a spark or
flash. Items to be considered may include, but are not limited to, the following:
• Performing energized work
• Grinding or welding
• Trees contacting electrical conductors
• Hot saws
• Chainsaws
• Weed whackers
• Sawzalls
4. Monitor the condition of the worksite throughout the project, including prior to leaving
the work area for the night or before moving on to the next structure.
Idaho Power Company Wildland Fire Preparedness and Prevention Plan
Page 7
5. If employee cooking stoves are brought to the worksite, follow the following practices:
• No open flames permitted
• The stove or grill must be in good repair and of sturdy construction.
• Stoves must be kept clean; grease build up is not allowed.
• Fueling of the stove must follow the fueling procedures when liquid fuels are used.
• Cooking must be in areas free of combustible materials.
6. If smoking on the job site, follow the following practices:
• Do not discard any tobacco products from a moving vehicle.
• Smoke only in designated areas and dispose of smoking materials in half-filled water
bottles or coffee containers half-filled with sand. Smoking materials shall not be
discarded on any site.
7. Conduct a final inspection or post-check the work site for any ignition hazards that
may remain.
B. Behaviors Relating to Vehicles and Combustion Engine
Power Tools
Employees must follow the vehicle-related processes set out below when working in WRZs
during wildfire season.
1. Vehicle Procedures:
• Regularly inspect engine exhaust, spark arresters, and electrical systems of vehicles
used off road for debris, holes, or exposed hot components, and ensure heat shields
and protective components are in place.
• Conduct inspections of the vehicle undercarriage before entering or exiting the
project area to clear vegetation that may have accumulated near the vehicle’s exhaust
system.
• Park vehicles overnight in areas free from flammable vegetation at a minimum
distance of 10 feet.
• Vehicles and equipment should not be stationary in areas where grass, weeds, or
other flammable vegetation will be in contact with the exhaust system. If there is no
other workable option for a location that doesn’t include weeds, grass, or other
flammable vegetation, the vegetation and debris should be removed or a
Idaho Power Company Wildland Fire Preparedness and Prevention Plan
Page 8
fire-resistant material, such as a welding blanket, can be used to cover flammable
material to act as a heat shield.
2. Fueling procedures:
• Tools or equipment should NOT be fueled while running.
• Allow a cool-down period to give equipment time to no longer be considered a
fire risk.
• Allow for a 10-foot radius from all ignition sources.
• Clear any combustible debris from the immediate area.
• Never smoke while fueling.
3. Combustion engine power tools:
• Inspect spark arrester screens daily; clean or replace when clogged, damaged, or
missing or remove from service until repaired for combustion engine power tools
such as:
• Generators
• Pony motors
• Pumps
• Chainsaws
• Hot saws
• Weed whacker
• Brush hog
5. Reporting
A. Fire Ignition
All fire ignitions shall be reported to IPC regional or system dispatch as soon as practicable.
All work shall immediately stop, and reasonably prudent steps taken to extinguish the fire with
available tools, water, and equipment considering the individual’s training and experience,
subject to the safety of personnel. If the fire gets too large to safely contain or extinguish,
ensure all employees are accounted for and get to a safe location.
Idaho Power Company Wildland Fire Preparedness and Prevention Plan
Page 9
B. Fire Reporting
When reporting a fire ignition to IPC regional or system dispatch provide the
following information:
• Your name
• Location—Reference points, including an address, road or street name, cross streets,
mountain range, GPS coordinates, as applicable
• Fire information
• Size and behavior of the fire
• Weather conditions
6. Training
Each employee who performs work in WRZs shall be trained on the content of this document
and be required to complete annual refresher courses through the Workday system.
Employees that may enter a designated fire area are required to complete fire extinguisher and
fire shelter training annually. Documentation of all training shall be retained in Workday.
7. Roles and Responsibilities
Employee 1. Be familiar with the requirements specified in this Plan and operate in accordance with
this Plan.
Crew Foreman and
Front-Line Leaders
1. Ensure direct report employees are familiar with and follow Plan requirements.
2. Ensure the crew or team conducts field operations in accordance with this Plan.
3. Be aware of daily weather forecast and FPI level (by viewing the FPI dashboard or by
calling in to dispatch or a leader):
a) Ensure employees are aware of the FPI level.
b) Ensure work practices comply with Plan.
4. Ensure annual training of employees is completed prior to wildfire season.
5. Ensure required tools and equipment are in place prior to wildfire season.
Manager (Regional
Operations Manager,
Area Manager,
T&D Construction Manager)
1. Ensure crew foremen and front-line leaders understand they are to operate in
accordance with Plan requirements.
2. Support crew foremen and front-line leaders in scheduling training and making
required tools and equipment available.
3. View daily weather forecast and FPI dashboard:
a) Authorize any exceptions to working when FPI is “Red” and the WRZ is Tier 3.
b) Ensure specified audits are completed in a timely manner.
Atmospheric Sciences
Department
1. Provide daily weather forecast and update the FPI dashboard.
Idaho Power Company Wildland Fire Preparedness and Prevention Plan
Page 10
Wildfire Mitigation
Department
1. Monitor local, state, and federal land management agencies for any wildfire restriction
orders issued.
2. Communicate content of any orders issued to Power Supply, Customer Operations and
Safety, and Planning Engineering and Construction leadership.
Vice President of Planning,
Engineering and Construction
(VP of PEC)
1. Ensure annual review/update of this Plan is conducted.

8. Audit
Before the start of wildfire season (May 10), all vehicles associated with work on transmission
and distribution lines will be informally audited by leadership to ensure those required to carry
certain equipment pursuant to this Plan are properly equipped with firefighting equipment.
The following checklist must be completed, dated, and signed by the vehicle operator.
Wildland Fire Preparedness Audit Checklist
Inspector
Signature
Date
Crew

Individual Vehicle
During wildfire season, each vehicle working in a WRZ is required to carry the following items:
• One round, pointed shovel at least 8 inches wide, with a handle at least 26 inches
long.
• One axe or Pulaski with a 26-inch handle or longer.
• A combination of shovels, axes, or Pulaskis to each person on the crew.
• One fire extinguisher rated no less than 2A:10BV (5 pounds).
• A supply of water, sufficient for initial attack, with an effective spraying mechanism
(i.e., backpack pumps, water sprayer, etc.).
Line Crew
During wildfire season, employees working on construction or maintenance of T&D are
obligated to have at least one on-site vehicle equipped with at least the following:
Idaho Power Company Wildland Fire Preparedness and Prevention Plan
Page 11
• Fire suppression hand tools (shovels, Pulaski, axes, etc.) for each member of the crew
• A 16- to 20-pound fire extinguisher
• A supply of water, sufficient for initial attack, with an effective spraying mechanism
(i.e., backpack pumps, water sprayer, etc.)
• A 30- to 200-gallon mechanical fire pumper
PPE: IPC and BLM standards
Each employee that enters a designated fire area is required to have the following PPE:
• Hard hat
• Safety glasses
• Hearing protection
• Long sleeve FR shirt and FR pants
• Leather gloves
• Exterior leather work boots 8-inch-high lace type with Vibram type soles
• Fire shelter

Idaho Power Company Wildland Fire Preparedness and Prevention Plan
Page 12

Appendix B: Wildfire Public
Safety Power Shutoff Plan

October 2026
© 2026 Idaho Power
Idaho Power Company Wildfire Public Safety Power Shutoff Plan
Page i
Table of Contents
1. Public Safety Power Shutoff Overview ..................................................................................... 1
2. Definitions ................................................................................................................................. 1
3. PSPS Implementation and Evaluation Considerations ............................................................. 2
3.1. Fire Potential Index .......................................................................................................... 2
3.2. National Weather Service Red Flag Warning ................................................................... 2
3.3. Publicly Available Weather Models ................................................................................. 3
3.4. Idaho Power Weather Model .......................................................................................... 3
3.5. Storm Prediction Center Fire Weather Outlooks ............................................................. 4
3.6. Current Weather Observations ........................................................................................ 4
3.7. GBCC Morning Briefing .................................................................................................... 4
3.8. GBCC Current and Predicted ERC and F100 ..................................................................... 4
3.9. Fire Agency Input ............................................................................................................. 4
3.10. De-Energization Windspeed Considerations ................................................................... 5
4. De-Energization Decision-Making ............................................................................................. 5
5. PSPS Operations and Communication Phases .......................................................................... 6
5.1. Phase 1 and Incident Team Activation ............................................................................. 6
5.2. Phase 2 ............................................................................................................................. 7
5.3. Phase 3: De-Energization ................................................................................................. 8
5.4. Phase 4: Re-Energization.................................................................................................. 9
6. Post-incident Review ................................................................................................................ 9
7. Exercises .................................................................................................................................... 9

Idaho Power Company Wildfire Public Safety Power Shutoff Plan
Page ii

Idaho Power Company Wildfire Public Safety Power Shutoff Plan
Page 1
1. Public Safety Power Shutoff Overview
A Public Safety Power Shutoff (PSPS) is among the wildfire mitigation practices described in
Idaho Power’s Wildfire Mitigation Plan (WMP). Idaho Power may conduct a PSPS for electrical
facilities located within wildfire risk zones if considered appropriate by Idaho Power. PSPS allows
for proactive de-energization of targeted electrical facilities located within wildfire risk zones
during extreme weather to reduce wildfire risk.
Idaho Power developed this Public Safety Power Shutoff Plan (PSPS Plan or Plan) to guide its use
of PSPS. The Plan includes implementation considerations, de-energization criteria, and the
associated community and customer communications protocols. Given the inherently disruptive
nature of power outages, PSPS events are evaluated to balance wildfire risk with potential PSPS
impacts on Idaho Power customers and the communities the company serves. Idaho Power will
only consider performing PSPS events when Idaho Power facilities located within wildfire risks
zones may be impacted by extreme weather. Depending on system configuration,
implementation of a PSPS event may also require de-energization of facilities outside wildfire
risk zone boundaries to safely isolate the electrical facilities serving the affected wildfire
risk zones.
The unpredictable nature of wildfire and weather patterns can create challenges with
forecasting when a PSPS event should be implemented. Real-time evaluations and
decision-making are therefore important in making PSPS determinations. Those determinations
may result in a decision not to de-energize or even a proactive de-energization in areas not
originally anticipated to be included in a PSPS event.
Idaho Power only considers implementation of PSPS during wildfire season. Outside of wildfire
season, Idaho Power is not required to consider PSPS events; therefore, this Plan is inactive.
This Plan is reviewed and updated annually, as necessary.
2. Definitions
Critical Facilities—The facilities identified by Idaho Power that, because of their function or
importance, have the potential to threaten life, safety, or disrupt essential socioeconomic
activities if their services are interrupted.
ESF-12 (Emergency Support Function-12)—Liaison from a given state’s designated emergency
support function for energy utilities during an emergency.
Exercise—Planned activities and assessments that ensure continuity of operations, provide and
direct resources and capabilities, and gather lessons-learned to develop core capabilities
needed to respond to incidents.
Idaho Power Company Wildfire Public Safety Power Shutoff Plan
Page 2
Community—A group of people who share goals, values, and institutions.1
Local Emergency Manager—A person assigned a role in a jurisdiction that oversees the day-to-
day emergency management programs and activities.2
Public Safety Partners—ESF-12, local emergency management, and other agencies
as applicable.
3. PSPS Implementation and Evaluation
Considerations
Idaho Power will initiate the process that may ultimately result in a PSPS if the company
determines a combination of anticipated critical conditions exist that indicate potential
significant wildfire risk associated with Idaho Power’s transmission and distribution (T&D)
facilities in a wildfire risk zone under those known conditions. Idaho Power will evaluate as a
whole (not relying on one single factor but a combination of all factors), without limitation, the
criteria set forth in this section both in deciding whether to initiate the process that may
ultimately result in a PSPS and in continuing to evaluate whether to proceed with the process
that may ultimately lead to de-energization. The following subsections list the varying data
sources Idaho Power may consider in deciding whether to initiate the PSPS process and in
evaluating continuation, postponement, or termination of the PSPS process.
3.1. Fire Potential Index
Idaho Power forecasts wildfire potential in each of Idaho Power’s wildfire risk zones during
wildfire season using a tool described as a Fire Potential Index (FPI), described further in
Section 4.2 of the WMP. This tool is designed to support operational decision-making during
wildfire season. The FPI converts environmental, statistical, and scientific data into a numeric
forecast of the short-term fire threat. As described in Section 4.2 of the WMP, a FPI score of 15
or 16 is classified Red and is considered to indicate higher potential for a fire to develop and
spread. Idaho Power will consider whether the FPI is Red in determining whether to initiate the
PSPS process.
3.2. National Weather Service Red Flag Warning
A Red Flag Warning (RFW) is a forecast warning issued by the National Weather Service (NWS)
to inform the public, firefighters, and land management agencies that conditions are ideal for

1 FEMA definition under “Communities” (pg. 26) National Response Framework (fema.gov).
2 FEMA definition under “Local Government” (pg. 29) National Response Framework (fema.gov).
Idaho Power Company Wildfire Public Safety Power Shutoff Plan
Page 3
wildland fire combustion and rapid spread. RFWs are often preceded by a Fire Weather Watch
(FWW), which indicates weather conditions that could occur in the next 12 to 72 hours.
The NWS has developed different zones across the nation for providing weather alerts (such as
RFWs) to more discrete areas. These zones are shown on this NWS webpage: Fire Weather.3
RFWs are monitored and factored into Idaho Power’s determination of whether to initiate the
PSPS process.
In rare instances, the NWS may issue a Red Flag Warning Particularly Dangerous Situation (PDS).
The PDS designation is reserved for the most critical fire weather conditions, when forecasters
have high confidence that a combination of very strong winds, extremely low humidity, and dry
fuels will result in rapid ignition and uncontrollable fire spread. Idaho Power is more likely to
initiate the PSPS process if an RFW PDS has been issued for an area in which a wildfire risk zone
is located; however, a RFW PDS does not, alone, dictate that Idaho Power must initiate the PSPS
process.
3.3. Publicly Available Weather Models
Idaho Power's Atmospheric Science department uses the following weather models to predict
weather timing, duration, and intensity:
• Pivotal Weather Link (pivotalweather.com/model.php): Provides numerical weather
data, including an NWS blend of models, European Centre for Medium-Range Weather
Forecasts (ECMWF), United Kingdom Meteorological Office weather service
information, and Geostationary Operational Environmental Satellite (GOES) 16 satellite
information.
• Graphical Weather Link (graphical.weather.gov/sectors/conusFireWeek.php): An NWS
website providing weather, water and climate data, forecasts, and warnings for the
United States for the protection of life and property. The Fire Weather page provides a
daily and weekly view of multiple weather and environmental conditions influencing
wildfire activity.
3.4. Idaho Power Weather Model
Idaho Power maintains its own Weather Research and Forecasting (WRF) model using
high-resolution data from Idaho Power’s weather stations across its service area. This model,
along with publicly available weather models, helps develop weather forecasts that include
timing, duration, and intensity of weather systems. An Idaho regional WRF low-resolution map
view is available to the public at atmo.boisestate.edu/view/.

3 National Weather Service, Fire Weather , Idaho, https://www.weather.gov/wrh/fire?wfo=boi.
Idaho Power Company Wildfire Public Safety Power Shutoff Plan
Page 4
3.5. Storm Prediction Center Fire Weather Outlooks
The Storm Prediction Center’s Fire Weather Outlook provides a current, one-day-ahead and
three- to eight-day forecast for wildfires over the contiguous U.S. This forecast accounts for pre-
existing fuel conditions combined with predicted weather conditions that result in a significant
risk of wildfire ignition or spread.
3.6. Current Weather Observations
Monitoring real-time weather conditions assists in determining whether the associated risks
warrant the need for a PSPS event. Resources available for observing current weather
conditions include direct, real-time data from Idaho Power’s network of fire weather stations as
well as Remote Automatic Weather Stations, and the NWS National Oceanic and Atmospheric
Administration’s (NOAA) Weather and Hazards Viewer.4
3.7. GBCC Morning Briefing
The Great Basin Coordination Center (GBCC) is the focal point for coordinating the mobilization
of resources for wildland fire and other incidents throughout the Great Basin geographic area,
which encompasses Utah, Nevada, Idaho south of the Salmon River, the western Wyoming
mountains, and the Arizona Strip. The GBCC hosts a morning briefing during wildfire season that
provides situational awareness for Idaho Power's service area.
3.8. GBCC Current and Predicted ERC and F100
The GBCC as described above also provides day-ahead Energy Release Component (ERC),
100-Hour Fuel Moisture (F100) and other fuel condition information that helps Idaho Power
understand wildfire potential in the service area.
3.9. Fire Agency Input
Idaho Power listens to update briefings provided by Boise NWS fire forecasters and National
Interagency Fire Center (NIFC) Predictive Service forecasters as needed, generally regarding data
clarification, to streamline the transfer of data, information, and communications about
wildland fires that may impact wildfire risk zones.
Idaho Power may work with other agencies, including the U.S. Bureau of Land Management
(BLM) and U.S. Forest Service, as wildland fires approach or impact Idaho Power T&D facilities.

4 NOAA, Weather and Hazards Viewer, https://www.wrh.noaa.gov/map/?obs=true&wfo=boi
Idaho Power Company Wildfire Public Safety Power Shutoff Plan
Page 5
3.10. De-Energization Windspeed Considerations
The environmental conditions in the areas where Idaho Power may consider initiating PSPS vary
drastically from high desert landscape to mountainous terrain. Weather and environmental
conditions also vary greatly within this area and can change in minutes. Regional vegetation
becomes “conditioned” to withstand different environmental conditions, which also influences
de-energization thresholds. To account for the impact these variations have on fire risk
generated by weather conditions, Idaho Power has developed regional windspeed
considerations, which it continues to refine. Idaho Power will consider forecasted windspeeds in
the context of deciding whether to initiate the process that may lead to PSPS.
4. De-Energization Decision-Making
Due to the dynamic and complex nature of wildfire and weather behavior, PSPS decisions are
made in real time using the best available information from meteorological forecasts,
field intelligence, and system conditions. Idaho Power prioritizes a risk-informed approach that
balances wildfire prevention with the need to maintain electric service for public safety, such as
firefighting activities, emergency communications, and essential services.
Idaho Power’s decision to de-energize will be based on the totality of the circumstances,
including the sources of data listed above in Section 3 and any field observer observations
(discussed further in Section 5.2), and thus is not reducible to a formula or definitive triggers. It
will involve an evaluation of multiple risk variables, including wind speed, relative humidity, fuel
moisture, and infrastructure type.
Idaho Power’s approach, due to the inherent risks and downsides with proactive de-
energization, is to employ de-energization only as a tool of last resort. It is thus Idaho Power’s
policy, subject to situation-by-situation assessments of all relevant factors as described above,
to employ PSPS de-energization for distribution or transmission lines, or the segments thereof
to the nearest zone of protection segmentation point or end of the line if none exists, within
designated wildfire risk zones if both 1) a fire potential element and 2) a windspeed element are
met for a given wildfire risk zone:
The fire potential element is met for a wildfire risk zone if any of the following occur:
• There is an FPI of 15 or higher for that wildfire risk zone for the time period when the
windspeed element is met and
• the National Weather Service has issued either a Red Flag Warning Particularly
Dangerous Situation (PDS) for a location(s) within that wildfire risk zone during the time
that the windspeed element is met or a High Wind Warning (defined as sustained winds
Idaho Power Company Wildfire Public Safety Power Shutoff Plan
Page 6
of 40 mph or higher for at least one hour or more and/or gusts of 58 mph or higher) for
that area.
The windspeed element is met if:
• Distribution Circuits: Idaho Power identifies observed winds exceeding 30 mph
sustained for at least one hour combined with wind gusts exceeding thresholds derived
from historical climatology stated in the 2027 Operational Wind Speed Guidelines for
EPSS and PSPS by Risk Zone for the applicable wildfire risk zone location.
• Transmission Circuits: Idaho Power identifies observed winds exceeding 40 mph
sustained for at least one hour and observed or known wind gusts exceeding 70 mph for
the wildfire risk zone location. Idaho Power may opt not to de-energize a transmission
segment or circuit if it determines the de-energization may cause grid instability or
reliability issues that could impact a large number of customers (such as a
de-energization that could impact 1,000 or more customers) or impact the bulk electric
system, or if Idaho Power believes it poses a risk to public safety.
Consistent with Idaho Power’s case-by-case evaluation of all relevant factors, even when
extreme fire weather is forecasted, a risk evaluation may support maintaining power if other
mitigation measures are in place, such as Enhanced Powerline Safety Settings (EPSS) or
hardened infrastructure that lowers the likelihood of ignition.
5. PSPS Operations and Communication Phases
Although the extent of the areas where Idaho Power has infrastructure and equipment,
the geographic and environmental diversity of those locations, and unpredictable nature of
weather make it challenging, Idaho Power is committed to providing as much advance notice as
reasonably possible in preparation for a PSPS event.
5.1. Phase 1 and Incident Team Activation
Once the criteria are met to initiate the process for a potential PSPS event, an internal incident
command team (IC team) will discuss the timing and impact of the event and make
recommendations pertaining to the issuance of preliminary notifications of a potential PSPS
event to customers, public safety partners, utility defined critical facilities operators, and/or the
ESF-12.
The intent of any initial communication is to allow public safety partners and critical facilities to
begin preparing for the PSPS event, which may include identification of back-up generation,
community resource centers, or heightened response for vulnerable populations. This step also
allows for coordinated communications with public safety partners, if deemed necessary by
Idaho Power.
Idaho Power Company Wildfire Public Safety Power Shutoff Plan
Page 7
These notifications may include emails, text messages, and/or phone calls. The mode of
communication is based on the preference of each audience as communicated to Idaho Power.
The Idaho Power IC team will continue meeting and providing updated community and
customer communications throughout a PSPS event, if feasible. This could include cancellation
of the event or restoration of the de-energized PSPS circuits and any related storm activity.
Throughout an event, there may be requests to delay proactive de-energization from the public
safety partners or ESF-12. This may occur for several reasons, such as the potential impact to a
customer or fire response agency’s ability to pump water for fire suppression during the outage.
Delay requests will be communicated to the IC team for consideration.
5.2. Phase 2
Phase 2 actions are determined by additional situational awareness activities and timing of
forecasted weather events. Upon transitioning to Phase 2, Idaho Power will discuss timing of
proactive customer communications.
Idaho Power’s PSPS program includes employees acting as field observers to report on site
conditions. Idaho Power typically deploys trained field observers to strategic locations, including
areas with limited weather and system condition visibility, before a weather system is
forecasted to arrive at wildfire risk zone to perform field observations for on-the-ground, real-
time information to inform PSPS de-energization decisions. Field observations include—without
limitation—conditional assessments of system impacts from wind and vegetation, flying debris,
and conductor impact.
Field observers are equipped with mobile weather kits that include wind meters, compasses,
and satellite communication devices to report real-time conditions. Information is
communicated to the PSPS Assessment Team for consideration during a PSPS event.
Due to the speed at which weather events can occur and the potential extent of areas in scope,
Idaho Power may not deploy field observers in every event, or to every in-scope area during
an event.
Idaho Power will strive to provide proactive customer communication as the likelihood of the
PSPS event increases. This may occur several hours or more after the initial public safety partner
and critical facility communication. Additionally, Idaho Power customer service representatives
(CSR) are provided with several resources, including PSPS talking points, scripts, and employee
trainings to support customers in a potential or actual PSPS scenario. CSRs also use and guide
customers to the public facing PSPS resources on the Idaho Power website.
Idaho Power Company Wildfire Public Safety Power Shutoff Plan
Page 8
As referenced with the illustration below, Idaho Power strives to follow the communication
timelines set in relevant state regulations, noting the timing of all proactive communications is
tied to the development of weather conditions and therefore subject to change.

5.3. Phase 3: De-Energization
After the determination to proactively de-energize is made, the assigned representative of the
IC team will inform Idaho Power’s Dispatch Operations to confirm the PSPS de-energization.
The considerations for de-energization are discussed in Section 4.
Idaho Power will continue providing community updates as it deems appropriate.
Customer communications may include email, text, and/or phone messages. The outage
Preliminary
Notifications
PSPS
Watch
PSPS
Warning
PSPS
Alert
Update
Final
Update
48-72 hours in advance of a potential PSPS event, notify Public Safety
Partners and operators of critical facilities.
24-48 hours in advance of an anticipated PSPS event, secondary
notification Public Safety Partners, operators of critical facilities and initial
notification to affected customers within the current PSPS event boundary.
1-4 hours in advance of an imminent PSPS event, if possible, notification to
Public Safety Partners, operators of critical facilities and all affected
customers within the current PSPS event boundary.
Upon initiating a PSPS, if possible, notification to Public Safety Partners,
operators of critical facilities and all customers within the PSPS event
boundary and at a minimum, with the status updates at 24-hour intervals
until restoration begins for PSPS events lasting longer than 24 hours.
When re-energization begins, if possible, notification to Public Safety
Partners, operators of critical facilities and all affected customers within
the PSPS event boundary.
Once re-energization is complete, Idaho Power will attempt to provide
notice to Public Safety Partners, operators of critical facilities and all
affected customers within the PSPS event boundary.
Event Timing Illustrative Description of Planned

Idaho Power Company Wildfire Public Safety Power Shutoff Plan
Page 9
notification will include the reason for the de-energization and where to find real-time updates
on outage status.
5.4. Phase 4: Re-Energization
5.4.1. System Inspections
If electrical facilities are de-energized for PSPS, Idaho Power follows a process to restore service.
When conditions are safe, de-energized T&D circuits and other potentially impacted facilities
are patrolled to confirm readiness for re-energization. Repairs may be completed as necessary,
and restoration is carried out in a controlled manner. Each operating region identifies the
resources and procedures to be used during PSPS events, helping restoration to occur safely,
efficiently, and in coordination with the dispatch manager.
5.4.2. Repair and Recovery
Line crews will repair impacted facilities based on internal priority coordination,
replacing damaged equipment, and performing other actions to support safe re-energization
of the affected portion of the T&D system.
5.4.3. Communicate PSPS Event Conclusion
Idaho Power will strive to provide customers with estimated restoration times until any storm or
PSPS repairs are complete, and it is safe to re-energize the system. This may occur in stages as
different feeders or feeder sections are determined safe to re-energize. The outage map on
Idaho Power’s website will be updated during the event. Idaho Power may also leverage existing
public agency outreach and notification systems as done at other points in the PSPS process.
6. Post-incident Review
Following the conclusion of a PSPS event, Idaho Power will conduct informal, high-level debriefs
to identify potential modifications to PSPS protocol based on lessons learned during the event.
An assigned representative will consolidate the feedback and file as part of the
incident documentation.
7. Exercises
Idaho Power will exercise this PSPS Plan on an annual basis prior to wildfire season using one or
more different scenarios and testing one or more portions of the Plan. These exercises may
include any of the following:
Idaho Power Company Wildfire Public Safety Power Shutoff Plan
Page 10
• Testing text and/or phone alerts with a test group of public safety partners, while
incorporating feedback following the exercise
• Testing tactical operational plans, such as reporting field observations or
positioning employees at manually operated disconnects to test timing for
de-energization and field inspections of T&D assets
• Discussing and/or practicing roles and responsibilities of both strategic and tactical
operations, including decision-making handoffs
• Discussing and/or developing re-energization plans
• Testing capacity limits on incoming and outgoing communications systems

• Including ESF-12, public safety partners, and/or critical facilities

Appendix C.
Wildfire Risk Zone
Map Book

October 2026
© 2026 Idaho Power
Idaho Power Company Wildfire Risk Zone Map Book
Page i
List of Figures
Figure 1
Canyon Region—North ................................................................................................................ 1
Figure 2
Canyon Region—South ................................................................................................................ 2
Figure 3
Capital Region—Boise Front ........................................................................................................ 3
Figure 4
Capital Region—Boise South........................................................................................................ 4
Figure 5
Capital Region—Centerville ......................................................................................................... 5
Figure 6
Capital Region—Idaho City .......................................................................................................... 6
Figure 7
Capital Region—Mountain Home Area ....................................................................................... 7
Figure 8
Eastern Region—American Falls .................................................................................................. 8
Figure 9
Eastern Region—Pocatello ........................................................................................................... 9
Figure 10
Eastern Region—Salmon Area ................................................................................................... 10
Figure 11
Eastern Region—Salmon North ................................................................................................. 11
Figure 12
Southern Region—Pine Featherville Area ................................................................................. 12
Figure 13
Southern Region—Rock Creek ................................................................................................... 13
Figure 14
Southern Region—Twin Falls/Buhl ............................................................................................ 14
Figure 15
Southern Region—Wood River Valley ....................................................................................... 15
Idaho Power Company Wildfire Risk Zone Map Book
Page ii
Figure 16
Western Region—Ola................................................................................................................. 16
Figure 17
Western Region—Cascade/Donnelly ......................................................................................... 17
Figure 18
Western Region—Council Area.................................................................................................. 18
Figure 19
Western Region—Emmett/Horseshoe Bend ............................................................................. 19
Figure 20
Western Region—Garden Valley/Crouch .................................................................................. 20
Figure 21
Western Region—Lowman ........................................................................................................ 21
Figure 22
Western Region—McCall/New Meadows ................................................................................. 22
Figure 23
Western Region—Riggins South ................................................................................................ 23
Figure 24
Western Region—Smiths Ferry .................................................................................................. 24
Figure 25
Western Region—Weiser Payette Area ..................................................................................... 25
Figure 26
Western Region—Yellow Pine ................................................................................................... 26
Figure 27
Changes Highlighted: Canyon Region—North ........................................................................... 27
Figure 28
Changes Highlighted: Capital Region—Boise Front ................................................................... 28
Figure 29
Changes Highlighted: Capital Region—Boise South .................................................................. 29
Figure 30
Changes Highlighted: Capital Region—Mountain Home Area .................................................. 30
Figure 31
Changes Highlighted: Eastern Region—Pocatello ..................................................................... 31
Figure 32
Changes Highlighted: Eastern Region—Salmon North .............................................................. 32
Idaho Power Company Wildfire Risk Zone Map Book
Page iii
Figure 33
Changes Highlighted: Southern Region—Twin Falls/Buhl ......................................................... 33
Figure 34
Changes Highlighted: Southern Region—Wood River Valley .................................................... 34
Figure 35
Changes Highlighted: Western Region—Emmett/Horseshoe Bend .......................................... 35
Figure 36
Changes Highlighted: Western Region—Riggins South ............................................................. 36

Idaho Power Company Wildfire Risk Zone Map Book
Page iv

Idaho Power Company Wildfire Risk Zone Map Book
Page 1

Figure 1
Canyon Region—North
Idaho Power Company Wildfire Risk Zone Map Book
Page 2

Figure 2
Canyon Region—South
Idaho Power Company Wildfire Risk Zone Map Book
Page 3

Figure 3
Capital Region—Boise Front
Idaho Power Company Wildfire Risk Zone Map Book
Page 4

Figure 4
Capital Region—Boise South
Idaho Power Company Wildfire Risk Zone Map Book
Page 5

Figure 5
Capital Region—Centerville
Idaho Power Company Wildfire Risk Zone Map Book
Page 6

Figure 6
Capital Region—Idaho City
Idaho Power Company Wildfire Risk Zone Map Book
Page 7

Figure 7
Capital Region—Mountain Home Area
Idaho Power Company Wildfire Risk Zone Map Book
Page 8

Figure 8
Eastern Region—American Falls
Idaho Power Company Wildfire Risk Zone Map Book
Page 9

Figure 9
Eastern Region—Pocatello
Idaho Power Company Wildfire Risk Zone Map Book
Page 10

Figure 10
Eastern Region—Salmon Area
Idaho Power Company Wildfire Risk Zone Map Book
Page 11

Figure 11
Eastern Region—Salmon North
Idaho Power Company Wildfire Risk Zone Map Book
Page 12

Figure 12
Southern Region—Pine Featherville Area
Idaho Power Company Wildfire Risk Zone Map Book
Page 13

Figure 13
Southern Region—Rock Creek
Idaho Power Company Wildfire Risk Zone Map Book
Page 14

Figure 14
Southern Region—Twin Falls/Buhl
Idaho Power Company Wildfire Risk Zone Map Book
Page 15

Figure 15
Southern Region—Wood River Valley
Idaho Power Company Wildfire Risk Zone Map Book
Page 16

Figure 16
Western Region—Ola
Idaho Power Company Wildfire Risk Zone Map Book
Page 17

Figure 17
Western Region—Cascade/Donnelly
Idaho Power Company Wildfire Risk Zone Map Book
Page 18

Figure 18
Western Region—Council Area
Idaho Power Company Wildfire Risk Zone Map Book
Page 19

Figure 19
Western Region—Emmett/Horseshoe Bend
Idaho Power Company Wildfire Risk Zone Map Book
Page 20

Figure 20
Western Region—Garden Valley/Crouch
Idaho Power Company Wildfire Risk Zone Map Book
Page 21

Figure 21
Western Region—Lowman
Idaho Power Company Wildfire Risk Zone Map Book
Page 22

Figure 22
Western Region—McCall/New Meadows
Idaho Power Company Wildfire Risk Zone Map Book
Page 23

Figure 23
Western Region—Riggins South
Idaho Power Company Wildfire Risk Zone Map Book
Page 24

Figure 24
Western Region—Smiths Ferry
Idaho Power Company Wildfire Risk Zone Map Book
Page 25

Figure 25
Western Region—Weiser Payette Area
Idaho Power Company Wildfire Risk Zone Map Book
Page 26

Figure 26
Western Region—Yellow Pine
Idaho Power Company Wildfire Risk Zone Map Book
Page 27
Risk Zone Changes Highlighted

Figure 27
Changes Highlighted: Canyon Region—North
Idaho Power Company Wildfire Risk Zone Map Book
Page 28

Figure 28
Changes Highlighted: Capital Region—Boise Front
Idaho Power Company Wildfire Risk Zone Map Book
Page 29

Figure 29
Changes Highlighted: Capital Region—Boise South
Idaho Power Company Wildfire Risk Zone Map Book
Page 30

Figure 30
Changes Highlighted: Capital Region—Mountain Home Area
Idaho Power Company Wildfire Risk Zone Map Book
Page 31

Figure 31
Changes Highlighted: Eastern Region—Pocatello
Idaho Power Company Wildfire Risk Zone Map Book
Page 32

Figure 32
Changes Highlighted: Eastern Region—Salmon North
Idaho Power Company Wildfire Risk Zone Map Book
Page 33

Figure 33
Changes Highlighted: Southern Region—Twin Falls/Buhl
Idaho Power Company Wildfire Risk Zone Map Book
Page 34

Figure 34
Changes Highlighted: Southern Region—Wood River Valley
Idaho Power Company Wildfire Risk Zone Map Book
Page 35

Figure 35
Changes Highlighted: Western Region—Emmett/Horseshoe Bend
Idaho Power Company Wildfire Risk Zone Map Book
Page 36

Figure 36
Changes Highlighted: Western Region—Riggins South

Appendix D.
Idaho and Montana
Requirements and
Recommendations

October 2026
© 2026 Idaho Power

Idaho Power Company Idaho and Montana Wildfire Requirements and Recommendations
Page i
Table of Contents
Idaho and Montana Wildfire Requirements and Recommendations ............................................. 1
Idaho Requirements and Recommendations ................................................................................. 1
Idaho Wildfire Standard of Care Act and IPUC Order No. 36774 Requirements ........................ 2
Other Items to Include in a WMP from Various IPUC Orders ..................................................... 8
IPUC Order No. 37004, Case No. IPC-E-25-32 ............................................................................. 8
IPUC Order No. 36929, Case No. GNR-E-25-02 ......................................................................... 12
IPUC Order No. 36774, Case No. GNR-E-25-02 ......................................................................... 12
IPUC Order No. 36742, Case No. IPC-E-25-05 ........................................................................... 13
IPUC Order No. 36042, Case No. IPC-E-23-11 ........................................................................... 14
IPUC Order No. 35717, Case No. IPC-E-22-27 ........................................................................... 14
2027 WMP Major Updates/Changes ........................................................................................ 15
Montana WMP Requirements ...................................................................................................... 16

Idaho Power Company Idaho and Montana Wildfire Requirements and Recommendations
Page ii

Idaho Power Company Idaho and Montana Wildfire Requirements and Recommendations
Page 1
Idaho and Montana Wildfire Requirements and Recommendations
This appendix is intended to aid reviewers in locating content specific to the various statutory
and regulatory requirements and recommendations pertaining to Idaho Power’s Idaho and
Montana 2027 Wildfire Mitigation Plan (WMP). This appendix first discusses Idaho
requirements and recommendations and then addresses Montana requirements and
recommendations. Appendix D is provided for ease of reference and is non-exhaustive.
The WMP is a complex document, and content pertaining to a particular requirement or
recommendation may be located in sections or appendices that are not specifically identified or
cross-referenced to that requirement or recommendation.
Idaho Requirements and Recommendations
This appendix provides information specific to WMP requirements, as well as WMP-related
recommendations, in Idaho pursuant to the Idaho Wildfire Standard of Care Act (WSCA) and as
directed by the Idaho Public Utilities Commission (IPUC or Commission).
Idaho Power Company Idaho and Montana Wildfire Requirements and Recommendations
Page 2
Idaho Wildfire Standard of Care Act and IPUC Order No. 36774 Requirements
Below is a mapping of WMP requirements set forth in the WSCA and by the IPUC through Order No. 36774 issued in Case No. GNR-E-
25-02, including the IPUC WMP Guidelines (Exhibit B to Order No. 36774), to the applicable section(s) within Idaho Power’s WMP.
Idaho Requirement—WSCA 61-1803 WMP Guidelines—IPUC Order No. 36774, Exhibit B Corresponding Location in WMP
(3) Each wildfire mitigation plan shall be
developed using approaches and methods that
are designed to protect the public interest and
are reflective of and commensurate with the
size and complexity of the electric
corporation's operations and of the nature of
the fire risk. At a minimum, each wildfire
mitigation plan shall identify a means for
mitigating wildfire risk that reflect a reasonable
balancing of mitigation costs with the resulting
reduction of wildfire risk.
WMPs must include a cost-benefit analysis that justifies the expenditures for risk
mitigation described within.
Section 1. Introduction
Section 2. Geographical Risk
Assessment
Section 3. Cost-Benefit Approach
Section 4. Situational Awareness and
Monitoring
Section 5. Mitigation Activity:
Workforce Preparedness
Section 6. Mitigation Activity: Line
Operation Practices
Section 7. Infrastructure Inspection
and Asset Management
Section 8. Methods of Line Design
Section 9. Vegetation Management
Section 10. Additional Preventative
Actions and Programs
Section 11. Public Outreach and
Engagement
Section 12. Government, Industry,
and Peer Utility Outreach
Section 13. Performance Monitoring
Section 14. WMP Cost Summary
Appendix A: Wildland Fire
Preparedness and Prevention Plan
Appendix B: Wildfire Public Safety
Power Shutoff Plan
Appendix F: Wildfire Mitigation
Activities and Cost Forecast 2027–
2029
Idaho Power Company Idaho and Montana Wildfire Requirements and Recommendations
Page 3
Idaho Requirement—WSCA 61-1803 WMP Guidelines—IPUC Order No. 36774, Exhibit B Corresponding Location in WMP
Appendix G: Grid Hardening List
(3)(a) 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.
Section 2. Geographical Risk
Assessment
Appendix C: Wildfire Risk Zone Map
Book
(3)(b) 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 the IPUC. For the three large investor-owned utilities, Staff recommends
that previous areas of focus of each utility’s WMPs continue to be included. A WMP's
preventative actions and programs must include, but is not limited to, the following:
• Situational Awareness Efforts
May include use of technology to aid in weather monitoring; fire season
outlook; daily, weekly, and monthly weather and fire modeling risk, etc.
Consistent with 61- 1803(3)(f) and the IPUC WMP Guidelines.
• Asset Inspections
Must include the frequency and standards of inspections for each type of
electric infrastructure within areas of elevated wildfire risk.
Consistent with 61- 1803(3)(g)(i) and the IPUC WMP Guidelines.
• Enhanced Vegetation Management Practices in Risk Zones
May include shorter vegetation management cycles than routine cycles, risk
tree programs, etc.
Consistent with 61- 1803(3)(g)(iii) and the IPUC WMP Guidelines.
• Operation Practices During Heightened Wildfire Risk Days or Zones
May include restrictions to workforce practices, potential use of proactive
de-energization.
Consistent with 61-1803(3)(g)(ii) and the IPUC WMP Guidelines.
• Community Education
Section 4. Situational Awareness and
Monitoring
Section 5. Mitigation Activity:
Workforce Preparedness
Section 6. Mitigation Activity: Line
Operation Practices
Section 7. Infrastructure Inspection
and Asset Management
Section 8. Methods of Line Design
Section 9. Vegetation Management
Section 10. Additional Preventative
Actions and Programs
Section 11. Public Outreach and
Engagement
Section 14. WMP Cost Summary
Appendix A: Wildland Fire
Preparedness and Prevention Plan
Appendix B: Wildfire Public Safety
Power Shutoff Plan
Appendix F: Wildfire Mitigation
Activities and Cost Forecast 2027–
2029
Appendix G: Grid Hardening List
Idaho Power Company Idaho and Montana Wildfire Requirements and Recommendations
Page 4
Idaho Requirement—WSCA 61-1803 WMP Guidelines—IPUC Order No. 36774, Exhibit B Corresponding Location in WMP
May include public service announcements to create awareness and provide
education of wildfire risks, providing preventative measures, etc.
Consistent with 61-1803(3)(c) and 61-1803(3)(d).
A WMP's preventative actions and programs may include, but is not limited to,
the following:
• System Hardening Strategies
May include pole replacements, line rebuilding, or undergrounding
if necessary, strategic fuse or reclosers installations, etc.
• Workforce Preparedness
May include workforce training, equipment provided to employees to reduce
the risk of wildfire, etc.
• Pilot Programs
If applicable.
(3)(c) 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 utility 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 is 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.
Section 11. Public Outreach and
Engagement
Appendix B: Wildfire Public Safety
Power Shutoff Plan
(3)(d) Outreach efforts to coordinate with
federal, state, tribal, and local officials and
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:
Section 4.6 Wildfire Detection
Cameras
Idaho Power Company Idaho and Montana Wildfire Requirements and Recommendations
Page 5
Idaho Requirement—WSCA 61-1803 WMP Guidelines—IPUC Order No. 36774, Exhibit B Corresponding Location in WMP
agencies on wildfire preparedness and
emergency response plans.
• If applicable, Public Safety Power Shutoff (PSPS) tabletop exercises with
interested parties and agencies.
• Communication with the agencies and the ESF-12 coordinator within the
PUC.
• If applicable, mitigation efforts with the agencies.
The WMP must detail all relationships (such as Bureau of Land Management [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.
Section 10.3.2 Wildfire Resilience
Partnerships and Fuels Reduction
Shared Stewardship (Pilot)
Section 11. Public Outreach and
Engagement
Section 12. Government, Industry,
and Peer Utility Outreach
(3)(e) 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.
Section 3. Cost-Benefit Approach
Section 6. Mitigation Activity: Line
Operation Practices
Section 8. Methods of Line Design
Section 10. Additional Preventative
Actions and Programs
Section 14. WMP Cost Summary
Appendix F. Wildfire Mitigation
Activities and Cost Forecast 2027–
2029
Appendix G: Grid Hardening List
(3)(f) 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:
• 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 becomes aware of another electric
corporation's de-energization (e.g., Bonneville Power Administration) and
how that is integrated into operations.
Section 2. Geographical Risk
Assessment
Section 4. Situational Awareness and
Monitoring
Section 5. Mitigation Activity:
Workforce Preparedness
Section 6. Mitigation Activity: Line
Operation Practices
Section 10. Additional Preventative
Actions and Programs
Appendix A: Wildland Fire
Preparedness and Prevention Plan
Appendix B: Wildfire Public Safety
Power Shutoff Plan
Idaho Power Company Idaho and Montana Wildfire Requirements and Recommendations
Page 6
Idaho Requirement—WSCA 61-1803 WMP Guidelines—IPUC Order No. 36774, Exhibit B Corresponding Location in WMP
(3)(g) Developing standards, procedures, and
schedules, subject to timely approval of access
to rights-of-way, if necessary, for the following
actions:
(i) Inspection of the electric corporation’s
assets, infrastructure, and facilities within the
areas that are identified as heightened fire risk
areas in the wildfire mitigation plan, where
financially prudent and reasonably practicable.
This section should provide a summary of an 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.
• Measurable targets/goals to be achieved within the WMP. E.g., miles of lines
inspected, corrected identified defects, etc.
Section 7. Infrastructure Inspection
and Asset Management
Section 9. Vegetation Management
Section 10. Additional Preventative
Actions and Programs
Appendix F: Wildfire Mitigation
Activities and Cost Forecast 2027–
2029
3(g)(ii) 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 third-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.
Section 6. Mitigation Activity: Line
Operation Practices
Section 11. Public Outreach and
Engagement
Section 14. WMP Cost Summary
Appendix B: Wildfire Public Safety
Power Shutoff Plan
3(g)(iii) 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
This section must provide an overview of the utility's vegetation management program
aimed at reducing the risk of vegetation-related contact with electric infrastructure in
areas with heightened wildfire risk within its rights-of-way or lands adjacent thereto.
Section 9. Vegetation Management
Section 10. Additional Preventative
Actions and Programs
Idaho Power Company Idaho and Montana Wildfire Requirements and Recommendations
Page 7
Idaho Requirement—WSCA 61-1803 WMP Guidelines—IPUC Order No. 36774, Exhibit B Corresponding Location in WMP
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.
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.
Section 12. Government, Industry,
and Peer Utility Outreach
Section 14. WMP Cost Summary
Appendix F: Wildfire Mitigation
Activities and Cost Forecast 2027–
2029

Idaho Power Company Idaho and Montana Wildfire Requirements and Recommendations
Page 8
Other Items to Include in a WMP from Various IPUC Orders
IPUC Order No. 37004, Case No. IPC-E-25-32
The following contains the directives contained exclusively in IPUC Order No. 37004 that pertain
to Idaho Power’s development and submission of WMP filings, including specific content
requirements.
Adopted Recommendation: Identify the types of infrastructure excluded from Idaho Power’s
risk modeling and, where such infrastructure is not incorporated into the company's models,
provide an explanation for its exclusion.
An explanation of infrastructure excluded from Idaho Power’s risk modeling is included in
Section 2.2. Identifying Areas of Heightened Wildfire Risk.
Adopted Recommendation: Incorporate quantitative model validation and analysis into its
geographic risk modeling and assessment.
A discussion on how the company has incorporated quantitative model validation and
analysis into its geographic risk modeling and assessment is included in Section 2.2.2.2.
Model Validation and Section 2.2.3. 2027 Wildfire Risk Zone Modification Process.
Adopted Recommendation: Provide the estimated cost, planned duration, and evaluation
metrics for each pilot program.
This information is included under Section 10.3. Pilot Projects.
Adopted Recommendation: Include a description of Idaho Power’s internal vegetation
management crew in Section 10.2 of the WMP
In 2026, Idaho Power transitioned its Internal Vegetation Management Crew pilot into a full-
time, permanent program. Accordingly, discussion of the Internal Vegetation Management
Crew is no longer relevant under Section 10 of the WMP. Instead, the requested description
has been included under Section 13.3.4. Internal Vegetation Management Crew.
Adopted Recommendation: Adopt and further develop industry best practices in
configuration management, requirements management, test management, and issue and
defect tracking for all custom models or software developed for the FPI tool, as well as other
custom developed models or applications that play a critical role in the company's WMP.
Idaho Power understands this recommendation as pertaining to situational awareness tools
developed internally by the company to inform operational decision making to reduce
wildfire threats and risks as required by Idaho Code 61-1803(3)(f), including the company’s
custom Fire Potential Index (FPI) tool and any related models or applications. As a point of
clarification, the company notes that the FPI tool is not a traditional software application but
rather a predictive indicator of wildfire-potential derived from a set of equations that utilize
Idaho Power Company Idaho and Montana Wildfire Requirements and Recommendations
Page 9
weather forecasts. As such, the FPI tool is not subject to all elements of a conventional
software development lifecycle and does not undergo a process for software configuration
management, requirements management, and issue and defect tracking similar to other
developed software programs. However, Idaho Power recognizes the importance of applying
governance and control practices consistent with the role the FPI tool plays in supporting
wildfire risk assessment and operational decision-making. Accordingly, the FPI process is
reviewed annually to assess and validate Idaho Power’s wildfire preparedness approach, as
discussed in Section 4.3. FPI Review and Evaluation.

Since the original development of the FPI tool, Idaho Power has continued to refine the
tool’s performance through maintenance and validation of the models and datasets
supporting its underlying components. As an example, the Weather Component of the FPI
tool considers data sourced from Weather Research and Forecasting (WRF) models
produced by Idaho Power using its High-Performance Computing system, as well as other
publicly available national models. Idaho Power’s WRF model has been evaluated, refined,
and parameterized to model Idaho’s topography and climate.

As more fully discussed in Section 4.4. Ensemble Forecast System, Idaho Power intends to
further enhance Weather Component calculations for the FPI tool by incorporating the
Ensemble Forecast System, which is a system developed by Idaho Power in partnership with
the National Center for Atmospheric Research that produces multiple custom, high-
resolution weather forecast models throughout the day.
Adopted Recommendation: Expand the description of resources available to call center agents
during a PSPS event within Appendix B.
A description of resources available to Idaho Power customer service representatives during
a PSPS event is included under Section 5.2 of Appendix B: Wildfire Public Safety Power
Shutoff Plan.
Adopted Recommendation: Identify average project costs, including installation costs for steel
poles, fire mesh wraps, wildfire detection cameras, undergrounding, covered conductors,
fiberglass cross-arms for wooden poles, and weather stations.
This information is contained within Appendix H: Average Mitigation Project Costs
(Confidential).
Adopted Recommendation: Include all metrics used in the WMP within their respective
sections and present in a format that enables tracking across versions of the WMP.
The targets and metrics of relevant sections of the WMP are documented within Appendix F:
Wildfire Mitigation Activities and Cost Forecast 2027–2029 to facilitate ease of reference
and tracking across WMP versions.
Idaho Power Company Idaho and Montana Wildfire Requirements and Recommendations
Page 10
Adopted Recommendation: Establish and publish annual mileage targets for all transmission
and distribution (“T&D”) hardening programs and projects by wildfire risk zone tier or feeder,
along with modeled ignition risk reduction per mile for each category.
Annual mileage targets for all T&D hardening programs have been included in Appendix F:
Wildfire Mitigation Activities and Cost Forecasts 2027–2029. In addition, Appendix G: Grid
Hardening List identifies the projects Idaho Power plans to complete in 2027, along with the
associated line miles and corresponding wildfire risk zone tier for each project.

In accordance with Commission Order No. 37004, the company is in the process of
developing its approach to risk reduction and mitigation effectiveness modeling. As such,
Idaho Power plans to use this information to inform its WMP beginning with its 2028 plan.
Adopted Recommendation: Adopt an effectiveness scorecard for each grid hardening
method—including, but not limited to, covered conductor, non-wooden poles, non-wooden
crossarms, and undergrounding—based on industry guidance.
In accordance with Commission Order No. 37004, the company is in the process of
developing its approach to risk reduction and mitigation effectiveness modeling. As such,
Idaho Power plans to start using this information to inform its WMP beginning with its
2028 plan.
Adopted Recommendation: Include a table in the WMP identifying all T&D rebuild and grid
hardening projects undertaken as part of Idaho Power’s wildfire mitigation strategy, including
the project name, type, primary driver, location, design standards, anticipated timeline, and
estimated costs, as well as an explanation of whether wildfire mitigation priorities affected
any aspect of the project, such as design, cost, or schedule.
This information is included in Appendix G: Grid Hardening List.
Adopted Recommendation: Conduct cost-benefit analyses on a project-by project basis to
demonstrate that each project reasonably balances costs with reductions in wildfire risk.
See Section 3.5. Risk Informed Mitigation Evaluation Framework, which discusses Idaho
Power’s Risk-Informed Mitigation Evaluation Framework (Framework) to support the
planning-level evaluation of both costs and benefits associated with line infrastructure
projects primarily driven by wildfire risk reduction. Application of the Framework with
respect to line infrastructure projects undertaken as part of Idaho Power’s wildfire
mitigation strategy in 2027 can be found in Attachment 2 to the Application accompanying
this WMP’s submission to the IPUC.

Idaho Power Company Idaho and Montana Wildfire Requirements and Recommendations
Page 11
Adopted Recommendation: IPUC Staff and the company should work collaboratively to
address Staff’s remaining recommendations.
Staff ’s recommendations that remained outstanding following Order No. 37004 were
as follows:
1. Include copies of Idaho Power’s four most recent quarterly NERC FAC-003-X compliance
reports as attachments in future WMPs; include copies of current transmission
maintenance and inspection plans used for NERC FAC-501- WECC-X compliance, along
with any violations identified in the most recent NERC compliance audit.
2. Expand reporting in future WMPs to include both T&D assets not covered by NERC
standards to provide a more comprehensive view of trends and effectiveness across the
utility’s entire system.
3. Take necessary steps to integrate asset condition and inspection data, as well as failure
modes, into ignition models as part of geographic risk modeling and assessment.
Idaho Power met with Commission Staff on July 9, 2026, and understands Staff ’s
outstanding recommendations 1 and 2, which relate to NERC compliance reports and
standards, seek information regarding the performance of the company’s system following
implementation of grid hardening activities. With this understanding, the company has
included discussion and data relating to the change in sustained outages by cause code
within Section 2C of the Application accompanying this WMP’s submission to the IPUC.

With respect to Staff’s outstanding recommendation 3, and based on Idaho Power’s
conversation with Commission Staff on July 9, 2026, the company understands Staff’s
recommendation to require the company to consider asset condition and inspection data, as
well as failure modes, when selecting mitigations. Discussion of how these factors are
considered by Idaho Power when evaluating mitigations is included under Section 3.5. Risk
Informed Mitigation Evaluation Framework.

Idaho Department of Lands (IDL) recommended that the company provide additional
descriptive narrative regarding the data used to develop its risk model, including a discussion
of diminishing returns within its cost-benefit analysis and the impact of electrical service
disruptions when making mitigation decisions.
Idaho Power met with IDL to discuss these recommendations, including the company’s risk
modeling approach and model inputs. Idaho Power understands the importance of
considering local, state and national risk assessments and mitigation plans. Accordingly,
additional details regarding the modeling inputs used by the company in its updated risk
analysis have been added under Section 2.2.2. 2027 Wildfire Risk Zone Modeling and
Validation. As part of developing a project-by-project cost-benefit framework to inform
future iterations of its WMP, beginning in 2028 pursuant to Commission Order No 37004,
Idaho Power Company Idaho and Montana Wildfire Requirements and Recommendations
Page 12
the company will discuss diminishing returns and the impact of electrical service disruptions
when making mitigation decisions.
IPUC Order No. 36929, Case No. GNR-E-25-02
The following contains the directives contained exclusively in IPUC Order No. 36929 that pertain
to Idaho Power’s development and submission of WMP filings, including specific content
requirements.
All electric corporations shall include a glossary within each WMP that defines each utility’s
terms, and that those terms should be consistent with the WSCA and with the Commission
WMP Guidelines (issued through Order No. 36774).

This information is contained within Appendix I: Glossary of Terms
IPUC Order No. 36774, Case No. GNR-E-25-02
The following contains other directives contained in IPUC Order No. 36774 that pertain to Idaho
Power’s development and submission of WMP filings, including specific content requirements.
An update of lessons learned from the previously approved WMP within the annual filings for
WMP review and approval.
An update of 2026 lessons learned is discussed within Section 13.3. 2026 Lessons Learned.
A breakdown of each program category’s forecasted costs by year for both capital and
operations and maintenance (O&M) expenditures through the length of the WMP.
This information is included in Section 14. WMP Cost Summary and Appendix F: Wildfire
Mitigation Activities and Cost Forecast 2027–2029.
A section in which Idaho Power describes how it addresses each of the IPUC’s orders and
Staff’s recommendations.
This information is contained within this Appendix D.
Rolling WMPs shall be developed with a minimum three-year planning horizon.
Idaho Power developed projections for a 3-year planning horizon, as presented within
Appendix F: Wildfire Mitigation Activities and Cost Forecast 2027–2029.

Idaho Power Company Idaho and Montana Wildfire Requirements and Recommendations
Page 13
An explanation of how the company’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
it must show how the mitigation project strikes the necessary “balance of mitigation costs
with the resulting wildfire reduction in wildfire risk,” as required by the WSCA.
This information is addressed within Section 3. Cost-Benefit Approach, Section 8. Methods
of Line Design, Section 14. WMP Cost Summary, and within Attachment 2 to the Application
accompanying this WMP’s submission to the IPUC.
WMPs must include a cost-benefit analysis that justifies the expenditures for risk mitigation
described within.
This information is included within Section 3. Cost-Benefit Approach. See also Section 14.
WMP Cost Summary and Attachment 2 to the Application accompanying this WMP’s
submission to the IPUC.
IPUC Order No. 36742, Case No. IPC-E-25-05
The following contains the directives contained exclusively in IPUC Order No. 36742 that pertain
to Idaho Power’s development and submission of WMP filings, including specific content
requirements.
List all pilot projects in the WMP, including the status of the pilot and an explanation of how
the company is evaluating least-cost, least-risk solutions.
Pilot projects, including their status, have been identified in Section 10.3. Pilot Projects. The
company’s approach to balancing mitigation costs with the resulting reduction of wildfire
risks specific to pilot projects is discussed in Section 3. Idaho Power interprets the IPUC’s
direction to evaluate “least cost, least risk” solutions to direct the company to evaluate
mitigations with an eye toward reasonably balancing the lowest cost mitigations against the
greatest amount of wildfire risk reduction for that cost.
Detail how the company identifies, selects, and evaluates projects as least-cost, least-risk for
line rebuilding, undergrounding, and covered conductor to be consistent with Idaho Code §
61-1803(3)(g), effective July 1, 2025.
Idaho Power interprets the direction to evaluate “least-cost, least-risk” solutions to direct
the company to evaluate mitigations that reasonably balance cost with the resulting
reduction of wildfire risk. Put differently, Idaho Power understands the IPUC to direct the
company to identify the reasonable intersection point between cost and risk reduction. With
this in mind, see Section: 3.5. Risk Informed Mitigation Evaluation Framework, as well as
sections 8.3 Transmission Line Rebuild Projects, 8.4.1. Overhead Primary Hardening
Program, 8.4.2. Overhead to Underground Conversion, 8.4.3 New Underground
Construction, 10.3.4. Covered Conductor (Pilot) and Attachment 2 to the Application
accompanying this WMP’s submission to the IPUC.
Idaho Power Company Idaho and Montana Wildfire Requirements and Recommendations
Page 14
IPUC Order No. 36042, Case No. IPC-E-23-11
Within the company’s IPUC-approved settlement stipulation to its 2023 general rate case,
Idaho Power agreed that future iterations of its WMP would break down internal labor
expenses for all WMP programs and to extend the WMP forecast to five years for each
version. The company also agreed to explore methods to reduce costs with communication
and education regarding wildfire and PSPS.
Pursuant to Commission Order No. 37004, the first portion of this requirement has been
superseded by Commission Order No. 36774, which states that WMP’s shall be developed
with a minimum 3-year planning horizon. Appendix F: Wildfire Mitigation Activities and Cost
Forecast 2027–2029 addresses this requirement. With respect to the company’s exploration
of methods to reduce costs with communication and education regarding wildfire and PSPS,
Idaho Power continues to evaluate opportunities to reduce costs related to these activities,
in part through partnering with local emergency managers on community preparedness
events and efforts as described in Section 11.2. Community Engagement.
IPUC Order No. 35717, Case No. IPC-E-22-27
The following contains the IPUC’s directives contained exclusively within Order No. 35717
related to Idaho Power’s development of WMP filings and the content to be contained therein.
Require the company to detail relationships it has that may benefit the wildfire program,
contribute to program costs, or provide for cost sharing opportunities in the WMP.
This requirement was incorporated in the IPUC WMP Guidelines and is addressed by the
company in various sections of the WMP, including Section 4.6. Wildfire Detection Cameras,
Section 10.3.2. Wildfire Resilience Partnerships and Fuels Reduction Shared Stewardship
(Pilot), and Section 12. Government, Industry, and Peer Utility Outreach.

Idaho Power Company Idaho and Montana Wildfire Requirements and Recommendations
Page 15
Require the company to provide details of all funding alternatives and sources pursued within the
WMP.
Idaho Power has pursued grant funding through the Idaho State Office of Energy and
Minerals Resources (OEMR) and Department of Energy (DOE) for grid modernization and
resilience. Idaho Power continues to investigate and apply for funding opportunities.
Grant Name WMP Project/Initiative
Awarding
Agency
Awarded Amount
($1,000) Timeline Status
Idaho Energy
Resiliency Grant
Program Round 1
Strategic Overhead to
Undergrounding of overhead
powerlines
OEMR/DOE $2,000 2025–2027 Active Project
Idaho Energy
Resiliency Grant
Program Round 2
Wildfire Situational Awareness
Equipment-- Weather Stations,
Cameras, line monitors
OEMR/DOE $1,499 2027 Pending Contract
Negotiation
Idaho Wildfire
Resilience Investment
Program (WRIP)
Strategic Overhead to
Undergrounding of powerlines
OEMR $650 2026–2027 Active Project

2027 WMP Major Updates/Changes
Below is a high-level summary of the major updates and changes to Idaho Power’s WMP since it
was last filed with the IPUC on October 10, 2025, in Case No. IPC-E-25-32.
• Updated risk modeling process description within Section 2, along with updated wildfire
risk zone boundaries as shown in Appendix C: Wildfire Risk Zone Map Book.
• Updates to Section 3: Cost-Benefit Approach to align with requirements from
Commission Order No. 37004.
• Section 7. Infrastructure Inspection and Asset Management was revised in some areas
to provide readers with additional clarity on Idaho Power’s Infrastructure and Asset
Management programs. The described programs remain unchanged.
• Section 9. Vegetation Management was re-written to provide readers with additional
clarity with respect to Idaho Power’s vegetation management programs. The described
vegetation management programs remain unchanged.
• Consistent with Commission Order No. 37004, additional information, including
evaluation metrics, duration and annual costs, was added for each pilot listed under
Section 10.3. Pilot Projects.
• The addition of Appendix G: Project Hardening List, Appendix H: Average Costs of
Mitigation Costs (Confidential), and Appendix I: Glossary of Terms.
• Updates to Section 13.3. 2026 Lessons Learned.
Idaho Power Company Idaho and Montana Wildfire Requirements and Recommendations
Page 16
Montana WMP Requirements
This Appendix D provides additional information specific to wildfire-related requirements in
Montana.
Pursuant to Montana Code Section 69-2-302, Idaho Power also filed this WMP with its statutory
“approval authority,” as the appropriate body responsible for its corporate governance. No
additional requirements were added by Idaho Power’s approval authority upon their approval
of the 2026 WMP. Montana Code Section 69-2-302 establishes requirements for the WMP as to
the Montana portion of this plan. The below crosswalk identifies where the plan meets
Montana Code Section 69-2-302’s requirements.
Montana Requirement—Montana Code 69-2-302 Corresponding Location in WMP
Section 2 (2)(a) A wildfire mitigation plan must include description
of areas in which the electric facilities provider has electric facilities
or electric transmission and distribution activities that may be
subject to a heightened risk of wildfire;
Section 2. Geographical Risk Assessment
Appendix C: Wildfire Risk Zone Map Book
Appendix E: Idaho Power Transmission Line Map Book
Section 2 (2)(b) A wildfire mitigation plan must include a description
of the strategies and programs that the electric facilities provider
will use to inspect, maintain, repair, and operate its electric
facilities;
Section 4. Situational Awareness and Monitoring
Section 5. Mitigation Activity: Workforce
Preparedness
Section 6. Mitigation Activity: Line Operation Practices
Section 7. Infrastructure Inspection and Asset
Management
Section 8. Methods of Line Design
Section 10. Additional Preventative Actions and
Programs
Appendix A. Wildland Fire Preparedness and
Prevention Plan
Section 2 (2)(c) A wildfire mitigation plan must include a description
of the strategies and programs that the electric facilities provider
will use to perform vegetation management;
Section 9. Vegetation Management
Section 10. Additional Preventative Actions and
Programs
Section 12. Government, Industry, and Peer Utility
Outreach
Appendix F: Wildfire Mitigation Activities and Cost
Forecast—2027–2029
Section 2 (2)(d) A wildfire mitigation plan must include a description
of the strategies for modifications or upgrades to electric facilities
and preventative programs that the electric facilities provider will
employ to reduce the risk of its electric facilities igniting a wildfire;
Section 4. Situational Awareness and Monitoring
Section 5. Mitigation Activity: Workforce
Preparedness
Section 6. Mitigation Activity: Line Operation Practices
Section 7. Infrastructure Inspection and Asset
Management
Section 8. Methods of Line Design
Section 10. Additional Preventative Actions and
Programs
Appendix A: Wildland Fire Preparedness and
Prevention Plan
Appendix B: Wildfire Public Safety Power Shutoff Plan
Idaho Power Company Idaho and Montana Wildfire Requirements and Recommendations
Page 17
Montana Requirement—Montana Code 69-2-302 Corresponding Location in WMP
Section 2 (2)(e) A wildfire mitigation plan must include a description
of the strategies and methods for de-energizing power lines and
modifying electric facility operations to mitigate potential wildfires
taking into consideration the ability of the electric facilities provider
to reasonably access the proposed electric facility to be de-
energized, the balance of the risk of wildfire with the need for
continued supply of electricity to a community, and any potential
impact to public safety, first responders, and health and
communications infrastructure;
Section 6. Mitigation Activity: Line Operation Practices
Appendix B: Wildfire Public Safety Power Shutoff Plan
Section 2 (2)(f) A wildfire mitigation plan must include a description
of the methods the electric facilities provider intends to use to
restore its electrical system in the event systems are de-energized
for the prevention of a wildfire;
Section 6. Mitigation Activity: Line Operation Practices
Appendix B: Wildfire Public Safety Power Shutoff Plan
Section 2 (2)(g) A wildfire mitigation plan must include a description
of the estimated incremental costs associated with implementing
the plan, including system improvements and upgrades for a
regulated utility;
Section 14. WMP Cost Summary
Appendix F: Wildfire Mitigation Activities and Cost
Forecast—2027–2029
Section 2 (2)(h) A wildfire mitigation plan must include a description
of the community outreach and public awareness efforts before and
during a wildfire season; and
Section 11. Public Outreach and Engagement
Appendix B: Wildfire Public Safety Power Shutoff Plan
Section 2 (2)(i) A wildfire mitigation plan must include a description
of the potential participation, if applicable, with state or local
wildland fire protection plans or wildfire mitigation plans.
Section 12. Government, Industry, and Peer Utility
Outreach

Idaho Power Company Idaho and Montana Wildfire Requirements and Recommendations
Page 18

Appendix E.
Idaho Power Transmission
Line Map Book

October 2026
© 2026 Idaho Power
Idaho Power Company Idaho Power Transmission Line Map Book
Page i
List of Figures
Figure 1
Idaho Power transmission lines ................................................................................................... 1
Figure 2
Idaho Power transmission line detail—A. Idaho/Montana ......................................................... 2
Figure 3
Idaho Power transmission line detail—B. Idaho/Montana ......................................................... 3
Figure 4
Idaho Power transmission line detail—C. Idaho/Wyoming ......................................................... 4
Figure 5
Idaho Power transmission line detail—D. Idaho/Nevada ........................................................... 5

Idaho Power Company Idaho Power Transmission Line Map Book
Page ii

Idaho Power Company Idaho Power Transmission Line Map Book
Page 1

Figure 1
Idaho Power transmission lines
Idaho Power Company Idaho Power Transmission Line Map Book
Page 2

Figure 2
Idaho Power transmission line detail—A. Idaho/Montana
Idaho Power Company Idaho Power Transmission Line Map Book
Page 3

Figure 3
Idaho Power transmission line detail—B. Idaho/Montana
Idaho Power Company Idaho Power Transmission Line Map Book
Page 4

Figure 4
Idaho Power transmission line detail—C. Idaho/Wyoming
Idaho Power Company Idaho Power Transmission Line Map Book
Page 5

Figure 5
Idaho Power transmission line detail—D. Idaho/Nevada
Idaho Power Company Idaho Power Transmission Line Map Book
Page 6

Appendix F.
Wildfire Mitigation
Activities and Cost Forecast
2027–2029

October 2026
© 2026 Idaho Power
Idaho Power Company Wildfire Mitigation Activities and Cost Forecast 2027–2029
Page i
List of Tables
Table 1
Estimated O&M expenses for wildfire mitigation, $000s (2027–2029)* ..................................... 1
Table 2
Wildfire mitigation forecasted capital investments, $000s, (2027-2029)* ................................. 3
Table 3
Wildfire mitigation plan asset inspection targets (2027–2029)* ................................................ 4
Table 4
Distribution asset management and situational awareness targets (2027–2029)** ................... 4
Table 5
2027–2029 vegetation management targets (2027–2029)* ....................................................... 5

Idaho Power Company Wildfire Mitigation Activities and Cost Forecast 2027–2029
Page ii
Idaho Power Company Wildfire Mitigation Activities and Cost Forecast 2027–2029
Page 1
Table 1
Estimated O&M expenses for wildfire mitigation, $000s (2027–2029)*
*As of October 1, 2026. These are best-known estimates at the time of this Wildfire Mitigation Program (WMP) filing and are subject to change. These numbers are provided only for the purpose of
review and approval of this WMP pursuant to the Idaho Wildfire Standard of Care Act (WSCA). They should not be used for any other purpose.
Wildfire Mitigation Program Description
2027
Forecast
2028
Forecast
2029
Forecast
A. Geographical Risk Assessment
Risk Modeling—Risk Maps, Fire Simulation, Probabilistic Model Development and Support $2,273 $2,347 $2,464
B. Situational Awareness and Monitoring
Weather Forecasting—System Development and Support, Data Services, Climatology $96 $96 $96
Weather Forecasting Personnel—Fire Potential Index (FPI) and Public Safety Power Shutoff (PSPS) $172 $177 $182
Weather Forecasting—Weather Station Maintenance $219 $241 $260
Pole Loading Modeling & Assessment (Contract service) $72 $72 $72
Wildfire Detection Cameras $288 $315 $340
C. Workforce Preparedness
Tools/Equipment $19 $24 $24
International Wildfire Risk Mitigation Consortium $40 $40 $40
D. Infrastructure Inspection and Asset Management
O&M Component of Capital Work $493 $592 $651
Annual O&M T&D Patrol Maintenance Repairs $125 $137 $151
Transmission Thermography Inspection Mitigation $48 $48 $48
Distribution Thermography Inspection Mitigation $48 $48 $48
Thermography Technician Personnel $164 $169 $171
Transmission Wood Pole Fire Resistant Wraps $239 $239 $239
Wildfire Mitigation Program Labor $1,242 $1,279 $1,318
Patrolmen for Wildfire Pre-Season Inspections in Wildfire Risk Zones $431 $444 $457
Covered Wire Evaluation—Pilot Program in PSPS Zones $2 $3 $0
Idaho Power Company Wildfire Mitigation Activities and Cost Forecast 2027–2029
Page 2
Wildfire Mitigation Program Description
2027
Forecast
2028
Forecast
2029
Forecast
Drone Beyond Visual Line of Sight Waiver for PSPS Patrols $0 $115 $0
UAS (drone) Inspection Pilot $867 $895 $922
E. Vegetation Management
Transition to/Maintain 3-year Vegetation Management Cycle (includes Enhanced Practices for Distribution Tier 3 &
Tier 2 Risk Zones)
$42,134 $44,609 $49,099
Internal Tree Trimming Crew $769 $792 $816
Line Clearing Personnel $197 $203 $209
Fuel Reduction Program $72 $72 $72
F. Public Outreach and Engagement
Wildfire/Wildfire Mitigation Education/Communication—Advertisements, Bill Inserts, Meetings, Other & PSPS
Customer Education/Communication—Advertisements, Bill Inserts, Other $164 $164 $164
Public Meetings/Event Fees for PSPS Engagement, Maps, Flyers $8 $10 $10
Community and Customer Engagement and Outreach $180 $185 $191
G. Line Operations Practices PSPS/Emergency Preparedness and Technology
Communication/Alert Tool for PSPS Customer Alerts/Extended Use $216 $216 $216
Fire Suppression Resources $180 $186 $191
Standby Helicopter Service $287 $287 $296
Community Resource Centers $5 $5 $5
Total $51,050 $54,010 $58,752
Idaho Power Company Wildfire Mitigation Activities and Cost Forecast 2027–2029
Page 3
Table 2
Wildfire mitigation forecasted capital investments, $000s, (2027-2029)*
Mitigation Program Program Description
2027 Planned in
Service
2028 Planned in
Service
2029 Planned in
Service
Overhead Primary Hardening Program Systematic replacement and upgrades of hardware and equipment $21,000 $24,000 $36,900
Strategic Undergrounding Select conversion of overhead to underground distribution in Tier 3
Risk Zones
$12,000 $12,000 $23,000
Recloser Segmentation and
Communication Upgrades
Installation, relocation, and expanded communication for automatic
reclosing overcurrent protection devices
$350 $600 $200
Wildfire Detection Cameras Cameras enabled with artificial intelligence to detect smoke and
notify first responders
$35 $35 $0
Atmospheric Science Weather Stations Installation of weather stations to gain situational awareness $100 $70 $70
Total $33,485 $36,705 $60,170
*These are estimates only. The costs may increase or decrease due to such factors as inflation or scope changes. These numbers are provided only for the purpose of review and approval of this WMP
pursuant to the WSCA. They should not be used for any other purpose.
Idaho Power Company Wildfire Mitigation Activities and Cost Forecast 2027–2029
Page 4
Table 3
Wildfire mitigation plan asset inspection targets (2027–2029)*
Wildfire Mitigation Plan Asset Inspection Initiatives 2027 Goal 2028 Goal 2029 Goal
Transmission Inspections
Wildfire Pre-Season Patrol (Annual Visual Inspection)—(Structures) 1,525 1,525 1,525
Infrared Thermography Patrol (Structures) 1,525 1,525 1,525
Distribution Inspections
Wildfire Pre-Season Patrol (Annual Visual Inspection)—(Poles) 23,475 23,475 23,475
Infrared Thermography Patrol—Tier 3 Zones (Poles) 4,000 4,000 4,000
* The targets shown are based on the current number of poles and structures and on the contents of Idaho Power’s 2027 WMP. They are subject to change in future WMPs.
Table 4
Distribution asset management and situational awareness targets (2027–2029)**
Initiative Wildfire Mitigation Plan Activity 2027 Target 2028 Target 2029 Target
Distribution System Hardening* System Hardening (miles) 78 80 130
Overhead Line Converted to Underground (miles) 13 13 25
Feeder Segmentation Installation or Relocation of Automatic Reclosing Devices 6 12 4
Wildfire Detection Cameras Cameras enabled with artificial intelligence to detect smoke and notify
first responders
1 1 0
Atmospheric Science Weather Stations Installation of weather stations to gain situational awareness 5 3 3
*Excludes reliability improvement projects outside of wildfire risk zones
** The targets shown are based on the contents of Idaho Power’s 2027 WMP. They are subject to change in future WMPs.
Idaho Power Company Wildfire Mitigation Activities and Cost Forecast 2027–2029
Page 5
Table 5
2027–2029 vegetation management targets (2027–2029)*
Wildfire Mitigation Plan Vegetation Management Initiatives* 2027 Goal (ID)** 2028 Goal (ID) 2029 Goal (ID)
Wildfire Mitigation Inspection Patrol/Mitigation (Number of T&D Circuits) 177 177 177
Line Clearing Cycles Patrol/Mitigation (Number of T&D Circuits) 209 265 273
Mid Cycle Patrol/Mitigation (Cycle Busters) (Number of T&D Circuits) 54 38 61
QA/QC Audit Patrols 100% of WRZs 100% of WRZs 100% of WRZs
Targeted Pole Clearing (Number of Poles) 500 Poles 500 Poles 500 Poles
*Idaho Power strives to meet the targets identified herein but may not meet them in all cases. The targets shown are based on the contents of Idaho Power’s 2027 WMP.
They are subject to change in future WMPs.
** Circuit numbers can potentially change due to circuit cutovers or reconfigurations.
*** Circuit as used for wildfire mitigation patrols means the portion of the circuit that is located within the wildfire risk zone boundaries.
Idaho Power Company Wildfire Mitigation Activities and Cost Forecast 2027–2029
Page 6

Appendix G.
Grid Hardening List

October 2026
© 2026 Idaho Power
Idaho Power Company Grid Hardening List
Page 1
Grid Hardening List
The table below identifies infrastructure projects primarily driven by wildfire risk reduction described in Section 8 of the WMP that
Idaho Power plans to undertake in 2027 as part of its wildfire mitigation strategy. Idaho Power’s goal is to complete 100% of the work
identified in the below table; however, emergencies, operational issues, access issues, permitting delays or other unplanned events
can occur and disrupt the planned work. All work is completed in accordance with safety and applicable requirements. Inclusion of a
project on this table reflects Idaho Power’s good faith representation of its construction plans for 2027; it is not a guarantee that a
project will be constructed exactly as described or even at all.
The estimated costs are planning-level cost categories used to identify the relative scale of mitigation investment planned in 2027.
Cost categories reflect planning-level estimates available at the time of preparing the Idaho and Montana 2027 Wildfire Mitigation
Plan (WMP). Actual project costs may change once project scopes are refined and engineering, permitting, procurement, bidding,
field investigations, and construction planning activities progress. As such, the estimated cost categories are provided only for the
purpose of review and approval of the WMP pursuant to the Wildfire Standard of Care Act. They should not be used for any other
purpose.
Project Description, Location, and Standards
Project Name Timeline Location (County/City)
Project Type, Description
and Design Standards WRZ Tier Estimated Cost Category Line Miles
Pocatello—13 2027-01 2027 Bannock County—
Southwest of Pocatello
Distribution, OH to UG
conversion with line
relocation, Section 8.4.2 of
2027 WMP
3 Less than $1 million 1.1
Eckert—41 2027-01 2027 Boise County—Idaho City Distribution, OH to UG
conversion, Section 8.4.2 of
2027 WMP
3 $1 million to less than $5 million 2.3
Horseshoe Bend—41 2027-01 2027 Boise County—Northeast of
Terrace Lakes
Distribution, OH to UG
conversion, Section 8.4.2 of
2027 WMP
3 $1 million to less than $5 million 2.4
McCall—41 2027-01 2027 Valley County—Ponderosa
State Park
Distribution, OH to UG
conversion, Section 8.4.2 of
2027 WMP
3 $1 million to less than $5 million 2.5
Idaho Power Company Grid Hardening List
Page 2
Project Name Timeline Location (County/City)
Project Type, Description
and Design Standards WRZ Tier Estimated Cost Category Line Miles
Boulder—41 2027-01 2027 Valley County—Eastside
Drive
Distribution, OH to UG
conversion, Section 8.4.2 of
2027 WMP
3 $1 million to less than $5 million 5.9
Ketchum—13 2027-01 2027 Blaine County — North of
Ketchum
Distribution, OH to UG
conversion, Section 8.4.2 of
2027 WMP
3 Less than $1 million 0.37
Horseshoe Bend—41 2027-02 2027 Boise County—Crouch Distribution, OH Hardening,
Section 8.4.1 of 2027 WMP
3 Less than $1 million 4.7
Portnuef—42 2027-01 2027 Bannock County—Southeast
of Pocatello
Distribution, OH Hardening,
Section 8.4.1 of 2027 WMP
3 Less than $1 million 3.1
Salmon—14 2027-01 2027 Lemhi County—East of
Salmon
Distribution, OH Hardening,
Section 8.4.1 of 2027 WMP
3 $1 million to less than $5 million 5.8
Terry—16 2027-01 2027 Bannock County—East of
Pocatello
Distribution, OH Hardening,
Section 8.4.1 of 2027 WMP
3 Less than $1 million 4.9
Terry—16 2027-02 2027 Bannock County—East of
Pocatello
Distribution, OH Hardening,
Section 8.4.1 of 2027 WMP
3 $1 million to less than $5 million 6.1
Terry—16 2027-03 2027 Bannock County—East of
Pocatello
Distribution, OH Hardening,
Section 8.4.1 of 2027 WMP
3 $1 million to less than $5 million 7.0
Eckert—41 2027-02 2027 Boise County—Idaho City Distribution, OH Hardening,
Section 8.4.1 of 2027 WMP
3 $1 million to less than $5 million 9.6
McCall—41 2027-02 2027 Valley County—Northeast
of McCall
Distribution, OH Hardening,
Section 8.4.1 of 2027 WMP
3 Less than $1 million 2.3
Horseshoe Bend—41 2027-03 2027 Boise County—East of
Terrace Lakes
Distribution, OH Hardening,
Section 8.4.1 of 2027 WMP
3 Less than $1 million 4.9
Bruneau Bridge—44 2027-01 2027 Elmore County—Southwest
of Mountain Home
Distribution, OH Hardening,
Section 8.4.1 of 2027 WMP
2 $1 million to less than $5 million 8.1
Beacon Light—11 2027-01 2027 Ada County—North of Star Distribution, OH Hardening,
Section 8.4.1 of 2027 WMP
2 $1 million to less than $5 million 6.3
Bruneau Bridge—44 2027-02 2027 Elmore County—South of
Mountain Home
Distribution, OH Hardening,
Section 8.4.1 of 2027 WMP
2 $1 million to less than $5 million 15.0

Appendix H.
Average Mitigation
Project Costs

October 2026
© 2026 Idaho Power
CONFIDENTIAL
Idaho Power Average Mitigation Project Costs
Page 1
Average Mitigation Project Costs

Mitigation Type Unit Average Project Installation Cost*

CONFIDENTIAL
Idaho Power Average Mitigation Project Costs
Page 2

Appendix I.
Glossary of Terms

October 2026
© 2026 Idaho Power
Idaho Power Company Glossary of Terms
Page 1
Glossary of Terms
Unless otherwise expressly stated, the following words and terms, for the purposes of the
WMP, have the meanings shown in this appendix.
Term Acronym Definition
Annual All references to ‘annual’ or ‘annually’ in this WMP mean once per calendar year,
unless stated otherwise.
Audit Throughout the WMP, the term ‘audit’ is used in an informal context and does not
mean a formal audit conducted by the company’s Audit Services Department or by
an outside auditing firm.
Bureau of Land Management BLM An agency within the United States Department of the Interior responsible for
administering United States federal lands.
Community Resource Center CRC Facilities that provide critical information to customers impacted by outages. The
CRC may also provide impacted customers with access to other services, such as
device charging, internet access, clean water, and ice.
Consequence Estimation of potential wildfire impacts under fire spread simulations to specific
resources (natural) and assets (human-made), such as residences, population,
and acreage.
Critical Facilities The facilities identified by Idaho Power that, because of their function or
importance, have the potential to threaten life, safety, or disrupt essential
socioeconomic activities if their services are interrupted.
Cycle Busters Vegetation identified by the Utility Arborist as exhibiting growth rates that may
result in encroachment into line clearances before the next scheduled
pruning cycle.
Dead Fuel Moisture FD The amount of water contained in vegetation with no living tissue, expressed as a
percentage of the fuel's oven-dry weight. Dead fuel moisture is governed primarily
by atmospheric conditions, including relative humidity, temperature, precipitation,
and solar radiation.
Dispatch Members of Idaho Power’s regional and system dispatch group tasked with
monitoring the regional grid and electric system.
Emergency Support Function-
12
ESF-12 Liaison from a given state’s designated emergency support function for energy
utilities during an emergency.
Enhanced Powerline Safety
Settings
EPSS Advanced safety settings implemented by Idaho Power on electric utility power
lines to reduce wildfire risk.
EPSS Mode 1: Auto-reclose turned off. This allows only a single trip, which
eliminates traditional re-energizations to test whether the fault has cleared on
the line.
EPSS Mode 2: Auto-reclose turned off and trip settings set to instantaneous
lockout. This is a more sensitive setting that will cause the automatic reclosing
device to lockout prior to most fuses. Mode 2 is designed to minimize the energy of
a fault to reduce ignition risk.
Exercise Planned activities and assessments that ensure continuity of operations, provide
and direct resources and capabilities, and gather lessons-learned to develop core
capabilities needed to respond to incidents.
Idaho Power Company Glossary of Terms
Page 2
Term Acronym Definition
Fire Potential Index FPI Idaho Power’s Landscape-scale index used to assess risk of a wildfire under current
and forecasted weather conditions.
Fire Weather Watch FWW Issued by the National Weather Service when the combination of dry fuels and
weather conditions support extreme fire danger within the next 12 to 72 hours.
Fuels Component FC The Fuels Component of the FPI represents the condition of dead and live woody
fuels that can potentially support wildfire, and is calculated as the ratio of dead fuel
moisture to live fuel moisture
Geographic Information
System
GIS A computer system that analyzes and displays geographically referenced
information.
Great Basin Coordination
Center
GBCC The focal point for coordinating resources for wildland fire and other incidents
through the Great Basin.
Hazard Trees Trees identified by the Utility Arborist as showing signs of mortality at the time of
patrol or have one or more structural defects that could make the tree likely to fail
and fall into or onto power lines.
High Wind Warning HWW Issued by the National Weather Service when sustained, strong winds with even
stronger gusts are expected or occurring. Generally, for sustained winds of 40 mph
or greater lasting for 1 hour or longer, or winds of 58 mph or greater for any
duration.
High-Priority Vegetation Any vegetation condition identified by the Utility Arborist as likely to cause a line
outage with a high risk of failure in the next few days or weeks. These are normally
tall Hazard Trees. High-Priority Vegetation could also be vegetation that is in good
condition but has grown so close to the line that it presents a high risk of coming
into contact with the line through a combination of conductor sag and/or wind-
induced movement of the conductor or the vegetation.
Line Clearing Cycles Identification and mitigation of vegetation risk by the Utility Arborist and removal
of enough vegetation such that, in the judgment of the Utility Arborist, the
vegetation is unlikely to grow into the line clearance envelope before the next cycle
pruning. This occurs on both transmission and distribution lines on a periodic basis.
Line Miles The number of miles of transmission and/or distribution circuits in linear miles,
regardless of the number of circuits.
Live Fuel Moisture LFM The amount of water contained in living vegetation, expressed as a percentage of
the fuel's oven-dry weight. Live fuel moisture is influenced by seasonal atmospheric
conditions and plant physiological processes, including water uptake, growth stage,
and seasonal phenology. The Growing Season Index is often used as a proxy for
estimating live fuel moisture.
Local Emergency Managers A person assigned a role in a jurisdiction that oversees the day-to-day emergency
management programs and activities.
Lock Out Lock out refers to the condition in which a protection device has operated and
remains de-energized until it is manually or remotely reset. Depending on the
protection scheme and settings, lockout may occur following one or more
trip/reclose attempts or after a single trip.
National Interagency Fire
Center
NIFC A facility in Boise, Idaho, where employees of multiple national and state agencies
work together to ensure wildland fire personnel across the United States receive
the support and information they need.
National Weather Service NWS A government agency that provides weather, water, and climate forecasts and
warnings for the United States, its territories, adjacent waters, and ocean areas.
Idaho Power Company Glossary of Terms
Page 3
Term Acronym Definition
Overhead OH Typically used to differentiate overhead electrical circuits from underground
electrical circuits.
Particularly Dangerous
Situation
PDS Issued by the National Weather Service for rare situations where long-lived strong
and violent weather conditions are possible. This enhanced wording may also
accompany severe thunderstorm watches for intense convective windstorms
Point of Delivery The junction point between the facilities owned by the company and the facilities
owned by the customer; or the point at which the company’s lines first become
adjacent to the customer’s property; or as otherwise specified in the company’s
tariff.
Priority 1 Findings Defects that, depending on the circumstances, require reporting and repair as soon
as reasonably possible, generally within 30 days upon identification by Idaho
Power. Timeframes can be extended as a result of conditions, such as access issues,
weather, and/or materials lead time.
Priority 2 Findings Defects that, depending on the circumstances, generally require reporting and
correction within 24 months of identification by Idaho Power, and the correction of
these defects are scheduled during crews’ normal work schedules. Timeframes can
be extended beyond 24 months as a result of conditions, such as materials lead
time, including the correction as part of a broader project, and access issues.
Priority 3 Findings Defined by Idaho Power as potential issues that may need correction over time and
should be monitored, but do not pose a threat to the system. A Priority 3
designation may also be used by Idaho Power personnel for tracking certain line
construction practices. Correction of Priority 3 issues may be deferred until the
next major work activity on the circuit, up to a maximum of 10 years after
discovery on transmission facilities. On distribution facilities, Priority 3 issues may
be monitored until the issues qualify as Priority 1 or Priority 2 defects.
Public Safety Partners State of Idaho or State of Montana Emergency Support Function-12, Local
Emergency Managers, and other agencies or entities that collaborate with Idaho
Power to manage, prepare for, and respond to emergencies.
Public Safety Power Shutoff PSPS The proactive de-energization, when deemed appropriate by Idaho Power, of
electric transmission and/or distribution facilities during extreme weather events
to reduce wildfire risk.
Red Flag Warning RFW A term used by fire-weather forecasters to call attention to limited weather
conditions of particular importance that may result in extreme burning conditions.
It is issued when it is an on-going event or the fire weather forecaster has a high
degree of confidence that Red Flag criteria will occur within 24 hours of issuance.
Red Flag criteria occurs whenever a geographical area has been in a dry spell for a
week or two, or for a shorter period, if before spring green-up or after fall color,
and the National Fire Danger Rating System (NFDRS) is high to extreme and the
following forecast weather parameters are forecasted to be met:
1) A sustained wind average 15 mph or greater
2) Relative humidity less than or equal to 25 percent and
3) A temperature of greater than 75 degrees Fahrenheit.
In some states, dry lightning and unstable air are criteria. A Fire Weather Watch
may be issued prior to the Red Flag Warning.
Risk Drivers Factors that may potentially lead to an ignition, as listed on the left side of Figure 7
in the 2027 Idaho Power WMP.
Subject-Matter Expert SME An individual who has advanced knowledge in a specific field.
Idaho Power Company Glossary of Terms
Page 4
Term Acronym Definition
Supervisory Control and Data
Acquisition
SCADA A system of hardware and software that enables an organization to remotely
control and monitor equipment, systems, and processes.
Transmission Line Test A transmission line “test” or transmission line “testing” refers to the human act of
re-energizing a line without completing a physical field patrol or observation of
a line.
Triggering Event The event Idaho Power aims to avoid, that could impact the company’s ability to
meet its objectives of providing safe, reliable, and affordable energy.
Vegetation Encroachments Vegetation identified by the Utility Arborist as growing into the clearance envelope
of the line. Because of Idaho Power’s cycle pruning efforts, Idaho Power generally
expects that vegetation encroachments found on vegetation management patrols
will be Cycle Busters.
Weather Research and
Forecasting
WRF A state-of-the-art mesoscale numerical weather prediction system designed for
both atmospheric research and operational forecasting applications.
Wildfire Hazard The likelihood and potential intensity of wildfire, regardless of the presence of
resources (natural) and assets (human-made).
Wildfire Probability Whether the landscape is conducive to ignition and spread (i.e., whether the
landscape can support an ignition).
Wildfire Risk The potential for wildfire hazard to impact resources (natural) and assets
(human-made) within a geographic area.
Wildfire Risk Zone WRZ Geographic area where Idaho Power has infrastructure or equipment that Idaho
Power considers may be subject to a heightened risk of wildfire. Idaho Power
categorizes its wildfire risk zones as Tier 2 or Tier 3.
Wildfire Season Idaho’s wildfire season is defined by Idaho Code § 38-115 as extending from
May 10 through October 20 each year, or as otherwise extended by the director of
the Idaho Department of Lands.
Montana’s wildfire season is defined by Montana Code § 76-13-102 as the period
of each year beginning May 1 and ending September 30. Montana’s wildfire season
can be extended by the Montana Department of Natural Resource pursuant to
Montana Code §76-13-203.
Wildland-Urban Interface WUI The line, area, or zone where structures and other human development meet or
intermingle with undeveloped wildland or vegetation fuels (National Wildfire
Coordinating Group).
Zone of Protection ZOP The area or segment of an electrical power system that is protected by a particular
protective device or protection system.

BEFORE THE

IDAHO PUBLIC UTILITIES COMMISSION

CASE NO. IPC-E-26-28

IDAHO POWER COMPANY

ATTACHMENT NO. 2
Idaho Power's 2027 WMP Risk-Informed Mitigation Evaluation Framework
Project Name Timeline Location (County/City) Project Type, Description and
Design Standards WRZ Tier Estimated Cost Category Line Miles
Pocatello-13 2027-01 2027
Bannock County—Southwest of
Pocatello
Distribution, OH to UG conversion
with line relocation, Section 8.4.2 of
2027 WMP
3 Less than $1 million 1.1
Eckert-41 2027-01 2027 Boise County—Idaho City Distribution, OH to UG conversion,
Section 8.4.2 of 2027 WMP 3 $1 million to less than
$5 million 2.3
Horseshoe Bend-41 2027-01 2027
Boise County—Northeast of
Terrace Lakes
Distribution, OH to UG conversion,
Section 8.4.2 of 2027 WMP 3 $1 million to less than
$5 million 2.4
McCall-41 2027-01 2027
Valley County—Ponderosa State
Park
Distribution, OH to UG conversion,
Section 8.4.2 of 2027 WMP 3 $1 million to less than
$5 million 2.5
Boulder-41 2027-01 2027 Valley County—Eastside Drive Distribution, OH to UG conversion,
Section 8.4.2 of 2027 WMP 3 $1 million to less than
$5 million 5.9
Ketchum-13 2027-01 2027
Blaine County — North of
Ketchum
Distribution, OH to UG conversion
with line relocation, Section 8.4.2 of
2027 WMP
3 Less than $1 million 0.37
Horseshoe Bend-41 2027-02 2027 Boise County—Crouch Distribution, OH Hardening, Section
8.4.1 of 2027 WMP 3 Less than $1 million 4.7
Portneuf-42 2027-01 2027
Bannock County—Southeast of
Pocatello
Distribution, OH Hardening, Section
8.4.1 of 2027 WMP 3 Less than $1 million 3.1
Salmon-14 2027-01 2027 Lemhi County—East of Salmon Distribution, OH Hardening, Section
8.4.1 of 2027 WMP 3 $1 million to less than
$5 million 5.8
Terry-16 2027-01 2027 Bannock County—East of Pocatello Distribution, OH Hardening, Section
8.4.1 of 2027 WMP 3 Less than $1 million 4.9
Terry-16 2027-02 2027 Bannock County—East of Pocatello Distribution, OH Hardening, Section
8.4.1 of 2027 WMP 3 $1 million to less than
$5 million 6.1
Terry-16 2027-03 2027 Bannock County—East of Pocatello Distribution, OH Hardening, Section
8.4.1 of 2027 WMP 3 $1 million to less than
$5 million 7.0
Eckert-41 2027-02 2027 Boise County—Idaho City Distribution, OH Hardening, Section
8.4.1 of 2027 WMP 3 $1 million to less than
$5 million 9.6
McCall-41 2027-02 2027
Valley County—Northeast of
McCall
Distribution, OH Hardening, Section
8.4.1 of 2027 WMP 3 Less than $1 million 2.3
Horseshoe Bend-41 2027-03 2027
Boise County—East of Terrace
Lakes
Distribution, OH Hardening, Section
8.4.1 of 2027 WMP 3 Less than $1 million 4.9
Bruneau Bridge-44 2027-01 2027
Elmore County—Southwest of
Mountain Home
Distribution, OH Hardening, Section
8.4.1 of 2027 WMP 2 $1 million to less than
$5 million 8.1
Beacon Light-11 2027-01 2027 Ada County—North of Star Distribution, OH Hardening, Section
8.4.1 of 2027 WMP 2 $1 million to less than
$5 million 6.3
Bruneau Bridge-44 2027-02 2027
Elmore County—South of
Mountain Home
Distribution, OH Hardening, Section
8.4.1 of 2027 WMP 2 $1 million to less than
$5 million 15.0
Page 1 of 3
Idaho Power's 2027 WMP Risk-Informed Mitigation Evaluation Framework
Project Name
Pocatello-13 2027-01
Eckert-41 2027-01
Horseshoe Bend-41 2027-01
McCall-41 2027-01
Boulder-41 2027-01
Ketchum-13 2027-01
Horseshoe Bend-41 2027-02
Portneuf-42 2027-01
Salmon-14 2027-01
Terry-16 2027-01
Terry-16 2027-02
Terry-16 2027-03
Eckert-41 2027-02
McCall-41 2027-02
Horseshoe Bend-41 2027-03
Bruneau Bridge-44 2027-01
Beacon Light-11 2027-01
Bruneau Bridge-44 2027-02
Alternatives Considered Risk Reduction Reliability Asset Benefit
Community
Benefit Critical Facilities Evacuation Route PSPS Reduction
OH Hardening with line
relocation ✓ ✓ ✓ ✓ ✓ ✓
OH Hardening ✓ ✓ ✓ ✓ ✓ ✓
OH Hardening ✓ ✓ ✓ ✓ ✓ ✓
OH Hardening ✓ ✓ ✓ ✓ ✓ ✓
OH Hardening ✓ ✓ ✓ ✓ ✓ ✓
OH Hardening with line
relocation ✓ ✓ ✓ ✓ ✓ ✓
UG Conversion ✓ ✓ ✓ ✓ ✓ ✓
UG Conversion ✓ ✓ ✓ ✓ ✓ ✓
UG Conversion ✓ ✓ ✓ ✓
UG Conversion ✓ ✓ ✓ ✓
UG Conversion ✓ ✓ ✓ ✓
UG Conversion ✓ ✓ ✓ ✓
UG Conversion ✓ ✓ ✓ ✓ ✓
UG Conversion ✓ ✓ ✓ ✓
UG Conversion ✓ ✓ ✓ ✓
UG Conversion ✓ ✓ ✓ ✓
UG Conversion ✓ ✓ ✓ ✓ ✓
UG Conversion ✓ ✓ ✓ ✓
Page 2 of 3
Idaho Power's 2027 WMP Risk-Informed Mitigation Evaluation Framework
Project Name
Pocatello-13 2027-01
Eckert-41 2027-01
Horseshoe Bend-41 2027-01
McCall-41 2027-01
Boulder-41 2027-01
Ketchum-13 2027-01
Horseshoe Bend-41 2027-02
Portneuf-42 2027-01
Salmon-14 2027-01
Terry-16 2027-01
Terry-16 2027-02
Terry-16 2027-03
Eckert-41 2027-02
McCall-41 2027-02
Horseshoe Bend-41 2027-03
Bruneau Bridge-44 2027-01
Beacon Light-11 2027-01
Bruneau Bridge-44 2027-02
Operational Benefit Project Rationale and Primary Driver Addressed
✓
Undergrounding was selected as a cost-effective option to maximize wildfire risk
reduction while improving reliability and long-term asset performance.
Relocating facilities from difficult-to-access terrain reduces ignition exposure,
enhances maintenance access, improves operational efficiency, and supports
more resilient service for the surrounding community.
✓
Undergrounding was selected as a cost-effective option to provide additional
wildfire risk reduction, address concentrated tree canopy, and provide benefit to
an area with limited evacuation routes. The project improves reliability, lowers
potential customer impacts from PSPS operations, and enhances overall
community resilience.
✓
Undergrounding was selected as a cost-effective option to provide additional
wildfire risk reduction, address concentrated tree canopy, and provide benefit to
an area with limited evacuation routes. The project improves reliability, lowers
potential customer impacts from PSPS operations, and enhances overall
community resilience.
✓
Undergrounding was selected as a cost-effective option to reduce wildfire risk
along a circuit serving critical facilities and recreation-based communities in an
area with concentrated tree canopy. The project improves service reliability,
supports essential community infrastructure, reduces potential PSPS impacts, and
leverages available grant funding to maximize customer value.
✓
Undergrounding was selected as a cost-effective option to enhance wildfire
resilience for recreation-based facilities and communities located in an area with
concentrated tree canopy, higher summer time population counts, and limited
evacuation routes. The project improves service reliability, reduces potential PSPS
impacts, and enhances overall community resilience.
✓
Undergrounding was a cost-effective option selected to reduce wildfire risk and
improve community resilience in an area with limited evacuation routes and
higher summer time population counts. The project also relocates portions of the
line to an accessible roadway corridor, improving maintenance access,
operational efficiency, and system reliability.
✓
Overhead hardening was selected as a cost-effective option to reduce wildfire risk
in an area with limited evacuation routes and minimal tree canopy. The project
improves system resilience and reliability while providing important community
benefit and risk reduction.
✓
Overhead hardening was selected as a cost-effective option to improve reliability
and reduce wildfire exposure along a key transportation corridor where
vegetation-related risk is limited.
✓Overhead hardening was selected as a cost-effective solution to reduce wildfire
risk while improving overall system reliability and performance.
✓
Overhead hardening was selected as a cost-effective option to reduce wildfire risk
in an area with minimal tree canopy. The project improves system resilience and
reliability while providing important community benefit and risk reduction.
✓Overhead hardening was selected as a cost-effective option to reduce wildfire
risk. The project improves system resilience and reliability.
✓
Overhead hardening was selected as a cost-effective option to reduce wildfire risk
in an area with minimal tree canopy. The project improves system resilience and
reliability.
✓Overhead hardening was selected as a cost-effective solution to reduce wildfire
risk while improving overall system reliability and performance.
✓
Overhead hardening was selected as a cost-effective option to reduce wildfire risk
while improving reliability for critical facilities and recreation-based communities.
Project area has good access for ongoing maintenance activities.
✓
Overhead hardening was selected as a cost-effective option to reduce wildfire risk
while improving reliability for critical facilities and recreation-based communities.
Project area has good access for ongoing maintenance activities.
✓
Overhead hardening was selected as a cost-effective option to reduce wildfire risk
and improve reliability along a transportation corridor where tree-related risk is
minimal. The project strengthens asset performance, enhances operational
resilience, and supports continued access for maintenance activities.
✓
Overhead hardening was selected as a cost-effective option to reduce wildfire risk
and improve reliability along a transportation corridor where tree-related risk is
minimal. The project strengthens asset performance, enhances operational
resilience, and supports continued access for maintenance activities.
✓
Overhead hardening was selected as a cost-effective option to reduce wildfire risk
and improve reliability along a transportation corridor where tree-related risk is
minimal. The project strengthens asset performance, enhances operational
resilience, and supports continued access for maintenance activities.
Page 3 of 3
BEFORE THE

IDAHO PUBLIC UTILITIES COMMISSION

CASE NO. IPC-E-26-28

IDAHO POWER COMPANY

ATTACHMENT NO. 3

1221 W. Idaho St (83702) P.O. Box 70 Boise, ID 83707
October 5th, 2026
VIA ELECTRONIC OR CERTIFIED MAIL DELIVERY
Re: Notice of Filing — Idaho Power’s 2027 Idaho and Montana Wildfire Mitigation Plan

Attn: Stakeholders and Interested Parties

In accordance with Idaho Code § 61-1804(2), Idaho Power hereby provides notice to the state
forester, cities, counties, fire protection districts, fire protection associations, and timber
protection associations within its Idaho service area that, on October 1, 2026, it filed its 2027
Idaho and Montana Wildfire Mitigation Plan (WMP) with the Idaho Public Utilities Commission
(IPUC) for its review and approval in accordance with the Wildfire Standard of Care Act (Chapter
18, Title 61, Idaho Code) and IPUC Order No. 36774. The 2027 WMP represents Idaho Power’s
seventh plan since its inaugural WMP was submitted to the IPUC in 2021.
Idaho Power’s approach to mitigating wildfire risk is designed to protect the public interest,
reflect the size and complexity of Idaho Power’s operations, and consider the specific wildfire
risks present within areas where Idaho Power has infrastructure and equipment. The purpose of
Idaho Power’s WMP is to guide wildfire mitigation strategies and reduce wildfire risk, supporting
Idaho Power’s focus on customer and community safety and the safe, reliable, and affordable
delivery of energy. Idaho Power’s 2027 Idaho and Montana WMP is built around the following
key components:
 Geographical Risk Assessment. Idaho Power uses a risk-informed approach that considers
wildfire probability and consequence to identify areas that may be subject to potential
heightened wildfire risk in areas where Idaho Power has infrastructure and equipment.
 Mitigation Approach: Idaho Power employs a risk-informed cost and benefit balancing
approach to select and prioritize wildfire mitigations carried out to reduce wildfire risk,
which include:
 Situational awareness capabilities
 Workforce preparedness
 Operational practices, including Enhanced Powerline Safety Settings
 Asset management and inspection programs
 System hardening and other line design strategies
 Vegetation management around electric infrastructure
 Additional preventative actions and programs
 Customer and stakeholder communication and outreach
 Coordination with government agencies, industry groups, and peer utilities
 Performance Monitoring: Idaho Power monitors program performance and compliance.
(Continued on reverse side)
October 5, 2026
Idaho Power Company Page 2 of 6
Visit idahopower.com/wildfire for more information on Idaho Power’s work to reduce the
risk of wildfires.
How to Participate:
Idaho Power’s 2027 WMP has been submitted to the IPUC for its review and approval and is
available for public review. Copies of the filing are available for public inspection during regular
business hours at the IPUC’s office located at 11331 W. Chinden Blvd. Building 8, Suite 201-A,
Boise, ID 83714, or the IPUC’s website at www.puc.idaho.gov. Click on the “ELECTRIC” icon, select
“Open Cases,” and click on Case No. IPC-E-26-28. Interested parties may also subscribe to the
IPUC’s RSS feed to receive periodic updates via email about the case.
Written comments regarding Idaho Power’s 2027 WMP can be filed with the IPUC; comments
are required to be filed through the IPUC’s website or by e-mail unless computer access is not
available. To comment electronically, visit puc.idaho.gov and click on the “Case Comment Form”
link on the upper left side of the page. Please use case number IPC-E-26-28 when filling out the
form. To comment using e-mail, please send comments to the e-mail addresses listed below and
include case number IPC-E-26-28. Commenters are required to include their name and address.
If computer access is not available, comments can be mailed to the IPUC secretary and Idaho
Power at the addresses listed below. Commenters are required to include case number IPC-E-26-
28, as well as their name and address.
For the Idaho Public Utilities Commission:
Commission Secretary
Idaho Public Utilities Commission
P.O. Box 83720 Boise, ID 83720-0074
[e-mail]

Street address for express mail:
11331 W. Chinden Blvd. Building 8, Suite 201-A
Boise, ID 83714
For Idaho Power:
Megan Goicoechea Allen
Regulatory Dockets
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
[e-mail]
[e-mail]
Tim Tatum
Connie Aschenbrenner
Riley Maloney
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
[e-mail]
[e-mail]
[e-mail]

1221 W. Idaho St (83702) P.O. Box 70 Boise, ID 83707
cc:
Idaho Department of Lands, ID, State
Forester
Idaho Department of Lands, ID, Timber
Industry Representative
Southern Idaho Timber Protection
Association, ID, Chief Fire Warden
Ada County, ID, County Clerk
City Of Boise, ID, Deputy City Clerk
City Of Boise Fire, ID, Fire Chief
City Of Eagle, ID, City Clerk
City Of Garden City, ID, City Clerk
City Of Kuna, ID, City Clerk
City Of Meridian, ID, City Clerk
City Of Meridian Fire, ID, Fire Chief
City Of Star, ID, City Clerk
Eagle Fire, ID, Fire Chief
Kuna Rural Fire, ID, Fire Chief
Meridian Fire, ID, Fire Chief
North Ada County Fire & Rescue, ID, District
Administrator
Star Fire, ID, Fire Chief
Whitney Fire, ID, Fire Chief
Adams County, ID, Emergency Manager
City Of Council, ID, City Clerk
City Of New Meadows, ID, City Clerk
Council Valley Fire #1, ID, Fire Chief
Indian Valley Fire, ID, Fire Chief
Meadows Valley Fire, ID, Fire Chief
Arimo Fire, ID, Fire Chief
Bannock County, ID, County Clerk
City Of Chubbuck, ID, City Clerk
City Of Chubbuck Fire, ID, Fire Chief
City Of Inkom, ID, City Clerk
City Of Pocatello, ID, City Clerk
City Of Pocatello Fire, ID, Fire Chief
McCammon Rural Fire Protection District,
ID, Fire Chief
North Bannock Fire, ID, Fire Chief
Pocatello Valley Fire, ID, Fire Chief
Aberdeen Springfield Fire, ID, Fire Chief
Bingham County, ID, County Clerk
Blackfoot Snake River Fire, ID, Fire Chief
City Of Aberdeen, ID, City Clerk
City Of Blackfoot, ID, City Clerk
Shelley Firth Fire, ID, Fire Chief
Blaine County, ID, County Clerk
Carey Fire, ID, Fire Chief
City Of Bellevue, ID, City Clerk
City Of Bellevue Fire, ID, Fire Chief (interim)
City Of Carey, ID, City Clerk
City Of Hailey, ID, City Clerk
City Of Hailey Fire, ID, Fire Chief
City Of Ketchum, ID, City Clerk
City Of Ketchum Fire, ID, Fire Chief
City Of Sun Valley, ID, City Clerk
City Of Sun Valley Fire, ID, Fire Chief
North Blaine County Fire District, ID, Fire
Chief
Wood River Fire, ID, Fire Chief
Boise County, ID, County Clerk
City Of Crouch, ID, City Clerk
City Of Horseshoe Bend, ID, City Clerk
City Of Idaho City, ID, City Clerk
City Of Idaho City Fire Protection District,
ID, Fire Chief
October 5, 2026
Idaho Power Company Page 4 of 6
City Of Placerville, ID, City Clerk
Garden Valley Fire Protection District, ID,
Fire Chief
Horseshoe Bend Fire, ID, Fire Chief
Placerville Fire Protection District, ID, Fire
Chief
Wilderness Ranch Fire, ID, Fire Chief
Camas County, ID, County Clerk
City Of Fairfield, ID, City Clerk
City Of Fairfield Fire, ID, Fire Chief
West Magic Fire, ID, Fire Chief
Caldwell Rural Fire, ID, Fire Chief
Canyon County, ID, County Clerk
City Of Caldwell, ID, City Clerk
City Of Caldwell Fire, ID, Fire Chief
City Of Greenleaf, ID, City Clerk
City Of Melba, ID, City Clerk
City Of Middleton, ID, City Clerk
City Of Nampa, ID, City Clerk
City Of Notus, ID, City Clerk
City Of Parma, ID, City Clerk
City Of Wilder, ID, City Clerk
Melba Fire, ID, Fire Chief
Middleton Fire, ID, Fire Chief
Middleton Rural Fire District, ID, Fire Chief
Nampa Fire, ID, Fire Chief
Parma Fire, ID, Fire Chief
Upper Deer Flat Fire, ID, Fire Chief
Wilder Fire, ID, Fire Chief
Albion Fire, ID, Fire Chief
Cassia County, ID, County Clerk
City Of Burley, ID, City Clerk
City Of Burley Fire, ID, Fire Chief
City Of Declo, ID, City Clerk
North Cassia Rural / Declo Fire, ID, Fire
Chief
City Of Oakley, ID, City Clerk
Oakley Fire, ID, Fire Chief
Raft River Fire Protection District, ID, Fire
Chief
North Custer Fire, ID, Fire Chief
City Of Glenns Ferry, ID, City Clerk
City Of Glenns Ferry Fire, ID, Fire Chief
City Of Grand View, ID, City Clerk
City Of Mountain Home, ID, City Clerk
City Of Mountain Home Fire, ID, Fire Chief
Elmore County, ID, County Clerk
King Hill Rural Fire, ID, Fire Chief
Mountain Home Rural Fire Protection
District, ID, Fire Chief
Oasis Fire Protection District, ID, Fire Chief
City Of Emmett, ID, City Clerk
City Of Emmett Fire, ID, Fire Chief
Gem County, ID, County Clerk
Gem County Fire Protection #1, ID, Fire
Chief
Gem County Fire Protection #2, ID, Fire
Chief
Bliss Fire, ID, Fire Chief
City Of Bliss, ID, City Clerk
City Of Gooding, ID, City Clerk
City Of Hagerman, ID, City Clerk
City Of Wendell, ID, City Clerk
Gooding County, ID, County Clerk
Gooding Fire, ID, Fire Chief
Hagerman Fire, ID, Fire Chief
Wendell Fire, ID, Fire Chief
October 5, 2026
Idaho Power Company Page 5 of 6
City Of Riggins, ID, City Clerk
City Of Riggins Fire, ID, Fire Chief
Idaho County, ID, Emergency Manager
Salmon River Rural Fire, ID, Fire Chief
City Of Eden, ID, City Clerk
City Of Hazelton, ID, City Clerk
City Of Jerome, ID, City Clerk
City Of Jerome Fire, ID, Fire Chief
First Segregation Fire Protection District, ID,
Fire Chief
Jerome #1 Fire, ID, Fire Chief
Jerome County, ID, County Clerk
Jerome Rural Fire District, ID, Fire Chief
City Of Leadore, ID, City Clerk
City Of Leadore Fire, ID, Fire Chief
City Of Salmon, ID, City Clerk
Elk Bend Fire Protection District, ID, Fire
Chief
Lemhi County, ID, County Clerk
Lemhi Fire Protection District, ID, Fire Chief
North Fork Fire Protection District, ID, Fire
Chief
City Of Dietrich, ID, City Clerk
City Of Richfield, ID, City Clerk
City Of Shoshone, ID, City Clerk
Dietrich Fire, ID, Fire Chief
Lincoln County, ID, County Clerk
Richfield Fire Protection District, ID, Fire
Chief
Shoshone City & Rural Fire Protection
District, ID, Fire Chief
Shoshone Bannock Tribe, ID, Executive
Director
City Of Acequia, ID, City Clerk
City Of Heyburn, ID, City Clerk
City Of Minidoka, ID, City Clerk
City Of Paul, ID, City Clerk
City Of Rupert, ID, City Clerk
City Of Rupert Fire, ID, Fire Chief
Minidoka County, ID, County Clerk
Minidoka County Fire, ID, Fire Chief
West End Fire, ID, Fire Chief
Oneida County, ID, County Clerk
Oneida County Fire, ID, Fire Chief
Bruneau Fire, ID, Fire Chief
City Of Homedale, ID, City Clerk
City Of Marsing, ID, City Clerk
Grand View Fire, ID, Fire Chief
Homedale Fire, ID, Fire Chief
Marsing Fire, ID, Fire Chief
Murphy-Reynolds-Wilson Fire Protection
District, ID, Fire Chief
Owyhee County, ID, County Clerk
City Of Fruitland, ID, City Clerk
City Of Fruitland Fire, ID, Fire Chief
City Of New Plymouth, ID, City Clerk
City Of Payette, ID, City Clerk
City Of Payette Fire, ID, Fire Chief
New Plymouth Fire, ID, Fire Chief
Payette County, ID, County Clerk
Sand Hollow Fire, ID, Fire Chief
American Falls Fire, ID, Fire Chief
City Of American Falls, ID, City Clerk
City Of Rockland, ID, City Clerk
Eastern Power County Fire Protection
District, ID, Fire Chief
Power County, ID, County Clerk
October 5, 2026
Idaho Power Company Page 6 of 6
Rockland City & Rural Fire Protection
District, ID, Fire Chief
Buhl Fire, ID, Fire Chief
Castleford Fire Protection District, ID, Fire
Chief
City Of Buhl, ID, City Clerk
City Of Castleford, ID, City Clerk
City Of Filer, ID, City Clerk
City Of Filer Fire, ID, Fire Chief
City Of Hansen, ID, City Clerk
City Of Hansen Fire, ID, Fire Chief
City Of Hollister, ID, City Clerk
City Of Kimberly, ID, City Clerk
City Of Murtaugh, ID, City Clerk
City Of Twin Falls, ID, City Clerk
City Of Twin Falls Fire, ID, Fire Chief
Filer Rural Fire Protection District, ID, Fire
Chief
Rock Creek Fire Protection District, ID, Fire
Chief
Salmon Tract Fire Protection District, ID,
Fire Chief
Twin Falls County, ID, County Clerk
Twin Falls Rural Fire Protection District, ID,
Fire Chief
Cascade Rural Fire, ID, Fire Chief
City Of Cascade, ID, City Clerk
City Of Donnelly, ID, City Clerk
City Of McCall, ID, City Clerk
Donnelly Rural Fire Protection District, ID,
Fire Chief
McCall Fire Protection, ID, Fire Chief
Valley County, ID, Emergency Manager
Yellow Pine Fire, ID, Fire Chief
Cambridge Fire, ID, Fire Chief
City Of Cambridge, ID, City Clerk
City Of Midvale, ID, City Clerk
City Of Weiser, ID, City Clerk
Midvale Fire, ID, Fire Chief
Washington County, ID, County Clerk
Weiser Area Fire #1, ID, Fire Chief
Black Canyon Rangeland Fire Protection
Association, Chair
Camus Creek Rangeland Fire Protection
Association, Chair
Henry’s Creek Rangeland Fire Protection
Association, Chair
Mountain Home Rangeland Fire Protection
Association, Chair
Notch Butte Rangeland Fire Protection
Association, Chair
Owyhee Rangeland Fire Protection
Association, Chair
Saylor Creek Rangeland Fire Protection
Association, Chair
Shoshone Basin Rangeland Fire Protection
Association, Chair
Three Creek Rangeland Fire Protection
Association, Chair
Weiser River Rangeland Fire Protection
Association, Chair