Response to Order No. 37174

NORTHERN LIGHT INC.’S RESPONSE TO RECONSIDERATION ORDER NO. 37174: 2
The supplemental record clarifies two matters central to that determination. First, WUI was
not absent from NLI’s wildfire risk assessment. Athena incorporated SILVIS WUI information,
including WUI Density and WUI Proximity, into the geospatial analysis used for NLI’s 2026
WMP. The supplemental evidence explains how that information was used and makes the WUI
component of the existing analysis expressly identifiable.
Second, infrastructure information is not absent from NLI’s wildfire risk evaluation merely
because facility type, age, and condition are not inputs to Athena’s landscape model. Athena
identifies geographic wildfire risk. NLI separately maintains information concerning its electrical
facilities through its GIS, system records, inspections, testing, maintenance, and operational
experience and uses that information together with Athena’s geographic wildfire risk information
in its wildfire mitigation decisions. The record now includes concrete examples of that process,
including NLI’s use of geographic wildfire risk to select higher risk portions of its Idaho system
for its 2026 drone inspection and to identify portions of the system warranting heightened
protection settings during Red Flag conditions in August 2026.
NLI has also done what the Commission asked it to address on reconsideration. It has
incorporated each of the seven categories of WMP Update Material identified in Order No. 37120
and responded to each of the IDL Recommendations. Where those recommendations concern
information NLI already possesses or practices already in place, NLI has described and
incorporated that information. Where the Commission expressly directed additional system
component, vegetative height, and soil information to “future evaluations of wildfire risk,” NLI
has committed to addressing that information prospectively as its wildfire risk evaluation process
develops. This distinction is consistent with the Commission’s treatment of substantially similar
NORTHERN LIGHT INC.’S RESPONSE TO RECONSIDERATION ORDER NO. 37174: 3
recommendations in the KEC proceeding, of which the Commission took official notice in Order
No. 37174.
The supplemental record therefore does not present a fundamentally different WMP from
the one Staff recommended for approval. Rather, it clarifies the record concerning the WUI
information already incorporated in Athena’s analysis, provides the fuller explanation and
incorporation of existing information requested by the Commission, demonstrates how NLI uses
geographic wildfire risk and infrastructure information together, and addresses additional
enhancements identified for future wildfire risk evaluations. NLI respectfully requests that the
Commission reconsider Order No. 37120 and approve its 2026–2028 WMP as supplemented.
Alternatively, if the Commission determines that further formal incorporation should be made a
condition of approval, NLI requests conditional approval consistent with the procedure employed
in the KEC proceeding.
II. PROCEDURAL BACKGROUND
NLI filed its 2026–2028 WMP on February 2, 2026, and an updated Application seeking
Commission approval on February 19, 2026. Commission Staff and IDL subsequently filed
comments, and NLI filed a reply. On July 31, 2026, the Commission issued Order No. 37120
denying approval of the WMP and identifying WMP Update Materials and IDL Recommendations
for incorporation into future WMP filings. Order No. 37120 at 15–17.
NLI timely petitioned for reconsideration and moved to admit IDL’s comments from the
KEC and Raft River WMP proceedings and for official notice of Orders Nos. 36774 and 37081.
On September 18, 2026, the Commission granted reconsideration and NLI’s motion. Order No.
37174 at 1–5. The Commission permitted NLI to supplement the record with information relevant
to its wildfire risk modeling and the matters identified in Order No. 37120, including the WMP
NORTHERN LIGHT INC.’S RESPONSE TO RECONSIDERATION ORDER NO. 37174: 4
Update Materials and IDL Recommendations. Id. at 4. The Commission also admitted IDL’s
comments in the KEC and Raft River proceedings and took official notice of Orders Nos. 36774
and 37081.
Pursuant to Order No. 37174, NLI submits the supplemental materials and supporting
evidence addressed below.
III. STANDARD ON RECONSIDERATION
Under Idaho Code § 61-626, reconsideration permits the Commission to reconsider
questions previously determined and provides an opportunity to correct mistakes or omissions in
a final order. Washington Water Power Co. v. Kootenai Environmental Alliance, 99 Idaho 875, 879,
591 P.2d 122, 126 (1979). Order No. 37174 at 2–3. The Commission has granted reconsideration
and expressly permitted NLI to supplement the record concerning the wildfire risk modeling issues
identified in Order No. 37120 and whether the 2026 WMP could be updated with the WMP Update
Materials and IDL Recommendations. Order No. 37174 at 3–4. The Commission therefore
considers NLI’s 2026 WMP on reconsideration in light of the supplemental record authorized by
Order No. 37174.
IV. ARGUMENT
A. The WSCA and the Commission’s Guidelines Establish the Standards Governing
Approval of NLI’s WMP.

The Wildfire Standard of Care Act (“WSCA”) requires a wildfire mitigation plan to use
“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.” I.C. § 61-1803(3). The plan must identify means of mitigating wildfire risk
that reflect “a reasonable balancing of mitigation costs with the resulting reduction of wildfire
risk.” Id. The Legislature thus made the appropriate scope of a WMP dependent upon the utility,
NORTHERN LIGHT INC.’S RESPONSE TO RECONSIDERATION ORDER NO. 37174: 5
its operations, the nature of its wildfire risk, and the reasonable relationship between mitigation
measures and their costs.
Idaho Code section 61-1803(3)(a)–(g) identifies the subjects each WMP must address,
including geographic areas of heightened wildfire risk; preventative actions and programs; public
outreach and governmental coordination; line design; weather monitoring; and standards,
procedures, and schedules for infrastructure inspection, de-energization, and vegetation
management. The statute addresses wildfire risk through multiple related components; it does not
prescribe a single analytical model for evaluating every aspect of wildfire risk.
The Commission’s review is bounded by the authority delegated by the Legislature. “The
Idaho Public Utilities Commission has no authority other than that granted to it by the legislature.”
Idaho State Homebuilders v. Washington Water Power, 107 Idaho 415, 418, 690 P.2d 350, 353
(1984). Its jurisdiction is limited, and nothing is presumed in favor of that jurisdiction. United
States v. Utah Power & Light Co., 98 Idaho 665, 667, 570 P.2d 1353, 1355 (1977). Consistent with
those limits, § 61-1804(1) directs the Commission to ensure that a WMP meets the requirements
of § 61-1803 and to consider the plan’s consistency with public health, safety, and welfare; its
feasibility and cost; and the degree to which it adequately minimizes wildfire risk and provides for
response to wildfires that occur. I.C. § 61-1804(1). Those considerations guide the Commission’s
evaluation of a WMP; they do not confer independent authority to prescribe substantive
requirements or particular analytical methodologies beyond the authority delegated by the
Legislature.
The Commission’s WMP Guidelines provide additional direction within the statutory
framework. For geographical risk assessment, the Guidelines require a description of “the wildfire
risk assessment or model used to guide wildfire mitigation activities.” Order No. 36774, Ex. B at
NORTHERN LIGHT INC.’S RESPONSE TO RECONSIDERATION ORDER NO. 37174: 6
2. The assessment should identify areas of elevated fire risk considering factors “such as
vegetation, weather, topography, historical fire occurrence, structure density, and asset location,”
and should include a map identifying differing levels of risk and an explanation of what determines
those levels. Id. Neither the statute nor the Guidelines prescribe a particular wildfire risk model or
require all information relevant to wildfire mitigation to be incorporated as inputs into a single
model. Indeed, Order No. 37120 recognized that “the WSCA does not require a specific wildfire
risk model or prescribe a particular analytical framework.” Order No. 37120 at 14.
The Guidelines separately address infrastructure inspection and maintenance. They require
a summary of programs for inspecting infrastructure, assets, and facilities within heightened
wildfire risk areas to identify and correct conditions that could contribute to wildfire ignition,
including inspection standards and schedules, baseline and enhanced inspection methods, and
procedures for classifying, prioritizing, and correcting defects. Order No. 36774, Ex. B at 6. Thus,
although geographic wildfire risk and infrastructure information may be used together in wildfire
mitigation planning, the Guidelines treat geographic risk assessment and infrastructure inspection
and maintenance as distinct components of a WMP.
The WSCA likewise defines the role of the State Forester. Although I.C. § 61-1804(3)
directs the Commission to consult with the State Forester and other identified entities, it affords a
presumption of reasonableness and appropriateness to State Forester recommendations only
“[w]ith respect to elements of the plan that relate to vegetation management, reduction of wildfire
fuels, and other duties of the state forester under title 38, Idaho Code.” I.C. § 61-1804(3). Order
No. 36774 similarly recognized that “the relevance and persuasive force of IDL’s comments and
recommendations may vary from case to case.” Order No. 36774 at 16. The statutory presumption
NORTHERN LIGHT INC.’S RESPONSE TO RECONSIDERATION ORDER NO. 37174: 7
therefore does not transform every IDL recommendation into an additional requirement for
approval.
Finally, the WSCA requires approved WMPs to be reviewed and updated annually. I.C. §
61-1803(4). The Commission likewise recognized that wildfire mitigation planning “is an evolving
process” and that future WMPs will develop as utilities gain operational experience, incorporate
new technologies, collect additional data, and evaluate mitigation effectiveness. Order No. 37120
at 14. The existence of additional data or analytical refinements that may improve NLI’s future
wildfire planning therefore does not, by itself, establish that its present WMP fails the governing
approval standards.
The question on reconsideration is whether NLI’s 2026 WMP, considered with the
supplemental record permitted by Order No. 37174, satisfies the WSCA, the Commission’s
Guidelines, and the considerations prescribed by § 61-1804. As demonstrated below, it does.
B. The Supplemental Record Confirms that WUI Was Included in NLI’s Geographic
Wildfire Risk Assessment.

Order No. 37120 found that NLI’s wildfire risk assessment required further development
because, among other things, it did not include identifiable wildland-urban interface (“WUI”) data.
Order No. 37120 at 14. On reconsideration, the Commission similarly asked NLI to address why
identifiable WUI “was not included in the modeling process.” Order No. 37174 at 3–4. The
supplemental record establishes that WUI was, in fact, included in the Athena analysis used by
NLI.
That conclusion is consistent with the record before Order No. 37120 was issued. In
response to Staff Production Request No. 5, NLI identified the University of Wisconsin SILVIS
Lab as a data source used in Athena’s analysis and specifically identified SILVIS WUI,
WUI_Density, and WUI_Proximity among the data used by Athena. Staff expressly considered
NORTHERN LIGHT INC.’S RESPONSE TO RECONSIDERATION ORDER NO. 37174: 8
that discovery response in evaluating NLI’s geographic risk assessment and concluded that NLI’s
“modeling approach to assess wildfire risk in its service territory . . . has met the requirements of
Idaho Code § 61-1803(3)(a) and the Guidelines.” Staff Comments at 8. Although Staff
recommended a fuller narrative describing Athena’s modeling process and inputs in future WMP
filings, it did so because “most of the information needed to meet the requirements was provided
in discovery.” Id. at 8–9.
The supplemental evidence now provides the fuller technical explanation. Athena founder
and CEO David Sypnieski leads the development of Athena’s geospatial profile modeling and has
been involved in developing every version of its WUI Block Landscape Wildfire Risk model,
including the version used for NLI. Sypnieski Decl. ¶¶ 1, 6. Sypnieski confirms that WUI
information was included in the Athena analysis provided to NLI. Id. ¶ 13. Athena used WUI
information from the University of Wisconsin-Madison SILVIS Lab, including SILVIS WUI
boundaries and the component attributes WUI Density and WUI Proximity. Id. ¶¶ 13–15. WUI
Density reflects housing density at the census block level, while WUI Proximity reflects housing
proximity to undeveloped wildland vegetation. Id. ¶ 15. Those attributes are assigned values used
to create WUI Density and WUI Proximity scores, which combine into a WUI Score used in
Athena’s geospatial analysis. Id. ¶ 16. Based upon his personal knowledge of the model used to
produce NLI’s wildfire risk information, Sypnieski confirms that “it would not be technically
accurate to state that identifiable WUI information was absent from Athena’s analysis.” Id. ¶ 17.
NLI has incorporated that additional explanation into its WMP Update Materials. Those
materials describe the Conditional Risk and Probability Risk components of Athena’s Landscape
Wildfire Risk analysis and expressly identify the SILVIS WUI information, WUI Density, WUI
Proximity, and resulting WUI Score used in Athena’s analysis. The Update Materials therefore
NORTHERN LIGHT INC.’S RESPONSE TO RECONSIDERATION ORDER NO. 37174: 9
provide the fuller narrative Staff recommended and make the WUI component of NLI’s existing
geographic risk assessment expressly identifiable.
Importantly, NLI has not added WUI to its wildfire risk assessment on reconsideration. The
supplemental record explains the WUI information that was already incorporated in the Athena
analysis used for the 2026 WMP. That distinction directly answers the premise of Order No.
37174’s inquiry as to why identifiable WUI “was not included in the modeling process.” Order
No. 37174 at 3–4. It was included. The supplemental record now explains how it was included and
resolves the factual concern concerning WUI identified in Orders Nos. 37120 and 37174.
C. The WSCA and Guidelines Do Not Require Infrastructure Type and Condition to Be
Inputs to a Single Geographic Wildfire Risk Model.

Order No. 37120 found that NLI’s risk assessment must include infrastructure data and
accepted IDL’s recommendation that information concerning NLI’s infrastructure be included in
the wildfire risk model. Order No. 37120 at 14. Infrastructure information is relevant to wildfire
mitigation. The issue, however, is whether the WSCA or the Commission’s Guidelines require
infrastructure type and condition to be inputs to the geographic wildfire risk model itself. They do
not.
The Guidelines require the geographic risk assessment to identify areas of elevated fire risk
considering factors “such as vegetation, weather, topography, historical fire occurrence, structure
density, and asset location.” Order No. 36774, Ex. B at 2. They identify asset location as a
consideration; they do not require infrastructure type, age, or condition to be inputs to the
geographic risk model. Instead, the Guidelines separately address infrastructure inspection and
maintenance, requiring utilities to describe inspection standards and schedules, inspection
methods, and the manner in which identified defects are classified, prioritized, and corrected. Id.,
NORTHERN LIGHT INC.’S RESPONSE TO RECONSIDERATION ORDER NO. 37174: 10
Ex. B at 6. Nothing in the Guidelines requires the information developed through those processes
to be incorporated into the geographic risk model as model inputs.
Staff’s review of NLI’s WMP reflects the same distinction. Staff concluded that Athena’s
approach to geographic wildfire risk satisfied the Guidelines, while identifying infrastructure
ignition risk as a limitation of the modeling process. Staff Comments at 9–10. Staff suggested that,
as NLI and Athena continued to refine the modeling process, NLI “consider adding infrastructure
ignition risk as an input into the risk model.” Id. at 10. Staff thus treated infrastructure ignition
modeling as a potential refinement, not as a requirement the existing geographic risk assessment
failed to satisfy.
The supplemental evidence explains why the distinction matters. Athena’s analysis is a
landscape-based geographic wildfire risk assessment designed to identify geographic areas of
greater wildfire risk without regard to the particular source of an ignition. Sypnieski Decl. ¶¶ 9,
21. Athena did not incorporate the type, age, or physical condition of individual NLI assets because
those characteristics are not necessary for the model to perform that geographic function. Id. ¶¶
18, 21. Infrastructure characteristics address a different question from the one Athena’s landscape
model was designed to answer. Id. ¶ 20.
That does not make infrastructure information unimportant. Electrical equipment is a
potential ignition source, and a utility can compare geographic wildfire risk with the location and
characteristics of its infrastructure to inform wildfire mitigation planning. Sypnieski Decl. ¶ 22.
But, as Sypnieski explains, that is a subsequent use of the geographic risk information, “not an
input needed to determine the underlying landscape wildfire risk.” Id.
Order No. 37120 itself recognized that “the WSCA does not require a specific wildfire risk
model or prescribe a particular analytical framework.” Order No. 37120 at 14. Neither the WSCA
NORTHERN LIGHT INC.’S RESPONSE TO RECONSIDERATION ORDER NO. 37174: 11
nor the Guidelines requires NLI to incorporate infrastructure type, age, or condition into a
particular model architecture. The relevant question is whether NLI adequately considers its
infrastructure information together with geographic wildfire risk in its wildfire mitigation planning
and activities. As discussed next, the supplemental record demonstrates that it does.
D. NLI Uses Geographic Wildfire Risk and Infrastructure Information Together in Its
Wildfire Mitigation Planning and Operations.

NLI maintains and uses information concerning the type, age, condition, and performance
of its electrical facilities independently of Athena’s geographic wildfire risk model. NLI maps its
overhead and underground facilities in its GIS; its system records identify facility type and, for the
majority of its facilities, age; and its inspection, testing, maintenance, and operational records
provide additional information concerning facility condition and performance. Burge Decl. ¶¶ 6–
7.
NLI uses this information in decisions concerning maintenance, repair, replacement,
system improvements, and capital projects. Id. ¶ 8. Those decisions consider reliability, asset
condition, load growth, cost, and wildfire risk reduction. Id. That is consistent with NLI’s pre-
reconsideration discovery response, which explained that its risk-informed planning framework
considers “system reliability, asset condition, load growth, and wildfire risk reduction” and
prioritizes, among other things, replacement of aging infrastructure and reduction of operational
and wildfire-related risk. Response to Staff Production Request No. 2.
NLI also uses its infrastructure information together with Athena’s geographic wildfire risk
information. NLI overlays its mapped electrical facilities with the Athena information, allowing it
to identify facilities located within areas of differing geographic wildfire risk and to consider that
risk together with the age, condition, and other information it maintains concerning those facilities.
Burge Decl. ¶¶ 9–10. The WMP Update Materials expressly describe this process and explain that
NORTHERN LIGHT INC.’S RESPONSE TO RECONSIDERATION ORDER NO. 37174: 12
NLI considers geographic wildfire risk together with its system and asset information in its
planning, inspection, maintenance, mitigation, and operational processes. WMP Update Materials,
Item 2.
NLI’s 2026 drone inspection provides a concrete example. NLI used Athena’s geographic
wildfire risk information to identify higher-risk portions of its Idaho system for drone inspection.
The completed inspection provided asset-specific information concerning the condition of
facilities within those areas and identified conditions requiring review or corrective action. NLI
incorporated that information into its inspection-tracking GIS and uses the inspection results,
together with geographic wildfire risk information, to evaluate and prioritize corrective work.
Burge Decl. ¶¶ 11–14.
The supplemental record therefore demonstrates that geographic wildfire risk and
infrastructure risk are not evaluated in isolation. Athena identifies areas of differing geographic
wildfire risk; NLI’s GIS and its inspection, testing, maintenance, and operational processes provide
information concerning the electrical facilities located in those areas; and NLI considers that
information together in its wildfire mitigation decisions. The fact that those functions are not
performed within a single model does not prevent NLI from integrating them in its wildfire
mitigation planning and operations.
E. NLI Has Incorporated the WMP Update Material Identified in Order No. 37120.

Order No. 37120 separately addressed information NLI provided during Staff’s review
concerning funding, wildfire risk mitigation benefits, risk scores, project details, the weather
station network, and DSAT. The Commission found that this supplemental information “was
consistent with the requirements of the WSCA and the Guidelines,” but concluded that it should
be included in NLI’s WMP to more comprehensively describe NLI’s wildfire mitigation measures.
NORTHERN LIGHT INC.’S RESPONSE TO RECONSIDERATION ORDER NO. 37174: 13
Order No. 37120 at 15. The Commission found that supplemental information NLI provided
during Staff’s review concerning funding, wildfire risk mitigation benefits, risk scores, project
details, the weather station network, and DSAT was ‘consistent with the requirements of the WSCA
and the Guidelines,’ but concluded that the information should be included in the WMP. Order No.
37120 at 15. The Commission then identified seven categories of information, including an
expanded narrative concerning Athena’s modeling process and inputs, as ‘WMP Update Material’
for inclusion in future WMP filings. Id. at 15–16.”
NLI has now incorporated each of those categories into its 2026 WMP through the WMP
Update Materials submitted on reconsideration. The Update Materials address: (1) funding
alternatives and sources; (2) Athena’s wildfire risk modeling process and inputs; (3) the wildfire
risk reduction and qualitative benefits of NLI’s mitigation activities; (4) the derivation and
presentation of wildfire risk scores; (5) project targets, costs, benefits, and alternatives considered;
(6) the status, areas of focus, costs, targets, and evaluation of NLI’s weather station program; and
(7) the operation and outputs of NLI’s Daily Situational Awareness Tool. WMP Update Materials,
Items 1–7.
This information is not being presented for the first time on reconsideration. Much of it
was developed during Staff’s review, and Staff recommended approval of NLI’s WMP while
recommending that these same categories of information be included in future WMP filings. Staff
Comments at 23–24. The WMP Update Materials incorporate that information into NLI’s 2026
WMP and, where appropriate, update and further develop it as contemplated by Order No. 37120.
The concern identified in Order No. 37120 regarding incorporation of the WMP Update
Material is therefore resolved. The Commission has already determined that the underlying
supplemental information was consistent with the WSCA and Guidelines, and NLI has now
NORTHERN LIGHT INC.’S RESPONSE TO RECONSIDERATION ORDER NO. 37174: 14
incorporated and further developed each category of WMP Update Material identified by the
Commission.
F. NLI Has Addressed the IDL Recommendations Consistent with Their Terms and the
Continuing Development of Its WMP.

Order No. 37120 identified six categories of IDL recommendations for incorporation into
NLI’s future WMP filings. Those recommendations do not all operate in the same manner. IDL’s
principal concern with the 2026 WMP was its conclusion that NLI’s risk modeling did not include
clearly identifiable WUI or comparable information. Order No. 37120 at 11–12. IDL separately
recommended that, “[f]or the Company’s future assessments of wildfire risk,” NLI include
information concerning system components, vegetative height, and soil types. Id. at 12. The
Commission maintained that distinction, directing NLI to include those additional data in “future
evaluations of wildfire risk.” Id. at 16.
NLI has addressed IDL’s present concern regarding the description of its risk modeling. As
discussed above, Athena already incorporated WUI information into its analysis. The WMP
Update Materials now expressly identify the SILVIS WUI information used by Athena, including
WUI Density and WUI Proximity, and explain how those values contribute to the WUI Score used
in Athena’s geospatial analysis. The Update Materials also provide an additional description of
Athena’s Conditional Risk and Probability Risk analyses and the derivation of the resulting Athena
Risk Score. WMP Update Materials, Items 2, 4. NLI has therefore supplied the additional modeling
description requested by IDL without adding WUI to the model after the fact or replacing the
geographic risk assessment used for its 2026 WMP.
NLI has also addressed the recommendation concerning system component information.
As demonstrated above, NLI maintains information on facility type, age, condition, and
performance and uses it, together with Athena’s geographic wildfire risk information, in its
NORTHERN LIGHT INC.’S RESPONSE TO RECONSIDERATION ORDER NO. 37174: 15
planning and operations. The 2026 drone inspection and NLI’s use of geographic wildfire risk
information during August 2026 Red Flag conditions provide concrete examples of those processes
operating together. WMP Update Materials, Items 2, 3. NLI will continue to include system
component information in future wildfire risk evaluations and describe that use in future WMP
filings. Response to IDL Recommendations § 2(a).
The remaining data identified in Recommendation 2 are prospective by their terms. NLI
will include available vegetative height information relevant to locations where surrounding tree
canopy is taller than adjacent above-ground electrical facilities and available soil layer information
relevant to vegetation-related risks in future wildfire risk evaluations. NLI will evaluate the
appropriate use of those data as its wildfire risk evaluation process evolves. Response to IDL
Recommendations §§ 2(b)–(c). These commitments respond directly to the Commission’s
direction concerning “future evaluations of wildfire risk” without converting prospective
enhancements into requirements to reconstruct Athena’s existing landscape model before the 2026
WMP may be approved.
NLI has likewise responded to IDL’s remaining operational recommendations. Its
Response to IDL Recommendations describes NLI’s existing coordination with county emergency
management agencies and its continued coordination with Idaho counties; addresses compensation
for live marketable timber identified for removal from timber company land adjacent to NLI’s
rights-of-way; provides additional detail concerning vegetation management in areas of elevated
wildfire risk; and identifies the metrics and other information NLI will use to evaluate
implementation and effectiveness of its WMP. Response to IDL Recommendations §§ 3–6.
NLI’s response to the IDL Recommendations does not concede that every IDL
recommendation is entitled to the statutory presumption afforded recommendations of the State
NORTHERN LIGHT INC.’S RESPONSE TO RECONSIDERATION ORDER NO. 37174: 16
Forester. I.C. § 61-1804(3) limits that presumption to recommendations concerning “vegetation
management, reduction of wildfire fuels, and other duties of the state forester under title 38, Idaho
Code.” As discussed above, Order No. 36774 likewise recognized that “the relevance and
persuasive force of IDL’s comments and recommendations may vary from case to case.” Order
No. 36774 at 16. NLI has addressed the recommendations identified by the Commission, but doing
so does not enlarge the statutory scope of the State Forester presumption.
The supplemental record therefore addresses the IDL Recommendations without
converting recommendations expressly directed to future development into present deficiencies.
That treatment follows the terms of Order No. 37120 and the Commission’s recognition that
wildfire mitigation planning “is an evolving process” and that subsequent WMPs will develop as
utilities gain operational experience, incorporate new technologies, collect additional data, and
evaluate the effectiveness of mitigation activities. Order No. 37120 at 14.
G. The Commission’s Treatment of KEC Supports Approval of NLI’s WMP as
Supplemented.

The Commission’s treatment of Kootenai Electric Cooperative’s (“KEC”) 2026 WMP
provides a useful comparison. In Order No. 37174, the Commission admitted IDL’s comments
concerning KEC into the record in this proceeding and took official notice of Order No. 37081,
which conditionally approved KEC’s WMP. Order No. 37174 at 4–5. The comparison is
particularly relevant because IDL raised substantially similar concerns regarding future wildfire
risk evaluation in the KEC proceeding.
In Order No. 37081, the Commission directed KEC to include information concerning its
electrical system in its “future modeling” and, “[f]or the Company’s future assessments of wildfire
risk,” to include data concerning system components, vegetation taller than surrounding
infrastructure, and soil types. Order No. 37081 at 14. Those recommendations closely parallel the
NORTHERN LIGHT INC.’S RESPONSE TO RECONSIDERATION ORDER NO. 37174: 17
recommendations made to NLI concerning system component, vegetative height, and soil layer
information. The Commission did not require KEC to complete a new wildfire risk model
incorporating those additional data before approving its 2026 WMP.
Instead, the Commission conditionally approved KEC’s 2026 WMP and required KEC,
within fourteen days, to incorporate specified “2026 WMP Update Materials.” Id. KEC complied
by filing an amended WMP incorporating the information required by Order No. 37081, much of
which had been developed through Staff discovery and meetings. The Commission subsequently
found that KEC had included the required information, satisfied the condition for approval, and
approved the amended WMP. Order No. 37118 at 1–2.
NLI has now followed a substantively comparable course. It has incorporated the seven
categories of WMP Update Material identified in Order No. 37120, including information
developed during Staff’s review concerning its risk modeling methodology, wildfire mitigation
benefits, risk scores, project details, weather station program, and DSAT. NLI has also addressed
the IDL Recommendations, including the additional information identified for future wildfire risk
evaluations. And, unlike a prospective modification to the risk model, the supplemental record
establishes that WUI information was already incorporated into the Athena analysis used for NLI’s
2026 WMP.
The comparison does not require identical WMPs or a uniform wildfire risk model. The
WSCA expressly requires each WMP to be “reflective of and commensurate with the size and
complexity of the electric corporation’s operations and of the nature of the fire risk.” I.C. § 61-
1803(3). But the distinction the Commission drew in the KEC proceeding is directly relevant here:
information available to supplement the current WMP was incorporated into that plan, while
additional system component, vegetative height, and soil data were directed to future modeling
NORTHERN LIGHT INC.’S RESPONSE TO RECONSIDERATION ORDER NO. 37174: 18
and wildfire risk assessments. Order No. 37081 at 14. The same distinction is appropriate for the
materially similar recommendations made to NLI.
The procedural treatment of KEC also demonstrates that conditional approval, rather than
denial, is an available means of addressing information the Commission determines should be
incorporated into a WMP. Here, however, NLI has already done what KEC was afforded fourteen
days following conditional approval to accomplish: NLI has incorporated the WMP Update
Materials identified by the Commission and has addressed the IDL Recommendations. The
supplemented record therefore supports approval of NLI’s 2026 WMP.
H. The Supplemental Record Supports Approval of NLI’s 2026 WMP.

The supplemental record resolves the concerns that led to denial of NLI’s 2026 WMP. Staff
concluded that NLI’s geographic wildfire risk assessment satisfied Idaho Code § 61-1803(3)(a)
and the Commission’s Guidelines and recommended approval. Staff Comments at 8, 23–24. The
supplemental record now clarifies that WUI was already incorporated in Athena’s analysis,
explains how NLI uses geographic wildfire risk together with infrastructure information, and
incorporates the WMP Update Material identified in Order No. 37120.
NLI has also addressed each of the IDL Recommendations. The recommendations
concerning system component, vegetative height, and soil information that Order No. 37120
expressly directed to “future evaluations of wildfire risk” will be addressed prospectively. Order
No. 37120 at 16. That treatment is consistent with the Commission’s treatment of materially
similar recommendations in the KEC proceeding, where those matters were directed to future
modeling and wildfire risk assessments rather than made conditions precedent to approval of
KEC’s 2026 WMP. Order No. 37081 at 14.
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Accordingly, NLI respectfully requests that the Commission reconsider Order No. 37120
and approve its 2026–2028 WMP as supplemented. Alternatively, if the Commission determines
that further formal incorporation of information is necessary, NLI requests conditional approval
consistent with the procedure employed in the KEC proceeding.
I think this is considerably better. It gives H one job: tie the established propositions to
the requested disposition. It also eliminates the last phrase about “prospective enhancements
addressed through future w

DATED this 2nd day of October, 2026.
JAMES, VERNON & WEEKS, P.A.

/s/ Susan P. Weeks
SUSAN P. WEEKS
Attorneys for Northern Lights, Inc.

CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the foregoing was served by email on the
following persons this 2nd day of October, 2026:

Idaho Public Utility Commission Staff
Erika K. Melanson, Deputy Attorney General
Kelsea E. Ross, Deputy Attorney General
EMAIL: [e-mail]

/s/ Susan P. Weeks
SUSAN P. WEEKS