20261021Comment_1.pdf

RECEIVED
October 21, 2026
IDAHO PUBLIC
UTILITIES COMMISSION
John A. Richards #10670
J.J. Winters#10327
IDAHO DEPARTMENT OF LANDS
300 N. 61h Street, Ste. 103
Boise, ID 83702
[phone]
[e-mail]
[e-mail]
Attorneys for Idaho Department of Lands
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF NORTHERN LIGHTS, CASE NO. C10-E-26-01
INC'S APPLICATION FOR APPROVAL OF
ITS 2026-2028 WILDFIRE MITIGATION IDAHO DEPARTMENT OF
PLAN LANDS' RESPONSIVE
COMMENTS
Idaho Department of Lands ("IDL") respectfully submits the following responsive
comments in the above-captioned matter pursuant to the Idaho Public Utilities Commission's
("Commission") Order No. 37174 issued on September 18, 2026.
IDL has thoroughly reviewed the documents submitted by Northern Lights Inc. on
October 2,2026,including the Response to IDL Recommendations,Response to Order No. 37174,
Declarations of Kristin Burge and David Sypnieski, and WMP Update Materials. The additional
information was helpful and is appreciated.
When considering the additional details, IDL has a clearer understanding of the risk
modeling completed by Northern Lights and agrees based on the provided details that the wildland
urban interface (WUI) is sufficiently captured in the risk modeling. With this critical detail
captured in the modeling, IDL withdraws its previous recommendation for rejection, and
recommends to the Commission that the plan be approved.
Respectfully submitted this 2 Pt day of October, 2026.
J.J.WINTERS
Attorney for Idaho Department of Lands
IDAHO DEPARTMENT OF LANDS'RESPONSIVE COMMENTS-1

CERTIFICATE OF SERVICE
I hereby certify that on this 2 1'day of October,2026, I caused to be served a true and
correct copy of the foregoing by the method indicated below, and addressed to the following:
Northern Lights, Inc. ❑x Email: [e-mail]
Kristin Burge [e-mail]
Susan P. Weeks
Idaho Public Utilities Commission ❑x Email: [e-mail]
Commission Secretary [e-mail]
P.O. Box 83720 [e-mail]
Boise, ID 83702-0074
Erika Melanson
Kelsea Ross
Deputy Attorney General
11331 W. Chinden Boulevard, Bldg. 8
Suite 201-A (83714)
P.O. Box 83720
Boise, ID 83702-0074
Is/Kayla Dawson
Kayla Dawson, Legal Assistant
IDAHO DEPARTMENT OF LANDS'RESPONSIVE COMMENTS-2