20210305IPC to Staff 1-13.pdf

LISA D. NORDSTROM
Lead Counsel
[e-mail]

March 5, 2021

VIA ELECTRONIC FILING

Jan Noriyuki, Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg 8,
Suite 201-A (83714)
PO Box 83720
Boise, Idaho 83720-0074

Re: Case No. IPC-E-21-02
In the Matter of Idaho Power Company’s Application for an Accounting Order
Authorizing the Deferral of Incremental Wildfire Mitigation and Insurance
Costs

Dear Ms. Noriyuki:

Attached for electronic filing, pursuant to Order No. 34602, is Idaho Power
Company’s Response to the First Production Request of the Commission Staff, Nos. 1
through 13.

If you have any questions about the attached document, please do not hesitate to
contact me.

Very truly yours,

Lisa D. Nordstrom
LDN:slb
Attachment
RECEIVED
2021March 5, PM 1:38
IDAHO PUBLIC
UTILITIES COMMISSION
IDAHO POWER COMPANY’S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 1
LISA D. NORDSTROM (ISB No. 5733)
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
[e-mail]

Attorney for Idaho Power Company

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF IDAHO POWER
COMPANY’S APPLICATION FOR AN
ACCOUNTING ORDER AUTHORIZING
THE DEFERRAL OF INCREMENTAL
WILDFIRE MITIGATION AND INSURANCE
COSTS
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CASE NO. IPC-E-21-02

IDAHO POWER COMPANY’S
RESPONSE TO THE FIRST
PRODUCTION REQUEST OF
THE COMMISSION STAFF

COMES NOW, Idaho Power Company (“Idaho Power” or “Company”), and in
response to the First Production Request of the Commission Staff to Idaho Power
Company dated February 12, 2021, herewith submits the following information:

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 2
REQUEST NO. 1: Please provide the name and company of the external
consultant the Company contracted with to produce the Wildfire Risk Map and Fire
Protection Index. Were the external consulting expenses included in the O&M costs
shown in Table No. 2, page 19 of the Application?
RESPONSE TO REQUEST NO. 1: Idaho Power hired Chris W. Lautenberger,
PhD, PE of REAX Engineering to aid the Company in developing the Wildfire Risk Map
and Fire Protection Index. This work was performed in 2019 and finalized in 2020 so
these expenses were not included in Table No. 2, page 19 of the Application.
The response to the request is sponsored by Doug Dockter, T&D Engineering &
Reliability Senior Manager, Idaho Power.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 3

REQUEST NO. 2: Please provide workpapers detailing how the Company
calculated the projected 5-year $385,000 Situational Awareness expenses discussed in
the Application at page 20.
RESPONSE TO REQUEST NO. 2: The Company’s Situational Awareness O&M
category includes two line items: personnel costs and the cost of cameras.
The first Situational Awareness line item, the personnel amount totaling $285,000
for the Fire Potential Index (“FPI”) will cover the labor costs for five years for an
additional Atmospheric Scientist. Please see the Excel spreadsheet associated with
this response for a calculation of the labor costs.
The second Situational Awareness line item, camera expenses, totals $100,000.
This amount reflects Idaho Power’s estimated allocable share of costs of coordinating
with other governmental agencies such as Bureau of Land Management (“BLM”) and/or
other stakeholders for visual monitoring and related activities.
The response to the request is sponsored by Doug Dockter, T&D Engineering &
Reliability Senior Manager, Idaho Power.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 4
REQUEST NO. 3: Did the Company calculate different risk values for each risk
zone to determine potential infrastructure losses, claims, and replacement costs? If so,
please explain the analysis for the risk values and provide the analysis and
documentation supporting the conclusions.
RESPONSE TO REQUEST NO. 3: Idaho Power’s consultant identified
geographic risk tiers using the methodology and risk calculations described in Idaho
Power’s Wildfire Mitigation Plan (“WMP”). Potential infrastructure losses, claims, and
replacement costs were not factored into the risk zones; only the number of man-made
structures was used in determining the “Consequence” term as indicated in Section 9,
page 5 of the WMP.
The response to the request is sponsored by Doug Dockter, T&D Engineering &
Reliability Senior Manager, Idaho Power.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 5
REQUEST NO. 4: Please provide the risk analysis or data demonstrating the
need for a 3-year vegetation management cycle in low-risk areas. Please explain how
the analysis or data supports the Company’s decision.
RESPONSE TO REQUEST NO. 4: Idaho Power’s wildfire mitigation efforts are
intended to reduce risk associated with the operation of its more than 310 substations,
4,800 miles of overhead transmission lines, and 19,300 miles of overhead distribution
lines. It is important to understand that adequate vegetation management is not limited
to the Company’s identified Red and Yellow Risk Zones. Vegetation management risk
exists anywhere vegetation is in proximity to Idaho Power’s lines and facilities, whether
in an elevated risk zone or not.
To determine the best vegetation management cycle, Idaho Power weighed
costs, risks, and observed trends and behavior of vegetation and vegetation
management across its entire system. In particular, the Company considered the
escalating costs associated with off-cycle or out-of-cycle reactive pruning projects (so-
called “Specials” that are notably distinct from scheduled mid-cycle pruning), the need
for which increase with longer vegetation management cycles. Over the past 15 years,
the Company observed that the average number of Specials more than tripled (226
percent increase). These projects include pruning “cycle busters” (trees that regrow too
rapidly to maintain minimum clearance throughout the duration of the pruning cycle).
Further, the average annual number of crew hours to perform this work is now almost
six times what it was 15 years ago (481 percent increase).

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 6
In the Company’s estimation, an ideal vegetation management cycle is one that
accomplishes proactive annual clearing while minimizing the number of Specials and
the amount of mid-cycle pruning. To that end, a three-year vegetation management
cycle for Idaho Power can be employed and followed without using mid-cycle pruning in
lower-risk areas. In comparison, a vegetation management cycle of greater than three
years requires consistent mid-cycle pruning and, more notably, increases the need for
Specials by a factor of 2.67 times. And, as the resource demand for Specials
increases, fewer resources are available for regular cycle pruning. This situation
creates a downward spiral making it more and more challenging to meet the pruning
needs of the entire system, not just the elevated wildfire risk areas.
Idaho Power evaluated other options and timelines by comparing the costs
associated with two-, three-, and four-year vegetation management cycles. As the table
below shows, a three-year cycle reasonably balances costs with the need for mid-
cycle/Special pruning. While a two-year cycle would not require any Special pruning,
the annual costs are significantly higher than for three- and four-year cycles.
Table 1 – Vegetation Management Cycle Cost Analysis
Length of Pruning
Cycle
Special/Cycle Buster
Pruning Hours
Total Cycle
Pruning Cost
Average Annual
Pruning Cost
2 Years 0 $38,498,290 $19,249,145
3 Years 38,395 $50,721,498 $16,907,166
4 Years 102,388 $64,460,575 $16,115,144

In contrast, a four-year cycle requires more than 100,000 Special pruning hours,
each hour representing increased risk of vegetation making contact with Idaho Power
equipment and having the potential to result in injuries to the public, ignite fires, damage
Idaho Power equipment and/or increase the number of power outages. The reduction
in risk associated with more consistent primary pruning and with fewer off-cycle pruning
IDAHO POWER COMPANY’S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 7
hours, in Idaho Power’s assessment, outweighs the additional estimated expense
associated with a three-year cycle.
The response to this request is sponsored by Brent Van Patten, Engineering
Leader, Idaho Power.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 8
REQUEST NO. 5: Has the Company applied for a special FAA waiver for
authorization to fly UAVs beyond visual line of site? If so, please explain the status of
the waiver. If the Company has not applied for a waiver, please explain why.
RESPONSE TO REQUEST NO. 5: No, Idaho Power has not yet applied for a
special Federal Aviation Administration (“FAA”) waiver for beyond visual line of sight
(“BVLOS”) unmanned aerial vehicle (“UAV”) operations. Currently, development of an
application for this waiver is a lengthy and exhaustive process (with applications usually
exceeding 500 pages) because the FAA has not set clear guidance, expectations, or
requirements for the conditions of approval.
However, the Company applied for—and received approval for—a so-called
daylight waiver to conduct nighttime operations of UAVs. This interim waiver was an
important procedural and educational step toward developing a full BVLOS waiver
application.
Simultaneously, the Company has been involved with peer utilities and various
industry trade associations—the Edison Electric Institute (“EEI”) and Electric Power
Research Institute—to study and exchange knowledge about the use of UAVs for
enhanced situational awareness (in particular, for wildfire mitigation, during wildfire
events, and for emergency storm response). Further, EEI and its member companies,
including Idaho Power, have been working with the FAA to streamline the waiver
process for BVLOS operations by utilities. As a first step, EEI has prioritized getting the
FAA to grant emergency approval for BVLOS operations such that utilities would not
need to have pre-authorization for flight operations during emergency events.
Secondarily, EEI and its member companies are focused on working with the FAA to
IDAHO POWER COMPANY’S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 9
streamline the waiver application and approval process for utility UAV use near utility
infrastructure.
The response to this request is sponsored by Mike Spengler, Power Quality
Technical Advisor, Idaho Power.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 10
REQUEST NO. 6: Has the Company considered sensor technology for remote
fire monitoring? If so, please explain that consideration.
RESPONSE TO REQUEST NO. 6: Idaho Power assumes the sensor
technology for remote fire monitoring in this request refers to sensors that can identify
smoke and heat that some utilities in California are currently using. Idaho Power has
not considered the use of these types of sensors at this time. The WMP efforts to-date
have been focused on the prevention of wildfires and prevention of Idaho Power
equipment damage (installing fire-resistant mesh pole wraps), not the detection of
wildfires. These and other tools may be considered for future implementation during
annual reviews of the WMP.
The response to the request is sponsored by Doug Dockter, T&D Engineering &
Reliability Senior Manager, Idaho Power.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 11
REQUEST NO. 7: Please provide the cost/benefit analysis or business case for
the pole mesh wraps. Please include all costs and benefits the Company included and
provide any performance data used to support the analysis.
RESPONSE TO REQUEST NO. 7: The mesh wraps Idaho Power specifies are
manufactured by Genics Inc. (“Genics”). Idaho Power based the costs of the mesh pole
wraps on historical per-pole installation costs obtained in 2015 from the installation work
performed on the Soda Fire on Idaho Power’s Gem – Jordan Valley 69 kV line.
Installation costs are $125 per pole. A video showing the installation process of the
Genics mesh wrap is at the following link: https://youtu.be/DeI7zbDAI6w.
The table below provides the cost/benefit analysis of mesh wraps, based on wrap
installation cost per pole compared to pole/structure replacement estimates for common
voltage classes and structure types Idaho Power has in Red Risk Zones. Considering
the difference in mesh wrap installation costs vs. structure replacement costs, Idaho
Power considered this solution to be a cost-effective method of proactive fire mitigation.
Structure Type and Voltage
Class
Mesh Wrap Installation
Cost (O&M)
Estimated Structure
Replacement Cost (Capital)
69 kV Single-pole Structure $125 $7,300
138 kV Single-pole Structure $125 $15,000
138 kV H-frame Structure $250 $25,000
230 kV H-frame Structure $250 $30,000

The benefits of installing the mesh pole wraps include the cost savings of
replacing the structures, quicker customer and/or system re-energization and realizing
full life of the installed asset. The Genics mesh wraps have a lifetime of 10 years or one
fire. Although these mesh wraps have been installed on some structures on the Gem–
Jordan Valley 69 kV line (as mentioned above) and some structures on the McCall–
Starkey 138 kV line during the 2020 Woodhead Fire, Idaho Power does not have first-
IDAHO POWER COMPANY’S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 12
hand knowledge of the actual performance of the mesh wraps. The mesh wraps
installed in 2020 were not put to the test as Idaho Power also received permission from
the Forest Service to clear vegetation down to the bare ground in a 10-foot radius
around each structure on which the mesh wraps were installed, which prevented the fire
from overtaking the structures.
Idaho Power is basing the mesh wrap performance data on the manufacturer’s
information, as well as the fact that other utilities such as PacifiCorp, Rocky Mountain
Power, Inland Power and Light, and Atco Electric in Alberta, Canada, are installing the
same (or similar) mesh wraps on their wood pole systems. A video demonstrating how
the Genics mesh system performs in fires is at the following link:
https://youtu.be/g8IW3uDwpxU.
Genics also provides the following information in a Q&A format:

 Question: Once the mesh has been through a fire and has been burnt, what
environmental impacts should be expected? Will there be a breakdown and
leaching of the chemicals after the burn?
Answer: During a fire event, the graphite is released from the polymer coating to
create the protective layer. What remains is essentially carbon - which would be
found in abundance in the aftermath of a fire. Any additional carbon would be
much less than the pole would contribute had it burned.
 Question: There is also a concern of perforations due to Lineman gaffs when
climbing a pole with the mesh on it. How would those perforations impact the
performance of the fire protection capabilities?
Answer: This question has come up a lot and we tested it at the Western Fire
Center and was in the report I sent you (I'm not sure if the email got through or
not). Test #1 had simulated gaff holes and completed the test in 26 minutes (16
minutes after heat and fire was removed the pole temperature reached <50C).
Observations showed that the Fire Mesh intumescent coating easily closed up
the ~1/2" diameter holes - one thing to remember is that gaffing merely moves
the product over but does not remove it from the mesh. Unless extensive tearing
occurs there would be no negative impact expected.
 Question: Can a portal or an 'x-cut' be introduced during the install that provides
an opening for future drilling and testing without compromising the performance
of the product? The ability to make such a portal would save removal and re-
install charges if still on the pole for next testing cycle.
IDAHO POWER COMPANY’S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 13
Answer: This could be done if desired. As long as any intrusions are closed up
within the 1/2 maximum testing has shown that it will still protect the pole.
Genics' opinion would be to simply install the full barrier and then, upon the next
inspection cut back a small 'flap' to accommodate a drill hole. Once the hole is
plugged the flap could then be stapled/nailed back in place. We will also be
selling patch kits which contain four 6"x6" pieces. These are primarily for
prewrapped poles purchased from McFarland Cascade in the off chance of some
damage during transport but would work for any area opened up during
inspection.
 Question: Does the product need to be removed from the pole immediately after
a fire? How difficult is the removal? If left on, will the remains affect the treated
wood?
Answer: The fire mesh does not need to be removed immediately after a fire but
as a full barrier (even though it is somewhat porous and would allow moisture to
escape the pole) could cause some issues over the long run. Genics
recommends replacing the 'activated' Fire Mesh within one year - to both avoid
moisture issues as well as to ensure ongoing protection of the pole from fire.

Idaho Power does have first-hand knowledge of products with similar objectives
as mesh wraps. Save a Pole (see Figure 1) was installed several years ago on an
Idaho Power distribution line in an area susceptible to fire. A fire ended up going
through the area shortly after installation and the results were positive with minimal
damage to the structures.

Figure 1 – Save a Pole
Idaho Power has also used spray-on retardants named Phos-Check and Fire
Kote. These have been beneficial when reactively protecting poles after a range fire
has started and is moving slowly toward the line.
IDAHO POWER COMPANY’S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 14
After comparing protective pole options, Idaho Power determined that the Genics
mesh wraps are cost-effective and the preferred solution based on product
performance, ease of installation, longevity, reduction in need to apply a chemical
treatment, and climb-ability for line personnel.
The response to the request is sponsored by Doug Dockter, T&D Engineering &
Reliability Senior Manager, Idaho Power.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 15
REQUEST NO. 8: What was the Company’s previous vegetation management
cycle before proposing a system-wide 3-year cycle with post trimming audits and
second year trimming for “rapid growing trees”?
RESPONSE TO REQUEST NO. 8: Idaho Power has different vegetation
management cycles depending on location. Transmission circuits are currently pruned
on a three-year cycle in valley locations and on a six-year cycle in mountain locations.
For distribution, the annual scope for patrol and pruning is determined in the fourth
quarter of the previous year. In 2020, Idaho Power trimmed roughly 20 percent of the
distribution system and 100 percent of the transmission system. As discussed and
proposed in Idaho Power’s application, the Company has increased spending annually
on vegetation management but has not been able to achieve greater clearing due to
escalating costs and labor shortages.
The measures and costs outlined in the Application represent the necessary
steps to move the Company from achieving 20 percent distribution system clearing
annually to a goal of clearing one-third of the distribution system per year (on a three-
year cycle, one-third of the system would be pruned per year). In Oregon, where
minimum clearances are prescribed by Oregon Administrative Rule, circuits are also
patrolled in the second year (mid-cycle) and pruned as required to ensure minimum
clearances are maintained for the duration of the cycle.
The response to this request is sponsored by Brent Van Patten, Engineering
Leader, Idaho Power.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 16
REQUEST NO. 9: Please describe the plan and process for identifying and
cataloging “rapid growing trees” (by zone, tree, or map) and provide details for how this
work will be managed. Please include cost estimates for the additional mid-cycle
pruning.
RESPONSE TO REQUEST NO. 9: During vegetation management patrols,
trees that are found to have grown back into the line before the end of their pruning
cycle are classified as “cycle busters”. Each parcel of land (site) that contains a cycle
buster is identified by GIS coordinates and listed in the vegetation GIS database. In
Red and Yellow Risk Zones, these cycle busters will be targeted for removal and
increased incentives will be offered to their owners to encourage them to authorize
these removals.
Where landowners do not authorize the removal of cycle busters, these sites will
be the focus of mid-cycle patrols. These trees will be pruned during the mid-cycle
pruning in the second year along with any other trees that appear to likely violate the
minimum clearance envelope before the next regular cycle pruning.
On average, mid-cycle pruning expenses in Red and Yellow Risk Zones is
estimated to total $324,000 (2021 dollars) and inflate annually at 5 percent thereafter.
The response to this request is sponsored by Brent Van Patten, Engineering
Leader, Idaho Power.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 17
REQUEST NO. 10: Does mid-cycle pruning amount to a 3-year vegetation
management cycle?
RESPONSE TO REQUEST NO. 10: No. A three-year vegetation management
cycle can be employed and followed without using mid-cycle pruning and minimizing the
number of Special pruning projects. In a three-year cycle arrangement, trained
arborists make pruning cuts where they believe will maintain clearance from power lines
for the duration of the three-year cycle. However, some trees will not behave as
expected and regrowth will violate the clearance envelope before the next pruning in
three years. Such areas will be identified and, as necessary, require some amount of
Special pruning projects.
However, Idaho Power proposes employing consistent mid-cycle pruning in Red
and Yellow Risk Zones as an added component to the three-year pruning cycle. The
purpose of the mid-cycle pruning is to catch trees that regrow more than expected
before they have violated the minimum clearance envelope. The Company will then
prune them a second time in an effort to ensure that the three-year pruning cycle can be
maintained for ALL trees on the circuit, including those that regrow more than expected.
As proposed, this additional mid-cycle pruning would take place in the elevated risk
zones to minimize the risk of vegetation contacting a conductor and igniting a fire. The
remainder of the system would utilize a standard three-year pruning cycle.
The response to this request is sponsored by Brent Van Patten, Engineering
Leader, Idaho Power.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 18
REQUEST NO. 11: Please describe the current vegetation management plan,
including the current year over year cycle of the current plan.
RESPONSE TO REQUEST NO. 11: Under Idaho Power’s current vegetation
management plan, transmission circuits in mountain locations are pruned on a six-year
cycle and transmission circuits in valley locations are pruned on a three-year cycle.
Where minimum clearances are documented, trees are pruned to maintain these
minimum clearances over the life of the cycle. Where minimum clearances are not
identified, trees are pruned to avoid contact with the line over the life of the cycle. Post
pruning, quality assurance/quality control (“QA/QC”) audits are performed on a sample
of pruned trees. Additionally, aerial patrols are performed annually on lines governed
by NERC FAC-003. Any hazard trees or “hot spots” (trees that have encroached on the
minimum clearance envelope) identified during these aerial patrols are mitigated before
the end of the current calendar year.
In 2020, Idaho Power trimmed roughly 20 percent of the distribution system and
100 percent of the transmission system. In Oregon, where minimum clearances are
prescribed by Oregon Administrative Rule, circuits are also patrolled in the second year
(mid-cycle) and pruned as required to ensure minimum clearances are maintained for
the duration of the cycle. Post-pruning, QA/QC audits are performed on a sample of
pruned trees.
Where approved by landowners, herbicides are used to prevent regrowth of
removed deciduous trees and to stop the growth of small volunteer trees along the
powerlines. Vegetation is cleared in a 20-foot radius around the bases of select wood
transmission and distribution poles and a ground sterilant is applied in a 15-foot radius
IDAHO POWER COMPANY’S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 19
where approved by the landowner. This clearing/sterilant treatment is applied in
grassland and sagebrush locations that are susceptible to wildfire.
The response to this request is sponsored by Brent Van Patten, Engineering
Leader, Idaho Power.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 20
REQUEST NO. 12: Please quantify the expected overall cost for the entire
Wildfire Mitigation Plan for the years 2021 through 2025. Please include the operating
expenses specific to the wildfire mitigation plan, the increased vegetation management
expenses, Wildfire Mitigation Plan capital investments, and the depreciation expense
associated with those capital expenditures, and the insurance cost. Please break down
the expenditures by project, by type of expense, and by year.
RESPONSE TO REQUEST NO. 12: The following table presents the expected
operating expenses and capital costs of the WMP over the next five years (in thousands
of dollars).
IDAHO POWER COMPANY’S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 21

Insurance Cost: For illustrative purposes, the insurance amounts included in
Idaho Power’s application reflect the Company’s total insurance costs. The table above
only includes incremental costs from a 2019 base. As mentioned in the original filing,
insurance markets continue to be volatile and premium increases are difficult to
forecast. The Company is estimating 2021 costs based on current premiums through
2021 2022 2023 2024 2025 2021 - 2025
Quantifying Wildland Fire Risk
Risk Map Updates 65$ -$ 67$ -$ 69$ 201$
Situational Awareness
Fire Potential Index (FPI) Personnel 52 55 57 59 62 285
Cameras - - - 50 50 100
Mitigation - Field Peronnel Practices
Tools/Equipment 5 5 5 5 5 25
Mitigation - Transmission & Distribution Programs
O&M Component of Capital Work 60 54 61 60 54 289
Annual O&M T&D Patrol Maintenance Repairs 50 50 50 50 50 250
Environmental Management Practices 25 25 25 25 25 125
Transmission Thermography Inspection Mitigation - Red Risk Zones 20 20 20 20 20 100
Distribution Thermography Inspection Mitigation - Red Risk Zones 30 30 30 30 30 150
Thermography Technician Personnel 150 155 160 165 170 800
Transmission Wood Pole Fire Resistant Wraps - Red Risk Zone 82 88 88 - - 258
Transmission Wood Pole Fire Resistant Wraps - Yellow Risk Zone 163 163 163 163 163 815
Vegetation Management
Vegetation Management Incremental Expense to Transition and Maintain 3-yr
cycle Line Clearing Program 1,500 8,087 8,796 9,547 8,372 36,302
Vegetation Distribution Red & Yellow Risk Zone: Pre-Fire Season
Patrols/Mitigation, Pole Clearing, Removals, Work QA 506 1,223 1,284 1,349 1,416 5,778
Line Clearing Personnel - 155 159 164 169 647
Communications
Communications - Advertisements/Meetings/Other 100 100 100 100 100 500
Insurance Expense 3,487 4,567 4,567 4,567 4,567 21,755
Depreciation Expense
Distribution - 124 235 360 484 1,203
Transmission Project Line 423 138kv,  Rebuild Huntington-Quartz - - - 89 89 179
Transmission Project Rebuild T412 Boise Bench to Emmett - - - - - -
Transmission Project T433 Rebuild existing WDRI-KCHM 138-kV transmission line - - - - - -
Transmission Project T410 Tap to OCHD - - 3 3 3 10
Transmission Project T401 - Relocate line terminal from CLIF to RMVW - - - - 2 2
Transmission Project T407 - Relocate line terminal from CLIF to RMVW - - - - 1 1
Transmission Project T452 - Relocate line terminal from CLIF to RMVW - - - - 1 1
Forecast Incremental Operating Expense Totals 6,295$ 14,901$ 15,870$ 16,807$ 15,904$ 69,776$
Capital Plant Closings 2021 2022 2023 2024 2025 2021 - 2025
Distribution 5,570$ 5,017$ 5,632$ 5,589$ 5,005$ 26,813$
Transmission Project Line 423 138kv,  Rebuild Huntington-Quartz - - 3,385 - - 3,385
Transmission Project Rebuild T412 Boise Bench to Emmett - - - - 2,365 2,365
Transmission Project T433 Rebuild existing WDRI-KCHM 138-kV transmission line - - - - 1,868 1,868
Transmission Project T410 Tap to OCHD - 122 - - - 122
Transmission Project T401 - Relocate line terminal from CLIF to RMVW - - - 87 - 87
Transmission Project T407 - Relocate line terminal from CLIF to RMVW - - - 52 - 52
Transmission Project T452 - Relocate line terminal from CLIF to RMVW - - - 54 - 54
Forecast Incremental Capital Plant Closings 5,570$ 5,139$ 9,017$ 5,782$ 9,238$ 34,746$
IDAHO POWER COMPANY’S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 22
mid-year 2021, when renewals occur, and then applying an increase based on broker-
provided high-level estimates. In addition, the Company is applying the new wildfire
load of $1 million also at mid-year 2021. For 2022, Idaho Power is estimating the cost
based on a full year of these premium increases. Due to the volatile nature of the
insurance market, the Company is estimating no increases for the mid-year 2022 policy
renewals and holding the estimate flat through 2025.
Depreciation Expense: Based on the types of activities and property units
anticipated for the WMP related to capital expenditures and current project schedules,
the Company has estimated depreciation expense as indicated in the table above.
The response to this request is sponsored by Doug Dockter, T&D Engineering &
Reliability Senior Manager, Idaho Power.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 23
REQUEST NO. 13: Please provide the budgeted amount and actual amount
spent for Vegetation Management for 2020 and the budgeted amount for 2021?
RESPONSE TO REQUEST NO. 13: The 2020 budget and actuals and 2021
budget for Vegetation Management are provided in the table below:
Category 2020 Budget 2020 Actual 2021 Budget
Purchased Services $ 10,498,053 $ 9,968,992 $ 13,090,607
Labor 508,841 461,627 539,505
Materials 21,000 33,324 21,000
Other 182,555 205,639 182,555
Total $ 11,210,449 $ 10,669,852 $ 13,883,667

Idaho Power attempted to secure additional contracted tree pruning resources in
the fourth quarter of 2020, but none were available at that time. The increase in
Purchased Services budget includes $506,000 for wildfire mitigation activities in Red
and Yellow Risk Zones (hot spot patrols, mitigation and inspections), and $1.5 million
for additional distribution cycle pruning to start the transition to a three-year pruning
cycle as outlined in Idaho Power’s filing. Because the Company was preparing the
regulatory accounting request at issue in this case during the 2021 budgeting process,
the 2021 budgeted amounts reflect the cost of baseline vegetation management
activities and the first-year incremental costs of the enhanced vegetation management
program identified in the WMP.
The response to this request is sponsored by Brent Van Patten, Engineering
Leader, Idaho Power.
DATED at Boise, Idaho, this 5th day of March 2021.

________________________________
LISA D. NORDSTROM
Attorney for Idaho Power Company

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 24
CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on the 5th day of March 2021, I served a true and
correct copy IDAHO POWER COMPANY’S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF upon the following named
parties by the method indicated below, and addressed to the following:

Commission Staff
Dayn Hardie
Deputy Attorney General
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg No. 8,
Suite 201-A (83714)
PO Box 83720
Boise, ID 83720-0074
Hand Delivered
U.S. Mail
Overnight Mail
FAX
X Email [e-mail]

________________________________
Stephanie Buckner, Executive Assistant

BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC-E-21-02

IDAHO POWER COMPANY

ATTACHMENT TO REQUEST NO. 2
TO
IDAHO POWER COMPANY’S RESPONSE TO THE
FIRST PRODUCTION REQUEST OF THE COMMISSION
STAFF
Attachment to Response to Staff's Request No. 2
Situational Awareness - Personnel
FPI Personnel Calculations:
Assumptions:
1 There 182 risk area/service area forecasts to independently calculate.
2 There are 4 forecasts each day (00:00-06:00; 06:00-12:00; 12:00-18:00; 18:00-24:00).
3 The FPI is calculated for a 7 day time period.
4 This totals 5,096 forecasts to perform each day (182x7x4).
5 This process is mostly automated but still requires human review for accuracy.
6 FPI requires approximately 5 hours per day to complete the daily forecast.
7 The FPI is calculated 5 days per week during fire season.
8 Fire season is assumed to be May 10 through October 20.
9 Assume 3 weeks preparation work in advance of the fire season.
10 Assume 4 weeks lessons learned/improvements after fire season for the following year.
11 Calculation is for 2021 personnel using 2020 wages.
12 Assume inflationary/wage increases plus additional time from lessons learned for outer years.
Loaded Hourly Wage:58.60$
Approximate Fire Season Days:120
Hours per day:5
Total - Fire Season:35,160$ $58.60 loaded hourly wage * 120 days * 5 hours per day
Preparation work:7,032$ $58.60 loaded hourly wage * 3 weeks * 40 hours per week
Lessons Learned:9,376$ $58.60 loaded hourly wage * 4 weeks * 40 hours per week
TOTAL LABOR:51,568$ Round to $52,000