20210129Howell Exhibit 12 Schedules 1-6.pdf

DAVID J. MEYER
VICE PRESIDENT AND CHIEF COUNSEL FOR REGULATORY & GOVERNMENTAL AFFAIRS AVISTA CORPORATION P.O. BOX 3727
1411 EAST MISSION AVENUE
SPOKANE, WASHINGTON 99220-3727 TELEPHONE: [phone] FACSIMILE: [phone] [e-mail]

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF THE APPLICATION ) CASE NO. AVU-E-21-01 OF AVISTA CORPORATION FOR THE ) CASE NO. AVU-G-21-01 AUTHORITY TO INCREASE ITS RATES )
AND CHARGES FOR ELECTRIC AND )
NATURAL GAS SERVICE TO ELECTRIC ) EXHIBIT NO. 12 AND NATURAL GAS CUSTOMERS IN THE ) OF STATE OF IDAHO ) DAVID R. HOWELL

FOR AVISTA CORPORATION

(ELECTRIC AND NATURAL GAS)
Avista Utilities
Wildfire Resiliency Plan
2020
2020
Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 1, Page 1 of 67
Avista has been delivering safe and reliable electric energy for over 130 years. Our history is one of
collaboration with communities and customers to ensure a balance of safety, economic vitality, and of
stewardship. Recent wildfires have galvanized our commitment to public safety, emergency
preparedness, and to protect our regional economy. Wildfires represent a growing threat to homes,
businesses, and our way of life. This Wildfire Resiliency Plan represents Avista’s commitment to
mitigating potential wildfire risk associated with the delivery of electricity. It also affirms our
commitment to working closely with community leaders, with property owners, and emergency first
responders.
This Plan leverages the Company’s experience with responding to adverse weather and environmental
conditions including wildland fires. It also represents the knowledge of Avista’s employees, that of peer
utilities, together with fire protection and land management agencies. This is who we are.
Heather Rosentrater
Senior Vice President, Energy Delivery and Shared Services
Sincerely,
Date: May 28, 2020
Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 1, Page 2 of 67
This report reflects the combined effort of many Avista employees. Though many hands were involved in
the development of this document and their contributions should not be overlooked, I would like to
acknowledge several key individuals without whom this report would not have been possible. To Bob
Brandkamp for doing the early work to quantify wildfire risk and for leading the PNW Utility Wildfire
Forum and the Spokane County Fire District committee. To Greg Hesler for initiating the ‘call to action’
and for his counsel throughout this process. To David Howell for his unwavering leadership & personal
support and for responding to Greg’s call to action. And finally, to Heather Rosentrater for making
Wildfire Resiliency one of her top priorities and for lending her voice to the issue. Many voices, one
message.
Thank you all for your time, involvement, counsel, and commitment to this effort.
David James, Wildfire Resiliency Plan Manager
_________________________________________________________________
The steering committee members of Avista’s Wildfire Resiliency Plan approve this document.
David Howell Bruce Howard Bob Brandkamp
Director, Electric Operations Sr. Director, Environmental
Affairs
Sr. Manager, Enterprise Risk
Signature Signature Signature
Date Date Date
Elizabeth Andrews Casey Fielder Annie Gannon
Sr. Manager, Revenue
Requirements
Manager, Corporate
Communications
Manager, Communications
Signature Signature Signature
Date Date Date
Alicia Gibbs Greg Hesler
Manager, Asset Maintenance Vice President, General Counsel
& Chief Compliance Officer
Signature Signature
Date Date
Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 1, Page 3 of 67
Executive Summary
Objective
This report details the recommended response to the increasing threat of wildfires within Avista’s
service territory. The recommendations within this report seek to reduce the risk of wildfire from the
interaction of Avista’s energy delivery system and the environment as well as the impacts of wildfire to
Avista’s system. These recommendations represent Avista’s initial Wildfire Resiliency Plan. The Plan will
be periodically reviewed to ensure consistency with industry best practices and that it is providing
benefits to customers and the communities Avista serves.
Background
Avista’s Wildfire Resiliency Plan reflects the Company’s 130-year operating history combined with
recent efforts to quantify and respond to the financial, safety related, and service reliability risks
associated with wildfires. Risks are not static and this Plan will be updated to align with environmental,
political, financial, and other factors that influence those risks. Plan objectives include focus in the
following strategic areas:
•Protect lives and property
•Ensure emergency preparedness and align operating practices with fire threat conditions
•Protect Avista’s energy delivery infrastructure
Protecting Lives and Property
Though many elements of this plan focus attention on Avista’s transmission and distribution
infrastructure and the effort to reduce spark ignition events, the reader should not lose sight of the
plan’s primary objective: to protect lives and property by reducing the number of utility involved
wildfires. In November 2018, 18,804 structures were destroyed and 85 residents lost their lives in the
wildfire at Paradise, California. Though investigations continue, it is clear that the initiating action
involved one of PG&E’s transmission towers. This fact spurred actions by utilities across the nation,
including Avista, to mitigate the potential for causing such fires.
Avista provides electrical service to over
380,000 customers with many customers living
in elevated fire risk areas. A key factor in
Avista’s plan is how best to reduce the
likelihood of a wildfire caused by Avista’s
electric operations. The recommendations
contained in this plan are based on the ability
to reduce the risks associated with public and
worker safety, the risks to property and
infrastructure, and to lessen the impact of
electric system outages. The relative
importance of those risks is indicated in the
graphic.
Utility
Infrastructure
Electric Service
Disruption
Homes &
Property
Worker &
Public Safety
Relative Importance of Risk Factors
Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 1, Page 4 of 67
Past Fire Mitigation
Avista has a long history of responding to adverse operating conditions including wildfires. In October of
1991, 60 mph winds combined with persistent drought sparked over 90 fires in the Spokane area.1 Most
of those fires were the result of vegetation contacts with powerlines. More recent fires in the Colville
and Davenport operating districts have also influenced operating, maintenance, and design construction
practices. This Plan builds upon that experience to mitigate the risk of wildfires. A few examples are
shown below:

Increased Frequency and Severity of Fire Activity
The number and size of wildfires is increasing throughout the western United States. Data from the
United States Forest Service (USFS) indicates that the number of large fires (>1000 acres) has tripled
since 1970. Also, the duration of fire season has grown by over 100 days. A report from NASA’s global
science department summarizes the situation indicating six underlying trends.2

1 Spokesman Review, 8/21/15 “Firestorm 1991”
2 NASA, global science, www.climate.nasa.gov/blog/2830
Steel Poles
Transmission lines
constructed with tubular
steel poles to protect critical
infrastructure.
Dry Land Operating Mode
During fire season,
distribution lines DO NOT
automatically reclose after a
line fault.
Risk Tree Program
Dead and dying trees that
might fall into powerlines are
removed.
Emergency (EOP)
Incident Command Structure
deployed during emergencies.
Current
Practice Grid Hardening
Upgrades to infrastructure in
elevated fire risk areas will
protect lines from fire damage
and limit the spark-ignition
potential of line faults.
Next Gen Dry Land
Additional circuit reclosers
will be deployed in elevated
fire risk areas.
Digital Data Collection
Collection of LIDAR survey
data to automate the
identification of potential
vegetation conflicts.
Fire Safety Readiness
Avista and Fire crews to
conduct joint training and
field exercises.
Wildfire
Resiliency
Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 1, Page 5 of 67
1.There are more fires (61% of fires in the western U.S. have occurred since 2000)
2.And those fires are larger (since 1950 acres burned per year has increased 600%)
3.A small percentage of the west has burned (11% of land mass impacted since 1950)
4.The same areas keep burning (~33% of land is subject to cyclic wildfire activity)
5.Fires are burning more coniferous forest than any other type of landscape (since 2000,
wildfires have shifted from burning shrub-lands to coniferous forest)
6.Wildfires are going to have a big impact on our future (climate simulations from National
Oceanic and Atmospheric Agency (NOAA) researchers suggest a 200-500% increase in the
number of large fires by mid-century)
Washington State’s Department of Natural Resources is
responsible for fire suppression on over 13 million acres of
private and state owned forest lands. Its 2015 forest health
report states that, “Nearly 2.7 million acres of eastern
Washington forestland need treatment to be more resilient
against insects, disease, and wildfires.” That report
recommends a variety of treatments including mechanical
thinning and prescribed burns. To compound the issue, there
are two million Washington homes located in elevated fire
threat areas.3
Researchers at NOAA predict that by mid-century
(2041-2070),4 the conditions for ‘very large fires’
will substantially increase throughout the western
United States. The graphic on the right indicates
the percentage increase for very large fires. Note
that areas of eastern Washington and northern
Idaho suggest a 300% to 400% increase. This
trend, based on NOAA climate studies, combined
with development in fire prone areas is projected
to make wildfire one of the most significant
environmental threats in the western United
States.5
3 Washington Dept. of Natural Resources Forest Health, www.dnr.wa.gov/ForestHealth
4 National Oceanic and Atmospheric Administration, www.climate.gov
5 Caitlyn Kennedy, “Risk of Very Large Fires Could Increase Sixfold by Mid-Century in the US,” Climate.gov, August 26, 2015,
https://www.climate.gov/news-features/featured-images/risk-very-large-fires-could-increase-sixfold-mid-century-us
40% of Avista’s distribution and 20%
of transmission lines are located in
elevated fire threat areas. 123,300
Avista electric customers reside in
these areas.
NOAA Fire Threat (2041-2070) – Indicates the % Increase of Very
Large Wildfire Conditions (> 1000 acre fires)
Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 1, Page 6 of 67
Public Safety Power Shutoff
In November 2018, a wildfire near Paradise, California burned over 18,000 homes and resulted in 85
fatalities. No wildfire in modern history has created an industry response equivalent to the ‘Camp Fire’.
The California Public Utilities Commission mandated that utilities develop fire mitigation strategies. As a
result, major utilities in California pre-emptively shutoff power to prevent spark-ignitions from overhead
powerlines. This system is known as Public Safety Power Shutoff (PSPS).6 Though Avista is closely
monitoring the situation in California and continues to work closely with utility peers including
PacifiCorp, Pacific Gas & Electric, San Diego Gas & Electric, and Southern California Edison, at this time
Avista does not plan to pre-emptively shutoff power to mitigate the risk of wildfire.
This report details 28 individual recommendations aimed to reduce the risk of wildfires. Many of those
elements support a system that Avista developed in the early 2000s. This system is known internally as
Dry Land Mode or Dry Land Conditions (page 28). Avista operations and engineering staff support
enhancements to the existing Dry Land system and believe it provides a balanced approach to mitigating
wildfire risk while maintaining electric service during fire season. As detailed in this report, Avista’s Dry
Land Mode system involves both identifying electric circuits that operate in elevated fire risk areas and
the reconfiguration of protection systems. Several elements of this plan support enhancements to that
system including:
•Development of a Fire-Weather Dashboard (computerized fire risk prediction system)
•Annual electric distribution fuse coordination report (optimal protection)
•Recloser event reporting (continuous improvement of protection systems)
•Dry Land Mode engineering review (comprehensive system review)
•Dry Land Mode ‘trigger’ (initiate seasonal protection based on fire risk threshold)
•Midline recloser communication
(retrofit existing circuit reclosers with monitoring & control equipment)
•Additional midline reclosers in elevated fire threat areas
(aligning system protection with fire risk)
•Wildland Urban Interface (identify elevated fire risk zones)
•Substation SCADA (retrofit existing substation with monitoring & control systems)
It is impossible to prevent all tree contacts or equipment failures associated with the electric delivery
system. However, by adding defense strategies specifically designed to reduce spark-ignition sources,
Wildfire Resiliency represents a holistic approach to safeguarding human lives, property, and
infrastructure against the threat of utility involved wildfires.
6 Public Safety Power Shutoff – California PUC – www.cpuc.ca.gov/deenergization
Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 1, Page 7 of 67
Goals and Objectives of Avista’s Wildfire Resiliency Plan
Throughout the development of
this Plan, a model framework has
been used to balance risks, costs,
and benefits. Collaboration
extended well beyond the internal
walls of Avista to include voices
from the community, fire
protection professionals,
regulators, utility peers, and
professional service and material
suppliers.
Understand the Risk – Combining infrastructure data with fire threat and weather conditions to yield a
‘fire risk potential’ metric.
Design for the Risk – Adapt transmission and distribution materials and construction to minimize the
potential for utility involved fire ignition.
Plan for an Event- Prepare field and office support staff through training and field simulation exercises.
Partner with others – Collaborate with others to leverage the strengths of various partners and create a
stronger response system for all involved.
Emergency Response
Emergency Operating
Plan
•To prepare and train for episodic wildfire events. To recognize wildfire as a recurring threat to utility
infrastructure, the communities we serve, Avista employees and customers.
Protect Life and PropertyPromote Safety
•To protect physical assets, property, and human lives against the threat of wildland fires. To recognize fire
potential as a manageable risk element of Avista's operating and maintenance strategies.
Safeguard Company AssetsFinancial Protection
•To mitigate the probability and consequence of direct financial and liability costs associated with large
scale fire events.
Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 1, Page 8 of 67
Wildfire Resiliency Plan Elements
This Plan includes 28 individual
recommendations grouped into four
categories. These categories are similar to
other utility wildfire plans including those
from PG&E, SDG&E, SCE, and PacifiCorp:7
• Grid Hardening – by replacing
infrastructure in fire prone areas, the
likelihood of a spark-ignition source
is mitigated and critical
infrastructure is protected from the
impacts of fire.
• Vegetation Management – by
identifying potential conflicts on an
annual basis and prioritizing those
risks from highest to lowest, Wildfire
Resiliency aligns resources with risk
metrics.
• Situational Awareness – by adding line and monitoring equipment, system operators can respond
quickly to variable weather and fire threat conditions.
• Operations & Emergency Response – through training and simulation, Avista personnel will be
better prepared to work with fire professionals during an event.

Plan recommendations also reflect cost prudency and were adopted on their basis to:
• Leverage existing asset programs and operating practices
• Promote public safety
• Mitigate financial risk

The following tables provide more information about the recommendations.
Grid Hardening and Dry Land Mode
Recommendation Current State Future State Benefits
Transmission Fire Retardant
(FR) Program
FR paint program requires
refresh every 3-5 years
Genic Fire-Mesh wrap with
20-year expected life
Will reduce operating
expense to maintain fire
protection of transmission
wood poles
Transmission Line Inspection Aerial surveys to identify
structure defects (reliability
based)
Aerial and ground
inspections to identify
structure defects
(fire risk based)
Reduce transmission fire
ignition events which are
less likely than distribution
related fires, but generally
result in larger fires
Dry Land Operating Mode
(DLM)
Seasonal implementation
(single mode)
Adapted to fire-weather
metrics
(multi-mode)
By aligning DLM modes with
weather and fire threat
conditions, operators can
balance service reliability
with fire risk potential
7 California Public Utilities Commission, www.cpuc.ca.gov/wildfiremitigationplans/
Enhanced Vegetation
Management
Situational Awareness
Operations &
Emergency Response
Grid Hardening &
Dry Land Mode
Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 1, Page 9 of 67
Grid Hardening and Dry Land Mode
Recommendation Current State Future State Benefits
Transmission Grid Hardening Condition-Based Steel
Conversion
Risk-Based Steel Conversion Reduce likelihood of damage
to Avista transmission
assets. 20% of Avista’s
transmission assets are
located in elevated fire
threat areas
Distribution Grid Hardening Condition based pole,
conductor, and equipment
programs
Risk based approach to
replacing equipment and
conductors associated with
spark-ignition potential
Reduce likelihood of
distribution related fires.
40% of Avista’s distribution
assets are located in
elevated fire threat areas

Enhanced Vegetation
Recommendation Current State Future State Benefits
Digital Data Collection Human based ground and
aerial inspections
Augment with computer
automated analysis to
identify vegetation
encroachment and
structural defects
Allows for scenario based
planning of treatment
options and serves as the QA
tool to assess the efficacy of
previous field work
Fuel Reduction Partnerships No formal program Partnering with Fire
Agencies to remove fuels
near critical infrastructure
Strengthens relationships
between Avista and fire first
responders and reduces fire
severity threats to
infrastructure

Widen Transmission Rights-
of-way
No formal program Align right-of-way
boundaries to fire risk
potential
Protect critical infrastructure
and serve as fire break
Annual Risk Tree Cadence based program
(e.g. 1-3 years)
System-wide effort to
annually identify and
remove dead, dying, and
diseased trees
Reduce tree fall-ins, which
are 3 times more likely to
occur than grow-ins
Public Outreach “Right Tree,
Right Place” Campaign
General information
available to all customers
Work with customers in
elevated fire risk areas to
remove tall growing trees
from underneath powerlines
Reduces the risk of tree
grow-ins and subsequent
spark-ignition sources

Situational Awareness
Recommendation Current State Future State Benefits
Fire-Weather Dashboard Weather forecast data
subject to individual
interpretation
By combing weather
forecast and fire threat
condition data, operating
personnel will have clear
guidance relative to
likelihood and potential
impact of fires
Promotes a more consistent
approach among operations
and emergency managers
Additional Distribution
Circuit Reclosers
Based on system protection
and reliability performance
Deployed in elevated fire
threat areas. Reflects a risk-
based strategy
Supports the evolution of
Avista’s Dry Land operating
mode to align with
forecasted weather and fire
threat conditions

Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 1, Page 10 of 67
Situational Awareness
Recommendation Current State Future State Benefits
Substation Supervisory
Control & Data Acquisition
(SCADA)
SCADA added to new or
reconstructed substations.
Reflects a condition based
approach
Enables control and
monitoring of substation
equipment including circuit
reclosers in elevated fire risk
areas
(as stated above)

Operations and Emergency Response
Recommendation Current State Future State Benefits
Emergency Operating
Procedure & Avista Incident
Command Representative
No formal wildfire policy Avista EOP to delineate
wildfire from other storm
events. Avista to offer
assistance at all fire ICS.
Coordinate Avista system
restoration with fire
protection and evacuation
activities
Wildfire Performance
Metrics
None Develop fire-specific
performance metrics to
ensure that Plan objectives
are being met
Supports the adaptation of
the Resiliency Plan to meet
current operating and
environmental conditions
Wildland Urban Interface
(WUI) map
Developed in Q3/2019 Categorize Avista T&D
infrastructure with respect
to fire ignition potential and
fire impact consequence
Focuses vegetation
management and grid
hardening efforts in the
highest fire risk areas
Emergency first responder
training
No formal program Annual fire safety training to
Avista field personnel and
electrical hazard training to
fire protection personnel
Promotes safety of first
responders and supports a
variety of partnering
activities including fuel
reduction and fire adapted
communities
Expedited Fire Response Draft MOU under
consideration with Spokane
Fire Districts
(2020 Pilot Project)
Fire agency personnel to
investigate transmission line
faults during fire season
Suppress fires before they
have an opportunity to
spread

The Wildland Urban Interface (WUI)
The interface area between forest lands and human development is referred to as Wildland Urban
Interface (WUI). Homes and businesses located near the WUI are most at-risk from the impact of
wildfires and are often located in rural areas that lack fire suppression resources.
In 2019, Avista’s GIS Technical Group created a WUI map for the electric service territory based on the
following principles:
• Fuel Concentration – areas identified as having moderate to high fuel concentrations were
considered. Fuels data was derived from the U.S. Department of Agriculture’s Wildfire
Hazard Potential map.8
• Housing Density – parcels smaller than 20 acres were included in the analysis but highly-
developed urban areas were excluded. Urban areas do not meet the definition of Wildland
Urban Interface because fuel canopies are dispersed and fire protection is readily available.
The WUI map helps to identify and prioritize areas of greatest risk and serves to inform the
recommendations and operational decisions related to wildfire resiliency. The Plan denotes the
8 U.S. Department of Agriculture, data.nal.usda.gov/dataset/wildfire-hazard-potential…….
Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 1, Page 11 of 67
combination of WUI Tiers 2 & 3 as “elevated fire threat areas”. These areas comprise 40% of Avista’s
electric distribution and 20% of the high-voltage transmission systems. Elevated fire threat levels are
depicted in orange (Tier 2) and red (Tier 3) highlighted areas. Portions of the map not highlighted are
classified as Non-WUI and represent areas with low fuel concentrations, very low housing densities, or
large urban areas (> 10,000 population).

Summary of Risks and Costs
Precise identification of the risk-cost for any given year is not realistic, and for wildfires, there is a
significant difference between small fire events which can occur many times per season versus a large
scale event which may occur once every few years. Therefore, in order to represent a more realistic
picture of relative risks and costs, a 10-year planning horizon was adopted.

The Plan denotes the
combination of WUI Tiers
2 & 3 as “elevated fire threat
areas”. These areas comprise
40% of electric distribution
and 20% of transmission
systems. Elevated fire threat
levels are depicted in orange
(Tier 2) and red (Tier 3).
Portions of the map not
highlighted are classified as
Non-WUI and represent
areas with low fuel
concentrations, very low
housing densities, or densely
populated urban areas.
Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 1, Page 12 of 67
Risk and cost values shown in the following table represent a 10-year planning horizon, and include both
incremental operating expenses as well as capital improvements to infrastructure. Capital plan elements
are projected to sunset in 10 years but the majority of expense items are on-going and are generally
related to vegetation management. In simple terms, risk is the product of the probability of an event
and financial consequence:
Risk = (The likelihood of occurrence, or probability) X (The financial impact of an event)
Inherent Risk - describes the current state risk level and reflects defense strategies already in place.
Managed Risk - describes the future state risk level with the addition of Wildfire Resiliency elements.
The values shown for risk are percentage based and reflect a range for each category. Note that
vegetation and grid hardening risk scores indicated a bounded range because the probability of
occurrence is based on the frequency of forced outages, and the frequency of electrical outages is well
understood. However, an event’s impact can vary widely based on several factors including weather, fire
risk levels, emergency response, and location. Note that the managed risk scores represent future state
levels and lower levels of event probability and event outcome. The column labeled ‘Risk Reduction’
indicates the average percentage difference between current state and future state risk levels.

Resiliency Risk and Cost Summary-Washington and Idaho Electric
2020-2029
Operating Horizon
Inherent Risk
(range %)
Managed Risk
(range %)
Risk
Reduction
(avg %)
10-yr Capital
Investment
($)
10-yr Operating
Expense ($)
Enhanced Vegetation
Management

48.3-100 3.2-14.5 88% $5,100,000 $51,175,000
Situational
Awareness

25.9-100 0.8-1.1 98% $17,965,000 $1,019,000
Operations &
Emergency Response

19.7-100 5.3-23.4 76% $300,000 $2,378,000
Grid Hardening & Dry
Land Mode

41-100 0.7-2.7 98% $245,600,000 $5,014,000
Plan Total
44.1-100 2.8-12.5 89% $268,965,000 $59,586,000

As noted, the wildfire resiliency program includes electric system (Washington and Idaho) capital
investments of $268,965,000 over 10 years with corollary operating expenses of $59,586,000.
Expenditures are illustrated on the following page from 2020 through 2029.
The single largest capital investment is grid hardening of the electric distribution system. This accounts
for $193,200,000 invested in distribution systems located in elevated fire risk areas and another
$44,000,000 invested in the transmission system to convert from wood to steel poles. These two Plan
elements account for 88% of total capital spend. For operating expense, three elements: T&D digital
data collection, annual risk tree, and the public safety initiative ‘right tree right place’ account for
Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 1, Page 13 of 67
$42,700,000 (72%) over the same 10-year period. Though, this Plan includes 28 recommendations to
mitigate the risk of wildfire, these five elements account for 85% of the total program investments.

Potential Operating & Maintenance Expense Cost Reductions
The goal of wildfire resiliency is to reduce the overall risk associated with wildfires. In short, the benefits
of this Plan are largely measured in terms of risk reduction for all parties involved. However, we
recognize the potential for costs savings and cost shifts from operating and maintenance expense
activities towards capital investment. The overall impact of cost savings is speculative until the Plan
becomes operational and performance data can be analyzed. However, one objective of this Plan is to
reduce the number of equipment failures and tree related outages and by doing so, avoid emergency
response. Consider a hypothetical scenario whereby Wildfire Resiliency reduces these outages by 10%.
From 2014 to 2018, the electric distribution system experienced 6,200 outages per year. This
corresponds to an annual frequency index (SAIFI) of 1.1 with a duration index (SAIDI) of approximately 2
hours and 20 minutes. On average, 67 customers were impacted during each outage.
Equipment failures and tree related outages account for approximately 1,000 outages per year and it is
these outages that wildfire resiliency aims to mitigate through grid hardening and enhanced vegetation
management. If those outages were reduced by just 10% (100 outages), the reduction in customer
impact would equate to $990,780 per year.9 Again, this is a hypothetical exercise to illustrate the Plan’s
value proposition.
9 Based on Avista Asset Management Risk Analysis Standard (service interruption cost = $63 per customer* hour)
2020 2021 2022 2023 2024 2025 2026 2027 2028 2029
Capital $5,265 $16,985 $27,055 $31,380 $31,380 $31,380 $31,380 $31,380 $31,380 $31,380
Operating $2,416 $5,371 $6,917 $7,435 $7,354 $6,772 $6,540 $6,059 $5,627 $5,096
$0
$5,000
$10,000
$15,000
$20,000
$25,000
$30,000
$35,000
$
0
0
0
'
s
Avista Wildfire Resiliency
Plan Cost Forecast
Capital Operating
Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 1, Page 14 of 67
The following table lists several potential cost savings opportunities associated with wildfire resiliency.
Plan Element Benefit Cost Savings/Shift
Annual Risk Tree and Right
Tree Right Place Programs
Improved System Performance
(fewer outages)
Reduced spend on emergency
response and unplanned repairs
Digital Data Collection Automates data gathering
process for vegetation and
structure condition inspection
Reduces field inspection
activities. Enables automated
QA/QC functions
Grid Hardening Improves System Performance
(fewer outages)
Reduced spend on emergency
response and unplanned repairs
Situational Awareness
(communication & control
systems)
Enables remote monitoring and
control of equipment
Reduced service related truck
rolls
Operations & Emergency
Response
Better prepared and equipped
first responders
Reduces the risk of injury and
accidents

It should be noted that this Plan indicates program level spend estimates and does not differentiate
between incremental and embedded costs. Though many Plan elements represent incremental costs,
some activities will simply be absorbed by the workforce. For example, annual fire safety training will
occur at monthly safety meetings which are well established. This imbedded cost is estimated at
$1,300,000 over 10-years. However, the bulk of the Plan elements including enhanced vegetation
management and grid hardening represent additional activities and incremental costs. As previously
indicated, these categories account for 85% of overall program costs.

Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 1, Page 15 of 67
Conclusion
The risk of large wildfire events is increasing across the western
United States. The recent fires in California serve to illustrate that
utility operating risks are increasing due to wildfires. Managing this
risk is critical for customers, communities, investors, and the regional
economy. Avista has taken a proactive approach for many years to
manage wildfire risks, and through this Plan, the Company has
identified additional wildfire defenses. The goals, strategies, and
tactics set forth in this Plan reflect a quantitative view of risk.
Additional research, conversation and analysis with Avista’s
operating staff and steering group provided critical qualitative and
contextual information that also shaped the recommendations. This
combination of quantitative and qualitative analysis ensures the
recommendations are robust, well-rounded, thoughtful, and align
with the Plan objectives.
Comprehensive risk analysis indicates a cumulative 10-year financial
risk of at least $8 billion dollars. This value includes the accumulated
risks associated with all 28 Plan recommendations and should not be
interpreted as a precise financial estimate. A better metric is the
percentage of risk mitigation which reflects a 90% reduction for the
overall Plan.
Though planned investments in infrastructure and vegetation
maintenance defenses represent the bulk of costs, human
investments in training, partnerships, and engagement with
customers are core components of Wildfire Resiliency.
Wildfire Resiliency represents a departure from traditional utility
strategies aligned with meeting customer demand (capacity) and
maintaining service continuity (reliability). Avista’s strategy aligns
with other utility wildfire plans by adding defenses in four key areas:
vegetation management, grid hardening, situational awareness and
operations and emergency response.
Avista has a long history and tradition of ‘doing the right thing’ for
our customers and the communities we serve. Working together to
promote safety and manage the risk of wildfire is not a new concept
but simply one that will be built upon.

End of Executive Summary____________________________
Partnering with Others
The Western Energy Institute
The Edison Electric Institute
Washington Department of Natural
Resources
Idaho Department of Lands
AEGIS Insurance
PNW Utility Wildfire Group
(PSE, PAC, CHPD, IPC, NWE, PGE, AVA)
The University of Idaho
Idaho Smart Growth Initiative
Spokane County Fire Districts
City of Spokane Fire Department
Spokane Valley Fire Department
Palouse County Fire Districts
Spokane Emergency Management
NOAA & NWS (Weather)
Washington Utilities and
Transportation Committee (WUTC)
Idaho Public Utilities Commission (IPUC)
Washington Dept. of Natural Resources
(DNR) Utility Taskforce
Western Governor’s Association
West Coast Utility Commission Seminar
(Vendors)
Quantum Spatial
Genics Corporation
Geo Digital Corporation
Western Weather
The Eaton Corporation
TROVE Corporation

Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 1, Page 16 of 67
TABLE OF CONTENTS
Executive Summary ............................................................................................................................ 4
Wildfire Resiliency Plan Overview ..................................................................................................... 18
Wildfire Resiliency Plan Goals .......................................................................................................... 20
Risk Assessment ............................................................................................................................... 20
Plan Recommendations Summary .................................................................................................... 25
Plan Recommendations by Category ................................................................................................ 28
Grid Hardening & Dry Land Mode ................................................................................................. 28
D-16/17 Distribution System Grid Hardening ..................................................................................................... 30
D-13 Additional Dry Land Mode Circuit Reclosers ........................................................................................ 31
D-6 Dry Land Mode Effectiveness Study ..................................................................................................... 32
D-8 Dry Land Mode Trigger ......................................................................................................................... 34
ST-12 Transmission System Grid Hardening ................................................................................................... 35
ST-10 Transmission Inspection Program ......................................................................................................... 36
ST-6 Transmission Wood Pole Fire Retardant Protection .............................................................................. 37
Enhanced Vegetation Management .............................................................................................. 38
D-10 Electric Distribution Annual Risk Tree .................................................................................................... 39
D-11 Public Safety Initiative: “Right Tree, Right Place” ................................................................................. 41
D-14 Distribution Digital Data Collection ....................................................................................................... 43
ST-5 Transmission System Digital Data Collection ......................................................................................... 45
ST-9 Conforming Transmission Rights-of-Way .............................................................................................. 46
ST-7 Fuel Reduction Partnerships .................................................................................................................. 47
D-4 Incorporating Vegetation Management into Distribution Designs ....................................................... 49
Situational Awareness .................................................................................................................. 50
D-15 Substation SCADA .................................................................................................................................. 51
D-12 Distribution Management System (DMS) Communication ................................................................... 53
ST-2 Fire-Weather Dashboard ....................................................................................................................... 55
Operations & Emergency Response .............................................................................................. 57
ST-1 Emergency Operating Program (EOP).................................................................................................... 58
ST-3 Transmission Design’s Role in Major Event Response ........................................................................... 59
ST-4 Wildfire Performance Metrics ............................................................................................................... 60
ST-8 Wildfire Training for Avista First Responders ........................................................................................ 60
ST-9 Expedited Fire Response ........................................................................................................................ 61
D-1 Fuse Coordination Study ........................................................................................................................ 62
D-2 Circuit Recloser Event Reporting ........................................................................................................... 63
D-3 Fire Ignition Tracking System ................................................................................................................. 63
D-5 Fire Suppression Water Additive ........................................................................................................... 64
D-7 WUI Layer in Avista GIS System ............................................................................................................. 64
D-9 Wildfire Notification System .................................................................................................................. 65
Conclusion ....................................................................................................................................... 66
Addendum ....................................................................................................................................... 67
Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 1, Page 17 of 67
Wildfire Resiliency Plan Overview
Avista’s Wildfire Resiliency Plan reflects the Company’s 130-year operating history combined with
recent efforts to quantify the financial risk of wildfires. Risks are not static and this Plan will adapt and
evolve over time to align with environmental, political, financial, and other factors that influence those
risks. The foundation of this Plan is the monetization of risk resulting in a series of recommendations to:
• Protect Avista’s energy delivery infrastructure
• Enhance vegetation management programs and reduce tree contacts with powerlines
• Deploy additional system monitoring and control equipment
• Align operating practices and emergency response with fire threat conditions

Past Fire Mitigation
Avista has a long history of responding to adverse operating conditions including wildfires. In October of
1991, 60 mph winds combined with persistent drought sparked over 90 fires in the Spokane area.10
Most of those fires were the result of vegetation contacts with powerlines. Recent fires in the Colville
and Davenport operating districts have also influenced operating, maintenance, and design construction
practices. This Plan builds upon that experience by leveraging current defense strategies and focusing
efforts in elevated fire risk areas. A few examples are shown below:
10 Spokesman Review newspaper, “Firestorm 1991”, August 21, 2015 publication
Steel Poles
Transmission lines
constructed with tubular
steel poles to protect
critical infrastructure.
Dry Land Operating Mode
During fire season,
distribution lines DO NOT
automatically reclose after
a line fault.
Risk Tree Program
Dead and dying trees that
might fall into powerlines
are removed.
Emergency (EOP)
Incident Command
Structure deployed during
emergencies.
Current
Practice
Grid Hardening
Upgrades to infrastructure
in elevated fire risk areas
will protect lines from fire
damage and limit spark-
ignition potential of line
faults.
Next Gen Dry Land
Additional circuit reclosers
deployed in elevated fire
risk areas to allow
alignment between fire risk
conditions and system
protection.
Digital Data Collection
Collection of LIDAR and Hi-
Res Photography to
automate the identification
of potential vegetation
conflicts and structure
defects.
Fire Safety Readiness
Avista and Fire crews to
conduct joint training and
field exercises.
Wildfire
Resiliency
Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 1, Page 18 of 67
Increased Frequency and Severity of Fire Activity
The number and size of wildfires is increasing throughout the western United States. Data from the
United States Forest Service (USFS) indicates that the number of large fires (>1000 acres) has tripled
since 1970. Also, the duration of fire season has grown by over 100 days. The graph below indicates
wildfire frequency from 1950 to 2017.11

Washington State’s Department of Natural Resources is
responsible for fire suppression on over 13 million acres of
private and state owned forest lands. Its 2015 forest health
report states that, “Nearly 2.7 million acres of eastern
Washington forestland need treatment to be more resilient
against insects, disease, and wildfires.”12 That report
recommends a variety treatments including mechanical
thinning and prescribed burns. To compound the issue, there
are two million Washington homes located in elevated fire
threat areas.13

11 NASA, www.climate.nasa.gov/blog/2830
12 Washington Department of Natural Resources 20-year Forest Health Plan (2017)
13 Spokesman Review newspaper, Carpenter Road Fire, September 15, 2015

Over the past six decades,
61% of fires in the western
U.S. have occurred since
2000.

40% of Avista’s distribution and 20%
of transmission lines are located in
elevated fire threat areas. 123,300
Avista electric customers reside in
these areas.
In September of 2015, the Carpenter road
fire impacted 64,000 acres of land near
Davenport, WA and damaged 42 structures.
The costs to suppress this fire exceeded
$200 million.13
1950 ---------------------------------------------------2017
Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 1, Page 19 of 67
Researchers at the National Oceanic and
Atmospheric Agency (NOAA) predict that by mid-
century (2041-2070), the conditions for ‘very large
fires’ will substantially increase throughout the
western United States.14 The graphic shown to the
right indicates the percentage increase for very large
fires. Note that areas of E. Washington and N. Idaho
indicate a 300% to 400% increase. The combined
trends of more frequent and larger fires combined
with development in fire prone areas is projected to
make wildfire one of the most significant
environmental threats in the western United States.
Wildfire Resiliency Plan Goals
Objective:
This report details Avista’s recommended response to the increasing threat of wildfires to the energy
delivery system. The plan will be periodically reviewed to ensure that it is consistent with industry best
practices and continues to provide benefits to customers and the communities Avista serves.
Goals of the Wildfire Resiliency Plan
The stated goals of this Plan are:
1. Emergency Preparedness – to prepare and train for episodic wildfire events. To recognize
wildfire as a recurring threat to infrastructure, the communities we serve, Avista employees and
customers.

2. Promote Public & Worker Safety – To protect physical assets, property, and human lives against
the threat of wildland fires. To recognize fire potential as a manageable risk element of Avista’s
operating and maintenance strategies.

3. Financial Protection – To mitigate the probability and consequence of direct financial costs and
liability associated with large scale fire events.
Risk Assessment
Wildfire Risk Framework
Recommended actions described in this Plan are based on Avista’s Enterprise Risk Model and Asset
Management risk methodology. In addition to risk analysis, a model framework was established to help
guide the process for identifying, quantifying, and adopting recommendations.
14 Internet source: www.climate.gov/news-features/featured-images/risk-very-large-fires-could-increase-sixfold-mid-century-
us
NOAA Fire Threat (2041-2070) – Indicates the % Increase of
Very Large Wildfire Conditions (> 1000 acre fires)
Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 1, Page 20 of 67

Risk Assessment Methodology
The recommendations in this report are based on their ability to reduce the operating and financial risk
of wildfires. Understanding how to quantify risk is fundamental to understanding the content of this
report.
In order to illustrate this concept, consider the risk of distribution pole fires. Pole fires are a common
occurrence on overhead electric distribution system and generally occur when dust and other
contaminates accumulate during a prolonged period of drought. In most years, the drier months of July
through September present the most likely period to experience a pole fire. For each pole fire there is
an associated risk cost.

Understand the Risk – Combining infrastructure data with fire threat and weather conditions to
yield a ‘fire risk potential’ metric.

Design for the Risk – Adapt transmission and distribution materials and construction to minimize
the potential for utility involved fire ignition.

Plan for an Event- Prepare field and office support staff through training and field simulation
exercises.

Partner with Others – Direct collaboration with Fire Protection Agencies and customers to reduce
fuel loadings near homes and powerlines.
Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 1, Page 21 of 67
On average, Avista experiences 92 pole fires per year. In most cases, Avista crews use fire suppression
equipment to contain the fire and repair any damage. In some instances, pole fires are conveyed to the
ground and can spread quickly under the right fuel and weather conditions. Wildfire Resiliency risk
modeling considered three potential impacts:
Public Safety – the cost of injuries associated with Avista employees and the general public.
Service Reliability – the costs associated with service disruption based on the Department of
Energy’s Interruption Cost Estimator (ICE). For Avista customers, this value is $63 dollars per
customer-hour.
Financial Impact– the replacement costs of infrastructure (direct) and third party claims to
reimburse for property damage, timber loss, and fire suppression (indirect).

The following table provides an example of outcomes and impacts.
Outcome Probability
per event
Impact Cost ($) Risk Cost ($) Notes
Optimistic Pessimistic Optimistic Pessimistic
Direct Financial 1 $1,500 $7,500 $1,500 $7,500 Avista crews
responding to pole fires
Indirect Financial
(minor) 0.1 $5,000 $20,000 $500 $2,000 3rd Party costs
(e.g. suppression)
Indirect Financial
(large) .002 $100,000 $2,000,000 $200 $4,000 Ground fire spread by
wind and fuel loading
Safety-Employee .05 $2,500 $75,000 $125 $3,750
Employee injury
ranging from minor
burn to back or
shoulder injury
Safety-Public (minor) .01 $10,000 $50,000 $100 $500 Injury
Safety-Public (major) .001 $2,000,000 $10,000,000 $2,000 $10,000 Fatality
Reliability (minor) 0.7 $200 $2,000 $140 $1,400 Service point
(2-15 customers)
Reliability (moderate) 0.25 $18,000 $30,000 $3,600 $6,000 Lateral circuit
(140-240 customers)
Reliability (major) 0.05 $190,000 $378,000 $9,500 $18,900 Feeder circuit
(1500-3000 customers)
Total (per event) $14,515 $48,800
Inherent Risk =
92 events/year x
$/event
$1,335,380 $4,489,600 Pole fire risk cost per
year.
Inherent Risk over 10-
year planning horizon
(assumes level rate)
$13,353,800 $44,896,000
This is illustrative of the
range used in the
Wildfire Resiliency Plan
for a sub element of
distribution grid
hardening

Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 1, Page 22 of 67
The table on the previous page reflects the inherent risk (current state) of
pole fires. Poles fires are mitigated by replacing wood crossarms with
fiberglass units. In the above example, the outcome scenario or impact
would remain unchanged but the probability of occurrence would be
drastically reduced.
For illustration purposes, if one assumes an 80% efficacy rate, the new risk
costs ranges from $2,670,000 to $8,880,000 reflecting a median risk
reduction of $23,300,000 over the 10-year planning horizon. This value
would then be compared to cost estimates to determine if the treatment is
warranted.
In May and June of 2019, a series of Wildfire Risk Workshops were
facilitated by Avista’s Business Process Improvement team to assess the
overall risk cost of wildfires. Six individual workshops were held over a 15-
day period involving 30 employees. Over 160 treatments were identified
and nearly half of those were analyzed for their risk reduction capacity.
Ultimately, 28 treatments were carried forward and serve as the individual
recommendations in this report.
_________________________________________________

The Wildland Urban Interface (WUI)
An additional element of risk reduction includes the prioritized application
of solutions. Recommendations within this report consider geographic
location and apply risk reduction measures in areas with higher fire threat potential.
Homes and businesses most at-risk from the impact of wildfires are those located near the boundaries
of forest lands and in rural areas that lack fire suppression resources. In 2019, Avista’s GIS Technical
Group created a Wildland Urban Interface map based on the following principles:
Fuel Concentration – Areas identified as having moderate to high fuel concentrations were considered
in the analysis. Fuels data was derived from the U.S. Department of Agriculture’s Wildfire Hazard
Potential map.15
Housing Density – Parcel’s smaller than 20 acres were included in the analysis but highly-developed
urban areas were excluded.16 Urban areas do not meet the definition of Wildland Urban Interface.

15 USDA, Wildfire Hazard Potential, 2018
16 Avista GIS System, Electric Distribution Service Connections
Pole fires generally occur on wood poles with
wood crossarms. Since the early 2000's, Avista
has adopted fiberglass crossarms as the standard
unit. Replacing wood crossarms in elevated fire
risk areas is a component of Wildfire Resiliency.
Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 1, Page 23 of 67
WUI Risk Levels – Similar to the work done in California, Avista’s WUI identifies three wildfire risk levels:
Tier 1 – Moderate levels of fuel and low to moderate housing densities (low)

Tier 2 – Moderate to high levels of fuel and moderate housing densities (medium)

Tier 3 – High fuels levels and moderate to high housing densities (high)

Avista’s Wildland Interface Map

This Plan describes the
combination of WUI Tiers 2 &
3 as “elevated fire threat
areas”. These areas comprise
40% of the electric
distribution and 20% of the
transmission systems.
Elevated fire threat levels are
depicted in orange (Tier 2)
and red (Tier 3) highlighted
areas. Portions of the map
not highlighted are classified
as Non-WUI and represent
areas with low fuel
concentrations, very low
housing densities, or densely
populated urban areas.

Many of the elements
described in this Plan will be
deployed only in elevated fire
threat areas including grid
hardening, digital data
collection, and fire-specific
aerial inspections.
Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 1, Page 24 of 67
Plan Recommendations Summary
This Plan contains 28 individual recommendations grouped into four categories. These categories are
similar to other utility wildfire plans including those from PG&E, SDG&E, SCE, and PacifiCorp and include:

• Grid Hardening – Replacing infrastructure in fire prone areas, the likelihood
of a spark-ignition source is mitigated and critical infrastructure is protected
from the impacts of fire.
• Enhanced Vegetation Management – Identifying potential conflicts on an
annual basis and prioritizing those risks from highest to lowest, Wildfire
Resiliency aligns resources with risk.
• Situational Awareness – Adding line and monitoring equipment, system
operators can respond quickly to variable weather and fire threat conditions.
• Operations & Emergency Response – Through training and simulation,
Avista personnel will be better prepared to work with fire professionals
during an event.

Plan recommendations reflect cost prudency and were adopted on their basis to:
• Leverage existing asset programs and operating practices
• Promote safety and safe practices
• Mitigate financial risks to property and infrastructure

The following tables provide more information about the recommendations.

Grid Hardening and Dry Land Mode
Recommendation Current State Future State Benefits
Transmission Fire Retardant
(FR) Program
FR paint program requires
refresh every 3-5 years
Genic Fire-Mesh wrap with
20-year expected life
Will reduce operating
expense to maintain fire
protection of transmission
wood poles
Transmission Line Inspection Aerial surveys to identify
structure defects (reliability
based)
Aerial and ground
inspections to identify
structure defects
(fire risk based)
Reduce transmission fire
ignition events which are
less likely than distribution
related fires, but generally
result in larger fires
Dry Land Operating Mode
(DLM)
Seasonal implementation
(single mode)
Adapted to fire-weather
metrics
(multi-mode)
By aligning DLM modes with
weather and fire threat
conditions, operators can
balance service reliability
with fire risk potential
Transmission Grid Hardening Condition-Based Steel
Conversion
Risk-Based Steel Conversion Reduce likelihood of damage
to Avista transmission
assets. 20% of Avista’s
transmission assets are
located in elevated fire
threat areas
Distribution Grid Hardening Condition based pole,
conductor, and equipment
programs
Risk based approach to
replacing equipment and
conductors associated with
spark-ignition potential
Reduce likelihood of
distribution related fires.
40% of Avista’s distribution
assets are located in
elevated fire threat areas
Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 1, Page 25 of 67
Enhanced Vegetation
Recommendation Current State Future State Benefits
Digital Data Collection Human based ground and
aerial inspections
Augment with computer
automated analysis to
identify vegetation
encroachment and
structural defects
Allows for scenario based
planning of treatment
options and serves as the QA
tool to assess the efficacy of
previous field work
Fuel Reduction Partnerships No formal program Partnering with Fire
Agencies to remove fuels
near critical infrastructure
Strengthens relationships
between Avista and fire first
responders and reduces fire
severity threats to
infrastructure

Widen Transmission Rights-
of-way
No formal program Align right-of-way
boundaries to fire risk
potential
Protect critical infrastructure
and serve as fire break
Annual Risk Tree Cadence based program
(e.g. 1-3 years)
System-wide effort to
annually identify and
remove dead, dying, and
diseased trees
Reduce tree fall-ins, which
are 3 times more likely to
occur than grow-ins
Public Outreach “Right Tree,
Right Place” Campaign
General information
available to all customers
Work with customers in
elevated fire risk areas to
remove tall growing trees
from underneath powerlines
Reduces the risk of tree
grow-ins and subsequent
spark-ignition sources

Situational Awareness
Recommendation Current State Future State Benefits
Fire-Weather Dashboard Weather forecast data
subject to individual
interpretation
By combing weather
forecast and fire threat
condition data, operating
personnel will have clear
guidance relative to
likelihood and potential
impact of fires
Promotes a more consistent
approach among operations
and emergency managers
Additional Distribution
Circuit Reclosers
Based on system protection
and reliability performance
Deployed in elevated fire
threat areas. Reflects a risk-
based strategy
Supports the evolution of
Avista’s Dry Land operating
mode to align with
forecasted weather and fire
threat conditions
Substation Supervisory
Control & Data Acquisition
(SCADA)
SCADA added to new or
reconstructed substations.
Reflects a condition based
approach
Enables control and
monitoring of substation
equipment including circuit
reclosers in elevated fire risk
areas
(as stated above)

Operations and Emergency Response
Recommendation Current State Future State Benefits
Emergency Operating
Procedure & Avista Incident
Command Representative
No formal wildfire policy Avista EOP to delineate
wildfire from other storm
events. Avista to offer
assistance at all fire ICS.
Coordinate Avista system
restoration with fire
protection and evacuation
activities
Wildfire Performance
Metrics
None Develop fire-specific
performance metrics to
ensure that Plan objectives
are being met
Supports the adaptation of
the Resiliency Plan to meet
current operating and
environmental conditions
Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 1, Page 26 of 67
Operations and Emergency Response
Recommendation Current State Future State Benefits
Wildland Urban Interface
(WUI) map
Developed in Q3/2019 Categorize Avista T&D
infrastructure with respect
to fire ignition potential and
fire impact consequence
Focuses vegetation
management and grid
hardening efforts in the
highest fire risk areas
Emergency first responder
training
No formal program Annual fire safety training to
Avista field personnel and
electrical hazard training to
fire protection personnel
Promotes safety of first
responders and supports a
variety of partnering
activities including fuel
reduction and fire adapted
communities
Expedited Fire Response Draft MOU under
consideration with Spokane
Fire Districts
(2020 Pilot Project)
Fire agency personnel to
investigate transmission line
faults during fire season
Suppress fires before they
have an opportunity to
spread

Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 1, Page 27 of 67
Plan Recommendations by Category
Grid Hardening & Dry Land Mode
Nearly 10% of Avista distribution outages are related to equipment and
conductor failures. These include transformers, overhead conductor,
connectors, insulators, and larger equipment like circuit reclosers and
voltage regulators. Over 600 outages per year occur due to these
failures. Recent data from the California State Fire Authority (CAL FIRE)
indicates that over 1,000 utility involved fires occurred in California
during 2018. The breakdown of that data is shown below and indicates
that 38% of utility events were related to utility equipment. CAL FIRE
estimates that utility ignition sources account for approximately 10% of
wildfires across the state, while data from Washington State indicates a range of 4-6% for the Pacific
Northwest region.17 Though the contribution is relatively low, wildfires are increasing in both size and
number across the western United States, and represent a significant risk to companies.
Currently, Avista does not track fire ignition events
associated with transmission or distribution line
faults. As noted, Avista’s Outage Management
System (OMS) is the system of record for T&D
customer outage records, and, in many instances,
forms the basis of fire probability used in this
report.

Between 2014 and 2018 the breakdown of Avista’s
distribution system outages is summarized in the
table on the left. Based on this information and
subsequent risk analysis, the grid hardening
objectives are:
1. Reduce the number of spark ignition
events on the distribution system
(Event Probability)
2. Reduce wildfire impact to transmission
lines (Event Outcome)

17 Western Utility Commission Wildfire Seminar, Portland OR, April 2019
2018 California Utility Involved Fires
(source: CAL FIRE) # of ignitions
Vegetation Contact 552
Equipment 151
Downed Wire 218
Fuse 35
Animal 117
Total 1,073

Annual Avista Electric Distribution
Unplanned Outages
(source: Avista 2014-2018 OMS Data)
Vegetation Contact 6.2%
OH Equipment/Conductor 9.5%
Pole Fire 1.5%
Public Fire 2.1%
Wind 26.1%
Animal 9.0%
Car Hit Pole 2.8%
Storm Related & UG 42.7%

As part of the Wildfire
Resiliency Plan, Avista will
track fire ignition data
associated with powerline
electrical faults.
Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 1, Page 28 of 67

As part of Wildfire Resiliency, Avista will focus grid hardening efforts in the Wildland Urban Interface
Tier 2 and 3 areas (elevated fire risk). The program includes:
• Transmission Wood Pole Fire Retardant Protection (Fire-Mesh Wrap)
• Transmission Line Fire Inspection Program
• Transmission Grid Hardening (Wood to Steel Pole Conversion)
• Dry Land Mode engineering review
• Dry Land Mode standing operating procedure (initiating)
• Distribution Midline Recloser in WUI Areas
• Distribution Grid Hardening
Grid hardening efforts reflect the bulk of capital investment in the Wildfire Resiliency Plan. On average,
equipment and conductor failures account for 10% of all forced outages and reducing those outages is a
primary objective of this Plan. Many sources of powerline outages are difficult to control, including
winter storms, strong wind events, thunderstorms, and public caused outages including vehicular
accidents and trees that are felled through powerlines. However, by upgrading powerline conductor and
equipment, these failures are manageable and represent a cost effective means to reduce the overall
number of spark-ignition events. Take for instance, pole fires.
The mechanism that causes pole top fires is well-known and is related to insulator leakage current which
increases during periods of hot, dry weather when insulators become covered with dust and other
contaminants. This leakage current can be concentrated between wood to wood contacts such as the
contact point between wood crossarms and wood poles. In the early 2000’s, Avista began using
fiberglass crossarms and this has virtually eliminated fires on poles with the new fiberglass crossarms. As
part of Wildfire Resiliency, wood crossarms on structures located in elevated fire areas will be replaced
with fiberglass units. Grid hardening risk levels and costs are summarized in the table below.

Grid Hardening & Dry Land Mode operations 2020-2029
Inherent Risk Exposure (category %) 41-100
Managed Risk Exposure (category %) 0.7-2.7
Risk Mitigation (average %) 98%
Total Operating Expense $5,014,000
Total Capital Investment $245,600,000

Various internal reports including the Wildfire Summary Risk Analysis and Wildfire Resiliency Cost Plan
included a numbering system used to track individual Plan elements. For example, the Plan element
designated as “D-16/17 Distribution System Grid Hardening” is described on the next several pages.
That numbering system is maintained throughout this report to assist with continuity between various
internal reports and datasets.

Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 1, Page 29 of 67
D-16/17 Distribution System Grid Hardening
Recommendation: Replace aging and obsolete equipment
in elevated fire risk areas
(40% System)
Cost: $23,000,000/year Capital Investment
($193,200,000 total over 10 years)
Benefit: Reduced fire events caused by Avista’s
electric distribution system.

Distribution grid hardening represents the single largest infrastructure investment in this Plan. Pole fires,
together with equipment failures, can potentially be reduced by replacing aging and deteriorated poles,
equipment, and conductors. Though Avista has well-established programs to replace poles, conductor,
and equipment, existing programs are condition-based and aligned with reliability objectives. Wildfire
grid hardening objectives are focused on reducing the number of spark ignition events. The following
activities are included in the distribution grid hardening plan:
• Replace wood crossarms with fiberglass units
• Remove small copper wire
• Install wildlife guards (e.g. fuse holders, lightning arrestors, and transformer bushings)
• Replace wood poles with steel poles at ‘high value’ locations
(e.g. highway crossings, corner poles, and heavy equipment poles)
• Eliminate open wire secondary districts
• Install wedge/bail clamps at hot tap connection points
Pole fires are a significant contributor to wildfire risk. Each year there are approximately 90 pole fires on
Avista’s distribution system, and the vast majority are related to wood on wood contact between
crossarms and poles.

The combination of wood poles with
fiberglass crossarms rarely cause pole top
fires. This is a proven tactic for reducing
the risk of utility involved fires and is a
component of distribution grid hardening.

Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 1, Page 30 of 67
Avista adopted the use of fiberglass crossarms in the early 2000’s and has been replacing wood units
steadily since that time. However, many wood crossarms remain on the system. By replacing wood
crossarms in elevated fire risk areas, the number of pole fires can be significantly reduced. Of the grid
hardening efforts listed above, this is the most cost effective treatment to reduce fire risk. The following
table lists current outage rates for each treatment. The data is from the 2014-2018 operating period and
reflects an annual rate.

Material Unit Outage Driver Annual Outage
Rate (#/yr.)
% of System
Outages
Wood Crossarms Pole Fires 92 1.5%
Small Copper Wire Primary Conductor
Failures
81 1.3%
Wildlife Guards Animal related outages 557 9.0%
Secondary Wire
Districts
Secondary Conductor Failures 101 1.6%
Hot Tap Connection Primary Connector Failures 69 1.1%
Totals 1,087 14.5%
Source Avista OMS 2014-2018

Risk Evaluation: Distribution Grid Hardening
D-16/17: Distribution Grid Hardening 2020-2029
Inherent Risk Exposure (category %) 39.3-94.5
Managed Risk Exposure (category %) 0.3-1.9
Risk Mitigation (average %) 98%
Total Capital Investment $193 million

D-13 Additional Dry Land Mode Circuit Reclosers
Recommendation: To install additional circuit reclosers in elevated fire threat areas
(40% System)
Cost: $600,000 Capital Investment ($5,400,000 total over 10 years)
$44,400 Operating Investment ($444,000 total over 10 years)
Benefit: Provide protection schemes that can adjusted for the wildfire threat
based on the operating location.

Midline circuit reclosers are often deployed on long distribution lines where substation-based
equipment cannot adequately protect the entire length of the circuit. Urban distribution lines are
typically 5 to 10 miles in length, while rural counterparts can extend hundreds of miles. As noted, Avista
is evaluating its current dry land program and, although that work is on-going, there is consensus that
additional equipment will help delineate elevated fire threat and non-WUI areas. It is estimated that
upwards of 75 modern reclosers will be installed on the system, which is approximately one additional
Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 1, Page 31 of 67
recloser for every two rural distribution circuits. The situation is illustrated on the following page where
elevated fire threat areas exists near the end of a distribution line.

By adding circuit reclosers at strategic locations, Avista Distribution Operations can re-task those devices
during periods of elevated fire danger to operate in fire protection mode rather than reliability mode. A
proposed scheme is illustrated in the block diagram below.

D-6 Dry Land Mode Effectiveness Study
Recommendation: To conduct an engineering review of Avista’s Dry Land Mode protection
scheme (in-process since March 2020)
Costs: $100,000 Operating Expense (2 year engineering review)
Benefit: More timely and responsive protection schemes that minimize fault
energy and reduce the potential to start a wildfire.

During fire season, Avista operates a significant portion of the distribution system in what is referred to
as Dry Land Mode (DLM). Electric circuits in DLM mode are operated with auto-reclosing and
instantaneous overcurrent tripping disabled. In this configuration, faults that occur on lateral circuits are
Avista has used a summer operating
strategy or “Dry Land Mode” since the
early 2000’s. Avista anticipates adapting
DLM to fire threat conditions and re-
tasking circuit reclosers to align with field
conditions.
Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 1, Page 32 of 67
cleared through fuse action while faults on trunk segments are cleared via circuit reclosers. During the
Avista wildfire workshops, engineers agreed that the dry land operating system could be improved. A
small work group was formed including several area engineers, the manager of protection engineering,
and electric servicemen. The group is expected to issue recommendations prior to the 2020 fire season.
Most Avista circuit reclosers are configured with three automatic breaker trips and two reclose settings.
Normal and DLM modes are illustrated below.

Normal Configuration DLM

The initial recloser trip is generated via instantaneous overcurrent relay and accounts for only 5-10% of
total fault energy. The remaining recloser trips occur via time-delay relays and are coordinated with
downstream fuse devices. If the fault is located downstream of a fuse, the fuse will blow and isolate the
faulted segment. However, if the fault is located on the main trunk line, the circuit recloser will go
through the automatic trip-reclose sequence to a final open, or lock-out condition. As the illustration
suggests, by limiting the circuit recloser to a single, time-delay trip, fault energy can potentially be
reduced by up to 60%.

3rd Trip
(Time Delay)
40-45%
Fault Energy
2nd Trip
(Time Delay)
40-45%
Fault Energy
Initial Trip
(Fast)
10-20%
Fault Energy
Auto
Reclose
Auto
Reclose
Circuit
Open
Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 1, Page 33 of 67
D-8 Dry Land Mode Trigger
Recommendation: To develop a fire threat index to determine when Avista initiates Dry
Land Mode (complete, June 2019)
Costs: $2,000 Operating Expense per year ($20,000 over 10 years)
Benefit: System operations that are consistent with wildfire risk.

In 2019, Avista’s Technical Services group created a system to
gather information from the Wildland Fire Assessment System
(WFAS)18 and used that information to determine when the
distribution system would be set to dry land conditions. The DLM
“trigger” was established as:
1) When 30% of Avista’s Electric Operating area is designated
as “High” fire threat, or
2) When 10% of the operating area is designated as “Very
High”
By providing a clear metric, Avista aligns its operations with fire threat conditions.

Risk Evaluation: Dry Land Mode Operating Program (D-6, D-8, and D-13)
Dry Land Operating Program 2020-2029
Inherent Risk Exposure $43-69.6 million
Managed Risk Exposure $6.2-17.4 million
Risk Mitigation (average %) 83%
Total Operating Expense $564,000
Total Capital Investment $5.4 million
18 Wildland Fire Assessment System (USFS), Missoula MT, wfas.net
The GIS Technical Services group
created a fire threat index map for
electric operations. This daily report
for July 18, 2019 is shown for the north
and south operating areas. Areas
indicated with yellow, orange, and red
highlights are associated with High,
Very High, and Extreme fire danger.

Data Source: USFS/WFAS, Missoula
Montana
Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 1, Page 34 of 67
ST-12 Transmission System Grid Hardening
Recommendation: To convert wood poles to steel structures in elevated fire threat areas
(20% System)
Cost: $5,000,0000 Capital Investment ($44,000,000 total over 10 years )
Benefit: Reduce the impact of wildfire on Avista’s operating system.

Avista began installing tubular steel transmission poles in the late 1980’s, with full adoption of steel as a
standard material item in 2006. Since then, reconstruction projects have converted a number of circuits
from wood to steel, and that trend will continue. Though Avista is committed to steel conversion, one of
the objectives of the Wildfire Resiliency Plan is to accelerate that process in fire prone areas. The largest
capital transmission investment in this Plan is wood to steel conversion, at a cost of $44 million dollars
over a 10-year period. As noted, a significant risk to transmission lines is the impact from wildfires.

Risk Evaluation: Transmission Grid Hardening (Wood to Steel Pole Conversion)
ST-12: Transmission Grid Hardening 2020-2029
Inherent Risk Exposure (category %) n/a
Managed Risk Exposure (category %) n/a
Risk Mitigation (average %) n/a
Total Capital Investment $44 million

Avista’s 230 kV system was initially built
in the late 1950’s and early 1960’s, after
the construction of the Noxon Rapids
and Cabinet Gorge dams. In 2003,
portions of the system were upgraded as
part of the West of Hatwai agreement
with Bonneville Power. Several wood
lines were converted to steel during that
time period including:

Beacon-Boulder-Rathdrum
Benewah-Shawnee (new line)
Beacon-Bell #5

The average age of transmission
wood poles is 54 years (2020 data).
Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 1, Page 35 of 67
ST-10 Transmission Inspection Program
Recommendation: To conduct annual fire threat assessments of the transmission system
Cost: $200,000 Operating Expense ($2,000,000 total over 10 years )
$300,000 Capital Investment ($3,000,000 total over 10 years)
Benefit: Identify and repair system defects prior to failure.

Visual inspection of assets is a fundamental tenet of any preventative maintenance plan. This is a widely
accepted process for generation power plants and electrical substations, but inspection of thousands of
miles of powerlines presents unique challenges. Transmission Engineering has conducted annual aerial
inspections for many years, and Avista will continue to leverage that experience. By identifying defects
before they present as equipment failures, inspections help to minimize fire ignition events. While
current programs are geared towards identifying reliability risks (e.g. Osprey nests, gunshot insulators,
cracked crossarms, woodpecker damage, etc.), a wildfire based approach focuses attention on other
factors:
A. Logging or other construction activities near
powerlines
B. Excessive conductor sag over agricultural or roadway
areas
C. Corroded attachment hardware
D. Disruptions or changes to the ground profile
E. Unauthorized attachments or encroachments
F. Thermal issues (e.g. hot splices or connectors)
G. Wood debris slash piles in right of way

This list is not intended to be a complete list, but rather to
contrast the differences between conventional inspections
based on reliability and those focused on preventing utility
involved wildfires.

Risk Evaluation: Transmission Inspection
ST-10: Transmission Inspection Program 2020-2029
Inherent Risk Exposure $4-59 million
Managed Risk Exposure $1.1-2.6 million
Risk Mitigation (average %) 94%
Total Operating Expense $2 Million
Total Capital Investment $3 Million

Increasingly, UAVs or Drones are
being used to inspect powerlines.
Avista plans to deploy this technology
as part of Wildfire Resiliency.
Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 1, Page 36 of 67
ST-6 Transmission Wood Pole Fire Retardant Protection
Recommendation: Wrap wood poles with a fire-resistant material.
Cost: $250,000 Operating Expense ($2,450,000 total over 10 years )
Benefit: Protect wood poles in grassland areas from the impacts of fire.

Fire damage to the Lolo-Oxbow 230 kV line in the early 2000’s prompted Transmission Engineering to
initiate a fire retardant (FR) wood pole painting program. Wood transmission structures are painted
near ground line, which is an effective means of preventing damage caused by ground fires. Though
Avista has experience with Osmose ‘Fireguard’, the paint product must be reapplied every three to five
years and the maintenance expense is on-going.
Avista has participated in a number of peer utility forums including Western Energy Institute’s Wildfire
Task Force.19 At that meeting, Southern California Edison (SCE) discussed their work with Genics
Corporation to develop a wire mesh product that is chemically reactive to extreme heat. As of this
writing, SCE has installed Fire-Mesh on over 1,300 poles and plans to fire wrap 20,000 more poles in
2020. Avista will adopt this program as part of their effort to protect transmission system wood poles
from the impact of grassland fires.

Risk Evaluation: Wood Pole Fire Retardant Protection
ST-6: Wood Pole FR Mesh-Wrap Protection 2020-2029
Inherent Risk Exposure $9.6-28 million
Managed Risk Exposure $4.3-4.8 million
Risk Mitigation (average %) 76%
Total Operating Expense $2.45 Million

19 Western Energy Institute Wildfire Meeting, July 19-20,2019, SDG&E

On March 3rd, 2020, Avista
conducted a field test of the Genics
Fire-Mesh product. An FR wrapped
pole was subjected to a 30-minute
fire and sustained only minor
damage. Unlike FR paint, this mesh
product does not require on-going
maintenance and can be applied
much more easily than paint.
Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 1, Page 37 of 67

Enhanced Vegetation Management
Vegetation management is an integral part of maintaining overhead
electric distribution and transmission lines. Historically, utilities have
trimmed and removed trees with a focus on improving reliability and
reducing the frequency of outages. With the increasing threat of
wildfires as a result of poor forest health, past fire suppression
activities and periods of prolonged drought, Avista plans to enhance
vegetation management practices especially in elevated fire threat
areas.
For the five year period from 2014 to 2018, there were nearly 2,000
tree related events on Avista’s electric distribution network.20 Though
tree induced fire outcomes are not specifically tracked, consensus
among Avista operating personnel suggests that vegetation contacts
with overhead powerlines represent a significant fire hazard. This is
consistent with other utility risk assessments.
This Plan recommends the following enhanced vegetation management activities:
• Transmission and distribution system digital data collection (LIDAR)
• Fuel reduction partnerships
• Widening transmission rights of way
• Annual risk tree surveys
• Review and support of the Right Tree, Right Place customer safety initiative

The ten year cost forecast to implement a fire-informed, enhanced vegetation management program is
approximately $51 million dollars and will supplement current maintenance activities. These wildfire
specific vegetation management activities would be implemented in addition to, not in place of, the
regular five-year vegetation management cycle to maintain system reliability. The forecast of risks and
investments is summarized below.
Enhanced Vegetation Management 2020-2029
Inherent Risk (range %) 48.3-100
Managed Risk (range %) 3.2-14.5
Risk Mitigation (average %) 88%
Total Operating Expense $51.2 Million
Total Capital Investment $5.1 Million

20 Avista Outage Management System, 2014-2018 dataset
2014 Windstorm Damage
North Spokane
Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 1, Page 38 of 67

D-10 Electric Distribution Annual Risk Tree
Recommendation: To identify and remove dead, dying, and diseased trees, or ‘risk trees’
adjacent to distribution lines. (100% System)
Cost: $2,500,000 Operating Expense ($25,500,000 total over 10 years )
Benefit: Reduce interaction between vegetation and Avista’s distribution
facilities.

In order to identify ‘at-risk’ trees, Avista plans to use a
combination of traditional, ground-based inspections and
aerial digital data collection. By identifying trees that are
dying or diseased, Avista can remove those trees that
represent a fall-in risk to nearby powerlines.
In total, 40% of Avista’s distribution system is located in
elevated fire risk areas (see the WUI map on the following
page). During the five year period between 2014 and 2018,
603 trees fell into electric distribution lines during the late
spring and summer months (May-September). In total, trees
account for nearly 400 outages per year with fall-in events
outnumbering grow-ins by nearly a 3 to 1 margin. In short,
most tree related outages are caused by trees located
outside of the right-of-way falling into powerlines. And,
vegetation contacts during periods of moderate to high
winds represent a significant contributor to the fire risk
profile. This is a combination that the Wildfire Resiliency
Plan aims to mitigate.
Forests face an increasing threat of insects, drought, and poor
land management. A warming climate is contributing to these
factors and there is general consensus among foresters that
significant stem loss will occur over the next several decades.
The 2017 USDA Forest Health report includes drought
statistics that indicate wide-spread drought conditions from
2015-2017 Precipitation 2015-2017 Precipitation
2013-2017 Precipitation
Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 1, Page 39 of 67
2015 to 201721, with many areas rated as severe to extreme (see illustration). One might observe that
this is only a 3-year period and not indicative of an underlying trend. However, data from the 5-year
period from 2013 to 2017 indicates an even deeper drought, especially throughout California and the
desert southwest.

Risk Evaluation
The risk of trees falling into powerlines represents a significant financial cost, with the 10-year inherent
risk estimated that exceeds $2.8 dollars. The risk and cost-benefit estimates are indicated below.
D-10: 100% Annual Risk Tree Program 2020-2029
Inherent Risk Exposure (category %) 21.8-44.3
Managed Risk Exposure (category %) 2-9.5
Risk Mitigation (average %) 83%
Total Operating Expense $25.5 Million

21 U.S. Department of Agriculture, fs.fed.us/foresthealth/publications/conditionsreport_2017.pdf
Wildland Urban
Interface (WUI)
Avista’s WUI map indicates the
potential for utility caused wildfires
and their impact to homes and
communities. It also represents
where treatment plans will be
targeted. Elevated fire threat is
noted as the Tier 2 (orange) and Tier
3 (red) areas and encompasses 40%
of Avista’s electric distribution
system.
Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 1, Page 40 of 67
D-11 Public Safety Initiative: “Right Tree, Right Place”
Recommendation: To contact customers located in elevated fire threat areas and work
with them to remove tall growing trees near powerlines (40% System).
Cost: $1,000,000 Operating Expense ($9,600,000 total over 10 years )
Benefit: Reduce interaction between vegetation and Avista’s operating system.

“Right Tree, Right Place”
Avista currently supports an approach to vegetation management called “right tree, right place.”
Through this approach, Avista seeks to educate landowners about utility-compatible trees, and
publishes a brochure, which states, “Avista provides a no-cost inspection and mitigation to make the
following certain tree-related situations safe.” The brochure includes a graphic (above) indicating that
only Type I, low growing, trees should be planted near powerlines.
In the five year period from 2014 to 2018, there were 322 tree ‘grow-in’ incidents during the fire season
(May-September). Like tree fall-ins, these incidents tend to happen during windy days and thus elevate
the risk of starting and spreading a fire.
From a wildfire resiliency perspective, there is opportunity to build on and reshape this program, which
may include additional agency partnerships and public outreach, to minimize the fire-related risks
presented by trees coming into contact with Avista’s electric system.
By partnering with fire agencies, such as Washington Department of Natural Resources and the Idaho
Department of Lands, Avista can reach residents living in elevated fire threat areas and work with them
Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 1, Page 41 of 67
to remove incompatible trees. By incentivizing owners to remove tall growing trees, Avista can reduce
the risk of fire and the need to trim trees in the
future.
It is recommended that a “right tree, right place”
program be established similar to Avista’s energy
efficiency rebate program. It would allow
customers to submit a request and select from a
list of qualified contractors. This would ease the
burden on internal resources and encourage local
tree trimmers to become line clearance certified.
In this Plan, the recommendation would focus on
areas associated with elevated fire risk. An
additional element of this program would be
partnership with fire agencies, such as Washington
Department of Natural Resources and the Idaho
Department of Lands, and to work with agency
partners to create fire-adapted communities.

Risk Evaluation
Trimming customer owned trees is a known dissatisfier. Customers sense a loss of control and perceive
the activity as ‘happening to them’ rather than ‘occurring for them’. By providing customers with a
choice about removing trees, we promote a partnership focused on fire prevention rather than utility
operations.

D-11: Right Tree, Right Place Campaign 2020-2029
Inherent Risk Exposure $563-1,145 million
Managed Risk Exposure $2.3-28.2 million
Risk Mitigation (average %) 98%
Total Operating Expense $9.6 Million

Type 1 low growing trees are compatible with utility
overhead powerlines and pose little or no threat to
their operation.
Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 1, Page 42 of 67
D-14 Distribution Digital Data Collection
Recommendation: Annual digital surveys of the elevated fire threat areas. Includes
computer post processing (40% System).
Cost: $1,000,000 Operating Expense ($7,750,000 total over 10 years )
Benefit: Identify conflicts between vegetation and system structural defects.

This element is similar in scope and function to
ST-5 “Transmission Digital Data Collection”
whereby LIDAR surveys, high resolution
photography, and infrared images would be
collected on Avista’s overhead distribution lines.
The project scope is limited to elevated fire
threat areas.
Avista operates 7,600 miles of overhead primary
distribution lines, and nearly 40% of those
facilities are located in elevated fire threat areas.
However, unlike transmission, distribution lines
have lateral, branch circuits that make aerial
surveys difficult. Ground based techniques,
similar to Google Earth’s Street View Project,
may be deployed in combination with
conventional and drone aircraft.
Avista maintains distribution vegetation on a five year cycle, or about 20% of the system per year. This
includes trimming trees and removing trees. This is a reliability-based approach generally known as
‘routine maintenance’. By deploying annual digital inspections, Avista will transition towards a more
‘risk-informed’ approach combining elements of fire threat risk (i.e. WUI Map and Infrastructure Health
Index) with the volume of vegetation and the proximity to energized lines and equipment. Though this
treatment is justified solely on its ability to identify potential vegetation conflicts, high resolution
photography and infrared imagery also support structural inspections. A number of use cases have been
identified.

Electric Distribution Outage Rates
(Events/Year)

10% 600 Overhead Equipment Failures
6.5% 400 Tree Related
3% 200 Underground Equipment
50% 3,100 Wind & Weather
30.5% 1,890 Other Sources

(Source data: Avista outage management system
2014-2018)
Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 1, Page 43 of 67

Risk Evaluation
Annual risk tree and digital data collection rank at the top of treatment options to reduce the
opportunity for powerline fire ignitions. Maintaining an accurate inventory of both infrastructure and
vegetation in the elevated fire threat areas is a critical component of fire resiliency.

D-14: Distribution Digital Data Collection 2020-2029
Inherent Risk Exposure (category %) 21.8-44.3
Managed Risk Exposure (category %) 1.0-4.4
Risk Mitigation (average %) 92%
Total Operating Expense $7.75 Million

Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 1, Page 44 of 67
ST-5 Transmission System Digital Data Collection
Recommendation: Annual digital survey of the transmission system (100%).
Cost: $750,000 Operating Expense ($6,825,000 total over 10 years )
Benefit: Identify potential conflicts with vegetation and structure defects.

Avista operates 700 miles of 230 kV
and 1,570 miles of 115 kV
transmission lines throughout
eastern Washington, northern
Idaho, and western Montana.22
Vegetation management of the
transmission grid is subject to NERC
regulation FAC-003-4 which
requires that all 230 kV and select
115 kV circuits be patrolled
annually to assess vegetation
growth both in the right-of-way
(encroachment) and adjacent to the
right-of-way (fall-in risk). Since
2006, Avista has conducted annual
aerial patrols as part of the
Company’s Transmission
Vegetation Management Plan
(TVMP).23 The regulatory focus on
transmission has helped reduce conflicts between vegetation and powerlines, and adding fire-informed,
risk-based elements to existing programs, Wildfire Resiliency aims to build upon that success.
Increasingly, utilities are using LIDAR (light detection and ranging) to assess vegetation encroachment of
overhead powerlines. The ability to collect survey data via an aerial platform is a significant advantage
over ground-based techniques. This technology is helping vegetation managers identify, prescribe
treatments, and audit field work using machine learning computer algorithms.
Since transmission lines are linear features and located within established corridors, data can be
collected via fixed wing aircraft equipped with multiple instruments including LIDAR, Hi-Resolution
cameras, and near-infrared detectors.
By collecting data annually, Avista vegetation and asset managers can detect changes from year to year,
including unauthorized encroachments, as well as assess the proximity to vegetation, and quantify the
risk of tree fall-ins. Transitioning from human based inspections to digital data collection will have a
substantial impact on data accuracy, work processes, productivity, and record keeping.
22 2019 Avista Quick Facts
23 Avista Transmission Vegetation Management Plan, see Addendum
Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 1, Page 45 of 67
Risk Evaluation
The relatively low risk of contact between vegetation and transmission lines reflects Avista’s
commitment to comply with NERC regulation FAC 003-4. Between 2014 and 2018, only 21 tree related
outages were reported on the transmission system.24 Though collecting digital data will improve our
ability to identify both tree grow-in and fall-in risks, benefits extend beyond vegetation management
and include the ability to automate the structure inspections, detect thermal hot-spots, and conduct
field work audits.
ST-5: Transmission Digital Data Collection 2020-2029
Inherent Risk ($) $9.6 - $17.7 Million
Managed Risk ($) $0.9 - $2.4 Million
Risk Mitigation (average %) 88%
Total Operating Expense $6.8 Million

ST-9 Conforming Transmission Rights-of-Way
Recommendation: Widen transmission line rights-of-way in elevated fire risk areas
(20% System)
Cost: $500,000 Capital Investment ($5,000,000 total over 10 years )
Benefit: Reduce interaction between vegetation and Avista’s transmission
facilities.

Typically, transmission line corridors are established via
negotiations with private landowners and include a centerline
description and specify width (e.g. 50-100 feet wide). Avista
transmission lines have standard width requirements:
• 230 kV – 100 feet
• 115 kV H-frame (2 pole) – 60 feet
• 115 kV single pole – 50 feet
Although, variations exist in particular circumstances, standard
corridor widths provide sufficient clearance between conductors
and adjacent vegetation. However, some historic transmission line
easements do not meet today’s standards and elevate the risk of
vegetation contacts. Likewise, transmission circuits located in
public road rights-of-way do not necessarily allow Avista to
manage vegetation on adjacent properties.
The photograph on the right shows a 115 kV line routed along US
Highway 95 near Hayden, Idaho. Trees located on the adjacent property cannot be managed without
24 Avista Outage Management System, 2014-2018 dataset
CDA-Rathdrum 115 kV along US Hwy 95
Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 1, Page 46 of 67
owner consent. By addressing these areas through easement acquisition, Avista reduces vegetation
risks.
Risk Evaluation
At the time of this report, Avista has not conducted a complete inventory of corridor agreements. It is
important to note that easements obtained prior to 1950 are generally ‘non-width specific’. Although
courts have interpreted these easements as conforming to current standards, the risk of disputes with
adjacent landowners still exist. Likewise, circuits located on public road rights-of-way do not allow for
vegetation management on adjacent properties.
While the cost-benefit ratio for this activity is relatively low, benefit calculations from the fire risk
workshops did not take into account the ability to maintain and reconstruct facilities. Expanding corridor
‘rights’ drives benefits that go beyond the risk of wildfire.
ST-9: Conforming Transmission Rights-of-Way 2020-2029
Inherent Risk Exposure $4.8 - $8.8 Million
Managed Risk Exposure $0.2 - $1.4 Million
Risk Mitigation (average %) 88%
Total Capital Investment $5 Million

ST-7 Fuel Reduction Partnerships
Recommendation: Participate in annual fuel reduction efforts conducted by the local Fire
Districts (e.g. Washington DNR, Idaho IDL)
Cost: $167,000 Operating Expense ($1,500,000 total over 9 years )
Benefit: Reduce fuel loading near operating facilities and strengthen working
relationships with fire first responders.

The Washington Department of Natural Resources (DNR) has embarked on a 20-year plan to improve
forest health on 2.7 million acres of forest land in central and eastern Washington. As Hilary Franz,
Washington Commissioner of Public Lands, states: “We have a forest health crisis in our state……. Hot,
dry conditions coupled with diseased and dying forests are leading to explosive wildfires.”25 In 2017, a
record number of wildfires (1,850) cost Washington taxpayers over $150 million in suppression costs
alone. Since 1970, both the number and size of wildfires has increased substantially. The United States
Forest Service (USFS) estimates that large fires have tripled in number since 1970 and the length of the
wildfire season is now 100 days longer.26
25 Internet Website: dnr.wa.gov
26 Climate Central, Western Wildfires, 2016
Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 1, Page 47 of 67
By partnering directly with fire protection
agencies including the Washington Department
of Natural Resources and the Idaho Department
of Lands, Avista plans to work alongside forest
thinning and brushing crews to remove excess
fuels and to reduce the severity of future fires.
Projects that remove fuels near critical
infrastructure such as the Beacon Hill area (see
photograph) are an opportunity to both reduce
fire risk and to strengthen relationships
between Avista and fire protection personnel.
Over the course of Plan development, Avista has
met with several fire protection agencies and a
recurring theme has emerged: It is important
that Avista operating personnel maintain strong
working relationships with local and state fire
agencies. This Plan contains opportunities to strengthen those relationships through joint training and
simulation exercises, joint efforts to promote fire-adapted communities, and through fuel reduction
projects.
The following graph illustrates the correlation between hotter summers and large fires on federal lands.
While Federal and State efforts to improve forest health involve widespread thinning and prescribed
burns, Avista’s approach will target areas adjacent to critical infrastructure and be performed in
conjunction with local fire districts. Recent work with local fire districts, together with the Idaho
Department of Lands and Washington DNR, have already identified several potential projects.

In 2018, a fire erupted on Beacon Hill near Avista’s main office
building and threatened several transmission circuits. Residents
were evacuated as the fire spread to over 100 acres. Over 50
fire engines responded to the blaze.

IN IDAHO, THE NUMBER OF
LARGE FIRES ON FEDERAL
LANDS HAS INCREASED
FROM 10 (1970) TO OVER 30
PER YEAR.
IN 2009, OVER 1.5 MILLION
ACRES OF FEDERAL LANDS
WERE IMPACTED BY
WILDFIRES IN IDAHO.
Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 1, Page 48 of 67
Risk Evaluation
While Avista cannot reasonably marshal resources to impact forest health on a landscape level, it can
support local efforts to conduct mechanical thinning and prescribed burns. Avista plans to invest
$150,000 annually to assist with local efforts to reduce fuel loading.
ST-7: Fuel Reduction Partnerships 2020-2029
Inherent Risk Exposure $15 - $29 Million
Managed Risk Exposure $3 - $29 Million
Risk Mitigation (average %) 27%
Total Operating Expense $1.5 Million

D-4 Incorporating Vegetation Management into Distribution Designs
Recommendation: Incorporate vegetation clearing into distribution design packages
(addition to work process)
Cost: $10,000 capital labor ($100,000 total over 10 years )
Benefit: Reduce interaction of vegetation with Avista’s distribution facilities.

During the Avista Wildfire Risk Workshops, participants cited examples of electric distribution designs in
conflict with existing vegetation. By incorporating vegetation treatment into the design process,
potential conflicts are addressed prior to construction. This is largely a training exercise for the
Construction Project Coordinator (CPC) department, but does add to the overall design effort and
requires coordination between construction and vegetation management functions.
Risk Evaluation
D-4: Incorporating Vegetation Management into
Distribution Designs 2020-2029
Inherent Risk Exposure $20 - $278 Million
Managed Risk Exposure $10 - $21 Million
Risk Mitigation (average %) 90%
Total Capital Investment $100,000

Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 1, Page 49 of 67
Situational Awareness
The ability to monitor and control electric transmission and distribution equipment is critical when
responding to wildfires. This effort will leverage existing systems including Transmission SCADA
(supervisory control and data acquisition), Distribution DMS (distribution management system), and AMI
(automated meter infrastructure or “smart meters”). These systems are known technologies and offer
scalable opportunities to enhance wildfire resiliency.
In addition to leveraging existing systems, Avista will develop a “Fire-Weather” dashboard, combining
elements of weather forecasting and fire threat assessment. This computerized system will help system
operators, district managers, and area engineers make informed decisions related to fire risk potential
and estimated fire impact spread & severity.
Avista’s Wildfire situational awareness plan consists of three elements:
• Fire-Weather Dashboard
• Substation Supervisory Control & Data Acquisition (SCADA)
• Distribution Midline Equipment Communications

The 10-year cost to fully implement these treatments is $19 million dollars and may mitigate the current
state categorical risk by as much as 98%. A summary forecast of costs and risks are shown below.
Situational Awareness 2020-2029
Inherent Risk Exposure $151 – $585 Million
Managed Risk Exposure $5 - $7 Million
Risk Mitigation (average %) 98%
Operating Expense 2020-2029 $1 Million
Capital Investment 2020-2029 $18 Million

Fire-Weather Dashboard Midline Communications Substation SCADA
Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 1, Page 50 of 67
D-15 Substation SCADA
Recommendation: To retrofit supervisory control and data acquisition systems (SCADA)
into elevated fire risk area substations (40% Distribution System).
Cost: $2,000,000 Capital Investment ($17,000,000 total over 10 years)
$9,700 Operating Expense ($97,000 total over 10 years)
Benefit: Provide ability to adjust protection equipment based on the imminent
fire risk and weather conditions.

Supervisory Control and Data Acquisition systems or
SCADA, are used in many industries to monitor and control
manufacturing plants, national defense systems, and utility
infrastructure, including generation plant and transmission
circuit infrastructure. These systems, originally deployed in
the late 1960’s and early 1970’s, have matured to current
‘fourth generation’ web-based systems. Avista operates
approximately 176 substations, ranging from very large, 500 MVA 230-115 kV transmission stations, to
small, rural distribution stations. While Avista’s transmission system is fully SCADA integrated, a number
of distribution stations are not equipped with remote monitoring and control systems. A majority of
these rural stations are located in elevated fire risk areas.
Avista operates 33 substations without SCADA. These stations are effectively ‘dark’, without any remote
sensing, monitoring, or equipment control systems. Though substations are designed to operate
autonomously, the inability to adjust protection systems based on weather conditions or de-energize
electrical circuits in an emergency elevates the safety risk for emergency first responders.
One of the elements of Avista’s strategy is to align circuit protection schemes with fire threat conditions
(see Dry Land Mode). During the fire season, Avista operates a number of distribution lines in non-
reclosing mode, which reduces fault
energy by 40-50%. However, weather
forecasts that indicate high
temperatures and high winds may
warrant a more sensitive protection
regime, such as Trip-Reclose-Trip, where
circuit reclosers rely on instantaneous
rather than time-delay tripping. This
could reduce fault energy by as much as
70-80%.
By adding SCADA, system operators can
issue instructions to recloser units and
effect changes. Without these systems,
servicemen must be dispatched to the
substations to manually effect the

33 Avista Substations are not
currently equipped with control
and monitoring systems (SCADA)
Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 1, Page 51 of 67
change. In a dynamic system, manual intervention is not practical and may lead to prolonged customer
outages and elevated risk.

Risk Evaluation
Avista plans to install SCADA at 33 substations based on their location within the Wildland Urban
Interface. Elevated fire threat areas (Tier 2/3) would be prioritized over non-WUI and WUI Tier 1 areas.
D-15: Substation SCADA 2020-2029
Inherent Risk Exposure $132 - $547 Million
Managed Risk Exposure $0 - $1.6 Million
Risk Mitigation (average %) 100%
Total Operating Expense $97,000
Total Capital Investment $17 Million

Circuit Recloser
Relays
Modern circuit reclosers are
controlled via microprocessor
relays. In this photograph, a
Schweitzer SEL-351R relay is
being tested prior to installation.
Equipment connected to
communication systems (SCADA
& DMS) are continuously
monitored and capable of
remote operation. This
functionality is an important
element in Avista’s wildfire
strategy.
Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 1, Page 52 of 67
D-12 Distribution Management System (DMS) Communication
Recommendation: To retrofit circuit reclosers with communication systems and enable
control and monitoring of equipment in elevated fire threat areas
(40% System).
Cost: $60,000 Capital Investment ($540,000 total over 10 years )
$30,000 Operating Expense ($272,000 total over 10 years)
Benefit: Extending communications for circuit reclosers enables remote
operation, and allows operators to align protection schemes with
current fire threat conditions

As part of the 2010 Spokane and Pullman Smart Grid projects,
Avista installed a Distribution Management System, or DMS, to
collect data from circuit reclosers, voltage regulators, and
capacitor banks. DMS is similar to SCADA, but is specific to
distribution and can collect data from both substation and
powerline devices. However, a number of circuit reclosers
located in elevated fire risk areas lack communications and are
not included in the DMS system. Extending communications to
these devices is like the SCADA initiative and will enable remote
monitoring and control of these devices.

Electric Distribution Line Protection
Avista operates 7,600 miles of overhead distribution line and 40% of that system is located in elevated fire
risk areas. This diagram indicates a typical distribution configuration, with a main trunk protected via
circuit reclosers (substation and midline) and lateral circuits protected via fuse links. Circuit reclosers are
similar to household breakers and operate (open) when fault overcurrent is detected. Faults that occur on
lateral circuits are interrupted when a fuse link opens (thermal operation).
By adding communications to midline circuit reclosers, Avista adds monitoring and control functionality,
including the ability to operate the device remotely.

Emergency first responders
rely on Avista’s ability to de-
energize electric lines
near wildfires
Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 1, Page 53 of 67

Risk Evaluation
Extending communications to circuit reclosers enables remote operation and allows operators to adapt
protection schemes to align with current fire threat conditions. For example, Avista may install Hot Line
Holds (one shot tripping, no automatic reclose) during red flag warnings. Reducing the potential for
spark ignition is an important component of Avista’s strategy and adapting system protection to fire
threat conditions helps to achieve those goals.

D-12: DMS Communications 2020-2029
Inherent Risk Exposure $14.6 - $29 Million
Managed Risk Exposure $250,000 – 280,000
Risk Mitigation (average %) 99%
Total Operating Expense $272,000
Total Capital Investment $540,000

Midline Circuit Recloser Fuse Link Assembly Cutout
Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 1, Page 54 of 67
ST-2 Fire-Weather Dashboard
Recommendation: Combine weather forecast and fire threat data into a fire predictive,
web-based program.
Cost: $150,000 Capital Investment ($425,000 total over 3 years )
$75,000 Operating Expense ($650,000 total over 10 years)
Benefit: Better understand and respond to the potential impact of weather
conditions on Avista’s operating system.

The Wildland Fire Assessment System (WFAS)
operated by the USFS in Missoula, Montana,
provides near real time information on fire
threat conditions. This information is an
important tool in determining both the
probability and impact of wildfires.
The precision of weather forecasting and,
especially, micro climate forecasting, has
significantly improved over the last few decades.
Advancements in forecasting, coupled with broadband communication has made weather information
more available than ever before. Prevailing weather conditions, including temperature, humidity, and
especially wind, are key factors in fire behavior. By combining fire threat information with forecasted
weather, system planners, operators, and field personnel are better equipped to predict and respond to
wildfires.

Data from the National
Weather Service for Post
Falls, Idaho (3/3/20).
Temperature, humidity,
and wind levels are
important factors in
predicting wildfires.

Avista System Operations declared “Dry Land
Operating Conditions” on July 23, 2019 based
on data from the Wildland Fire Assessment
System (WFAS).
Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 1, Page 55 of 67
By combining information from the Wildland Fire Assessment System (WFAS) and the National Weather
Service (NWS), Avista will be able to quantify fire risk by service territory. An example is shown below. At
the time of this report, a detailed scoping of the “Fire-Weather Dashboard” is not yet complete.

July 16, 2020 48 Hour 96 hour
Service Area Temp
F°
Wind
mph
Fire
Index
DLM Temp Wind Fire
Index
DLM
Hi/Lo Gust/Sust Hi/Lo Gust/Sust
Sandpoint 82/54 12/4 M NOM 95/78 52/22 EC HLH
CDA 86/58 16/5 M NOM 101/82 62/45 EC HLH
Kellogg 80/50 12/5 H NOM 92/68 51/20 EC HLH
St. Maries 82/50 14/4 H NOM 95/66 32/15 E TRT
Lewiston 92/68 28/10 H NOM 112/85 12/5 H NOM
Grangeville 85/50 35/15 E TRT 108/76 8/4 H NOM
Colville 88/58 8/2 M NOM 102/80 16/6 H NOM
Deer Park 82/54 6/2 L NOM 98/75 12/6 H NOM
Spokane 86/54 4/2 M NOM 99/74 16/9 H NOM
Othello 88/62 12/2 M NOM 100/78 5/2 M NOM
Davenport 85/56 8/4 M NOM 96/76 6/2 M NOM
Pullman 78/55 22/14 H NOM 95/69 12/8 H NOM
Legend: Fire Index (Low, Moderate, High, Extreme, Extreme Catastrophic)
Dry Land Mode (Nominal, Trip-Reclose-Trip, Hot-Line-Hold)

This is illustration indicates how fire threat indicators might be combined with weather forecasts to
influence Avista’s operating systems, such as Dry Land Mode. Other activities, including EOP pre-
activation and staging first responders, may also be informed through this system.

Risk Evaluation
Developing a fire-weather dashboard will not reduce fire risk on a standalone basis, however, this
information is vital to adapting operations and emergency response to the potential for wildfire.
ST-2: Fire-Weather Dashboard 2020-2029
Inherent Risk Exposure $4.8 - $8.8 Million
Managed Risk Exposure $4.3 - $4.8 Million
Risk Mitigation (average %) 33%
Total Operating Expense $650,000
Total Capital Investment $425,000

Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 1, Page 56 of 67
Operations & Emergency Response
The primary objective of Wildfire Resiliency is to reduce the number of utility involved ignition events
and to minimize the damage of infrastructure due to wildfires. The bulk of that effort is rooted in long-
term planning and implementation of methods to clear vegetation away from powerlines and to protect
infrastructure from fire damage. Meeting these objectives requires a steadfast and committed approach
to investing in the energy delivery system. Wildfires will continue to occur, and Wildfire Resiliency
includes support elements such as first responder training, defining the role of engineering during major
events, and establishing wildfire metrics.
Historically, Avista’s response to wildfire has been similar to other large scale weather events, with a
focus towards outage service restoration. Though major storms present employee and public safety
challenges, wildfire is particularly acute with respect to safety. In addition to mitigating the risk of
wildfire, Avista plans to:
1. Prioritize public and worker safety over customer restoration.
2. Recognize wildfire response as a shared responsibility with other emergency first responders.
3. Use performance metrics to adjust and align planned future actions.
Plan elements in this category include:
• Emergency Operating Program (EOP) document review & fire incident command representative
• Transmission design review of major events
• Wildfire performance metrics
• Emergency first responder training
• Expedited fire response (2020 pilot project)
• Comprehensive fuse coordination review
• Circuit recloser event reporting
• Fire ignition tracking system
• Fire suppression chemical additive
• Wildland urban interface layer in Avista’s GIS data system
• ARCOS system wildfire notification operating procedure

The cost to align operating tactics with Wildfire Resiliency is $2.7 million over 10 years. However, this is
projected to reduce risk exposure by several hundred million dollars.
Operations & Emergency Response 2020-2029
Inherent Risk Exposure (category %) 19.7-100
Managed Risk Exposure (category %) 5.3-23.4
Risk Mitigation (average %) 76%
Total Operating Expense $2,378,000
Total Capital Investment $300,000

Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 1, Page 57 of 67

Transmission & System Operations
Recommendation: ST-1 Formalize EOP response to large scale wildfire events
ST- 3 Transmission engineering review after major events
ST-4 Establish wildfire resiliency metrics
ST-8 Conduct annual fire safety and electrical hazard training
ST-11 Expedited fire district response following transmission line faults
Cost: $160,000 Operating expense ($1,593,000 total over 10 years)
$10,000 Capital investment ($100,000 total over 10 years)
Benefit: Enhanced awareness and response to wildfire events.

Five treatments are described in this section which encompass the overall energy delivery operating
environment. Those elements include:
• Emergency Operating Program Review & Fire Incident Command Representative
• Transmission Design Review of Major Events
• Wildfire Performance Metrics
• Emergency First Responder Training
• Expedited Fire Response (2020 Pilot Project)

ST-1 Emergency Operating Program (EOP)
Since 2014, Avista has activated the electric EOP, or
incident command structure, 16 times, including the
Company’s largest event, the windstorm in November
of 2015. By declaring an EOP, Avista operations shifts to
emergency response, with service restoration as the
primary objective.
Wildfires present a number of safety related challenges.
In August of 2015, Avista activated an EOP in response
to numerous wildfires across the service territory. The
largest of these fires was the Carpenter Road Fire near
Davenport, Washington which impacted 64,000 acres
and involved over 1,000 firefighters. Evacuation orders
were issued for residents throughout the Springdale-
Hunters area and approximately 42 structures were
damaged or destroyed by the blaze. Though Avista has
a long history of responding to wildfire events, it recognizes wildfire as separate and distinct from storm
events. Therefore, Avista plans to implement the following changes to its EOP program:
1. Conduct an EOP document review to align with Wildfire Resiliency
2. Formalize resource commitments to Fire Incident Command (Avista Fire Representative)

4
7
3
2
Wildfire Wind Event Snow Storm Safety
Avista Electric EOP
2014-2019
Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 1, Page 58 of 67
In most large wildfire situations, local response (city, county) is superseded by state and federal
authorities. In Washington State, the Department of Natural Resources is responsible for most non-
federal fire suppression, and in Idaho, the Department of Lands takes the lead. In either state, responses
to fires larger than 100 acres triggers a Fire Incident Command Structure (ICS). While Avista has a long
history of working closely with fire protection agencies, divisional operations managers have
committed to embed Avista field personnel into the Fire ICS. A basic flow-process diagram is indicated
below. The primary duty of the Avista representative is to serve as the liaison between the fire Incident
Commander and Avista.

Embedding Avista Personnel into Fire Incident Command Structure

ST-3 Transmission Design’s Role in Major Event Response
The reconstruction cost of overhead transmission lines ranges from $500,000 to over $1 million dollars
per mile. This is in sharp contrast to electric distribution facilities which typically range from $150,000 -
$250,000 per mile in rural areas. During the wildfire workshops, engineers and system operators
estimated that wildfires impact transmission lines 2 to 4 times per year. Though electric operations is
responsible for restoration, during large scale events, transmission design shall be consulted to conduct
damage assessments prior to reconstruction.

Appointed by
Divisional Operating
Manager
Initial Check-
In with Fire IC
Attends Daily
ICS Briefing(s)
Liason
between Fire
ICS and Avista
•Minimal Structure Damage (1-3)
•Customers without power
•Safety Issue (e.g. highway crossing)
•Isolated Event
Direct Restoration by Operations
•Moderate Structure Damage (> 3)
•Damage to conductor
•Property and or third party damages
•Major Event
Transmission Design Consulted Prior
to Reconstruction
Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 1, Page 59 of 67
ST-4 Wildfire Program Metrics
Electric reliability is determined through a series of metrics established by the Institute of Electrical and
Electronics Engineers (IEEE), and includes outage frequency and duration. Indices such as MAIFI
(momentary outage frequency), SAIDI (sustained outage duration), and CEMI (customers experiencing
multiple interruptions) are commonplace throughout the industry. In contrast, fire metrics are
characterized as the number of acres burned, suppression costs, structures damaged, and injuries.
Though Avista does track some fire-related information, such as the number of pole fires, it does not
have a systematic approach to quantify the effectiveness of wildfire resiliency measures.
It is recommended that Avista implement a set of performance measures to quantify and better
understand the risk of wildfire on operating systems. The performance measures should allow for
evaluation and continuous improvement.

ST-8 Wildfire Training for Avista First Responders
Avista electric operations employees are located in 12 districts ranging from Colville to Grangeville and
from Kellogg to Othello. Avista employs over 550 electric line workers who are trained as emergency
first responders. As part of this Plan, divisional managers are responsible for conducting basic fire
training at one of their monthly safety meetings. Where feasible, managers would involve a fire agency
professional to conduct training in the April-May timeframe prior to start of fire season. Though there is
consensus among division managers that Avista first responders should have basic firefighting and fire
safety training, a core tenant of this Plan is to promote and strengthen relationships with fire agencies.
By conducting joint training and emergency response simulations, Avista plans to support those key
relationships.

The Plan-Do-Check-Act model is a
continuous improvement technique
also known as the Deming Circle or
Shewhart Cycle. Establishing wildfire
metrics partially fulfills the ‘Check’
component and drives adjustments to
Plan strategies and tactics. Though
the Plan must adapt to ever-changing
climatic, social, and political
influences, the objectives are clear:
Emergency Readiness, Public Safety,
and Financial Protection.
DO
CHECKACT
PLAN
Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 1, Page 60 of 67
ST-9 Expedited Fire Response
It is recommended that Avista implement expedited response for potential fire related disturbances on
the transmission system.
Avista’s outage management system (OMS) is used to track electric events on both the transmission and
distribution networks. As noted, sustained distribution outages are 50 times more prevalent than
transmission events. However, 80% of transmission events are characterized as momentary and
generally involve the automatic reclosing of circuit breakers to restore power. Though distribution line
faults may cause spark ignitions, distribution events generally involve Avista crew response. However, if
a transmission line successfully trips and then recloses, no Avista response is triggered.
During the development of this Plan, Avista engaged fire agency professionals, including Washington
DNR and Idaho IDL, together with Spokane County Fire Districts. It was through these conversations that
the concept of Expedited Fire Response was developed. During dry land mode operations, Avista
System Operator will initiate a 911 call whenever there is an isolated transmission fault. Subsequently,
fire fighters will be dispatched to the scene.
At the time of this report, a Memorandum of Understanding (MOU) is under review with Spokane
County Fire to conduct a ‘pilot project’ during the 2020 fire season. For purposes of the pilot, the
program will extend only to the Spokane County boundaries, and will align with Avista’s seasonal
declaration of Dry Land Conditions (typical July-September).
Risk Evaluation
The following table summarizes the risks and estimated 10-year costs associated with the transmission
system elements of wildfire operations and emergency response.
2020-2029 Risk & Costs (Transmission & System Operations)
Inherent Risk
($ Millions)
Managed Risk
($ Millions)
Risk
Mitigation (%)
Capital
Investment ($)
Operating
Expense ($)
EOP & Fire ICS $13.65 $13.65 0 $50,000
Engineering
Design Review
$3.95 $1.65 58% $100,000
Wildfire Metrics $13.8 $2.45 82% $150,000
First Responder
Training
$2.05 $0.6 71% $1,300,000
Expedited
Response
Not
evaluated
-- -- -- $93,000
Total $33.5M $18.3M 75% $100,000 $1,593,000

Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 1, Page 61 of 67
Electric Distribution Operations

Recommendation: D-1 Conduct annual distribution fuse coordination assessment
D-2 Evaluate circuit recloser event data to ensure nominal operation
D-3 Track the number of powerline caused fire ignitions
D-5 Add chemical additives to field crew ‘water cans’
D-7 Deploy the Wildland Urban Interface data-set to the GIS system
D-9 Use ARCOS to notify key personnel in the event of wildfire
Cost: $70,000 Capital Investment ($200,000 total over 3 years )
$78,500 Operating expense ($785,000 total over 10 years)
Benefit: Enhanced distribution operations and fire response.

Six elements are included in this section:
• Fuse Coordination Study
• Circuit Recloser Event Reporting
• Fire Ignition Tracking System
• Fire Suppression Water Additive
• WUI Layer in Avista GIS
• ARCOS Wildfire Notification System
As noted, electric distribution facilities account for 6,200 unplanned outages per year with a number of
these events occurring during the fire season. Though the bulk of distribution risk reduction is
associated with enhanced vegetation management and grid hardening, those treatments occur on a
long term planning horizon. Elements described in this section inform the near-term operating horizon.
D-1 Fuse Coordination Study
It is recommenced that Avista ensure
proper fuse sizing and coordination on an
annual basis.
Fuses are an important element in the
protection of electric distribution systems.
Avista’s distribution system is configured
as a trunk and lateral system, with lateral
circuits protected via fuse links and trunk
lines protected via circuit reclosers.
Avista’s Area Engineers are accountable
for ensuring that fuse sizes and types
operate in a coordinated fashion. In
simple terms, fuses closest to loads are
smallest with increasing fuse size towards
the trunk connection (see illustration).
40T Fuse •Trunk Line to 3-phase Lateral
15T Fuse •3-phase Lateral to 1-phase
Lateral
6K Fuse •1-ph Lateral to Service
Transformer
Downstream
Upstream
Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 1, Page 62 of 67
D-2 Circuit Recloser Event Reporting
It is recommended to analyze recloser event reports to determine that protection systems are operating
nominally.
Protection Engineering keeps a log of all transmission line circuit breaker operations and ensures that
devices and relays are operating nominally. As communication systems become available to distribution
devices, so does the ability to remotely access data from circuit reclosers. To ensure that reclosers are
operating nominally and are coordinated with downstream fuse links, it is imperative that system events
be analyzed by technical staff.

D-3 Fire Ignition Tracking System
It is recommended to implement a fire ignition tracking system to better understand and respond to fire
events.
As noted, Avista’s Outage Management System (OMS) is used to track electric outages, and includes
information such as: tree fall-ins, car hit poles, wind, animal, underground cable, overhead equipment,
and etc. Fire is listed as an outage category, but generally relates to structure fires. Also listed is Pole
Fire, which occurs when excessive electrical tracking leads to hot-spots between wood crossarms and
poles. However, the OMS system does not include provisions for tracking outcomes beyond direct
customer impacts (e.g. customer duration without power). Though still in development, Avista plans to
extend mobile data collection devices (e.g. tablet computers) to field first responders. This would
replace paper products, including Avista’s damage response form. In order to determine if Wildfire
Resiliency treatments are effective, it is important that utility involved fires are tracked by first
responders.

Utility grade tablet computers are being
deployed to conduct damage assessment
and to document field repairs. This
collection process will include provision to
capture fire ignition events.
Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 1, Page 63 of 67
D-5 Fire Suppression Water Additive
It is recommended to use chemical additives in
Avista fire suppression water cans to extend the
efficacy of water blankets.
Electric line and vegetation field crews are often
required to adhere to state and federal fire-
related work restrictions. In many situations, field
crews are required to spray their work area with
water prior to activity. This helps prevent fire
ignitions generated by spark emitting devices such
as power drills and saws. Water evaporates
rapidly during hot days, but there are a number of
chemical additives that delay this process and
extend the effectiveness of water blankets. The
Fire Protection Research Foundation
(www.nfpa.org/founation) conducted analysis in
2013 to determine the effectiveness of several
chemical additives. By using one of the chemical
additives, Avista plans to increase the
effectiveness of water blankets and water based
fire suppression tools.

D-7 WUI Layer in Avista GIS System
In September of 2019, Avista developed a Wildland Urban Interface map based on the USDA’s 2018
Wildland Hazard Potential and Avista’s distribution system. This map helps identify and prioritize the
work required to clear vegetation hazards and to ‘harden’ electric lines. The WUI map was developed by
Avista’s GIS Technical Services group and as of this writing, the WUI map is being published to the
Company’s GIS applications. GIS Technical Services has the lead on this effort (see addendum D-7
Wildland Urban Interface for a more complete description).

Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 1, Page 64 of 67
D-9 Wildfire Notification System
In July of 2019, Avista Distribution
Operations added provisions for wildfire
notification to their ARCOS emergency call-
out system. This system allows Distribution
Operations to dispatch messaging to first
responders and key stakeholders. The
Wildfire Notification system sends SMS text
messages and emails to a pre-determined list
of recipients. The Wildfire Resiliency Plan
manager is responsible for updating this list
and coordination with the Distribution
Operations Manager.
Risk Evaluation
The following table summarizes the risks and estimated 10-year costs associated with the electric
distribution elements of wildfire operations and emergency response.
2020-2029 Risk & Costs (Electric Distribution Operations)
Inherent Risk
($ Millions)
Managed
Risk
($ Millions)
Risk
Mitigation
(%)
Capital
Investment
($)
Operating
Expense ($)
Fuse Coordination $74 $4.9 93% $200,000
Recloser Event Reporting $51.5 $4.85 91% $400,000
Fire Ignition Tracking
System
$339.5 $129.5 62% $200,000 $100,000
Fire Suppression “Wetting”
Agent
$317.5 $38.5 88% $50,000
WUI Layer in GIS Not evaluated -- -- -- $30,000
ARCOS Wildfire Notification Not evaluated -- -- -- $5,000
Totals $783 $177.8 77% $200,000 $785,000

Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 1, Page 65 of 67

Conclusion
Summary of Risks, Benefits, and Costs
The risk and cost expenditures shown in the following table represent a 10-year planning horizon from
2020 to 2029. Note that the Plan includes both operating expense elements as well as capital
improvements to infrastructure. Capital elements are planned to sunset after 2029 but the majority of
the expense items are on-going and generally related to vegetation management.
While project/program cost estimates are normal and routine, assigning financial risk to these fire
resiliency measures is new. Avista is committed to reducing the risk of wildfire by incorporating cost
justified and prudent measures. Fire resiliency is an important element among many in determining
capital and operating expenditures, and funds are not unlimited. It is not feasible to eliminate the fire
risk to the electrical system.
The column labeled ‘inherent risk’ is based on the current state risk for each operating category and
indicates the range of risk from optimistic (low) to pessimistic (high). The values are specific to each
category with the high end of the range normalized to 100 basis points. The next column labeled as
‘managed risk’ indicates the risk reduction by adding wildfire resiliency defenses (future state). Note
that defenses with a high confidence of success were selected and the cumulative impact of choosing
‘the best of the best’ is to drive the risk exposure downward. The column labeled ‘risk mitigation’
compares the midpoint of the inherent risk range to that of the managed risk range.

Wildfire Resiliency Risk Benefit and Cost Summary
2020-2029
Operating Horizon
Inherent Risk
(range %)
Managed Risk
(range %)
Risk
Mitigation (%)
Capital
Investment ($)
Operating
Expense ($)

Grid Hardening &
Dry Land Mode

41-100 0.7-2.7 98% $245,600,000 $5,014,000
Enhanced
Vegetation
Management

48.3-100 3.2-4.5 88% $5,100,000 $51,175,000
Situational
Awareness

25.9-100 0.8-1.1 98% $17,965,000 $1,019,000
Operations &
Emergency
Response

19.7-100 5.3-23.4 76% $300,000 $2,378,000
Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 1, Page 66 of 67
Addendum

This version is printed without addendum materials. A full report version will be available later and will
include the following supporting materials:
1. Wildland Urban Interface Map (WUI), November 2019
2. Wildfire Risk Summary, Proposed Actions, September 2019
3. Wildfire Resiliency Cost Plan, January 2020
4. Wildfire Resiliency Plan, Project Charter, March 2019
5. Standard Operating Procedures, internal memos, various dates
6. Transmission Vegetation Management Plan (NERC, TVMP)
7. Transmission Maintenance Inspection Plan (NERC, TMIP)
8. Distribution Vegetation Management Plan

Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 1, Page 67 of 67
David James, Wildfire Resiliency Plan Mgr. September 2019
Avista Utilities
Wildfire Risk Analysis Summary
Actions under Consideration
September 2019
Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 2, Page 1 of 21
Avista Internal Work Product
Page | 2
Report Summary
In June of 2019, a series of wildfire workshops were convened to evaluate opportunities to
reduce the risk of wildfire associated with Avista’s transmission and distribution systems.
Those workshops together with consideration from the Wildfire Steering Committee and the
broader Wildfire SME community serve to inform “Avista’s Wildfire Resiliency Plan”. This
document is a summary of the effort to date and includes preliminary recommendations for
systems & practices along with modifications to existing maintenance & construction programs.
The stated goals of the Wildfire Resiliency Plan are:
o Enhance Emergency Operation Preparedness: to recognize wildfire as a recurring threat to utility
infrastructure, the communities we serve, and our customers.
o Promote Safety: to protect physical assets, property, and human lives. To manage the risk of
wildfire through design-based, system operations, asset maintenance, and outreach activities.
o Safeguard Company Assets: to mitigate the impact of direct financial costs and liability exposure
associated with large-scale wildfire events.
In addition to these objectives, a model-framework was identified to promote a comprehensive
approach to wildfire risk. The elements of the model include:
Maintenance Monitoring
Plan Elements addressed in this report
The table below summarizes the risk cost reduction (risk savings) associated with transmission
and distribution treatment options. A detailed listing is included in the report. Be advised, the
risk savings and cost estimates are shown as 10 year costs. Most actions are recurring.
Electric
Transmission
10 Yr. Risk Cost Savings
($M’s)
10 Yr. Cost
Est.
Electric
Distribution
10 Yr. Risk Cost Savings
($M’s)
10 Yr. Cost
Est.
Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 2, Page 2 of 21
Avista Internal Work Product
Page | 3
Wildfire Threat Increasing in the Western States
The number of large wildland fires continues to trend upward. Data from Climate Central’s 2016
Western Wildfire Report suggests a 3-fold increase in large fires since 1970 and is particularly
acute in several states including Wyoming, Idaho, and Montana where a 10-fold increase has
occurred. In terms of total acres burned, there has been a 6-fold increase since the 1970’s.
Both the frequency and scope of wildfires are on the rise.
2016 Climate Central - Western Wildfires
Information from the 2016 Western
Wildfires report also indicates that
the number of days associated
“High Fire Danger” or “Red Flag” is
increasing. Though southwestern
states are most at-risk, note that
Washington and Idaho are ranked
in the top ten. This increases the
probability of fire starts and
elevates the overall risk of fire
impact.
“ANNUAL TOTAL ACRES
BURNED HAVE
INCREASED
6-FOLD SINCE 1970”
Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 2, Page 3 of 21
Avista Internal Work Product
Page | 4
Washington State Responds to Wildfire
In Washington State, the Department of Natural
Resources (DNR) takes the lead on most large
wildland fires outside of federal lands. In 2015, the
DNR published a 20-year “Forest Health & Strategic
Plan” for Central and Eastern Washington and
identified 2.7 million acres (30%) as ‘unhealthy
forest’. In these areas, fuel loading and drought
conditions have resulted in forests most at risk of
catastrophic wildfire.
Treatment plans include, commercial logging
activities, thinning, prescribed burning, and re-
planting with native species.
2015 DNR 20-Year Forest Health Strategic Plan
An acronym has emerged in the fire vernacular to
describe the interaction between forest land and human development: Wildland-Urban Interface
(WUI). Homes built in or near forest lands add to the costs of fire suppression. In Washington alone,
2.2 million homes are located in WUI areas (Washington DNR, 2018). Avista’s fire resiliency
plan will focus attention and treatment in these WUI areas.
Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 2, Page 4 of 21
Avista Internal Work Product
Page | 5
Reading this Report
The SME workshops and subsequent analysis has focused on understanding the risk exposure
of wildfires in general, but also the opportunity to reduce risk through specific actions. Risk is
quantified as the probability an event occurring times the financial impact of the event.
(Risk = Probability X Impact) In this report, impact is characterized as the sum of:
1)Direct Financial Cost (replacement costs, fire suppression, 1st party damages) +
2) Customer (interruption cost estimate (ICE), 3rd party claims) +
3)Safety (public and employee injuries)
For example, if one considers the risk exposure associated with using fire retardant paint on
wood transmission poles, the probability of a wildfire impacting a transmission line is generally
1-2 times per year. (Probability of Occurrence = 1-2/year)
The impact costs including the cost of replacement, fire suppression, public and worker safety,
and customer disruption ranges between $961,000 and $1,378,000 per event. This translates
into an accumulated 10-year inherent risk value ranging from $9,610,000 to $27,560,000.
Inherent risk indicates the risk exposure before treatment.
Now consider what happens if fire retardant paint is used. In this scenario, the probability of
occurrence remains unchanged (1-2/year) but the 10-year managed risk ranges between
$4,285,000 and $4,830,000. The risk reduction or ‘risk savings’ is the difference between
inherent and managed risk. This report includes both inherent and managed risk costs together
with the treatment implementation costs. Again, all costs are indicated as 10-year accumulated
amounts and are order of magnitude estimates. For the fire retardant (FR) paint example, the
table on page 7 indicates:
Inherent Risk ($M) Managed Risk ($M) Implement
Description Low High Low High 10-year
In the body of this report, proposed treatment actions are identified and grouped as:
•Base Level – efforts that support or enable other actions; or standalone actions that can be
readily incorporated by the organization.
•Primary – actions that represent significant value (risk reduction) and are recognized as industry
best-practices.
•Secondary – actions that represent the highest risk value but require significant human and or
financial commitments.
•Future – identified as providing value but of lower priority and therefore, not considered in the
initial phase of the Wildfire Resiliency Plan.
Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 2, Page 5 of 21
Avista Internal Work Product
Page | 6
Electric Transmission
In 2006, Avista adopted tubular steel poles as the ‘standard
installation’ for 115 and 230 kV powerlines. Approximately 30% of
Avista’s transmission system is now steel and as circuits are
reconstructed and poles replaced, that percentage will continue to
increase. In 2009, NERC published the “Transmission Vegetation
Management” standard FAC-003-2 which fundamentally reshaped the
industry’s approach to transmission line clearance activities. For
Avista, the combination of system hardening and well maintained
rights-of-way have increased the fire resiliency of the transmission
system.
Transmission fire ignition events
are rare. From 2014 to 2018 there
were 611 sustained outages but
only 252 between May and
September (fire season).
However, there were over 3,000
momentary outages and nearly half
of those (1,500) occurred during
fire season. Eighty percent (80%)
of transmission line faults are
momentary (less than 5 minutes)
and are generally the result of
lightning, wind, and planned
switching operations. Conversely,
the impact of fire to transmission
structures can be significant. The
replacement cost of a single wood
transmission structure ranges from
$7,500 to over $25,000 and
damages to conductor can
escalate into the millions of dollars.
____________________________________________________________________________
steel structures as
standard construction
2009 – NERC Vegetation
Management Standards
2014-2018 System
Performance
622 Sustained outages
3,000 Momentary outages
18 Tree Fall-In Incidents
59 Wind Related
89 Pole Fire (distribution
underbuild ignitions)
2019 WW-Wanapum
Fire Damage, $1.2M
Transmission
June 2019 WW-Wanapum Fire
Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 2, Page 6 of 21
Avista Internal Work Product
Page | 7
Base Level Actions (transmission system)
EOP & Fire ICS 9.6 17.7 9.6 17.6 $50k
Fire Weather
Dashboard
4.8 8.8 4.3 4.8 $50k
Engineering Review
Post Major Event
1.0 6.9 0.9 2.4 $100k
Wildfire Compliance
Tracking
9.6 18 2.2 2.7 $150k
1.EOP and Fire ICS- fire events are distinct from other storm-outage scenarios and Avista’s Emergency
Operating Plan (EOP) should reflect that reality. In most fire situations, outage restoration should be
secondary to employee and public safety. Restoring power in an active fire area may expose line
personnel to unnecessary risks and draw evacuated residents back into homes and businesses. Also,
there is broad consensus that Avista should have a representative in all fire ICS situations. The
representative would serve as the liaison between fire command and utility personnel such as
system operations, distribution dispatch, electric operations, and engineering. The division
operations manager would serve in this capacity or delegate a staff member.
2.Fire Weather Dashboard- situational awareness is vital to decision making; especially in operations
control rooms or emergency operations environments. Weather data is readily available in the
public domain as is fire condition information. There is strong consensus that these public
information streams should be combined to support decision making including public safety power
shutoff (PSPS). Though PSPS is recognized as a ‘deferred action’, actions included in the resiliency
plan will support a future deployment.
3.Engineering Review Post Major Event – transmission engineering requests time to conduct damage
assessment following a significant event. The EOP should include a 24-48 hour stand-down period
allowing engineering staff to determine the appropriate scope of reconstruction.
4.Wildfire Compliance Tracking – in order to monitor and measure the effectiveness of the Wildfire
Resiliency Plan, the Committee recommends metric monitoring similar to NERC/CIP. This system
would provide a clear record of performance and track modifications to the program.
Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 2, Page 7 of 21
Avista Internal Work Product
Page | 8
Primary Actions (transmission system)
Digital Data Collection 9.6 17.7 0.9 2.4 $7.5M
Wood Pole Fire
Retardant
9.6 28 4.3 4.8 $2.5M
Fuel Reduction 15 29 3.0 29 $15M
1st Responder Training 1.8 2.3 0.3 0.9 $1.5M
1.Digital Data Collection – Laser Detection & Ranging (LIDAR) is widely recognized as an industry best
practice and provides accurate locations of structures, vegetation, buildings, roads, and etc.
Transmission Engineering currently uses this technology to monitor conductor ground clearance.
That data can be used to determine vegetation management work plans and to assess the
effectiveness of treatment. This system could become Avista’s ‘system of record’ for both
vegetation management and system integrity. LIDAR is quickly becoming the industry de-facto
standard for transmission vegetation management due to its ability to quantify tree growth rates,
tree fall-in risks, and to accommodate a variety of risk/benefit scenarios. The tabular estimate
reflects standalone data gathering and analysis costs. However, we anticipate cost savings by
reducing the need for ground based activities and helicopter aerial patrols.
2.Wood Pole Fire Retardant – fire resistant paint has been used on Avista’s wood transmission
structures since the late 1990’s, and in most cases, paint is applied from ground-line up to 6-8 feet.
This has proven to be an effective treatment for transmission structures not subject to tree crown
fire activity. However, maintenance funding for this activity has been constrained and the
recommended application frequency of once every three to five years has not been met. A new
product in-use on SCE’s system consists of a fire-activated pole wrap (GENIC Fire Mesh) and does
not require follow-on maintenance. Transmission engineering is currently evaluating this product.
The June 2019 Walla Walla-Wanapum fire impacted approximately 17 miles of transmission line.
These poles had been treated with FR paint in 2009 and many structures were protected as a result
of this application. Total repairs associated with the fire totaled $1.2M however replacement costs
of a 17 mile section of this facility ranges between $13M and $20M dollars.
3.Fuel Reduction– though State and Federal agencies are actively pursuing fuel reduction strategies,
most do not encompass electric transmission facilities nor do they involve local fire protection
districts. The Steering Committee recommends that Avista participate with local fire districts to
reduce the fuel loading in critical areas such as multi circuit corridors, critical infrastructure areas,
and extreme risk fuel zones.
4.1st Responder Training – line personnel respond to a variety of emergency situation including pole
fires and must have basic fire suppression skills. During fire season, fire protection agencies often
impose work-site restrictions that involve fire watch and area preparation. Conversely, fire fighters
are often tasked with working around utility infrastructure and must have a basic awareness of
electric hazards. Joint training with Avista line and fire district personnel currently occurs but only
on an as-needed basis. The Steering Committee recommends that joint training occur annually.
Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 2, Page 8 of 21
Avista Internal Work Product
Page | 9
Secondary Actions (transmission system)
Conforming
Transmission Rights-of-
Total 9 68 1 4 50M CapX
5M OpX
1.Conforming Transmission Rights-of-Way – though, wholesale expansion of transmission corridors is
well beyond the scope of this effort, conforming rights-of-ways to established engineering and
vegetation management standards should be evaluated on a case by case basis. This effort would
be constrained to WUI areas or circuits with known vegetation issues.
2.Engineering Line Patrols…. – transmission engineering conducts annual aerial patrols to ensure
structural integrity and to monitor other direct hazards such as bird nests and building
encroachments. Currently, this is an open loop process and by closing this process, a clear record of
treatment is maintained.
3.Fire Protection Expedited Response – 80% of transmission line outages are temporary with the line
first tripping and then automatically reclosing. In most scenarios, Avista crews are not dispatched to
inspect these lines unless there is a secondary indication of a problem. Recent discussions with local
fire districts indicates a willingness to investigate the potential for fire events after a trip-reclose
event. This system would be deployed in conjunction with the distribution ‘dry land condition’
declaration and apply only to participating fire district areas. At this point, it is unknown whether
local fire districts would seek compensation.
4.Additional Line Patrols in WUI Areas – a major theme in the California utility plans is the emphasis
on structure inspections in fire prone areas. Investments in more frequent patrols would support
both engineering and asset maintenance objectives.
Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 2, Page 9 of 21
Avista Internal Work Product
Page | 10
Future Actions (transmission system)
Minor Rebuild 0.5 1.0 0.2 0.8 $30M
T/R Patrols 0.9 2.4 0.8 2.2 $1.8M
Supervised 115 kV
MOAS Operation
0.2 0.5 0.1 0.1 $40k
Splices & Obsolete
Conductor
7.8 8.7 0.4 0.9 $7.5M
Fire-wise Education 3.8 57 1.0 6.9 $3M
R/W Road System 4.8 13.8 4.3 4.8 $40M
Inspect before re-
energizing policy
0.2 0.5 0.4 0.5 $250k
Red Card Certification 4.8 13.8 4.0 4.8 $380k
Fire Prevention Grant
Writer
1.8 6.9 0.9 2.4 $700k
In-house fire
suppression crews
9.6 17.6 4.4 5.5 $1.5M
Fire training for pre-
apprentice tree crews
0.9 2.4 0.4 1.0 $1.5M
Increase ground
clearance standards
2.5 28 1.3 11.3 $25M
Dry Land Mode 0.2 0.9 0.4 1.0 $1.8M
Marker Balls on static
lines
0.2 0.9 0.1 0.1 $2.5M
Advanced Line
Protection
3.6 4.4 3.6 4.4 $10M
1.Minor Rebuild – to supplement the existing pole replacement program with a focus on wood to
steel conversions in the WUI areas.
2.T/R Patrols – similar to expedited fire response but would involve dispatching Avista personnel
following an isolated trip-reclose event. Expedited response is a more targeted approach.
3.Supervised 115 kV MOAS – many 115 kV air switches can be remotely operated. If air switches
operate incorrectly, arcing may result and could produce an ignition.
4.Splices & Obsolete Conductor – conductor splice failure is rare. From 2014 to 2018, only 4
conductor/connector outages were reported.
5.Firewise Education – combined with distribution ‘right tree-right place’ public outreach program.
6.R/W Road System – to construct permanent roads on transmission rights-of-ways.
7.Inspect before energizing – to expand existing field practices of ensuring personnel and equipment
in the clear before re-energizing a circuit that was taken out of service for maintenance.
8.Red card certification – to provide 3-5 day training to line personnel effectively making them fire
fighter qualified.
9.Fire prevention grant writer- paid staff writer to apply for federal and state grant monies.
10.In-house fire suppression crews – dedicated firefighting personnel and equipment.
11.Fire training for pre-apprentice tree crews – an addition to the existing program effectively making
tree personnel firefighting qualified.
12.Increase ground clearance standards – to increase 115 and 230 kV ground clearance design
standards.
Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 2, Page 10 of 21
Avista Internal Work Product
Page | 11
13.Dry Land Mode – to adapt the non-reclosing practice for electric transmission lines.
14.Marker Balls on Static Wires – In the 1990’s, several aerial marker balls failed associated with
electric field stress.
15.Advance line protection – adding line relays and communication equipment to existing transmission
lines.
Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 2, Page 11 of 21
Avista Internal Work Product
Page | 12
Electric Distribution
The vast majority of electric outages occur on the distribution
system but the impact to customers is restricted by line fuse
action (1-100 customers typical). To contrast this situation,
transmission outages are infrequent (low probability) but often
impact thousands of customers. The exact opposite is true in a
majority of distribution outages where the fuse protection scheme
limits the impact to outages to lateral circuits. However, from a
fire prevention standpoint, the distribution system is the ignition
source for most utility caused fires. Data from the Outage
Management System (OMT) indicates that annually, one hundred
(100)fire ignition events are associated with overhead distribution
lines. In almost all cases, these fires are extinguished by 1st
responders including Avista line servicemen. It is the distribution
system that requires more focus with respect to fire ignition and
this risk is especially acute in the wildland-urban interface (WUI).
Fire ignition sources
include tree contacts with
powerlines but also include
animal contacts, equipment
failure, and electrical pole
fires. Between 2014 and
2018 there were 1,933 tree
related outages with 1,011
occurring during fire
season. Over that time
period there 462 reported
pole fires (see inset).
Though vegetation management spends $5-7M annually,
there is a $3M work backlog and the number of danger
trees continues to increase.
A warming climate and drought conditions have stressed trees resulting in widespread damage from insects and disease. In many cases, trees subject to insect damage die
within six to eighteen months making it difficult to identify dead or dying trees with
ground patrols.
Whereas the risk profile of transmission is largely associated to the costs of fire impact to
transmission lines, the risk profile of distribution is aligned with ignition. The 1991 Firestorm involved over ninety (90) ignition events. A majority of those fire starts were related to
distribution lines.
2000 – Fiberglass Xarms
adopted system wide
(reduces pole fires)
2003 – Dry Land Mode
Protection developed
2014-2018 System
Performance (outages)
873 Car Hit Poles (3%)
646 Public Fire (2%)
462 Pole Fire (1%)
2,785 Animal (9%)
1,933 Tree (6%)
8,108 Wind (26%)
3,248 Unknown (10%)
30,780 Total Contingency
Distribution
Tussock Moth (attacks fir trees)
Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 2, Page 12 of 21
Avista Internal Work Product
Page | 13
Base Level Actions (distribution system)
Comprehensive Fuse
Coordination Study
41 107 1.6 8.2 $200k
Formalize event
reporting
21 82 1.3 8.4 $400k
Fire ignition tracking
system
132 547 46 213 $300k
Incorporate Veg Mngt in
CPC designs
20 278 10 21 $100k
Fire Suppression
Wetting Agent
53 582 11 66 $50k
Dry Land Mode
‘effectiveness’ study
21 57 .6 4.2 $50k
GIS WUI Design Layer 0 0.11 0 0.11 Complete
Dry Land Mode ‘trigger’ Complete
ARCOS WF Notification Complete
1.Comprehensive Fuse Coordination – distribution faults are a known source of fire ignition.
Miscoordination of fuses may transfer more energy to a fault and increase the probability of a fire
start. Ensuring proper fuse sizing is an important component of the distribution protection system.
2.Formalize event reporting – protection engineering conducts analysis for all transmission breaker
activity. This would extend that analysis to the distribution system and ensure that circuit
breakers/reclosers are functioning properly. Again, fire ignition is directly related to line fault
activity and ensuring ‘as-designed’ operation of equipment helps to reduce probability of fire
ignition.
3.Fire Ignition Tracking System – to implement a computerized tracking system for fire ignition events.
4.Incorporate Veg. Mngt in CPC Design – trees are often overlooked during the distribution design
process and subsequent unplanned treatment is often expensive and disruptive.
5.Fire Suppression Wetting Agent – additives are commercially available that extend the ‘wetting’
properties of water. During periods of high fire danger, crews often use water to spray down an
area prior to performing work. Water additives such as Cold Fire significantly increase the
effectiveness of this procedure.
6.Dry Land Mode ‘effectiveness study – report by Protection Engineering on the overall effectiveness
of DLM together with recommendations for future enhancements.
7.GIS WUI Design Layer- Engineering services has developed a Wildfire Urban Interface layer based on
the national wildfire hazard potential (WHP – 2018). This layer will be used to identify fire risk areas
and help prioritize maintenance and reconstruction efforts.
Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 2, Page 13 of 21
Avista Internal Work Product
Page | 14
8.Dry Land Mode ‘trigger’ – the USFS publishes a daily ‘fire threat index’ ranging from low to extreme.
This system is in use at Avista now determines when we reconfigure distribution circuits to operate
without automatic reclosing.
9.ARCOS WF Notification – Distribution Dispatch uses a computerized notification system to call-out
crew resources during outages. That system is now being used to notify key personnel, including
senior management, in the event of a fire that threatens customers or infrastructure.
Primary Actions (distribution system)
Annual Risk Tree 2,816 5,722 264 1,226 $5M
“Right Tree-Right Place” 563 1,145 2.25 28.2 $15.5M
Midline Recloser
Communications
14.6 29 0.25 0.28 $600k
Additional Midline
Reclosers
22.6 39 5.63 13.2 $10M
1.Annual Risk Tree – to conduct annual inspections and treatment programs in WUI areas. Currently,
hazard tree assessments are conducted as part of the 5-year routine maintenance program.
2.“Right Tree-Right Place” – this is an established program throughout the industry and promotes the
planting of Type I trees near powerlines. Type I trees mature at heights less than 20 feet and pose
no threat of fall-in or grow-in to electric lines. Avista has worked with city officials, arborists,
developers, and individual landowners promoting this concept but has not conducted a wide-spread
public campaign nor offered an incentive program to promote the removal of Type II/III trees. Right
Tree-Right Place is a vehicle, a brand that we can broadly support and has the potential of drastically
reducing the need for vegetation management maintenance in out-years.
3.Midline Recloser Communications – modern electronic circuit reclosers are capable of remote
operation and monitoring via cell modem, 4-wire telephone, or fiber optic communications. Though
our current standard includes communications, many existing units operate locally. Adding ‘comms’
is a cost effective solution to support various functions including emergency operations, system
planning, and distribution system management functions such as integrated volt-var control.
4.Additional Midline Reclosers – the ability to limit fault exposure on the distribution system is a well-
established risk mitigation technique. The fire ignition potential of a line fault is related to current
and clearing times. By adding circuit breakers to the system, both quantities are reduced.
Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 2, Page 14 of 21
Avista Internal Work Product
Page | 15
Secondary Actions (distribution system)
Digital Data Collection 2,816 5,722 132 564 *$20M
100% Substation
SCADA
132 547 0 1.6 $22.5M
WUI Grid Hardening 1,326 3,189 11 66 $150M
1.Digital Data Collection – note that the values shown for inherent risk reflect the lack of a purely
objective ‘system of record’ for trees near distribution lines. It is also indicates the constraints
associated with public rights-of-way and the lack of property rights adjacent to most distribution
lines. Although the inherent risk is likely overstated, vegetation management is the largest risk
element associated with distribution lines. LIDAR imaging is commonly used on transmission lines
and many utilities are now extending that practice to distribution circuits. Portland General is
investing in distribution LIDAR as are most California Utilities including SMUD. * The 10-year, $20M
dollar cost does not include offset costs associated with fewer ground patrols and labor savings in
the field.
2. 100% Substation SCADA – Though we’ve slowly reduced the number on non-scada substations,
there are several remaining stations without visibility. The inability to monitor or control equipment
in these stations is a significant risk component. Substation scada is widely recognized as an
industry best practice.
3.WUI Grid Hardening – during the workshops, several hardware components were singled out such
as fiberglass x-arms, hot tap connections, steel poles, and obsolete copper wire. Rather than list
them individually, the group consensus is to modify the GridMod program to fire harden system inWUI areas. For example, portions of the Colville 12F4 circuit route through WUI zones. Design
scope in that area would include elements to mitigate fire ignition.
Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 2, Page 15 of 21
Avista Internal Work Product
Page | 16
Future Actions
Overhead Conversion to
Underground
2,816 5,723 113 195 $500M
Develop Crew “Standby”
System
332 797 66 282 $15M
Fiberglass pole top pin 11 26 .5 2.6 $65M
Video Surveillance in
WUI
1.0 1.0 0.2 2.5 $1.35M
Arc Sensing Protective
Relays
23 39 1.1 6.6 $6.5M
Scarify Poles Bases in
WUI Zones
8.3 132 1.1 6.6 $14M
S&C Intellirupter 23 39 1.3 6.6 $13M
Create Internal Fire
Work Restrictions
1.0 5.0 0 0.5 $750K
Non Expulsive Fuses 0.5 2.6 0.2 0.8 $10M
Full Length Treated
Poles
41 164 16 82 $5M
Inset Poles Reduce
Span Lengths
16 63 0.6 2.6 $250M
Insulated Primary Tree
Wire
11.3 21 0.5 2.1 $30M
Avian Covers in WUI 0.3 2.7 0.13 0.17 $72M
50-CL1 Poles in WUI 3.3 16 2.3 11.3 $36M
Aerial Cable in WUI 11.3 26 0.1 1.1 $300M
Amend Forest Practice
to remove powerline
Total 3,431 7,671 244 767 $1,369M
1.Overhead to Underground Conversion –the systematic conversion of overhead facilities to
underground. Virtually all new distribution construction is underground and GridMod is converting
circuit segments when feasible and cost effective.
2.Develop Crew Standby – Avista’s after-hours crew call-out is strictly voluntary. By paying for crew
stand-by time, personnel would be pre-selected for call-out and reduce overall response during
contingency events.
3.Fiberglass pole top pin – not included in the WUI GridMod proposal, current pole top pin assemblies
are made from steel and are a possible source of fire ignitions. However, analysis of distribution
pole fires indicates that the wood x-arm contact is the primary ignition point for most pole fires.
4.Video Surveillance – many California utilities are using video surveillance to detect fire starts but we
believe the risk value proposition is low.
5.Arc Sensing relays – though pilot work is currently underway to develop the next generation of
distribution relays, this technology is in its infancy.
6.Scarify pole bases - this is a common practice in dry scrubland environments (sage brush) but a
majority of Avista’s rural distribution lines route through forested and agricultural areas.
Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 2, Page 16 of 21
Avista Internal Work Product
Page | 17
7.S&C Intellirupter – an alternative device to a conventional circuit breaker. Adding conventional
midline breakers is a recommended action.
8.Create internal fire restrictions – to mirror work restrictions issued by forest land managers.
Deemed as low value by workshop attendees.
9.Non-expulsive fuses – though conventional fuse action does represent an ignition source,
observational feedback does not support replacing them at this time.
10.Full length treated poles – treated poles offer some fire resistant characteristics but are not
supported by engineering, supply chain, or field operations.
11.Inset poles – reducing span lengths increases overall circuit strength and minimize wire-wire
contacts due to wind and storm events.
12.Insulated primary tree wire – focus will be on improved vegetation management.
13.Avian covers – extending avian covers in WUI would reduce ignition by animal contacts.
14.50 Cl-1 poles – increases ground clearance
15.Aerial cable in WUI – Insulted OH cable provides significant insulation but is very expensive and
presents hazards if supporting structures fail.
16.Amend Forest Practices… - when commercial timber harvest is conducted near powerlines, trees
near electric facilities are often left. These become risk/danger trees to the facilities. Requiring that
these trees be removed helps to minimize fall-in issues.
17.FR 3 Transformers – FR 3 oil does not support combustion but transformer tanks rarely fail during an
electrical fault.
___________________________________________________________________________
Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 2, Page 17 of 21
Avista Internal Work Product
Page | 18
Addendum
Q & A:
Q: Why isn’t Public Safety Power Shutoff listed?
A: Pre-emptive power shutoff (PSPS) is a system in-use in California (SDGE, SCE, PG&E,
PAC, and others) and while it was discussed during the SME Workshops, it requires systems
and processes not yet available at Avista. However, the concept will be addressed in the April
2020, Avista Wildfire Resiliency Plan and this plan does include recommendations that would
support a future deployment of PSPS.
Q: Why is 100% Substation SCADA identified as a fire risk?
A: Supervisory control systems are common throughout substation and power generating
facilities and allow for equipment monitoring, unit dispatch, and operational control over
equipment including power circuit breakers, voltage regulators, power transformers, and
generating equipment. The inability to de-energize a transmission or distribution circuit is a
general safety risk and may prevent Avista system operations to de-energize circuits.
_________________________________________________________________________
Core Logic Study
In 2018, Avista hired the Core Logic
Company to study the financial impacts
of a large scale, utility-caused wildfire
event. They estimate the property loss of
a 100 year event at $24 million dollars
and a 500 year event at $69 million.
These values pale in comparison to the
$30 billion dollar damage estimate
associated with the 2018 ‘Camp Fire’ in
Paradise, CA. However, it should be
noted that the Core Logic study did not
consider loss of human lives nor other indirect costs such as human displacement,
economic disruption, or fire suppression. The societal costs associated with catastrophic
wildfire is difficult to forecast and subject to a number of factors.
Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 2, Page 18 of 21
Avista Internal Work Product
Page | 19
SME Wildfire Risk Workshops
In the Wildfire Resiliency Plan Charter, March 2019, it was noted that recommended actions
would be based on risk-reduction whether directly financial, safety related, or related to
customer impacts. A series of workshops were held to identify opportunities to reduce risk on
the overhead transmission and distribution systems. The primary goal of the workshops were
to:
1)Identify actions to reduce the probability of electric ignition
2)Quantify the consequence or impact of potential actions
The workshops were divided into three sub-sections:
1)Design based (material and construction standards)
2)Operations (control center and field operations)
3)Maintenance (programmatic asset maintenance and vegetation management)
During the course of the six (6) workshops, over one hundred and sixty (160) actions were
identified. The Business Process Improvement (BPI) department assisted with the workshops
and assisted with the exercises. An ‘affinity exercise’ was used to identify actions. During the
affinity exercise, individuals are asked to use post-it notes to note individual actions such as
(examples):
a)Widen transmission rights-of-ways
b)Use steel poles on distribution lines
c)Develop a non-reclosing program (DLM) for transmission
d) Employ a dedicated firefighting crew at Avista
e) Convert overhead distribution lines to underground facilities
f)Develop a fire-weather forecast and monitoring system
In many cases, workshop attendees had similar items and were asked to group and agree on a
central idea. This provided an opportunity to discuss and clarify the proposed actions.
The group then identified the effort and benefit associated with each idea. Effort is associated
with financial commitment, complexity, sustainability, and manpower requirements. Benefit was
based on the relative risk reduction to reduce the likelihood and or impact associated with
wildfire. Items with high benefit, low effort were noted as the most likely to produce cost effective
results while low benefit, high effort items were discarded. Items deemed as cost effective and
prudent, moved on to the risk evaluation exercise.
The risk evaluation was modeled after the Asset Management Risk Matrix and the Enterprise
Risk Registry. In this treatment, a before and after probability was assigned along with the
impacts:
a)Financial (e.g. direct impact to infrastructure, 1st party claims, fire suppression)
b)Customer (the disruption to customers as monetized by multiplying customer*hours by
the interruption cost estimate (ICE, Avista $63/customer*hour) and 3rd party claims)
c)Safety (the potential for injury to both Avista employees, 1st responders, and the public)
Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 2, Page 19 of 21
Avista Internal Work Product
Page | 20
For example, conversion to underground significantly reduces the probability of electric ignition
with the before or ‘inherent’ risk associated directly to overhead distribution lines. Outage
statistics indicate that Avista’s distribution system is involved with approximately one-hundred
fire ignition events per year. Subsequent impact is related to fuel loading and weather
conditions. However, conversion of circuits in the wildland urban interface (WUI) virtually
eliminates tree to wire contacts which is the majority of fire ignition events related to powerlines.
During the workshop, the inherent risk associated with “OH/UG Conversion” was 78 or 90
possible points and though the risk was reduced by 38 points, the costs of conversion was
estimated at $500 million dollars over a 10-year period.
A subsequent ‘scoring’ exercise was conducted by indentifying items associated with:
1.Highest Inherent Risk --- items with significant risk should be considered for treatment
2.Highest Risk Reduction – opportunities that significantly reduce risk should be promoted
3.Lowest Overall Cost – low cost items should be considered before high cost alternatives
Scoring was based on the delineation of:
Gold – Best value (2 points)
Silver – Good value (1 point)
Bronze – Moderate value (0.5 points)
Scores were assigned based on the outcome of the “BPI” lead workshops. In addition, the
Wildfire Steering Group were asked to identify their top three (gold, silver, bronze) opportunities
for electric distribution. A subsequent employee workshop involving T&D subject matter experts
was convened to gather feedback on opportunities. Again, a review exercise was conducted to
ensure that recommended actions were supported by the broader engineering, operations, and
maintenance communities. Indeed, this report is a summarized version of those outcomes with
Low & No Cost items listed together with Recommended Actions (Should Do), while those
identified as Advised or Deferred did not receive consensus support or are cost prohibitive.
Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 2, Page 20 of 21
Avista Internal Work Product
Page | 21
The Legacy of Firestorm
The October 16, 1991 Firestorm is firmly etched into the minds
of local residents and WWP employees. Though October is not
generally considered ‘high fire season’, drought conditions
prevailed and 60 mph winds caused trees to fall through
powerlines. The majority of October-1991 fire ignitions were
related to trees contacting powerlines.
Between 1970 and 1990, population growth in Spokane grew
by 25% to 360,000 and during that time frame, homes were
built in unincorporated areas 11 times faster than in cities for a
total of 24,000 new homes in the wildland urban interface.
_______________________________________________
Avista has a long history of responding to fire events such as
the 2005-06 fires that burned significant portions of the Benton-
Othello line, the 2015 Carpenter Road Fire (Colville), and the
2019 fire that impacted seventeen (17) miles of the Walla
Walla-Wanapum 230 kV line. Nearly every year there is a fire
that impacts the Lolo-Oxbow 230 line. The ‘Oxbow’ line is
Avista’s interconnection with Idaho Power and is an important
asset connecting north and south Idaho. The line routes
through extremely rugged terrain in the Salmon and Snake
River country. Many structures are accessed via jet boat while
others require road building and hours of slow travel to reach.
The impact of wildfire is an ever-present risk to Avista
infrastructure, our employees, and customers.
However, fire is unlike other storms that disrupt power and utility experts recognize that service
restoration must be in coordination with fire protection activities and in many instances, be
postponed until it is safe to enter an area. One of the recommended actions is to delineate fire
in Avista’s Emergency Operations Procedure to ensure close coordination with fire incident
command and to promote the safety of employees and 1st responders above service restoration.
Firestorm Facts
o 114 homes destroyed
o 60 mph wind
o 42 days without rain
o 35,000 acres burned
o 90 fires
o 3,000 calls to 911, 24 hours
o 2 fatalities
o WWP Call Center – 11,000
calls in 2 hours
o WWP pays over $10 million in
fire suppression costs, $50
million in infrastructure costs
Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 2, Page 21 of 21
January 2020 David James, Avista Wildfire Plan Mgr.
Wildfire Resiliency Plan
Avista Utilities
Wildfire Resiliency Cost Forecast
January 2020
Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 3, Page 1 of 19
Avista Internal Work Product
PAGE 2
This report details the 10-year cost forecast associated with Avista’s 2020 Wildfire
Resiliency Plan and is consistent with a risk analysis report published in September
2019: “Wildfire Risk Analysis Summary, Proposed Actions, September 2019”.
This report will focus on forecasted capital investments and operating expenses based
on the recommendations from the Risk Analysis Summary. This report reflects a
refinement in scope versus that of the Risk Analysis Summary and includes preliminary
cost estimates. Several estimates are based on results of Avista’s Subject-Matter-
Expert Fire Workshops (June 2019), while others reflect parametric estimates based on
subsequent efforts to develop the Wildland Urban Interface (WUI) map. Feasibility
estimates generally reflect accuracy levels between 30 and 50%. Definitive cost
estimates require final engineering design and contractual commitments for materials
and labor.
PLAN LEVEL FORECAST
Consistent with the Risk Analysis Summary, this report is based on a 10-year planning
horizon from 2020 to 2029, with activities grouped into four main categories:
1.Enhanced Vegetation Management – This includes actions in excess of Avista’s
current Vegetation Management program and reflects a focus on reducing fire
ignition events. Plan elements include collecting vegetation data via digital hi-
resolution photography and Light Imaging, Detection, and Ranging (LIDAR),
increasing the frequency of the Risk Tree treatments in fire prone areas, and
conducting a public outreach campaign associated with ‘right tree-right place’
concepts.
2. Situational Awareness – This category includes extending Supervisory Control and
Data Acquisition (SCADA) systems to a portion of Avista’s thirty-three non-
communication substations (dark stations). Using SCADA to monitor and control
powerlines is a fundamental tenant of utility wildfire plans across the western U.S.
and Canada. Avista also plans to develop a web-based ‘fire-weather dashboard’;
combining publicly available weather and fire threat information to inform
operational readiness and enable enhancements to the Dry Land Mode (DLM)
distribution protection scheme.
Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 3, Page 2 of 19
Avista Internal Work Product
PAGE 3
3.Operations “Toolkit” & Metrics – Avista has a number of existing work processes
and programs aimed at reducing the impact of wildfire. Enhancements to existing
programs and the addition of other ‘operating’ elements are included in this group.
4.Grid Hardening & Dry Land Mode – Avista developed a non-reclosing distribution
protection scheme back in the early 2000’s to mitigate fire ignitions. The protection
scheme known internally as Dry Land Mode (DLM) will be updated to ensure
alignment with program objectives. Additionally, infrastructure replacements or
grid hardening will be implemented to reduce fire ignitions.
The total cost forecast of these efforts is depicted in the following graphs. The 10-year
capital cost forecast is $268,965,000 with a corollary operating expense cost of
$59,636,0001. By far, the largest capital investment is associated with electric distribution grid hardening ($193,200,000).
Significant operating expenses include enhancements to Avista’s vegetation
management program including annual risk tree removals in fire prone areas. These
additional measures account for $48,600,000 of the 10-year operating expense
forecast.
1 All operating expenses provided in this report reflect incremental amounts above existing expense levels
and are specific to the wildfire resiliency plan.
2020 2021 2022 2023 2024 2025 2026 2027 2028 2029
Capital $5,265 $16,985 $27,055 $31,380 $31,380 $31,380 $31,380 $31,380 $31,380 $31,380
Operating $3,016 $5,154 $6,800 $7,319 $7,337 $6,755 $6,524 $6,042 $5,611 $5,079
$0
$5,000
$10,000
$15,000
$20,000
$25,000
$30,000
$35,000
$
0
0
0
'
s
Avista Wildfire Resiliency
Plan Cost Forecast
Capital Operating
Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 3, Page 3 of 19
Avista Internal Work Product
PAGE 4
The following graphs reflect the 10-year cost forecasts of system and transmission level
programs and those associated solely with electric distribution. System-wide elements
include: personnel training, revisions to work processes, metrics tracking along with
fire-protective pole wraps and widening transmission rights-of-way. As noted, the single
largest investment element is the grid hardening of the electric distribution system.
Electric system outage history (2013-2018) indicates a 50:1 ratio between sustained
distribution and transmission system outages. Of particular note are the pole fires
associated with the distribution system. From 2013 to 2018, there were over 90 pole
fires on an annual basis. These fires generally follow periods of hot dry weather
combined with a light rain which increases leakage current across insulators and wood
cross-arms. Excessive leakage current produces pole fires. Also, the rate of vegetation
contacts is higher on the distribution system yielding a distribution to transmission
vegetation contact ratio of 100:1. Since the bulk of potential fire ignitions occur on
distribution circuits, efforts to reduce vegetation contacts and equipment failures are
aligned with those assets.
The 10-year cost forecast for capital investments and support systems on the transmission grid total $52,525,000 with an operating expense of $15,068,000.
2020 2021 2022 2023 2024 2025 2026 2027 2028 2029
Capital $2,010 $3,960 $5,885 $5,810 $5,810 $5,810 $5,810 $5,810 $5,810 $5,810
Operating $1,080 $1,308 $1,585 $1,585 $1,585 $1,585 $1,585 $1,585 $1,585 $1,585
$0
$1,000
$2,000
$3,000
$4,000
$5,000
$6,000
$7,000
$
0
0
0
'
s
Avista Wildfire Resiliency System & Transmission
Plan Cost Forecast
Capital Operating
Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 3, Page 4 of 19
Avista Internal Work Product
PAGE 5
As noted, the largest capital spend program is the effort to ‘harden’ the distribution grid
by replacing wood cross-arms, removing small copper wire, replacing obsolete
insulators, and installing wildlife guards. Operating expenses reflect efforts to enhance
vegetation management including conducting public outreach to replace tall growing
trees such as maples and pines with lower growing species like plums and dogwoods.
The accumulated 10-year cost forecast for distribution system capital is $216,400,000
with an operating expense of $44,569,000.
2020-2029 Avista Wildfire Resiliency Plan Cost Forecast
2020-2029 Capital Investment Operating Expense
System & Transmission $52,525,000 $15,068,000
Electric Distribution $216,400,000 $44,569,000
Plan Total $268,965,000 $59,636,000
2020 2021 2022 2023 2024 2025 2026 2027 2028 2029
Capital $3,255 $13,025 $21,170 $25,570 $25,570 $25,570 $25,570 $25,570 $25,570 $25,570
Operating $1,936 $3,847 $5,215 $5,734 $5,752 $5,170 $4,939 $4,457 $4,026 $3,494
$0
$5,000
$10,000
$15,000
$20,000
$25,000
$30,000
$
0
0
0
'
s
Avista Wildfire Resiliency Distribution Infrastructure
Plan Cost Forecast
Capital Operating
Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 3, Page 5 of 19
Avista Internal Work Product
PAGE 6
1.0 ENHANCED VEGETATION MANAGEMENT
The single largest contributor to possible fire
ignition events on Avista’s T&D system is electrical
contact between energized powerlines and
vegetation. Between 2013 and 2018, there were
nearly 2,000 vegetation contacts to the electric
distribution system. Though many of these
contacts occur during winter storm events, nearly
40% of contacts occur during the summer months.
Adapting and innovating Avista’s vegetation
management system is a primary objective of the
Wildfire Resiliency Plan. One element of the plan
is to collect digital data for 100% of Avista’s
transmission system (2,270 miles) and
approximately 40% of the distribution system
(3,040 miles).
The 10-year cost forecast for enhanced vegetation includes a capital investment of
$5,100,000 and operating expenses of $51,175,000. This is the largest operating
expense category.
2020 2021 2022 2023 2024 2025 2026 2027 2028 2029
Capital 510 510 510 510 510 510 510 510 510 510
Operating 2,275 4,400 6,000 6,500 6,500 5,900 5,600 5,150 4,700 4,150
0
1,000
2,000
3,000
4,000
5,000
6,000
7,000
$
0
0
0
'
s
Enhanced Vegetation Management
Plan Cost Forecast
Capital Operating
Information in this section reflects
findings from the “Wildfire Risk
Analysis Summary, September 2019”.
Individual plan elements are coded
with an alphanumeric such as ST-2 or
D-3. “ST” indicates System &
Transmission and reflects elements
such as the fire-weather dashboard
and others specific to the transmission
grid like protective FR mesh wraps for
wood poles. “D” indicates elements
specific to the electric distribution
system such as midline recloser
communications (D-12) where
communication systems will be added
to circuit reclosers.
Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 3, Page 6 of 19
Avista Internal Work Product
PAGE 7
Enhanced Vegetation Management Capital
10-yr
Operating
10-yr
ST-5 Transmission Digital Data Collection 0 6,825
ST-7 Fuel Reduction Partners (DNR, IDL, USFS) 0 1,500
ST-9 Widen Transmission Rights-of-Way 5,000 0
D-4 Vegetation Management included in
distribution designs
100 0
D-10 Distribution Annual Risk Tree in WUI areas 0 25,500
D-11 Public Outreach 'Right Tree-Right Place' 0 9,600
D-14 Distribution Digital Data Collection 0 7,750
Vegetation Total $5,100 $51,175
$ shown in 000’s
Enhanced Vegetation Management Plan Elements
ST-5 & D-14 Digital Data Collection – This includes aerial surveys and post flight
processing of high resolution photography and laser imaging (LIDAR) to identify
structure integrity issues (i.e. broken cross-arms, hot splices, code clearance violations,
and unauthorized attachments) and vegetation encroachments including conductor
clearance to the vegetation undergrowth and identification of risk/danger trees.
ST-7 Fuel Reduction Partners – Avista plans to partner with County Fire Districts and
State agencies including the Department of Natural Resources (WA) and Idaho
Department of Lands to reduce fuel loading near critical infrastructure sites such as
major substations and transmission corridors.
ST-9 Transmission Rights-of-Way – Many of Avista’s transmission easements do not
specify width nor do they provide clear language to remove danger trees. Modernizing
these transmission rights-of-way is a significant effort to reduce the risk of vegetation
contact.
D-4 Vegetation Management embedded in design – This acknowledges the need to
include vegetation clearing associated with both greenfield new construction and
brownfield reconstruction efforts.
D-10 Annual Risk Tree – To conduct annual assessments and removal of risk trees
associated with overhead distribution circuits.
D-11 Public Outreach “Right Tree-Right Place” – For many years Avista has
encouraged property owners to plant low growing trees near powerlines. This effort
would pair a public media campaign with field efforts to remove and replace trees.
Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 3, Page 7 of 19
Avista Internal Work Product
PAGE 8
2.0 SITUATIONAL AWARENESS
The ability to monitor and control transmission and distribution systems is a
fundamental tenant to effective risk mitigation. Avista operates 165 substations. Thirty-
three of those substations are not connected to transmission SCADA or the distribution
management system (DMS). Adding SCADA and/or DMS capability aligns with the Dry
Land Mode protection scheme and allows system operators to remotely configure
substation reclosers. In addition, Avista plans to develop a fire-weather heads-up
display that combines current weather forecasts with fire threat indices.
The 10-year cost forecast for situational awareness includes a capital investment of
$17,965,000 and operating expenses of $1,019,000.
Situational Awareness Capital
10-yr
Operating
10-yr
ST-2 Fire-Weather Dashboard 425 650
D-12 Midline Recloser Communications 540 272
D-15 100% Substation SCADA 17,000 97
17,965 1,019
$ shown in 000’s
2020 2021 2022 2023 2024 2025 2026 2027 2028 2029
Capital 220 1,190 2,135 2,060 2,060 2,060 2,060 2,060 2,060 2,060
Operating 2 57 91 99 107 116 124 133 141 149
0
500
1,000
1,500
2,000
2,500
$
0
0
0
'
s
Situational Awareness
Plan Cost Forecast
Capital Operating
Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 3, Page 8 of 19
Avista Internal Work Product
PAGE 9
Situational Awareness Plan Elements
ST-2 Fire-Weather Dashboard – Develop a web-based display combining near term
weather forecasts with prevailing fire threat conditions. This dashboard will be used to
inform operational posture and manage the Dry Land Mode program.
D-12 Midline Recloser Communications – Retrofit modern distribution midline
reclosers with cellular modems to enable remote operation, configuration, and
monitoring of distribution circuits in WUI Risk Tiers 2 and 3.
D-15 100% Substation SCADA – Add substation communication systems to non-com
stations located in or near WUI Tier 2 and 3 areas.
3.0 “OPERATIONS TOOLKIT” & METRICS TRACKING
During the Wildfire Risk Workshops conducted in June of 2019, a number of
opportunities were identified to elevate the Avista’s operational readiness during fire
season. Avista has a long history of working within highly regulated compliance
environments such as the Federal Department of Transportation for natural gas
operations, the Federal Energy Regulatory Commission for the transmission system,
and Environmental Protection Agency’s clean air and water requirements to name a
few. The Wildfire Plan elements will also be held to compliance level oversight.
The 10-year cost forecast for the operations toolkit includes a capital investment of
$300,000 and operating expenses of $2,285,000.
2020 2021 2022 2023 2024 2025 2026 2027 2028 2029
Capital 35 85 110 10 10 10 10 10 10 10
Operating 229 229 229 229 229 229 229 229 229 229
0
50
100
150
200
250
$
0
0
0
'
s
"Operations Toolkit" & Metrics Tracking
Plan Cost Forecast
Capital Operating
Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 3, Page 9 of 19
Avista Internal Work Product
PAGE 10
"Operations Toolkit" & Metrics Tracking Capital 10-yr Operating 10-yr
ST-1 EOP & Fire ICS Representative 0 50
ST-3 Engineering Review Major Events 100 0
ST-4 Wildfire Compliance Tracking 0 150
ST-8 Emergency Responder Training 0 1,300
D-1 Fuse Coordination Study 0 200
D-2 Recloser Event Reporting 0 400
D-3 Fire Ignition Tracking System 200 100
D-5 Fire Suppression 'wetting' agent 0 50
D-7 WUI layer in GIS 0 30
D-9 Arcos Wildfire Notification 0 5
Ops Toolkit & Metrics Total 300 2,285
$ shown in 000’s
“Operations Toolkit” & Metrics Tracking Plan Elements
ST-1 EOP & Fire ICS Representative – Aligns Avista’s Emergency Operating Plan
(EOP) with the Wildfire Resiliency Plan to account for the labor costs of embedding
Avista personnel in 100% of all County, State, and Federal Incident Command
Structures (ICS).
ST-3 Engineering Review Major Events – Require a 24-48 hour stand-down period
following major transmission events to allow for an engineered reconstruction plan.
ST-4 Wildfire Compliance Tracking – System level metric tracking of the Plan
elements.
ST-8 Emergency Responder Training – Provide annual fire safety training for electric
operating personnel as well as electric hazard safety training delivered to fire protection
personnel.
D-1 Fuse Coordination Study – This is an annual effort to ensure proper coordination
of distribution system fuses.
D-2 Recloser Event Reporting – To conduct engineering review of recloser events in
WUI areas.
D-3 Fire Ignition Tracking System – Adapting Avista’s Outage Management System
(OMS) to capture fire ignition outcomes.
D-5 Fire Suppression ‘wetting’ agent – Use of chemical additives such as ‘cold fire’ to
maintain the ‘wetting’ action of water.
D-7 WUI Layer in GIS – Annual maintenance of Avista’s Wildland Urban Interface
system.
Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 3, Page 10 of 19
Avista Internal Work Product
PAGE 11
D-9 Arcos Wildfire Notification – Provide annual dispatcher training on the use and
implementation of the Arcos call-out system to provide real time fire updates to key
personnel; including executive management.
4.0 GRID HARDENING AND “NEXT GEN” DRY LAND MODE
Since the early 2000’s, Avista has adapted the
protection of distribution circuits in fire prone
areas. Internally, this program to disable both
instantaneous tripping and automatic reclosing
is known as “Dry Land Mode”. Avista will
conduct a holistic review of this program and will
recommend program changes including adding
midline reclosers.
In order to reduce ignition events and to
effectively ‘harden’ the system against the
impacts of fire, a number of programmatic
measures are recommended to replace wood
structures, remove small copper wire, add
wildlife guards, and to protect wood poles with
fire-retardant (FR) mesh wrap. This is by far the
largest capital investment of the plan and
represents alignment with other regional utilities
including Northwestern, Idaho Power, Chelan
PUD, Portland General Electric, and PacifiCorp.
The 10-year cost forecast for grid hardening and
dry land mode includes a capital investment of
$245,600 and operating expenses of
$5,157,000.
Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 3, Page 11 of 19
Avista Internal Work Product
PAGE 12
Grid Hardening & DLM Capital
10-yr
Operating
10-yr
ST-6 Wood Pole Fire Retardant Mesh Wrap 0 2,500
ST-10 Structure Integrity Line Patrols 3,000 0
ST-11 Expedited Fire Response 0 93
ST-12 Additional Transmission Patrols in WUI 0 2,000
ST-13 Transmission Grid Hardening 44,000
D-6 Dry Land Mode 'Effectiveness' Study 0 100
D-8 Dry Land Mode 'Trigger' 0 20
D-13 Additional Midline Reclosers 5,400 444
D-16 WA Grid Hardening in WUI Tiers 2-3 120,000 0
D-17 ID Grid Hardening in WUI Tiers 2-3 73,200 0
Grid Hardening & DLM Total 245,600 5,157
$ shown in 000’s
2020 2021 2022 2023 2024 2025 2026 2027 2028 2029
Capital 3,500 12,200 19,300 23,800 23,800 23,800 23,800 23,800 23,800 23,800
Operating 510 469 481 491 501 511 571 531 541 551
0
5,000
10,000
15,000
20,000
25,000
$
0
0
0
'
s
Grid Hardening & Dry Land Mode Operations
Plan Cost Forecast
Capital Operating
Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 3, Page 12 of 19
Avista Internal Work Product
PAGE 13
Grid Hardening and Dry Land Mode Plan Elements
ST-6 Wood Pole Fire Retardant Mesh Wrap – This is a program to add fire retardant
mesh wraps on transmission poles subject to ground level fires (e.g. channeled
scablands, agricultural areas, and dry grasslands.) Avista is currently using fire retardant pole paint and is considering moving to a more permanent mesh wrap.
ST-10 Structure Integrity Line Patrols – Provides additional funds for capital follow-up
work to ensure that defects likely to produce ignition are treated prior to fire season.
ST-11 Expedited Fire Response – This is an agreement with fire protection agencies to
patrol transmission fault events during fire season.
ST-12 Additional Patrols in WUI – An annual line inspection patrol specific to fire
ignition and fire impact hazards.
ST-13 Transmission Grid Hardening – To convert existing transmission wood to steel
Structures in WUI Tiers 2 & 3.
D-6 Dry Land Mode ‘Effectiveness Study’ – Review Avista’s summer operating mode
including electric circuits in WUI Tier 2 & 3 areas.
D-8 Dry Land Mode ‘Trigger’ – Monitor US Forest Service Fire Threat Index to
implement DLM. This is a GIS based system.
D-13 Additional Midline Reclosers – Enhance DLM to require the installation of
several circuit reclosers and communications systems.
D-16 WA Grid Hardening in WUI Tier 2-3 – The Washington component of distribution
grid hardening includes replacing wood cross-arms with fiberglass, replacing small
copper conductor, installing select steel poles, and adding wildlife guards to fuses,
arrestors, and transformer bushings.
D-17 ID Grid Hardening in WUI Tier 2-3 – The Idaho component of the above element.
Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 3, Page 13 of 19
Avista Internal Work Product
PAGE 14
ADDENDUM
Wildland Urban Interface
Assessing the risk of wildfire and aligning
treatments to reduce that risk is the objective of
Avista’s Wildfire Resiliency Plan. The concept
of Wildfire Urban Interface (WUI) has emerged
as a widely adopted method for quantifying that
risk. At Avista, we recognize that our T&D
facilities are both vulnerable to the impact of fire
(consequence of fire) and are a potential source
of fire ignition (probability of fire). Avista’s Plan
is squarely focused on reducing both fire
consequence and probability. Jake Jacobs, GIS
Specialist, has developed a WUI map based on
Avista’s electric distribution system, housing
density, and Wildfire Hazard Potential data as
provided by the U.S. Department of Agriculture.
As referenced in “Wildfire Risk Analysis
Summary, September 2019” and in this report,
the WUI risk map allows Avista to target
treatments to reduce fire risk to our customers,
the communities that we serve, and to
safeguard our employees. The importance of
aligning actions with risk cannot be overstated.
A larger version of the WUI map is reprinted on the following page. The WUI is divided
into three tier levels:
Tier 1 (Low) – Yellow Highlight – Geographic areas with <10% of Wildfire
Hazard Potential (WHP) rated at moderate fuel levels or higher.
Tier 2 (Elevated) – Orange Highlight – Geographic areas with 10-50% of WHP
rated at moderate fuels levels or higher.
Tier 3 (High) - Red Highlight – Geographic areas with 50-100% of WHP rated at
moderate fuel levels or higher.
Areas not highlighted fall below the criteria for WUI either because they are heavily
populated (cities) and have well developed fire defense mechanisms or they are so
sparsely populated that the consequence of fire is low. Do not confuse the WUI map
with fire probability. Most national forest lands fall outside of the WUI because human
development is low or non-existent. The WUI map indicates where human development
is most at-risk from the impact of wildfire.
Note that most of Avista’s vegetation and system hardening efforts will be targeted in the WUI Tier 2 and 3 areas.
Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 3, Page 14 of 19
Avista Internal Work Product
PAGE 15
Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 3, Page 15 of 19
Avista Internal Work Product
PAGE 16
Enhanced Vegetation Management
Historically, utility vegetation management systems were focused at maintaining
reliability service levels. However, over the past decade, utility trends are shifting
towards a more risk-based approach with fire risk mitigation as a primary factor.
The following chart and table indicates actual spend in Avista’s distribution vegetation
program. The program has three main elements:
1.Planned Maintenance – to systematically trim and remove vegetation growing underneath or
directly adjacent to primary distribution circuits (13.2-34.5 kV). This program coveredapproximately 20% of the system per year resulting in a 5-year rotation cycle.
2.Unplanned Maintenance – Avista responds to customer requests for tree trimming including
‘internal’ customers. The upward trend of unplanned work presents a significant resource
challenge and oftentimes erodes planned maintenance.
3.Risk Tree – in addition to proximity trimming, dead and dying trees within the strike distance ofthe line are slated for removal. This oftentimes requires property owner consent as most of
these trees are located outside of established easement areas.
2012-2018 – actual program spend indicated
2019-2020 – budget forecast amounts
01,000,0002,000,0003,000,0004,000,0005,000,0006,000,0007,000,0008,000,0009,000,000
2012A 2013A 2014A 2015A 2016A 2017A 2018A 2019B 2020B
Distribution Vegetation
Management
Miscellaneous Risk Tree Unplanned Maintenance Planned Maintenance
Risk Tree Shifts
to Wildfire
Resiliency
Starting in 2020
Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 3, Page 16 of 19
Avista Internal Work Product
PAGE 17
Adding wildfire risk mitigation to the base vegetation program results in three actions:
1.Digital Data Collection – The industry is trending away from cadence based programs and
towards risk based programs. Avista plans to collect LIDAR data in the elevated fire risk areas
(WUI Tiers 2&3). This data will be used to design line clearance prescriptions, it will also serve as
an audit of prior work.
2.Annual Risk Tree- By separating the risk tree activities from planned maintenance, Avista will
prioritize risk tree removals on a risk-cost basis.3.Right Tree-Right Pace – Avista plans to conduct a customer outreach program and encourage
the removal of tall growing trees with more compatible species. Tree that mature at a crown
height of 20-25 feet typically do not require trimming and do not pose a hazard for powerline
operation or maintenance.
If one assumes a base vegetation spend of $8M/year, adding fire resiliency to the base
plan results in a cost forecast as shown below. This graph simply reflects the addition
of wildfire efforts to Avista’s existing program with the exception of transitioning the risk
tree element to the wildfire plan.
02,000,0004,000,0006,000,0008,000,00010,000,00012,000,00014,000,00016,000,000
2020 2021 2022 2023 2024 2025 2026 2027 2028 2029
Wildfire + Distribution
Vegetation Management
Base Level Dx Vegetation Dx Digital Data CollectionAnnual Risk Tree Right Tree-Right Place
Base Level
Distribution
Vegetation Plan
($8M/year)
Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 3, Page 17 of 19
Avista Internal Work Product
PAGE 18
Cost Forecast Data
The bulk of this report
identifies the forecasted
annual costs associated
with the Wildfire Plan.
As with any forecast,
these values are subject
to revision and should
not be conflated as
definitive cost
estimates. However,
they do convey the
scope and breadth of
Avista’s commitment to
promoting public safety
and to safeguarding
homes, property, and
infrastructure. The
various charts and
graphs included in this
report are based on this
dataset.
This table is reprinted on the following page.
Capital Operating
System & Transmission 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 10-yr 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 10-yr
ST-1 EOP & Fire ICS Representation 0 5 5 5 5 5 5 5 5 5 5 50
ST-2 Fire-Weather Dashboard 200 150 75 425 50 75 75 75 75 75 75 75 75 650
ST-3 Engineering Review Major Events 10 10 10 10 10 10 10 10 10 10 100 0
ST-4 Wildfire Compliance Tracking 0 15 15 15 15 15 15 15 15 15 15 150ST-5 Digital Data Collection 0 325 500 750 750 750 750 750 750 750 750 6,825ST-6 Wood Pole FR Mesh Protection 0 250 250 250 250 250 250 250 250 250 250 2,500ST-7 Fuel Reduction Partner 0 150 150 150 150 150 150 150 150 150 150 1,500ST-8 Emergency Responder Training 0 130 130 130 130 130 130 130 130 130 130 1,300ST-9 Conforming Rights-of-Way 500 500 500 500 500 500 500 500 500 500 5,000 0ST-10 Structure Integrity Line Patrols 300 300 300 300 300 300 300 300 300 300 3,000 0ST-11 Expedited Fire Response 0 5 8 10 10 10 10 10 10 10 10 93
ST-12 Additional Patrols in WUI 0 200 200 200 200 200 200 200 200 200 200 2,000
ST-13 Transmission Grid Hardening 1,000 3,000 5,000 5,000 5,000 5,000 5,000 5,000 5,000 5,000 44,000
Annual Total $2,010 $3,960 $5,885 $5,810 $5,810 $5,810 $5,810 $5,810 $5,810 $5,810 $52,525 $1,080 $1,308 $1,585 $1,585 $1,585 $1,585 $1,585 $1,585 $1,585 $1,585 $15,068
Capital Operating
Electric Distribution 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 10-yr 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 10-yr
D-1 Fuse Coordination Study 0 20 20 20 20 20 20 20 20 20 20 200
D-2 Recloser Event Reporting 0 40 40 40 40 40 40 40 40 40 40 400
D-3 Fire Ignition Tracking System 25 75 100 200 10 10 10 10 10 10 10 10 10 10 100
D-4 Veg Mngt in CPC designs 10 10 10 10 10 10 10 10 10 10 100 0D-5 Fire Suppression 'wetting' agent 0 5 5 5 5 5 5 5 5 5 5 50D-6 Dry Land Mode 'effectiveness' study 0 50 50 100D-7 WUI layer in GIS 0 3 3 3 3 3 3 3 3 3 3 30D-8 Dry Land Mode 'trigger'0 2 2 2 2 2 2 2 2 2 2 20D-9 Arcos Wildfire Notification 0 1 1 1 1 1 1 1 1 1 1 6D-10 Distribution Annual Risk Tree 0 1,300 2,500 3,100 3,100 3,100 2,900 2,700 2,500 2,300 2,000 25,500D-11 Public Outreach 'Right Tree-Right Place'0 500 1,000 1,500 1,500 1,500 1,100 1,000 750 500 250 9,600
D-12 Midline Recloser Communication 20 40 60 60 60 60 60 60 60 60 540 2 6 12 18 24 30 36 42 48 54 272
D-13 Additional Midline Reclosers 200 400 600 600 600 600 600 600 600 600 5,400 3 9 19 29 39 49 59 69 79 89 444
D-14 Digital Data Collection 0 0 250 500 1,000 1,000 1,000 1,000 1,000 1,000 1,000 7,750
D-15 100% Substation Scada 0 1,000 2,000 2,000 2,000 2,000 2,000 2,000 2,000 2,000 17,000 0 1 4 6 8 11 13 16 18 20 97D-16 WA Grid Hardening in WUI Tier 2-3 2,000 6,500 10,000 14,500 14,500 14,500 14,500 14,500 14,500 14,500 120,000 0D-17 ID Grid Hardening in WUI Tier 2-3 1,000 5,000 8,400 8,400 8,400 8,400 8,400 8,400 8,400 8,400 73,200 0Annual Total $3,255 $13,025 $21,170 $25,570 $25,570 $25,570 $25,570 $25,570 $25,570 $25,570 $216,440 $1,936 $3,847 $5,215 $5,734 $5,752 $5,170 $4,939 $4,457 $4,026 $3,494 $44,569
Plan Total $5,265 $16,985 $27,055 $31,380 $31,380 $31,380 $31,380 $31,380 $31,380 $31,380 $268,965 $3,016 $5,154 $6,800 $7,319 $7,337 $6,755 $6,524 $6,042 $5,611 $5,079 $59,636
Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 3, Page 18 of 19
Avista Internal Work Product
PAGE 19
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Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 3, Page 19 of 19
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Sources: Esri, HERE, Garmin, FAO, NOAA, USGS, © OpenStreetMap contributors, and the GIS User Community
Electric Distribution System
Wildland Urban Interface
Tier 1
Tier 2
Tier 3
Proposed Wildland Urban Interface
11/19/2019
Datasets:
2018 USDA Wildfire Hazard Potential
2019 Avista Electric Distribution System
Prepared by Erika Jacobs, Senior GIS Analyst
WA 932 1,418 555 2,236
ID 376 917 378 873
State Tier 1 Miles Tier 2 Miles Tier 3 Miles Non-WUI Miles
Exhibit No. 12
Case Nos. AVU-E-21-01 & AVU-G-21-01
D. Howell, Avista
Schedule 4, Page 1 of 1
AVISTA’S WILDFIRE RESILIENCY PLAN
Communications Plan
Overview
Wildfires pose a large and growing risk to millions of Americans. In recent years, public focus on
this significant risk – and the role that power providers play – has intensified and the stakes for
utilities have never been higher.
To that end, Avista is taking its role and responsibilities seriously and has developed a
comprehensive Wildfire Resiliency Plan involving both strategic investments to mitigate risk, as
well as a set of processes and responses that can be deployed in case of a wildfire.
Avista’s comprehensive Wildfire Resiliency Plan builds on and enhances Avista’s emergency
operation preparedness; promotes public safety and protection of physical assets and property;
and safeguards company assets to mitigate financial and liability risks. In addition, the Wildfire
Resiliency Plan emphasizes collaboration with land-management and fire response agencies. It
includes the following goals:
1.Promote Public & Worker Safety: Protect Avista employees and customers from the
impact of wildfires.
2.Emergency Preparedness: Minimize service disruptions caused by wildfires and other
extreme weather events.
3.Financial Protection: Protect the Company from financial and reputational liability.
To meet these goals, the plan’s recommendations are focused in four key areas:
1.Vegetation Management- Implement actions above and beyond traditional, reliability-
based approaches with the goal of reducing contact between vegetation and utility
powerlines in targeted geographic areas.
2.Situational Awareness- Implement tools and systems that enhance Avista’s capabilities
and knowledge in weather forecasting, fire prediction, and equipment control to inform
operational decision-making.
3.Operations and Emergency Response- Recognize wildfire as separate and distinct
from other significant weather events, and utilize training and simulation for Avista
personnel to better prepare them to work with fire professionals during an event.
4.Grid Hardening- Replace and strengthen infrastructure in fire-prone areas, reducing the
likelihood of a spark-ignition source and protecting critical infrastructure from the impacts
of fire.
A key element of this Wildfire Resiliency Plan is ensuring that Avista stakeholders know the plan
is in place, buy into it, and take pride in the fact that the Company is taking the right
precautionary steps to reduce the potential for and impact of wildfires. A strong and effective
strategic communications campaign is critical to the Company to ensure broad awareness and
demonstrate Avista’s commitment to preventing wildfires—a plan directed at all of Avista’s key
Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 5, Page 1 of 4
stakeholders, including: customers, employees, state and local government officials and
regulators, law enforcement/fire departments, local media, and shareholders.
The following is the framework for communicating about the Wildfire Resiliency Plan.
Communications Objectives
•Ensure awareness among all key stakeholders of the significant actions and investment
Avista is taking to prevent or mitigate the risk of wildfires.
•Instill confidence in Avista as a proactive and responsible corporate citizen.
•Get “buy-in” support and recognition from key stakeholders that Avista is taking wildfire
safety seriously and has a Wildfire Resiliency Plan in place.
•Help generate support and recognition for Avista as a leader that is doing all it can to
help avoid wildfires and has in place a strong wildfire prevention and safety program.
•Demonstrate Avista’s focus on prioritizing the safety and well-being of its customers and
the communities it serves.
Phase 1 Communications
The first phase of communications about the Wildfire Resiliency Plan will be focused on the
plan’s launch and the communications objectives noted above. The timing and implementation
of the tactics will be aligned with when the plan is finalized. No communications will begin until
the organization is ready from an operational and regulatory standpoint.
The second phase of communications would support specific strategies included within the plan,
such as enhanced vegetation management. Each initiative that requires customer or external
stakeholder behavior change would have its own communications plan with objectives, tactics
and timelines associated, as appropriate.
Recommended materials for development of phase one include:
Item Description/Details
Fact sheet •Overarching description of the Wildfire Resiliency Plan that is
simple and easy to understand
•Provides key highlights and elements of the plan
•Designed piece that aligns with Avista brand
•Can be used internally and externally
News release •Announces launch of plan
•Sent nationally over the wire
Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 5, Page 2 of 4
Page on
myavista.com
•Serve as home base for information about the plan
•Provides information about Avista’s approach and commitment to
wildfire resiliency
•Would include a link to the plan, the fact sheet, the news release,
Avista’s vegetation management and right tree right place web
pages
•Provide customers information they need about wildfire, including
links to partners and community resources
Customer email •Use key messages
•Educate customers about steps Avista is taking to keep them safe
and provide reliable energy
Customer
handout
•Collateral piece that can be provided to customers to give them
information on emergency preparedness and wildfire safety
Presentation •Tell Avista’s Wildfire Resiliency Plan story
•Align with communications objectives
•For use with media, community groups, business leaders, etc.
Visual assets •Identify and/or develop visual assets that can be used in the fact
sheet, on the web, on social, in customer communications, in media
engagements, etc.
Internal
communications
materials
•Leader communication
•Employee communication
•E.view EXTRA
•Additional TBD
Public Relations Activities by Audience
Below are the tactics per audience that should be put in place.
1.Communications Targeted to All Audiences
•Broadly issued press release
•Media outreach and coordination
•A dedicated section on Avista’s website which will serve as a repository of
resources on prevention, preparedness and support. Content should be
continuously updated and eventually include content mentioned above:
Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 5, Page 3 of 4
o Wildfire Plan fact sheet
o Advice on what customers can do to be prepared
•Social media posts with links to wildfire safety web page, content about
upcoming inspections and repairs, tips during wildfire season, and other wildfire
related announcements.
•Provide Avista wildfire links to state Commissions for use on state sites.
2.Employees
•All leader communication, all employee communication, E.view EXTRA to align
with news release distribution.
3.Customers (business and residential)
•Communicate the Avista Wildfire Resiliency Plan through customer email(s).
•Highlight the plan and include timely information in customer newsletters.
4.Local communities
•Identify appropriate/relevant opportunities for communications with key
stakeholders, which could include newsletter articles, community leader meetings
and/or presentations, town hall meetings, etc. in targeted communities served by
Avista.
•Engage with media as appropriate in cities/towns across the service area to
coincide with any community presentations or engagement.
•Add information and FAQs about wildfire safety related work to web page.
•Include tips on how to avoid wildfires, how to prepare for outages, what to put in
an emergency kits, and other resources to help get people informed.
Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 5, Page 4 of 4
Wildfire Resiliency Plan (July 2020)
Business Case Justification Narrative Page 1 of 10
EXECUTIVE SUMMARY
The threat of wildfires poses a significant risk to utilities across the western United States. In May
of 2020, Avista published its “2020 Wildfire Resiliency Plan” which details twenty-eight actions
to mitigate the risk of wildfire. The Plan includes upgrades to infrastructure aimed at reducing
spark-ignition events and protecting critical infrastructure from the threat of wildfires. The Plan
details a 10-year time horizon. The $268,965,000 Plan includes investments in the four
categories:
Enhanced Vegetation Management
Widen Transmission R/Ws ($5,000,000)
Vegetation management incorporated into CPC designs ($100,000)
Situational Awareness
Fire-Weather Dashboard & TROVE risk analysis ($425,000)
Midline Reclosers Communications ($540,000)
100% Substation SCADA ($17,000,000)
Operations and Emergency Response
Transmission Design Review of Major Events ($100,000)
Fire Ignition Tracking System ($200,000)
Grid Hardening & Dry Land Mode
Transmission Fire Inspection ($3,000,000)
Transmission Grid Hardening ($44,000,000)
Midline Reclosers ($5,400,000)
Distribution Grid Hardening (193,200,000)
Wildfire Plan (CapX 2020-2029) $268,965,000
The 10-year accumulated inherent risk of wildfire is estimated between $8.05 and $18.2 billion
dollars. The mitigated risk (with controls) is estimated between 0.5 and $2.3 billion dollars. Again,
accumulated over a 10-year period. The risk reduction is estimated at between 8X and 16X with
a cost – benefit ratio between 22.9 and 48.6 including $60 million dollars of O&M expense.
VERSION HISTORY
Version Author Description Date Notes
0 David James Initial Submission to Capital
Planning
April 1,
2020 Initial submission
1 David James Refresh using 2020 BC narrative
template
July 29,
2020
No revision to capital
requirements
Exhibit No. 12Case Nos. AVU-E-21-01 & AVU-G-21-01
D. Howell, AvistaSchedule 6, Page 1 of 10
Wildfire Resiliency Plan (July 2020)
Business Case Justification Narrative Page 2 of 10
GENERAL INFORMATION
Requested Spend Amount $268,965,000 (2020-2029) CAPX
$59,586,000 (2020-2029 OPX) for information
Requesting Organization/Department Electric Operations
Business Case Owner David Howell
Business Case Sponsor Heather Rosentrater
Sponsor Organization/Department Electric Operations
Category Program
Driver Customer Service Quality & Reliability
Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 6, Page 1 of 10
Wildfire Resiliency Plan (July 2020)
Business Case Justification Narrative Page 3 of 10
1. BUSINESS PROBLEM
1.1 What is the current or potential problem that is being addressed?
The risk of wildfires is increasing throughout the western United States. Data from the
U.S. Forest service indicates a 300% increase in the number of wildfires since 1970
Data specific to fires in Washington and Idaho fires suggest that fire size has increased
400-500% over the last several decades. Though the number of powerline involved
wildfires remains relatively low (5-7% WA DNR statistics, 1990-2015), wildfire is
differentiated from natural disasters in that ‘cause and origin’ investigations often lead
to claims for fire suppression costs, property damage, timber loss, and personal injury.
In the fall of 2018, a small team of Avista employees was assembled to assess the
risks, develop defensive strategies, and implement a Wildfire Resiliency Plan. This
business case reflects the 10-year strategy to build defense strategies against wildfire.
1.2 Discuss the major drivers of the business case and the benefits to the customer?
Wildfire does not align well with the existing business case drivers. Unlike most asset
replacement programs, Wildfire Resiliency is a risk-based, not a condition-based
program. Therefore, it is best aligned with Customer Service Quality & Reliability and
is expected to reduce risk exposure by at least $7.5 billion dollars over a 10-year period.
1.3 Identify why this work is needed now and what risks there are if not approved or
is deferred – Avista has published a “2020 Wildfire Resiliency Plan” and have
committed to implementation at the highest levels of the Company including the Board
of Directors. It is a Tier 1 Enterprise Level risk.
1.4 Identify any measures that can be used to determine whether the
investment would successfully deliver on the objectives and address the
need listed above – As part of Wildfire Resiliency, performance metrics will be
tracked including, fire ignition events, to measure the efficacy of the program.
Transmission and Distribution Operations tracks system outages including cause-code,
duration, and impacted customers. The primary goal of the program is to limit the
number of spark-ignition events and the reduction in outages will enhance customer
experience.
1.5 Supplemental Information
1.5.1 Please reference and summarize any studies that support the problem
Several supporting documents are available for review:
2020 Avista Wildfire Resiliency Plan (June 2020)
Wildfire Resiliency Cost Plan (January 2020)
Wildfire Risk Assessment (September 2019)
Wildfire Plan Charter (May 2019)
1.5.2 For asset replacement, include graphical or narrative representation of metrics
associated with the current condition of the asset that is proposed for
replacement.
Wildfire Resiliency is a comprehensive, risk-based program and includes targeted
equipment replacement. Condition based metrics are not considered.
In May and June of 2019, a series of risk workshops were held to identify potential defensive
strategies to reduce the risk of wildfire. These workshops were facilitated by the Business
Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 6, Page 2 of 10
Wildfire Resiliency Plan (July 2020)
Business Case Justification Narrative Page 4 of 10
Process Improvement team with support from Senior Risk Manager, Bob Brandkamp, and
Asset Management Analyst, Jeff Smith. Over the course of 6-workshops, 160 mitigation
strategies were identified. 60 of those were analyzed in detail and ultimately, 28 strategies
were adopted into the plan including transmission and distribution grid hardening, a
comprehensive review of dry land mode operating strategies, and systems to actively monitor
fire-risk. In addition to internal processes, Avista participated in several utility forums
sponsored by the Western Energy Institute including the Wildfire Planning & Mitigation
workshop. In general, the approach to fire mitigation is consistent throughout the utility
sector.
Option Capital Cost Start Complete
Wildfire Resiliency Plan $268,965,000 07 2020 12 2029
2.1 Describe what metrics, data, analysis or information was considered when
preparing this capital request.
Wildfire Resiliency is a risk-based plan. Inherent (existing) and mitigated (future) risks
were assessed in three categories:
Financial (the cost of replacing T&D infrastructure associated with wildfire events
and response to third party and other claims for fire suppression and damages)
Customer (the cost impact to customers including outage duration and societal
disruption)
Safety (costs associated with worker and public injuries)
Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 6, Page 3 of 10
Wildfire Resiliency Plan (July 2020)
Business Case Justification Narrative Page 5 of 10
The following is a list of the 28 recommended actions indicating a range of inherent and
mitigated risk costs. Note that not all the actions reflect capital investments (e.g.
vegetation management). Monetized risk values represent a 10-year operating time
horizon.
Inherent Risk ($M) Managed Risk ($M) Cost: Benefit Risk Red
System & Transmission Low High Low High Low High %
EOP & Fire ICS Representation 9.6 17.7 9.6 17.6 0.0 2.0 0%
Fire-Weather Dashboard 4.8 8.8 4.3 4.8 0.5 3.7 33%
Engineering Review Major Events 1 6.9 0.9 2.4 1.0 45.0 58%
Wildfire Compliance Tracking 9.6 18 2.2 2.7 49.3 102.0 82%
Digital Data Collection 9.6 17.7 0.9 2.4 1.3 2.2 88%
Wood Pole FR Mesh
Protection 9.6 28 4.3 4.8 2.2 9.5 76%
Fuel Reduction Partner 15 29 3 29 8.0 0.0 27%
Emergency Responder Training 1.8 2.3 0.3 0.9 1.2 1.1 71%
Conforming Rights-of-Way 4.8 8.8 0.2 1.4 0.9 1.5 88%
Transmission Inspection Pym 4 59 1.1 2.6 0.6 11.3 94%
Expedited Fire Response - - - - n/a
Transmission Grid Hardening n/a
Transmission Total $70 $196 $27 $69 0.6 1.9 64%
Inherent Risk ($M) Managed Risk ($M) Cost: Benefit Risk Red
Electric Distribution Low High Low High Low High %
Fuse Coordination Study 41 107 1.6 8.2 197.0 494.0 93%
Recloser Event Reporting 21 82 1.3 8.4 49.3 184.0 91%
Fire Ignition Tracking System 132 547 46 213 286.7 1113.3 62%
Veg Mngt in CPC designs 20 278 10 21 100.0 2570.0 90%
Fire Suppression 'wetting' agent 53 582 11 66 840.0 10320.0 88%
Dry Land Mode 'effectiveness' study 21 57 0.6 4.2 204.0 528.0 94%
WUI layer in GIS 0 0.11 0 0.11 0.0 0.0 0%
Dry Land Mode 'trigger' - - - - n/a
Arcos Wildfire Notification - - - - n/a
Distribution Annual Risk Tree 2,816 5,722 264 1,226 100.1 176.3 83%
Public Safety Initiative 'Right
Tree-Right Place' 563 1,145 2.25 28.2 58.4 116.3 98%
Midline Recloser Communication 14.6 29 0.25 0.28 17.7 35.4 99%
Additional Midline Reclosers 22.6 39 5.63 13.2 2.9 4.4 69%
Digital Data Collection 2,816 5,722 132 564 346.3 665.5 92%
100% Substation Scada 132 547 0 1.6 7.7 31.9 100%
WA Grid Hardening in WUI Tier 2-3 823.6 1980.75 6.83 41 6.8 16.2 98%
ID Grid Hardening in WUI Tier
2-3 502.4 1208.25 4.17 25 6.8 16.2 98%
Distribution Total $7,978 $18,046 $486 $2,220 28.7 60.6 90%
Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01
D. Howell, Avista
Schedule 6, Page 4 of 10
Wildfire Resiliency Plan (July 2020)
Business Case Justification Narrative Page 6 of 10
2.2 Discuss how the requested capital cost amount will be spent in the current
year (or future years if a multi-year or ongoing initiative). (i.e. what are the
expected functions, processes or deliverables that will result from the capital spend?). Include
any known or estimated reductions to O&M as a result of this investment.
The illustration indicates the estimated capital and operating investments. Though we
do expect outage rates associated with vegetation and equipment failures to trend
downward, O&M ‘offsets’ are not a significant factor. The primary focus of this plan is
risk reduction and to protect the financial viability of the Company.
Capital cost breakdown by year and project (values in $000’s).
2020 2021 2022 2023 2024 2025 2026 2027 2028 2029
Capital $5,265 $16,985 $27,055 $31,380 $31,380 $31,380 $31,380 $31,380 $31,380 $31,380
Operating $2,416 $5,371 $6,917 $7,435 $7,354 $6,772 $6,540 $6,059 $5,627 $5,096
$0
$5,000
$10,000
$15,000
$20,000
$25,000
$30,000
$35,000
$
0
0
0
'
s
Avista Wildfire Resiliency
Plan Cost Forecast
Capital Operating
CapitalSystem & Transmission 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 10-yr
ST-1 EOP & Fire ICS Representation 0
ST-2 Fire-Weather Dashboard 200 150 75 425ST-3 Engineering Review Major Events 10 10 10 10 10 10 10 10 10 10 100
ST-4 Wildfire Compliance Tracking 0
ST-5 Digital Data Collection 0
ST-6 Wood Pole FR Mesh Protection 0
ST-7 Fuel Reduction Partner 0ST-8 Emergency Responder Training 0
ST-9 Conforming Rights-of-Way 500 500 500 500 500 500 500 500 500 500 5,000
ST-10 Transmission Inspection Pgm 300 300 300 300 300 300 300 300 300 300 3,000
ST-11 Expedited Fire Response 0
ST-12 Transmission Grid Hardening 1,000 3,000 5,000 5,000 5,000 5,000 5,000 5,000 5,000 5,000 44,000
Transmission Total $2,010 $3,960 $5,885 $5,810 $5,810 $5,810 $5,810 $5,810 $5,810 $5,810 $52,525
CapitalElectric Distribution 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 10-yr
D-1 Fuse Coordination Study 0
D-2 Recloser Event Reporting 0
D-3 Fire Ignition Tracking System 25 75 100 200
D-4 Veg Mngt in CPC designs 10 10 10 10 10 10 10 10 10 10 100
D-5 Fire Suppression 'wetting' agent 0
D-6 Dry Land Mode 'effectiveness' study 0
D-7 WUI layer in GIS 0D-8 Dry Land Mode 'trigger'0
D-9 Arcos Wildfire Notification 0
D-10 Distribution Annual Risk Tree 0
D-11 Public Safety Initiative 'Right Tree-Right Place'0
D-12 Midline Recloser Communication 20 40 60 60 60 60 60 60 60 60 540D-13 Additional Midline Reclosers 200 400 600 600 600 600 600 600 600 600 5,400
D-14 Digital Data Collection 0
D-15 100% Substation Scada 0 1,000 2,000 2,000 2,000 2,000 2,000 2,000 2,000 2,000 17,000
D-16 WA Grid Hardening in WUI Tier 2-3 2,000 6,500 10,000 14,500 14,500 14,500 14,500 14,500 14,500 14,500 120,000
D-17 ID Grid Hardening in WUI Tier 2-3 1,000 5,000 8,400 8,400 8,400 8,400 8,400 8,400 8,400 8,400 73,200
Distribution Total $3,255 $13,025 $21,170 $25,570 $25,570 $25,570 $25,570 $25,570 $25,570 $25,570 $216,440
D-10 - $500k/per year added to the above for budget
Plan Total $5,265 $16,985 $27,055 $31,380 $31,380 $31,380 $31,380 $31,380 $31,380 $31,380 $268,965
Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 6, Page 5 of 10
Wildfire Resiliency Plan (July 2020)
Business Case Justification Narrative Page 7 of 10
2.3 Outline any business functions and processes that may be impacted (and
how) by the business case for it to be successfully implemented.
Implementation has and will impact many areas of the Company including electric
operations, engineering, supply chain, IT, asset management, finance and accounting.
However, great care has been taken to leverage existing workflow processes and
technologies to minimize disruption to the organization. This is an enterprise level
program.
2.4 Discuss the alternatives that were considered and any tangible risks and
mitigation strategies for each alternative.
A complete list of alternatives is included in the
September 2019 publication entitled, “Wildfire Risk
Analysis Summary – actions under consideration”. This
document focuses on the risks and costs of viable
alternatives and laid the groundwork for actions adopted
in the Resiliency Plan.
2.5 Include a timeline of when this work will be
started and completed. Describe when the
investments become used and useful to the
customer.
The scope of this plan is considerable. Both transmission
and distribution grid hardening projects will be ramped
from 2020 through 2023 and then levelized through 2029.
Other efforts including technology projects such as the fire-weather dashboard and the
TROVE risk analysis will be conducted on the front end of the ten-year horizon. The
following table indicates the capital spend levels, by year. This is a surrogate for
activity.
Values in $000’s.
Capital
2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 10-yr
$5,265 $16,985 $27,055 $31,380 $31,380 $31,380 $31,380 $31,380 $31,380 $31,380 $268,965
Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 6, Page 6 of 10
Wildfire Resiliency Plan (July 2020)
Business Case Justification Narrative Page 8 of 10
2.6 Discuss how the proposed investment aligns
with strategic vision, goals, objectives and
mission statement of the organization.
The stated goals of the resiliency plan are:
Protect lives and property
Ensure emergency preparedness and align
operating practices with fire threat conditions
Protect Avista’s energy delivery infrastructure
The effort to develop a comprehensive wildfire mitigation strategy has been fully
embraced by Avista’s Board of Directors and executive management. The Board has
requested quarterly updates since early 2020 and will receive another briefing on
August 5, 2020 (D. Howell and D. James).
2.7 Include why the requested amount above is considered a prudent
investment, providing or attaching any supporting documentation. In
addition, please explain how the investment prudency will be reviewed
and re-evaluated throughout the project
Prudency is a fundamental tenant of cost recovery. Avista has engaged directly with
Idaho and Washington Utility Commissioners and their staffs. Avista’s rates
department recently petitioned the IPUC for deferral treatment of all wildfire related
costs (capital and O&M). Discussions continue with Washington Commissioners.
Events surrounding the November 2018 ‘Camp Fire’ lead to the bankruptcy of PG&E
and served as the catalyst for many utilities to assess their systems and defenses
associated with wildfire.
2.8 Supplemental Information
2.8.1 Identify customers and stakeholders that interface with the business case
Avista electric customers located in Wildland Urban Interface zones 2 & 3 will be directly
engaged via the process. Grid hardening and enhanced vegetation management
strategies will be focused in those areas. In addition, Avista is coordinating with local and
regional stakeholders including fire protection agencies, electric utilities, the Washington
department of natural resources (DNR), the Idaho department of lands (IDL), and groups
with an interest in or impacted by Avista’s plan.
2.8.2 Identify any related Business Cases
N/A
Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 6, Page 7 of 10
Wildfire Resiliency Plan (July 2020)
Business Case Justification Narrative Page 9 of 10
3.1 Steering Committee or Advisory Group Information
Since February of 2019, a Wildfire Steering Committee has actively engaged in the
formation and adoption of the Plan. That committee remains active and will guide
efforts throughout the life of the program. Members include:
Name Title
David Howell Director, Electric Operations (Business Case Owner)
Bruce Howard Sr. Director, Environmental Affairs and Real Estate
Greg Hesler Vice President, General Counsel & Chief Compliance Officer
Alicia Gibbs Manager, Asset Maintenance
Elizabeth Andrews Sr. Manager, Revenue Requirements
Bob Brandkamp Sr. Manager, Risk
Annie Gannon Manager, Communications
Casey Fielder Manager, Corporate Communications
3.2 Provide and discuss the governance processes and people that will
provide oversight
The Wildfire Resiliency Plan will adapt and evolve to align with risk conditions and
available technologies to mitigate those risks. Governance and oversight will be a
consistent element throughout the life of the Plan including direct involvement by
senior management and oversight via the Board of Directors.
3.3 How will decision-making, prioritization, and change requests be
documented and monitored
Program management is a prescribed function of the Wildfire Plan Manager position.
Monthly status reports will include status of costs, production, and forecasts including
resource requirements. This plan will adapt over time as we gain experience with new
elements including risk-based vegetation management, digital data collection, grid
hardening, and emergency operations tactics specific to fire response.
The undersigned acknowledge they have reviewed the Wildfire Resiliency Plan
business case and agree with the approach it presents. Significant changes to this
Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 6, Page 8 of 10
Wildfire Resiliency Plan (July 2020)
Business Case Justification Narrative Page 10 of 10
will be coordinated with and approved by the undersigned or their designated
representatives.
Signature: Date:
Print Name: David Howell
Title: Director, Electric Operations
Role: Business Case Owner
Signature: Date:
Print Name: Heather Rosentrater
Title: Sr Vice President, Energy Delivery
& Shared Services
Role: Business Case Sponsor
Signature: Date:
Print Name: David Howell (on behalf of WFRES
Steering Group)
Title:
Role: Steering/Advisory Committee Review
8/2/20
Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 6, Page 9 of 10
will be coordinated with and approved by the undersigned or their designated
representatives.
Date:
David Howell
Director, Electric Operations
Business Case Owner
Date:
Heather Rosentrater
Sr Vice President, Energy Delivery
& Shared Services
Business Case Sponsor
Date:
David Howell (on behalf of WFRES
Steering Group)
Steering/Advisory Committee Review
10/7/2020
Exhibit No. 12 Case Nos. AVU-E-21-01 & AVU-G-21-01 D. Howell, Avista
Schedule 6, Page 10 of 10