20210422Reply Comments.pdf

<Emr.
'1.,j,.:lr1rf:.I-l
:'r*!Ji-i'l;L;^nE COPPOomp.rry
April22,2021
VIA ELECTRONIC FILING
Jan Noriyuki, Secretiary
ldaho Public Utilities Commission
11331 W. Chinden Blvd., BIdg 8,
Suite 201-A(83714)
PO Box 83720
Boise, ldaho 83720-007 4
Re Case No. IPC-E-21-02
ln the Matterof ldaho PowerCompany'sApplication foran Accounting Order
Authorizing the Deferral of lncremental Wildfire Mitigation and lnsurance
Costs
Dear Ms. Noriyuki
Attached for electronic filing, purcuant to Order No.34781, is ldaho Power
Company's Reply Comments.
If you have any questions about the attached document, please do not hesitate to
contact me.
Very truly yours,
LISA D. NORDSTROM
Lead Counsel
![e-mail]
LDN:slb
Attachment
,i;;,:,ltIt AHli:53
,'r I,
'''. r, r1'tsr, i tl(-",;rl'1l,I, - _r t,r, f ,.i;lrlL., lL;il
Lisa D. Nordstrom
fr- !.(^,1.t,^,
LISA D. NORDSTROM (lSB No. 5733)
ldaho Power Company
1221 West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
I no rd strom @ ida ho power. com
Attomey for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION FOR AN
ACCOUNTING ORDER AUTHORIZING
THE DEFERRAL OF INCREMENTAL
WILDFIRE MITIGATION AND INSURANCE
COSTS
CASE NO. tPC-E-2'.1-02
IDAHO POWER COMPANY'S
REPLY COMMENTS
)
)
)
)
)
)
)
ldaho Power Company ("ldaho Powefl or'Company") respectfully submits the
following Reply Comments in response to Comments filed by ldaho Public Utilities
Commission Staff ("Staff), ldaho Conservation League ("!CL'), and individua! members
of the public.
The Company is grateful for StafPs careful assessment of ldaho Power's Wildfire
Mitigation Plan ('WMP') and associated incremental costs. Staffs supportive
recommendations are based on diligent review and, ultimately, indicate that ldaho Power
has developed a reasonable and comprehensive plan to proactively mitigate wildfire risk.
IDAHO POWER COMPANY'S REPLY COMMENTS - 1
Wth respect to lCL, ldaho Power appreciates the group's comments and
suggestions on collaborative land management. ICL recommends that the Company
amend its WMP "to include specific collaboration between the land management
agencies." ICL Comments at 2. Additionally, ICL suggests that ldaho Power "proactively
collaborate in ongoing management planning processes to ensure the complexities of
landscape management in the face of wildfires are being addressed by all strakeholders
in a coordinated manner." ICL Comments at 3.
ldaho Power certainly recognizes the importance of agency coordination. To that
end, many of ICL's suggestions align with efforts already undertaken or ongoing by ldaho
Power. The Company initiated agency dialogue through meetings with ldaho's Bureau
of Land Management ("BLM') Fire Management staff during development of the \ /TvlP.
Those agency meetings helped ldaho Power gain an understanding of BLM's fire
protection priorities, identiff BLM datasets relevant to the Company's planning efforts,
establish a rapport with BLM fire staff, and initiate discussion regarding potential, future
collaborative fi re mitigation projects.
Subsequent meetings with BLM's Deputy State Resource Services Director and
State Fire Management fficer focused on WMP implementation, BLM District staff
outreach strategies, and potential BLM prioritization of ldaho Powerfire mitigation project
reviews. ldaho Power continues to work with BLM to identify outreach strategies to
educate BLM District staff and solicit feedback from them.
ln preliminary conversations with the Company, U.S. Forest Service ('USFS")
Region 4 recognized that there was no statewide forum for wildland fire management
coordination. To address this gap, ldaho Power and the USFS in early 2020 discussed
IDAHO POWER COMPANY'S REPLY COMMENTS - 2
potentia! cooperative fire mitigation strategies, resulting in ldaho Power joining the ldaho
Wildfire Board (the "Board"), a new consortium of local, state, and federalagencies. The
intent of the Board is to bring together different agencies working on wildland fire
management in the state of ldaho. The Board's first meeting is on Apri! 22,2021. ldaho
Power intendsto leverage its participation to expand WMP coordination with USFS, ldaho
Military Division, the Federa! Emergency Management Agency, ldaho Department of
Lands, and BLM.
ICL also suggested coordination with Governor Little's Shared Stewardship
Advisory Group. \Mlile this group's scope is extensive and goes beyond wildfire
collaboration, ldaho Power recognizes its value. As such, the Company has engaged
with the group and will continue to follow its progress.
Finally, ldaho Power is grateful for the comments it received from its customers
and the general public. The Company understands that wildfire-related issues are of
great interest to the public and commends those who commented for taking the time to
show their support for the Company's efforts.
DATED at Boise, ldaho, this 22nd day of Apfl 2021.
X* !-(""u+*-*,
LISA D. NORDSTROM
Aftomey for ldaho Power Company
IDAHO POWER COMPANY'S REPLY COMMENTS.3
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the22d day of April2021, I served a true and conect
copy IDAHO POWER COMPANY'S REPLY COMMENTS upon the following named
parties by the method indicated below, and addressed to the following:
Commission Staff
Dayn Hardie
Deputy Attomey General
!daho Public Utilities Commission
11331 W. Ghinden Blvd., Bldg No.8,
Suite 201-A(83714)
PO Box 83720
Bolse, lD 83720-0074
ldaho Gonservation League
Benjamin J. Otto
ldaho Conservation League
710 N.6s Street
Boise, lD 83702
Hand Delivered
_U.S. Mail
_Ovemight Mail
_FAXX Email [e-mail]
_Hand Delivered
_U.S. Mail
Ovemight Mail
_FAX_FTP Site
X Email [e-mail]
Stephanie Buckner, Executive Assistant
IDAHO POWER COMPANY'S REPLY COMMENTS - 4