20210122Application.pdf

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AnDACOnpCotrBny
LISA D. NORDSTROM
Lead Counsel
[e-mail]
January 22,2021
VIA ELECTRONIC FILING
Jan Noriyuki, Secretary
ldaho Public Utilities Commission
11331 W. Chinden BIvd., Bldg 8,
Suite 201-A(83714)
PO Box 83720
Boise, ldaho 83720-0074
Re Case No. IPC-E-21-02
ln the Matter of the Application of ldaho Power Company for an Accounting
OrderAuthorizing the Defenalof lncrementalWildfire Mitigation and lnsurance
Costs
Dear Ms. Noriyuki
Enclosed for electronic filing, pursuant to Order No. 34602, please find ldaho Power
Company's Application in the above-entitled matter.
lf you have any questions about the enclosed documents, please do not hesitate to
contact me.
Very truly yours,
X*!.7/^*+r,*-,
Lisa D. Nordstrom
LDN:slb
Enclosures
LISA D. NORDSTROM (lSB No. 5733)
Idaho Power Company
1221West Idaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
I no rd strom @ ida hopower. co m
Attorney for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR AN
ACCOUNTING ORDER AUTHORIZING
THE DEFERRAL OF INCREMENTAL
WILDFIRE MITIGATION AND
INSURANCE COSTS
CASE NO. IPC-E-21-02
APPLICATION
ldaho Power Company ("ldaho Powe/'or "Company"), in accordance with ldaho
Code S 61-524 and -525 and RP 052, respectfully submits its Wildfire Mitigation Plan
('WMP' or "Wildfire Plan") to the ldaho Public Utilities Commission ("Commission" or
'IPUC') and requests that the Commission issue an order authorizing deferred accounting
of actual incremental costs the Company wil! incur associated with wildfire mitigation
efforts and additional incremental costs related to insurance premiums that have
increased as a result of wildfires. Specifically, the Company is requesting the
Commission's approval to defer the ldaho jurisdictional share of incremental operation
and maintenance ("O&M") expenses and capital depreciation expenses detailed in this
Application, until identified expenses can be included in base rates or another acceptable
collection method. ldaho Power will seek the amortization of the deferred costs, including
APPLICATION - 1
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a review of the actual costs associated with mitigation efforts, in a future Commission
proceeding. ldaho Power is not seeking to change customer rates at this time.
To assist in the review of this Application, Idaho Power provides the following table
of contents:
Descri P
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tv.
V.
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VIII.
tx.
x.
Background
Summary of ldaho Power's Wildfire Mitigation Plan
Quantifying the Benefits of Wildfire Risk Mitigation
Forecast of lncremental O&M for Wildfire Mitigation
Other lndirect Wildfi re-Related Costs
Depreciation of Capital lnvestment
Proposed Accounting Treatment
Modified Procedure
Communications
Request for Relief
2
4
15
18
25
28
29
30
30
30
Additionally, accompanying and in support of this Application are Attachments A
through D:
. Attachment A: ldaho Power's Wildfire Mitigation Plano Attachment B: ldaho Power's Wildfire Risk Map. Attachment C: Forecast of lncremental O&M Expenses for Wildfire Mitigation. Attachment D: lnsurance Broker Memo on Escalating lnsurance Costs
I. BACKGROUND
1. ln recent years, the Western United States ('U.S.") has experienced an
increase in the frequency and intensity of wildland fires ("wildfires"). A variety of factors
have contributed in varying degrees to this trend including climate change, increased
human encroachment in wildland areas, historical land management practices, and
changes in wildland and forest health, among other factors.
2. While ldaho Power has not experienced the type of catastrophic wildfires
within its service area that have occurred in other Westem states, such as California and
more recently Oregon, millions of acres of rangeland in Southern ldaho's forests have
APPLICATION - 2
burned in the last 30 years.l ln that same time period, the wildfire season has expanded
by 70 days.2 In light of changing wildfire conditions in the West, ldaho Power evaluated
conditions and risks in its service area to assess existing practices for mitigation of wildfire
risk, determine which practices should be proactively expanded or revised, and identify
which new efforts and measures should be implemented.
3. This Application is premised on reducing wildfire risk for the safety of ldaho
Power's customers, the continued and reliable delivery of electricity to more than 570,000
retail customers in Southern ldaho and Eastem Oregon, and good stewardship of the
beautiful and natural lands within ldaho Power's service area and beyond. Accordingly,
the Company's wildfire mitigation efforts are also intended to reduce risk associated with
the operation of its more than 310 substations, 4,800 miles of overhead transmission
lines, and 19,300 miles of overhead distribution lines.
4. This Application provides the following: a comprehensive overview of ldaho
Power's efforts to assess wildfire risk, including a summary of its Wildfire Plan (included
as Attachment A); discussion of necessary actions and measures to mitigate wildfire risk;
and identification and examination of incremental O&M costs associated with
implementing and completing wildfire mitigation efforts, as wel! as certain indirect wildfire-
related costs.
5. lmportantly, ldaho Power has identified some operational practices and
measures that the Company believes should be updated to proactively mitigate wildfire
risk. For example, the Company is proposing a sizeable shift in its approach to vegetation
1 Rocky Barker, 70% of S. /daho's Foresfs Burned in the Last 30 Years. Think That Will Change? Think
Again., ldaho Statesman, October 4,2020.
2 ld.
APPLICATION - 3
management, and has done so in recognition that climate, weather, wildland
encroachment, and vegetation growth-key contributors to heightened wildfire risk-are
expected to continue to change in the coming years. ldaho Power's decisions on
operational practices and measures outlined in this Application also have been informed
by participation in workshops and working groups, on-site visits, conferences, and peer-
sharing events with other Western utilities and with government entities to learn current
and potential industry practices used to reduce wildfire risk.
6. Considering ldaho Power's extensive effort to study its wildfire risk and
evaluate proactive measures to mitigate that risk, the incremental costs and related
expenses identified in this Application are not only prudent, but fundamental to
implementing and expanding necessary wildfire mitigation measures across ldaho
Power's entire service area and transmission corridors in ldaho and Oregon.
II. SUMMARY OF IDAHO POWER'S WILDFIRE MITIGATION PLAN
7. The Company developed its Wildfire Plan to identify and implement
strategies to accomplish two critical objectives: (1) reduce wildfire risk associated with
ldaho Power's transmission and distribution ('T&D') facilities and associated field
operations, and (2) improve the resiliency of the Company's T&D system impacted by
wildfire events.
8. Wildfire Risk Assessment: To accomplish the two objectives identified
above, ldaho Power leveraged an external consultiant that specializes in assessing and
quantifying wildfire risk. To conduct a comprehensive assessment of the Company's
service area and transmission conidors, the consultant used a risk-based methodology
that incorporates weather modeling, wildfire spread modeling, and Monte Carlo
simulations, among other modeling techniques. This type of modeling approach is not
APPLICATION - 4
unique to ldaho Power's Wildfire Plan. The California Public Utilities Commission
("CPUC') used the same modeling approach-and the same consultant-as part of its
development of the CPUC Fire Threat Map. Other utilities in Oregon, ldaho, Nevada, and
Utah have utilized similar modeling approaches to identify and quantify wildfire risk.
9. The consultant's modeling methodology for determining wildfire risk
considers a wildfire event's probability multiplied by its potential negative consequences
or impacts, should that event occur. Expressed as a formula:
Wildfire Risk = Fire Probability x Consequence
The first term, Fire Probability, is based on fire volume (i.e., spatial integral of fire
area and flame length) because rapidly spreading fires are more likely to escape initial
containment efforts and become extended fires rather than slowly developing fires. The
second term, Consequence, reflects the number of structures (i.e., homes, businesses,
and other man-made structures) that could be impacted by a wildfire. Using this formula,
the highest wildfire risk exists in those areas in which both Fire Probability and
Consequence are elevated. Conversely, combinations of low Fire Probability and
elevated Consequence (or elevated Fire Probability but low Consequence) will not
typically be areas with highest risk. While ldaho Power does not expect the underlying
formula to quantify risk will change, the wildfire risk assessment will be reviewed and
updated biennially by ldaho Power.
10. ldaho Power's consultant, using the above methodology and risk
calculation, identified geographic risk tiers that are visually represented in the Company's
Risk Map (included as Attachment B). More precisely, the Risk Map displays zones of
elevated risk relative to ldaho Power's service area-a Yellow Risk Zone, reflecting
APPLICATION - 5
increased risk, and a Red Risk Zone, reflecting highest risk. As the Risk Map indicates,
ldaho Power's Red Risk Zones exist entirely in ldaho and adjacent to population centers,
such as the Boise foothills, the forested areas around Payette Lake in McCall, and in the
Wood River Valley. As described earlier, these Red Risk Zones were determined to have
the greatest wildfire risk based on the combination of Fire Probability and Consequence.
11. Situational Awareness: ln development of the Wildfire Plan, ldaho Power
also created a new Fire Potential Index ('FPl') toolto support operationaldecision making
to reduce wildfire threats and risks. The tool takes data on weather, prevalence of fuel
(i.e., trees, shrubs, grasses), and topography, and then converts that data into an easily
understood forecast of the short-term fire threat for different geographic regions in ldaho
Power's service area. The FPI produces a score of 1 to 16, with scores of 1 to 11 falling
in the Green category of lower fire potential, scores of 12 to 14 falling in the Yellow
category of elevated fire potential, and scores of 15 to 16 falling in the Red category of
highest fire potential. During wildfire season, the FPI will be calculated and issued each
weekday for a seven-day forecast period to help ldaho Power personnel take necessary
steps in advanced planning and preparation. The tool will be updated and enhanced
annually to advance the Company's wildfire preparedness.
12. Field Personnel Practices for Wildfire Mitiqation: ldaho Power's wildfire
mitigation strategy includes procedural measures to prevent the accidental ignition and
spread of wildfires due to ldaho Power-related activities. ldaho Power developed a
Wildland Fire Preparedness and Prevention Plan (included as an attachment to the
Company's Wildfire Plan) to provide guidance to ldaho Power employees and
contractors. The Preparedness and Prevention Plan will inform crews about such factors
APPLICATION - 6
as fire season tools and equipment available on the job site; daily situational awareness
regarding areas with heightened fire conditions; expected actions and mechanisms for
reducing on-the-job wildfire risk, as well as reporting requirements in the event of an
ignition; and training and compliance requirements. All ldaho Power crews, and certain
field personnel and contractors performing work on or near ldaho Power's facilities, will
be expected to operate in accordance with the provisions of this Preparedness and
Prevention Plan and conduct themselves in a fire-safe manner.
13. Operational Mitioation Practices: Another key component of the Company's
Wildfire Plan is to continue the safe and reliable operation of T&D lines while also reducing
wildfire risk. ln assessing existing operations, ldaho Power identified a number of ways
to include best practices in wildfire risk mitigation, including deploying temporary
operating procedures for transmission Iines during fire season; developing operational
strategies for management of distribution lines during periods of elevated wildfire risk and
during fire season; and evaluating a Company-specific approach to Public Safety Power
Shutoffs ('PSPS") to determine the appropriateness and operation of PSPS as a tool in
ldaho Power's service area and transmission corridors.
14. PSPS is generally defined as the proactive and planned de-energization of
lines when extreme wildfire risk conditions (i.e., combinations of very high winds, high
temperatures, dry fuels, and low humidity) are forecasted. Due to the complex nature of
implementing PSPS, ldaho Power is stil! researching and developing its PSPS strategy
with anticipation of its completion in advance of the 2022fire season.
15. T&D Proorams: Another key aspect of ldaho Power's Wildfire Plan is to
manage certain conditions related to its T&D lines, such that they operate in the most
APPLICATION - 7
safe and reliable manner, thereby reducing the risk of igniting a fire. This is accomplished
through a portfolio of asset management programs, as well as ldaho Power's vegetation
management program.
16. The Company's asset management programs support wildfire prevention
and mitigation through a robust process of inspections, line protection, asset replacement,
and overallsystem hardening. Several mature transmission management programs have
been operated effectively by ldaho Powerfor decades, and include condition-based aerial
and ground inspections, detailed camera-based visual inspections, transmission wood
pole inspection and treatment, and cathodic protection.
17. Visual inspections are a critical component of transmission line-related
wildfire mitigation efforts. On an annua! basis, ldaho Power uses helicopters in the visual
aerial inspection of transmission lines that are Westem Electricity Coordinating Council
("WECC") path lines. Under the Wildfire Plan, ldaho Power will continue to use this
method of line inspection for all transmission lines located in Red Risk Zones.
Additionally, unmanned aerial vehicles3 with high-definition cameras will be used to
inspect facilities on these lines in certain situations. These inspections allow personnel
to look for potential line defects that, if found, are noted and scheduled for repair.
18. Other vita! asset management programs include on-the-ground and
detailed visual (high-resolution photography) inspections, wood pole inspection and
3 ldaho Power believes that drones or unmanned aerial vehicles ('UAVs") hold great potential for assisting
with wildfire mitigation activities, primarily aerial line inspections, facilities inspections, and vegetation
management assessments. Compared to manned aerial inspections via helicopter, UAVs are more cost-
effective, efficient, and safe. However, ldaho Power, like many other utilities, can only use UAVs within the"line of sight' of the pilot. A special waiver is required from the Federal Aviation Administration in order togain authorization to fly UAVs beyond visual line of sight ('BVLOS'). ldaho Power is supportive of and
engaging in industry efforts to streamline approval of strategic BVLOS operations by utilities for purposes
such as reducing wildfire risk.
APPLICATION - 8
treatment, cathodic protection and inspection, and thermal imaging inspection. Thermal
inspections using infra-red are not new to ldaho Power, but the use of this tool will be
greatly expanded to include all Red Risk Zones. Additionally, ldaho Power will extend its
existing wood pole wildfire protection program to Red and Yellow Risk Zones for
transmission structures. This protective measure involves adding "mesh wraps" to wood
poles prior to being exposed to wildfires. These mesh wraps, which have a ten-year life
in the absence of fires, provide protection for a single wildfire event and then must be
replaced with a new wrap.
19. For distribution lines, ldaho Power also has several mature programs that
witl continue to be utilized and enhanced in Red Risk Zones. Similar to the Company's
transmission programs, its distribution-focused programs include condition-based visual
inspections, distribution wood pole inspection and treatment, and line equipment
inspection.
20. ldaho Power's Wildfire Plan also provides for creating an overhead
distribution "hardening" program to implement in Red Risk Zones. Examples of specific
work that will be performed in the hardening program include programmatic replacement
of small conductor and associated hardware. Additionally, for transmission lines of 138
kV and above that are scheduled to be rebuilt or replaced, ldaho Power may convert the
poles from wood to steel. Decisions about pole-conversion system hardening will be
based on the ability to reduce structural damage due to wildfire and will be evaluated
across ldaho Power's entire service area and transmission corridors, not just the elevated
risk zones.
APPLICATION - 9
21. Enhanced Veoetation Manaoement for Wildfire Mitiqation: !n terms of time,
expense, and overall risk reduction, enhanced vegetation management is the most critical
aspect of ldaho Powe/s Wildfire Plan. The Company is required by Rule 218 of the2017
National Electric Safety Codea to maintain clearance between trees adjacent to T&D
corridors and the Company's overhead electric facilities (i.e., T&D lines and equipment).
To accomplish this requirement, ldaho Power patrols T&D corridors and actively manages
vegetation to provide clearance around the Company's electrical lines and equipment.
The Company endeavors to maintain a regular vegetation management cycle for
transmission and distribution lines. ln addition, transmission lines are patrolled by
helicopter annually to identify any dead or dying trees that should (to the extent permitted
by rights-of-way and permits) be removed to prevent them from falling into or onto
electrical lines or equipment.
22. The Wildfire Plan identified geographic Red and Yellow Risk Zones where
enhanced vegetation management should occur to reduce the risk of wildfire-related
damage. But while the identified risk zones serve as a good foundation for enhanced and
expanded vegetation management, ldaho Power believes it is imperative to proactively
address risk in a holistic manner. Accordingly, the Company will strive to consistently
maintain a three-year vegetation management cycle across its entire service areas, not
just in the Red and Yellow Risk Zones. ldaho Power believes that this enhanced and
expanded approach to vegetation management reflects a broader notion of risk that
exists, and the Company offers the following justification to support its position.
4 IPUC Safety and Accident Reporting Rule 101, IDAPA 31.11.01.101.
5 ldaho Power will continue to clear transmission right-of-way corridors located in mountainous areas on a
six-year cycle.
APPLICATION - 1O
23. The Company has observed several climate-related shifts that increase
wildfire risk, such as changing weather patterns, more extreme weather events, longer
growing seasons (leading to more vegetation), as well as more extensive presence of
pests such as the bark beetle, which are responsible for tree damage and death
throughout the Rocky Mountains and Western U.S.6 More broadly, climate change is
fundamentally altering the way trees and forests work. For example, the increase in the
concentration of atmospheric carbon dioxide stimulates the photosynthetic activity of
trees, which causes some tree species to grow faster.T Additionally, wetter springs and
longer, warmer falls-such as ldaho has experienced in recent years-lengthen the
annual growing period of trees and other vegetation. While greater volume of tree and
vegetation growth is clearly a new challenge in efforts to prevent wildfires, faster tree
growth has also resulted in less density in the wood, which now contains less material
than just a few decades ago.8 Less solid wood in living trees increases the risk of damage
events such as breakage due to wind, hail, and snow.
24. Changes in vegetation growth have impacted ldaho Power's current
vegetation management program, as faster growth has resulted in longer timeframes to
clearthe same power lines compared to historical periods. Adding to the challenge, ldaho
Power has observed that contracted trimming crews are less experienced than past crews
due to a shortage of qualified labor. The dramatic increase in demand for vegetation
management across the U.S. has led to a shortage of qualified vegetation management
6 U.S. Forest Service, Research and Development Bark Beetles: https://www.fs.fed.us/research/invasive-
species/insects/bark-beetle. php
7 Marlies Kovenock and Abigail L.S. Swann, Leaf Trait Acclimation Amplifies Simulated Climate Warming
rn Response to Elevated Carbon Dioxide, Global Biogeochemical Cycles (Volume 32, lssue 10), October
2018.8 Hans Pretzsch el al., Wood Density Reduced While Wood Volume Grovtth Accelerated in Central
European Foresfs Since 1870, Forest Ecology and Management, Augusl14, 2018.
APPLICATION - 11
crews and an increased cost associated with those resources. ln response, vegetation
management companies have hired new crews that, by and large, are less experienced
yet are charging higher hourly rates. The result is tree trimming crews that cost more and
produce less.
25. The combination of vegetation growing at an increased rate and crews with
less experience is problematic. When vegetation grows closer-and sometimes into-
power lines, it not only poses a fire risk and safety concern, but also increases the amount
of time needed to clear those sections of lines. ln turn, the higher level of difficulty to
clear the vegetation further increases trimming time and associated costs. These
conditions have also been observed by other utilities, resulting in a significant increase in
vegetation management efforts utility industry-wide, and thereby significantly increasing
the demand for vegetation management.
26. Considering the aforementioned challenges, ldaho Power believes it is
important to take a modified approach to vegetation management-<ne that achieves the
dua! objectives of reliability and wildfire risk mitigation. As such, ldaho Power believes
that enhanced and expanded vegetation management practices are necessary for
effective and proactive wildfire risk mitigation. Having evaluated existing practices, the
Company proposes taking steps to move to a three-year vegetation management cycle
across its entire service area.
27. ldaho Power believes that a three-year cycle will be the most efficient and
effective vegetation management approach, allowing efforts to focus almost entirely on
proactive rather than reactive (or catch-up) trimming. lt is also worth noting that a
consistently maintained vegetation management cycle will be less intrusive and
APPLICATION. 12
noticeable to customers because the amount of vegetation trimmed during routine
t6mming is less than it would be under longer or less consistent trimming cycles.
28. ln the process of concluding that a three-year cycle offers the best
combination of risk reduction and cost, the Company considered other vegetation
management altematives, including shorter trimming cycles, longer trimming cycles, and
strategies that evaluate each tree individually and only trim it once it has nearly grown
back to the power line (so-called 'lust-in-time trimming"). Each alternative presents its
own challenge or negative impact. While shorter trimming cycles result in less vegetation
being removed during each trimming cycle, it costs more due to the need for more
resources and more frequent trimming of trees near the power lines. ln contrast, longer
cycles result in less frequent trimming of each tree but larger amounts of vegetation that
must be removed in order to maintain larger clearance envelopes around the power lines
to accommodate additional years of vegetative growth. Further, longer trimming cycles
create logistical challenges that are exacerbated by tree biology. Some trees simply grow
faster than a given trimming cycle and the longer the trimming cycle, the more pervasive
this issue becomes. Longer cycles that call for heavy pruning also lead to hormonal
imbalances between a tree's canopy and its root system. To correct this imbalance, the
tree aggressively re-grows new sprouts to quickly replace its lost canopy. ln this regard,
heavier pruning results in a faster rate of tree regrowth than normal, making it even more
difficult to consistently maintain longer trimming cycles. Finally, 'lust-in-time" trimming is
primarily a reactive strategy that ultimately leads to challenges associated with securing
qualified tree-trimming crews, as this ad hoc approach involves hiring crews on an as-
needed basis rather than on a consistent schedule. After evaluating these altemative
APPLICATION - ,13
approaches, ldaho Power concluded that the goal of maintaining a consistent three-year
trimming cycle is the most cost-effective and sustainable strategy to keep vegetation
away from the power lines in a proactive manner.
29. ldaho Power recognizes that achieving a consistent three-year vegetation
management cycle across the Company's service area (on an on-going basis) involves a
sizeable increase in incremental expense. But after developing the Wildfire Plan and
weighing the most important, cost-effective measures ldaho Power could take to reduce
the likelihood of an ignition event and protect utility infrastructure, the Company
determined that this shift in vegetation management pr:actices is a wise and prudent
course of action. lt is also the approach that has been adopted by many of ldaho Power's
peer utilities.e
30. ln addition to the goa! of achieving a consistent three-year vegetation
management cycle, the Company will employ enhanced vegetation management in its
Red and Yellow Risk Zones. These enhanced practices include the following: annua!
patrols to identify immediate pruning needs to avoid trees making contact with power
lines; mid-cycle pruning in the second year of the trimming cycle for trees that regrow
more rapidly than expected; increased incentives to customers that own trees that
consistently regrow more rapidly than the three-year cycle (so-called "cycle buste/'trees);
clearing and sterilizing the soil around selected distribution poles; and performing post-
trimming audits on al! pruned trees in Red and Yellow Risk Zones.
e ln Utah, PacifiCorp (Rocky Mountain Power) seeks to achieve a three-year vegetation management cycle,
but the Company aims for a two-year cycle in its service area in California and a four-year cycle in Wyoming.
Additionally, CenterPoint Energy (Texas), Texas-New Mexico Power, and Bowling Green Municipal Utilities
(Kentucky) each aim to achieve a three-year vegetation management cycle.
APPLICATION - 14
31. ln Section lV of this Application, ldaho Power provides more historical
context for cost increases in vegetation management and details the estimated
incremental costs associated with striving to achieve a consistent three-year vegetation
management cycle across the Company's service area.1o
32. WMP Performance Monitorino and Metrics: ldaho Power's Wildfire Plan will
be reviewed, updated, and intemally approved on an annual basis. Additionally, the
Company will monitor and update as necessary its key efforts in the areas of situational
awareness, field personnel practices, operations, T&D programs, and vegetation
management.
33. The Company's Chief Operating Officer is designated with oversight of the
Wildfire Plan, while the Vice President of Planning, Engineering, and Construction is
responsible for compliance monitoring, necessary training, and annual review of the
WMP.
III. OUANTIFYING THE BENEFITS OF WILDFIRE RISK MITIGATION
34. In assessing the probability and consequence of wildfire risk, and
quantifying the benefits of additional wildfire mitigation efforts, ldaho Power engaged with
its outside consultant and considered several sources of empirical data on the costs of
major wildfires, both in terms of fires that burn into Idaho Power's facilities or that originate
from electric infrastructure. These costs can include replacement costs of the Company's
property, the cost of fire suppression and environmental damage, third-party claims for
property damage, employee and public injuries and fatalities, and other economic losses.
Obtaining a precise calculation of the potentialcosts of future wildfires is not realistic. The
10 ldaho Power will continue to clear transmission right-of-way corridors located in mountainous areas on a
six-year cycle.
APPLICATION - 15
damage that any fire may cause depends on factors such as wind and weather,
vegetation, fire risk levels, location, population and structure density, and response times
from fire suppression entities.
35. The general probability of fires igniting, however, is known because wildfires
occur in ldaho Power's service area each year from numerous sources of ignition, both
natural and human-caused. ldaho Powe/s assessment of the potential costs of wildfires,
used in developing the Wildfire Plan and the scope of proposed updates to practices,
involved a review of prior catastrophic fires in other states, as well as calculations
undertaken by other utilities in the West. While this assessment did not yield a precise
quantification of potential benefits specific to ldaho Power, it provides a helpful illustration
of the potential costs of not taking actions aimed at reducing wildfire risk.
36. ldaho Power reviewed and considered calculations that analyzed the
potential reduction in probability of igniting wildfires based on risk-mitigating activities
outlined in theWildfire Plan. Forinstance, Avista Corporation ("Avista"), in its June 1,
2020, filing before this Commission in Case No. AVU-E-20-05, stated that its "analysis
indicates a 10-year inherent potential risk exposure of at least $8 billion dollars," though
noted the figure should not be interpreted as a precise financial estimate.ll Avista further
noted that the actions it proposes in its own wildfire resiliency plan result in an average
percentiage of risk mitigation of 89 percent for the overal! plan.1z
37. ln California, costs and damages associated with wildfires in recent years
have exceeded $10 billion per year, with those associated with the 2020 fires alone
11 ln the Matter of Avista Corporation's Application for an Order Authorizing Accounting and Ratemaking
Treatment of Cosfs Associafed with the Company's Wldfire Resiliency Plan, Case No. AVU-E-20-05,
Application at 17.
12 ld.
APPLICATION - 16
potentially set to exceed $20 billion.l3 This staggering increasela is consistent with the
fact that, with few exceptions, the prevalence, intensity, and devastation of wildfires
continues to escalate year after year as evidenced by information compiled by the
California Department of Forestry and Fire Protection ("CAL FIRE") and detailed below in
Table 1.15
Table 1. GAL FIRE Wildfire Data bv Year
Year Estimated Acres
Burned
No. of
Wildfires
No. of Confirmed
Fatalities
No. ofStructures
Damaged or Destroyed
2020 4,L97,628 9,279 31 10,488
20L9 259,823 7,864 3 732
2018 L,975,086 7,948 100 24,226
2017 L,548,429 9,270 47 10,280
2016 669,534 6,954 6 t,274
38. CAL FIRE reported that there were 1,073 California utility-involved fires in
2018.16 Further, CAL FIRE reported that over 50 percent of those fires resulted from
vegetation contact, with equipment, downed wires, and animals being other notable
contributing causes of the fires. ln its 2020 Wildfire Mitigation Plan, Pacific Gas & Electric
reviewed drivers of ignition probability based on various events on its own system, such
as contacts from objects and equipment failure, showing that several events per year
were likely resulting from many of the utility-caused factors.lT
13 Jill Cowan, How Much Wll the Wildfires Cosf2, The New York Times, Sept. 16, 2020, at
https:/iwww.nytimes.com 12020 l09l 1 6lus/california-fi res-cost.html.
1a ldaho Power believes that its system is in notably better condition than some utilities in California.
Nevertheless, these figures illustrate the destruction that can occur from vegetation contact if vegetation is
not actively managed.
ls This information can be found at https://www.fire.ca.gov.
16 ld.
17 Pacific Gas and Electric Company, 2020 Wildfire Mitigation Plan Report - Updated, Rulemaking 18-10-
007, Feb. 28,2020, pp.3-7 to 3-12.
APPLICATION - 17
39. The data compiled by peer utilities, historic fire costs, and known damage
from prior fires are instructive. Considering peer metrics and analyses on probability and
magnitude, as well as ldaho Power's own empirical review of wildfire events such as
those in California and Oregon-and the resulting loss of lives-it is reasonable to
conclude that the potential human and capital costs and damage from wildfire events
vastly exceed the incrementa! costs of wildfire mitigation efforts identified in the
Company's Wildfi re Plan.
M. FORECAST OF INCREMENTAL O&M FOR WILDFIRE MITIGATION
40. ln development of its Wildfire Plan, ldaho Power determined it should take
specific actions and measures to proactively mitigate wildfire risk. The Company then
identified existing expenses related to wildfire mitigation measures and determined
incremental costs associated with expanding and/or implementing new efforts related to
the Wildfire Plan. Notably, the Company proposes to continue to pay for capital
projectsls, as well as baseline levels of O&M escalated annually for inflation,le out of its
existing budgets and is not seeking an accounting deferral of those costs at this time.
41. ldentified incrementa! O&M costs, as shown in Table 2 and included as
Attachment C, reflect additiona! expenses necessary to take new or expanded measures
related to mitigating wildfire risk set forth in the Wildfire Plan. The identified expenses
are grouped into the following categories: (A) Quantifying Wildland Fire Risk, (B)
Situational Awareness, (C) Mitigation-Field Personnel Practices, (D) Mitigation-
Transmission and Distribution Programs, (E) Enhanced Vegetation Management, and
18 ln Section Vl of this Application, ldaho Power requests authorization to defer depreciation expense
associated with wildfire mitigation-related capital investment.
1s Annual inflation is based on the Consumer Price lndex ('CPl') for 2019 of 1.81 percent.
APPLICATION - 18
(F) Communication. Over the next five years, ldaho Power estimates it will incur
approximately $46.6 million in total incremental O&M expenses to implement these
measures on a system-wide basis. The Company is seeking to defer the ldaho
jurisdictional share of incremental expenses.
Table 2. Forecast of lncremental O&M Expenses for Wildfire Mitiqation. 2021-2025 ($000s)
2021 2022 2023 2024 2025 2lJ2a-2o2s
A. Ouantifvinr wildland Fir. Risk
Risk Mao Uodates s 65 s s 67 s 69 S 201
B. Situationel Awaranes s
Fire Potential lndex (FPll Personnel s 52 s 55 s 57 s 59 s 62 s 285
Cameras s s s s 50 s 50 s 100
C. Mitisation - Field Personnel Practices
Tools/Equipment s s s s s 5 s 5 s 25
D. Mitipation - Transmission & Distribution ProErams
a)&M Comoonenf of Ca.italWark s 50 s 54 s 61 s 50 54 s 289
Annual O&M T&D Patrol Maintenance Reoairs s 50 s 50 s 50 s 50 s 50 S 2so
Environmental Manasement Practices s 25 s 25 s 25 s 25 s 25 s 725
Transmission ThermocraDhv lnsoection Mitipation - Red Risk Zones s 20 s 20 s 20 s 20 s 20 s 100
Distribution Thermosraohv lnsmction Mitigation - Red Risk Zones s 30 s 30 s 30 s 30 s 30 s 150
Thermograohv Technician Personnel s lSO s 155 g 160 s 165 s r70 s 800
Transmission Wood Pole Fire Proof wraos - Red Risk zones s 82 s 88 s 88 s s S 258
Transmission Wood Pole Fire Resistant wraps - Yellow Risk Zones s 153 153 163 s 163 s 163 s 815
E. Enhanced Vesetation ManaEement
Tranrition to/Maintain l-vr Veretation Manaeement Cv.le s 1.500 s 8.087 s 8.796 s 9.s47 s 8-372 s 35.302
Enhanced Practices for Distribution Red & Yellow Risk Zones (Pre-
Fire Season Patrols/Mitisation. Clearinc- Removals. work OA)s 506 s 1.223 s 1.284 s 1.349 S 1.416 s s.778
Iine ClearinP Personnel 3 s 155 159 s IM s 169 647
F, Communication s
Communication - Advertirements/Me.tines/Other s 100 s 100 s 100 s 100 s 100 s 500
Forecast lncrem€ntal Totals s 2.808 S ro.21o s 11.065 3 LL.7t7 s 10.755 s 45.62s
42. Cateqorv A. Quantifuinq Wildland Fire Risk: While ldaho Power intends to
update its Wildfire Plan on an annual basis, the underlying Risk Map wil! be updated
biennially. The Company projects an update expense of $65,000 in 2021, $67,000 in
2023, and $69,000 in 2025, for a total of $201,000 over the next five years. Prior to
2020,ldahoPowerhadnotdevelopedaRiskMapofitsservicearea. Assuch,theentire
amount of the projected cost is incrementa! to the Company. Rather than wait until2022
to update the Risk Map, ldaho Power has planned to immediately update it in 2021 to
incorporate data from the 2020 Census, as population is a key piece of data informing
the Risk Map.
APPLICATION - 19
43. Cateoorv B. Situational Awareness: Over the next five years, ldaho Power
proposes spending a totalof $385,000 on SituationalAwareness. Like the priorcategory
of expenses, identified Situational Awareness expenses are new to ldaho Power. As
such, the entire amount of the projected cost is incremental to the Company. The
primary expense in this category is the cost of additional personnel required to manage
the new Fire Potential lndex, which the Company projects will cost $285,000 over the
next five years. Additionally, ldaho Power plans to explore the use of cameras to
enhance situational awareness, beginning with $50,000 each in 2024 and 2025. The
Company considers this an initial expense to assess the value of cameras in strategic
locations to inform wildfire mitigation efforts, as well as enhance situationa! awareness
for field personnel and first responders in the event of a wildfire.
44. Cateqorv C. Mitiqation-Field Personnel Practices: A relatively small but
critica! expense is the equipment necessary to mitigate wildfire risk by ldaho Power field
personnel. The Company has identified a need for more widespread supply of fire-
specific mitigation tools (e.9., on-truck water pumping equipment, fire extinguishers,
shovels, and Pulaskis2o), which can be used in the field to reduce the likelihood of an
ignition event or quickly and immediately extinguish a sparked fire. Over the next five
years, ldaho Power has identified $25,000 in incremential costs associated with new tools
and equipment.
45.Cateoorv D. Mitioation-Tra and Distribution Proorams:
ldentified incremental O&M expenses associated with ldaho Power's T&D programs
20 A Pulaski is a hand tool specifically used for fighting fires that combines an axe and an adze atop a single
handle. The tool is the invention of Edward Crockett Pulaski, a ranger with the U.S. Forest Service who
was based in Wallace, ldaho, in the early 1900s.
APPLICATION - 20
include a variety of items, most notably the cost of applying fire-proof or fire-resistant
mesh wraps to wood poles in Red and Yellow Risk Zones. Additionally, ldaho Powerwill
perform expanded and more frequent T&D line inspections and will add a new technician
to assist in T&D program activities to perform wildfire mitigation efforts. ln total, the
Company projects spending $2.8 million over the next five years on incremental T&D
program activities.
46. Cateqorv E. Enhanced Veqetation Manaoement: As noted above in Section
Il, ldaho Power has determined that working to maintain a consistent three-year
vegetation management cycle should be implemented across the Company's entire
service area, with one{hird of the service area managed each year.z1 Moving to a
consistent cycle will require ldaho Power to incur certain incremental costs beyond what
it already spends annually on vegetation management. ldaho Power has, in recent
years, experienced a growing set of challenges in its current vegetation management
program, driven by additional vegetation groMh, shortages of qualified labor, and
increased resource costs. As a result of these challenges, the Company has observed
a widening gap between the amount of vegetiation management expenses it was
authorized to recover in the Iast general rate case and the actual amount the Company
spends each year. Table 3, below, shows that the 5 percent gap between actual and
authorized vegetation management costs in2011 has since grown to 68 percent in 2019.
It is critical to understand that ldaho Power has not been achieving more line miles of
vegetation management with this increased spending. On the contrary: each year, a
21 ldaho Power will continue to clear transmission right-of-way corridors located in mountainous areas on a
six-year cycle.
APPLICATION - 21
dollar spent on vegetiation management continues to purchase fewer line miles cleared
due to the numerous challenges discussed in Section ll and below.
Table 3. Authorized v. ActualVeqetation Manasement Expenses ($000s)
*Authorized amounts actual
47. A variety of factors help explain the cost increases ldaho Power has
experienced in vegetation management. Most notably, the availability of qualified Iabor
has diminished while demand for vegetation management services has grown across the
Western U.S. lmportantly, the vegetation management companies hired by ldaho Power
and other utilities are not simple arborists or Iandscapers. Vegetation management
companies qualified to work near electrical lines and equipment require special
certifications and training. The limited number of companies offering such qualified
services are in high demand in many Westem states, and especially in Califomia, where
labor rates are higher for the work itself and the labor that provides it. ldaho Power has
felt the effect of out-of-state competition in the form of double-digit cost increases and
qualified labor shortages.
48. Another exacerbating factor is ldaho's growth. Greater population density
and expansion of homes into more vegetation-dense areas has made it harderto maintain
APPLICATION -22
Authorized Amount*Actual Expenses Gap in Authorized &
Actual Costs
s5,3702010
S6,3zo 56,6lq 5%20tt
2012 s6,180 S6,946 L2%
56,4L4 57,332 L4%2013
s7,78820t4s6,183 26%
20ts s6,259 S8,084 29%
$6,229 57,719 24o/o2016
SG,393 s8,0482017 260/o
55,400 S11,0952018 73%
20L9 s6,378 $L0,741 68%
a consistent vegetation management cycle.2z New development is routinely built with
frontage trees and other vegetation. The growth in newly planted trees certainly Ieads to
more work, but a concomitant problem is that these trees are often inappropriate for their
location and environment. Trees that grow wide and tall and/or mature quickly are poor
candidates for planting near or beneath electrical lines, and yet tree selection is more
often made based on aesthetics rather than safety. ldaho Power efforts to communicate
and educate on appropriate tree selection in several ways, including the "Right Tree,
Right Place" tree planting guide, which offers detailed information on selecting
appropriate trees and planting them at safe distances from power lines.23
49. As discussed in Section ll, climate change is another factor contributing to
escalating vegetation management costs. ln recent years, ldaho has experienced wetter
springs followed by more temperate summers and falls, leading to longer vegetation
growing seasons. This fact alone, even without the qualified labor shortages, has
increased the amounts of money ldaho Power has spent to trim and prune the same
service area. Another climate-related issue is the spread of pests such as the bark beetle
that leave dead trees in their wake. Failure to remove dead or dying vegetation-a
problem felt most acutely on government land-complicates vegetation management
22 Related to vegetation management and ldaho Power's customers, the Company occasionally encounters
customers who are unwilling to allow the Company to complete vegetation management practices, which
can result in multiple trips by crews and equipment to a specific property. ldaho Power incurs a significant
expense each time a vegetation management crew is turned away from a site and then must be re-
dispatched. Considering the importance of timely, consistent, and routine vegetation management, ldaho
Power will study the extent of costs associated with return trip expenses and may assess the possibility of
devising a retum trip charge to be paid by customers to recoup the additional costs incurred when they do
not allow efforts to complete tree trimming or other vegetation management.23 More information about "Right Tree, Right Place" is available here on ldaho Power's website:
https ://docs. idahopower.com/pdfs/SafetyiTree_Plan ning_Guide.pdf
APPLICATION - 23
work and makes adhering to a routine clearing cycle more challenging, time consuming,
and, thereby, more costly.
50. The costs associated with vegetation management are Idaho Powe/s
largest incremental wildfire mitigation expense. Over the next five years, the Company
forecasts spending $42.7 million on incremental vegetiation management expenses, with
most of that amount stemming from efforts to work toward maintaining a three-year
pruning cycle. Recognizing that heightened risk exists in the Red and Yellow Risk Zones,
ldaho Power will take greater precautions and measures in these areas with respect to
vegetation management, including additional inspections, patrols, and maintenance pre-
fire season.
51. ldaho Power proposes to continue to absorb the costs of a base level of
vegetation management-approximately $10.7 million in 2019 and escalated annually for
inflation.2a ldaho Power considers the gap between the authorized amount from ldaho
Power's most recent genera! rate case (approximately $6.4 million) and the actual amount
incurred in 2019 to be reflective of "regulatory lag." ln summary, ldaho Power is
requesting authority to defer the ldaho jurisdictional share of incremental vegetation
management costs above a base level of 2019 actual costs (identified in Table 2 and
Attachment C); and, as noted earlier, that base level wil! be escalated annually for
inflation.
52. Because the goal of a consistent three-year vegetation management cycle
comes with significant incremental expense relative to other WMP components, ldaho
2a Annual inflation is based on the Consumer Price lndex ('CPl') tor 20'lg of 1 .81 percent.
APPLICATION - 24
Power proposes testing the three-year cycle for a period of four or five years to verifu that
such a cycle can be maintained and that the expected benefits are realized.
53. Cateqorv F. Communication: Over the next five years, the Company
projects $500,000 in new communications expenses2s related to customer and
community educational outreach via advertisements, printed media, social media, and
meetings. The purpose of these new @mmunications will be to keep customers aware
of mitigation and fire-related activities before, during, and after fire season.
V. OTHER INDIRECT WILDFIRE.RELATED COSTS
54. !n addition to the incremental costs associated with efforts to mitigate
wildfire risk, ldaho Power incurs other expenses indirectly related to wildfire. Most
notably, the Company has experienced significant increases in insurance premiums as a
result of heightened wildfire risk in the Western U.S. ldaho Power's total insurance costs,
as shown below in Table 4, have remained relatively stable until 2020, when a sizeable
jump can be observed. An even larger increase is expected lor 2021.
25 Future communications expenses related to ldaho Power's PSPS strategy are not included in this
estimate.
APPLICATION - 25
Table 4. ldaho Power Historic lnsurance Costs ($000s)
*2021 estimate assumes renewals, broker estimated 2021 increases,
and the impact of the new wildfire load
55. As noted in the memo from ldaho Power's insurance broker (Attachment
D), increases in liability premiums are largely attributable to the frequency and magnitude
of Western-state wildfires in recent years, as wel! as ldaho Power's specific wildfire risk.
The sizeable increase in ldaho Power's liability policy cost that is expected beginning in
2021 is due largely to a new "wildfire load" charge of approximately $1 million annually
that is being added to electric utilities such as ldaho Power that insurers have determined
operate in high-risk zones for wildfire. For 2021, this wildfire load is in addition to an
expected 11 percent liability premium increase and an expected increase of almost 20
percent for property insurance premiums.
56. ldaho Power believes that it is vital and in customers' best interest for the
Company to have adequate insurance coverage. The Company is taking extensive
proactive measures to reduce the likelihood of wildfire ignition, but in the event of an
unforeseen wildfire, ldaho Power must be able to protect its customers by recovering
damages through insurance. Moreover, insurance coverage strengthens the Company's
Total Company lnsurance Costs ($000s1
20to S7.sss
20tt 57,27t
2012 S8,o7s
20L3 St,se7
20t4 fi,tsq
2015 s7,676
2016 St,ott
2017 St,zot
2018 57,209
20t9 Sz,soo
2020 S8,819
202L*Srr.osg
APPLICATION - 26
balance sheet and credit profile so that it can continue to access debt and equity capital
at reasonable rates and remain financially viable, particularly in light of the significant
number of risk-based questions the Company has received in recent years from debt and
equity investors, analysts, and credit rating agencies on wildfire risk and mitigation.
57. While ldaho Power undertakes significant efforts to ensure it receives the
greatest insurance value possible for its customers, the Company is in large part a price-
taker in the insurance market and must absorb price increases as insurers raise
premiums due to losses. Therefore, the Company believes that incremental insurance
premium costs are appropriately included in this request for deferral authority.
58. Because insurance markets continue to be volatile, premium increases are
difficult to forecast. ldaho Power anticipates that, notwithstanding its efforts to negotiate
favorable rates, premiums for insurance will continue to increase for the foreseeable
future. This trend has been echoed by ldaho Power's insurance broker, who has
explained that insurance premiums will continue to increase due to prior losses incurred-
and increased risks of losses by insurers-from wildfires.
59. To manage these premium increases and to ensure that ldaho Power can
maintain an adequate level of insurance, the Company is requesting the authority to defer
the ldaho jurisdictional share of actual incremental insurance costs over 2019 levels.
Because ldaho Power cannot reasonably or accurately forecast the cost of policy
premiums beyond 2021, the Company will present actual deferred incremential insurance
premiums for the Commission's review in a future ratemaking proceeding.
60. ln summary, ldaho Power is not asking for cost deferral associated with
historic amounts of insurance, but rather deferral of costs associated with the actual
APPLICATION - 27
incremental increases in insurance from the current base amount of 2019. Because
changes in insurance premiums are not driven by general inflationary factors, the
Company is not proposing to escalate the 2019 base amount annually, as is proposed for
the measurement of other incremental O&M.
U. DEPRECIATION OF AL INVESTMENT
61. ln addition to the incremental costs identified in Sections lV and V of this
Application, ldaho Power requests the authority to deferfor later recovery the depreciation
expense of incremental capital investments related to wildfire mitigation. Over the next
five years, the Company's estimates investing $34.7 million in incrementalcapital related
to wildfire mitigation, as shown below in Table 5.
Table 5. Estimated lncremental Gapital lnvestment Related to Wildfire Mitigation ($000s)
202L 2022 2023 2024 2025 2021,-2025
T&D lncremental
Capital lnvestment S5,570 Ss,t39 S9,017 55,782 s9,238 Stq,t+a
62. ldaho Power's identified incremental capital investments will focus on
system hardening. Distribution hardening comprises the largest estimated investment
because the Company's Red and Yellow Risk Zones have more distribution facilities than
transmission. Distribution upgrades and hardening will include, but not be limited to, the
following kinds of investment: replacement of small conductors, installation of fiberglass
crossarms (replacing wood components), and installation of polymer switches (replacing
porcelain switches). On the transmission end, the Company will evaluate upcoming
transmission line construction projects-such as new line construction and line re-
builds-with the plan to use steel construction for all lines of 138kV and above.
APPLICATION - 28
63. ldaho Power requests the same authority to defer actual depreciation
expense associated with incremental capital that the Commission approved for Avista in
Order No. 34883.26 ldaho Power is not requesting the authority to defer the return
associated with its capital investment at this time.
64. Consistent with traditional accounting, the Company will record the
investments in appropriate plant accounts as assets are placed in service, with
depreciation commencing the following month. The Company will seek recovery of the
return on these wildfire-related capital investments, net of accumulated depreciation, in a
future ratemaking proceeding.
VlI. PROPOSEDACCOUNTINGTREATMENT
65. ldaho Power seeks authorization from the Commission to defer, for future
amortization, the ldaho jurisdictional share of actual incremental O&M expense and
depreciation expense of certain capital investments necessary to implement the
Company's wildfire mitigation measures, as well as incremental insurance costs, as
measured from the base levels presented in this Application. The Company will track
actua! expenses and actual incremental wildfire-related capital incurred on or after the
filing date of this Application and proposes to record such incremental O&M and related
depreciation expense amounts that would be subject to the deferral in accordance with
the Code of Federal Regulations to the Federal Energy Regulatory Commission ("FERC")
Account 182.3 (Other Regulatory Assets). The detailed costs and recovery method of
the costs associated with the Company's wildfire mitigation efforts would be addressed in
a future regulatory proceeding.
26 Case No. AVU-E-20-05, Order No. 34883
APPLICATION - 29
UI!. MODIFIED PROCEDURE
66. ldaho Power believes that it would be appropriate to process this case by
means of modified procedure (i.e., by wriften submission rather than by hearing) in
accordance with the provisions of RP 201-210. However, if the Commission prefers
another procedure for processing this case, ldaho Power will present its case in support
of the relief requested in this Application.
IX. COMMUNICATIONS
67. Communications and service of pleadings, with reference to this
Application should be sent to the following:
Lisa D. Nordstrom
Lead Counsel
ldaho Power Company
P.O. Box 70
Boise, Idaho 83707
I n o rd strom @ ida hooower. co m
Alison Williams
Regulatory Policy & Strategy Advisor
ldaho Power Company
P.O. Box 70
Boise, ldaho 83707
awill iam s@ idahopower.com
ldaho Power Dockets: [e-mail]
X. REQUEST FOR RELIEF
68. Wildfire risk in the West is increasing, and ldaho Power is taking proactive
measures to adjust to that increasing risk, particularly considering the magnitude of
damages and loss of life experienced in California and Oregon in recent years. Taking
actions to reduce the risk of wildfires is critical for ldaho Power's customers, the
communities in which the Company operates, and investors who provide capital to the
Company.
69. To that end, ldaho Power has conducted a comprehensive, rigorous
assessment of wildfire risks across its service area, resulting in the Company's Wildfire
Mitigation Plan. From the Wildfire Plan, the Company has identified several new and
APPLICATION - 30
expanded actions necessary to reduce wildfire risk, which align with actions that other
utilities are taking.
70. The incremental costs identified in this Application are foundational to
ensuring that ldaho Power can implement necessarywildfire mitigation measures across
its service area. To continue to safely and reliably serve its customers in the upcoming
fire season and beyond, the Company requests authorization to defer for later
ratemaking treatment the ldaho jurisdictional share of its prudently incuned incremental
O&M costs associated with wildfire mitigation expenses and related efforts, as well as
depreciation expense. ldaho Power requests authorization to record these incremental
costs as a regulatory asset until the Company can request amortization of the defened
costs in a future Commission proceeding, at which time the Commission will have the
opportunity to review actual costs prior to the Company receiving recovery of prudently
incurred costs through retail rates. These proposed incremental costs are not cunently
included in ldaho Power's rates or otherwise recovered through other existing regulatory
mechanisms.
DATED at Boise, ldaho, this 22nd day of January 2021.
f*rt-Y|"**-*,
LISA D. NORDSTROM
Attorney for ldaho Power Company
APPLICATION - 31
TTrE[0
EIPOT'ER=
An DlooRPoomrry
Wildfire Mitigation
Plan 2021
January 2021 (V1.0)
@ 2021 Idaho Power
ldaho Power Company Wildfire Mitigation Plan 2021
TeeLe oF CoNTENTS
Table of Contents
List of Tables........
List of Figures......,
List of Appendices
1.Introduction......
1V
..1
..1
..1
1.1. Background
1.2. Idaho Power Profile and Service Area.............'...
1.3. Asset Overview..1
1.4. Objectives of this Wildfire Mitigation Plan...
2. govemment, industry, and peer utility engagement
2. 1. Objective..............
2.2. Govemment and Industry Engagement ...'.....
.J
,4
.4
.4
2.3. P eer Utility Engagement ,.......4
........53. Quantifuing Wildland Fire Risk...........
3. 1. Objective................
3.2. Identiffing Areas of Elevated Wildfire Risk 5
6
7
3.2. 1 . Wildfire Risk Modeling Process ............
3.2.2. W ildfire Risk Areas
3.2.2.1. Boardman to Hemingway Proposed 500kV Transmission Line .........8
.......104. Situational Awareness
4.1. Overview 10
l0
t2
4.2. Fbe Potential Index.........
4.3. FPI Annual Process Review
5. Mitigation-Field Personnel Practices ..............1 3
..............13
..............1 3
5.1. Overview
5.2. Wildland Fire Preparedness and Prevention Plan
6. Mitigation--Operations
6.4.1. PSPS Definition
6.4.2. PSPS P1an...........
7. Mitigation-T&D Programs............
7. l. Overview...............
7 .2. T &D Asset Management Programs..
7 .2.1 . T ransmission Asset Management Programs
6.1. Overview.............. ..............14
6.2. Transmission Line Operational Strategy ..................14
6.2.l.Fire Season Temporary Operating Procedure for Transmission Lines....................14
6.2.2.Red Risk Zone Transmission Operational Strategy..... ......I4
6.3. Distribution Line Operational Strategy...........15
6.3.1. Red Risk Zone Distribution Operational Stategy..
6.4. Public Safety Power Shutoff......
t4
l5
..15
..15
t6
t6
................16
.,,...........,.17
7 .2.1 .1. Aerial Visual Inspection Program.............18
7.2.1.2. Ground Visual Inspection Program
7.2.1.3. Detailed visual (High-resolution Photography) Inspection program.
7.2.1.4. Wood Pole Inspection and Treatment Program....
7.2.1.5. Cathodic Protection and Inspection Program
7 .2.L.6. Thermal Imaging (Infra-red) Inspections t9
7 .2.1 .7 . Wood Pole Wildfre Protection Program ...........
7.2.1.8. Transmission Steel Poles .........
7.2.2. Distnbution Asset Management Programs ......20
7.2.2.1. Ground Detailed Visual Inspection Program.... ........20
7.2.2.2. Wood Pole Inspection and Treatrnent Program.... .......................21
7.2.2.3. Line Equipment Inspection Program ........................21
7.2.2.4. Overhead Primary Hardening Program .....................21
7.2.2.4.1. Conductor "Small" Replacement ......................21
...... I 8
......1 8
......19
......19
.20
Wildfire Mitigation Plan 2021 ldaho Power Company
ldaho Power Company Wildfire Mitigation Plan 2021
7.2.2.4.2. Wood Pin and Crossarm Replacement ))
....22
))
....22
....22
7 .2.2.4.3. Porcelain Switch Replacement
7 .2.2.4.4. Fuse Options ................
7 .2.2.4.5. Thermal Imaging (Infra-red) Inspections
7.2.2.4.6. Wood Pole Wildfire Protection Program
7 .3. T &D Vegetation Management
7.3. 1. Definitions...........
...............22
....,,......,,.23
)A
...............24
7 .3.2. Trunsmission Vegetation Management.
7 .3 .2.1 . Transmission Vegetation Inspections .......................'
7.3.2.2. Transmission Line Clearing Cycles )A
......24
)A
......25
......25
7.3.2.3. Transmission Line clearing Quality control and Assurance.........
7.3.3. Distribution Vegetation Management
7.3.3.1. Distribution Line Clearing Cycles '....'..
7 .3 .3 .2. Distribution Vegetation lnspections
7 .3 .3 .3 . Distribution Line Clearing Procedures
7.3.3.4. Distribution Line Clearing Quality Control and Assurance ................,
,.,.,,....25
..........26
..........267 .3.4. P ole Clearing of Vegetation.
8. Wildfrre Response .............27
.............278. 1. Overview..............
8.2. Response to Active Wildfires
8.3. Restoration of Electrical Service ......
,.27
..27
..27
..28
8.4. Emergency Line Patrols......
8.5. Construction Activities .......
8.5. 1. Mutual Assistance.........28
8.6. Public Outreach and Communications........28
.29
.29
.29
9. Communicating the Plan
9. 1. Objective................
9.2. Idaho Power External Communications
ilt
Wildfire Miti gation Plan 2021 ldaho Power Company
9.2. 1. Regulatory Entities......
9.2.2. Government Agencies..........................
.29
.29
.309.2.3. Idaho Power Customers.
9.2.3.1Prior to Wildfire Season...........30
9.2.3.2 During Wildfue Season...
9.2.3.3 After Wildfire Season ......
....3 1
....3 1
....32
.,,.33
....33
....33
....33
9.3. Idaho Power Internal Communications-Employees..
10. Performance Monitoring and Metrics
10.1. Wildfire Mitigation Plan Compliance..
1 0.2. Internal Audit.......
10.3. Annual Review..
10.4. Wildfire Risk Map 33
1 0.5. Situational Awareness..........
1 0.6. Wildfire Mitigation-Field Personnel Practices
..........33
..........33
.,.,,,,,,.34
......',,.34
1 0. 7. Wildfi re Mitigation--Operations.......
1 0.8. Wildfire Mitigation-T&D Programs
Ltsr oF TABLES
Table L
overhead transmission voltage level and approximate line mileage (Dec. 3l, zolg)..................2
Table 2
overhead distribution voltage level and approximate line mileage (Dec. 3l,z0lg).....J
Table 3
summarized r&D asset management programs (associated with the wMp).16
.23
.34
Table 4
VMP summary
Table 5
IV
T&D programs metrics
ldaho Power Company Wildfi re Mitigation Plan 2021
LIsT OF FIGURES
Figure L
Idaho Power service area ...............,2
Figure 2
Wildfire Mitigation Plan-Risk Map ..........
Figure 3
Boardman to Hemingway proposed route risk zones
8
9
LIST OF APPENDICES
Appendix A
The Wildland Fire Preparedness and Prevention Plan
V
Wildfi re Mitigation Plan 2021 ldaho Power Company
VI
ldaho Power Company Wildfire Mitigation Plan 2021
1. lntRoDucnoN
1.1. Background
In recent years, the Western United States has experienced an increase in the frequency and
intensity of wildland fires (wildfires). A variety of factors have contributed in varying degrees to
this trend including climate change, increased human encroachment in wildland land areas,
historical land management practices, and changes in wildland and forest health,
among other factors.
While Idaho Power Company (Idaho Power) has not experienced the type of catasffophic
wildfires within its service area that have occurred in other western states, such as California and
more recently cental Oregon, millions of acres of rangeland and southern Idaho forests have
burned in the last 30 years.l ln that same time period, the wildfire season has expanded by
70 days.zIn light of changing wildfre conditions in the west, Idaho Power evaluated conditions
and risks in its service area to determine existing and new practices for mitigation of wildfire
risk, establish practices requiring expansion or revision, and identiff which new efforts and
measures to be implemented.
1.2. ldaho Power Profile and Service Area
Idaho Power is an investor owned utility headquartered in Boise, Idaho, that is engaged in the
generation, transmission, and distribution of electricity. Idaho Power is regulated by the Federal
Energy Regulatory Commission (FERC) and the state regulatory commissions of Idaho and
Oregon. Idaho Power serves more than 570,000 retail customers throughout a 24,000 square mile
area in southem Idaho and eastern Oregon (see Figure 1).
I Rocky Barker, 70% of S. Idaho's Forests Burned in the Last 30 Years. Think That Will Change? ThinkAgain.,
Idaho Statesman, October 4,2020.
2 Id.
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Wildfire Mitigation Plan 2021 ldaho Power Company
Ir&p6rtaGAn9Ooog* SOImi .o,t re
Figure 1
ldaho Power seryice area
1.3. Asset Overview
Idaho Power delivers electricity to its customers via more than 310 substations, 4,800 miles of
overhead transmission lines, and 19,300 miles of overhead distribution lines.
Table 1
overhead transmission voltage leveland approximate line mileage (Dec.31,2019)
Transmission Voltage Line Miles
46 kV
69 kV
115kV
138 kV
161 kV
230 kv
345 kV
500 kv
384
1,136
3
1,435
84
1,144
473
102
Page2
Table 2
Overhead distribution voltage leveland approximate line mileage (Dec' 31' 2019)
Distribution Voltage Pole Miles
12.5 kV
25 kV
34.5 kV
14,300
468
4,548
1.4. Objectives of this Witdfire Mitigation Plan
The primary objectives of this Wildfire Mitigation Plan (WMP) are to identifu and implement
strategies that accomplish the following:
1. Reduce wildfire risk associated with Idaho Power's transmission and distribution (T&D)
facilities and associated field operations.
2. Improve the resiliency of Idaho Power's T&D system to any wildfire event,
independent of the ignition source.
Idaho Power's approach to achieving these objectives includes the following actions:
o Engage with government and industry entities and electric utility peers to ensure
understanding and commonality of wildfrre mitigation plans.
o Utilize a risk-based approach to quantiff wildland fire risk that considerswildfire
probability and consequence to identifu areas subject to an elevated risk of wildfire
relative to Idaho Powei's service area. Resulting areas of elevated wildfire risk will be
incorporated within Idaho Power's geographic information system (GIS)
mapping system.
o Create specific targeted actions in operations and maintenance practices,
system hardening programs, vegetation management, and field personnel practices to
mitigate wildfire risk.
o Incorporate sifuational awareness information around current and forecasted weather and
field conditions into operational practices.
o Determine public safety power shutoffs (PSPS) strategy for Idaho Power's service area
and transmission corridors.
o Evaluate the performance and effectiveness of strategies identified in this WMP through
metrics and monitoring. The WMP and all its components will be reviewed prior to fire
season each year.
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ldaho Power Company Wildfi re Mitigation Plan 2021
Wildfire Mitigation Plan 2021 ldaho Power Company
2. GoVERNMENT, INDUSTRY, AND PEER UTILITY ENGAGEMENT
2.1. Obiective
Idaho Power recognized the importance of engaging with the Idaho Public Utilities Commission(IPUC) and the Public Utility Commission of Oregon (OPUC) as the company developed its
WMP. In addition, Idaho Power parhrered with industry entities and peer utilities in the
development of its WMP. This collaboration ensured the commonality of core components of theutilities' respective wildfire mitigation plans.
2.2. Government and lndustry Engagement
Idatro Power is a member of both the Edison Electric Institute (EEI) and the Westem Electric
Institute fl^fED. The company participated in multiple workshops and conferences with both
entities and their member utilities to ensure the Idaho Power WMP is robust and effective.
Additionally, the Idaho Power CEO and President, Lisa Grow, is an active member of the EEI
Electricity Subsector Coordinating Council Wildfire Working Group. This working group has
been partnering with the U.S. Departrnent of Energy and other government agencies to
collectively minimize wildfire threats and potential impacts of wildfires.
Idaho Power engaged with both the IPUC and OPUC during development of its WMp.
Idaho Power also participated as presenters and panelists in OPUC workshops focused on
wildfire mitigation planning.
2.3. Peer Utility Engagement
Although Idaho Power utilized templates developed by several of the California utilities when
formulating this WMP, it modified those templates in light of Idaho Power's considerably
different risk profile. Idaho Power also participated in multiple workshops with San Diego Gas
and Electric, Southern Califomia Edison, Pacific Gas and Electric, Sacramento Municipil Utility
District, and PacifiCorp.
Many utilities in the Pacific Northwest worked collaboratively to understand and ensure
commonality of their various wildfire mitigation plans, while also understanding each utility's
unique service territory. These utilities included Idaho Power, Avista Utilities, portland General
Electric, Rocky Mountain Power, Pacific Power, Chelan County Public Utility District,
Puget Sound Energy, and Northwestern Energy.
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ldaho Power Compa ny Wildfire Mitigation Plan 2021
3. QUINTIFYING WILDLAND FINT RIST
3.1. Objective
IdahoPower,sapproachtoquantiffingwildlandfireriskistoidentislthosegeographicareas
that are at an elevated risk of wildfire should there be an ignition near a power line. Once
elevated wildfire risk areas are identified, mitigation actions and programs can be prioritized in
those areas.
3.2. ldentifying Areas of Elevated Wildfire Risk
Idaho Power hired an extemal consultant that specializes in assessing and quantiffing the threat
of wildfire through a risk-based methodology thatleverages weather modeling, wildfire spread
modeling, and Monte Carlo simulation. This type of modeling approach is not unique to Idaho
power's WMP. The California Public Utilities Commission (CPUC) used the same modeling
approach (and in fact, the same consultant) as part of its development of the CPUC lire Threat
frAap. fn udditiorr, other utilities in Oregon, Idaho, Nevada, and Utah have utilized similar
modeling approaches to identifu and quantiff wildfire risk.
This modeling methodology is consistent with conventional definitions of nsft, which is usually
taken as an event' s p robability multiplied by its potential negative consequences or impacts
should that event occur. For Idaho Power's wildfire risk assessment, this formula is:
Wildfire Risk = Fire Probabitlty x Consequence
The defrnition of each component is as follows:
Fire Probabilitv. Fire volume (i.e., spatial integral of fire area and flame length) is used as Fire
Pr"b"btttty b*ause rapidly spreading fires are more likely to escape initial containment efforts
and become extended fires than slowly developing fires. Data inputs used in the fire spread
model to determine the fire volume (Fire Probability) include:
o Historical weather (temperature, wind speed/direction, relative humidity)
. Topography
o Fuel types present
o Fuel moisture content (both dead and live fuels)
Consequence. Number of structures (i.e., homes, businesses, other man-made structures)
that may be impacted by a wildfire is used as the Consequence.
Wildfire Risk. Wildfrre Risk is the Fire Probability multiplied by the Consequence. The highest
Wildfre Risk areas will be those where bottr the Fire Probability and Consequence are elevated.
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Wildfi re Mitigation Plan 2021 ldaho Power Company
Conversely, combinations of low Fire Probability and elevated Consequence, or elevated Fire
Probability and low Consequence, will typically indicate lower wildfire Risk.
3.2.1. Wildfire Rrsk Modeling Process
The wildfire risk modeling process incorporated the following major steps:
l. AZD-year (2000-2019) fire weather climatology was developed utilizing the Weather
Research and Forecasting (WRF) model to recreate historical days of fire weather
significance across Idaho Power's service territory. This analysis generated
high-resolution hourly gridded fields of relative humidity, temperature, dead fuel
moisture, and wind speed/direction that was used as input to a Monte Carlo-based fire
modeling analysis.
2. Estimates of seasonal variation in live fuel moisture across Idaho Power's service territory
were developed. This was accomplished by analyzinghistorical fuel measurements
and/or weather station observations. This step was necessary because live fuel moisture
data is needed for fire spread modeling, but the WRF weather model does not provide
live fuel moistures.
3. The federal LANDFIRE program was utilized to provide high-resolution
(approximately 100 feeQ fuel rasters for use in fire spread modeling.3
4. The data developed above (WRF climatology,live fuel moisture, and LANDFIRE data)
was used to drive a Monte Carloa fre spread modeling analysis. This Monte Carlo
simulation was accomplished by randomly selecting an ignition location and a randomly
selected day from the fre weather climatology developed in step 1 above.
Ignition locations were limited in the model to be within a two-kilometer buffer
surrounding Idaho Power's overhead T&D lines (i.e., I kilometer on either side).
Note that transmission lines jointly owned by Idaho Power and PacifiCorp were included
in the analysis. Furthermore, the proposed Boardman-to-Hemingway (B2H) 500kV line
route was also included in this analysis. For each combination of ignition location and
time of ignition, fire progression was then modeled for 6 hours. For each modeled fre,
potential fire impacts to structures were quantified using structure data. This was repeated
across Idaho Power's service territory for millions of combinations of ignition location
and time of ignition.
5. The Monte Carlo results were processed, and GIS based data depicting fine grained
wildfire risk was developed. This risk was then visually depicted on GIS based wildfire
risk maps.
3 Chris Lautenberger, Mapping areas at elevated risk of large-scale structure loss using Monte Carlo simulation and
wildland fire modeling. IAFSS 126 Symposium20lT.
4 tbid.
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ldaho Power Company Wildfi re Mitigation Plan 2021
3.2.2. Wildfire Risk Areas
Based on the previously described modeling, draft risk tiers were generated algorithmicallys by
establishing threshold values above which ar,area is considered as Tier 2 and Tier 3. This was
accomplished by manually setting threshold values on naturally occurring breaks.
Consequently, the resulting risk tiers reflect risk relative to Idaho Power's service territory only
and not absolute risk. As set forth later in this plan, Idaho Power's risk profile is significantly
lower than utilities serving California.
An integral part of the consultant's mapping process involved reviewing the tiers and making
necessary adjustrnents to account for unique aspect of certain areas, including factors that may
increase or decrease risk, which would not be accounted for in the computer modeling.
Several factors were considered, including the following:
a Topography and resistance to fire control
a Means of ingress and egress
a Presence/absence of defensible space
a Vulnerable populations
a Cell phone coverage
o Non-burnable land cover such as built up urban areas
The final two-tier risk map reflecting relative increased risk Yellow Risk Zones (YRZ) and
higher risk Red Risk Zones (RRZ) is shown in Figure 2.
s tbid.
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Wildfire Mitigation Plan 2021 ldaho Power Company
?
1'.
.
Figure 2
Wildfire Mitigation Plan-Risk Map
3.2.2.1. Boardman to Hemingway proposed 50okv rransmission Line
Idaho Power specifically considered the proposed route of the B2H 500kV transmission line aspart of the WMP. The proposed route was included in the wildfire risk assessment and associated
map analysis (see Figure 3). Two locations are identified along the route as having increasedwildfire risk (Yellow Risk Zones), and there were no areas of higher risk (Red niJk Zones).
Idaho Power plans to address these locations consistent with the mitigation strategy for
transmission lines as described in sections 6 and,7 of this WMp.
tur* loNr
t
t,
t
a
1
t'
I,. gh
i'p
- i$"i ,
Page 8
ldaho Power Company Wildfire Mitigation Plan 2021
i w.[Wril.
W ,:!L
ffi%
3!
n[fi ! wir_Df r*f
hA:AflO AREN!
uir
Figure 3
Boardman to Hemingway proposed route risk zones
Page 9
4. STUATIoNAI. AwaRENESS
4.1. Overview
Visibility and readily available access to current and forecasted meteorological conditions and
fuel conditions is a key aspect of Idaho Power's wildfire mitigation strategy. Meteorological and
fuel conditions can vary significantly across Idaho Power's service territory. Idaho Power
leverages its internal meteorology department's modeling/forecasting capabilities, its existing
field weather stations, and publicly available weather/fuel data to develop projections of current
and future wildfire potential across Idaho Power's service territory. This wildfire potential
information is then available to operations personnel to factor into their operational
decision-making.
4.2. Fire Potential lndex
Idaho Power has developed a Fire Potential Index (FPI) tool based upon original work completed
by San Diego Gas and Electric, the National Forest Service, and the National Interagency Fire
Center and modified for Idaho Power's Idaho and Oregon service territory. This tool is designed
to support operational decision-making to reduce fire threats and risks. This tool converts
environmental, statistical, and scientific data into an easily understood forecast of the short-term
fire threat which could exist for different geographical areas in the Idaho Power service territory.
The FPI is issued for a seven-day period to provide for planning of upcoming events by Idaho
Power personnel.
The FPI reflects key variables, such as the state of native vegetation across the service territory
("green-up"), fuels (ratio of dead fuel moisture component to live fuel moisture component), and
weather (sustained wind speed and dew point depression). Each of these variables is assigned a
numeric value and those individual numeric values are summed to generate a Fire Potential value
from zero to sixteen, each ofwhich expresses the degree offire threat expected for each ofthe
7 days included in the forecast. The FPI scores are grouped into the following index levels:
o Green: FPI score of 1 through I I indicates low potential for a large fire to develop and
spread as there is normal vegetation and fuel moisture content as well as weak winds and
high relative humidity.
Yellow: FPI score of 12 through 14 indicates an elevated potential for a large fire to
develop and spread as there are lower than normal vegetation and fuel moisture content
as well as moderate winds and lower than normal relative humidity.
Red: FPI score of 15 through 16 indicates a higher potential for a large fire to develop
and spread as there are well below normal vegetation and fuel moisture content as well as
strong winds and low relative humidity.
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a
a
Wildfi re Mitigation Plan 2021 ldaho Power Company
Fire Potentiallndex category
12to 14
The state of native grasses and shrubs, or Green-Up Component, of the FPI is determined using
satellite data for locations throughout the Idaho Power areas of interest. This component is rated
on a 0-to-5 scale ranging from very wet (or "lush") to very dry (or "cured"). The scale is tied to
the Normalized Difference Vegetations Index (NDVI), which ranges from 0 to 1, as follows:
The Fuels Component (FC) of the FPI measures the overall state of potential fuels which could
support a wildfire. Values are assigned based on the overall state of available fuels (dead or live)
for a fre using the following equation:
FC=FD/LFM
Where FC represents Fuels Component in the scale below, FD represents lO-hour Dead Fuel
Moisture (using a 1-to-3 scale), and LFM represents Live Fuel Moisture (percentage). This data
will be collected from satellite sources and regional databases supported by state and federal
agencies.
The product of this equation represents the fuels component that is reflected in the FPI
as follows:
The weather component of the FPI represents a combination of sustained wind speeds and
dew-point depression as determined using the following scale. Regional adjustment to criteria
limits for the upper wind speeds may occur after further discussion with subject matter experts
from each of the regional operations. This data will be sourced from the weather, research and
forecasting (WRF) products produced by Idaho Power using its High-Perfornance Computing
(HPC) system. In addition to the HPC system produced WRF data, several national level
Page 1 1
Green-Up Component
ldaho Power Company Wildfire Mitigation Plan 2021
Wildfire Mitigation Plan 2021 ldaho Power Company
meteorological products will be used. These products will include regional weather observations
used to validate model information.
4.3. FPI Annual Process Review
The FPI process will be reviewed annually after completion of the fire season and, withconsultation of interested parties (e.g., Load Serving Operator, Line Crews, and oihers), will beupdated to enhance Idaho Power's wildfire preparedness.
Page 12
5. MrtcATloN-Fleup PensouNEL PmcncES
5.1. Overview
A component of Idaho power's wildfire mitigation strategy is to prevent the accidental ignition
and spiead of wildfires due to employee work activities. Idaho Power has developed the
Witdiand Fire Preparedness and Prevention Plan (Appendix A) to provide eUrdange to Idaho
power employees and conffactors to help prevent the accidental ignition and spread of wildfires
due to.o-purry work activities in locations and under conditions where wildfire risk is
heightened. ,A.ti tOaho Power crews and certain field personnel performing work on or near Idaho
poier,s facilities will be expected to operate in accordance with the Plan and continue to
conduct themselves in a flre-safe manner.
5.2. Wildland Fire Preparedness and Prevention Plan
The Wildtand Fire Preparedness and Prevention Plan informs Idaho Power personnel and its
line construction contractors about the following factors:
. Annual fire season tools and equipment to be available when on the job site
o Daily situational awareness regarding locations of heightened potential for fire risk and
weather conditions in those areas
Expected wildfle ignition prevention actions while working and reporting instructions in
the event of fire ignition
Training and compliance requirements
a
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ldaho Power ComPanY Wildfire Mitigation Plan 2021
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6. M rloATtoN-O pe nnnoNs
6.1. Overview
A component of Idaho Power's wildfire mitigation strategy is to continue safe and reliable
operation of its T&D lines while also reducing wildfire risk. These operational practices
primarily center around the following:
o Temporary operating procedures for tansmission lines during the fire season6
o An operational strategy for transmission and distribution lines during time periods of
elevated wildfire risk during the fire season
o If applicable, a PSPS strategy for Idaho Power's service area and transmission corridors
6.2. Transmission Line Operational Strategy
6.2.1. Fire Season Temporary Operating Procedure for
Transmission Lines
Each year, typically in May, leadership within Idaho Power's Load Serving Operations (LSO)
deparhnent updates and issues its Fire Season Temporary Operating Procedure. The purpose of
this temporary operating procedure is to provide LSO employees with guidelines for operating
transmission lines during the summer fre season. The procedure aims to reduce wildfue risk
through practices relating to information collection, notification, and procedures for
testing/closing in on locked-out transmission lines.
6.2.2. Red Risk Zone Transmission Operational Strategy
During the fire season, Idaho Power will determine a daily FPI as described in Section 4 of this
WMP. The FPI will inform the transmission line operational strategy for those lines owned,
operated, and located in the wildfire Red Risk Zones. These lines will be operated in normal
settings mode but with no "testing"T of a line that may have "locked out" au.ing the time of red
FPI. Essentially, in the event of a fault on the specified transmission lines during the red FpI,
the line will operate as normal and may "lock out" at which time the line(s) will either need to be
patrolled before "testing," or the FPI level drops out of the red category.
6 The duration of the fire season will be reviewed and defined annually.
7 Transmission line "testing" refers to the human act of re-energizirgaline without completing a physical field
patrol or observation of a line.
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Wildfire Mitigation Plan 2021 ldaho Power Company
6.3. Distribution Line Operational Strategy
6,3.1. Red Risk Zone Distribution Operational Strategy
During the fire season, Idaho Power will determine a daily FPI as described in Section 4 of this
WMP. The FPI will inform the Distribution line operational strategy for those lines located in the
wildfire RRZs. These lines will be operated in a non-reclosing8 state during the time of red FPI.
Essentially, in the event of a fault on the specified distribution lines during the red FPI, the line
will be automatically de-energized with no reclosing attempts until either the lines have been
patrolled, or the FPI level drops out of the red category.
In addition, certain distribution lines may also be operated in a mode of "instantaneous trip."e
6.4. Public Safety Power Shutoff
6.4.1. PSPS Definition
Public Safety Power Shutoff (PSPS), as used in this WMP, is generally defined as the proactive
and planned de-energization of lines when extrerne wildfire risk conditions (i.e., combinations of
veryhigh winds, high temperatures, dry fuels, and low humidity) are forecasted. The concept is,
if significant weather events can be predicted far enough in advance, that resulting proactive line
de-energization before the forecasted weather conditions materialize could mitigate the risk of a
wildfire. A PSPS process has significant customer impact and would necessarily require
significant planning.
PSPS is not the practice of de-energizing lines in the following types of situations:
o Unplanned de-energizationof lines required for emergencies and during outage
restoration situations.
o Planned line or station work activities which requires a planned outage (Idaho Power
currently has a planned outage customer notification process in place for this).
Idaho Power will continue its current practices of de-energization in these, and comparable,
situations. These outage situations are not defined as PSPS events in the context used here.
6.4.2. PSPS Plan
Idaho Power evaluated whether PSPS would be a reasonable wildfire mitigation tool as part of
its wildfire mitigation strategy. Although the wind patterns in ldaho Power's service territory are
of a much lower sustained velocity and often less predictable (i.e., micro-bursts) than other
8 Distribution line "non-reclosing" refers to the deactivation of automatic re-energization of a distribution line.
e Instantaneous trip refers to the automatic de-energization of a line with no intended time delay.
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ldaho Power Company Wildfire Mitigation Plan 2021
Wildfire Mitigation Plan 2021 ldaho Power Company
utilities' service areas where PSPS has been utilized (i.e., California), the company will develop
a PSPS plan-which will evaluate the conditions in ldaho Power's service area-if any, that may
warrant Public Safety Power Shutoffs. The PSPS plan is in the early stages of development with
anticipation of completion in advance of the 2022 fu.e season.
7. MTIcATIoN-T&D PnoGRAMS
7.1. Overview
A component of Idaho Power's wildfire mitigation strategy is to manage certain conditions
related to its T&D lines such that they continue to operate in a safe and reliable manner thus
reducing the risk of igniting a fire. This is accomplished through a portfolio of asset management
programs and Idaho Power's vegetation management program.
7.2. T&D Asset Management Programs
Idaho Power has numerous and robust asset management programs intended to reduce the
probability of igniting wildfires. Idaho Power plans to continue previously implemented
infrastructure management programs in conjunction with new programs.
Additionally, Idaho Power continues to research, monitor, and pilot emerging technologies and
strategies to manage its T&D infrastructure.
Idaho Power's key asset management programs that support wildfire prevention and mitigation
are summarized in the table below.
Table 3
Summarized T&D asset management programs (associated with the WMP)
Transmission Asset Management Programs
Aerial Visual lnspection Program
Ground Visual lnspection Program
Detailed Visual (High Resolution Photography) lnspection Program
Wood Pole lnspection and Treatment Program
Cathodic Protection and lnspection Program
Wood Pole Wildfire Protection Program (enhanced)
Steel Pole (Structures) (enhanced)
Distribution Asset Management Programs
Ground Detail lnspection Program (enhanced)
Page 16
Wood Pole lnspection and Treatment
Wood Pole Fire Protection Program (enhanced)
Line Equipment lnspection Program
Overhead Primary Harden Program
Replace "small conductor" with new 4acsr or larger conductor (new)
Replace or repair damaged conductor
Re-tension loose conductors including "flying taps" and slack spans as required
Replace wood-stubbed poles with new wood poles (enhanced)
Replace white and yellow square tagged poles with new wood poles
Replace wood pins/wood crossarm with new steel pins/fiberglass crossarms
Replace steel insulator brackets with new steel pins/fiberglass crossarms (new)
Replace wedge deadends on primary taps with new polymer deadend strain insulators
Replace aluminum deadend strain insulators with new polymer deadend strain insulators (new)
Replace porcelain switches with new polymer switches
Replace hot line clamps
Replace aluminum stirrups
lnstall avian cover
Relocate anesters
lnstall bird/animal guarding
Update capacitor banks
Replace swelling capacitors
Replace oil-filled switches with vacuum style
Replace porcclain switches with polymer switches
lnstall disconnect switches on CSP transformers
lnstall avian cover
Update down guys
Replace/lnstall down-guy insulators with fiberglass insulators
Tighten down guys
Tighten hardware
Correct 3rd party pole attachment clearances (report to Joint Use Department)
ldaho Power Company Wildfire Mitigation Plan 2021
7.2.1. Transmission Assef Management Programs
Several transmission management programs are mature and have been implemented by Idaho
Power for decades. These programs include condition-based aerial visual inspections,
gound visual inspections, detailed visual (generally using high resolution photography)
inspections, transmission wood pole inspection and treaftnent, and cathodic protection.
Additionally, Idaho Power has used various methods and materials to prevent wildfire from
damaging wood structures and now intends to use a fire-resistant mesh wraps installed on
structures located in the RRZ and YRZs.
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Wildfire Mitigation Plan 2021 ldaho Power Company
7.2.1.1. Aeria! Visual lnspection Program
Annually, Idaho Power uses helicopters to assist Idaho Power qualified personnel in the visual
aerial inspection of transmission lines identified as Western Electricity Coordinating Council
(WECC) Path Lines. This method of line inspection will now be utilized for tuansmission lines
located in the RRZs. In addition, unmanned aerial vehicles with high definition cameras will be
used in certain situations to inspect facilities on these lines. These inspections allow personnel tolook for potential line defects, which if found, are noted and scheduled for repair.
All noted defects are prioritized as Priority 1, Priority 2, or Priority 3, based on the criteria
listed below:
a Priority 1: Defects that, depending on the circumstances, require reporting and repair as
soon as reasonably possible.
o Priority 2: Defects that, depending on the circumstances, generally require reporting and
correction within 24 months of identification. The correction of these defects sfrouta be
scheduled during crews' normal work schedules. Priority 2 defects not assigned a
corrective plan within 24 months will be reviewed by the T&D vegetation and
maintenance engineering leader.
o PrioritY 3: Potential issues that may need correction but do not pose a threat to the
system and should be monitored. A Priority 3 designation may also be used by Idaho
Power personnel for tracking of certain line construction practices.
Corrective action plans for Priority I and2 defects are determined by engineering personnel for
each prioritized defect and are scheduled and repaired.
7.2.1.2. Ground Visual lnspection Program
Annually, Idaho Power qualified personnel (i.e., trained in transmission line inspection
procedures and experienced in transmission line conskuction) complete ground visual
inspections of all transmission lines. Ground patrols are completed using four-wheel-drive
vehicles, all-terrain vehicles, utility terrain vehicles, or on foot. These inspections identiSr
potential line defects that are noted and scheduled for repair following the same process as
described in7.2.lJ.
7.2.1.3. Detailed visual (High-resolution photography) lnspection program
In addition to the annual inspections and associated maintenance, Idaho Power also completes
detailed visual inspections generally utilizing high resolution photography. This detailed
inspection is typically completed using helicopters, unmanned aerial vihicles, and contracted
professionals operating high definition cameras and, if potential line defects are noted, they are
scheduled for repair following the same process as described in 7 .2.I.1. The detailed inspections
are completed on a l0-year cycle in conjunction with the l0-year cycle of wood pole ground line
inspection and treatment (see 7 .2.1.4).
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ldaho Power Company Wildfire Mitigation Plan 202'l
7.2.1.4.Wood Pole lnspection and Treatment Program
All wood poles are visually inspected, sounded, and bored for defects and decay on a lO-year
cycle. The poles are categorized according to the following:
o Reported: Any wood pole inspected and found to be installed within 10 years of the
manufactured date or last inspection date.
o Treated: Any wood pole inspected and found to be installed 11 years or more prior to the
inspection date and is determined to be in sound enough condition to warrant treatnent.
o Rejected: Any wood pole determined to fit the following criteria:
o Have less than 4 inches of shell at 48 inches above the ground line; and/or
o Less than2 inches of shell at 15 inches above the ground line; and/or
o Less than2 inches of shell at the ground line; or
o Is deteriorated and does not meet minimum strength criteria; or
r Fails a visual inspection.
Rejected poles are categorized as: reinforceable with steel, non-reinforceable and are to
be replaced.
o Visually Rejected: Any wood pole that has been damaged (i.e., burncd, split, broken, hit
by a vehicle, damaged by animals, etc.) above the ground line to such an extent as to
warrant rejection and that cannot be further tested to determine priority status.
o Sounded, Bored, and Treated: Any wood pole set in concrete, asphalt, or solid rock 11
years or more prior to the inspection date is internally treated. Intemal treatment involves
fumigating the good wood and flooding the voids with fumigant'
7.2.1.5. Cathodic Protection and lnspection Program
Cathodic protection systems are employed on select steel transmission towers. These systems use
either * irop..rr"d cunent corrosion protection system (ICCP) or direct-buried sacrifrcial
magnesium anodes. Included in Idaho Power's tower maintenance plan, every l0 years,
stnicture{o-soil potential testing is performed on select towers with direct-buried anodes.
For ICCP systems, rectifiers and ground-beds are tested to ensure they are functioning properly'
Based on test results repairs and adjustments are completed. Each year all rectifiers are
inspected, and direct current (DC) voltage and DC current readings noted.
7.2.1.6.Thermal lmaging (lnfra'red) lnspections
Idaho Power will complete annual inspections of lines and equipment using thermal imaging
(infra-red) cameras. This inspection methodology, although not new to Idaho Power, is being
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Wildfire Mitigation Plan 2021 ldaho Power Company
expanded to specifically include the RRZs. Compromised electrical connections and overloaded
equipment may be identified using thermal imagery. Identified risks will be prioritized and
mitigated using the prioritization methodology noted n7.2.lJ of this WMP.
7.2.1.7. Wood Pole Wildfire Protection Program
Idaho Power has utilized numerous technologies to minimizethe damage to wood poles that
have been exposed to wildfues. The current technology of "mesh wraps" will be utilized on
transmission wood poles located in the RRZs and YRZs.
7.2.1.8. Transmission Steel Poles
To minimize damage from wildfires, beginning on January l,202l,Idaho Power will
generally fiilize steel poles or structures for construction of all new and major rebuild projects
on all transmission voltages of l38kV and greater that are located in undeveloped lands
(whether Federal, State, or private). The use of steel-pole construction will be considered, but is
not required, in developed areas, regardless of whether the development is agricultural,
residential, commercial, or some other form of development. The choice of pole material will be
made based on the specific engineering requirernents for each individual project. Because of
inconsistencies in structural framing dimensions between wood and steel 138kV H-frame
structures, Idaho Power will continue to utilize wood H-frame structures for maintenance
replacement structures on existing l38kV wood H-frame lines, as necessary. Idaho Power will
continue to utilize steel construction for all structure replacements and new lines at voltages of
230kV and above.
7.2.2. Distribution Assef Management Programs
Idaho Power has several distribution asset management programs that are mature, have been
implemented for decades, and will continue to be utilized in the RRZs. These programs include
condition-based, detailed, and ground visual inspection; distribution wood pole inspection and
treatment; and line equipment inspection.
Idaho Power will also create an enhanced overhead distribution "hardening" program to
implement in the RRZs. Examples of specific work included in the hardening program include
replacement of small conductors and associated hardware and replacement of wooden pins and
associated wooden crossarrns.
7.2.2.1. Ground Detailed Visual Inspection Program
Annually, qualified line patrol personnel (trained in distribution line inspection procedures and
experienced in distribution line construction) complete detailed ground inspections of the
distribution lines located in the RRZs. The ground patrols are completed using four-wheel-drive
vehicles, all-terrain vehicles, utility terrain vehicles, or on foot. These inspections identiff
potential line defects that are noted and scheduled for repair.
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ldaho Power Company Wildfi re Mitigation Plan 2021
All noted defects are prioritized as Priority 1, Priority 2, or Priority 3, based on the criteria
listed below:
. Priority L: Defects that, depending on the circumstances, require reporting and repair as
soon as reasonably possible.
o Prioriry 2: Defects that, depending on the circumstances, generally require reporting and
correction within 24 months of identification. The correction of these defects should be
scheduled during crews' normal work schedules. Priority 2 defects not assigned a
corrective plan within 24 months will be reviewed by the T&D Vegetation and
maintenance engineering leader.
o Priority 3: Potential issues that may need correction but do not pose a threat to the
system and should be monitored; or tracking of certain line construction practices.
Corrective action plans for Priority I and2 defects are determined by engineering personnel for
each prioritized defect and are scheduled and repaired.
7.2.2.2. Wood Pole lnspection and Treatment Program
All wood poles are visually inspected, sounded, and bored for defects and decay. The procedure
is noted lr:,7.2.1.4.
7.2.2.3. Line Equipment lnspection Program
Line equipment, particularly distribution system protection line equipment, is inspected annually
by line operations technicians. The inspection includes a visual inspection and, when electronic
reclosers are present, data is retrieved from controls and analyzed for proper operation.
7.2.2.4. Overhead Primary Hardening Program
Overhead distribution infrastructure located in the RRZs will be analyzed and may be inspected
and hardened depending upon proximity to fuels conducive to wildfires in the unlikely event of
failure of the line infrastructure. It is expected to take multiple years to inspect and harden all
applicable overhead distribution lines.
The Overhead Primary Hardening program is intended to upgrade or repair certain overhead
distribution infrastructure. Criteria as outlined in Table 3 drives the program work.
Notable criteria are further explained in the following sections of this WMP.
7.2.2.4. 1. Conductor "Small" Replacement
Idaho Power is implementing a new focus on replacement of small conductors in the RRZs.
Small conductors are those in sizes less than that of 4ACSR conductor. Examples of small wires
include 6Cu, 6-355, 8A, 8A CW, 9IR, etc. These small conductors will be replaced with
standard larger conductors, primarily with 4ACSR conductor.
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Wildfire Mitigation Plan 2021 ldaho Power Company
7.2.2.4.2. Wood Pin and Crossarm Replacement
Wooden crossarms installed with wooden pins will continue to be replaced with fiberglass
crossarms and steel pins. This work will be coordinated and included in the overhead primary
hardening progftIm. And, whenever work is being completed on a structure that requires
replacement of wooden crossarms, Idaho Power will, generally, install fiberglass crossarms.
7. 2. 2. 4. 3. Porcelain Switch Replacement
Porcelain switches located in the RRZs will continue to be replaced with pollmrer switches.
Additionally, associated hot clamps and stimrps will be replaced. This work will be coordinated
and included in the overhead primary hardening program.
7.2.2.4.4. Fuse Options
Idaho Power is investigating reasonable alternatives for the replacement of certain expulsion
fuses and expulsion arrestors. A pilot program was initiated:.rr,2020 to replace several expulsion
fuses with non-expulsion fuses in the vicinity of the Boise foothills. The non-expulsion fuses are
being reviewed for proper operation, feasibility of handling, storage capability, and overall safety
ofuse.
7. 2. 2. 4. 5. Thermal Imaging (Infra-red) Inspections
Idaho Power will complete annual inspections of lines and equipment using thermal imaging
(infra-red) cameras. This inspection methodology, although not new to Idaho Power, is being
expanded to specifically include the RRZs. Compromised electrical connections and overloaded
equipment may be identified using thermal imagery. Identified risks will be prioritized and
mitigated using the prioritization methodology noted :rr.7.2.2.1of this WMP.
7.2.2.4.6. Wood Pole Wildfre Protection Program
Idaho Power has utilized numerous technologies to minimizethe damage to wood poles that
have been exposed to wildfires. The current technology of "mesh wraps" will be utilized on
certain distribution wood poles located in the RRZs.
7.3. T&D Vegetation Management
Idaho Power's T&D vegetation management program (VMP) addresses public safety and
electric reliability and helps to safeguard T&D lines from trees and other vegetation that may
cause an outage or damage to facilities. Specifically, the lines are inspected periodically,
and trees and vegetation are cleared away from the line while certain trees are removed entirely.
In addition, the VMP addresses the clearing of vegetation near the base of certain poles and line
structures. The responsibilities of the VMP include the planning, scheduling, and quality control
of VMP associated work. The VMP is active year-round and complies with applicable NESC,
federal, and state requirements. Additional vegetation monitoring tools are in various stages of
development, and Idaho Power will evaluate such tools for potential future implementation.
Idaho Power's key components of its VMP, relative to the WMP, are summarized in the
table below.
Page22
Table 4
VMP summary
Transmission
Pre-Fire Season lnspection and Mitigation
Line Clearing Cycle Goal: &year cycle for valley areas & 6-year cycle for mountiain areas
Tree Removals - Hazard Trees
Targeted Pole Clearing
100% Quality Assurance/Quality Control Auditing in RRZS and YRZs
Distribution
Pre-Fire Season lnspection and Mitigation
Line Clearing Cycle Goal: 3-year cycle in all areas with mid-cycle pruning occuning in 2d year in RRZs and YRZs*
Tree Removals - Cycle Busters/Hazard Trees
Targeted Pole Clearing
100% Quality Assurance/Quality Control Auditing in RRZs and YRZs
ldaho Power Company Wildfire M itigation Plan 2021
*Distribution line clearing rycles vary by utility. ldaho Power has set a goal of achieving a &year ryde of distribution line clearing.
7.3.1. Definitions
Applicable Transmission Lines-Each overhead transmission line operated within the WMP
RRZ at 46 kilovolts (kV) or higher.
Cycle Buster-Trees that grow at a rapid rate, requiring a more frequent trimming schedule than
the normal trim cycle.
HaztrdTrerAny vegetation issue that poses a threat of causing a line outage but has either a
low or medium risk of failure in the next month.Hazardtrees will be further defined as posing
either a medium hazardor low hazard.
High-Priority Tree-Any vegetation condition likely to cause a line outage with a high risk of
failure in the next few days or weeks. High-priority trees could also be vegetation that is in good
condition but has grown so close to the lines that it could be brought into contact with the line
through a combination of conductor sag and/or wind-induced movement in the conductor or the
vegetation.
Line Clearing Cycles-Transmission and Distibution clearing of lines defined on a
periodic basis.
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Wildfire Mitigation Plan 2021 ldaho Power Company
7.3.2. Transmission Vegetation Management
Maintaining azone near transmission lines that is free of vegetation has long been a priority forIdaho Power. The clearance zone is voltage level dependent and defined bylederal and state
regulations.
7.3.2.1. Transmission Vegetation lnspections
Page24
Utility arborists annually conduct aerial and/or ground patrols on each applicable transmissionline to identifu and mitigate vegetation hazards. [n addition, transmission patrol personnel
inspect all applicable transmission lines once a year to identifr any transmissiorrdefects and
vegetation hazards. During these inspections, the patol personnel will identi$r hazardous
vegetation, within or adjacent to the Right of Way (ROW), that could fall in or onto thetransmission lines or associated facilities. The patrol personnel will evaluate the hazardous
vegetation as to the level of threat posed by categorizing the vegetation as a high priority,
medium hazard, ot low hazard. Any hazardous vegetation found is reported to th; utility arboristand documented. Any hazardous vegetation categorized as a high priority andthat presents a riskto cause an outage at any moment shall also be reported without any intentional time delay to theGrid Operator. The utility arborist will conduct a follow-up inspection if potential hazard.trees orgrow-ins are identified. The utility arborist prioritizes and schedules any iemedial action for allreported vegetation issues.
7.3.2.2. Transmission Line Clearing Cycles
Transmission lines will be cleared on long-term cycles based on 3 years for urban and ruralvalley areas and 6 years for mountain areas. However, shorter clearing cycles may occur ifconditions dictate out-of-cycle trimming. ln most cases, vegetation is cleared primarily through
manual cutting of targeted trees and tall shrubs. However, when appropriate and in compliance
and permission with federal and state requirements, tree-growth regulators and spot herbicide
treatrnents are applied as effective techniques for reducing re-growth of sprouting deciduous
shrubs and trees and extending maintenance cycles.
7.3.2.3. Transmission Line clearing euatity Gontrol and Assurance
When line clearing work is required either a utility arborist or a contracted notifier completesfield inspections to make sure the clearing work meets requirements. A line clearing audit formis completed and retained.
7.3.3. Distribution Vegetation Management
Subject to regulatory approval, Idaho Power will strive to clear distribution lines throughout
Idaho Power's service territory on a 3-year cycle.l0In the RRZs and yRZs, Idaho power willcomplete annual vegetation line inspections, complete mid-cycle clearing of the lines in the
l0 Srhject to regulatory approval, Idaho Power proposes testing the 3-year cycle for a period of4 or 5 years toveri$, that such a cycle can be maintained and that the expected benefits ne realized,.
ldaho Power ComPanY Wildfi re Mitigation Plan 2021
second year, increase the number of trees removed, and complete 100% quality control reviews
of contractor line clearing work by certified arborists.
7.3.3.L Distribution Line Clearing Gycles
Idaho Power will strive to clear distribution lines on ayear cycle' In RRZs and YRZs,
Idaho power's goal is to perform mid-cycle pruning in the second year to remove faster growing
vegetation to ensure the lines are clear of vegetation for the full pruning cycle. In addition,
Idaho power clears lines based upon'ospecial request" in the situations that fast growing,
unexpected growth occurs and is reported by any employee or customer.
7 .3.3.2. Distri b utio n Ve getatio n I ns pections
In addition to regular cycle pruning activities, utility arborists will annually conduct ground
patrols to identifu potential ,.grtuiion hazards of each distribution line identified in the RRZs
and yRZs. In addition, distribition paffol personnel also inspect the lines in the RRZs annually.
During these inspections, the patrol personnel will identiff infrastructure defects and hazardous
vegeta:tion, within or adjacenfto the ROWs, that could fall in or onto the distribution lines or
associated facilities. The patrol personnel will evaluate the hazardous vegetation as to the level
of threat posed by categorizing ihe vegetation as ahigh priority, medium hazard, or low hazard'
Any hazardous vegetation found is reported to the utility arborist and documented.
Any hazardous vegetation categorized as a high priority and that presents a risk to cause an
outage at any moment shall also be reported without any intentional time delay to the Grid
Opeiator. The utility arborist will con-duct a follow-up inspection if potential hazald trees or
grow-ins are identified. The utility arborist prioritizes and schedules any remedial action for all
reported vegetation issues.
7.3.3.3. Distribution Line Clearing Procedures
In most cases, vegetation is cleared as scheduled work and includes, but is not limited to, the
removal of dead branches overhanging power lines, weak branch attachments, damaged root
base or dead or dying trees leaning to**a Idaho Power facilities. Vegetation clearing methods
include crews using ihain .u*. oi.p"cializedpruning machines. Trees are cleared using a
pruning procedureialled directiorrui ot natural pruning, a method recommended by the
^tot..nutioral society of Arboriculture, and the ANSI 4300 standards.
However, when appropriate and in compliance and permission with federal and state
requirements, tree-growth regulators an-d spot herbicide treatments are applied as effective
tec'hniques for reducing re-growth of sprouting deciduous shrubs and trees and extending
maintenance cycles.
Through its vegetation management program, Idaho Power intends to maintain clearance
distance between vegetation and conductors as follows:
o Five feet for conductors energized at 600 through 50,000 volts.
o Clearances may be reduced to 3 feet if the vegetation is not considered to be readily
climbable because the lowest branch is greater than 8 feet above ground level'
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Wildfi re Mitigation Plan 2021 ldaho Power Company
New tree growth that is no larger than% inch in diameter may intrude into this minimum
clearance area provided it does not come closer than 6 inches to the conductor. This new
growth will be identified during line patrols and removed.
a For conductors energized below 600 volts, vegetation will be pruned to prevent the
vegetation from causing unreasonable strain on electric conductors.
7.3.3.4. Distribution Line Clearing Quality Control and Assurance
When line clearing work is required, either a utility arborist or a contracted notifier completes
field inspections to make sure the clearing work meets requirements. A line clearing audit form
is completed and retained.
7.3.4. Pole Cleartng of Vegetation
Idaho Power has historically cleared vegetation from the base of certain transmission wood poles
and a limited number of distribution wood poles. This clearing of vegetation has been found to
be a very effective method of minimizing wildfue damage to existing wood poles.
Where acceptable and permissible, vegetation is removed (i.e., cleared) in a 2O-foot radius
surrounding the wood poles and the application of a lO-year weed-control ground sterilant
(SpraKil SK-26 Granular) is applied. However, some property managers (e.g., Bureau of Land
Management in the State of Oregon) where Idaho Power facilities exist do not allow the
application of this sterilant. This program will be implemented in certain situations in the RRZs
and YRZs (e.g., capacitor bank poles).
Page 26
8. WrtoFtRE Resporuse
8.1. Overview
Idaho Power responds to wildfire events that have resulted in an outage and, depending upon the
situation, to wildfire events that potentially may result in an outage. The response, as used in this
wildfire context, refers to Idaho Power's actions in:
o Responding to active flue situations and taking appropriate steps, where safe to do so,
to protect Idaho Power-owned facilities from experiencing fire damage
o Restoring electrical service following wildfire caused outages
o Communicating and informing customers
These actions are taken on a 24-hour basis.
8.2. Response to Active Wildfires
Idaho Power field crews are trained to respond to active wildfire scenes with the intent to
monitor the situation regarding Idaho Power's facilities. The employees are not professionally
trained firefighters and have been instructed not to place themselves in any hazardous situation
with respect to any fire situation. When responding to any active fire situation, Idaho Power
personnel immediately report to, and take appropriate direction from, the Incident Commander
(IC) or the oflicial jurisdictional fire response entity. However, when reasonable, responding
field crews have the capability to extinguish small fires.
8.3. Restoration of Electrical Service
Idaho Power personnel provide restoration of electrical service whenever it is safe to do so.
Trained field crews report to the outage areas and patrol and assess the situation. Field crews
with appropriate equipment and materials remove damaged facilities and repair or rebuild
the lines.
8.4. Emergency Line Patrols
At certain times, unplanned de-energization of lines requires qualified line personnel to conduct
"emergency" patrols (inspections) of the de-energized lines. These patrols identiff outage
causes, damaged facilities, ingress/egress routes, and requirements for restoration (number of
crews, crew sizes, and necessary materials).
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ldaho Power Company Wildfire Mitigation Plan 2021
Wildfi re Mitigation Plan 2021 ldaho Power Company
8.5. Construction Activities
Idaho Power personnel provide restoration of electrical service whenever it is safe to do so.Trained field crews report to the site where damage has occurred with equipment and new
materials and develop a plan to remove and rebuild damaged facilities. Iiepending upon thesituation, contacted field crews-such as line crews and vegetatiorrn*ug"-".rt-"r"*r-
are also deployed to assist in restoration efforts. Restoration work may tak; hours or, in some
rare cases, days to complete. Depending on the extent of damage, customers may need toperform repairs on their facilities and pass inspections by local agencies prior to having fullelectric service restored.
Due to the unique construction, need for specialized equipment, and-in many cases-remote location of many of Idaho Power's transmission lines, a Transmission Emergency
Response Planhas been developed. This plan includes restoration process information rlhtirrg toall transmission voltage classes from 46 through 500 kV. The plan outlines the basic approach
and certain details about notification, materials, damage assessment, coordination,
and preparedness.
8.5.1 . Mutual Assisfance
Idaho Power is a member of the Western Region Mutual Assistance Agreement (WRMAA).
The great majority of western United States electric utilities are memblrs of this group.
As members, utilities.will provide emergency repair and restoration assistance to-a peer memberthat requests such assistance when their electric facilities are damaged by a significant event. lnthe event of a catastrophic wildfire that causes widespread damagelo taano power's system, it isan option for Idaho Power to request restoration assistance via thi WRMAA. This is alast resortoption after utilizing all available internal and contracted personnel.
8.6. Public Outreach and Communications
Idaho Power maintains an Emergency Response Communication Plan. The intent of thiscommunication plan is to provide consistent and reliable intemal and external communication inlarge outage or emergency situations that have wide-ranging impacts on Idaho power's service
areas. Procedures for internal and external communications driven by a wildfire situation will bein accordance with this plan. The plan is reviewed and updated uorrrutty by ldaho power,s
Corporate Communications Department.
Page 28
ldaho Power CompanY Wildfi re Mitigation Plan 2021
9. CoUMUNIcATING THE Plltt
9.1. Objective
Idaho power intends to communicate about this wMP internally to employees and extemally to
the public. The company will provide related fact sheets and maps depicting areas of elevated
wildfire risk. Additionuily, the company will provide online resources, which will include the
following information specific to Idaho Power's WMP:
o Demonstrate Idaho Power's focus on the integrity and reliability of its systems and their
impacts on the Public
o Ensure the confidence of the IPUC and the OPUC that Idaho Power is proactively and
responsibly addressing wildfire risk
o lnform and collaborate with federal, state, and local government and agencies
Inform Idaho Power customers
lnform and guide Idaho Power employee and contractor behaviors
9.2. ldaho Power External Communications
9.2.1. Regulatory Entities
Idaho power will frle its WMp with both the IPUC and the OPUC. ln addition, Idaho Power will
continue to inform and discuss the WMP with the IPUC and OPUC. Idaho Power provided an
overview of its Wildfrre Mitigation Plan to the IPUC in 2019. Idaho Power has also been a
participating member with other investor owned utilities and the OPUC in the Oregon Wildfre
and Elictric Collaborative (OWEC) workshops and Wildfire Mitigation Rulemaking Docket
AR 638.
9.2.2. Government Agencfes
Idaho power intends to present and distribute information regarding its WMP to a wide variety
of stakeholders (e.g., thi Bureau of Land Management (BLM), U.S. Forest Service, county and
city officials). presentations will be tailored to the specific audiences and their areas of interest.
a
a
Idaho power has worked with the BLM in a collaborative manner (e.g., extend a firebreak along
Hwy 93 in Jerome County). The company also worked collaboratively with the Boise City Fire
Deparhnent in development of certain portions of the Boise City Fire Code{43019.
Page 29
Wildfi re Mitigation Plan 2021 ldaho Power Company
9.2.3. ldaho Power Customers
Safety is Idaho Power's most important value. Attention to the detail of safe operations
permeates our workplace and interactions with customers. This standard is applied to protecting
Idaho Power's equipment from wildfire, reducing the likelihood of wildfir. *d informing the -
public about the likelihood of wildfire and ways customers should respond.
Idaho Power will distribute information regarding its WMP to its customers via the
following tools:
o Fact sheets
o Mass media articles/video
o Community and/or individual presentations/discussion
o Social media
o Idaho Power online website
o CustomeremaiVmailings
9.2.3.1 Prior to Wildfire Season
Idaho Power will communicate to customers and the public what steps the company is taking,
such as vegetation management and equipment maintenance, to reduce the likeliho-oa ofwildfires. Various communication mediums include:
o Connections (This monthly newsletter is an effective way to give customers nuanced
information about the work Idaho Power does, but its planning and development takes
months, so it is not an effective way to communicate urgent information.)
o eNews (video stories about a variety of topics, such as vegetation management)
o Emails
o Social media
o Posts on Facebook, Instagram, Twitter and other platforms are an efficient way to
reach large numbers of customers and the public. They are less intrusive than
newsletters or phone calls.
Idaho Power will also monitor long-term weather forecasts and fuel conditions and communicate
to customers and the public our assessment of the likelihood of wildfires.
Again, various communication mediums are:
o Connections
Page 30
Emails telling customers how to prepare for wildfires, the potential loss of power and
potential evacuation.
Social media
News media (news releases, appearances on broadcast TV and radio shows,
interviews, etc.)
a Idaho Power website
9.2.3.2 During Wildfire Season
Idaho power will monitor weather forecasts and fuel conditions near Idaho Power equipment and
communicate to customers and the public plans for reducing wildfire risk and protecting
company equipment should a wildfire occur. Various communication mediums include:
o Emails (If the likelihood of wildfire is elevated, these messages would take on greater
*g"n y, though they would contain much of the same information as pre-wildfire season
messages.)
o Social media (this is the quickest way to spread word of safety concerns, potential loss of
power, evacuations, etc. ihis communication likely would contain up-to-date information
f.orn o.g*izations like National Interagency Fire Center, USFS, BLM.)
o News media
. Idaho Power website
o Phone calls and text messages to customers
9.2.3.3 After Wildfire Season
Idaho Power will communicate to customers and the public the scope of wildfires that
approached Idaho Power equipment, how Idaho Power communicated safety messages to
.*to-"r, and the public, ,.r"ur*"r Idaho Power took to keep power lines safe, and the status of
any ongoing r""o.rery measures, such as replacement of poles,lines, and other equipment.
Various communications mediums include:
Connections
eNews
Social media
News media
a Idaho Power website
a
a
a
a
a
a
a
ldaho Power ComPanY Wildfi re Mitigation Plan 2021
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Wildfire Mitigation Plan 2021 ldaho Power Company
9.3. ldaho Power lnternal Communications-Employees
Idaho Power communicates with its employees in a variety of ways:
o Netvs Scans for all employees
. Leadercommunications
o GlS-based visual communication of risk zones and affected overhead lines
o Online taining for employees influenced by the WMP
o In-person, hands-on, training for certain field employees
Page 32
10. PenFoRMANce MouroRlNG AND Mernlcs
10.1. Wildfire Mitigation Plan Gompliance
The Chief Operating Officer (COO) is the designated oversight officer for the Idaho Power
WMP. The Vice President of Planning, Engineering and Construction (VP) is responsible for
compliance monitoring, necessary training, and annual review of this WMP.
10.2.lnternal Audit
Idaho Power's internal audit department, Audit Services, provides an independent and objective
assurance and consulting function that reviews corporate activities and furnishes management
and the Audit Committee with evaluations and recommendations. As determined through its
annual risk assessment process, Audit Services will periodically review the WMP and provide
reasonable assurance regarding the achievement of the Plan's objectives and adherence to
policies and procedures. Further, Idaho Power's Compliance department will perform periodic
reviews of Idaho Power's compliance with federal reliability standards as they pertain to
vegetation management.
10.3. Annual Review
Each year the WMP will be reviewed, updated, and approved prior to start of the fire season.
10.4. Wildfire Risk Map
The Wildfire Risk Map was established in 2020 by an external consultant. As noted in Section 2
of this report, the 2020 analysis was based, in part, on population census data from 201 0.
The national census is being conducted again in 2020. Therefore, to improve the Wildfire Risk
Map information, Idaho Power will update the map after the information is available.
Thereafter, Idaho Power will update the map periodically.
1 0.5. Situational Awareness
The Fire Potential Index will be shared regularly and broadly with Idaho Power personnel during
the fire season to help ensure employees and contractors are alerted to operating requirements in-
effect.
10.6. Wildfire Mitigation-Field Personnel Practices
Idaho Power crews and certain personnel are required to follow the Field Personnel Practices
when working on lines in the Red and Yellow Risk Zones at times of red Fire Potential Index.
The Field Personnel Practices document should be consulted for information regarding the
specific requirements.
Page 33
ldaho Power Company Wildfire Mitigation Plan 2021
10.7, Wi ldfi re M itigation-Operations
Each year in preparation for the fire season Idaho Power reviews and establishes:
o Temporary operating procedures for tansmission lines during the fire season
An operational strategy for distribution lines during time periods of elevated wildfire risk
during the fire season
Ongoing evaluation of the use PSPS and whether it continues to be a reasonable wildfire
mitigation tool for Idaho Power
1 0.8. Wildfire Mitigation-T&D Programs
This section lists metrics used to evaluate Idaho Power's asset management and vegetation
management programs. Work is identified and prioritized eachyear and approved by executive
management. Idaho Power's goal is to complete 100% of the work plan each year; however,
emergencies or other unplanned events can occur and disrupt the annual work plan. All work is
completed in accordance with safety and applicable requirements and industry standards.
Table 5
T&D programs metrics
a
o
Transmission Asset Management Programs
Aerial Visual lnspection Program
Ground Visual lnspection Program
Detailed Visual (High Resolution Photography) lnspection Program
Wood Pole lnspection and Treatment Program
Cathodic Protection and lnspection Program
Wood Pole Wildfire Protection Program
Description
Perform annual patrols and document identified defects
according to priority. Complete repairs according to priority
definition.
Perform annual patrols and document identified defects
according to priority. Complete repairs according to priority
definition.
Perform 10-year cycle patrols and document identified defects
according to priority. Complete repairs according to priority
definition.
Perform l0-year cycle patrols and document identified defects
according to priority. Complete repairs according to priority
defnition.
Perform 1O-year structure-to-soil potential testing on select
towers with direct-buried anodes. Perform 10-year rectifier andground-bed testing on ICCP systems. Annually inspect and
record DC voltage and cunent readings of rectifiers. Complete
repairs and adjustments.
lnspect and install wraps on selected poles.
Wildfire Mitigation Plan 2021 ldaho Power Company
anagement Programs
Wood Pole lnspection and Treatment Program
Line Equipment lnspection Program
Ground Detailed lnspection Program
Distribution lnfrastructure Hardening Program
Description
Perform 1O-year cycle patrols and document identified defects
according to priority. Complete repairs according to priority
definition.
Complete annual inspections and data analysis and mitigate
defects
Perform annual patrols and document identified defects
according to priority. Complete repairs according to priority
definition.
Complete annual work plan
Page 34
Replace'small conductor'' wilh new 4acsr or larger conductor
Replace or repair damaged conductor
Re-tension loose conductors including 'flying taps" and slack
spans as required
Replace wood-stubbed poles with new wood poles
Replace white and yellow square tagged poles with new wood
poles
Replace wood pins/wood crossarm with new steel pins/fiberglass
crossarms
Replace steel insulator brackeG with new steel pinslfiberglass
crossarms
Replace wedge deadends on primary taps with new polymer
deadend strain insulators
Replace aluminum deadend strain insulators with new polymer
deadend strain insulators
Replace porcelain switches with new polymer switches
Replace hot line clamps
Replace aluminum stirrups
lnstall avian cover
Relocate anesters
lnstall bird/animal guarding
Update capacitor banks
Replace swelling capacitors
Replace oil-filled switches with vacuum style
Replace porcelain switches with polymer switches
Replace certain expulsion anestors
lnstall disconnect switches on CSP transformers
lnstall avian cover
Update down guys
Replace/lnstall downguy insulators with fi berglass insulators
Tighten down guys
Tighten hardware
Conect 3rd party pole attachment violations (report to Joint Use
Department)
Replace certain expulsion fuses
ldaho Power Company Wildfi re Mitigation Plan 2021
Pre-Fire Season lnspection and Mitigation
Line Clearing Cycles: Strive to maintain &year cycle for valley
areas & 6-year cycle for mountain areas
Tree Removals - Hazard Trees
Targeted Pole Clearing
100% QA/QC Audits in RRZs and YRZs
Distribution
Pre-Fire Season lnspection and Mitigation
Line Clearing Cycle: Strive to maintain 3-year cycle
Mid-Cycle Pruning in RRZs and YRZs
Tree Removals - Cycle Busters/Hazard Trees
Targeted Pole Clearing
100% OI/QC Audits in RRZs and YRZs
Descriptlon
Perform annual pre-fire season inspections and mitigate noted
'hot spots'
Complete annual cycle pruning work plan
Remove targeted hazard trees
Complete annually targeted structtlres
Complete annually QA/QC audits
Description
Perform annual pre-fire season inspections in RRZS and YRZS
and mitigate noted "hot sPots"
Complete annual cycle pruning work plan
Complete annual mid-cycle pruning work plan in RRZs and YRZs
Complete annual cycle pruning work plan
Complete annually targeted structures
Complete annually QA/QC audits
Page 35
ldaho Power Company The Wildland Fire Preparedness and Prevention Plan
AppendixA
The Wildland Fire Preparedness and Prevention Plan
Appendices
The Wildland Fire Preparedness and Prevention Plan ldaho Power Company
<IHm*
An IOACORP Company
Wildland Fire
Preparedness and
Prevention Plan
Appendices
ldaho Power Company The Wildland Fire Preparedness and Prevention Plan
TnaLE OF CONTENTS
l. Plan Overview
A. Intent of Plan
B. Scope Plan
2. Situational Overview and Applicability
A. Wildfire Season
B. Wildfire Risk Zones
C. Fire Potential Index
D. Decision Making for Field Work Activities
3. Preparedness-Tools and Equipment
A. Required Personal Protective Equipment
B. Required Tools and Equipment
C. Land Management Agency Restrictions and Waivers
4. Prevention-Practices of Field Personnel
A. General Employee Practices
B. Practices Relating to Vehicles and Combustion Engine Power Tools
5. Reporting
A. Fire Ignition
B. Fire Reporting
6. Training
7. Roles and Responsibilities
8. Audit
Appendices
1. Plan Overview
A. Intent of Plan
The purpose of this Wildland Fire Preparedness and Prevention Plan (Plan) is to provide
guidance to Idaho Power Company (IPC) employees to help prevent the accidental ignition and
spread of wildland fues (wildfires) due to employee work activities in locations and under
conditions where wildfire risk is heightened. It is expected that all IPC employees be aware of
the provisions of this Plan, operate in accordance with the Plan and conduit themselves in a
fue-safe manner.
B. Scope of Plan
The scope of this Plan includes tools, equipment, and field behaviors IpC employees should
incorporate when working in locations and under conditions where wildfire igniiion
is heightened.
Operations of Transmission and Distribution (T&D) lines facilities, vegetation management, andT&D lines progfttms that mitigate wildfire risks are not included in thiJ plan; they are referenced
in the separate Wildfire Mitigation Plan.
2. Situational Overview and Applicability
A. Wildfire Season
The provisions of this Plan shall be applicable during wildfue season. Within IpC's service area,wildfire season is defined as the closed fire season of May l0 through October 20 of each yatr,
as established by Idaho State Law, Title 38-l15.
Should any local, state, or federal government land management agency (i.e., the Bureau of Land
Management [BLM], U.S. Forest Service, Oregon Department of Foresty, Idaho Department of
Lands, etc.) issue any wildfire related order that extends wildfire season beyond that specified
above, then compliance with that agency's order shall govern.
Many variables-such as drought conditions, weather, and fuel moisture-<an cause the wildfire
season to begin and./or end earlier or later. In summary, flexibility, judgment, attention to current
and forecasted field conditions, and attention to governmental agency issued wildfire orders arenecessary such that operational practices can be adjusted accordingly.
B. Wildfire Risk Zones
IPC's Wildfire Mitigation Plan includes a Wildflre Risk Map of IPC's service area.
This Wildfire Risk Map may be accessed at the Idaho Power SharePoint site. All lands in thevicinity of IPC facilities are mapped as Red Zone, Yellow Zone or areas of minimal wildfire risk
(i.e., not within a Red or Yellow Zone). Red and Yellow Zones are designated as Wildfire Risk
Appendices
The Wildland Fire Preparedness and Prevention plan ldaho Power Company
ldaho Power ComPanY The Wildland Fire PreParedness and Prevention Plan
Zones (WRZ). The provisions of this Plan shall apply to work activities taking place during
wildfire season in these WRZs.
Should any local, state, or federal government land management agency (i'e', BLM, U'S' Forest
Service, Oregon Department of Foiestry, Idaho Department of Lands, etc.) issue any wildfire
related order, then compliance with that agency's order shall govern if their order is more
restrictive than that set forth in this Plan.
C. Fire Potential lrdex
Idaho power's Atmospheric Sciences department has developed a Fire Potential Index (FPI)
rating system that forecasts wildfire potantial across [PC's service territory. The FPI considers
man; current and forecasted elements such as meteorological (winds-surface and aloft,
temperatures, relative humidity, precipitation, etc.) and fuel state (both live and dgad). The FPI is
designed and calibrated for IPa'i service area; specifically, those areas in proximity to IPC
transmission, distribution, and generation facilities.
The FpI consists of a numerical score ranging from 1 (very green, wet fuels with low to no wind
and high humidity) to 16 (very brown and dry, both live and dead dry fuels with low humidity
ana higfr temperatures). The FPI scores are grouped into the following 3 index levels:
. I: FPI score of 1 through 11
o Yellow: FPI score of 12 throughl4
. I, FPI score of 15 through 16
The FpI is updated daily during wildfire season and will provide information for the next 5 to 7
days via u *ildfrr" *ruth". foricast and FPI dashboard. This weather forecast and FPI dashboard
is Lontained within the IPC Enviro Viewer that is available to all IPC employees.
A conceptual depiction of how this FPI dashboard will look is shown below'
Appendices
RH(96'
Wind (mph!
wind (mphl
Preclpltation (in)
Cover (96 coverage)
((n{rr)
Min Temp (0
72
70
35
5
8
0
zo
13
75
31
6
8
0
20
N
13
75
31
5
8
0
10
N
t4
76
25
5
7
0
10
N
t4
77
24
5
5
0
20
N
13
75
31
6
8
0
85
FPr (0G12Ll
Min Temp (0
RH (96I
wind (mph|
wlnd (mphl
Preclpltation (lnl
Cover (96 coveraget
t2
70
36
5
8
0
20
N
13
75
31
5
8
0
20
N
13
75
31
5
8
0
10
N
14
76
25
5
7
0
15
N
74
77
24
5
5
0
20
N
13
75
31
5
8
0
10
RH (%)
wind (mph!
wlnd (mphl
Precipitation (in)
Cover (% covorage,
FPr (12-18t 1
Temp (fl
13
101
13
8
10
0
10
13
103
11
9
11
0
10
N
14
105
10
8
10
0
10
N
L4
105
9
8
10
0
20
YN
RH (%l
wind (mphl
wind (mphl
Precipitation (inl
Cloud Cover (% coveragel
(1&2.r)
Temp (0
13
101
13
8
10
0
10
13
103
11
9
11
0
10
N
74
105
10
8
10
0
10
N
L4
105
9
8
10
0
25
N
D. Decision Making for Field Work Activities
Employees working in the field shall be cognizant of current and forecasted weather and fieldconditions. Awareness of these conditions, and exercising appropriate judgment, is essentialwhen considering whether to undertake work activities when combinaiioni of high temperatures,low humidity, dry fuels, and/or wind are present or forecasted to be present.
The following process steps shall apply to employees and crews contemplating field work duringwildfire season:
Planned or Scheduled Work Activities:
l. Fire Potential Indices:
a) Employees working in the field-Nor working on transmission orprimary
distribution lines should:
i. Be aware of the current and forecasted weather and the FpI level for the
area in which the work will be performed, through the FpI dashboard.
The Wildland Fire Preparedness and prevention plan ldaho Power Company
Appendices
ii. Once the FPI level for the work zone is identified, proceed with work but
consider utilizing Prevention-Practices of Field Personnel (see section 4
of this Plan).
b) Employees working in the field-working on transmission or primary distribution
lines should:
Be aware of the current and forecasted weather and the FPI level for the
area in which the work will be performed.
ii. Once the FPI level for the work zone is identified, proceed as follows for
each FPI level:
1. I in Alt Zones: Proceed with the work.
consider utilizing Prevention-Practices of Field Personnel
(see section 4 of this Plan)
2. Yellow FPI in All Zones: Proceed with the work'
Consider utilizing Prevention-Practices of Field Personnel
(see section 4 of this Plan)
3. I
a) In Normal Zonez Proceed with the work'
Consider utilizing Prevention-Practices of Field Personnel
(see section 4 of this Plan)
b) In Medium zonez Proceed with the work. However. it is a
requirement to follow the Prevention-Practices of Field
Personnel (see section 4 ofthis plan)
c)InllighZone..sToP.Noplannedworkactivitiesshall
take place unless approved by operations level manager'
work consideration will be restoration of electric service or
work deemed critical to providing safe, reliable electric
service. If work is approved to proceed it is a requirement
to follow the Prevention-Practices of Field Personnel
(see section 4 of this Plan).
ldaho Power CompanY The Wildland Fire PreParedness and Prevention Plan
Appendices
The Wildland Fire Preparedness and Prevention Plan ldaho Power Company
2. Land Management Agency Restrictions: Follow the requirements and restrictions of any
wildfire restrictions related order that is issued by local, state, or federal land
management agencies.
a) Immediately upon receiving knowledge of an order, The Environmental Services
department will notifr, via email, operations leadership within power Supply,
customer operations and Business Development, and T&D Engineering and
Construction of wildfire related requirements and restrictions orders that are
issued by local, state, or federal land management agencies.
Emereency Response and Outase Restoration Work Activities:
Follow the same steps as identified above for planned work activities. However, it is recognized
that the nature of emergency response and outage restoration situations will often require
exceptions to the above. In these situations, leadership should be consulted, and appropriatejudgment should be used given the nature of the emergency or outage at hand.
Gt!
xo!,tr
t!
Ptro
oo.oL
l!
Proceed with work
Uti I ize Prevention/Practices of
Field Personnel
(Optional)
Proceed with work
Utilize Prevention/Practices of
Field Personnel
Required
STOP / NO WORK
a.E
o9--(Iats
Proceed with work
Uti I ize Prevention/Practices of
Field Personnel
(Optional)
Proceed with work
Uti I ize Preve ntion/Practices of
Field Personnel
(Optional)
Proceed with work
Utilize Prevention/Practices of
Field Personnel
(Optional)
Proceed with work
uti I ize Prevention/Practices of
Field Personnel
(Optional)
Proceed with work
Utilize Prevention/Practices of
Field Personnel
(Optional)
Proceed with work
Util ize Preventi on/Practices of
Field Personnel
(Optional)
None Yellow
Wildfire Risk Zones
Appendices
ldaho Power Company The Wildland Fire PreParedness and Prevention Plan
3. Preparedness-Tools and Equipment
A. Required Personal Protective Equipment
Standard IPC Personal Protective Equipment (PPE) shall be worn in accordance with the IPC
Safety Standard.
When entering a designated fire area being managed by the BLM or the U.S. Forest Service,
additional PPE requirements may be in force by those agencies. These typically include:
o Hardhat with chinstrap
o LonB sleeve flame-resistant (FR) shirt and FR pants
o Leather gloves
o Exterior leather work boots, 8" high, lace-type with Vibram type soles
o Fire shelter
B. Required Tools and EquiPment
Employees NOT working on transmission or distribution lines: Standard tools and equipment in
accordance with the IPC Safety Standard and Fleet Services.
Employees working on transmission or distribution lines: IPC and the State of Idaho BLM
entered into a March 2019 Master Agreement that governs various IPC and BLM interactions,
including wildfire prevention related provisions. In addition to State of Idaho BLM lands, IPC
has elected to apply these requirements to all work activities taking place on all WRZ in Idaho,
Nevada, Montana, and Oregon. These requirements include:
During the wildfire season (May lG{ctober 20) or during any other wildfire season
ordered by a local, state, or federal jurisdiction, IPC, including those working on IPC's
behalf, will equip at least 1 on-site vehicle with firefighting equipment, including, but not
limited to:
a
a) Fire suppression hand tools (i.e. shovels, rakes, Pulaski's, etc.),
b) a l6-20-pound fire extinguisher,
c) a supply of water, sufficient for initial affack, with a mechanism to effectively
spray the water (i.e. backpack pumps, water sprayer, etc.). This requirement to
carry water is dependent on the vehicle type and weight restrictions. For example,
a mini-excavator would not be required to carry water since there is no safe way
to do so, or a loaded bucket truck may not be required to carry water because of
weight limitations.
Appendices
IPC personnel will be trained to use the above tools and equipment to aid in extinguishing a fire
ignition before it gets out of control and take action that a prudent person would take to control
the fire ignition while still accounting for their own personal safety.
C. Land Management Agency Restrictions and Waivers
The Environmental Services deparfrnent will notifu operations leadership within Power Supply,
Customer Operations and Business Development, and T&D Engineering and Construction of anywildfire related requirements and restrictions orders that are issued by local, state, or federal land
management agencies. Typical orders issued each fire season include:
a
O
a
a
At a minimum, equip each truck that will be driven in the WRZs during wildfire season
with at least:
a) One round, pointed shovel at least 8-inches wide, with a handle atleast26
inches long
b) One axe or Pulaski with a 26-nchhandle or longer
c) A combination of shovels, axes, or Pulaskis available to each person on the crewd) One fire extinguisher rated no less than 2A:108V (5 pounds)
e) 30-200 gallons of water in a fire pumper and 5-gallon back packs
BLM. During BLM's stage II Fire Restrictions, IPC's Environmental Services
departrnent will obtain an appropriate waiver. Field personnel shall take appropriate
precautions when conducting work activities that involve an internal combustion engine,
involve generating a flame, involve driving over or parking on dry grass, involve the
possibility of dropping a line to the ground, or involve explosives. Precautions include a
Fire Prevention Watch Person who will remain in the area for t hour following the
cessation of that activity. Also, IPC personnel will not smoke unless within an enclosed
vehicle, building, or designated recreation site or while stopped in an area atleast 3 feet
in diameter that is barren or cleared of all flammable materials. All smoking materials
will be removed from work sites. No smoking materials are to be discarded.
State of Oregon Deparbnent of Forestry (ODF). Prior to each summer fire season,
the ODF issues a o'Fire Season Requirements" document that specifies required tools,
equipment, and work practices. In addition to State of Oregon lands, IPC has elected to
apply these requirements to all work activities taking place on all WRZ, BLM lands,
and Forest Service lands within the State of Oregon. Go to
https://www.oregon.eov/ODF/Fire/Pages/Restrictions.aspx for ODF's Fire Season
Requirements order.
Other sites for reference that contain fire restriction orders include:
o Oregon- Blue Mountain lnteragency Fire Center at httn:/,/hmidc .shtmlo Nevada-Fire Information at https://www.nevadafireinfo.ors/restrictions-and-
closures
o Montana-https://flrerestrict
The Wildland Fire Preparedness and Prevention Plan ldaho Power Company
Appendices
4. Prevention-Practices of Field Personnel
A. General Employee Practices
The below listing includes, but is not limited to, practices and behaviors employees shall
incorporate depending on the FPI and level of WRZs during fire season.
l. Daily tailboards must include discussion around fire mitigation planning. Discussion
topics include, but are not limited to:
a. Items 2 through 7 below
b. Water suppression
c. Hand tools
d. Welding blankets
e. Mowing highbrush areas (weed wacker)
f. Watering down the worksite before setting up equipment
2. Weather conditions and terrain to be worked shall be considered and evaluated. Items to
be considered include, but are not limited to:
a. Identiff the FPI for the area being worked (see Section 3.C)
b. Monitor weather forecasts and wind and humidity conditions
c. Identiff surroundings. i.e., wildland-urban interface, BLM lands, Forest Service
lands, proximity to any homes and structures, etc.
d. Identifr local fire departments and locations
e. Evaluate the terrain you are working in (steep or flat)
f. Consider whether the work will occur during the day or at night
3. Work procedures and tools that have potential to cause a spark or flash shall be
considered and evaluated. Items to be considered include, but are not limited to:
a. Performing energized work
b. Grinding or welding
c. Trees contacting electrical conductors
d. Hot saws
e. Chainsaws
f. Weed wackers
g. Sawzalls
4. Monitoring the worksite throughout the project.
It is imperative that all crews and equipment working in the WRZs areas are continuously
monitoring and thoroughly inspecting the worksite throughout the project. This includes
prior to leaving the work area for the night or before moving on to the next structure.
Appendices
ldaho Power Company The Wildland Fire Preparedness and Prevention Plan
The Wildland Fire Preparedness and Prevention Plan ldaho Power Company
5. Employee cooking stoves.
When working in remote locations, often employees bring food that needs to be cooked.
Open flames should not be allowed. Cook stoves may be permitted by leadership but
special precautions must be followed to use:
a. The stove or grill must be in good repair and of sturdy construction
b. Stoves must be kept clean, grease build up is not allowed
c. Fueling of the stove must follow the fueling procedures when liquid fuels are usedd. Cooking must be in areas free of combustible materials
6. Smoking on the job site.
Carelessly discarded smoking materials can result in wildfire ignition. The following
practices shall be followed:
a. Do not discard any tobacco products from a moving vehicle.
b. Smoking while standing in or walking through forests or other outdoor areas
when IPC's FPI rating is above a Green level is prohibited.
c. All employees must smoke only in designated areas and smoking materials must
be disposed of in half filled water bottles or coffee containers half filled with
sand. Smoking materials shall not be discarded on any site.
7. Post job site inspection.
Final inspection orpost-checking the work site for any ignition hazards that may remain
is essential to the proper completion of the work and true mitigation of the hazards.
Post-checking the work will help ensure the hazards were mitigated and provide a final
chance to see if any new hazards or hot spots exist before leaving the work site.
B. Behaviors Relating to Vehicles and Combustion Engine Power Tools
It is important to consider work procedures, equipment conditions, employee actions, potential
causes, and other sources that could lead to fire ignition. Some work practices may be performed
on roadways that have little to no risk of fire ignition. Leadership should consider scheduling off-
road equipment use during times of green fire risk. Employees should also consider alternative
tools, work methods or enhanced suppression tools to reduce the risk or spread of fire.
l. Additional heat may bring vegetative materials to an easier point of ignition.
This includes, but is not limited to, the following vehicles:
a. Pickups, crew cabs, line-beds, buckets trucks (large and small), backhoes,
excavators and rope trucks, and any other motorized equipment.
2. Vehicle Procedures:
a. Inspect all engine exhaust, spark arresters and electrical systems of vehicles used
off road, daily for debris, holes or exposed hot components and to ensure that heat
shields and protective components are in place.
Appendices
b. Conduct inspections of the vehicle undercarriage before entering or exiting the
project area to clear vegetation that may have accumulated near the vehicle's
exhaust system.
c. Vehicles shall be parked overnight in areas free from flammable vegetation at a
minimum distance of 10 feet.
d. Vehicles and equipment will not be stationary or in use in areas where grass,
weeds or other flammable vegetation will be in contact with the exhaust system.
e. If there is no other workable option for the location that doesn't include weeds,
grass or other flammable vegetation, the vegetation and debris will need to
be removed.
f. Consider using a fire-resistant material such as a welding blanket to cover
flammable material to act as a heat shield; fire blankets may be a suitable option
to avoid removal of vegetation.
3. Hot brakes on vehicles and equipment:
a. Park vehicles in areas free of combustible materials.
b. Hot brake emergency parking, during times of yellow or red FPI shall be cleared
of combustible materials for a distance of at least 10 feet from the heat source.
4. Fueling procedures:
a. Tools or equipment should NOT be fueled while running.
b. Cool down period must be given to allow equipment time to no longer be
considered a fire risk.
c. Allow for a ten-foot radius from all ignition sources.
d. Any combustible debris should be cleared from the immediate area.
e. Never smoke while fueling.
f. Designate fueling areas for all gas-powered tools.
5. Combustion engine power tools:
Poorly maintained or missing spark arrester screens may allow sparks to escape and
causeignition of vegetation. Ensure proper spark arrester screens are in place for the
following tools:
a. Generators
b. Pony motors
c. Pumps
d. Chain saws
e. Hot saws
f. Weed eaters
g. Brush hog
Inspect spark arresters daily; clean or replace when clogged, damaged or missing or
remove from service until repaired.
ldaho Power Company The Wildland Fire Prepared ness and Prevention Plan
Appendices
The Wildland Fire Preparedness and Prevention Plan ldaho Power Company
5. Reporting
A. Fire Ignition
All fire ignitions shall be immediately reported to regional or system dispatch. Dispatch will
notiff local fire authorities. All work shall immediately stop and necessary steps taken to
extinguish the fire with available tools, water, and equipment. If the fire gets too large to safely
contain or extinguish, ensure all employees are accounted for and get to a safe location.
B. Fire Reporting
When reporting a fire ignition to regional or system dispatch provide the following information:1. Yourname
2. Location-reference points including an address, road or street name, cross streets,
mountain range, GPS coordinates, as applicable
3. Fire information
4. Size and behavior of the fire
5. Weather conditions
6. Training
Each employee who performs work in wildland fire designated zones shall be trained on the
content of this document and be required to complete annual refresher courses through the
Learning Management System (LMS). Employees are required to complete fire extinguisher and
fire shelter training annually as part of the lineman safety compliance. Documentation of all
training shall be retained in the LMS.
Appendices
ldaho Power Company The Wildland Fire Preparedness and Prevention Plan
7. Roles and Responsibilities
!ndividual
Crew Foreman and
Front-Line Leaders
Manager (Regional
Operations Manager, Area
Manager, T&D
Construction Manager)
Roles and Responsibilities
Be familiar with the requirements specified in this Plan and operate tn
accordance with this Plan.2. Be aware of daily weather forecast and FPI level.
3. Be aware of whether field work will be performed in a WMZ.
1. Establish expectations to direct report employees they are to be familiar
with, and follow, Plan requirements.2. Ensure the crew or team conducts field operations in accordance with this
Plan.3. Be aware of daily weather forecast and FPI level (by viewing the FPI
dashboard or by calling into dispatch or a leader):a) Ensure employees are aware of the FPI level.b) Ensure work practices comply with this Wildland Fire Preparedness
and Prevention Plan when the FPI is "Red" and the Vl/tt4Z is Yellow.
c) Ensure no work takes place when FPI is "Red" and the WMZ is Red.
Any exceptions to be discussed with manager.4. Ensure annual training of employees is completed prior to wildfire season.
5. Ensure required tools and equipment are in place prior to wildfire season.
1. Establish expectations to Crew Foremen and Front-Line Leaders they are
to operate in accordance with Plan requirements.2. Support Crew Foremen and Front-Line Leaders in scheduling training and
making required tools and equipment available.3. View daily weather forecast and FPI dashboard:
a) Authorize any exceptions to working when FPI is "Red" and the WRZ
is Red.b) Ensure specified audits are timely completed.
Meteorology Department
Environmental Services
Department
Operations Procurement
Department
Vice-President of Planning,
Engineering and
1 Provide daily weather forecast and update the FPI dashboard contained
within the IPC Enviro Viewer.
1. Monitor local, state, and federal land management agencies for any wildfire
restriction orders that are issued.2. Communicate content of any orders issues to Power Supply, COBD' and
PEC operations leadershiP.
1. Ensure contractors have a copy of this Plan and that contractual
requirements are in place to ensure adherence to the Plan.
1. Ensure annual reviedupdate of this Plan is conducted following the
completion of each wildfire season.
of
8. Audit
Prior to the start of wildfire season (May 10), all vehicles will be audited by leadership to ensure
that those working in WRZs are properly equipped with hrefighting equipment. The following
checklist must be completed, dated, and signed by a member of leadership (front-line supervisor
or above) and kept with the crew or individual until fire season has ended (Oct 20). A copy of
each audit checklist shall be sent to the respective managff and senior manager.
Appendices
Wildland Fire Preparedness Audit Checklist:
Inspector:
Signature:
Date:
Crew:
Crew:
At least 1 vehicle will be equipped with the following:
Fire suppression hand tools (shovels, Pulaski, axes, etc.) for each member of the crew
A lG2O-pound fire extinguisher (2-10-pound fire extinguishers)
A supply of water, sufficient for initial attack, with an effective spraying mechanism
(i.e., backpack pumps, water sprayer, etc.)
3f75-gallon mechanical fire pumper
Individual Truck:
One round, pointed shovel at least 8-inches wide, with a handle at least 26 inches long
One axe or Pulaski with a 26-inchhandle or longer
A combination of shovels, axes, or Pulaskis to each person on the crew
One fre extinguisher rated no less than 24:l0BV (5 pounds)
30-200 gallons of water in a fre pumper and 5-gallon back packs
Personal protective equipment (PPE) IPC and BLM standards: Each employee will be
required to have the following PPE:
- Hard hat with a chin strap
- Safety glasses
- Hearing protection
- Long sleeve FR shirt FR pants
- Leather gloves
- Exterior leather work boots 8" high lace type with Vibram type soles- Fire shelter
Appendices
The Wildland Fire Preparedness and Prevention Plan ldaho Power Company
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Greg Miller
6 MARSH Marsh USA lnc.
1301 Fifth Avenue
Suite 1900
Seattle, WA 98101
+1 2ffi 214 3073
[e-mail]
www.marsh.com
Jeff Pleimann
lnsurance & Risk Administrator
ldaho Power
1221West ldaho St.
Boise, lD 83702
December 21st,2020
Subject: Wildfire / Excess Liability and Property premiums
Dear Jeff,
This letter summarizes information regarding insurance premiums paid by ldaho power for coverage
for liability related to wildfire currently, as well as information on what ldaho Power should expect 6pay in the future assuming maintenance of existing levels of coverage.
ALLOCATION OF CURRENT PREMIUMS TO WILDFIRES
Coverage for ldaho Power's liability for wildfire is provided within your excess liability insurance tower,with three separate insurers. Generally, insurers are reluctant to attribute how much of a policy is
related to a specific risk. With regard to wildfire risk, however, it is understood that a significani portion
of ldaho Power's excess liability policies are related to wildfires. Additionally, the latesGxcess liabilitypolicy was purchased expressly to cover ldaho Power's exposure to wildfire-related risk. As a result,the full premium in this layer is due to wildfire liability risk, since ldaho Power would not havepurchased this layer but for the desire for additional protection for wildfire-related risk.
FUTURE PREMIUM INCREASE EXPECTATTONS
The mutual insurance company that provides ldaho Power's primary excess liability policy, has
advised all policyholders that they should expect excess liability premiums for 2021to increase, on
average, at least 15% over 2020 levels. ln addition, they have advised that utilities in wildfire prone
areas will be charged a "wildfire load" in addition to their base premium. The load varies depending
on the relative exposure. For ldaho Power, we have been informed that the load will be up to $1million beginning in 2021, with the potential to increase annually thereafter.
The insurance company that provides ldaho Power's second layer of excess liability coverage has not
formally advised policyholders of anticipated increases for 2021. For most renewals in 2020 from theinsurance company, the premiums are increasing between 10 and 15%. We anticipate the same
range will apply in 2021for most utilities, including ldaho power.
i'MARSH&MCLENNAN
COMPANIES
G MARSH
Page2
December 21st,2020
Jeff Pleimann
ldacorp
For the third layer of excess liabitity coverage, this is placed in the commercial market and is therefore
subject to general market conditions. For 2020, the commercial market for excess liability for electric
utilities has seen rate increases generally falling between 2Ao/o and 50%. We anticipate ldaho Power
will be at the higher end of this range.
For 2O22and beyond, we anticipate the liability insurance market to temper and annual rate of
premium growth should decrease in magnitude after the significant recent and near-term adjustments;
ho*ever we do not have significant clarity to future market conditions and future increases could
continue to be notable. Our expectation is subject to change based on wildfire losses in the western
U.S.
With regard to insurance premiums in general, losses from natural disasters, including wildfires
(whether natural or human-caused), and the various causes of losses across numerous forms of
coverage, are a concern to underwriters and have contributed to the general hardening of the
insurance market and associated sizeable increases in premiums.
Please let me know if you have any questions.
Sincerely,
lrr/
Greg Miller
Managing Director
MARSH&MCLENNAN
COMPANIESG'