20210222Notice_of_Application_Order_No_34926.pdf

NOTICE OF APPLICATION
NOTICE OF MODIFIED PROCEDURE
ORDER NO. 34926 1

Office of the Secretary
Service Date
February 22, 2021

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

On January 22, 2021, Idaho Power Company (“Company”) filed an Application for an
accounting order authorizing it to defer Idaho’s jurisdictional share of incremental costs associated
with its wildfire mitigation and insurance costs. The Application includes a comprehensive
overview of the Company’s efforts to assess wildfire risk, discussion of necessary actions and
measures to mitigate wildfire risk, and identification and examination of incremental operations
and maintenance costs associated with implementing and completing wildfire mitigation efforts
(“Wildfire Plan”).1 The Company requests its Application be processed by Modified Procedure.
The Commission now sets deadlines for interested persons to comment on the
Application, and for the Company to reply.
NOTICE OF APPLICATION
YOU ARE HEREBY NOTIFIED that the Company is proposing a shift in its approach
to vegetation management in recognition that climate, weather, urban-wildland encroachment, and
vegetation growth are expected to continue to change in the coming years.
YOU ARE FURTHER NOTIFIED that the Wildfire Plan uses the Fire Potential Index
(“FPI”) to support operational decision making to reduce wildfire threats and risks. 2 During fire
season, the FPI will be calculated and issued each weekday to help Company personnel in
advanced planning and preparation.
YOU ARE FURTHER NOTIFIED that the Company’s wildfire mitigation strategy
includes internal procedural measures to prevent accidental ignition and spread of wildfires.

1 The Company’s Application includes a copy of the 2021 Wildfire Mitigation Plan.
2 The FPI produces a score from 1-16. Scores of 1-11 are green “lower fire potential;” scores of 12-14 are yellow
“elevated fire potential;” and scores of 15 or 16 are red “highest fire potential.”
IN THE MATTER OF IDAHO POWER
COMPANY’S APPLICATION FOR AN
ACCOUNTING ORDER AUTHORIZING
THE DEFERRAL OF INCREMENTAL
WILDFIRE MITIGATION AND INSURANCE
COSTS
)
)
)
)
)
)
)
)
CASE NO. IPC-E-21-02

NOTICE OF APPLICATION

NOTICE OF
MODIFIED PROCEDURE

ORDER NO. 34926
NOTICE OF APPLICATION
NOTICE OF MODIFIED PROCEDURE
ORDER NO. 34926 2

YOU ARE FURTHER NOTIFIED that the Wildfire Plan includes operational
mitigation practices for deploying temporary operating procedures for transmission lines during
fire season; developing operational strategies for management of distribution lines during periods
of elevated fire risks 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.3
YOU ARE FURTHER NOTIFIED that the Company’s Wildfire Plan also includes
management of certain conditions related to its transmission and distribution (“T&D”) facilities.
This will be accomplished through asset management programs and vegetation management. The
asset management programs include visual inspections, line protection, asset replacement, and
system hardening. Under the Wildfire Plan, the Company will continue to visually inspect its
transmission lines using helicopter (aerial), on-the-ground, wood pole inspection treatment,
cathodic protection and inspection, and thermal imaging inspection methods. The Company will
use unmanned aerial vehicles (drones) with high-definition cameras in certain situations. For
distribution lines, the Company will use visual inspections, distribution wood pole inspection and
treatment, and line equipment inspection. The Company will also work to “harden” its
infrastructure by replacing small conductor and associated hardware. For transmission lines of 138
kilovolt and above, the Company may convert wood poles to steel.
YOU ARE FURTHER NOTIFIED that the Company proposes to implement and
achieve a consistent three-year vegetation management cycle across its entire service area. For FPI
yellow or red zones (see fn n.2) the Company will employ enhanced vegetation management
practices including annual patrols to identify immediate pruning needs; mid-cycle pruning during
year two for fast growing species; increased incentives for customers who own trees that regrow
ahead of the three-year trimming cycle; clearing and sterilizing the soil around certain distribution
poles; performance of post-trimming audits on all pruned trees in yellow and red zones.
YOU ARE FURTHER NOTIFIED that the Company has identified incremental
operations and maintenance (“O&M”) expenses related to mitigating wildfire risk as set forth in
the Wildfire Plan. The expenses are grouped into these categories: (A) quantifying Wildland Fire
Risk; (B) Situational Awareness; (C) Mitigation—Field personnel Practices; (D) Mitigation T&D;

3 PSPS is generally defined as the proactive and planned de-energization of lines when extreme risk conditions are
forecasted.
NOTICE OF APPLICATION
NOTICE OF MODIFIED PROCEDURE
ORDER NO. 34926 3

(E) Enhanced Vegetation Management; and (F) Communication. In the next five years, the
Company estimates it will incur approximately $46.6 million in incremental O&M expenses to
implement these measures. The Company seeks to defer Idaho’s jurisdictional share of incremental
expenses.4
YOU ARE FURTHER NOTIFIED that the costs associated with enhanced vegetation
management are the largest incremental wildfire mitigation expense. The Company estimates
spending approximately $42.7 million on incremental vegetation management expenses over five
years. The Company noted that its actual expenses for vegetation management have been
increasing faster than authorized amounts in recent years. The Company notes several factors are
pushing vegetation management costs upward including additional growth (vegetation and
population), shortages of qualified labor,5 and increased resource costs. The Company seeks to
defer Idaho’s jurisdictional share of incremental vegetation management costs above a base level
of 2019 actual costs.
YOU ARE FURTHER NOTIFIED that the Company proposes testing the three-year
enhanced vegetation management cycle for four or five years to verify that a shorter cycle can be
maintained, and expected benefits are realized.
YOU ARE FURTHER NOTIFIED that the Company will review and update its
wildfire risk assessment biennially.
YOU ARE FURTHER NOTIFIED that the Application and attachments are available
for public inspection during regular business hours at the Commission’s office. These documents
are also available on the Commission’s web site at www.puc.idaho.gov. Click on the
“ELECTRIC” icon, select “Open Cases,” and click on the case number as shown on the front of
this document.
YOU ARE FURTHER NOTIFIED that all proceedings in this case will be held
pursuant to the Commission’s jurisdiction under Title 61 of the Idaho Code, specifically Idaho
Code § 61-501.

4 The Company proposes to continue to pay for baseline levels of O&M escalated annually for inflation out of its
existing budget and does not seek deferral of those costs.
5 The Company’s Application cites two factors contributing to the shortages in labor: (1) special requirements to trim
trees near power lines and equipment that require special certifications and training; and (2) increased demand for
vegetation management services in the western US—including California where labor rates are higher.
NOTICE OF APPLICATION
NOTICE OF MODIFIED PROCEDURE
ORDER NO. 34926 4

YOU ARE FURTHER NOTIFIED that all proceedings in this matter will be conducted
pursuant to the Commission’s Rules of Procedure, IDAPA 31.01.01.000 et seq.
NOTICE OF MODIFIED PROCEDURE
YOU ARE FURTHER NOTIFIED that the Commission has determined that the public
interest may not require a formal hearing in this matter and will proceed under Modified Procedure
pursuant to Rules 201 through 204 of the Idaho Public Utilities Commission’s Rules of Procedure,
IDAPA 31.01.01.201 through .204. The Commission notes that Modified Procedure and written
comments have proven to be an effective means for obtaining public input and participation.
YOU ARE FURTHER NOTIFIED that persons desiring to state a position on this
Application may file a written comment explaining why the person supports or opposes the
Application. Persons who would like a hearing must specifically request a hearing in their written
comments. Persons shall have until April 8, 2021 to file written comments. Comments must
be filed through the Commission website or by e-mail unless computer access is unavailable. To
comment electronically, please access the Commission’s home page at www.puc.idaho.gov. Click
the “Case Comment Form” and complete the form using the case number as it appears on the front
of this document. To file by e-mail, the customer must e-mail the comments to the e-mail
addresses listed below. In addition to submitting the comments to the Commission Secretary, the
customer must also e-mail the Company at the e-mail addresses listed below. If computer access is
unavailable, then comments may be mailed to the Commission and Company at these addresses:
For the Idaho Public Utilities
Commission:

Commission Secretary
Idaho Public Utilities Commission
P.O. Box 83720
Boise, ID 83720-0074
[e-mail]

Street Address for Express Mail:

11331 W. Chinden Blvd.
Building 8, Suite 201-A
Boise, Idaho 83714
For Idaho Power:

Lisa Nordstrom
Alison Williams
1221 West Idaho Street 83702
P.O. Box 70
Boise, ID 83707-0070
[e-mail]
[e-mail]
[e-mail]

NOTICE OF APPLICATION
NOTICE OF MODIFIED PROCEDURE
ORDER NO. 34926 5

YOU ARE FURTHER NOTIFIED that Idaho Power must file any reply comments by
April 22, 2021.
YOU ARE FURTHER NOTIFIED that if no written comments or protests are received
within the time limit set, the Commission will consider this matter on its merits and enter its order
without a formal hearing. If written comments are received within the time limit set, the
Commission will consider them and, in its discretion, may set the same for formal hearing.
O R D E R
IT IS HEREBY ORDERED that the Company’s Application be processed by Modified
Procedure, Rule 201-204 (IDAPA 31.01.01.201-.204). Persons interested in submitting written
comments must do so by April 8, 2021. the Company must file any reply comments by April 22,
2021.
IT IS FURTHER ORDERED that parties should continue to comply with Order No.
34781, issued September 17, 2020. All pleadings should be filed with the Commission
electronically and shall be deemed timely filed when received by the Commission Secretary. See
Rule 14.02. Service between parties should also be accomplished electronically. Voluminous
discovery-related documents may be filed and served on CD-ROM or a USB flash drive.
///

NOTICE OF APPLICATION
NOTICE OF MODIFIED PROCEDURE
ORDER NO. 34926 6

DONE by Order of the Idaho Public Utilities Commission at Boise, Idaho this 22nd
day of February 2021.

PAUL KJELLANDER, PRESIDENT

KRISTINE RAPER, COMMISSIONER

ERIC ANDERSON, COMMISSIONER

ATTEST:

Jan Noriyuki
Commission Secretary

I:\Legal\ELECTRIC\IPC-E-21-02\Orders\IPCE2102_Ntc App Mod_dh.docx