20210408Idaho Conservation League Comments.pdf

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION r r, :,r, - i Pi,i lc, I 2
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-2I-02
IDAHO CONSERVATION LEAGUE
COMMENTS
The Idaho Conservation League (lCL) recommends the Commission approve Idaho
Power's Application with slight modification. We have read the Application as well as the
Wildfire Mitigation Plan itself and believe that this Plan is a necessary step for Idaho Power to
prepare for the impacts of climate change within its management and operations.
Overall, ICL supports Idaho Power's Wildfire Mitigation Plan. We believe that this Plan
takes a proactive, pragmatic approach to prepare for and to mitigate fires in the Idaho Power
service area. While Idaho Power currently plans to operate its wildfire practices independently,
we recommend that Idaho Power instead include collaboration with these land management
agencies as a major component of its Wildfire Mitigation Plan.
Accounting for Climate C hange
Idaho Power recognizes that climate change is directly impacting their operations. In the
Application, Idaho Power acknowledges they have "observed several climate-related shifts that
increase wildfire risk" and that "more broadly, climate change is fundamentally altering the way
trees and forests work". IPC Application at I 1. ln light of the climatic changes occurring in the
region, Idaho Power wants to adequately reduce wildfire risk associated with the operations and
management in their service area. This Wildfire Mitigation Plan is a good example in making
proactive changes to prevent an incident instead of retroactively mitigating after the incident has
occurred. ICL appreciates and commends this protective approach to environmental
management.
ICL believes that accounting and planning for the costs of climate change ahead of time
is likely to lead to less cost than mitigating the results of climate change after the fact. The
o,,i--,
, r..iq: I
rPC-E-2r-02
ICL Comment April 8,2021
preparation on Idaho Power's part shows that they are committed to providing their customers
with safe, adequate, and reliable power. This Plan also reveals that Idaho Power is committed to
the adequate stewardship of resources associated with their service area and transmission and
distribution area as a whole. ICL appreciates this commitment.
Land Management Agency Collaboration
The foundation for the Wildfire Mitigation Plan, according to Idaho Power, is to maintain
safety and reliable electricity delivery for customers as well as good stewardship of the
landscape. IPC Application at 3. Idaho Power states that they value their good stewardship
within and beyond their designated service area. [n order to achieve the best stewardship of the
landscape and natural resources, ICL recommends Idaho Power amend the Wildfire Mitigation
Plan to include more specific collaboration between the land management agencies such as the
Forest Service and the Bureau of Land Management (BLM), who are responsible for the Iands
over which ldaho Power's infrastructure extends.
Much of ldaho Power's infrastructure crosses public lands managed by the U.S. Forest
Service, Bureau of Land Management, and other federal and state agencies. All these land
managers have wildfire assessment and mitigation plans. Idaho Power's Plan does not discuss
how the Company will coordinate with these land managers to align activities and spending
Throughout its Wildfire Mitigation Plan, Idaho Power only states that it plans to concede to
local, state, and federal land management agencies if they issue a formal decision regarding
wildfire restrictions and waivers. Beyond supporting these land managers' authority, Idaho
Power should proactively collaborate in ongoing management planning processes to ensure the
complexities of landscape management in the face of wildfires are being addressed by all
stakeholders in a coordinated manner. Partnering with land managers and other stakeholders to
coordinate wildfire mitigation activities can enable Idaho Power to leverage utility investments
with other planned public spending to improve wildfire resilience across the entire landscape, not
just within the Idaho Power service area.
Wildfires do not recognize boundaries. Independent wildfire management and fuel
reduction efforts that are compartmentalized within different land ownerships are not nearly as
effective as more comprehensive, coordinated efforts spanning multiple ownerships on a
IPC-E-21-02
ICL Comment
2
April 8,2021
landscape scale. Working proactively across ownerships can be a more effrcient use of planning
effiorts and leveraging resources once they are mobilized on the ground. For example, if Idaho
Power timed its own fuel reductions within its rights of way with adjacent efforts, these efforts
would likely be far more effective.
The Forest Service and State of Idaho are working under the Shared Stewardship
Agreement in which both agencies have agreed on an "all hands, all lands" approach. The Forest
Service and State are seeking additional partnerships with private property owners and others on
a landscape-scale approach in which the federal and state funds could be used for hazardous fuel
reduction treatments on other properties. To assist with the implementation of the Shared
Stewardship Agreement, the Governor has convened a Shared Stewardship Advisory Group.
Members include the State Fire Marshal, Forest Service and Department of Lands
representatives, among others. Temporary Ad Hoc members from utilities, insurance companies,
and others may be appointed as needed to provide technical expertise. The Idaho Shared
Stewardship Coordinator is Ara Andrea, who can be contacted at208-666-8624 or
[e-mail]. We recommend contacting Ara to see how Idaho Power's might be able
to coordinate its Wildfire Mitigation Plan with various Shared Stewardship efforts.
In addition, each National Forest in Idaho has a five-year plan for forest management
projects. Many of these projects have a goal of making forests and watersheds more resilient to
wildfires through thinning and prescribed burning. Each National Forest also has an independent
local forest restoration collaborative which makes recommendations for forest restoration
activities. These collaboratives are formed by diverse stakeholders including county
governments, forest product industry representatives, conservation groups, sportsmen,
recreationists, ranchers, and others. In National Forests where Idaho Power has rights of way
with upcoming maintenance needs, we recommend that Idaho Power give a presentation to the
collaborative and Forest Service about the Wildfire Mitigation Program, learn about the five-year
plan, and develop a formal cooperative approach to wildfire mitigation with these land managers.
At a minimum an Idaho Power representative should participate in the monthly collaborative
meetings to develop forest restoration recommendations. The Idaho Forest Restoration
Partnership is a statewide support group for these collaboratives and has the contact information
for each collaborative.
IPC-E-21-02
ICL Comment
3
April8,202l
We also recommend coordinating with the BLM to see if there are any cheatgrass
management or ecologically-sound fuel reduction projects planned in the vicinity of Idaho Power
rights of way. The BLM is currently analyzing and implementing a number of fuel breaks and
cheatgrass management programs in an effort to preserve intact sage steppe habitats and reduce
wildfire risk. Since powerline corridors are disturbed habitat, they are susceptible to invasion by
cheatgrass which elevates the fire risk for both the right of way and the surrounding rangelands.
Because range fires can move very quickly and cover great distances, we believe that a
coordinated cheatgrass reduction program on a larger area would be far more beneficial than
focusing treatments solely within the rights of way. Coordinating with the BLM could also help
improve recreation management issues, reduce improper target shooting and reduce the risk of
human-caused wildfires. By working with the BLM to address these issues both within and
surrounding the rights of way, Idaho Power has a greater likelihood of success in reducing
wildfires. We also recommend working with the BLM and Rangeland Fire Protection
Associations. These associations are collaborative efforts between ranchers, the BLM and Idaho
Department of Lands and provide proactive training for coordinated wildfire responses.
Conclusion
ICL appreciates Idaho Power's recognition that climate change is impacting Idahoans
today through increased risk of wildfires. We support taking action to mitigate this risk, both to
keep Idaho Power's infrastructure secure and to prevent this same system igniting fires on the
landscape. To improve the Plan, ICL recommends Idaho Power more formally collaborate with
land management agencies to leverage investments and activities across utility dollars and other
public spending.
Respectfully submitted this 8th day of April202l,
/s/ Dainee M. Gibson-Webb
Dainee M. Gibson-Webb
Conservation Analyst
Idaho Conservation League
/s/ Beniamin J. Otto
Benjamin J. Otto
Energy Associate
Idaho Conservation League
LPC-E-zI-02
ICL Comment
4
April 8,2021
CERTIFICATE OF SERYICE
I hereby certiff that on this 8th day of April202l,I delivered true and correct copies of
the foregoing COMMENTS to the following persons via the method of service noted:
/s/ Beniam in Otto
Idaho Conservation League
Electronic Mail only (See Order 34602):
Idaho Public Utilities Commission
Jan Noriyuki, Commission Secretary
secretary@puc. idaho. gov
Dayn Hardie, Deputy Attorney General
Idaho Public Utilities Commission
[e-mail]. gov
Idaho Power
Lisa D. Nordstrom
Allison Williams
[e-mail]
[e-mail]
[e-mail]
tPc-E-2l-02
ICL Comment
5
April8,202l