20230104Wildfire Mitigation Plan 2023 (Version 5.0).pdf

LISA D. NORDSTROM
Lead Counsel
[e-mail]
January 4, 2023
VIA ELECTRONIC FILING
Jan Noriyuki, Secretary
Idaho Public Utilities Commission
11331 West Chinden Blvd., Building 8
Suite 201-A
Boise, Idaho 83714
Re: Case No. IPC-E-22-27 Wildfire Mitigation Plan version supplement
Dear Ms. Noriyuki:
When Idaho Power Company (“Idaho Power” or “Company”) filed its then-current
Wildfire Mitigation Plan (Version 4.0) as Attachment 1 to its Application on October 20,
2022, the Company anticipated that a new version would become available as review of
the Company’s Application to Defer Newly Identified Incremental Wildfire Mitigation
Costs was in process. As described in footnote 12 of the Application, Idaho Power
committed to supplementing the existing Application with its 2023 Wildfire Mitigation
Plan (Version 5.0) when it became available to ensure the Commission had the most
current version.
To that end, please find enclosed a copy of Idaho Power’s 2023 Wildfire Mitigation Plan
(Version 5.0). If you have any questions about the attached document, please do not
hesitate to contact me or Regulatory Policy and Strategy Leader Alison Williams at
[e-mail] or 208-388-5994.
Very truly yours,
Lisa D. Nordstrom
LDN:sg
Enclosures
RECEIVED
Wednesday, January 4, 2023 4:47:55 PM
IDAHO PUBLIC
UTILITIES COMMISSION
MITIGATION
WILDFIRE
PLAN
2023
©2022 Idaho Power
Version5–Updated December2022
Idaho Power Company Wildfire Mitigation Plan 2023
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TABLE OF CONTENTS
Table of Contents ............................................................................................................................. i
List of Tables ...................................................................................................................................v
List of Figures ................................................................................................................................ vi
List of Appendices ........................................................................................................................ vii
Review/Revision History ....................................................................................................... viii
Executive Summary .........................................................................................................................1
Regulatory Context ........................................................................................................................13
1. Introduction ................................................................................................................................15
1.1. Background .......................................................................................................................15
1.2. Idaho Power Profile and Service Area ..............................................................................15
1.3. Asset Overview .................................................................................................................16
1.4. Objectives of this Wildfire Mitigation Plan ......................................................................17
2. Government, Industry, and Peer Utility Engagement ................................................................19
2.1. Objective ...........................................................................................................................19
2.2. Government Engagement..................................................................................................19
2.3. Industry and Peer Utility Engagement ..............................................................................19
3. Quantifying Wildland Fire Risk.................................................................................................22
3.1. Objective ...........................................................................................................................22
3.2. Identifying Areas of Elevated Wildfire Risk ....................................................................22
3.2.1. Wildfire Risk Modeling Process ..............................................................................23
3.2.2. Wildfire Risk Areas .................................................................................................24
3.2.2.1. Boardman to Hemingway Proposed Transmission Line ................................30
4. Costs and Benefits of Wildfire Mitigation .................................................................................32
4.1. Objective ...........................................................................................................................32
4.2. Risk-Based Cost and Benefit Analysis of Wildfire Mitigation ........................................32
4.3. Wildfire Mitigation Cost Summary ..................................................................................34
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4.4. Mitigation Activities .........................................................................................................36
4.4.1. Quantifying Wildland Fire Risk...............................................................................36
4.4.2. Situational Awareness—Weather Forecasting Activities and Personnel ................36
4.4.3. Situational Awareness—Advanced Technologies ...................................................37
4.4.4. Field Personnel Practices .........................................................................................38
4.4.5. Transmission and Distribution (T&D) Programs for Wildfire Mitigation ..............39
4.4.5.1. Annual T&D Patrol, Maintenance, and Repairs .............................................39
4.4.5.2. Thermography Inspections..............................................................................39
4.4.5.3. Wood Pole Fire-Resistant Wraps ....................................................................40
4.4.5.4. Covered Conductor Pilot.................................................................................41
4.4.6. Enhanced Vegetation Management .........................................................................41
4.4.7. Communications and Information Technology Customer Notification
Enhancements ........................................................................................................43
4.4.8. Incremental Capital Investments..............................................................................43
4.4.8.1. Circuit Hardening and Infrastructure Upgrades ..............................................43
4.4.8.2. Overhead to Underground Conversions..........................................................46
4.4.8.3. Transmission Steel Poles ................................................................................46
5. Situational Awareness ................................................................................................................47
5.1. Overview ...........................................................................................................................47
5.2. Fire Potential Index ...........................................................................................................47
5.3. FPI Annual Process Review..............................................................................................49
6. Mitigation—Field Personnel Practices ......................................................................................50
6.1. Overview ...........................................................................................................................50
6.2. Wildland Fire Preparedness and Prevention Plan .............................................................50
7. Mitigation—Operations .............................................................................................................51
7.1. Overview ...........................................................................................................................51
7.2. Operational Protection Strategy ........................................................................................51
7.3. Transmission Line Operational Strategy ..........................................................................52
7.3.1. Fire Season Temporary Operating Procedure for Transmission Lines ....................52
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7.3.2. Red Risk Zone Transmission Operational Strategy .................................................52
7.4. Distribution Line Operational Strategy .............................................................................53
7.4.1. Red Risk Zone Distribution Operational Strategy ...................................................53
7.5. Public Safety Power Shutoff .............................................................................................53
7.5.1. PSPS Definition .......................................................................................................53
7.5.2. PSPS Plan.................................................................................................................54
8. Mitigation—T&D Programs ......................................................................................................55
8.1. Overview ...........................................................................................................................55
8.2. T&D Asset Management Programs ..................................................................................55
8.2.1. Transmission Asset Management Programs ............................................................57
8.2.1.1. Aerial Visual Inspection Program ...................................................................57
8.2.1.2. Ground Visual Inspection Program ................................................................58
8.2.1.3. Detailed Visual (High-resolution Photography) Inspection Program .............58
8.2.1.4. Wood Pole Inspection and Treatment Program ..............................................58
8.2.1.5. Cathodic Protection and Inspection Program .................................................59
8.2.1.6. Thermal Imaging (Infra-red) Inspections ........................................................59
8.2.1.7. Wood Pole Wildfire Protection Program ........................................................59
8.2.1.8. Transmission Steel Poles ................................................................................59
8.2.2. Distribution Asset Management Programs ..............................................................60
8.2.2.1. Ground Visual Inspection Program ................................................................60
8.2.2.2. Wood Pole Inspection and Treatment Program ..............................................60
8.2.2.3. Line Equipment Inspection Program ..............................................................61
8.2.2.4. Thermal Imaging (Infra-red) Inspections ........................................................61
8.2.2.5. Overhead Primary Hardening Program ..........................................................61
8.2.2.5.1. Conductor “Small” Replacement ...........................................................61
8.2.2.5.2. Wood Pin and Crossarm Replacement ..................................................61
8.2.2.5.3. Porcelain Switch Replacement ..............................................................61
8.2.2.5.4. Fuse Options ..........................................................................................61
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8.2.2.5.5. Wood Pole Wildfire Protection Program ...............................................62
8.3. T&D Vegetation Management ..........................................................................................62
8.3.1. Definitions................................................................................................................64
8.3.2. Transmission Vegetation Management....................................................................64
8.3.2.1. Transmission Vegetation Inspections .............................................................64
8.3.2.2. Transmission Line Clearing Cycles ................................................................64
8.3.2.3. Transmission Line Clearing Quality Control and Assurance .........................65
8.3.3. Distribution Vegetation Management ......................................................................65
8.3.3.1. Distribution Line Clearing Cycles ..................................................................65
8.3.3.2. Distribution Vegetation Inspections ...............................................................65
8.3.3.3. Distribution Line Clearing Procedures ...........................................................66
8.3.3.4. Distribution Line Clearing Quality Control and Assurance ...........................66
8.3.4. Pole Clearing of Vegetation .....................................................................................66
9. Wildfire Response ......................................................................................................................68
9.1. Overview ...........................................................................................................................68
9.2. Response to Active Wildfires ...........................................................................................68
9.3. Emergency Line Patrols ....................................................................................................68
9.4. Restoration of Electrical Service ......................................................................................68
9.4.1. Mutual Assistance ....................................................................................................69
9.5. Public Outreach and Communications ..............................................................................69
10. Communicating About Wildfire ..............................................................................................70
10.1. Objective .........................................................................................................................70
10.2. Community Outreach ......................................................................................................70
10.2.1. Community Engagement .......................................................................................70
10.2.2. Community Resource Centers ...............................................................................72
10.3. Customer Communications .............................................................................................73
10.3.1. Key Communication Methods ...............................................................................75
10.3.2. Timing of Outreach ................................................................................................79
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10.3.3. Communication Metrics .........................................................................................79
10.4. Idaho Power Internal Communications—Employees .....................................................82
11. Performance Monitoring and Metrics ......................................................................................83
11.1. Wildfire Mitigation Plan Compliance .............................................................................83
11.2. Internal Audit ..................................................................................................................83
11.3. Annual Review................................................................................................................83
11.4. Wildfire Risk Map ..........................................................................................................83
11.5. Situational Awareness .....................................................................................................83
11.6. Wildfire Mitigation—Field Personnel Practices .............................................................83
11.7. Wildfire Mitigation—Operations....................................................................................84
11.8. Wildfire Mitigation—T&D Programs ............................................................................84
11.9. Long-term Metrics ..........................................................................................................86
LIST OF TABLES
Table 1 Wildfires impacting Idaho Power operations and facilities in 2022 .............................................3
Table 2
2022 WMP activity summary and results .....................................................................................5
Table 3 Overhead transmission voltage level and approximate line mileage by state (Dec. 31, 2021) ...........................................................................................................................................17
Table 4
Idaho Power’s transmission and distribution lines by risk zone in Idaho and Oregon* .............25
Table 5 CAL FIRE wildfire data by year .................................................................................................33
Table 6
Estimated system-wide incremental O&M expenses for wildfire mitigation, $000s
(2023–2025) ................................................................................................................................35
Table 7 Summarized T&D asset management programs (associated with the WMP) ............................55
Table 8
Summary of asset inspections and schedules by state and zone .................................................57
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Table 9 VMP summary ............................................................................................................................62
Table 10
Summary of vegetation management activities and schedules ...................................................63
Table 11 T&D programs metrics ...............................................................................................................84

LIST OF FIGURES
Figure 1 A field team installs a mesh wrap on a wood pole in 2022 ..........................................................2
Figure 2
A line worker installs a spark prevention unit near Eagle, Idaho .................................................4
Figure 3 Idaho Power developed an educational video to explain PSPS ....................................................6
Figure 4 A contractor trims trees in a bucket truck .....................................................................................7
Figure 5
Idaho Power uses visual graphics to illustrate the conditions that could require a PSPS event ..............................................................................................................................................8
Figure 6 Idaho Power service area ............................................................................................................16
Figure 7
Wildfire Mitigation Plan—Risk Map .........................................................................................26
Figure 8 Wildfire Risk Map—western Idaho and eastern Oregon ............................................................27
Figure 9
Oregon-specific zones .................................................................................................................28
Figure 10 Wildfire Risk Map—southern Idaho ...........................................................................................29
Figure 11 Wildfire Risk Map—eastern Idaho .............................................................................................30
Figure 12
B2H proposed route risk zones ...................................................................................................31
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Figure 13 Comparison of reclosing strategies with respect to customer reliability and wildfire risk .........52
Figure 14
Outreach samples for the 2022 wildfire season ..........................................................................74
Figure 15 May 2022 edition of Connections ...............................................................................................75
Figure 16
Idaho Power developed an educational video on how we protect wooden poles from
wildfire ........................................................................................................................................76
Figure 17 Sample image of social media post .............................................................................................77
Figure 18
Sample image of social media post .............................................................................................77
Figure 19 Idaho Power’s Wildfire Safety landing webpage .......................................................................78
Figure 20 Wildfire mitigation meeting PowerPoint cover slide ..................................................................79
Figure 21
Wildfire safety webpage views ...................................................................................................80
Figure 22 May 2, 2022, edition of News Scans ...........................................................................................82

LIST OF APPENDICES
Appendix A The Wildland Fire Preparedness and Prevention Plan.
Appendix B
The Public Safety Power Shutoff (PSPS) Plan.
Appendix C Oregon Wildfire Requirements and Recommendations.

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Review/Revision History
This document has been approved and revised according to the revision history recorded below.
Review Date Revisions
Jan. 22, 2021 WMP Version 1 was filed with the Idaho Public Utilities Commission and posted to the Idaho Power website.
Modifications including expanded cost-benefit discussion, plan progress and updates, and inclusion of Idaho Power’s Public Safety Power Shutoff plan.
2022 Added Appendix C.
Added information to comply with the Public Utility Commission of Oregon’s conditions of approval of Idaho Power’s 2022 Wildfire Mitigation Plan.
Updated cost table within the WMP and filed with the Idaho Public Utilities Commission.
9, 2022 WMP Version 5.0, including 2022 season in review, changes for 2023 season, and addition of Appendix C—Oregon Wildfire Requirements and Recommendations.

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EXECUTIVE SUMMARY
Idaho Power is dedicated to the safety of our customers and communities, and to delivering
reliable, affordable energy. In pursuit of that mission, we built off our existing Wildfire Mitigation Plan (WMP) and took major steps in 2022 to enhance our situational awareness in the field, enhance vegetation management, further harden the electrical system, and expand and better the ways in which we communicate and alert customers and communities about wildfire
and wildfire risk. As the company enters its third year with a WMP, this new edition
(Version 5.0) has been improved to reflect key learnings, feedback from stakeholders, and a focus on new technology. The WMP also provides supporting information on wildfire requirements and actions specific to our Idaho and Oregon regulators, but the document remains—first and foremost—an evolving guide that provides holistic and prudent strategies for
reducing wildfire risk.
This Executive Summary—a new introduction in the 2023 WMP—provides a comprehensive summary of the 2022 wildfire season and the company’s lessons learned and progress toward our wildfire mitigation objectives. Additionally, the Executive Summary previews changes to the company’s risk management framework and lessons learned that will inform 2023 wildfire
mitigation efforts and beyond.
2022 Weather and Fire Potential
The spring of 2022 brought above normal precipitation and below normal temperatures. As an example, parts of southern Idaho—including the Boise area—experienced heavy snowfall in the second week of May 2022.1 This led to an abundance of fuels across the region. The summer
months saw record high temperatures and below normal relative humidity that increased wildfire
potential. Idaho Power atmospheric scientists conducted regular forecasts during wildfire season to determine a daily Fire Potential Index (FPI) value across the company’s service area. The FPI is used to inform Idaho Power’s on-the-ground, operational strategies when the fire potential is high.
A combination of record heat and low humidity led to a dramatic increase in FPI levels
throughout the summer of 2022. There were nearly three times as many high-fire-potential days as in 2021. Despite the seasonal challenges, the company fulfilled and executed the WMP as planned for 2022.

1 Carolyn Komatsoulis. 2022. Idaho Press. It’s Pretty Unusual: Half-Inch of Snow, Power Outages Make
for Manic Monday in Boise. May 2, 2022.
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Figure 1 A field team installs a mesh wrap on a wood pole in 2022
Idaho Power continues to monitor climate variability and changing conditions to determine how wildfire risk is shifting season to season and in the longer term. Historical data shows temperature has increased over the past 80 years in southern Idaho and eastern Oregon. Studies show a connection between higher temperatures and increased wildfire activity, both in intensity and size of wildfires.2 Further, extreme fire weather days are increasing, and fire season
is getting longer.3
As climate conditions change, the company is committed to monitoring increased wildfire risk and enhancing the WMP to keep customers and communities safe.
Impacts of Wildfires in 2022
This year, both Idaho and Oregon had fewer wildfires and acres burned during wildfire season
than the previous 20-year average.4 However, wildfires did affect Idaho Power equipment both

2 Idaho reviewed academic, scientific, and governmental climate change studies, including those from the Center for Climate and Energy Solutions, the US Environmental Protection Agency, the National Aeronautics and Space Administration, the National Oceanic and Atmospheric Administration, North Carolina State University, and National Geographic.
3 In late 2022, Idaho Power analyzed temperatures over the last 80 years in the Idaho Power service area to assess changing climate conditions. The analysis showed that daily high temperatures and extreme weather events are increasing.
4 Interagency Fire Center. Current National Statistics. www.nifc.gov/fire-information/statistics.
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inside and outside of our service area. Three major wildfires threatened or burned wood structures. In some cases, we de-energized lines to keep firefighters safe.
Table 1
Wildfires impacting Idaho Power operations and facilities in 2022
Incident Name Location Fire Discovery Date Containment Date Acres Cause Facilities Impacted
Moose 17 Miles North of Salmon, ID 7/17/2022 11/9/2022 130,144 Unattended Campfire Transmission
Four Corners 6 Miles west of the City of Cascade, ID 8/13/2022 10/20/2022 13,702 Lightning Distribution
Double Creek 10 miles SE of Imnaha, OR 8/30/2022 10/25/2022 175,937 Lightning Transmission
Idaho Power’s mapping applications include geographic information system (GIS) data for active wildfires to inform operational planning and provide insight into areas that could be
threatened throughout the fire season. The company monitored fire activity throughout the
season to compare fire behavior to modeling. We expect to learn more about how real-time fire analytics can inform risk-based decision-making in coming fire seasons.
Key Objectives of 2022 WMP
Idaho Power met the 2022 WMP’s key objectives, including the completion of major projects to
ensure the WMP could be effectively carried out. A new Public Safety Power Shutoff (PSPS) program was implemented and all processes and procedures guiding customer communication, weather forecasting, switching plans and de-energization criteria were completed before fire season. This includes the installation and commissioning of a new communication system used to expedite notifications of PSPS events via voice, text messaging, and e-mail. We also installed
17 protective devices to isolate line segments and provide a means of remote de-energization.
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Figure 2 A line worker installs a spark prevention unit near Eagle, Idaho
Overview of 2022 WMP Progress
By almost all measures, Idaho Power met or exceeded its WMP goals in 2022. Work plans are established at the beginning of the year and these items are tracked throughout the year to
identify areas needing corrective action or attention. As some wildfire mitigation work is on a
rotating cycle based on wildfire season (and not the calendar year), some of the items listed are still in progress at the time of writing this 2023 WMP.
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Idaho Power’s Progress Toward 2022 Wildfire Mitigation Goals
Table 2 2022 WMP activity summary and results
*Excludes hardening work outside of wildfire risk zones
**Estimated year end completion
As can be observed from the numbers above, vegetation management is a challenging area.
Much of the delay in reaching 2022 goals is attributable to broader challenges in the workforce. Idaho Power uses contractors to perform vegetation management and audit work. The company witnessed labor shortages, more inexperienced contract workers than in the past, and increased turnover that led to lower vegetation management production levels throughout the year.
Vegetation management production was also lower than anticipated because more climbing work
was required than originally expected. Climbing to prune or remove vegetation requires contractors with more skill and takes more time. Despite these challenges, Idaho Power continues to work with contractors to push toward its goals and estimates that, by the end of the calendar year, the production level will be near 70% of target.
Audits were also impacted by resource availability, as contractors did not reach full staff levels
until December 2022. Because of this, random sampling was used in lieu of auditing all vegetation management work in wildfire risk zones. Idaho Power will work with contractors at the end of 2022 to develop corrective action plans and make necessary adjustments to meet targeted performance levels in 2023.
Plan Area Wildfire Mitigation Plan Activities 2022 Goal Completed % Complete 2023 Goal
Distribution System Hardening
System Hardening Line Miles 48 48.91*69
Overhead Line Miles Converted to Underground 1.85 1.85 100%1
Expulsion Fuse Replacement 930 942 101%1319
Surge Arrester Replacement 830 839 101%1175
Segmentation Devices
Installation or Relocation of Automatic Reclosing Devices 17 17 100%8
Transmission Fire Mesh Installation
Red Risk Zone Poles 492 492 100%-
Yellow Risk Zone Poles 406 585 144%870
Transmission Inspections
Wildfire Pre-Season Patrol - Red Risk Zones (Structures)923 923 100%923
Infrared Thermography Patrol (Structures) 923 923 100%923
Distribution Inspections
Wildfire Pre-Season Patrol - Red Risk Zones (Structures)20,192 20,192 100%20,192
Infrared Thermography Patrol - Red Risk Zones (Structures)3,000 3,800 127%4,000
Pruning Cycle
Transition to a 3-Year Pruning Cycle (circuits)282 173 70%**320
Enhanced Vegetation Management
Annual Patrol - Red & Yellow Risk Zones (circuits)65 65 100%65
Annual Mitigation - Red & Yellow Risk Zones (circuits)65 65 100%65
Mid-Cycle Patrols - Red & Yellow Risk Zones (circuits)47 47 100%1
Mid-Cycle Pruning - Red & Yellow Risk Zones (circuits)47 47 100%1
Hazard Trees Identified and Pruned -77 100%100% of All Identified
Hazard Trees Identified and Removed -49 100%100% of All Identified
Audits of Pruning Activities - Red & Yellow Risk Zones (worksites)6,324 977 15%**100% of All Identified
Idaho Power Weather Stations
Weather Station Installations 5 5 100%5Meteorology
System
Hardening
Feeder
Segmentation
Fire Mesh
Installation
Asset
Inspections
Vegetation
Management
102%
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Regarding customer communication in 2022, Idaho Power used several methods to inform customers throughout the year of our WMP and PSPS plan. These included social media, radio,
customer newsletters, postcards, and voice and text messaging. Before the 2022 wildfire season,
the company focused on asking customers—especially those in PSPS potential zones—to update their contact information and prepare for potential PSPS events. Additionally, the company conducted over 20 in-person and virtual meetings to engage with customers, counties, and fire and other public agencies to discuss and seek feedback on the WMP and PSPS efforts.

Figure 3 Idaho Power developed an educational video to explain PSPS
Fortunately, the company did not need to fully implement a PSPS in 2022. However, the company’s planning and communication apparatuses were tested in one instance in
Pocatello, Idaho, where the company anticipated a PSPS event due to high winds and extremely high fire potential. The company took the steps to inform public safety partners, critical facilities, and customers in the area that a PSPS was imminent. Rain showers preceded high winds in the area and the PSPS event was canceled before de-energization took place.
Looking Ahead—Expanded Mitigation Activities
As detailed in the WMP, Idaho Power deploys a comprehensive and multi-faceted strategy to reduce wildfire risk. The company plans to implement new activities and expand existing ones in 2023. The list below summarizes new or expanded activities.
Infrastructure Hardening In 2022, we hardened approximately 49 line miles to decrease the risk of wildfire in Red
Risk Zones—areas with the highest wildfire risk based on wildfire probability and potential impacts. The hardening program is 26% complete, with Red Risk Zones given the highest priority at this time. This work will increase in 2023 by 40% and include hardening to 69 line miles.
Strategic Undergrounding
In 2022, Idaho Power buried approximately 1.85 miles of overhead distribution line in
areas of highest wildfire risk. This work primarily targeted the main trunk of distribution
feeders. In 2023, we will target a smaller line segment in an area that includes residences.
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The company’s goal is to work through the complexities and costs associated with burying
primary overhead powerlines, overhead services, and converting customer-owned
service-entrance equipment. This work will take place in a PSPS zone in Idaho with high
fire probability and potential impact. The projects in 2022 and upcoming work in 2023
will inform future underground conversion strategies by helping us weigh costs and
risk-reduction benefits against those of traditional feeder hardening and covered
conductor conversions.
Vegetation Management Idaho Power’s effort to achieve a three-year pruning cycle will continue in 2023. It is a
critical aspect of meeting our objective to reduce wildfire risk. We will expand brush clearing
and applying ground sterilant around wood poles to reduce fuels. We are also exploring an
opportunity to partner with the National Forest Foundation, Boise National Forest, Bureau of
Land Management, and local fire districts on a shared stewardship program in the Boise
Front. This work is expected to provide a means for Idaho Power to participate in fuel
reduction activities outside of the right of way, which will reduce wildfire risk by decreasing
surface fuels and the potential of tree contact.

Figure 4 A contractor trims trees in a bucket truck
Risk Modeling
Risk modeling of Idaho Power’s service area is used to prioritize mitigation activities. In
2023, we will re-evaluate our risk modeling by incorporating new structure information
based on 2020 Census data and explore new areas of consequence based on the feedback
received in the past year from fire agencies and customers.
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Situational Awareness The FPI is forecasted daily during fire season and provides critical information that informs
operational changes during days with high fire potential. In 2023, we will work to improve
the communication and calculation of the FPI by creating more clear and concise messaging
to stakeholders.
PSPS While the company did not proactively de-energize any customers as part of its PSPS
program in 2022, engagement with communities and customers this year highlighted their
concerns—specifically the inability to communicate or suppress fire via electric wells and
water pumps without power. This feedback highlights the need for the company to find ways
to limit the impact and frequency of future PSPS events. Many of the activities being pursued
here, such as strategic undergrounding and utilizing covered conductor, will decrease the
likelihood of PSPS. However, PSPS will remain a tool available to the company to mitigate
wildfire risk during extreme fire weather conditions.

Figure 5 Idaho Power uses visual graphics to illustrate the conditions that could require a PSPS event
Segmentation We completed the installation of 17 automatic reclosing devices (reclosers) in Red Risk
Zones as part of an effort to isolate circuit segments and improve reliability for customers
outside of those zones. In 2023, we will continue this work and install an additional eight
reclosers in Red Risk Zones.
New Technology and Innovations New technology and innovative programs were explored in 2022 to find new ways to reduce
the risk and impacts of wildfire. In 2023, we will conduct pilots based on our findings with
the goal of learning more about their implementation complexities and to analyze costs and
risk reduction benefits prior to fully integrating into the WMP. These pilots or trials include
the following:
• Satellite Imagery—Using satellite imagery to detect vegetation encroachment and
hazard trees.
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• Covered Conductor—Covered conductor is a solution used throughout the industry
to decrease the potential of ignition if an object contacts powerlines. A trial of
covered conductor will be carried out in our training yard to determine overall costs, tooling requirements, work methods, and construction standards and specifications.
• Structural Resilience of Wood Poles—We will increase situational awareness in Red Risk Zones by performing a survey of distribution poles using Light Detection and
Ranging (LiDAR) technology to identify structural loading capacity of existing wood poles.
• Shared Stewardship—We will partner with federal agencies on a shared stewardship fuel reduction program in forested areas and evaluate the benefits in terms of reduced
surface fuels and fire spread potential. The collaboration will also provide the company with the opportunity to work with land managers and owners to expand vegetation management and reduce the potential of ignition from vegetation contact.
• Fire Detection Cameras—In 2022, we explored the benefits that cameras can have in
early fire detection and became part of the Wildfire Detection Camera Strategy Work
Group in Oregon. We are working to identify optimal locations and developing partnerships with state and federal agencies and will expand our knowledge of cameras that utilize artificial intelligence for fire detection. We plan on piloting cameras in 2023 to further understand the complexities of installations, permitting, systems used for notification, and overall accuracy. The pilot will be critical in
determining a long-term strategy for the use of cameras to reduce wildfire risk.
Lessons Learned
Idaho Power has conducted its own assessment of lessons from the 2022 wildfire season and the company’s wildfire mitigation practices. The following lessons learned were developed by
supplementing this analysis with feedback heard from stakeholders, customers, public safety
partners, peer utilities, and through wildfire-related forums, research, and education.
Pre-Wildfire Season Patrols Idaho Power strives to complete wildfire patrols prior to the start of each wildfire season to identify issues that may pose a risk of ignition if left unchecked. Above-normal precipitation
and below-normal temperatures in the spring months of 2022 created access issues in
mountain areas where snow levels were several feet deep. Late, heavy snow delayed completion of these patrols until mid-June, which, while later than target, was still prior to the onset of conditions conducive for wildfire.
Situational Awareness
The FPI is an essential tool to support operational decision making. It includes detailed
forecasts of 148 different geographical areas or zones throughout the service area and is used to determine when a PSPS is necessary. The preparation for a PSPS event in August 2022 highlighted an opportunity to improve the communication and precision of the forecasts. In that case, a line segment subject to the potential PSPS was included in two different FPI
zones that had different fire potential across their geographical areas. Initially, this created
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confusion as to which forecast to use for decision-making purposes. In 2023, we will review areas that have overlapped FPI zones and refine mapping and forecasted boundaries to
eliminate the potential of this situation occurring again.
Vegetation Management Pruning levels in 2022 did not meet the target established for the year largely due to labor issues. We added outsourced crews from throughout the country to assist in conducting vegetation management activities and expect to reach approximately 70% of targeted
vegetation management pruning by the end of 2022. In 2023, we will conduct a thorough
review of all activities and assess means of working with contractors to drive towards 2023 production goals.
Expansion of the Wildland Urban Interface As the population in Idaho Power’s service area continues to grow, we’ve seen an expansion
of new construction in the wildland urban interface (WUI). This expansion creates challenges
for wildfire mitigation as new wildfire risks emerge. In 2023, we will analyze the growth of the WUI and create new strategies to address new risks.
Functional Exercises Two functional exercises were conducted in the spring of 2022 to test processes and
procedures needed to fully execute the PSPS program. The exercises were beneficial and
ensured that the company was prepared to effectively carry out a PSPS prior to the onset of severe fire weather. Forty action items were identified throughout the exercises and consisted of refining and improving communication methods, timing, documentation, and website functionality. We found that PSPS events can be complex and occur within different parts of
the company’s service area simultaneously. To help ensure expedited and accurate
communication for all potential scenarios, templates were developed for communication activities involving customers, Public Safety Partners, Emergency Support Function (ESF-12), and departments within the company. The templates will be reviewed and improved as needed in 2023.
List of Stakeholders
The PSPS functional exercises highlighted the need for accurate and readily available lists of Public Safety Partners and critical facilities. We developed a central repository for all information related to PSPS which includes contacts for Public Safety Partners, operators of critical facilities, and Emergency Support Function ESF-12 personnel.
Estimated Time of Restoration
As with all outages, having accurate estimates for the time or restoration (ETR) is a priority. The PSPS functional exercises highlighted that setting an initial ETR for PSPS events is more challenging than ordinary unplanned or planned outages. The company determined that the ETR for a PSPS should take into consideration the duration of the weather event and the
time needed for safety patrols to occur. Internal atmospheric scientists became a crucial part
of determining the duration of weather events. Operational plans were developed for each region to guide restoration and switching procedures to expeditiously restore power during a PSPS. These plans include estimated patrol times which are also used for establishing an initial ETR. We plan on reviewing any assumptions in the operational plans each year and
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include lessons learned from the previous year into the patrol estimates to ensure we are providing the best information possible.
Field Observer Program
PSPS events are carefully evaluated by an assessment team to balance wildfire risk with potential PSPS impacts on the customers and the communities we serve. In 2022, we expanded the PSPS decision-making process to include real-time on-site conditions from Field Observers (FOBs). FOBs are Idaho Power personnel positioned within pre-defined
PSPS zones to monitor system conditions and periodically report observations to help inform
the PSPS assessment team. The location of FOBs in PSPS zones was examined to ensure their safety during severe weather conditions and communication templates were developed to ensure accurate and consistent fire weather reporting. We found that, in some areas, cellular and radio communication does not exist and we had to rely on satellite messaging
services. The FOB program became more complex than anticipated, and we will work in
2023 to improve the documentation and procedures as well as increase the number of qualified resources to perform FOB duties in situations where multiple areas are at risk of PSPS.
Customer Communication
Notifying customers in PSPS zones was a priority this year and consisted of telephone,
text, and e-mail outreach. We found that some of the targeted customers did not have up-to-date contact information associated with their account. Several efforts were made to encourage customers to update their contact information, and additional information was mailed to those customers without current contact information. This will be a continued focus
in 2023.
Community Feedback The company conducted over 20 WMP and PSPS plan presentations throughout the service area, to advise customers of our plans and to solicit feedback to help inform future versions of the WMP. Seven public meetings were held in Oregon at the end of fire season, and we
received good feedback from local fire chiefs, emergency managers, and the general public.
Feedback and themes from these meetings and others throughout the year will be incorporated into the 2023 WMP and include:
• Adjusting the timing of public meetings in Oregon to coincide with fire season
• Partnering with agencies and other programs, such as Firewise, when conducting public meetings
• Reviewing risk modeling to include additional areas of consequence
• Having more collaboration with fire agencies including the Idaho Bureau of Land
Management (BLM), Forest Service, Baker County, and La Grande Rural Fire Protection District
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Vulnerable Populations Idaho Power participated in two mock events, one conducted by Malheur County in Oregon
and another as part of the Idaho Office of Emergency Management’s Cascade Rising event.
These two events highlighted two opportunities to improve our support for vulnerable populations during an outage or PSPS event. First, the Red Cross was added as a Public Safety Partner in Malheur County based on their role in coordinating Community Resource Centers (CRC). Second, the emPower program was identified as a tool to help notify
customers on durable medical devices (DME) if a PSPS event is predicted. Targeted outreach
to vulnerable populations was also conducted to include outage preparedness flyers sent to Meals on Wheels participants. In 2023, Idaho Power will further the efforts made in identifying and communicating with vulnerable populations.
Risk Management Process
A review of Idaho Power’s risk management process used in developing previous versions of
the WMP was completed in 2022. The review found opportunities to improve by strategically incorporating a more formalized risk management process into the WMP. The International Standardization Organization (ISO 31000-2018) is a recognized standard for risk management and will be integrated into the 2023 plan. The standard will help position the
company to achieve the objectives of the WMP by fostering continuous improvement and
ensuring a consistent approach to risk-based decision making.
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REGULATORY CONTEXT
As part of Idaho Power Company’s (Idaho Power or company) commitment to deliver safe,
reliable, and affordable energy, the company developed a comprehensive Wildfire Mitigation Plan (WMP) to reduce wildfire risk associated with its facilities. The WMP has three core objectives:
1. Reducing wildfire risk for the safety of Idaho Power’s customers and the communities in
which it operates.
2. Ensuring the continued and reliable delivery of electricity to more than 600,000 retail customers in Southern Idaho and Eastern Oregon.
3. Furthering the company’s good stewardship of the beautiful and natural lands within Idaho Power’s service area and beyond.
Idaho Power released its inaugural WMP in January 2021. The company’s WMP is a living
document that will evolve over time. Idaho Power will seek to review, modify, and expand the WMP in the coming years to reflect shifts in industry best practices and to ensure the company is following procedures and requirements established by its regulators. Given that Idaho Power operates in both Oregon and Idaho, below is a description of recent wildfire-related regulatory
activities by state.
Idaho
On January 22, 2021, Idaho Power proactively filed its first WMP with the Idaho Public Utilities Commission (IPUC). The company’s application provided a narrative of Idaho Power’s effort to develop the WMP, including discussion of risk analysis across its service area and evaluation of
specific wildfire mitigation activities (e.g., enhanced vegetation management and system
hardening) the company would undertake in the coming fire season. Idaho Power asked the IPUC for authority to defer the Idaho jurisdictional share of incremental operations and maintenance expenses and capital depreciation expenses related to implementing the measures in the WMP, as well as incremental insurance costs.
On June 17, 2021, the IPUC issued Order No. 35077, granting the company’s application and
allowing cost deferral of all incremental wildfire mitigation and insurance expenses identified in Idaho Power’s application.
On October 20, 2022, the company filed an updated WMP and a new application for deferral of newly identified wildfire mitigation-related costs.
Oregon
In August 2020, the Public Utility Commission of Oregon (OPUC) opened an informal rulemaking related to mitigating wildfire risks to utilities, utility customers, and the public. The scope of this docket (AR 638) shifted following the 2020 wildfire season, splitting into two
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tracks—a temporary wildfire rulemaking to govern the 2021 wildfire season and a secondary track to establish replacement permanent rules for the 2022 fire season.
On July 19, 2021, Oregon Governor Kate Brown signed into law Senate Bill 762 (SB 762),
a wildfire bill that, among other actions, established minimum requirements for utility wildfire protection (or mitigation) plans. The bill required that utilities file inaugural plans no later than December 31, 2021.
In response to the passage of SB 762, the OPUC halted the permanent wildfire rulemaking in AR
638 and opened docket AR 648 to develop interim permanent rules adhering to the requirements
and timing of the new law. On September 8, 2022, the OPUC issued Order No. 22-335 in AR 638 finalizing requirements specific to requirements for utility WMPs.
Idaho Power added Appendix C to the WMP to provide Oregon-specific information related to wildfire requirements and recommendations.

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1. INTRODUCTION
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 areas,
historical land management practices, and changes in wildland and forest health, among other factors.
While Idaho Power has not experienced catastrophic wildfires within its service area at the same level experienced in other western states, such as California and more recently certain areasin Oregon, millions of acres of rangeland and southern Idaho forests have burned in the last
30 years.5 In that same time period, the wildfire season in Idaho has expanded by 70 days.6
Idaho’s wildfire season is defined by Idaho Code § 38-115 as extending from May 10 through October 20 each year, or as otherwise extended by the Director of the Idaho Bureau of Land Management (BLM). Oregon’s wildfire season is designated by the State Forester each year pursuant to Oregon Revised Statute § 477.505 and typically begins in June. Idaho Power’s
operational practices account for the differences between Idaho and Oregon’s wildfire seasons
and requirements.
1.2. Idaho Power Profile and Service Area
Idaho Power is an investor-owned utility headquartered in Boise, Idaho, 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 approximately 600,000 retail customers throughout a 24,000 square mile area in southern Idaho and eastern Oregon (see Figure 6).

5 Rocky Barker, 70% of S. Idaho’s Forests Burned in the Last 30 Years. Think That Will Change? Think Again., Idaho Statesman, October 4, 2020.
6 Ibid.
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Figure 6 Idaho Power service area
Of Idaho Power’s 24,000 square mile service area, approximately 4,745 square miles are located
in Oregon and 19,255 in Idaho. Approximately 20,000 customers are served in Oregon and
580,000 in Idaho.
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 3 summarizes the overhead powerline asset information by state. Approximately 2,871 pole miles (12%) are in Oregon and 21,042 (87%) are in Idaho.

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Table 3 Overhead transmission voltage level and approximate line mileage by state (Dec. 31, 2021)

1.4. Objectives of this Wildfire Mitigation Plan
The primary objectives of this WMP are to identify and implement strategies to 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 in a wildfire event, independent of the ignition source.
3. Comply with all wildfire mitigation requirements established by its regulators.7
Idaho Power’s approach to achieving these objectives includes the following actions:
• Engage with government and industry entities and electric utility peers to ensure understanding and commonality of wildfire mitigation plans.
• Utilize a risk-based approach to quantify wildland fire risk that considers wildfire
probability and consequence to identify areas of elevated wildfire risk within Idaho Power’s service area. These identified areas are then incorporated in Idaho Power’s geographic information system (GIS) mapping.
• Create specific and targeted operations and maintenance practices, system hardening
programs, vegetation management, and field personnel practices to mitigate wildfire risk.

7 The OPUC established docket AR 648, the interim permanent wildfire rulemaking, after the Oregon legislature passed Senate Bill 762. The bill created a requirement for public utilities in Oregon to submit
“wildfire protection plans” to the OPUC by December 31, 2021.
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• Incorporate information regarding current and forecasted weather and field conditions
into operational practices to increase situational awareness.
• Employ public safety power shutoff (PSPS) protocols for Idaho Power’s service area and transmission corridors.
• 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 wildfire season each year.

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2. GOVERNMENT, INDUSTRY, AND PEER UTILITY ENGAGEMENT
2.1. Objective
Idaho Power recognizes the importance of engaging with federal, Idaho and Oregon State governments, and local governments as an integral part of mitigating wildfire risk. Idaho Power also recognizes the importance of engagement and outreach with respect to potential future PSPS
events to minimize customer impact.
Idaho Power’s wildfire mitigation plan and outage preparedness strategy includes specific activities to engage with key stakeholders to share information, gain feedback, and incorporate lessons learned. Peer utility engagement is crucial to ensure the company’s efforts are informed by the best practices of its peers in Idaho and Oregon.
2.2. Government Engagement
Much of Idaho Power’s service area extends over land managed by the BLM and U.S. Forest Service. Idaho Power engages with both agencies to share information and identify areas and
activities that are mutually beneficial. For example, Idaho Power allowed for an extended firebreak along Highway 93 in Jerome County, Idaho, on its property to help with BLM wildfire mitigation initiatives.
Idaho Power is also a member of the Idaho Fire Board, which was initiated by the U.S. Forest Service. Membership is voluntary and currently includes the Forest Service, BLM, Federal
Emergency Management Agency (FEMA), Idaho State Lands Department, Idaho Department of Insurance, Idaho Military Division, City of Lewiston, Idaho Power, and The Nature Conservancy in Idaho.
Idaho Power is actively engaged with both the IPUC and the OPUC with respect to wildfire mitigation activities. Idaho Power filed its WMP with the IPUC in 2021 and again in 2022.
In Oregon, the company is required to submit an updated WMP by the end of each calendar year. Idaho Power continues to participate in the OPUC’s Oregon Wildfire and Electric Collaborative (OWEC) and ongoing rulemaking efforts.
2.3. Industry and Peer Utility Engagement
Although Idaho Power relied on plans developed by several California utilities in drafting its own WMP, modifications were made to account for Idaho Power’s considerably different risk profile. Additionally, Idaho Power participated in multiple workshops with San Diego Gas and
Electric, Southern California Edison, Pacific Gas and Electric, Sacramento Municipal Utility
District, and PacifiCorp. The company continues to engage with these utilities to learn about California’s evolving practices.
In the Pacific Northwest, many utilities work collaboratively to understand and ensure commonality of their various wildfire mitigation plans, while accounting for the variation in each
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utility’s unique service area. These utilities include Idaho Power, Avista Utilities, Portland General Electric, Rocky Mountain Power, Pacific Power, Chelan County Public Utility
District, Puget Sound Energy, NV Energy, Bonneville Power Administration (BPA),
and Northwestern Energy.
Idaho Power is also a member of both the Edison Electric Institute (EEI) and the Western Electric Institute (WEI). The company participated in multiple workshops and conferences with both entities and member utilities to evaluate the strength and effectiveness of Idaho Power’s
WMP in comparison to other members’ plans. Additionally, Idaho Power’s CEO and President is
an active member of the EEI Electricity Subsector Coordinating Council Wildfire Working Group. This working group has been partnering with the U.S. Department of Energy and other government agencies to collectively minimize wildfire threats and potential impacts.
These workshops continue to prove valuable for sharing wildfire mitigation best practices and
discussing new and existing technology related to wildfire mitigation. For example, EEI and
WEI workshops, as well as independent investigations, led Idaho Power to expand its use of Unmanned Aircraft Systems ([UAS] also known as drones) during line patrols, replace expulsion fuses with energy limiting fuses, and add mesh wraps to wood poles in wildfire risk zones. Idaho Power has also enlisted a team of employees to focus on wildfire mitigation technologies
by identifying opportunities to incorporate new and innovative technologies into Idaho Power’s
wildfire mitigation efforts.
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2022 Industry and Peer Utility Engagement

Idaho Power continues to engage with industry groups and peer utilities to gain knowledge of new mitigation activities, industry best practices, and employing technology to reduce wildfire risk. The following summarizes 2022 activities:
• Technology—Held meetings with over 30 vendors and manufacturers to identify new
technology and innovations used to mitigate wildfire risk. The findings were used to develop a roadmap and led to the creation of pilot projects in 2022 and 2023.
• Electric Power Research Institute (EPRI)—Engaged with EPRI to learn more about new technology and the attributes of covered conductor, particularly the UV performance
and reliability performance.
• Utility Wildfire Symposium—Attended a symposium hosted by EPRI and Portland General Electric focused on new technology, trends, and ways to mature risk modeling.
• NW Wildfire Group—Attended biennial meetings and shared details of Idaho Power’s
WMP and PSPS plan with attendees including how new technology and innovative materials are being incorporated.
• WEI—Provided a presentation and details of Idaho Power’s documented processes and procedures used in PSPS execution and customer notifications.
• WEI Wildfire Planning and Mitigation Virtual Meeting—Attended a two-day conference to gain insight into mitigation activities and strategies other utilities are pursuing.
• International Wildfire Risk Mitigation Consortium—Held meetings throughout the year
with program managers and participated in a risk reduction seminar focused on vegetation management.
• Oregon Wildfire Detection Camera Strategy Group—Became a member of a workgroup focused on the interoperability of different camera platforms to improve fire detection,
suppression efficiency, and response time. This group has provided valuable information into the benefits that cameras hold for early fire detection and how partnerships can be utilized to expedite the installation.
• Wildfire Technology Webinar—Attended webinar focused on using artificial
intelligence (AI) drones for grid inspections, aerial sensors, and cameras to gain situational awareness.
• National Forest Foundation (NFF)—Attended multiple meetings with the NFF and other agencies to learn more about the benefits of fuel treatments and shared stewardship programs and how utilities have participated in other locations. Lessons learned
include details of the success achieved in the Upper Arkansas Forest Fund in the State of Colorado.
• British Standards Institute (BSI) —Attended a two-day course taught by BSI to gain knowledge of the International Organization for Standardization (ISO) 31000 risk
management framework and how it can be applied to the company’s WMP.
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3. QUANTIFYING WILDLAND FIRE RISK
3.1. Objective
Idaho Power’s approach to quantifying wildland fire risk is to identify geographic areas of elevated wildfire risk if a wildfire ignites near a power line. Mitigation actions and programs are prioritized in those areas identified as elevated wildfire risk areas.
3.2. Identifying Areas of Elevated Wildfire Risk
Idaho Power hired an external consultant that specializes in assessing and quantifying the threat of wildfire through a risk-based methodology that leverages weather modeling, wildfire spread
modeling, and Monte Carlo simulation. This methodology 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) in developing its CPUC Fire Threat Map. In addition, other utilities in Oregon, Idaho, Nevada, and Utah have utilized similar modeling to identify and quantify wildfire risk.
This methodology is consistent with conventional definitions of risk, which is usually taken as an event’s probability 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 Probability x Consequence
The definition of each component is as follows:
Fire Probability. Fire volume (i.e., spatial integral of fire area and flame length) is used as Fire Probability because 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:
• Historical weather (temperature, wind speed/direction, relative humidity)
• Topography
• Fuel types present
• 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.
Wildfire Risk. Fire Probability multiplied by the Consequence. The highest Wildfire Risk areas are those where both the Fire Probability and Consequence are elevated. Conversely,
combinations of low Fire Probability and elevated Consequence, or elevated Fire Probability and
low Consequence typically indicate lower Wildfire Risk.
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3.2.1. Wildfire Risk Modeling Process
The wildfire risk modeling process incorporated the following major steps:
1. A 20-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 area. 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 area
were developed. This was accomplished by analyzing historical 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 feet) fuel rasters for use in fire spread modeling.8
4. The data developed above (WRF climatology, live fuel moisture, and LANDFIRE data) was used to drive a Monte Carlo9 fire spread modeling analysis. This Monte Carlo simulation was accomplished by randomly selecting an ignition location and a randomly selected day from the fire 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., 1 kilometer on either side). The model used equal ignition probability for all overhead distribution and transmission asset types. Urbanized areas having underground circuitry were not included in the model due to a low probability of wildfire associated with underground electrical equipment.
Note that transmission lines jointly owned by Idaho Power and PacifiCorp were included in the analysis. Furthermore, the proposed Boardman to Hemingway (B2H) 500 kilovolt (kV) 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 fire, potential fire impacts to structures were quantified using structure data.
This was repeated across Idaho Power’s service area 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.

8 Chris Lautenberger, Mapping areas at elevated risk of large-scale structure loss using Monte Carlo simulation and wildland fire modeling. IAFSS 12th Symposium 2017.
9 Ibid.
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3.2.2. Wildfire Risk Areas
Based on the previously described modeling, draft risk tiers were generated algorithmically10 by an automated process. Tiers were established which, if exceeded, would classify an area as Tier 2 (elevated risk) or Tier 3 (high risk). To aid in customer and public understanding,
Idaho Power also color-coded the tiers to reflect relative risk—Yellow Risk Zones (YRZ) for Tier 2 and Red Risk Zones (RRZ) for Tier 3. This was accomplished by manually setting threshold values at naturally occurring breaks. Idaho Power held several public workshops wherein tiers were reviewed and adjusted based upon consideration of local and institutional knowledge and potential impacts to communities. This was a similar approach taken by the
California Public Utilities Commission in developing a state wildfire risk map. Consequently, the resulting risk tiers reflect risk relative to Idaho Power’s service area 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 adjustments to account for unique aspects 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:

10 Ibid.
2023 Risk Modeling Update

With the help of our consultant in 2023, Idaho Power will strive to improve risk modeling to better understand wildfire risk and estimations of wildfire consequences along electric lines and equipment. Ares of focus include:
• Incorporate structure density information using 2020 Census data
• Incorporate proposed building developments in or near wildfire risk zones
• Explore new available data to potentially incorporate into wildfire probability and consequence. Examples include:
• Fire history
• Land use changes
Additionally, Idaho Power’s risk modeling update will include assessing feedback from customers and agencies received throughout the year. Enhancements made will provide more
understanding and improved methods to better inform operational decision-making and
risk treatments.

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•Topography and resistance to fire control
•Means of ingress and egress
•Presence/absence of defensible space
•Vulnerable populations
•Cell phone coverage
•Non-burnable land cover such as built-up urban areas
This review helped define overall tier boundaries and, in some cases, expanded Tier 3 areas or moved certain Tier 2 areas into Tier 3. For example, the Charlotte fire was a human-caused fire
that occurred in Pocatello in 2012 and burned more than 1,000 acres and destroyed 66 homes and
29 outbuildings. It was a difficult fire to control and highlighted the dangers of juniper trees intermixed within the wildland urban interface (WUI). Local knowledge of this event was used to expand outlying Tier 2 areas in the vicinity of the Charlotte fire into Tier 3. As part of integrating the ISO 31000 risk management processes into the WMP, Idaho Power plans to
review tier levels and boundaries as part of continuous improvement and maturing our risk
modeling methods.
Table 4 provides a breakdown of pole miles in risk zones on a system-wide basis and by state. Across Idaho Power’s service area, 8% of pole miles exist in elevated risk zones (either RRZs or YRZs). In Idaho, 5% of pole miles exist in YRZs and 3% exist in RRZs. In Oregon, less than 1%
of pole miles exist in YRZs. The company has no RRZs in Oregon.
Table 4 Idaho Power’s transmission and distribution lines by risk zone in Idaho and Oregon*
*Geospatial analysis was performed in 2022 to reconfirm the pole miles in wildfire risk zones.
The final two-tier risk map reflecting relative increased risk in YRZs and RRZ is shown in Figure 7. The map is the foundation of Idaho Power’s wildfire mitigation and risk reduction strategies. It is used to determine and prioritize targeted investments, inspection activities,
and increase situational awareness for field personnel.
The risk zone map can be viewed in detail on Idaho Power’s website. Individual addresses can be entered on the map to determine proximity to identified risk zones.
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Figure 7 Wildfire Mitigation Plan—Risk Map
Additionally, Figures 8 through 11 delineate risk zones in Idaho and Oregon.

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Figure 8 Wildfire Risk Map—western Idaho and eastern Oregon

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Figure 9 Oregon-specific zones

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Figure 10 Wildfire Risk Map—southern Idaho

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Figure 11
Wildfire Risk Map—eastern Idaho
3.2.2.1. Boardman to Hemingway Proposed Transmission Line
Idaho Power specifically considered the proposed route of the B2H 500 kV transmission line as part of the WMP. The proposed B2H route was included in the wildfire risk assessment and associated map analysis (see Figure 3). Two locations are identified along the route as having increased wildfire risk (YRZs), and there were no areas of higher risk (RRZs). Although the B2H
transmission line has not been constructed as of the publication of this 2023 WMP, Idaho Power
intends this WMP (as it will be reviewed annually) will apply to B2H. Additionally, Idaho Power will continue to update its fire risk mapping periodically and address the locations with elevated risk consistent with the mitigation strategy for transmission lines as described in sections 5–9 of this WMP.

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Figure 12 B2H proposed route risk zones

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4. COSTS AND BENEFITS OF WILDFIRE MITIGATION
4.1. Objective
This section details Idaho Power’s assessment of high-level risk with respect to undertaking wildfire mitigation activities. This assessment provides a framework for understanding the potential consequences of wildfire damage and the possibility of diminishing those consequences
through targeted mitigation activities.
To that end, Section 4.3 identifies selected mitigation activities and the estimated costs of those activities on a system level. In Section 4.4, each mitigation activity is discussed in detail, with an assessment of why it was selected, what alternatives (if any) may be available, and any additional benefits (referred to as “co-benefits”) the company believes may result from
pursuing it.
4.2. Risk-Based Cost and Benefit Analysis of Wildfire Mitigation
In assessing the probability and consequence of wildfire risk, and to identify benefits of various wildfire mitigation efforts, Idaho Power engaged with its external 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.
Through its research, Idaho Power found that obtaining a precise calculation of the potential costs of future wildfires is not realistic. The damage that any fire may cause depends on factors such as wind and weather, vegetation, fire risk levels, location, and population and structure density.
Idaho Power’s assessment of the potential costs of wildfires—used in developing the WMP and the scope of proposed updates to practices—involved a review of prior major fires in other states, as well as calculations by other western utilities. While this assessment did not yield a precise quantification of potential benefits specific to Idaho Power, it provides a helpful illustration of the potential costs of not taking actions aimed at reducing wildfire risk.
Idaho Power reviewed and considered calculations analyzing the potential reduction in probability of igniting wildfires based on risk-mitigating activities. For instance, in a June 2020 filing before the IPUC, Avista Corporation (Avista) stated that its “analysis indicates a 10-year inherent potential risk exposure of at least $8 billion dollars,” though noted the figure should not
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be interpreted as a precise financial estimate.11 Avista further noted that the actions it proposes in its own wildfire resiliency plan result in an average percentage of risk mitigation of 89% for the
overall plan.12
In California, costs and damages associated with wildfires in recent years have exceeded $10 billion per year, with those associated with the 2020 fires alone potentially set to exceed $20 billion.13 This increase14 is consistent with the fact that, with few exceptions, the prevalence,
intensity, and impact 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 in Table 5. Table 5 CAL FIRE wildfire data by year
Year Estimated Acres Burned No. of Wildfires
No. of Confirmed Fatalities
No. of Structures Damaged or Destroyed
2020 4,197,628 9,279 31 10,488
2019 259,823 7,860 3 732
2018 1,975,086 7,948 100 24,226
2017 1,548,429 9,270 47 10,280
2016 669,534 6,954 6 1,274
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 Idaho 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 any incremental costs of wildfire mitigation efforts identified in this WMP.

11 In the Matter of Avista Corporation’s Application for an Order Authorizing Accounting and Ratemaking Treatment of Costs Associated with the Company’s Wildfire Resiliency Plan, Case No. AVU-E-20-05, Application at 17.
12 Ibid.
13 Jill Cowan, How Much Will the Wildfires Cost?, The New York Times, Sept. 16, 2020,
at https://www.nytimes.com/2020/09/16/us/california-fires-cost.html.
14 Idaho 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.
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4.3. Wildfire Mitigation Cost Summary
From 2022–2025, Idaho Power estimates investing $46.8 million in incremental operations and
maintenance (O&M) expenses to further wildfire mitigation measures. The following table
summarizes the company’s planned expenditures associated with executing its WMP through 2025. Estimated amounts reflect the company’s best estimates and plans as of the 2022 WMP. These estimates will likely change in the future as the company reviews and refines its WMP and associated mitigation activities. For the 2022 WMP, each wildfire mitigation category—
and associated estimated expenditures in Oregon and Idaho—is discussed in Section 4.4.

2023 Wildfire Mitigation Analysis Framework

In 2022, Idaho Power reviewed the risk management process used in developing previous versions of the WMP. The review consisted of reexamining existing risk management practices, specifically how risk is analyzed, evaluated, treated, and continuous improvement is applied. We also benchmarked against other western utilities’ risk management approaches and consulted
with risk management professionals, both internal and external to Idaho Power.
A formalized risk management process will provide greater structure and consistency in decision making, continuous improvement, and maturing our analytical approach to balancing costs and mitigation benefits. As part of this work, the company determined that the international standard ISO 31000 is widely used by other utilities as a guide or foundation for their WMPs and was
recommended to be incorporated by risk management professionals. The ISO 31000 is one of
several guides to effective risk management and much of the processes used to create previous versions of the WMP align with the recommended practices found in the standard. However, the ISO 31000 provides a more comprehensive approach to risk management than what was being employed prior and will be integrated into the plan in 2023. This effort will start by
performing the following:
• Engage Idaho Power stakeholders to participate in risk review processes and activities with the goal that all employees become managers of risk
• Develop a comprehensive picture of all risk management activities associated with the
WMP and how they compare to the ISO 31000
• Determine how the ISO 31000 principles can be applied, achieved, measured, and tracked
• Develop a framework based on the ISO 31000 that provides a structured and effective
approach to managing wildfire-related risk and includes a process of reviewing and
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Table 6 Estimated system-wide incremental O&M expenses for wildfire mitigation, $000s (2023–2025)15

15 As of December 29, 2022.
2023 2024 2025
Idaho Power
System Total
2023 - 2025
Risk Map Updates 67$ -$ 69$ 136$
Weather Forecasting - System development and support 47$ 74$ 74$ 195$
Weather Forecasting Personnel - Fire Potential Index (FPI) and
Public Safety Power Shutoff (PSPS) 178$ 99$ 102$ 379$
Weather Forecasting - Weather Station Maintenance 19$ 24$ 30$ 73$
Pole Loading Modeling & Assessment (Contract service)75$ 75$ 75$ 225$
Cameras 165$ 220$ 220$ 605$
Tools/Equipment 5$ 5$ 5$ 15$
Mobile Weather Kits for Field Observers 10$ -$ -$ 10$
International Wildfire Risk Mitigation Consortium 40$ 40$ 40$ 120$
O&M Component of Capital Work 61$ 60$ 54$ 175$
Annual O&M T&D Patrol Maintenance Repairs 50$ 50$ 50$ 150$
Environmental Management Practices 25$ 25$ 25$ 75$
Transmission Thermography Inspection Mitigation - Red Risk Zone 20$ 20$ 20$ 60$
Distribution Thermography Inspection Mitigation - Red Risk Zones 30$ 30$ 30$ 90$
Thermography Technician Personnel 160$ 165$ 170$ 495$
Transmission Wood Pole Fire Resistant Wraps - Red Risk Zone 88$ -$ -$ 88$
Transmission Wood Pole Fire Resistant Wraps - Yellow Risk Zone 163$ 163$ 163$ 489$
Wildfire Mitigation Program Manager 191$ 196$ 202$ 589$
Covered Wire Evaluation - Pilot Program in PSPS Zones 50$ 50$ -$ 100$
Transition to/Maintain 3-year Vegetation Management Cycle 11,196$ 13,347$ 12,172$ 36,715$
Enhanced Practices for Distribution Red & Yellow Risk Zones (Pre-
Fire Season Patrols/Mitigation, Pole Clearing, Removals, Work
QA)1,284$ 1,349$ 1,416$ 4,049$
Line Clearing Personnel 159$ 164$ 169$ 492$
Fuel Reduction Program 75$ 75$ 75$ 225$
Vegetation Mgmt Satellite and Aerial patrols 150$ 300$ 300$ 750$
Wildfire/Wildfire Mitigation Education/Communication -
Advertisements, Bill Inserts, Meetings, Other 100$ 100$ 100$ 300$
PSPS Customer Education/Communication - Advertisements, Bill
Inserts, Other 71$ 71$ 71$ 213$
G. Information Technology
Communication/Alert Tool for PSPS Customer Alerts/Extended
Use 129$ 129$ 129$ 387$
14,608$ 16,831$ 15,761$ 47,200$
A. Quantifying Wildland Fire Risk
Forecast Incremental O&M Expenditures Total
B. Situational Awareness
C. Mitigation - Field Personnel Practices
D. Mitigation - Transmission & Distribution Programs
E. Vegetation Management
F. Communications
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4.4. Mitigation Activities
Idaho Power selected individual wildfire risk mitigation activities based on a variety of factors, including assessment of industry best practices in wildfire mitigation; discussions with peer utilities; consultation with government entities and agencies; and with consideration of alternatives that could be pursued.
Below is a narrative of each mitigation activity, its purpose, estimated near-term cost,
potential co-benefits of the activity to Idaho Power and its customers, and potential alternatives.
With respect to Idaho and Oregon cost estimates, the estimated costs identified below are grounded in cost assignment between the company’s Idaho and Oregon service areas and further informed by anticipated work in the two service areas.
4.4.1. Quantifying Wildland Fire Risk
Idaho Power’s assessment of wildland fire risk is discussed in Section 3 of this WMP.
The first step in developing Idaho Power’s WMP was to conduct a comprehensive assessment of the company’s service area and transmission corridors. The company worked with Reax Engineering, a consulting firm that specializes in wildfire risk modeling and fire science, to conduct Idaho Power’s wildfire risk analysis. The company determined that hiring an external consultant was beneficial for two reasons: (1) an external consultant was more cost effective than
hiring additional resources within Idaho Power to perform the modeling, and (2) an outside consultant helped ensure Idaho Power’s risk analysis approach was similar to its peer utilities.
An additional co-benefit of hiring an external consultant is aligning risk analysis with other utilities’ practices to create a basis for comparison of risk and also a standard terminology and methodology in discussing risk. Idaho Power deemed Reax Engineering a qualified consultant to
perform wildfire risk analysis based on the work it performed for the CPUC in developing the CPUC Fire Threat Map. Other utilities in Oregon, Idaho, Nevada, and Utah have utilized similar modeling approaches to identify and quantify wildfire risk.
Cost Estimate for Quantifying Wildland Fire Risk (2023–2025)
Idaho Power intends to re-evaluate its risk analysis using an external consultant on two more
occasions between 2023 and 2025. Idaho Power estimates system-wide expenditure for these services to be approximately is $136,000.
4.4.2. Situational Awareness—Weather Forecasting Activities and Personnel
Idaho Power discusses specific situational awareness practices in Section 5 of this WMP.
In developing the WMP, Idaho Power created a new Fire Potential Index (FPI) tool to support operational decision-making to reduce wildfire threats and risks. The tool takes data on weather,
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prevalence of fuel (i.e., trees, shrubs, grasses), and topography, and converts that data into an easily understood forecast of the short-term fire threat for different geographic regions in Idaho
Power’s service area. Additionally, Idaho Power plans to continue to enhance meteorological and
weather forecasting capabilities to further improve FPI forecasting and help determine when a Public Safety Power Shutoff may be necessary in Idaho Power’s service area.
The benefits of developing the FPI and enhancing the company’s meteorological forecasting capabilities is greater situational awareness of Idaho Power’s system during critical peak summer
months. To continue to generate useful information and system benefits, Idaho Power’s
situational awareness activities will be evaluated and updated annually as necessary to support the company’s wildfire preparedness.
The company considers the FPI and related efforts an essential part of reducing the risk of ignition from work activities. This provides Idaho Power field personnel would not have a tool to
assess the fire potential on a consistent basis. Given the distinct benefits that result from the FPI
and enhanced foresting capabilities, Idaho Power did not consider alternatives to the development of these critical tools.
Cost Estimate for Situational Awareness—Weather Forecasting Activities and Personnel (2023–2025)
The estimated expenditure for weather forecasting activities (weather forecasting tools,
system development, weather station maintenance, and personnel) is $647,000 between 2023 and 2025.
4.4.3. Situational Awareness—Advanced Technologies
Beginning in 2022, Idaho Power created a Technology Strategy Initiative team aimed at determining how new technologies and innovative practices can be incorporated into the company’s wildfire mitigation practices to further decrease wildfire risk. Technology-based
practices being considered include—amongst others—strategic use of cameras, satellite, and aerial imagery to detect vegetation hazards, pole loading modeling (to assess the structural integrity of poles), as well as covered conductors. With regard to cameras, the company is evaluating a pilot to test placement of cameras in strategic, high-risk locations to enhance situational awareness. Additionally, the company is learning more about artificial intelligence
and how it can be leveraged to detect wildfire ignitions. Multiple camera and analytics companies are being considered to determine potential cost-effective solution(s). The company is also working with local agencies to explore the possibility of partnering on the installation and ongoing use of cameras which may lead to reduced cost.
Cost Estimate for Situational Awareness—Pole Loading Modeling and Assessment (2023–2025)
The estimated system-wide expenditure to conduct pole loading modeling and assessment, which includes LIDAR assessment, is $225,000 for 2023 through 2025. Idaho Power plans to conduct the assessment in its highest risk zones, which are located exclusively in Idaho, as detailed in Table 4.
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Cost Estimate for Situational Awareness—Cameras (2023–2025)
The estimated system-wide expenditure for the pilot evaluation installation of cameras in
high-risk areas is $605,000 from 2023 through 2025. Idaho Power plans to prioritize the use of cameras in its highest risk zones, which are located exclusively in Idaho as detailed in Table 4.
4.4.4. Field Personnel Practices
Idaho Power discusses its field personnel practices in Section 6 of this WMP.
Idaho Power’s wildfire mitigation strategy includes procedural measures to reduce potential
ignition and spread of wildfires. Idaho Power developed a Wildland Fire Preparedness and
Prevention Plan (included as Appendix A to this WMP) to provide guidance to Idaho Power employees and contractors. The plan includes information regarding fire season tools and equipment available on the job site; daily situational awareness relative to 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 Idaho Power crews, and certain field personnel and contractors performing work on or near Idaho Power’s facilities are required to operate in accordance with the provisions of the Wildland Fire Preparedness and Prevention Plan and expected to conduct themselves in a fire-safe manner. They should be prepared for wildfire by carrying specific tools, including but not
limited to, shovels, Pulaskis,16 and water for initial suppression. Additionally, Idaho Power’s PSPS program (included as Appendix B to this WMP) includes employees acting as Field Observers to report on site conditions as part of the de-energization process. Field Observers are equipped with mobile weather kits that include wind meters, compasses, and satellite communication devices to report real-time conditions.
The preparedness of Idaho Power crews and contractors is critical to comprehensive wildfire risk reduction practices. The incremental investment in field personnel equipment is focused on additional tools carried by employees working in elevated risk zones. Additionally, Idaho Power will join the International Wildfire Risk Mitigation Consortium (IWRMC), a group whose mission is to share lessons learned, best practices, and innovation in the area of wildfire
mitigation. Many of Idaho Power’s utility peers are part of the consortium. The company is not aware of any other effort or group that provides a similar level of access or insight into global thinking and advancements in wildfire mitigation as the IWRMC.
Cost Estimate for Field Personnel Equipment (2022–2025)
The estimated system-wide expenditure for field personnel equipment (tools, mobile weather
kits, and participation in the IWRMC) is $145,000 between 2023 and 2025.

16 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.
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4.4.5. Transmission and Distribution (T&D) Programs for Wildfire Mitigation
Idaho Power’s T&D-related wildfire mitigation activities primarily involve expanded asset management programs and system hardening efforts, discussed in detail in Section 8.2 of this WMP. The narratives below provide insight into Idaho Power’s consideration and selection of
certain mitigation and hardening practices.
4.4.5.1. Annual T&D Patrol, Maintenance, and Repairs
Visual inspections are a critical component of T&D line-related wildfire mitigation efforts. On an annual basis, Idaho Power uses helicopters for visual aerial inspection of transmission lines that are Western Electricity Coordinating Council (WECC) path lines. Under the WMP,
Idaho Power will continue to use this method of line inspection for all transmission lines located
in Red Risk Zones. Idaho Power strives to complete these inspections prior to the start of the wildfire season; however, spring weather and snow levels may create access issues and delay the completion until June 15 in some areas.
Distribution lines that are located within RRZs are inspected on an annual basis to identify
‘Priority 1’ defects, or conditions that may result in an outage or potential ignition. The patrols
will be completed by personnel that have been trained in distribution line inspection procedures and have experience in distribution line construction. Targeted defects may include cracked/broken crossarms, avian nesting hazards, damaged equipment and hardware, floating conductors, NESC violations, and other obvious defects that pose an immediate threat
to the continued operation of the line. Similar to visual inspections for transmission lines,
Idaho Power will strive to complete distribution inspections prior to the start of each wildfire season; however, access issues may delay the completion until June 15 in some areas.
Helicopters are not practical for carrying out all distribution patrols due to greater population, structural, and vegetation density, so unmanned aerial vehicles (UAV) with high-definition
cameras are used to aid in these inspections in certain situations. These inspections allow
personnel to look for potential line defects that may not be obvious from the ground. Priority 1 defects are immediately reported and repaired as soon as possible.
The company will continue to explore the expanded use of UAVs, as the detailed images and data collected through high-resolution aerial inspections can provide several co-benefits,
including more granular data on vegetation growth and line and facility conditions.
Cost Estimate for Annual T&D Patrol, Maintenance, and Repairs (2023–2025)
The estimated system-wide incremental expenditure for annual T&D patrols, maintenance, and repairs is $150,000 from 2023 to 2025.
4.4.5.2. Thermography Inspections
While Idaho Power periodically conducts infrared thermography inspections as part of reliability
and maintenance programs, the company is expanding these inspections in Red Risk Zones on an
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annual basis. These inspections are conducted using hand-held and drone-mounted cameras with thermal-sensing technology and can help identify defects associated with the overheating of
equipment, connections, splices, or conductors.
As part of the thermography inspections, temperature gradients are analyzed to detect potential problems and issues found are prioritized based on their severity and repaired. Idaho Power recently created a new Thermography Technician position to carry out the inspections and coordinate repair activities, and additional resources may be added to perform this function
across more of Idaho Power’s service area if a single technician proves insufficient. To prioritize
the use and information gained from this technology, it will initially be employed only in RRZs. 2022 is the test year to determine how many inspections can be performed, and the overall cost-benefit of the technology to help evaluate the possibility of expanding use and adding more resources.
Thermography inspections are uniquely valuable in that they are able to uncover problems
undetectable to the naked eye. From the company’s perspective, there is not a viable alternative to this practice. The technology enables more proactive identification of potential issues than would otherwise be possible.
Cost Estimate for Thermography Inspections (2023–2025)
The estimated expenditure for thermography inspections is $645,000 from 2023 to 2025.
Idaho Power will prioritize the use of this mitigation practice in its highest risk zones, which are exclusively in Idaho, as detailed in Table 4.
4.4.5.3. Wood Pole Fire-Resistant Wraps
To help improve the resiliency of the company’s wood transmission poles, Idaho Power now
wraps them with a fire-resistant mesh in Red and Yellow Risk Zones. The mesh wrap helps
protect the integrity of the pole if it is exposed to fire and improves the resiliency of Idaho Power’s transmission system. An alternative to installing fire-proof mesh wrap is to replace wood poles with structures made of non-combustible material, such as steel. With 3,863 existing wood transmission poles in Idaho Power’s Red and Yellow Risk Zones, the cost of replacing all
wood poles is much higher than the cost of covering with a fire-resistant mesh.
Prior to developing the WMP, Idaho Power evaluated different products to determine the most cost-effective approach for protecting existing wood poles from fire. Several products were considered and trialed, including short-term spray-on and paint-on fire retardants, long-term retardants, and steel wraps. In 2020, the company evaluated a protective mesh wrap and
compared the cost and performance to the alternatives. The evaluation found that the mesh wrap
was approximately 53% less costly than the alternatives and offered the same level of risk reduction. The decision to use a mesh wrap product was not based solely on cost; other criteria were considered, including availability of the product, ease of installation, expected protective life span, and performance when exposed to fire. By all these measures, fire-resistant mesh was
the best solution.
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Cost Estimate for Wood Pole Fire-Resistant Wraps (2023–2025)
The estimated system-wide expenditure for applying fire-resistant mesh wraps to transmission
poles in Red and Yellow Risk Zones is $577,000 between 2023 and 2025.
4.4.5.4. Covered Conductor Pilot
Idaho Power’s Technology Strategy Initiative identified covered conductor as a potential mitigation measure to pilot. Benchmarking and feedback from other utilities highlighted the potential benefit of covered conductor as a mitigation measure. The company will conduct a pilot
of covered conductor through 2024 to explore the benefits, tooling requirements for field
personnel, and design parameters. While covered conductor may reduce the risk of wildfire, the company will analyze potential co-benefits, including improved reliability outside of wildfire season and reduced outage restoration costs.
Cost Estimate for the Covered Conductor Pilot (2023–2024)
The estimated cost of the pilot is $100,000 from 2023–2024. While this pilot will take place in
Idaho, the lessons from it will extend across the company’s service area.
4.4.6. Enhanced Vegetation Management
Idaho Power’s enhanced vegetation management practices are discussed in detail in Section 8.3 of this WMP.
In the initial stage of developing its WMP, Idaho Power conducted an analysis to determine the most likely sources of ignition across the company’s service area. Reliability data revealed
vegetation contact as one of the most common causes of outages on Idaho Power’s system. With the goal of eliminating potential ignition sources and to reduce risk, enhanced vegetation management was recognized as a critical aspect of Idaho Power’s WMP.
To prioritize risk reduction from vegetation contact, Idaho Power determined it would move to a three-year pruning cycle and apply enhanced vegetation management practices in Red and
Yellow Risk Zones. These enhanced practices include pre-fire season vegetation patrols, more targeted pole clearing and vegetation removal, and additional quality assurance for vegetation management practices.
The company considered other vegetation management alternatives, 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 (known as “just-in-time trimming”). Each alternative presented challenges or resulted in negative impacts that undermined any potential benefits.
While shorter trimming cycles result in less vegetation being removed during each trimming cycle, this practice costs more due to the need for more resources and more frequent trimming
of trees near the power lines. In contrast, longer cycles result in less frequent trimming of each tree but larger amounts of vegetation that must be removed to maintain larger clearance
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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. In 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, “just-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 alternative approaches, Idaho 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.
Moving forward with a three-year cycle and performing the additional activities detailed above will involve a sizeable increase in incremental O&M expenditure. An alternative to enhancing Idaho Power’s vegetation management program is to convert overhead distribution circuits to
underground. While undergrounding is used in certain circumstances, undergrounding has
generally not been determined to be a cost-effective expense relative to enhanced vegetation management. That said, the company continues to evaluate and implement underground solutions, as appropriate, as part of its WMP hardening efforts detailed below.
Although vegetation management is a sizeable increased wildfire mitigation expense,
performing this work is expected to have notable co-benefits, including reduced
vegetation-caused outages in Red and Yellow Risk Zones. Idaho Power plans to monitor performance and outage metrics to confirm the success of the enhanced program.
Decreasing vegetation outages was considered one of the most important, cost-effective measures Idaho Power could take to reduce the likelihood of an ignition event and protect utility
infrastructure. Shifting vegetation management practices was deemed a prudent course of action
based on the number of potential outages or ignition sources that may be eliminated. It is also the approach that has been adopted by many of Idaho Power’s peer utilities.
Additionally, the company will participate in a regional fuel reduction program, in which Idaho Power will work in partnership with the Idaho Department of Lands, the National Forest
Foundation, the U.S. Forest Service, and the U.S. Bureau of Land Management to remove hazard
trees and other vegetation from utility rights-of-way. The partnership is designed to enhance forest resilience to wildfire, decrease hazardous fuel accumulations, increase powerline resiliency while minimizing the risk of ignitions, and improve forest conditions in the vicinity of Idaho Power infrastructure. This program is similar to what other western utilities have
taken part in and is modeled after projects performed in Washington, California, Colorado,
and Arizona. Participation in the effort is estimated to cost $225,000 through 2025.
The company also plans to deploy satellite and aerial patrols of vegetation in the company’s wildfire risk zones. The technology used in these satellite and aerial patrols will help identify encroachment and clearance issues in areas that are growing faster than expected and hazard
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trees that have the potential of falling into powerlines. Data collected through this technology may reshape the company’s vegetation management strategy and shift from a systemwide
cycle to a more targeted approach that identifies and focuses on high-growth vegetation areas.
The company will conduct limited vegetation-focused satellite and aerial patrols in 2023 before expanding to a larger area in 2024 and 2025, pending outcomes from the pilot program years. The company estimates spending $750,000 on this technology through 2025.
Cost Estimate for Enhanced Vegetation Management (2023–2025)
The estimated system-wide expenditure for enhanced vegetation management is $41.3 million
from 2023 to 2025.
4.4.7. Communications and Information Technology Customer
Notification Enhancements
Idaho Power’s efforts to communicate with customers and the public about wildfire and
mitigation are discussed in detail in Section 10 of this WMP.
Idaho Power considers communication a vital part of its wildfire mitigation efforts. Customer and public awareness and education are a vital part of ensuring that the communities
that Idaho Power serves are protected and safe from the threat of wildfire. New communication
expenses related to customer and community educational outreach include advertisements, printed media, social media, and public meetings. The purpose of these communications is to keep customers aware of mitigation and fire-related activities before, during, and after fire season. Additionally, the company is building out communication systems to be able to alert
customers more quickly and easily about wildfire events and outages, including potential
PSPS events.
Cost Estimate for Communication and Customer Notification Enhancements (2023–2025)
The estimated system-wide expenditure for communication expenses is $513,000 and $387,000 for customer notification system enhancements, totaling $900,000 from 2023 to 2025.
4.4.8. Incremental Capital Investments
Idaho Power’s wildfire mitigation efforts include capital investments in system hardening
practices including approaches deployed after internal testing and analysis, many of which also provide co-benefits to the company.
Idaho Power’s capital investments for wildfire mitigation are discussed in detail in Section 8.2 (T&D Asset Management Programs) of this WMP.
4.4.8.1. Circuit Hardening and Infrastructure Upgrades
Idaho Power estimates spending $5.1 million annually through 2025 on circuit hardening and
infrastructure upgrades across its system.
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Idaho Power’s WMP includes an overhead distribution hardening program for Red Risk Zones. The program includes systematic replacement of hardware, equipment, and materials to improve
safety and reliability and reduce ignition risk. The first five years of the program are focused on
circuits in Red Risk Zones, but it may be expanded to Yellow Risk Zones in the future. The company will review hardening outcome metrics annually to determine the benefit of the program and to determine whether to expand the program after 2025.
Prior to developing its WMP, Idaho Power successfully implemented many of the same
hardening measures detailed below as part of the company’s reliability program. Outage data and
analytics showed that customer outages were reduced by approximately 38% in areas where hardening projects were carried out. With the success of reducing outages, some of these same activities to increase reliability were chosen to be part of the WMP to help reduce ignition potential in Red Risk Zones. Enhanced system hardening efforts include installation of fire safe
fuses, Spark Prevention Units, and fiberglass crossarms.
All the hardening activities and equipment identified in this program were evaluated by patrolmen, troublemen, reliability engineers, and the company’s Methods and Materials department to determine cost-effective solutions that balance overall costs with expected risk reduction.
As an alternative to conducting circuit hardening upgrades, the company considered converting
overhead distribution circuits to underground. While underground conversions are used in certain circumstances, the cost is estimated to be 2–10 times higher than the cost of carrying out hardening work. In general, overhead hardening efforts provide the benefit of being able to impact a greater number of circuit miles and customers in a shorter time horizon with less
investment than undergrounding. Idaho Power will continue to evaluate underground
opportunities as part of overall system hardening efforts.
The following summarizes the incremental capital investments the company is making to harden its system and further reduce wildfire risk:
Wood Pole Replacement—The company will replace wood poles if field evaluations
determine that significant deterioration or damage has occurred since the last inspection or
treatment. Poles are inspected above the groundline to determine strength and climbability. Poles identified as “rejects” will be replaced. Furthermore, poles having wood stubs/structural reinforcements are changed out pursuant to current practices.

Fuse Replacements—Expulsion fuses located in Red Risk Zones will be changed out with energy-limiting and power fuses. Fuse applications include overhead transformers, line taps, risers, and capacitor banks. In 2018, Idaho Power began exploring different fusing technology to replace expulsion fuses with non-expulsion fuses. Three different fuse types
were considered and subsequently piloted. The pilot was used to determine the performance
of each fuse type, installation requirements, and coordination characteristics. Financial analysis included the cost of each fuse along with associated cutout and hardware and helped determine the most cost-effective option. This information was used to evaluate non-expulsion fuses. Replacement of all expulsion fuses in Red Risk Zones is expected to take
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approximately three years at a cost of approximately $1.9 million. Because this work will be conducted in Red Risk Zones, the company does not anticipate replacing fuses in Oregon at
this time.
Spark Prevention Units—Porcelain arresters used for overvoltage protection will be changed out with arresters utilizing Spark Prevention Units (SPU). The SPU acts to eliminate the potential of catastrophic failure during arrester operation. This work includes all
distribution arresters located on primary distribution lines in Red Risk Zones. In 2019, Idaho
Power piloted new arrester technology to determine performance characteristics, installation requirements, and potential benefits in reducing ignition risk. As part of the pilot, Idaho Power compared different manufacturers with similar technology and conducted performance analysis to determine the most cost-effective solution. Replacement of the
arresters is expected to take approximately three years to complete and will cost
approximately $1.7 million. Because this work will be conducted in Red Risk Zones, the
company does not anticipate replacing arrestors in Oregon at this time. Fiberglass Crossarms—Idaho Power began piloting fiberglass crossarms in 2018 to
determine potential cross-functional benefits associated with fiberglass. The pilot focused on
cost, ease of installation, strength, supply availability, and reduced potential for tracking of electrical current. Tracking is known as the flow of current over an insulator, which can generate heat. The company compared different crossarm types and manufacturers and determined that fiberglass was most cost effective when considering up-front capital and
installation costs. The pilot program, along with benchmarking of peer utilities, helped
determine that fiberglass crossarms provided a number benefits relative to improved safety and reliability. Therefore, Idaho Power’s hardening program includes the installation of both tangent and dead-end fiberglass crossarms in Red Risk Zones. However, Idaho Power does not intend to replace all wood crossarms with fiberglass immediately. As part of the fielding
phase, company distribution designers will assess wood crossarms and initially change those
showing signs of defects or damage. Identified crossarms utilizing wood pins will also be replaced with fiberglass. This approach will spread the cost out over time and help reduce the upfront cost of the program.
Small Conductor—In the early stages of developing the WMP, Idaho Power considered the
possible risk associated with small conductor and the potential for breakage. As a result of this exercise, the company’s WMP hardening program includes the replacement of overhead distribution conductor that meets certain criteria which includes approximately 60 miles in Red Risk Zones. Conductor losses were analyzed and showed that replacing the conductor
will result in an approximately 50% reduction of line losses, resulting in co-benefits for the
company and customers in terms of greater reliability and line loss improvements. Porcelain Switches—Idaho Power’s Outage Management System and feedback from field personnel revealed potential benefits of switches made of material other than porcelain.
Therefore, porcelain switches installed in Red Risk Zones will be changed out with cutouts
featuring Ethylene Propylene Diene Monomer Rubber (EPDM). Idaho Power’s Methods and Materials Department trialed different cutout switches made up of different material, including silicone and polymer, to determine the most cost-effective solution. The results of
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the trial highlighted the potential for avian issues with silicone (i.e., ravens tended to eat the silicone), and the cost of EPDM versus polymer was nearly equivalent. The financial analysis
determined that EPDM would preserve the integrity of the insulator body, prevent outages,
and provide an estimated savings of $10,798 per year over silicone. Avian Protection—Idaho Power employs several different protection measures to protect wildlife on existing structures including but not limited to covers, insulated conductor,
diverters, perches, nesting platforms, and structural modifications. The company has an
extensive history working with manufacturers of animal guards/covers and regularly seeks new solutions for avian issues to prevent mortalities, increase reliability, and eliminate other risks. The company’s Avian Protection Plan (APP) was developed in the mid-2000s and many of the practices identified in the APP are used for wildfire mitigation in Red and
Yellow Risk Zones. For example, new wildlife guards were recently developed and installed
in conjunction with the installation of new power fuses and SPUs. Idaho Power consulted with different manufacturers to develop new products that would accomplish the dual goals of avian protection and wildfire mitigation. The best solution is determined on a case-by-case basis depending on the specific location, the type and extent of avian presence, and other
relevant factors.

4.4.8.2. Overhead to Underground Conversions
Another aspect of Idaho Power’s system hardening program is the select conversion of overhead to underground distribution lines in Red Risk Zones. In 2022, the company will convert 1.5 miles
of overhead distribution lines to underground lines. In 2023 and beyond, the company will work
to build a strategic undergrounding program to weigh the cost-benefit of undergrounding versus other circuit hardening measures. While underground distribution lines offer benefits associated with being less exposed to the elements and external forces, conversion may not be possible, advisable, or economical in certain situations. The company will continue to evaluate the
feasibility of underground conversions as well as the relative value and cost effectiveness as part
of the WMP.
4.4.8.3. Transmission Steel Poles
In 2021 and as part of its WMP, Idaho Power revised its transmission construction standards to utilize steel poles and structures for new line construction built to 138 kV and above in elevated
wildfire risk zones. This change is intended to minimize the potential for wildfire damage,
improve transmission line resiliency, and increase reliability for customers. Wood poles continue to be accepted and used in the industry, and the company will still utilize wood poles in many transmission system applications in consideration of the availability of steel poles, the specific engineering, right-of-way, permitting, and scheduling requirements for each project.
In addition, wood poles will continue to be the standard construction practice for transmission
line voltages below 138 kV unless a different material is needed to meet specific engineering or planning requirements. As discussed above, Idaho Power will wrap wood poles located in Red and Yellow Risk Zones with fire-proof mesh.

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5. SITUATIONAL AWARENESS
5.1. 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 area. Idaho Power leverages
its internal atmospheric science 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 area. This wildfire potential information is then available to operations personnel to factor into their operational decision-making.
5.2. Fire Potential Index
Idaho Power has developed an 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 area. 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 area. 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 area (“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 of which expresses the degree of fire threat expected
for each of the 7 days included in the forecast. The FPI scores are grouped into the following index levels:
• Green: FPI score of 1 through 11 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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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 fire using the following equation:
FC = FD / LFM
Where FC represents Fuels Component in the scale below, FD represents 10-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-Performance Computing (HPC) system. In addition to the HPC system produced WRF data, several national level
Normal Elevated High
FPI Range 1 to 11 12 to 14 15 - 16
Fire Potential Index (FPI) Category
NDVI
Very
Wet/Lush:
1.00 to 0.65
0.64 to 0.60 0.59 to 0.55 0.54 to 0.50 0.49 to 0.40
Very
Dry/Cured
0.39 to 0.00
Score 0 1 2 3 4 5
Green-Up Component
Very Wet Very Dry
0 1 2 3 4 5
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meteorological products will be used. These products will include regional weather observations used to validate model information.

5.3. FPI Annual Process Review
The FPI process will be reviewed annually after completion of the fire season and, with consultation of interested parties (e.g., Load Serving Operator, Line Crews, and others), will be
updated to enhance Idaho Power’s wildfire preparedness.

Dewpoint
Depression/Wind ≤5 mph 6 to 11 mph 12 to 18 mph 19 to 25 mph 26 to 32 mph ≥33 mph
≥50ºF 4 4 4 5 5 6
40ºF to 49ºF 3 3 4 4 5 5
30ºF to 39ºF 3 3 3 4 4 5
20ºF to 29ºF 3 3 3 3 3 4
10ºF to 19ºF 2 2 2 2 2 3
˂10ºF 0 1 1 1 1 2
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6. MITIGATION—FIELD PERSONNEL PRACTICES
6.1. Overview
A component of Idaho Power’s wildfire mitigation strategy is to prevent the accidental ignition and spread of wildfires due to employee work activities. Idaho Power developed the Wildland Fire Preparedness and Prevention Plan (Appendix A) to provide guidance to Idaho Power
employees and contractors to help prevent the accidental ignition and spread of wildfires due to company work activities in locations and under conditions where wildfire risk is heightened. All Idaho Power crews and certain field personnel performing work on or near Idaho Power’s facilities are expected to operate in accordance with the Plan and continue to conduct themselves in a fire-safe manner.
6.2. Wildland Fire Preparedness and Prevention Plan
The Wildland 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
• Daily situational awareness regarding locations of heightened potential for fire risk and weather conditions in those areas
• Expected wildfire ignition prevention actions while working and reporting instructions in
the event of fire ignition
• Training and compliance requirements

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7. MITIGATION—OPERATIONS
7.1. 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:
• Temporary operating procedures for transmission lines during the fire season17
• An operational strategy for T&D lines during time periods of elevated wildfire risk during the fire season
• A PSPS strategy for Idaho Power’s service area and transmission corridors
7.2. Operational Protection Strategy
Operational protection strategies were developed to reduce the probability of ignition during
fault events on Idaho Power’s transmission and distribution system. Analysis was performed by
Reliability Engineers to assess the available fault energy under different protection schemes and configurations and the effect each would have on customers in terms of increased and extended outages. Idaho Power analyzed the following configurations for automatic reclosing devices:
• Reclose off
• Limited energy reclose
• Limited energy lockout
The analysis performed included assessing Time Current Curves and fault energy of different
circuits to gauge the overall reduction in energy between different protection configurations and coordination challenges. Figure 13 below summarizes the different protection configurations evaluated along with estimated benefits in terms of reduced fault energy and impacts to customers. At this time, reclose off appears to provide the best balance between reducing fire
ignition risk and customer reliability impacts.
This analysis, along with consideration of historic outage events associated with reclose off, led to the determination that enhanced protection strategies were warranted only in RRZs due to their higher level of wildfire risk. Idaho Power plans to evaluate the effectiveness of protection strategies and will work to mature in this area. New advancements in relay protection used to decrease wildfire risk were evaluated in 2022. The company plans to further our understanding

17 The duration of the fire season will be reviewed and defined annually.
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of their capabilities and integration into existing relay apparatus by testing new algorithms and schemes as part of the company’s wildfire technology roadmap from 2024 through 2028.

Figure 13 Comparison of reclosing strategies with respect to customer reliability and wildfire risk
7.3. Transmission Line Operational Strategy
7.3.1. Fire Season Temporary Operating Procedure for Transmission Lines
Each year, typically in May, leadership within Idaho Power’s Load Serving Operations (LSO) department 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 fire season. The procedure aims to reduce wildfire risk
through practices relating to information collection, notification, and procedures for testing/closing in on locked-out transmission lines.
7.3.2. Red Risk Zone Transmission Operational Strategy
During wildfire season, Idaho Power determines a daily FPI as described in Section 5 of this WMP. The FPI informs the transmission line operational strategy for those lines owned, operated, and located in RRZs. These lines will be operated in normal settings mode but with no
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“testing”18 of a line that may have “locked out” during the time of a red FPI. Essentially, in the event of a fault on the specified transmission line(s) during a 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 wait until the FPI level drops out of the red category prior to being reenergized.
7.4. Distribution Line Operational Strategy
7.4.1. Red Risk Zone Distribution Operational Strategy
During wildfire season, Idaho Power determines a daily FPI as described in Section 5 of this
WMP. The FPI informs the distribution line operational strategy for those lines located in the wildfire RRZs. These lines will be operated in a non-reclosing19 state during the time of red FPI. Essentially, in the event of a fault on the specified distribution line(s) during the red FPI, the line(s) will be automatically de-energized with no reclosing attempts until either the line(s)
has been patrolled or the FPI level drops out of the red category.
7.5. Public Safety Power Shutoff
7.5.1. PSPS Definition
PSPS, as used in this WMP, is defined as the proactive de-energization of electric transmission and/or distribution facilities during extreme weather events to reduce the potential of those
electrical facilities becoming a wildfire ignition source or contributing to the spread of wildfires.
The concept is as follows: if significant weather events can be predicted far enough in advance, the resulting proactive line de-energization before the forecasted weather conditions materialize could mitigate the risk of a wildfire. A PSPS event has significant customer impact and requires significant planning.
PSPS is not the practice of de-energizing lines in the following types of situations:
• Unplanned de-energization of lines required for emergencies and during outage restoration situations.
• Planned line or station work activities that require a planned outage (Idaho Power
currently has a planned outage customer notification process in place for this).
• Reactive de-energization of electric transmission and/or distribution facilities, which may be either at Idaho Power’s determination or at the request of fire managers (e.g., BLM,

18 Transmission line “testing” refers to the human act of re-energizing a line without completing a physical field
patrol or observation of a line.
19 Distribution line “non-reclosing” refers to the deactivation of automatic re-energization of a distribution line or use of a non-reclosing device such as a fuse.
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U.S. Forest Service, or other fire-fighting managers) in response to existing/encroaching wildfire threatening to burn into such facilities.
• Automated de-energization of electric transmission and/or distribution facilities due to smoke/fire from an existing fire causing a fault on the line.
Idaho Power will continue its current de-energization practices in the above referenced, and comparable situations. Such outage situations are not defined as PSPS events in the context
used here and, as a result, would not trigger PSPS protocols.
7.5.2. PSPS Plan
Idaho Power developed a PSPS Plan (see Appendix B) that operates in parallel with its wildfire mitigation strategy. Although the wind patterns in Idaho Power’s service area are generally of a much lower sustained velocity and often less predictable (i.e., micro-bursts) than other utilities’ service areas where PSPS has most frequently been utilized (i.e., California), the company’s PSPS Plan generally follows industry best practices by considering other utilities’ PSPS plans
and incorporating input from Idaho Power’s external consultant, discussed in 3.2 above, which developed the company’s WMP risk maps.
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8. MITIGATION—T&D PROGRAMS
8.1. Overview
Idaho Power’s wildfire mitigation strategy relies in part on its various asset management programs and vegetation management program to maintain safe and reliable operation of its T&D facilities in reducing wildfire risk.
8.2. T&D Asset Management Programs
In addition to maintaining a number of existing and newly implemented robust asset management programs intended to reduce wildfire risk, 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 supporting wildfire prevention and mitigation are summarized in the table below.
Table 7 Summarized T&D asset management programs (associated with the WMP)
Transmission
Transmission Asset Management Programs
Aerial Visual Inspection Program
Ground Visual Inspection Program
Detailed Visual (High Resolution Photography) Inspection Program
Wood Pole Inspection and Treatment Program
Cathodic Protection and Inspection Program
Thermal Imaging (Infra-Red) Inspections
Wood Pole Wildfire Protection Program (enhanced)
Steel Pole (Structures) (enhanced)
Distribution
Distribution Asset Management Programs
Ground Detail Inspection Program (enhanced)
Wood Pole Inspection and Treatment
Wood Pole Fire Protection Program (enhanced)
Line Equipment Inspection Program
Thermal Imaging (Infra-Red) Inspections
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
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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
Install avian cover
Relocate arresters
Install bird/animal guarding
Update capacitor banks
Replace swelling capacitors
Replace oil-filled switches with vacuum style
Replace porcelain switches with polymer switches
Install disconnect switches on CSP transformers
Install avian cover
Update down guys
Replace/Install down-guy insulators with fiberglass insulators
Tighten down guys
Tighten hardware
Correct 3rd party pole attachment clearances (report to Joint Use Department)

Idaho Power has a robust and proven inspection and correction strategy and schedule. Current practices will continue in YRZs. Risk quantification and modeling performed shows that
RRZs have a higher level of risk from wildfires so, in addition to its current practices,
Idaho Power believes it is prudent to add an annual inspection to minimize the likelihood of a wildfire ignition as well as targeted infrared inspections in select RRZs to identify any potential issues that may not be apparent on visual inspection. As part of the ISO 31000 risk management process, Idaho Power plans to evaluate the effectiveness of inspection and correction activities
and schedules and further grow in this area as wildfire risk evolves. The following table
summarizes inspection work performed and inspection frequency with respect to wildfire risk zones.

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Table 8 Summary of asset inspections and schedules by state and zone
Inspection Interval
Asset Inspection Type Idaho Non- Risk Zone Oregon Non- Risk Zone Idaho YRZ Oregon YRZ Idaho RRZ

Visual Annually Annually Annually Annually Annually
Detailed 10 Years 10 Years 10 Years 10 Years 10 Years
Groundline (Wood Pole Test and Treat) 10 Years 10 Years 10 Years 10 Years 10 Years
Wildfire Mitigation Patrol None None None None Annually
Infrared Patrol None None None None Annually

Visual/Detailed 3 Years 2 Years 3 Years 2 Years 3 Years
Groundline (Wood Pole Test and Treat) 10 Years 10 Years 10 Years 10 Years 10 Years
Wildfire Mitigation Patrol None None None None Annually
Infrared Inspections None None None None Targeted

8.2.1. Transmission Asset Management Programs
Several of Idaho Power’s transmission management programs have been in place for decades
and include condition-based aerial visual inspections, ground visual inspections, detailed visual (generally using high-resolution photography) inspections, transmission wood pole inspection and treatment, 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.
8.2.1.1. Aerial Visual Inspection Program
Annually, Idaho Power uses helicopters to assist Idaho Power qualified personnel in the visual aerial inspection of transmission lines identified as WECC Path Lines. This method of line inspection is now used for transmission lines located in the RRZs. In addition, unmanned aerial
vehicles with high-definition cameras are now used in certain situations to inspect facilities on
these lines. These inspections allow personnel to look 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:
• Priority 1: Defects that, depending on the circumstances, require reporting and repair as soon as reasonably possible.
• Priority 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
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corrective plan within 24 months will be reviewed by the T&D vegetation and maintenance engineering leader.
• 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 1 and 2 defects are determined by engineering personnel for
each prioritized defect and are scheduled and repaired.
8.2.1.2. Ground Visual Inspection Program
Annually, Idaho Power qualified personnel (i.e., trained in transmission line inspection procedures and experienced in transmission line construction) complete ground visual inspections of all transmission lines. Ground patrols are completed using four-wheel-drive
vehicles, all-terrain vehicles, utility terrain vehicles, and/or on foot. These inspections identify
potential line defects that are noted and scheduled for repair following the same process as described in 8.2.1.1.
8.2.1.3. Detailed Visual (High-resolution Photography) Inspection 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 vehicles, 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 8.2.1.1. The detailed inspections are completed on a 10-year cycle in conjunction with the 10-year cycle of wood pole ground line
inspection and treatment (see 8.2.1.4).
8.2.1.4. Wood Pole Inspection and Treatment Program
All wood poles are visually inspected, sounded, and bored for defects and decay on a 10-year cycle. The poles are categorized according to the following:
• Reported: Any wood pole inspected and found to be installed within 10 years of the
manufactured date or last inspection date.
• 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 treatment.
• 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 than 2 inches of shell at 15 inches above the ground line; and/or
o Less than 2 inches of shell at the ground line; or
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o Is deteriorated and does not meet minimum strength criteria; or
o Fails a visual inspection.
Rejected poles are categorized as: reinforceable with steel, non-reinforceable and are to
be replaced.
• Visually Rejected: Any wood pole that has been damaged (i.e., burned, 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.
• 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. Internal treatment involves fumigating the good wood and flooding the voids with fumigant.
8.2.1.5. Cathodic Protection and Inspection Program
Cathodic protection systems are employed on select steel transmission towers. These systems use either an impressed current corrosion protection system (ICCP) or direct-buried sacrificial magnesium anodes. Included in Idaho Power’s tower maintenance plan, every 10 years, structure-to-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.
8.2.1.6. 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 in 8.2.2.1 of this WMP.
8.2.1.7. Wood Pole Wildfire Protection Program
Idaho Power has utilized numerous technologies to minimize the damage to wood poles that
have been exposed to wildfires. The current technology of “mesh wraps” is utilized on transmission wood poles located in the RRZs and YRZs.
8.2.1.8. Transmission Steel Poles
Idaho Power will utilize steel poles or structures for new transmission line construction projects built to 138 kV standards and above in an attempt to minimize wildfire damage and improve
transmission line resilience. Wood poles may be used on 138 kV structures for emergency and maintenance replacements based on the specific engineering, right-of-way, permitting, and scheduling requirements for each project. Wood construction is used for voltages below 138 kV unless a different material is needed to meet specific engineering or planning requirements.
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8.2.2. Distribution Asset 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 also has an enhanced overhead distribution “hardening” program to implement in the RRZs. Examples of specific work include replacement of small conductors and associated hardware and replacement of wooden pins and associated wooden crossarms.
8.2.2.1. Ground Visual Inspection Program
Annually, qualified line patrol personnel (trained in distribution line inspection procedures and experienced in distribution line construction) complete visual wildfire mitigation inspections of the distribution lines located in the RRZs to identify Priority 1 defects and those that may cause an outage or possible ignition. The ground patrols are completed using four-wheel-drive vehicles, all-terrain vehicles, utility terrain vehicles, or on foot. These inspections identify
potential line defects that are noted and scheduled for repair. Detailed distribution inspections are completed on a predetermined schedule and may be performed in conjunction with annual visual inspections.
All noted defects are prioritized as Priority 1, Priority 2, or Priority 3, based on the criteria listed below:
• Priority 1: Defects that, depending on the circumstances, require reporting and repair as soon as reasonably possible.
• Priority 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.
• 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 1 and 2 defects are determined by engineering personnel for each prioritized defect and are scheduled and repaired.
8.2.2.2. Wood Pole Inspection and Treatment Program
All wood poles are visually inspected, sounded, and bored for defects and decay. The procedure
is noted in 8.2.1.4.
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8.2.2.3. Line Equipment Inspection Program
Line equipment in wildfire risk zones, including capacitor banks, automatic reclosing devices,
and regulators, are inspected annually prior to wildfire season by line operations technicians.
The inspection includes a visual inspection and, when electronic controls are present, data is retrieved and analyzed for proper operation.
8.2.2.4. 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 in 8.2.2.1 of this WMP.
8.2.2.5. 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 7 drives the program work.
Notable criteria are further explained in the following sections of this WMP.
8.2.2.5.1. Conductor “Small” Replacement
Idaho Power is implementing 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,
6-3SS, 8A, 8A CW, 9IR, etc. These small conductors will be replaced with standard larger
conductors, primarily with 4ACSR conductor.
8.2.2.5.2. 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 program. And, whenever work is being completed on a structure that requires
replacement of wooden crossarms, Idaho Power will, generally, install fiberglass crossarms.
8.2.2.5.3. Porcelain Switch Replacement
Porcelain switches located in the RRZs will continue to be replaced with polymer switches. Additionally, associated hot clamps and stirrups will be replaced. This work will be coordinated
and included in the overhead primary hardening program.
8.2.2.5.4. Fuse Options
Idaho Power investigated reasonable alternatives to replace certain expulsion fuses and expulsion arrestors. A pilot program was initiated in 2020 to replace several expulsion fuses with
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non-expulsion fuses in the vicinity of the Boise foothills. This pilot program was successful and Idaho Power implemented a subsequent program to replace expulsion fuses with non-expulsion
fuses in RRZs as a part of its distribution overhead primary wildfire hardening program.
8.2.2.5.5. Wood Pole Wildfire Protection Program
Idaho Power has utilized numerous technologies to minimize the damage to wood poles that have been exposed to wildfires. The current technology of “mesh wraps” is utilized on certain distribution wood poles located in the RRZs.
8.3. 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.
Table 9 VMP summary
Vegetation Management
Transmission
Pre-Fire Season Inspection and Mitigation
Line Clearing Cycle Goal: 3-year cycle for valley areas & 6-year cycle for mountain areas
Tree Removals - Hazard Trees
Targeted Pole Clearing
100% Quality Assurance/Quality Control Auditing in RRZs and YRZs
Distribution
Pre-Fire Season Inspection and Mitigation
Line Clearing Cycle Goal: 3-year cycle in all areas with mid-cycle pruning occurring in 2nd year in RRZs and YRZs*
Tree Removals - Cycle Busters/Hazard Trees
Targeted Pole Clearing
100% Quality Assurance/Quality Control Auditing in RRZs and YRZs
*Distribution line clearing cycles vary by utility. Idaho Power has set a goal of achieving a 3-year cycle of distribution line clearing.
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Vegetation contact with energized powerlines is a cause of outages and potential source of ignition for wildfires. Idaho Power’s transition to a sustainable three-year pruning cycle will help
reduce wildfire risk across the company’s service area. In non-wildfire risk zones,
distribution feeders and valley-located transmission lines will be patrolled and pruned on a three-year cycle. A six-year cycle will continue to be employed for transmission lines in mountain locations. Specific to each tree pruned, directional pruning methods will be employed where cuts will meet ANSI A300 standard and adequate clearance will be obtained
that should accommodate regrowth without violating the prescribed minimum clearance
throughout the cycle.
Reliability data has shown that vegetation contact is one of the most likely sources of faults and possible ignition on the system. As a result, Idaho Power employs the same enhanced vegetation management practices in both YRZs and RRZs despite the different levels of wildfire
risk. These practices include mid-cycle patrols and pruning in the second year of the cycle to
address “cycle buster” trees and annual “hotspot” patrols to address any new hazard trees or unexpected vegetative growth that poses an immediate threat of contact with energized facilities. In addition, the company strives to complete audits for all pruning work performed in YRZs and RRZs, regardless of reason for the pruning. The audits confirm that pruning cuts meet
the specification and proper clearance was obtained. The following table summarizes vegetation
management activities with respect to wildfire risk zones.
Table 10 Summary of vegetation management activities and schedules
Vegetation Management Inspection Interval
Inspections and Activity Schedule Idaho Non-Risk Zone Oregon Non-Risk Zone Idaho YRZ Oregon YRZ Idaho RRZ
Hazard Tree Patrol Annually Annually Annually Annually Annually
Cycle Patrol/Pruning—Valley
Cycle Patrol/Pruning—Mountain
Distribution
Quality Assurance (Transmission and
Post-Pruning Audit Inspections Sampling Sampling 100% 100% 100%

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8.3.1. 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.
Hazard Tree—Any 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. Hazard trees will be further defined as posing either a medium hazard or 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—T&D clearing of lines defined on a periodic basis.
8.3.2. Transmission Vegetation Management
Maintaining a zone near transmission lines that is free of vegetation has long been a priority for
Idaho Power. The clearance zone is voltage-level dependent and defined by federal and state regulations.
8.3.2.1. Transmission Vegetation Inspections
Utility arborists annually conduct aerial and/or ground patrols on each applicable transmission
line to identify and mitigate vegetation hazards. In addition, transmission patrol personnel
inspect all applicable transmission lines once a year to identify any transmission defects and vegetation hazards. During these inspections, the patrol personnel will identify hazardous vegetation, within or adjacent to the Right of Way (ROW), that could fall in or onto the transmission 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, 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 operator. The utility arborist will conduct a follow-up inspection if potential hazard trees or
grow-ins are identified. The utility arborist prioritizes and schedules any remedial action for all
reported vegetation issues.
8.3.2.2. Transmission Line Clearing Cycles
Transmission lines will be cleared on long-term cycles based on 3 years for urban and rural valley areas and 6 years for mountain areas. However, shorter clearing cycles may occur if
conditions dictate out-of-cycle trimming. In most cases, vegetation is cleared primarily through
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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
treatments are applied as effective techniques for reducing re-growth of sprouting deciduous
shrubs and trees and extending maintenance cycles.
8.3.2.3. Transmission Line Clearing Quality Control and Assurance
In non-wildfire risk zones, audits are performed on a random sample of pruning worksites. These audits are performed through a combination of the contracted arborists that
planned the work and Idaho Power’s utility arborists. Due to the elevated risk of wildfire in
YRZs and RRZs, audits will be performed on pruning work performed in YRZs and RRZs regardless of the reason for the patrols and pruning. The audits will be performed by a combination of contracted arborists and Idaho Power’s utility arborists to check whether pruning cuts meet specification and proper clearance was achieved.
8.3.3. Distribution Vegetation Management
Idaho Power is actively working to clear distribution lines throughout Idaho Power’s service area
on a three-year cycle.20 Additionally, in the RRZs and YRZs, Idaho Power completes annual vegetation line inspections and mid-cycle clearing of the lines in the second year, is increasing the number of trees removed, and is completing 100% quality control reviews of contractor line clearing work by certified arborists.
8.3.3.1. Distribution Line Clearing Cycles
Idaho Power is actively working to clear distribution lines on a three-year 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 “special request” in the situations that fast growing, unexpected growth occurs and is reported by any employee or customer.
8.3.3.2. Distribution Vegetation Inspections
In addition to regular cycle pruning activities, utility arborists are annually conducting ground patrols to identify potential vegetation hazards of each distribution line identified in the RRZs and YRZs. In addition, distribution patrol personnel also inspect the lines in the RRZs annually. During these inspections, patrol personnel identify infrastructure defects and hazardous
vegetation, within or adjacent to the ROWs, that could fall in or onto the distribution lines or associated facilities. The patrol personnel then evaluate the hazardous vegetation as to the level of threat posed by categorizing the vegetation as a high 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

20 Idaho Power will test a three-year cycle for a period of 4 or 5 years to verify that such a cycle can be maintained and that the expected benefits are realized.
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Operator. The utility arborist will conduct a follow-up inspection if potential hazard trees or grow-ins are identified. The utility arborist prioritizes and schedules any remedial action for all
reported vegetation issues.
8.3.3.3. 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 toward Idaho Power facilities. Vegetation clearing methods
include crews using chain saws or specialized pruning machines. Trees are cleared using a
pruning procedure called directional or natural pruning, a method recommended by the International Society of Arboriculture, and the ANSI A300 standards.
However, when appropriate and in compliance and permission with federal and state requirements, tree-growth regulators and spot herbicide treatments are applied as effective
techniques for reducing re-growth of sprouting deciduous shrubs and trees and extending
maintenance cycles.
Through its vegetation management program, Idaho Power has a target to maintain clearance distance between vegetation and conductors as follows:
• Five feet for conductors energized at 600 through 50,000 volts.
• Clearances may be reduced to three feet if the vegetation is not considered to be readily climbable because the lowest branch is greater than eight feet above ground level.
• New tree growth that is no larger than ½ inch in diameter may intrude into this minimum
clearance area provided it does not come closer than six inches to the conductor. This new growth is identified during line patrols and removed.
• For conductors energized below 600 volts, vegetation is pruned to prevent the vegetation from causing unreasonable strain on electric conductors.
8.3.3.4. Distribution Line Clearing Quality Control and Assurance
Similar to the transmission section, in non-wildfire risk zones, audits are performed on a random sample of pruning worksites. These audits are performed through a combination of the contracted arborists that planned the work and Idaho Power’s utility arborists. Due to the elevated risk of wildfire in YRZs and RRZs, audits will be performed on pruning work
performed in YRZs and RRZs regardless of the reason for the patrols and pruning.
8.3.4. Pole Clearing of Vegetation
Idaho Power has historically cleared vegetation from the base of certain transmission wood poles
and a limited number of distribution wood poles in Idaho. These vegetation clearing practices have been deemed an effective method of minimizing wildfire damage to existing wood poles. Where acceptable and permissible, Idaho Power removes or clears vegetation in a 20-foot radius
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surrounding the wood poles and applies a 10-year weed-control ground sterilant (SpraKil SK-26 Granular). Idaho Power submitted an SF-299 application with the Oregon BLM Vale District
Office to prepare an Environmental Assessment to use the same ground sterilant on transmission
and distribution facilities in Oregon. BLM staff estimate issuing herbicide permits in mid-2024.
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9. WILDFIRE RESPONSE
9.1. Overview
Idaho Power responds to wildfires involving or impacting its facilities and/or resulting in a system outage; depending on the specific circumstances, Idaho Power may also respond to wildfires with the potential to result in an outage. Idaho Power’s actions include
without limitation:
• Taking appropriate steps, where safe to do so, to protect Idaho Power-owned facilities from fire damage;
• Restoring electrical service following an outages; and,
• Communicating with and informing customers.
These actions are taken on a 24-hour basis.
9.2. Response to Active Wildfires
Idaho Power field crews are trained to respond to active wildfires to monitor the situation regarding Idaho Power’s facilities. Although they carry certain fire suppression equipment for use on very small fires in limited situations, Idaho Power’s crews are not professionally trained firefighters and are instructed not to place themselves in a hazardous position when responding
to wildfires. When responding to an active wildfire, Idaho Power personnel immediately report
to, and take appropriate direction from, the Incident Commander (IC) or other fire response entity official with jurisdiction over the incident.
9.3. 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 identify outage causes, damaged facilities, ingress/egress routes, and restoration requirements (number of crews, crew sizes, and necessary materials).
9.4. Restoration of Electrical Service
Idaho Power personnel restore electrical service when it is safe to do so following a wildfire.
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. Depending on the situation, contracted field crews—such as line crews and vegetation management crews—are also deployed to assist in restoration efforts. Restoration work may take hours or, in some rare cases, days to complete. Depending on the extent of damage, customers may need to
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perform repairs on their facilities and pass inspections by local agencies prior to having full electric 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, Idaho Power developed a
Transmission Emergency Response Plan. This plan includes restoration processes related to all 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.
9.4.1. Mutual Assistance
Idaho Power is a member of the Western Region Mutual Assistance Agreement (WRMAA),
of which the majority of western United States electric utilities are also members. Member utilities provide emergency repair and restoration assistance to other member utilities requesting assistance when dealing with damaged electric facilities following a significant wildfire or weather event. In the event of a catastrophic wildfire that causes widespread damage to Idaho Power’s system, Idaho Power may request restoration assistance via the WRMAA as a
last resort option after utilizing available internal personnel and contracted entities.
9.5. Public Outreach and Communications
In 2022, Idaho Power developed and began following an Outage Communication Playbook
(Playbook) to guide PSPS and load shed protocols. The Playbook ensures consistent and reliable communication to internal and external stakeholders. External communication includes targeted customers, Public Safety Partners, and operators of critical facilities. The Playbook guides activities and identifies key roles and responsibilities of internal Idaho Power employees. Supplemental information and resources are also included to ensure effective and consistent
communication is made prior to, during, and after an event.
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10. COMMUNICATING ABOUT WILDFIRE
10.1. Objective
Idaho Power communicates information about this WMP, including PSPS, and wildfire issues in general, to employees, customers, government officials, the public and other stakeholders. Topics of these communications vary due to timing and audience. For example, all customers
can benefit from outage preparedness tips and information about how we are hardening the grid. We discuss PSPS plans in greater detail with Public Safety Partners and operators of critical facilities, as well as customers who live in PSPS zones.
The following core messages are the foundation for all wildfire-related communications:
• How customers can prepare for wildfire-related outages, including where to find outage
and PSPS information and how to sign up for alerts and update contact information
• Ways customers can reduce wildfire risk
• Idaho Power’s work to protect the grid from wildfire and reduce wildfire risk
10.2. Community Outreach
10.2.1. Community Engagement
Idaho Power presents and distributes information on its WMP to a wide variety of stakeholders including the BLM, U.S. Forest Service, and county and city officials.
Idaho Power engages with various Public Safety Partners, including local governments,
emergency managers, and Idaho and Oregon’s ESF-12 and social service and welfare agencies (e.g., Oregon’s Department of Human Services). These engagements focus on wildfire awareness, prevention, and outage preparedness. For example, the company worked with the Boise City Fire Department to develop updates to the Boise City Fire Code related to
Wildland-Urban interface areas.
Idaho Power meets with all Public Safety Partners at least once a year and more frequently as needed. In counties with active local emergency planning committees, Idaho Power is an engaged member. The company uses a variety of methods to communicate with Public Safety Partners, including personal contact via phone, email, and text. We meet with identified
Public Safety Partners annually and document their communication preferences in our
outreach database. During an event, this information will be used to contact each partner.
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Idaho Power conducted over 20 WMP and PSPS plan presentations in 2022. At each one, stakeholders were asked to provide feedback to inform future versions of the WMP.
Notable presentations included:
• Local emergency management planning committee meetings across our service area
• Public meetings in communities with PSPS zones and in all Oregon counties we serve
• Idaho Emergency Preparedness Conference
• Idaho Public Health Planning Conference
• Snake River Fire Chiefs annual meeting held in Oregon
• Idaho VOAD (Volunteer Organizations Active in Disasters) Annual Conference
• Seven public meetings in Ontario, Huntington, and Halfway at the end of fire season to gain feedback from customers and stakeholders to help inform future plans. Similar meetings will be held in Idaho counties prior to the 2023 fire season.
Idaho Power has also conducted functional exercises with Public Safety Partners before wildfire
season. These exercises mimic fire emergencies, including PSPS events, to improve all parties’ wildfire preparedness. For example, in June 2022, Idaho Power conducted a PSPS mock event in our Idaho service area. Several Public Safety Partners were included in the event to test our communication and coordination protocols. The event was held over a three-day period
and assumed PSPS events across several wildfire risk zones. Following the event,
participants were asked to provide feedback, which has been incorporated into our plan. Feedback received included:
• Public Health Districts were added as Public Safety Partner contacts.
Previously, the Idaho Department of Health and Welfare had planned to communicate
to the Public Health Districts in case of a PSPS event. Through the event, we identified that this created a delay in communication to the Public Health Districts.
• Back-up contacts for the Idaho Public Utility Commission were identified in case our primary ESF-12 contact is unavailable.
• The Idaho Office of Emergency Management requested they receive a list of critical facilities that could be impacted by the PSPS event. We added this step to our protocols for Idaho and Oregon.
In addition, Idaho Power participated in two mock events, one conducted by Malheur County
and the second with the Idaho Office of Emergency Management’s Cascade Rising event.
Each event mimicked large power outages. While these were not PSPS-specific, we were able to
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test and discuss our outage communication protocols. Through those events, two opportunities
were identified:
• The Red Cross was added as a Public Safety Partner in Malheur County based on their
role in coordinating and supporting CRCs.
• The emPower program was identified as a tool to help notify customers on DMEs if a
PSPS event is predicted. Idaho Power is working with the Idaho Department of Health
and Welfare, the Independent Living Network, and the Idaho Office of Emergency
Management to expand this program to all Idaho counties.

10.2.2. Community Resource Centers
Each county in Idaho Power’s service area has unique needs during outage events and requires
a customized, flexible approach. During annual meetings with county emergency managers,
Idaho Power developed county-specific strategies in preparation for potential large-scale,
extended outages. These strategies include working with emergency managers to identify CRC
locations to be used, as needed, in a PSPS event. The company formulated strategies for Oregon
counties in 2022 and will further explore county strategies for Idaho in 2023. If a PSPS event is
forecasted, Idaho Power will strive to work directly with local Public Safety Partners to identify
and meet the needs of the local community. Services provided in collaboration with emergency
managers could include:
• Stand-up of CRC
• CRC location(s) and logistics included in community outreach/outage notifications
2022 Public Safety Partner Feedback Summary County emergency managers, the Idaho Office of Emergency Management, the Oregon
Office of Emergency Management, and the Idaho Department of Health and Welfare
reviewed Idaho Power’s WMP plan, PSPS protocols, community outreach strategy and
materials, critical facilities, and CRC strategies. Feedback received has been incorporated into
our programs. Improvements based on this feedback include:
• Updates to identified critical facilities
• Changes to outreach materials to include county specific information as requested
o Example: Sign-up information was included for counties with active emergency alert systems
• Revised GIS tools that will be provided to Public Safety Partners if a PSPS event is forecasted

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• CRC resources
o Food, water, and other basic needs
o Charging stations
o Auxiliary service coordination such as medical services, housing assistance, family reunification, etc.
10.3. Customer Communications
Safety is one of Idaho Power’s core values. It guides our communication strategy for wildfire-related communication to our customers. Communication methods and timing vary based on the audience we are trying to reach and the goal of the communication.
Communication generally falls into two categories: 1) broad outreach to all customers, and 2)
targeted outreach to customers in PSPS zones. The company uses a variety of outreach methods to reach a broad customer base with messages about wildfire safety, summer outage preparedness, and grid hardening efforts.
Outreach to customers in PSPS zones was more targeted and frequent. Idaho Power repeatedly
urged these customers to update or confirm accurate contact information.

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Figure 14 Outreach samples for the 2022 wildfire season
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10.3.1. Key Communication Methods
Idaho Power communicates with customers and the public before and throughout wildfire season to inform them of steps the company is taking to reduce wildfire risk and ways they can help prevent wildfires and prepare for outages. Various communication mediums used to accomplish
this include:
• Connections (This monthly newsletter is an effective way to give customers more in-depth information about the work Idaho Power does, but it is not an effective way to communicate urgent information.)

Figure 15 May 2022 edition of Connections
• Videos on topics like vegetation management and PSPS
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Figure 16 Idaho Power developed an educational video on how we protect wooden poles from wildfire
• Emails, texts, and phone calls telling customers how to prepare for wildfires,
encouraging them to update their contact information, and providing information about grid hardening efforts
o The company used a new communication tool to notify all customers in PSPS zones by text message, phone call, or email. We mailed letters to customers we couldn’t
reach with this tool. Every year, the company will work to obtain accurate contact
information for all customers in PSPS zones.
• News media (news releases, appearances on broadcast TV and radio shows, interviews, etc.)
• Social media (posts on Facebook, Instagram, and Twitter are an efficient way to reach large numbers of customers and the public in a timely manner). Social media continues to be a critical tool for engaging with customers and communicating wildfire safety. The company’s social media campaign for wildfire season focused on three main themes:
o Wildfire prevention: What Idaho Power is doing and what customers can do to reduce
wildfire risk
o Outage preparation: How customers, especially those who live or have businesses in high-risk areas, should prepare for wildfire-related outages
o Grid maintenance: How Idaho Power protects the grid, keeping energy safe, reliable and affordable, even during wildfire season.
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Figure 17 Sample image of social media post
Social media posts are focused on various aspects of each theme, such as putting out campfires as shown in Figure 18 below; creating defensible spaces around homes and businesses; building a summer outage kit as shown in Figure 17, above; and updating contact information. Posts also include information on installing SPUs on the power distribution system and wrapping wood poles with fire-resistant mesh.

Figure 18
Sample image of social media post
• Postcards and flyers
• Paid advertising (radio, digital, and print advertisements)
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• Idaho Power’s website (wildfire safety information, such as videos, safety tips, and the
latest version of the WMP) can be found at https://www.idahopower.com/outages-
safety/wildfire-safety/.

Figure 19 Idaho Power’s Wildfire Safety landing webpage
• As shown in Figure 19, on this webpage, the company introduces wildfire and its relationship to delivering power, information on PSPS, and the following links:
o What is a PSPS?: Explanation of PSPS events, including a map customers can use to
determine if their homes or businesses are inside a PSPS zone
o Be Prepared for Wildfire Season: Preparation tips like building an outage kit and making a plan for feeding livestock, etc.
o Protecting the Grid: Idaho Power measures to enhance grid resiliency and reduce wildfire risk; an interactive map showing red and yellow risk zones and a link to the
WMP
o How You Can Reduce Wildfire Risk: Tips for preventing wildfires when camping, using fireworks, hauling trailers, etc.
o PSPS Event Information: Real-time information on active PSPS events, estimated shutoff time, outage duration, and customers impacted
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• Public engagement with the company holding at least one public meeting per year in both
Oregon and Idaho, offering a virtual meeting with additional access and functionality options. Feedback opportunities are also provided during and after the meetings.

Figure 20 Wildfire mitigation meeting PowerPoint cover slide
10.3.2. Timing of Outreach
The timing of the outreach generally occurs before and during wildfire season. In 2022,
Idaho Power originally planned to begin preseason wildfire outreach in early- to mid-April.
Due to an unusually wet and cold spring (Boise had accumulating snow on the valley floor on
May 9) and a desire to maximize impact, the company delayed release of social media posts,
ads, and other communications until the weather changed such that wildfire was more
prominently on people’s minds. The tone of early communications was meant to encourage
customers to think about wildfire season, how they could prepare for it, their role in preventing
wildfires, and steps Idaho Power is taking to keep the grid safe and reduce wildfire risk.
When the potential for wildfire increased, communications shifted in tone. Messaging put more
emphasis on asking customers, especially those in PSPS zones, to update their contact
information and prepare for wildfire.
10.3.3. Communication Metrics
Idaho Power uses metrics and monitoring of communication activities to evaluate the
effectiveness of our outreach efforts. Idaho Power published a Wildfire Safety landing webpage
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in April 2022 with information on wildfire safety, PSPS, and interactive maps. In the roughly six
weeks that followed, before general outreach efforts began, the page saw fewer than 200 hits.
However, a campaign of radio, print, and online ads began in earnest in late June and traffic
immediately jumped, with 1,443 hits the first week of the campaign as shown in the following
graph. Traffic stayed high for about a month before dropping off again.

Figure 21 Wildfire safety webpage views
The following is a summary of metrics from Idaho Power’s 2022 paid communication campaign.
• Radio—Idaho Power’s wildfire-safety radio ad campaign ran from May 16 to July 31
in the Idaho Falls, Twin Falls, and Boise markets. The Boise market includes eastern Oregon, reaching as far west as Baker City. The campaign included a total of 4,327 paid and public safety announcement (PSA) match spots; 967 of which were in Spanish and played on Spanish language stations.
• Programmatic Display Ads—Idaho Power’s digital display ads appeared on regional websites from May 16 to July 31. These ads resulted in a total of 3,496 clicks in Idaho and Oregon to our wildfire landing webpage, with almost 3.7 million impressions. Almost three-quarters (74.21%) of these impressions occurred via mobile devices.
• 2021 Versus 2022—Idaho Power’s 2021 wildfire-safety campaign was comparable to what we deployed in previous years, with the company relying mainly on displays on the Idaho Power website. The 2022 campaign was a much more robust, intricately planned and carefully executed effort. It involved a larger outreach goal and more ads on radio and Spotify that ultimately led to 1.24 million more impressions than the 2021 wildfire-
safety campaign.
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2022 WMP Communication Summary Idaho Power used traditional and social media in 2022 to inform customers about the company’s WMP, efforts to protect the grid from wildfire, how customers could reduce wildfire risk, how to prepare for
wildfire-related outages, and PSPS. Outlets included:
• Newspapers—Print ads and news coverage
• Radio—Paid ads in English and Spanish and news coverage
• TV news coverage
• Printed flyers
• Social media
• Idaho Power website
• Digital display ads
• Postcards—Used to inform customers of the PSPS program and invitations for
public meetings
• Spotify—Paid ads
• News Releases—Includes news releases with other Oregon utilities
• Customer email
• Customer newsletters
• Text Messages—Customers in PSPS zones
• Phone Calls—Customers in PSPS zones
• Letters—Customers in PSPS zones
The following updates to the website were made to include new pages focused on wildfire safety in 2022:
• Searchable map of PSPS zones by customer address
• Summer outage preparation
• How Idaho Power protects the grid including mitigation efforts
• How customers can help prevent wildfires
• An active PSPS event page that provides details of active PSPS areas and outage duration information
Additionally:
• Postcards were sent to all customers in PSPS zones to inform them of program details
• Printed 2,600 outage preparedness flyers (English and Spanish) and gave to the Idaho Commission on Aging for delivery with Meals on Wheels
• Wildfire themed customer newsletter (Connections) was sent to all customers in May
• Wildfire themed customer email sent to all customers with email addresses on file (approx. 350,000) in May
• Implemented a “pop-up” in the customer My Account web page encouraging customers to update contact information
• Post fire-season postcards were mailed to all Oregon customers in November for invitation
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10.4. Idaho Power Internal Communications—Employees
Idaho Power communicates with its employees in a variety of ways:
• News Scans for all employees

Figure 22 May 2, 2022, edition of News Scans
• Emails
• Leader communications
• GIS-based visual communication of risk zones and affected overhead lines
• Online training for employees influenced by the WMP
• In-person, hands-on, training for certain field employees

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11. PERFORMANCE MONITORING AND METRICS
11.1. Wildfire Mitigation Plan Compliance
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.
11.2. Internal Audit
Idaho Power’s internal audit department, Audit Services, will periodically conduct an independent and objective evaluation of the WMP to assess compliance with policies and
procedures and evaluate achievement of the Plan’s objectives. Idaho Power’s Compliance department will also periodically review Idaho Power’s compliance with federal reliability standards regarding vegetation management practices.
11.3. Annual Review
Idaho Power will conduct an annual review of its WMP and incorporate necessary updates prior to wildfire season.
11.4. 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 2010. Idaho Power plans to reconduct risk modeling in 2023 to include 2020 Census data and explore other areas of consequence as described in Section 3.2.1. Idaho Power intends to review our risk
modeling approach on an annual basis and perform modeling updates biennially.
11.5. Situational Awareness
Idaho Power will share its FPI regularly and broadly with Idaho Power personnel and contractors
during wildfire season to ensure condition-specific operating requirements are met.
11.6. 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 RRZs and YRZs during a red FPI. Specific requirements are found in Idaho Power’s Field Personnel Practices which is consulted by such crews working in these areas.
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11.7. Wildfire Mitigation—Operations
Each year in preparation for the fire season, Idaho Power reviews and establishes:
• Temporary operating procedures for transmission lines during the fire season
• An operational strategy for distribution lines during time periods of elevated wildfire risk
during the fire season
• Use of PSPS as a tool of last resort to prevent Idaho Power T&D facilities from becoming a wildfire ignition source or contributing to the spread of wildfires
11.8. Wildfire Mitigation—T&D Programs
This section lists metrics used to evaluate Idaho Power’s asset management and vegetation management programs. The metrics are based on progress made towards completing mitigation activities, such as quantities of inspected units. Work is identified and prioritized each year 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 11 T&D programs metrics
Transmission Transmission Asset Management Programs Description
according to priority. Complete repairs according to priority
according to priority. Complete repairs according to priority
according to priority. Complete repairs according to priority
according to priority. Complete repairs according to priority
towers with direct-buried anodes. Perform 10-year rectifier and ground-bed testing on ICCP systems. Annually inspect and record DC voltage and current readings of rectifiers. Complete
Distribution
Distribution Asset Management Programs Description
according to priority. Complete repairs according to priority
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according to priority. Complete repairs according to priority
thermal imaging (infra-red) cameras.
spans as required
crossarms
deadend strain insulators
deadend strain insulators
Replace hot line clamps Replace aluminum stirrups Install avian cover Relocate arresters
Replace swelling capacitors Replace oil-filled switches with vacuum style Replace porcelain switches with polymer switches
Install avian cover
Replace/Install down-guy insulators with fiberglass insulators Tighten down guys
Department)
Vegetation Management
Transmission Description
areas & 6-year cycle for mountain areas

Distribution Description
Wildfire Mitigation Plan 2023 Idaho Power Company
Page 86
11.9. Long-term Metrics
In 2022, Idaho Power identified new metrics to measure the performance of the WMP and its
effectiveness over time. Vegetation management and grid hardening work is expected to reduce
outages and improve reliability in wildfire risk zones. A new approach in gauging the
effectiveness of the WMP includes tracking reliability data and specific outage counts based on
causes or failures that are considered potential drivers of ignition. The following outage causes
were established as baseline potential drivers of ignition and will be monitored for each wildfire
risk zone:
• Tree/Vegetation Contact
• Equipment Failure
• Loose Hardware
• Corrosion
• Animal Contact
Historical data was analyzed in 2022 in both RRZ and YRZ to establish baseline metrics that
will be used to measure performance over time. Potential drivers of ignition in wildfire risk
zones through October have decreased by 8% compared to the previous four-year average.
This improvement occurred despite being in early stages of wildfire hardening and enhanced
vegetation management activities. The use of outage data to gauge overall WMP performance is
expected to be a long-term metric and it takes several years to develop trendlines and averages to
draw definitive conclusions and a causal relationship to wildfire mitigation activities. In 2023,
the company plans to continue to develop long-term benchmarks based on outage counts and
cause codes and will refine our approach by expanding the use of data analytics.
Idaho Power Company The Wildland Fire Preparedness and Prevention Plan
Appendices
Appendix A The Wildland Fire Preparedness and Prevention Plan.

The Wildland Fire Preparedness and Prevention Plan Idaho Power Company
Appendices

Wildland Fire
Preparedness and
Prevention Plan

Idaho Power Company The Wildland Fire Preparedness and Prevention Plan
Appendices
TABLE OF CONTENTS
1. 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

The Wildland Fire Preparedness and Prevention Plan Idaho Power Company
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 fires (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 conduct themselves in a
fire-safe manner. B. Scope of Plan
The scope of this Plan includes tools, equipment, and field behaviors IPC employees incorporate
when working in locations and under conditions where wildfire ignition is heightened. Operations of Transmission and Distribution (T&D) lines facilities, vegetation management, and T&D lines programs that mitigate wildfire risks are not included in this 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 wildfire season. Within IPC’s service area, wildfire season is defined as the closed fire season of May 10 through October 20 of each year,
as established by Idaho State Law, Title 38‐115.
Should any local, state, or federal government land management agency (i.e., the BLM, U.S. Forest Service, Oregon Department of Forestry, 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—can 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 are
necessary such that operational practices can be adjusted accordingly. B. Wildfire Risk Zones

IPC’s Wildfire Mitigation Plan includes a Wildfire Risk Map of IPC’s service area. This Wildfire Risk Map may be accessed at the Idaho Power SharePoint site. All lands in the
vicinity 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 zones (WRZ). The provisions of this Plan shall apply to work activities taking place during wildfire season in these WRZs.
Idaho Power Company The Wildland Fire Preparedness and Prevention Plan
Appendices
Should any local, state, or federal government land management agency (i.e., BLM, U.S. Forest
Service, Oregon Department of Forestry, 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 Index

Idaho Power’s Atmospheric Science department has developed an FPI rating system that forecasts wildfire potential across IPC’s service area. The FPI considers many current and forecasted elements such as meteorological (winds-surface and aloft, temperatures, relative humidity, precipitation, etc.) and fuel state (both live and dead). The FPI is designed and calibrated for IPC’s 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 and high temperatures). The FPI scores are grouped into the following 3 index levels:

• Green: FPI score of 1 through 11
• Yellow: FPI score of 12 through 14
• Red: FPI score of 15 through 16

During wildfire season, Idaho Power will determine a daily FPI as described in Section 5 of the WMP. This weather forecast and FPI dashboard is contained within IPC geographic information system (GIS) viewers available to all IPC employees.
D. Decision Making for Field Work Activities
Employees working in the field shall be cognizant of current and forecasted weather and field conditions. Awareness of these conditions, and exercising appropriate judgment, is essential when considering whether to undertake work activities when combinations 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 during wildfire season: Planned or Scheduled Work Activities:
1. Fire Potential Indices:

a) Employees working in the field—NOT working on transmission or primary
distribution lines should:

The Wildland Fire Preparedness and Prevention Plan Idaho Power Company
Appendices
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.

ii. Once the FPI level for the work zone is identified, proceed with work but
consider utilizing Prevention—Practices of Field Personnel (see Section 6
of this Plan).
b) Employees working in the field—working on transmission or primary 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.
ii. Once the FPI level for the work zone is identified, proceed as follows for
each FPI level:

1. Green FPI in All 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. Red FPI

a) In Normal Zone: Proceed with the work.
Consider utilizing Prevention—Practices of Field Personnel
(see Section 6 of this plan)
b) In Medium Zone: Proceed with the work. However, it is a
requirement to follow the Prevention—Practices of Field
Personnel (see Section 6 of this plan)

c) In High Zone: STOP. No planned work activities shall
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 6 of this plan).

Idaho Power Company The Wildland Fire Preparedness and Prevention Plan
Appendices

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 notify, 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.

Emergency Response and Outage 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 appropriate
judgment should be used given the nature of the emergency or outage at hand. 3. Preparedness—Tools and Equipment

A. Required Personal Protective Equipment

The Wildland Fire Preparedness and Prevention Plan Idaho Power Company
Appendices
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:
• Hardhat with chinstrap
• Long sleeve flame-resistant (FR) shirt and FR pants
• Leather gloves
• Exterior leather work boots, 8” high, lace-type with Vibram type soles
• 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 10–October 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) Fire suppression hand tools (i.e. shovels, rakes, Pulaski’s, etc.),
b) a 16-20-pound fire extinguisher,
c) a supply of water, sufficient for initial attack, 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.

• 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 at least 26
inches long
b) One axe or Pulaski with a 26-inch handle or longer
c) A combination of shovels, axes, or Pulaskis available to each person on the crew
Idaho Power Company The Wildland Fire Preparedness and Prevention Plan
Appendices
d) One fire extinguisher rated no less than 2A:10BV (5 pounds)
e) 30-200 gallons of water in a fire pumper and 5-gallon back packs

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 department will notify operations leadership within Power Supply, Customer Operations and Business Development, and T&D Engineering and Construction of any
wildfire related requirements and restrictions orders that are issued by local, state, or federal land management agencies. Typical orders issued each fire season include:
• BLM. During BLM's Stage II Fire Restrictions, IPC’s Environmental Services
department 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 1 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 at least 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 Department of Forestry (ODF). Prior to each summer fire season,
the ODF issues a “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.gov/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 Interagency Fire Center at http://bmidc.org/index.shtml
o Nevada—Fire Information at https://www.nevadafireinfo.org/restrictions-and-
closures
o Montana—https://firerestrictions.us/mt/

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.
The Wildland Fire Preparedness and Prevention Plan Idaho Power Company
Appendices
1. 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 high brush 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. Identify the FPI for the area being worked (see Section 3.2.2)
b. Monitor weather forecasts and wind and humidity conditions
c. Identify surroundings. i.e., wildland-urban interface, BLM lands, Forest Service
lands, proximity to any homes and structures, etc.
d. Identify 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. 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 used
d. Cooking must be in areas free of combustible materials

Idaho Power Company The Wildland Fire Preparedness and Prevention Plan
Appendices
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 or post-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.

1. 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.
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.
The Wildland Fire Preparedness and Prevention Plan Idaho Power Company
Appendices
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 cause ignition 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. 5. Reporting

A. Fire Ignition
All fire ignitions shall be immediately reported to regional or system dispatch. Dispatch will notify 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

Idaho Power Company The Wildland Fire Preparedness and Prevention Plan
Appendices
When reporting a fire ignition to regional or system dispatch provide the following information: 1. Your name
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 Workday system. 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 Workday.

The Wildland Fire Preparedness and Prevention Plan Idaho Power Company
Appendices
7. Roles and Responsibilities

Individual Roles and Responsibilities
Employee 1. Be familiar with the requirements specified in this Plan and operate in 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.
Front-Line Leaders 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 WMZ 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.
Operations Manager, Area Manager, T&D
Construction Manager)
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.
within the IPC Enviro Viewer.
Department restriction orders that are issued. 2. Communicate content of any orders issues to Power Supply, COBD, and
PEC operations leadership.
Department requirements are in place to ensure adherence to the Plan.
Engineering and completion of each wildfire season.

8. Audit

Prior to the start of wildfire season (May 10), all vehicles associated with work on transmission
and distribution lines will be audited by leadership to ensure that those working in WRZs are
properly equipped with firefighting 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 manager and senior manager.

Idaho Power Company The Wildland Fire Preparedness and Prevention Plan
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 16–20-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.)
- 30–75-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-inch handle or longer
- A combination of shovels, axes, or Pulaskis to each person on the crew
- One fire extinguisher rated no less than 2A:10BV (5 pounds)
- 30-200 gallons of water in a fire 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

The Wildland Fire Preparedness and Prevention Plan Idaho Power Company
Appendices

Idaho Power Company Public Safety Power Shutoff Plan
Appendices
Appendix B The Public Safety Power Shutoff (PSPS) Plan.

Idaho Power Company’s
Wildfire Public Safety Power Shutoff Plan

© 2021 Idaho Power
Idaho Power Company Wildfire Public Safety Power Shutoff Plan
Page i
TABLE OF CONTENTS
Table of Contents ............................................................................................................................. i
List of Tables ................................................................................................................................. iv
List of Figures ................................................................................................................................ iv
1. Introduction ................................................................................................................................1
2. List of Acronyms .........................................................................................................................2
3. Definitions....................................................................................................................................3
4. Public Safety Power Shutoff Overview .......................................................................................4
5. Scope ............................................................................................................................................4
6. Key Tenets ...................................................................................................................................4
7. Wildfire Zones .............................................................................................................................5
8. PSPS Implementation Considerations .........................................................................................5
8.1. Fire Potential Index .............................................................................................................5
8.2. National Weather Service Red Flag Warning .....................................................................6
8.3. NWS Fire Weather Forecasts ..............................................................................................6
8.4. Publicly Available Weather Models ...................................................................................7
8.5. Idaho Power Weather Model ..............................................................................................7
8.6. Storm Prediction Center Fire Weather Outlooks ................................................................7
8.7. Current Weather Observations ............................................................................................7
8.8. National Significant Wildland Fire Potential Forecast Outlook .........................................8
8.9. Great Basin Coordination Center Morning Briefing ..........................................................8
8.10. GBCC Current and Predicted ERC and F100 ...................................................................8
8.11. Agency Input .....................................................................................................................8
8.12. De-Energization Windspeed Considerations ....................................................................8
8.13. Engineering Assessment ...................................................................................................9
8.14. Alternative Protective Measures .......................................................................................9
8.15. Real-time Field Observations ...........................................................................................9
Wildfire Public Safety Power Shutoff Plan Idaho Power Company
Page ii
8.16. Other .................................................................................................................................9
9. Responsibilities ............................................................................................................................9
9.1. Load Serving Operations ....................................................................................................9
9.2. Atmospheric Science ........................................................................................................10
9.3. TDER Senior Manager .....................................................................................................10
9.4. Customer Operations and T&D Construction ...................................................................11
9.5. Supply Chain/Stores..........................................................................................................11
9.6. Fleet/Equipment Resource Pool ........................................................................................12
9.7. Supply Chain Contracting .................................................................................................12
9.8. Substation Operations .......................................................................................................12
9.9. Corporate Communications ..............................................................................................12
9.10. Distribution Engineering and Reliability ........................................................................13
9.11. Safety ..............................................................................................................................14
9.12. Vegetation Management .................................................................................................14
9.13. Geographic Information Systems ...................................................................................14
9.14. Customer Service ............................................................................................................14
9.15. Communication Systems (Stations) ................................................................................15
9.16. Customer Operations Support .........................................................................................15
9.17. Legal ...............................................................................................................................15
9.18. Regulatory .......................................................................................................................15
10. PSPS Operations ......................................................................................................................16
10.1. General ............................................................................................................................16
10.2. PSPS Preparedness..........................................................................................................17
10.2.1. Idaho Power Programs ...........................................................................................17
10.2.2. Coordination with Government Entities ................................................................18
10.2.3. Community Preparedness ......................................................................................18
10.2.4. Information Sharing ...............................................................................................18
10.2.5. Notifications and Emergency Alerts ......................................................................18
Idaho Power Company Wildfire Public Safety Power Shutoff Plan
Page iii
10.2.6. Training and Exercises ...........................................................................................18
10.3. Proactive Communications .............................................................................................19
10.4. Wildfire Season Operations ............................................................................................20
10.4.1. Situational Awareness Activities ...........................................................................20
10.4.2. GIS Wildfire Information ......................................................................................20
10.4.3. Key Grid Interdependent Utilities and Agencies ...................................................20
10.5. Phase 1 ............................................................................................................................21
10.5.1. PSPS Assessment Team Activation .......................................................................21
10.5.2. Community Notifications.......................................................................................21
10.6. Phase 2 ............................................................................................................................21
10.6.1. Activate Event Coordinator ...................................................................................22
10.6.2. Conduct Operational Risk Analysis .......................................................................22
10.6.3. Request to Delay a PSPS Event .............................................................................22
10.6.4. PSPS Event Strategy ..............................................................................................22
10.6.5. Field Observations and Response Teams ..............................................................22
10.6.6. Customer and Community Notifications ...............................................................22
10.7. Phase 3 ............................................................................................................................23
10.7.1. Customer and Community Notification .................................................................23
10.8. Phase 4 ............................................................................................................................23
10.8.1. System Inspections.................................................................................................23
10.8.2. Repair and Recovery ..............................................................................................23
10.8.3. Incident Management Support ...............................................................................24
10.8.4. Communicate PSPS Event Conclusion ..................................................................24
10.8.5. Re-energization ......................................................................................................24
10.9. Post-incident Review ......................................................................................................24
11. Financial Administration .........................................................................................................25
12. Reporting..................................................................................................................................25
13. After-Action Report .................................................................................................................25
Wildfire Public Safety Power Shutoff Plan Idaho Power Company
Page iv
14. Training ....................................................................................................................................25
15. Exercises ..................................................................................................................................25
LIST OF TABLES
Table 1 Incident phase decision triggers ..................................................................................................16

LIST OF FIGURES
Figure 1 PSPS Preparedness Cycle ...........................................................................................................17
Figure 2 PSPS Event Communication Timeline .......................................................................................19

Idaho Power Company Wildfire Public Safety Power Shutoff Plan
Page 1
1. INTRODUCTION
Wildfires in the Pacific west have increased in their intensity in recent years. In an effort to
keep Idaho Power’s customers and the communities it serves safe and continue improving
the resiliency of Idaho Power’s transmission and distribution facilities, Idaho Power implemented a Wildfire Mitigation Plan in 2021, focused on situational awareness, field personnel safety practices and operational wildfire mitigation strategies to prevent the accidental ignition of wildfires. As part of its operational mitigation practices, Idaho Power
has developed this Public Safety Power Shutoff Plan (PSPS Plan or Plan) to proactively
de-energize electrical facilities in identified areas of extreme wildfire risk to reduce the potential of those electrical facilities becoming a wildfire ignition source or contributing to the spread of wildfires. This Plan identifies the relevant considerations, process flow and implementation protocol before, during and after a PSPS event. The Plan will be active
during wildfire season and reviewed annually and updated as necessary prior to the start of
the next wildfire season.
This Plan identifies PSPS implementation considerations and responsibilities for different Idaho Power departments before, during and after PSPS events. Table 2 describes the different phases Idaho Power will use during PSPS events and Figure 7 depicts the
communication audiences and timeline Idaho Power will ideally follow during an event.
Finally, this Plan describes activities Idaho Power will undertake to prepare and improve the Plan over time, including interactions with local emergency agencies, and briefly describes the financial administration of the Plan.
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2. LIST OF ACRONYMS
AAR—After Action Review
BLM—Bureau of Land Management
COO—Chief Operations Officer
ECMWF—European Centre for Medium-Range Forecasts
EMT—Emergency Management Team
ERC—Energy Release Component
F100—100-Hour Fuel Moisture
FPI—Wildfire Mitigation Plan Fire Potential Index
FWW—Fire Weather Watch
GBCC—Great Basin Coordination Center
GIS—Geographic Information System
IPUC—Idaho Public Utility Commission
IRWIN—Integrated Reporting of Wildland-Fire Information
LSO—Load Serving Operations
NIFC—National Interagency Fire Center
NOAA—National Oceanic and Atmospheric Administration
NWS—National Weather Service
OPUC—Oregon Public Utility Commission
PEC—Planning, Engineering and Construction
PSPS—Public Safety Power Shutoff
RFW—National Weather Service issued Red Flag Warning
SGM—Smart Grid Meter
SME—Subject Matter Expert
T&D—Transmission & Distribution
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TDER—Transmission & Distribution Engineering and Reliability
UKMET—United Kingdom Meteorological Office
WMP—Wildfire Mitigation Plan
WRF—Weather Research and Forecasting
3. DEFINITIONS
(1) Critical Facilities—Refers to the facilities identified by Idaho Power that, because of their function or importance, have the potential to threaten life safety
or disrupt essential socioeconomic activities if their services are interrupted.
(2) ESF-12—Refers to Emergency Support Function-12 and is the Idaho Power Company liaison from the State Office of Emergency Management for energy utilities issues during an emergency for both Idaho and Oregon.1
(3) Exercise—Refers to planned activities and assessments that ensure continuity
of operations, provide and direct resources and capabilities and gather
lessons-learned to develop core capabilities needed to respond to incidents.
(4) Community—Refers to a group of people that share goals, values and institutions.2
(5) Local Emergency Manager—Refers to a jurisdiction’s role that oversees the
day-to-day emergency management programs and activities.3
(6) Public Safety Partners—As defined by Idaho Power refers to ESF-12, Local Emergency Management and Idaho’s and Oregon’s Department of Human Services (or equivalent).
(7) Public Safety Power Shutoff or PSPS—A proactive de-energization of a
portion of an Electric Utility’s electrical network, based on the forecasting of and
measurement of extreme wildfire weather conditions.

1 Federal Emergency Management Institute (FEMA) National Response Framework (NRF) Emergency Support Functions (ESF) National Response Framework | FEMA.gov.
2 FEMA definition under “Communities” (pg. 26) National Response Framework (fema.gov).
3 FEMA definition under “Local Government” (pg. 29) National Response Framework (fema.gov).
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4. PUBLIC SAFETY POWER SHUTOFF OVERVIEW
In recent years, the western United States (U.S.) has experienced an increase in the 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. Recent events in western states have increased awareness of electric utilities’ role in wildfire prevention and mitigation.
In an effort to keep Idaho Power’s customers and the communities it serves safe and continue
improving the resiliency of Idaho Power’s transmission and distribution (T&D) facilities,
Idaho Power implemented a Wildfire Mitigation Plan (WMP) in 2021 focused on situational awareness, field personnel safety practices and operational wildfire mitigation strategies. As part of its operational mitigation practices, Idaho Power developed this Wildfire Public Safety Power Shutoff Plan (PSPS Plan or Plan) to proactively de-energize electrical facilities in identified
areas of extreme wildfire risk to reduce the potential of those electrical facilities becoming a
wildfire ignition source or contributing to the spread of wildfires. Based on the inherently disruptive nature of power outages, Public Safety Power Shutoff (PSPS) events must be carefully evaluated under this Plan to balance wildfire risk with potential PSPS impacts on Idaho Power customers and the communities it serves.
The unpredictable nature of wildfire and weather patterns create significant challenges with
forecasting PSPS events. Real-time evaluations and decision-making are therefore critical in making PSPS determinations and, depending on the associated wildfire risk, those determinations may result in proactive de-energization in areas not originally anticipated.
5. SCOPE
This PSPS Plan identifies the relevant considerations, process flow and implementation protocol before, during and after a PSPS event. The Plan will be active during wildfire season and reviewed and updated annually as necessary prior to the start of the next wildfire season. Wildfire season (also known as “closed season”) is defined by Idaho Code § 38-115 as extending
from May 10 through October 20 each year, or as otherwise extended by the Director of the
Idaho Bureau of Land Management (BLM). Oregon’s wildfire season generally aligns with Idaho’s wildfire season and is designated by the State Forester each year pursuant to Oregon Revised Statute 477.505.
6. KEY TENETS
• Advancing the safety of Idaho Power employees, customers and the general public
• Collaborating with key external stakeholders (agencies, counties, local governments, public safety partners, first responders)
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• Minimizing both potential wildfire risk and power outage impacts on communities and customers
• Maintaining reliable electric service
7. WILDFIRE ZONES
Idaho Power’s WMP identifies areas of heightened wildfire risk within its service territory reflected by the following risk zones:
• Tier 2 Yellow Risk Zones are deemed increased risk areas.
• Tier 3 Red Risk Zones are deemed higher risk areas.
In its WMP, Idaho Power identifies operational practices specific to these zones of heightened
wildfire risk for purposes of (1) reducing potential wildfire risk associated with Idaho Power’s
T&D facilities and field operations, and (2) improving the resiliency of the Idaho Power’s T&D system impacted by wildfire. This PSPS Plan sets forth Idaho Power’s PSPS evaluation criteria and processes, including operational and communication protocol, for implementing a PSPS.
8. PSPS IMPLEMENTATION CONSIDERATIONS
Idaho Power will initiate a PSPS if the company determines a combination of critical conditions indicate the T&D system at certain locations is at an extreme risk of being an ignition source and wildfire conditions are severe enough for the rapid growth and spread of wildfire. Idaho Power will evaluate as a whole (not relying on one single factor but a combination of all factors), without limitation, the criteria set forth in 9.1–9.17 below.
8.1. Fire Potential Index
In addition to the Risk Zone designations in its WMP, Idaho Power developed a Fire Potential Index (FPI) to forecast wildfire potential across Idaho Power’s service area. The FPI converts
data on weather; prevalence of fuel (shrubs, trees, grasses); and topography into a numerical FPI score to forecast the short-term wildfire threat in geographical areas throughout Idaho Power’s service area. FPI scores range 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 and high temperatures). FPI scores are grouped into the following 3 index levels:
1) Green—lower fire potential: FPI score of 1 through 11 2) Yellow—elevated fire potential: FPI score of 12 through 14 3) Red—highest fire potential: FPI score of 15 and 16
The FPI supports operational decision-making to reduce potential wildfire risk. During wildfire
season, Idaho Power will determine a daily FPI as described in Section 5.2 of the WMP. The FPI
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forecast is broken into four 6-hour time periods throughout each seven-day forecast. FPI information is provided via email, certain Geographic Information System (GIS) viewers and an FPI dashboard accessible to both Idaho Power employees and contractors from Idaho Power’s
website. The WMP details operational mitigation efforts in Red Risk Zones when the FPI score in that Red Risk Zone is also Red, including stopping planned work and changing distribution protection operations. A Red FPI score will be a consideration in Idaho Power’s determination of whether to initiate a PSPS.
8.2. National Weather Service Red Flag Warning
A Red Flag Warning (RFW) is a forecast warning issued by the National Weather Service (NWS) to inform the public, firefighters and land management agencies that conditions are ideal
for wildland fire combustion and rapid spread. RFWs are often preceded by a Fire Weather
Watch (FWW), which indicates weather conditions that could occur in the next 12–72 hours. The NWS has developed different zones across the nation for providing weather alerts (such as RFWs) to more discrete areas. These zones are shown on this NWS webpage: Fire Weather. RFWs for Idaho Power’s service territory include Idaho Zones (IDZ) 401, 402, 403, 413, 420
and 422; and Oregon Zones (OR) 636, 637, 642, 634, 644, 645 and 646; and are monitored and
are factored into Idaho Power’s determination of whether to initiate a PSPS. Boise and Pocatello NWS offices will not issue RFWs if fuels are moist and fire risk is low. The following thresholds are used by most NWS offices:
• Daytime:
• Relative humidity of 25% or less
• Sustained winds greater than or equal to 10 miles per hour (mph) with gusts greater than or equal to 20 mph over a four-hour time period
• Nighttime:
• Relative humidity of 35% or less
• Sustained winds greater than or equal to 15 mph with gusts greater than or equal to
25 mph over a three-hour time period
• Lightning:
• The NWS rarely issues RFWs for lightning in the western United States. For this to occur, the Lightning Activity Level—a measure of lightning potential specifically as
it relates to wildfire risk—needs to be at 3 or higher.
8.3. NWS Fire Weather Forecasts
The NWS provides detailed forecasts for the different weather zones with an emphasis on fire
weather indicators (wind speed, relative humidity, lightning potential). A discussion
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summarizing the weather patterns and highlighting fire threats is included in their extended forecast.
8.4. Publicly Available Weather Models
Idaho Power's Atmospheric Science department uses the following weather models to predict weather timing, duration and intensity:
• Pivotal Weather Link (pivotalweather.com/model.php): Provides numerical weather data,
including a NWS blend of models, European Centre for Medium-Range Weather Forecasts (ECMWF), United Kingdom Meteorological Office weather service information and GOES-16 satellite information.
• Graphical Weather Link (graphical.weather.gov/sectors/conusFireWeek.php): A NWS
website providing weather, water and climate data, forecasts and warnings for the United States for the protection of life and property. The Fire Weather page provides a daily and weekly view of multiple weather and environmental conditions influencing wildfire activity.
8.5. Idaho Power Weather Model
Idaho Power maintains its own Weather Research and Forecasting (WRF) model using high-resolution data from Idaho Power’s weather stations across its service area. This model,
along with publicly available weather models, helps develop weather forecasts that include
timing, duration and intensity of weather systems. An Idaho regional WRF low-resolution map view is available to the public at atmo.boisestate.edu/view/.
8.6. Storm Prediction Center Fire Weather Outlooks
The Storm Prediction Center’s Fire Weather Outlook provides a current, one-day-ahead and three- to eight-day forecast for wildfires over the contiguous United States. This forecast takes into account pre-existing fuel conditions combined with predicted weather conditions that result in a significant risk of wildfire ignition or spread.
8.7. Current Weather Observations
Identifying real-time wildfire weather and associated risks requires predicting conditions that could trigger a PSPS based on observing current weather conditions. Resources available for
observing current weather conditions include direct, real-time data from Idaho Power’s network
of weather stations, available real-time wind speed information from Idaho Power’s network of Smart Grid Meters (SGM), as well as Windy: Wind Map and Weather Forecast and the National Weather Service National Oceanic and Atmospheric Administration’s (NOAA) Weather and Hazards Viewer.
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8.8. National Significant Wildland Fire Potential
Forecast Outlook
The National Significant Wildland Fire Potential Forecast Outlook provides wildland fire
expectations for the current month, the following month and a seasonal look at the two months
beyond that. The main objective of this tool is to provide information to fire management decisionmakers for proactive wildland fire management, reducing firefighting costs and improving firefighting efficiency.
8.9. Great Basin Coordination Center Morning Briefing
The Great Basin Coordination Center (GBCC) is the focal point for coordinating the mobilization of resources for wildland fire and other incidents throughout the Great Basin Geographic Area, which encompasses Utah, Nevada, Idaho south of the Salmon River, the western Wyoming mountains and the Arizona Strip. The GBCC hosts a morning briefing
(around 10 a.m. most mornings) that provides situational awareness for Idaho Power's service area.
8.10. GBCC Current and Predicted ERC and F100
The GBCC as described above also provides day-ahead Energy Release Component (ERC), 100-Hour Fuel Moisture (F100) and other fuels conditions information that helps Idaho Power understand wildfire potential in the service area.
8.11. Agency Input
Idaho Power works with Boise NWS Fire Forecasters through daily briefings and NIFC Predictive Service Forecasters on an as-needed basis, generally regarding data clarification, to streamline the transfer of data, information and communications about wildland fire critical to
Idaho Power's service area.
Idaho Power works with other agencies, including the U.S. BLM and U.S. Forest Service, as wildland fires approach and impact Idaho Power T&D facilities.
8.12. De-Energization Windspeed Considerations
Idaho Power’s service area covers 24,000 square miles across southern Idaho and eastern Oregon. The environmental factors across this area vary drastically from high desert landscape to mountainous terrain. Weather and environmental conditions also vary greatly within this area. Regional vegetation becomes “conditioned” to withstand different environmental conditions,
which also influences de-energization thresholds. Idaho Power developed windspeed
considerations, which it will continue to refine with additional data and weather technology based on historic wind conditions compared to system outage information.
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8.13. Engineering Assessment
Idaho Power follows robust transmission and distribution maintenance and inspection practices. When a potential PSPS event is identified, Idaho Power’s T&D Maintenance and Engineering department will evaluate potential impacts to current or planned maintenance activities.
8.14. Alternative Protective Measures
Considering the significant potential impact of a PSPS to customers, Idaho Power will thoroughly evaluate other potential alternatives for reducing wildfire risk prior to implementing a PSPS.
8.15. Real-time Field Observations
Idaho Power uses SGMs for various purposes on its the distribution systems, including communication (where available) to provide near real-time information and to detect wind speed with anemometers. This information is displayed on a GIS viewer and used to inform
Idaho Power’s evaluation and decision-making during storm events.
Idaho Power may also deploy field personnel to evaluate if a PSPS event should be initiated.
8.16. Other
Idaho Power plans to evaluate expanding existing capabilities to enhance weather forecasting and add new capabilities to detect fires.
9. RESPONSIBILITIES
Developing and implementing PSPS protocol involves various groups throughout the company.
Below is a non-exhaustive list of responsibilities by department, representatives of which will
work together to promote organized, consistent and safe implementation of PSPS events.
9.1. Load Serving Operations
• Develop and implement safe and reliable power shutoff protocols and procedures
• Ensure System and Regional Dispatch employees are appropriately trained to perform relevant responsibilities under this PSPS Plan, and that such employees receive timely information regarding wildfire risk and weather conditions for purposes of performing
those responsibilities in the event of a PSPS
• Assist with PSPS evaluation and decision-making
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• Safely restore service to PSPS areas when notified by Customer Operations it is safe to re-energize
• Provide required notifications to public safety partners to enhance public safety
• Participate in After-Action Reviews (AAR) (further discussed in Section 13 below) and ensure modifications to PSPS protocol are implemented as necessary
9.2. Atmospheric Science
• Monitor daily, weekly and long-term weather forecasts
• Monitor fuels conditions and trends
• Monitor Fire Weather Watches, Red Flag Warnings and High Wind Watches and Warnings
• Communicate with external agencies for increased situational and conditional awareness.
Increase communications as conditions require
• Communicate internally to Idaho Power’s Transmission & Distribution Engineering and Reliability (TDER) senior manager when extreme conditions indicate a PSPS event is likely
• Support PSPS activities such as planning, training and exercises
• Assist in PSPS information-gathering, evaluation and decision-making
• Participate in AARs and ensure modifications to PSPS protocol are implemented
as necessary
9.3. TDER Senior Manager
• Oversee wildfire mitigation program and support cross-departmental collaboration
• Monitor daily, weekly and long-term weather and wildfire forecasts
• Monitor Fire Weather Watches, Red Flag Warnings and High Wind Watches and Warnings
• Develop and lead training modules for PSPS implementation
• Activate the PSPS Assessment Team if a PSPS is likely
• Communicate with Oregon and Idaho ESF-12
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• Ensure PSPS activities such as operations planning, training and exercises occur annually
• Ensure a coordinated and cohesive external and internal communication and notification
plan is in place and reviewed annually
• Coordinate with Atmospheric Science to continue evaluating enhancements to situational awareness capabilities
• Participate in AARs and provide input on, and monitor as necessary, modifications to PSPS protocol
9.4. Customer Operations and T&D Construction
• Develop and implement safe and reliable power shutoff protocols and procedures
• Ensure field personnel are appropriately trained to perform all relevant responsibilities under this PSPS Plan
• Assist in PSPS information-gathering, evaluation and decision-making
• Ensure crews and equipment are available to support PSPS events
• Perform field observations, line patrols and other PSPS tasks as necessary
• Perform required repairs to safely re-energize the system after a PSPS event
• Request/obtain air patrol contractors for line inspections as required
• Participate, with assistance from Corporate Communications, in Idaho Power’s general
external education campaign
• Develop, with assistance from Corporate Communications, a cohesive notification framework with public safety partners while consistently evaluating ways to increase communication and outreach effectiveness
• Engage with public safety partners and critical facilities before, during and after a PSPS event
• Participate in AARs and ensure modifications to PSPS protocol are implemented as necessary
9.5. Supply Chain/Stores
• Ensure preparedness for wildfire season with materials readily available for
restoration purposes
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• Work with Customer Operations and T&D Construction in response to a PSPS event, which could include pre-event activities such as staging materials and supplies
• Participate in AARs and ensure modifications to PSPS protocol are implemented as necessary
9.6. Fleet/Equipment Resource Pool
• Ensure employees are appropriately trained to perform all relevant responsibilities under this PSPS Plan
• Ensure readiness of employees and resource pool equipment for a PSPS event
• Participate in AARs and ensure modifications to PSPS protocol are implemented as necessary
9.7. Supply Chain Contracting
• Ensure contract resources are appropriately trained to perform all relevant responsibilities under this PSPS Plan
• Work with Customer Operations to provide contracting resources as required
• Participate in AARs and ensure modifications to PSPS protocol are implemented as necessary
9.8. Substation Operations
• Monitor substations and perform actions to support PSPS operations
• Coordinate activities with Dispatch and Customer Operations
• Participate in AARs and ensure modifications to PSPS protocol are implemented
as necessary
9.9. Corporate Communications
Corporate Communications will develop and execute PSPS communications to Idaho Power customers and employees and support other business units in their communication efforts with regulators, critical facility operators, public safety partners and other stakeholders.
Corporate Communications will:
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• In coordination with Customer Operations and Regulatory Affairs, work with public safety partners, critical facilities, regulators and other stakeholders to develop a
comprehensive, coordinated and cohesive customer notification framework.
• With input from public safety partners, develop and implement a wildfire education and awareness campaign focused on wildfire prevention and mitigation, PSPS awareness and outage preparedness for customers.
• In the event of a PSPS:
• To the extent possible and in coordination with Customer Service and IT, notify customers before, during and after a PSPS event with the following information:
• Expected timing and duration of the PSPS event
• 24-hour contact information and website resources
• Provide up-to-date information on a dedicated Idaho Power PSPS webpage
prominently linked on the Idaho Power homepage.
• Distribute information via media and social media channels.
• Participate in AARs and modify communication practices as necessary.
9.10. Distribution Engineering and Reliability
• Support Dispatch and Customer Operations in developing de-energization and re-energization plans for PSPS events
• Monitor and verify the protection system operated correctly after any device operations caused by events on the circuit as appropriate
• Evaluate and enact protective device setting changes as required.
• Support rapid repairs of damaged infrastructure as needed.
• Support Load Serving Operations in planning improvements to PSPS operational capabilities
• Participate in AARs and ensure modifications to PSPS protocol are implemented
as necessary
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9.11. Safety
• Ensure the safety professionals are appropriately trained to perform all relevant responsibilities under this PSPS Plan
• Provide PSPS training for field personnel
• Assist in AARs after a PSPS event (or potential event in which the PSPS Team is activated)
9.12. Vegetation Management
• Following de-energization, and when it is safe to do so, Customer Operations will report impacts to infrastructure and assets from vegetation, as appropriate. Vegetation Management will then work toward removing vegetation debris necessary for re-energization.
• Ensure contractors and field personnel are appropriately trained to perform all relevant responsibilities under this PSPS Plan.
• Use reasonable efforts to ensure contract resources are available and prepared for
PSPS events.
• Participate in AARs and ensure modifications to PSPS protocol are implemented as necessary.
9.13. Geographic Information Systems
• Work with Customer Operations and Corporate Communications to develop PSPS boundary information for PSPS GIS maps required for the PSPS website
• Before wildfire season and during preliminary notifications of a potential PSPS event,
provide relevant GIS data within the confines of applicable law to public safety partners
9.14. Customer Service
• Respond to customer calls and respond to questions with information provided by Corporate Communications
• Ensure customer service representatives are trained to manage customer interactions during a PSPS event
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9.15. Communication Systems (Stations)
• Provide monitoring and on-call presence for the following:
• Radio communications and infrastructure
• Network infrastructure and connectivity
• SCADA communications
• Ensure readiness to deploy mobile 2-way radio trailer during a PSPS event
• Participate in AARs and ensure modifications to PSPS protocol are implemented
as necessary
9.16. Customer Operations Support
• May lead AARs to ensure modifications to PSPS protocol are implemented as necessary
9.17. Legal
• Provide legal guidance in evaluating a potential PSPS event
• May direct AARs after a PSPS event (or potential event in which the PSPS Team is activated)
• May be involved in reviewing communications to customers, public safety partners and
critical facilities
9.18. Regulatory
• May provide regulatory guidance in evaluating a potential PSPS event
• May be involved in reviewing communications to customers, public safety partners and critical facilities
• Assist in/direct regulatory reporting/filing activities
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10. PSPS OPERATIONS
10.1. General
Section 11 details the phases, and protocol within each phase, of a PSPS event. Additional procedures are found in plans linked below and the attached Appendices as referenced herein.
Table 2 below summarizes the PSPS phases.
Table 1 Incident phase decision triggers

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10.2. PSPS Preparedness
PSPS preparedness is a cyclical effort involving Idaho Power, public safety partners, state and local governments, communities and customers. Idaho Power’s main objectives of preparedness are: 1) performing wildfire prevention and mitigation activities; and 2) engaging with external public safety partners, critical facilities and communities to develop relationships and provide education to safely and effectively implement this plan. The TDER senior manager coordinates
and facilitates activities of multiple Idaho Power business units for wildfire prevention and mitigation activities while Customer Operations and Corporate Communications facilitates public outreach and coordination efforts with external stakeholders.

Figure 1 PSPS Preparedness Cycle
Idaho Power’s goal is to take a community approach to wildfire preparedness by educating and encouraging individual preparedness and relying on existing protocols and procedures currently available through local governments and emergency response professionals.
10.2.1. Idaho Power Programs
Idaho Power’s WMP facilitates PSPS preparedness through vegetation management protocol
specific to wildfire season, distribution and transmission hardening efforts, situational awareness
coinciding with wildfire operational protocol, training programs, communications strategies and coordinated planning with both internal and external stakeholders. This PSPS Plan and emergency response protocol correspond with Idaho Power’s WMP preparedness measures in an effort to further reduce wildfire risk consistent with industry best practices and
regulatory requirements.
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10.2.2. Coordination with Government Entities
Coordination with local government and emergency response entities is critical to Idaho Power’s reliance on existing protocols and procedures developed by these external stakeholders. Customer Operations engages in these coordination efforts through ongoing communications and
additional activities as required by this Plan. Activities include, without limitation:
• Being a trusted energy advisor to mayors, city managers, county leaders, elected officials and other stakeholders
• Educating and encouraging individual preparedness
• Educating stakeholders about Idaho Power wildfire preparedness and mitigation efforts, PSPS planning and capabilities
• Enhancing relationships with external stakeholders for improving interoperability and
wildfire coordination
• Enhancing relationships with community services partnerships
10.2.3. Community Preparedness
Engage with public sector agencies and communities where PSPS events are likely to leverage existing emergency response plans and resources to increase the effectiveness of PSPS communications.
10.2.4. Information Sharing
Coordinate with public safety partners in advance of a PSPS event to prepare information needed
by these partners and establish communication protocols for critical decision-making before and during a PSPS event, including restoration activities.
10.2.5. Notifications and Emergency Alerts
Collaborate with agencies in advance of PSPS events to allow for use of existing notification methods to communicate effectively during PSPS events.
10.2.6. Training and Exercises
Coordinate and participate in tabletop exercises with public safety partners to enhance
knowledge of each other’s emergency operations for smooth interactions during PSPS events.
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10.3. Proactive Communications
Although the size of Idaho Power’s service area, geographic and environmental diversity, and unpredictable nature of Idaho and Oregon weather make it challenging, Idaho Power is committed to providing as much advance notice as reasonably possible in preparation for a PSPS event. Table 3 provides Idaho Power’s optimal communication timeline for PSPS events, circumstances permitting.

Figure 2 PSPS Event Communication Timeline

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10.4. Wildfire Season Operations
As described here and in Idaho Power’s WMP, normal operations during wildfire season differs from normal operations during the rest of the year based on heightened requirements specifically targeted at predicting and reducing wildfire risk.
10.4.1. Situational Awareness Activities
During wildfire season, Idaho Power closely monitors fire conditions and weather patterns. Idaho Power’s Atmospheric Science team prepares a monthly “Seasonal Wildfire Outlook”
report beginning in April and continuing through wildfire season containing information on
regional drought conditions obtained from the National Drought Monitor, weather and climate outlook, seasonal precipitation and temperature outlooks from NOAA and the NWS, and a regional wildfire outlook.
During wildfire season, the Atmospheric Scientists will determine a daily FPI as described in
Section 5.2 of the WMP describing shorter-term weather and fire conditions specific to WMP
risk zones across Idaho Power’s service territory and in identified risk zones where transmission facilities extend beyond service territory boundaries.
10.4.2. GIS Wildfire Information
Idaho Power’s GIS team pulls regional wildfire information from a feature layer sourced by the GIS mapping software company ESRI, which pulls the data from the Integrated Reporting of
Wildland-Fire Information (IRWIN) and the National Interagency Fire Center (NIFC).
This information is added to multiple GIS viewers utilized by Idaho Power employees. These viewers also overlay current wildfire information to geospatially show physical relationships to transmission and distribution lines which provides valuable situational awareness in understanding wildfire activity near Idaho Power’s T&D systems. This information is updated near real-time.
10.4.3. Key Grid Interdependent Utilities and Agencies
Idaho Power exchanges dispatch information with key grid interdependent utilities and energy
providers to expedite communication and coordination during wildfire events. These contacts include Avista, Bonneville Power Administration, Northwestern Energy, NVEnergy, Oregon Trail Electric Cooperative, PacifiCorp, Raft River Electric, Seattle City Light and U.S. Bureau of Reclamation. Idaho Power also exchanges dispatch information with NIFC, BLM Fire
Dispatch and various National Forest Service District Offices—including Idaho Power dispatch
receiving BLM and US Forest Service incident command information during wildfire events—to improve communication and coordinate fire-related activities.
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10.5. Phase 1
The decision to implement a PSPS event will be based on the best available data for weather and other fire-related conditions as detailed above in Section 8—PSPS Implementation Considerations. Multiple events may require simultaneous management such as other storm-related outages or other PSPS events.
10.5.1. PSPS Assessment Team Activation
Idaho Power will transition from normal wildfire season operations to Phase 1 of a PSPS event at
the direction of the TDER senior manager. During Phase 1, Idaho Power will activate the PSPS
Assessment Team, which includes the TDER senior manager, a regional senior manager of the area potentially impacted, Load Serving Operations (LSO) senior manager, a documentation subject matter expert (SME), and representatives from the Atmospheric Science team and Corporate Communications. The PSPS Assessment Team will hold conference calls as needed to
discuss current and forecasted weather conditions and other critical information regarding a
potential PSPS event. The TDER senior manager will facilitate PSPS Assessment Team meetings and conference calls and the PSPS Assessment Team will be responsible for determining whether to recommend maintain Phase 1, escalate to Phase 2, or de-escalate to normal operations. The PSPS Assessment Team will decide if Idaho Power will issue a
preliminary notification of a potential PSPS event to public safety partners, critical facilities
operators and ESF-12 as described in Table 3 above. During Phase 1, the PSPS Assessment Team will review the PSPS Plan and supporting documents. An operational risk assessment will be performed as well to determine current operational factors (existing outages, facilities under construction, personnel availability, etc.), risks and vulnerabilities. Ultimate determination will
be made whether to escalate to Phase 2 by the TDER senior manager. Within one hour of Phase
2 notification, the full PSPS team will be placed on stand-by and team member availability will be determined. The full PSPS team is the PSPS Assessment Team plus the VP of Planning, Engineering and Construction, the Customer Operations VP and VP of Power Supply or their assigns.
10.5.2. Community Notifications
Depending on the situation and timing, public safety partners and critical facility operators may
be notified during this phase. These notifications may include emails, text messages and/or phone calls as described in Idaho Power internal processes and procedures.
10.6. Phase 2
Phase 2 actions are determined by additional situational awareness activities, timing of forecasted weather events and risk tolerance. Upon transitioning to Phase 2, Idaho Power will provide external notifications as called out in Table 3 above with specific roles and responsibilities as described in internal process and procedure documents.
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10.6.1. Activate Event Coordinator
Idaho Power will assign an Event Coordinator as outlined in Wildfire Mitigation and PSPS Plan. The event coordinator’s main role is to coordinate activities across the region associated with PSPS implementation and restoration.
10.6.2. Conduct Operational Risk Analysis
The PSPS Assessment Team will present its operational risk analysis recommendation to the VP
of PEC, VP of Customer Operations and the COO who will then evaluate the PSPS Assessment Team’s recommendation, and the COO will make the final determination of whether to proceed to Phase 3 implementation of a PSPS event.
10.6.3. Request to Delay a PSPS Event
There may be requests to delay proactive de-energization from the public safety partners. This may occur for several reasons, with the most anticipated being loss of power for pumping
water to fight wildfires. Delay requests should be routed through dispatch and sent to the PSPS
Team for evaluation. The PSPS Team will provide the COO a recommendation on whether to approve the proactive de-energization delay and the COO will make the final decision. As soon as practicable after receiving the request, Idaho Power will notify the ESF-12 liaison of the delay request and basis of such request, as well as the final determination and the
underlying justification.
10.6.4. PSPS Event Strategy
Regional operations personnel developed action plans and switching orders as part of their preparedness activities. These plans and switching orders will be reviewed and refined as necessary based on the current and forecasted conditions and will include situation-specific tactics and detailed instructions.
10.6.5. Field Observations and Response Teams
Regional Operations will coordinate field personnel to be mobilized and dispatched to strategic
locations, including areas with limited weather and system condition visibility, to perform field
observations for on-the-ground, real-time information critical to inform decisions on proactive de-energization. Field observations include—without limitation—conditional assessments of system impacts from wind and vegetation, flying debris and slapping conductors.
10.6.6. Customer and Community Notifications
Depending upon the timing and situation, Idaho Power may use various forms of communication
(including media outreach) to provide information and updates to public safety partners,
critical facility operators, and customers, particularly those impacted by the PSPS event. Information and updates will include the reason for the potential de-energization, where to find
Idaho Power Company Wildfire Public Safety Power Shutoff Plan
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real-time updates on outage status and other relevant safety and resources. Internal processes and procedures will be followed to ensure accurate, up-to-date communication is provided.
10.7. Phase 3
Upon the COO making a determination to proactively de-energize, the LSO representative of the PSPS Team will inform System and Regional Dispatch Operations and request coordination of the estimated time to begin the PSPS. The regional manager, or their assigned representative of
the region in which the PSPS will take place, will coordinate with the event coordinator to pre-position field personnel where manual de-energization is required and to stand by for orders to de-energize. System and Regional Dispatch Operations will implement the PSPS according to their established processes. Stations and communications system operations personnel will be
prepared to support PSPS activities as needed. Idaho Power will take the following
community-centered actions as soon as safely possible. Regional teams will follow internal processes and procedures to safely and effectively implement a PSPS event.
10.7.1. Customer and Community Notification
Relying on internal processes and procedures, Idaho Power will use various forms of communication (including media outreach) to provide information and updates to customers and other stakeholders, particularly those impacted by the PSPS event. Information and updates will
include the reason for the de-energization, where to find real-time updates on outage status and
other relevant safety and resource information regarding the PSPS. Specific protocols may be included in individual work group plans.
10.8. Phase 4
10.8.1. System Inspections
When it is safe to do so, Idaho Power will begin line patrolling activities to inspect T&D circuits and other potentially impacted Idaho Power facilities. Patrol personnel will report system conditions back to System and Regional Dispatch Operations for coordination with field crews. Patrols will be performed as required to ensure conditions and equipment are safe
to re-energize.
10.8.2. Repair and Recovery
Line crews will repair T&D facilities as coordinated with System and Regional Dispatch
Operations, replacing damaged equipment and performing other actions to support safe re-energization of the T&D system.
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10.8.3. Incident Management Support
Support throughout the PSPS event will continue as described in Idaho Power’s Wildfire Mitigation and PSPS Operational Plan. The PSPS Team will continue to monitor fire and weather conditions. Logistics and mutual assistance requirements will be determined and acted
upon per existing plans and processes. If timely re-energization is not possible based on the
magnitude of the event, the EMT will be notified for additional support.
10.8.4. Communicate PSPS Event Conclusion
Idaho Power will use various forms of communication (including media outreach) to inform customers and other stakeholders, particularly those impacted by the PSPS event, when repairs are complete and it is safe to re-energize the system. This may occur in stages as different
feeders or feeder sections are repaired and safe to re-energize. This will be viewable on the
outage map on Idaho Power’s website during the event. Idaho Power will also leverage existing public agency outreach and notification systems as done at other points in the PSPS process.
10.8.5. Re-energization
Once re-energization activities are completed and service is restored, crews and support staff will demobilize and return to normal fire season operations as described in internal process and procedure documents.
10.9. Post-incident Review
During the PSPS phases the documentation SME will collect and maintain in the Regional Dispatch Operations logs incident information required for reporting purposes.
Following conclusion of a PSPS event, the Regional Manager or their assigned representative
will conduct informal, high-level debriefs to identify potential modifications to PSPS protocol based on lessons learned during the event. The regional manager or assigned representative will consolidate the feedback and provide to the documentation SME.
Also following the PSPS event, the TDER senior manager will conduct an AAR with the PSPS
Team to identify potential modifications to PSPS protocol based on lessons learned during the
event. The TDER senior manager will consolidate the feedback and provide to the documentation SME.
After wildfire season, the Customer Operations support leader may conduct an AAR focusing on operational processes, communications, customer support as well as emergency response and
restoration. Idaho Power may also request feedback from external stakeholders on coordination
efforts, communications and outreach effectiveness for integration into the AAR report.
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11. FINANCIAL ADMINISTRATION
Idaho Power will track expenses related to PSPS events for OPUC and IPUC reporting and
potential recovery. Expense should be tracked for the entire PSPS event (Phase 1 through
conclusion of the Post-Incident Review and filing the PSPS event report with the OPUC) to include, without limitation, time reporting, equipment and supplies used to set up customer resource centers and provided to customers (e.g., water, ice, etc.)
12. REPORTING
Employees are required to manage information regarding PSPS events pursuant to Idaho Power’s Information Retention Policy and underlying standards. Idaho Power will submit reports to the IPUC and OPUC as required.
13. AFTER-ACTION REPORT
An AAR is a structured review or de-brief process used to evaluate the effectiveness of the Plan
and potential areas for improvement. This process may be performed after a PSPS event and may be confidential at the direction of Legal to improve the PSPS processes and procedures.
14. TRAINING
Idaho Power will strive to provide annual training, prior to or shortly after the beginning of
wildfire season, to relevant employees on their respective roles in performing this PSPS Plan.
15. EXERCISES
Idaho Power will exercise this PSPS Plan at least annually using various scenarios and testing all or any portion(s) of the Plan which may include:
• Testing text and/or phone alerts with a test group of public safety partners
• Testing tactical operational plans such as reporting field observations or positioning employees at manually operated disconnects to test timing for
de-energization and field inspections of T&D assets
• Discussing and/or practicing roles and responsibilities of both strategic and tactical operations, including decision-making handoffs and hypothetical scenarios
• Discussing and/or developing re-energization plans
• Testing capacity limits on incoming and outgoing communications systems
Oregon Wildfire Requirements and Recommendations Idaho Power Company
Appendices
Appendix C Oregon Wildfire Requirements and Recommendations.
Oregon Requirements and Recommendations
This appendix provides additional information specific to wildfire-related requirements, as well as wildfire-related recommendations, in Oregon.
Oregon Administrative Rule (OAR) Requirements
Below is a mapping of wildfire mitigation plan rules to sections within Idaho Power’s WMP.
Wildfire Protection Plan Filing Requirements—OAR 860-300-0020
Oregon Requirement—OAR 860-300-0020 Corresponding Location in WMP
(1) Wildfire Protection Plans and Updates must, at a minimum, contain
the following requirements as set forth in Section 3(2)(a)-(h), chapter 592, Oregon Laws 2021 and as supplemented below:
(a) Identified areas that are subject to a heightened risk of wildfire, including determinations for such conclusions, and are:
See Section 3: Quantifying Wildland Fire Risk
See Idaho Power website for details of wildfire risk zones outside of service territory
(A) Within the service territory of the Public Utility, and
(B) Outside the service territory of the Public Utility but within the Public Utility's right-of-way for generation and transmission assets.
See Section 3.2.2: Wildfire Risk Areas See Figure 3: Boardman to Hemingway (B2H) Proposed Route Risk Zones
(b) Identified means of mitigating wildfire risk that reflects a reasonable
balancing of mitigation costs with the resulting reduction of wildfire risk.
See Section 4: Costs and Benefits of Wildfire Mitigation
(c) Identified preventative actions and programs that the Public Utility
will carry out to minimize the risk of utility facilities causing wildfire.
See Section 5: Situational Awareness; Section 6: Mitigation—Field Personnel Practices; Section 7: Mitigation—Operations; Section 8: Mitigation—T&D Programs; and Section 8.3: T&D Vegetation Management
(d) Discussion of outreach efforts to regional, state, and local entities, including municipalities regarding a protocol for the de-energization of power lines and adjusting power system operations to mitigate
wildfires, promote the safety of the public and first responders and preserve health and communication infrastructure.
See Section 10.2 Community Outreach and Section 10.2.1: Community Engagement See Appendix B: Idaho Power's Public Safety Power Shutoff Plan, Section 10.2.1: Coordination with Government Entities and Section 10.2.2: Community Preparedness
(e) Identified protocol for the de-energization of power lines and adjusting of power system operations to mitigate wildfires, promote the safety of the public and first responders and preserve health and
communication infrastructure.
See Section 7.4: Public Safety Power Shutoff and Appendix B: Idaho Power's Public Safety Power Shutoff Plan
(f) Identification of the community outreach and public awareness
efforts that the Public Utility will use before, during and after a wildfire season.
See Section 10: Communicating About Wildfire
Idaho Power Company Oregon Wildfire Requirements and Recommendations
Appendices
Oregon Requirement—OAR 860-300-0020 Corresponding Location in WMP
(g) Description of procedures, standards, and time frames that the
Public Utility will use to inspect utility infrastructure in areas the Public Utility identified as heightened risk of wildfire.

For Transmission, see Section 8.2.1: Transmission Asset Management Programs (with information on aerial, ground, detailed visual, pole, and other protection programs) For Distribution, see Section 8.2.2: Distribution Asset Management Programs
(with information on visual, pole, and line equipment inspection programs)
(h) Description of the procedures, standards, and time frames that the Public Utility will use to carry out vegetation management in in areas
the Public Utility identified as heightened risk of wildfire.
See Section 8.3.2: Transmission Vegetation Management and Section 8.3.3: Distribution Vegetation Management
(i) Identification of the development, implementation, and administrative costs for the plan, which includes discussion of risk-based cost and benefit analysis, including consideration of
technologies that offer co-benefits to the utility's system.
See Section 4: Costs and Benefits of Wildfire Mitigation, specifically Section 4.3: Wildfire Mitigation Cost Summary and Section 4.4: Mitigation Activities
(j) Description of participation in national and international forums,
including workshops identified in Section 2, chapter 592, Oregon Laws 2021, as well as research and analysis the Public Utility has
undertaken to maintain expertise in leading edge technologies and operational practices, as well as how such technologies and operational practices have been used develop implement cost
effective wildfire mitigation solutions.
See Section 2: Government, Industry, and Peer Utility Engagement

Risk Analysis—OAR 860-300-0030
Oregon Requirement—OAR 860-300-0030 Corresponding Location in WMP
(1) The Public Utility must include in its Wildfire Mitigation Plan risk analysis that describes wildfire risk within the Public Utility’s service
territory and outside the service territory of the Public Utility but within the Public Utility’s right of way for generation and transmission assets. The risk analysis must include, at a minimum:
(a) Defined categories of overall wildfire risk and an adequate discussion of how the Public Utility categorizes wildfire risk. Categories
of risk must include, at a minimum:
See Section 3: Quantifying Wildland Fire Risk

See Section 3.2.2: Wildfire Risk Areas and risk zone map on Idaho Power’s website for detailed map of wildfire risk zones
(A) Baseline wildfire risk, which include elements of wildfire risk that are expected to remain fixed for multiple years. Examples include topography, vegetation, utility equipment in place, and climate;
(B) Seasonal wildfire risk, which include elements of wildfire risk that are expected to remain fixed for multiple months but may be dynamic throughout the year or from year to year; Examples include cumulative
precipitation, seasonal weather conditions, current drought status, and fuel moisture content;
(C) Risks to residential areas served by the Public Utility; and

See Section 3.2 for discussion of fixed risk elements
See Section 3.2.1 for discussion of variable risk elements that change throughout the year

See Section 3.2.1 paragraph 4 addresses the consideration of residential areas in risk analysis
Oregon Wildfire Requirements and Recommendations Idaho Power Company
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Oregon Requirement—OAR 860-300-0030 Corresponding Location in WMP
(D) Risks to substation or powerline owned by the Public Utility.

See Section 3.2.1 paragraph 4 addresses overhead power lines. Note: Idaho Power does not model wildfire progression or spread within substations due to zero vegetation within the fenced area.
Also see Section 3.2.2.1 for discussion of risk modeling of proposed Boardman to
Hemingway transmission line
(b) a narrative description of how the Public Utility determines areas of heightened risk of wildfire using the most updated data it has available from reputable sources.
See Section 3.2.2: Wildfire Risk Modeling Process and the 2023 Risk Modeling Update
(c) a narrative description of all data sources the Public Utility uses to
model topographical and meteorological components of its wildfire risk as well as any wildfire risk related to the Public Utility’s equipment.
See Section 11.4: Wildfire Risk Map
source of data is updated; and
(B) The Public Utility must make clear how it plans to keep its data
sources as up to date as is practicable.
See Section 11.4: Wildfire Risk Map

(d) The Public Utility’s risk analysis must include a narrative
description of how the Public Utility’s wildfire risk models are used to make decisions concerning the following items:
(A) Public Safety Power Shutoffs
(B) Vegetation Management;
(C) System Hardening;
(D) Investment decisions; and
(E) Operational decisions.

A) See Section 7.5.2: PSPS Plan B) See Section 8.3: T&D Vegetation Management C) See Executive Summary on Infrastructure Hardening; Section 8.2.2: Distribution Asset Management Programs; Section 11.9: Long-Term Metrics D) Risk analysis informs Red and Yellow Risk Zones mitigation activities. See Section 4: Costs and Benefits of Wildfire Mitigation and Section 4.4 Mitigation Activities E) See Section 7.2: Operational Protection Strategy and Appendix A: Wildland Fire Preparedness and Prevention Plan
(e) For updated Wildfire Mitigation Plans, the Public Utility must include a narrative description of any changes to its baseline wildfire
risk that were made relative to the previous plan submitted by the utility, including the Public Utility’s response to changes in baseline wildfire risk, seasonal wildfire risk, and Near-term Wildfire Risk.
For the 2023 WMP, Idaho Power did not make changes to baseline wildfire risk, but will evaluate and discuss changes in the 2024 WMP.
Idaho Power Company Oregon Wildfire Requirements and Recommendations
Appendices
Oregon Requirement—OAR 860-300-0030 Corresponding Location in WMP
(2) To the extent practicable, the Public Utility must confer with other
state agencies when evaluating the risk analysis included in the Public Utility’s Wildfire Mitigation Plan.
See Executive Summary section on Lessons Learned: Community Feedback
Wildfire Mitigation Plan Engagement Strategies—OAR 860-300-0040
Oregon Requirement—OAR 860-300-0040 Corresponding Location in WMP
(1) The Public Utility must include in its Wildfire Mitigation Plan a Wildfire Mitigation Plan Engagement Strategy. The Wildfire Mitigation Plan Engagement Strategy will describe the utility’s efforts to engage
and collaborate with Public Safety partners and Local Communities impacted by the Wildfire Mitigation Plan in the preparation of the Wildfire Mitigation Plan and identification of related investments and
activities. The Engagement Strategy must include, at a minimum:
(a) Accessible forums for engagement and collaboration with Public Safety Partners, Local Communities, and customers in advance of
filing the Wildfire Mitigation Plan. The Public Utility should provide, at minimum:
(A) One public information and input session hosted in each county
or group of adjacent counties within reasonable geographic proximity and streamed virtually with access and functional needs considerations; and
(B) One opportunity for engagement strategy participants to submit follow-up comments to the public information and input session.
See Section 10: Communicating About Wildfire

See Section 10.2: Community Outreach and Section 10.2.1: Community Engagement

See Section 10.2.1: Community Engagement and Section 10.3.1: Key Communication Methods

(b) A description of how the Public Utility designed the Wildfire Mitigation Plan Engagement Strategy to be inclusive and accessible,
including consideration of multiple languages and outreach to access and functional needs populations as identified with local Public Safety Partners.
See Section 10.2.1: Community Engagement and Section 10.3.1: Key Communication Methods

(2) The Public Utility must include a plan for conducting community
outreach and public awareness efforts in its Wildfire Mitigation Plan. It must be developed in coordination with Public Safety Partners and informed by local needs and best practices to educate and inform
communities inclusively about wildfire risk and preparation activities.
See Section 10.2.1: Community Engagement and Section 10.3.1: Key Communication Methods

(a) The community outreach and public awareness efforts will include
plans to disseminate informational materials and/or conduct trainings that cover:
(A) Description of PSPS including why one would need to be
executed, considerations determining why one is required, and what to expect before, during, and after a PSPS;
(B) A description of the Public Utility’s wildfire mitigation strategy;
(C) Information on emergency kits/plans/checklists;
(D) Public Utility contact and website information.
For (A) – (D), see Section 10.2.1: Community Engagement; Section 10.3: Customer Communications; and Section 10.3.1: Key Communication Methods
Oregon Wildfire Requirements and Recommendations Idaho Power Company
Appendices
Oregon Requirement—OAR 860-300-0040 Corresponding Location in WMP
(d) Discussion of outreach efforts to regional, state, and local entities,
including municipalities regarding a protocol for the de-energization of power lines and adjusting power system operations to mitigate
wildfires, promote the safety of the public and first responders and
preserve health and communication infrastructure.
(b) In formulating community outreach and public awareness efforts, the Wildfire Mitigation Plan will also include descriptions of:
(A) Media platforms and other communication tools that will be used to disseminate information to the public;
(B) Frequency of outreach to inform the public;
(C) Equity considerations in publication and accessibility, including, but not limited to:
(i) Multiple languages prevalent to the area;
(ii) Multiple media platforms to ensure access to all members of a Local Community.
See Section 10.2.1: Community Engagement

For (A)-(C): See Section 10.2.1: Community Engagement; Section 10.3: Customer
Communications, and Section 10.3.1: Key Communication Methods
(3) The Public Utility must include in its Wildfire Mitigation Plan a
description of metrics used to track and report on whether its
community outreach and public awareness efforts are effectively and equitably reaching Local Communities across the Public Utility’s
service area.
See Section 10.3.3: Communication Metrics
Strategy in its Wildfire Mitigation Plan. The Coordination Strategy will describe how the Public Utility will coordinate with Public Safety Partners before, during, and after the fire season and should be
additive to minimum requirements specified in relevant Public Safety Power Shut Off requirements described in OAR 860-300-0050. The Coordination Strategy should include, at a minimum:
(a) Meeting frequency and location determined in collaboration with Public Safety Partners;
(b) Tabletop Exercise plan that includes topics and opportunities to
participate;
(c) After action reporting plan for lessons learned in alignment with
Public Safety Partner after action reporting timeline and processes.
See Section 10.2.1: Community Engagement
OPUC Order Nos. 22-133 and 22-312
This appendix also addresses recommendations received from Oregon Public Utility Commission (OPUC) Staff in Docket No. UM 2209 and approved by the OPUC Order Nos. 22-133 and 22-312. The italicized text below reflects OPUC Staff’s specific
recommendations for the company.
Idaho Power Company Oregon Wildfire Requirements and Recommendations
Appendices
Recommendations Pertaining to OPUC Order No. 22-312
Category: Cost Allocation
1) Provide detailed cost allocation assumptions of the transmission and distribution patrol,
maintenance, and repair program, separated by transmission and distribution, as well as
any associated maintenance and repair program including justification and reasoning for
the cost allocation between Idaho and Oregon.

2) Provide details explaining the proposed cost allocation between Idaho and Oregon
associated with wildfire mitigation program capital investments.
Idaho Power removed the cost allocation information contained in an earlier version of the
WMP, as the WMP is intended as an evolving document and not one related to prudency of
specific investments.
To address Staff’s interest in this subject, the company will file a wildfire mitigation-related cost deferral application with the OPUC in December 2022 so it may be reviewed in concert with the 2023 WMP.
Category: Risk Framework
3) Provide detailed explanation of the strategy pertaining to its risk analysis framework.
See Executive Summary of WMP. Idaho Power carried out a review of risk management processes and will consider the ISO 31000-2018 framework and process in the 2023 WMP.
Recommendations Pertaining to OPUC Order No. 22-133
The following summarizes OPUC Staff’s recommendations for the company to include in its
2023 WMP.
Risk Modeling—OAR 860-300-0020 (1 )(a)(A) & (B):
1) Provide details regarding the mileage of overhead facilities that lie within its designated
YRZs and RRZs.
See Section 3.2.2. for details of overhead line mileage in designated wildfire risk zones.
2) Idaho Power provide details of the analysis completed for establishing the risk tiers and
the threshold values utilized for classifying the YRZs and RRZs.
See Section 3.2.2. Tier levels were established based on quantitative results of modeling and numerous workshops held with our consultant and individuals having local knowledge of topography, fuels, fire history, and overhead facilities in their area. Tier levels were generated
algorithmically as a starting point in the analysis and refined through workshops. Idaho Power
did not base tier levels solely on risk scores.
Oregon Wildfire Requirements and Recommendations Idaho Power Company
Appendices
3) Idaho Power provide information regarding an analysis of the risk from specific utility asset types.

See Section 3.2.1. The company used equal probability of ignition occurring on overhead transmission and distribution facilities in quantifying wildfire risk. As we mature our risk modeling methodology, the company plans to include reliability data to improve risk models.
4) Idaho Power provide details of the process and timing that will be followed to evaluate
the established heightened wildfire risk zones, and what data inputs and portions of the
analysis will be reviewed annually. See sections 3.2.1. and 11.4. Idaho Power is planning to update its risk modeling in 2023.
5) Idaho Power address the concerns raised by STOP B2H Coalition as thoroughly
as possible.
Idaho Power met with Stop B2H Coalition representative Jim Kreider on November 11, 2022, to provide an overview of the risk analysis performed for the Boardman to Hemingway (B2H) route. A presentation was delivered that highlighted Idaho Power’s approach to quantifying
wildfire risk and provided details of analysis performed along the B2H route that exceeded
analysis performed in other locations within the service area. Risk analysis conducted along the B2H route includes quantifying wildfire risk similarly to other overhead facilities as described in Section 3. In addition, the following was also performed:
• Analysis of surface fuels within 1 mile of the B2H route to determine the potential of
crown fire
• Determination of the influence of topographical slope on resistance to control and spread rate within 1 mile of the B2H route
• A review of temperature, precipitation, and relative humidity of the project site
• A review of the wildland urban interface and estimation of land use area within 1 and 10 miles of the project site
• A review of historic ignitions and the perimeter of historic fires within 50 miles of the
project site going back 50 years
Transmission design engineers at Idaho Power also reviewed the design of lattice and H-frame structures proposed for B2H construction. A review was performed to identify the design characteristics that lead to decreased potential of ignition. This information was shared with Mr. Kreider and the overall fire potential for the area surrounding Morgan Lake. Mr. Kreider
provided good feedback and recommended that Idaho Power meet with the new fire chief for the La Grande Rural Fire District and Baker County to compare risk maps and methodology. Idaho Power agreed and will have more engagement with Mr. Kreider and agencies in 2023. Additionally, the company plans to include the B2H route when reconducting risk modeling in 2023.
Idaho Power Company Oregon Wildfire Requirements and Recommendations
Appendices
WMP Effectiveness—OAR 860-300-0020 (1)(b):
6) Include a description of how it will measure the overall effectiveness of its wildfire
mitigation activities, as well as information on wildfires in the service territory for the
prior year. See the Executive Summary and Section 11.9. Metrics include tracking and monitoring
mitigation programs to identify gaps and areas requiring corrective action. Long-term metrics
were incorporated in 2022 to track potential drivers of ignition with respect to outage counts.
Plan Objectives—OAR 860-300-0020 (1)
7) Idaho Power include details on whether the objectives of key preventative actions outlined in previous year’s WMP have been met.

See the Executive Summary.
8) Idaho Power describe, to what degree, the preventable measures outlined in previous year’s WMP have reduced the risk of the utility’s infrastructure from causing ignitions.
See Section 11.9. Idaho Power believes that mitigation activities have reduced wildfire risk but
we need more time in concluding the magnitude of risk reduction. Idaho Power expects that reliability data and outage analytics will provide greater confidence of risk reduction with time.
9) Idaho Power describe any adjustments made to its wildfire prevention programs that were included in previous year’s WMP.

See the Executive Summary. Adjustments were made to pre-season wildfire patrols due to snow levels. Also, Idaho Power did not meet all vegetation management production goals set for the year and had to adjust quality assurance and control audits from 100% in wildfire risk zones to a random sample approach.
Outreach Efforts—OAR 860-300-0020 (1)(d)

10) Idaho Power include more detailed information about how it used learnings from the previous year to improve its 2023 Plan. The company should consider Public Safety Partner input through After Action Reports (from exercises and events), surveys or other
feedback mechanisms, and company lessons learned.
See the Executive Summary and Section 10.2.1.
11) Idaho Power include clarification about CRCs in its 2023 WMP Update, to include:
See sections 10.2.1. and 10.2.2.
12) Idaho Power incorporate the following in its 2023 WMP:

Oregon Wildfire Requirements and Recommendations Idaho Power Company
Appendices
• Map showing areas of its service territory at higher risk for PSPS events.
See PSPS program in Appendix B.

• List of Public Safety Partners the company engages with related to WMP.
Idaho Power maintains routine contact with county emergency managers and state-level Public Safety Partners for both Oregon and Idaho. Specific contacts can be provided upon request.
• Frequency of communication with Public Safety Partners.
See sections 10.2.1. and 10.2.2.4.
• Methods of communication with Public Safety Partners.
See Section 10.2.1.
• Feedback received from Public Safety Partners, and description of how the
information influences the WMP.
See Section 10.2.1.
Lessons Learned—OAR 860-300-0020 (1)(e)
13) Idaho Power include previous year’s lessons learned regarding de-energization of power
lines to include findings from after action reports, including survey results from exercises
and actual events (when available), in its 2023 WMP. See the Executive Summary. While Idaho Power did not call a PSPS event in 2022, there were
several lessons learned from functional exercises and one near PSPS event that was subsequently
canceled due to precipitation.
14) Idaho Power include more information about the analysis completed to make their programmatic decisions of modifying system operations. The information should clarify why the company describes plans for RRZs not YRZs, and differences in system
operations between transmission lines and distribution circuits.
See Section 7.2. Communication and Outreach—OAR 860-300-0020 (1)(f)
15) Idaho Power incorporate the following its 2023 WMP:

• Examples of messaging;
• Selection process for methods of outreach;
• Determination of target audience;
Idaho Power Company Oregon Wildfire Requirements and Recommendations
Appendices
• Metric and criteria used to evaluate effectiveness of outreach;
• Outcome of previous year’s outreach evaluation;
• Description of company personnel and external resources responsible for outreach efforts;
• Description of timing of the outreach, including before, during, and after
wildfire season;
• Description of Wildfire Mitigation Information/Resources maintained by the company on its website; and
• Description of Social Media Campaign developed and implemented by the company
to inform customers about potential wildfire impacts (i.e., potential loss of power,
preparedness, safety and awareness, etc.).
See Section 10.2.
16) Idaho Power conduct wildfire training and exercises and include a discussion about
community outreach and public awareness efforts prior to the upcoming fire season to
clarify these activities, and to solicit input from participating Stakeholders. See the Executive Summary and Section 10.2.

Asset Inspections—OAR 860-300-0020 (1)(g)
17) Idaho Power clearly identify inspection and correction procedures and protocols for non-wildfire risk zones, inspection and correction procedures and protocols for RRZs, and inspection and correction procedures and protocols for YRZs, along with the
impacted line miles and structure counts for transmission and distribution assets
in Oregon. See Section 3.2.2. for line miles in wildfire risk zones and Section 8.2. for details of programs taking place in those zones.

18) Idaho Power include logic and details of analysis completed for their inspection and
correction programming decisions in YRZs (and if any future RRZs) in Oregon. See Section 8.2.
Vegetation Management—OAR 860-300-0020 (1)(h)
19) Idaho Power clearly identify vegetation management practices and protocols for
non-wildfire risk zones, vegetation management practices and protocols for RRZs, and vegetation management practices and protocols for YRZs, along with the impacted line miles and structure counts for transmission and distribution assets in Oregon.
Oregon Wildfire Requirements and Recommendations Idaho Power Company
Appendices
See Section 8.3.
20) Idaho Power provide logic and details of analysis completed for their programming
decisions in YRZs (and if any future RRZs) in Oregon regarding vegetation management
practices and protocols. See sections 4.4.6. and 8.3.

21) Idaho Power provide more information regarding their quality control/quality assurance
program and audits for vegetation management work completed in the RRZs, YRZs, including measures employed and resource types.
See sections 8.3.2. and 8.3.3.4.

22) Idaho Power provide analysis of any historical events pertaining to its power lines, specific equipment type, vegetation, and wildfires that informed the program’s design and monitoring approach.

See Section 3.2.2. Expert Forums—OAR 860-300-0020 (1)(i)
23) Idaho Power discuss the impact of participation in expert forums
(see OAR 860-300-0020(1 )U)) on identification of solutions most likely to provide the
benefits anticipated. This should include:

• Cited research, reports, and studies used in any analysis, unless the source
is confidential.
• How the factors unique to the company's facilities and service territory were used when considering the applicability of specific options to its systems.
See Section 2.3. In addition to participation in wildfire mitigation forums, Idaho Power spent significant time in 2022 developing a six-year roadmap to integrate new technology into the
WMP. This consisted of researching products and meeting with 30 different companies throughout the year. We worked with the Electric Power Research Institute on gaining feedback of the performance and mitigation benefit of different technologies. Covered conductor was a key area of focus and helped develop a pilot plan. Additionally, the company has invested in the Westly Group, a fund that invests in startups focused on the digitalization and sustainability of
energy, mobility, buildings, and industrial technology. One of our focus areas with the Westly Group in 2022 was reviewing new wildfire technologies.
Idaho Power Company Oregon Wildfire Requirements and Recommendations
Appendices
The following were references used during the year to form changes in the 2023 WMP.
Wildfire Mitigation
Chiu, B., Rajdeep, R., and Thuan, T. 2022, January/February. Wildfire Resiliency. IEEE Power
& Energy, 20(1), 28–37.
Mead, J. and Schoenman, E. 2021, August 18. New Tools in the Fight to Reduce Wildfire Ignition. T&D World. www.tdworld.com/wildfire/article/21168997/new-tools-in-the-fight-to-reduce-wildfire-ignition
Moreno, R., Trakas, D., Jamieson, M., Panteli, M., Mancarella, P., Strbac, G., Marnay, C., and
Hatziargyriou, N. 2022, January/February. Microgrids Against Wildfires. IEEE Power & Energy, 20(1), 78-89.
North American Electric Reliability Corporation. 2021. Wildfire Mitigation Reference Guide.
Porter, T., Richwine, M., and Batjer, M. 2021. California Power Line Fire Prevention Field
Guide. California Office of the Sate Fire Marshal.
https://osfm.fire.ca.gov/media/3vqj2sft/2021-power-line-fire-prevention-field-guide-ada-final_jf_20210125.pdf
Serrano, R., Carvalho, M., Araneda, J., Alamos, O., Barroso, L., Bayma, D., Ferreira, R., and Moreno, R. 2022, January/February. Fighting Against Wildfires in Power Systems, IEEE
Power & Energy, 20(1), 38-51.
Sharafi, D., Dowdy, A., Landsberg, J., Bryant, P., Ward, D., Eggleston, J., and Liu, G. 2022, January/February. Wildfires Down Under. IEEE Power & Energy, 20(1), 52-63.
Udren, E. Bolton, C. Dietmeyer, D. Rahman, T., and Flores-Castro, S. 2022, January/February. Managing Wildfire Risks. IEEE Power & Energy, 20(1), 64-77.
Utility Products. 2019, October 24. Wildfire Mitigation: Doing Your Part to Prevent the Spark.
Utility Products. www.utilityproducts.com/safety/article/14069290/wildfire-mitigation-doing-your-part-to-prevent-the-spark
Wolfram, J. Urban, J., and Guillermo, R. .2022, January/February. Powerlines and Wildfires: Overview, Perspectives, and Climate Change. IEEE Power & Energy, 20(1), 16-27.
Advanced Relay Protection
Davoudi, M., Efaw, B., Avendano-Mora, M., Lauletta, J., and Huffman, G. “Reclosing of
Distribution Systems for Wildfire Prevention”. IEEE Transactions on Power systems, Vol 36, No. 4.
Eaton Power Systems (2021). Overcurrent Fault Data in The Form6
Oregon Wildfire Requirements and Recommendations Idaho Power Company
Appendices
Hayes, S., Hau, D., and Fischer, N. (2021) Understanding Ground Fault Detection Sensitivity and Ways to Mitigate Safety Hazards in Power Distribution Systems. Presented at the 57th
Annual Minnesota Power Systems Conference.
Hou, D. 2007. Detection of High Impedance Faults in Power Distribution Systems. Presented at the 6th Annual Clemson University Power Systems Conference, Clemson, South Carolina.
Kirkpatrick, B., Ramdoss, R., Bolbolian, V., Ojeda, A., Swisher, and A., Rorabaugh, J. 2022,
January 20). Heading Off Southern California Wildfires: Distribution Open Phase
Detection. T&D World. www.tdworld.com/wildfire/article/21182896/heading-off-southern-california-wildfires-distribution-open-phase detection?utm_source=TW+TDW+Energizing&utm_medium=email&utm_campaign=CPS220121036&o_eid=7607D2261456E6L&rdx.ident[pull]=omeda|7607D2261456E6L&
oly_enc_id=7607D2261456E6L
Li, J., Loehner, H., and Doshi, T. Detecting and Isolating Falling Conductors in Midair Using
900 MHZ Private LTE at Protection Speeds. Schweitzer Engineering Laboratories Inc.
Rahiminejad, A., Hou, D., Nakamura, N., and Bundhoo, M. Fire Mitigation for Distribution, Achieve Quick Progress with Advanced Technology Solutions. Schweitzer Engineering
Laboratories Inc and G&W Electric.
Taylor, D. and Damron, K. What’s the Risk? One Utility’s Approach to Strengthening Its Wildfire Resiliency. Understanding Ground Fault Detection Sensitivity and Ways to Mitigate Safety Hazards in Power Distribution Systems. Avista Utilities Paper.
Willis, L. and Rashid, M. Protective Relaying, Principles and Applications, Third Edition.
Covered Conductor
Barber, J. and Cardella, E. 2020, April 27. Covered Wire Combats California Wildfires. T&D World. www.tdworld.com/wildfire/article/21129731/covered-wire-combats-california-wildfires.
Bravo, R., Pham, E., Luy, A., Rorabaugh, J., and Hutchinson, E. 12 kV Covered Conductor
Testing. IEEE PES Transmission and Distribution Conference and Exposition,
October 2020.
Kabot, O., Fulnecek, J., Misak, S., and Prokop, L. Partial Discharges Pattern Analysis of Various Covered Conductors. Published in 21st International Scientific Conference on Electric Power Engineering, October 2020.
Zimackis, V. and Vitolina, S. Simulation of Direct Lightning in Medium Voltage Covered
Conductor Overhead Line with Arc Protection Device. Published in 58th International Scientific Conference on Power and Electrical Engineering of Riga Technical University, October 2017.
Idaho Power Company Oregon Wildfire Requirements and Recommendations
Appendices
Risk Management
International Organization for Standardization. 2018. A Risk Practitioners Guide to ISO 31000:
2018.
International Organization for Standardization. 2018. Risk Management—Guidelines.
United Nations Industrial Development Organization. 2021. ISO 31000:2018 Risk Management, A Practical Guide.
Group Participation and Learnings—OAR 860-300-0020 (1)0)

24) Idaho Power include more specifics on what it has learned by participating in these
groups. Staff would like assurance the company is leveraging the learnings from other utilities and experts to facilitate implementation of solutions with the highest benefit cost ratio.

See Section 2.3. 25) Idaho Power include its contribution to these forums including any research projects it is supporting or participating in.

See Section 2.3.
CERTIFICATE OF SERVICE - 1
CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on the 4th day of January 2023, I served a true and
correct copy of Idaho Power Company’s 2023 Wildfire Mitigation Plan (Version 5) upon
the following named parties by the method indicated below, and addressed to the
following:

Commission Staff
Riley Newton
Deputy Attorney General
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg No. 8
Suite 201-A (83714)
PO Box 83720
Boise, ID 83720-0074

Hand Delivered
U.S. Mail
Overnight Mail
FAX
FTP Site
X Email [e-mail]

Stacy Gust, Regulatory Administrative
Assistant