20240102Wildfire Mitigation Plan 2024.pdf

©2023 Idaho Power
PLAN
WILDFIREMITIGATION
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Idaho Power Company Wildfire Mitigation Plan 2024
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Table of Contents
Table of Contents .............................................................................................................................. i
List of Tables ................................................................................................................................... vi
List of Figures ................................................................................................................................ viii
List of Appendices ............................................................................................................................ x
Review/Revision History ........................................................................................................... xi
Executive Summary ......................................................................................................................... 1
WMP Approach and Progress ................................................................................................... 2
2023 Weather and Fire Season Overview .......................................................................... 3
2023 Wildfires ............................................................................................................... 4
Mitigating Wildfire Risk ....................................................................................................... 5
Risk Modeling ................................................................................................................ 6
2023 Wildfire Mitigation Goals and Accomplishments ................................................ 6
Grid Hardening .............................................................................................................. 7
Feeder Segmentation .................................................................................................... 7
Strategic Undergrounding ............................................................................................. 7
Transmission and Distribution Asset Inspections ......................................................... 9
Vegetation Management .............................................................................................. 9
WMP Technology and Innovation .............................................................................. 10
Situational Awareness................................................................................................. 11
Seasonal Wildfire-Safe Operational Settings .............................................................. 11
Public Safety Power Shutoff Program ......................................................................... 12
Customer Communications .............................................................................................. 12
Key Take Aways and Lessons Learned from 2023 ............................................................ 13
Situational Awareness........................................................................................... 13
Vegetation Management ...................................................................................... 13
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Community Feedback ........................................................................................... 14
Expansion of the Wildland Urban Interface ......................................................... 14
Wildfire Team Capacity ......................................................................................... 15
Regulatory Context ....................................................................................................................... 16
1. Introduction .............................................................................................................................. 17
1.1. Background ...................................................................................................................... 17
1.2. Idaho Power Profile and Service Area ............................................................................. 17
1.3. Asset Overview ................................................................................................................ 19
1.4. Objectives of this Wildfire Mitigation Plan ...................................................................... 20
1.5. Wildfire Mitigation Plan Maturity .................................................................................... 21
2. Government, Industry, and Peer Utility Engagement .............................................................. 22
2.1. Objective .......................................................................................................................... 22
2.2. Government Engagement ................................................................................................ 22
2.3. Industry and Peer Utility Engagement ............................................................................. 22
3. Quantifying Wildland Fire Risk .................................................................................................. 27
3.1. Objective .......................................................................................................................... 27
3.2. Identifying Areas of Elevated Wildfire Risk ...................................................................... 27
3.2.1. Wildfire Risk Modeling Process .............................................................................. 28
3.2.2. Establishing Wildfire Risk Zones ............................................................................. 31
3.3. Wildfire Risk Zones ........................................................................................................... 33
3.3.1. Maps........................................................................................................................ 36
3.3.2. Boardman to Hemingway Proposed Transmission Line ......................................... 49
4. Costs and Benefits of Wildfire Mitigation ................................................................................. 50
4.1. Objective .......................................................................................................................... 50
4.2. Risk-Based Cost and Benefit Analysis of Wildfire Mitigation .......................................... 50
4.3. Risk Analysis and Drivers .................................................................................................. 52
4.4. Wildfire Mitigation Cost Summary .................................................................................. 56
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4.5. Mitigation Activities ......................................................................................................... 59
4.5.1. Quantifying Wildland Fire Risk ................................................................................ 60
4.5.2. Situational Awareness—Weather Forecasting Activities and Personnel ............... 60
4.5.3. Situational Awareness—Advanced Technologies ................................................... 61
4.5.4. Field Personnel Practices ........................................................................................ 62
4.5.5. Transmission and Distribution (T&D) Programs for Wildfire Mitigation ................ 63
4.5.5.1. Annual T&D Patrol, Maintenance, and Repairs ............................................. 63
4.5.5.2. Thermography Inspections ............................................................................ 64
4.5.5.3. Wood Pole Fire-Resistant Wraps ................................................................... 65
4.5.5.4. Covered Conductor Pilot ................................................................................ 65
4.5.6. Enhanced Vegetation Management ....................................................................... 65
4.5.6.1. Fuels Reduction Shared Stewardship Project ................................................ 67
4.5.7. Communications and Information Technology Customer Notification
Enhancements ...................................................................................................... 68
4.5.8. Incremental Capital Investments ............................................................................ 68
4.5.8.1. Circuit Hardening ........................................................................................... 70
4.5.8.2. Overhead to Underground Conversions ........................................................ 72
4.5.8.3. Recloser Segmentation .................................................................................. 73
4.5.8.4. Transmission Steel Poles ................................................................................ 73
5. Situational Awareness ............................................................................................................... 74
5.1. Overview .......................................................................................................................... 74
5.2. Fire Potential Index .......................................................................................................... 74
5.3. FPI Review and Evaluation ............................................................................................... 76
5.4. Forecast Ensemble ........................................................................................................... 77
6. Mitigation—Field Personnel Practices ...................................................................................... 78
6.1. Overview .......................................................................................................................... 78
6.2. Wildland Fire Preparedness and Prevention Plan ........................................................... 78
7. Mitigation—Operations ............................................................................................................ 79
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7.1. Overview .......................................................................................................................... 79
7.2. Operational Protection Strategy ...................................................................................... 79
7.3. Transmission Line Operational Strategy .......................................................................... 81
7.3.1. Fire Season Temporary Operating Procedure for Transmission Lines 115 kV
& Above ................................................................................................................. 81
7.3.2. Tier 3 Zone Transmission Operational Strategy 69 kV & Below ............................. 81
7.4. Distribution Line Operational Strategy ............................................................................ 81
7.4.1. Tier 3 Zone Distribution Operational Strategy ....................................................... 81
7.5. Public Safety Power Shutoff ............................................................................................. 82
7.5.1. PSPS Definition ........................................................................................................ 82
7.5.2. PSPS Plan ................................................................................................................. 82
8. Mitigation Initiatives ................................................................................................................. 83
8.1. Overview .......................................................................................................................... 83
8.2. T&D Asset Management and Inspections ........................................................................ 83
8.3. Inspection and Correction Timeframes ........................................................................... 84
8.4. Transmission Asset Management and Inspection Initiatives .......................................... 86
8.4.1. Aerial Visual Inspection Program ............................................................................ 86
8.4.2. Ground Visual Inspection Program ......................................................................... 86
8.4.3. Detailed Visual (High-resolution Photography) Inspection Program ..................... 86
8.4.4. Thermal Imaging (Infra-red) Inspections ................................................................ 86
8.4.5. Wood Pole Inspection and Treatment Program ..................................................... 87
8.4.6. Cathodic Protection and Inspection Program ........................................................ 87
8.4.7. Transmission Asset Protection ................................................................................ 88
8.4.7.1. Wood Pole Wildfire Protection Program ....................................................... 88
8.4.7.2. Transmission Steel Poles ................................................................................ 88
8.4.7.3. Transmission Line Rebuild Projects ............................................................... 88
8.5. Distribution Asset Management and Inspection Initiatives ............................................ 92
8.5.1. Ground Visual Inspection ........................................................................................ 92
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8.5.2. Line Equipment Inspection Program ...................................................................... 92
8.5.3. Thermal Imaging (Infra-red) Inspections ................................................................ 93
8.5.4. Wood Pole Inspection and Treatment Program ..................................................... 93
8.5.5. Overhead Primary Hardening Program .................................................................. 93
8.6. Ignition Tracking and Analysis .......................................................................................... 95
8.6.1. Root Cause Analysis ................................................................................................ 97
8.7. T&D Vegetation Management ......................................................................................... 97
8.7.1. Vegetation Management Definitions ..................................................................... 99
8.7.2. Transmission Vegetation Inspection and Management ....................................... 100
8.7.2.1. Transmission Vegetation Inspections .......................................................... 100
8.7.2.2. Transmission Line Clearing Cycles ............................................................... 100
8.7.2.3. Transmission Line Clearing Quality Control and Assurance ........................ 101
8.7.3. Distribution Vegetation Management .................................................................. 101
8.7.3.1. Distribution Line Clearing Cycles ................................................................. 101
8.7.3.2. Distribution Vegetation Inspections ............................................................ 101
8.8.3.3. Distribution Line Clearing Procedures ......................................................... 102
8.8.3.4. Distribution Line Clearing Quality Control and Assurance .......................... 102
8.7.4. Pole Clearing of Vegetation .................................................................................. 103
9. Wildfire Response ................................................................................................................... 104
9.1. Overview ........................................................................................................................ 104
9.2. Response to Active Wildfires ......................................................................................... 104
9.3. Emergency Line Patrols .................................................................................................. 104
9.4. Restoration of Electrical Service .................................................................................... 104
9.4.1. Mutual Assistance ................................................................................................. 105
9.5. Public Outreach and Communications .......................................................................... 105
10. Communicating About Wildfire ............................................................................................ 106
10.1. Objective ...................................................................................................................... 106
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10.2. Community Outreach................................................................................................... 106
10.2.1. Community Engagement .................................................................................... 106
10.2.2. Community Resource Centers ............................................................................ 108
10.3. Customer Communications ......................................................................................... 109
10.3.1. Key Communication Methods ............................................................................ 109
10.3.2. Timing of Outreach ............................................................................................. 115
10.3.3. Communication Metrics ..................................................................................... 115
10.3.4. Customer Feedback ............................................................................................ 117
10.4. Idaho Power Internal Communications—Employees .................................................. 119
11. Performance Monitoring and Metrics .................................................................................. 120
11.1. Wildfire Mitigation Plan Compliance ........................................................................... 120
11.2. Internal Audit ............................................................................................................... 120
11.3. Annual Review ............................................................................................................. 120
11.4. Wildfire Risk Map ......................................................................................................... 120
11.5. Situational Awareness ................................................................................................. 120
11.6. Wildfire Mitigation—Field Personnel Practices ........................................................... 120
11.7. Wildfire Mitigation—Operations ................................................................................. 121
11.8. Wildfire Mitigation—T&D Programs............................................................................ 121
11.9. Long-term Metrics ....................................................................................................... 123
List of Tables
Table 1
Grid hardening and situational awareness .................................................................................. 6
Table 2
Inspection and Vegetation Management program summary ..................................................... 8
Table 3
Overhead transmission voltage level and approximate line mileage by state* ........................ 19
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Table 4
2024 risk zone changes .............................................................................................................. 34
Table 5
Idaho Power’s overhead transmission and distribution lines by risk zone in Idaho and
Oregon*...................................................................................................................................... 35
Table 6
CAL FIRE wildfire data by year ................................................................................................... 51
Table 7
Estimated system-wide O&M expenses for wildfire mitigation, $000s (2023–2028)* ............. 57
Table 8
Safety, reliability, and resilience co-benefits of wildfire mitigation initiatives ......................... 59
Table 9
WMP forecasted capital investments ........................................................................................ 69
Table 10
Asset management and inspection initiatives ........................................................................... 83
Table 11
Service area asset overview ....................................................................................................... 84
Table 12
Summary of asset inspections and schedules by state and zone .............................................. 85
Table 13
Transmission line rebuild projects ............................................................................................. 89
Table 14
Vegetation Management program summary ............................................................................ 98
Table 15
Summary of vegetation management activities and schedules ................................................ 99
Table 16
Key communication metrics .................................................................................................... 116
Table 17
T&D programs metrics ............................................................................................................. 121
Table 18
Outage metrics ......................................................................................................................... 124
Table 19
Overhead circuit hardening reliability improvements ............................................................. 125
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List of Figures
Figure 1
Approach to wildfire mitigation ................................................................................................... 5
Figure 2
Idaho Power service area ........................................................................................................... 18
Figure 3
Wildfire risk-based methodology ............................................................................................... 27
Figure 4
Risk zone evaluation and determination process ...................................................................... 32
Figure 5
Idaho Power wildfire risk zones ................................................................................................. 37
Figure 6
Eastern Idaho–Pocatello area .................................................................................................... 38
Figure 7
Eastern Region–Salmon area ..................................................................................................... 39
Figure 8
Southern Region–Wood River Valley ......................................................................................... 40
Figure 9
Southern Region–Pine-Featherville ........................................................................................... 41
Figure 10
Capital Region–Boise Front ........................................................................................................ 42
Figure 11
Centerville .................................................................................................................................. 43
Figure 12
Idaho City area ........................................................................................................................... 44
Figure 13
Cascade/Donnelly area .............................................................................................................. 45
Figure 14
Garden Valley/Crouch area ........................................................................................................ 46
Figure 15
McCall/New Meadows area ....................................................................................................... 47
Figure 16
Halfway Oregon ......................................................................................................................... 48
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Figure 17
Proposed B2H route ................................................................................................................... 49
Figure 18
Joint Oregon IOU–risk spend efficiency process timeline ......................................................... 52
Figure 19
Idaho Power WMP risk management framework ..................................................................... 53
Figure 20
Risk bow-tie ................................................................................................................................ 54
Figure 21
Comparison of reclosing strategies with respect to customer reliability and wildfire risk ....... 80
Figure 22
Example of Idaho Power outage dashboard .............................................................................. 96
Figure 23
May 2023 edition of Connections ............................................................................................ 111
Figure 24
Idaho Power developed an educational video on how we protect wooden poles from
wildfire ..................................................................................................................................... 111
Figure 25
Customer email from May 2023 .............................................................................................. 112
Figure 26
Postcard to customer living in a PSPS zone ............................................................................. 112
Figure 27
Example social media posts ..................................................................................................... 113
Figure 28
Postcard to customer living in an area where grid inspections were taking place ................. 113
Figure 29
Idaho Power’s wildfire safety landing webpage ...................................................................... 114
Figure 30
Wildfire mitigation meeting PowerPoint cover slide ............................................................... 114
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List of Appendices
Appendix A
The Wildland Fire Preparedness and Prevention Plan.
Appendix B
The Public Safety Power Shutoff (PSPS) Plan.
Appendix C
Wildfire risk zone map book.
Appendix D
Oregon wildfire requirements and recommendations.
Idaho Power Company Wildfire Mitigation Plan 2024
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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.
rch 18, 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.
Annual updates associated with developing the 2024 WMP, including updates to the Executive Summary, changes for the 2024 season, modifications to and progress on mitigation efforts,
pilot projects, partnership updates and grant funding, WMP forecasted costs, communication efforts, PSPS program, and the addition of Appendix C—Wildfire risk zone map book.
Wildfire Mitigation Plan 2024 Idaho Power Company
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Idaho Power is dedicated to the safety of our
customers and communities, and to delivering reliable,
affordable energy. In pursuit of that mission, Idaho
Power implements and continuously evolves the
company’s Wildfire Mitigation Plan (WMP).
Throughout 2023, Idaho Power worked to reduce the
risk of wildfire ignition through the implementation
of core mitigation approaches such as hardening of
our electrical system, expansion of our situational
awareness capabilities, further enhancement of our
vegetation management program, and re-evaluation of
our risk modeling practices. 2024 will mark the fourth
year of Idaho Power’s WMP and brings in key lessons
learned that will support the overall programmatic
maturity of our WMP in the years to come.
The WMP 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 based on numerous variables
intended to reduce wildfire risk.
This Executive Summary provides a comprehensive
review of the 2023 wildfire season, an overview of the
WMP, and a snapshot of the progress made toward our
systemwide wildfire mitigation objectives. Additionally,
the Executive Summary highlights lessons learned from
the 2023 wildfire season and previews changes that
will be incorporated into Idaho Power’s 2024 wildfire
mitigation efforts and beyond.
Executive Summary
Page 1
WMP Approach and Progress
The fundamental goals of Idaho Power’s WMP are to reduce
wildfire risk associated with the company’s transmission and
distribution (T&D) facilities and associated field operations, and
improve the resiliency of Idaho Power’s T&D system in a wildfire
event, independent of the ignition source. These efforts are taken
to prioritize the safety of the customers and communities we
serve and to support the overall resiliency of Idaho Power’s
T&D system.
Each year, Idaho Power develops high-level goals and
approaches for WMP implementation. By almost all measures,
Idaho Power met or exceeded the established goals for 2023. In
June 2023, Idaho Power added a permanent, full-time Wildfire
Mitigation Program Manager to staff, bringing additional
capacity for programmatic tracking and focus on the continuous
improvement of the WMP. Idaho Power is in the process of hiring
additional positions for 2024 that will focus on WMP efforts.
Engagement with government and
industry entities and electric utility
peers to ensure understanding and a
baseline level of commonality of wildfire
mitigation plans and best practices.
Ongoing evaluation of and overall
improvement in the company’s approach
to identification and quantification
of wildland fire risk, including robust
consideration of the two key elements
of determining wildfire risk: wildfire
probability and consequence.
Continued implementation of targeted
operations and maintenance practices,
system hardening programs, enhanced
vegetation management, and refinement
of field personnel practices to mitigate
wildfire risk.
Collection and incorporation of
information regarding current and
forecasted weather and field conditions
into operational practices to increase
situational awareness.
Analysis of public safety power shutoff
(PSPS) protocols.
Evaluation of the performance and
effectiveness of strategies, including pilot
projects, identified in the WMP through
metrics and monitoring.
KEY achievementsin 2023
I N C L U D E D :
1
2
3
4
5
6
Page 2
2023 Weather and Fire Season Overview
The early part of 2023 was characterized by well-below-normal
temperatures from January through April across the majority
of Idaho Power’s service area. Precipitation was mixed during
that same period, with January, February, and April averaging
66% of normal. March, however, was 166% of normal, bringing
the first four months of the year to approximately 90% of
normal precipitation. The combined effect of lower-than-normal
temperatures and precipitation resulted in a delayed start to the
drying of vegetation (fuels) and, as a result, a delay to active
wildfire season.
May through July experienced mild above-normal temperatures,
while May and June saw well-above-normal precipitation. This set
of circumstances helped promote fine fuels growth in the southern
sections of Idaho Power’s service area. Combined higher-than-
normal temperatures and precipitation at less than 20 % of
normal in July led to drying of fuels and a resulting rise in wildfire
risk throughout the month. August and September continued to
see above-normal temperatures but were combined with more
than 250% of normal precipitation, lowering fire concerns in
many areas across the service area and, ultimately, contributing to
a much less impactful fire season than the 2022 wildfire season.
Overall acres burned in Idaho Power’s service area in 2023 was
well below the 20-year average for wildfires.1
During this past wildfire season, Idaho Power atmospheric
scientists performed frequent forecasts to determine a daily Fire
Potential Index (FPI) value across the company’s service area,
as detailed in section 5.2 of the WMP. The FPI produces scaled
values that are associated with colors—with red FPIs indicating
highest fire potential and green FPIs indicating lowest fire
potential. The FPI is used to inform Idaho Power’s on-the-ground
and operational strategies. Seasonal weather conditions led to an
increase in FPI levels throughout the summer of 2023 with a
focused period of increased risk in July and the start of August.
The 2023 wildfire season recorded a total of 11 days in which a
red FPI occurred in a wildfire risk zone compared to a total of 30
days in 2022.
While the 2023 summer months
saw some higher-than-normal
temperatures, above normal
relative humidity and precipitation
ultimately decreased wildfire
potential compared to 2022.
1 National Oceanic and Atmospheric Administration: September 2023 Wildfires
Report | National Centers for Environmental Information (NCEI) (noaa.gov)
Page 3
2023 Wildfires
Throughout the summer months,
Idaho Power monitors for active
wildfires and tracks events as they
progress. Wildfire tracking informs
operational planning and provides
insight into areas or infrastructure
that could be threatened throughout
the fire season. During active
wildfire events, Idaho Power
coordinates closely with fire incident
command to ensure safety of fire
responders, protection of utility
infrastructure, and timely power
restoration for customers in the
event of an outage.
By the end of the 2023 fire season, a
total of 124 wildfire incidents were
recorded by the National Interagency
Fire Center within the company’s
service area, the largest of which
was the Hayden Fire located in
Lemhi County, Idaho. This wildfire
was active from July 19 through
September 21 and, at one point,
required Idaho Power to de-energize
a portion of distribution line to
support firefighter safety while they
established firebreaks.
The Rural Assist2 Fire in Gooding
County, Idaho, that began on
July 11, was the most impactful
from an outage standpoint—with
approximately 600 customers
affected after a distribution line
tripped due to thick smoke in the
area. Fortunately, the fire was
contained in just under one hour
and Idaho Power was able to restore
power to these customers within
90 minutes of the outage.
Page 4
Figure 1
Approach to Wildfire Mitigation
Mitigating Wildfire Risk
Idaho Power deploys a variety of wildfire risk mitigation activities through its WMP. As displayed in Figure
1, the company’s strategy to reduce wildfire risk is multi-pronged and involves activities and actions to:
1) reduce the likelihood of wildfire, 2) reduce the intensity of wildfire, and 3) reduce the susceptibility
to wildfire. Reducing the likelihood of wildfire primarily involves the deployment of wildfire mitigation
initiatives. These are identified and adopted based on a variety of factors including industry best practices
for reducing wildland fire risk, evaluation of inherent risk across the service area, and consideration of
alternatives that could be pursued.
To reduce the susceptibility to wildfires, Idaho Power focuses on education and communication,
specifically engagement with government agencies, industry entities, expert forums, Public Safety
Partners, and electric utility peers to build our understanding of wildfire risk and commonality of wildfire
mitigation plans.
Finally, to reduce the potential intensity of wildfire, Idaho Power works to reduce the amount of
available fuel that can burn. These efforts include fuel reduction partnerships, pole clearing, and
the pilot implementation of wildfire detection cameras.
Work on all three fronts—likelihood, intensity, and susceptibility—is on a rolling and/or rotating cycle
and, as a result, some of the Idaho Power’s activities are in progress at the time of writing this 2024 WMP.
Page 5
Risk Modeling
Idaho Power worked with a contractor in 2023 to update its wildfire risk model using new data on
climatology, vegetation, population growth, and outages. The company also conducted a qualitative
evaluation of factors not accounted for in the quantitative risk modeling, including Public Safety Partner
feedback, ingress/egress route evaluation, emergency response times and capabilities, topographical
considerations, and defensible space.
Simultaneously, Idaho Power began evaluating new approaches to wildfire risk modeling, including real-
time wildfire forecasting platforms that offer analytical capabilities to inform grid design and operational
decision making. Idaho Power’s evaluation of risk modeling and approach will continue throughout 2024.
2023 Wildfire Mitigation Goals and Accomplishments
Tables 1 and 2 provide a snapshot of WMP activity throughout 2023 as well as wildfire mitigation goals
for 2024.
Plan Area Wildfire Mitigation Plan Activities
2023
Planned
2023
Completed
Idaho
2023
Completed
Oregon
%
Complete
2024
Planned
Idaho
2024
Planned
Oregon
System Hardening*
Distribution System Hardening
System Hardening Line Miles 69 70.9 — 103% 75 Design
Overhead Line Miles Converted
to Underground
0.61 0.61 — 100% — —
Feeder Segmentation
Segmentation Devices
Installation or Relocation of
Automatic
—
Reclosing Devices 8 8 — 100% 18 7
Fire Mesh Installation
Transmission Fire Mesh Installation
Number of Poles Protected 870 649 205 98% 632 68
Situational Awareness
Situational Awareness
Weather Station Installation 5 5 —100% 4 1
Wildfire Detection Cameras**— — — — 6 Evaluate
Table 1: Grid hardening and situational awareness
*Excludes hardening work outside of wildfire risk zones ** Indicates Pilot Project
Page 6
Grid Hardening
Idaho Power’s grid hardening
program includes maintenance
actions and system upgrades that
provide for additional wildfire-
resistant protections. The 2023
grid hardening program was
expanded by nearly 40% from
2022 to 2023 and resulted in the
hardening of 69 new line miles in
Tier 3 Zones across the
company’s service area. Idaho
Power intends to continue its
grid hardening work throughout
2024, with a goal of completing
hardening efforts for an
additional 75-line miles
in 2024.
ADDITIONAL75 line miles
Feeder Segmentation
Segmentation allows Idaho Power to isolate sections (or segments) of its T&D system to more precisely
control operations in higher wildfire risk areas from lower wildfire risk areas. Segmentation is most efficiently
accomplished through the installation of devices that can be controlled remotely, as opposed to manual
adjustments performed in the field. In 2023, Idaho Power completed the installation of eight automatic
reclosing devices (reclosers) in Tier 3 Zones as part of an effort to isolate circuit segments. Moving into
2024, Idaho Power has a goal installing approximately 25 automatic reclosers throughout its service area,
as well as improving the company’s remote communication capabilities to distant segmentation devices.
Strategic Undergrounding
Idaho Power performs risk assessments to
determine optimal underground conversion
locations. Criteria for assessing underground
projects include evaluation of wildfire risk
modeling scores, fire history, ignition probability,
PSPS and sensitive protection setting impacts,
and impacts to critical facilities.
In 2023, Idaho Power converted approximately
0.61 miles of overhead distribution line in eastern
Idaho to underground in areas of highest wildfire
risk. The company will continue to evolve and
refine its approach to strategic undergrounding,
including continued expansion of the company’s
evaluation of spending on risk-reduction activities.
0.61 MILES
C O N V E R T E D
TO UNDERGROUND
2024
2023
Page 7
Initiative
Wildfire Mitigation Plan Asset
Inspection and Vegetation
Management Initiatives
2023
Goal
2023
Completed
Idaho
2023
Completed
Oregon
%
Complete
2024
Goal
Idaho
2024
Goal
Oregon
Asset Inspections
Transmission Inspections
923 923 0 100% 1,114 341
210 n/a 210 100% n/a 341
Wildfire Pre-Season Patrol—Tier3 Zones (Structures)
Ignition Prevention
Inspections
(OR Division 24) (structures)
Infrared Thermography Patrol
(Structures)
923 923 0 100% 1,114 341
Distribution Inspections
20,192 20,193 0 100% 19,382 1,780
567 n/a 567 100% n/a 1,780
Wildfire Pre-Season Patrol—
Tier3 Zones (Poles)
Ignition Prevention
Inspections (OR Division 24)
(Poles)
Infrared Thermography Patrol
—Tier3 Zones (Poles)
4,000 6,773 0 169% 4,000 1,000
Vegetation Management
Pruning Cycle
Transition to a 3-Year
Pruning Cycle (Circuits)
336 243 0 79% 269 22
Enhanced Vegetation Management
65 59 6 100% 138 11
65 59 6 100% 138 11
1 1 0 100% 18 8
1 1 0 100% 18 8
100% of All
Identified
2 0 100%100% of All
Identified
100% of All
Identified
Annual Patrol— Tier2 & Tier3
Zones (Circuits)
Annual Mitigation— Tier2 &
Tier3 Zones (Circuits)
Mid-Cycle Patrols— Tier2 &
Tier3 Zones (Circuits)
Mid-Cycle Pruning— Tier2 &
Tier3 Zones (Circuits)
Hazard Trees Identified & Pruned
Hazard Trees Identified &
Removed
100% of All
Identified
83 0 100%100% of All
Identified
100% of All
Identified
Audits of Pruning Activities—
Tier2 &Tier3 Zones (Worksites)
100% of All
Identified
1,358 71 100%100% of All
Identified
100% of All
Identified
Table 2: Inspection and vegetation management
Page 8
Vegetation Management
Idaho Power’s Vegetation Management program
(VMP) addresses public safety and electric reliability by
safeguarding T&D lines from trees and other vegetation
that may cause an outage or damage facilities. Vegetation
management remains an important mitigation strategy for
Idaho Power and each year the Company sets targets to
drive production.
Throughout 2023, Idaho Power continued to work toward a
three-year pruning cycle even as contract labor availability,
contractor production, equipment availability, and rising
costs of these limited resources remained a challenge.
Moisture received during the longer than average growing
season created additional challenges and led to slower
progress than anticipated. Idaho Power prioritizes Tier 2
and Tier 3 Zones and completed all planned enhanced
vegetation management activities in these areas including
annual patrols and mid-cycle pruning.
Additional vegetation monitoring tools and innovative
approaches were piloted in 2023, such as the use of a
LiDAR-based approach for vegetation encroachment
detection. The company continues to evaluate these types
of tools and others for potential future implementation.
Transmission and Distribution Asset Inspections
To reduce wildfire risk and continue to safely operate the grid, Idaho Power
implements and continuously evaluates a robust set of asset inspection
initiatives, including condition-based aerial visual inspections, ground visual
inspections, detailed visual inspections (generally using high-resolution
photography), thermography inspections, and wood pole inspection and
treatment. Fundamental to these efforts is ongoing evaluation and research
into industry best practices and strategic piloting of emerging technologies
and approaches that may aid in the identification of potential issues not
visible by traditional ground inspections or where terrain or other constraints
may limit the ability to perform a detailed ground inspection. Despite this
being an area for evolution and refinement, in 2023, Idaho Power met or
exceeded its established WMP asset inspection goals.
Page 9
WMP Technology and Innovation
Idaho Power’s approach for identifying and implementing new wildfire mitigation technology is based
on the continual evaluation of industry learnings, practices, and new technological advancements. Idaho
Power approaches pilot projects with the goal of learning about implementation complexities, efficacy for
risk reduction, and cost analysis of new technologies prior to full integration into the WMP. Engagement in
industry forums and workgroups, such as the International Wildfire Risk Mitigation Consortium, continue
to provide a valuable venue for informal peer-to-peer sharing of emerging technology and lessons learned.
In 2023, Idaho Power initiated or continued its evaluation process of several pilot projects.
Thermal Inspections: Idaho Power uses specialized thermal imaging (infra-
red) equipment that can identify compromised electrical connections and overloaded
equipment that may not be apparent through other inspection processes. In the recent
wildfire season, this work detected several anomalies, including four issues located in
Tier 3 zones that were subsequently repaired. In 2024, Idaho Power will be evaluating
the feasibility and benefit of expanding the use of thermal inspections across other
wildfire risk zones.
Wildfire Detection Cameras: In 2023, Idaho Power began the process of
installing six wildfire detection cameras in Idaho. This pilot project will run through
2024 and serve to inform organizational understanding of the complexities of
installations, permitting, agency and Public Safety Partner coordination, and the
systems used for notifications. The camera feeds can be used by firefighting agencies
and Idaho Power to aid in the early detection of wildfire, track real-time weather
and fuel conditions, and allow for first responders to better allocate the appropriate
number of assets in the event of a fire.
Covered Conductor: In 2023, Idaho Power launched a covered conductor
(or covered wire) pilot project intended to explore the benefits, tooling
requirements for field personnel, and design parameters of the technology.
Throughout 2024, the company will continue to analyze the feasibility of
integrating covered conductor into broader operational practice. The feasibility
study includes evaluation of potential co-benefits, such as improved reliability
outside of wildfire season and reduced outage restoration costs.
Cross-Boundary Fuels Reduction Collaboration: Throughout 2023, Idaho
Power worked closely with the United States Forest Service, Bureau of Land Management,
Idaho Department of Lands, National Forest Foundation, and other federal, state, and local
governments and fire agencies on development and ongoing implementation of priority
projects that include hazardous fuel reduction efforts adjacent to utility rights of way and
high wildfire risk communities. The partnership is focused on more than 2.3 million acres
across southern Idaho and includes multijurisdictional land in Idaho, including in Ada,
Boise, Adams, Valley, and Idaho counties.
Pole Loading: This technology evaluates pole loading using a modeling software that
creates 3-D representations of actual Idaho Power structures and surroundings. The model
results support a better understanding of potential loading constraints on equipment that
could lead to a failure. Idaho Power initiated this project in 2023 and plans to conduct the
assessment in its Tier 3 zones located in Idaho and, depending on efficacy, will evaluate
expansion of the program to other areas across the service territory, including Oregon.
The pilot project is anticipated to run through 2025.
Page 10
Situational Awareness
Throughout the 2023 wildfire season, Idaho Power’s
Atmospheric Sciences department utilized modeling and
forecasting capabilities, combined with existing field
weather stations and publicly available weather and
fuel data, to develop and internally circulate daily Fire
Potential Index (FPI) forecasts. This information is important
for informing Idaho Power’s approach to field personal
practices and operational settings during the wildfire
season. FPI forecasts are also used in conjunction with
Idaho Power’s weather forecasting efforts to detect
extreme weather events that may support a public safety
power shutoff (PSPS). Idaho Power intends to install five
additional field weather stations in Tier 3 Zones in 2024.
Seasonal Wildfire-Safe
Operational Settings
Enhanced Protection Settings (EPS)—sometimes
called sensitivity settings—are used to reduce
the probability of ignition during fault events on
Idaho Power’s T&D system. In 2023, Idaho Power
began additional analysis and testing of advanced
wildfire-safe protection schemes for its overhead
power lines and plans to utilize additional EPS in
targeted areas of the system in 2024. Idaho Power
is working with peer utilities that have adjacent
service areas to coordinate EPS terminology,
usage, and customer communications.
Page 11
Customer Communications
Safety is one of Idaho Power’s core values,
and it guides our strategy for wildfire-related
communication to our customers and the
communities in which we serve. 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. Core approaches to communication
include social media, radio, customer
newsletters, postcards, and voice and text
messaging. Additionally, the company
conducted over 30 in-person and virtual
meetings to engage with customers, counties,
fire, and other public agencies to discuss and
seek feedback on the WMP and PSPS efforts.
Communication methods and metrics are
detailed in Chapter 10 of the WMP.
Public Safety Power Shutoff Program
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 risk of wildfire. The company
did not proactively de-energize any customers as part of its PSPS program in 2023, however the
PSPS assessment team was brought together on four different occasions during the wildfire season
to monitor potential weather events. The decision regarding PSPS is based on a number of dynamic
factors, and each weather event is unique. While PSPS remains a last resort tool for Idaho Power, results
from a customer survey sent out by Idaho Power in October indicated that 71% of respondents would
support the use of PSPS in extreme weather conditions to reduce wildfire risk. Yet, conversations with
Public Safety Partners and communities throughout the year continued to highlight the complexity
of PSPS, such as impacts on vulnerable populations; the ability for Public Safety Partners to send and
receive notifications across power-reliant platforms; and fire suppression efforts that may be reliant on
electricity to power wells and water pumps. Idaho Power remains focused on limiting the impact and
frequency of future PSPS events and is continually evaluating the value and efficacy of initiatives under
the WMP that could decrease the need for PSPS in the future, such as enhanced protection settings
during wildfire season and strategic undergrounding.
MEETINGS
I N - P E R S O N
AND VIRTUAL30
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Situational Awareness
While the 2023 wildfire season was relatively mild
compared to past years, the PSPS assessment team
was pulled together four times to monitor potential
extreme weather events, with none resulting in
proactive de-energization. These exercises—even
without a PSPS ultimately being called—provided
valuable insight into areas for future improvement
and specifically highlighted the potential benefits of
having expanded real-time operational risk modeling
capabilities that work in concert with Idaho Power’s
existing forecasting process. As discussed in Sections
4.5.2 and 5 of the WMP, Idaho Power continues to
explore new options for technologies to improve
situational awareness and weather forecasting across
the company’s service area. In late 2023, Idaho Power
began assessing additional tools and products that
could support Idaho Power’s forecasting capabilities
on a line-segment level, providing more precise insight
into areas that may be at risk from extreme weather
and heightened fire potential.
Vegetation Management
Idaho Power continued to make progress towards
it’s long-term goal of achieving a three-year pruning
cycle. 265 circuits across the service area were
pruned in 2023, including all enhanced vegetation
management activities in wildfire risk zones. 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 than
anticipated. More climbing work was also required
than originally expected in 2023. Climbing to remove
vegetation requires contractors with more skill and
takes more time to complete.
While vegetation management expenditures were
increased in 2023, the Company plans to continue to
increase expenditures annually over the next three
years to help achieve desired production levels and
secure contractor resources. Idaho Power piloted
LiDAR-based vegetation encroachment technology
to gain efficiency and cost savings. Unfortunately,
this technology has not yet produced the level of
accuracy necessary to meet standards and as such,
the Company will be periodically reassessing as
improvements in machine learning and Artificial
Intelligence are made. In 2023, Idaho Power
completed a thorough assessment of its contracted
work and process for managing that work and
will evaluate potential changes to its strategy in
2024. Idaho Power remains dedicated to evaluating
technological advancements and approaches that
may increase efficiencies moving forward.
KEY TAKE AWAYSand LESSONS LEARNED
from 2023
Page 13
Community Feedback
The company conducted more than 30 WMP and PSPS
plan presentations throughout its service area. In these
meetings, Idaho Power advised customers and partners
of our plans, discussed updated risk modeling efforts,
and solicited feedback to help inform future versions
of the WMP. Four public meetings were held in Oregon
at the end of fire season (two in-person, two virtual).
While Idaho Power received good feedback from the
customers who attended the Oregon meetings, the
overall turnout was small. Feedback and themes from
these meetings and others throughout the year will be
incorporated into the 2024 WMP communications and
engagement strategy and include:
• Holding public meetings in Oregon before fire season
instead of after it.
• Partnering with agencies and other programs, such
as Firewise, will continue to be a valuable tool for
bringing about additional awareness of wildfire risk
and mitigation efforts.
• Understanding of PSPS varied across the company’s
service area. The future strategy will require a more
extensive, holistic, and broad effort to educate and
raise awareness about the circumstances that might
warrant a PSPS.
Expansion of the Wildland Urban Interface
As the population in Idaho Power’s service area has
grown, so has the expansion of new construction
in the wildland urban interface (WUI). Over the
past several decades, Ada County, which includes
Boise, has experienced explosive housing growth
and rapid WUI area expansion. From 1990 to 2020,
WUI housing expanded by 107%. 2 This expansion
creates new challenges for wildfire mitigation
as new wildfire risk areas and new wildfire risks
emerge. In 2023, as part of Idaho Power’s risk
model update and review process, the company
instituted additional strategies to assess risk factors
such as defensible space, ingress/egress routes, and
wildfire response times and capability.
2 USDA Forest Service Northern Research Station-Understanding
the Wildland Urban Interface (1990–2020) (arcgis.com).
Page 14
Wildfire Team Capacity
Idaho Power has historically relied on existing staff to
come together for the planning and implementation
of the WMP. Recognizing the increase in the annual
and year-round level of wildfire work, Idaho Power
added a Wildfire Mitigation Program Manager to
staff in June 2023 and has plans to add additional
positions in 2024. The manager is the first fully
dedicated employee in the company’s wildfire
program. As Idaho Power’s approach to wildfire
mitigation work continues to evolve, so too will the
need to bring on additional dedicated staff to support
situational awareness, technology advancements,
communications and outreach, project management,
and regulatory engagement.
Page 15
Regulatory Context
Page 16
As part of Idaho Power’s commitment to deliver safe, reliable, and affordable energy, the company developed
the WMP to evaluate and reduce wildfire risk associated with its facilities.
The company’s WMP is a living document that will continue to 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. As a two-state utility, Idaho
Power’s regulators in Idaho and Oregon provide meaningful input and recommendations into ways to improve
the WMP on an annual basis. A recent history of wildfire-related regulatory activities is provided below 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 and insurance costs. The IPUC authorized the deferral of these newly identified costs in
Order No. 35717.
Oregon
In August 2020, the 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 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. These wildfire requirements are memorialized in Oregon Administrative Rules,
Division 300.
Idaho Power’s Appendix D to the WMP provides Oregon-specific information related to wildfire requirements
and recommendations.
Regulatory Context
Idaho Power Company Wildfire Mitigation Plan 2024
Page 17
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 wildfires within its service area at the same level
experienced in other western states, such as California and more recently certain areas in
Oregon and Hawaii, millions of acres of rangeland and southern Idaho forests have burned in
the last 30 years.3 In that same time period, the wildfire season in Idaho has expanded by
70 days.4 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, headquartered in Boise, Idaho, is an investor-owned utility engaged in the
generation, transmission, and distribution of electricity. Idaho Power is regulated by the Federal
Energy Regulatory Commission (FERC) and the state regulatory commissions of Idaho and
Oregon. Idaho Power serves more than 620,000 customers with a culture of safety first,
integrity always, and respect for all.
Idaho Power’s 24,000 square mile service area includes approximately 4,745 square miles in
Oregon and 19,255 in Idaho (Figure 2). The company serves approximately 20,000 customers in
Oregon and 600,000 in Idaho.

3 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.
4 Ibid.
Wildfire Mitigation Plan 2024
Idaho Power Company
Page 18

Figure 2
Idaho Power service area
Idaho Power Company Wildfire Mitigation Plan 2024
Page 19
1.3. Asset Overview
Idaho Power delivers electricity to its customers via more than 310 substations, 4,700 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. Additional detailed information on
Idaho Power’s Assets is included in Section 8.
Table 3
Overhead transmission voltage level and approximate line mileage by state*
Asset
TOTAL IDAHO OREGON MONTANA NEVADA WYOMING
Pole
Miles
Pole
Miles %
Pole
Miles %
Pole
Miles %
Pole
Miles %
Pole
Miles %
46 kV Transmission Lines 382 382 100% 0%
69 kV Transmission Lines 1136 743 65% 344 30% 50 4%
115 kV Transmission Lines 3 3 100%
138 kV Transmission Lines 1456 1249 86% 141 10% 66 5%
161 kV Transmission Lines 84 84 100% 0%
230 kV Transmission Lines 1151 930 81% 219 19%
345 kV Transmission Lines 474 365 77% 0% 110 23%
500 kV Transmission Lines 103 53 51% 50 49%
Total OH Transmission Lines 4789 3806 79% 757 16% 50 1% 66 1% 110 2%
Total OH Distribution
Lines 19397 17289 89% 2108 11%
Total OH Pole Miles 24186 21095 87% 2865 12% 50 0.21% 66 0.27% 110 0.45%
*Current as of as of December 31, 2022. Line mileage reported includes co-owned assets.
Wildfire Mitigation Plan 2024 Idaho Power Company
Page 20
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.5

Idaho Power’s approach to achieving these objectives includes the following actions:
o Engage with government and industry entities and electric utility peers to ensure
understanding and commonality of wildfire mitigation plans.

o 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.

o Create specific and targeted operations and maintenance practices,
system hardening programs, vegetation management, and field personnel
practices to mitigate wildfire risk.

o Incorporate information regarding current and forecasted weather and field
conditions into operational practices to increase situational awareness.

o Employ public safety power shutoff (PSPS) protocols for Idaho Power’s service
area and transmission corridors.

o Evaluate the performance and effectiveness of strategies identified in this WMP
through metrics and monitoring. The WMP and all its components will be
reviewed prior to wildfire season each year.

5 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.
Idaho Power Company Wildfire Mitigation Plan 2024
Page 21
1.5. Wildfire Mitigation Plan Maturity
For each update to its WMP, Idaho Power reviews its own practices and outcomes and also
benchmarks against the practices of other utilities’ WMPs.

In some parts of the utility industry, WMP “maturity” is an evolving topic of discussion.
The purpose of so-called “maturity models” is to understand the evolution of a utility’s WMP
based on an established standard of progress—most often specific to an individual state
regulator’s objectives. These “models” are in various states of evolution.

In 2023, Staff of the Oregon Public Utilities Commission (OPUC) recommended “Idaho Power
and joint Oregon IOUs evaluate the California PUC WSD maturity model and develop an Oregon
IOU rubric as part of their 2024 WMPs.” There are a number of ways to perform such maturity
reviews, but the version noted by OPUC Staff involves a survey process that requires an
individual utility to gather information related to a maturity category. Findings can be used
internally for evaluation purposes and/or be provided to regulatory staff. Information is
subsequently used by state regulators—or other reviewing bodies—to help assess a utility’s
current activities, capabilities, and strategy for reducing wildfire risk. In such a context,
the “maturity” of a WMP does not result in any sort of judgement about a utility’s practices but,
rather, simply places the utility on a point along a path established by regulators—in this case,
the California Public Utilities Commission (CPUC).

To comply with the OPUC’s requirement to review maturity models, Idaho Power evaluated
two wildfire risk maturity models: the CPUC Wildfire Safety Division (WSD) maturity model and
the International Wildfire Risk Mitigation Consortium (IWRMC) Wildfire Risk Mitigation
Maturity Model. The CPUC model was first deployed in 2020 and in 2022 significantly expanded
and now exceeds 1000 survey questions that veer into additional areas of focus, such as carbon
reduction. The IWRMC Wildfire Risk Mitigation Maturity Model was developed collaboratively
among IWRMC program member utilities as an enhancement to the CPUC maturity model and
focuses on 50 key capabilities organized into 10 broad categories. The IWRMC model has been,
and continues to be, tested among the Consortium’s membership to validate findings, and
identify opportunities for collective and individual utility improvement.

The development of a maturity model rubric and the associated incorporation of a WMP
maturity model into Idaho Power’s WMP processes is a multi-year undertaking that would
require a significant diversion of funding and resources that may otherwise be focused on
wildfire mitigation and operational efforts across Idaho Power’s service area. As such,
Idaho Power will continue to prioritize mitigation activities that are directly related to reducing
risk exposure to its customers consistent with the approach for meeting the objectives of the
Wildfire Mitigation Plan. Additionally, Idaho Power will continue to engage with IWRMC and
peer utilities on the testing, validation, and discussion around the IWRMC model and will assess
the overall timeliness and prudency of maturity model adoption in the future.

Wildfire Mitigation Plan 2024 Idaho Power Company
Page 22
2. Government, Industry, and Peer Utility Engagement
2.1. Objective
Idaho Power recognizes the importance of engaging with various levels of government—
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, in 2023 Idaho Power partnered with
Federal, State, and local government agencies in southern Idaho to identify areas of collective
concern for wildfire risk and discuss strategic risk mitigation actions. This partnership resulted
in the completion of approximately 705 acres of fuels reduction treatment on U.S. Forest
Service land adjacent to Idaho Power’s wildfire risk zones in Boise County.
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 files its WMP annually with IPUC. 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
The first iterations of Idaho Power’s WMP relied on learnings and processes developed by
several California utilities, with Idaho-specific modifications that account for the unique
qualities of Idaho Power’s service area and risk profile. Idaho Power continues to engage with
California utilities including San Diego Gas and Electric, Southern California Edison, Pacific Gas
Idaho Power Company Wildfire Mitigation Plan 2024
Page 23
and Electric, Sacramento Municipal Utility District, and PacifiCorp to continue to advance Idaho
Power’s WMP and stay abreast of California’s evolving practices.
Idaho Power additionally and increasingly relies on engagement with peer utilities throughout
the Pacific Northwest, which is critical for understanding and ensuring commonality of wildfire
mitigation plans, while accounting for the variation in each utility’s unique service area. These
utilities include Avista Utilities, Portland General Electric (PG&E), Rocky Mountain Power, Pacific
Power, Chelan County Public Utility District, Puget Sound Energy, NV Energy, Bonneville Power
Administration (BPA), and Northwestern Energy.
In 2023, Idaho Power joined the International Wildfire Risk Mitigation Consortium (IWRMC).
The IWRMC is an industry-sponsored collaborative designed to facilitate the sharing of wildfire
risk mitigation insights and innovations from across the globe. The program is led by a Utility
Executive Steering Group, whose members work specifically on wildfire/bushfire issues in
Australia and the Western United States. Idaho Power’s engagements with IWRMC are focused
on operations and protocols, asset management, vegetation management, and risk
management with additional participation from Idaho Power’s VP of Planning, Engineering,
and Construction in IWRMC’s Executive Strategy Forums. In September of 2023, Idaho Power
along with Oregon Investor-Owned Utilities (IOU), arranged for an IWRMC-led presentation and
discussion with Oregon PUC staff on the IWRMC Wildfire Maturity and Readiness Model.
Idaho Power is also a member of the Edison Electric Institute (EEI) and the Western Electric
Institute (WEI). Throughout 2023, the company participated in multiple workshops and
conferences with EEI and WEI that provided insights into emerging technologies and
advancements for WMPs. 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 (DOE) and other government
agencies to collectively minimize wildfire threats and potential impacts.
These forums and workgroups continue to prove valuable for sharing wildfire mitigation
best practices and discussing new and existing technology related to wildfire mitigation.
For example, Idaho Power’s participation in the Oregon Wildfire Detection Camera
Interoperability Committee led to key insights related to early wildfire detection technologies,
including the complexities with wildfire detection camera network build outs6 and associated
partnership development. Many of the lessons learned through the Oregon group have been
carried into ongoing workgroup processes for Idaho and resulted in Idaho Power issuing a
Request for Proposal (RFP) in 2023 for a wildfire detection camera pilot project. These
engagements have additionally informed evaluation criteria that Idaho Power and partners in
Idaho will use in 2024 to assess camera functionality, interoperability, and overall benefit for
early detection and situational awareness.
6 Ankita Mohapatra, Early Wildfire Detection Technologies in Practice—A Review. Sustainability 2022, 14(19).
https://doi.org/10.3390/su141912270.
Wildfire Mitigation Plan 2024 Idaho Power Company
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2023 Industry, Fire Expert, and Peer Utility Engagement
Idaho Power continues to engage with industry groups, wildfire experts, and peer utilities to gain knowledge of new
mitigation activities, industry best practices, and employing technology to reduce wildfire risk. The following
summarizes 2023 activities.
Academia—Idaho Power is working to expand collaboration with academic institutions, which can provide
research-based and peer-reviewed insights into the risks of wildfire and associated impacts on customers.
Highlights of the company’s 2023 engagements include:
•Took part in a qualitative study hosted by San Jose State aimed at understating the impacts to
communities from PSPS events and overall perceptions of wildfire mitigation.
Ada County Fire Adapted Communities (ADAFAC) Workgroup—Idaho Power is an active partner of ADAFAC which supports wildfire education and community preparedness.
AMCL Risk Assessment Workshop—Attended a two-day workshop on risk management approaches,
including frameworks, processes, and tools, aligned to ISO 31000 that enables effective risk-based
decision-making.
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.
Edison Electrical Institute (EEI)—Idaho Power is a member company of EEI and in 2023 attended two EEI’s
hosted events specific to wildfire:
•Wildfire Technology Summit—Attended presentations specifically on wildfire risk assessments, drone use
in wildfire (inspections, PSPS events), weather data programs, wildfire risk software, and wildfire
program benchmarking.
•UAS Working Group Conference—Attended presentation on drone use for wildfire mitigation, drone infrared
inspections, wildfire drone patrols, use of BVLOS fixed wing aircraft for storm damage assessment,
stringing rope to pull wire with drones, and use of drone-in-a-box solutions for distribution inspections.
Electric Power Research Institute (EPRI)—Continued engagement with EPRI, including participation and
contributing towards the development of a Wildfire Advisory Group and attendance at EPRI’s Climate READi
workshop in September of 2023 which focused on wildfire and extreme heat. Presentations and discussions included wildfire insight from National Oceanic and Atmospheric Administration (NOAA), PNNL, DOE, UC
Merced, Oregon PUC, BPA, PG&E, and Seattle City Light.
Governors Wildfire Roundtable—Participated in the Idaho Governor’s Wildfire Roundtable and provided details
of utility practices to decrease wildfire risk, PSPS, and liabilities. The outcome of the roundtable will result in
future work groups aimed at decreasing the risk and impacts of wildfire in Idaho.
Institute of Electrical and Electronic Engineers (IEEE)—Attended 2023 general meeting which included panel
presentations on power quality, ignition reporting, and results following wildfire hardening practices.
International Association of Arson Investigators—IPC staff participated in a 40-hour fire investigation course
and will be pursuing additional courses in wildland fire cause and investigation. Additionally, IPC hosts annual training for staff on first responder fire investigation principals.
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2023 Industry, Fire Expert, and Peer Utility Engagement (continued)
International Wildfire Risk Mitigation Consortium (IWRMC)—In 2023, Idaho Power joined IWRMC, an industry
sponsored collaborative that facilitates the sharing of risk mitigation insights and utility wildfire practices from
across the globe. Idaho Power actively participates in monthly workgroup forums for operations and protocols,
asset management, vegetation management, and risk management.
National Grid Alliance—Provided presentation on Idaho Power’s Vegetation Management program with details
of the company’s satellite and aerial imagery pilot project for wildfire mitigation.
National Interagency Fire Center—Met with NIFC staff to learn more about the Quantitative Wildfire Risk
Assessment (QWRA) and Interagency Fuel Treatment Decision Support System (IFTDSS). Idaho Power will
continue to work with NIFC in 2024 to evaluate the future use of these tools in the utility setting.
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.
Oregon Wildfire Detection Camera Interoperability Committee—Continue to participate with this committee
which is evaluating the siting/logistics, technology, governance, and financial needs associated with the growing
network of wildfire detection camera systems in Oregon.
Pacific Northwest Economic Region (PNWER) 32nd Annual Summit—Attended and presented during the general
session on developing policy and strategies for wildfire prevention, response, and how government and private industry are responding to the ever-growing challenge of wildfires.
Peer to Peer Engagements—Idaho Power met numerous peer utilities in 2023 to learn about WMP
programmatic advancements, collaborate on operational practices, and learn about individual pathways
towards programmatic maturity. Highlights included:
•PG&E Advanced Technology Lab in San Ramon, California—Discussions included approach
to vegetation management, enhanced system settings for wildfire, distribution hardening, PSPS event
planning, wildfire risk analysis, wildfire risk software (Technosylva), pole loading, weather data, andignition tracking.
•Oregon Joint IOU collaboration-Idaho Power staff spend approximately 400 hours throughout 2023
working directly with PacifiCorp and Portland General on collective WMP regulatory compliance and
programmatic maturity.
Southern Idaho Priority Landscape Partnership—Active participant in a multi-jurisdictional and cross-ownership
boundary fuels reduction partnership effort that spans 2.3 million acres in southern Idaho.
Southern Idaho Wildfire Detection Camera Strategy Group—Began hosting monthly meetings with State and
Federal agency partners who are interested in growing a network of wildfire detection cameras throughout Idaho. Idaho Power is bringing lessons learned to this group from the Oregon Wildfire Detection Camera
Interoperability Committee.
Technology—Idaho Power maintains and regularly updates our five-year WMP technology roadmap. This
roadmap provides a framework for ongoing evaluation of existing and new technologies and informs the process for the incorporation of new innovations into our WMP pilot project cycle. As part of our technology roadmap
process, Idaho Power annually meets with a variety of wildfire technology vendors.
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2023 Industry, Fire Expert, and Peer Utility Engagement (continued)
Urban Land Institute Sustainability Conference—Attended and participated on a panel to discuss the role utilities
are playing to reduce wildfire risk and the challenges around development in wildland urban interface areas.
U.S. Forest Service (USFS) Forest Leadership Teams—Met with R4 USFS leadership teams across our Idaho service area to provide an overview of the company’s WMP, discuss risk modeling efforts, and initiate conversation on
collective opportunities for wildfire risk mitigation work within and adjacent to Idaho Power’s utility right of ways.
WEI Wildfire Planning and Mitigation Virtual Meeting—Attended a two-day conference to gain insight into
mitigation activities and strategies other utilities are pursuing.
Western Energy Institute (WEI)—Participated and presented on WMP metrics at the annual WEI Wildfire
Conference.
Wildfire Technology Webinar—Attended webinar focused on using artificial intelligence (AI) drones for grid inspections, aerial sensors, and cameras to gain situational awareness.
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3. Quantifying Wildland Fire Risk
3.1. Objective
Idaho Power’s approach to quantifying wildland fire risk includes qualitative and quantitative
strategy 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 works with 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 commonly used across the
industry with other utilities in California, Oregon, Idaho, Nevada, and Utah utilizing a similar
approach to identify and quantify wildfire risk. The CPUC utilized the same consultant as Idaho
Power did in the original development of the CPUC Fire Threat Map.
This wildfire risk-based methodology is consistent with conventional definitions of risk, which is
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:
Figure 3
Wildfire risk-based methodology
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Each component is defined 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,
topography, fuel type, and fuel moisture content.
Consequence. Estimation of the fire’s impact on structures (i.e., homes, businesses,
other man-made structures) and acres burned.
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.
3.2.1. Wildfire Risk Modeling Process
The wildfire risk modeling process incorporated the following major steps:
1. A twelve-year (2011–2022) 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.7
4.The data developed above (WRF climatology, live fuel moisture, and LANDFIRE data)
was used to drive a Monte Carlo8 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.
7 Lautenberger, C.W., “Mapping areas at elevated risk of large-scale structure loss using Monte Carlo simulation and wildland fire modeling,” Fire Safety Journal 91: 768-775 (2017).
8 Ibid.
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Ignition locations were limited in the model to be within a 240-meter buffer surrounding
Idaho Power’s overhead T&D lines (i.e., 120 meters on either side). The model used
equal ignition probability for all overhead distribution and transmission asset types.9
Urbanized areas having underground circuitry were not included in the model due to a
low probability of wildfire associated with underground electrical equipment. For each
combination of ignition location and time of ignition, fire progression was then modeled
for 12 hours. For each modeled fire, potential fire impacts to structures were quantified
using structural location 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.
9 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.
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2023 Risk Modeling Input Updates
Idaho Power worked with a wildfire risk modeling consultant in 2023 to update wildfire risk models
for Idaho Power’s service area. Key input updates include the following:
Climatology—Updated 12-year (2011–2022) fire weather climatology was utilized for the 2023
risk model. This climatology set was developed using the Weather Research and Forecasting
(WRF) model to recreate historical days of fire weather significance across IPC’s service area.
High-resolution hourly gridded fields of relative humidity, temperature, dead fuel moisture, and
wind speed/direction were extracted from this analysis and provided as input to a Monte Carlo-
based fire modeling analysis. Up-to-date and granular climatology inputs are used for Idaho
Power’s wildfire risk modeling process, as it allows Idaho Power greater insight into how climate
variability is and will continue to influence wildfire risk within the service area1. Idaho Power is
exploring the feasibility of bringing a greater resolution climatology package in-house that could
be used to inform risk modeling and operational weather forecasting across the service area
moving forward.
Predicting future fire regime change requires insight into how temperatures and precipitation
may influence vegetation over time, recognizing that climate variability as a determinant of fire
activity does not impact all landscape and vegetation types uniformly. Idaho Power’s service area
includes significant variation in ecotypes (ranging from high desert vegetation to alpine forests)
and as such, it will be increasingly important to understand locations throughout the service area
that are particularly prone to near and longer-term fire regime change. While fire regime
remains one of the strongest factors to overall acres burned, the effects of Wildland Urban
Interface (WUI) expansion combined with fire regime change has an influence greater than the
sum of their individual effects, suggesting that climate variability may have an outsized impact in
fire prone areas that are experiencing population expansion.2
Idaho Power Infrastructure and Outage Information—Infrastructure expansions were added
into the modeling. Two years of outage information from across the service area was also used
to better discern areas that have a higher probability of high wind or other seasonal impacts.
Structural Data—Datasets were updated to include 2020 census block level and Microsoft
Building footprints. This enabled a better understanding of both existing population as well as
insight into new building development near wildfire risk zones and within Wildland
Urban Interface.
Vegetation Classification—Fuels inputs were obtained from the most recent LANDFIRE product
(2.3.0). This version includes disturbances, such as fires, through 2022 and reclassified certain
vegetative conditions allowing for more granularity.
1Keeley, J., and Syphard, A., 2016, Climate change and future fire regimes—Examples from California: Geosciences, v. 6, no. 3, 14 p.,
doi.org/10.3390/geosciences6030037.
2Liu, Z., Wimberly, M.C., Lamsal, A., Sohl, T.L., and Hawbaker, T.J., (2015), Climate change and wildfire risk in an expanding wildland–
urban interface—a case study from the Colorado Front Range corridor: Landscape Ecology, v. 30, no. 10, p. 1943–1957,
doi.org/10.1007/s10980-015-0222-4.
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3.2.2. Establishing Wildfire Risk Zones
Based on the previously described modeling, draft risk tiers are generated algorithmically10
by an automated process. Tiers are established which, if exceeded, would classify an area as
Tier 2 (elevated risk) or Tier 3 (higher risk). This was accomplished by manually setting
threshold values at naturally occurring breaks and is a similar approach to that 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. Idaho Power color-codes the tiers—Yellow Risk Zones (YRZ) for Tier 2 and Red
Risk Zones (RRZ) for Tier 3.
Iterative review of wildfire risk across the service area remains integral to the maturity of Idaho
Power’s risk modeling methodology and is consistent with the ISO 31000 risk management
process that informs Idaho Powers WMP. Annual risk area adjustments are used to account for
unique factors that may increase or decrease risk due to changes that have occurred overtime,
such as increased development in a wildland urban interface or recent large-scale fires that
alter vegetation composition. In addition to the quantitative assessment provided by the
wildfire risk model, Idaho Power simultaneously utilizes a qualitative assessment process to
account for factors that are not incorporated into the wildfire risk modeling, detailed below in
Figure 4.
10 Ibid.
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Figure 4
Risk zone evaluation and determination process
Incorporating Local Feedback into Risk Zone Establishment
Throughout the year, Idaho Power routinely attends Local Emergency Planning Committees
(LEPC). Among other topics, this forum provides a platform to receive valuable feedback from
county-level Public Safety Partners on the WMP, including risk areas, mitigation approaches,
outage preparedness, and emergency planning. In 2023, Idaho Power also met one-on-one with
local fire departments and rural fire protection districts in Oregon and Idaho, and State and
Federal resource managers, including Idaho Department of Lands, Oregon Department of
Forestry, BLM District-level leadership in Oregon and Idaho, and USFS Forest-level leadership in
Idaho to review Idaho Power’s risk modeling process and gain feedback on localized areas
relative to wildfire risk. The feedback gained from these one-on-one meetings was particularly
informative for understanding suppression capabilities, ingress/egress routes, and localized
factors that may influence fire regime. For example, qualitative feedback received from
meetings relative to two distant areas of Idaho Power’s service area—Unity, Oregon, and
Salmon, Idaho—resulted in changes to risk zones that better reflect the risk profiles in those
areas. In addition, Idaho Power is engaging with localized wildfire mitigation planning
processes, such as Community Wildfire Protection Plans, to better correlate risk identification
and mitigation approaches.
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Idaho Power’s process for incorporating customer feedback into the WMP utilizes a variety of
approaches, including public workshops. Section 10 details Idaho Power’s approach to
customer outreach and feedback relative to the WMP, including risk zone establishment.
Wildfire Risk Zone Calibration with Peer Utilities
Idaho Power routinely engages with peer utilities and forums to benchmark and
continually improve the company’s WMP, including with the approach to risk modeling.
In 2023, Idaho participated in conversations with PacifiCorp, the Oregon Trail Electric Co-Op,
and Avista to better understand each utility’s approach to risk assessment and risk zone
designation. Since joining the International Wildfire Risk Management Consortium in 2023,
Idaho Power has also participated in a subgroup within the forum that is focused on risk-based
topics, including risk assessments, mapping, and modeling. While the fundamental processes
for conducting wildfire risk modeling are not inherently different across the utility industry,
individual processes for evaluating impacts to highly valued resources and assets (HVRA)
may differ. Idaho Power defines consequence as a fire’s impact on structures and acres burned,
thus the relative importance of these two factors is primary to the company’s determination of
risk zones. HVRAs may be defined or weighted differently depending on the goals associated
with wildfire modeling and as such risk profiles can vary.11 Idaho Power will continue to work
with peer utilities to inform collective understanding and decision making around wildfire risk
modeling with the goal of continually improving Idaho Power’s approach.
3.3. Wildfire Risk Zones
As detailed above, Idaho Power’s wildfire risk zones reflect risk relative to Idaho Power’s service
area only and not absolute risk. To aid in customer and public understanding, Idaho Power
color-codes the tiers—Yellow Risk Zones (YRZ) for Tier 2 and Red Risk Zones (RRZ) for Tier 3.
The full risk zone map can be viewed in detail on Idaho Power’s website and individual
addresses can be entered on the map to determine proximity to identified risk zones.
The service-wide risk zone map provides a foundation for Idaho Power’s wildfire mitigation and
risk reduction strategies and is used in part to support the determination and prioritization of
investments, inspection activities, and increased situational awareness. For 2024, Idaho Power
made twelve zone changes across the service area (Table 4).
11 Scott, Joe H., etal. (2013). A wildfire risk assessment framework for land and resource management. United States Department of Agriculture,
Forest Service, Rocky Mountain Research Station.
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Table 4
2024 risk zone changes

Table 5 provides a breakdown of pole miles in risk zones on a system-wide basis and by state.
State New YRZ New RRZ Elevated YRZ to RRZ
Idaho 2 - 6
Oregon 3 1 -
Total 5 1 6
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Table 5
Idaho Power’s overhead transmission and distribution lines by risk zone in Idaho and Oregon*
Asset
ALL IPC LINES
LINES IN
WILDFIRE RISK
ZONES
WILDFIRE RISK ZONES BY STATE
T2-IDAHO T3-IDAHO T2-OREGON T3-OREGON T2-NEVADA T3-NEVADA
Total Pole
Miles
Total
Pole
Miles
% All Lines
Total
Pole
Miles
% All Lines
Total
Pole
Miles
% All Lines
Total
Pole
Miles
% All Lines
Total
Pole
Miles
% All Lines
Total
Pole
Miles
% All Lines
Total
Pole
Miles
% All Lines
Transmission
Lines 4,651 517 11% 362 7.8% 120 2.6% 23.6 0.5% 0 0.0% 11 0.2% 0 0%
Distribution Lines 19,407 1649 8% 857 4.4% 710 3.7% 41.3 0.2% 40 0.2% 0 0.0% 0 0%
Total Pole
Miles 24,057 2166 9% 1219 5.1% 830 3.5% 64.9 0.3% 40 0.2% 11 0.0% 0 0%
*Current as of November 15, 2023. Line mileage reported includes 100% Idaho Power owned assets and does not include assets in co-ownership.
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3.3.1. Maps
The following two-tier wildfire risk map in Figure 5, is illustrative of Tier 2 (Yellow Risk Zones)
and Tier 3 (Red Risk Zones) throughout Idaho Power’s service area. Additionally, figures 6
through 16 reflect Tier 3 Zones by region and service area. An illustrative map book of all zones
is included in Appendix C. A full and up-to-date risk zone map can be viewed in detail on Idaho
Power’s website.
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Figure 5
Idaho Power wildfire risk zones
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Figure 6
Eastern Idaho–Pocatello area
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Figure 7
Eastern Region–Salmon area
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Figure 8
Southern Region–Wood River Valley
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Figure 9
Southern Region–Pine-Featherville
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Figure 10
Capital Region–Boise Front
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Figure 11
Centerville
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Figure 12
Idaho City area
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Figure 13
Cascade/Donnelly area
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Figure 14
Garden Valley/Crouch area
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Figure 15
McCall/New Meadows area
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Figure 16
Halfway Oregon
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3.3.2. 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 17). Two locations are identified along the route as having
elevated wildfire risk (Tier 2 Zones), and there are no areas of higher risk (Tier 3 Zones).
Although the B2H transmission line has not been constructed as of the publication of this 2024
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 through 9 of this WMP.

Figure 17
Proposed B2H route

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4. Costs and Benefits of Wildfire Mitigation
4.1. Objective
This section details Idaho Power’s assessment of general 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 4.4 identifies selected mitigation activities and the estimated costs of those
activities on a system level. In Section 4.5, 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.
For example 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
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exceed $20 billion.12 This increase13 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 6.
Table 6
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 and reasonably conclude that the incremental costs of wildfire mitigation efforts are
prudent. Considering the available historical information and data regarding wildfire risks and
losses, Idaho Power worked with PacifiCorp and Portland General Electric as a joint utility
working group to begin developing a strategy for the future creation of a common framework
evaluating risk spend efficiency.
Risk spend efficiency (RSE) is a tool that can be used to better understand how a proposed
mitigation approach may incrementally reduce wildfire risk. At a basic level, RSE is calculated as
a ratio between overall cost and risk reduction achieved. RSE includes analyzing risk mitigation
alternatives, the expected risk reduction, and considers the lifecycle costs and other constraints
of the mitigation. RSE metrics can be compared to one another, ultimately allowing for the
ability to assess one mitigation approach against another to evaluate the effectiveness of an
investment relative to reducing wildfire risk while minimizing ratepayer impact.
With RSE being a ratio, it is important to note that mitigations with high costs and associated
risk reduction may have the same RSE as mitigation with low cost and small associated risk
reduction. Overall risk levels may warrant greater spend to achieve the objectives of an
independent utility’s WMP. Idaho Power will continue to expand RSE efforts with a specific
focus on trying to accurately quantify risk reduction and to determine how RSE may be used as
one of many inputs in the overall decision-making processes for mitigation approaches and

12 Jill Cowan, How Much Will the Wildfires Cost?, The New York Times, Sept. 16, 2020, at nytimes.com/2020/09/16/us/california-fires-cost.html.
13 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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alternatives. A detailed roadmap for the creation of a collaboratively developed, uniform RSE
framework process will be developed in 2024.

Figure 18
Joint Oregon IOU–risk spend efficiency process timeline
4.3. Risk Analysis and Drivers
Idaho Power’s risk management framework is modeled after the internationally recognized risk
management standard, ISO 31000. ISO 31000 provides a comprehensive framework for
effective risk management with six distinct steps summarized in the graphic below.

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Figure 19
Idaho Power WMP risk management framework
Idaho Power faces evolving wildfire risk and continues to advance its risk management
processes to better understand sources of risk and to identify the best solutions to further
reduce risk in the future. Managing risk is an evolving process and while not all risk can be
eliminated, Idaho Power’s goal is to proactively prepare and enhance its infrastructure and
operational practices to deliver safe and reliable energy today and in the future. The company
continues to work to systematically identify, analyze, evaluate, mitigate, and monitor risks
associated with wildfire.
In 2023 Idaho Power partnered with a consulting firm to reassess ignition risks from overhead
transmission and distribution facilities and gain a deeper understanding of how wildfire risk can
be quantified. A project team was formed and began an assessment process by conducting
three workshops throughout the year with subject matter experts from various departments
within the company. The team used the ISO 31000 standard as a guide for identifying and
evaluating equipment specific risks in the context of wildfire ignition. Risk drivers and scenarios
were analyzed to determine the likelihood and impact of wildfire. This process included a
review of how uncertainties can be quantified to help prioritize risk and assess mitigation
efficiency and effectiveness. This work led to the creation of a risk bow-tie diagram, shown in
Figure 20, used as a visual representation of risk.

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The bow tie analysis considers the risk exposure throughout Idaho Power’s 24,000 square mile
service area and locations having overhead transmission and distribution facilities. The bow tie
is constructed using three components described below.
• The Triggering Event: The event that Idaho Power aims to avoid that could
impact the company’s ability to meet its objectives of providing safe, reliable,
and affordable energy.

• Risk Drivers: Factors that may potentially lead to an ignition are listed on the left-hand
side of the bow tie. Actual conditions play an important role of whether a wildfire occurs
as a result of an ignition, and it is important to note that the risk drivers shown are only
an indication that a risk event may occur.

o Contact from a foreign object—contact with foreign objects, including
vegetation, animals, balloons, and other wind-blown objects.

o Equipment failure—the unexpected failure of line equipment due to discrete
(internal) or destructive (external) conditional changes.

Figure 20
isk bow-tie
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o Environmental—extreme weather conditions that include high wind, low
humidity, and drought, contribute to increase the risk of wildfire, and can lead to
tree failure, vegetation contact, and failure of electrical equipment.

o Other—overhead powerlines may be at risk of vehicle collisions, vandalism,
or physical attack. Construction activities, including activities performed by
sub-contractors, near overhead powerlines may be a risk driver if proper safety
precautions are not taken to eliminate inadvertent equipment contact.

• Risk Impacts: While most fires are extinguished quickly, the right-hand side of the bow
tie describes the range of possible outcomes associated with the risk event. Impacts
vary largely on where the event occurs, and actual conditions and the impacts shown
are worst case scenarios and rare for Idaho Power’s service area.

Idaho Power has identified and implemented mitigations for each of the top risk drivers shown
in the risk bow tie with details provided throughout the WMP. Each type of mitigation is
designed to reduce one of more of the risk driver frequencies or modify the potential impacts
or outcomes. Primary mitigation programs and activities include overhead circuit hardening,
underground conversions, expanded vegetation management and asset inspections, and Public
Safety Power Shutoff. The company plans to perform an annual review of risk drivers and
evaluate alternative mitigation strategies as part of our commitment to continuously improve
upon each version of the WMP.
Probabilistic Risk Modeling
Idaho Power’s approach to performing wildfire risk assessments includes the identification of
hazards and estimating their relative likelihood of occurrence and potential consequences
through feedback from subject matter experts and utilizing data when available. In 2023, the
company began exploring new methods to measure risk beyond traditional ranking methods to
account for uncertainties in estimations. This work involved the initial development of
preliminary probabilistic operational risk models. The models may help Idaho Power quantify
the frequency of risk drivers and range of possible outcomes under varying levels of
uncertainty. Idaho Power is preliminarily planning to use Monte Carlo simulations to model
multiple likelihood and consequence scenarios to produce a distribution of outcomes. This is
expected to provide the company a path forward for enhancing a data driven, risk-informed
decision-making framework.
Refining and incorporating risk models into risk assessment methodologies is expected to take
several years to complete due to complex nature of assessing failure rates, likelihood of
ignition, and range of consequences before and after mitigation is applied. However, the
company recognizes the importance of improving quantification methods and the benefits it
will have towards developing a risk spend efficiency methodology.
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4.4. Wildfire Mitigation Cost Summary
From 2024 through 2028, Idaho Power estimates investing $209 million in operations and
maintenance (O&M) expenses to further wildfire mitigation measures. Table 7 summarizes
the company’s planned expenditures associated with executing its WMP through 2028.
Estimated amounts reflect the company’s best estimates and plans as of the 2023 WMP.
These estimates will likely change in the future as the company reviews and refines its WMP
and associated mitigation activities. For the 2024 WMP, each wildfire mitigation category—
and associated estimated expenditures in Oregon and Idaho—is discussed in Section 4.5.
Idaho Power Company Wildfire Mitigation Plan 2024
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Table 7
Estimated system-wide O&M expenses for wildfire mitigation, $000s (2023–2028)*
2023
Planned
2023
Estimated
Year End
Actuals
2024
Forecast
2025
Forecast
2026
Forecast
2027
Forecast
2028
Forecast
5-Year
Forecast
Total
5-Year
Forecast
Total–
Idaho
5-Year
Forecast
Total–
Oregon
A. Quantifying Wildland Fire Risk
Risk Map Updates and Dynamic Risk Modeling $67 $61 $10 $868 $873 $879 $884 $3,515 $3,339 $176
B. Situational Awareness
Weather Forecasting - System development and support $47 $47 $74 $254 $74 $74 $74 $550 $523 $28
Weather Forecasting Personnel–Fire Potential
Index (FPI) and Public Safety Power Shutoff (PSPS)
$178 $100 $103 $264 $271 $280 $288 $1,206 $1,145 $60
Weather Forecasting–Weather Station
Maintenance
$19 $19 $23 $31 $38 $45 $52 $189 $162 $27
Pole Loading Modeling & Assessment (Contract service) $75 $72 $75 $75 $150 $150 $ - $450 $375 $75
Cameras $165 $37 $200 $240 $280 $280 $320 $1,320 $1,264 $56
C. Mitigation - Field Personnel Practices
Tools/Equipment $5 $ - $5 $5 $ 5 $5 $5 $25 $24 $1
Mobile Weather Kits for Field Observers $10 $10 $2 $10 $ - $ - $5 $17 $16 $1
International Wildfire Risk Mitigation Consortium $35 $35 $35 $35 $35 $35 $35 $175 $166 $9
D. Mitigation - Transmission & Distribution Programs
O&M Component of Capital Work $61 $100 $111 $122 $135 $149 $165 $681 $606 $75
Annual O&M T&D Patrol Maintenance Repairs $50 $190 $50 $50 $50 $50 $50 $250 $238 $13
Annual Recloser Segmentation Maintenance and
Communication Fees
$ - $ - $ 5 $23 $32 $37 $42 $139 $ 80 $59
Environmental Management Practices $25 $25 $25 $25 $25 $25 $25 $125 $ - $125
Transmission Thermography Inspection Mitigation $20 $122 $200 $20 $20 $20 $20 $280 $109 $171
Distribution Thermography Inspection Mitigation $30 $ - $30 $30 $30 $30 $30 $150 $143 $8
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2023 Planned 2023 Estimated Year End Actuals
2024 Forecast 2025 Forecast 2026 Forecast 2027 Forecast 2028 Forecast 5-Year Forecast Total
5-Year Forecast Total– Idaho
5-Year Forecast Total– Oregon
Thermography Technician Personnel $200 $210 $216 $223 $229 $236 $243 $1,148 $1,091 $57
Transmission Wood Pole Fire Resistant Wraps $163 $259 $250 $250 $250 $250 $250 $1,250 $1,188 $63
Wildfire Mitigation Program Labor $191 $161 $516 $531 $547 $564 $581 $2,740 $2,603 $137
Covered Wire Evaluation–Pilot Program in PSPS Zones $50 $117 $50 $ - $ - $ - $ - $50 $48 $3
E. Vegetation Management
Transition to/Maintain 3-year Vegetation
Management Cycle
$22,728 $25,709 $33,884 $37,311 $44,686 $32,980 $34,632 $183,493 $174,319 $9,175
Enhanced Practices for Distribution Tier 3 & Tier 2 Zones (Pre-Fire Season Patrols/Mitigation,
Pole Clearing, Removals, Work QA)
$1,284 $1,284 $1,348 $1,416 $1,486 $1,561 $1,639 $7,450 $7,077 $372
Line Clearing Personnel $159 $159 $168 $173 $178 $184 $189 $892 $847 $45
Fuel Reduction Program $75 $150 $ - $75 $75 $75 $225 $225 $ -
Vegetation Mgmt. Satellite and Aerial Imagery $150 $119 $150 $300 $300 $300 $300 $1,350 $1,283 $68
F. Communications
Wildfire/Wildfire Mitigation Education/Communication–Advertisements, Bill Inserts, Meetings, Other & PSPS Customer Education/Communication–Advertisements,
Bill Inserts, Other
$171 $100 $171 $171 $171 $171 $171 $855 $812 $43
G. Information Technology
Communication/Alert Tool development (System set up, outage maps, critical facilities identification)
$ - $- $ - $ - $ - $ - $ - $ - $ - $ -
Communication/Alert Tool for PSPS Customer
Alerts/Extended Use
$129 $129 $161 $161 $161 $161 $161 $805 $765 $40
Total $26,087 $29,075 $37,862 $42,663 $50,104 $38,540 $40,161 $209,330 $198,446 $10,884
*As of December 29, 2023.
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4.5. Mitigation Activities
Idaho Power utilizes 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. While these initiatives are first and foremost intended to
mitigate the risk and impacts associated with wildfire, additional co-benefits such as
increased safety, reliability, and resiliency of the system are also achieved (see Table 8).
As such, Idaho Power considers co-benefits a part of the evaluation process. Below is a
narrative of each mitigation activity, its purpose, estimated near-term cost, and additional
potential co-benefits of the activity to Idaho Power and its customers, and possible 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.
Table 8
Safety, reliability, and resilience co-benefits of wildfire mitigation initiatives
Mitigation Initiative
Safety Reliability Resiliency
Defined as the potential
to pose a danger, risk, or
injury to life or property
Defined as the ability of the power system to withstand instability,
uncontrolled events, cascading failures, or unanticipated loss of
system components
Defined as the
ability for the grid system to adapt to, withstand, and
quickly recover from disruptive events or changes within the surrounding environment
Enhanced Vegetation Management x x
Asset Inspections and Corrections x x
Grid Hardening x x x
Undergrounding x x x
Quantifying Wildfire Risk x
Situational Awareness–Weather Forecasting,
FPI, Weather Stations x x x
R&D x x
Advanced Technologies–Wildfire Detection
Cameras x
Advanced Technologies–Pole Loading x x
Covered Conductor Pilot x x x
Community Programs x
Customer Notification Enhancements x
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4.5.1. 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 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 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.
5-Year Cost Estimate for Quantifying Wildland Fire Risk (2024–2028)
Idaho Power intends to continue work with an external consultant to re-evaluate its risk
analysis between 2024 and 2028. During this time, the company also plans to evaluate new
developments in risk modeling tools that would potentially give Idaho Power a data driven
platform for assessing real-time wildfire spread and potential impact to infrastructures.
The new platform would potentially elevate the company’s risk-informed decision-making
approach by providing the ability to track, forecast and evaluate events in real-time and in
relation to each circuit within the service area. Idaho Power estimates system-wide expenditure
for these services to be approximately is $3.5 million between 2024 and 2028.
4.5.2. 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, 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 warranted 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
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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 a tool to assess the fire
potential on a consistent basis and across the service area. Given the distinct benefits that
result from the FPI and enhanced forecasting capabilities, Idaho Power did not consider
alternatives to the development of these critical tools.
In conjunction with the FPI, Idaho Power is evaluating complementary technology that
would inform real-time wildfire forecasting and Idaho Power’s wildfire simulation capabilities.
These tools may provide additional support for cost-benefit analysis of mitigation and
potentially better inform operational decision-making during wildfire season.
5-Year Cost Estimate for Situational Awareness—Weather Forecasting Activities and Personnel
(2024–2028)
The estimated expenditure for weather forecasting activities (weather forecasting tools,
system development, weather station maintenance, and personnel) is $1,945,000 between
2024 and 2028.
4.5.3. 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 AI-enabled wildfire
detection cameras, satellite, and aerial imagery to detect vegetation hazards, pole loading
modeling (to assess the structural integrity of poles), as well as covered conductors.
Regarding cameras, the company initiated a pilot project in 2023 to test the placement of
cameras in strategic, Tier 3 locations to enhance situational awareness. With input from state
and federal fire responders, Idaho Power developed rigorous evaluation criteria, which includes
learning related to artificial intelligence capabilities in wildfire ignition detection. Multiple
camera vendors are being considered to determine potential cost-effective solution(s).
Idaho Power is additionally working with federal, state, and local agencies to explore the
possibility of partnering on the installation and ongoing use of cameras which may lead to
possibilities for cost sharing and larger wildfire detection camera networks in the future.
5-Year Cost Estimate for Situational Awareness—Pole Loading Modeling and Assessment
(2024–2028)
The estimated system-wide expenditure to conduct pole loading modeling and assessment,
which includes LIDAR assessment, is $450,000 for 2024 through 2028. Idaho Power plans to
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conduct the assessment in Tier 3 Zones located in Idaho and depending on efficacy,
will evaluate expansion of the program to other areas across the service area, including Oregon.
5-Year Cost Estimate for Situational Awareness—Cameras (2024–2028) The estimated expenditure for the pilot evaluation installation of cameras in or adjacent to
Tier 3 Zones is $200,000 in 2024. Idaho Power estimates that the use of cameras will continue
beyond the pilot period and estimates a total system wide expenditure of $1.3 million from
2024 through 2028. Idaho Power plans to prioritize initial camera installment and
evaluation in Tier 3 Zones in Idaho. However, Idaho Power will be assessing the need,
feasibility, and potential partnership opportunities associated camera installation in Oregon.
4.5.4. 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 where there
is a heightened risk of wildfire; 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,14 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 an important component of
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.
In 2023, Idaho Power joined the International Wildfire Risk Mitigation Consortium (IWRMC),
a group whose mission is to share lessons learned, best practices, and innovation in wildfire
mitigation. Idaho Power actively participates in monthly workgroup forums for operations and

14 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, Idaho, in the early 1900s.
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protocols, asset management, vegetation management, and risk management.
These workgroup forums both inform operational preparedness for wildfire season as well
as provide insight into global thinking and advancements in wildfire mitigation.
5-year Cost Estimate for Field Personnel Equipment (2024–2028)
The estimated system-wide expenditure for field personnel equipment (tools, mobile weather
kits, and participation in the IWRMC) is $217,000 between 2024 and 2028.
4.5.5. 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.
4.5.5.1. Annual T&D Patrol, Maintenance, and Repairs
Visual inspections are an important 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 Tier 3 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 Tier 3 Zones are inspected on an annual basis to
identify 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.
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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.
Idaho Power plans to expand the use of overcurrent protection devices called reclosers to
isolate areas of higher wildfire risk from areas with lower risk. This work improves the reliability
of for customers outside of wildfire risk zones and involves installation of new devices or
relocation of existing. This work also typically involves upgrading communication capabilities so
PSPS and sensitivity setting changes can be made remotely in real-time.
5-Year Cost Estimate for Annual T&D Patrol, Maintenance, Repairs, and Segmentation
(2024–2028)
The estimated system-wide incremental expenditure for annual T&D patrols,
maintenance, repairs, and recloser segmentation is $1.2 million from 2024 to 2028.
4.5.5.2. Thermography Inspections
While Idaho Power periodically conducts infrared thermography inspections as part of
reliability and maintenance programs, the company is expanding these inspections in
Tier 3 Zones on an 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 repairs of issues found are prioritized based on their severity.
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 Tier 3 Zones. A combination of Idaho Power personnel and contracted resources are
used to perform thermography inspections.
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.
5-Year Cost Estimate for Thermography Inspections (2024–2028)
The estimated expenditure for thermography inspections is $1,578,000 from 2024 to 2028.
Idaho Power will prioritize the use of this mitigation practice in Tier 3 Zones.
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4.5.5.3. Wood Pole Fire-Resistant Wraps
To help improve the resiliency of Idaho Power’s transmission system and the company’s
wood transmission poles, Idaho Power wraps them with a fire-resistant mesh. The mesh
wrap helps protect the integrity of the pole if it is exposed to fire. The use of the fire-resistant
mesh is often more cost efficient than replacing all wood poles with structures made of
non-combustible material, such as steel.
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.
5-Year Cost Estimate for Wood Pole Fire-Resistant Wraps (2024–2028)
The estimated system-wide expenditure for applying fire-resistant mesh wraps to transmission
poles in elevated wildfire risk areas is $1.3 million between 2024 and 2028.
4.5.5.4. 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 took steps to
evaluate covered conductor in in 2023 and plans to 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 the potential for improved reliability outside of wildfire season
and the potential for reduced outage restoration costs.
5-Year Cost Estimate for the Covered Conductor Pilot (2024–2028)
The estimated cost of continuing the pilot in 2024 is $50,000. While this pilot will take place in
Idaho, the lessons from it will extend across the company’s service area.
4.5.6. Enhanced Vegetation Management
Idaho Power’s enhanced vegetation management practices are discussed in detail in Section 8.7
of this WMP.
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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 an important part of Idaho Power’s WMP.
To prioritize risk reduction from vegetation contact, Idaho Power established a target to meet a
three-year pruning cycle with enhanced vegetation management practices in Tier 3 and Tier 2
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
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 targeted three-year cycle and performing the additional
activities detailed above will involve a sizeable increase in incremental O&M expenditure.
One 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
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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 long-term co-benefits, including reduced
vegetation-caused outages in Tier 3 and Tier 2 risk zones. The 2023 wildfire season saw an
increased number of storm events, high winds, and more lightning throughout the service area
than in previous years. While storm activity was higher, outages associated with vegetation fell
by 27% compared to previous years—indicating that the company’s vegetation management
practices are reducing risk. Idaho Power plans to continue to monitor performance and outage
metrics to confirm the success of the enhanced program.
4.5.6.1. Fuels Reduction Shared Stewardship Project
In 2023, Idaho Power began participating in a regional fuel reduction program, in which
Idaho Power works 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 in and near utility rights-of-way and Tier 3 areas.
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. Other western utilities
participate in similar programs and this program is modeled after projects performed in
Washington, California, Colorado, and Arizona. Participation in the effort is estimated to cost
$225,000 from 2024 through 2028. Idaho Power’s monetary investment in fuels reduction is
leveraged significantly with state and federal funding.
In 2022 and 2023, the company conducted pilot projects that tested the capabilities of satellite
and high-altitude Geiger mode LiDAR patrols of vegetation in the company’s wildfire risk zones.
These pilot projects concluded that these technologies do not accurately identify encroachment
and clearance issues at the level needed to make risk informed decisions, so they will not be
deployed on large scale for conducting vegetation patrols until the technologies mature.
5-Year Cost Estimate for Vegetation Management (2024–2028)
The estimated system-wide expenditure for vegetation management is at least $193 million
from 2024 to 2028. However, given recent escalations in vegetation management costs across
the United States, this figure could increase if Idaho Power continues to strive to meet
certain targets.
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4.5.7. 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.
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 provide real-time alerts to customers about wildfire events and outages, including potential
PSPS events.
Cost Estimate for Communication and Customer Notification Enhancements (2024–2028)
The estimated system-wide expenditure for communication expenses is $855,000 and $805,000
for customer notification system enhancements, totaling $900,000 from 2024 to 2028.
4.5.8. 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. Capital investment programs and 5-year forecasts are
summarized in Table 9. Section 8.4.7.3 additionally summarizes transmission line rebuild
projects that are planned over the next five years. These projects will improve reliability for
customers and increase resiliency of the transmission system from wildfire.
Idaho Power’s capital investments for wildfire mitigation are discussed in detail in Section 8.2
(T&D Asset Management Programs) of this WMP.
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Table 9
WMP forecasted capital investments
*These are estimates only. The costs may increase or decreased due to such factors as inflation or scope changes.
Wildfire Mitigation Forecasted Capital Investments, $000s*
Mitigation
Program
Description
of the
Program
Risk Reduction
Benefit
2023
Planned
In Service
2024
Planned
In Service
2025
Planned
In Service
2026
Planned In Service
2027
Planned In Service
2028
Planned In Service
5-Year
Planned
In Service
Total
5-Year
Total Idaho
5-Year
Total Oregon
Overhead Primary Hardening
Program
Systematic replacement and upgrades
of hardware
and equipment
Reduced potential of equipment failure, utilizing
material and
equipment with less energy release and potential of
ignition, increased
resiliency $7,379 $6,150 $7,225 $7,395 $8,100 $8,556 $37,426 $34,966 $2,460
Strategic
Undergrounding
Select
conversion of
overhead to
underground conversion in Tier 3 Zones
Reduce exposure and potential of
ignition by
locating power lines underground $580 $- $- $4,000 $5,000 $6,250 $15,250 $15,250 $-
Recloser
Segmentation and Communication
Upgrades
Installation,
relocation, and expanded communication
for Automatic
Reclosing overcurrent protection
devices
Isolate circuit
segments and improve reliability for enhanced Fire
Potential Index
settings and PSPS
$194 $1,453 $1,599 $1,731 $866 $866 $6,515 $5,383 $1,132
Atmospheric
Science Weather Stations
Installation of
weather stations to gain situational
awareness
Provides ability to
model and forecast fire potential and
severe weather
conditions for FPI and PSPS $51 $116 $113 $116 $120 $94 $559 $ 467 $92
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4.5.8.1. Circuit Hardening
Idaho Power estimates spending approximately $8 million annually from 2024 through 2028 on
circuit hardening and infrastructure upgrades across its system.
Idaho Power’s WMP includes an overhead distribution hardening program for Tier 3 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 Tier 3 Zones, but it may be expanded to Tier 2 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 2028.
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 Tier 3 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 upfront 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 upfront 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 follow the prioritization process outlined in
the WMP to 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.

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Fuse Replacements—Expulsion fuses located in Tier 3 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 evaluated 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.
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 failure during arrester operation. All distribution arresters located on
primary distribution lines in Tier 3 Zones will be replaced. In 2019, Idaho Power piloted new
arrester technology to evaluate performance characteristics, installation requirements, and
potential benefits in reducing ignition risk. In the pilot, Idaho Power compared different
manufacturers with similar technology and conducted performance analysis to determine
the most cost-effective solution.

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 reduction of tracking of
electrical current. Tracking occurs when the flow of current over an insulator generates
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 of 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 Tier 3 Zones. Idaho Power is prioritizing
replacement of wood crossarms with fiberglass on cross arms identified as having defects or
damage and those still utilizing wood pins. Installation of fiberglass crossarms will continue
over time, which allows the company to spread the cost out 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 Tier 3 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.
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Therefore, porcelain switches installed in Tier 3 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 find the most cost-effective and reliable solution.
The results of 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—To protect wildlife, Idaho Power employs several different protection
measures 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 Tier 3 and Tier 2 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. Solution are determined on a case-by-case basis
depending on the specific location, the type and extent of avian presence, and other
relevant factors.

4.5.8.2. Overhead to Underground Conversions
Idaho Power estimates spending approximately $15 million from 2024 through 2028 on
converting overhead distribution circuits to underground construction.
Another aspect of Idaho Power’s system hardening program is the select conversion of
overhead to underground distribution lines in Tier 3 Zones. Areas selected for
underground conversion are based on the results of risk quantification and modeling work,
feedback from local fire officials, fire history, PSPS likelihood based on historic weather
conditions, and consideration of infrastructure access and public egress. In 2023, the company
converted 0.61 miles of overhead distribution lines to underground lines, bringing the total line
miles converted to underground construction to nearly 2.5-miles.
In 2024 and beyond, the company will continue to build a strategic undergrounding program
by weighing the cost-benefit of undergrounding versus other circuit hardening measures.
This work includes evaluating the Johnny Creek area in Pocatello, Idaho, for potential
underground conversion in 2025 or 2026. 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
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the feasibility of underground conversions as well as the relative value and cost effectiveness as
part of the WMP.
4.5.8.3. Recloser Segmentation
Idaho Power estimates spending approximately $6.5 million from 2024 through 2028 on the
installation, relocation, and communication upgrade of reclosers.
Segmentation is a strategy involving the placement of overcurrent protection devices,
called reclosers, to isolate or segment areas of higher wildfire risk from areas with lower risk.
The goal of segmentation is to improve the reliability for customers outside of wildfire risk
zones. Reclosers provide a point of de-energization for PSPS and are also used to adjust
protection settings on days having higher fire potential to limit the risk of ignition. Idaho Power
plans to install new and relocate existing reclosers throughout the service area as well as
improve the company’s remote communication capabilities over the next five years.
4.5.8.4. 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 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 Tier 3
and Tier 2 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 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 lower 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.

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• 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.
Fire Potential Index (FPI) Category
Normal Elevated Higher
FPI Range 1 to 11 12 to 14 15 to 16

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.
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
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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
meteorological products will be used. These products will include regional weather
observations used to validate model information.

5.3. FPI Review and Evaluation
The FPI process is reviewed annually after completion of the fire season and, with consultation
of interested parties (e.g., Load Serving Operator, Line Crews, and others). Evaluation of the FPI
process is used to assess and validate Idaho Power’s wildfire preparedness approach.
Very Wet Very Dry
0 1 2 3 4 5
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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5.4. Forecast Ensemble
Idaho Power has reviewed available forecasting tools and modeling systems used to support
fire related forecasting operations. Utilities active in the atmospheric science community with
well-established WMPs were surveyed. All use a multi-model ensemble of atmospheric
models. An ensemble approach provides a higher level of accuracy and precision of forecasts
(both spatial and temporal) while also allowing the development of probabilities for the
occurrence of when, where, and of what magnitude of events may occur by being able to
better account for the variability between model realizations and other complexities. Based on
the lessons learned from the review, Idaho Power plans to incorporate a multi-model ensemble
into future FPI forecasting and PSPS decision making. The development of an ensemble is in its
early stages and in 2023 the company began installation of necessary computing hardware to
develop the system. Full implementation of an ensemble in Idaho Power’s fire weather
forecasting is expected to start in 2025 or 2026.
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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 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 working in locations and under conditions where there is a heightened risk of
wildfire. 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, including weather conditions, regarding locations where
there is a heightened risk of wildfire

• 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 season.15

• 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 assessed Time Current Curves and fault energy of different circuits to gauge
the overall reduction in energy between different protection configurations and
coordination challenges. Figure 21 below summarizes the different protection
configurations evaluated along with estimated benefits in terms of reduced fault energy
and impacts to customers.

15 The duration of the fire season will be reviewed and defined annually.
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Figure 21
Comparison of reclosing strategies with respect to customer reliability and wildfire risk
As part of the evaluation process of the operational protection schemes for wildfire protection,
the company benchmarked with other utilities and found a variety of approaches to wildfire
protection schemes and advanced settings. The review highlighted an evolution of protection
schemes over utilities’ years of experience in wildfire mitigation. For example, in 2023,
the company traveled to San Francisco to meet with PG&E to learn more about their Enhanced
Powerline Safety Settings (EPSS). The lessons learned led to evaluating and evolving our own
protection system approach to wildfire mitigation in the coming years.
Idaho Power’s current operational protection strategy involves implementing reclose off in fire
risk zones during red FPI conditions. The company plans to continue to use reclose off as the
first level of operational protection in fire risk zones in 2024 and will continue analyzing and
begin piloting more advanced protection schemes.

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7.3. Transmission Line Operational Strategy
7.3.1. Fire Season Temporary Operating Procedure for Transmission Lines 115 kV
& Above
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. Tier 3 Zone Transmission Operational Strategy 69 kV & Below
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 Tier 3 Zones. These lines will be operated in normal settings mode but
with no “testing”16 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. Tier 3 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 Tier 3 Zones. These lines will be operated in a non-reclosing17 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 a decision is made by the Regional Operations manager. Idaho Power is
analyzing and testing advanced protection schemes and plans to pilot more sensitive protection
scheme targeted areas of the system in 2024.

16 Transmission line “testing” refers to the human act of re-energizing a line without completing a physical field patrol or observation of a line.
17 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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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 extreme 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 can result in customer impact and
requires extensive planning and strategy leading up to, during and after a PSPS event.
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, 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 wildfire risk relative to Idaho Power’s service area. While a PSPS event is more
probable in an elevated wildfire risk zone, Idaho Power retains the ability to utilize PSPS
anywhere throughout the service area. The decision regarding PSPS is based on a number of
dynamic factors, and each weather event is unique.
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8. Mitigation Initiatives
8.1. Overview
Idaho Power’s wildfire mitigation strategy relies in part on its various asset management
programs, including asset inspections and the Vegetation Management program (VMP),
to maintain safe and reliable operation of its T&D facilities in reducing wildfire risk.
8.2. T&D Asset Management and Inspections
To prevent wildfire and safely operate the grid, Idaho Power implements and continuously
evaluates a robust set of asset management and inspection initiatives. Fundamental to these
efforts is the continual research into industry best practice and strategic piloting of emerging
technologies and approaches to complement and improve Idaho Power’s core asset
management strategy. Idaho Power’s approach for supporting wildfire prevention and
mitigation through asset management and inspection initiatives is summarized in Table 10 and
subsequently detailed throughout this section. Table 11 provides detail on Idaho Power’s assets
relative to wildfire risk zones.
Table 10
Asset management and inspection initiatives
Wildfire Mitigation Asset Management Inspection Initiatives
Transmission Distribution
Aerial Visual Inspection Program
Ground Visual Inspection Program
Detailed Visual Inspection Program
Wood Pole Inspection and Treatment Program
Cathodic Protection and Inspection Program
Thermal Imaging Inspections
Wood Pole Wildfire Protection Program
Steel Pole Program
Ground Detail Inspection Program (enhanced)
Wood Pole Inspection and Treatment
Wood Pole Fire Protection Program
Line Equipment Inspection Program
Thermal Imaging Inspections
Overhead Primary Hardening Program

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Table 11
Service area asset overview18
Type of Equipment
Total
Idaho
Tier 3
Idaho
Tier 2
Idaho
Total
Oregon
Tier 3
Oregon
Tier 2
Oregon
Substations 288 8 17 43 - 1
Power Generation Facilities 20 1 - 3 - -
Overhead Transformers 120050 11907 9039 10161 308 359
Reclosers 1044 64 46 146 4 2
Voltage Regulators 826 41 36 117 3 4
Capacitor Banks 44 22 28 83 1 -
Wood Poles (transmission) 34145 886 3490 7728 - 335
Steel Poles (transmission) 7628 75 919 467 - -
Transmission Towers 2525 153 238 560 - 6
Overhead Conventional Line Fuses 29438 661 480 1708 28 35
8.3. Inspection and Correction Timeframes
Idaho Power implements a T&D inspection and correction strategy and schedule that enables
the identification and repair of equipment conditions that could pose a risk for wildfire.
Asset management inspections allow personnel to look for potential defects, which, if found,
are documented, categorized, and scheduled for repair based on priority designation.
Corrective action plans for Priority 1 and 2 defects are determined by engineering personnel
and subsequently scheduled and repaired consistent with OAR 860-024-0018. Defects are
categorized 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 warrant reporting
and correction within 24 months of identification and the correction of these defects
are scheduled during crews’ normal work schedules. Priority 2 defects that are not
assigned a corrective plan within 24 months will be reviewed by the T&D vegetation and
maintenance engineering leader.

• Priority 3: Defined by Idaho Power as potential issues that may need correction
overtime and should be monitored, but do not pose a threat to the system. A Priority 3
designation may also be used by Idaho Power personnel for tracking of certain line

18 - See Table 5 for overhead conductor line miles.
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construction practices. Correction of Priority 3 issues may be deferred until the next
major work activity on the circuit up to a maximum of ten years after discovery.
Risk quantification and modeling indicates that Tier 3 Zones have a higher potential of risk from
wildfires and as such, Idaho Power performs additional inspections in these areas—including
annual ground-based inspection and targeted infrared inspections. As part of the ISO 31000 risk
management process, Idaho Power will continue to enhance its distribution and transmission
inspection programs by expanding future evaluation processes of inspection and correction
activities and schedules. Quality assurance inspections are performed annually across the
service area to enhance the safety of the public and to verify the quality of new construction is
consistent with the National Electrical Safety Code. Work orders are randomly selected for
inspection and deficiencies are recorded and corrected based on the priority level. The results
of the inspections are shared with regional field workers to help foster learning and ensure
construction meets current standards. In addition to randomly selected inspections,
duplication annual inspections provide quality assurance by having utility arborists and
thermography technicians check overhead assets as part of other ongoing inspections in
wildfire risk zones.
Idaho Power is additionally evaluating the use of emerging technologies that support the
identification of potential issues not visible by traditional ground inspections or where terrain
or other constraints may limit the ability to perform a detailed ground inspection. The following
table summarizes Idaho Power’s inspection initiatives and frequency with respect to wildfire
risk zones.
Table 12
Summary of asset inspections and schedules by state and zone
Inspection Interval
Asset Inspection Type
Idaho
Non- Risk Zone
Oregon
Non- Risk Zone
Idaho
Tier 2
Oregon
Tier 2
Idaho
Tier 3
Oregon
Tier 3
Transmission Defect Inspections
Visual* Annually Annually Annually Annually Annually Annually
Detailed 10 Years 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 10 Years
Infrared Patrol None None None None Annually Annually
Distribution OH Defect Inspections
Visual/Detailed* 3 Years 2 Years 3 Years 2 Years 3 Years 2 Years
Groundline (Wood Pole Test and Treat) 10 Years 10 Years 10 Years 10 Years 10 Years 10 Years

Wildfire Mitigation/Potential Ignition Source Patrol* None None None Annually Annually Annually
Infrared Inspections None None None Annually Annually Annually
*Includes Ignition Prevention Inspection consistent with Oregon Administrative Rules in Chapter 860, Division 24.
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8.4. Transmission Asset Management and Inspection Initiatives
Idaho Power’s transmission asset management inspections programs 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.
8.4.1. Aerial Visual Inspection Program
Annually, Idaho Power uses helicopters to assist Idaho Power qualified personnel in the aerial
visual inspection of transmission lines identified as WECC Path Lines. This method of line
inspection is part of Idaho Power’s Wildfire Mitigation Patrols and is additionally used on an
annual basis pre-wildfire season for non-WECC transmission lines located in Tier 3 Zones.
Unmanned aerial vehicles with high-definition cameras are also being used in certain situations
to inspect facilities on these lines.
8.4.2. 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 support
the identification of potential line defects that are documented and scheduled for repair based
on defect classification.
8.4.3. 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 consistent with defect classification. 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.
8.4.4. Thermal Imaging (Infra-red) Inspections
Idaho Power annually inspects transmission lines and equipment within Tier 3 Zones using
thermal imaging (infra-red) cameras. Compromised electrical connections and overloaded
equipment may be identified using thermal imagery and as such, support the identification of
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potential issues that may not be apparent on visual inspection. Identified risks will be prioritized
and mitigated consistent with defect classification.
8.4.5. Wood Pole Inspection and Treatment Program
All wood poles are visually inspected, sounded, and bored for defects and decay on a 10-year
cycle. 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

o Is deteriorated and does not meet minimum strength criteria; or

o Fails a visual inspection.
Rejected poles are categorized as either reinforceable with steel or
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.
8.4.6. 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,
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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.
8.4.7. Transmission Asset Protection
8.4.7.1. Wood Pole Wildfire Protection Program
To help improve the resiliency of Idaho Power’s transmission system and the company’s
wood transmission poles, Idaho Power wraps them with a fire-resistant mesh. The mesh wrap
helps protect the integrity of the pole if it is exposed to fire. Idaho Power is in the process of
installing mesh wrapping on transmission wood poles located in the Tier 3 and Tier 2 zones and
may utilize mesh in additional areas that have higher fire return intervals outside of wildfire
risk zones.
8.4.7.2. Transmission Steel Poles
Idaho Power utilizes steel poles or structures for new transmission line construction projects
built to 138 kV standards and above 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.
8.4.7.3. Transmission Line Rebuild Projects
Idaho Power takes proactive steps to repair or replace transmission line components
on an ongoing basis as part asset management and aging infrastructure assessments.
Annually, inspection activities inform maintenance needs with short and long-term plans
developed to manage line assets. In some cases, lines are selected to be rebuilt in the future to
increase capacity, reliability, or improve safety. Wildfire risk and the location of transmission
lines are considered as part of the prioritization of transmission line rebuild projects. Table 13
summarizes transmission line rebuild projects that are planned over the next five years.
These projects will improve reliability for customers and increase resiliency of the transmission
system from wildfire. Construction schedules and material lead times may change and adjust
the in-service dates shown.
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Table 13
Transmission line rebuild projects
Transmission Line Rebuild Projects, Estimated Planned Investment ($000s) and Timeline
Transmission Line Description 2024
Planned
2025
Planned
2026
Planned
2027
Planned
2028
Planned
5-Year
Planned
Idaho
5-Year
Planned
Oregon
Line 412 - Rebuild of existing Boise Bench to Emmett 138KV
transmission line, Idaho
Rebuild the Boise Bench to Emmett 138kV Line, using steel structures instead of
wood as identified in WMP. $13,086 $9,380 $- $- $- $22,466 $ -
Line 423 -Rebuild of existing Huntington-Quartz 138kV
transmission line, Oregon
Replace 286 structures from Huntington to Quartz substation in Oregon with
tubular steel 138kV H-frame
structures. $14,649 $- $- $- $- $- $14,649
Line 433 - Rebuild existing Wood
River to Ketchum 138-kV
transmission line, Idaho
Rebuild the existing 138-kV transmission line from Wood
River to Ketchum substation,
Idaho, using steel structures instead of wood as identified in WMP. $127 $355 $293 $7,999 $- $8,775 $-
Rebuild Boise to Emmett
Junction, the Cairo to Fruitland tap to 138 kV specifications, Idaho
Rebuild existing 69 kV line
structures to 138 kV
capabilities, using steel structures instead of wood as identified in WMP. $- $- $36 $98 $14,691 $14,825 $-
Line 328 - Rebuild Existing Emmett to Warm Lake 69 kV Line to 138 kV specifications, Idaho
Rebuild existing 69 kV line
structures to 138 kV capabilities, using steel structures instead of wood as
identified in WMP. $81 $108 $84 $25,398 $25,758 $51,428 $-
Line 423 - Rebuild the Ontario to Huntington 138 kV transmission
line, Oregon
Rebuild the Ontario substation to Huntington substation, Oregon, with
tubular steel 138 KV H-frame
structures. $31 $104 $0 $9,634 $10,421 $- $20,190
Line 701 - Rebuild from Quartz substation to La Grande 230 kV
Replace wood structures with tubular steel 230 kV H-frame
structures. $- $65 $177 $43 $0 $- $285
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Transmission Line Rebuild Projects, Estimated Planned Investment ($000s) and Timeline
Transmission Line Description 2024
Planned
2025
Planned
2026
Planned
2027
Planned
2028
Planned
5-Year Planned Idaho
5-Year Planned Oregon
Line 906 Boise Bench to
Midpoint substation 230kV, Idaho
Replace poles, cross arms, and
insulators identified during
the Pole Inspection and
Ground line Treatment Program and the annual routine Line Patrols. $5,501 $1,572 $- $- $- $7,073 $-
Line 906 - Boise Bench to Midpoint substation, 230 kV #2, Idaho
Rebuild line from Boise Bench
Substation to Midpoint Substation, Idaho. Wood structures will be replaced
with Tubular steel 230 kV H-
frame structures. $- $- $16 $37 $0 $54 $-
Line 908 - Rebuild the Pallette to Imnaha 230 kV transmission line,
Oregon, currently in preliminary
scoping
Rebuild the Pallette to Imnaha 230kV line, Oregon, with
tubular steel H-frame
structures. $464 $4,828 $5,001 $- $- $- $10,294
Line 902 - Rebuild from Rattle Snake Station to DRAM segment
on the Boise Bench to DRAM to
Midpoint #1 230kV line, Idaho
Phase one of four phases of the transmission line rebuild. The Line is to be constructed
using steel H-Frame
structures. $13,160 $- $- $- $- $13,160 $-
T902 Rebuild the Boise Bench to DRAM substation segment on
the Boise Bench to DRAM to
Midpoint #1 230kV line (Phase 2), Idaho
Phase two of four phases of the transmission line rebuild.
The Line is to be constructed
using steel H-Frame structures. $168 $2,295 $- $- $- $2,463 $-
Line 902 - Rebuild the Mountain
Air Wind Park to Rattle Snake
Station segment on the Boise Bench to DRAM to Midpoint #1 230kV line (Phase 3), Idaho
Phase three of four phases of
the transmission line rebuild.
The Line is to be constructed using steel H-Frame structures. $- $1,600 $7,341 $- $- $8,941 $-
Line 902 - Rebuild the Midpoint
to Mountain Air Wind Park
Station segment on the Boise Bench to DRAM to Midpoint #1 230kV line (Phase 4), Idaho
Phase four of four phases of
the transmission line rebuild.
The Line is to be constructed using steel H-Frame structures. $- $- $3,700 $13,482 $13,482 $30,665 $-
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Transmission Line Rebuild Projects, Estimated Planned Investment ($000s) and Timeline
Transmission Line Description 2024
Planned
2025
Planned
2026
Planned
2027
Planned
2028
Planned
5-Year Planned Idaho
5-Year Planned Oregon
Line 410 - Rebuild Lucky Peak
Junction to Mountain Home
Junction segment of Lucky Peak
to King Line 138kV Line rebuild, Idaho
Rebuild with steel poles
instead of wood.
$236 $28,470 $1 $- $23 $28,731 $-
Line 410 - Rebuild the Black
Mesa Substation to Cassia Wind
Park segment of Lucky Peak to King 138 kV line rebuild, Idaho
Rebuild with steel poles
instead of wood. $11 $- $- $8,478 $- $8,489 $-
Line 410 - Rebuild DRAM to
Lucky Peak of the 138kV Line
rebuild, Idaho
Rebuild with steel poles
instead of wood. $6 $- $- $- $4,230 $4,236 $-
Line 410 - Rebuild Mountain Home Junction to Black Mesa
segment of Lucky Peak to King
138kV Line rebuild, Idaho
Rebuild with steel poles
instead of wood.
$50 $- $- $- $23 $74 $-
Line 925 - Rebuild Lucky Peak Junction to the Lucky Peak segment of the Lucky Peak to
King 138kV Line rebuild, Idaho
Rebuild with steel poles instead of wood.
$12 $- $4,795 $1 $2- $5,808 $-
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8.5. Distribution Asset Management and Inspection Initiatives
Idaho Power has several distribution asset management programs that are mature, have been
implemented for decades, and will continue to be utilized in elevated risk zones in Oregon and
Tier 3 Zones in Idaho. These programs include condition-based, detailed, and ground visual
inspection; distribution wood pole inspection and treatment; and line equipment inspection.
Annual inspections performed in Oregon Tier 2 and Tier 3 zones comply with the requirements
of Oregon Administrative Rules in Chapter 860, Division 24 frequency of inspections and
identification of defects and potential ignition sources. Line patrol personnel meet on a
quarterly basis to review and maintain alignment on the types of defects they look for as well as
the proper priority categorization placed on defect identification. These exercises help to create
and maintain consistency in inspection and reporting practices among inspectors and across the
regions in Idaho Power’s service area.
Idaho Power implements an enhanced overhead distribution “hardening” program in Tier 3
Zones. Examples of specific work include replacement of small conductors and associated
hardware and replacement of wooden pins and associated wooden crossarms.
8.5.1. Ground Visual Inspection
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 Tier 3 Zones to identify Priority 1 defects. The ground patrols
are completed using four-wheel-drive vehicles, all-terrain vehicles, utility terrain vehicles, or on
foot. They involve inspection at each individual pole and incorporate the use of visual
observation, binoculars, and/or unmanned aerial vehicle (UAV). These inspections identify
potential line defects which are then documented, prioritized, and scheduled for repair.
Detailed distribution inspections are completed on a predetermined schedule and may be
performed in conjunction with annual visual inspections.
8.5.2. 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.
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8.5.3. Thermal Imaging (Infra-red) Inspections
Idaho Power annually inspects targeted distribution lines and equipment within Tier 3 Zones
using thermal imaging (infra-red) cameras. Compromised electrical connections and overloaded
equipment may be identified using thermal imagery and as such, support the identification of
potential issues that may not be apparent on visual inspection. Identified risks will be prioritized
and mitigated consistent with defect classification.
8.5.4. Wood Pole Inspection and Treatment Program
All wood poles are visually inspected, sounded, and bored for defects and decay. The procedure
for the Distribution Wood Pole Inspection and Treatment Program is consistent with and
elaborated on earlier in this Section under the Transmission Wood Pole Inspection and
Treatment Program.
8.5.5. Overhead Primary Hardening Program
Overhead distribution infrastructure located in Tier 3 Zones is analyzed, inspected, and may be
hardened depending upon proximity to fuels conducive to wildfires. The Overhead Primary
Hardening program is intended to upgrade or repair certain overhead distribution
infrastructure to reduce potential risk of ignition. The following outlines the core strategies
Idaho Power utilizes as part of the Overhead Primary Hardening Program. However, Idaho
Power’s team is continually researching and evaluating industry practices and emerging
technologies relative to primary hardening Notable hardening criteria is expanded upon below.
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Idaho Power Overhead Distribution Primary Hardening
Program Strategies

• Replace “small conductor” with new 4 ACSR or larger conductor
• Replace or repair damaged conductor
• Re-tension loose conductors including “flying taps” and slack spans as required
• Replace wood-stubbed poles with new wood poles
• Replace white and yellow square tagged poles with new wood poles
• Replace wood pins/wood crossarm with new steel pins/fiberglass crossarms
• Replace steel insulator brackets with new steel pins/fiberglass crossarms
• Replace wedge deadends on primary taps with new polymer deadend strain insulators
• Replace aluminum deadend strain insulators with new polymer deadend strain insulators
• Replace porcelain switches with new polymer switches
• Install bird/animal guarding
• Replace hot line clamps
o Replace aluminum stirrups
o Install avian cover
o Relocate arresters
• Update capacitor banks
o Replace swelling capacitors
o Replace oil-filled switches with vacuum style
o Replace porcelain switches with polymer switches
• Install disconnect switches on CSP transformers
o Install avian cover
• Update down guys
o Replace/Install down-guy insulators with fiberglass insulators
• Tighten down guys
o Tighten hardware
• Correct third-party pole attachment clearances (report to Joint Use department)
• Install wood pole mesh wrap (in targeted locations)

Conductor “Small” Replacement
Idaho Power is implementing replacement of small conductors in Tier 3 Zones.
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.
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.
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Porcelain Switch Replacement
Porcelain switches located in Tier 3 Zones 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.
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 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 Tier 3 Zones as a part of its distribution overhead primary wildfire
hardening program.
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 Tier 3 Zones.
8.6. Ignition Tracking and Analysis
The WMP is founded on the goal of minimizing the probability that various components of the
company’s transmission and distribution system acts as an ignition source. The company has
evaluated and implemented mitigation strategies to reduce the likelihood of ignition and tracks
outage events to gauge performance.
The company maintains an Outage Management System (OMS) database which is used for
reliability and measurement reporting purposes. Outage events are analyzed to determine
whether certain equipment is prone to experiencing outages or has the potential to act as an
ignition source. This analysis considers the leading drivers of ignition identified as part of the
risk assessment and risk bowtie in Section 3.2. It includes assessing the location and date of
outages to determine whether an event occurred during wildfire season or within a wildfire risk
zone. The vast majority of outage events do not result in an ignition and depend upon several
factors, such as the circumstances beyond Idaho Power’s control that led to the event and
environmental conditions (e.g., fuel type, moisture content, weather conditions, and time of
year). A combination of the information provided in the company’s OMS database, along with
notes and feedback from troublemen and dispatch operators, help determine whether an
ignition event occurred for a particular outage.
The image below details a Power BI dashboard tool that that links to the company’s OMS
database. This dashboard provides details of outage events that involve the operation of
primary line fuses, transformer fuses, and automatic reclosing devices. It was created to assist
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in analyzing outage events specific to wildfire risk zones for distribution circuits and provides a
means to track performance over time. When an outage is reported, the fields are populated,
and the dashboard provides an assortment of filters and functionality to aid analysis.
When outages are associated with equipment failure, additional analysis of the equipment
can be conducted to determine if the equipment issues are associated with reported ignitions.
As an example, a review performed in early 2023 identified specific areas where vegetation
caused several outages during the 2022 wildfire season in a particular wildfire risk zone beyond
the same overcurrent protection device. The company’s Wildfire Mitigation utility arborist
incorporated the dashboard into work procedures to identify problematic areas and proactively
investigate and correct issues.

Figure 22
Example of Idaho Power outage dashboard

Ignition Tracking Database

In 2023, the company benchmarked with several western utilities to gain insight into their
ignition tracking methodologies and to determine opportunities for improvement. Based on
the lessons learned through the engagement, the company will develop a roadmap in
2024 to enhance its ignition tracking process and tools used for gathering detailed
ignition information.
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8.6.1. Root Cause Analysis
Idaho Power may conduct investigations and root cause analysis (RCA) for repetitive equipment
or material failure, significant incidents, and near misses. RCA is a systematic process of
investigating adverse events and includes gathering evidence and details of the failure to
determine the cause and prevent future occurrences. The company’s RCA process typically
involves the following steps:
1. Equipment or material failure (i.e., repetitive failures or those associated with a
significant incident or outage) is reported by field personnel

2. Failed items are placed in designated storage areas for analysis

3. A Materials Analyst researches the failure frequency and provides details to the
company’s Methods and Materials department

4. The Methods and Materials department performs an evaluation of the item(s) to
determine reason for failure and the mode of the failure

5. The Methods and Materials department provides recommendations for changes

6. If required, communication is provided for field personnel to notify of the issue and to
provide details of replacement equipment/material

7. On a case-by-case basis, vendors and manufacturers are made aware of the failure(s)
and asked to provide deeper levels of analysis and develop corrective action plans

As an example of how the RCA process is applied, in 2023, a 12.47 kV shunt capacitor bank
experienced a failure where an individual capacitor failed unexpectedly. While the failure did
not occur within a wildfire risk zone or lead to a wildfire, the failure mode indicated a potential
manufacturing defect. RCA was performed to determine if the capacitor was defective and
whether any action should be made to other capacitors of similar vintage within the service
area or within wildfire risk zones. The company’s Methods and Materials department
investigated the incident and engaged the manufacturer for further analysis. The results of the
analysis and corrective action plan are still pending, and the company plans to use the feedback
to determine if modifications or replacement of existing capacitors are needed to prevent
future failures.
8.7. 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,
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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
following table.
Table 14
Vegetation Management program 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 Tier 3 and Tier 2 zones
Distribution
Pre-Fire Season Inspection and Mitigation
Line Clearing Cycle Goal: 3-year cycle in all areas with mid-cycle pruning occurring in second year in
Tier 3 and Tier 2 zones*
Tree Removals–Cycle Busters/Hazard Trees
Targeted Pole Clearing
100% Quality Assurance/Quality Control Auditing in Tier 3 and Tier 2 zones
*Distribution line clearing cycles vary by utility. Idaho Power has set a goal of achieving a 3-year cycle of distribution line clearing.
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 enhanced vegetation
management practices in both Tier 2 and Tier 3 zones. 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 imminent threat of contact with energized facilities. In addition, Idaho Power strives to
complete audits for all pruning work performed in Tier 2 and Tier 3 zones, regardless of reason
for the pruning. The audits confirm that pruning cuts meet the specification and proper
clearance was obtained. Table 15 summarizes vegetation management activities with respect to
wildfire risk zones.
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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.
Table 15
Summary of vegetation management activities and schedules
Vegetation Management Inspection Interval
Inspections and Activity
Schedule Non-Risk Non-Risk Idaho
Tier 2 Zone
Oregon
Tier 2 Zone
Idaho
Tier 3 Zone
Oregon
Tier 3 Zone
Transmission Hazard Tree Patrol on
NERC/WECC Lines Annually Annually Annually Annually Annually Annually
3 Years 3 Years 3 Years 3 Years 3 Years 3 Years
Cycle Patrol/Pruning— Mountain Locations 6 Years 6 Years 6 Years 6 Years 6 Years 6 Years
Wildfire Mitigation Patrol/Pruning None None None None Annually Annually
Cycle Buster Patrol/Pruning (Documented Cycle Buster Trees) 18 Months 18 Months 18 Months 18 Months 18 Months 18 Months
Distribution
Wildfire Mitigation Patrol/Pruning None None Annually Annually Annually Annually
Cycle Patrol/Pruning 3 Years 3 Years 3 Years 3 Years 3 Years 3 Years
Mid-Cycle Patrol/Pruning None None 2 Years after
Cycle Prune
2 Years after
Cycle Prune
2 Years after
Cycle Prune
2 Years after
Cycle Prune
Cycle Buster Patrol/Pruning None 18 Months

Quality Assurance (Transmission and Distribution)
Post-Pruning Audit Inspections Sampling Sampling 100% 100% 100% 100%
8.7.1. Vegetation Management Definitions
Applicable Transmission Lines—Each overhead transmission line operated within WMP
Tier 3 Zones 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.
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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.
8.7.2. Transmission Vegetation Inspection and Management
Maintaining a vegetation-free clearance zone near transmission lines has long been a priority
for Idaho Power. The clearance zone is voltage-level dependent and defined by federal and
state regulations.
8.7.2.1. 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 also evaluate the hazardous
vegetation on the level of threat posed by categorizing the vegetation as a higher priority,
medium hazard, or lower hazard. Any hazardous vegetation found is reported to the utility
arborist and documented. Any hazardous vegetation categorized as a higher 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.
8.7.2.2. Transmission Line Clearing Cycles
Transmission lines will be cleared on long-term cycles based on three years for urban and rural
valley areas and six 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
manual cutting of targeted trees and tall shrubs. When appropriate, tree-growth regulators
and spot herbicide treatments are applied in compliance with federal or state requirements.
These treatments are effective for reducing re-growth of sprouting deciduous shrubs and trees
and extending maintenance cycles.
Terra Spectrum VMSuite vegetation management software is utilized to plan tree pruning
and removal work, to assign this work to crews, and to document the dates work is planned,
assigned, completed, and audited.
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8.7.2.3. 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
Tier 2 and Tier 3 zones, audits will be performed on 100% of pruning work performed in Tier 2
and Tier 3 zones 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. This quality
control and assurance program has proved valuable. For example, audits performed on two of
Idaho Power’s distribution circuits in 2022 discovered numerous trees that were either
improperly pruned or not pruned at all. As a result, Idaho Power requested the pruning
contractor re-prune these circuits to achieve satisfactory results.
8.7.3. Distribution Vegetation Management
Idaho Power is actively working to clear distribution lines throughout Idaho Power’s service
area on a three-year cycle.19 Additionally, in Tier 2 and Tier 3 zones, 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.
8.7.3.1. Distribution Line Clearing Cycles
Idaho Power is actively working to clear distribution lines on a three-year cycle. In Tier 2 and
Tier 3 zones, 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 upon an “as needed basis” in the situations that fast
growing, unexpected growth occurs and is reported by any employee or customer.
8.7.3.2. 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 Tier 2 and
Tier 3 zones. In addition, distribution patrol personnel also inspect the lines in the Tier 3 Zones
annually. During these inspections, patrol personnel identify infrastructure defects and
hazardous vegetation, within or adjacent to the ROWs, that could fall 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 higher priority, medium hazard,
or lower hazard. Any hazardous vegetation found is reported to the utility arborist and

19 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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documented. Any hazardous vegetation categorized as a higher 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.
Terra Spectrum VMSuite vegetation management software is utilized to plan tree pruning and
removal work, to assign this work to crews, and to document the dates work is planned,
assigned, completed, and audited.
8.8.3.3. 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.
When appropriate, tree-growth regulators and spot herbicide treatments are applied in
compliance with federal or state requirements. These treatments are effective 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.
8.8.3.4. Distribution Line Clearing Quality Control and Assurance
Similar to Idaho Power’s vegetation audit process for Transmission, 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
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utility arborists. Due to the elevated risk of wildfire in Tier 2 and Tier 3 zones, audits will be
performed on pruning work performed in Tier 2 and Tier 3 zones regardless of the reason
for the patrols and pruning. This quality control and assurance program has proved valuable.
For example, audits performed on two of Idaho Power’s distribution circuits in 2022 discovered
trees that were either improperly pruned or not pruned at all. As a result, Idaho Power
requested the pruning contractor re-prune these circuits to achieve satisfactory results.
8.7.4. 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 are 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 surrounding 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—
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are also deployed to assist in restoration efforts. Restoration work may take hours or, in some
cases, days to complete. Depending on the extent of damage, customers may need to 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 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 was reviewed and updated in
2023 and 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
assist with effective and consistent communication 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 information in greater detail with Public Safety Partners, operators of
critical facilities, and customers who live in zones where PSPS events are more likely.
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 how to 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 state, 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. Throughout 2023, the company worked with several counties
within the service area as they went through updated processes to their Community Wildfire
Protection Plans (CWPPs).
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. Idaho Power documents each
Public Safety Partner’s communication preferences in an internal outreach database for use
during events.
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Idaho Power conducted over 30 WMP and PSPS plan presentations in 2023. At each one,
stakeholders were asked to provide feedback to inform future versions of the WMP.
Notable presentations and/or meetings included:
• Local emergency management planning committee meetings and 1:1 meetings with
emergency managers across the service area

• Public meetings in communities with PSPS zones and in all Oregon counties

• Meeting with State of Idaho Emergency director

• Baker County Oregon Emergency Preparedness Fair

• Garden Valley Idaho Wildfire Preparedness Event

• Southern Idaho Landscape Wildfire Working Group

• Ada County Firewise

• Boise, Vale, Unity, Union County and McCall fire departments or fire protection districts

• Idaho Department of Lands and Oregon Department of Forestry, including Idaho and
Oregon Fire Marshalls

• U.S. Forest Service Leadership teams with the Sawtooth, Boise, Payette,
and Salmon-Challis National Forest

• BLM Idaho Falls and Vale District offices

• The Empower program was identified as a tool to help notify customers on durable
medical equipment if a PSPS event is predicted. Idaho Power continues to work 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.
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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
Community Resource Center (CRC) locations to be used, as needed, in a PSPS event.
The company first formulated strategies for Oregon counties in 2022 and updated these
strategies in 2023. Idaho Power is in the process of exploring and establishing county strategies
for Idaho. 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

• 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.
2023 Public Safety Partner Feedback Summary

High-level feedback received as part of Idaho Power’s 2023 outreach effort to partners is summarized below:
• The most beneficial time to engage Public Safety Partner (PSP) and communities about the WMP is before
or during wildfire season. Post fire season briefings were less effective.

• Partnering with agencies and engaging in programs such as Firewise is highly desired. These engagements
are a valuable tool for bringing about additional awareness of Idaho Power’s mitigation efforts and open
opportunities for collaboration between Idaho Power, agencies, and public safety partners.

• Understanding of PSPS varied across Idaho Power’s service area. Future communications and outreach
efforts will require a more extensive, holistic, and broad-reaching approach to education and awareness
about the circumstances that would warrant a PSPS event.
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10.3. Customer Communications
Safety is one of Idaho Power’s core values, and it guides our 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)
additional outreach to customers in zones where PSPS events are more likely. 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 in 2023 was more targeted and frequent, including urging
these customers to update or confirm accurate contact information and know what to do to
prepare for outages.
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 23).

• Videos on topics like vegetation management and PSPS (Figure 24).

• 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 (Figure 25).

o The company notified all customers in PSPS zones by text message, phone call and
postcard (Figure 26) with additional information about PSPS and how to prepare.
When text messages or phone calls failed, the company sent follow-up letters or
postcards urging customers to update their contact information. In some cases,
employees visited customers’ service addresses.

• 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
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(Figure 27). 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
wildfire risk zones, 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

• Postcards and flyers (Figure 28)

• Paid advertising (radio, digital, and print advertisements)

• Idaho Power’s website (wildfire safety information, such as videos, safety tips, and the
latest version of the WMP) can be found at idahopower.com/outages-safety/wildfire-
safety/. As shown in Figure 29 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 Tier 3 and Tier 2 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
• 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 30).
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Figure 23
May 2023 edition of Connections

Figure 24
Idaho Power developed an educational video on how we protect wooden poles from wildfire
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Figure 25
Customer email from May 2023

Figure 26
Postcard to customer living in a PSPS zone

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Figure 27
Example social media posts

Figure 28
Postcard to customer living in an area where grid inspections were taking place

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Figure 29
Idaho Power’s wildfire safety landing webpage

Figure 30
Wildfire mitigation meeting PowerPoint cover slide

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10.3.2. Timing of Outreach
The timing of the outreach generally occurs before and during wildfire season. In 2023,
preseason wildfire outreach had to wait until flooding receded in certain area of our service
area. Holding social media posts, ads, and other communications until wildfire is more
prominently on people’s minds helps increase the likelihood people will hear and retain the
messages. 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 to update their contact information, prepare for the risk of wildfire, and help
prevent wildfires while engaging in recreational activities.
10.3.3. Communication Metrics
Idaho Power uses metrics and monitoring of certain communication activities to evaluate the
effectiveness of our outreach efforts and make adjustments as needed.
Table 16 summarizes key metrics from Idaho Power’s 2023 communication campaign.
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Table 16
Key communication metrics
Metric Definition Success
Criteria Reason for Metric Results/Discussion Considerations for Future
Digital Display Ads—Outage Preparation and Wildfire Prevention (May 26–Aug. 15)
Click Through Rate Number of people who clicked/total
number who were
served the ad, expressed as a percentage.
Industry average Identifies how well customers are engaging
with messaging
These ads on regional website resulted in a total of 10,615 clicks in Idaho and Oregon to our wildfire landing webpage and a click
through rate of 0.16%, surpassing the click-through rate
benchmark of 0.05%. Idaho Power was well ahead of the industry average for click through rate.
Expand target audience demographics to reach more
people outside the Boise area.
Impressions The number of times an ad has been served.
Growth in impressions Helps gauge total reach These ads on regional website resulted in almost 6.6 million impressions.
Radio—Wildfire Prevention (May 26–Aug. 15)
Number of Spots Total number of spots ran, including add-on PSAs
Count increasing/leveraging additional
free spots as
PSAs
Identifies number of customers exposed to messaging
Idaho Power’s wildfire-safety radio ad campaign ran 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 3,763 paid and public safety announcement
(PSA) match spots, 748 of which were in Spanish and played on Spanish language stations.
Consider focusing additional spots during June and July. A wet, cool August meant we didn’t have the
right timing for this message in
late summer.
Streaming Audio—Wildfire Prevention (May 26–Aug. 15)
Impressions The number of
times an ad has been served.
Growth in
impressions
Helps gauge total reach English and Spanish ads ran on services such as Pandora, Amazon
Podcast Marketplace, and iHeartMedia. The campaign resulted in 358,561 impressions, reaching nearly 140,000 households.
Consider focusing efforts on
weekdays when click through rates were highest.
Listen Through Rate The percentage of ad plays that were listened to in their entirety
Industry average Identifies how well customers are engaging with messaging
English and Spanish ads ran on services such as Pandora, Amazon Podcast Marketplace, and iHeartMedia. Listen-through rate of 97.5% was above the industry average by 3.5%.
Customer Email—Wildfire Season Preparedness (May 2023)
Number Sent Total number of emails sent Customer feedback/count increasing as we
have more email
addresses
Identifies number of customers receiving the message on widely
preferred channel
Delivered to 312,119 customers.

Other outage preparedness messaging was included in additional emails, but consider
another targeted push on wildfire
prevention later in the summer given the success of this approach. Open Rate Percentage of
recipients who open the email
Industry average Identifies how well
customers are engaging with messaging
Open rate of over 55%—well above industry average.
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Idaho Power will continue looking at what metrics can help provide actionable feedback to
guide modifications to future communications.
10.3.4. Customer Feedback
In October 2023, Idaho Power sent out a customer survey to its Empowered Community
seeking feedback on general attitudes about utilities and wildfire, including perceptions of risk
and support for mitigation measures. In addition to providing a baseline to measure against as
wildfire communication continues, it will help inform outreach efforts in 2024. The following
are some high-level takeaways from the survey:
• 71% would support the use of PSPS in extreme weather conditions to reduce the risk
of wildfire.

• Knowing Idaho Power has a PSPS program somewhat positively or positively impacts the
perception of 60% of survey respondents.

• 74% said they would be interested in learning more about measures Idaho Power takes
to protect the grid and prevent wildfire.
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2023 WMP Communication Summary

Idaho Power used traditional and social media in 2023 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
The Idaho Power website continued to provide information related to wildfire safety in 2023:
• 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
• 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
to public meetings
• Implemented a customer survey to learn more about customer perception, support and
knowledge of fire-mitigation efforts, including PSPS.

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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

• 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 originally established in 2020 by an external consultant. As noted in
Section 3, Idaho Power reconducted risk modeling in 2023 and included updated information
on population, vegetation, and climatic conditions. 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 Tier 2 and Tier 4 zones during a red FPI. Specific requirements are
found in Idaho Power’s Regional WMP Operational Plans and Field Wildfire Risk Procedures
documents which are 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 17
T&D programs metrics
Transmission
Aerial Visual Inspection Program Perform annual patrols and document identified
defects according to priority. Complete repairs
according to priority definition.
defects according to priority. Complete repairs
according to priority definition.
Program defects according to priority. Complete repairs
according to priority definition.
defects according to priority. Complete repairs
according to priority definition.
select 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 repairs and
adjustments.
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Distribution
Distribution Asset Management Programs Description
defects according to priority. Complete repairs
according to priority definition.
mitigate defects
defects according to priority. Complete repairs
according to priority definition.

Distribution Infrastructure Hardening Program
using thermal imaging (infra-red) cameras.
Complete annual work plan
spans as required
poles
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 guy
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Department)
Vegetation Management
Transmission Description
than June 15 of each year and mitigate noted "hot
spots"
areas & 6-year cycle for mountain areas

Distribution Description
than June 15 of each year in Tier 3 and Tier 2 Zones and mitigate noted "hot spots"
and Tier 2 zones
11.9. Long-term Metrics
Idaho Power measures the performance of the WMP and its effectiveness over time by tracking
outage counts in wildfire risk zones during wildfire season and the progress made towards
completing mitigation programs and activities. Vegetation management and grid hardening
work is expected to reduce outages and improve reliability in wildfire risk zones. The company’s
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 are
tracked annually for each wildfire risk zone:
•Tree/Vegetation Contact
•Equipment Failure
•Loose Hardware
•Corrosion
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• Animal Contact
The use of outage data to gauge overall WMP performance is expected to be a long-term
metric and take several years to develop trendlines and averages to draw definitive conclusions
and a causal relationship to wildfire mitigation activities. Table 18 below summarizes outage
counts in wildfire risk zones during the 2023 wildfire season (May 10 through October 20) and
provides the percent changes compared to a baseline that includes the average annual wildfire
season outage counts for the 2019 through 2021 wildfire seasons.
Table 18
Outage metrics
Wildfire Risk Zone Outage Metrics–Leading Drivers of Ignition by Cause Code
Cause Code 2023 Outage Count % Change Compared to Baseline
Tree/Vegetation 39 -27%
Equipment Failure 46 30%
Small Animal or Bird 40 -4%
Corrosion 11 22%
Foreign Object Contact 2 0%
Loose Hardware 3 80%

The following summarizes the assessment made regarding outage metrics and WMP
performance:
• The total number of outage counts during the 2023 wildfire season was 2% less than
the baseline.

• The 2023 wildfire season saw an increased number of storm events, high winds,
and more lightning caused outages throughout the service area than in previous years.
This attributed to an increase of outages associated with equipment failure, both
mechanical and electrical caused. In 2024, the company will explore the use of weather
climatology to quantify the annual change in severe weather conditions that attribute
to outages.

• The number of lightning caused outages was nearly double the baseline. In 2024,
the company plans to conduct analysis of the lightning caused outages in wildfire risk
zones to determine the need for more surge arresters in higher lightning prone areas.

• While outage counts increased due to storm activity, outages caused by vegetation
contact fell by 27%, indicating that the enhanced vegetation management practices are
reducing vegetation risk even under higher-than-normal storm activity.
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•Four overhead service transformers failed in 2023 which is consistent with baseline
levels. The failure rate of transformers is less than 0.04% in wildfire risk zones. While the
failure rate is considered low, the company will take proactive steps in 2024 to
determine a method to proactively assess transformer loading based on metered data.
In 2023, Idaho Power began analyzing and evaluating the effectiveness of overhead circuit
“hardening” practices by calculating reliability performance indices and outage rates per
100 line-miles for hardened feeders before and after the hardening work was complete.
The reliability performance indices assessed include the System Average Interruption
Frequency Index (SAIFI), System Average Interruption Duration Index (SAIDI), and the outage
rate for circuits that have had WMP hardening.
Hardened circuits or “feeders” were compared to baseline feeders which are defined as all
other distribution feeders that do not have completed WMP Hardening projects. This analysis is
most informative with several years of actual before and after data to calculate valid
comparisons and identify system hardening benefits. There is little history to work with since
initial WMP hardening projects were completed in late 2021, but initial analysis indicates
improvement by hardening as shown in the table below. Idaho Power will re-evaluate and
calculate specific results over the coming years as more “post-hardening” time has passed.
Table 19
Overhead circuit hardening reliability improvements
Overhead Circuit Hardening Reliability Improvements
SAIFI % improvement with WMP hardening 15%
SAIDI % improvement with WMP hardening 27%
Outage rate % improvement with WMP hardening 13%
Idaho Power Company Oregon Wildfire Requirements and Recommendations
Appendices
Appendix A
The Wildland Fire Preparedness and Prevention Plan.
Wildland Fire Preparedness
and Prevention Plan
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The Wildland Fire Preparedness and Prevention Plan Idaho Power Company
Page i
Table of Contents
Table of Contents .............................................................................................................................. i
1. Plan Overview ............................................................................................................................. 1
A. Intent of Plan ........................................................................................................................ 1
B. Scope of Plan ......................................................................................................................... 1
2. Situational Overview and Applicability ....................................................................................... 1
A. Wildfire Season ..................................................................................................................... 1
B. Wildfire Risk Zones ............................................................................................................... 2
C. Fire Potential Index ............................................................................................................... 2
D. Decision Making for Field Work Activities ............................................................................ 2
3. Preparedness—Tools and Equipment ........................................................................................ 5
A. Required Personal Protective Equipment ............................................................................ 5
B. Required Tools and Equipment ............................................................................................ 5
C. Land Management Agency Restrictions and Waivers .......................................................... 6
4. Prevention—Practices of Field Personnel .................................................................................. 7
A. General Employee Practices ................................................................................................. 7
B. Behaviors Relating to Vehicles and Combustion Engine Power Tools ................................. 8
5. Reporting ................................................................................................................................... 10
A. Fire Ignition ......................................................................................................................... 10
B. Fire Reporting ..................................................................................................................... 10
6. Training ..................................................................................................................................... 10
7. Roles and Responsibilities ......................................................................................................... 11
8. Audit .......................................................................................................................................... 11

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The Wildland Fire Preparedness and Prevention Plan Idaho Power Company
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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) associated with employee work activities in locations and
under conditions where is a heightened risk of wildfire. It is expected that all applicable Idaho
Power 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 there is a heightened risk of wildfire.

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. 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.

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.
Idaho Power Company The Wildland Fire Preparedness and Prevention Plan
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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 through GIS applications. All lands in the vicinity of Idaho Power
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.
C.Fire Potential Index
Idaho Power’s Atmospheric Sciences 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:
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Planned or Scheduled Work Activities:
1.Fire Potential Indices:
a)Employees working in the field—NOT 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, 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. Evaluate need for
utilizing Prevention—Practices of Field Personnel (see section 4 of
this Plan)
2.Yellow FPI in All Zones: Proceed with the work. Evaluate need for
utilizing Prevention—Practices of Field Personnel (see section 4 of
this plan)
3.Red FPI
a)In Normal Zone: Proceed with the work. Consider and
evaluate need for utilizing Prevention—Practices of Field
Personnel (see Section 6 of this plan)
b)In Tier 2 Zone: Proceed with the work. However, 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
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c)In Tier 3 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).
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
The Wildland Fire Preparedness and Prevention Plan Idaho Power Company
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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
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
Idaho Power Company The Wildland Fire Preparedness and Prevention Plan
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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
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:
•Bureau of Land Management (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
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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 bmidc.org/index.shtml
o Nevada—Fire Information at nevadafireinfo.org/restrictions-and-closures
o Montana—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.
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
Idaho Power Company The Wildland Fire Preparedness and Prevention Plan
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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
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
The Wildland Fire Preparedness and Prevention Plan Idaho Power Company
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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.
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:
Idaho Power Company The Wildland Fire Preparedness and Prevention Plan
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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 wacker
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
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 wildfire risk 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.
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7.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 WRZ.
Front-Line Leaders 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 WRZ is Yellow.
c)Ensure no work takes place when FPI is “Red” and the WRZ 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)
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.
Department 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 in place to ensure adherence to the Plan.
Engineering and Construction 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
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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).
- A supply of water, sufficient for initial attack, with an effective spraying mechanism
(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.

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
Oregon Wildfire Requirements and Recommendations Idaho Power Company
Appendices
Appendix B
The Public Safety Power Shutoff (PSPS) Plan.
Idaho Power Company’s
Wildfire Public Safety
Power Shutoff Plan
December 2023
© 2023 Idaho Power
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Idaho Power Company Wildfire Public Safety Power Shutoff Plan
Page i
Table of Contents
Table of Contents .............................................................................................................................. i
List of Figures .................................................................................................................................. iii
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 ........................................................................................... 7
8.4. Publicly Available Weather Models ................................................................................. 7
8.5. Idaho Power Weather Model .......................................................................................... 8
8.6. Storm Prediction Center Fire Weather Outlooks ............................................................. 8
8.7. Current Weather Observations ........................................................................................ 8
8.8. National Significant Wildland Fire Potential Forecast Outlook ....................................... 8
8.9. GBCC Morning Briefing .................................................................................................... 8
8.10. GBCC Current and Predicted ERC and F100 ..................................................................... 9
8.11. Fire Agency Input ............................................................................................................. 9
8.12. De-Energization Windspeed Considerations ................................................................... 9
8.13. Alternative Protective Measures ..................................................................................... 9
8.14. Real-time Field Observations ........................................................................................... 9
8.15. Other .............................................................................................................................. 10
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Page ii
9. Responsibilities ......................................................................................................................... 10
9.1. Load Serving Operations ................................................................................................ 10
9.2. Atmospheric Science ...................................................................................................... 10
9.3. Transmission and Distribution Engineering and Reliability ........................................... 11
9.4. Customer Operations Support and Regional Operations .............................................. 12
9.5. Substation Operations ................................................................................................... 12
9.6. Corporate Communications ........................................................................................... 13
9.7. Safety.............................................................................................................................. 13
9.8. Customer Service ........................................................................................................... 14
10. PSPS Operations ...................................................................................................................... 14
10.1. Preparedness ................................................................................................................. 14
10.1.1. Community Preparedness..................................................................................... 15
10.1.2. Training and Exercises ........................................................................................... 15
10.2. Wildfire Season Operations ........................................................................................... 15
10.2.1. Situational Awareness Activities ........................................................................... 16
10.2.2. Key Grid Interdependent Utilities and Agencies .................................................. 16
10.3. Proactive Communications ............................................................................................ 16
10.3.1. Notifications and Emergency Alerts ..................................................................... 16
10.4. PSPS Phases .................................................................................................................... 17
10.4.1. Phase 1 & PSPS Assessment Team Activation ...................................................... 17
10.4.1.1. Phase 1 Notifications ................................................................................... 18
10.4.2. Phase 2 .................................................................................................................. 18
10.4.2.1. Regional Event Operations and Coordination ............................................. 19
10.4.2.2. Conduct Operational Risk Analysis .............................................................. 19
10.4.2.3. Request to Delay a PSPS Event .................................................................... 19
10.4.2.4. Field Observations and Response Teams .................................................... 19
10.4.2.5. Customer and Community Notifications ..................................................... 20
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10.4.3. Phase 3 .................................................................................................................. 20
10.4.3.1. Customer and Community Notification ....................................................... 20
10.4.4. Phase 4 .................................................................................................................. 20
10.4.4.1. System Inspections....................................................................................... 20
10.4.4.2. Repair and Recovery .................................................................................... 21
10.4.4.3. Incident Management Support .................................................................... 21
10.4.4.4. Communicate PSPS Event Conclusion ......................................................... 21
10.4.4.5. Re-energization ............................................................................................ 21
10.4.5. Post-incident Review ............................................................................................ 21
11. Financial Administration ......................................................................................................... 22
12. Reporting................................................................................................................................. 22
13. After-Action Report ................................................................................................................. 22
14. Training ................................................................................................................................... 22
15. Exercises .................................................................................................................................. 23
List of Figures
Figure 1
PSPS preparedness cycle ............................................................................................................ 14
Figure 2
Optimal PSPS event communication timeline ........................................................................... 17
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Idaho Power Company Wildfire Public Safety Power Shutoff Plan
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1. Introduction
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 developed and implemented a Wildfire Mitigation Plan (WMP) in 2021.
The fundamental goals of Idaho Power’s WMP are to reduce wildfire risk associated with
the company’s transmission and distribution (T&D) facilities and associated field operations
as well as to improve the resiliency of Idaho Power’s T&D system in a wildfire event,
independent of the ignition source. The WMP is reviewed and updated annually.
As part of its operational mitigation practices, Idaho Power developed a Public Safety
Power Shutoff Plan (PSPS Plan or Plan) to proactively de-energize electrical facilities
if necessary to reduce wildfire risk. This Plan identifies the relevant considerations,
process flow, and implementation protocol before, during, and after a PSPS event. The Plan
is active during wildfire season and reviewed and updated as needed on an annual basis.
Wildfire Public Safety Power Shutoff Plan Idaho Power Company
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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
SME—Subject Matter Expert
T&D—Transmission & Distribution
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TDER—Transmission & Distribution Engineering and Reliability
UKMET—United Kingdom Meteorological Office
VMP—Vegetation Management Program
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 other agencies as applicable.
(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 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 frequency
and intensity of wildland fires (wildfires). A variety of factors contribute 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 a Public Safety Power
Shutoff Plan (PSPS Plan or Plan) to proactively de-energize electric transmission and/or
distribution facilities during extreme weather events to reduce the risk of wildfire. 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 can create challenges with
forecasting when a PSPS event should be implemented. Real-time evaluations and
decision-making are therefore important in making PSPS determinations and, depending on the
associated wildfire conditions, those determinations may result in proactive de-energization in
areas not originally anticipated to be included in a PSPS event.
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 as necessary on an annual basis. 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 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
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•Collaborating with key external stakeholders (agencies, counties, local governments,
public safety partners, and first responders)
•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 elevated wildfire risk within its service area using a
process explained in the company’s Wildfire Mitigation Plan. Idaho Power’s risk tiers reflect risk
relative to Idaho Power’s service area only and not absolute risk. Idaho Power color-codes the
tiers—Yellow Risk Zones (YRZ) for Tier 2 and Red Risk Zones (RRZ) for Tier 3.
In its WMP, Idaho Power identifies operational practices specific to these zones for purposes of
reducing wildfire risk associated with the company’s transmission and distribution (T&D)
facilities and associated field operations and improving the resiliency of Idaho Power’s T&D
system in a wildfire event, independent of the ignition source. 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
exist that indicate a potential wildfire risk associated with Idaho Power’s T&D facilities under
those known conditions. 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 sections 8.1 through
8.15. The subsections below list the varying data sources Idaho Power may consider before
initiating a PSPS.
8.1. Fire Potential Index
In addition to the risk tier designations in its WMP, Idaho Power developed a Fire Potential
Index (FPI) to forecast wildfire potential across Idaho Power’s service area as described in
Section 5.2 of the WMP. This tool is designed to support operational decision-making during
fire season. The FPI 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
foresight into potential upcoming changes in the FPI which may trigger operational mitigation
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efforts, including stopping planned work and changing distribution protection operations in
certain locations.
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 16, each of which expresses the degree of fire threat expected for
each 6-hour time period 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 lower 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.
FPI information is provided internally 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 when the FPI score is
red, including stopping planned work and changing distribution protection operations in certain
locations. A Red FPI score is 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:
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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
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.
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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 and observing real-time weather conditions and associated risks requires predicting
conditions that could make a PSPS event necessary. Resources available for observing current
weather conditions include direct, real-time data from Idaho Power’s network of weather
stations as well as Remote Automatic Weather Stations, Windy: Wind Map and Weather
Forecast, and the National Weather Service National Oceanic and Atmospheric Administration’s
(NOAA) Weather and Hazards Viewer.
Additionally, Idaho Power’s PSPS program includes employees acting as field observers to
report on site conditions, detailed in section 8.14. Field observers are equipped with mobile
weather kits that include wind meters, compasses, and communication devices to report
real-time conditions.
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. GBCC 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,
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which encompasses Utah, Nevada, Idaho south of the Salmon River, the western Wyoming
mountains, and the Arizona Strip. The GBCC hosts a morning briefing during fire season 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. Fire Agency Input
Idaho Power works with Boise NWS Fire Forecasters through daily briefings and National
Interagency Fire Center (NIFC) Predictive Service Forecasters on an as-needed basis,
generally regarding data clarification, to streamline the transfer of data, information,
and communications about wildland fires that may impact 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.
8.13. Alternative Protective Measures
Considering the significant potential impact of a PSPS to customers, prior to implementing a
PSPS Idaho Power thoroughly evaluates other potential alternative protective measures for
operating its T&D system during fire season.
8.14. Real-time Field Observations
Idaho Power may deploy trained field observers to certain potential PSPS locations prior
to de-energization to evaluate and report on weather and circuit conditions on-site.
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Field observers are equipped with mobile weather kits that include wind meters,
compasses, and communication devices to report real-time conditions. Information is
communicated to the PSPS Assessment Team for consideration during a PSPS event.
8.15. Other
As further described in the WMP, Idaho Power continues to evaluate expansion of its weather
forecasting tools, and enhance the company’s capability to detect and respond to fires with
wildfire detection camera systems.
9. Responsibilities
Implementation of the PSPS Plan 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. Roles and
responsibilities are reviewed annually and updated as necessary.
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 during a PSPS event
•Assist with PSPS evaluation and decision-making
•Safely restore service to PSPS areas when notified by the acting incident commander
•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
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•Communicate with external agencies for increased situational and conditional awareness.
Increase communications as conditions or circumstances require
•Communicate internally to Idaho Power’s Transmission & Distribution Engineering and
Reliability (TDER) department when conditions or circumstances indicate a PSPS may
be necessary
•Support PSPS activities such as planning, training, and exercises prior to and during
fire season
•Assist in PSPS information-gathering, evaluation, and decision-making during a PSPS event
•Participate in AARs and ensure modifications to PSPS protocol are implemented
as necessary
9.3. Transmission and Distribution Engineering and Reliability
•Oversee wildfire mitigation program and support cross-departmental collaboration
•Develop and implement safe and reliable power shutoff protocols and procedures
•Act as incident command (IC) for PSPS events
•Activate PSPS Assessment Team as needed
•Ensure PSPS activities such as operations planning, training, and exercises occur annually
•Coordinate with Atmospheric Science to continue evaluating enhancements to situational
awareness capabilities
•Support Dispatch and Customer Operations in developing de-energization and
re-energization plans for PSPS events
•Support rapid repairs of damaged infrastructure as needed
•Support Load Serving Operations in planning improvements to PSPS operational capabilities
•Following de-energization, and when it is safe to do so, coordinate with the
Vegetation Management Program (VMP) to begin removal of vegetation debris necessary
for re-energization
•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
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9.4. Customer Operations Support and Regional Operations
•Ensure field personnel are appropriately trained to perform all relevant responsibilities
under this PSPS Plan
•Develop and lead training modules for PSPS implementation (Customer Operations only)
•Communicate with Oregon and Idaho ESF-12
•Assist with incident command (Customer Operations only)
•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 following a PSPS event
•Participate, with assistance from Corporate Communications, in Idaho Power’s general
external education campaign
•Ensure a coordinated and cohesive external and internal communication and notification
plan is in place and reviewed annually
•During PSPS phases, collect and maintain Regional Dispatch Operations logs and other
incident information for reporting purposes.
•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
•Coordinate with emergency managers to deploy community resource centers as necessary
Lead AARs and ensure modifications to PSPS protocol are implemented as necessary
9.5. Substation Operations
•Monitor substations and perform actions to support PSPS operations as required
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•Coordinate activities with Dispatch and Customer Operations
•Participate in AARs and ensure modifications to PSPS protocol are implemented,
as necessary
9.6. Corporate Communications
Corporate Communications develops and executes PSPS communications to Idaho Power
customers and employees and supports other business units in their communication efforts
with regulators, critical facility operators, public safety partners, and other stakeholders.
Corporate Communications will:
•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.
9.7. Safety
•Ensure safety professionals are appropriately trained to perform all relevant responsibilities
as needed under the PSPS Plan.
•Provide training on the PSPS Plan requirements for field personnel.
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•Participate in AARs and modify communication practices as necessary.
9.8. Customer Service
•Respond to customer calls and questions about a PSPS event with information provided by
Corporate Communications or the IC
•Ensure customer service representatives are trained to manage customer interactions
during a PSPS event
10. PSPS Operations
10.1. Preparedness
PSPS preparedness is a continuous effort involving Idaho Power, public safety partners,
state and local governments, communities, and customers. The Transmission and Distribution
Engineering and Reliability department coordinates and facilitates activities of 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
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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. Idaho Power uses
metrics and monitoring of certain communication activities to evaluate the effectiveness of
outreach efforts and adjusts as needed based on feedback from customers and public
safety partners.
10.1.1. Community Preparedness
Idaho Power communicates with customers and public safety partners before and throughout
wildfire season through a variety of platforms to inform them of steps the company is taking to
reduce wildfire risk and ways they can help prevent wildfires and prepare for outages.
Communication themes include the following:
• What is a PSPS?: Explanation of PSPS events, including a map customers can use to
determine if their homes or businesses are located in either a red or yellow risk zone.
• Be Prepared for Wildfire Season and PSPS events: Preparation tips like building an
outage kit and planning for feeding livestock, etc.
• Protecting the Grid: Measure’s that Idaho Power is taking to enhance grid resiliency and
reduce wildfire risk.
• How You Can Reduce Wildfire Risk: Tips for preventing wildfires when camping,
using fireworks, hauling trailers, etc.
• PSPS Event Information: Real-time information on active PSPS events, estimated shutoff
time, outage duration, and customers impacted.
10.1.2. Training and Exercises
Idaho Power coordinates and participates in tabletop exercises with public safety partners to
enhance knowledge of each other’s emergency operations and ensure smooth interactions
during PSPS events.
10.2. 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 forecasting and reducing wildfire risk.
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10.2.1. 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, the NWS, and a regional
wildfire outlook.
During wildfire season, the Atmospheric Science team will determine a daily FPI as described in
Section 5.2 of the WMP describing shorter-term weather and fire conditions specific to wildfire
risk zones across Idaho Power’s service territory.
10.2.2. 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.
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. Figure 2 provides Idaho Power’s optimal communication timeline for PSPS events,
including notifications to public safety partners, circumstances permitting.
10.3.1. Notifications and Emergency Alerts
Consistent with Oregon Division 300 Administrative Rules and Emergency Support Function-12,
Idaho Power coordinates 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.
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Figure 2
Optimal PSPS event communication timeline
10.4. PSPS Phases
10.4.1. Phase 1 & PSPS Assessment Team Activation
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
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Considerations. Multiple events may require simultaneous management of other
storm-related outages or other PSPS events.
Idaho Power will transition from normal wildfire season operations to Phase 1 of a PSPS event
at the direction of the TDER senior manager or designee. During Phase 1, Idaho Power will
activate the PSPS Assessment Team, which includes representation from a minimum of the
departments identified in Section 9. The TDER senior manager or designee will establish an
incident commander for the event to lead the PSPS Assessment Team during the phases of the
PSPS event. The PSPS Assessment Team will hold in person meetings and/or conference calls
(collectively referred to as meetings) as needed to discuss current and forecasted weather
conditions and other information regarding a potential PSPS event. The IC will facilitate PSPS
Assessment Team meetings and the PSPS Assessment Team will be responsible for
recommending maintaining Phase 1, escalating to Phase 2, or de-escalating to normal
operations. The PSPS Assessment Team will also recommend issuance of preliminary
notifications of a potential PSPS event to customers, public safety partners, critical facilities
operators, and ESF-12 leads consistent with Oregon Division 300 Administrative Rules and
Emergency Support Function-12.
During Phase 1, the PSPS Assessment Team will review the PSPS Plan and supporting
documents. An operational risk assessment will be performed to develop a recommendation
for PSPS escalation. Ultimate determination will be made whether to escalate to Phase 2 is
made by the IC. Within one hour of Phase 2 notification, the full PSPS Assessment Team will be
placed on stand-by and team member availability will be determined. In addition, the VP of
Planning, Engineering, and Construction (PEC), the Customer Operations VP, and Chief
Operations Officer or their designees will be placed on stand-by for decision making purposes.
10.4.1.1. Phase 1 Notifications
Depending on the timing and specific circumstances of the PSPS event, 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 determined by the PSPS Assessment Team in
coordination with Corporate Communications.
10.4.2. Phase 2
Phase 2 actions are determined by additional situational awareness activities and timing of
forecasted weather events. Upon transitioning to Phase 2, Idaho Power will provide external
notifications as detailed in Figure 2, as determined by the PSPS Assessment Team in
coordination with Corporate Communications.
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10.4.2.1. Regional Event Operations and Coordination
In collaboration with the PSPS Assessment Team, Idaho Power regional leadership will establish
a regional event coordinator. The event coordinator’s main role is to coordinate activities
across the region associated with the PSPS event and restoration of electric service, as needed,
following a PSPS event.
Regional Operations personnel have 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.
10.4.2.2. 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 or their designees who will then evaluate the
PSPS Assessment Team’s recommendation for final determination; provided, however, that all
three positions may not be available during an event. In which case, any one of the three
positions (i.e., the VP of PEC, VP of Customer Operations, or COO) have the authority to make a
final determination of whether to proceed to Phase 3 implementation of a PSPS event based on
the PSPS Assessment Team recommendation.
10.4.2.3. Request to Delay a PSPS Event
There may be requests to delay proactive de-energization from the public safety partners or
ESF-12. This may occur for several reasons, with the most anticipated being an impact to a
customer or fire response agency’s ability to pump water for fire suppression during the
outage. Delay requests should be routed through dispatch and sent to the PSPS Assessment
Team for evaluation. The PSPS Assessment Team will provide the VP of PEC, VP of Customer
Operations, and the COO (or designee) a recommendation on whether to approve the proactive
de-energization delay. The decision will be made by the VP of PEC, VP of Customer Operations,
and/or the COO (or designee). 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.
10.4.2.4. Field Observations and Response Teams
TDER and 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.
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10.4.2.5. Customer and Community Notifications
Depending upon the timing and specific circumstances of the PSPS event, 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 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.
10.4.3. Phase 3
Upon determination to proactively de-energize, the Load Serving Operations (LSO)
representative of the PSPS Assessment 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.
Regional teams will follow internal processes and procedures to safely and effectively
implement a PSPS event.
10.4.3.1. Customer and Community Notification
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.
10.4.4. Phase 4
10.4.4.1. 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 prior to re-energization. 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.
Idaho Power Company Wildfire Public Safety Power Shutoff Plan
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10.4.4.2. 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.
10.4.4.3. Incident Management Support
The PSPS Assessment Team will continue to monitor fire and weather conditions throughout
the event. Logistics and mutual assistance requirements will be determined and acted upon per
existing internal plans and processes. If re-energization will be delayed longer than anticipated
due to the magnitude of the event, the Emergency Management Team (EMT) will be utilized for
additional support.
10.4.4.4. 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. The outage map on Idaho
Power’s website will be updated during the event. Idaho Power will also leverage existing public
agency outreach and notification systems as done at other points in the PSPS process.
10.4.4.5. Re-energization
Once re-energization activities are completed and service is restored, crews and support staff
will demobilize and return to normal wildfire season operations as described in the Wildfire
Mitigation Plan.
10.4.5. Post-incident Review
During PSPS phases, the Customer Operations lead will collect and maintain Regional Dispatch
Operations logs and other incident information required for reporting purposes.
Following conclusion of a PSPS event, the Customer Operations lead or their designee will
conduct informal, high-level debriefs to identify potential modifications to PSPS protocol based
on lessons learned during the event. The assigned representative will consolidate the feedback
and file as part of the incident documentation.
Also following the PSPS event, IC will conduct an AAR with the PSPS Assessment Team to
identify potential modifications to PSPS protocol based on lessons learned during the event.
The IC will consolidate the feedback and provide to the Customer Operations lead.
Wildfire Public Safety Power Shutoff Plan Idaho Power Company
Page 22
After wildfire season, the Customer Operations lead 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.
11. Financial Administration
Idaho Power will track expenses related to PSPS events for OPUC and IPUC reporting and
potential recovery of expenses through regulatory processes. Expenses will 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 Idaho Power’s general counsel or designee to improve
the PSPS processes and procedures.
14. Training
Idaho Power will 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.
Idaho Power Company Wildfire Public Safety Power Shutoff Plan
Page 23
15. Exercises
Idaho Power will exercise this PSPS Plan on an annual basis prior to wildfire season 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
Idaho Power Company Oregon Wildfire Requirements and Recommendations
Appendices
Appendix C
Wildfire risk zone map book.
Wildfire
.
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Idaho Power Wildfire Risk Zone Map Book
Page i
List of Figures
Figure 1
Idaho Power wildfire risk areas—detail key map ........................................................................ 1
Figure 2
Canyon Region—Tier 2 zones ...................................................................................................... 2
Figure 3
Capital Region–Boise south ......................................................................................................... 3
Figure 4
Capital Region–Boise Front .......................................................................................................... 4
Figure 5
Capital Region–Centerville ........................................................................................................... 5
Figure 6
Capital Region–Mountain Home area ......................................................................................... 6
Figure 7
Capital Region–Idaho City ............................................................................................................ 7
Figure 8
Eastern Region—American Falls .................................................................................................. 8
Figure 9
Eastern Region–Pocatello south .................................................................................................. 9
Figure 10
Eastern Region–Pocatello area .................................................................................................. 10
Figure 11
Eastern Region–Salmon area ..................................................................................................... 11
Figure 12
Out of territory—Austin Junction, Oregon ................................................................................ 12
Figure 13
Out of territory—Tollgate, Oregon ............................................................................................ 13
Figure 14
Out of territory—Clark County .................................................................................................. 14
Figure 15
Out of territory—Elko County, Nevada ...................................................................................... 15
Figure 16
Southern Region—Pine Featherville area .................................................................................. 16
Wildfire Risk Zone Map Book Idaho Power Company
Page ii
Figure 17
Southern Region—Rock Creek, Twin Falls south ....................................................................... 17
Figure 18
Southern Region—Wood River Valley ....................................................................................... 18
Figure 19
Western Region—Ola................................................................................................................. 19
Figure 20
Western Region—Cascade/Donnelly ......................................................................................... 20
Figure 21
Western Region—Council area .................................................................................................. 21
Figure 22
Western Region—Emmett/Horseshoe Bend ............................................................................. 22
Figure 23
Western Region—Garden Valley/Crouch .................................................................................. 23
Figure 24
Western Region—Halfway, Oregon ........................................................................................... 24
Figure 25
Western Region—Jordan Valley, Oregon .................................................................................. 25
Figure 26
Western Region—Juntura, Oregon ............................................................................................ 26
Figure 27
Western Region—Lowman ........................................................................................................ 27
Figure 28
Western Region—McCall/New Medows ................................................................................... 28
Figure 29
Western Region—Riggins south ................................................................................................ 29
Figure 30
Western Region—Smiths Ferry .................................................................................................. 30
Figure 31
Western Region—Unity, Oregon ............................................................................................... 31
Figure 32
Western Region—Yellow Pine ................................................................................................... 32
Figure 33
Western Region—Tier 2 zones ................................................................................................... 33
Idaho Power Wildfire Risk Zone Map Book
Page 1
Figure 1
Idaho Power wildfire risk areas—detail key map
Wildfire Risk Zone Map Book Idaho Power

Page 2

Figure 2
Canyon Region—Tier 2 zones
Idaho Power Wildfire Risk Zone Map Book
Page 3
Figure 3
Capital Region–Boise south
Wildfire Risk Zone Map Book Idaho Power
Page 4
Figure 4
Capital Region–Boise Front
Idaho Power Wildfire Risk Zone Map Book
Page 5
Figure 5
Capital Region–Centerville
Wildfire Risk Zone Map Book Idaho Power
Page 6
Figure 6
Capital Region–Mountain Home area
Idaho Power Wildfire Risk Zone Map Book
Page 7
Figure 7
Capital Region–Idaho City
Wildfire Risk Zone Map Book Idaho Power
Page 8
Figure 8
Eastern Region—American Falls
Idaho Power Wildfire Risk Zone Map Book
Page 9

Figure 9
Eastern Region–Pocatello south
Wildfire Risk Zone Map Book Idaho Power

Page 10

Figure 10
Eastern Region–Pocatello area
Idaho Power Wildfire Risk Zone Map Book
Page 11

Figure 11
Eastern Region–Salmon area
Wildfire Risk Zone Map Book Idaho Power

Page 12

Figure 12
Out of territory—Austin Junction, Oregon
Idaho Power Wildfire Risk Zone Map Book
Page 13

Figure 13
Out of territory—Tollgate, Oregon
Wildfire Risk Zone Map Book Idaho Power

Page 14

Figure 14
Out of territory—Clark County
Idaho Power Wildfire Risk Zone Map Book
Page 15

Figure 15
Out of territory—Elko County, Nevada
Wildfire Risk Zone Map Book Idaho Power

Page 16

Figure 16
Southern Region—Pine Featherville area
Idaho Power Wildfire Risk Zone Map Book
Page 17

Figure 17
Southern Region—Rock Creek, Twin Falls south
Wildfire Risk Zone Map Book Idaho Power

Page 18

Figure 18
Southern Region—Wood River Valley
Idaho Power Wildfire Risk Zone Map Book
Page 19

Figure 19
Western Region—Ola
Wildfire Risk Zone Map Book Idaho Power

Page 20

Figure 20
Western Region—Cascade/Donnelly
Idaho Power Wildfire Risk Zone Map Book
Page 21

Figure 21
Western Region—Council area
Wildfire Risk Zone Map Book Idaho Power
Page 22
Figure 22
Western Region—Emmett/Horseshoe Bend
Idaho Power Wildfire Risk Zone Map Book
Page 23
Figure 23
Western Region—Garden Valley/Crouch
Wildfire Risk Zone Map Book Idaho Power

Page 24

Figure 24
Western Region—Halfway, Oregon
Idaho Power Wildfire Risk Zone Map Book
Page 25

Figure 25
Western Region—Jordan Valley, Oregon
Wildfire Risk Zone Map Book Idaho Power

Page 26

Figure 26
Western Region—Juntura, Oregon
Idaho Power Wildfire Risk Zone Map Book
Page 27

Figure 27
Western Region—Lowman
Wildfire Risk Zone Map Book Idaho Power

Page 28

Figure 28
Western Region—McCall/New Medows
Idaho Power Wildfire Risk Zone Map Book
Page 29

Figure 29
Western Region—Riggins south
Wildfire Risk Zone Map Book Idaho Power

Page 30

Figure 30
Western Region—Smiths Ferry
Idaho Power Wildfire Risk Zone Map Book
Page 31

Figure 31
Western Region—Unity, Oregon
Wildfire Risk Zone Map Book Idaho Power

Page 32

Figure 32
Western Region—Yellow Pine
Idaho Power Wildfire Risk Zone Map Book
Page 33
Figure 33
Western Region—Tier 2 zones
Oregon Wildfire Requirements and Recommendations Idaho Power Company
Appendices
Appendix D
Oregon wildfire requirements and recommendations.

Oregon Requirements
and Recommendations
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Oregon Wildfire Requirements and Recommendations Idaho Power Company
Page 1
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 and Appendix C for
details of wildfire risk zones outside of
service area
(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 3.3: Wildfire Risk Zones
See Section 3.3.2 and Figure 17: 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—
Initiatives; and Section 8.7: 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 10.1: Objective and Section 10.2.1:
Community Engagement
See Appendix B: Idaho Power's Public Safety
Power Shutoff Plan, 10.1: Community
Engagement and Section 10.3:
Proactive Communications
(e) Identified protocol for the de-energization of power lines and adjusting ofpower system operations to mitigate wildfires, promote the safety of the
public and first responders and preserve health and communication
infrastructure.
See Section 7.5: 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
Page 2
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 8.4: Transmission
Asset Management and Inspection Initiatives
(with information on aerial, ground, detailed
visual, pole, and other protection programs)

For Distribution, see Section 8.5: Distribution
Asset Management and Inspection Initiatives
(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 8.7.2: Transmission Vegetation
Management and Section 8.7.3: 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 4.4: Wildfire
Mitigation Cost Summary and Section 4.5:
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 3.3: Wildfire Risk Zones, Appendix C WMP mapbook, 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
See Section 3.2.1 paragraph 4 addresses
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.

not model wildfire progression or spread within
substations due to zero vegetation within the
fenced area
Also see Section 3.3.2 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 3.2.1: Wildfire Risk Modeling
Process and the 2023 Risk Modeling Input
Updates, and Section 11.4 Wildfire Risk Map
(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 3.2.1: Wildfire Risk Modeling Process
and the 2023 Risk Modeling Input Updates, and
Section 11.4 Wildfire Risk Map
(A) The Public Utility must make clear the frequency with which each 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 3.2.1: Wildfire Risk Modeling Process and the 2023 Risk Modeling Input
Updates, and 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 8.7: T&D Vegetation Management C) See Executive Summary on Infrastructure Hardening; Section 8.5: Distribution Asset Management and Inspection Initiatives; Section 11.9: Long-Term Metrics D) Risk analysis informs Tier 2 and Tier 3
mitigation activities. See Section 4: Costs and Benefits of Wildfire Mitigation and Section
4.5 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.
See Section 3.2.2 Establishing Wildfire Risk Zones
and Section 3.3 Wildfire Risk Zones
Idaho Power Company Oregon Wildfire Requirements and Recommendations
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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 Section 3.3.2., specifically incorporating local
feedback into risk zone establishment and
wildfire risk zone calibration with peer utilities

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,
Section 10.3.1: Key Communication Methods,
and Section 10.3.3 Communication Metrics

(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
Page 5
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 No. 23-222
This appendix also addresses recommendations received from the OPUC Staff in Docket
No. UM 2209 and approved by the OPUC in Order No. 23-222. The italicized text below reflects
OPUC Staff’s specific recommendations for the company to include in its 2024 WMP.
Idaho Power Company Oregon Wildfire Requirements and Recommendations
Page 6
OAR 860-300-0020 (1)(a)(A) and (B)
(1) Provide explicit details of assets within and outside the YRZ and RRZ using a common
reporting structure (for multistate utilities).

See Table 11, Section 8.2 T&D Asset Management and Inspections and Table 5, Section 3.3
Wildfire Risk Zones

(2) Provide details for incorporation of climate change modeling in refining the YRZ and RRZs.

See Section 3.2.1 Wildfire Risk Modeling Process, specifically “2023 Risk Modeling
Input Updates”

(3) Provide details on calibration of wildfire risk modeling methods to ensure that when and
where overlaps occur, they are consistent, or explicably inconsistent, in their risk designation.
Such designation and coordination across utilities may lend greater clarity for stakeholders and
Staff to understand relative risks.
See Section 3.2.2 Establishing Wildfire Risk Zones, specifically “Wildfire Risk Zone Calibration
with Peer Utilities”
(4) Detail recommendations from local partners and customers in establishing risk zones,
including the inclusion of remote fire suppression resources in establish [sic] risk levels.
See Section 3.2.2 Establishing Wildfire Risk Zones, specifically Figure 4 and “Incorporating
Local Feedback into Risk Zone Establishment”
(5) Provide historic root cause analysis supporting equipment ignition risk determinations.
See Section 8.6.1 Root Cause Analysis
OAR 860-300-0020 (1)(b)
(6) Provide effectiveness results using specific outage causes within YRZ, RRZ and non-fire risk
areas compared to the mitigation measures undertaken within those specific areas and
calculate mitigation effectiveness

See Section 11.9 Long-Term Metrics, specifically Table 18 Outage metrics and Table 19
Overhead circuit hardening reliability improvements.

(7) Demonstrate the Company's ignition reporting processes.

See Section 8.6 Ignition Tracking and Analysis

Oregon Wildfire Requirements and Recommendations Idaho Power Company
Page 7
(8) Demonstrate the use of effectiveness metrics and ignition reporting investigation in
modifying programmatic changes to specific assets or equipment types

See Section 11.9 Long-Term Metrics and Section 4 Costs and Benefits of Wildfire Mitigation

(9) Detail progress made towards a uniform risk-spend valuation methodology

See Section 4.2, Risk-Based Cost and Benefit Analysis of Wildfire Mitigation

OAR 860-300-0020 (1)(c)
(10) Provide planned and actual work completed and dollars planned and actually spent by
program for the prior and future years, as well as associated estimations of risk reduction for
the work completed, compared to their original estimations separated by system,
Oregon, and Idaho.

See Section 4.4 Wildfire Mitigation Cost Summary, specifically Table 7 Estimated system wide
incremental O&M expenses for wildfire mitigation, and Section 4.5 Mitigation Activities

(11) Provide a multiyear plan with project-level details for multi-year capital investments, with
objective priorities identified and the estimated wildfire risk reduction for the project's
selected mitigation method separated by system, Oregon, and Idaho.

See Section 4.5.8 Incremental Capital Investments, and Table 9 WMP forecasted
capital investments
OAR 860-300-0020 (1)(d)
(12) Include in WMP a clear map of Oregon service territory that could be affected by PSPS or
other modified system operations.

See Section 7.5.2 PSPS Plan and Section 3.3.1 Maps. See Section 7.2 for Operational
Protection Strategy. While a PSPS event is more probable in an elevated wildfire risk
zone, Idaho Power retains the ability to utilize PSPS anywhere throughout its service
area. The decision regarding PSPS is based on a number of dynamic factors, and each
circumstance is unique.

(13) Engage with Public Safety Partners, including ESF-12, in areas outside and within RRZ and
YRZ to discuss wildfire risks and methods taken to mitigate risk including modified system
operations and PSPS.

See Appendix B, The Public Safety Power Shutoff (PSPS) Plan and WMP Section 10.2.1
Community Engagement
Idaho Power Company Oregon Wildfire Requirements and Recommendations
Page 8

(14) Include as an appendix to its WMP a registry of Public Safety Partner events, identifying
hosting organization, with feedback provided and actions taken because of the feedback.

See Section 10.2.1 Community Engagement, specifically “2023 Public Safety Partner
Feedback Summary”
OAR 860-300-0020 (1)(e)
(15) Provide findings of analyses on operational modifications based upon "fire season," FPI
levels or other relevant elevated wildfire periods.
See Executive Summary, 2023 weather and fire season overview, for analysis of fire season
FPI. See Section 7 for operational practices and actions taken during wildfire season and
during times of elevated wildfire risk.

(16) Staff recommends that Idaho Power outline roles and responsibilities that are in
place during modified system operations, including PSPS activations; Idaho Power should
communicate this structure to Public Safety Partners, at a minimum during tabletops
or exercises.

See Appendix B, The Public Safety Power Shutoff (PSPS) Plan

(17) Staff recommends that Idaho Power explore how and when placing and operating CRCs is
reasonable given the remote areas in which Idaho Power serves in Oregon.

See Section 10.2.2 Community Resource Centers

(18) Joint IOUs establish language for Public Safety Partners and communities regarding
modified operational practices, including "sensitive settings", PSPS and other utility
operational modes to mitigate wildfire risk.

See Appendix B, The Public Safety Power Shutoff (PSPS) Plan, Section 2.3 Industry and Peer
Utility Engagement
OAR 860-300-0020 (1)(f)
(19) Coordinate community outreach with partners, including ESF-12, and consider
broadening the workshop to include relevant community safety topics, inviting Public Safety
Partners regarding other topics appropriate to the community.

See Section 10.2 Community Outreach

Oregon Wildfire Requirements and Recommendations Idaho Power Company
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(20) Detail methods for determining the effectiveness of customer outreach and describe any
modifications made to outreach strategies as a result.

See Section 10.3.1 Key Communication Methods and Section 10.3.3 Communication Metrics,
specifically Table 16 Key Communication Metrics
OAR 860-300-0020 (1)(g)
(21) Provide summary of planned versus actuals for assets in Oregon consistent with
inspection intervals.

See Section 8.3 Inspection and Correction Timeframes, specifically Table 12 Summary of
asset inspections and schedules by state and zone, and Executive Summary, Table 2
Inspection and Vegetation 2023 goals and accomplishments

(22) Validate that correction timeframes in Idaho Power's routine inspection and correction
program relating to Priority 3 violations are corrected consistent with
OAR 860-024-0018.

See Section 8.3 Inspection and Correction Timeframes. As a matter of record, Idaho Power
complies with all Oregon requirements and statutes. With respect to Idaho Power’s “Priority
3” issues, these are defined by the company as potential issues that should be monitored
and that may require correction at a future point in time. Idaho Power’s Priority 3 issues do
not pose a threat to the system and do not correlate to a heightened risk of fire ignition.
Priority 3 designations are not in violation of section 2 of OAR 860-024-0012 or
OAR 860-024-0018.

(23) Provide greater detail outlining methods to identify elevated fire risk observations during
ignition inspection or routine inspection activities.

See Sections 8.3 through 8.6 for detailed methodology.

(24) Demonstrate the use of its ignition tracking process to support its approach to ignition
prevention inspections.

See Section 8.6 Ignition Tracking and Analysis
(25) Assess and validate its quality assurance and quality control program for ignition
prevention and other inspection activities and outline a reasonable quality assurance level
and associated costs for administering the program.

See Section 8.3 Inspection and Correction Timeframes
OAR 860-300-0020 (1)(h)
Idaho Power Company Oregon Wildfire Requirements and Recommendations
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(26) Utilize the previously recommended RSE methodology to determine the risk reduction for
enhanced vegetation management both inside YRZs as well as outside YRZ or RRZs.
See Section 4.2 Risk-Based Cost and Benefit Analysis of Wildfire Mitigation and Section 4.5.6
Enhanced Vegetation Management. Idaho Power will continue to evaluate RSE efforts
with a specific focus on trying to accurately quantify risk reduction and to determine
how RSE may be used as one of many inputs in overall decision-making processes for
mitigation approaches and alternatives. A detailed roadmap for the creation of a
collaboratively developed, uniform RSE framework process will be developed in 2024.
(27) Provide details for work planned and completed relating to vegetation management both
within and outside YRZs in Oregon (as well as system-wide)

See Table 2 Inspection and Vegetation 2023 goals and accomplishments, and Table 7
Estimated system-wide O&M expenses for wildfire mitigation

(28) Conduct root cause analysis for vegetation-related risks be conducted to support the
determination of optimal vegetation management actions.

Section 8.6.1 details the company’s RCA process. Section 4.5.6 Enhanced Vegetation
Management and Section 8.7 T&D Vegetation Management details the company’s process
for determining optimal vegetation management actions. Although vegetation
management is a sizeable increased wildfire mitigation expense, performing this work is
expected to have notable long-term co-benefits, including reduced vegetation-caused
outages in Tier 3 and Tier 2 Risk zones. The 2023 wildfire season saw an increased
number of storm events, high winds, and more lightning throughout the service area
than in previous years. While storm activity was higher, outages associated with
vegetation fell by 27% compared to previous years—indicating that the company’s
vegetation management practices are reducing risk.

(29) Demonstrate the use of Idaho Power's reporting process to evaluate the logic of its
programmatic decisions for vegetation management in YRZs and non-YRZs in Oregon and
system wide.
Section 8.6 Ignition Tracking and Analysis details the company’s Outage Management
System (OMS) database, which is used for reliability and measurement reporting
purposes. Section 11.9 Long-term Metrics elaborates on the company’s approach for
gauging the effectiveness of the WMP, including tracking reliability data and specific
outage counts based on causes.
As an example, a review performed in early 2023 identified specific areas where
vegetation caused several outages during the 2022 wildfire season, in a particular
wildfire risk zone beyond the same overcurrent protection device. The company’s utility
arborist incorporated the dashboard into work procedures to identify problematic areas
and proactively investigate and correct issues.
Oregon Wildfire Requirements and Recommendations Idaho Power Company
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(30) Provide plan and actual experience with QA/QC program performance within and outside
YRZs in Oregon and system wide.
See Section 8.7 T&D Vegetation Management, specifically Table 15 Summary of vegetation
management activities and schedules, Section 8.7.2.3 Transmission Line Clearing Quality
Control and Assurance, and Section 8.8.3.3 Distribution Line Clearing Quality Control
and Assurance.
OAR 860-300-0020 (1)(i)
(31) Include a summary of the quantitative analysis used in the choice and prioritization of
specific solutions and investments, segmented by state and risk zone versus non-risk zone

Section 4.4 identifies selected mitigation activities and the estimated costs of those activities
on a system level. In Section 4.5, 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.

(32) Explain how solutions providing co-benefits have been considered in its
investment strategies.

See response to recommendation 31, above. In addition, See Table 8: Safety, reliability, and
resilience co-benefits of wildfire mitigation initiatives

(33) Discuss the impact of participation in expert forums on identification of solutions were
most likely to provide the benefits anticipated. This should include:
a. Cited research, reports, and studies used in any analysis, unless the source
is confidential.
See reference list.
b. How the factors unique to the Company's facilities and service territory were used
when considering the applicability of specific options to its systems.

(a) See reference list at the end of this Appendix.
(b) See Section 2.3 Industry and Peer Utility Engagement.
OAR 860-300-0020 (1)(j)
(34) In Recommendation 33, Staff recognized certain of the industry learnings were likely
related to risk valuation, however directly responsive to the broader research and
development and industry participation, Staff recommends Idaho Power provide specifics on
program changes made in response to learnings from industry forums, as well as greater
detail of who from the company participates and in what roles they function in various
industry forums.
Idaho Power Company Oregon Wildfire Requirements and Recommendations
Page 12

See Section 2.3 Industry and Peer Utility Engagement, specifically 2023 Idaho Power Wildfire
Mitigation Engagements

(35) Staff recommends Idaho Power and joint utilities evaluate the CPUC WSD maturity model
and develop an Oregon IOU rubric as part of their 2024 WMPs; Staff would welcome the
opportunity to participate in such a collaborative work effort

See Section 1.5 Wildfire Mitigation Plan Maturity

(36) Explicit reporting on pilots identified but not carried out in Oregon

See Executive Summary, specifically WMP Technology and Innovation, Section 4.5.3
Situational Awareness-Advanced Technologies, 4.5.5.4 Covered Conductor Pilot, and 4.5.6.1
Fuels Reduction Shared Stewardship Project.
OAR 860-300-0020 (1)(j)
(37) Staff recommends Idaho Power demonstrate the use of its ignition management
database to perform root cause analyses which led to any ignition inspection
program changes.

See Section 8.6 Ignition Tracking and Analysis and Section 8.6.1 Root Cause Analysis.
Section 11.9 Long-term Metrics summarizes the assessments made in 2023 regarding
outage metrics.
The following were references used during the year to inform changes in the 2024 WMP.
Wildfire Mitigation
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Bruzgul, Judsen, and Weisenfeld, Neil, 2023, November 17, Wildfire Risks in the US are soaring.
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Chiu, B., Rajdeep, R., and Thuan, T. 2022, January/February. Wildfire Resiliency. IEEE Power &
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Cohen, Ethan, 2022, December 6. Infographic: Top Priorities, Technologies and Challenges in
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Idaho Power Company Oregon Wildfire Requirements and Recommendations
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Scott, Joe H., et al. 2013. A wildfire risk assessment framework for land and resource
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Serrano, R., Carvalho, M., Araneda, J., Alamos, O., Barroso, L., Bayma, D., Ferreira, R., and
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