Docket Number	Docket Name	Company
UM 2207	PACIFICORP WILDFIRE PROTECTION PLANS	PACIFIC POWER

Comment Number	Created Date	Email Received Date	Company Name	Comment Type	Source Type	First Name	Last Name	Email	Nearest City	Comment
UM 2207-1	4/9/2025 8:48:53 PM		OTHER	General Comment	Web	Rich	Fairbanks		JACKSONVILLE	Comments on Pacific Power’s Wildfire Mitigation Plan (Docket UM 2207) I feel qualified to speak on this Wildfire Mitigation Plan for the following reasons. I held various positions in the wildfire Incident Command System (ICS) and the Forest Service fire organization, including Interagency Hotshot Crew Foreman, Suppression Crew Foreman, Division Supervisor and others. Retiring after a 32-year career with the Forest Service, I worked 6 years for The Wilderness Society, leading their California fire program. I currently own Fairbanks Forest Management LLC, a company primarily engaged in wildfire investigation for law firms and insurance companies. I studied fire behavior as a graduate student . I have a degree in forestry and hold a master’s degree in planning. The following comments are based on my education and experience. 1) I live in the Little Applegate. I have a powerline right-of-way running through my property. Many of my neighbors are in a similar situation. If I had more time, I could organize people to comment and otherwise participate in the development of these Wildfire Mitigation Plans (WMP’s). Please consider extending the deadline for comments. 2) The new policy/practice of shutting off our power when the wind blows during fire season may protect Pacific Power from litigation, but will damage the interests of rural residents, including your customers. I will cite just one effect of this policy. Each time you shut off power, we are all a bit more likely to go out and buy a loud, smelly generator. Each generator comes with a fuel tank, often sited within a few feet of our homes. Whether propane, diesel or gasoline, this is adding to the hazard. If improperly wired, generators may even add to the risk of a wildfire ignition. Pacific Power says it is mitigating risk from wildfire? It seems to be mitigating risk from litigation. 3) Like Pacific Power and others in Southwest Oregon, I am spending time and money cleaning up after the ‘Firmageddon’ flat head borer bark beetle (Phaenops Drummondii) outbreak. There is peer-reviewed science indicating the size and severity of this outbreak is a direct result of climate change. Climate change is a direct result of the activities of oil companies. I do not have the money to sue the oil companies to recover my costs from cleaning up the mess they created by increasing temperatures by two degrees Fahrenheit, thus supercharging the beetle outbreak. Pacific Power has also incurred huge costs to fell snags near its lines. Pacific Power has battalions of lawyers and has every reason to sue and win to recover costs from the oil giants. Please consider suing the oil companies or perhaps joining the Oregon Attorney General’s suit. 4) Trimming trees and felling trees that have established under its lines is a major cost. I am experimenting with a couple of techniques to reduce this ingrowth of trees along my little chunk of your power line. Please consider under-burning, competitive planting of short stature shrubs and other ways to reduce vegetation management costs. You are welcome to contact me to discuss specifics. 5) Even before the beetle outbreak, Pacific Power’s vegetation management activities turned many tons of live, hydrated trees into dry, flammable slash. The 0” to 3” diameter material (limbs and tops) is richly supplied with oxygen during the passage of a flaming front. Thus, the companies own management activities function as an accelerant to the Rate Of Spread (ROS) and Resistance To Control (RTC) of a potential wildfire. You need to under-burn or pile and burn or chip this material. Thank you for the opportunity to comment. Sincerely Rich Fairbanks 9651 Sterling Creek Road Jacksonville OR 97530 April 9, 2025