20211019Staff 1-11 to Avista.pdf

ERICK SHANER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, TDAHO 83720-0074
[phone]
IDAHO BAR NO. 5214
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Street Address for Express Mail:
I I331 W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE, ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF AVISTA CORPORATION FOR AN
ORDER AUTHORIZING PILOT PROGRAMS
FOR THE RESEARCH AND DEVELOPMENT
OF ELECTRIC TRANSPORTATION
CASE NO. AVU.E-21-13
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO AVISTA CORPORATION
The Staff of the Idaho Public Utilities Commission, by and through its attorney of
record, Erick Shaner, Deputy Attorney General, requests that Avista Corporation provide the
following documents and information as soon as possible, but no later than TUESDAY,
NOVEMBER 9, 2021.
This Production Request is to be considered as continuing, and the Company is requested
to provide, by way of supplementary responses, additional documents that it, or any person
acting on its behalf, may later obtain that will augment the documents or information produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations, and the name, job title, and telephone number of
the person preparing the documents. Please also identift the name, job title, location, and
telephone number of the record holder.
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATTON
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I ocToBER t9,2021
In addition to the written copies provided as response to the requests, please provide all
Excel spreadsheets and electronic files on CD with formulas intact and enabled.
REQUEST NO. 1: How many DC fast charging sites does the Company own and how
many are in service? Final Report at 2.
REQUEST NO. 2: Please provide a workpaper that supports the calculation of all
values listed in Table I of the Final Report. Final Report at 4.
REQUEST NO. 3: Please provide a workpaper that shows how $1,206 per EV in net
grid benefits was calculated. Final Report at 6.
REQUEST NO. 4: Please provide a workpaper that shows how a $1,661 per EV net
benefit was calculated. Final Report at 6.
REQUEST NO. 5: Please itemize cost components in the "Utility Generation and
Delivery Cost" column in Table 7. Transportation Electrification Plan, Exhibit 2, at 41.
REQUEST NO. 6: Please describe how these market transformation programs promote
energy efficiency. Specifically, please describe how they reduce the amount of energy used.
REQUEST NO. 7: In the Company's first area of focus on "integrated charging, on-site
renewables, and battery storage research," please answer the following about the proposal to
"develop and implement a research project and report summarizing the current state of integrated
stations":
a. When is the estimated completion of the research?
b. Please provide workpapers and a breakdown for the estimated annual expenses
for this research. Please provide the workpapers in Excel format, with all
formulas intact.
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION 2 ocToBER 19,2021
c. Please provide workpapers and a breakdown for the estimated total cost to
complete this research. Please provide the workpapers in Excel format, with all
formulas intact.
d. How will the research be presented and who will be able to access it?
REQUEST NO. 8: In the Company's first area of focus on "integrated charging, on-site
renewables, and battery storage research," please answer the following about the proposal to
"develop a parametric model used to identifr variable cost factors and resulting charging outputs
on an ongoing basis":
a. When is the estimated completion of the area of focus?
b. Please provide workpapers and a breakdown for the estimated annual expenses
for this area of focus. Please provide the workpapers in Excel format, with all
formulas intact.
c. Please provide workpapers and a breakdown for the estimated total cost to
complete this area of focus. Please provide the workpapers in Excel format, with
all formulas intact.
d. How could the parametric model be implemented for use?
e. Does the Company anticipate future cost after completion in order to maintain the
parametric model?
REQUEST NO. 9: In the Company's first area of focus on "integrated charging, on-site
renewables, and battery storage research", please answer the following about the "construction
project design and implementation plan" proposed and how the area of focus will be scalable:
a. What specifically will be included in the design? Integrated charging with
batteries and onsite renewables? Will the Company propose various designs with
different Electric Vehicle charging station designs? Will the project be designed
for residential, workplace, commercial, industrial, or other facilities?
b. Who will be able to access the designs and implementation plan? How will they
be able to use this information
FIRST PRODUCTTON REQUEST
TO AVISTA CORPORATION 3 ocToBER t9,2021
c. What are the components that would need to change on the project design to be
able to implement the design at various locations, i.e., Geographical Information
System data, electrical diagrams, onsite renewables designs?
d. When is the estimated completion of this area of focus?
e. Please provide workpapers and a breakdown for the estimated annual expenses
for this area of focus. Please provide the workpapers in Excel format, with all
formulas intact.
f. Please provide workpapers and a breakdown for the estimated total cost to
complete this area of focus. Please provide the workpapers in Excel format, with
all formulas intact.
g. Does the Company anticipate future cost after completion in order to maintain the
results and assist future customers with the implementation of this design?
REQUEST NO. 10: In Order No. 35129, atpage 9, the Commission ordered that "the
Company shall propose and seek approval of an updated R&D program that includes metrics and
measurable targets." Please describe how the Company will provide metrics and measurable
targets for each of the 3 areas proposed in the "integrated charging, on-site renewable, and
battery storage research" areas on page 8 of the Application, lines 7-12, ard the "workplace,
fleet, and rural access charging infrastructure" program.
REQUEST NO. 11: Please provide workpapers and supporting documentation and
calculations for the proposed charging infrastructure of $360,000. Please provide the
workpapers in Excel format, with all formulas intact.
FIRST PRODUCTTON REQUEST
TO AVISTA CORPORATION 4 ocToBER 19,2021
DATED at Boise,Idaho, ftr, / ?*L
day of October202l
Shaner
Deputy Attorney General
i:umise:prodreq/avue2l. l3esksktt prod req I
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION 5 ocToBER 19,2021
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 19TH DAY OF OCTOBER 202I,
SERVED THE FOREGOING FIRST PRODUCTION REQTIEST OF TIIE
COMMISSTON STAX'F TO AVISTA CORPORATION , IN CASE NO. AVU-E-21-13,
BY E.MAILING A COPY THEREOF, TO THE FOLLOWING:
LINDA GERVAIS-FALKNER
SR MGR, REG POLICY
AVISTA CORPORATION
PO BOX3727
SPOKANE WA99220-3727
E.MAIL:
I inda. servais-falkner@avistac orc.com
dockets@avistacoro. com
DAVID J MEYER
VP & CHTEF COLINSEL
AVISTA CORPORATION
PO BOX3727
SPoKANE WA99220-3727
E-MAIL : [e-mail]
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SECRETAR/
CERTIFICATE OF SERVICE