20211201Staff 12-18 to Avista.pdf

ERICK SHANER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 5214
Street Address for Express Mail:
1 133I W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE,ID 83714
Attomey 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 DEYELOPMENT
OF ELECTRIC TRANSPORTATION
CASE NO. AVU.8.21.13
SECOND PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO AVISTA CORPORATION
The Staff of the Idaho Public Utilities Commission, by and through its attomey 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 WEDNESDAY,
DECEMBER 15, 2021.1
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
I Stuff ir requesting an expedited response. If responding by this date will be problematic, please call Staff s
attorney at [phone].
SECOND PRODUCTION REQUEST
TO AVISTA CORPORATION
)
)
)
)
)
)
)
)\
I DECEMBER I,2O2I
RECEIVED
2021 DEC -1 PM 4:14
IDAHO PUBLIC
UTILITIES COMMISSION
the person preparing the documents. Please also identify the name, job title, location, and
telephone number of the record holder.
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. 12: Please describe how the Company will request and utilize funds, if
any, from the National Electric Vehicle Formula Program in the Congressional Bill, H.R. 3684 -
Infrastructure and Jobs Acts, to deploy electric vehicle charging infrastructure in the Company's
Idaho service territory. Please provide a timeline of potential electric vehicle infrastructure
projects from the funds provided from the Congressional Bill H.R. 3684.
REQUEST NO. 13: Please provide the rationale for the proposed charging
infrastructure breakdown of 20 workplace, 5 fleet, and 5 rural access charging infrastructure per
year. In the explanation, please include the following:
a. Why doesn't the Company install more rural access or fleet charging stations?
b. What are the benefits of having significantly more workplace chargers than fleet and
rural access charging?
c. Any other rationale(s)?
REQUEST NO. 14: In the Company's responses to Production Requests No. 7-9, the
Company indicated that the "integrated charging, on-site renewable, and battery storage
research" will be completed by the end of third quarter of 2023. Please confirm that this area of
focus will expire in2023 and no expenses will occur in2024. If the project or expenses extend
into 2024, please explain which expenses and why they will be incurred.
REQUEST NO. 15: What is the Company's intended pilot length of the workplace,
fleet, and rural access charging infrastructure program?
REQUEST NO. 16: What is the Company's intended pilot length for the entire electric
transportation programs proposed in the Application?
SECOND PRODUCTION REQUEST
TO AVISTA CORPORATION 2 DECEMBER I, 2O2I
REQUEST NO. 17: Of the $300,000 of Research and Development funds allocated for
2021, how much of the funds have been used to date and does the Company expect to carry over
any unused funds into2022?
REQUEST NO. 18: In the Company's Reply Comments on AW-E-20-13, the
Company stated, "that it is appropriate that it be allowed to continue with any R&D work already
in progress, especially for projects already contracted." Please provide additional details about
existing contracts including, but not limited to, completion dates, and expenses that will carry
beyond 2021.
DATED at Boise,Idaho, this lst day of December 2021.
Erick Shaner
Deputy Attorney General
i:umisc:prodreq/avue2 l. I 3estt prod req 2
SECOND PRODUCTION REQUEST
TO AVISTA CORPORATION aJ DECEMBER I,2O2I
CERTIFICATE OF SERYICE
I HEREBY CERTIFY THAT I HAVE THIS l't DAY OF DECEMBER 2021,
SERVED THE FOREGOING SECOND PRODUCTION REQTIEST OF THE
coMMrssloN STAFF TO AYTSTA 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 i nda. gervai s-falkner@avistacorrr. com
dockets@avi staco rp. com
BENJAMIN J OTTO
ID CONSERVATION LEAGUE
710 N 6TH ST
BOISE ID 83702
E-MAIL : [e-mail]
DAVID J MEYER
VP & CHIEF COUNSEL
AVISTA CORPORATION
PO BOX3727
SPOKANE WA99220-3727
E-MAIL: [e-mail]
EMMA E SPERRY
ID CONSERVATION LEAGUE
710 N 6TH ST
BOISE ID 83702
E-MAIL : esperr.v@ idahoconservation.org
J, fl,l..^
SECRETART
CERTIFICATE OF SERVICE