20231122Staff 1-19 to AVU.pdf

CHRIS BURDIN O
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE,IDAHO 83720-0074 MíSSION
[phone]
IDAHO BAR NO.9810
Street Address for Express Mail:
11331 W CHINDEN BLVD,BLDG 8,SUITE 201-A
BOISE,ID 83714
Attorneyfor the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION )OF AVISTA CORPORATION,D/B/A AVISTA )CASE NO.AVU-E-23-16UTILITIES,REQUESTINGAUTHORITY TO )ESTABLISH TARIFF SCHEDULE 23 FOR )DIRECT CURRECT FAST CHARGING )FIRST PRODUCTION
(DCFC)OF ELECTRIC VEHICLES )REQUESTOF THE
)COMMISSION STAFF
)TO AVISTA CORPORATION
Staff of the Idaho Public Utilities Commission,by and through its attorney of record,
Chris Burdin,Deputy AttorneyGeneral,requests that Avista Corporation ("Company")provide
the followingdocuments and information as soon as possible,but no later than WEDNESDAY,
DECEMBER 6,2023.1
This Production Request is to be considered as continuing,and the Company is requested
to provide,by way of supplementaryresponses,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 Staffis requesting an expedited response.If responding by this date will be problematic,please call Staff'sattorneyat(208)334-0314.
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION 1 NOVEMBER 22,2023
the person preparing the documents.Please also identify the name,job title,location,and
telephonenumber of the record holder.
In addition to the written copies provided as response to the requests,please provide all
Excel spreadsheets and electronic files with formulas intact and enabled.
REQUESTNO.1:Please provide all actual usage data for Direct Current Fast Charging
("DCFC")customers in 2021 and 2022.
REQUESTNO.2:Please provide all workpapers showing revenue neutralityforecasts
under the proposed Schedule 23.
REQUESTNO.3:Please provide the proposed tariff for Schedule 23.
REQUESTNO.4:Of the current customers with DCFC,are there any customers taking
service under Schedule 11 or 21 with multiplemeters?If so,please explain.
REQUESTNO.5:How many DCFC customers currentlytake service under Schedule
11 and Schedule 21,respectively?
REQUESTNO.6:Please clarify how,if at all,the environmental benefits described in
the Application at 2 will reduce or otherwise benefit Idaho customers'electric rates.Please
provide a timeline showing the expected benefit as the penetration of DCFC stations grows.
REQUESTNO.7:Please clarify how,if at all,the economic benefits described in the
Application at 2 will reduce or otherwise benefit Idaho customers'electric rates.Please provide
a timeline showing the expected benefit as the penetration of DCFC stations grows.
REQUESTNO.8:Please clarify how,if at all,the Company's proposal claims the grid
benefit of net positive revenue if the proposal is designed to be revenue neutral.
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION 2 NOVEMBER 22,2023
REQUESTNO.9:The Company's Application describes that 95%of electric vehicle
("EV")charging occurs at home or at work.Please explain how the Company's proposal will
accelerate the adoption of EV's in Idaho when the majority of charging for local EV owners
occurs at home.
REQUESTNO.10:Please explain how the Company benefits from being an early
adopter of DCFC infrastructure as opposed to a naturallyoccurring growth pattern.
REQUESTNO.11:The Company describes utilization and cost data it expects to get
from the proposed schedule in the Application at 9.Please describe in detail what the Company
expects to receive for utilization and costs from DCFC stations,i.e.,cars charged,duration of
charge,make of cars,cost to operate,cost to install,etc.
REQUESTNO.12:Please provide the supporting workpapers used to develop Table 3
in the Application,in excel format with formulas enabled and intact.
REQUESTNO.13:Please describe and quantifythe costs incurred by the Company for
the installation of a DCFC station.
a.Please breakdown these costs by those covered under existing tariffs and costs not
covered under existing tariffs.
REQUESTNO.14:Please explain if there are any Company owned DCFC stations in
its Idaho or Washington service territory.If so,where?If not,does the Company intend on
operating DCFC stations in the future?
REQUESTNO.15:In reference to existing customers who offer EV charging and are
eligible for Schedule 23,please respond to the following:
a.If other schedule customers besides Schedule 21 customers are eligible for
Schedule 23,please explain why these other schedule customers should be
eligible to take service under Schedule 23 when the rates are based off Schedule
21 rates;
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION 3 NOVEMBER 22,2023
b.Please provide the total number of existing EV charging customers on the
Company's system who would be eligible for Schedule 23 and identify which
Schedule(s)they currentlytake service under;
c.Please provide the total number of existing customers the Company expects to
adopt the new Schedule 23 rates;and
d.Please provide a modification to the cost-of-service study provided in the last
general rate case that includes the proposed Schedule 23 using existing EV
charging customers who currentlyare included in existing classes that are
expected to take service under Schedule 23.Please provide the reallocations to
the various classes and the proposed Schedule 23 rates using the approved
settlement information from Case No.AVU-E-23-01.
REQUESTNO.16:Please provide the total number of customers the Company expects
to adopt the new Schedule 23 rate schedule in the next three years.
REQUESTNO.17:On page 7 of the Application,the Company states,"The new rate
schedule is priced in a way that would derive the same total revenue as currentlybeing recovered
under Schedule 21,under current usage patterns."Please provide workpapers in electronic
format and formulas enabled demonstrating that the same total revenue would be recovered.
REQUESTNO.18:The Company's workpaper named "20231103Workpapers -DCFC
Rate Tariff",Tab "Sheetl",Cell "L8"shows a calculation of the Block 1 Schedule 21 kWh's by
subtracting the weather normalization and unbilled revenue adjustments from the Block 1
Schedule 21 kWh's.Please explain if the weather normalization and unbilled revenue
adjustments include adjustments from Block 2 Schedule 21 kWh's.If Block 2 Schedule 21
kWh's are a part of the adjustments,please explain why the Block 2 kWh's were included in the
Block 1 kWh calculation.
REQUESTNO.19:Please provide all supporting documentation and calculations for
the numbers used in Table No.1 of the Application,including the average number of charging
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION 4 NOVEMBER 22,2023
session per month,energy consumption,user fee rate,and max electricity power demand.Please
provide the workpapers in excel format with the formulas enabled.
DATED at Boise,Idaho,this Í $day of November 2023.
Chris Burdin
Deputy Attorney General
i:umise:prodreq/AVU-E-23-16 PR #1
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION 5 NOVEMBER 22,2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 22nd DAY OF NOVEMBER 2023,
SERVED THE FOREGOING FIRST PRODUCTION REQUESTOF THE
COMMISSION STAFF TO AVISTA CORPORATION,IN CASE NO.AVU-E-23-16,
BY E-MAILING A COPY THEREOF TO THE FOLLOWING:
PATRICK EHRBAR DAVID J MEYER
DIR OF REGULATORY AFFAIRS VP &CHIEF COUNSEL
AVISTA CORPORATION AVISTA CORPORATION
PO BOX 3727 PO BOX 3727
SPOKANE WA 99220-3727 SPOKANE WA 99220-3727
E-mail:[e-mail] E-mail:david.meyer avistacorp.com
[e-mail]
Ida Elmasian
CERTIFICATE OF SERVICE