20231206AVU to Staff 1-6_10-12_14-18.pdf

AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 12/05/2023 CASE NO: AVU-E-23-16 WITNESS: N/A REQUESTER: IPUC RESPONDER: Lisa Garrett TYPE: Production Request DEPARTMENT: Products & Services
REQUEST NO.: Staff-001 TELEPHONE: [phone] REQUEST:
Please provide all actual usage data for Direct Current Fast Charging ("DCFC") customers in 2021 and 2022. RESPONSE:

Please see table below for usage data for DCFC customers in 2021 and 2022. Data is summarized by customer, by month and year. Customer A:

End Meter Read Date kWh KW

RECEIVED
Wednesday, December 6, 2023 11:33:33 AM
IDAHO PUBLIC
UTILITIES COMMISSION
Customer B:

End Meter Read Date kWh KW
Customer C: End Meter Read Date kWh KW

Of note for Customer C, PlugShare indicates they have a DCFC capable of 50 kW. Based on actual usage, it appears this unit was installed between May to June 2023 and thus usage provided above does not reflect the higher kW demand.
Customer D: Started service June 1, 2023 and therefore has no actual usage data in 2021 or 2022.
Customer E: Started service July 24, 2023 and therefore has no actual usage data in 2021 or 2022.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 12/05/2023 CASE NO: AVU-E-23-16 WITNESS: N/A REQUESTER: IPUC RESPONDER: Joe Miller TYPE: Production Request DEPARTMENT: Regulatory Affairs
REQUEST NO.: Staff-002 TELEPHONE: [phone] REQUEST:
Please provide all workpapers showing revenue neutrality forecasts under the proposed Schedule 23. RESPONSE:

Given the relatively small number of customers, and the diversity of usage characteristics amongst these customers expected to take service on this schedule, the Company has not conducted any revenue neutrality forecasts.
As explained in other production requests, the Company believes that there will be a limited
number of customers expected to take service on Schedule 23 and the revenue and load impacts will be minimal. Yet, this Schedule is necessary in order to encourage the build out of electric vehicle fast charging stations to support the broad charging network required to encourage the advancement of electric vehicles in the state of Idaho.

AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 12/05/2023 CASE NO: AVU-E-23-16 WITNESS: N/A REQUESTER: IPUC RESPONDER: Paul Kimball TYPE: Production Request DEPARTMENT: Regulatory Affairs
REQUEST NO.: Staff-003 TELEPHONE: [phone] REQUEST:
Please provide the proposed tariff for Schedule 23. RESPONSE:

Please see Staff_PR_003 Attachment A.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 12/05/2023 CASE NO: AVU-E-23-16 WITNESS: N/A REQUESTER: IPUC RESPONDER: Lisa Garrett TYPE: Production Request DEPARTMENT: Products & Services
REQUEST NO.: Staff-004 TELEPHONE: [phone] REQUEST:
Of the current customers with DCFC, are there any customers taking service under Schedule 11 or 21 with multiple meters? If so, please explain. RESPONSE:

Yes, all customers that the Company knows of that have DCFC have multiple meters. Each DCFC is separately metered with each premise having at least one additional electric meter serving non-DCFC load.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 12/05/2023 CASE NO: AVU-E-23-16 WITNESS: N/A REQUESTER: IPUC RESPONDER: Lisa Garrett TYPE: Production Request DEPARTMENT: Products & Services
REQUEST NO.: Staff-005 TELEPHONE: [phone] REQUEST:
How many DCFC customers currently take service under Schedule 11 and Schedule 21, respectively? RESPONSE:

Please see table below for current DCFC customers taking service under the respective rate schedules. Schedule # DCFC Customers
I011
I021

AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 12/05/2023 CASE NO: AVU-E-23-16 WITNESS: N/A REQUESTER: IPUC RESPONDER: Shawn Bonfield TYPE: Production Request DEPARTMENT: Regulatory Affairs
REQUEST NO.: Staff-006 TELEPHONE: [phone] REQUEST:
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.
RESPONSE: Environmental benefits will not reduce or otherwise benefit customers’ electric rates, rather environmental benefits are a societal benefit for all Idaho residents. The Company does not have a timeline available that shows the expected benefit as the penetrations of DCFC stations grow.
However, each EV powered by Avista’s electricity produces 77% lower emissions than the
average gasoline-powered light-duty vehicle.1
1 Choose EV Calculator Tool, accessed at
https://www.myavista.com/energy-savings/electric-transportation/for-your-home
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 12/05/2023 CASE NO: AVU-E-23-16 WITNESS: N/A REQUESTER: IPUC RESPONDER: Shawn Bonfield TYPE: Production Request DEPARTMENT: Regulatory Affairs
REQUEST NO.: Staff-010 TELEPHONE: [phone] REQUEST:
Please explain how the Company benefits from being an early adopter of DCFC infrastructure as opposed to a naturally occurring growth pattern. RESPONSE:

The Company is not proposing to install, own or operate any DCFC stations in Idaho as part of its application for approval of Schedule 23, thus is not looking to be an early adopter of DCFC infrastructure. Rather, Avista has proposed a DCFC charging rate only. The proposed rate option is designed to eliminate a key barrier of private investment in DCFC in Idaho. We don’t expect many
customers to utilize this optional rate schedule in the near term but nonetheless, it’s key to
supporting private investment and spurring beneficial market adoption in Idaho.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 12/05/2023 CASE NO: AVU-E-23-16 WITNESS: N/A REQUESTER: IPUC RESPONDER: Shawn Bonfield TYPE: Production Request DEPARTMENT: Regulatory Affairs
REQUEST NO.: Staff-011 TELEPHONE: [phone] REQUEST:
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.
RESPONSE: Because Avista will not be the owner or operator of the DCFC stations, it will not receive any data regarding the utilization and costs of the DCFC stations, other than the overall kWh consumption
and kW demand of each separately metered EV charging site.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 12/05/2023 CASE NO: AVU-E-23-16 WITNESS: N/A REQUESTER: IPUC RESPONDER: Paul Kimball TYPE: Production Request DEPARTMENT: Regulatory Affairs
REQUEST NO.: Staff-012 TELEPHONE: [phone] REQUEST:
Please provide the supporting workpapers used to develop Table 3 in the Application, in excel format with formulas enabled and intact. RESPONSE:

Please see Staff_PR_012 Attachment A.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 12/05/2023 CASE NO: AVU-E-23-16 WITNESS: N/A REQUESTER: IPUC RESPONDER: Shawn Bonfield TYPE: Production Request DEPARTMENT: Regulatory Affairs
REQUEST NO.: Staff-014 TELEPHONE: [phone] REQUEST:
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? RESPONSE:

The Company does not own any DCFC stations in Idaho and currently has no plans to do so. The Company does own DCFC stations in Washington and per it’s Washington Transportation Electrification Plan, will continue to install and operate additional DCFC stations in Washington in the future. The following is the current list of Washington DCFC stations that the Company
owns.

*Chewelah DCFC is expected to be online by the end of the year. Station is installed and energized and just awaiting
network commissioning (12/11/23) before it will be available for use.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 12/05/2023 CASE NO: AVU-E-23-16 WITNESS: N/A REQUESTER: IPUC RESPONDER: Joe Miller TYPE: Production Request DEPARTMENT: Regulatory Affairs
REQUEST NO.: Staff-015 TELEPHONE: [phone] REQUEST:
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;
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 currently take 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 currently are 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. RESPONSE:

a. The Company’s practice is to put customers on the most economical rate schedule for which they qualify. The Company based Schedule 23 on the present Schedule 21 rates because this is the most likely schedule that a DCFC customer would take service on as electric vehicle charging advances and these DCFC stations are more widely used. Also,
Schedule 21 incorporates a fixed demand charge for the first 50 kW of demand or less. Customers on Schedule 23 would continue to pay the fixed demand charge ensuring they contribute a reasonable amount of the fixed costs of the system as compared to a Schedule 11 customer with a much lower basic charge.
b. There are currently five customers in Avista’s Idaho electric service territory with separately metered DC fast chargers that would be eligible for Schedule 23. Each of these customers are currently taking service under I011. c. Four of the five of the customers indicated above would be expected to adopt the new
Schedule 23, if approved. d. The Company is unable to conduct a cost-of-service study that would provide reliable results for this new class of customer given the small number of existing customers with
very diverse and evolving load characteristics. In particular, the Company does not have
the necessary hourly demand data and would have to make estimates for these customers
that could cause the cost-of-service results to vary widely depending on whether these customers were on, or off, the Company’s coincident peak.

As explained in other production requests, the Company believes that there will be a limited number of customers expected to take service on Schedule 23 and the revenue and load impacts will be minimal. Yet, this Schedule is necessary in order to encourage the build out of electric vehicle fast charging stations to support the broad charging network
required to encourage the advancement of electric vehicles in the state of Idaho.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 12/05/2023 CASE NO: AVU-E-23-16 WITNESS: N/A REQUESTER: IPUC RESPONDER: Shawn Bonfield TYPE: Production Request DEPARTMENT: Regulatory Affairs
REQUEST NO.: Staff-016 TELEPHONE: [phone] REQUEST:
Please provide the total number of customers the Company expects to adopt the new Schedule 23 rate schedule in the next three years. RESPONSE:

Please see the Company’s response to Staff_PR_015. In terms of a forecast of customers that may adopt the new Schedule 23 rate schedule in the next three years, the Company does not have such a forecast. We don’t expect many customers to utilize this optional rate schedule in the near term but nonetheless, it’s key to supporting private investment, including access to grant funding, and
spurring market adoption in Idaho.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 12/05/2023 CASE NO: AVU-E-23-16 WITNESS: N/A REQUESTER: IPUC RESPONDER: Joe Miller TYPE: Production Request DEPARTMENT: Regulatory Affairs
REQUEST NO.: Staff-017 TELEPHONE: [phone] REQUEST:
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 currently being 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.
RESPONSE: Please refer to the workpaper labeled “Workpapers – DCFC Rate Tariff 023”. The Company priced the Schedule 023 rates in a way that eliminated the variable demand charge for all Schedule
21 customers and expressed the dollars associated with the variable demand charge as an excess
energy charge, which is additive to the Schedule 021 base rate. This rate design recovers the same amount of revenue based on the billing determinants for all Schedule 021 customers, thus providing a reasonable basis for the Schedule 023 schedule. The Company views this rate design as a reasonable option for EV customers until such time that the Company deploys new AMI
meters which will allow for more advanced rate design options, such as time of use rates, in the future. As explained in other production requests, the Company believes that there will be a limited number of customers expected to take service on Schedule 23 and the revenue and load impacts
will be minimal. Yet, this Schedule is necessary in order to encourage the build out of electric vehicle fast charging stations to support the broad charging network required to encourage the advancement of electric vehicles in the state of Idaho.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 12/05/2023 CASE NO: AVU-E-23-16 WITNESS: N/A REQUESTER: IPUC RESPONDER: Joe Miller TYPE: Production Request DEPARTMENT: Regulatory Affairs
REQUEST NO.: Staff-018 TELEPHONE: [phone] REQUEST:
The Company's workpaper named "20231103Workpapers – DCFC Rate Tariff", Tab "Sheet l", 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. RESPONSE:
The above referenced calculation includes the Block 1 kWh’s, weather, and unbilled kWh’s only.