20231218Staff 20-22 to AVU.pdf

CHRIS BURDIN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE,IDAHO 83720-0074 SS N(208)334-0314
IDAHO BAR NO.9810
Street Address for Express Mail:
11331 W CHINDEN BLVD,BLDG 8,SUITE 201-A
BOISE,ID 83714
Attorney for 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 )SECOND 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 TUESDAY,
JANUARY 2,2024.1
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
'Staffis 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 1 DECEMBER 18,2023
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.20:In reference to the Company's response to Production Request No.
12,please provide documentation for the support of the numbers in "Table 1 -Example Monthly
DCFC Operator Costs and Revenue in Idaho on Avista's Rate Schedule 11".In particular,
please provide support for how the followingnumbers were reached:
a.30,the number of charging sessions per month the business will likelyhave;
b.900 kWh,the amount of energy consumption;
c.180 kW,the max electricitypower demand for the DCFC site;
d.$1,292.15,the total monthlyoperating costs;and
e.$0.45/kWh,the usage rate fee.
REQUESTNO.21:Referencing the Company's response to Production Request No.1,
current customers have a much higher usage than the example in Table 1.Please show the
difference between schedule 11 and schedule 23 for Customer A in December 2022.
REQUESTNO.22:Please provide all actual usage data for DCFC customers in 2023.
Please identify the five DCFC customers (i.e.Customer A,B,C,D,E)consistent with the
Company's response to Staff's Production Request No.1 and provide usage data in the same
format.
DATED at Boise,Idaho,this day of December 2023.
Chris Burdin
Deputy AttorneyGeneral
i:umise:prodreq/AVU-E-23-16 PR #2
SECOND PRODUCTION REQUEST
TO AVISTA CORPORATION 2 DECEMBER 18,2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 18nd DAY OF DECEMBER 2023,
SERVED THE FOREGOING SECOND 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:[e-mail]
[e-mail]
Ida Elmasian
CERTIFICATE OF SERVICE