20210909Application.pdf

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Avista Corp.
141 I East Mission P.O. Box 3727
Spokane. Washington 99220-0500
Telephone [phone]
Toll Free 800-727-9170
Septerrber 9,2021
Jan Noriyuki, Secretary
Idaho Public Utilities Commission
11331 W. ChindenBlvd. Bldg.8, Ste.20l-A
Boise,Idaho 83714
RE: Case No. AW-E-21'13
Dear Ms. Noriyuki:
Attached for filing with the Commission is Avista Corporation's, doing business as Avista
Utilities', application requesting that the Commission authorize the Company to implernent pilot
electric transportation programs as outlined in the attached Application.
Please direct any questions regarding this filing to Linda Gervais at 509-495-a975 (linda.gervarS:
falkner@ avi stacorp. com) or me at 509 .49 5.8 620 (Patri ck. ehrbar@.avi stacorp. com).
Sincerely,
lol ?aarU eh/a,,
Patrick Ehrbar
Director of Regulatory Affairs
Enclosure
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DAVID J. MEYER
VICE PRESIDENT AND CHIEF COUNSEL FOR
REGULATORY AND GOVERNMENTAL AFFAIRS
AVISTA CORPORATION
I4II E. MISSION AVENUE
P.O.BOX3727
SPOKANE, WASHINGTON 99220-37 27
PHONE: (509) 49s-4316
IN THE MATTER OF THE APPLICATION OF
AVISTA CORPORATION FOR AN ORDER
AUTHORIZING PILOT PROGRAMS FOR THE
RESEARCH AND DEVELOPMENT OF
ELECTRIC TRANSPORTATION
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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CASE NO. AVU.E,.ZI-B
APPLICATION OF
AVISTA CORPORATION
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19 I. INTRODUCTION
20 In accordance with IDAPA 31.01.01 (Rules of Procedure, or RP), RP 052 and RP
21 201, et seq., Avista Corporation, doing business as Avista Utilities (hereinafter Avista or
22 Company), hereby respectfully makes application to the Idatro Public Utilities
23 Commission (IPUC or the Commission) for an order authorizing the Company to
24 implement pilot electric transportation programs. The Company proposes to offer these
25 programs under its electric tariff Schedule 90, "Electric Energy Efficiancy Programs",
26 specifically under the Market Transformation Program and associated Research and
27 Development (R&D), and fund the programs under its electric tariff Schedule 91,
28 "Energy Effrciency Rider Adjustment", effective November 1,2021.
29 The Company requests that this filing be processed under the Commission's
30 Modified Procedure rules through the use of written comments.
1Application of Avista Corporation
I Communications in reference to this Application should be addressed to:
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David J. Meyer
Vice President and Chief Counsel for
Regulatory and Govenrmental Affairs
Avista Corporation
P.O.Box3727
l41l E. Mission Avenue, MSC-7
Spokane, WA 99220-3727
Phone: [phone]
da vi d. m eye r(g) av i st a com. com
Linda Gervais-Falkner
Senior Manager, Regulatory Policy Advisor
Avista Corporation
P.O.Box3727
l4l I E. Mission Avenue, MSC-27
Spokane, WA 99220-3727
Phone: [phone]
linda. gervais-falkner(@avistacorp.com
dockets@ avistacorp.com
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The Company has included the following attachments in support of this filing,
which are also referenced below:
a) Exhibit No. I - Avista Electric Vehicle Supply Equipment Pilot Final Report
b) Exhibit No. 2 - Avista Transportation Electrification Plan
II. BACKGROUND
ln November 2020, NARUC President Paul Kjellander announced the theme for
his term, "Connecting the Dots: Innovative/Disruptive Technology and Regulation."
This theme seeks to explore the many different emerging technologies and innovations
that will impact electricity, natural gas, telecommunications, and water utilities. This
theme highlights how the utility sector faces unprecedented pressure created by energy
policy shifts, growing consumer expectations, and rapidly evolving technological
advancements that could fundamentally alter the utility landscape. Concerns about deep
decarbonization, electrification, grid modemization, the need for more renewable energy
resources, cybersecurity, and the surge of distributed energy resource development are
among the many drivers that will alter this landscape. There remains uncertainty as to
which ernerging technologies and innovations will carry the industry forward and what
impact those changes will have on the current regulatory regime. As utilities confront the
2Application of Avista Corporation
I changes that could significantly alter the value proposition of their serrrices, what role
2 should regulators play in the integration of these potentially disruptive technologies and
3 innovations?
4 Avista recognizes that innovation often happens through a series of incremental,
5 smaller steps, rather than in a great leap forward. In this spirit, the Company proposes a
6 relatively small set of electric transportation programs in Idaho, which could lead to larger
7 scale innovations and benefits in the long rrur. The programs also align with the need to
8 "connect the dots" in fransportation electrification, now poised to make dramatic impacts
9 on the energy indusfiry and society as a whole over the next several decades.
l0 This isn't the Company's first venture in electric transportation. Back in the early
I I 1900s, Avista (then Washington Water Power) briefly parhered with the General Vehicle
12 Company to market and sell electric vehicles, including cars and trucks. It also invested
13 in public electric hansportation in the form of electric trolleys to help expand early growth
14 in the Inland Northwest.
15 Illustration No. I
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Application of Avista Corporation
I Over a century has passed since the intemal-combustion engine achieved
2 dominance in the transportation sector. However, modern advances in battery technology
3 and costs, and the global imperative to reduce greenhouse gas ernissions and airpollution,
4 positions electric transportation to transform both the transportation and energy sectors -
5 not just in the light-duty passenger vehicle market, but also in medium- and heavy-duty
6 segments, including freight and material transport of all kinds - on the road, by rail, and
7 even over air and water in some cases.
8 Today, driving a light-duty electric vehicle (EV) fueled by Avista's electricity
9 costs less than an equivalent $1 per gallon of gasoline at a stable price, saves $300 per
10 year in maintenance expenses, and results in zero tailpipe emissions, for a total COz
I I ernissions reduction of 80%.1 If all light-duty vehicles were electric, this would result in
12 regional savings of over $ I billion per year - creating a powerful ripple effect for the
13 economy - and avoided annual emissions of 2.5 million tons of COz, using local and
14 relatively clean anergy sources.2 Other electrified transportation beyond light-duty
15 passenger vehicles could result in even greater reduced emissions and operational
16 savings. In addition, electric transportation provides grld benefits for all utility customers,
17 in the form of net revenue that helps pay for fixed utility infrastructure costs. By 2050,
18 electric transportation may represent 20o/o or more of overall utility electric load, as
l9 modeled by the National Renewable Energy Laboratory. This is illustrated below:
I Estirnates assume Avista's current mix of electric generation sources, 3.3 miles/kWh and $0. I l/kWh for
EVs, and $3/gallon, 26 mpg for conventional vehicles.
2 Avista Transportation Electrification Plan (2020),p.4 and40-43.
4Application of Avista Corporation
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I Illustration No.2 - U.S Historical and Proiected Annual Electricitv Consumotion3
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I I Fortunately, tansportation loads are very flexible, in that a large portion of
12 charging may occtrr when equipment is idled, such as while a personal EV is parked at
13 work during the day or at home overnight. In the future, the greatest benefits may be
14 realizd by capitalizing on this flexibility, charging EVs when grid resources are less
15 constrained, and/or when renewable energy resources such as solar and wind are
16 abundant. In other words, elechic hansportation can benefit all customers and society as
17 a whole - not just those using EVs and other forms of electrified transportation equipment
18 - by using a cheaper and cleaner fuel, more efficiently utilizing grid infrastructure, and
19 integrating re,newable energy resources that energize a more efficient and sustainable
20 economy. Initial modeling indicates positive net benefits both from a regional and a
2l customer rate-impact perspective, which may be further amplified when charging off-
22 peak:
3 Electrification Futures Study: Scenarios of Electric Technology Adoption and Power Consumption for
the United States, p. xiv. National Renewable Energy Laboratory, 2018.
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5Application of Avista Corporation
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Fiqure No. 1-Net Benefits from Lisht-Dutv EVsa
Avista Customer Perspective Costs and Benefits Per EV
without Managed Charging (2019-2038), Baseline Scenario
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Costs Benefits
10 The electric utility is in a unique position to support electric transportation for the
I I benefit of all customers, mainly through charging infrasfructure investrnents, education
12 and outreach, and grid optimization through load management. The industry and markets
l3 continue to rapidly evolve, making constant monitoring and learning a necessity.
14 I.rr-z}lg,Avista completed a three-year EV pilot in the State of Washington.s The
15 Company had significant learnings from the pilot regarding utility support of light-duty
16 vehicle electrification - costs and benefits, grid impacts, and customer experience for
17 example. The utility does play an important role in supporting beneficial electrification,
18 primarily in areas of charging infrastructure, load management, and education and
19 outreach. It is clear that the transition to electric transportation will result in significant
20 economic and environmental benefits for the region and customers over the long term,
2l e.g. driving an EV costs less than $l/gallon equivalent, results in an 80% reduction of
22 COz emissions. Avista believes it is now well positioned to propose initial
a Avista Transportation Electrification Plan (2020), p. 37
5 httlrs://www.utc.wa.eov/casedocket/20 I 6/l 60082
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Application of Avista Corporation
I comprehensive pilot strategies and activities for ldaho customers that build upon this
2 experience, being responsive and flexible to evolving conditions in a variety of market
3 segments and technologies.
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5 III. STRATEGY FOR IDAHO
6 In order to be successful, the strategy for Idaho must incorporate a regional
7 approach as summarized in further detail in the Company's Exhibit No. 2 to this
8 Application - "Avista Transportation Electrification Plan." The intent of these programs
9 is meant to be scalable. Given the multiple technology and program options, these
l0 programs as proposed will assist with determining future efforts. These proposed
11 programs will provide experience in Idaho and the ability to examine cost-effectiveness
12 and customer acceptance, thereby better defining system and infrastructure requirernents,
13 and assessing costs/benefits.
14 Avista proposes electric transportation programs in two areas of focus:
On-site Renewables- and Batterv Storase Research
The Company has received an increasing number of questions from
commercial customers, interested in the possibility of installing charging
infrastructure integrated with on-site renewable power generation and battery
storage, either connected or isolated from the grid. In addition, with improved
technology and costs, such an integrated system could prove essential to cost-
effectively deploy fast-charging in more remote areas where three-phase,
medium-voltage utility power is not practically available. This includes many
rest-stops along major travel corridors (I-90 from Post Falls to the Montana
Border, and Highway 95 from the Canadian Border to the southern tip of our
15 l. lntesrated Chareins.
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7Application of Avista Corporation
1 senrice territory) and a variety of other public and commercial locations in both
urban and rural locations where chargrng infrastructure is strategically important.
Finally, a distribution of chargrng stations less reliant on the grid could prove
especially beneficial in terms of community resiliency in the wake of power
outages, particularly in the future when a high percentage of transportation is
electrified.
The Company proposes the following: (1) to develop and implement a
research project and report summarizing the current state of integrated stations,
(2) develop a parametric model used to identiff variable cost factors and resulting
charging outputs on an ongoing basis, and (3) a construction project design and
implementation plan with estimated costs and benefits, which may be executed in
the future provided funding from grant and other contibuting funds, or at such
time that economic thresholds are met. The Company intends to collaborate and
solicit assistance from local research institutions and industry experts, developing
knowledge and contributing to the general body of knowledge in the industry,
with $50,000 proposed annually for the research project.
2. Workplace. Fleet. and Rural Access Chareing Infrastructure
This program makes it easy and less costly for commercial customers to
install workplace and/or fleet charging infrastructure on their property, for a
variety ofbeneficial uses, and provides significant benefits in overcoming barriers
to early adoption and enables Avista to develop load management capabilities.
Low-cost and reliable chargrng infrastructure would be installed by Avista, with
customers contributing a minimum cost share of 50%o of the dedicated circuit
wiring from their electric supply panel downstream of the utility meter, to the EV
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8Application of Avista Corporation
I chargers.
Charging infrastucture installed at locations designated for public rural
access utilization would not require a customer cost share, as the specific site hosts
in the smaller rural towns across Avista's service territory may be limited in
means, which would be a significant barrier to adoption. In all cases, commercial
customers would pay for the additional electricity supplied by their existing
metered service to the EV chargers on their rezular monthly bill, with options to
collect user/usage fees to help offset modest electricity costs and agree to
participate in load management experiments.
Charging infrastructure is proposed to be installed at an estimated 30 sites
per year, broken down by 20 workplace, 5 fleet, and 5 rural access locations, at
an estimated cost of $345,000. Ongoing maintenance and load managanent costs
are estimated at $15,000 peryear. The Company intends to verifu thatworkplace
charging stands out as a powerful catalyst for EV adoption, while simultaneously
providing grid benefits from reduced EV charging at home during the evening
peak hours.
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l8 IV. BUDGET AI\D REPORTING
l9 The Company proposes to fund the programs under its electric tariffSchedule 91,
20 as they will be provided under the Market Transformation Program and associated
2l Research and Development (R&D) outlined in tariff Schedule 90.6 In its Order No.
6 On August 30, 2013, Avista applied for an order authorizing it to accumulate and account for customer
revenues that provided funding for selected electric energy efficiency research and development (R&D)
projects, proposed and implemented by the state of Idaho's four-year Universities. On October 31,2013,
Order No. 32918 was issued authorizing the Company's R&D efforts. Avista now recovers up to $300,000
per year of revenue for research R&D from the Company's Schedule 9l Energy Efficiency Rider tariff.
9Application of Avista Corporation
| 35129, atpage 9, (the Company's request for a prudency determination of its 2018-2019
2 electic and natural gas energy efficiency), the Commission stated "that the Company
3 may continue with its R&D programs that it has already committed to fund but before
4 committing to future R&D progftrms the Company shall propose and seek approval of an
5 updated R&D program that includes metrics and measurable targets."
6 As provided earlier in this application, and in support of the Commission's Order
7 referenced above, the intent of these programs is meant to be scalable given the multiple
8 technology and program options. These proposed programs will provide experience in
9 Idaho and the ability to examine cost-effectiveness and customer acceptance, thereby
l0 better defining systan and infrastructure requirernents, and assessing costs/benefits.
1l Total annual spending is estimated at $410,000. Avista is not requesting an
12 additional change in the Schedule 91 funding, Avista's tariff Schedule 9l is o'trued up"
l3 on a regular basis to match revenues with expenses.
14 Table No. 1
Activity Capital o&M Total
Workplace, Fleet, and Rural Access Charging
Infrastructure $345,000 $15,000 $360,000
Integrated Charging, On-site Renewables, and
Battery Storase Research $50,000 $50,000
Total $345.000 $65,000 $410,000
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16 Financial reporting will be included in Avista's annual Demand Side Management
17 (DSM) Report due to the connection ofboth DSM, Market Transformation, and the R&D
18 programs to Schedule 91. Given the desire to implement these programs within the
19 market transformation and research and development defined in Avista Tariff Schedule
20 90, the reports will not be accompanied by the traditional cost-effectiveness tests. Avista
2l hosts semi-annual energy efficiency Advisory Group meetings plus webinars on current
Application of Avista Corporation l0
I topics of public interest, attended by the Commission Staff, among other interested
2 stakeholders. The Company will include electric transportation activities on the regularly
3 scheduled meeting agendas.
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5 V. CUSTOMER NOTIFICATION
6 Notice to the public of the proposed revisions, pursuant to IDAPA 31.21.02.102,
7 will be gtven simultaneously with the filing of this Application by posting a notice to the
8 Company's Website at www.myavista.com.
9
VI. CONCLUSION
Avista respectfully requests the Commission issue an Order authorizing the
electic transportation programs described herein. The Company proposes to offer and
fund these programs under electric tariff Schedule 90 and Schedule 91, effective
Noverrber 1,2021, with this Application processed under Modified Procedure through
the use of written comments.
Dated at Spokane, Washington this 9th day of Septembq 2021.
AVISTA CORPORATION
/s/ David J- Mever
David J. Meyer
Vice President and Chief Counsel for
Regulatory and Governmental Affairs
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Application of Avista Corporation 1t