20231103CL_Application.pdf

Avista Corp.
1411 East Mission P.O. Box 3727
Spokane. Washington 99220-0500
Telephone [phone]
Toll Free 800-727-9170
November 3, 2023
Jan Noriyuki, Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd. Bldg. 8, Ste. 201-A
Boise, Idaho 83714
RE: Case No. AVU-E-23-__
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 establish a new
tariff Schedule 23 for Direct Current Fast Charging (DCFC) of electric vehicles as outlined in
the attached Application.
Please direct any questions regarding this filing to Rendall Farley at 509-495-2823
([e-mail]) or me at 509.495.4584 ([e-mail]).
Sincerely,
/s/ Paul Kimball
Paul Kimball
Manager of Compliance & Discovery
Enclosure
RECEIVED
Friday, November 3, 2023 3:01:31 PM
IDAHO PUBLIC
UTILITIES COMMISSION
16
DAVID J. MEYER
VICE PRESIDENT AND CHIEF COUNSEL FOR
REGULATORY AND GOVERNMENTAL AFFAIRS
AVISTA CORPORATION
P.O. BOX 3727
1411 EAST MISSION AVENUE
SPOKANE, WASHINGTON 99220-3727
TELEPHONE: [phone]
[e-mail]
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF
AVISTA CORPORATION, D/B/A AVISTA
UTILITIES, REQUESTING AUTHORITY TO
ESTABLISH TARIFF SCHEDULE 23 FOR DIRECT
CURRECT FAST CHARGING (DCFC) OF
ELECTRIC VEHICLES
)
)
)
)
)
)
CASE NO. AVU-E-23-___
APPLICATION OF AVISTA
CORPORATION
APPLICATION OF AVISTA CORPORATION
16

Application of Avista Corporation
Case No. AVU-E-23-___ Page 1
I. INTRODUCTION
Avista Corporation, doing business as Avista Utilities (hereinafter “Avista” or
“Company”), at 1411 East Mission Avenue, Spokane, Washington, pursuant to Section 61-524
Idaho Code and Rule 52 of the Idaho Public Utilities Commission (“Commission Rules of
Procedure”), hereby applies to the Commission for an order authorizing the approval of a proposed
electric tariff Schedule 23, “Direct Current Fast Charging (DCFC) Rate Option”, effective
February 1, 2024.
Avista is a utility that provides service to approximately 406,000 electric customers and
373,000 natural gas customers in a 26,000 square-mile area in northern Idaho, eastern Washington,
and Oregon. The largest community served by Avista is Spokane, Washington, which is the
location of its corporate headquarters.
The Company requests that this filing be processed under the Commission's Modified
Procedure rules through the use of written comments.
Communications in reference to this Application should be addressed to:
David J. Meyer, Esq. Patrick Ehrbar
Vice President and Chief Counsel for Director of Regulatory Affairs
Regulatory & Governmental Affairs Avista Corporation
Avista Corporation 1411 E. Mission Avenue, MSC 27
1411 E. Mission Avenue, MSC 13 Spokane, Washington 99220-3727
Spokane, Washington 99220-3727 Telephone: [phone]
Telephone: [phone] E-mail: [e-mail]
E-mail: [e-mail] E-mail: [e-mail]

A table of contents for this Petition follows:

Description Page
I. Introduction 1
II. Background 2
III. DCFC Rate Design 6
IV. Request for Relief 9

Application of Avista Corporation
Case No. AVU-E-23-___ Page 2
II. BACKGROUND
Transportation electrification (TE) is accelerating around the world and in the U.S.,
due to a number of factors.1 Over time, this transition will provide substantial economic and
environmental benefits, as a result of significantly lower operating and fuel costs for
transportation, major reductions in air pollution, and increasing net utility revenue that
benefits all electric customers. Today, driving a light-duty electric vehicle (EV) fueled by
Avista’s electricity costs less than an equivalent $1 per gallon of gasoline, saving an average of
$1,772 in fuel costs and $300 per year in maintenance expenses, and resulting in zero tailpipe
emissions with total CO2 emission reductions of 77%.2 If all 1,681,500 light-duty gasoline and
diesel vehicles in Idaho were electric, this would result in regional savings of $3.5 billion per year
– creating a positive ripple effect for the economy – and avoided annual emissions of 7.2 million
tons of CO2 using local energy sources.3 Other forms of electrified transportation beyond light-
duty passenger vehicles, including medium- and heavy-duty on-road vehicles, and a number of
off-road passenger and freight applications, could result in even greater operational savings and
lower air pollution across the state.
In addition, electric transportation provides grid benefits for all utility customers, in the
form of net positive revenue that helps pay for fixed utility infrastructure costs. By 2050,
electric transportation may represent 20% or more of overall utility electric load, as indicated
by the National Renewable Energy Laboratory.4 In the case of light-duty EVs, modeling

1 Electric Vehicle Outlook 2023, Bloomberg New Energy Finance. Accessed at https://about.bnef.com/electric-
vehicle-outlook/
2 Choose EV Calculator Tool, accessed at https://www.myavista.com/energy-savings/electric-transportation/for-
your-home; estimates assume Avista’s current mix of electric generation sources, 3.5 miles/kWh and $0.091/kWh
for EVs, and $3.91/gallon, 26 mpg for conventional vehicles.
3 Alternative Fuels Data Center, Vehicle Registration Counts by State, accessed at https://afdc.energy.gov/vehicle-
registration
4 Electrification Futures Study: Scenarios of Electric Technology Adoption and Power Consumption for the United
States, p. xiv. National Renewable Energy Laboratory, 2018.

Application of Avista Corporation
Case No. AVU-E-23-___ Page 3
indicates that each EV provides positive net benefits both from a regional and a customer rate-
impact perspective, which may be further amplified when charging off-peak, as shown in Figure
No. 1 below.
Figure No. 1 – Net Benefits from Light-Duty EVs5

Idaho has a lower rate of EV adoption compared to the U.S. average but nevertheless
is expected to increase in the future as the overall market matures and accelerates, and certain
barriers such as the upfront cost and availability of EVs and charging infrastructure improves.6
Regarding charging infrastructure, 95% of EV charging may be done very inexpensively and
with a minimum of charging infrastructure costs, at home or at work in the case of personal
vehicles, or at a commercial facility in the case of fleet vehicles. In these instances, AC Level
2 equipment is often utilized which operates at 240V and delivers 7kW power or less while
charging. However, approximately 5% of charging will occur utilizing public chargers, of
which direct current fast chargers (DCFC) are especially important to enable longer distance

5 Avista Economic and Grid Impact Study (2018)
6 See https://www.atlasevhub.com/materials/state-ev-registration-data/

Application of Avista Corporation
Case No. AVU-E-23-___ Page 4
trips.7 Today’s DCFC generally require access to high voltage, 3-phase utility electricity
supply, and deliver 150kW or more power levels – resulting in much higher installation costs,
typically over $200,000 per DCFC site. DCFC along travel corridors and in more populated
areas is critical to serving Idaho customer needs and enabling beneficial EV market growth.8
Northern Idaho currently has nine DCFC sites in operation,9 compared to an estimated
1,800 DC fast charging port connections required to support 200,000 EVs in Idaho by 2030.10
However, in areas of low EV adoption and utilization of DCFC such as in northern Idaho,
private investment is lacking due to the long timeline required to recover investments in
DCFC, let alone earn any reasonable returns on the investments. In order to enable market
transformation and service Idaho customers, public investments in the form of federal grants
are currently available to offset the costs of DCFC equipment and installation partially or
fully.
However, ongoing operating costs for electricity, equipment maintenance and repair,
and site upkeep are typically not covered by grants and must be borne by the owner-operator
of the DCFC. This presents a problem as the operating costs typically are much higher than
the revenue acquired from DCFC user-fees, primarily due to existing utility rates structures
that result in high variable demand charges on a customer’s monthly bill. The table below
illustrates an example DCFC where the owner-operator incurs negative net revenue as a result

7 Consumer Guide to Electric Vehicle Charging. Electric Power Research Institute (2019). Accessed at
https://www.epri.com/research/products/000000003002016961
8 “The 2030 National Charging Network: Estimating U.S. Light-Duty Demand for EV Charging
Infrastructure,” pp. v-x. National Renewable Energy Laboratory (2023). Accessed at:
https://driveelectric.gov/files/2030-charging-network.pdf
9 see www.plugshare.com
10 “The 2030 National Charging Network: Estimating U.S. Light-Duty Demand for EV Charging
Infrastructure,” p. 43. National Renewable Energy Laboratory (2023). Accessed at:
https://driveelectric.gov/files/2030-charging-network.pdf

Application of Avista Corporation
Case No. AVU-E-23-___ Page 5
of operating a public DCFC.11

Table No. 1 – Example Monthly DCFC Operator Costs and Revenue in Idaho on Avista’s
Rate Schedule 11

Average No. of Charging Sessions per Month 30
Energy Consumption 900 kWh
Max Electricity Power Demand for the DCFC Site 180 kW
Monthly Electricity Bill - Basic Charge $18.00
- Energy Charge $84.15
- Demand Charge $1,040.00
Other Operating Costs (Networking/Comms, Maintenance, etc) $150.00
Total Monthly Operating Costs $1,292.15
User Fee Rate $0.45/kWh
User Fee Revenue $405.00
Net Monthly Revenue (Cost) ($887.15)

Using current rate schedules, the example DCFC operator must achieve an average of
four charging sessions per day just to break-even on direct operating costs. This level of
utilization is uncertain and therefore owner-operators are likely to incur direct losses of nearly
$1,000 or more per month for a long period of time. In this situation, private enterprises are
greatly discouraged from owning and operating DCFC, even if the site acquisition and
construction costs are covered by federal grants. As demand charges represent nearly 80% of
the total operating cost, this barrier to investment and operation may only be addressed by a
new utility rate structure that is better suited to accommodate DCFC operation while
supporting reasonable utility cost recovery. Such an improvement will further the interests of
attracting capital funding and supporting a network of reliable DCFC in Idaho that is critical
to achieving market growth and the significant economic and environmental benefits it will
enable.

11 this example is based on a customer’s monthly electricity bill and user-fee revenue as reported by the customer
operating a DCFC on rate schedule 11, at a moderate utilization level

Application of Avista Corporation
Case No. AVU-E-23-___ Page 6
III. DCFC RATE DESIGN
In order to achieve the objective of supporting a reliable network of DCFC in North
Idaho, the Company proposes a new optional commercial EV rate schedule primarily as a way
to address the significant market barrier associated with high variable demand charges in
existing rates. The EV rate schedule for general service (Schedule 23) customers will encourage
greater investment in public DCFC, while also continuing to recover utility costs through a
higher per kWh charge.
In a 2018 study of 51 EV rate options from 21 electric utilities in the U.S., it was found
that relatively few rate options were available to commercial customers, and that additional on-
peak energy charges without demand charges, combined with monthly fixed charges and
seasonal adjustments were most common.12 In the last few years, a number of new commercial
EV rate schedules have been proposed and/or approved, for example Pacific Gas and Electric’s
Business EV rate plans,13 Portland General Electric’s Schedule 53 for heavy-duty EV
charging,14 and a number of other rate designs such as for Dominion Energy, DTE Energy,
Florida Power & Light, and Xcel Energy.15 In Washington, Pacific Power was approved for an
optional rate applicable to public DCFC sites with less than 1 MW maximum demand,16 and
Avista received approval for its commercial EV Time-of-Use (TOU) rate in 2021.
Avista proposes optional commercial EV rate schedule 23 for DCFC charging general
commercial service. In addition to the fixed demand charge, the Company proposes to increase the

12 “Review and Assessment of Electric Vehicle Rate Options in the United States.” EPRI Report 3002012263
(2018).
13 See https://www.pge.com/en_US/small-medium-business/energy-alternatives/clean-vehicles/ev-charge-
network/electric-vehicle-rate-plans.page
14 PGE Advice No. 21-03, February 10, 2021.
15 “Electric Transportation Rate Design Principles for Regulated Utilities.” p. 19. Alliance for Transportation
Electrification (2021).
16 PacifiCorp Advice No. 18-03, September 6, 2018.

Application of Avista Corporation
Case No. AVU-E-23-___ Page 7
per kWh charge and eliminate the variable demand charge for this new rate schedule. The table
below details a comparison of both the existing Schedule 21 base rates and the proposed
Schedule 23 DCFC base rates.
Table No. 2 – Schedule 21 and 23 Base Rate Comparison
Monthly Bill Component Schedule 023 Schedule 021
Fixed demand charge $ 500.00 $ 500.00
Demand charge over 50 kw $ 0.00 $ 6.50
First 250,000 kWh $ 0.08509 $ 0.07135
Over 250,000 kWh $ 0.07386 $ 0.06012

The calculations of the increase in the per kWh charge for Schedule 23 base rates were
derived from the billing determinants and base rates associated with rate Schedule 21 from the
Company’s most recent general rate case filing (AVU-E-23-01), the same rate schedule a large
new DCFC customer would likely take service from absent the approval of this new rate
schedule. 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. The Company
derived the increase in the per kWh rate by taking the total variable demand revenue for
Schedule 21 and dividing it by the first block usage for all Schedule 21 customers. This rate
design will remove the variable demand charge barrier that exists for DCFC customers today
until such time that the Company deploys new AMI meters in Idaho which will then allow the
Company to offer other rate design options such as TOU rates.
Schedule 23 base rates are proposed to be shown as a stand-alone rate class for purposes
of cost of service studies and rate spread and rate design proposals in future general rate case
filings. Schedule 23 base rates will be updated based on approved Schedule 21 rates, and any
future modifications to the pricing of these new rate schedules will be evaluated in the context

Application of Avista Corporation
Case No. AVU-E-23-___ Page 8
of a future general rate case filing. The full calculation of the proposed rates for Schedule 23
have been provided as workpapers to this filing.
Commercial EV rate schedule 23 will be subject to the same adder schedules (DSM,
PCA, FCA, etc.) and miscellaneous charges consistent with existing schedule 21, which will
similarly change over time in accordance with regular system-wide adjustments. The new EV
rate schedules will be made available to commercial customers, provided that EV charging
loads are metered separately from other facility loads and peak demand does not exceed 1 MW.
Above this threshold, it must be demonstrated that all reasonable measures are being taken to
mitigate impacts and required upgrades to the local distribution grid as a condition of utilizing
the EV rate, and load management will be required where practical.
The proposed rates provide reasonable recovery of utility costs based on a simple flat
rate for energy charges, while eliminating demand charges that currently inhibit market growth.
In this way, they establish easily understood and sensible electric billing rates, encouraging
early and sustained third-party ownership of public DC fast charging. In addition, the proposed
rates provide a significant benefit to customers. Table No. 3 below compares the example from
Table No 1 above if the proposed rates are approved.
Table No. 3 – Example Monthly DCFC Operator Costs and Revenue in Idaho on Avista’s
Rate Schedule 11 compared to proposed Rate Schedule 23
Schedule 11 Schedule 23
Average No. of Charging Sessions per Month 30 30
Energy Consumption 900 kWh 900 kWh
Max Electricity Power Demand for the DCFC Site 180 kW 180 kW
Monthly Electricity Bill - Basic Charge $18.00 $500.00
- Energy Charge $84.15 $76.58
- Demand Charge $1,040.00 $0.00
Other Operating Costs (Networking/Comms., Maint., etc) $150 $150.00
Total Monthly Operating Costs $1,292.15 $726.58
User Fee Rate $0.45/kWh $0.45/kWh
User Fee Revenue $405.00 $405.00
Net Monthly Revenue (Cost) ($887.15) ($321.58)

Application of Avista Corporation
Case No. AVU-E-23-___ Page 9
A relatively small number of customers are expected to adopt this optional rate schedule
over the next few years. However, it may still be effective in removing a key market barrier to
early adoption, while also providing a means to acquire utilization and cost data to inform
revisions to the commercial EV rate schedules in the future.
IV.REQUEST FOR RELIEF
WHEREFORE, Avista respectfully requests that the Commission issue a final Order
authorizing the Company to establish tariff Schedule 23, “Direct Current Fast Charging (DCFC)
Rate Option” on February 1, 2024. The Company requests that the matter be processed under the
Commission’s Modified Procedure rules through the use of written comments.
DATED at Spokane, Washington, this 3rd day of November 2023.