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Home My WebLink About20240222Comments_2.pdf Idaho Public U�li�es Commission 11331 W. Chinden Boulevard, Building 8, Suite 201-A Boise, ID 83720 Re: Avista Filing for DC Fast Charging Tariﬀ for EVs (Sched. 23 proposal), Case# AVU-E-23-16 Dear Commission Secretary: We strongly support the proposal that Avis Corpora�on recently ﬁled with the Commission to oﬀer a revised rate design for commercial customers engaging in DC fast charging of electric vehicles (EVs). Since this industry is s�ll in a nascent stage with low u�liza�on of these charging assets, tradi�onal demand charges become a major barrier to successful use of EVs with adequate and reliable charging infrastructure. Many other u�li�es and state Commissions in every region of the country have developed demand charge mi�ga�on rates and measures, with Commission approval, that address these issues while preserving cost-of-service studies and not spreading undue costs to other customers or classes. We believe that Avista’s proposal achieves this goal through a straigh�orward and fairly simple rate design which commercial customers, such as auto dealers or private EV charging providers, can understand and implement in their business models. General points Despite what one may be reading in the press and social media, EV sales grew substan�ally na�onally (about 50% year-to-year) in 2023, which include both full batery electric vehicles (BEVs) and plug-in electric vehicles (called “PHEVs”). Idaho as a state is not as far along in the EV adop�on curve as other states, but with the introduc�on of pick-up trucks (such as the Ford F-150 Lightning) and other light trucks in addi�on to the SUVs and sedans, adop�on is increasing in Idaho as well. Increasing EV adop�on is coming to Avista’s service territory in northern Idaho. The broad industry trends are toward lower price points (recognizing the earlier EVs entered the market at higher price points) and lower batery prices due to increasing scale. The electriﬁca�on of transporta�on marks a major change in key industries like automobile, auto parts and services, auto dealers, energy supply and distribu�on, and EV charging providers (both host sites/landlords and network operators). ATE believes that each of these major industrial sectors needs to change and adjust as EVs become more prevalent in scale. Si�ng and building infrastructure for EV charging is one such challenge that poses obstacles, whether the use case be residen�al, commercial, workplace, or publicly accessible charging loca�ons along highway corridors or metropolitan areas. Each use case is unique and diﬀerent, but it requires a strong role for the regulated u�lity in several areas: good program design, sound rate design based on cost-of-service principles, educa�on and outreach to key accounts and customers, and eﬃcient interconnec�on policies. RECEIVED Tuesday, February 20, 2024 4:06PM IDAHO PUBLIC UTILITIES COMMISSION While certain grants and incen�ves are available from federal and state agencies, the costs of designing, building, and most importantly, opera�ng EV charging facili�es with electric power supplied by the distribu�on grid of the u�lity are quite high in this nascent phase of growth. If u�liza�on of charging sta�ons is low in these early days of growth, the energy costs (today mostly demand charges depending on the type of charger and number of sessions per month) will o�en be the highest opera�ng cost. Speciﬁcs points Many other u�li�es in other jurisdic�ons or their Commissions have authorized or developed demand charge mi�ga�on measures. We have writen three white papers on these topics, with Paper #2 focused on the variety of demand charge mi�ga�on op�ons. They include peak demand limiters (through a credit); a sliding scale discount based on u�liza�on; a cost-of-service based rate without a demand charge (e.g., low load factor customers like irriga�on districts, or certain industrial customers). All of these mechanisms recognize that these EV charging facili�es opera�ng for the public or for their own beneﬁt are at this stage low load factor customers. Avista’s ﬁling reﬂects some of these best prac�ces by dele�ng the tradi�onal demand charge, and pu�ng more of those costs into the basic charge, among others. The following are a few brief comments on the speciﬁc elements: • The expected low load factor (calculated either monthly or yearly) should be a key determinant for the Commission when examining this proposed Schedule 23 tariﬀ, and the evidence; • Although we are s�ll in the early days of development, there is ample evidence on the high and some�mes prohibi�ve cost that these demand charges pose to customers; • To minimize the “cost-shi�ing”, the u�lity can either shi� ﬁxed costs to the basic charge, or increase the energy (volumetric, or per kwH) rates. • Avista has made a sensible choice here in increasing the basic charge for a commercial customer to $500 per month, while maintaining the per kwH (energy charges) • The evidence in the ﬁling demonstrates that this will oﬀer substan�al savings to the operator/customer of the EVSE equipment, or the commercial customer, as demonstrated in the applica�on submited by Mr. Meyer in this docket, • Avista has created a separate class for this type of commercial (Schedule 23), which will segregate these costs and beneﬁts in a class, • Avista will update this tariﬀ, as appropriate, during future rate cases as a new cost-of-service study with revisions may be carried out for a future general rate case, which may reﬂect changes in cost alloca�on or rate spread. In summary, ATE believes that Avista’s proposal is both balanced and straigh�orward and atempts to address legi�mate challenges in the EV market today while recognizing tradi�onal cost-of-service principles that should be sustained over �me. Sincerely, Philip B. Jones Philip B. Jones, Execu�ve Director Alliance for Transporta�on Electriﬁca�on (ATE) 1402 Third Avenue, Suite 1315, Seatle, WA 98101 Kathy Knoop, Manager Electric Vehicle Infrastructure Policy Global Public Policy General Motors Global Headquarters MC : 482-C30-B36 300 Renaissance Center Detroit, MI 48265-3000 Phone : 602-820-7483 Email : kathy.knoop@gm.com February 20, 2024 Monica Barrios-Sanchez, Secretary Idaho Public Utilities Commission 11331 W. Chinden Blvd. Bldg. 8, Ste. 201-A Boise, Idaho 83714 secretary@puc.idaho.gov Re: Case No. AVU-E-23-16 (Avista) General Motors (GM) Support for the Avista Utilities application requesting the Company to establish a new tariff Schedule 23 for Direct Current Fast Charging (DCFC) of electric vehicles Dear Ms. Barrio-Sanchez, I am writing on behalf of General Motors LLC (GM) to express our staunch support for Avista Utilities' application to the Commission seeking approval for Electric Tariff Schedule 23, "Direct Current Fast Charging (DCFC) Rate Option". GM is a leader in developing the market for plug-in electric vehicles (PEVs) and is helping to realize the grid benefits of widespread transportation electrification. Automakers – including GM – are investing billions of dollars in electric vehicle technologies and are also working on innovative programs to facilitate market development. Examples of this work include extensive efforts to facilitate infrastructure deployment and expose more people to electric vehicles. Electricity rates are central to these transportation electrification efforts. PEVs represent a fundamentally different type of load and it is increasingly clear that targeted rates are needed. By affecting the cost of charging, smart rate design can: help build consumer interest in PEVs by ensuring cost savings compared with gasoline; facilitate infrastructure deployment; and enable sustainable models for EV deployments in new mobility and fleet applications. Throughout the nation, regulatory commissions are increasingly approving utility electric vehicle (EV)- specific rates to foster accessible and equitable EV charging solutions. Avista's proposed rates (Electric Tariff Schedule 23) not only aim to facilitate the growth of affordable public DCFC but also play a crucial role in supporting auto dealerships in Idaho. These dealerships, including 24 GM affiliated dealerships, must charge both new EVs for sale and those undergoing maintenance, typically with a DCFC. GM has seen elevated initial energy expenses confronting its dealerships in Idaho. The existing Avista commercial electric rate linked to DC fast charging incurs exorbitant overall costs per kilowatt-hour (kWh), primarily due to low utilization and steep demand charges. Employing the current commercial electricity rate with demand charges disproportionately affects dealerships that may only have a few EVs charging per month, yet the resulting costs soar for charging an extremely limited number of electric vehicles. This financial strain is unsustainable for these small businesses. RECEIVED Wednesday, February 21, 2024 12:46PM IDAHO PUBLIC UTILITIES COMMISSION - 2 - February 20, 2024 Nationally, utilities are actively formulating rates tailored to DCFC, underscoring the importance of creating such structures to bolster the expansion of the EV market. Beyond supporting our dealerships, GM is collaborating with Pilot company 1 to install DCFC stations for public use across the US as well as in Idaho. Approval of the proposed rate will significantly improve the business model to expand public charging in Idaho and keep rates affordable for drivers. In states like Idaho, where the EV market is still emerging, supportive policies for both vehicles and charging infrastructure are crucial for sustained growth. GM is committed to advancing EV adoption, a key objective as we strive toward a zero-emission future, exemplified by our development of compelling EVs like the Silverado EV. Drawing inspiration from the success of states and utilities implementing innovative rate designs to accelerate the EV market, GM is pleased to endorse Avista's proposal in the current rate application. Thank you for considering our support for Avista Utilities' initiative, which aligns with our shared vision for a sustainable and thriving EV ecosystem. Respectfully submitted, Kathy Knoop Kathy Knoop Manager, EV Infrastructure Policy General Motors, LLC kathy.knoop@gm.com .cc David J. Meyer, Esq. Vice President and Chief Counsel for Regulatory & Governmental Affairs 1411 E. Mission Ave., MSC 13 Spokane, WA 99220-3727 david.meyer@avistacorp.com Patrick Ehrbar Director of Regulatory Affairs 1411 E. Mission Ave., MSC 27 Spokane, WA 99220-3727 patrick.ehrbar@avistacorp.com dockets@avistacorp.com 1 https://news.gm.com/newsroom.detail.html/Pages/news/us/en/2022/jul/0714-gmpilot.html