20241017Clearwater_Sofidel - Reply Comments.pdf

RECEIVED
Thursday, October 17,2024
IDAHO PUBLIC
UTILITIES COMMISSION
I Peter Richardson, ISB 3195
RICHARDSON ADAMS, PLLC
2 515 N. 27"' St.
Boise, ID 83702
3 Telephone: [phone]
Email: peter a richardsonadams.com
4
5 C. Tom Arkoosh
ARKOOSH LAW OFFICES
6 913 River Street, Ste. 450
Boise, ID 83701
7 T'om.arkoosh a arkoosh.com
Lrin.cecil arkoo5_h.corn
8
Attorneys for Clearwater Paper Corporation
9 and Sofidel America Corporation
10
I I BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
12
13 IN THE MATTER OF THE JOINT APPLICATION OF Case No.: AVU-E-24-12
CLEARWATER PAPER CORPORATION, AVISTA
14 CORPORATION AND SOFIDEL AMERICA
CORPORATION FOR A TEMPORARY WAIVER OF
IS REPLY COMMENTS OF CLEARWATER PAPER
MASTER-METERING RULES FOR ELECTRIC
CORPORATION AND SOFIDEL AMERICA
16 UTILITIES CORPORATION
17 COMES NOW, Clearwater Paper Corporation ("Clearwater")and Sofidel America Corporation
18 ("Sofidel")and file their joint Reply Comments to the Comments of the Commission Staff in the above captioned
19 matter. These Reply Comments are filed pursuant to the Commission's Notice of Application and Notice of Petition
20 and Notice of Modified Procedure issued in Order No. 36342 on October 3,2024, requiring any Reply Comments to
21 be lodged no later than October 18, 2024.
22 Clearwater and Sofidel appreciate the Commission Staffs thoughtful and thorough comments
73 recommending Commission approval of their requested temporary waiver of Avista's Tariff prohibiting master-
24 metering of electric service. While noting, in general, that the method Clearwater will use to bill Sofidel is
25 "reasonable", Staff did express concern that possible"billing discrepancies"could arise regarding how the
26 Minimum Demand Charge under Schedule 25P will be allocated. Staff also expressed concern regarding billing
27
28 REPLY COMMENTS OF CLEARWATER PAPER CORPORATION AND SOFIDEL AMERICA
CORPORATION - I

I discrepancies that may result from the possibility that peak demands may not be coincident and how such non-
2 coincident peak demands will be allocated and measured.
3 Clearwater and Sofidel are working to provide a workable and reasonable solution to Staffs
4 concerns and are doing so in consultation with Avista. A compliance tiling clarifying how Staffs concerns will be
5 addressed will be timely tiled in response to the Commission's directive which is expected to be issued shortly.
6 Dated this 171"day of October 2024.
7
9 Peter Richardson
Attorney for Clearwater Paper Corporation
10 //SS//
C. Tom Arkoosh
I I Attorney for Sofidel America Corporation
12
13 CERTIFICATE OF SERVICE
14 1 hereby certify that I have on this 18"' day of October 2024, served the foregoing Reply
15 Comments of Clearwater Paper Corporation, and Sofidel America Corporation in case no AVU-E-24-12
by emailing a copy thereof to the following:
16
17 Chris Burdin
Deputy Attorney General
18 Idaho Public Utilities Commission
PO BOX 83702
19 BOISE, IDAHO 83702-0074
C hris.burdinQ,puc.idaho.gov
20 Secreta!y(t�i puc.idaho.gov
21
David J. Meyer, Esq.
2-) Avista Corporation
1411 E. Mission Street, MSC-27
23 P.O. Box 3727
Spokane, WA 99202-3727
24 David.mqycr c avista, core eom
[e-mail]
25
26 By:
Peter Richardson
27
78 REPLY COMMENTS OF CLEARWATER PAPER CORPORATION AND SOFIDEL AMERICA
CORPORATION - 2