20241217Compliance Filing.pdf

RECEIVED
Peter Richardson, ISB Tuesday, December 17, 2024#3195 IDAHO PUBLIC
5 15 N. 2 7'DSON ADAMS, PLLC UTILITIES COMMISSION
5 15 N. �' St.
Boise, ID 83702
Telephone: [phone]
Email getei�&richardsonadams.com
Counsel for Clearwater Paper Corporation
C. Tom Arkoosh, ISB #2253
ARKOOSH LAW OFFICES
913 W. River Street, Suite 450
P.O. Box 2900
Boise, Idaho 83701
Telephone: [phone]
Fax: [phone]
Email: [e-mail] Admin
copy: [e-mail]
Counsel for Sofidel America Corp.
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE JOINT PETITION OF Case No. AVU-E-24-12
CLEARWATER PAPER CORPORATION, AVISTA
CORPORATION AND SOFIDEL AMERICA CORP.
FOR APPROVAL OF A CONTRACT TEMPORARILY JOINT COMPLIANCE FILING BY CLEARWATER
WAIVING AVISTA'S PROHIBITION AGAINST PAPER CORPORATION AND SOFIDEL AMERICA
MASTER-METERING ITS ELECTRIC SERVICES CORP.
COMES NOW, Clearwater Paper Corporation and Sofidel America Corp. (herein collectively the
"Parties"or each individually a"Party"or"Clearwater"or"Sofidel," respectively)and, pursuant to Order No.
36371 issued in the above captioned matter by the Idaho Public Utilities Commission ("Commission"or"IPUC")on
October 28, 2024,jointly submit this compliance filing regarding demand charge billing discrepancies.
1.
BACKGROUND
On September 20,2024,the Parties filed a Joint Petition with the Commission for approval of a contract
between Sofidel and Clearwater providing for a temporary waiver of Avista's tariff prohibiting master-metering of
electric services. As recited by the Commission in Order Nol 36371:
JOINT COMPLIANCE FILING BY CLEARWATER PAPER CORPORATION AND SOFIDEL AMERICA
CORP. - I

The Parties represented that Clearwater has entered into an agreement("Agreement') to sell its
Consumer Products Division(the Tissue Plant') to Sofidel. Petition at 2. The Parties staled that each
company would separately contract with Avista for the provision of electric power and energy pursuant to
Avisla's approved larif�s; however, because the current electrical infrastructure was designed and
constructed to serve an integraled single entity, it was not currently physically possible for Avista to
separately meter and serve the Tissue Plant as an individual customer Id. at 2-3. The Parties indicated
that it may lake up to three years for Avista to construct the required Infrastructure to provide separate
metering to the companies. Id. at 3.
The Commission processed the Petition pursuant to its modified procedure rules. After duly considering comments
filed by the PUC Staff and separate Reply Comments filed by Clearwater, Sofidel and Avista,the Commission
approved the Petition by Order No. 36371 issued on October 28,2024. The Commission, in Order No. 36371, inter
alia, ordered the Parties to:
submit a compliancefiling by December 31, 2024, clarifying how demand charge billing discrepancies will
be resolved.
Clearwater and Sofidel herein provide their joint clarification as to how demand charge billing discrepancies will be
resolved pending Avista's completion of the required infrastructure to provide separate metering services for Sofidel
and Clearwater.
11.
DEMAND CHARGE BILLING DISCREPANCY
1. Billing Discrepancies are a Very Remote Possibility
The internal metering and monitoring equipment(herein "Meters")being used by Clearwater and Sofidel to
measure billing demand by the Tissue Plant(now wholly owned by Sofidel) is,and has been at all relevant times, in
place and operational. The Meters have been in place for many years and in that time have been relied on by
Clearwater for parsing internal billing and accounting allocations. The Meters have proved to be extremely reliable,
are regularly maintained, and are subject to audit by both Clearwater and Sofidel,thus billing discrepancies are not
anticipated.
2. Dispute Resolution Process—the Lewiston Complex Committee and Demand Billing Process
Clearwater and Sofidel have established a mechanism to address shared services and integration issues such
as potential, albeit unanticipated,electric service demand billing discrepancies via the"Lewiston Complex
JOINT COMPLIANCE FILING BY CLEARWATER PAPER CORPORATION AND SOFIDEL AMERICA
CORP. -2

Committee: Site Shured Services Committee"(herein the"Committee"). The Committee is constituted for the
purpose of resolution of issues that may arise in connection with the provision and receipt of shared
services/facilities at the Lewiston Complex inclusive of utility-type services such as water,sewage, steam and fire
protection. The sub-metering provision of electric demand and energy is one such service. It should be noted that
there is currently no discrepancy or dispute relative to the electric demand billing process between Sofidel and
Clearwater. That process utilizes the Commission approved demand rates in Avista's Clearwater tariff. Sofidel's
electric demand(kva) is charged in such a manner so as to mirror the demand billing that Sofidel will experience
after Avista assumes its responsibility For providing metering and billing services to the Sofidel plant. As noted
above,there is no dispute as to the billing process, however, as with any of the other shared services noted above,
should a billing discrepancy arise related to the electric service demand charge billing it will be submitted to the
Committee for resolution. Sofidel and Clearwater have equal representation on the Committee which is comprised
of two individuals from each Sofidel and Clearwater. Its members must be selected from the highest-ranking
managers from each company at the Lewiston Complex.
III.
CONCLUSION'
Clearwater and Sofidel have arrived at a mutually agreeable billing process that utilizes state-of-the-art
metering equipment to fairly apportion and bill for electric demand services being sub metered by Clearwater For the
benefit of the Sofidel facility. The parties have created a Committee consisting of equal representation to resolve
disputes in the unlikely event of a billing discrepancy. The Parties commend the Commission and its Staff for their
diligence and oversight to insure that the net billing arrangement it has approved is implemented in a non-
discriminatory manner that is fair to all involved.
' Avista has reviewed and concurs with this filing.
JOINT COMPLIANCE FILING BY CLEARWATER PAPER CORPORATION AND SOFIDEL AMERICA
CORP. -3

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Dated this 17th day of December 2024.
Peter Richardson,Counsel for Clearwater Paper
Corporation
//SS//
C. Tom Arkoosh,Counsel for Sofidel America,Corp.
JOINT COMPLIANCE FILING BY CLEARWATER PAPER CORPORATION AND SOFIDEL AMERICA
CORP. -4