20110414PAC to Monsanto 1 (1-3).pdf

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~ROCKY MOUNTAINPOER
A DIISI OF PAFlORP RECEtVED
iou APR , 4 PM 2: 09
201 South Main, Suite 2300
Salt Lake City, Utah 84 III
April 13, 2011
VLEMAL
AND OVERNIGHT DELIVERY
Randall C. Budge, ISB No. 1949
P.O. Box 1391; 201 E. Center
Pocatello, Idaho 83204-1391
rcb(gracinelaw.net (C)
RE: ID PAC-E-I0-09
Monsanto 1 st Set Data Request (1-3)
Please find enclosed Rocky Mountan Power's responses to Monsanto Data Requests 1.1-1.3.
Provided on the enclosed. CD are Attachments Monsanto 1.1 and 1.2 -1. Provided on the
enclosed Confidential CD is Confdential Attchment Monsanto 1.2 -2. Confdential Attchment
Monsanto 1.2 -2 is being provided to the requesting pary only. Confdential information is
provided subject to the terms and conditions of the protective agreement.
If you have any questions, please feel free to call me at [phone].
Sincerely,
0\Tøt(Y~/~
J. Ted Weston
Manager, Regulation
Enclosure
C.c.: Jean Jewell/IPUC(3 copies) jjewel1(mpuc.state.id.us (C)
Scott Woodbur scott.woodburCÐpuc.idaho.gov
Gar Kajander gar.r.kajanderCÐmonsanto.com
James R. Smith jim.r.smithCÐmonsanto.com (C)
Maurce Brubaker mbrubakerCÐconsultbai.com
Eric L. Olsen eloCÐracinelaw.net
Anthony Yanel tonyCÐyankeL.net
Matt Elam matt.elamCÐpuc.idaho.gov
Terri Carlock terri.carlockCÐpuc.idaho.gov
,
Mark C. Moench
Daniel E. Solander
Rocky Mountain Power
201 South Main Street, Suite 2300
Salt Lake City,Uta 84111
Telephone: [phone]
Email: mark.moenchCÐpacificorp.com
daniel.solanderwacificorp.com
Attorneys for Rocky Mountain Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION )
OF PACIFICORP DBA ROCKY MOUNTAIN )
POWER REQUESTING APPROV AL OF )
AMENDMENTS TO THE REVISED )PROTOCOL ALLOCATION )METHODOLOGY )
)
)
)
)
)
CASE NO. PAC-E-IO-09
ATTORNEY'S CERTIFICATE
CLAIM OF
CONFIDENTIALITY
RELATING TO DISCOVERY
RESPONSES
I, Danel E. Solander, represent Rocky Mountain Power in the above captioned
matter. I am Senior Counsel for Rocky Mountain Power and am appearing on its behalf in
this proceeding.
I make this certification and claim of confidentiality regarding responses to discovery
requests Monsanto Set 1 pursuant to IDAPA 31.01.01 because Rocky Mountain Power,
through its supporting workpapers, is disclosing certain information that is Confdential and
constitutes Trade Secrets as defined by Idaho Code Section 9-340 and 48-801 and protected
under IDAPA 31.01.01.067 and 31.01.01.233.
Rocky Mountain Power herein asserts that the aforementioned responses are
confidential in that the information contains commercially sensitive projections of sales, net
power costs, operating expenses, and revenues. Disclosing this information could give
entities access to competitive information Rocky Mountain Power believes could be used to
disadvantage it and its customers.
I am of the opinion that this information is "Confdential," as defined by Idaho Code
Section 9-340 and 48-801, and should therefore be protected from public inspection,
examination and copying, and should be utilized only in accordance with the terms of the
Protective Agreement between Rocky Mountain Power and Idaho Public Utilities
Commission Staff.
DATED this 13th day of April, 2011.
Respectfully submitted,
By --sl Danel Solander
Mark C. Moench
Danel E. Solander
Attorneys for Rocky Mountain Power
PAC-E-I0-09/Rocky Mountain Power
April 13, 2011
Monsanto 1 st Set Data Request 1.1
Monsanto i st Data Request 1.1
Please provide a copy of all data requests received from Commission Staff and
other paries. Please consider ths to be a continuing request and supplement your
response as additional requests are received.
Response to Monsanto 1st Data Request 1.1
Please refer to Attchment Monsanto 1.1.
Going forward, the Company will provide data requests received from
Commission Staff and other paries as they are responded to.
Recordholder: NI A
Sponsor: NIA
PAC-E-I0-09/Rocky Mountain Power
April 13,2011
Monsanto 1 st Set Data Request 1.2
Monsanto pt Data Request 1.2
Please provide a copy of your responses to the data requests from Commission
Staff and other paries. Please consider this to be a continuing request and
supplement your response as additional requests are received.
Response to Monsanto 1 st Data Request 1.2
Please refer to the Attachment Monsanto 1.2 -1 and Confidential Attchment
Monsanto 1.2 -2. Confdential information is provided subject to the terms and
conditions of the protective agreement in this case.
Recordholder: NI A
Sponsor: NI A
PAC-E-I0-09/Rocky Mountan Power
April 13,2011
Monsanto 1 st Set Data Request 1.3
Monsanto 1st Data Request 1.3
Please provide a copy of your responses to requests conveyed to Rocky Mountain
Power other than though formal data requests from Commission Staf and other
paries. Please consider this to be a continuing request and supplement your
response as additional requests are received.
Response to Monsanto 1st Data Request 1.3
No responses to requests have been provided to Commission Staff and other
paries outside of the formal data request process.
The Company wil supplement this response, as appropriate.
Recordholder: NI A
Sponsor: NIA