20120309Attorney Certificate 3.pdf

RECEIVED
Mark C. Moench
Yvonne R. Hogle
Rocky Mountai Power
201 South Mai Street, Suite 2300
Salt Lae City, Uta 84111
Telephone No. [phone]
Facimle No. [phone]
Emai: yvonne.hogle~acificoip.com
20l2 MAR -9 PH~: 53
Attorney for Rocky Mountain Power
BEFORE TH IDAHO PUBLIC UTILITÆS COMMSSION
)
IN THE MATTER OF THE APPLICATION )
OF ROCKY MOUNTAI POWER FOR )
AUTHORITY TO INCREASE RATES BY )
$2.6 MILION TO RECOVER DEFERRD )
NET POWER COSTS THROl1Ca TIl )
ENERGY COST ADJUSTMENT )MECHAISM )
)
)
""0'
CASE NO. PAC-E-ii-03
ATTORNEY'S CERTIFCATE
CLAI OF CONFIENTIAITY
RELATING TO DISCOVERY
RESPONSES
I, Yvonne R. Hogle, represent Rocky Mountan Power in the above captioned mattet. I
am Senor Counsel for Rocky Mountai Power.
I inl:e ths cerfication and.claim .ofconfidentiality regarding responses to the attached
discover requests and responses Monsanto 4 and 14 pursuant to IDAPA 31.01.01 because
Rocky Mountan Power, though its supportng workpapers, is disclosing ceain information tht
is Confdential and GOnstitues Trad Secets as defied by Idaho Code Sectnn 9-340 and 48-801
and protected under IDAPA 31.01.01.067 and 31.01.01.233.
Rocky Mountai Power herein assers that the aforementioned responses are confidential
l
jn. that the information contai coerally sensitive projectons of sales, net power costs,
operatig expenses, and revenues. Disclosing ths information could give entitiesaaei;s to
compettive information Rocky Mountan POwer believes could be used to disadvantage it and its
cutomers.
I am of the opinion tht tIsinformtion is ~'Confdential," as defied by Idaho Code
Section 9.340 an 48.801, and should therfore be proteced from public inspecton, examation
and copyig, and should be utilized only in accnrdance with the ters of the Protectve
Agreement beteen Rocky Mounta Power and Idaho Public Utilities Commssion Staff
DATED ths 9t day of March, 2012.
B
· ar C.Moeich
vone R. Hogle
Atteys for Rocky Mountan Power
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