20120309PAC Attorney Certificate.pdf

Mark C. Moench
Yvonne R. Hogle
Rocky Mountai Power
201 South Mai Str, Suite 2300
Salt Lae City, Uta 84111
Telephone No. [phone]
Facimle No. [phone]
Email: yvonne.hogle(?acíficorp.com
RECEIVED
,012 MAR -9 AM II: 08
IDAHO PU8LiC
UTILITIES COMMISSION
Attorney for Rocky Mountain Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMSSION
)
IN THE MATTER OF THE APPLICATION )
OF ROCKY MOUNTAI POWER FOR )
AUTHORIY TO INCRE RATES BY )
52.6 MILION TO RECOVER DEFERRD )
NET POWER COSTS THROUGH THE )
ENERGY COST ADJUSTMENT )MECHAISM )
)
)
CASE NO. PAC-E-12-03
ATTORNEY'S CERTIFICATE
CLAIM OF CONFIDENTALITY
RELATING TO DISCOVERY
RESPONSES
I, Yvonne R. Hogle, represent Rocky Mountain Power in the above captioned matter. I
am Senor Counsel for Rocky Mountai Power.
I make this ceification and claim of confidentiality regading responses to the attched
discover request and responses Monsanto 1, 6, 12, 17, 18, and 28 puruant to IDAP Å 31.01.01
because Rocky Mounta Power, thugh its supporng workpaper, is disclosing cerin
information that is Confidential and costtutes Trade Secet as defined by Idaho Code Section
9-340 and 48-801 and proteced under IDAP A 31.01.01.067 and 31.01.01.233.
Rocky Mountai Power herein assers that the aforeentioned respnses are confidential
in that the information contais commercially sensitive projections of sales, net power costs,
operating expenes, and revenues. Disclosing this information could give entities acce~ to
compettive information Rocky Mountai Power believes could be used to disadvantage it and its
customers.
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I am of the opinon that ths inrmation is "Confidential," as defined by Idaho Code
Secon 9-340 and 48-801, and should therfore be protected from public inspection, examination
and copyig, and should be utilized only in acance with the ters of the Protective
Agreement betwee Rocky Mountan Power and Idaho Public Utilities Commssion Staff
DATED ths 8th day of Marh, 2012.
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