20130117PAC Certificate of Confidentiality.pdf

REC E
Mark C. Moench
Yvonne Hogle
Rocky Mountain Power
201 South Main Street, Suite 2300
Salt Lake City, Utah 84111
Telephone No. [phone]
Facsimile No. [phone]
Email: yvonne.hoale(äpacificorp.com
Attorneys for Rocky Mountain Power
U13 JAN i PM 2: 15
1U iMM'.SStON
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
)
IN THE MATTER OF THE APPLICATION )
OF ROCKY MOUNTAIN POWER FOR CASE NO. PAC-E-12-14
AUTHORITY TO CANCEL ELECTRIC )
SERVICE SCHEDULE NOS. 72 AND 72A ) ATTORNEY'S CERTIFICATE
IRRIGATION LOAD CONTROL TARIFFS ) CLAIM OF CONFIDENTIALITY
AND APPROVE A NEW DEMAND SIDE ) RELATING TO DISCOVERY
MANAGEMENT CONTRACT ) RESPONSES
)
I, Yvonne R. Hogle, represent Rocky Mountain Power in the above captioned matter. I
am Senior Counsel for Rocky Mountain Power.
I make this certification and claim of confidentiality regarding responses to discovery
requests and responses Idaho Irrigation Pumpers Association (IJPA) 1.3 and 1.4 pursuant to
IDAPA 3 1.01.01 because Rocky Mountain Power, through its supporting workpapers, is
disclosing certain information that is Confidential 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 hourly system load data. Disclosing this
information could give entities access to competitive information Rocky Mountain Power
believes could be used to disadvantage it and its customers.
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I am of the opinion that this information is "Confidential," 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 17th day of January. 2013.
Moench
R. Hogle
s for Rocky Mountain Power
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