20130204PAC Certificate of Confidentiality.pdf

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Mark C. Moench
Yvonne R. Hogle
Rocky Mountain Power
201 South Main Street, Suite 2300
Salt Lake City, Utah 84111
Telephone No. (801) 2204050
Facsimile No. [phone]
Email: yvonne.hogle®pacificorp.com
Attorney for Rocky Mountain Power
2013 FEB -t AMU:
1C ri L.LJ .j
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.
am Senior Counsel for Rocky Mountain Power.
I make this certification and claim of confidentiality regarding the response to the
attached discovery request and response IPUC Staff 4 pursuant to IDAPA 31.01.01 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 1DAPA 31.01.01.067 and 31.01.01.233.
Rocky Mountain Power herein asserts that the aforementioned response is confidential in
that the information contains commercially sensitive pricing terms related to the winning bid
submitted in the irrigation load control program RFP. 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 "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 1st day of February, 2013.
Respectfully submitted,
C. Moench ( J -
ie R. Hogle
keys for Rocky Mountain Power
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