20130308PAC Attorney Certificate.pdf

Mark C. Moench
Yvonne R. Hogle
Rocky Mountain Power
201 South Main Street, Suite 2300
Salt Lake City, Utah 84111
Telephone No. [phone]
Facsimile No. [phone]
Email: yvonne.hogle®pacificorp.com
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Attorney for Rocky Mountain Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
)
IN THE MATTER OF THE APPLICATION )

OF ROCKY MOUNTAIN POWER TO ) CASE NO PAC-E-13-03
INCREASE RATES BY $2.2 MILLION TO )

RECOVER DEFERRED NET POWER) ATTORNEY'S CERTIFICATE

COSTS THROUGH THE ENERGY "COST ) CLAIM OF CONFIDENTIALITY
ADJUSTMENT MECHANISM ) RELATING TO DISCOVERY

) 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 the response to the
attached discovery requests and responses to Monsanto 2, 4, 6, 9, 11, 12, and 14 pursuant to
IDAPA 310101 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 information related to hourly loads and
generation, power system operations, and contingency reserves, as well as risk management
policies and procedures, and internal and external reviews and testing. Disclosing this
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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 7th day of March, 2013.
Respectfully submitted,
R. Hogle
vs for Rocky Mountain Power
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