20130308PAC Certificate of Attorney.pdf

RECEI
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: [e-mail]
Attorney for Rocky Mountain Power
2011 MAR -° PH 3:18
IDAHO ff"IF l.j
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 request and response to Monsanto 10 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 IDAPA 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 information related to hydroelectric plant
outages during the ECAM period. 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 8th day of March, 2013.
Respectfully submitted,
C. Moench
ie R. Hogle
ieys for Rocky Mountain Power
2