20140114PAC Certificate of Attorney.pdf

Mark C. Moench
Yvonne R. Hogle
Rocky Mountain Power
201 South Main Streeq Suite 2300
salt Lake city, utah 84111
Telephone No, (801) 220-405A
Facsimile No. [phone]
Email : yvonne.ho g1e@pacifico{p. com
Attorneyfor RoclE Mountain Power
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BEFORE THE IDAHO PTJBLIC UTILITIES COMNIISSION
IN THE MATTER OF TIIE APPLICATION
OF ROCKY MOI]NTAIN POWER TO
INCREASE RATES BY $2.2 MILLION TO
RECO\rER DETERRED NIET POWER
COSTS THROUGH THE ENERGY COST
AI}JUSTMENT MECIHNISM
CASE NO. PAC.E.T3.O3
ATTORNEY'S CERTIFICATE
CLAIM OT' CONFIDENTTALITY
RELATING TO DISCOYERY
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 resporure to the
attached discovery request and response to Monsanto 2.1 pursuant to IDAPA 31.01.01 because
Rocky Mountain Power, through its supporting workpapers, is disclosing certain infonnation 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 price and quantity information related to
Renewable Energy Credits. 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 tbat this information is "Confidentia1," as defined by Idatro 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 wilh the terms of the Protective
Agreement between Rocky Mountain Power and Idaho Public Utilities Commission Staff.
DATED this l3th day of January,2}l4.