20140226PAC Attorney Certificate.pdf

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 @ pacifi corp.com
Attorney for Roclqt Mountain Power
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF ROCKY MOUNTAIN POWER TO
RECOVER DEFERRED NET POWER
COSTS THROUGH THE ENERGY COST
ADJUSTMENT MECHANISM
CASE NO. PAC.E.14.O1
ATTORNEY'S CERTIFICATE
CLAIM OF CONFIDENTIALITY
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 IPUC On-Site Audit Requests pursuant to IDAPA
31.01.01 because Rocky Mountain Power 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. Specifically, Rocky Mountain Power asserts that
the response to IPUC On-Site Audit Request 7 contains confidential information.
Rocky Mountain Power herein asserts that the aforementioned response is confidential in
that it contains commercially-sensitive energy trading self-assessment information. 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, a16 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 25th day of Febilffy, 2014.
Respectfully submitted,
By
Yvonne R. Hogle
Attorneys for Rocky Mountain Power