20150714PAC Attorney Attestation.pdf

R. Jeff Richards
Yvonne R. Hogle
Rocky Mountain Power
201 South Main Street, Suite 2400
Salt Lake City, Utah 84111
Telephone No. [phone]
Facsimile No. [phone]
Email: [e-mail]

Attorney for Rocky Mountain Power

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
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CASE NO. PAC-E-15-01
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 Assistant General Counsel for Rocky Mountain Power.
I make this certification and claim of confidentiality regarding the responses to the
attached discovery requests and responses to IPUC Audit Requests 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. Specifically,
Rocky Mountain Power asserts that the responses to the following Requests contain confidential
information: IPUC Audit Requests 1, 3, 4, 6, and 7.
Rocky Mountain Power herein asserts that the aforementioned responses are confidential
in that the information contains commercially sensitive information regarding 1) Jim Bridger
accounting, 2) hourly electrical generation, 3) power cost transaction-level detail, 4) information

on the timing of forced outages and derates at electrical generation stations, and 5) transaction
confirmations for fuel hedge contracts. 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 16th day of January, 2015.

Respectfully submitted,

By__________________________
R. Jeff Richards
Yvonne R. Hogle
Attorneys for Rocky Mountain Power