20150723PAC Attorney Attestation.pdf

Yvonne R. Hogle (ISB #8930)
R. Jeff Richards
Rocky Mountain Power
201 South Main Street, Suite 2400
Salt Lake City, Utah 84111
Telephone No. (801) 2204050
Facsimile No. [phone]
Email : yvonne.ho gle@pacifi corp.com
Attorneyfor RoclE Mountain Power
,"' lr. l,rrllL
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF ROCKY MOUNTAIN POWER TOMODIFY THE ENERGY COST
ADJUSTMENT MECHANISM AND
INCREASE RATES
CASE NO. PAC.E.T5-09
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 Idaho Irrigation Pumpers Association 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 confiCential information: Monsanta 1.2,1.8, 1.10, 1.12, and 1.14.
Rocky Mountain Power herein asserts that the aforementioned responses are confidential
in that the information contains commercially sensitive wholesale sales contracts, coal cost
workpapers, Renewable Energy Credit workpapers, and 2015 power cost study results in native
format with underlying workpapers. ln addition, in these responses, the Company is also
providing Monsanto copies of confidential responses to other parties' data requests in this
docket. 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 Monsanto.
DATED this 22nd day of July,2015.
R.
Richards
for Rocky Morurtain Power