HomeMy WebLinkAbout20150806PAC Attorney Attestation.pdfYvonne R. Hogle (ISB #8930)
R. Jeff Richards
Rocky Mountain Power
201 South Main Street, Suite 2400
Salt Lake City, Utah 8411I
Telephone No. (801) 220-4A50
Facsimile No, (801) 220-3299
Email : yvonne.hogle@pacifi corp.com
Attorneyfor RoclE Mountain Power
BEFORE TIIE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OT'THE APPLICATION
OT ROCKY MOUNTAIN POWER TOMODIF'Y TITE ENERGY COST
ADJUSTMENT MECHANISM AND
INCREASE RATES
CASE NO. PAC-E-15-09
ATTORNEY'S CERTTFICATE
CLAIM OF' CONTIDENTIALITY
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 PacifiCorp Idaho tndustrial Customers (PIIC)
pursuant to IDAPA 31.01.01 because Rocky Mountain Power, through its supporting
workpapers, is disclosing certain information that is Conlidential 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: PIIC Requests 3 and 4.
Rocky Mountain Power herein asserts that the aforementioned responses are confidential
in that the information contains commercially sensitive Power Cost Model input files,
workpapers, and user manuals. 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, Brrd should be utilized only in accordance with the terms of the Protective
Agreement between Rocky Mountain Power and PIIC.
DATED this 5th day of August,2015.
Respectfully submiued,
for Rocky Mountain Power