20160223Certificate of Attorney.pdf

Yvonne Hogle
Rocky Mountain Power
1407 W. North Temple, Suite 320
Salt Lake City, Utah 841l6
Telephone No. [phone]
Facsimile No. [phone]
Emai I : Yvonne.ho gle@pacifrcorp. com
Attorneys for Roclqt Mountain Power
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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IN THE MATTER OF THE
FORTHCOMING APPLICATION OF
PACIFICORP D/B/A ROCKY MOUNTAIN
POWER REGARDING THE ENERGY
COST ADJUSTMENT MECHANISM
CASE NO. PAC-E-16-05
ATTORNEY'S CERTIFICATE
CLAIM OF CONFIDENTIALITY
RELATING TO DISCOYERY
RESPONSES
I, Yvonne 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 Requests pursuant to IDAPA 31.01.01
because Rocky Mountain Power, through its responses, is disclosing certain information that is
Confidential and/or constitutes Trade Secrets as defined by Idaho Code SectionT4-101, et seq.
and 48-801 and protected under IDAPA 31.01.01.067 and 31.01.01.233. Specifically, Rocky
Mountain Power asserts that the attachments to and/or referenced in IPUC 1.1 and 1.2 contain
commercially sensitive terms and conditions within confidential contracts between the Company
and its counterparties as well as sensitive budgetary information of the counterparty.
Rocky Mountain Power herein asserts that the aforementioned responses are confidential
in that the information contains commercially sensitive terms and conditions within confidential
contracts between the Company and its counterparties as well as sensitive budgetary information
of the counterparty.
I am of the opinion that this information is "Confidential," as defined by Idaho Code
Section 74-101, et seq. 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 this22nd day of February,2016.
Respectfully submitted,
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Assistant General Counsel for Rocky Mountain Power