20170915Certificate of Attorney Monsanto 1.1.pdf

Yvonne R.Hogle (ISB#8930)
Rocky Mountain Power
1407 W.North Temple,Suite 310
Salt Lake City,Utah 84116
TelephoneNo.[phone]
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Attorneys for Rocky Mountain Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
)CASE NO.PAC-E-17-06
IN THE MATTER OF THE )APPLICATION OF ROCKY )ATTORNEY'S CERTIFICATE
MOUNTAIN POWER FOR BINDING )CLAIM OF CONFIDENTIALITY
RATEMAKING TREATMENT FOR )RELATING TO DISCOVERY
WIND REPOWERING )RESPONSES
I,Yvonne R.Hogle,represent Rocky Mountain Power in the above captionedmatter.I am
Assistant General Counsel for Rocky Mountain Power.
I make this certification and claim of confidentialityregarding the response to the attached
Monsanto discovery request pursuant to IDAPA 31.01.01 because Rocky Mountain Power,
through its response,is disclosing certain information that is Confidential and/or constitutes Trade
Secrets as defined by Idaho Code Section 74-101,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 attachment
to the 16'Supplemental response to Monsanto Data Request 1.1 contains Company proprietary
information that could be used to its commercial disadvantage.
Rocky Mountain Power herein asserts that the aforementioned response is confidential in
that the information contains Company proprietary information.
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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 Monsanto.
DATED this 29th day of August,2017.
Respectfullysubmitted
Yvonne R.Hogle
Assistant General Counsel
Rocky Mountain Power
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