20180227Certificate of Attorney.pdf

Yvonne R. Hogle (ISB# 8930)
Rocky Mountain Power
1407 W. North Temple, Suite 310
Salt Lake City, Utah 841l6
Telephone No. [phone]
Facsimile No, [phone]
Email : yvonne.hogle@pacifi corp.com
Attorneys for Roclqt Mountain Power
BEFOR.E THE IDAHO PUBLIC UTILITIES COMMISSION
RE CE IVED
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IN THE MATTER OF THE APPLICATION
OF PACIFICORP DBA ROCKY MOTINTAIN
POWER FOR BINDING RATEMAKING
TREATMENT FOR WIND REPOWERING
CASE NO. PAC-E-17.06
ATTORNEY' S CERTIFICATE
CLAIM OF CONFIDENTIALITY
RELATING TO DISCOVERY
RESPONSES
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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 response to the attached
Idaho Public Utilities Commission Staff discovery request pursuant to IDAPA 31.01.01 because
Rocky Mountain Power, through its response, is disclosing certain information that is at a
minimum 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 highly confidential attachments provided with the
Company's response to IPUC Data Request 42 contains Company proprietary information that
could be used to its commercial disadvantage.
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Rocky Mountain Power herein asserts that the aforementioned responses contain highly
confidential Company proprietary information.
I am of the opinion that this information is at a minimum "Confidential," as defined by
Idaho Code SectionT4-101, 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 in this proceeding.
DATED this 23rd day of February,20l8
Respectfully
R. Hogle
GeneralCounsel
Mountain Power
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