20181207Certificate of Attorney.pdf

Yvonne R, Hogle (ISB# 8930)
Rocky Mountain Power
1407 W. North Temple, Suite 320
Salt Lake City, Utah 841l6
Telephone No. [phone]
Facsimile No. [phone]
Emai I : yvonne.hogle@pacifi corp.com
Attorneyfor Roclqt Mountain Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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IN THE MATTER OF THE APPLICATION OF
ROCKY MOUNTAIN POWER FOR
AUTHORIZATION TO CHANGE
DEPRECI-ATION RATES APPLICABLE TO
ELECTRIC PROPERTY
CASENO, PAC-E-I8-08
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 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, provided with the Company's 2018 Depreciation Study Monsanto
Data Request 2, contain 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
confidential in that the information contains Company proprietary information.
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 in this proceeding.
DATED this 7th day of December,20l8.
Respectfully
By
R. Hogle
General Counsel
Mountain Power
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