20191206Certificate of Attorney.pdf

Yvonne R. Hogle (lSB# 8930)
Rocky Mountain Power
1407 W. North Temple, Suite 320
Salt Lake City. Utah 84116
Telephone No. [phone]
Facsimile No. [phone]
Email : yvonne.hogle@pacifi corp.com
Attorney.for Roclq Mountain Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
RECEIVED
r0l9 DEC -5 Pll h: 07
IN THE MATTER OF THE APPLICATION OF
ROCKY MOLNTAIN POWER TO CLOSE
THE NET METERING PROGRAM TO NEW
SERVICE & IMPLEMENT A NET BILLING
PROGRAM TO COMPENSATE CUSTOMER
GENERATORS FOR EXPORTED
GENERATION.
CASE NO. PAC-E-I9-08
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
ldaho 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 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 attachments, provided with the Company's IPUC Data Request 3, contain Company
proprietary information that could be used to its commercial disadvantage.
Rocky Mountain Power herein asserts that the aforementioned responses contain
confrdential 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 in this proceeding.
DATED this 6th day of December, 201 9.
Respectfully
B
R. Hogle
General Counsel
Mountain Power
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