20191210Certificate of Attorney.pdf

Yvonne R. Hogle (lSB# 8930)
Rocky Mountain Power
1407 W. North Tanple, Suite 320
salt Lake city, Utah 841 t6
Telephone No. [phone]
Facsimile No. (801) 220 -3299
Email: yvonne.hogle@pacifi corp.com
Attorney for RoclE Mountain Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
RECEIVED
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IN THE MATTER OF THE APPLICATION OF
ROCKY MOUNTAIN 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.19-08
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 Section 74-101, et seq. and 48-801 and
protected under IDAPA 3 1.01.01.067 and 31.01.01.233. Specifically, Rocky Mountain Power
asserts that the attachments, provided with the Company's IPUC Data Request 4, contain Company
proprietary information that could be used to its commercial disadvantage.
Rocky Mountain Power herein asserts that the aforernentioned responses contain
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 copfing, and should be utilized only in accordance with the terms of the
Protective Agreernent in this proceeding.
DATED this I Oth day of Dccember, 2019.
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