20190610Certificate of Attorney.pdf

DAVID J. MEYER
VICE PRESIDENT AND CHIEF COI.INSEL FOR
REGULATORY & GOVERNMENTAL AFFAIRS
AVISTA CORPORATION
P.O. BOX 3727
14I1 EAST MISSION AVENUE
SPOKANE, WASHINGTON 99220 -37 27
TELEPHONE: (509) 49s-4316
FACSIMILE: (509) 495-885 I
DAVID.MEYER@AVISTACORP. COM
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF AVISTA CORPORATION FOR THE
AUTHORITY TO TNCREASE ITS RATES
AND CHARGES FOR ELECTRIC SERVICE
TO ELECTRIC CUSTOMERS TN THE
STATE OF TDAHO
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CASE NO. AVU-E-I9-04
ATTORNEY' S CERTIFICATE
CLAIM OF CONFIDENTIALITY
RELATING TO PORTIONS
OF AVISTA'S EXHIBIT'S
AND WORKPAPERS
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FOR AVISTA CORPORATION
I, David J. Meyer, represent Avista Corporation. I am Vice President and Chief
Counsel for Regulatory and Governmental Affairs for Avista Corporation (Avista or
Company) and I am appearing on its behalf in this proceeding.
I make this certification and claim of confidentiality pursuant to IDAPA 31.01.01
because Avista, through its supporting workpapers, is disclosing certain information that
is CONFIDENTIAL and constitutes TRADE SECRETS as defined by Idaho Code
Section 9-340 and 48-801 and protected under IDAPA 31.01.01 .067 and 31.01.01.233.
The printed information Avista provides will, as required under IDAPA Rule
31.01.01 .067,be marked as CONFIDENTIAL, will be reproduced on any colored paper
other than white, and will be provided under separate cover. The electronic information
Avista provides will be reproduced separately on a compact disk (CD) and will also be
marked as CONFIDENTIAL.
The confidential information that Avista is disclosing includes, but is not limited
to: l) certain results providing detailed information on the Company's load and resource
positions by month, 2) certain equity issuances as detailed in the January 1,2020 through
December 31,2020 pro forma capital structure, 3) Risk Management Policies which
contain general policies, guidelines, and position limits, and 4) Interest Rate Risk
Management Plan which contains policies and guidelines.
Avista herein asserts that the aforementioned information is confidential in that:
l) making the load and resource information public will give entities access to
competitive information on future operating plans and market purchase requirements and
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ATTORNEY'S CERTIFICATE - I
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Avista believes the information could be used to disadvantage its customers, 2)
disclosing planned equity issuances may financially disadvantage the Company, 3) the
Risk Management Policies and hedging practices, and the Interest Rate Risk
Management Plan, if shared with competitors, could also be used to disadvantage
Avista's customers.
I am of the opinion that this information is CONFIDENTIAL, as defined by Idaho
Code Sections 9-340D and 48-801, 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 AVISTA CORPORATION AND PARTIES
WHO HAVE REQUESTED SUCH AN AGREEMENT.
RESPECTFULLY SUBMITTED this 7th day of June 2019
David J. Meyer
Vice President and Chief Counsel for
Regulatory & Governmental Affairs
Avista Corporation
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ATTORNEY'S CERTIFICATE - 2