20121011Attorney Certificate.pdf

DAVID J. MEYER
VICE PRESIDENT AND CHIEF COUNSEL FOR
REGULATORY & GOVERNMENTAL AFFAIRS
AVISTA CORPORATION
P.O. BOX 3727
1411 EAST MISSION AVENUE
SPOKANE, WASHINGTON 99220-3727
TELEPHONE: [phone]
FACSIMILE: [phone]
DAVID . MEYER@AVISTACORP . COM
?912001 1, 1 PM 3:53
1'
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF AVISTA CORPORATION FOR THE
AUTHORITY TO INCREASE ITS RATES
AND CHARGES FOR ELECTRIC AND
NATURAL GAS SERVICE TO ELECTRIC
AND NATURAL GAS CUSTOMERS IN
OF IDAHO
CASE NO. AVU-E-12-08
CASE NO. AVU-G-12-07
ATTORNEY'S CERTIFICATE
CLAIM OF CONFIDENTIALITY
RELATING TO PORTIONS
OF AVISTA'S EXHIBIT'S
AND WORKPAPERS
I FOR AVISTA CORPORATION
2 I, David J. Meyer, represent Avista Corporation. I am
3 Vice President and Chief Counsel for Regulatory and
4 Governmental Affairs for Avista Corporation (Avista or
5 Company) and I am appearing on its behalf in this proceeding.
6 I make this certification and claim of confidentiality
7 pursuant to IDAPA 31.01.01 because Avista, through its
8 supporting workpapers, is disclosing certain information that
9 is CONFIDENTIAL and constitutes TRADE SECRETS as defined by
10 Idaho Code Section 9-340 and 48-801 and protected under IDAPA
11 31.01.01.067 and 31.01.01.233.
12 The printed information Avista provides will, as required
13 under IDAPARu1e 31.01.01.067, be marked as CONFIDENTIAL, will
14 be reproduced on any colored paper other than white, and will
15 be provided under separate cover. The electronic information
16 Avista provides will be reproduced separately on a compact disk
17 (CD) and will also be marked as CONFIDENTIAL.
18 The confidential information that Avista is disclosing
19 can be classified into the following basic categories: 1)
20 certain results providing detailed information on the
21 Company's load and resource positions by month, 2) certain
22 equity issuances as detailed in the June 30, 2012 through June
ATTORNEY'S CERTIFICATE - 2
1 30, 2013 pro forma capital structure, 3) details regarding high
2 priority transmission facilities, and 4) Risk Management
3 Policies which contain general policies, guidelines, and
4 position limits.
5 Avista herein asserts that the aforementioned
rel information is confidential in that: 1) making the load and
7 resource information public will give entities access to
8 competitive information on future operating plans and market
9 purchase requirements and Avista believes the information
10 could be used to disadvantage its customers, 2) disclosing
11 planned equity issuances may financially disadvantage the
12 Company, 3) information relating to the Company's most
13 important transmission facilities may give market
14 participants privileged information, and 4) the Risk
15 Management Policies, if shared with competitors, could also
16 be used to disadvantage Avista's customers.
17 I am of the opinion that this information is CONFIDENTIAL,
18 as defined by Idaho Code Sections 9-340D and 48-801, should
19 therefore be protected from public inspection, examination and
20 copying, and should be utilized only in accordance with the
21 terms of the PROTECTIVE AGREEMENT BETWEEN AVISTA CORPORATION
22 AND IDAHO PUBLIC UTILITIES COMMISSION STAFF.
ATTORNEY'S CERTIFICATE - 3
1 RESPECTFULLY SUBMITTED this 10th day of October, 2012
2
3
4 David J. Meyer
5 Vice President and Chief Counsel for
6 Regulatory & Governmental Affairs
7 Avista Corporation
ATTORNEY'S CERTIFICATE - 4