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Request for Trade Secret Protection for Natural Gas Supply Information

Strategic Insights

— 2 min read

New York State's Rochester Gas and Electric Corporation has submitted a request to the Department of Public Service for trade secret protection of sensitive information regarding its natural gas supply purchases. The document, filed on June 26, 2015, consists of three pages detailing the Company's gas supply purchases for delivery during July 2015. The information includes the sources of gas purchased, delivery routes, differential from the NYMEX price, and total dollar volumes attributable to each cost component.

The Corporation argues that disclosure of this information would be of material advantage to its competitors and other suppliers, and would be injurious to RG&E and its customers. The document is highly sensitive, and the Corporation claims that its disclosure would jeopardize its ability to obtain optimal pricing terms on its purchases and non-tariffed sales of gas.

Key Takeaways:

  • RG&E submitted a request for trade secret protection of sensitive information regarding its natural gas supply purchases on June 26, 2015.
  • The document consists of three pages detailing the Company's gas supply purchases for delivery during July 2015.
  • The information includes the sources of gas purchased, delivery routes, differential from the NYMEX price, and total dollar volumes attributable to each cost component.
  • The Corporation argues that disclosure of this information would be of material advantage to its competitors and other suppliers, and would be injurious to RG&E and its customers.
  • The document is highly sensitive, and the Corporation claims that its disclosure would jeopardize its ability to obtain optimal pricing terms on its purchases and non-tariffed sales of gas.
  • The Corporation requests that the entirety of the document be accorded trade secret protection, citing the potential for competitors to derive substantial advantage from this information.
  • The document contains data on different dollar amounts to be paid to various suppliers, and about the volumes of gas purchased from them.
  • The direct recital of demand, capacity, and total gas costs with respect to each supplier is also considered proprietary and commercially sensitive.

Statistics:

  • 3 pages of sensitive information regarding RG&E's natural gas supply purchases.
  • 89 East Avenue, Rochester, NY 14649-0001 is the address of the RG&E's office.
  • 585.771.4692 is the telephone number, and 585.750.1666 is the cell phone number of Mark Marini, Director of Regulatory, RG&E.
  • 16 NYCRR SS 6-1.3 and Public Officers Law Section 87.2(c) and (d) are referenced as the regulations governing trade secret protection.

Sources:

  • IBERDROLA USA Mark 0. Marini Director - Regulatory June 26, 2015
  • Ms. Donna Giliberto Records Access Officer New York State Department of Public Service Three Empire State Plaza Albany, NY 12223-1350

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