DR 97-186 New Hampshire Electric Cooperative, Inc. Petition for Approval of Purchased Power Agreement Order Granting Confidential Treatment O R D E R N O. 23,132 February 1, 1999 On September 9, 1997, the New Hampshire Electric Cooperative (NHEC) filed with the New Hampshire Public Utilities Commission (Commission) a petition for Approval of a Purchase Power Contract (Contract) between NHEC and Waste Management of New Hampshire, Inc. (WMNH). At that time, NHEC also filed a Motion for Confidential Treatment order covering the terms of the Contract. The Contract provides for the purchase of 4.4 MW of baseload capacity produced at WMNH's landfill gas recovery facility located in Rochester, New Hampshire. The Contract was negotiated pursuant to the procedures approved by the Commission in Re New Hampshire Electric Cooperative, Inc.,80 NH PUC 489 (1995) for purchases of power from Qualifying Facilities (QF) under the federal Public Utilities Regulatory Policy Act of 1978 (PURPA) and RSA 362-A (LEEPA). The procedure adopted by the Commission allowed NHEC to issue requests for proposals (RFP) for the purpose of soliciting competitive bids from QFs, thereby meeting NHEC's PURPA and LEEPA obligations to purchase QF power at its avoided cost. NHEC avers that the Contract contains sensitive confidential, commercial and financial information that would cause harm to NHEC, its members, and WMNH if it were released to the public. NHEC asserts that revelation of this information to persons who might use such information in any future RFPs issued by NHEC would frustrate NHEC's ability to obtain the least cost and most beneficial terms for its members. NHEC also asserts that public disclosure of the contract would reveal sensitive cost information concerning WMNH's Rochester facility and its operation. Thus, NHEC asserted the information is exempt from disclosure under RSA 91-A:5,IV and N.H. Admin. Rules, Puc 204.06. Pursuant to RSA 91-A, all government meetings and records shall be open and available to the public unless they fall within a narrow set of exemptions set forth at RSA 91-A:5. See generally, Union Leader Corporation v. New Hampshire Housing Authority, 142 N.H. 540 (1997). RSA 91-A:5,IV provides that records pertaining to "confidential, commercial, or financial information" are exempt from the general provisions of the Right-to-Know Law that would otherwise subject such information to disclosure. We believe the subject information contained in the Contract falls within the definition of commercial or financial information addressed by RSA 91-A:5, IV. The New Hampshire Supreme Court has held, however, that information that falls into one of these categories is not, per se, exempt from disclosure. Union Leader Corp., 142 N.H. 540, 553. Rather, the Court has held that the negative impact of disclosure of the "commercial or financial interest must be balanced against the public's interest in disclosure." Id.; Accord, Re New England Telephone Company (Auditel), 80 NHPUC 437 (1995); Re Bell Atlantic, Order No. 22,851 (February 17, 1998); Re EnergyNorth Natural Gas, Inc., Order No. 22,859 (February 24, 1998). Applying this balancing test to the case at hand, we conclude that NHEC has demonstrated that the public's interest in disclosure is outweighed by the potential competitive harm to NHEC, its members and WMNH. Thus, the motion will be granted subject to further review upon any request by the public to review the material pursuant to RSA 91-A. Based upon the foregoing, it is hereby ORDERED, that the New Hampshire Electric Cooperative, Inc.'s Motion for Confidential Treatment is GRANTED; and it is FURTHER ORDERED, that this Protective Order is subject to the reconsideration under RSA 91-A, on motion of the Commission, on motion of Staff, on motion any party or on the motion of any other member of the public, at which time the New Hampshire Electric Cooperative, Inc. and Waste Management of New Hampshire, Inc. shall bear the burden of maintaining the confidential treatment granted herein. By order of the Public Utilities Commission of New Hampshire this first day of February, 1999. Douglas L. Patch Susan S. Geiger Nancy Brockway Chairman Commissioner Commissioner Attested by: Thomas B. Getz Executive Director and Secretary