ML20004C550

Affidavit That Info from Bethelehem Steel Corp on Future Production Plans of Burns Harbor Plant Is Given to Util in Confidence & Is Considered Confidential

ML20004C550
Person / Time
Site:	Bailly
Issue date:	05/22/1981
From:	Leidner R BETHLEHEM STEEL CORP., NORTHERN INDIANA PUBLIC SERVICE CO.
To:
Shared Package
ML20004C549	List: ML20004C548 ML20004C550 ML20004C551 ML20004C552 ML20004C553 ML20004C555 ML20004C558 ML20004C563
References
NUDOCS 8106040258
Download: ML20004C550 (2)

Text

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ATTAC!! MENT 1 l

9 CCM: C:NEALTH OF PENUSYLVANIA )

) SS:

COUNTY OF LEHIGH )

AFFIDAVIT I

l The undersigned, Roy N. Leidner, being duly sworn j upon his oath, deposes and says: ,

l. That he is Director Corporate Etergy Affair I

-l of Bethlehem Steel Corporation (Lethlehem) and as such is f authorized to atake this affidavit for and on behalf of said l

corporation. ,

2. Bett.lehem is a Delaware corporation with its f prir.cipal off.ces in Bethlehem, Pennsylvania and is engaged in the business of prc ducing steel and related products.

A 3

That Bethlehem owns and operates a fully  !

integ* _1 steel mill located in Porter Count */, Indiana l (known cs its Burns riarbor Plant) which represents approximately f 24 percent of its total steel producing capability.

4 That in the prccess of produaing steel at its Burns Harbor Plant, Betalehem purchases large auantities of J electric &l ener er " rom Northern Indiana fublic Service i

' Company (NIPSCO).

I S. That from time to time Bethlehem furnishes information to NIPSCO crgarding the future production plan for the Burns Harbor plant in order to aid and assist NIPSCO l 1

in determining future electrical demands on the NIPCCO system.

6. That the information given to NIPSCO is not l announced to the public, is considered confidential by f I

Bethlehem and is given to :lIPSCO in confidence. i i

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7. That to Bethlehen's knowledge N!?SCO has always treated such information as confidential.

'I S. That disclosure to its ecmpetitors in the steel industry of the information furnished to NIPSCO could place Bethlehem at an economic disadvantage, for example,

• its competitors could use information related to projected future electrical energy needs to predict Bethlehem's corporate strategy as to production means and product type and to take steps to counter such strategy, therefore Bethlehem protects such information from public disclosure atd has provided such information to NIPSCO with the under-t ar. ding that NIPSCO will prevent its public disclosure.

And further the Affiant sayeth not.

BETHLEHTM STEEL CCRP RATION

'/' ,

Sy: /D/ . amu-[#_d (

CCMMON'4EALTH CF PENNCYL7ANIA )

) SS:

COUNTY OF LEHIGH )

l Eefore me, a Notary Public, in and for said County and Ccemenwealth, this 22nd day of May, 1981, personally appeared Roy N. Leidner of Bethlehem Steel Cceporation and acknowledged the execution of the foregoing instrument as the free and voluntary act of said corporation s.nd as his free and voluntary act acting for said corporation and swears that the statements contained in his Affidavit are to the best of his knowledge and belief true and correct.

GIVEN under my hand and notarial seal this 22nd day of May, 1981 i

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.v a b u. /

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j NOTARX FUBLIC /

My Commission expires:

My Commmion Espire apa n n>

Cp d &&seum Lehmb Couary P00R ORIGINAI.