20240401Attorney Certificate.pdf

RECEIVED
Monday,April 1,2024 3:43 PM
IDAHO PUBLIC
UTILITIES COMMISSION
Joe Dallas (ISB# 1033)
Rocky Mountain Power
825 NE Multnomah, Suite 2000
Portland, OR 97232
Telephone: [phone]
Email:[e-mail]
Attorney for Rocky Mountain Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. PAC-E-24-05
IN THE MATTER OF THE APPLICATION )
OF ROCKY MOUNTAIN POWER ) ATTORNEY'S CERTIFICATE
REQUESTING APPROVAL OF $62.4 ) CLAIM OF CONFIDENTIALITY
MILLION ECAM DEFERRAL ) RELATING TO TESTIMONY AND
WORKPAPERS
I, Joe Dallas, represent Rocky Mountain Power a division of PacifiCorp, in the above
captioned matter. I am a senior attorney for Rocky Mountain Power.
I make this certification and claim of confidentiality pertaining to portions of testimony
filed to this docket and certain designated workpapers provided pursuant IDAPA 31.01.01 because
Rocky Mountain Power is disclosing certain information that is Confidential and/or constitutes
Trade Secrets as defined by Idaho Code Section 74-101, et seq. and 48-801 and protected under
IDAPA 31.01.01.067 and 31.01.01.233. Specifically, Rocky Mountain Power asserts that the
designated portions Jack's Painter's testimony filed on April 1, 2024, and associated workpapers
provided,that are designated as confidential, contain Company proprietary information that could
be used to its commercial disadvantage. Specifically, the designated portions of testimony and
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workpapers contain contracted coal amounts that constitute Company proprietary information that
could be used to its commercial disadvantage.
I am of the opinion that this information is "Confidential," as defined by Idaho Code
Section 74-101, et seq. and 48-801, and should therefore be protected from public inspection,
examination and copying, and should be utilized only in accordance with the terms any Protective
Agreement in this proceeding.
DATED this 1st day of April, 2024.
Respectfully submitted,
Joe Dallas
Senior Attorney
Rocky Mountain Power
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