20150225PAC Certificate of Attorney.pdf

Daniel E. Solander (ISB #8931)
Rocky Mountain Power
201 South Main Street, Suite 2400
Salt Lake city, Utah 841I I
Telephone No. [phone]
Facsimile No. [phone]
Email : dan iel.solander@pacifi corp.com
Attorneyfor Roclcy Mountain Power
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATIONOF PACIFICORP DIBIA ROCKY
MOUNTAIN POWER AIID IDAHO
POWER COMPAI\IY FOR AI\ ORDER
AUTHORIZING THE EXCHANGE OF
CERTAIN TRANSI\{ISSION ASSETS.
CASE NO. PAC.E-I4-II
ATTORNEY'S CERTIFICATE
CLAIM OF CONFIDENTIALITY
RELATING TO DISCOVERY
RESPONSES
I, Daniel E. Solander, represent Rocky Mountain Power in the above captioned matter. I
am a Senior Attomey for Rocky Mountain Power.
I make this certification and claim of confidentiality regarding the responses to the
attached discovery requests and responses to IPUC Requests pursuant to IDAPA 31.01.01
because Rocky Mountain Power, through its responses, is disclosing certain information that is
Confidential and constitutes Trade Secrets as defined by Idaho Code Section 9-340 and 48-801
and protected under IDAPA 31.01.01.067 and 31.01.01.233. Specifically, Rocky Mountain
Power asserts that the response to IPUC Request l4 contains confidential information.
Rocky Mountain Power herein asserts that the aforementioned responses are confidential
in that the information contains commercially sensitive information regarding third-party load
information related to the exchange of transmission assets with Idaho Power. Disclosing this
information could give entities access to competitive information Rocky Mountain Power
believes could be used to disadvantage it and its customers.
I am of the opinion that this information is "Confidential," as defined by Idaho Code
Section 9-340 and 48-801, and should therefore be protected from public inspection, examination
and copying, and should be utilized only in accordance with the terms of the Protective
Agreement between Rocky Mountain Power and Idaho Public Utilities Commission Staff.
DATED this 24th day of February,2015.
Attorneys for Rocky Mountain Power
Respectfully submitted,