20110705PAC to Monsanto Attorney Attestation.pdf

Mark C. Moench
Daniel E. Solander
Rocky Mountain Power
201 South Main Street, Suite 2300
Salt Lake City, Utah 84111
Telephone: [phone]
Email: mark.moench@pacifìcorp.com
danieL. so landerC(ù,pacificorp. com
Attorneys for Rocky Mountain Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF ROCKY MOUNTAIN POWER FOR
APPROVAL OF CHANGES TO ITS
ELECTRIC SERVICE SCHEDULES AND A
PRICE INCREASE OF $32.7 MILLION, OR
APPROXIMATELY 15.0 PERCENT
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CASE NO. PAC-E-ll-12
ATTORNEY'S CERTIFICATE
CLAIM OF
CONFIDENTIALITY
D"l¡,T A TTNC' TO nT~rCnJ"l¡,DV..I.'-..L:J.L.Jrã. i. i,1 'lI'\J i. '-' ..,i.J,J''L-''4J' 'l' .A.:...J.I.' i
RESPONSES
I, Daniel E. Solander, represent Rocky Mountain Power in the above captioned
matter. I am Senior Counsel for Rocky Mountain Power and am appearing on its behalf in
this proceeding.
I make this certification and claim of confidentiality regarding responses to the
attached discovery requests and responses Monsanto 2.34, 2.37, 2.39, 2.40, 2.50, 2.54, 2.56,
2.59,2.70,2.77,2.87 -1, 2.87 -2 pursuant to IDAPA 31.01.01 because Rocky Mountain
Power, through its supporting workpapers, 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.
Rocky Mountain Power herein asserts that the aforementioned responses are
confidential in that the information contains commercially sensitive projections of sales, net
power costs, operating expenses, and revenues. 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.
DA~ TED this 1 st day of July, 2011.
Respectfully submitted,
By
Mark .M ench
Daniel E. Solander
Attorneys for Rocky Mountain Power