20110829PAC Attorney Attest to Staff Set 5.pdf

Mark C. Moench
Daniel E. Solander
Rocky Mountain Power
201 South Main Street, Suite 2300
Salt Lake City, Utah 84111
Telephone No. [phone]
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Attorney 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)
PRICE INCREASE OF $32.7 MILLION, )
OR APPROXIMA TEL Y 15.0 PERCENT )
)
)
CASE NO. PAC-E-ll-12
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 Senim Counsel fm Rocky Mountain Power.
I make this certification and claim of confidentiality regarding responses to the attached
discovery requests and responses IPUC 138, 140, 141, 142, 151, 158, 162, and 167 pursuant to
IDAPA 31.01.01 because Rocky Mountain Power, through its supporting workpapers, is
disclosing certain infmmation 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
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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 25th day of August, 2011.
Respectfully submitted,
Daniel E. Solander
Attorneys for Rocky Mountain Power
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