20130617Attorney Certificate.pdf

)
IN THE MATTER OF THE APPLICATION )
OF ROCKY MOUNTAIN POWER FOR )CASE NO.PAC-E-13-02
AUTHORITY TO CHANGE )
DEPRECIATION RATES APPLICABLE )ATTORNEY’S CERTIFICATE
TO ELECTRIC PROPERTY )CLAIM OF CONFIDENTIALITY
)RELATING TO DISCOVERY
)RESPONSES
)
)
I,Daniel E.Solander,represent Rocky Mountain Power in the above captioned matter.I
am Senior Counsel for Rocky Mountain Power.
I make this certification and claim of confidentiality regarding the responses to the
attached discovery requests IPUC 9 and 11 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 consists of commercially sensitive appropriation requests for scrubber
upgrades at the Naughton generating station as well as project approval documents and
expenditures to date on the Merwin Hydroelectric Upstream Collect and Transport project.
—rMarkC.Moench
Daniel E.Solander -./U !iRockyMountainPowerI f
201 South Main Street,Suite 2300
Salt Lake City,Utah 84111 H
Telephone No.[phone]
Facsimile No.[phone]
Email:clan [e-mail]
Attorney for Rocky Mountain Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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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 13th day of June,2013.
Respectfully submitted,
By_____________________
Mark C.Moench
Daniel E.Solander
Attorneys for Rocky Mountain Power
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