20130513Cert of Attorney.pdf

Mark C. Moench
Daniel E. Solander
Rocky Mountain Power
201 South Main Street, Suite 2300
Salt Lake City, Utah 84111
Telephone No. (801) 2204014
Facsimile No. [phone]
Email: [e-mail]
Attorney for Rocky Mountain Power
SIC

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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
)
APPLICATION FOR AUTHORITY TO )

SELL ST. ANTHONY HYDROELECTRIC ) CASE NO. PAC-E-13-06
GENERATING PLANT )

) ATTORNEY'S CERTIFICATE

) CLAIM OF CONFIDENTIALITY

) RELATING TO DISCOVERY

) RESPONSES
)
I, Daniel B. 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 response to the
attached discovery requests and responses IPUC Staff 3, 5, 6, 7, and 8 pursuant to JDAPA
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 information related to the sale of the St.
Anthony Hydroelectric Generating Plant. Disclosing this information could give entities access
to competitive information Rocky Mountain Power believes could be used to disadvantage it and
its customers.
1
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 9th day of May, 2013.
Respectfully submitted,
BY 'V VI\
Daniel E. Solander
Attorneys for Rocky Mountain Power