20130712Attorney Cert.pdf

P n ..-
Mark C.Moench
Daniel B.Solander Lfl13 JUL 12 p;i 2RockyMountainPower
201 South Main Street,Suite 2300
Salt Lake City,Utah 84111
Telephone No.[phone]
facsimile No.[phone]
Email:[e-mail]
Attorneyfor Rocky Mountain Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
)
IN THE MATTER OF THE APPLICATION )
OF ROCKY MOUNTAIN POWER FOR )CASE NO.PAC-E-13-1O
AUTHORITY TO REVISE ELECTRIC )
SERVICE SCHEDULE 155 )ATTORNEY’S CERTIFICATE
AGRICULTURAL ENERGY SERVICES )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 a confidential document
provided in response to IPUC 8 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 response is confidential in
that the information consists of responses to the RFP for Idaho Irrigation Energy Savers,part of a
multiple program,multi-year evaluation RFP for all of PacifiCorp’s demand-side management
programs.Disclosing this information could give entities access to competitive information
Rocky Mountain Power believes could be used to disadvantage it and its customers.
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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 12th day of July,2013.
Respectfully submitted,
By_______
Mark C.Moench
Daniel E.Solander
Attorneys for Rocky Mountain Power
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