20150203Certificate of Attorney.pdf

R. JeffRichards
Daniel E. Solander
Rooky Mountain Power
201 South Main StreerL Suite 2400
Salt Lake Citn Utah 841I I
Telephone No. [phone]
Facsimile No. (80 1) 220-3299
Email: [e-mail]
Attorneysfor RoclE Mountain Power
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BET'ORE THE IDAEO PUBLIC UTILITIES COMMISSIOX
IN THE MATTER OF TIIE APPLICATION
OT ROCI(Y MOT]NTAIN POWER T'OR
APPROVAL OF THE TRANSACTION TO
CLOSE DEER CREEK I}trNE AFID FOR A
DEF'ENRED ACCOTINTING ORDER
CASE NO. PAC.E-14.10
ATTORNEY'S CERTItr'ICATE
CLAIM OF CONFIDENTIALITY
RELATING TO DISCOVERY
RESPONSES
I, Daniel E. Solander, represent Rocky Mountain Power in the above capfioned matter. I
am Se,nior Attorney for Rocky Mountain Power.
I make this crrtification and claim of confidentiality regarding the responses to the
attached discovery requests and responses to IPUC Requests pursuant to IDAPA 31.01.01
because Rocky Mountain Powe,r, through its supporting workpapers, is disclosing certain
inforuration that is Confidential and constitutes Trade Secrets as defined by tdatro Code Section
9-340 and 48-801 and protected under IDAPA 31.01.01.067 and 31.01.01.233. Specifically,
Rocky Mountain Power asserts that the response to IPUC Request 4 contains confidential
information.
Rocky Mountain Power herein asserts that the aforsmentioned response is confidential in
that the inforrration contains commeroially sensitive information regarding Deer Creek mine and
projeaed fuel costs for the Hunter and Huntington power plants. Disclosing this information
could give entities access to competitive inforrnation Rocky Mountain Power believes could be
used to disadvantags 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 3rd day of Februar.v,2015.
Attomeys forRocky Mountain Power
Respectfully submitted,
R. JeffRichards