20150206Certificate of Attorney.pdf

R. JeffRichards
Daniel E. Solander
Rocky Mountain Power
201 South Main Street, Suite 2400
Salt Lake Ciry, Utah 841I I
Telephone No. [phone]
Facsimile No. [phone]
Email : daniel. solander@pacificorp. com
Attorneysfor RoclE Mountain Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF ROCKY MOUNTAIN POWER FOR
APPROVAL OF THE TRANSACTION TO
CLOSE DEER CREEK MINE AND FOR A
DEFERRED ACCOUNTING ORDER
CASE NO. PAC-E-14.10
ATTORNEY'S CERTTFICATE
CLAIM OF CONFIDENTIALITY
RELATING TO DISCOVERY
RESPONSES
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I, Daniel E. Solander, represent Rocky Mountain Power in the above captioned matter. I
am Senior Attorney for Rocky Mountain Power.
I make this certification 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 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. Specifically,
Rocky Mountain Power asserts that the response to IPUC Request 16 contains confidential
information.
Rocky Mountain Power herein asserts that the aforementioned response is confidential in
that the information contains commercially sensitive information regarding projected
environmental capital additions to the Hunter and Huntington power plants. 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 infonnation is "Confidential," as defined by Idaho Code
Section 9-340 and 48-801, and should therefore be protected from public inspection, examination
and copying, ffid 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 Sth day of February.2015.
Respectfirlly submitted,
Attorneys for Rocky Mountain Power
R. JeffRibhards