20150218Certificate of Attorney.pdf

R. JeffRichards
Daniel E. Solander
Rocky Mountain Power
201 South Main Street, Suite 2400
Salt Lake City, Utah 84111
Telephone No. [phone]
Facsimile No. (80 1 ) 220-3299
Email: daniel.solander@pacifi corp.com
Attorneysfor RoclE Mountain Power
.-,r-'1r'1i...
?0!5 FtB lB AH I0: 03
Ir'r, i. , .; -
i 11tl-rJijl.l-'.; i,i':" ; i$"-"
BEFORE THE IDAHO PUBLIC UTILITTES COMIrIISSION
IN THE MATTER OF THE APPLICATION
OF ROCKY MOUNTAIN POWER FOR
APPROVAL OT TIIE TRANSACTION TO
CLOSE DEER CREEK MINE AND FOR A
DEFERRED ACCOUNTING ORDER
CASE NO. PAC.E-14-10
ATTORNEY'S CERTIFICATE
CLAIM OF CONT'IDENTIALITY
RELATING TO DISCOVERY
RESPONSES
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 ldaho Code Section
9-340 and 48-801 and protected under IDAPA 31.01.01.067 and 31.01.01.233. Specifically,
Rocky Mountain Power a.sserts that the response to IPUC Request 5 contains confidential
information.
Rocky Mountain Power herein asserts that the aforementioned response is confidential in
that the infomration contains commercially sensitive information regarding Deer Creek mine and
projected fuel costs for 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 information is "Coufidential," 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 lTth day of February,2015.
Attorneys for Rocky Mountain Power
R JeffRichards
Daniel E. Solander