20150311Certificate of Attorney.pdf

R. JeffRichards
Daniel E. Solander
Rocky Mountain Power
201 South Main Sfieet, Suite 2400
Salt Lake CitS Utah 84111
Telephone No. (801) 22A-4014
Facsimile No. [phone]
Email: [e-mail]
Attamrysfor Rocky Mountain Power
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BEFORE TIIE IDAHO PUBLIC UTILITIES COMII{ISSION
IN THE MATTER OF TIIE APPLICATION
OF ROCICT MOUNTNN FOWER FOR
APPROVAL OF TIIE TRANSACTION TO
CLOSE DEER CREEK MINE A}iD FOR A
I}EFERRED ACCOI]NTING ORDER
cAsE NO. PAC-E-14-10
ATTORNEY'S CERTItr'ICATE
CLAIM OT CONTIDENTIALITY
RELATING TO DISCOYERY
RESPONSES
I, Daniel E. Solander, represe,Irt Rocky Mountain Power in the above captioned matter. I
am Senior Attornoy for Rocky Mountain Power.
I make this certification and claim of confidentiality regarding tle responses to the
attached discovuy request and responses to IPUC Requests pursuant to IDAPA 31.01.01
because Rocky Mountain Power, througb its zupporting workpapers, is disclosing c€rtain
infonnation that is Confidential and constitutes Trade Sesrets 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 26 contains confidential
information.
Rocky Mountain Power herein asserts that the aforeme,ntioned response is confidential in
part in that the information consists of copies of Company responses to numerous discovery
roquests received from parties in Deer Creek Mine clozure and asset sale approval proceedings in
Utah, Wyoming, Oregon, and Califomiq and that these responses include commercially
sensitive information on a variety of topics. Disclosing this inforrnation could give entities
access to eompetitive information Rocky Mountain Power beliwes could be used to
disadvantage it and its customers.
I am of the opinion that this information is "Confidential," as defined by ldaho Code
Section 9-340 and 48-801 , and should therefore be protected from public inspection, exarnination
and copyrng, and should be utilized only in accordance with the tel:ns of the Protective
Agreement betwee,n Rocky Mountain Power and ldaho Public tltilities Commission Staff.
DATED this l lth day of March, 2015.
Attornep for Rocky Mountain Power
R. JeffRib,hards