20150318Certificate of Attorney.pdf

R. JeffRichards
Daaiel E. Solander
Rocky Mountain Power
201 South Main Street, Suite 2400
Salt Lake City, Utah 84111
Telephone No. (801) 2204014
Facsimile No. [phone]
Email : daniel. solander@pacifi corp.com
Attorneys for Rocky Mountain Power
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BEF'ORE TIIE IDAIIO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF ROCKY MOUNTAIN POWER FOR
APPROVAL OF TIIE TRANSACTION TO
CLOSE DEER CREEK MINE AI{D FOR A
DEFERRED ACCOUNTING ORDER
CASE NO. PAC-E-14.10
ATTORNEY'S CERTItr"ICATE
CLAIM OX' CONF'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 Idaho Code Section
9-340 and 48-801 and protected tlrder TDAPA 31.01.01.067 and 31.01.01.233. Specifically,
Rocky Mountain Power asserts that the responses to IPUC Requests 23 and 24 contatn
confidential information.
Rocky Mountain Power herein asserts that the aforementioned responses are confidential
in that the information contains commercially sensitive infonnation regarding projected costs
related to closure of Deer Creek Mine and sale of related assets. 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 "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 17th day of March, 2015.
Respectfully submitted,
g
By
Daniel E. Solander
Attomeys for Rocky Mountain Power