20150401PAC Certificate 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. [phone]
Email: [e-mail]
Attorneysfor Roeky Mountain Power
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BEFORX TIIE 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
DES'ERRED ACCOIINTING ORDER
CASE NO. PAC.E.I4.lO
ATTORI\EY'S CERTIFICATE
CLATM OT CONTIDENTIALITY
RELATING TO DISCOVERY
RESPONSES
[, 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
attaehed discovery request 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 Confrdential 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 its l*t Supplemental response to IPUC Request 26 contains
confidential information.
Rocky Mountain Power herein asserts that the aforementioned response is confidential in
that the information consists of copies of Company responses to discovery requests received
from parties in Deer Creek Mine closure and asset sale approval proceedings in Utah and
Oregon, and that these responses include commercially sensitive information on a variety of
topics. 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 copyinB, a116 should be utilized only in accordance with the terms of the Protective
Agreement between Rocky Mountain Power and ldaho Public Utilities Commission Staff.
DATED this lst day of April,2015.
R. JeffRichards
Daniel E. Solander
Attorneys for Rocky Mountain Power
Respectfully submi