HomeMy WebLinkAbout20150206PAC Certificate of Attorney.pdfDaniel E. Solander (ISB #8931)
Rocky Mountain Power
201 South Main Street, Suite 2400
Salt Lake city, Utah 841l1
Telephone No. (801) 220-4014
Facsimile No. (801) 220-3299
Email : daniel.solander@pacificorp.com
Attorneysfor Rocky Mountain Power
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BEFORE THE IDAHO PUBLIC UTILITIES COMNflSSION
IN THE MATTER OF THE APPLICATION
OF PACIFICORP DIBIA ROCKY
MOI'NTAIN POWER AI\D IDAHO
POWER COMPAI\IY FOR AI\t ORDER
AUTHORIZING TIIE EXCHANGE OF
CERTAIN TRANSII{ISSION ASSETS.
CASE NO. PAC.E.l4.T1
ATTOR}IEY'S CERTIFICATE
CLAIM OF COIYFIDENTIALITY
RELATING TO DISCOVERY
RESPONSES
I, Daniel E. Solander, represent Rocky Mountain Power in the above captioned matter. I
am a 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 ICIP Requests pursuant to IDAPA 31.01.01
because Rocky Mountain Power, through its responses, 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 asserts that the response to ICIP Requests 3, 4,6 and 8 contain confidential information.
Rocky Mountain Power herein asserts that the aforementioned responses are confidential
in that the information contains commercially sensitive information regarding the projected costs
and benefits related to the exchange of transmission assets with ldaho Power. 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 tdaho Public Utilities Commission Staff.
DATED this 5th day of February,Z0l1.
Attorneys for Rocky Mountain Power
Respectfu lly submitted,