20150407PAC Certificate of Attorney.pdf

R. Jeff Richards
Daniel E. Solander
Rocky Mountain Power
201 South Main Sheet, Suite 2400
Salt Lake City, Utah 84111
Telephone No. [phone]
Facsimile No. (801) 22A-3299
Email: daniel.solander@pacifi corp.com
Attorneysfor Rocky Mountain Power
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BEFORE TIIE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OT' THE PETITION
FOR MODIT'ICATION OF TERMS AND
CONDITIONS OF PURPA CONTRACTS
CASE NO. PAC.E.Is.O3
ATTORNEY'S CERTIFICATE
CLAIM OF CONTIDENTIALITY
RELATING TO DISCOYERY
RESPONSES
I, R. JeffRichards, represent Rocky Mountain Power in the above captioned maffer. I am
General Counsel 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 under IDAPA 31.01.01.067 and 31.01.01.233. Specifically,
Rocky Mountain Power asserts that the responses to IPUC Requests 2 and 3 contain confidential
information.
Rocky Mountain Power herein asserts that the aforementioned responses are confidential
in that the information contains commercially sensitive supporting information regarding
avoided cost calculations, a listing of the current QF queue for PacifiCorp in Idaho, as well as a
list of proposed Idaho PURPA projects currently seeking contracts with PacifiCorp. 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 "Confidentiai," as defined by Idatro Code
Section 9-340 and 48-801, and should therefore be protected from public inspection, examination
and copying, and slrould be utilized only in accordance with the terms of the Protective
Agreement between Rocky Mountain Power and Idatro Pubiic Utilities Commission StaJf,
DATED this 6th day of April,2015.
Re spectfu I I y submittgd,