20151230Certificate of Attorney.pdf

Daniel E. Solander (ISB #8931)
Rocky Mountain Power
1407 West North Temple Suite 320
salt Lake city, uT 841l6
Telephone No. [phone]
Email : daniel. solander@pacifi corp.com
Attorneysfor RoclE Mountain Power
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UTILITIES COhIMISSION
BEFORE TIIE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF PACIFICORP DTBIA ROCKY
MOUNTAIN POWER TO UPDATE
ELECTRIC SERYICE REGULATION NO.
13 CURTAILMENT PLAN FOR
ELECTRIC ENERGY
CASE NO. PAC.E.15-10
ATTORNEY'S CERTIFICATE
CLAIM OF CONFIDENTIALITY
RELATING TO DISCOYERY
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 certain responses to the
IPUC discovery requests in the maffer referenced above pursuant to IDAPA 31.01.01 because
Rocky Mountain Power, through its responses, is disclosing certain information that is
Confidential and/or constitutes Trade Secrets as defined by Idaho Code Sections 74-101, et seq.
and 48-801 and protected under IDAPA 31.01.01.067 and 31.01.01.233. Specifically, Rocky
Mountain Power asserts that the affachments to the responses to IPUC Requests 23,28,31, 3l
and 35 contain commercially sensitive information, confidential transmission and generation
information, and/or critical infrastructure information. Disclosing this information could give
entities access to competitive information andlor critical information regarding generation and
transmission infrastructure Rocky Mountain Power believes could be used to disadvantage it and
its customers and/or create a public safety hazard.
Rocky Mountain Power herein asserts that the aforementioned responses are confidential,
critical infrastructure information andlor trade secrets in that the information contains
commercially sensitive information as described above.
I am of the opinion that this information is "Confidential," and or constitutes Trade
Secrets as defined by Idaho Code Section 74-101, et seq. 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 30s day of December, 2015.
Respectfully submitted,
Daniel E. Solander
Attorneys for Rocky Mountain Power