20160115PAC Attorney Attestation.pdf

1 
Daniel E. Solander (ISB #8931)
Rocky Mountain Power
201 South Main Street, Suite 2400
Salt Lake City, Utah 84111
Telephone No. [phone]
Facsimile No. [phone]
Email: [e-mail]

Attorneys for Rocky Mountain Power

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

)
IN THE MATTER OF THE APPLICATION )
OF PACIFICORP D/B/A ROCKY )
MOUNTAIN POWER OF THE ASSET )
PURCHASE AGREEMENT )
BETWEEN ROCKY MOUNTAIN )
POWER AND THE CITY OF IDAHO )
FALLS. ) )

CASE NO. PAC-E-15-15

ATTORNEY’S CERTIFICATE
CLAIM OF CONFIDENTIALITY
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 IPUC Requests pursuant to IDAPA 31.01.01
because Rocky Mountain Power, through its response, is disclosing certain information that is
Confidential and/or constitutes Trade Secrets as defined by Idaho Code Section 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 attachment to the response to IPUC Request 1 contains
confidential customer information.
Rocky Mountain Power herein asserts that the aforementioned response is confidential in
that the information contains confidential customer information.
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I am of the opinion that this information is “Confidential,” 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 14th day of January, 2016.

Respectfully submitted,

By
Daniel E. Solander
Attorneys for Rocky Mountain Power