20161018PAC Certificate of Attorney.pdf

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Daniel E. Solander (ISB #8931)
Rocky Mountain Power
1407 W. North Temple, Suite 310
Salt Lake City, Utah 84116
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
PPLICATION OF PACIFICORP
DBA ROCKY MOUNTAIN POWER TO
UPDATE BASE NET POWER COSTS
ND IMPLEMENT A RATE
STABILITY PLAN.
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CASE NO. PAC-E-16-12

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 response to the attached
discovery request and response to PIIC Requests 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 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 attachments to the Company’s response to PIIC 8 contain proprietary data and
software.
Rocky Mountain Power herein asserts that the aforementioned attachments to this response
are confidential in that the information provided contains proprietary data and software.
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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 PacifiCorp Idaho Industrial
Customers.

DATED this 18th day of October, 2016.

Respectfully submitted,

By__________________________
Daniel E. Solander
Attorneys for Rocky Mountain Power