20161214PAC Certificate of Attorney.pdf

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Daniel E. Solander (ISB #8931)
Rocky Mountain Power
1407 W. North Temple, Suite 320
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
FOR PRUDENCY DETERMINATION
OF DEMAND-SIDE MANAGEMENT
EXPENDITURES.
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CASE NO. PAC-E-16-14

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 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 (1) the attachment to the Company’s response to IPUC Data
Request 1 contains confidential vendor information; (2) the attachment to the Company’s
response to IPUC Data Request 4 contains proprietary forecast data; and (3) the attachment to
the Company’s response to IPUC Data Request 6 contains customer specific information.
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Rocky Mountain Power herein asserts that the aforementioned response is confidential. 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 13th day of December, 2016.

Respectfully submitted,

By__________________________
Daniel E. Solander

Attorneys for Rocky Mountain Power