20170112PAC Certificate of Attorney.pdf

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Daniel E. Solander (ISB #8931)
Rocky Mountain Power
1407 West North Temple
Suite 320
Telephone No. [phone]
Email: [e-mail]

Attorney for Rocky Mountain Power

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF THE APPLICATION
OF ROCKY MOUNTAIN POWE
REQUESTING A PRUDENCY
DETERMINATION ON DEMAND-SIDE
MANAGEMENT EXPENSES
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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 data 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 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 attachment to the response to IPUC Set 2, Request 16 contains
confidential customer information. Disclosing this information could give entities access to
confidential customer information Rocky Mountain Power believes could be used to disadvantage
it and its customers.
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Rocky Mountain Power herein asserts that the aforementioned response is confidential
information and/or 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 11th day of January 2017.

Respectfully submitted,

By__________________________
Daniel E. Solander
Attorneys for Rocky Mountain Power