20180914Certificate of Attorney.pdf

Daniel E. Solander (ISB #8931)
Rocky Mountain Power
1407 West North Temple
Suite 320
Telephone No. [phone]
Email: daniel. soland [e-mail]
Attorneyfor RoclE Mountain Power
RECEIVED
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IN THE MATTER OF THE ROCKY
MOUNTATN POWER'S APPLICATION FOR
A DETERMINATION OF 2016 AND 2017
DEMAND-SIDE MANAGEMENT
EXPENSES AS PRUDENTLY INCURRED
CASENO. PAC-E-I8-07
ATTORNEY' S CERTIFICATE
CLAIM OF CONFIDENTIALITY
RELATING TO DISCOVERY
RESPONSES
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I, Daniel E. Solander, represent Rocky Mountain Power in the above captioned matter. I
am Assistant General Counsel for Rocky Mountain Power ("Company").
I make this certification and claim of confidentiality regarding the response to the attached
Idaho Public Utilities Commission Staffdiscovery request 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 SectionT4-L0t, 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 provided with the Company's response to IPUC Data Request 1
contains Company proprietary information that could be used to its commercial disadvantage.
Rocky Mountain Power herein asserts that the aforementioned responses contain
confidential in that the information contains Company proprietary information.
I
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
I am of the opinion that this information is "Confidential," as defined by Idaho Code
Section 74-10I, 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 in this proceeding.
DATED this l4th day of September,2018
Respectfu lly submitted,
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Daniel E. Solander
Attorneys for Rocky Mountain Power
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