HomeMy WebLinkAbout20190322Certificate of Attorney.pdfi} rll .n il I 1 I E i'ti!,- /1,-l'J I*L"'
i-r ;liiir: 22 Pli 2: llDaniel E. Solander (ISB #8931)
Rocky Mountain Power
1407 WestNorth Temple
Suite 320
Telephone No. (801 ) 220-40t4
Email: daniel. solander(grpaciflcorp. com
Attorneyfor RoclE Mountain Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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IN THE MATTER OF THE APPLICATION
FOR APPROVAL OF THE SANDY DOWNS
ASSET PURCHASE AGREEMENT
BETWEEN ROCKY MOUNTAIN POWER
AND THE CITY OF IDAHO FALLS
CASE NO. PAC-E-19-02
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 Staff discovery 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 SectionT4-101, 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 provided with the Company's response to IPUC Data Request I
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.
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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 in this proceeding.
DATED this22"d day of March,z}lg.
Respectfu lly submitted,
Daniel E.
Attorneys for Rocky Mountain Power
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