20221115Certificate ofAttorney.pdf

Joe Dallas (lSB #10330)
825 NE Multnomah, Suite 2000
Portland, OR97232
Telephone No. [phone]
Emai I : j oseph. dall as@pacifrcorp. com
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Attorneyfor Rocly Mountain Power
BEFORE TIIE IDAHO PT]BLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLTCATION
OF ROCKY MOUNTAIN POWER FOR
APPROVAL OF A CAPACITY DEFICIENCY
PERIOD TO BE USED FOR AVOIDED COST
CACULATIONS
CASE NO. PAC-E.22-14
ATTORNEY'S CERTIFICATE
CLAIM OF CONFIDENTIALITY
RELATING TO DTSCOVERY
RESPONSES
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l, Joe Dallas, represent Rocky Mountain Power in the above captioned matter. I am an
attorney for Rocky Mountain Power.
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 Section 74-101, et seq. and 48-801 and
protected under IDAPA 31.01.01.M7 and 31.01.01.233. Specifically, Rocky Mountain Power
asserts that Confidential Attachment IPUC l, 4,8, and l2-2 provided with the Company's response
to IPUC Data Requests Nos. l-24 contain 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 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 this l5th day ofNovenrber,2022.
Respectfu lly submitted,
a <.,
Joe Dallas
Senior Attorney
Rocky Mountain Power
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