20221220Certificate of Attorney.pdf

Joe Dallas (ISB# 1033)
Rocky Mountain Power
825 NE Multnomah, Suite 2000
Portland, OR97232
Telephone : [phone]
Email: joseph.dallas@pacifi corp.com
Attorneyfor Rocley Mountain Power
BEFORE TIIE IDAHO PT'BLIC UTILITIES COMIVISSION
,ir_cflvEO
t*i? 0[c 20 PH 5: t 5
j :'. ji;'i Iu3llc,r::t CC,\!MISSION
IN THE MATTER OF THE APPLICATION
OF ROCKY MOUNTAIN POWER
APPROVAL OF A CAPACITY
DEFICIENCY PERIOD TO BE USED
FOR AVOIDED COST CALCUI,ATIONS
CASE NO. PAC-E-22-14
ATTORNEY'S CERTIFICATE
CLAIM OF CONFIDENTI,ALITY
RELATING TO DISCOVERY
RESPONSES
)
)
)
)
)
)
)
)
)
)
)
)
I, Joe Dallas , represent Rocky Mountain Power in the above captioned matter. I am an
attomey 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 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 first supplemental response to IPUC
data request 9 contains Company proprietary information that could be used to its commercial
disadvantage.
Rocky Mountain Power hwin asserts that the aforementioned rosponse contains
confidential in that the information contains Company 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 thenefore be protected from public inqpection,
examination and copying and should be utilized only in accordance with the temrs of the
Protective Agreement in this proceeding.
DATED this 20th day of December, 2022.
Reqpectfully submite4
Joe Dallas
SeniorAttomey
Rocky Mountain Power
2