HomeMy WebLinkAbout20230306Attorney Attestation PAC to ICL_NWEC 14.pdf 1
Joe Dallas (ISB# 1033) Rocky Mountain Power 825 NE Multnomah, Suite 2000 Portland, OR 97232
Telephone: 360-560-1937 Email: joseph.dallas@pacificorp.com
Attorney for Rocky Mountain Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF ROCKY MOUNTAIN POWER’S APPLICATION FOR AUTHORITY TO IMPLEMENT THE RESIDENTIAL RATE MODERNIZATION PLAN
-E-22-15
DISCOVERY
I, 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 Conservation League (“ICL”) NW Energy Colation (“NWEC”) data 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 31.01.01.067 and 31.01.01.233.
Specifically, Rocky Mountain Power asserts that the attachments provided with the Company’s
response to ICL and NWEC data request 14 contains Company proprietary information that could
be used to its commercial disadvantage.
RECEIVED
2023 March 6, PM 12:11
IDAHO PUBLIC
UTILITIES COMMISSION
2
Rocky Mountain Power herein asserts that the aforementioned response contains
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 22th day of December, 2022.
Respectfully submitted,
By__________________________ Joe Dallas
Senior Attorney
Rocky Mountain Power