20200828Certificate of Attorney.pdf

Emily L. Wegener (admitted pro hac vice)
Rocky Mountain Power
1407 W. North Temple, Suite 320
Salt Lake City, Utah 84116
Telephone No. [phone]
Facsimile No. [phone]
Email: emily.wegen [e-mail]
ii{:+:ilibr**
;ultj '!-:* ?8 fiS llr lt
,t,,'- ; ; ur*l"j- ,*i ,',1: ii*r,{isLqSi*-}{
Attorneyfor Roclqt Mountain Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF ROCKY MOUNTAIN POWER FOR
AUTHORZATION TO CHANGE
DEPRECIATION RATES APPLICABLE TO
ELECTRIC PROPERTY
CASENO. PAC-E-I8-08
ATTORNEY' S CERTIFICATE
CLAIM OF CONFIDENTIALITY
RELATING TO DISCOVERY
RESPONSES
)
)
)
)
)
)
)
)
)
)
I, Emily L. Wegener, represent Rocky Mountain Power in the above captioned matter. I
am a senior 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 Section74-l0l,et seq. and 48-801 and
protected under IDAPA 31.01.01.067 and 3I.U.01.233. Specifically, Rocky Mountain Power
asserts that the attachment provided with the Company's response to IIPA 3.1 I't Supplemental
contains Company proprietary information that could be used to its commercial disadvantage.
Rocky Mountain Power herein asserts that the aforementioned response contains Company
propri etary information.
I
I am of the opinion that this information is "Confidential," as defined by Idaho Code
Section 74-lOI, 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 28th day of August,2020
Respectfully submitted,
I
Emily egener
Senior Attorney
Rocky Mountain Power
2