20200915Certificate 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.wegener@pacifi corp.com
Attorneyfor Roclqt Mountain Power
BEFORE THE IDAIIO PUBLIC UTILITIES COMMISSION
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IN THE MATTER OF THE APPLICATTON
FOR APPROVAL OF POWER PURCHASE
AGREEMENT WITH FALL RIVER
ELECTRIC
CASE NO. PAC-E.20-10
ATTORNEY' S CERTIFTCATE
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 SectionT4-L}L, 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 attachment provided with the Company's responses to IPUC Set 4 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 tdaho 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 15th day of September, 2020.
Respectfully submitted,ryMr
EmilyWegener
Senior Attorney
Rocky Mountain Power
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