20201106Certificate 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 : emi ly. wege ner@pacifrcofp. com
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Attorneyfor Roclqt Mountain Power
BEFORE TIIE IDAHO PI]BLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
FOR CAPACITY DEFICIENCY PERIOD
USED FOR AVOIDED COST
CALCULATIONS
CASENO. PAC.E.2O-13
ATTORNEY'S CERTIFICATE
CLAIM OF CONFIDENTIALITY
RELATING TO DISCOVERY
RESPONSES
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I, Emily L. Wegener, represent Rocky Mountain Power in the above captioned matter. I
am a senior 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
andlor 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 Confidential attachment IPUC I provided with the Company's responses to IPUC Set
I 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.
I am of the opinion that this information is 'oConfidential," as defined by Idaho Code
Section 74-l}l, 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 6th day ofNovember, 2020.
Respectfu lly submitted,ryW
Emily Wegener
Senior Attorney
Rocky Mountain Power
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