20201204Certificate of Attorney.pdf

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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: [e-mail]

Attorney for Rocky Mountain Power BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
APPLICATION CAPACITY DEFICIENCY PERIOD

-E-20-13
CONFIDENTIALITY

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 Staff discovery 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 Confidential Attachment IPUC 18 provided with the Company’s responses to IPUC
Set 3 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.
RECEIVED
2020December 4, PM 3:48
IDAHO PUBLIC
UTILITIES COMMISSION
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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 4th day of December, 2020.

Respectfully submitted,

By__________________________
Emily Wegener Senior Attorney Rocky Mountain Power