20210804Certificate of Attorney.pdf

Emily L. Wegener (ISB #11614)
Rocky Mountain Power
1407 W. North Temple, Suite 320
Salt Lake City, Utah 84116
Telephone No. [phone]
Facsimile No. [phone]
Email : emi ly. weg ener @pacifi corp. com
Attorney for Roclry Mountain Power
BEFORE THE IDAHO PUBLIC UTILITMS COMMISSION
IN THE MATTER OF THE APPLICATION
OF ROCKY MOUNTAIN POWER FOR
AUTHOzuTY TO INCREASE ITS RATES
AND CHARGES IN IDAHO AND
APPROVAL OF PROPOSED ELECTRIC
SERVICE SCHEDULES AND
REGULATIONS
CASE NO. PAC-E-21-07
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 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 Motrntain 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 attachments provided with the Company's responses to IIPA Set 3 contain Company
proprietary information that could be used to its commercial disadvantage.
I
Rocky Mountain Power herein asserts that the aforementioned responses contain
confidential infonnation that the information contains Company proprietary information.
I am of the opinion that this information is "Confidential," as defined by Idatro 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 August,z0zl.
Respectfrrlly submiued,ryW
Emily Wegener
SeniorAttorney
Rocky Morurtain Power
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