20210805PAC to Bayer Certificate of Attorney.pdf

Emily L. Wegener (ISB #11614)
Rocky Mountain Power
1407 W. North Temple, Suite 320
Salt Lake ciry, utah 84116
Telephone No. [phone]
Facsimile No. [phone]
Email : emi ly. wege ner @pacifrcorp. com
Attorneyfor Roclqt Mountain Power
BEFORE THE IDAHO PUBLIC UTILITMS COMMISSION
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IN THE MATTER OF THE APPLICATION
OF ROCKY MOUNTAIN POWER FOR
AUTHORITY 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 afforney 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 the attachments and responses provided with the Company's responses to Bayer 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 information that the information contains Company proprietary information.
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 5th day of August, 2021.
Respectfrrlly submitted,ryW
Emily Wegener
SeniorAttorney
Roclcy Mountain Power
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