20210907Certificate of Attorney.pdf

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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: [e-mail]
Attorney for Rocky Mountain Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF ROCKY MOUNTAIN POWER FOR

-E-21-07

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 the attachment provided with the Company’s response to Bayer 21 1st Supplemental
contains Company proprietary information that could be used to its commercial disadvantage.
RECEIVED
2021 SEP 7 PM 2:54
IDAHO PUBLIC
UTILITIES COMMISSION
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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 7th day of September, 2021.

Respectfully submitted,
By__________________________ Emily Wegener
Senior Attorney
Rocky Mountain Power