20210920Certificate of Attorney.pdf

Emily L. Wegener (lSB #11614)
Rocky Mountain Power
1407 W. North Temple, Suite 320
Salt Lake City, Utah 841l6
Telephone No. [phone]
Facsimile No. [phone]
Emai I : emi ly.wege ner @pacifrcorp. com
Attorneyfor Rocky Mountain Power
BEFORE TIIE IDAHO PI]BLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF ROCKY MOUNTAIN POWER FOR
AUTHORITY TO TNCREASE ITS RATES
AND CHARGES TN IDAHO AND
APPROVAL OF PROPOSED ELECTRIC
SERVTCE SCHEDULES AND
REGULATIONS
CASENO. PAC.E-21.07
ATTORNEY'S CERTIFICATE
CLAIM OF CONFTDENTIALITY
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 affomey for Rocky Mountain Power.
I make this certification and claim of confidentiality regarding the response to the attached
ldaho 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 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 the attachment provided with the Company's responses to Bayer Set I I 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 20th day of September,202l
Respectfu lly submitted,ryW
Emily Wegener
SeniorAttomey
Rocky Mountain Power
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