20210923Certificate of Attorney.pdf

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Emily L. Wegener (lSB #11614)
Rocky Mountain Power
1407 W. North Temple, Suite 320
Salt Lake City, Utah 841l6
Telephone No. (801) 2204526
Facsimile No. [phone]
Email: [e-mail]
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Attorneyfor Rocly Mountain Power
BEFORE TIIE IDAHO PUBLIC UTILITIES COMMISSION
TN THE MATTER OF THE APPLICATION
OF ROCKY MOI-]NTAIN POWER FOR
AUTFIORITY TO TNCREASE ITS RATES
AND CHARGES IN IDAHO AND
APPROVAL OF PROPOSED ELECTRIC
SERVICE SCHEDULES AND
REGULATTONS
CASENO. 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 mafier. I
am a senior attomey 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 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 attachment provided with the Company's responses to PIIC 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 23rd day of September,202l.
Respectfu lly submitted,4W
Emily Wegener
Senior Attomey
Rocky Mountain Power
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