20211013Certificate of Attorney (Bayer3).pdf

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:liitiT i3 Pt{ 5:03Emily L. Wegener (lSB #11614)
Rocky Mountain Power
1407 W. North Temple, Suite 320
Salt Lake city, utah 84116
Telephone No. (801) 2204526
Facsimile No. [phone]
Email : emi ly. wege ner @pacificorp. com
SgicN
Attorneyfor Rocly Mountain Power
BEFORE TIIE IDAHO PTJBLIC UTILITIES COMMISSION
TN THE MATTER OF THE APPLICATION
OF ROCKY MOUNTATN POWER FOR
AUTHORITY TO INCREASE ITS RATES
AND CHARGES IN IDAHO AND
APPROVAL OF PROPOSED ELECTRIC
SERVICE SCHEDULES AND
REGULATIONS
CASENO. PAC.E.2I.O7
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 3l .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 response provided with the Company's responses to Bayer Set 15, specifically the
I't Revised Response to Bayer Data Request 167 contains Company proprietary information that
could be used to its commercial disadvantage.
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Rocky Mountain Power herein asserts that the aforementioned rtsponses contain
confidenfial informationthatthe infonnationcontains Companyproprietary information
I am of the opinion {rat *ris information is "Confidential," as defiued by Idaho Code
Section 74-101, et seq. and 48-801, and should flrerefore be proteeted from public inspoction,
exsmination and copying, and shoukl be utilized only in accordance wittr the torms of the
hotoctive Agreement in this proceding.
DATED this l3th day of October, 2A21.
Respectfu lly submitted,ryW
Emrly Wegener
SeniorAttorney
Rocky Mountain Power
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