20211013Certificate of Attorney.pdf

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:;i: xiT i3 Pi{ 5: illEmily L. Wegener(lSB #l 1614)
Rocky Mountain Power
1407 W. North Temple, Suite 320
Salt Lake City, Utah 84116
Telephone No. (801) 2204526
Facsimile No. [phone]
Email : emi ly.wegener@pacificorp. com
Attorneyfor Roclcy Mountain Power
BEFORE TIIE IDAHO PTIBLIC UTILITIES COMIVIISSION
TN THE MATTER OF THE APPLICATION
OF ROCKY MOUNTATN POWER FOR
AUTHORITY TO TMPLEMENT A BATTERY
DEMAND RESPONSE PROGRAM
CASENO. PAC.E.2I-I6
ATTORNEY'S CERTIFICATE
CLAIM OF CONFTDENTI-ALITY
RELATTNG TO DISCOVERY
RESPONSES
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I, Emily L. Wegener, represent Rocky Mountain Power in the above captioned matter. 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 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 responses provided with the Company's responses to IPUC Set 3 contain 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.
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I am of the opinion drat this information is 'Confidential," as defined by Idaho Code
Section 74-lAL et seq. and 48-801, and should thereforc be protocted from public inspection,
examination and copying, and should be utilized onty in accordance with fte tefins of the
Protective Agreement in dds proceeding.
DATED ftis 13t]t dayof October, 2021.
Respccdulty submited,ryW
Emily lVegener
SeniorAttorney
Rocky Morrrtain Power
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