20220316Certificate of Attorney.pdf

Emily L. Wegener (ISB #l1614)
Rocky Mountain Power
1407 W. North Temple, Suite 320
Salt Lake City, Utah 84116
Telephone No. (801) 2204526
Facsimile No. [phone]
Email: [e-mail]
Attorneyfor Rocley Mountoin Power
BEFORE TIIE IDAHO PTJBLIC UTILITIES COMMISSION
i{[CEIVED
;::; iifii i s &H ll: 37
' ,. ! l/t.,1 .l ilj:". '_t. i \.. : L, r/ ! r v: 1i i.;ti:: l-; r- li:,i;,!l$sloltj
IN TT{E MATTEROF THE PACIFICORP'S
APPLICATION FOR
ACKNOWLEDGEMENT OF THE 2021
INTEGRATED RESOURCE PLAN
CASENO. PAC.E.2I-19
ATTORNEY'S CERTTFICATE
CLAIM OF CONFIDENTIALITY
RELATING TO DISCOVERY
RESPONSES
)
)
)
)
)
)
)
)
)
)
[, Emily L. Wegener, represent Rocky Mountain Power in the above captioned matter. I
am a senior attomey for Rocky Mountain Power.
I make ttris certification and claim of confrdentiality regarding the response to the attached
Idaho Public Utilities Commission Staffdiscovery request pursuant to IDAPA 31.01.01 because
Rocky Mourtain 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 TDAPA 31.01.01.067 and 31.01.01.233. Specifically, Rocky Mountain Power
asserts that the attachment provided with the Company's response to Sierra Club 2, 2fr
Supplemental contains Company proprietary information that could be used to its commercial
disadvantage.
I
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 l6th day of March,2022.
Respectfu lly submitted,
Emily Wegener
Senior Attorney
Rocky Mountain Power
ry
2