20220510Certificate of Attorney.pdf

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Emily L. Wegener (admitted pro hac vice)
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 @pacifrcorp. com
Attorneyfor Roclgt Mountain Power
BEFORE TIIE IDAHO PUBLIC UTILITIES COMMISSION
IN TI{E MATTER OF THE APPLICATION
OF ROCKY MOUNTAIN POWER
APPROVAL OF POWER COST DEFERRAL -
DECREASE IN RATES IECAM]
CASE NO. PAC.E-22.05
ATTORNEY'S CERTIFICATE
CLAIM OF CONFIDENTIALITY
RELATING TO DISCOVERY
RESPONSES
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I, Emily L. Wegener, represent Roclcy 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 Staffdiscovery 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 defrned by ldaho Code SectionT4-lOl, 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 attachments provided with the Company's responses to PIIC Set I contain
Company proprietary information that could be used to its commercial disadvantage.
Rocky Mountain Power herein asserts that the aforementioned responses contain
confidential in that the information contains Company proprietary information.
I am of the opinion ttrat this information is "Confidential," as defined by tdaho Code
Section 74-101, et seq. and 48-801, and should ttrerefore 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 10th day of May,2022.
Respectfu lly submitted,4w
Emily Wegener
Senior Attorney
Rocky Mountain Power
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