20221005Certificate of Attorney.pdf

Joe Dallas 0SB #10330)
825 NE Multnomah, Suite 2000
Portland, OR97232
Telephone No. [phone]
Email : joseph.dallas@pacifi corp.com
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Attorneyfor Roclry Mountain Power
BEFORE TIM, IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF ROCKY MOUNTATN POWER
REQUESTTNG A PRUDENCY
DETERMINATION ON DEMAND-SIDE
MANAGEMENT EXPENDITURE S
CASE NO. PAC-E-22-12
ATTORNEY'S CERTIFICATE
CLAIM OF CONFIDENTIALITY
RELATTNG TO DISCOVERY
RESPONSES
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I, Joe Dallas, 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 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 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 the attachments provided with the Company's response to IPUC Data Requests No. 4
and 7 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 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 5th day of October,2022.
Respectfully zubmitte{
Joe Dallas
SeniorAttomey
Rocky Momtain Power
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