20221101Certificate of Attorney.pdf

iJ.ECEIVED
iii;i fi0\l - I Al'l ll: h6Joe Dallas (lSB #10330)
825 NE Multnomah, Suite 2000
Portland, OR97232
Telephone No. [phone]
Email : joseph. dallas@pacifi corp.com
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Attorneyfor Rocly Mountain Power
BEFORE TIIE IDAHO PIIBLIC UTILITMS COMMISSION
IN THE MATTER OF THE APPLICATION
OF ROCKY MOUNTAIN POWER FOR
AUTHORITY TO IMPLEMENT A
COMMERICAL AND INDUSTRIAL
DEMAND RESPONSE PROGRAM
CASE NO. PAC-E.22.13
ATTORNEY' S CERTIFICATE
CLAIM OF CONFIDENTTALTTY
RELATING TO DISCOVERY
RESPONSES
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I, Joe Dallas, represent Rocky Mountain Power in the above captioned matter. I am an
attomey 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 Confidential Attachment IPUC 16 provided with the Company's response to IPUC
Data Requests No. 12 and 16 contain Company proprietary information that could be used to its
commercial disadvantage.
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Rocky Mountain Power herein asserts that the aforementioned reqponses contain
confidentialinthatthe informationoontains Company information.
I am of the opinion that this information is *Confidential," as defined by Idalrc Code
Section 74-101, et seq. and 48-801, and should thenefore be protected from public inspectiort
examination and copying.
DATED this lst day ofNovember, 2A22.
Respectfirlly submitted,
Joe Dallas
SeniorAttorney
Rooky Mountain Powet
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