20230124Certificate of Attorney.pdf

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Joe Dallas (ISB# 1033) Rocky Mountain Power 825 NE Multnomah, Suite 2000 Portland, OR 97232
Telephone: [phone] Email: [e-mail]
Attorney for Rocky Mountain Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF ROCKY MOUNTAIN POWER’S APPLICATION FOR AUTHOIRTY TO IMPLEM,ENT A COMMERCIAL AND INDUSTRIAL DEMAND RESPONSE PROGRAM

-E-22-13
CONFIDENTIALITY

I, Joe Dallas , represent Rocky Mountain Power in the above captioned matter. I am an
attorney for Rocky Mountain Power.
I make this certification and claim of confidentiality regarding the response to the attached
Bayer Corporation (“Bayer”) 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 attachments provided with the Company’s response to Bayer data requests 2 and 3
contains Company proprietary information that could be used to its commercial disadvantage.
Rocky Mountain Power herein asserts that the aforementioned response contains
confidential in that the information contains Company proprietary information.
RECEIVED
Monday, January 23, 2023 3:06:59 PM
IDAHO PUBLIC
UTILITIES COMMISSION
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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 executed with Bayer in this proceeding.

DATED this 23rd day of January, 2023.

Respectfully submitted,

By__________________________
Joe Dallas Senior Attorney Rocky Mountain Power