20221220Certificate of Attorney.pdf

Joe Dallas 0SB# 1033)
Rocky Mountain Power
825 NE Multnomah, Suite 2000
Portland, OR97232
Telephone: [phone]
Email : joseph.dallas@pacifi corp.com
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Attorneyfor Rocly Mountain Power
BEFORE TIIE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF ROCI(Y
MOUNTAIN POWER'S APPLICATION
FOR AUTHORITY TO IMPLEMENT
THE RESIDENTIAL RATE
MODERNIZATION PI,AN
CASENO. PAC-E-22-15
ATTORNEY'S CERTIFICATE
CLAIM OF CONFIDENTIALITY
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 the attachments provided with the Company's response to IPC data request 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.
I
I am of the opinion tlut this information is "Confidential"" as defined by Idatro Code
Sestion 74-101, et seq. and 48-801, and should therefure be protected from public inspection,
exarninadon and copying, srd strould be utilized only in accordance with the terms of the
Prctective Agreement in this proceding.
DATED this 20th day of December, 2022.
Respectfrrlly submitre4
tG\
IoeDallas
SeniorAttomey
Rocky Mormhin Power
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