20240308Attorney Attestation.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 APPROVAL OF ADJUSTMENTS TO THE IRRIGATION LOAD CONTROL PROGRAM

-E-24-XX
DISCOVERY

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 Staff 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 the Company’s response IPUC Data Request No. 1 and 10 contains 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.
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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 in this proceeding.

DATED this 4th day of March, 2024.

Respectfully submitted,

By__________________________
Joe Dallas Senior Attorney Rocky Mountain Power