20200511Certificate of Attorney.pdf

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Adam Lowney (ISB#10456)
McDowell Rackner Gibson PC
419 SW 11th Avenue, Suite 400
Portland, Oregon 97205
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]

Attorney for Rocky Mountain Power

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF THE APPLICATION
OF ROCKY MOUNTAIN POWER
APPROVAL OF POWER COST DEFERRAL -
DECREASE IN RATES [ECAM]

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CASE NO. PAC-E-20-02

ATTORNEY’S CERTIFICATE
CLAIM OF CONFIDENTIALITY
RELATING TO DISCOVERY
RESPONSES

I, Adam Lowney, represent Rocky Mountain Power in the above captioned matter.
I make this certification and claim of confidentiality regarding the response to the attached
PacifiCorp Idaho Industrial Customers (PIIC) discovery requests 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 the attachments provided with the Company’s Responses to PIIC’s
Data Requests 3 and 5 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.
RECEIVED
2020 May 11PM3:23
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 in this proceeding.

DATED this 11th day of May, 2020.

Respectfully submitted,
By__________________________
Adam Lowney
Attorney for Rocky Mountain Power