20210225Certificate of Attorney.pdf

Adam Lowney (158#10456)
McDowell Rackner Gibson PC
419 SW l lth Avenue, Suite 400
Portland, Oregon 97205
Telephone: [phone]
Facsimile: [phone]
Email : adam@mr g-law. com
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Attorneyfor Rocly Mountain Power
BEFORE TIIE IDAHO PTIBLIC UTILITMS COMMISSION
IN THE MATTER OF THE APPLICATION
FOR APPROVAL OF TRANSFER
AGREEMENT WITI{ LOWER KLAMATH
HYDROELECTRIC PROJECT
CASENO. PAC.E.21.O1
ATTORNEY'S CERTIFICATE
CLATM OF CONFIDENTIALITY
RELATING TO DISCOVERY
RESPONSES
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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
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 IPUC Set I 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.
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 25th day of February,2l2l.
Respectfu lly submitted,
Adam Lowney
Attomey for Rocky Mountain Power
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