20210406Certificate of Attorney.pdf

Adam Lowney (ISB#10456)
McDowell Rackner Gibson PC
419 SW l lth Avenue,Suite 400
Portland,Oregon 97205
Telephone:[phone]
Facsimile:[phone]
Email:[e-mail]
Attorneyfor Rocky Mountain Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
)CASE NO.PAC-E-21-01INTHEMATTEROFTHEAPPLICATION)FOR APPROVAL OF TRANSFER )ATTORNEY'S CERTIFICATEAGREEMENTWITHLOWERKLAMATH)CLAIM OF CONFIDENTIALITYHYDROELECTRICPROJECT)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
Idaho Public Utilities Commission Staff discovery request pursuant to IDAPA 31.01.01 because
Rocky MountainPower,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 response to IPUC Set 2 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 proprietaryinformation.
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I am of the opinion that this information is "Confidential,"as defmed 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 6th day of April,2021.
Respectfully submitted,
By
Adam Lowney
Attorney for Rocky Mountain Power
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