20210429Certificate of Attorney.pdf

Adam Lowney (lSB#l 0456)
McDowell Rackner Gibson PC
419 SW 1lth Avenue, Suite 400
Portland, Oregon 97205
Telephone: [phone]
Facsimile: [phone]
Email : adam@mr g-law. com
Attorneyfor RoclE Mountain Power
BEFORE TIIE IDAHO PUBLIC UTILITMS COMMISSION
IN THE MATTER OF THE JOINT
APPLICATION BETWEEN ROCKY
MOI.INTAIN POWER AND P4
PRODUCTION, L.L. C. REQUESTING
APPROVAL OF AN AGREEMENT TO
RETIRE RECS
CASE NO. PAC.E.21-08
ATTORNEY'S CERTIFICATE
CLAIM 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 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 responses and attachments provided with the Company's responses 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.
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I am of the opinion that this information is "Confidentiat" as defind by Idaho Code
Section 74-101, et seq. and 4&801, and should ih€reforc be protected from public inspectioq
examination and copying, and should be utilired only in accordance with fte t€rms of the
Protective Agreement in this proceeding.
DATED this 29th day of April,z02l.
Respectfully submitted,
Adam Lowney
Attomey for Rocky Mountain Power
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