20210511Certificate of Attorney.pdf

Adam Lowney 058#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
Attorneyfor Roclry Mountoin Power
BEFORE THE IDAHO PI'BLIC UTILITIES COMMISSION
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IN THE MATTER OF THE JOINT
APPLICATION BETWEEN ROCKY
MOUNTAIN POWER AND P4
PRODUCTION, L.L.C. REQUESTING
APPROVAL OF AN AGREEMENT TO
RETIRE RECS
CASE NO. PAC.E.2I.O8
ATTORNEY' S CERTIFICATE
CLAIM OF CONFIDENTIALITY
RELATING TO DISCOVERY
RESPONSES
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[, 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 deflu:ed 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 attachments provided with the Company's responses 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 information that the information contains Company proprietary information.
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I am of the opinion that this information is "Confidential," as d€fined by Idaho Code
Section 74-t01, et seq. and 48-801, and should therefore be protectd from public inspection"
examination and copying, 6od should be utilized only in accordance wift fte t€rms of fte
Protective Agneement in this proceeding.
DATED this I lth day of l[ay, 2021.
Respwtfrrlly submittcd,
Adam Loumey
Attomey forRocky Mountain Power
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