20180124Certificate of Attorney.pdf

ELIZABETH THOMAS
PARTNER
K&L GATES LLP
925 FOURTH AVENUIi
SUITE 29OO
SEATTLE, WA 98104
PHONE: [phone]
LTz.THOMAS@KLGATES,COM
REC E IVE D
?OI8 JAN 2L AH 9: 55
ii),n,i,'ii) ullilLl0f ir l-1-ii:ri coMMtssl0N
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OT THE JOINT
APPLICATION OF HYDRO ONE LIMII'ED
AND AVTSTA CORPORATION I?OR
APPROVAL OF MERCER AGREEMHNT
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CASE NO. AVU.E.I7.O9
CASE NO. AVU-G-i7.05
ATTORNEY' S CERTIFICATE
CLAIM OF
CONFIDENTIALITY
RELATING TO HYDRO ONE
LIMITED'S DISCOVERY
RESPONSES
ATTORNEY'S CERTIFICATE . 1
600992033 v2
FOR HYDRO ONE LIMiTEI)
I, Elizabeth'fhornas, represent Hydro One Limited.I arn a partner at K&L Gates LLP,
and I am appearing on Hydro One's behalf in this proceeding, I rnake this certification and claim
of confidentiality pursuant to IDAPA 31.01,01 because Hydro One, through its response to Idaho
WNIDCL PR 20(HC)(H1), is disclosing certain information that is HIGHLY CONF'IDENTIAL
and constitutes'IRADE SECRETS as defined by Idaho Code Section 48-801 and protected
under Idaho Code 74-lO7 and IDAPA Rules 31.01.Oi,OOZ and 31.01,01.233.
The printed information Hydro One provides will, as rcquired under IDAPA Rule
3 1.01.01.067, be marked as I{lGIilLY CONFIDENTIAL and will be reproduced on green paper.
The highly confidential infonnation that Hydio One is di.sclosing is a list, timeline, and
schedule, for the period 2017 -2021 , of its future or active capital projects valued at more than $ I
million.
Hydro One asserts that the aforementioned informalion is highly confidential because:
(1) the information is not publicly available, (2) Hydr'<r One's potential contractors could use this
information to Eain an advantage in Hydro One's bidding process tbr future projects, and (3)
Hydro One's competitors and suppliers.could obtain econornic value from knowing Hydro
One's list, timeline, and schedule, for the period 2017.2021, for its future or active capital
projects valued at rnore than $l rnillion.
I am of the opinion that this information is HIGHLY CONFIDENTIAL, as defined by
Idaho Code 74-rc7 and 48-801, should tlierefore be protected from pubtic inspection,
examination and copying, and should be utilized only in accordance with the terms of thc
protective agreernents between Hydro One Lirnited, Avista Corporation, the Idaho Public
Utilities Commission Stafl, and the other parties to this proceeding.
ATTORNEY'S CERTIFICATE . 2
500992033 v2
RESPECTFULLY SUBMITTED this 13 TAY Of JCN,, 20 I 8.
Elizabeth Thomas
On behalf of Hydro One Limited
ATTORNEY'S CERTIFICATE - 3
500992033 v2