# LP-075 §13.1 Cold Review Set

**Review set:** LP075-SECTION-13-1-REVIEW-SET  
**Amendment filed:** 2289-03-01  
**Cold review published:** 2290-01-15  
**Reviewer replies published:** 2290-05-01  
**Chamber adoption:** 2291-01-15  
**Presidential disposition and enactment:** 2291-01-20

## I. Mechanical reviewer selection

The Meritboard audit-methodology ranking was snapshotted on 2289-03-15. Rank 1 was ineligible because of prior authorship exposure. Rank 2, AUDIT-METHOD-ENTITY-12, was eligible and therefore selected mechanically as the highest-ranked eligible entity. Rank 3 was not reached. No sponsor, drafter, chamber, or Presidency office selected the reviewer.

The machine-readable ranking, eligibility reasons, findings, dispositions, replies, adoption votes, and veto flag publish in `lp-075-section-13-review-set-data.json`.

## II. Cold-review findings and replies

### R1 — Conflict with the Presidency's Part V no-duty holding

**Severity:** Highest.  
**Finding:** Compelled commencement reverses the adopted statement that non-commencement is not a defect and that the status quo bears no burden of motion.  
**Disposition:** Sustained as a real conflict and presented as a prospective Charter amendment, not construed away.  
**Reviewer reply:** Section 13.1 permits the chambers to amend cadence prospectively. The amendment is legally available only if it preserves the first window as lawful history and leaves every factual and evidentiary gate untouched. The reviewer maintained a standing objection to reversal of the no-duty policy, requiring a presidential veto flag.

### R2 — RR-8 and the first window

**Severity:** High.  
**Finding:** RR-8 prices 2279–2288 non-commencement as lawful history.  
**Disposition:** Sustained and preserved.  
**Reviewer reply:** LP-075 does not retroactively relabel the first window. It creates a prospective cadence duty and a remedial constitution for the second window. RR-8 remains the controlling description of the first.

### R3 — Risk that commencement becomes compelled certification

**Severity:** High.  
**Finding:** A commencement duty could be read as pressure toward a rate outcome.  
**Disposition:** Cured by outcome neutrality.  
**Reviewer reply:** Certification, failure, and every legally recognized void remain available. LP-075 changes no Finding, threshold, estimand, evidentiary quarantine, or Lower incidence standard and gives no chamber power to direct the result.

### R4 — Strategic non-locking

**Severity:** Medium.  
**Finding:** A constituted Commission could dissolve and recreate omission.  
**Disposition:** Cured by replacement constitution, public attribution, and Meritboard sanction.  
**Reviewer reply:** The replacement duty closes strategic dissolution without altering the audit's merits or evidence.

Every reviewer reply above published before the adoption vote.

## III. Chamber adoption

| Gate | Result |
|---|---:|
| Meritboard | 73% |
| Supreme Court | 7/10 |
| Sanctuary | 97% |
| Main | 84% |
| Lower-layer aggregate | 72% |

The chambers adopted LP-075 as a §13.1 amendment to cadence only. They did not set a rate, activate a schedule, or weaken A1–A8 or B1–B6.

## IV. Presidential veto flag

The highest-severity standing objection was flagged to the Presidency. The veto was not exercised. The published disposition held that the no-duty rule was binding under the 2279 Charter but amendable through §13.1; that LP-075 displaced it prospectively, not retroactively; that the first window remained lawful; and that compelling a fact-finding process did not prejudge the fact found.

## V. Final disposition

LP-075 survived §13.1. It was enacted on 2291-01-20, required the remedial Commission within 180 days, and required a lock no later than 2292. Its authority was procedural. LP-074 and the later certificates remained the only route to a rate change.

Part of the 2294 Ratification Record