Parties Respond to Joint IOU's Motion to Amend Scoping Memo

San Diego Community Power and Clean Energy Alliance:

• The motion should be denied because the proposed changes prejudice intervenors by leaving them without critical information and without adequate time to prepare between major deadlines. The schedule would advance intervenor testimony by six weeks, from March 17, 2023, to February 2, 2023, before the prior year’s recorded cost data is made available, and it would advance the beginning of evidentiary hearings by over a month, from May 22, 2023, to April 17, 2023.
• Upon a meet and confer, parties universally opposed Sempra's proposed schedule.
• The proposed schedule changes will substantially advantage Sempra and substantially disadvantage intervenors without improving outcomes in this proceeding.

TURN:

• Sempra Utilities’ frivolous Motion to Amend the Assigned Commissioner’s Scoping Memorandum and Ruling should be summarily denied because it repeats the same arguments already rejected by the Assigned Commissioner’s Scoping Memo, and it could set a dangerous and harmful precedent.
• Sempra Utilities are not able to articulate a reason for why the time to respond should be shortened, Sempra Utilities’ Joint Motion to Shorten Time for Responses should be denied.

Community Legal Services:

• Relitigating the same arguments wastes everyone’s time and goes against the important policy of conserving judicial resources. Sempra fails to either provide new information that was not available before or to cite to any change in circumstances that warrants reconsideration of the same arguments.
• The Sempra GRC is essentially two GRCs rolled into one with limited overlap, which means that intervenors need sufficient time to review the extensive amount fo information provided by both utilities; therefore, the Commission should keep the schedule as set out in the scoping memo.
• Intervenors have planned the handling of this GRC and balancing their involvement in it with other cases on the premise that the schedule set in the Scoping Memo is the schedule that will be followed.
• If the Commission were to adopt Sempra’s proposed schedule, CommLegal respectfully requests that the start of evidentiary hearings be moved to after April 27, 2023.