Surfrider Foundation's Comments on the Proposed Settlement
Agreement on Plant Size and Level of Operation
SURFRIDER FOUNDATION'S COMMENTS ON THE PROPOSED SETTLEMENT AGREEMENT ON PLANT SIZE AND LEVEL OF OPERATION
Thursday, September 12, 2013
Proceeding Number A.12-04-019 SURFRIDER FOUNDATION'S COMMENTS ON THE PROPOSED SETTLEMENT AGREEMENT ON PLANT SIZE AND LEVEL OF OPERATION
ABSTRACT: Re: In the Matter of the Application of California American Water Company (U 210 W) for Approval of the Monterey Peninsula Water Supply Project and Authorization to Recover All Present and Future Costs in Rates, SURFRIDER FOUNDATION'S COMMENTS ON THE PROPOSED SETTLEMENT AGREEMENT ON PLANT SIZE AND LEVEL OF OPERATION document is embedded. Importantly, CONCLUSION ...Surfrider Foundation respectfully urges the Commission to reject the Sizing Agreement. The settling parties have not carried their burden; the Commission should therefore make an independent determination of the appropriate size of the desalination component of the MPWSP and impose appropriate conditions to ensure that the project advances the public interest and meets the relevant environmental mandates. Without the EIR, the record is incomplete and cannot support the Sizing Agreement. If the Commission determines that the record will be insufficient to support the agreement even after the EIR's release, the Commission should direct further evidentiary hearings at the earliest reasonable date. The Commission's determination could require further evidence on topics including, but not limited to: (1) the amount of water that lots of record are reasonably likely to demand, (2) the expected demand from tourism bounce back, (3) how customer demand in each tier will change in response to the rate increases that the MPWSP will cause, and (4) how much potable water the Pacific Grove projects will offset. The current schedule for this proceeding, which includes briefing in April and May of 201474 and proposed evidentiary hearings regarding GWR in February 2015, could easily accommodate such hearings.
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