Thursday, February 13, 2014

Proceeding Number A.12-04-019 SURFRIDER FOUNDATION’S OPENING BRIEF 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 OPENING BRIEF ON THE PROPOSED SETTLEMENT AGREEMENT ON PLANT SIZE AND LEVEL OF OPERATION document is embedded. ARGUMENT I. The Record Does Not Support the Calculated Demand for Lots of Record, II. The Agreement’s Allocation for Tourism Bounceback Lacks Record Support, III. The Sizing Agreement Should Restrict any Water Allocated for Lots of Record or Tourism Bounceback Solely to those Uses and IV. Pacific Grove’s Local Project Should Be Incorporated Into the Sizing Agreement’s Supply Portfolio. CONCLUSION For all of these reasons, in addition to the reasons stated in Surfrider’s original comments on the Sizing Agreement, the Commission should reject the Sizing Agreement as it is currently proposed.
Filing Date 01-21/14
SURFRIDER FOUNDATION’S OPENING BRIEF ON THE PROPOSED SETTLEMENT AGREEMENT ON PLANT SIZE AND LEVEL OF OPERATION

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