Proceeding Number A.12-04-019 SURFRIDER FOUNDATION’S REPLY 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 REPLY BRIEF ON THE PROPOSED SETTLEMENT AGREEMENT ON PLANT SIZE AND LEVEL OF OPERATION document is embedded. CONCLUSION For the foregoing reasons, Surfrider respectfully requests that the Commission reject the Sizing Agreement in its current form.

SURFRIDER FOUNDATION’S REPLY BRIEF ON THE PROPOSED ON PROPOSED SETTLEMENT AGREEMENT.pdf

Filing Date 02-14-14
SURFRIDER FOUNDATION’S REPLY BRIEF ON THE PROPOSED SETTLEMENT AGREEMENT ON PLANT SIZE AND LEVEL OF OPERATION

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.

SURFRIDER FOUNDATION’S OPENING BRIEF ON THE PROPOSED SETTLEMENT AGREEMENT ON PLANT SIZE AND LEVEL OF OPERAT...

Filing Date 01-21/14
SURFRIDER FOUNDATION’S OPENING BRIEF ON THE PROPOSED SETTLEMENT AGREEMENT ON PLANT SIZE AND LEVEL OF OPERATION

Proceeding Number A.12-04-019 SURFRIDER FOUNDATION'S REQUEST FOR OFFICIAL NOTICE

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 REQUEST FOR OFFICIAL NOTICE document is embedded.  Importantly, Pursuant to Rule 13.9, Surfrider Foundation respectfully requests that the Commission take official notice of the following attached documents:  Attachment 1: State Water Resources Control Board, Order WR 2009-0060, Cease and Desist Order (Oct. 20, 2009); Attachment 2: California Public Utilities Commission, Policy Statement on Greenhouse Gas Performance Standards (Oct. 6, 2005); Attachment 3: State Water Resources Control Board, Notice of Application 30215A and Draft Permit for Diversion and Use of Water (Sept. 6, 2012).
 Surfrider Foundation's Request for Official Notice Filing Date 08-30-13
SURFRIDER FOUNDATION'S REQUEST FOR OFFICIAL NOTICE

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.

Surfrider Foundation's Comments on the Proposed Settlement Agreement on Plant Size and Level of Operation Filing Date 08-30-13

SURFRIDER FOUNDATION'S COMMENTS ON THE PROPOSED SETTLEMENT AGREEMENT ON PLANT SIZE AND LEVEL OF OPERATION

Proceeding Number A.12-04-019 SURFRIDER FOUNDATION'S RESPONSE TO MARINA COAST WATER DISTRICT'S MOTION TO MODIFY PROCEDURAL SCHEDULE

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 RESPONSE TO MARINA COAST WATER DISTRICT'S MOTION TO MODIFY PROCEDURAL SCHEDULE document is embedded.  Importantly, “Surfrider Foundation agrees with the reasoning and conclusion of the Marina Coast Water District ( "MCWD") in its Motion to Modify Procedural Schedule: the nature of this proceeding requires that the parties' briefs have the benefit of the information that will be contained in the environmental impact report ("EIR") for the proposed project.” “Surfrider Foundation respectfully requests that the ALJ adopt the briefing schedule proposed by Marina Coast Water District or, alternatively, the schedule proposed herein.

 

Filing Date 05-17-13

SURFRIDER FOUNDATION'S RESPONSE TO MARINA COAST WATER DISTRICT'S MOTION TO MODIFY PROCEDURAL SCHEDULE