HomeMy WebLinkAboutGSWC Comments on Proposed Resolution W-5218 (re PFAS memo account)00 Golden: State
Via° a 't e r C 0 Oil P a rX y
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BY EMAIL
(U 133 W)
Water Division
California Public Utilities Commission
505 Van Ness Avenue
San Francisco, California 94102
Water.Division@cpuc.ca.gov
COMMENTS OF GOLDEN STATE WATER COMPANY ON
PROPOSED RESOLUTION W-5218
Pursuant to California Public Utilities Commission ("Commission") General Order
("GO") 96-B and Rule 14.5 of the Commission's Rules of Practice and Procedure, Golden State
Water Company ("GSWC") submits these comments on Proposed Resolution W-5218
("Proposed Resolution"). GSWC addresses herein critical flaws in the Proposed Resolution,
which (i) fails to consider appropriately the serious nature of the public health issues presented,
(ii) inaccurately characterizes key information supporting Advice Letter ("AL") 1795-WA and
GSWC's underlying request for authorization to establish the Polyfluoroalkyl Substances
("PFAS") Memorandum Account ("PFASMA"), (iii) misapplies the Commission's criteria for
establishing memorandum accounts, and (iv) inadequately describes the relevant procedural
history. For the reasons set forth below, GSWC respectfully requests that the Commission revise
the Proposed Resolution to reverse Water Division's ("WD") disposition rejecting AL 1795-WA
("Disposition") and to authorize GSWC to establish the PFASMA.
I1�7LMAIRM[13►`I
A. The Proposed Resolution fails to acknowledge the important public policy
considerations arising from PFASMA contamination.
The Proposed Resolution errs in failing to conclude that GSWC's AL 1795-WA
adequately supports adoption of the PFASMA under the oft -cited criteria for the establishment of
memorandum accounts, as discussed below, but that is just one component of a broader failure.
Throughout its review process, WD ignored that water supplies contaminated with PFAS raise
critical public policy concerns that require prompt and decisive action. The Commission has
specifically discussed the role of public policy considerations when reviewing the establishment
of memorandum accounts, acknowledging that it does not necessarily require that all of the
pertinent factors that the Commission may consider when reviewing memorandum account
requests be met. 1 Rather, the Commission has, at different tunes "relied on other public policy
factors in determining whether to authorize a memorandum account."'-- Approval of AL
1795-WA is particularly warranted because of the overarching public policy issues associated
with PFAS contamination.
Now is the time for the Commission to go on record as using every tool at its disposal to
protect the public from the potential health effects of PFAS contamination. Although the State
Water Resources Control Board ("SWRCB") has yet to establish a Maximum Contaminant Level
("MCL") for PFAS, and many wells have yet to be thoroughly tested, PFAS contamination of
water supplies is widely regarded as a burgeoning public health crisis.3 On January 22, 2020,
just five days after WD issued the Disposition denying AL 1795-WA, during a State Assembly
Standing Committee on Utilities and Energy hearing, State Assemblymember Cristina Garcia
(District 58, Bell Gardens) diverged from wildfire discussions to raise the urgent need to address
PFAS.4 Assemblymember Garcia emphasized the importance not just of testing for and
disclosing PFAS contamination, but of cleaning up PFAS in order to keep constituents safe, and
she asked Commission President Batjer what actions the Commission is taking to address PFAS.
President Batjer was unfamiliar with PFAS, but assured Assemblymember Garcia that she would
take the issue under advisement and follow up. In response, Assemblymember Garcia further
described PFAS as a "forever chemical" that never breaks down and as a known carcinogen that,
in some communities, impacts every single well. Assemblymember Garcia explained:
' D.10-04-031 at 71.
'- Id.
3 California Finds Widespread Water Contamination of 'Forever Chemicals', Anne M. Phillips and Anthony Pesce,
LA Times (Oct. 14, 2019), available at htti)s://www.latimes.coin/l)olitics/storv/2019-10-10/california-finds-
widesbread-contamination-of-chemicals ("The results offered the clearest picture yet of California's exposure to a
public health crisis that is playing out nationally.")
a Assem. Standing Corn. on Utilities and Energy, Oversight Hearing on Annual Review of P.U.C. and the Public
Advocates Office (Jan. 22, 2020), available at: httr)s://www.assemblv.ca.2ov/media/assembly-utilities-ener2v-
coinmittee-20200122/video (beginning at 1:37:00).
We do have some utilities that are trying to be responsive in the
area, but they're trying to figure out how to pay for this and what to
do. And I know that they've put in requests to the CPUC and so as
we're managing ... the important work of wildfires, we don't
forget about all the other work you have to be doing, including stuff
tied to PFAS.S
President Batjer assured the committee that she is "concerned as a fellow Californian" about the
"serious nature" of water quality issues in California and that the Commission would look into
the PFAS issue and get back to the committee.6 Given that GSWC serves Assemblymember
Garcia's constituents in Bell Gardens and is among the utilities to which she referred, the
Commission's final resolution of AL 1795-WA will likely be viewed as the response to
Assemblymember Garcia's inquiry.
By expeditiously approving the PFASMA, the Commission can get in front of the rapidly
advancing developments related to HAS and demonstrate —not only to the State Assembly's
Committee on Utilities and Energy but to the public —both proactive concern for public health
and competent stewardship of water utilities and water quality. By rejecting adoption of the
PFASMA, the Proposed Resolution instead takes the view that nothing is amiss and business as
usual will suffice. In so doing, the Commission risks putting itself on the wrong side of history.
GSWC fully appreciates its duty to provide safe drinking water to its customers and the
importance of instilling public confidence in the State's water supply and regulatory process.
This is why GSWC took immediate action to shut down its well in its Norwalk system when the
well tested positive for PFAS contamination at a level requiring notification to customers, even
though the HAS concentration was, at that time, below the level requiring an immediate
response.' And this is why GSWC requested the establishment of the PFASMA in advance of
any further decisions or orders by SWRCB, which are likely to follow world-wide trends and
further regulate PFAS contamination. In light of the potential health consequences and public
concern associated with PFAS, GSWC expects to devote significant necessary resources to
address HAS contamination in the near future.
5 Id. at approximately 1:38.
Id. at approximately 1:38:30
At the time that GSWC closed the Norwalk well, the level was above the notification level but below the response
level. As the Proposed Resolution recognizes, on February 6, 2020, SWRCB lowered the response levels to 10 ppt
for PFOA and 40 ppt for PFOS, down from a combined 70 ppt for both chemicals (Proposed Resolution at 2). A
response would be required for the Norwalk well under the new guidelines.
The Commission too has a responsibility with regard to this matter: to provide for the
recovery of costs prudently incurred in connection with GSWC's efforts to address PFAS
contamination. Memorandum accounts are the Commission's well -established mechanism for
preserving the utilities' opportunity to obtain cost recovery when a utility prudently incurs
substantial costs that were not previously forecasted and cannot be delayed until the utility's next
rate case. The Proposed Resolution would have the Commission sidestep its responsibility and
instead direct utilities to divert funds that were authorized for other important capital projects,
have shareholders bear this financial burden, or simply delay PFAS clean-up that is not
mandated by SWRCB. Each of these paths is untenable. Neither the Commission nor the water
utilities can ignore the coming public health crisis that PFAS contamination poses. GSWC
therefore urges the Commission to once again demonstrate the leadership that it customarily
shows in the face of such threats and revise the Proposed Resolution.
In particular, the Commission should (i) acknowledge the significant and widespread
public concern for health and safety related to PFAS, (ii) declare that it is appropriate to adopt all
reasonable measures to remediate this potential threat, and (iii) approve GSWC's request to
establish the PFASMA. These determinations will appropriately allow GSWC to seek recovery
of the substantial costs related to PFAS in a later proceeding, upon a showing that the costs were
reasonably and prudently incurred, without encountering retroactive ratemaking issues.
B. The Proposed Resolution misapplies the Commission's criteria for
authorizing memorandum accounts, fails to consider all of the relevant costs
related to PFAS, and misstates the substantial nature of those costs.
The Commission's criteria for establishing a memorandum account focus on the timing
and nature of the new costs at issue, the amount thereof, and the public benefits associated with
establishing the memorandum account. Instead of thoughtfully considering these criteria, the
Proposed Resolution sets forth inadequate alternatives to address PFAS contamination, stating
"if utilities believe plant additions are necessary to provide safe water service in the immediate
term, they have the opportunity to either use existing capital budget spending authority
previously authorized by the Commission or file applications to demonstrate the need for
incremental capital budgetary authority."' The first alternative would require diverting funds
from projects the Commission determined to be necessary by either deferring or mothballing
a Proposed Resolution at 6.
those projects. The second would require an 18-month application process. The discovery of
PFAS contamination creates an urgency for action that can no more wait for the preparation and
submittal of an application and the completion of a full proceeding than it can wait for the
commencement, much less completion, of GSWC's next GRC.
The reasoning of the Proposed Resolution appears to be based on fundamental errors
concerning the magnitude and nature of the potential costs associated with treating PFAS,
contending that the flaws GSWC identified in the Disposition with regard to treatment costs were
of little consequence. The Proposed Resolution asserts:
The Utilities claim that Water Division erred in the original
disposition by referring to "treatment costs" rather than all the
costs the Utilities propose to include in the PFASMA, but the
Utilities have ultimately not made an adequate showing that the
incremental operating costs associated with PFAS will be
substantial.9
This is not accurate. The actual issue that GSWC raised in the Request for Review was that WD
failed to take the utility's exposure for "treatment costs" into account, not that the Disposition
considered treatment costs but failed to consider other costs. Specifically, GSWC explained that
WD erred in the Disposition by limiting its consideration of the costs to be included in the
PFASMA to "testing costs,"10 and did not consider potential "treatment costs."
With regard to "treatment costs", the Disposition asserts: "given [SWRCB]'s expected
timeline for implementing a [MCL] for [PFAS], any needed treatment costs will not occur before
Golden State's next scheduled rate case in July 2020 or the rate case there after in July 2023."11
Although the Proposed Resolution acknowledges "that the incremental plant investments
associated with PFAS remediation have the potential to be substantial,"12 it nevertheless largely
accepts this incorrect premise from the Disposition about treatment costs, stating "the costs that
might be eligible for memorandum account recovery would be the subset of those costs which
occur before the utilities' next rate case which, overall, are de minimis."13 In attempting to
support its conclusion that PFAS treatment costs that might be incurred before the next rate case
will be de nzinimis, the Proposed Resolution reveals the fundamental flaw with WD's logic,
'Id.
10 Request for Review at 6.
" Disposition at 1.
''- Proposed Resolution at 7
13 Id.
M
stating: "the costs that might be outside the utilities' control would be only incremental costs
associated with response level exceedances and SWRCB-ordered testing."14
WD has apparently concluded that GSWC should take no action (other than notifying
customers that their water is contaminated with PFAS) when PFAS contamination is found
above customer notification levels but below response levels. This position reflects a failure of
WD to understand what it means that GSWC is required to notify its customers that their
drinking water is contaminated with PFAS at the lower notification levels. Upon being so
notified, particularly at a time when information about the health effects of PFAS contamination
and recommendations for remediation at various concentration levels is changing, any customer
would reasonably expect swift remedial action, even if such action carries substantial costs and
even if such action is not currently required by SWRCB. For example, had GSWC not taken
action in its Norwalk system when its well tested above HAS notification levels but below
response levels, GSWC expects that its customers in that system would have been dissatisfied
with an explanation that the amount of PFAS in their water was high enough to require
notification but below SWRCB response levels. And rightly so: within a few months, SWRCB
revised its thresholds and the PFAS levels in that contaminated well exceeded the revised
response levels.
There are readily accessible narrative accounts in reliable news publications of
customers' frustration in exactly the situation presented today, 15 accounts that GSWC customers
are likely to come across within minutes of researching the meaning of the notice that they
receive. Accordingly, soon after sending the legally required notices to its customers, GSWC
will need to take further actions to respond to elevated HAS levels, both because GSWC takes
seriously its duty to provide safe and reliable water service to its customers and because its
customers are likely to demand such actions. The Proposed Resolution's conclusion that PFAS
remediation costs before the next rate case will not be substantial, on which much of the
Proposed Resolution's reasoning appears to be based, is premised upon the tone deaf and
fundamental misconception that GSWC need not take remedial action when PFAS levels are
found at concentration levels above notification levels but below response levels.
"Id. (emphasis added).
15 E.g., The Lcniyer Who Became DuPont's Worst Nightmare, Nathaniel Rich, New York Times Magazine (Jan. 6,
2016), available at httns.//www.nvtimes.com/2016/01/10hnaaazine/the-lawver-who-became-dui)onts-worst-
ni2htmare.html.
With regard to this topic, the Proposed Resolution misunderstands a central point made in
GSWC's Request for Review. Much was made of GSWC's statement, partially quoted in the
Proposed Resolution, that "without the PFASMA, GSWC would be forced to tell customers, who
may have received required notifications of PFAS contamination after SWRCB-mandated
testing, that while it is aware of the contamination and understands their concern and anger, it
has not yet received the regulatory approvals from the Commission"16 to deal with PFAS
contamination. GSWC did not, however, intend for the Commission to take this comment
literally. GSWC used this hyperbole to communicate that its customers will, justifiably, not be
satisfied unless GSWC takes all necessary, prudent, and reasonable actions in order to protect
health and safety (as GSWC did in its Norwalk system), and GSWC's customers may question
whether GSWC has done so if undertaking such actions would have negative financial
consequences for the utility. It is incumbent on the Commission, and necessary to instill public
confidence in the regulatory process, to support GSWC's efforts by authorizing the ratemaking
mechanism (i.e., the PFASMA) that aligns the desired conduct with an opportunity for full cost
recovery.
C. The Proposed Resolution erroneously asserts that utilities should reprioritize
capital budgets to cover PFAS costs and erroneously contends that utilities'
return on equity is intended to compensate investors for the risk of being
unable to recover costs of the nature that would be recorded in the PFASMA.
The Proposed Resolution asserts, despite the substantial nature of costs related to PFAS
(and probably based upon its incorrect conclusion that the related costs are not likely to be
substantial), "we believe utilities can either use existing capital budgetary authority previously
authorized by the Commission or file applications to demonstrate the need for incremental
capital budgetary authority." 17 The potential costs of PFAS-related activities, however, are so
substantial that a strategy of reprioritizing previously approved capital budgetary authority to
address PFAS piecemeal, as the Proposed Resolution suggests, likely will result in GSWC
making increasingly difficult choices between the adequacy of its PFAS response and other
investments necessary to provide safe and reliable water service to its customers. A case in point
16 GSWC Request for Review at 8. The Proposed Resolution includes only "forced to tell their customers" in its
quotation. Proposed Resolution at 6.
7 Proposed Resolution at 7.
no
is Orange County Water District ("OCWD"), which currently estimates the cost of addressing
PFAS in its territory at nearly $850 million.18
In light of the potentially substantial costs associated with PFAS remediation, the
Proposed Resolution's solution for addressing PFAS contamination is fundamentally flawed
because it fails to take into account that GSWC's capital budget was approved based on the
Commission's determination that projects reviewed in the prior GRC are necessary to providing
safe and reliable water service. Diverting funds to PFAS remediation jeopardizes completion of
those approved projects. There is a limited amount of resources that GSWC can divert to PFAS
before significantly disrupting projects that were deemed reasonable and prudent, projects which
are themselves complex and already in progress. This is precisely why the Commission allows
memorandum accounts to be established, so that utilities do not have to try to reallocate
significant resources when faced with potentially material amounts of unplanned costs. GSWC's
request to establish the PFASMA is a proactive measure designed to ensure that GSWC can
prudently deploy adequate resources to address potentially health -affecting contamination
without compromising the approved projects that address other important matters and priorities.
Perhaps more flawed still is the Proposed Resolution's assertion that the PFASMA is
unnecessary because the utilities' return on equity is intended to compensate for the risk of being
unable to recover incremental costs, such as costs to address PFAS, in between rate cases. 19 To
the contrary, a utility's return on equity, determined in the cost of capital proceeding, is premised
on an explicit understanding that there exist regulatory accounting mechanisms, such as
memorandum accounts, that allow for the potential recovery of substantial, unplanned costs and
expenses in between rate proceedings. If the Commission were to reject requests to establish
memorandum accounts when they are appropriately sought, as is the case with the PFASMA, the
Commission would be imposing undue risks on utilities that are not presently reflected in their
returns on equity. For the Proposed Resolution to assert otherwise is simply wrong.
Moreover, diverging from the Commission's well -established practices and adopting a
new policy that places utilities at risk for unexpected, substantial costs would be a recipe for
" Water Agencies in Orange County Initiate Stel)s to Protect Public Health, Press Release, Orange County Water
District (Feb. 6, 2020), ai,ailable at lhttos://www.ocwd.coin/media/K503/rl-announcennent.pdf. In the Request for
Review, GSWC was only able to cite the $200 million figure that OCWD planned to spend on construction of
treatment facilities. OCWD has since announced more comprehensive estimates of costs.
19 Proposed Resolution at 7.
7
disaster. Even if the utilities do the right thing to protect health and safety, as GSWC always
intends to do, such a policy would ultimately jeopardize the utility's financial health and ability
to provide high quality service. This would undermine the public's confidence in the utilities, the
Commission and the regulatory process. It is imperative that the Commission refrain from
adopting a policy, whether formal or informal, that is so plainly antithetical to the public interest.
D. The Proposed Resolution inadequately describes the procedural history.
GSWC also requests that the Proposed Resolution be modified to describe correctly the
procedural history associated with AL 1795-WA. First, the Proposed Resolution fails to address
that Cal PA's response was not the final submission in this matter. The last sentence in the
"Request for Review" section states: "Subsequent to Water Division's rejection of the three
Advice Letters, Cal PA requested the opportunity to respond to the Utilities' Requests for
Review, which Water Division granted." The Proposed Resolution fails to mention that, on
February 21, 2020, GSWC submitted a reply to Cal PA's response, which fully refuted Cal PA's
contentions.
Second, the Proposed Resolution does not address the unusual circumstances of Cal PA's
response to GSWC's Request for Review.20 At the outset, Cal PA did not protest the original AL
1795-W. They instead requested an extension to submit their response and thereafter conferred
with GSWC regarding the PFASMA. GSWC then submitted a revised version, AL 1795-WA,
that specifically addressed questions posed by Cal PA regarding GSWC's support for the
PFASMA. Given GSWC's efforts to address Cal PA's questions, and Cal PA not protesting the
advice letter, GSWC was surprised to learn that Cal PA submitted a response to GSWC's
Request for Review challenging the Disposition. The first GSWC heard of a request by Cal PA
to respond, as stated in the Proposed Resolution, was in the Proposed Resolution. The first
GSWC heard of Cal PA's response was when it received a copy of the response on February 14,
2020.
GSWC acknowledges that the advice letter process is less formal than full Commission
proceedings, but the failure to follow even basic standards of procedure, such as notice, is
troubling. Moreover, as detailed in GSWC's reply to Cal PA, Cal PA's response made no
20 GO 96-B does not provide for any intervenor participation once a utility has filed a request for Commission
review of an industry division disposition, even if the intervenor in question had protested the advice letter, which
Cal PA did not. Nor does GO 96-B explicitly afford an industry division any discretion to solicit or accept
comments or input before drafting a proposed resolution for presentation to the Commission.
N.
attempt to rebut the arguments presented in the Request for Review and failed to make even a
passing mention of any Commission precedent, the standards for approving memorandum
accounts, or the central issue of retroactive ratemaking, which were the subject of AL 1795-WA,
the Disposition, and the Request for Review. Cal PA instead focused on portraying the
memorandum account requests as evidence that the utilities believe "certainty of cost recovery is
more important than [their] duty and obligation to proactively address potentially health -
affecting contamination," accusing GSWC of making "threats" to spread "disinformation,"21 and
arguing that utilities do not "need" memorandum accounts because they can instead "reprioritize
their budgets."' These are all deeply flawed premises that nonetheless found their way into the
Proposed Resolution.
GSWC respectfully requests that the Commission revise the Proposed Resolution to
include an adequate and complete description of the procedural history of this matter and to
accord Cal PA's contentions in its response the appropriate weight —which would be none.
III. CONCLUSION
For the reasons discussed above, as well as in GSWC's Request for Review, and Reply to
Cal PA, GSWC respectfully requests that the Commission revise the Proposed Resolution to
reverse the Disposition rejecting AL 1795-WA and grant GSWC's underlying request for
authorization to establish the PFASMA.
Very Truly Yours,
Keith Switzer
Vice President, Regulatory Affairs
Golden State Water Company
cc: Alice Stebbins, Executive Director
21 Cal PA Letter dated Feb. 14, 2020.
„ Id.
9
Lucian Filler, Deputy Executive Director, Communications and Water
Bruce DeBerry, CPUC Water Division
Jim Boothe, CPUC Water Division
Jeremy Ho, CPUC Water Division
Richard Rauschmeier, CPUC Public Advocates Office
Victor Chan, CPUC Public Advocates Office
10
GOLDEN STATE WATER COMPANY
REGION 1, 2 & 3 - SERVICE LIST
Sacramento Suburban Water Dist.
3701 Marconi Avenue —Suite 100
Sacramento, CA 95821
HHernandez(c)sswd.ora
DYork(a)sswd.orq.
Carmichael Water District
7837 Fair Oaks Blvd.
Carmichael, CA 95608-2405
Cypress Ridge Owner's Association
Attn: President
1400 Madonna Road
San Luis Obisbo, CA 93405
Corv.Bauer(a�manaciementtrust.com
City of Folsom
50 Natoma Street
Folsom, CA 95630
Director
Sacramento County Water Agency
827-7th Street, Room 301
Sacramento, CA 95814
DWRexecsecretarvCo),saccou ntv. net
Bay Point Municipal Advisory Council
3105 Willow Pass Road
Bay Point, CA 94565-3149
Contra Costa Water District
P. O. Box H2O
Concord, CA 94520
Diablo Water District
P. O. Box 127
Raley's Shopping Center — 2107 Main Street
Oakley, CA 94561-0127
Dmuelrath(cDdiablowater.orq
cbelleci(a)diablowater.orci
City of Martinez
525 Henrietta Avenue
Martinez, CA 94553
Citrus Heights Water District
6230 Sylvan Road
Citrus Heights, CA 95610
California -American Water Co.
4701 Beloit Drive
Sacramento, CA 95838-2434
ca.rates(cDamwater.corn
Fair Oaks Water District
10317 Fairoaks Blvd.
Fairoaks, CA 95628
Orange Vale Water Co
P. O. Box 620800
9031 Central Avenue
Orange Vale, CA 95662
swilcox(@oranqevalewater.com
City of Antioch
P. O. Box 5007
Antioch, CA 94531
City of Brentwood
Public Works Operations
Eric Brennen, Water Operations Manager
2201 Elkins Way
Brentwood, CA 94513
Contra Costa County
Chief Assistant Clerk of the Board
651 Pine Street, Room 106
Martinez, CA 94553
Jami.napier(a)cob.cccountv.us
Richard Lou, Principal Management Analyst
East Bay Municipal Utility District
375— 1 1th Street, MS#804
Oakland, CA 94607
Riou(cbebmud.com
Highlands Water Company
14580 Lakeshore Drive
Clearlake, CA 95422-8100
Page 1 of 12
GOLDEN STATE WATER COMPANY
REGION 1, 2 & 3 - SERVICE LIST
Konocti County Water District
15844 — 3511 Street
Clearlake, CA 95422
kcwd(@mchsi.corn
Arroyo Grande Municipal Water Dept.
P.O. Box 550
Arroyo Grande, CA 93420
stavlor(d)arrovoqrande.ora
Cambria Community Services Dist.
1316 Tamson Drive — Suite 201
P.O. Box 65
Cambria, CA 93428
Los Osos CSD
2122 - 911 Street
Los Osos, CA 93402
S & T Mutual Water Co.
P.O. Box 6391
Los Osos, CA 93412
STMutualwater(a)cimail.com
Nipomo Community Services Dist.
147 S. Wilson Street
Nipomo, CA 93444-0326
Mlqlesias(cDncsd.ca.qov
Calleguas Municipal Water District
2100 Olsen Road
Thousand Oaks, CA 91360
stavior(a)callequas.com
City Clerk
City of Clearlake
14050 Olympic Drive
Clearlake, CA 95422
mswanson(a)clearlake.ca.us
City Attorney & City Clerk
City of Santa Maria
110 East Cook Street
Santa Maria, CA 93454
raarietz(a),ci.santa-maria.ca.us
r)sinco(o),dtvofsantamaria.orq
County Clerk
County of Sacramento
720 911 Street
Sacramento, CA 95814
Local Agency Formation Commission
P. O. Box 2694
Granite Bay, CA 95746
i.benoit4(a)icloud.com
Avila Beach Community Service District
P 0 Box 309
191 San Miguel Street
Avila Beach, CA 93424
avilacsd(a),qmail.com
Community Services District
P. O. Box 6064
Los Osos, CA 93412
Morro Bay City Water (City Hall)
595 Harbor Blvd.
Morro Bay, CA 93442
rlivick(a-)morrobavca.qov
San Luis Obispo City Water
879 Morro Street
San Luis Obispo, CA 93403
City of Santa Maria
2065 East Main Street
Santa Maria, CA 93454
lmlonq('0ci.sant:a-maria.ca.us
City Attorney
City of Clearlake
14050 Olympic Drive
Clearlake, CA 95422
City Clerk & City Attorney
City of Guadalupe
918 Obispo Street
Guadalupe, CA 93434
City Clerk & City Attorney
City of Simi Valley
2929 Tapo Canyon Road
Simi Valley, CA 93065
County Clerk
County of San Luis Obispo
1055 Monterey Street - #D-120
San Luis Obispo, CA 93408
Page 2 of 12
GOLDEN STATE WATER COMPANY
REGION 1, 2 & 3 — SERVICE LIST
Department of Water Resources
Steve Pedretti, Division Chief
827 7th Street, Room 301
Sacramento, CA 95814
DWRexecsecretarv(@.saccou ntv. net
County Counsel
105 East Anapamu Street,
Santa Barbara, CA 93101
LAFCO
1042 Pacific Street, Suite A
San Luis Obispo, CA 93401
dblovd(@sIolafco.com
City of Bellflower
Water Department
16600 Civic Center Drive
Bellflower, CA 90706
RStoverCc)bellflower.ora,
City of Downey
Director of Public Works
P. O. Box 90241-7016
Downey, CA 90241
City of Huntington Park
Water Department
6550 Miles Street
Huntington Park, CA 90255
City of Lakewood
Water Department
P.O. Box 220
Lakewood, CA 90714-0220
County Counsel
County of San Luis Obispo
County Government Center - #D-320
San Luis Obispo, CA 93408
John Farnkopf, Senior Vice President
Rm. 201 HILTON FARNKOPF & HOBSON, LLC
2175 N. California Blvd — Suite 990
Walnut Creek, CA 94596
ifarnkoDf(az,hfh-consultants.com
Honorable Mayor Eric Garcetti
City of Los Angeles
200 N. Spring Street — Room 303
Los Angeles, CA 90012
City of Norwalk
Water Department
12700 Norwalk Blvd.
Norwalk, CA 90650
Santa Barbara LAFCO
105 E. Anapamu - Room 406
Santa Barbara, CA 93101
lafco(cDsblafco.orq
City of Cerritos
Water Department
P.O. Box 3130
Cerritos, CA 90703
borteqa(a),cerritos.us
City of Hawthorne
4455 W. 1126' Street
Hawthorne, CA 90250
City of Inglewood
One Manchester Blvd. - Suite 900
P. O. Box 6500
Inglewood, CA 90301
Long Beach Water Department
Chris Garner, General Manager
1800 E. Wardlow Road
Long Beach, CA 90807
City of Los Angeles
Department of Water & Power
P 0 Box 51111
Los Angeles, CA 90051-0100
City of Paramount
Water Department
— Room #5 16420 Colorado Street
Paramount, CA 90723
sho(a-)r)aramountcitv.com
City of Santa Fe Springs
Water Department
11736 E. Telegraph Road
Santa Fe Springs, CA 90670
City of South Gate
Water Department
8650 California Street
South Gate, CA 90280
rdickev(a)soqate.orq
dtorres(a)soqate.orq
Page 3 of 12
GOLDEN STATE WATER COMPANY
REGION 1, 2 & 3 — SERVICE LUST
City ofTorrance
Water Department
3031Torrance Blvd.
Torrance, CA 00503
California Water Service Co.
2632West 237mStreet
Torrance, CA 00505'5272
Liberty Utilities
9750Washburn Road
Downey, CA 90241
K8oywpmd Mutual VVater- No. 2
3521 East S|auounStreet
Maywood, CA 00270
Orchard Dale County
Water District
13818East Telegraph Road
VVhittior, CA 90604
mi|vett(cDodwd.om
ecwataneduCo),odwd.om
K41ishev(cDodwdorq
San Gabriel Valley Water Co.
11142 Garvey Avenue
BMonte, CA 91733
dadeUoaa(o)sqvweher.00m
Tract 10O-Mutual Water Co.
4544E.Florence Avenue
Cudahy, CA 00201
Central Basin MVV0
General Manager
5252 Telegraph Road
Commerce, CA 90040-2512
Hilda Solis — 1st District
L��County Board mfSupervisors
856Kenneth Hahn Hall ofAdmin
500West Temple Street
Los Angeles, C/\ 00012
City of Whittier
1323OPenn Street
Whittier, CA 00082
California Water Service
Rancho Dominguez District
2832VVast 237mStreet
Torrance, CA 00505-5272
hwind((Dca|waLer.omm
Maywood Mutual Water - No. 1
5953Gifford Street
Huntington Park, CA 80255
Maywood Mutual Water - No. 3
8151 Heliotrope Avenue
Maywood, CA 00270'3418
Pico County Water District
P.O. Bnx758
Pico Rivera, CA 80600-0708
Robert Kelly, VPo[Regulatory Affairs
Suburban Water Systems
1325N.Grand Avenue, Suite 10O
Covina, CA 91724-4044
Water Replenishment District
General Manager
4040Panamuunt Blvd.
Lakewood, CA 00712~4127
mvhitaken(o)wrd.orq
West Basin MVVQ
Ju|ieFrazier-Mothewu—EoaoubveAsst.
PathckShai|do—Genera|Nlmnogar
17140S.Avalon Blvd. — Suite 210
Carson, CA 00748-1206
Ju|ieF(o)westbasin.oro
PathokS(aywestboainuvq
Mark Ridley -Thomas —2nd District
LA.County Board mfSupervisors
Room 866'Hall ofAdministration
500 West Temple Street
Los Angeles, CA 00012
K8arkhd|ev'thomaa(cD.bna.|acountv.qov
kkatonaCd)buo.|aoountv.qov
Page 4or1u
GOLDEN STATE WATER COMPANY
REGION 1, 2 & 3 — SERVICE LUST
City Attorney & City Clerk
City ofArtesia
18747C|arkoda|eAvenue
Artesia, CA 98701
City Manage
City ofBell Gardens
71O0S.Garfield Avenue
Bell Gardens, CA 00201
saimonion(cDbeUoordens.ono
imrouezaCcDbe||qordonn.orq
oc|ark(cDb*||qardensorq
City Attorney & City Clerk
City of Cerritos
PD.Box 3130
Cerritos, CA 90703
Acting City Manager & City Clerk
City ofCudahy
5250Santa Ana Street
Cudahy, CA 00201
aniahizaki(cDoih/ofoudahyoa.00v
City Attorney &City Clerk
City of Downey
11111 Brookshire Avenue
Downey, CA 00241
citvu|orh��downovoa.00v
City Clerk
City ofGardena
1700VV. 162'mS8reet
Gardena, CA 90247
cityo|erk(o)ci.qerdena.ca.us
City Attorney &City Clark
City ofHawthorne
4460VV.126mStreet
Hawthorne, CA 90250
oitvo|erk(a)citvofhowthorna.oro
City Attorney & City Clerk
City ofInglewood
One Manchester Blvd.
P{}Box 0500
Inglewood, CA 00381
City Attorney, Clerk &Manager
City ofBell
O33OPine Avenue
Bell, CA 90201
oo|mshim(d),awam`mms.uvm-Dale meomm
xe"mamonu,(o)Cuvumen.orq-City Clerk
iohm(a),onvufbnnum-Jackie Choi
City Attorney & City Clerk
City ofCarson
701 E.Carson Street
Carson, CA 90745
City Attorney & City Clerk
City pfCompton
205VV.Willowbrook Avenue
Compton, CA 90220
ocornvvu||(o)oomptoncitY.onl
City Attorney & City Clerk
City mfCulver City
Q770Culver Blvd.
Culver City, CA 00230
Qh/.o|erk(cDou|veroity.orq
City.adorney(aDcu|vercityonl
City Attorney & City Clerk
City ofBSegundo
350Main Street
BSegundo, CA 00245
City Attorney & City Clerk
City sfHawaiian Gardens
21815Pioneer Blvd.
Hawaiian Gardens, CA 90716
City Clerk
City pfHuntington Park
855OMiles Avenue
Huntington Park, CA 00255
City Clerk
City ofLakewood
5O50N.Clark Avenue
Lakewood, CA 90714
Page oor1u
GOLDEN STATE WATER COMPANY
REGION 1, 2 & 3 - SERVICE LUST
City Attorney & City Clerk City Attorney & City Clerk
City ofLaMirada City mfLam/ndm|e
13788LoMirada Blvd. 14717Burin Avenue
LaMirada, CA 98638 Lawnda|e.CA 90208
City Clerk City Attorney & City Clerk
City ofLong Beach City ofNorwalk
333Ocean Boulevard 12700Norwalk Blvd.
Long Beach, CA 90802 Norwalk, CA 90050
cityderk(cD|onqbeach. qov
City Attorney &City Clark City Attorney 8City Clerk
City o[Paramount City ofSanta FmSprings
164O0S.Colorado Avenue 1171OE.Telegraph Road
Paramount, CA 00723 Santa FuSprings, C/\ 00670
JCavanauqh(a)Cavanauqh|aw.net !anotmertinez(c)sanbafoeVrinqs.onl
City Attorney & City Clerk County Clerk
City ofSouth Gate County ofLos Angeles
8850California Avenue 12400 Imperial Highway
South Gate, CA 90280 Norwalk, CA 90650
County Clerk County Counsel
County nfOrange City pfOrange
12Civic Center Plaza 333VV.Santa Ana 0vd..4mFloor
Santa Ana, CA 92702 Santa Ana, CA 92701
County mfLAWaterworks Dist. Apple Vm|hm, Ranchos Water Co.
23G33West Civic Center Way Tony Pennm—General Manager
Malibu, CA 00265 2178UOttawa Road
Attn: Mark Carney P.O.Box y005
drydman(a-)dmw.|acounty.qov Apple Valley, CA 92308
tpenno(d)avnwater.cum
Director mfPublic Services BarlenMutual Water
Town ufApple Valley P.[>.Box 77
14055Dale Evans Parkway Barstow, CA 02311
Apple Valley, CA 02307 bar|mnvvatar(o),hotmai|.com
California Department mfCorrections California Dept. ofForestry
P.O. Box50U1 710bAirway Drive
7018Blair Road Yucca Valley, CA 02284
Ca|ipotrio.CA 82233
California Dept. of Forestry Hdqtna County Water
3800N.Sierra Way P.C>.Box B}01
San Bernardino, CA 92405 Victorville, CA 92393-5001
Daggett Community Service East Orange County Water
P.O. Box308 18bN.McPherson Road
Daggett, CA 02327 Orange, CA 82860-3720
|oh|und(a)mocmd.onm
eooh20(cbeocvvd.com
Page 0or1u
GOLDEN STATE WATER COMPANY
REGION 1, 2 & 3 — SERVICE LUST
East Pasadena Water Co.
3735Mountain View Avenue
Pasadena, CA 91107
Jun0HeuberQer, CEP, Executive Officer
LAFCO
1122VV.State Street, SuibsD
El Centro, CA 92243-2840
Local Agency Formation Commission
215North DStreet — Suite 2U4
San Bernardino, CA 92415-0490
|afcu(a-)|afuo.uboountv.qov
K8mnmnQmValley Community
Service Distribution
P.O. Box4S
MorongoValley, CA 02256
RonmherbosWater Co.
P.<]. Bnx348
Apple Valley, CA 82307
RK4VVC1954(a-)qmei|.00m
Seeley County Water District
P.(]. Box161
Seeley, CA 92273
Sheep Creek Water Company
P.[).Box 20182O
Phelan, CA 02329-1820
Attn: Chris Cummings
shoencneek(EDvehzonomt
TmentVminePalms Water District
72401 Hatch Road
PD.Box 1735
TwentyninePalms, CA 92277
Walnut Valley Water District
271 G.Brea Canyon Road
Walnut, CA 81789
Water Issues Committee
VVrghtmmoodProperty Owners Assoc.
PD.Box 487
VVhghtwood.CA 02307
City ofArcadia Water Co.
P.O. BoxG0021
240VV.Huntington Drive
Arcadia, CA 81088-8021
Raymond Castillo, Chairman
County Administration Center
Q40VV.Main Street -#20Q
E|Centro, C/\ 02243'2871
Juniper Riviera CWD
PD.Box 38S
Apple Valley, CA 92307
jrowd(a)basicinooet
Mariana Ranchos County Water District
A60OMunzanhoStreet
Apple Valley, CA 92308
Navajo Mutual Water Company
P.O. Box302
Apple Valley, CA 92307
Gmnmmc(a)qmoiioom
San Gabriel County Water Co.
8308Grand Avenue
Rosemead, CA 91770
Jim(d)sqcwd.mm
Serrano Water Dist. — Villa Park
18021 East Lincoln Street
Villa Park, CA 92667
Sunny Slope Water Co.
1U4OBCampo Drive
Pasadena, CA 01107-5506
Kon��SunnvS1opeVVatorComPony.com
Kanan(a)SunnyS|ooeVVobarComuenv.com
Victor Valley Water District
14343Civic Drive
P0 Bom50N1
ViotnrviUe.CA 92392
Westmorland Water Company
PD.Box 098
Westmorland, CA 92281
City of Anaheim
City Clerk's Office
200S.Anaheim Blvd. — Suite 217
Anaheim, CA 02805
City mfAlhambra Utilities Dept.
111 S.First Avenue
Alhambra, CA 91801
Page ror1u
GOLDEN STATE WATER COMPANY
REGION 1, 2 & 3 - SERVICE LIST
City of Brawley Water Co.
400 Main Street
Brawley, CA 92227
TSa Icido(c), brawl ev-ca. qov
City of Buena Park
6650 Beach Boulevard
Buena Park, CA 90620
Fqutierrez(@.l3uenaPark.com
City of Covina
534 Barranca Avenue
Covina, CA 91723-2199
CMarcarello(cDcovinaca.aov
City Attorney
City of El Monte
11333 Valley Blvd.
El Monte, CA 91732
cmoselev(a)elmonte.ca.qov
City of Garden Grove
13802 Newhope Street
Garden Grove, CA 92643
Zackb(@,ci.qarden-qrove.ca.us
Heber Public Utility District
P. O. Box H
Heber, CA 92249
City of Imperial
Water Department
420 S. Imperial Avenue
Imperial, CA 92251
City of La Verne
Water Department
3660 "D" Street
La Verne, CA 91750
lestrelia(cDci.la-verne.ca.us
City of Monterey Park Water Co.
320 W. Newmark Avenue
Monterey Park, CA 91754
City of Monrovia Water Company
415 S. Ivy Avenue
Monrovia, CA 91016
City of Brea
Water Department
#1 Civic Center Drive
Brea, CA 92621
City of Calexico Water Co.
608 Heber Avenue
Calexico, CA 92231
City of El Centro Water Co.
307 W. Brighton Avenue
El Centro, CA 92243
City of Fullerton Water
Fullerton Water Department
303 W. Commonwealth Avenue
Fullerton, CA 92631
aarh(a),ci.fullerton.ca.us
City of Glendora
116 East Foothill Blvd.
Glendora, CA 91740
City of Hesperia
Water Department
9700 Seventh Avenue
Hesperia, CA 92345
jwvman(c)citvofhesperia.us
City of La Palma
7822 Walker Street
La Palma, CA 90623
Attn: Jeff Moneda, PW Director
Monte Vista Water District
10575 Central Avenue
Montclair, CA 91763
City Attorney
City of Monterey Park
2600 W. Olive Avenue, Suite 500
Burbank, CA 91505
Kberqer(a)hensleviawaroup.com
City of Orange
Water Department
189 South Water Street
Orange, CA 92866
.idefrancesco(a-)citvoforanqe.orq,
Page 8 of 12
GOLDEN STATE WATER COMPANY
REGION 1, 2 & 3 — SERVICE LUST
City of Santa Ana Water
20Civic Center Plaza
Santa Ana, CA 02702
City of Seal Beach
211 8m Street
Seal Beach, CA 90748
City of West Covina
Water Department
825S.Sunset Avenue
West Covina, CA 01700
Steve Conklin, Acting General Manager
Yorbm Linda Water District
1717 E. K4ina|omeAvenue
Placentia, CA 92870
SoonNin((i)v|wd.00m
RVVeabon��V!vvd.com
City Attorney
City ofBarstow
222E.Mountain View Street
Barstow, CA 02311
City Attorney
City ofClaremont
P. [}. Box88O
Claremont, CA 01711
City Attorney
City ofCypress
5275Orange Avenue
Cypress, CA 90630
City pfBMonte
11333Valley Blvd.
BMonte, CA 91731
|mueamndun(c)ci.m|-monto.ca.uu
City Attorney
City ofLmPalma
7822Walker Street
LaPalma, CA 00680
City of San Dimas
245E.Bonita Avenue
San Dimas, CA 01773
City of Upland
Water Department
460N.Euclid Street
Upland, CA 01788
RHoeminoCU)ciuo|and.caua
JRob|eaCo)ciuo|and.nauo
K4K8adhz0),ciup|and.oa.um
City ofWestminster
8200Westminster Blvd.
Westminster, CA 02683
City Attorney
City ofArcadia
240West Huntington Drive
Arcadia, CA 91000
City Attorney
Oswalt &Associates
Mr. William (BiU)8mendon
POBox 60R
Imperial, CA 02251
City Attorney
City ofCovina
125E. College Street
Covina, CA 01723
City Attorney
City ofDuarte
1SUOHuntington Drive
Duarte, CA 91010
ime|chinq(cDrutan.00m
City Attorney
City mfIrwindale
505ON.Irwindale Avenue
Irwindale, CA 01706
City Attorney
City mfLa Verne
3660'U'Stneed
LaVerne, CA 01750
Page 8or1u
GOLDEN STATE WATER COMPANY
REGION 1, 2 & 3 — SERVICE LUST
Administrative Services Director
City ofLos Alamitos
3101 KataUaAvenua
Los Alamitos, CA 00720
City Attorney
City ofMontclair
5111 Benito Avenue
Montclair, CA 91703
der(a-)vobbinshoNamay.com
City Attorney
City of Orange
3OOE.Chapman Avenue
Orange, CA 92866
vvwinthona(@.oih/oforonoe.orq
City ofPomona
505S.GareyAvenue
Pomona, CA 91780
F(oza|uia ouUmY(a-)ci.pomona.oaus
City Attorney, BonUaoioGarcia
City o[Rosemead
8838E.Valley Blvd.
Rosemead, CA 91770
City Attorney
City ofSan Gabriel
425 G. Mission Ohvo
San Gabriel, CA 91770
City Attorney
City ofStanton
78OUKaheUuAvenue
Stanton, CA 90680
City Manager
City ofYorb Linda
4845Casa Loma Avenue
YorboLinda, CA 92880-3364
City Clark
City ofBarstow
222E. MounteinViowEK—Suihu/\
Barstow, CA 02311
City Attorney
City of Monrovia
415South Ivy Avenue
Monrovia, CA 01010
City Attorney, Karl H. Berger
City ofMonterey Park
280OVV.Olive Avenue, Suite 500
Burbank, CA91505
kbenler(a)hene|eY|avvqn`un.00m
City Attorney
City ofPlacentia
401 E.Chapman Avenue
Placentia, CA 02870
Interim Water Resources Director
City mfPomona
148 N. Huntington Street
Pomona, CA 81768
Robert DmLoaoh(@,ci.Pomona ooxs
Assistant City Manager
City pfSan Dimas
245E. Bonita Avenue
San Dimas, CA 01773
City Attorney
City of Seal Beach
211 8m8trend
Seal Beach, CA 90740
nbarrow(a),nwo|aw.00m
City Attorney
City ofTemple City
0701 Las Tunas Drive
Temple City, CA 01780
City Council
City mfCo||potra
125 North Park Avenue
Ca|ipetha.CA 92233
City Clerk
City pfClaremont
P.O. Box88O
Claremont, CA 01711
sdeaauka|s(a�,oidammonimaua
Page 18ov1u
GOLDEN STATE WATER COMPANY
REGION 1, 2 & 3 - SERVICE LUST
Community Services Director City Clerk
City ofClaremont City mJCovina
1010Monte Vista Avenue 125E. College Street
Claremont, CA 91711 Covina, CA 01723
City Clerk
Deputy City Clerk
City ofCypress
City mfDuarte
b275Orange Avenue
180OHuntington Drive
Cypress, CA 00630
Duarte, CA 01010
adm(a)cvr)resa.ua.us
hernanakanan(cDmcoeasdumrte.nom
City Clerk
City Clerk
City ofEl Monte
City mfIrwindale
11333Valley Blvd.
505ON.Irwindale Avenue
BMonte, CA 01731
Irwindale, CA 01706
LinduK(cDciimwindo|e.oa.ua
City Clark City Clerk
City pfLaPalma City of La Verne
7822Walker Street 3860'D'EXreet
LaPalma, CA 00880 LaVerne, C/\ 01750
City Clerk City Clerk
City ofLos Alamitos City mfMonrovia
3191 Kahs||aAvenue 415S.Ivy Avenue
Los Alamitos, CA 90720 Monrovia, CA 91010
VVClintunar(cD,oitvoOoau|amitom.onz
City Clerk City Clerk
City ofMontclair City of Orange
5111 Benito Avenue 3O0E.Chapman Avenue
Montclair, CA 91763 Chapman, CA 92806
City Clerk City ofRosemead
City ofPlacentia 8838Valley Blvd.
401 E. Chapman Avenue Rosemead, CA 91770
Placentia, CA 02870 EHornandez(c)CitvofRosemeadonl
NHaworth (a)CitvofRosemead.onl
City Clerk's Department
City Clerk
City mfSan Gabriel
City ofSeal Beach
4258. Mission Drive
211 8mStreet
San Gabriel, CA 91776
Seal Beach, CA 90740
CitvC|erk(c-oaoch.orq
psan*ovo(oDooa|uoaoxcmuov
TKe|sev(a),xea|ueanxoa.vov
City Clerk, Patricia Vazquez City Manager
City ofStanton City mfTemple City
7800Kahs||aAvenue 9701 Las Tunas Drive
Stanton, CA 90080 Temple City, CA 91780
pvmzquez(o)oi.atentun.oa.ua
Page 11ov1u
GOLDEN STATE WATER COMPANY
REGION 1, 2 & 3 - SERVICE LIST
County Counsel
County of San Bernardino
385 N. Arrowhead Avenue, 2nd Floor
San Bernardino, CA 92415-0140
Chamber President
Niland Chamber of Commerce
P. O. Box 97
Niland, CA 92257
County Counsel
County of Los Angeles
500 W. Temple Street — 5t" Floor
Los Angeles, CA 90012
Scott Blaising
Braun Blaising McLaughlin & Smith PC
915 L Street, Suite 1270
Sacramento, CA 95814
blaisina(a)braunleaal.com
Naval Facilities Engineering Command
Rea D. Estrella
Southwest Division
1220 Pacific Highway
San Diego, CA 92132
Rea.estrella(cDnavv.mil
Liberty Utilities (California)
9750 Washburn Road
Downey, CA 90241
Advice LetterService(a) Li bertvUti I iti es. com
City Clerk
City of Yorba Linda
4845 Casa Loma Avenue
Yorba Linda, CA 92686
County of San Bernardino
Water & Sanitation Area
P.O. Box 5004
Victorville, CA 92393-5004
Michael Kent
Contra Costa Health Services
597 Center Avenue, Suite 320
Martinez, CA 94553-4635
Fred G. Yanney
Yanney Law Office
17409 Marquardt Ave., Unit C-4
Cerritos, CA 90703
FredYannev(@amail.com
Megan Somogyi
Goodin, MacBride, Squeri & Day, LLP
505 Sansome Street, Suite 900
San Francisco, CA 94111
MSomogv(d?aoodinmacbride.com
County of Ventura
800 S. Victoria Street
Ventura, CA 93009
Page 12 of 12