COST OF CAPITAL
Thank you to all who attended the Public Participation Hearing back in November and have written letters to the appropriate people at the CPUC. The 5 commissioners voted on ALJ Bemesderfer’s REVISED* proposed decision this Thursday, March 22, 2018. The revised proposed decision can be viewed at http://docs.cpuc.ca.gov/PublishedDocs/Published/G000/M212/K335/212335370.PDF
With this vote approving higher than originally proposed* lower return rates. We will see a slight reduction in our rates. i.e. 3/4” meter customers using 15ccfs per month will see their bi- monthly bill reduce by $3.32.
We believe that if it weren’t for the efforts by WRATES and customers writing specific Cost of Capital letters to the appropriate CPUC people, the water utility return rates would be much higher.
*CofC Proposed Decision Time Line
2/6/18 - ALJ Bemesderfer files his Proposed Decision (PD) resulting in:
Cal Water ROE = 8.22%
Cal Am ROE = 8.23%
Golden State ROE = 8.23%
SJWC ROE = 8.3%
2/14/18 - All 4 water companies begin inundating the 5 commissioners and their advisors with ex parte closed door meetings to influence the commissioners to NOT accept the PD. Ratepayers were not granted this privilege.
2/26/18 - 3/20/18 - The 4 water companies rally their attorneys, lobbyists, unions, special interest groups, leadership groups etc. to write letters to the commissioners and law judge denouncing the PD, the ORA, and even the law judge. 43 letters in all. (All these groups are paid for by the utilities through direct payment, dues or donations.) Many of the strongly worded letters were insulting to the law judge and the CPUC process because the water companies did not achieve the numbers they wanted.
Here is a letter from California Water Association (CWA), one of the largest California water lobbyist that the water utilities pay hundreds of thousands of dollars to. CWA was noted in a November 2017 article as ranking in the top 500 of CA Lobbyists that spent the most money influencing legislature (Rank of No. 56). CWA even called the ratepayer activist group out in this letter stating, “CWA acknowledges that the Constitutionally independent Commission is under political pressure from the legislature, the media, and certain activist groups (dominated by affluent and high-volume water users) to appear responsive to ratepayer interests…”
CWA describes the PD as woeful, abysmal, abuse of discretion, harmful to customers, error-filled, in violation of regulatory principles, invalid and phony, flawed, misinformed, solely to benefit customers, egregious assertion, Commissioners’ priorities changed, denial of due process, unduly discriminatory, stunning failure, unjust outcome.
This letter alone shows how the commissioners and the law judge were bullied and strong armed into changing the PD.
3/21/18 - One day before the commissioners were to vote on the PD, ALJ Bemesderfer filed a new PD with revised returns. To take a quote from the CWA letter, “This suggests that external pressures played a large role in shaping this unjust outcome.”
Cal Water ROE = 8.22% increased to 9.2%
Cal Am ROE = 8.23% increased to 9.2%
Golden State ROE = 8.23% increased to 8.9%
SJWC ROE = 8.3% increased to 8.9%
3/22/18 - The 5 commissioners unanimously voted to approve the NEW REVISED Proposed Decision. By doing this, the commissioners and law judge have reinforced the bullying behavior of the IOUs and given them the green light to continue this behavior in future proceedings.
Although WRATES considers this a small win, it is fraught with CPUC failures starting with the decision being changed in the 11th hour. Going forward your support will be needed on the next stage of increases currently b being reviewed, the General Rate Case.
With this vote approving higher than originally proposed* lower return rates. We will see a slight reduction in our rates. i.e. 3/4” meter customers using 15ccfs per month will see their bi- monthly bill reduce by $3.32.
We believe that if it weren’t for the efforts by WRATES and customers writing specific Cost of Capital letters to the appropriate CPUC people, the water utility return rates would be much higher.
*CofC Proposed Decision Time Line
2/6/18 - ALJ Bemesderfer files his Proposed Decision (PD) resulting in:
Cal Water ROE = 8.22%
Cal Am ROE = 8.23%
Golden State ROE = 8.23%
SJWC ROE = 8.3%
2/14/18 - All 4 water companies begin inundating the 5 commissioners and their advisors with ex parte closed door meetings to influence the commissioners to NOT accept the PD. Ratepayers were not granted this privilege.
2/26/18 - 3/20/18 - The 4 water companies rally their attorneys, lobbyists, unions, special interest groups, leadership groups etc. to write letters to the commissioners and law judge denouncing the PD, the ORA, and even the law judge. 43 letters in all. (All these groups are paid for by the utilities through direct payment, dues or donations.) Many of the strongly worded letters were insulting to the law judge and the CPUC process because the water companies did not achieve the numbers they wanted.
Here is a letter from California Water Association (CWA), one of the largest California water lobbyist that the water utilities pay hundreds of thousands of dollars to. CWA was noted in a November 2017 article as ranking in the top 500 of CA Lobbyists that spent the most money influencing legislature (Rank of No. 56). CWA even called the ratepayer activist group out in this letter stating, “CWA acknowledges that the Constitutionally independent Commission is under political pressure from the legislature, the media, and certain activist groups (dominated by affluent and high-volume water users) to appear responsive to ratepayer interests…”
CWA describes the PD as woeful, abysmal, abuse of discretion, harmful to customers, error-filled, in violation of regulatory principles, invalid and phony, flawed, misinformed, solely to benefit customers, egregious assertion, Commissioners’ priorities changed, denial of due process, unduly discriminatory, stunning failure, unjust outcome.
This letter alone shows how the commissioners and the law judge were bullied and strong armed into changing the PD.
3/21/18 - One day before the commissioners were to vote on the PD, ALJ Bemesderfer filed a new PD with revised returns. To take a quote from the CWA letter, “This suggests that external pressures played a large role in shaping this unjust outcome.”
Cal Water ROE = 8.22% increased to 9.2%
Cal Am ROE = 8.23% increased to 9.2%
Golden State ROE = 8.23% increased to 8.9%
SJWC ROE = 8.3% increased to 8.9%
3/22/18 - The 5 commissioners unanimously voted to approve the NEW REVISED Proposed Decision. By doing this, the commissioners and law judge have reinforced the bullying behavior of the IOUs and given them the green light to continue this behavior in future proceedings.
Although WRATES considers this a small win, it is fraught with CPUC failures starting with the decision being changed in the 11th hour. Going forward your support will be needed on the next stage of increases currently b being reviewed, the General Rate Case.
********************************************************
On February 6, 2018, Administrative Law Judge Karl Bemesderfer submitted his Proposed Decision for the Cost of Capital Application A.1704001 in favor of reduced return rates.
The 4 class 'A' investor owned water utilities (IOUs) are not happy with his decision. The 4 IOUs have been granted numerous exparte meetings over the last few weeks with the 5 Commissioners to influence their decision to NOT accept ALJ Bemesderfer's decision. They are currently requesting an 80 minute Oral Argument before the commission to plead their case. They are requesting this after all arguments in the proceeding have been heard and a decision has been rendered. In the real world court system this would not be allowed. The CPUC does not seem to have a problem with influence peddling by the IOUs the are regulating.
WRATES REBUTTAL LETTER. Click HERE for a summary of the WRATES talking points used at the Nov. 6 Public Hearing to draw inspiration from when writing you email.
-------------------------------
On February 6, 2018, Administrative Law Judge Karl Bemesderfer submitted his Proposed Decision for the Cost of Capital Application A.1704001 in favor of reduced return rates.
The 4 class 'A' investor owned water utilities (IOUs) are not happy with his decision. The 4 IOUs have been granted numerous exparte meetings over the last few weeks with the 5 Commissioners to influence their decision to NOT accept ALJ Bemesderfer's decision. They are currently requesting an 80 minute Oral Argument before the commission to plead their case. They are requesting this after all arguments in the proceeding have been heard and a decision has been rendered. In the real world court system this would not be allowed. The CPUC does not seem to have a problem with influence peddling by the IOUs the are regulating.
WRATES REBUTTAL LETTER. Click HERE for a summary of the WRATES talking points used at the Nov. 6 Public Hearing to draw inspiration from when writing you email.
-------------------------------
ADDED 3/19/18 - SJWC MERGER WITH CONNECTICUT WATER SERVICE; SJWC has announced an all stock merger with Connecticut Water Services (CTWS). This will make SJWC the third largest in the Nation serving 1.5 million people. The new CEO, Eric Thornburg, was CEO of CTWS before becoming SJW CEO. He stated that this merger will lower their Cost of Capital. This merger seems like information the CPUC should have known about in the Cost of Capital proceedings. If the CEO himself is saying that this merger will lower their Cost of Capital and SJWC has been vigorously fighting for higher Cost of Capital returns, this appears disingenuous at best. SJWC carries a debt of $431.1M and SJW will assume $255.2M of CTWS’ debt.
https://marketexclusive.com/sjw-group-nysesjw-files-an-8-k-entry-into-a-material-definitive-agreement/2018/03/
https://seekingalpha.com/article/4157565-thoughts-san-jose-water-connecticut-water-merger?auth_param=1djdcs:1davq50:c3fd7b787a081aca136a4ff035d299ee&uprof=45&dr=1
https://marketexclusive.com/sjw-group-nysesjw-files-an-8-k-entry-into-a-material-definitive-agreement/2018/03/
https://seekingalpha.com/article/4157565-thoughts-san-jose-water-connecticut-water-merger?auth_param=1djdcs:1davq50:c3fd7b787a081aca136a4ff035d299ee&uprof=45&dr=1
11/1/17 Article - Hearing Set as San Jose Water Company Requests Rate Hike; Overbilling Questions Still Linger. CPUC will host a public hearing at City Hall on Monday, as SJWC is petitioning for an increase in its cost of capital and rate of return for infrastructure projects through 2020. If the CPUC approves the petition, San Jose Water would see an overall increase in revenues of nearly $7.6 million, which would cost the average customer about $2.14 more per month (or $4.28 per bimonthly billing cycle). “By attending the CPUC hearing on Monday, the customers of SJWC will finally have a chance to speak, on the record, to the CPUC decision makers to let them know that we have had enough of SJWC’s outrageous rate increases,” Benton told San Jose Inside. “We will actually see a reduction in our water rates come January if the CPUC lowers SJWC’s investment returns.” By Jennifer Wadsworth, Metro/SanjoseInside
-------------------------------
COST OF CAPITAL DOCUMENTS
In this proceeding, four of California’s largest investor-owned water utilities have requested increases in their authorized rates of return. The authorized rate of return compensates utilities for their costs of financing necessary infrastructure. The authorized rate of return takes into consideration the cost of debt, a return on investor’s equity, and the proportion of debt and equity that comprise a utility's overall capital structure. The current cost of capital proceeding will establish authorized rates of return for the 2018 through 2020 period.
ADDED 3/4/18 - February 6, 2018 PROPOSED DECISION by Law Judge Bemesderfer FIXING COST OF CAPITAL FOR CALENDAR YEARS 2018, 2019 AND 2020 FOR CAL WATER, CAL-AM, GOLDEN STATE AND SJWC
ADDED 3/6/18
NOTICE OF EX PARTE COMMUNICATION - 2/26/18 from 1:30 to 2:00 - between Lester Wong, advisor advisor to Comm. Liane Randolph and Presidents, Executive VP & Attorney's for Cal Water, Golden State, Cal-Am and SJWC. During the meeting, Applicants urged the Commission to modify the Proposed Decision (“PD”) issued on February 6, 2018 so that the return on equity (“ROE”) proposed for each company appropriately reflects the Commission’s policy goals and the evidentiary record. The Applicants explained that, if adopted as-is, the PD will have long-term negative effects for customers in the form of higher rates.
EX PARTE MEETING - 2/23/18 from 11:00 to 11:35 - between CPUC Commissioner Guzman-Aceves, her advisor Michael Minkus and CEOs, Presidents, VP of Regulatory, Executive VP & Attorney for Cal Water, Golden State, Cal-Am and SJWC. During the meeting, Applicants urged the Commission to modify the Proposed Decision (“PD”) issued on February 6, 2018 so that the return on equity (“ROE”) proposed for each company appropriately reflects the Commission’s policy goals and the evidentiary record. The Applicants explained that, if adopted as-is, the PD will have long-term negative effects for customers in the form of higher rates.
JOINT MOTION OF APPLICANTS CAL-AM, CAL WATER, GOLDEN STATE AND SJWC FOR ORAL ARGUMENT - Submitted 2/28/18 - Applicants did not submit a timely request for oral argument, yet the 4 water utilities believe that the Proposed Decision of Administrative Law Judge (“ALJ”) Bemesderfer shows no sign of an objective, balanced review of the evidentiary record and are asking the commission to grant them 80 minutes to plead their case.
SUPPORT LETTER FROM SANTA CLARA & SAN BENITO COUNTIES BUILDING & CONSTRUCTION TRADES COUNCIL - 2/26/18 - urging the commission to reconsider ALJ Bemesderfer's decision so SJWC can continue to deliver safe, high quality, reliable water service at just and reasonable rates and create thousands of jobs for the proud union men and women.
SUPPORT LETTER FROM NATIONAL ASSOCIATION OF WATER COMPANIES (NAWC) - In the Proposed Decision (PD) issued on February 6, 2018, conclusions are reached that are both factually incorrect, and also have profound long-term negative consequences for the four utilities and their customers.
EX PARTE MEETINGS - The 4 water utilities held meetings with advisors and commissioners at the request of applicants. Applicants urged the Commission to modify the Proposed Decision (“PD”) issued on February 6, 2018 so that the return on equity (“ROE”) proposed for each company appropriately reflects the Commission’s policy goals and the evidentiary record.
EX PARTE MEETINGS - 2/27/18 AT 3:30 between ORA and Shannon O'rourk, Advisor to Comm. Carla J. Peterman. ORA urged the Commission to uphold the outcome of the Proposed Decision (“PD”) issued on February 6, 2018. ORA reinforced that the return on equity is not the sole determinant of the overall rate of return established in this proceeding. ORA ATTACHMENTS.
COMMENTS OF SJWC ON PROPOSED DECISION OF ALJ BEMESDERFER - filed 2/26/18 by Executive VP and attorneys for SJWC -
The Proposed Decision of ALJ Bemesderfer fails to provide an objective, balanced review of the evidentiary record. To the contrary, the Proposed Decision reflects reliance almost exclusively on the testimony of ORA’s witnesses, to the point that substantial segments of the Proposed Decision read like a paraphrase of ORA’s briefs.
THREE-DAY ADVANCE NOTICE OF EX PARTE COMMUNICATION OF TE ORA - 2/27/18 at 3:30 with Shannon O'Rourke, Advisor to Comm. Carla J. Peterman; 2/28/18 at 11:30 with Elizabeth Podolinksy, Advisor to President Michael Picker; 3/1/18 at 1:00 with Travis Foss, Advisor to Comm. Clifford Rechtschaffen and ORA Richard Rauschmeier, Program and Project Supervisor, Mr. Aaron Rothschild, financial consultant and Ms. Vanessa Young, attorney for ORA.
NOTICE OF EX PARTE MEETING WITH SHANNON O'ROURKE, ADVISOR TO COMMISSIONER CARLA J. PETERMAN HAS BEEN GRANTED - 2/15/18 - Meeting will be held at 1:30 on 2/21/18
NOTICE OF EX PARTE MEETING WITH TRAVIS FOSS, ADVISOR TO COMMISSIONER CLIFFORD RECHTSCHAFFEN HAS BEEN GRANTED - 2/14/18 - Meeting will be held at 1:30 on 2/20/18
NOTICE OF EX PARTE MEETING WITH COMMISSIONER GUZMAN ACEVES HAS BEEN GRANTED - 2/20/18 - Meeting will be held at 11:00 on 2/23/18
NOTICE OF EX PARTE MEETING WITH LESTER WONG, ADVISOR TO COMMISSIONER LIANE RANDOLPH HAS BEEN GRANTED - 2/22/18 - Meeting will be held at 1:30 on 2/26/18
NOTICE OF EX PARTE MEETING WITH ELIZABETH PODOLINSKY, ADVISOR TO PRESIDENT MICHAEL PICKER HAS BEEN GRANTED - 2/14/18 - Meeting will be held at 1:00 on 2/20/18
THREE-DAY ADVANCE NOTICE OF EX PARTE MEETING - 3/6/18 at 10:30 - between Shannon O'Rourke, advisor to Comm. Peterman and Executive VP, CFO, inside and outside attorneys for SJWC
ADDED 6/18/17 - Cost of Capital Application - SJWC filed application A.17-04-001 on April 3, 2017. The CPUC decision will be made some time in December 2017. This Cost of Capital (CofC) is the foundation for the next General Rate Case for setting our rates for the years 2019, 20 & 21 and it will also affect our current General Rate Case effective January 1, 2018. The current CofC allows SJWC an 9.43% rate of equity. SJWC is seeking to increase its rate of equity to 10.75%. ORA testimony seeks to decrease the rate of equity to 8.30%.
On August 1, 2017, ORA served testimony based upon its independent analysis of the utilities’ applications. The following table compares each of the four utilities’ requests with ORA’s recommendations and calculates the approximate annual difference in customer rates that would be expected to result.
The Commissioner and Administrative Law Judge assigned to the CofC application are:
- Commissioner Martha Guzman Aceves
- Administrative Law Judge Karl Bemesderfer
Cost of Capital Attachments:
Direct Testimony of Aaron Rothschild for ORA - Proceeding A.17-04-001 et al.
Documents Referenced in Direct Testimony of Aaron Rothschild - Proceeding A.17-04-001 et al.
Direct Testimony of Mukunda Dawadi for ORA - Proceeding A.17-04-001 et al.
Lynch Testimony & Schedules.pdf
Ahern Exhibits.pdf
Ahern Testimony.pdf
Opening Brief of SJWC - Proceeding A.17-04-001 et al.
Reply Brief of SJWC - Proceeding A.17-04-001 et al.
____________________________
COST OF CAPITAL DOCUMENTS
In this proceeding, four of California’s largest investor-owned water utilities have requested increases in their authorized rates of return. The authorized rate of return compensates utilities for their costs of financing necessary infrastructure. The authorized rate of return takes into consideration the cost of debt, a return on investor’s equity, and the proportion of debt and equity that comprise a utility's overall capital structure. The current cost of capital proceeding will establish authorized rates of return for the 2018 through 2020 period.
ADDED 3/4/18 - February 6, 2018 PROPOSED DECISION by Law Judge Bemesderfer FIXING COST OF CAPITAL FOR CALENDAR YEARS 2018, 2019 AND 2020 FOR CAL WATER, CAL-AM, GOLDEN STATE AND SJWC
ADDED 3/6/18
NOTICE OF EX PARTE COMMUNICATION - 2/26/18 from 1:30 to 2:00 - between Lester Wong, advisor advisor to Comm. Liane Randolph and Presidents, Executive VP & Attorney's for Cal Water, Golden State, Cal-Am and SJWC. During the meeting, Applicants urged the Commission to modify the Proposed Decision (“PD”) issued on February 6, 2018 so that the return on equity (“ROE”) proposed for each company appropriately reflects the Commission’s policy goals and the evidentiary record. The Applicants explained that, if adopted as-is, the PD will have long-term negative effects for customers in the form of higher rates.
EX PARTE MEETING - 2/23/18 from 11:00 to 11:35 - between CPUC Commissioner Guzman-Aceves, her advisor Michael Minkus and CEOs, Presidents, VP of Regulatory, Executive VP & Attorney for Cal Water, Golden State, Cal-Am and SJWC. During the meeting, Applicants urged the Commission to modify the Proposed Decision (“PD”) issued on February 6, 2018 so that the return on equity (“ROE”) proposed for each company appropriately reflects the Commission’s policy goals and the evidentiary record. The Applicants explained that, if adopted as-is, the PD will have long-term negative effects for customers in the form of higher rates.
JOINT MOTION OF APPLICANTS CAL-AM, CAL WATER, GOLDEN STATE AND SJWC FOR ORAL ARGUMENT - Submitted 2/28/18 - Applicants did not submit a timely request for oral argument, yet the 4 water utilities believe that the Proposed Decision of Administrative Law Judge (“ALJ”) Bemesderfer shows no sign of an objective, balanced review of the evidentiary record and are asking the commission to grant them 80 minutes to plead their case.
SUPPORT LETTER FROM SANTA CLARA & SAN BENITO COUNTIES BUILDING & CONSTRUCTION TRADES COUNCIL - 2/26/18 - urging the commission to reconsider ALJ Bemesderfer's decision so SJWC can continue to deliver safe, high quality, reliable water service at just and reasonable rates and create thousands of jobs for the proud union men and women.
SUPPORT LETTER FROM NATIONAL ASSOCIATION OF WATER COMPANIES (NAWC) - In the Proposed Decision (PD) issued on February 6, 2018, conclusions are reached that are both factually incorrect, and also have profound long-term negative consequences for the four utilities and their customers.
EX PARTE MEETINGS - The 4 water utilities held meetings with advisors and commissioners at the request of applicants. Applicants urged the Commission to modify the Proposed Decision (“PD”) issued on February 6, 2018 so that the return on equity (“ROE”) proposed for each company appropriately reflects the Commission’s policy goals and the evidentiary record.
EX PARTE MEETINGS - 2/27/18 AT 3:30 between ORA and Shannon O'rourk, Advisor to Comm. Carla J. Peterman. ORA urged the Commission to uphold the outcome of the Proposed Decision (“PD”) issued on February 6, 2018. ORA reinforced that the return on equity is not the sole determinant of the overall rate of return established in this proceeding. ORA ATTACHMENTS.
COMMENTS OF SJWC ON PROPOSED DECISION OF ALJ BEMESDERFER - filed 2/26/18 by Executive VP and attorneys for SJWC -
The Proposed Decision of ALJ Bemesderfer fails to provide an objective, balanced review of the evidentiary record. To the contrary, the Proposed Decision reflects reliance almost exclusively on the testimony of ORA’s witnesses, to the point that substantial segments of the Proposed Decision read like a paraphrase of ORA’s briefs.
THREE-DAY ADVANCE NOTICE OF EX PARTE COMMUNICATION OF TE ORA - 2/27/18 at 3:30 with Shannon O'Rourke, Advisor to Comm. Carla J. Peterman; 2/28/18 at 11:30 with Elizabeth Podolinksy, Advisor to President Michael Picker; 3/1/18 at 1:00 with Travis Foss, Advisor to Comm. Clifford Rechtschaffen and ORA Richard Rauschmeier, Program and Project Supervisor, Mr. Aaron Rothschild, financial consultant and Ms. Vanessa Young, attorney for ORA.
NOTICE OF EX PARTE MEETING WITH SHANNON O'ROURKE, ADVISOR TO COMMISSIONER CARLA J. PETERMAN HAS BEEN GRANTED - 2/15/18 - Meeting will be held at 1:30 on 2/21/18
NOTICE OF EX PARTE MEETING WITH TRAVIS FOSS, ADVISOR TO COMMISSIONER CLIFFORD RECHTSCHAFFEN HAS BEEN GRANTED - 2/14/18 - Meeting will be held at 1:30 on 2/20/18
NOTICE OF EX PARTE MEETING WITH COMMISSIONER GUZMAN ACEVES HAS BEEN GRANTED - 2/20/18 - Meeting will be held at 11:00 on 2/23/18
NOTICE OF EX PARTE MEETING WITH LESTER WONG, ADVISOR TO COMMISSIONER LIANE RANDOLPH HAS BEEN GRANTED - 2/22/18 - Meeting will be held at 1:30 on 2/26/18
NOTICE OF EX PARTE MEETING WITH ELIZABETH PODOLINSKY, ADVISOR TO PRESIDENT MICHAEL PICKER HAS BEEN GRANTED - 2/14/18 - Meeting will be held at 1:00 on 2/20/18
THREE-DAY ADVANCE NOTICE OF EX PARTE MEETING - 3/6/18 at 10:30 - between Shannon O'Rourke, advisor to Comm. Peterman and Executive VP, CFO, inside and outside attorneys for SJWC
ADDED 6/18/17 - Cost of Capital Application - SJWC filed application A.17-04-001 on April 3, 2017. The CPUC decision will be made some time in December 2017. This Cost of Capital (CofC) is the foundation for the next General Rate Case for setting our rates for the years 2019, 20 & 21 and it will also affect our current General Rate Case effective January 1, 2018. The current CofC allows SJWC an 9.43% rate of equity. SJWC is seeking to increase its rate of equity to 10.75%. ORA testimony seeks to decrease the rate of equity to 8.30%.
On August 1, 2017, ORA served testimony based upon its independent analysis of the utilities’ applications. The following table compares each of the four utilities’ requests with ORA’s recommendations and calculates the approximate annual difference in customer rates that would be expected to result.
The Commissioner and Administrative Law Judge assigned to the CofC application are:
- Commissioner Martha Guzman Aceves
- Administrative Law Judge Karl Bemesderfer
Cost of Capital Attachments:
Direct Testimony of Aaron Rothschild for ORA - Proceeding A.17-04-001 et al.
Documents Referenced in Direct Testimony of Aaron Rothschild - Proceeding A.17-04-001 et al.
Direct Testimony of Mukunda Dawadi for ORA - Proceeding A.17-04-001 et al.
Lynch Testimony & Schedules.pdf
Ahern Exhibits.pdf
Ahern Testimony.pdf
Opening Brief of SJWC - Proceeding A.17-04-001 et al.
Reply Brief of SJWC - Proceeding A.17-04-001 et al.
____________________________