BEFORE THE PUBLIC UTILITIES COMMISSION

OF THE STATE OF CALIFORNIA

FILED
6-22-15
04:59 PM

Application of California-American Water

Company (U210W) for Approval of the
Monterey Peninsula Water Supply Project
and Authorization to Recover All Present and
Future Costs in Rates.

Application 12-04-019
(Filed April 23, 2012)

MOTION OF CURE TO BECOME A PARTY

June 22, 2015

Tanya A. Gulesserian
Laura Horton
Adams Broadwell Joseph & Cardozo
601 Gateway Boulevard, Suite 1000
South San Francisco, CA 94080
(650) 589-1660 Voice
(650) 589-5062 Facsimile
tgulesserian@adamsbroadwell.com
lhorton@adamsbroadwell.com
Attorneys for California Unions for Reliable
Energy

1840-023cv

BEFORE THE PUBLIC UTILITIES COMMISSION

OF THE STATE OF CALIFORNIA
Application of California-American Water
Company (U210W) for Approval of the
Monterey Peninsula Water Supply Project
and Authorization to Recover All Present and
Future Costs in Rates.

Application 12-04-019
(Filed April 23, 2012)

MOTION OF CURE TO BECOME A PARTY

Pursuant to Rule 1.4 of the Commissions Rules of Practice and Procedure,
California Unions for Reliable Energy (CURE) respectfully submits its motion to
become a party to this proceeding.
CURE is a coalition of unions whose members construct, maintain and
operate industrial projects in California. Additionally, union members live along
the Monterey Bay and use the areas that suffer the impacts of environmentally
detrimental projects. Thus, the Monterey Peninsula Water Supply Project directly
affects the union members immediate economic, environmental, and other
interests.
CURE seeks party status in order to participate in the environmental review
process for the Project, pursuant to the California Environmental Quality Act
(CEQA) and any related cost issues that arise from the CEQA review. In
accordance with the Revised Common Briefing Outline filed on June 5, 2015, CURE
would participate in legal and policy briefing insofar as it relates to environmental
and CEQA issues. CURE does not seek to broaden the issues in this proceeding, nor
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1840-023cv

to unduly delay the schedule of this proceeding. CURE further believes that its
becoming a party will not result in any prejudice to any party.
In order to preserve its ability to provide comments related to the
Commissions compliance with CEQA and related cost issues, CURE respectfully
requests that the Commission grant its motion to become a party in this proceeding.

Communications to CURE may be sent to:

Laura Horton
Adams Broadwell Joseph & Cardozo
601 Gateway Boulevard, Suite 1000
South San Francisco, CA 94080
(650) 589-1660
lhorton@adamsbroadwell.com
Dated: June 22, 2015

Respectfully submitted,
_______________/s/__________________
Tanya A. Gulesserian
Laura Horton
Adams Broadwell Joseph & Cardozo
601 Gateway Boulevard, Suite 1000
South San Francisco, CA 94080
tgulesserian@adamsbroadwell.com
lhorton@adamsbroadwell.com
Attorneys for California Unions for Reliable
Energy

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1840-023cv