500 CAPITOL MALL, SUITE 1000, SACRAMENTO, CA 95814
OFFICE: 916-446-7979 FAX: 916-446-8199
SOMACHLAW.COM
August 3, 2022
Via Electronic Mail Only
E. Joaquin Esquivel, Chair
State Water Resources Control Board
P.O. Box 100
Sacramento, CA 95814
[email protected]
Re: Proposed Order on City of Stockton Pending Application 30531B Dear Chair Esquivel and Members of the Board:
On behalf of the City of Stockton (City), I respectfully request that the State Water Resources Control Board (State Water Board) reject the Administrative Hearing Officer’s (AHO) Proposed Order on Pending Application 30531B (Proposed Order) and maintain Application 30531B (A030531B) with a reduced maximum allowable diversion volume of 33,600 acre-feet per year (af/yr). This letter contains the City’s basis for this request.
A. The City Has Initiated the Construction of Works Required to Divert and Use Water Under A030531B and Has a Feasible Plan and the Financial Resources to Finish Construction of Facilities Required to Divert and Use Water Under A030531B
An application will be denied when it appears after hearing or a proceeding in lieu of a hearing that (a) the applicant does not intend to initiate construction of the works required for the contemplated use of water within a reasonable time and thereafter diligently prosecute the construction and use of water to completion, or (b) the applicant will not be able to proceed within a reasonable time, either because of absence of a feasible plan, lack of the required financial resources, or other cause. (Cal. Code Regs., tit. 23, § 840.)
1. The City has initiated construction of works required to divert and use water under A030531B and specified the additional works required to divert and use water under A030531B
The Proposed Order states that “the City has not offered sufficient evidence to show the City will initiate construction of the works required to divert and use that water within a ATTACHMENT 2
E. Joaquin Esquivel, Chair
State Water Resources Control Board
Re: City of Stockton Pending Application 30531B
August 3, 2022
reasonable time under any of the City’s scenarios for using Application 30531B water.” (Proposed Order, p. 21.) More specifically, the Proposed Order states that “Stockton did not offer evidence during the hearing of what facilities need to be constructed to use either source of Application 30531B water or when Stockton would initiate construction of such facilities.” (Proposed Order, pp. 28-29.)
The City provided evidence that it has constructed some of the Delta Water Supply Project (DWSP) facilities necessary to use water under A030531B at a total cost of approximately $25 million. (Stockton-01, p. 5:10-24.) Specifically, as of May 2012, the City had installed the first phase of the DWSP, including an intake structure and raw water pipeline to accommodate water use greater than that authorized by Permit 21176, which is 30 million gallons per day (mgd).1
(Stockton-01, p. 5:10-15.) Also, the City installed a 13-mile pipeline from the DWSP point of diversion on the San Joaquin River to the City’s Drinking Water Treatment Plant (DWTP) capable of conveying 60 mgd. Also, the intake structure was designed to accommodate an 80 mgd pumping capacity, meaning that the structure and fish screens were sized to accommodate an 80 mgd pumping rate. (Stockton-01, p.5:15-19; Hearing Recording (HR) 34:42-35:10; 1:29:01-1:29:17.) Also, the DWTP was constructed to provide the flexibility to add treatment without taking the DWTP offline. (Stockton-01, p. 5:21-22; HR 37:14-37:23.) Mr. Robert Granberg estimated that the incremental additional cost of constructing a raw water pipeline and an intake structure capable of conveying 60 mgd versus 30 mgd was approximately $25 million. (Stockton-02, p. 9:6-23.) During the hearing, the City identified the additional DWSP facilities that would be necessary to divert and treat water under A030531B – i.e., more than 30 mgd. Mr. Granberg noted that, to use water under A030531B, the City would need additional pumping capacity, meaning installation of replacement and or additional pumps capable of pumping more than 30 mgd. (HR 56:17-57:01.) Specifically, Dr. Mel Lytle noted that, with additional settling basins and membrane filtration at the DWTP, the DWTP can accommodate up to 60 mgd. (HR 37:07-37:44.) Echoing Dr. Lytle, Mr. Granberg noted that the DWTP would need additional treatment units (i.e., membrane filtration) to accommodate greater than 30 mgd. (HR 56:17-57:01.) Importantly, the City was very intentional about sizing these facilities to accommodate diversions under A030531B. (HR 36:38-37:12; 1:27:58-1:30:40.) The AHO cites to Dr. Lytle stating that additional construction would be needed at the DWTP, and at buildout “new tooling” at the actual intake station and an additional raw water line would be needed, as well as expansion of treatment works. (Proposed Order, p. 29, citing to HR 38:50-39:17). The AHO appears to rely on this statement to conclude that additional, unspecified construction would be necessary at the intake, and an additional raw water line would be necessary to convey water under A030531B. Other portions of the written and oral
1 The City currently holds Permit 21176, which authorizes the City to divert a maximum of 33,600 af/yr (i.e., 30 mgd). The City diverts water pursuant to this permit through the DWSP facilities.
ATTACHMENT 2
E. Joaquin Esquivel, Chair
State Water Resources Control Board
Re: City of Stockton Pending Application 30531B
August 3, 2022
testimony, however, clarify that, to use A030531B water, additional pump capacity would be required at the intake to ensure pumping capacity greater than 30 mgd. (HR 56:17-57:01.) Also, both Dr. Lytle and Mr. Granberg note that the existing raw water pipeline was sized to 60 mgd. (Stockton-01, p.5:15-19; Hearing Recording (HR) 34:42-35:10; HR 37:02-37:12; 1:29:01-1:29:17.) So, there is currently no need to install a new raw water pipeline to convey more than 30 mgd and up to 60 mgd from the intake station to the DWTP. Also, Dr. Lytle was specific that to treat more than 30 mgd at the DWTP it would be necessary to add settling basins and membrane filtration. (HR 37:07-37:44.) Thus, there is specific evidence in the record regarding the facilities that the City needs to construct to use water under A030531B.
The AHO notes that “Mr. Granberg explained that in 2070, additional treatment and pumping capacity would be needed.” (Proposed Order, p. 29.) To clarify, Mr. Granberg did not say that additional treatment and pumping capacity would be needed in 2070. When Mr.
Granberg’s statements are read in context, it is clear that he was saying that additional treatment and pumping capacity would be needed to divert and treat more than 30 mgd (33,600 af/yr). According to Mr. Granberg’s projections in Stockton-02, Table 1, additional treatment would be needed by 2035 when the WID contract water supply increases from 6,500 af/yr to 13,000 af/yr and SEWD supplies are no longer available. The City not only treats Permit 21176 water at the DWTP, but also treats WID water at the DWTP. With these two supplies combined, in 2030, the City would have a total of 37,800 af available to treat.
The City assumes that, when it expands treatment capacity for WID water, it will expand treatment capacity for any foreseeable use of A030531B water. Expanding treatment capacity to 60 mgd, which is the next planned capacity increment, coupled with additional pumping capacity at the intake facility, would allow the City to use the entire 33,600 af/yr requested under A030531B by 2070 as shown in Stockton-02, Table 1.
The AHO states that the City does not explain how a permit issued on A030531B would allow the City to pump more water at the intake facility in 2035 because the DWSP is currently subject to Biological Opinion (BiOp) and Incidental Take Permit (ITP) pumping restrictions that limit annual pumping to 25,000 af/yr. (Proposed Order, p. 31.) Permit 21176 limits diversions to no more than the 15-day running average of wastewater discharges to the San Joaquin River. That limitation, coupled with the BiOp and ITP pumping restrictions, equates to a limit on the City’s ability to fully utilize Permit 21176. The City assumes that at least a portion of A030531B water would not be restricted to a 15-day wastewater discharge running average because a permit issued on A030531B would provide, in part, for diversion of natural flow on the basis of an area of origin claim. Without the 15-day running average limitation, the City would be able to divert a greater amount of water outside of the BiOp and ITP pumping restriction periods such that total annual diversions could exceed 25,000 af/yr.
If the Eastern San Joaquin County Groundwater Authority (ESJGA) implements further restrictions on groundwater pumping for basin recovery, the City could initiate a limit on groundwater pumping to no more than 10% of potable water demand throughout its water ATTACHMENT 2
E. Joaquin Esquivel, Chair
State Water Resources Control Board
Re: City of Stockton Pending Application 30531B
August 3, 2022
service area. Under that scenario, Stockton-02, Table 1 demonstrates a need for both an expansion of the water treatment plant and a permit for A030531B water to meet demand sometime between 2030 and 2035, when the SEWD contract expires. Regarding diversions at the intake facility, Stockton-02, Table 1, projects the City exceeding 33,600 af/yr sometime between 2045 and 2050, assuming groundwater production is limited to 10% of demand.
Since the BiOp and ITP currently limit pumping at the intake facility to 30 mgd, the City assumes that it will obtain an amendment to the BiOp and ITP by this time that would allow for a greater daily pumping rate. The City recently engaged a fish biologist to re-evaluate fish conditions in anticipation of further discussions with United States Fish and Wildlife Service and California Department of Fish and Wildlife about modifications of the pumping restriction periods in the spring and the 30 mgd limit.
The AHO’s response to Comment 2 states that “Stockton still has not identified when it would make these modifications … or complete the CEQA project-specific supplement.” (Proposed Order, p. 41.) Similarly, the response to Comment 5m states that “Stockton has not identified the minor modifications that it would need to complete to use Application 30531B water, nor has Stockton offered a construction timeline for completion of these modifications.” (Proposed Order, p. 49.) See the City’s responses, above. The City would make these modifications in advance of needing to divert and treat more than 30 mgd.
Treatment of more than 30 mgd would be needed in 2035 once the combined total volume of Permit 21176 water and WID water exceed 33,600 af/yr and SEWD supplies are no longer available. Design, permitting and construction of additional diversion2 and treatment facilities would require approximately three years, and CEQA would need to begin in advance of detailed design; therefore, CEQA and subsequent water rights proceedings under Application 30531B would need to realistically start no later than 2027.3
The AHO faults the City for failing to timely develop a schedule to respond to the “worst case scenario” of the City’s Stockton East Water District (SEWD) contract water supply no longer being available after 2035. (Proposed Order, p. 29.). It was on May 12, 2021, that the City learned that SEWD does not plan to serve the City beyond 2035. SEWD confirmed this assumption when it adopted its Urban Water Management Plan on June 8, 2021. The City noted that it would have had almost no time to develop a construction schedule in light of this circumstance. (See City Comment Letter, p. 7.) In response, the AHO stated that the City’s assertion that it did not have enough time to develop a construction schedule before the hearing is unconvincing. (Proposed Order, p. 46.) For this hearing, the AHO required parties to submit testimony by October 8, 2021, and held the hearing on
2 Additional pumping capacity would be included in the expansion facilities along with the treatment facilities. 3 This assumes that a CEQA analysis would be necessary and that an exemption would not apply for modifications to existing facilities (Cal. Code Regs., tit. 14, § 15301). Further, the State Water Board estimates that the processing time for new water right applications can take 5-7 years from the date an application is submitted. (https://www.waterboards.ca.gov/waterrights/water issues/programs/applications/.) ATTACHMENT 2
E. Joaquin Esquivel, Chair
State Water Resources Control Board
Re: City of Stockton Pending Application 30531B
August 3, 2022
November 9, 2021, which provided the City approximately 4-5 months after confirming this assumption. To assess the necessary modifications to the pumping capacity and DWTP, and identify a specific construction schedule that accounts for any necessary environmental review and permitting, the City needs at least 12 months to complete the necessary engineering and environmental effort to establish the project scope, budget, schedule, and CEQA effort.
With respect to the City’s projection that it may need A030531B water in 2050 if its contract with Woodbridge Irrigation District terminates, the AHO notes that such an assumption is inconsistent with the City’s assumption that it plans to double use of WID water starting in 2030. (Proposed Order, p. 31.) However, as Mr. Granberg explained, the WID contract expires in 2048, and so assuming this supply would no longer be available in 2050 is reasonable. (See Stockton-22 [WID Contract], § 3.) While the City may have adequate supply in 2050 to meet demand if it removes the BiOp and ITP restrictions and is able to pump 23,100 af/yr of groundwater, pumping this quantity of groundwater is not a certainty if the ESJGA decides there is a need to further limit groundwater pumping to ensure basin sustainability. The Department of Water Resources recently found that the ESJGA’s groundwater sustainability plan is incomplete, and thus there is substantial uncertainty about the City’s ability to rely on groundwater.4
As shown in Table 1 of Stockton-02, with a
reduction to groundwater pumping at 10% of demand, A030531B water would still be necessary in 2050 even if the City were able to pump the maximum of 33,600 af/yr under Permit 21176.
As discussed above, the City’s construction efforts distinguish it from the applicants in the decisions cited by the AHO in support of its proposed denial of A030531B. In Decision 884, the State Water Board denied the applications, in part, because the applicant had only provided a “highly indefinite and speculative” construction schedule based on the future need for the water. (Decision 884, pp. 72-73, 85-86, 95.) In Decision 1083, the State Water Board denied the applications at issue because the applicant had not specified, and the State Water Board could not specify based on the record, an estimate of the date that the applicant would begin construction. (Decision 1083, pp. 4, 7.) With respect to Decision 893, the AHO highlights the denial of a group of applications with facts distinct from A030531B. Notably, the State Water Board denied the Sacramento Municipal Utility District’s (SMUD) application because SMUD did not intend to construct the necessary reservoirs to perfect the water right, but rather planned to wait until a federal or state agency constructed them, and the record contained no indication as to when these agencies would commence construction. (Decision 893, pp. 56-57.) The AHO also highlights the denial of 12 other applications where the State Water Board found the applicants were “evidently unable or indisposed to proceed with development … at the present time.” (Id. at p. 58.) However, these applicants had
4 file:///C:/Users/aferguson/Downloads/EasternSanJoaquin Subbasin GSP2022 Determination.pdf ATTACHMENT 2
E. Joaquin Esquivel, Chair
State Water Resources Control Board
Re: City of Stockton Pending Application 30531B
August 3, 2022
apparently filed their applications, in part, to hold the priority date in case the contemplated supplemental applications by the state were not filed. (Id. at pp. 58-59.) In contrast to the applicants in Decisions 884 and 1083, the City has initiated construction and provided an estimate of its construction schedule for additional facilities by identifying a start date prior to the date it has projected that it needs water under A030531B.
Further, unlike SMUD’s application in Decision 893, the City plans to construct the necessary facilities to divert and use water under A030531B. Also, the City has not filed a placeholder application as an alternative to a state-filed application.
2. The City will construct additional facilities prior to realizing demand for A030531B water.
The Proposed Order further states that, “Section 840 requires the applicant to show, prospectively, that it is ‘ready, willing, and able’ to begin construction ‘within a reasonable time after receiving a permit.’ (Decision 1083 (1962), p. 6.) Dr. Lytle stated during the hearing that this project is ‘ready to go.’ ([HR] at 38:38-38:49.) But it is difficult to believe no construction would be needed to use Application 30531B water in 2035 or 2050.” (Proposed Order, p. 32.) The testimony of Dr. Lytle and the City’s other evidence (discussed above) clarify that, with the exception of additional pumping capacity at the intake station and additional settling basins and membrane filtration at the DWTP (HR 37:07-37:44; 56:17- 57:01), all facilities necessary to divert and use an initial increment of water under A30531B have been constructed. Design and construction of pumping and treatment capacity to reach the full 60 mgd operation could take approximately 2-3 years with CEQA and water rights proceedings adding additional years on the project timeline, indicating the City needs to begin this effort as early as 2027.
The City’s projection that it could use up to 845 af/yr in 2035 under a permit issued on A030531B, assuming SEWD water is no longer available in 2035 and the City limits groundwater pumping to 10% of demand, is reasonable. (See Proposed Order, p. 30.) Again, SEWD assumes that, as of 2035, it will not deliver water to the City under the Second Amended Contract. (Stockton-02, ¶ 9.) Given SEWD’s assumption it will not serve the City beyond 2035, it is reasonable for the City to make contingency plans for the loss of this supply. Further, the City’s assumption that it may limit groundwater production to 10% of demand is reasonable based on the critical condition of overdraft that exists in the Eastern San Joaquin Groundwater Subbasin. (See Stockton-02, ¶14.) The City is a member of the ESJGA, which is the entity that has prepared and will implement the Eastern San Joaquin Groundwater Sustainability Plan (ESJGSP) for the Eastern San Joaquin Subbasin to comply with the Sustainable Groundwater Management Act. The ESJGSP (Stockton-17) identifies overdraft of approximately 78,000 af/yr in the basin. (Id., pp. ES-6, 6-1.) Drastic action may be necessary to address this overdraft condition, and members such as the City may need to ATTACHMENT 2
E. Joaquin Esquivel, Chair
State Water Resources Control Board
Re: City of Stockton Pending Application 30531B
August 3, 2022
reduce pumping and increase surface water use to meet the basin’s sustainability target by the year 2040.
The Proposed Order states that “the City argued in its closing brief that the City’s projections for water use in 2035 or 2050 do not reflect “’the estimated 5,100 af/yr in potential demand for groundwater recharge.’” (Proposed Order, p. 30.) It further states that the City “offered no evidence of specific plans for how Application 30531B surface water would help meet this demand for groundwater recharge.” (Proposed Order, p. 30.) In fact, the City’s comments on the Draft Order stated that the 5,100 af/yr should be included as an additional demand line item in Table 1 of Stockton-02, thereby creating a demand for Delta water sooner than projected in Table 1. For example, by adding 5,100 af/yr to the “Demand” row, the totals in the row labeled “30531B Needed – Groundwater Limited to 10% of Demand” would increase by 5,100 af/yr. By doing so, the City would exceed the 33,600 af/yr diversion limit on Permit 21176 between 2035 and 2040 (assuming the City could remove the current BiOp and ITP pumping restrictions). Further, the City’s petition for extension of time explains that it has conducted initial recharge analyses. (Stockton-14, p. 9.) Additionally, Dr. Lytle explained that the City owns land at its DWTP that can be used for groundwater recharge, and the City is proceeding with hydrogeologic investigations to support this groundwater recharge effort. (HR at 1:12:24-1:16:42.) At the hearing, Dr. Lytle stated that the City will soon release a request for proposals to evaluate the capability of its proposed recharge sites in 2022 and anticipates receiving a $2 million state grant for this work. (HR at 1:15:25-1:16:47.) The City has since confirmed that it will receive $2 million of a $6.5 million in Integrated Regional Water Management (IRWM) grant program funds that have been allocated to the Greater San Joaquin IRWM funding area. The North San Joaquin Water Conservation District and San Joaquin County will receive $2 million and $1.5 million, respectively, of the regional IRWM grant. The City will soon be submitting its IRWM grant application, which is due by the end of August 2022; the funding is assured because the regional allocations are non-competitive. The funding is required to be spent by 2026. The recharge basin hydrogeologic investigation is now underway, and Geosyntec Inc., the contractor, is currently onsite at the DWTP. The project cost is $583,000 and should be completed by next spring. The City also was approved for $300,000 in SGMA Round 1 funds as part of the ESJGA’s $7.6 million grant application in addition to the $2 million it will receive under the IRWM program.
While ESJGSP Project 20 was written generally to describe potential recharge projects, this general description should not be used as evidence that the City’s potential recharge project is theoretical. As discussed above, the City’s petition for extension of time and Dr. Lytle’s testimony are evidence that it is not. 5
In the Revised ESJGSP recently adopted by the ESJGA,
the City’s groundwater recharge project was updated to a Category A Project (i.e., a project that
5 Further, the Proposed Order notes that the City has not indicated what facilities would be constructed for groundwater recharge or when the facilities would be needed. (Proposed Order, p. 30.) The City is, necessarily, first investigating the potential for the groundwater basin to accommodate recharge at the DWTP. Once the recharge capability is better understood, the City can identify any facilities it will need.
ATTACHMENT 2
E. Joaquin Esquivel, Chair
State Water Resources Control Board
Re: City of Stockton Pending Application 30531B
August 3, 2022
is likely to advance in the next five years and has existing water rights or agreements). (See attached Tech. Memo No. 1 Pg 3-6, Table 1, without appendices.) B. Given the State Water Board’s Water Right Application Processing Timeline and Necessary Lead Time for Construction of Additional Facilities, It Would Be Inefficient to Deny the City’s Application
The Proposed Order emphasizes the City’s ability to file a new application when it is ready to provide a construction schedule and CEQA documentation, and to start diverting and beneficially using the water. (Proposed Order, p. 43-44.) As noted above, however, that the State Water Board estimates that the processing time for new water right applications can take 5-7 years from the date an application is submitted.
(https://www.waterboards.ca.gov/waterrights/water issues/programs/applications/.) If the City needs water under A030531B in 2035, it would need to file an application at least 5-7 years prior, in order to provide time for issuance of a permit and construction of the additional facilities. It would be inefficient to cancel this application, just to have the City turn around and file a new application in a few years.
C. Payment of the State Water Board’s Application Fee for a New Water Right Application Would Present a Severe Financial Hardship for the City As noted by Dr. Lytle, the City has paid approximately $82,000 in water rights fees to the State Water Board since the year 2005 to maintain A030531B. (Stockton-20 [Water Right Fees Paid table].) This amount of money would be lost if the State Water Board denies and/or cancels A030531B. Further, if the City were to file a new water right application today for the City’s proposed reduced amount of 33,600 af/yr, the one-time application fee would be $504,850 ($1,000 + $15/AF greater than 10 AF.) That is a severe financial hardship, and certainly prejudicial. Recently, at the hearing denying the County of San Joaquin’s application for American River water, State Water Board Members acknowledged the potential significant financial hardship associated with having to pay substantial fees to file a new application on top of the fees already paid to maintain the existing application. The State Water Board appeared willing to investigate solutions within its authority to mitigate this financial hardship. If the State Water Board decides to deny/cancel A030531B, the City requests the same consideration
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ATTACHMENT 2
E. Joaquin Esquivel, Chair
State Water Resources Control Board
Re: City of Stockton Pending Application 30531B
August 3, 2022
D. Conclusion
The City requests that the State Water Board reject the AHO’s Proposed Order and maintain A030531B with a reduced maximum allowable diversion volume of 33,600 acre-feet per year (af/yr).
SOMACH SIMMONS & DUNN
A Professional Corporation
By_________________________________
Aaron A. Ferguson
Attorney
ATTACHMENT 2
SERVICE LIST
Department of Water Resources (DWR)
Erick D. Soderlund
Department of Water Resources
1416 Ninth Street
Sacramento, CA 95814
[email protected]
Attorney for Department of Water
Resources
Thomas L. Hanson
Department of Water Resources (DWR)
P.O. Box 942836
Sacramento, CA 94236-0001
Bureau of Reclamation (Reclamation)
Lisa M. Holm
2800 Cottage Way CGB-440
Sacramento, CA 95825
[email protected]
Attorney for Bureau of Reclamation
Bureau of Reclamation
Robert F. Stackhouse
2800 Cottage Way CGB-440
Sacramento, CA 95825
Stockton East Water District
PO BOX 5157
Stockton, CA 95205
[email protected]
Jeanne Zolezzi
Herum\Crabtree \Suntag
5757 Pacific Avenue, Suite 222
Stockton, CA 95207
[email protected]
Attorney for Stockton East Water
District
Gary W. Sawyers
Law Offices of Gary W. Sawyers
575 East Alluvial Ave., Suite 101
Fresno, CA 93720
Attorney for San Joaquin River Group
Authority
Oakdale Irrigation District
San Joaquin Irrigation District
Modesto Irrigation District
Turlock Irrigation District
Merced Irrigation District
San Joaquin River Exchange
Contractors Water Authority
Friant Water Users Authority
Gary W. Sawyers
Sullivan McGregor & Doerr LLP
5200 N. Palm Ave, Suite 404 Fresno CA
93704
[email protected]
Attorney (in 1998) for San Joaquin River
Group Authority
Oakdale Irrigation District
San Joaquin Irrigation District
Modesto Irrigation District
Turlock Irrigation District
Merced Irrigation District
San Joaquin River Exchange
Contractors Water Authority
Friant Water Users Authority
Lucinda Shih
Water Resources Manager
Contra Costa Water District
P.O. Box H20
Concord, CA 94524
[email protected]
Douglas E. Coty
Bold, Polisner, Maddow, Nelson &
Judson
2125 Oak Grove Rd, Suite 210
Walnut Creek, CA 94598
[email protected]
Attorney for Contra Costa Water District
ATTACHMENT 2
Jon D. Rubin
Westlands Water District
P.O Box 6056
Fresno, Ca 93703
400 Capitol Mall, 28th Fl,
Sacramento, CA 95814
[email protected]
Attorney for Westlands Water District
Rebecca Akroyd
San Luis & Delta-Mendota Water
Authority
1331 Garden Highway, 2nd Floor
Sacramento, CA 95833
[email protected]
Attorney for San Luis and DeltaMendota Water Authority Robert Granberg
2324 Jonathan Court
Escalon, CA 95320
[email protected]
Mel Lytle
Municipal Utilities Department
City of Stockton
11373 N. Lower Sacramento Road
Lodi, CA 95242
[email protected]
Kelley M. Taber
Somach Simmons & Dunn
500 Capitol Mall, Suite 1000
Sacramento, CA 95814
[email protected]
Attorney for City of Stockton
Aaron Ferguson
Somach Simmons & Dunn
500 Capitol Mall, Suite 1000
Sacramento, CA 95814
[email protected]
Attorney for City of Stockton
Lori Asuncion
Acting City Attorney
Office of the City Attorney
City of Stockton
425 N. El Dorado St, 2
nd Floor
Stockton, CA 95202-1951
[email protected]
ATTACHMENT 2