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Sjwc letter to water division 05 10-17
1. 50 California Street
34th Floor
San Francisco, CA 94111
T 415.398.3600
F 415.398.2438
Martin A. Mattes
D 415.438.7273
mmattes@nossaman.com
Refer To File #: 190640-0005
56053276.v2
May 10, 2017
Raminder S. Kahlon, Director
Water Division
California Public Utilities Commission
505 Van Ness Avenue
San Francisco, CA 94102
Re: Request of San Jose Water Company for Commission Review
of Water Divisionâs Rejection of Its Advice Letter No. 501
Dear Mr. Kahlon:
San Jose Water Company (âSJWCâ) filed its Advice Letter No. (âALâ) 501 on
January 9, 2017, as a Tier 2 advice letter requesting authorization, pursuant to the
Commissionâs Decision (âD.â) 16-12-026, Ordering Paragraph 3, to implement a Sales
Reconciliation Mechanism (âSRMâ) to conform water forecasts authorized in its last General
Rate Case (âGRCâ) to recorded consumption for the period October 2015 through September
2016. AL 501 requested that the submitted rate changes become effective March 15, 2017.
Water Division suspended AL 501 prior to its effective date, stating that the AL was
not in compliance with a Commission decision but also that âD.16-12-026 has to be
modified.â On April 6, 2017, the Commission adopted D.17-04-002, correcting errors in
D.16-12-026. The Commission noted in D.17-04-002 that Water Divisionâs review of AL 501
had identified an error in D.16-12-026âs description of the SRM by the use of the word
ârevenueâ rather than âsales,â and so the April decision replaced references to ârevenuesâ in
the context of the SRM with references to âsalesâ at several points in the text and also in
Ordering Paragraph 3. By your letter of May 3, 2017, Water Division now rejects AL 501,
based on a reading of D.16-12-026 as âspecifically requir[ing] that there exist a declared
drought.â
A. SJWC Requests Commission Review of Water Divisionâs Rejection of AL 501.
By this letter, submitted in accordance with Section 7.7.1 of General Order No. (âGOâ)
96-B, SJWC respectfully requests Commission review of Water Divisionâs disposition of AL
501. In the paragraphs below, SJWC sets forth the specific grounds on which SJWC
contends that Water Divisionâs action is unlawful and erroneous. Those grounds may be
summarized as follows:
VIA ELECTRONIC MAIL & U.S. MAIL
2. Raminder S. Kahlon, Director
May 10, 2017
Page 2
56053276.v2
ďˇ Water Division engaged in an unlawful discretionary review of AL 501.
To provide such a review, Water Division should have prepared a
resolution for the Commissionâs consideration.
ďˇ Water Division fails to apply the clear wording of D.16-12-026, Ordering
Paragraph 3, which unambiguously authorizes SJWC to request an SRM
by Tier 2 advice letter under the circumstances on which SJWCâs request
was based.
ďˇ Water Division erroneously relies on the text of D.16-12-026, which is
completely consistent with Ordering Paragraph 3, to reach a conclusion
inconsistent with the clear wording of that ordering paragraph.
ďˇ Water Division fails to consider the Commissionâs policy discussion in
D.16-12-026, which supports authorization of an SRM to mitigate a
mismatch between authorized and actual sales during a drought year
regardless of whether the drought has ended.
ďˇ Water Division fails to consider the various state policies and initiatives
intended to make water conservation a California way of life, or the
complementary local conservation requirements, which can be expected
to prolong the mismatch between SJWCâs authorized and actual sales
absent allowance of an SRM.
B. AL 501 Anticipated the Corrected Requirements of D.16-12-026.
In drafting AL 501, SJWC anticipated the correction to D.16-12-026 that the
Commission made by D.17-04-002. Thus, AL 501 compared the sales forecast of 49,861
Kccf1 authorized in its most recent GRC decision, D.16-06-004, with SJWCâs total actual
sales of 40,173 Kccf during the 12-month period of October 1, 2015 through September 30,
2016, noting that this total divergence of 19.4% exceeded the five percent trigger authorized
in D.16-06-004. Per the authorized SRM, SJWC recalculated rates to account for 50% of the
divergence between authorized and actual sales, resulting in increased quantity rates and a
3.65% increase in the typical residential customer bill.
Water Division found no fault with any aspect of AL 501 except the alleged
dependence of Ordering Paragraph 3 of D.16-12-026 on the existence of a âdeclared
drought.â As noted above, Water Divisionâs reading of D.16-12-026 and especially of
Ordering Paragraph 3 is incorrect. This letter will explain why.
1 âKccfâ stands for one thousand one-hundred cubic feet.
3. Raminder S. Kahlon, Director
May 10, 2017
Page 3
56053276.v2
C. AL 501 Meets the Requirements of Ordering Paragraph 3 but Water Division
Invents an Additional Requirement to Deny the Requested SRM.
Ordering Paragraph 3 of D.16-12-026, as corrected by D.17-04-002, reads as follows:
Class A and B Water Investor-Owned Utilities that have a five percent or greater
divergence (higher or lower) between authorized and actual sales during a
drought period in their current General Rate Case cycle, shall consider filing for
an individual district or several districts a Tier 2 Advice Letter requesting a Sales
Reconciliation Mechanism to conform water forecasts authorized in the current
General Rate Case to actual consumption, in light of the drought and
circumstances faced in their district(s).
Based on the clear wording of Ordering Paragraph 3, SJWC was authorized to file AL
501. SJWC, a Class A water utility, had a divergence greater than five percent (actually
19.4%) between authorized and actual sales during the 12-month period from October 2015
through September 2016.2 That 12-month period occurred during the Drought State of
Emergency declared by Governor Brown on January 17, 2014, which was subsequently
terminated for all except four counties in the state by the Governorâs Executive Order B-40-
17, issued April 7, 2017. Accordingly, SJWC properly filed AL 501 as a Tier 2 advice letter to
implement an SRM âin light of the drought and circumstances faced in [its district].â
Despite identifying no ambiguity in Ordering Paragraph 3, Water Division finds that it
must âinterpretâ the ordering paragraph by consulting the text of D.16-12-026. Water Division
discovers that page 6 of the decision authorizes an SRM advice letter to be filed only âduring
a drought period.â That is the same phrase used in Ordering Paragraph 3, so it does not
help to âinterpretâ it. Water Division then refers to page 33 of the decision, which states that
an SRM filing may be made âduring declared drought yearsâ â which seems entirely
consistent with the âduring a drought periodâ reference and leads Water Division to conclude
that âthere must exist a drought in order to make an SRM advice letter filing.â And so there
was when SJWC filed the SRM request on January 9, 2017 â the very same drought that
Governor Brown declared in 2014 and did not declare terminated (in 48 of 52 counties) until
April 7, 2017.
Having exhausted its references to the text of D.16-12-026, Water Division goes on to
state the obvious â that the drought was declared over before AL 501 was, belatedly, acted
upon. Noting that Santa Clara Valley Water District continues to call for 20% water
conservation (which Water Division inaccurately describes as âvoluntaryâ), Water Division
dismisses this âcall for conservationâ as not relevant to the âintent or plain language of D.16-
12-026 requiring âthat there exist a declared drought.â Water Division then notes that SJWC
has requested authority to suspend the drought allocations and surcharges in its Schedule
14.1 (but not the Schedule itself) and on that basis concludes that âSJWC neither has the
drought conditions, nor the need to implement drought allocations that would require an SRM
adjustment for 2017.â
2 As SJWC explained in AL 501, rate changes due to triggering an SRM are typically made
concurrently with escalation rate increases, so usage for the prior 12-month period through
September is applied to determine divergence from authorized sales.
4. Raminder S. Kahlon, Director
May 10, 2017
Page 4
56053276.v2
D. Water Divisionâs Rejection of AL 501 Based on a Convoluted Interpretation of
D.16-12-026 Amounts to an Improper Discretionary Review.
Water Divisionâs conclusion that an SRM cannot be required absent drought
conditions and drought allocations, and the consequent rejection of AL 501, are based on
misinterpretation of D.16-12-026 and an incomplete and inaccurate understanding of the
relevant facts. SJWC will correct these errors in the paragraphs that follow, but first must
state emphatically that Water Division has no authority or discretion to reject a Tier 2 advice
letter based on the sort of analysis your letter presents. Water Division is authorized to reject
a Tier 2 advice letter only when such action is ministerial in nature.3 Whenever a more
discretionary determination is required, the appropriate procedure is for Water Division to
prepare and place on the Commissionâs meeting agenda a resolution approving, rejecting, or
modifying the advice letter as submitted â giving affected parties opportunity to comment on
the proposed disposition in advance.4 Water Divisionâs rejection of AL 401 based on a
convoluted interpretation of the plain language of D.16-12-026, Ordering Paragraph 3, is
certainly more than a ministerial act. Water Division should have prepared a resolution to
permit the Commission to interpret, for itself, whether use of the SRM mechanism, which it
had so recently authorized should now, suddenly, be forbidden.
E. Not Only the Express Terms of Ordering Paragraph 3 but Also the Relevant
Policy Discussion in D.16-12-026 Justify Approving SJWCâs Request for an
SRM.
SJWC was justified in filing AL 501 to establish an SRM not only by the express terms
of D.16-12-026, Ordering Paragraph 3, but also by the policy considerations on which that
ordering paragraph was based. Despite the subsequent official end to the drought, those
policy considerations continue to justify approving AL 501 and allowing SJWC to implement
an SRM.
D.16-12-026 prominently recognized not only the Governorâs declaration of a Drought
State of Emergency in 2014 but also his then most recent Executive Order B-37-16, issued
May 9, 2016, which aimed âto make conservation a way of life in California,â and went on to
describe the actions of the Commission and also the State Water Resources Control Board
(âWater Boardâ) intending to âbuild on the 25 percent water reduction levels imposed by
previous Executive Orders, and reflect lessons learned during the drought.â5 D.16-12-016
also prominently featured the Commissionâs concern about inaccurate sales forecasts,
emphasizing that â[i]naccurate forecasts provide the air that balloons the WRAM and
surcharges,â and providing for utilities to request SRMs âto conform water forecasts
authorized in the GRC to actual consumption in light of the circumstances faced in their
districts.â6
3 See, GO 96-B, §7.6.1.
4 Id., §7.6.2; see also, Rule 14.5 of the Commissionâs Rules of Practice and Procedure.
5 D.16-12-026, at 4-5.
6 Id. at 6.
5. Raminder S. Kahlon, Director
May 10, 2017
Page 5
56053276.v2
Looking beyond these summary declarations to the details of D.16-12-026âs analysis,
we find confirmation that this âDecision Providing Guidanceâ was intended to set a path
forward not just for the duration of the current drought but for the longer-term future. The
Decisionâs discussion of âForecasting and SRMâ recognized that traditional forecasting
methods did not adequately capture either recent drought conservation effects or expected
changes in water consumption resulting from the Governorâs Executive Orders and the
Commissionâs actions. The Decision especially noted the Governorâs direction to the
Department of Water Resources (âDWRâ) to develop new water use targets as part of a
permanent framework for water agencies, and âthe steps that many California water
agencies are taking to promote and mandate conservation.â7 Noting concern about
âmismatchesâ between authorized revenue and actual sales, the Decision saw need for
action âto better alignâ forecasted and recorded sales.â That action was to order water
utilities with a five percent or greater divergence between authorized and actual revenue
(later corrected to refer to âsalesâ) during declared drought years in their current GRC cycle
to consider filing for an SRM, which would recalculate rates âthrough the remainder of the
GRC cycle.â8
Conclusion of Law 3 summarized the Commissionâs reasoning:
3. Authorizing Class A and B utilities to consider filing a Tier 2 Advice letter to
implement a drought SRM is consistent with this Commissionâs resolution to
promote conservation, our policies to communicate transparent cost-signals to
ratepayers, and Pub. Util. Code §701.10.9
In summary, D.16-12-026 did not envision the SRM solely as a response to the
drought. First and foremost, the Commission saw the SRM as a means of addressing the
mismatch between authorized revenue and sales that resulted from inaccurate sales
forecasts in the context of continuing success in water conservation. Those policy
considerations justified SJWCâs filing of AL 501 to establish an SRM and they continue to
justify approving AL 501 today, whether or not the drought continues. Given the
Commissionâs evident interest in the SRM as a means of addressing âmismatches between
authorized revenue and sales,â continuation of the drought is not necessary to justify
implementing an SRM, where the mandated five percent âdivergenceâ already has occurred.
F. Many Factors of Statewide and Local Policy and Practice Support an
Expectation of a Continuing Mismatch Between SJWCâs Adopted and Actual
Sales.
In SJWCâs case, the âmismatch between authorized revenue and salesâ was not just
five percent, but 19.4% in the drought year on which AL 501âs SRM request was based.
Absent the requested SRM, that 19.4% âmismatchâ may increase or decrease through the
last two years of SJWCâs current GRC cycle, but it certainly will not disappear. Several
7 Id. at 28-30.
8 Id. at 33-34.
9 Id. at 83.
6. Raminder S. Kahlon, Director
May 10, 2017
Page 6
56053276.v2
relevant factors suggest that SJWCâs sales will remain substantially below the level forecast
in its most recent GRC:
ďˇ Governor Brownâs most recent Executive Order B-40-17, while rescinding his
2014 Drought Proclamation, also ordered that âthe orders and provisions of
Executive Order B-37-16, Making Water Conservation a California Way of
Life, remain in full force and effect except as modified by this Executive Order.â
ďˇ Executive Order B-40-17 expressly directed the Water Board to âcontinue
development of permanent prohibitions on wasteful water use and requirements
for reporting water use by urban water agencies.â
ďˇ Executive Order B-40-17 also directed DWR to continue work with the Water
Board to develop standard for urban water suppliers to use in setting new urban
water use efficiency targets and to direct actions to minimize water system leaks
that waste large amounts of water.
ďˇ On April 7, 2017, the same day the Governor rescinded his Drought Proclamation,
th Commission, DWR, the Water Board, and two other California executive
agencies issued their final report, Making Water Conservation a California Way of
Life, implementing Executive Order B-37-16, providing an array of
ârecommendations for how to implement long-term improvements to water supply
management that support water conservation.â
ďˇ Santa Clara Valley Water District has maintained its call for a water use reduction
target equal to 20% of 2013 water use, for restriction of outdoor watering of
ornamental landscapes or lawns with potable water, and for local enforcement of
the Water Boardâs prohibitions of wasteful water use.10 Contrary to Water
Divisionâs assertion, the District has not described these restrictions as
âvoluntary.â
ďˇ SJWCâs Rule 14.1 and Schedule 14.1, providing for water shortage contingency
plans, remain in effect. Rule 14.1 continues to prohibit wasteful water use
practices. As Water Division notes, SJWC filed its AL 505 in January 2017 to
suspend Schedule 14.1âs drought allocations and drought surcharges, but
Schedule 14.1 and all of the water use restrictions defined therein remain in
effect.
Based on all these factors, it would be inconsistent and unwise for the Commission
now to disown and abandon the procedure that it so recently adopted in D.16-12-026 for
allowing utilities that have experienced a significant mismatch between authorized and actual
sales during a drought year, based on their most recent GRC decisions, to implement an
SRM that will ameliorate that mismatch and help to achieve more appropriate price signals to
customers. Official termination of the drought does not justify reversing that policy, since
such a reversal would run counter to local and state conservation objectives.
10 See, Santa Clara Valley Water District Resolution No. 17-08, adopted January 31, 2017.
7. Raminder S. Kahlon, Director
May 10, 2017
Page 7
56053276.v2
G. Conclusion
D.16-12-026, as corrected by D.17-04-002, included as a condition for requesting an
SRM that a water utility have a divergence of five percent or more between authorized and
actual sales âduring a drought periodâ in its current GRC cycle. As discussed above, SJWC
met that condition during the relevant 12-month period and also when it filed AL 501. None
of Water Divisionâs âinterpretationsâ of Ordering Paragraph 3 justify transforming that
condition into a requirement that the drought continue into the âremainder of the GRC cycleâ
when the SRM would be in effect. To the contrary, the policies the Commission articulated in
D.16-12-026 as its reasons for authorizing the SRM argue strongly against imposing such an
added requirement.
For all the reasons stated in this letter, SJWC respectfully urges the Commission,
upon review, to reverse Water Divisionâs rejection of AL 501 and, instead, to approve the
advice letter as proposed.
Respectfully submitted,
Martin A. Mattes
of Nossaman LLP
Attorneys for SAN JOSE WATER
COMPANY
MAM:mt
cc: Protesting Parties (see attached Service List)
10. Page 3 of 5
SERVICE LIST BY U.S. MAIL
Kathy Cleary
20645 Montalvo Heights Drive
Saratoga, CA 95070
Armando Lopez, Jr.
376 Jerome Street
San Jose, CA 95125
Yakoub Bellawala
1440 Harriet Avenue
Campbell, CA 95008
Dolores Cunha
620 Kenneth Avenue
Campbell, CA 95008
W. Higginson
487 Skall Drive
San Jose, CA 95111
Ulysses Sambajon
10587 Franklin Boulevard
Elk Grove, CA 95757
Floyd Okada
14085 Taos Drive
Saratoga, CA 95070
Don and Vera Reed
6067 Pietz Court
San Jose, CA 95123
Cynthia Ryan Francis
1652 Naglee Avenue
San Jose, CA 95126
William Nevis
126 Fox Avenue
San Jose, CA 95110
Thomas Valdez, Jr.
1343 Mich Bluff Drive
San Jose, CA 95131
Laura Schneider
638 Auzerais Avenue
San Jose, CA 95126
Benton Hooper
1881 Ensendada Drive
Campbell, CA 95008
Nellie Jenks
6106 Iowa Drive
San Jose, CA 95123
Mary E. Keifer
1362 Hillcrest Court
San Jose, CA 95120
Dr. Gerald Bittner, Jr.
14309 Chester Avenue
Saratoga, CA 95070
Anita Gable
1363 Winona Drive
San Jose, CA 95125
William and Macy Ip
12921 Brandywine Drive
Saratoga, CA 95070
Laurie Stapleton
10395 Moretti Drive
Cupertino, CA 95014
David Shade
16615 Englewood Avenue
Los Gatos, CA 95032
Kitrick E. Whitney
735 Carlotta Court
San Jose, CA 95136
Michael Jenks
1584 Keesling Avenue
San Jose, CA 95125
Catherine Comer
1494 Cherry Valley Drive
San Jose, CA 95125
Ivan and Jeanette Aladjoff
112 Belwood Lane
Los Gatos, CA 95032
Dolores T. Kloss
20031 Somerset Drive
Cupertino, CA 95014
Beth Keifer
1873 Huxley Court
San Jose, CA 95125
Yelena Yakirina
1200 Valley Quail Circle
San Jose, CA 95120
Dorothy A. Brown
2350 Shade Tree Lane
San Jose, CA 95131
Philip J. Shanker
15949 Cerro Vista Court
Los Gatos, CA 95032
David H. Mowbray
1032 Empey Way
San Jose, CA 95128
Joseph and Deborah Isham
2196 Willester Avenue
San Jose, CA 95124
Seyed M. Sabahi
2205 Corktree Lane
San Jose, CA 95132
William and Mirella Auer
6077 Burnbank Place
San Jose, CA 95120
Larry and Vicky Toder
1858 Gunston Way
San Jose, CA 95124
Samuel A. Moiseff
6262 Paso Los Cerritos
San Jose, CA 95120
Margaret Jasper
20191 Bonnie Brae Way
Saratoga, CA 95070
Muthukumar Mudaliar
1413 Vallejo Drive
San Jose, CA 95130
Darline Lohman
1114 Virgil Place
San Jose, CA 95120
Katherine Jen
19431 San Marcos Road
Saratoga, CA 95070
Ron and Rhondda Leckie
18779 Kosich Drive
Saratoga, CA 95070
F.T. Comstock
15730 Oak Knoll Drive
Los Gatos, CA 95030
Sally and Dave Baum
1484 Pollard Road
Los Gatos, CA 95032
11. Page 4 of 5
Silvia Malley
5453 Muir Drive
San Jose, CA 95124
Rennis Kauffman
109 Treseder Court
Los Gatos, CA 95032
Pascuala Huerta
103 Loma Vista Court
Los Gatos, CA 95032
Hugh Reynolds
1622 Montrose Way
San Jose, CA 95124
Laura P. Bence
P.O. Box 3697
Los Altos, CA 95024
Kathy J. Smith
David A. Craig
5085 Capistrano Avenue
San Jose, CA 95129
Fred Luk
18021 Rose Court
Monte Sereno, CA 95030
Donna
814 Century Drive
Campbell, CA 95008
Jessie Villicana
716 Harrison Street
San Jose, CA 95125
Larry Fabian
18660 Vista De Almaden
San Jose, CA 95120
Qianfan Xu, Xiaojia Hou,
and Lexi Xu
6021 Calle De Felice
San Jose, CA 95124
Edward M. Pacheco
1426 Mt. Stanley Way
San Jose, CA 95127
Neil Knott
17150 Scott Drive
Monte Sereno, CA 95030
Edith and Blair Gallant
661 Cambrian Drive
Campbell, CA 95008
Christine Brum
1807 Kirklyn Drive
San Jose, CA 95124
Dina Sargis
6564 Northridge Drive
San Jose, CA 95120
Aileen Gulesserian
111 Vallecitos Way
Los Gatos, CA 95032
Bobbie Morrison
2300 Shibley Avenue
San Jose, CA 95125
Steven and Pat Moore
18971 Easton Place
Saratoga, CA 95070
Leigh Haldeman
1730 Santa Lucia Drive
San Jose, CA 95125
Ronald Franken
5304 McKee Road
San Jose, CA 95127
Michael S. Blodgett
70 Decker Way
San Jose, CA 95127
Raymond and Carol Copeland
1202 Chateau Drive
San Jose, CA 95120
Suzanne Regul
4667 Mossbrook Circle
San Jose, CA 95130
Angela Giacalone
1569 Cherry Glen Way
San Jose, CA 95125
Suzette Bromagem
1735 Wickham Court
San Jose, CA 95132
Mickey Starr
5419 Starcrest Drive
San Jose, CA 95123
Wendy Watkins
984 Willow Glen Way
San Jose, CA 95125
Vanessa and Clay Fiske
1524 Monteval Place
San Jose, CA 95120
Stanford and Pamela Atwood
16125 Greenwood Lane
Monte Sereno, CA 95030
Norvelle Benevento
821 Plaza Drive
San Jose, CA 95125
Gary Wiesehahn
1576 Sheffield Avenue
San Jose, CA 95125
Susan Eiguren
2530 Calma Court
San Jose, CA 95128
Linda M. Haro
54 Birch Lane
San Jose, CA 95127
Brad and Michelle Foote
1090 Holmes Avenue
Campbell, CA 95008
Karen Clark
4313 Faraday Drive
San Jose, CA 95124
Robert Antone
1752 El Codo Way
San Jose, CA 95124
Ed Saxon
1484 Elsman Court
San Jose, CA 95120
Nick Lamberti
1656 Sweetbriar Drive
San Jose, CA 95125
Dean R. Kwarta
Kathleen Stenberg
1829 Kirkland Drive
San Jose, CA 95125
George and Barbara Callisch
2929 Kring Drive
San Jose, CA 95125
Sharon and Wayne Wood
4160 Golf Drive
San Jose, CA 95127
Nathan T. Ballard
1171 Utopia Place
San Jose, CA 95127
Anne Zingale
725 Pershing Avenue
San Jose, CA 95126
12. Page 5 of 5
Scott Levene
125 Dillon Avenue
Campbell, CA 95008
R.A. and W. Guardino
1479 De Tracey Street
San Jose, CA 95128
Steve McArthur
1837 Kirkland Avenue
San Jose, CA 95125
Bea Sines
641 Rebecca Way
San Jose, CA 95117
Mark Warneke
14544 Berry Way
San Jose, CA 95124
Shirley Kong
3476 Ramstad Drive
San Jose, CA 95127
Alma Baillif
5840 Recife Way
San Jose, CA 95120
Khanh Cao
110 Drysdale Drive
Los Gatos, CA 95032
Tom and Cassandra Owen
3859 Via Montalvo
Campbell, CA 95008
David Schulze
1009 Mount Carmel Drive
San Jose, CA 95120
Gurcan and Sumru Aral
1040 November Drive
Cupertino, CA 95014
Nicola McAllister
15612 Kavin Lane
Monte Sereno, CA 95030
Ingrid Oakley-Girvan
260 El Cajon Way
Los Gatos, CA 95032
Josh Palmer
877 Almarida
Campbell, CA 95008
Sergio Villaverde
637 Soni Court
San Jose, CA 95116
Brenda and Thomas Dohmen
7016 Wooded Lake Drive
San Jose, CA 95120
Barbara G. Bacile
1088 Fleetwood Drive
San Jose, CA 95120
Sylvia O. Ortiz
3474 Cherry Avenue
San Jose, CA 95118
Rudy Crespo
3482 Crespo Drive
San Jose, CA 95118
Constantinos Bassias
6140 Cecala Drive
San Jose, CA 95120
Christine Brum
1807 Kirklyn Drive
San Jose, CA 95124
Brenda and Larry Mehringer
18709 Westview Drive
Saratoga, CA 95070
Krishraveni Meka
19170 Monte Vista Drive
Saratoga, CA 95070
Alex and Cherie Wheeler
1665 Cottle Avenue
San Jose, CA 95110
Kay Fontana
2143 Coastland Avenue
San Jose, CA 95125
Judy H. Lomas
19405 Bainter Avenue
Los Gatos, CA 95030
Fred Runco
1444 Cerro Verde
San Jose, CA 95120
Eva Runco
1444 Cerro Verde
San Jose, CA 95120
James Dutkiewicz
1511 Willowdale Drive
San Jose, CA 95118
Aileen Gulesserian
111 Vallecitos Way
Los Gatos, CA 95032
Michele & Gordon van Zuiden
17573 Eaton Lane
Monte Sereno, CA 95030
Rita Benton
18555 Ravenwood Drive
Saratoga, CA 95070
Laurie Lew-McCrigler
2436 Homewood Drive
San Jose, CA 95128
Ronald Moser
1577 Inverness Circle
San Jose, CA 95124
Mr. & Mrs. Joseph Shank
20756 Scenic Vista Drive
San Jose, CA 95120
Janice Hirata
866 Lincoln Court
San Jose, CA 95125
Lainey and Bruce Richardson
14801 Golf Links Drive
Los Gatos, CA 95032
Laura and Scott Kupor
18211 Bancroft Avenue
Monte Sereno, CA 95030
Alex and Carol Hanuska
804 Kenneth Avenue
Campbell, CA 95008