May 31, 2018


Martin A. Kropelnicki
Chief Executive Officer
California Water Service Group
1720 North First Street
San Jose, CA, 95112

       Re:    SJW Group
              DFAN14A filed May 14, 2018
              Response Dated May 24, 2018
              Filed by California Water Service Group
              File No. 001-08966

Dear Mr. Kropelnicki:

       We have reviewed your May 24, 2018 response to our comment letter, and
have the
following comments. In some of our comments, we may ask you to provide us with
information
so we may better understand your disclosure.

       Please respond to these comments within ten business days by providing
the requested
information or advise us as soon as possible when you will respond. If you do
not believe our
comments apply to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to these comments, we may have additional
comments.
Unless we note otherwise, our references to prior comments are to comments in
our May 22,
2018 letter.

DFAN14A filed May 14, 2018

   1. We note your response to comment 2, but are not persuaded by certain
aspects of your
      response. That is, we are not sure that the parties' cited statements
rule out future
      downward adjustments in customer rates as a result of the merger. In
future soliciting
      materials, please refrain from characterizing SJW's and CTWS' statements
that "there
      will be no changes to customer rates" as equating to "no savings will be
shared with
      customers." Alternatively, if you continue to assert that savings will
not be passed along
      to consumers, explain in the proxy materials how you arrived at this
conclusion from the
      parties' statements.
 Martin A. Kropelnicki
California Water Service Group
May 31, 2018
Page 2




       Please contact Katherine Bagley, Staff Attorney, at (202) 551-2545, Mara
Ransom,
Assistant Director, Office of Consumer Products, at (202) 551-3720, or me at
(202) 551- 3263
with any other questions.



                                                          Sincerely,

                                                          /s/ Christina Chalk

                                                          Christina Chalk
                                                          Senior Special
Counsel
                                                          Office of Mergers and
Acquisitions




cc:    Eduardo Gallardo, Esq. (via email)