June 25, 2018



Via Email

Eduardo Gallardo
Gibson, Dunn & Crutcher LLP
200 Park Avenue
New York, New York 10166

       Re:    SJW Group
              Schedule TO-T/A filed June 21, 2018
              Filed by California Water Service Group
              File No. 5-36500

Dear Mr. Gallardo:

       The Office of Mergers and Acquisitions has reviewed the amended filing
listed above.
Our comments follow. All defined terms have the same meaning as in the Offer to
Purchase
included as Exhibit (A)(1)(I) to the Schedule TO-T.

       Please respond to this letter by revising your Schedule TO-T, by
providing the requested
information, or by advising us when you will provide the requested response. If
you do not
believe our comments apply to your facts and circumstances or do not believe an
amendment is
appropriate, please tell us why in your response.

       After reviewing any amendment to your filing and the information you
provide in
response to these comments, we may have additional comments.

General

   1. Refer to comment 1 in our June 12, 2018 comment letter and your response,
including the
      changes you made in the revised tender offer materials in response to
that comment. For
      both the California Public Utility Commission and Public Utility
Commission of Texas
      approvals needed to consummate the Offer, you have noted in revised
disclosure that if
      anyone protests your acquisition or in the case of the Texas Commission,
if hearings are
      held, the time frame for approval could be or would likely be further
extended. As
      previously requested, include an estimate of the approximate timeframe
needed for
      regulatory review in the likely event (given the unsolicited nature of
your Offer) that SJW
      does not cooperate with or protests your applications. If there are
statutory maximum
      review periods with either the Texas or California regulatory bodies,
disclose those.
 Eduardo Gallardo, Esq.
Gibson Dunn & Crutcher LLP
June 25, 2018
Page 2


Withdrawal Rights, page 14

   2. Refer to comment 3 in our June 12, 2018 comment letter and your response.
As
      requested, please revise to explain the circumstances under which you
believe you could
      delay acceptance of or payment for accepted shares. In light of the
revisions to the tender
      offer materials made in response to comment 2 in which you state no
conditions will
      survive the expiration of the Offer, it is not apparent to us how or why
acceptance or
      payment could be delayed, consistent with the tender offer rules.

Source and Amount of Funds, page 22

   3. Refer to comments 4 and 5 in our June 12, 2018 comment letter. We believe
a
      reasonable period of time must remain in the Offer period after you enter
into the bridge
      loan facility, amend the Schedule TO to provide the required disclosure
under Item 1007
      about it, file the bridge loan agreement as an exhibit to the Schedule
TO, and disseminate
      this new information to SJW Group shareholders. See Rules 14d-3(b) and
14d-4(d)(1).
      In your response letter, tell us when you will file and how you will
disseminate this new
      information, with reference to the number of days the Offer will remain
open after you do
      so. We may have further comments.

Conditions to the Offer, page 29

   4. Refer to comment 8 in our June 12, 2018 comment letter. The changes you
made to the
      offer materials do not address the issue regarding the fact that as
drafted and as amended,
      a condition could be triggered by the actions or inactions of the bidder
in this Offer.
      Please revise.

Exhibit (a)(5)(ii)   Press Release dated June 15, 2018

   5. In future offer materials/proxy materials, avoid referencing the
Eversource Energy
      proposal to acquire Connecticut Water as an "unsolicited bid." That
language incorrectly
      implies that the proposal is a tender offer like your unsolicited Offer
to acquire SJW
      Group, when it is in fact something more preliminary.

   6. In future tender offer materials, avoid referencing the Private
Securities Litigation
      Reform Act of 1995 definition of forward-looking statements. The Reform
Act's safe
      harbor provisions do not extend to forward looking statements made in
connection with a
      tender offer.
 Eduardo Gallardo, Esq.
Gibson Dunn & Crutcher LLP
June 25, 2018
Page 3


        We remind you that the filing persons are responsible for the accuracy
and adequacy of
their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
Please contact me at (202) 551- 3263 with any questions about these comments.


                                                            Sincerely,


                                                            /s/ Christina Chalk


                                                            Christina Chalk
                                                            Senior Special
Counsel
                                                            Office of Mergers
and Acquisitions




cc:    Eduardo Gallardo, Esq. (via email)