UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549-7010 DIVISION OF CORPORATION FINANCE Mail Stop 3561 February 27, 2008 Via U.S. Mail Peter C. Nelson President and CEO California Water Service Group 1720 North First Street San Jose, California 95112 Re: California Water Service Group Form 10-K for the Fiscal Year Ended December 31, 2006 Filed March 14, 2007 Forms 10-Q for the Quarters Ended March 31, 2007, June 30, 2007 and September 30, 2007 Definitive Schedule 14A Filed March 14, 2007 File No. 1-13883 Dear Mr. Nelson: We have completed our review of your Proxy Statement on Schedule 14A, Forms 10-K and 10-Q, and have no further comments at this time. Sincerely, H. Christopher Owings Assistant Director cc: Lynne McGee Fax: (408) 367-8430