Laserfiche WebLink
Mr. Mel Ehrlich <br />July 31, 1992 <br />Page 2 <br />legally required to assume, and are not willing to enter into a cost sharing with your clients <br />for any additional assessment and/or remediation work at this time. <br />With respect to Ultramar filing a joint application with your clients for cleanup <br />funds from the California Petroleum Underground Storage Tank Cleanup Fund ("CUST <br />Fund"), as the owners of contaminated property and as the 'owners of the underground <br />facilities which purportedly caused the contamination at issue, your clients are in a more <br />faro able position. if they file on their own behalf. 1i The !�CUST Fund implementing <br />regulations incorporate a prioritization scheme whichgives ;,first priority to claims from <br />owners of underground storage tanks who, like your clients, meet the definition of a small <br />business. See California Code of Regulations, Title 23, Chapter 18, §2804 and <br />2811.1(a)(2). Notwithstanding our above articulated position,"�we believe that the structure <br />of the CUST Fund's prioritization of claims behooves your client to individually pursue any <br />CUST Fund claim independent of UItramar. A joint filing could only reduce the priority <br />given to your clients' application and the likelihood of reimbursement. <br />If you have any questions, please feel free to contact me at your convenience. <br />O <br />1WP511ENVRNMN'I1 "W.LTR <br />07.05.09 <br />Sincerely, <br />I� - <br />Alan R. Waskin <br />Corporate Counsel <br />� a <br />iM <br />Ji <br />