Mobile Home Park Natural Gas and
Electric Infrastructure 


On February 25, 2011, in response to a petition by mobile home park owners, the CPUC opened a Rulemaking to explore issues concerning the transfer of electric and gas distribution systems in master metered mobile home parks to direct utility service. Information about the age of condition of the majority of such systems is scarce and some parties expressed concern that many park systems had outlived their useful life and required replacement. Funds for such replacements are provided to mobile home park owners through the master meter discount, however, some parties expressed concern that these funds have not been used as intended in many parks. The rulemaking was opened to substantiate claims about the condition of mobile home parks in California and to develop a new framework for conversion to direct utility service.

On July 17, 2013, the CPUC released its Second Amended Scoping Memo requesting stakeholders provide input to develop a proposal to convert ownership of natural gas and electric infrastructures of California’s mobile home parks to investor owned utility ownership, including consideration for:

  • A 3-year pilot program.
  • Program eligibility to be determined by CPUC’s Safety and Enforcement Division, with natural gas systems holding priority and with electric-only systems served on a first come basis should program space allow.
  • A comparison of costs for conversion up to the meter and conversion beyond the meter.
  • A ‘pledge’ on the part of Mobile Home Park owners to collect and contribute ratepayer funding (included in the master meter discount owners receive) currently allocated to subsidize infrastructure replacement to the costs of conversion.

Evidentiary hearings were held at the CPUC on September 9 and 10, 2013.


ORA Policy Position

ORA is very concerned with issues of safety for mobile home park residents, and urges the CPUC to hold accountable the owners of master metered mobile home parks for any unsafe conditions in their parks. ORA worked with Joint Parties (ORA, The Utility Reform Network, Edison, SoCalGas, SDG&E, Bear Valley Electric, PacifiCorp, and Liberty Utilities), who developed a proposal for a voluntary, 3-year pilot conversion program with full ratepayer funding up to the meter. Joint Parties believe that ratepayers should not fund conversions beyond the meter as it is not, and should not be, the role of utilities or their ratepayers to pay for improvements beyond the traditional service delivery point. Mobile home parks that are able to demonstrate safety concerns would be given priority for participation in the pilot.

ORA supports the majority of Joint parties’ proposal, while dissenting on the issue of funding. Ratepayers should not be responsible for fully funding conversion to the meter because ratepayers have already funded infrastructure replacement through the master meter discount. Ratepayers should not be asked to pay twice because mobile home park owners choose not to use the funding with which they have already been provided for its intended purpose.

As a compromise, ORA proposed a 50/50 cost sharing between ratepayers and mobile home park owners for the 3-year pilot period.

See ORA’s/Joint Parties' August 19, 2013 Opening Testimony.

See ORA’s/Joint Parties' August 30, 2013 Rebuttal Testimony.

See ORA’s/Joint Parties' October 8, 2013 Opening Brief.

See ORA’s/Joint Parties' October 18, 2013 Reply Brief.


Proceeding Status

A CPUC Proposed Decision is expected in early 2014.

See the Proceeding docket.