Mobilehome Park Utility Upgrade Program Frequently Asked Questions

In 1997, Public Utilities Code §§ 2791-2799, established a statutory framework, Transfer of Facilities in Master-Metered Mobilehome Parks and Manufactured Housing Communities to Gas or Electric Corporation Ownership, for transferring such facilities to utilities that provide direct service where the park or community is located. However, because very few transfers have actually occurred since 1997, in 2014, the Commission initiated a voluntary three-year pilot program to transfer master-meter / submeter service to direct utility service. In 2017 the Commission began evaluating the Pilot Program to decide whether a new phase of the program would be established, and extended the Pilot program for continuity through the evaluation period. In 2019 the Commission decided to establish the MHP Utility Conversion Program which carries this program through 2030. The new Utility Conversion Program will accept new applicants to be prioritized with the parks on the exiting list.

The criteria for conversion of these systems focuses on safety first and then, on improvements in reliability and capacity. In an effort to improve the efficiencies, the program encourages joint trenching and conversion of both gas and electric systems in the entire park. Utilities, other than those providing gas and electric service, are encouraged to participate in the program to further improve efficiencies and potentially reduce overall program costs.

The MHP Utility Conversion Program applies only to mobilehome parks (MHP or MHPs) that have master-metered natural gas and/or electric systems that are sub-metered. MHPs that have both master-metered gas and electric systems (dual systems), but have no submeters on either of these systems, will NOT qualify for the MHP Utility Conversion Program.  However, MHPs with dual systems can still qualify if one of the MHP’s utility systems is sub-metered, even if the other system is not sub-metered. For example:  A master-metered electric system without submeters can be converted if the MHPs gas system, which has submeters, is selected for conversion, or vice-versa.

No other utility services provided by the MHP (i.e., water or sewage) are included for conversion through the MHP Utility Conversion Program. Moreover, no facilities owned by the MHP will be permitted to be placed in the same general trench containing the facilities of direct utility providers regulated by the CPUC. 

The MHP Utility Upgrade Program Pilot began on January 1, 2015 and will continue through July 1, 2020.

The second phase of the program, named the MHP Utility Conversion Program, will begin accepting Forms of Intent between January 1, 2021 and the end of the day on March 31, 2021.

No. Participation in the MHP Utility Conversion Program is voluntary. MHPs that chose to participate will do so through an application process that will include a completed CPUC Form of Intent (FOI) submitted by the MHP Owner/Operator to show interest and request to be included in the MHP Utility Conversion Program. Subsequently, if the MHP is included into the MHP Utility Conversion Program, the MHP Owner/Operator will need to complete and submit a more detailed formal application to the CPUC regulated gas and/or electric utility that serves the MHP. Please note that not all MHPs that submit the CPUC Form of Intent will have their system(s) converted through the MHP Utility Conversion Program (please see FAQ 11).  

In the third quarter of 2020, the CPUC will send Forms of intent to all master-meter gas operators within the CPUC’s database.  CPUC will also post the revised Form of Intent on the CPUC Website.  The CPUC is accepting completed Forms of Intent for the MHP Utility ConversionProgram Pilot starting on January 1, 2021 and the filing period closes at the end of the day on March 31, 2021. The CPUC’s Safety and Enforcement Division (SED) will prioritize MHPs for the upgrade program. Based primarily on the data contained in the CPUC Form of Intent and other factors, SED will place all eligable MHPs that apply and prioritize systems for conversion based on risk factors. In late June of 2021, the SED will notify the utilities with the prioiritized list and the utilities will start the communication process with their respective selected MHPs, provided contact representatives who could help clarify the utilities’ application and agreement process. Eventually, if the MHP meets necessary requirements and chooses to continue participating in the upgrade program, it is placed in a queue for construction work (please see FAQ 

 The SED continues to oversee the utilities’ efforts in all regards to the MHP Utility Conversion Program in order to ensure:

1. MHPs are able to make an informed decision about participating;
2. Difficulty, when applying for the program, is kept to a minimum and that the process and utility applications are uniform throughout California;
3. MHP Owner/Operators are able, with reasonable ease, to obtain answers to their questions regarding the application process, construction activities and schedules and whether the MHP is included into the MHP Utility Conversion Program.

Please note: Only MHPs that submit a CPUC Form of Intent during the period January 1, 2021 – March 31, 2021 are eligible to participate in the current MHP Utility Conversion Program.

All MHP owners/operators who wish to participate in the program will need to complete a new Form of Intent, even if they were accepted into the Pilot Program.  However, the owner/operators of parks who were accepted into the Pilot program will only need to fill out certain sections of the new Form of Intent so CPUC can have updated risk information.

There was great effort undertaken to ensure the application process, including the forms the MHP Owner/Operators need to submit, be uniform as much as possible throughout California and for all of the utilities. However, due to differences in operating territories, conditions and environments, each utility application may have slight variations in some areas.

Generally, we expect MHP residents will incur only minor, if any, costs in relation to the MHP Utility Upgrade Program. Such minor costs may include items essential for reconnecting MHP resident owned facilities such as gas flex connectors or auxiliary connections (e.g., air conditioners, fire place, BBQ unit, etc.) from the master-meter / sub-meter system to the new utility system. Generally, costs to reconnect the resident owned facilities to the new utility system(s) are borne by the pilot program; however, any resident owned facilities which, due to badly damaged condition, safety concerns with appliances, or non-compliance with California Department of Housing and Community Development (HCD) regulations, may be required to be replaced or corrected at MHP or mobilehome owner’s expense.

MHP Owner/Operators must obtain a qualified, licensed contractor to perform all necessary “beyond-the-meter” construction, plumbing and/or electrical work necessary to connect the new meters to connection points on each mobilehome. The utilities will reimburse the MHP owner for all prudently occurred and reasonable “beyond-the-meter” construction costs. Each utility will acquire routine, ministerial construction permits, such as encroachment permits necessary for utility trenching within public right-of-way.

MHP Owners or their representative (Operator) must acquire all other permits (environmental permits, CalTrans permits, railroad permits, building permits, HCD permits, etc.). Any environmental remediation or other resolution of environmental issues has been, and will continue to remain, the responsibility of each MHP Owner/Operator to address as required by any agency with jurisdictional authority over the MHP. This will include the removal of any MHP owned utility related facilities required to be removed after completion of work that converts the master-meter sub-metered service to direct utility service.

The utilities will be working with MHP Owner/Operators to minimize service interruption during construction and cutover of service. In almost all cases, the construction work will not take the master-metered/ sub-metered system out of service until the very end when the construction process will transfer the individual services from the master-metered / sub-metered system to the new utility system. Moreover, it is unlikely that anyone will need to enter residences other than perhaps to relight gas appliances.

The structure of ownership of the MHP or the master-meter system had no impact on the process for selecting a given master metered /sub-metered system for inclusion into the MHP Utility Upgrade Program. The MHP resident who owns the land that their residence sits has to provide legal easements that enable the utilities to install their pipeline mains and electric distribution facilities throughout the entire MHP in order for any work to commence. At the end of the conversion process, there cannot be both a direct utility system and a master-meter system providing the same service (e.g. gas and/or electric) to mobilehomes within the MHP. All mobilehome residents must convert to direct utility service.

No. Applying for the conversion program does not guarantee that your system will be converted under the MHP Utility Conversion Program. MHPs will be selected and prioritized for conversion from the original list of MHPs that submit the CPUC Form of Intent between the period January 1, 2021 and March 31, 2021. The selected MHPs will have to further meet other requirements (e.g., remediation of any environmental issues, ability to meet HCD requirements related to abandoned facilities, etc.) before an agreement is signed with a utility.

MHPs whose CPUC Form of Intent is received beyond March 31, 2021, or that exceed the program's space conversion threshold of approximately 50%, will be placed on a waiting list and may be selected for conversion later if the situation warrants. Moreover, the program will focus primarily on safety and secondarily on system reliability and capacity.

YES! Until the utilities complete their work in the MHPs selected for conversion under the MHP Utility Upgrade Program, and until ALL utility services are transferred from the master-meter / sub-metered systems to the utilities’ systems, MHP owners maintain liability for their systems and must continue to operate and maintain the existing master-meter sub-meter system in compliance with CPUC and HCD regulations.

Pursuant to California Public Utilities Code Section 4357, failure to operate and maintain the existing master-meter gas facilities in compliance with CPUC regulations will continue to be a violation of the rules or orders of the CPUC, which is a misdemeanor subject to civil penalties. The CPUC will closely monitor MHPs selected for conversion under the MHP Utility Conversion Program for violations of regulations.

Residents of MHPs selected for conversion under the MHP Utility Conversion Program will become new customers of the local serving CPUC regulated utility once the MHP is converted to direct utility services. Rates for service will be the same as that of other residential customers of the utility; because of CPUC requirements that prevent MHPs from charging rates any higher than what the utility could charge, MHP residents, in general, should not see a significant change in their rates.

In starting direct service with the serving utility, MHP residents will receive “grandfathered” status. Per CPUC directive, the initial new customer credit check and service deposit, which utilities normally require when customers start service, will not apply to MHP residents currently served by the master-meter / sub-metered system that converts to direct utility service. However, after initial service begins, and as is the case with any other residential customer, MHP residents, including those that later becomes residents of the MHP or begin receiving utility service, will be subject to the requirements of utility tariffs under which utilities must operate.

The CPUC lacks the regulatory authority to require municipal or other public agency utilities that provide natural gas or electric service to assist in funding or participating in the MHP Utility Conversion Program. If a CPUC regulated utility serves the natural gas and/or electric master-meter / submeter system in a given MHP, then the MHP is eligible to seek to have the applicable system converted under the MHP Utility Conversion Program. If a municipal entity provides either natural gas or electric service, the CPUC expects CPUC-regulated utilities to consult with the entity, during the early stages of the design work for a MHP included in the MHP Utility Conversion Program, to determine if, and how, that entity may be able to participate in the MHP Utility Conversion Program.

Yes. CPUC decision 20-04-004 allows an MHP selected for utility conversion to choose a contractor to perform the BtM portion of the upgrade work. However, in selecting a BtM contractor, the MHP owner and utilities need to consider the qualification of contractors, contractor bids or work, inability to meet schedule requirements, the contractor’s ability to carry costs while awaiting reimbursement from the utility and other factors. Inability to meet one or more of these factors may render a contractor as unacceptable to the MHP owner and/or the utilities involved in the MHP’s upgrade work. MHP owners need to make informed decisions to avoid complications with the upgrade project in their MHP and the MHP’s reimbursement of BtM expenses. To that effect, it is imperative that MHP owners consult with the utility representatives assigned to their upgrade work, as well as any contractor lists the utilities can provide, prior to selecting a contractor, or signing any contracts for BtM work.

Please click here for Gas and Electric Utility Contacts for contractors to obtain information related to BtM work or to be included on any lists maintained by the utilities.

To reach the CPUC with questions about the MHP Utility Conversion Program, please call (800) 755-1447 or by e-mail at MHPUtilityUpgradeProgram@cpuc.ca.gov.

 CPUC-regulated utilities participating in the MHP Utility Conversion Program can also provide information on the upgrade program. Please consult the Utility Contact List for contact information related to the specific utility(ies) which serve your MHP.