Mobilehome Park Utility Upgrade Program Frequently Asked Questions
In 1997, Public Utilities Code §§ 2791-2799, established a statutory framework, the “Transfer of Facilities in Master-Metered Mobilehome Parks and Manufactured Housing Communities to Gas or Electric Corporation Ownership”, for transferring master-metered gas and electric facilities to Investor-Owned Utility (IOU) companies that provide direct service where the park or community is located. However, because very few transfers had occurred since 1997, in 2014 the CPUC initiated a voluntary three-year MHP Utility Upgrade (Pilot) Program to transfer master-metered gas and electric systems to direct utility service. In 2017, the CPUC evaluated the Pilot Program to decide whether a new phase of the program would be established and extended the Program through the end of 2020. In 2019, the CPUC established the MHP Utility Conversion Program, which carries the program through 2030.
The criteria for conversion of these systems focuses on safety first, followed by improvements in reliability and capacity. To improve the efficiency of work done, the program encourages joint trenching and conversion of both gas and electric systems in the entire park. Utilities, other than the IOUs 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 and manufactured communities (MHP) that have master-metered natural gas and/or electric systems. Master-metered propane systems are NOT eligible for this program.
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 service providers regulated by the CPUC.
The MHP Utility Upgrade (Pilot) Program began on January 1, 2015 and continued through July 1, 2020. The second phase of the program, named the MHP Utility Conversion Program, accepted applications from January to March 2021 and merged new applicants with the existing risk analysis list in June 2021.
The next application period for the program is scheduled to be open from January 1, 2025 through March 31, 2025. CPUC will be accepting new applications, performing a new risk analysis of all parks in the program, and producing new priority lists for the Utility Companies.
The MHP Utility Conversion Program is designed to sunset at the end of 2030. However, there is an evaluation of the program scheduled for 2025, and the CPUC will be collecting data to decide whether to extend the program past 2030.
No.
Participation in the MHP Utility Conversion Program is voluntary. MHP Owners that choose to participate will submit a completed CPUC Form of Intent (FOI) to the CPUC to request to be included in the MHP Utility Conversion Program. Subsequently, if the MHP is included in the MHP Utility Conversion Program, the MHP Owner/Operator will need to complete and submit a more detailed formal application to the CPUC-regulated utility that serves the MHP.
Applying for the program does not guarantee that the MHP will be converted under the MHP Utility Conversion Program. MHPs will be prioritized for conversion from the list of eligible MHPs that submit the CPUC Form of Intent. 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 can be signed with a utility.
The MHP Utility Conversion Program has proven to be very popular, and there are many eligible applicants. Participating utilities are allowed to convert approximately 3% of all registered mobilehome spaces in their service territory, and thus, not all MHPs will be chosen for conversion before the scheduled end of the Program in 2030. There is an evaluation of the program scheduled for 2025, and the CPUC will be collecting data to decide whether to extend the program past 2030.
In the fourth quarter of 2024, the CPUC will send a new Form of Intent to all master-metered natural gas operators within the CPUC’s database that are not already within the program. CPUC will also post the revised Form of Intent on the CPUC website.
The CPUC will continue accepting completed Forms of Intent for the MHP Utility Conversion Program starting on January 1, 2025, and will close the filing period at the end of day on March 31, 2025.
Based on the data contained in the CPUC Form of Intent and from other sources, the CPUC’s Safety and Enforcement Division (SED) will place all eligible MHPs onto a priority list and rank systems for conversion based on risk factors (e.g., age of system, leak history, materials, etc.). In June 2025, the SED will provide the utilities with the priority list and the utilities will start the communication process with their respective selected MHPs. Afterwards, if the MHP meets the necessary requirements and chooses to continue participating in the conversion program, it will be placed in a queue for construction work.
Any applications received after the application period ends will be saved by SED in a waitlist to include in the potential next phase of the program.
SED continues to oversee the utilities’ efforts in all regards to the MHP Utility Conversion Program to ensure that:
- MHPs can make an informed decision about participating in the program;
- Difficulty and confusion about applications is kept to a minimum and that the process and utility applications are uniform throughout California;
- MHP Owners and Operators can obtain answers to their questions regarding the application process, construction activities and schedules, and whether the MHP is included in the MHP Utility Conversion Program.
No. Once an MHP is prioritized within the program it will stay on the priority list until either the utility systems are converted to direct utility service or the MHP Owner voluntarily withdraws from the program.
However, the MHP Owners who were accepted into Pilot Program can submit a new Form of Intent to update the CPUC with any risk or contact information that may have changed for the MHP.
To apply to the MHP Utility Conversion Program, MHP Owners will only have to submit a Form of Intent to the CPUC. However, once the utility contacts an MHP to start the planning and permitting process, the MHP Owner must complete other forms and contracts governing the construction of new utility systems.
There was great effort undertaken to ensure the application process, including the forms that MHP Owners/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.
Generally, we expect MHP residents will incur minor costs, if any, in relation to the MHP Utility Conversion Program. These costs may include equipment, such as gas flex connectors or auxiliary connections, essential for reconnecting MHP resident-owned facilities (e.g., air conditioners, fireplaces, BBQ units, etc.) from the master-metered system to the direct utility service. Generally, costs to reconnect the resident owned facilities to the new utility service(s) are borne by the program; however, any resident-owned facilities, due to damage, 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 the MHP or mobilehome owner’s expense.
MHP Owners 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 construction permits, such as encroachment permits, necessary for utility trenching within public right-of-way.
Depending on the layout of the park, the MHP Owner may be responsible for the cost of new “beyond-the-meter” gas and electric service facilities to common-use, non-residential areas of the park (e.g. laundry rooms, pool heaters, clubhouses, etc.). including any service panels.
MHP Owners must acquire all other permits (e.g., environmental permits, Caltrans permits, railroad permits, building permits, HCD permits, etc.) necessary for construction.
Any environmental remediation or other resolution of environmental issues has been, and will continue to remain, the responsibility of each MHP Owner. This includes the removal of any MHP-owned utility-related facilities required to be removed after completion of work that converts the master-metered service to direct utility service.
Any cultural remediation costs are also the responsibility of the MHP Owner.
The utilities will be working with MHP Owner/Operators to minimize service interruption during construction and transfer of service. In almost all cases, the construction work will not take the master-metered systems out of service until completion, at which point the individual services from the master-metered system will be transferred to the new direct utility service. Moreover, it is unlikely that anyone will need to enter residences other than to relight gas appliances.
The structure of ownership of the MHP or the master-meter system has no impact on the process for selecting a given master-metered system for inclusion into the MHP Utility Conversion Program. The MHP resident who owns the land that their residence sits upon must 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. As a result, all residents within a mobilehome park must agree to convert to direct utility service for inclusion into the MHP Utility Conversion Program.
No.
Submitting a Form of Intent does not guarantee that your system will be converted under the MHP Utility Conversion Program. MHPs will be added to the Program’s risk ranking list and prioritized for conversion based off of their risk profile. 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 outside of an application period, 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. Above all, the program will focus primarily on safety and secondarily on system reliability and capacity.
Yes.
Until the utility companies complete their construction work within an MHP selected for conversion, and until ALL utility services are transferred from the master-metered systems to direct utility service, MHP owners maintain liability for their systems and must continue to operate and maintain the existing master-metered system in compliance with CPUC and HCD regulations.
Pursuant to California Public Utilities Code Section 4357, failure to operate and maintain the existing master-metered 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 service. 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-metered system after conversion 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 become 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-metered system within a given MHP, then the MHP is eligible to apply to be converted under the MHP Utility Conversion Program. If a municipal utility serves the natural gas and/or electric master-metered system, the CPUC expects CPUC-regulated utilities to consult with the municipal utility during early stages of an MHP’s conversion planning to determine if, and how, a municipal utility could 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 utility conversion. However, in selecting a BtM contractor, the MHP owner and utilities need to consider the qualification of contractors, ability to meet schedule requirements, 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 ineligible to perform BtM work related to the MHP’s utility conversion. MHP owners need to make informed decisions to avoid complications with their MHP’s utility conversion and their MHP’s reimbursement for BtM expenses. To that effect, it is imperative that MHP owners consult with the utility representatives assigned to their utility conversion, as well as any contractor lists the utilities can provide, prior to selecting a contractor or signing any contracts for BtM work.
The CPUC maintains a list of Utility Contacts for Beyond-the-Meter Contractors to obtain information related to BtM work or to be included on any BtM contractor lists maintained by the utilities.
To reach the CPUC with questions about the MHP Utility Conversion Program, please call (800) 755-1447 or e-mail at MHPUtilityUpgradeProgram@cpuc.ca.gov.
CPUC-regulated utilities participating in the MHP Utility Conversion Program can also provide information on the program. Please consult the Utility Contact List for contact information related to the specific utilities which serve your MHP.