CPUC Decision 14-03-021

1. CPUC Decision 14-03-021 Three Year Pilot Program for Voluntary Conversion of Master-meter Gas & Electric Systems to Direct Utility Service (“The MHP Utility Upgrade Program”) Sunil Shori, Utilities Engineer California Public Utilities Commission Safety and Enforcement Division Gas Safety and Reliability Branch September 28, 2016

2. Who am I? Utilities Engineer, with the Gas Safety and Reliability Branch of the Safety and Enforcement Division of the California Public Utilities Commission (CPUC). The CPUC has safety oversight authority over master-metered gas systems in MHPs as well as authority to set the master-meter discount which MHPs use to set residential rates. I have been involved with gas pipeline safety for over 26 years.

3. Background In March of 2014, the Commission approved Decision 14-03-021 which implemented a three-year long state-wide voluntary pilot program to allow select Mobilehome park owners to convert their master-metered gas and/or electric systems to direct utility service.

4. CPUC Findings As a group, no MHP master-meter/submeter distribution systems are so unsafe or unreliable that they pose an imminent danger; however… “…various problems are not uncommon, given the aging infrastructure at most MHPs.”

5. Pilot Program Objectives First and foremost, improve the safety of residents of mobilehome parks currently served by master-metered gas systems. Secondly, improve the reliability, and for electric system the capacity, of existing systems in these MHPs which while safe, are aging and/or limit the ability of residents to utilize equipment or appliances for uses many now consider as essential (e.g., air conditioning, electric vehicle charging, etc.)

6. Pilot Program Objectives Thirdly, the Pilot enables MHP residents to participate in established public purpose and load management programs widely available to those who receive direct service including, for example, those developed to promote low-income energy efficiency, the California Solar Initiative and advanced metering infrastructure.

7. Pilot Program Objectives Generally, during the period January 1, 2015 thru December 31, 2017, the 3-year Pilot targets to replace 10% of master-metered spaces in each utilities’ territory to direct utility service; Overall, program factors gas safety concerns higher in prioritizing conversions; however, it also factors in existing electric capacity (e.g., 30 or 50 amps) and geographic location into the prioritization process. MHPs changing their mind about converting both gas & electric systems may be removed from Pilot.

8. CPUC Expectations Generally, most new utility facilities are installed in a common trench in easements MHP/residents provide the utility. New meters are installed near front of homes, unless impractical or other reasonable concerns; “Beyond the Meter” (BTM) costs cover necessary work, performed by MHP’s selected contractor, to reconnect services to homes; Utilities may use different contractors to perform their respective work; moreover, those contractors may differ from contractors performing BTM work.

9. CPUC Expectations The pilot program “maximize uniformity of the MHP conversion process by standardizing the program across utilities,” and throughout territories. Utility conversion will result in new distribution system(s), both to and beyond the meter. Ratepayer costs kept to reasonable expenditures and levels Any remedial environmental costs, abandonment costs; and some costs related to services to common areas (pool, rec room, street lights, etc.) are the responsibility of MHP.

10. CPUC Expectations Safety throughout the construction process while minimizing disruptions in service. Newer systems to improve overall safety. Safe abandonment of existing systems after commencement of direct utility service. The utility must disconnect the legacy system service connections and for gas, purge the master-meter system….”

11. CPUC Expectations For MHPs selected for transfer of service, the Program generally expects that a master-meter system and direct utility system will not operate concurrently in the same MHP; Also, once a park is accepted into the Program and service transfer work begins, no park will be left partially completed, even if the 10% limit is exceeded through the work by a utility. Any MHP that is well into construction, but not completed by December 31, 2017 may extend into 2018 (these will be exceptions and not the norm).

12. CPUC Expectations Safety and Enforcement Division works closely with Department of Housing and Community Development to address issues that arise. The Pilot continues to incorporate lessons learned while it works to develop/implement a program that improves safety, is consistent, meets all regulatory requirements, and is cost effective; All utilities, as well as BTM contractors, are expected to work towards the mutual goal of improving MHP safety and meeting CPUC and HCD directives necessary to the Pilot’s success.

13. CPUC Expectations “If the utility and MHP owner fail to agree upon the qualifications of the contractor selected to perform “beyond the meter” work, they should consult with SED to resolve the dispute….”

14. Issues Experienced As The Pilot Has Been Implemented Some disagreements between MHP Owners and utilities have been “refereed” by SED; Disagreements concern meter/pedestal placements, and in some cases, BtM work bids; Interpretations and requirements clarified throughout the Pilot (nature of any Pilot); How RV spaces and fixed buildings, other than common area locations, are to be handled so utility services can continue to be provided.

15. Issues Experienced As The Pilot Has Been Implemented Overall, all utilities, MHP owners, residents, BtM contractors, and HCD have worked cooperatively towards making the Pilot successful.

16. Pilot Extension Beyond 2017? D.14-03-021 allows any utility participating in the Pilot to request an extension to the Pilot within 45 days of the second annual report filing (e.g., around mid-March 2017) if its experience appears to warrant continuing the program without major modifications. The utility’s request must address specifics for extending (e.g., application process, targets for conversion, etc.)

17. Questions?