Vieth Agenda Dec. on Petition for Modification of Decision 01-05-058, concerning Water Rates at Mobilehome Parks with Submetered Water Systems

5. The Supplement to the Petition

WMA filed the supplement to its petition in the course of its participation in a separate proceeding, Application (A.) 00-09-046, in which Southern California Water Company (SoCalWater) seeks authority to establish a lifeline rate in Regions II and III of its service territory. WMA has appeared in A.00-09-046 to advocate that MHP tenants at parks with submetered water systems should receive the benefit of any lifeline rate the Commission may approve. The central issue raised in WMA's supplement is that a literal reading of the billing alternatives established by D.01-05-058 may prevent the pass through to eligible tenants of lifeline rate reductions. WMA served its supplement on the service lists in both this proceeding and A.00-09-046. GSMOL's response, the only one filed, does not address this issue directly.

WMA's concern focuses on the billing alternative D.01-05-058 establishes for a MHP owner/operator who chooses not to remove from the rent the embedded capital and operation costs associated with the submeter water system. In such a case:

... the submeter customer may be charged only for volumetric submeter usage plus a pro rata allocation of any other charges billed to the master meter. (D. 01-05-058 at pp. 29-30.)

WMA asks that we exempt lifeline programs from D.01-05-058 or revise the decision to clarify that MHP owners/operators are not prohibited from passing lifeline discounts onto their tenants at parks with submetered water systems. We agree that tenants at submetered parks should be able to enjoy the benefits of a lifeline rate if they meet the eligibility requirements. Therefore we will modify D.01-5-058 as follows:

... the submeter customer may be charged only for volumetric submeter usage plus a pro rata allocation of any other charges billed to the master meter. However, nothing in this decision shall be interpreted to prohibit the master meter owner/operator from passing lifeline rate discounts on to eligible submeter customers.

We will defer review of the specific lifeline proposals at issue in A.00-09-046, and the mechanics for implementing them at MHPs, to a decision in that proceeding since the evidence is part of the record of that proceeding, and not I.98-12-012.