Agreed to by Pacific Gas and Electric Company (PG&E), Southern California Gas Company, San Diego Gas & Electric Company, Southwest Gas Company, Southern California Edison Company, the Western Manufactured Housing Community Association, and The Utility Reform Network.

1. Definitions.


· Common areas: facilities available for use by all tenants such as: swimming pools, buildings, recreation rooms, clubhouses, parking lots, laundry facilities, and street and common area lighting. This excludes utility-owned load control devices, such as air conditioning cycling mechanisms, where applicable.


· Pedestal: The pedestal is a rectangular metal box that sits near the concrete pad on which the mobile home is placed. It supports the service panel that contains the meter socket, breaker, and receptacle to connect the electric supply to the mobile home. In a directly-metered MHP, this is a component of the required service equipment (Applicant's responsibility) as specified in Electric Rule 16.D.1.c.


· Distribution Line Extension Allowance: Distribution Line Extension and Service Extension allowances are granted to Applicants requesting electric service based on expected revenues from permanent loads in accordance with Electric Rules 15 and 16. The allowances for residential electric service are set as a fixed amount per meter or residential dwelling unit.

2. Boundaries of the distribution system and services within
the master-metered mobile home park (MHP) whose costs
are recovered through the sub-metering discount. - Distribution system and service facilities running from the master meter to, and including, the tenant's meter that are used to deliver electricity to the sub-metered tenant. This does not include required service equipment that would otherwise be owned and maintained by a directly-metered MHP owner pursuant to Electric Rule 16.D.1.c. (including but not limited to: the meter pedestal, its foundation and the meter panel). It also does not include, where applicable, the excavation and supporting substructures of the required service equipment that would otherwise be owned and maintained by a directly-metered MHP owner pursuant to Electric Rule 16.D.1.a.

3. Utility avoided costs - Categories of costs the utility incurs when directly serving MHP tenants that are avoided by the utility when a master-metered MHP is sub-metered. These categories of costs are those for which the owner of a master-metered MHP is reimbursed through the discount provided pursuant to the utility tariff for service to master-metered mobile home parks (to the extent these costs do not exceed the average costs the utility would have incurred in providing direct service), and may not be separately charged to MHP tenants by the MHP owner. The following is a general list of costs incurred in the provision of direct service that are avoided in a sub-metered MHP, i.e., utility avoided costs (electric):


· Operations and maintenance expenses including, but not limited to, meter reading, billing, maintenance, and repair of the distribution system and service facilities, including distribution and service trenching, distribution and service conduit, distribution and service substructures, and distribution protective structures maintenance, where appropriate, as defined in the applicable utility tariffs, e.g., Electric Rules 15 and 16.


· Administrative and general expenses.


· Uncollectibles.


· Unaccounted for loss of electrical energy.


· Capital Investment Costs: Utility cost portion of initial and subsequent capital investment, including capital expenditures for replacement, and improvement of the distribution system and service facilities.


· This may include, but is not limited to:

_ Capital investment for maintenance-related trenching, conduit (maintenance), transformers, poles, service lines, service drops, and meters as specified in the applicable utility tariffs.


· Capital investment-related cost components include:

_ depreciation,

_ return on investment (rate base)

_ taxes related to capital investment (including property taxes).


· Other taxes (not related to capital investments) associated with operations and maintenance, as well as meter reading and billing, that are the utility's responsibility under the applicable tariffs, e.g., Electric Rules 15 and 16.

4. Costs not covered by the discount - Categories of costs related to electric utility service that are either not incurred by the utility when it directly serves MHP tenants or are not reflected in utility rates for direct service, but are incurred by the owners or operators of master-metered MHPs. This may include Applicant (MHP owner) responsibility service equipment required by utilities to provide service to the MHP (Electric Rule 16) and equipment to hook-up the mobile home to the MHP's electric service. The following are the categories of electric costs for which the owners of master-metered MHPs are not compensated through the electric sub-metering discount provided pursuant to a utility tariff. Such costs may only be separately charged to sub-metered tenants if doing so can be shown not to violate any of the following: (1) Public Utilities Code Section 739.5(a), (2) related case and statutory law that owners of sub-metered MHPs may not pass through to tenants as rent increases costs related to the repair and maintenance of their sub-metered electric utility systems if such cost components are covered by the sub-metering discount, or (3) other local rent control ordinances:


· Costs related to common area


· Purchase and capital-related installation, repair and maintenance costs for: pedestals, meter sockets, circuit breakers, service panels, and support pads.


· Trenching (excavation) for (1) underground service reinforcements, as defined by Rule 16.F.1; and (2) expansion of sub-metered distribution and services under Rules 15.B.1.a and 16.D.1.a(2).2 (Trenching for maintenance and repair is included in the discount)


· Conduits for (1) service reinforcements, as defined by Rule 16.F.1; and (2) expansion of sub-metered distribution and services under Rule 15.B.1.a and 16.D.1.a(3).3 (Capital-related costs for initial installation only, not maintenance and repair, which are already covered by the discount).


· Substructures and protective structures for (1) service reinforcements as defined by Rule 16.F.1; and (2) expansion of sub-metered distribution and services under Rule 15.B.1.a and 16.D.1.a.4


· Capital investment related costs for the cost components listed in this Section 4 if not otherwise directly recovered by the MHP owner, such as:

_ depreciation

_ return on investment

_ taxes related to capital investment (including property taxes).


· Operations and maintenance expenses for the interconnection between the meter set and each sub-metered dwelling unit (mobile home), including associated taxes.


· Other taxes (not related to capital investments) not otherwise directly recovered by the MHP owner associated with operations and maintenance that are the responsibility of the owner of the master-metered mobile home park under the applicable tariffs, e.g., Electric Rules 15 and 16.

The inclusion on the above list of any cost category does not warrant automatic approval by a rent board of related rent increases for the sub-metered tenants of a master-metered MHP. The MHP owner must first demonstrate that costs incurred properly fall within the categories of costs set forth above. Then, the rent board would need to determine that any related recovery of these costs through rent is not prohibited by (1) Public Utilities Code Section 739.5(a), (2) related case and statutory law, and (3) other local rent control ordinances.

2 PG&E's policy is that master-metered mobile home parks cannot be expanded by the addition of additional sub-metered spaces. 3 PG&E's policy is that master-metered mobile home parks cannot be expanded by the addition of additional sub-metered spaces. 4 PG&E's policy is that master-metered mobile home parks cannot be expanded by the addition of additional sub-metered spaces.

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