3. NOI to Claim Compensation

By the August 18, 1999 Assigned Commissioner's ruling, CMRAA's NOI was considered timely filed, but CMRAA was required to provide additional information in its request for compensation regarding its customer status and significant financial hardship. The ruling also required CMRAA to submit a declaration with its request stating:

a. what percentage of the total membership consists of persons who reside in a member-owned mobilehome park;

b. who controls the provision of and billing for water and sewer services at those member-owned mobilehome parks; and

c. whether the organization is claiming to represent such residents of member-owned mobilehome parks in this proceeding, and if so, how such persons meet the §1802(b) definition of customer.

CMRAA filed its request for compensation on July 13, 2001, and included a declaration by its president, Dave Hennesy. CMRAA states that it represents tenants in MHPs that have submetered utility systems (electric, gas and water). These tenants are normally considered customers of the park owners and customers of the serving utilities. In the declaration, Hennesy states that CMRAA has no local chapters in any member-owned park. He also states that he is not aware of any individual members amongst the thousands of members who reside in a member-owned park. We find that CMRAA meets the statutory requirements of a customer, in that it is a participant representing consumers, customers, subscribers of any electrical, gas, ". . . or water corporation" that we regulate. (§ 1802(b).)