VIII. Are there Requirements that should be Placed on MHP Owners to Ensure that the Discounts are Used to Pay for the Intended Expenditures, to Facilitate Gathering Data to be Used in Determining the MHP Owners' Costs in Setting the Discount Rate, or for Some Other Purposes?

This issue was addressed primarily by TURN and WMA. TURN recommends that the utilities be required to modify their master-meter tariffs to require MHP owners to place discount funds intended to cover physical equipment in an escrow account as a condition of receiving the discount. TURN represents that this is intended to encourage MHP owners to maintain their submetered systems. WMA opposes this recommendation for a variety of reasons including the fact that submetered MHPs are not utilities.

As discussed previously, since the MHP owner records are inadequate to determine the MHP owner's costs to provide submetered services, we set the discount at the cap. As a result, there is no reason to impose requirements on MHP owners to gather data for use in setting the discount.¹⁵

In D.95-02-090, the Commission included a suggestion that MHP owners establish a reserve account for infrastructure improvements. In D.95-08-056, the Commission modified D.95-02-090 to eliminate that discussion, and stated that it would not consider ordering such a requirement without more information on how often there are surpluses in discount revenues for infrastructure improvements. TURN's proposal in this proceeding is similar. There is some information in the record to indicate that some MHPs would likely require significant investments to make them suitable for transfer to the serving utility. However, there is not sufficient information in the record to demonstrate that there are surpluses in discount revenues for infrastructure improvements, or that MHP owners as a whole are not adequately maintaining or providing improvements to their submetered systems. Therefore, there is no need to impose such a requirement at this time.