ALJ/JPO/avs Mailed 11/24/2004

Decision 04-11-033 November 19, 2004

BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA

Order Instituting Rulemaking on the Commission's Own Motion to Re-Examine the Underlying Issues Involved in the Submetering Discount for Mobile Home Parks and to Stay D.01-08-040.	Rulemaking 03-03-017 (Filed March 13, 2003)
Order Instituting Investigation on the Commission's Own Motion to Re-Examine the Underlying Issues Involved in the Submetering Discount for Mobile Home Parks and to Stay D.01-08-040.	Investigation 03-03-018 (Filed March 13, 2003)

Bruce A. Reed, Attorney at law, for Southern California Edison Company; Gail L. Slocum, and Andrew L. Niven, Attorneys at Law, for Pacific Gas and Electric Company; David Norris, Attorney at Law, for Sierra Pacific Power Company; and Andrew Bettwy, Attorney at Law, for Southwest Gas Corporation; Charles Eshleman, and Vicki Thompson, Attorneys at Law, for San Diego Gas and Electric Company, and Southern California Gas Company, respondents.

Edward G. Poole, Irene K. Moosen, and Sheila Dey, Attorneys at Law, for Western Manufactured Housing Community Association;

Richard MCCann, for M. Cubed; James Squeri, Attorney at Law, for Manufactured Home Communities, Inc.; Daniel Edington, and Haley Goodson, Attorneys at Law, for The Utility Reform Network; Susan Brown, Attorney at Law, and Enrique Gallardo, for Latino Issues Forum, interested parties.

TABLE OF CONTENTS

TITLE PAGE

OPINION 22

I. Summary 22

II. Background 55

III. Threshold Issues 88

1. The Adequacy of MHP Owner Records 88

2. Setting the Discount at the Cap 88

3. Uniform Statewide Discount 99

4. Where the Discount Should be Set 99

5. Settlements 1111

IV. Should the Commission Adopt a Uniform
Statewide Rate Structure for the Discount? 1212

V. Should the Commission Adopt a Uniform
Statewide Method to Calculate the Discount? 1313

VI. Are there Fair and Reasonable Ways to Mitigate
the Cost to MHP Owners of Converting
Existing Submetered Systems to Directly-Metered Service? 1818

1. Motion to Establish a Separate Proceeding 2222

VII. Should the Commission Revise the Methods
and Formulas by Which Refunds are
Currently Paid to Submetered Tenants by MHP Owners? 2323

1. LIF Recommendations 2626

2. TURN Recommendations 2828

3. WMA Recommendations 2929

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? 3131

IX. Effective Date 3232

X. Comments on Proposed Decision 3333

XI. Assignment of Proceeding 3333

Findings of Fact 3333

Conclusions of Law 4242

ORDER 4747

OPINION