5. Mobilehome Park Issues

WMA urges that the Commission extend SCWC's CARW proposal to persons who otherwise meet lifeline rate eligibility requirements and who reside at MHPs with submetered water distribution systems. SCWC agrees. ORA's reply brief states that extending any lifeline rate program to MHPs "is speculative at this time". (ORA reply brief at 4.) Though ORA claims that the evidentiary record has not been developed sufficiently to permit program extension to MHPs, its own witness' testimony suggests the actual problem is that ORA's service charge waiver proposal cannot be implemented readily at many MHPs. The problem arises where a MHP elects to calculate each submeter bill as a pro rata share of the master meter bill.⁹ Mechanically, since the MHP does not assess a service charge, there is no service charge to waive. Mathematically, because individual submeter bills calculated on this basis tend to be lower than those calculated by the alternative method, the problem cannot be solved by applying the value of the service charge as a credit against the submeter bill- the result is a "negative" bill, in many cases.

While the record demonstrates a conceptual mismatch between ORA's lifeline rate and the realities of ratemaking at MHPs, we cannot agree that the solution is to exclude MHP residents from the benefits of low-income rate relief. CARE discounts are available to eligible MHP residents and we see no reason a water rate relief program should not be available to all who meet the criteria for eligibility. Recently, in another proceeding, we clarified that neither of the alternative methods a MHP owner/operator may use to calculate submetered water charges prohibits that owner, as the master-meter customer of the utility, from passing lifeline rate discounts on to eligible submeter customers. (D.01-10-024, mimeo at 9, modifying D.01-05-058 in I.98-12-012.)

WMA's witness describes the mechanics of calculating the appropriate reduction in the master-meter bill to permit a 15% discount to all eligible MHP residents, as well as the mechanics of flowing that discount through on the submeter bills. The analysis relies on the basic methodology used to calculate the CARE discount to submetered customers for gas and electricity at MHPs. As WMA's witness explains, two variables must be established: the number of non-lifeline submeter customers at a MHP and the number eligible for the lifeline discount. Given this information, SCWC can then:

(1) bill the master-meter customers at the usual total volumetric charge and monthly service charge, (2) calculate the average usage per submetered customer, (3) calculate the total discount on the volumetric and service charges for the total of the CARW customers in the park, and (4) then subtract the total discount from the master-meter bill. The master-meter customers will then be compelled to bill the CARW customers at a 15% discount from the usual domestic water rate. (Ex. 100.)

We agree that the CARE program provides a useful model for discounts to submeter water customers. The approach is simple, practical and fair. As with the CARE program, verification requires cooperation between the MHP master-meter customer and SCWC. SCWC commits to provide information, including its tariff sheets and Form No. 20, to its MHP master-meter customers so that they can advise their tenants about the CARW program and its eligibility requirements. Each MHP master-meter customer, in turn, will need to provide SCWC with annually verified counts of the number of submeter customers at the MHP who qualify for a lifeline rate discount under the low-income guidelines approved by the Commission. Considering that SCWC has a customer relationship with the master-meter customers, not the submeter customers, and that the discounts flow through to benefit the submeter customers, we think annual verification is reasonable.

While WMA urges us to follow D.01-06-010, which applies to CARE in the service territories of the four largest energy utilities in California (Pacific Gas and Electric Company, Edison, SoCalGas, and San Diego Gas and Electric Company, and to authorize a 20% rate discount, the record does not provide the data which would enable us to estimate how much this would increase participation levels and program costs. Once SCWC has gained experience with the CARW we adopt today, we may review whether CARW should follow this aspect of the CARE program, as approved for the service territories of the large energy utilities.