BILL ANALYSIS                                                                                                                                                                                                    



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          CONCURRENCE IN SENATE AMENDMENTS


          AB  
          682 (Williams)


          As Amended  June 25, 2015


          2/3 vote. Urgency


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          |ASSEMBLY:  |75-0  |(May 22, 2015) |SENATE: |40-0  |(August 31,      |
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          Original Committee Reference:  H. & C.D.




          SUMMARY:  Authorizes a person to have specified alterations,  
          conversions, and repairs made to a mobilehome without filing an  
          application with the Department of Housing and Community  
          Development (HCD).  Specifically, this bill:  


          1)Authorizes a person to, without filing an application for an  
            alteration or conversion with HCD, alter or convert, or cause  
            to be altered or converted, the structural, fire safety,  
            plumbing, heat-producing, or electrical systems and  
            installations or equipment of a mobilehome in order to extend  
            a gas line and/or electrical feeder line from a utility-owned  
            service line to the electrical subpanel or gas inlet of a  
            mobilehome only for the purpose of a natural gas and/or  
            electric service utility upgrade within a mobilehome park that  
            is subject to or consistent with the requirements of the  








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            Public Utilities Commission's (CPUC) Mobilehome Park Utility  
            Upgrade Program (MHP Pilot Program).


          2)Authorizes a defect in the mobilehome relating to the  
            heat-producing or electrical systems or installations or  
            equipment to be repaired or replaced without filing an  
            application for an alteration or conversion with HCD if the  
            following conditions are met:


             a)   The defect is found at the time that natural gas or  
               electric service is connected to a mobilehome as part of a  
               utility upgrade within a mobilehome park that is subject to  
               or consistent with the requirements of the MHP Pilot  
               Program.


             b)   The repair or replacement is necessary to correct the  
               defect;


             c)   The repair or replacement is made promptly; and


             d)   HCD approves the repair or replacement.


          3)Requires HCD to inspect any such alterations or conversions to  
            ensure that health and safety standards are met.


          The Senate amendments:


          1)Provide that this bill is an urgency measure.


          2)Strike language providing that HCD may establish and charge an  
            hourly technical service fee to cover the reasonable costs of  
            inspecting mobilehome alterations or conversions pursuant to  
            the MHP Pilot Program.








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          FISCAL EFFECT:  According to the Senate Appropriations  
          Committee:


          1)HCD staffing costs of $952,000 in 2015-16, $928,000 in  
            2016-17, and $464,000 in 2017-18 for 8 Personnel Years to  
            perform construction inspections of mobilehome utility meter  
            installations in conjunction with the MHP Pilot Program  
            (Mobilehome-Manufactured Home Revolving Fund).


          2)All costs are expected to be fully offset by inspection fee  
            revenues.  Position and fee authority for 2015-16 and 2016-17  
            was approved as part of the 2015 Budget Act.


          COMMENTS:  MHP Pilot Program:  Existing law establishes the  
          procedure for transferring master-metered mobilehome parks to  
          utilities that provide direct service.  However, due to a  
          variety of reasons, few transfers have actually occurred since  
          the law took effect in 1997.  In 2014, the CPUC initiated a  
          voluntary three-year pilot program to encourage park owners to  
          transfer master-meter and submeter service to direct utility  
          service.  


          The MHP Pilot Program is a voluntary three-year program which  
          authorizes each California investor-owned utility to convert  
          10%, approximately 40,000, of master-metered gas and/or electric  
          mobilehome park spaces within its operating territory to direct  
          utility service.  Each participating utility is authorized to  
          fully recover in distribution rates the costs of the pilot  
          program, subject to reasonableness review.  There are numerous  
          benefits to converting to direct utility service, including  
          safety inspections by the utilities and local agencies, as well  
          as infrastructure upgrades.  The pilot program involves the  
          replacement of utility lines and installation of new meters for  
          new locations, and existing service inlets.  It also requires  
          new service lines from the new meters to the existing service  
          inlets for the mobilehomes which will be accompanied by  








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          installing new gas and/or electric lines to the underside of  
          mobilehomes in the park.  It requires extensive plan reviews and  
          inspections of contractor work.  


          According to the CPUC, "in February 2011, following a petition  
          filed by the Western Manufactured Housing Communities  
          Association (WMA), the CPUC opened a rulemaking proceeding  
          (R.11-02-018) to examine what could be done to encourage owners  
          of mobilehome parks and manufactured housing communities (both  
          referred herein as MHPs) to upgrade aging gas and electric  
          distribution systems in an effort to enhance both public safety  
          and service reliability for MHP residents.


          "On March 13, 2014, the CPUC issued Decision 14-03-021,  
          establishing a three-year pilot program authorizing each  
          California investor-owned utility to convert 10% of  
          master-metered gas and/or electric MHP spaces within its  
          operating territory to direct utility service." 


          The MHP Pilot Program will run for three years, beginning  
          January 1, 2015, and continuing through December 31, 2017.   
          There was a 90-day open enrollment period, from January 1 to  
          March 31, 2015, in which the CPUC's Safety and Enforcement  
          Division (SED) accepted initial applications from park owners  
          interested in participating in the program.  The SED is  
          responsible for prioritizing and selecting parks for the upgrade  
          program.  Selected parks will need to meet additional  
          requirements to go through with the pilot program. 


          Once the park is converted to direct utility services, current  
          residents will become new customers of the local serving CPUC  
          regulated utility, and will be "grandfathered" into the program  
          so as to avoid the normal credit check and service deposit  
          requirements.  Generally, residents should not see a significant  
          change in their rates.


          Purpose of this bill:  According to the author, "the law  








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          requires construction permits for alterations made to a  
          mobilehome, and a permit can only be issued if a homeowner has  
          the title or proper paperwork certifying they own their unit.   
          However, it's not uncommon for a mobilehome owner to lack the  
          title or appropriate paperwork for their mobilehome, due to  
          multiple title transfers.  


          "AB 682 provides a narrow exemption to the permit requirements  
          for alterations to mobilehomes thereby ensuring the smooth  
          implementation of the MHP Pilot Program.  The narrow exemption  
          would allow a utility to upgrade the electric and gas system to  
          mobilehome park tenants who may or may not have up-to-date  
          paperwork.  Mobilehome tenants would be able to participate in  
          the pilot program without a current title or appropriate  
          paperwork.  The pilot program's successful implementation means  
          upgrading aging gas and electric distribution systems in an  
          effort to enhance both public safety and service reliability for  
          the state's mobilehome residents.


          "AB 682 will address the issue of the utility transfer pilot  
          program not being implemented due to lack of current and proper  
          documentation, while expediting the utility upgrades." 


          Senate amendments add an urgency clause to this bill, and strike  
          language providing that HCD may establish and charge an hourly  
          technical service fee to cover the reasonable costs of  
          inspecting mobilehome alterations or conversions pursuant to the  
          MHP Pilot Program.  HCD already has the authority to charge a  
          technical service fee for technical services.  Since the bill  
          categorizes MHP Pilot Program inspections as technical services,  
          HCD is authorized to charge a fee under existing law and does  
          not need to establish a new technical service fee.


          Analysis Prepared by:                                             
                          Rebecca Rabovsky / H. & C.D. / (916) 319-2085     
                                                                  FN:  
          0001292









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