BILL ANALYSIS Ó
AB 682
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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, |
| | | | | |2015) |
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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
AB 682
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