BILL ANALYSIS                                                                                                                                                                                                    Ó



                                                                      



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          |SENATE RULES COMMITTEE            |                  AB 1830|
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                                 THIRD READING


          Bill No:  AB 1830
          Author:   V. Manuel Pérez (D)
          Amended:  8/21/12 in Senate
          Vote:     21

           
           SENATE ENERGY, UTIL. & COMMUNIC. COMM.ITTEE  : 9-0, 7/3/12
          AYES:  Padilla, Fuller, Corbett, DeSaulnier, Kehoe, Pavley, 
            Rubio, Strickland, Wright
          NO VOTE RECORDED:  Berryhill, De León, Emmerson, Simitian

           SENATE APPROPRIATIONS COMMITTEE  :  7-0, 8/16/12
          AYES: Kehoe, Walters, Alquist, Dutton, Lieu, Price, 
            Steinberg

           ASSEMBLY FLOOR  :  74-1, 5/30/12 - See last page for vote


           SUBJECT  :    Water service:  mobilehome parks

           SOURCE  :     California Rural Legal Assistance Foundation


           DIGEST  :    This bill authorizes the Public Utilities 
          Commission (PUC), if it finds after an investigation, that 
          a mobile home park has charged an unjust or unreasonable 
          rate, to order the mobile home park to reimburse current 
          and former tenants affected by the rate.

           ANALYSIS  :    

          Existing law:

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          1. Authorizes the PUC to regulate utilities, including 
             water corporations, determine whether rates charged are 
             just and reasonable and service is adequate, and award 
             customers restitution for past overcharges on rates 
             deemed not just and reasonable.

          2. Provides that a mobilehome park that provides water 
             service to its tenants from its own water supplies and 
             facilities that are not otherwise dedicated to public 
             service is not a water corporation, but authorizes the 
             PUC, if a tenant complains about rates or service, to 
             investigate and determine whether rates are just and 
             reasonable and service is adequate.

          3. Authorizes the PUC, after investigation of mobilehome 
             park water service, to award "rate relief" or order the 
             park owner to improve its water supply, facilities, and 
             services.  The PUC concluded in a decision that this law 
             does not authorize the PUC to award restitution for past 
             overcharges.

          This bill:

          1. Authorizes the PUC to investigate rates and adequacy of 
             water service if a complaint  is filed by tenants of the 
             mobilehome park that represent 10 percent or more of the 
             park's water service connections during any 12-month 
             period, claiming that the water rates charged by the 
             park are not just and reasonable or that the service is 
             inadequate.  

          2. Requires the PUC, if it determines that a mobilehome 
             park has charged an unjust or unreasonable rate, to 
             order the mobilehome park to reimburse overcharges to 
             current and former tenants affected by the rate, if no 
             discrimination will result from the reimbursement.

          3. Requires a mobilehome park to provide tenants, at the 
             time of establishing residence and each time it changes 
             rates or service, written notice of their right to, and 
             how to, file with the PUC a complaint about water rates 
             and service.

          4. Requires that the notice to tenants be in English, 

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             Spanish and some Asian dialects, and be made available 
             on its Internet Web site.  Requires a mobilehome park 
             use the then-current language made available by the PUC. 
              

          5. Makes a failure to provide notice subject to a penalty 
             of not less than $500 or more than $20,000 per offense.

           Background
           
          Mobilehome parks, like apartments, frequently provide water 
          to tenants through a master meter whereby the park receives 
          water from a utility and then installs separate meters to 
          bill tenants individually.  Some mobilehome parks provide 
          tenants' water with their own water, such as well water, 
          and use separate meters to bill tenants individually.

          In response to concern about water service in mobilehome 
          parks, the Legislature enacted AB 290 (Clute, 1991) and SB 
          585 (Craven, 1995), which provided that, although 
          mobilehome parks providing tenants water service with their 
          own water supply were not utilities, the PUC can 
          investigate complaints from tenants and award "rate 
          relief."  

          In 2009, residents of Sunbird mobilehome park located in 
          the unincorporated community of Thermal, filed a complaint 
          with the PUC because residents' water bills were sometimes 
          in excess of $500.  The park is an 87-space unit occupied 
          by low-income families, many of them farm workers.  In 
          2006, the park had instituted a rate structure with four 
          tiers with a flat rate of $7.36 monthly service charge.  
          One resident complained of receiving a monthly water bill 
          of more than $1,000. After investigation, the PUC found 
          that the tier 3 and 4 rates at Sunbird reflected an 
          increase of 2,781.3% and 5,754.9%, respectively, over tier 
          1 rates.  In addition to the exorbitant water charges, the 
          water sold was contaminated with arsenic, which was found 
          to exceed the safe drinking water standard.

          The PUC found that the Sunbird water rates were not just 
          and reasonable and residents qualified for "rate relief" 
          under current law.  The PUC suspended tier 3 and 4 rates 
          but determined that it lacked authority to reimburse the 

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          residents for past overcharges even though residents had 
          been overpaying for water for three years.

           Comments
           
          According to the author's office, this bill ensures that 
          residents of mobilehome parks are afforded the same rights 
          and protections as customers of water corporations.  Many 
          of California's poorest families and individuals reside in 
          mobilehome parks, making them disproportionately 
          susceptible to the possibility that they will not be 
          eligible for reimbursement if overcharged for water.  This 
          bill also ensures that mobilehome park owners don't 
          unjustly profit off of low-income residents. 

           FISCAL EFFECT  :    Appropriation:  No   Fiscal Com.:  Yes   
          Local:  Yes

          According to the Senate Appropriations Committee, $95,000 
          in 2012-13 and $189,000 annually from the Utilities 
          Reimbursement Account to review and analyze just and 
          reasonable expenses and the capital needs of a mobilehome 
          park's water system and the rate charged.  Estimated 
          workload is for one utility engineer and one consumer 
          affairs representative to perform the above noted duties.

           SUPPORT  :   (Verified  8/21/12)

          California Rural legal Assistance Foundation (source)
          Clean Water Action
          Comite Civico Del Valle
          Community Water Center
          Consumer Federation of California
          Environmental Justice Coalition for Water
          Division of Ratepayer Advocates
          Golden State Manufactured-home Owners League, Inc.
          PolicyLink
          Promotores Comunitarios del Desierto
          The Utility Reform Network
          Unitarian Universalist Service Committee
          Western Center on Law and Poverty

           OPPOSITION  :    (Verified  8/21/12)


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          Western Manufactured Housing Communities Association 
          (unless amended)

           ARGUMENTS IN SUPPORT  :    The Division of Ratepayers 
          Advocates supports this bill, which requires mobilehome 
          parks that provide water service to reimburse current and 
          former tenants when the PUC finds water service quality and 
          rates charged are unreasonable.

          California deserves affordable, safe, and reliable water 
          service.  Customers pay their monthly bill with this 
          expectation.  If unjust and unreasonable service is 
          provided at unfair monthly service rates the situation 
          needs to be immediately addressed and customers deserve 
          full restitution.  This bill helps better protect 
          mobilehome parks water customers by (1) requiring that they 
          be advised of their right to file a complaint with the PUC 
          about rates or services in writing and (2) requiring the 
          PUC, after complaints are filed and an investigation is 
          conducted, to require mobilehome parks to provide its 
          current and former tenants with a refund for the inadequate 
          service dating back to when the inadequate service began, 
          with interest.

           ARGUMENTS IN OPPOSITION  :    Western Manufactured Housing 
          Communities Association (WMA) suggest that the bill be 
          amended to include a safe harbor provision such that an 
          operator would not have to go through an entire 
          investigation of rates if the PUC determines that the 
          operator is charging rates in line with the local water 
          provider.  A safe harbor provision could save a 
          well-meaning operator over a $100,000 in fees for a rate 
          study, to only find out they are not charging enough. 

          WMA also has some concerns about reimbursing prior tenants 
          after a complaint proceeding especially if they were not a 
          party to the complaint to the PUC.  Reimbursement 
          compensation should not extend prior to the initial 
          complaint and we don't believe interest should be charged.  
           

           ASSEMBLY FLOOR  :  74-1, 5/30/12
          AYES: Achadjian, Alejo, Allen, Ammiano, Atkins, Beall, Bill 
            Berryhill, Block, Blumenfield, Bonilla, Bradford, 

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            Brownley, Buchanan, Butler, Charles Calderon, Campos, 
            Carter, Cedillo, Chesbro, Conway, Cook, Davis, Dickinson, 
            Eng, Feuer, Fong, Fuentes, Furutani, Beth Gaines, 
            Galgiani, Garrick, Gatto, Gordon, Gorell, Grove, Hagman, 
            Hall, Harkey, Hayashi, Roger Hernández, Hill, Huber, 
            Hueso, Huffman, Jeffries, Jones, Knight, Lara, Bonnie 
            Lowenthal, Ma, Mansoor, Mendoza, Miller, Mitchell, 
            Monning, Morrell, Nestande, Nielsen, Norby, Olsen, Pan, 
            Perea, V. Manuel Pérez, Portantino, Skinner, Smyth, 
            Solorio, Swanson, Torres, Wagner, Wieckowski, Williams, 
            Yamada, John A. Pérez
          NOES: Donnelly
          NO VOTE RECORDED: Fletcher, Halderman, Logue, Silva, 
            Valadao


          RM:d  8/21/12   Senate Floor Analyses 

                         SUPPORT/OPPOSITION:  SEE ABOVE

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