California Manufactured Housing Utility Billing: Operator's Guide

California manufactured housing utility billing rests on several layers — the Mobilehome Residency Law (MRL), the Public Utilities Code and California Public Utilities Commission (CPUC) decisions, the CARE and FERA programs, and in some places local ordinances. An operator who bills utilities to residents meets all of the layers that apply at once, and using a third-party billing agent does not move those duties off management. For how utility billing works in manufactured housing generally — the billing methods, meters and statements — see how manufactured housing utility billing works nationally.

The law gives residents real remedies. Under Cal. Civ. Code § 798.85, the prevailing party in an action under the MRL recovers reasonable attorney fees and costs, so a bill you can show your work on settles questions quickly.

This guide covers the core billing and disclosure requirements for California manufactured housing communities; the full rule list, utility by utility, is in our California rules guide. It is organized by topic, with specific statute citations for each obligation. Where multiple regulatory layers apply to the same requirement, the interactions are noted. It is a plain-English summary, not legal advice; the source text controls.

How Each Utility Is Billed, at a Glance

The gas and electric row covers gas from the investor-owned gas utilities and electricity from investor-owned utilities, electric service providers and community choice aggregators; a city- or district-owned utility such as LADWP or SMUD applies its own submetering rule (Cal. Pub. Util. Code § 380(k)). Where LADWP supplies the water, its Rule 18.C.2.b allows no submetering fee, so Sentinel charges none there.

Each statute has its own page: § 739.5, § 798.40, § 798.41 and § 798.43.1. To test a water fee against both limits, use the water fee cap calculator.

The Regulatory Framework

California manufactured housing utility billing is not governed by a single statute. Instead, operators must navigate several overlapping regulatory layers, each with distinct requirements and enforcement mechanisms.

Mobilehome Residency Law (MRL)

The MRL (Cal. Civ. Code §§ 798–799.13) is the primary statutory framework governing the relationship between manufactured housing operators and residents. It establishes baseline requirements for utility billing, including rate limitations, disclosure obligations, billing format rules, and the CARE discount pass-through (FERA reaches residents through Pub. Util. Code § 739.5(a)). The MRL applies to every manufactured housing community in California (a “mobilehome park” in the statute), however its utilities are metered.

Public Utilities Code and CPUC

The California Public Utilities Commission imposes additional requirements on master-metered manufactured housing communities through Cal. Pub. Util. Code § 739.5, CPUC decisions and the utilities' filed tariffs. These overlay the MRL requirements and add specific obligations around rate parity, rebate passthrough, rate schedule posting, and itemized billing. Properties that are individually metered by the serving utility are generally not subject to CPUC master-metering rules, though they remain subject to the MRL.

Section 739.5 reaches gas from the investor-owned gas utilities and electricity from investor-owned utilities, electric service providers and community choice aggregators. It does not reach a city- or district-owned electric utility such as LADWP or SMUD (Cal. Pub. Util. Code § 380(k)); there that utility's own submetering rule governs.

HCD Title 25

The California Department of Housing and Community Development (HCD) regulates the physical infrastructure of manufactured housing communities under Title 25 of the California Code of Regulations. Title 25 addresses the technical standards for utility systems — electrical, gas, water, and sewer installations — rather than billing practices. However, the physical metering configuration (master-metered vs. individually metered, submeter specifications) affects which billing rules apply.

Local Ordinances

Some California jurisdictions impose additional requirements on manufactured housing utility billing through local rent stabilization ordinances or utility billing regulations. Local rules can add requirements where state law leaves room; some state provisions apply notwithstanding local ordinances (for example Cal. Civ. Code § 798.41(a) and Cal. Pub. Util. Code § 4358(c)). Operators should review applicable local ordinances in every jurisdiction where they operate.

How the Layers Interact

The practical effect of this layered framework is that each layer adds its own requirements. The MRL sets the floor. CPUC regulations add requirements for master-metered properties. HCD governs the physical infrastructure. Local ordinances can add further requirements where state law leaves room for them.

Billing Format and Disclosure Requirements

The MRL establishes several specific requirements for how utility bills must be formatted, what information they must contain, and what disclosures operators must provide to residents. Each requirement is tied to a specific statute.

Charges Equal the Utility's Rates

For gas and electricity from an investor-owned utility (including community-choice electricity), Cal. Pub. Util. Code § 739.5(a) requires the community to charge each resident “at the same rate that would be applicable if the user were receiving gas or electricity, or both, directly” from the utility — every charge and every tier of the utility's residential schedule, applied to the resident's own metered usage, with no added fee (apart from the CPUC gas safety surcharge, at cost and never above 25 cents per space a month — Pub. Util. Code § 4358(c)). For submetered water and sewer, Cal. Civ. Code § 798.40(c) lists the charges allowed: a usage charge by one of its methods, the purveyor's fixed charges shared by usage or equally among spaces, and one administrative fee within the § 798.40(c)(3) cap. Beyond those, § 798.40(e) preserves the community's recovery of its “costs to install, maintain, or improve its internal water delivery system, as may otherwise be allowed in any rental agreement or local regulation” — a water rule only.

Done right: The operator applies the current published tariff rate for the applicable rate schedule (e.g., SCE Schedule D, SoCalGas Schedule GR) to each resident's metered gas or electric consumption, and bills water by a § 798.40(c) method.

Where bills go wrong: a billing or administrative fee on a gas or electric line; a flat per-space gas or electric charge instead of the metered tariff rate; billing at a previous rate after the utility's new rate took effect; a water fee above the § 798.40(c)(3) cap.

Separate Itemization

Cal. Civ. Code § 798.41(d) requires every separately billed utility charge to be separately stated on each monthly or other periodic bill, and a charge of limited duration, or amortized over a set period, to state its expiration date on the first notice and on every bill while it is charged. For gas and electricity, Cal. Pub. Util. Code § 739.5(e) adds an itemized bill in the form of the utility's own, with the rates and quantities for each block.

Done right: The bill states electric, gas, water, and sewer as separate charges, each with its own rate, consumption, and total.

Where bills go wrong: a single “Utilities” charge that combines several separately billed utilities, or a separately billed charge folded into the rent figure. Keeping a utility inside the rent is lawful (§ 798.41(c)); it is then rent, not a utility charge.

Meter Readings on Bills

Cal. Civ. Code § 798.40(a) requires that, where management provides master-meter and submeter service, the charges for each billing period be separately stated along with the opening and closing readings for the resident's meter. This allows residents to verify that the billed consumption matches the actual meter reading and to identify potential errors. A state weights-and-measures regulation also requires each billing period's invoice to show the opening and closing readings and their dates and the rates and quantities for each block, and the rate schedules and billings to be kept for at least 12 months, open to the resident and the county sealer (Cal. Code Regs., tit. 4, § 4090).

Done right: Each utility line item on the bill shows the prior meter reading, the current meter reading, and the calculated consumption (e.g., “Prior (Sept 30): 4,512 | Current (Oct 31): 4,999 | Usage: 487 kWh”).

Where bills go wrong: The bill shows only a dollar amount without the underlying meter readings, or shows consumption without the opening and closing reads.

Common Area Metering Disclosure

Cal. Civ. Code § 798.43 applies when a gas, water or electric meter on a resident's own site also measures service to common-area facilities or equipment, including lighting (for example a clubhouse, pool pump or laundry; § 798.43(b) adds required roadway lighting that lights the resident's site). Where management knows of the condition, it discloses it before the tenancy begins or on discovery, and then either enters a written agreement compensating the resident for that portion of the service or stops using the resident's meter for the common area. Disclosure alone does not satisfy the statute. Separately, common-area water is never part of a resident's submetered water usage charge (§ 798.40(c)(1)(D)).

Done right: The condition is disclosed and cured — a signed compensation agreement, or the common-area load moved off the resident's meter.

Where bills go wrong: a resident's meter that still carries common-area load with no compensation agreement, even if the condition was disclosed.

Billing Agent Disclosure

Cal. Civ. Code § 798.40(b) requires that if a third-party billing agent or company prepares the community's utility billing, management disclose on each resident's billing the name, address, and telephone number of that agent or company.

Done right: Every bill carries the billing company's name, mailing address, and telephone number.

Where bills go wrong: a bill prepared by a third party that names it without an address or telephone number, or does not name it at all.

Rate Parity — The No-Markup Rule

The most consequential pricing rules are split by utility. For gas and electricity from an investor-owned utility (including community-choice electricity), Cal. Pub. Util. Code § 739.5(a) requires each resident to be charged “at the same rate that would be applicable if the user were receiving gas or electricity, or both, directly” from the utility. For submetered water and sewer, Cal. Civ. Code § 798.40(c) limits the bill to the statute's methods for sharing what the water purveyor charged (or, under § 798.40(c)(1)(B), its tier rates applied to evenly divided tier volumes), plus one capped administrative fee — not the purveyor's posted residential rates, unless the purveyor charges the community per space. Together these are commonly known as the “no-markup rule” or “rate parity.”

How Rate Parity Works with Master Meters

In a master-metered property, the utility delivers service through a single meter serving the entire community. The operator then distributes service to individual spaces through submeters and bills each resident based on their individual consumption. The rate parity requirement means that the price per kilowatt-hour or therm applied to each resident's submetered use equals the price on the utility's published residential schedule, tier by tier.

This creates a practical challenge: the community's own account is billed on a master-meter schedule (for example SCE DMS-2 or PG&E ET), which carries the submetering discount, while each resident is billed on the ordinary residential schedule (for example SCE Schedule D or PG&E E-1). Billing a resident on the master-meter schedule is a common wrong-schedule error.

Why This Is a Common Source of Disputes

Rate errors are a common source of utility billing disputes in California manufactured housing, for several reasons:

• Rate changes: Utilities publish new rates periodically (often annually, sometimes more frequently). If an operator continues billing at the previous rate after a new tariff takes effect, every bill since is priced wrong: if the new rate is lower, residents are over-billed; if higher, the community under-collects.
• Wrong rate schedule: Applying the wrong tariff schedule — for example, using a general service commercial rate instead of the applicable domestic or residential schedule — can result in systematic over- or under-billing.
• Tiered rate errors: Many utility tariffs use tiered or baseline pricing, where the price per kilowatt-hour or therm changes with consumption. Applying tiers incorrectly — wrong thresholds, wrong baseline allocations, wrong seasonal adjustments — breaks rate parity even if the base rate is correct.
• Administrative fees: On gas and electricity from an investor-owned utility, any fee added on top of the utility's rate — service charges, billing fees, administrative costs — breaks the same-rate rule (apart from the CPUC gas safety surcharge, at cost and never above 25 cents per space a month — Pub. Util. Code § 4358(c)). On submetered water, one administrative fee is allowed, capped at the lesser of $4.75 — which management may raise each calendar year, beginning January 1, 2022, by no more than the California CPI increase the Department of Finance determines — or 25% of the usage charge (Cal. Civ. Code § 798.40(c)(3)).

Why Accuracy Matters

The law gives residents real remedies (Cal. Civ. Code §§ 798.85, 798.86): in an action under the MRL the prevailing party — resident or community — recovers reasonable attorney fees and costs, so the cost of a dispute can run well past the overcharge itself. A bill you can show your work on is worth having.

CARE and FERA Discount Passthrough

Cal. Civ. Code § 798.43.1(c) requires operators to pass through the full amount of the CARE discount to every qualified resident, and Cal. Pub. Util. Code § 739.5(a) gives a FERA resident the discount a direct customer would receive. Neither discount can be reduced or kept back by management.

What CARE Is

The California Alternate Rates for Energy (CARE) program provides a discount on electric and gas bills for qualifying low-income households with income no greater than 200% of the federal poverty guideline (Cal. Pub. Util. Code § 739.1(a)). At electric utilities with 100,000 or more customer accounts, the average effective CARE discount is set between 30% and 35% (§ 739.1(c)(1)); the exact discount is on each utility's CARE schedule.

What FERA Is

The Family Electric Rate Assistance (FERA) program provides an 18% line-item discount on electric bills for households with income between 200% and 250% of the federal poverty guideline, at the state's three largest electric utilities — PG&E, SCE and SDG&E (Cal. Pub. Util. Code § 739.12(a)–(b)). SB 1130 removed FERA's minimum household size, effective January 1, 2025. FERA applies only to electric service. It reaches a submetered resident through § 739.5(a), which bills the resident as if served directly; § 798.43.1 itself is about CARE.

Operator Obligations

Under Cal. Civ. Code § 798.43.1 (CARE) and Cal. Pub. Util. Code § 739.5(a) (CARE and FERA alike), operators of master-metered manufactured housing communities have specific obligations beyond simply passing through the discount:

• Annual CARE notice: On or before February 1 each year, the billing statement carries written notice that CARE offers a discount on monthly gas or electric bills for qualifying low-income residents, with the serving utility's telephone number for CARE information and applications; the same notice is posted in a conspicuous place in the clubhouse, or, if there is no clubhouse, in a conspicuous public place in the community (§ 798.43.1(a)). Under § 798.14 as amended by AB 391 (effective January 1, 2026), the annual notices under §§ 798.15(c) and (i) and 798.43.1, including the CARE notice, may be combined and may also be delivered by email to a homeowner or resident who has given affirmative, written consent, obtained separately from any lease (§ 798.14(a), (c)); the posting is still required.
• Applications: Management may accept and help process CARE applications, and may not withhold from a resident who applies on their own any information the utility needs, including the account number (§ 798.43.1(b)).
• Full passthrough: The full amount of the CARE discount reaches every qualified resident (§ 798.43.1(c)), and a FERA resident receives the discount a direct customer would (§ 739.5(a)). The operator cannot retain any portion of either.
• Accurate application: The discount must be calculated correctly based on the utility's published CARE/FERA discount rates for the applicable tariff schedule. Applying the wrong discount percentage or calculating the discount on the wrong base amount falls short of the full passthrough.

How Discounts Should Appear on Bills

For CARE, the statement shows either the itemized amount of the discount or a notation that the resident is receiving the CARE discount on the electric bill, the gas bill, or both (§ 798.43.1(c)); either is lawful. Showing the full pre-discount charge, the discount amount, and the net charge is the more transparent of the two, and the easier for a resident to verify.

Privacy Considerations

CARE and FERA enrollment status is sensitive personal information because it indicates that a resident meets income-based eligibility criteria. Operators should handle enrollment data with appropriate privacy protections. Enrollment status should not be disclosed to other residents or to staff who do not have a legitimate need to know for billing purposes.

CPUC Requirements for Master-Metered Properties

Properties that receive utility service through a master meter are subject to additional requirements under the Public Utilities Code and CPUC decisions. Cal. Pub. Util. Code § 739.5 establishes the framework for how master-metered manufactured housing communities must bill residents for utility service.

Rate Parity Under § 739.5

Under Cal. Pub. Util. Code § 739.5(a), master-metered operators must bill residents for gas or electricity from an investor-owned utility (including community-choice electricity) at the same rate that would apply if the resident received it directly from the utility. This means operators must determine the applicable residential rate schedule and apply it correctly — including baseline allocations, tier structures, and seasonal adjustments.

Rebate Passthrough

A rebate the utility pays the community goes to its current residents, shared by each resident's use in the last billing period (Cal. Pub. Util. Code § 739.5(b)(1)); the statute expressly includes the greenhouse-gas allowance credits behind the electric Climate Credit (§ 739.5(b)(2)). Where the utility credits a refund per meter, the CPUC has ordered it passed on per submeter (CPUC D.04-11-033, Ordering Paragraph 8). SCE and SoCalGas credit the Climate Credit once for each home — SCE's master-meter schedule tells the community to distribute the credits to each submetered home, and SoCalGas asks that each home receive the same credit, and its Schedule G-CCC gives the community one credit for each submetered home — so we pass it on as one home's credit to each occupied space: we read the CPUC's per-meter rule (D.04-11-033, Ordering Paragraph 8) to apply because the utility credits per home. We know of no court or CPUC decision that has applied either method to the Climate Credit by name. In our reading, the gas Climate Credit is a rebate under § 739.5(b)(1) and passes through the same way.

Itemized Billing

Cal. Pub. Util. Code § 739.5(e) requires an itemized gas or electric bill to each resident, generally in the form and content of the utility's own residential bills, including the opening and closing readings and “the identification of all rates and quantities attributable to each block in the applicable rate structure.” Naming the rate schedule on the bill is not required by statute; it is good audit practice.

Rate Schedule Posting

The community posts, in a conspicuous place, the specific current residential rate schedule as the utility publishes it — or its web address, in which case it gives a free copy on request and says in the posting that residents may ask (Cal. Civ. Code § 798.40(a); Cal. Pub. Util. Code § 739.5(e)). The purpose is to enable residents to independently verify the rates applied to their bills.

CARE Eligibility in Mixed-Metering Properties

Some manufactured housing communities have a mix of metering arrangements — for example, master-metered for gas but individually metered for electric. In these properties, CARE eligibility and discount application must be evaluated separately for each utility type based on the metering arrangement. The community's pass-through duty covers only the utilities it bills through its master meter; for a utility the resident buys directly, the resident enrolls with that utility, which applies the discount itself. The CPUC may not deny a submetered resident CARE because some homes in the community are not submetered (Cal. Pub. Util. Code § 739.5(h)).

Record Retention and Audit Requirements

A state weights-and-measures regulation (Cal. Code Regs., tit. 4, § 4090) — not a CPUC rule — requires anyone billing utility service through submeters to keep the rate schedules and individual billings for at least 12 months, open to the resident and the county sealer, and to show on each billing period's invoice the opening and closing readings and their dates and the rates and quantities for each block. However, the 12-month minimum is just that — a minimum.

Best Practice: 7-Year Retention

Seven years is our practice, not a legal requirement; it leaves a wide margin for disputes that surface after a delay. Records kept longer than the 12-month minimum let an operator answer a question about billing from 18 or 24 months back.

What to Retain

A defensible record retention program for utility billing should include:

• Copies of the rate schedules used for each billing period, with effective dates
• Source documentation for each rate schedule (published tariff documents from the serving utility)
• Meter reading records for each space, each billing period
• Completed bills showing all line items, rates applied, discounts, and totals
• CARE and FERA enrollment records, including application dates and the utility's enrollment confirmations
• Correspondence with residents regarding billing disputes or questions
• Records of any billing corrections or adjustments

Why a Record of Each Step Matters

In a billing dispute, an operator who can show its arithmetic usually ends it early. Without a clear audit trail — from the published tariff to the rate in force to the meter reading to the bill — that answer is hard to give. A complete audit trail lets the operator show each step from the published rate to the bill.

Where Bills Commonly Go Wrong

The following are common sources of utility billing errors in California manufactured housing. Each is a specific statutory obligation that is easy to miss.

Not Showing Meter Readings on Bills

Statute: Cal. Civ. Code § 798.40(a); Cal. Pub. Util. Code § 739.5(e)

Bills that show only a dollar amount without the underlying meter readings prevent residents from verifying their consumption. This is one of the most straightforward requirements to meet, and a common one to miss — particularly when operators use manual billing processes or generic invoicing software not designed for utility billing.

Failing to Pass Through CARE Discounts

Statute: Cal. Civ. Code § 798.43.1(c)

A bill falls short of the full passthrough when CARE enrollment status is not tracked or the discount percentage is wrong. This is compounded when operators also skip the February CARE notice (§ 798.43.1(a)), which means eligible residents may never learn about the program in the first place.

Using Incorrect Rate Schedules After a Rate Change

Statute: Cal. Pub. Util. Code § 739.5(a)

Utilities publish new rates periodically, and the effective date is not always the same as the publication date. Operators who do not monitor tariff filings and update their billing rates promptly may continue billing at an incorrect rate for months. If the new rate is lower, residents are being overcharged. If the new rate is higher, the operator is under-collecting — and switching to the correct rate later may create confusion about why bills increased.

Not Separately Itemizing Utility Charges

Statute: Cal. Civ. Code § 798.41(d)

Once a utility is billed separately, combining several utilities into a single line, or folding a separately billed charge into the rent figure, does not meet the separate-statement requirement. (Keeping a utility inside the rent is lawful, § 798.41(c).) This prevents residents from understanding what they are paying for each utility and from verifying the rates applied.

Not Disclosing Billing Agent Relationships

Statute: Cal. Civ. Code § 798.40(b)

When a third-party billing agent or company prepares the community's utility billing, each resident's bill must carry its name, address, and telephone number. A bill without them falls short even if the charges themselves are accurate.

Not Disclosing Common Area Metering

Statute: Cal. Civ. Code § 798.43

A meter on a resident's site that also measures common-area service must be disclosed and then cured — by a written compensation agreement with the resident, or by moving the common-area load off that meter. Disclosure alone does not satisfy the statute.

How to Check Your Own Billing

Operators can check their own utility billing by reviewing the following areas. This is not a substitute for legal counsel, but it identifies common gaps.

Compare Rates Against Published Tariffs

For each utility type billed, obtain the current published tariff from the serving utility (SCE, SoCalGas, PG&E, or your local utility). For gas and electricity, identify the residential schedule a directly served home in your area would be on (for example SCE Schedule D, PG&E E-1 or SoCalGas GR) — not the community's own master-meter schedule — and compare each tier's price per kilowatt-hour or therm on your resident bills against it. They must match. For submetered water, check that the usage charge follows one of the § 798.40(c) methods against the purveyor's own bill, not the purveyor's posted residential rates. If they don't, determine whether you are over-billing (residents are owed a refund) or under-billing (revenue loss).

Verify CARE and FERA Passthrough

Review your resident roster for CARE and FERA enrollments. For each enrolled resident, verify that the correct discount percentage is being applied to the correct utility charges. Verify that the discount appears on the bill as an itemized amount or a CARE notation. Confirm that the February CARE notice went out in billing statements (it may also be emailed to residents who consented under § 798.14) and is posted in the clubhouse (or a conspicuous public place if there is no clubhouse).

Review Bill Format

Pull a sample bill and verify that it includes: opening and closing meter readings and their dates for each utility, consumption calculated from those readings, separate itemization by utility type, and the billing agent's name, address and telephone number (if a third party prepares the billing). Naming the rate schedule applied is good audit practice, though the law requires the schedule to be posted rather than printed on the bill. A common-area load on a resident's meter is disclosed when the tenancy begins or on discovery, not on the bill.

Check Rate Schedule Currency

Determine when each rate schedule you are using was last updated. Compare the effective date against the utility's most recently published tariff. If your rate schedules are not current, every bill generated since the new rate took effect may be priced wrong.

Assess Record Retention

Review your record retention practices. Can you produce the rate schedule, meter readings, and completed bill for any space for any billing period in the last 12 months? Beyond that? If not, your ability to show your work in a billing dispute is limited.

Document Everything

For each billing determination, maintain a documented chain from the published tariff to the rate applied to the bill. That chain is what answers a resident's question in any dispute; without it, all you can say is that you believe the bill is right. For a detailed look at the compliance checks Sentinel runs on every bill, see our compliance framework.

Sources

Primary sources for the rules in this guide. Utility rates and the CARE and FERA discounts themselves are set in each utility's tariff schedules, published on its website.

• Cal. Civ. Code § 798.31 — charges for services actually rendered
• Cal. Civ. Code § 798.32 — notice before a new service fee
• Cal. Civ. Code § 798.40 — statements, rate posting and submetered water
• Cal. Civ. Code § 798.41 — billing utilities separately from rent
• Cal. Civ. Code § 798.43 — common-area use on a resident's meter
• Cal. Civ. Code § 798.43.1 — the CARE discount in master-metered communities
• Cal. Civ. Code § 798.44 — propane sold by the community
• Cal. Civ. Code § 798.85 — attorney fees in actions under the Mobilehome Residency Law
• Cal. Pub. Util. Code § 739 — baseline and Medical Baseline allowances
• Cal. Pub. Util. Code § 739.1 — the CARE program
• Cal. Pub. Util. Code § 739.5 — master-metered gas and electric service
• Cal. Pub. Util. Code § 739.12 — the FERA program
• Cal. Pub. Util. Code § 4358 — the mobilehome park gas safety surcharge
• CPUC Decision 04-11-033 (November 19, 2004) — mobilehome park submetering
• Cal. Code Regs., tit. 4, § 4090 — submeter billing records and invoices