Manufactured Housing Utility Billing: How It Works, Methods and Rules

Key Takeaways

  • A manufactured housing community bills utilities in one of three ways: the utility bills each home directly, the community bills each home from its own submeter, or the community shares a bill by formula (allocation, or RUBS).
  • Which methods are allowed depends on the state, the utility's tariff and the rental agreement. In California, gas and electricity from an investor-owned utility (including community-choice electricity) served through a master meter are billed from each space's own meter at the utility's direct rate (Cal. Pub. Util. Code § 739.5(a)); at a city-owned utility such as LADWP, its own rules govern.
  • A good statement shows the readings and their dates, the usage, the rate for each tier, any discount or fee, and each utility on its own line.
  • In California, the CARE discount passes through in full to every qualified resident of a master-metered community (Cal. Civ. Code § 798.43.1(c)).
  • Rates come from each utility's published tariff schedules, and they change. A billing partner should find each change, apply it from its effective date, and show you the source behind every charge.

What Is Manufactured Housing Utility Billing?

Manufactured housing utility billing is how a community recovers the cost of the utilities its residents use — gas, electricity, water, sewer, trash and sometimes propane or cable — when the community, rather than each resident, is the utility's customer. It is often called mobile home park utility billing. The community receives the utility's bill, works out each resident's share, and adds it to the resident's monthly statement, usually beside the space rent.

It differs from apartment billing in two ways that matter. Many communities were built with one utility connection, a master meter, that serves every home, so the community is in the middle of every bill. And each home is a separate dwelling on its own space, often with its own submeter, so each resident can be billed on what that home used — and in California the law requires it for gas and electricity from an investor-owned utility (including community-choice electricity) served through a master meter. The rules that decide how billing is done come from state law, the utility's filed tariff or adopted rate schedule, and the rental agreement.

The Three Ways Communities Bill Utilities

MethodHow the resident's charge is setWho reads the metersWhere it fitsWhat to check
Direct utility accountsThe utility bills each home on its own accountThe utilityHomes with their own utility metersNothing for the community to bill; residents enroll in discounts with the utility
SubmeteringThe community pays the master bill and bills each home for what its own submeter measuredThe community or its billing providerA master meter with a submeter at each spaceThe rate applied, every tier, the readings, and any fee the state allows
Allocation (RUBS)The community shares a bill among homes by a formula, such as occupants or equal sharesNo space metersOnly where the state allows formula billing for that utilityWhether the method is allowed at all; common-area use kept out; shares never above the bill

1. Direct utility accounts

Each home has its own utility meter and its own account, and the utility bills the resident directly. The community has no billing role for that utility: the resident pays the utility, calls the utility with questions, and enrolls with the utility in any discount program. It is the simplest arrangement for the community, but it depends on the utility owning and serving a meter at every space, which many older communities do not have.

2. Submetering

The utility serves the whole community through a master meter and bills the community. A submeter at each space measures that home's own use, and the community bills each resident from it. Because each bill follows each home's measured use, a resident can check the bill against the meter. It comes with rules about price: in California, a submetered resident's gas or electricity from an investor-owned utility (including community-choice electricity) is billed “at the same rate that would be applicable if the user were receiving gas or electricity, or both, directly” from the utility (Cal. Pub. Util. Code § 739.5(a)), and submetered water is billed only by the methods the Civil Code lists (Cal. Civ. Code § 798.40(c)).

3. Allocation, or RUBS

Allocation — often called RUBS, for ratio utility billing — divides a bill among homes by a formula: by the number of occupants, by equal shares, or by some other measure, with no meter at each space. It is the most restricted of the three. Whether it is allowed at all depends on the state and the utility. In California, gas and electricity from investor-owned utilities (including community-choice electricity) served through a master meter are never billed by formula (Cal. Pub. Util. Code § 739.5(a) and the utility's resale rules), and at a city-owned utility such as LADWP its own rules govern; for water and sewer in a community without submeters, formula billing rests on Cal. Civ. Code § 798.41(a), and in our reading the shares together never exceed what the utility charged, net of common-area use, with no administrative fee. Our submetering vs. RUBS guide works through California's rules in detail.

Many communities use more than one method — for example, direct accounts for electricity, a master meter and submeters for gas, and water billed from the community's own water bill. Each utility follows its own rule.

Some communities instead include a utility in the rent, and some services, such as trash, are billed as a flat charge.

Master Meters and Submeters, Explained

A master meter is a utility meter that serves the community rather than a single home. The utility reads it and bills the community for everything it measured — every home's use, plus any common-area use such as the clubhouse, laundry, pool or street lighting, plus anything lost in the community's own pipes and lines. A submeter is a meter the community owns (or a submetering company provides) at each space that measures that one home's use.

In California, because the community owns and maintains the system beyond the master meter, the utility sells to it on a master-meter schedule at a discount; Cal. Pub. Util. Code § 739.5(a) requires the CPUC to set that discount for gas and electric master-meter customers of investor-owned utilities who submeter, and the utilities' master-meter tariffs say the discount prohibits further recovery of the costs of owning, operating, maintaining and replacing the submeter system (for example SCE Schedule DMS-2 Special Condition 9; PG&E Schedules ET and GT), under CPUC D.95-02-090. Each resident, meanwhile, is billed on the residential schedule a directly served home would be on — for example SCE Schedule D, PG&E E-1 or SoCalGas GR — never on the community's own master-meter schedule.

That is one reason the two totals differ. There is no master-bill ceiling on gas or electric; the ceiling is each resident's direct-service rate (§ 739.5(a)). Residents' charges can total more than the master bill; that is lawful — the master-meter discount is the community's compensation. Water works differently. Under the proportional method (Cal. Civ. Code § 798.40(c)(1)(A)), each resident's usage charge is a share of the purveyor's usage dollars in proportion to metered use, so together they never exceed them; under every method, common-area water and others' use stay out (§ 798.40(c)(1)(D)).

Who Reads the Meters

The utility reads its own meters: the master meter, and the meter of any home with a direct account. Submeters are read by the community or its billing provider — by a manager walking the community with a handheld app, or by automated meter reading that sends readings on its own. Whichever way, a few practices keep bills right:

  • Read every submeter at the same point in each billing period, and record the date.
  • Keep a photo or electronic record of each reading, so a question can be answered from the meter itself.
  • Check readings that are unusually high, low or zero before billing; they are often a misread digit, a stuck meter or a leak.
  • Replace a failed meter promptly, and record the old meter's final reading and the new meter's first.

In California 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).

What a Good Utility Statement Shows

A resident should be able to check every utility charge from the statement alone. A good statement shows:

  • The billing period, and the date of each reading.
  • The opening and closing readings, and the usage between them.
  • The rate for each tier and the quantity billed in it, and any daily or monthly fixed charge.
  • Any discount — such as CARE or FERA — and any fee, each shown plainly.
  • Each utility on its own line, apart from rent.
  • For a formula share: the bill being shared, the formula, and the resident's share.
  • Who prepared the bill, and how to reach them with a question.

In California most of this is required. The statement shows the period's charges and the opening and closing readings (Cal. Civ. Code § 798.40(a)); a third-party billing company that prepares it is named with its address and telephone number (§ 798.40(b)); each separately billed utility is stated on its own line, with an expiration date for any charge of limited duration (§ 798.41(d)); and a gas or electric bill is itemized in the form of the utility's own, with the rates and quantities for each block (Cal. Pub. Util. Code § 739.5(e)). The community also posts the current residential rate schedule, or its web address with a free copy on request (Cal. Civ. Code § 798.40(a)).

Income-Qualified Discounts: CARE and FERA in California

Many utilities offer discounts to households that qualify on income. When a community buys the utility through a master meter, the resident is not the utility's customer, so the discount reaches the resident only if the community passes it through. California shows how this works:

  • CARE (California Alternate Rates for Energy) discounts gas and electric bills for 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 discount is set between 30% and 35% (§ 739.1(c)(1)); the exact discount is on each utility's CARE schedule.
  • FERA (Family Electric Rate Assistance) is an 18% line-item electric discount for households with income between 200% and 250% of the federal poverty guideline, at PG&E, SCE and SDG&E (Cal. Pub. Util. Code § 739.12(a)–(b)).
  • In a master-metered community, management passes the full CARE discount through to every qualified resident, and the statement shows either the itemized discount or a CARE notation (Cal. Civ. Code § 798.43.1(c)). FERA reaches a submetered resident through Cal. Pub. Util. Code § 739.5(a), which bills the resident as if served directly (SCE's master-meter schedule DMS-2 names Schedule D-FERA expressly). Under the utilities' schedules, a household receives CARE or FERA, never both.
  • On or before February 1 each year, the statement carries a notice about CARE with the utility's phone number, and the same notice is posted in a conspicuous place in the clubhouse or, without one, in a conspicuous public place in the community (Cal. Civ. Code § 798.43.1(a)).
  • A resident who depends on life-support equipment, or has one of the conditions the statute lists, is eligible for an additional Medical Baseline allowance once certified through the utility's application (Cal. Pub. Util. Code § 739(c)).

Our CARE and FERA guide covers the passthrough in detail.

How Rates Are Found and Applied

Every utility publishes its rates in tariff schedules. An investor-owned utility files them with its state regulator; a city, district or cooperative utility usually adopts them through its own governing board or council. Where the law prices a submetered resident at the utility's direct rate, as California's does (Cal. Pub. Util. Code § 739.5(a)), a community needs four things from those schedules:

  1. The right schedule. In California, the resident's price comes from the residential schedule a directly served home is on, not from the community's own master-meter schedule.
  2. Every charge on it. The fixed charge, each tier's price, and the surcharges — applied to the resident's usage exactly as the utility would apply them to a direct customer (in California, Cal. Pub. Util. Code § 739.5(a)).
  3. The right allowance. Where the schedule has tiers, the lowest-priced tier is often a baseline allowance set by climate zone and season (in California, Cal. Pub. Util. Code § 739(a)(1), (b), (d)), scaled to the days billed.
  4. The effective date. When a rate changes part-way through a billing period, most utilities split the period at the effective date: days before the change are priced from the old schedule and days after from the new one. Whatever the utility's own tariff does with a mid-period change, the resident's bill does the same.

Water is often different. A submetered water bill may be shared from the community's own water bill (or, under § 798.40(c)(1)(B), its tier rates applied to evenly divided tier volumes) rather than priced from the water company's posted residential rates — in California, by the methods in Cal. Civ. Code § 798.40(c), unless the water company charges the community per space (§ 798.40(c)(1)(C)).

Rates change, and a missed change costs someone either way: bill too much and the resident is owed a refund; bill too little and the community loses money it was entitled to collect. The work is in noticing each change, reading the new schedule, and applying it from the right day.

Choosing a Billing Partner

Some communities bill utilities themselves; many hand part or all of the work to software or a billing company. Whoever does it, these questions separate a partner who gets every bill right from one who only produces bills:

  1. Who finds rate changes? Do you watch every utility's published rates, or do we have to tell you when one changes?
  2. Can you show your work? For any charge, can you show the published rate, the readings and the arithmetic behind it?
  3. Which rules do you check? Which state's law is each bill checked against before it goes out, and can you name the rules?
  4. How are discounts handled? How do CARE-type discounts and medical allowances reach the residents enrolled in them?
  5. Does it fit our system? Do charges post into our property management system, or does someone re-key them?
  6. Who reads the meters? Do you read them, or do we — and how are odd readings caught before they become bills?
  7. What happens when something is wrong? Who corrects a bill, how far back, and who explains it to the resident?
  8. What does it cost? Is pricing published, and what is included?

Our buyer's guide goes further for California communities.

The Rules Vary by State

Each state's rules differ; some have few specific to these communities, and a utility's own tariff can add more. California's rules are among the most detailed: a dedicated part of its Civil Code, the Mobilehome Residency Law, plus the Public Utilities Code and decisions of the California Public Utilities Commission. Our California guides cover them rule by rule:

Sentinel bills California today. We add states one at a time, starting in 2027, and only once every bill there can be checked against that state's law.

Frequently Asked Questions

What is mobile home park utility billing?

It is the same thing as manufactured housing utility billing: a community that buys gas, electricity, water or other services for its spaces bills each resident for that resident's share. How it may do so — from each home's own meter, or by sharing a bill by formula — is set by state law, the utility's tariff and the rental agreement.

Can a mobile home park charge residents for utilities separately from rent?

Where state law and the rental agreement allow it. In California, unless the rental agreement specifically provides otherwise, management may bill a resident separately for the utility fees and charges assessed for the spaces (Cal. Civ. Code § 798.41(a)); an agreement made before January 1, 1991 is excluded until it is extended or renewed (§ 798.41(b)). When a utility moves out of rent, the separate charge stays outside rent only if the rent is reduced at the first separate bill by the average the community was charged for that utility for that space over the 12 months before the notice (§ 798.41(a)).

Can a mobile home park add a fee or markup to utility bills?

It depends on the state and the utility. In California no fee may be added to a resident's gas or electric charge from an investor-owned utility, including community-choice electricity (apart from the CPUC gas safety surcharge, at cost and never above 25 cents per space a month — Pub. Util. Code § 4358(c)); the charge is billed at the rate the utility would charge the resident directly (Cal. Pub. Util. Code § 739.5(a)). At a city-owned utility such as LADWP, its own rules govern. Submetered water may carry one billing or administrative fee: 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)).

Is submetering or RUBS better for a manufactured housing community?

Submetering bills each home for what its own meter measured, so a resident's bill follows that resident's use. Allocation (RUBS) shares a bill by a formula and is the most restricted method: in California, gas and electricity from investor-owned utilities (including community-choice electricity) served through a master meter are never billed by formula (Cal. Pub. Util. Code § 739.5(a) and the utility's resale rules); at a city-owned utility such as LADWP, its own rules govern. Submetered water is billed only by the methods in Cal. Civ. Code § 798.40(c). Which methods are open to a community depends on its state, its utilities and its meters.

Who reads the meters in a manufactured housing community?

The utility reads its own meters — the community's master meter, and the meter of any home with its own utility account. The submeters at each space are read by the community or its billing provider, by walking the community or by automated meter reading, ideally at the same point in each billing period.

What should a resident's utility statement show?

The billing period, the opening and closing readings and their dates, the usage, the rate for each tier and the quantity billed in it, fixed charges, any discount, any fee, and each utility on its own line. In California these come from Cal. Civ. Code §§ 798.40(a)–(b), 798.41(d) and 798.43.1(c), Cal. Pub. Util. Code § 739.5(e) and Cal. Code Regs., tit. 4, § 4090, and a billing company that prepares the bill is named with its address and phone number.

Do CARE discounts reach residents of a master-metered community?

In California, yes. Management passes the full CARE discount through to every qualified resident and shows either the itemized discount or a CARE notation on the statement (Cal. Civ. Code § 798.43.1(c)). FERA, an 18% line-item electric discount, reaches a submetered resident through Cal. Pub. Util. Code § 739.5(a). Under the utilities' schedules, a household receives CARE or FERA, never both.

Why can residents' gas and electric charges add up to more than the community's master bill?

In California, where a community buys gas or electricity from an investor-owned utility (including community-choice electricity), it buys on a discounted master-meter schedule, while each resident is billed at the direct residential rate (Cal. Pub. Util. Code § 739.5(a)). There is no master-bill ceiling on gas or electric; the ceiling is each resident's direct-service rate. Residents' charges can total more than the master bill, and that is lawful — the master-meter discount is the community's compensation.

What happens when a utility changes its rates in the middle of a billing period?

Most utilities split the period at the effective date: days before the change are priced from the old schedule and days after from the new one. Whatever the utility's own tariff does with a mid-period change, the resident's bill does the same.

Does Sentinel bill communities outside California?

Sentinel bills California today. We add states one at a time, starting in 2027, and only once every bill there can be checked against that state's law.

Sources

Primary sources for the California rules cited in this guide. Utility rates and discount percentages are set in each utility's tariff schedules, published on its website.

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