Mobile Home Parks
The Safety and Enforcement Division (SED) is responsible for ensuring the safety of mastered metered natural gas systems in mobilehome parks. SED inspects mobilehome parks that take natural gas service through a master meter and then distribute it to park residents through their own system of underground pipes.
SED also inspects systems where liquefied petroleum gas (LPG), i.e. propane, is distributed from a master tank through underground pipes to multiple customers. SED has jurisdiction over Propane Master Tank systems serving two or more customers inside a mobilehome park or 10 or more customers in residential or commercial districts.
SED currently inspects over 2800 mobilehome park operators and 600 propane operators once every seven years pursuant to a risk-based inspection schedule. Inspections consist of reviewing operation and maintenance records, evaluating emergency procedures, and performing field inspections of the gas or propane systems.
What regulations must a small natural gas or propane system operator follow?
- Each operator must prepare and follow a manual of written procedures for conducting the following activities:
- Operations and Maintenance
- Emergency Response
- Operator Qualification
- Distribution Integrity Management
- Each year, each operator must submit an annual report to SED describing their system, the number of customers, and the dates of the most recent leak survey and cathodic protection survey.
Blank MHP Annual Report Form
Blank Propane Annual Report Form
Public Utilities Code, Sections 4351 through 4360
gives the California Public Utilities Commission (Commission)
jurisdiction over the safety of master-metered natural gas systems in
mobilehome parks. In January 1995 the Commission also assumed
jurisdiction over the safety of propane master tank distribution
systems. Assembly Bill 766 (Hauser) adopted Public Utilities Code, Sections 4451 through 4465
giving the Commission jurisdiction over Propane Master Tank systems
serving 10 or more customers not in a mobilehome park or two or more
customers inside a mobilehome park. The Gas Safety and Reliability
Branch (GSRB) of the Commission enforces Federal Pipeline Safety
Regulations through audits of jurisdictional MHP and Propane Master Tank
systems. Audits consist of reviewing operation and maintenance
records, evaluating emergency procedures, and performing field
inspections of the gas distribution facilities. If violations are found,
the operator is given an inspection form requesting that corrective
measures be taken within a specified time. If the operator complies and
reports the corrective actions to the inspector, the inspection is
closed. If the operator fails to comply, a citation and fine may
In resolution SU-24, dated 12/17/1993 the Commission delegated
authority to GSRB to cite and fine MHP operators for failure to comply
with pipeline safety regulations. Resolution USRB-001
dated July 31, 2008 delegated similar authority for operators of
propane master tanks. These fines are not to exceed $1,000 per day and
$200,000 per violation. In levying fines, GSRB considers a number of
factors including the gravity of the offense and the operator's history
of compliance. There is an appeal process.
Public Utilities Code Section 2791 put
a stop to the construction of master metered mobilehome parks. It
requires that residents of mobilehome parks built after January 1, 1997
be directly served by the gas and electric utilities serving in that
area. Sections 2791 through 2799
outline a process by which existing master metered mobilehome parks can
be converted to direct utility service. GSRB encourages such
conversions. Because the serving utilities are exclusively in the
business of providing gas and electric service, a consistently high
standard of maintenance and safety is assured. Benefits to operators of
master metered parks include relief from complying with increasingly
complex and demanding federal pipeline safety regulations and equally
complex requirements for rendering bills for service.
The Commission assumed
jurisdiction over the safety of master metered propane distribution
systems in January 1995, as mandated by Assembly Bill 766 (Hauser). The
Commission's Utilities Safety Branch administers the propane safety
program similar to its Mobilehome Park Safety Program, scheduling each
jurisdictional system for a safety inspection at least once every five years,
to assure compliance with the federal pipeline safety regulations
adopted by the Commission under General Order 112-E.
The GSRB is required by Section 4353(b)
to inspect the gas facilities of MHPs at least once every seven years
pursuant to a risk-based inspection schedule. Over 2,800 MHPs are
currently under the jurisdiction of the Commission. Section 4453(b)
requires GSRB to inspect Propane Master Tank Systems once every seven
years pursuant to a risk-based inspection schedule. Over 600 propane
operators are currently contained in the Commission's database.
On 8/1/2008, the Commission approved a resolution giving authority to GSRB staff to cite those propane operators who fail to abide by the Commission directives.
User fees: The
Commission is a user-funded agency and it collects fees based on the
number of customers served by the master metered MHP or propane system.
These fees are included in the master meter bill for natural gas
customers and may be passed through to the submetered customers.
The GSRB bills propane master tank systems annually at the time it mails
the annual report.
How to prepare an Operations and Maintenance (O&M) plan: Title 49 CFR 192, Section 192.605
requires each operator to prepare a manual of written procedures for
conducting operations, maintenance, and emergency activities. GSRB has
prepared a sample Guidance Manual to help small operators prepare
their own Operation, Maintenance and Emergency (OM&E) Plan, Operator
Qualification (OQ) Program, and Distribution Integrity Management
Program (DIMP). This guide provides information on what is required to
be included in your plans. Many outside vendors also can help you
prepare the OM&E Plan, OQ Program, and DIMP.
2012 Guidelines for Preparing OM&E Plans, OQ Plan, & DIMP for MHP Gas Systems
2012 Guidelines for Preparing OM&E Plans, OQ Plan, & DIMP for Propane Gas Systems
The CPUC is currently conducting a
three-year (2015-2017) Mobile Home Park Utility Upgrade Pilot Program to
convert master-metered gas and/or electric facilities to direct utility
service. For more details on the program, please click on the following
To help small utilities and operators, the U.S. Department of Transportation - Pipeline and Hazardous Materials Safety Administration publishes guidance manuals for operators of small natural gas and propane systems.
Each year, the GSRB presents seminars to operators of small gas systems on how to comply with the federal regulations.
The Western Manufactured Housing Communities Association (WMA) represents the interests of owners of mobilehome parks
The Western Propane Gas Association (WPGA) represents the interests of marketers of propane
The Golden State Manufactured-Home Owners League (GSMOL) represents the interests of people who live in mobilehomes