incidents have occurred, 4) the program has received high customer satisfaction, and 5) new eligible customers have been identified for the California Alternate Rates for Energy and Medical Baseline Allowance programs. SDG&E and SoCalGas also state that the Commission has already considered the policy arguments for and against the MHP Pilot and its various components, as well as costs, and ordered the initial step of the MHP Pilot to commence. SDG&E and SoCalGas contend that TURN’s end goal is to re-litigate the MHP Pilot and this should only be done by a petition for modification. Furthermore, SDG&E argue that the Commission ordered that a request to continue the MHP Pilot could be done by advice letter despite ORA’s proposal to require an application to be filed after the second year of the MHP Pilot in order to continue the program. This is consistent with the Commission’s stated goal “[t]o ensure the pilot can be flexibly extended to permit further, voluntary conversions.” SDG&E and SoCalGas have filed applications to continue the MHP Pilot to include an additional twenty percent of spaces within SDG&E and SoCalGas’ territories (Application 17-05-008 and Application 17-05-007, respectively). On April 2, 2017, the Western Manufactured Housing Community Association (WMA) sent a letter of support for the advice letter filings by PG&E, SCE, Southwest, SDG&E and SoCalGas. As an initial proponent of the program back in 2011, WMA agrees with the utilities that the program has been successful and should be continued. The City of Chula Vista and the City of Vista also each submitted a letter to the Commission on April 2, 2017 to support SDG&E’s AL. the ALs filed by the IOUs. Below in Table 1 and 2 are summaries of utility requests and status of their MHP pilot programs: Table 1: Electric Utilities Advice Letter Request and Current Program Status
PG&E SCE SDG&E CalPeco Electric Summary of Request Continue the MHP conversion program thru 12/31/2018 - address "Category 2 " MHPs (8,335 spaces) - convert ~2%/year - NO new application - balance account remain Open Continue beyond 2018 Revise Rule 28 Continue the MPH conversion program for another 6 years Convert additional 20% of MHP Continue to record to MMMA Revise Rule 27 Continue the MPH conversion program thru 2018 Convert additional 5% of MHP 20% thru 2023 Continue to record to Accept new application Revise Rule 44 Continue the MHP conversion program to 2021 Convert all Tier 2 (91 spaces), Tier 3 (346 spaces), and all other Parks. Total 526 spaces Accept new Application Revise Rule 23 Date to Extend the Program Continue beyond 2018 2018 - 2023 2018 - 2023 2018 - 2021 Current Program Status As of 12/31/2016: • Scheduled 150 MHPs (10,652 spaces) • Opted out 26 MHPs • Remaining 124 MHPs (8,910 spaces) • $22.8 M for completed 13 MHPs/635 Gas spaces & 525 Electric spaces • $64.3 M for in-progress work of 28 MHPs/3,170 spaces As of 1/2/2017: • Scheduled 172 MHPs (10,133 spaces) • $18,580,076 for completed 29 MHPs/1,622 spaces As of 12/31/2016: • Scheduled MHPs (3,344 spaces) • $11,541,080 for completed 6 MHPs/411 gas and electric spaces • In-progress work of 16 MHPs As of 2/1/2017: • Scheduled 2 MHPs (67 spaces) • $106,768.97 for completed 0 MHPs/0 spaces • Skylark MHP: Estimated Completion Date: 8/31/2017 • Kings Beach MHP: Estimated Completion Date: 6/31/2018 Cost/Space (Projected) $23,001.00 $22,319.00 $28,529.00 $7,252.00 Cost/Space (Actual) $39,928.00 $11,455.03 $28,080.49 Not available Table 2: Gas Utilities Advice Letter Request and Current Program Status SoCalGas Southwest Gas