Trailer Parking (MHP) (2023)

The Security and Enforcement Department (SED) is responsible for ensuring the safety of natural gas systems with main meters in caravan parks. SED's Gas Safety and Reliability Section (GSRB) controls trailer parks that take natural gas through the main meter and then distribute it to park residents through their own underground piping system.

The GSRB also controls the systems where Liquefied Petroleum Gas (LPG), ie propane, is distributed from the main tank through underground pipelines to various customers. The SED has jurisdiction over propane main tank systems serving two or more customers in an RV park or 10 or more customers in residential or commercial districts.

The GSRB currently controls more than 2,100 mobile park operators and 600 propane operators on a risk-based schedule of at least seven years. Inspections consist of reviewing operation and maintenance documentation, evaluating emergency procedures, and conducting field inspections of gas or propane installations.

What regulations must the operator of a small natural gas or propane plant comply with?

• Each operator must prepare and follow written procedures to perform the following tasks:
  • operations and maintenance
  • emergency response
  • operator qualification
  • Distribution Integrity Management (main meter gas operators are exempt from Distribution Integrity Management Program (DIMP) requirements effective March 12, 2021)

• Each operator must also maintain all records required by the above procedures for review by GSRB/SED inspectors.
• On an annual basis, each operator must submit an annual report to SED describing its system, number of customers and dates of the last leak test and cathodic protection.

Blank MHP annual report form

Blank propane annual report form

How to prepare an operation and maintenance (O&M) plan.

Title 49 CFR 192, section 192.605 requires each operator to prepare a written manual of procedures for operations, maintenance and emergency response. The GSRB has produced a sample guide to help small operators prepare their own Operations, Maintenance and Emergency Plan (OM&E), Operator Qualification Program (OQ) and Distribution Integrity Management Program (DIMP). This guide provides information on what to include in your plans. Many third-party vendors can also help you with your OM&E plan, OQ program, and DIMP.

Section 114 of the 2020 PIPES ACT Guidelines for Primary Measured Natural Gas Systems

Resources

To help small utilities and operators, the US Department of Transportation -Hazardous material and pipeline safety managementpublishes guides for small operatorsnatural gasEUpropanesystems.

Each year, the Gas Safety and Reliability Branch (GSRB) of the SED organizes seminars for small gas system operators on federal compliance.

Association of western prefabricated houses(WMA)represents the interests of caravan park owners. Visit the website for a list of duct service providers.

Western Propane Gas Association(WPGA)represents the interests of propane sellers.

Golden State Manufacturers League Owners(GSMOL)represents the interests of people living in mobile homes.

History

public utility code,Sections 4351 to 4360, grants jurisdiction to the California Public Utilities Commission over the safety of natural gas systems with main meters in trailer parks. In January 1995, the Commission also assumed jurisdiction over the safety of main propane tank distribution systems. Assembly Act 766 (Hauser) adopted the Public Services CodeSections 4451 to 4465giving the Commission jurisdiction over propane main tank systems serving 10 or more customers outside an RV park or two or more customers inside an RV park. The Gas Safety and Reliability Commission (GSRB) division enforces federal pipeline safety regulations through audits of jurisdictional MHP and propane main tank systems. Audits consist of reviewing operational and maintenance documentation, assessing emergency procedures and carrying out field inspections at gas distribution facilities. If irregularities are found, the operator receives an inspection form with a request for corrective action within a specified period. If the operator complies with the recommendations and reports the corrective actions to the inspector, the inspection is closed. If the operator does not comply with them, he may be fined and fined.

In Resolution SU-24 of December 17, 1993, the Commission delegated to the GSRB the power to sanction and impose fines on MHP operators for non-compliance with pipeline safety regulations. ResolutionUSRB-001dated July 31, 2008 delegated powers similar to the GSRB to operators of large propane tanks. These fines cannot exceed $1,000 per day and $200,000 per violation. When imposing fines, the GSRB considers a number of factors, including the severity of the breach and the operator's compliance record. There is an appeals process.

public utility codeSection 2791end construction of campervan parks with main meter. This requires occupants of trailer parks constructed after January 1, 1997 to be serviced directly by gas and electricity serving the area.Sections 2791 to 2799describe the process by which RV parks with existing prime meters can be converted to direct utility services. The GSRB encourages such conversions. As the utilities are dedicated exclusively to providing gas and electricity services, a consistently high standard of maintenance and safety is guaranteed. Benefits for metered farm operators include relief from increasingly complex and demanding federal pipeline safety regulations and equally complex service billing requirements.

The Commission assumed jurisdiction over the safety of the main metered propane distribution systems in January 1995, as mandated by Act No. 766 (Hauser). The GSRB operates a propane safety program similar to the trailer park safety program, scheduling a safety inspection of each jurisdictional system at least once every five years to ensure compliance with Federal Pipeline Safety Regulations adopted by the Commission under General Regulation 112-F.

The GSRB is required bySection 4353(b)inspect MHP gas systems at least every seven years in accordance with a risk-based inspection schedule. More than 2,800 MHP are currently under the Commission's jurisdiction.Section 4453(b)requires the GSRB to inspect major propane tanks every seven years according to a risk-based inspection schedule. There are currently over 600 propane operators in the Commission's database.

On January 8, 2008, the Commission approved aresolutionauthorization of GSRB staff to appoint propane operators who do not comply with Commission directives.

user fees

The Commission is a user funded agency and charges based on the number of customers served by the main MHP or metered propane system. These charges are included in the main meter bill for natural gas customers and can be transferred to customers using sub-meters. The GSRB invoices propane main tank systems each year at the time the annual report is submitted.

CPUC is currently running an extended Mobile Home Park Utility upgrade pilot program to convert major gas and/or electric appliances to direct utility services. Decision 20-04-004 established a 10-year MHP modernization program and new orders will be accepted from January 1, 2021. The GSRB is currently working with utilities to establish a timeline for the implementation of the new program.

For more information about the program, click on the link below:

• Parking Utility Modernization Pilot Program for Mobile Homes