Can RV Parks Submeter Electricity?

Recently, questions about submetering have been swirling around the RV park industry in California. Can RV parks submeter electricity? Well, like all regulatory in California – it depends! 

Utilities are regulated by multiple agencies; the Public Utilities Commission (PUC), regional utility departments such as Pacific Gas and Electric (PG&E) and Southern California Edison (SCE), local utility departments, and Weights and Measures. 

Weights and Measures inspects the equipment – in this case, the electrical pedestals. The PUC offers code and standards to PG&E, SCE, and the local agencies similar to the way that a set of bylaws dictates how an organization can run. PG&E, SCE, and/or local agencies set the policies that get applied to the process. 

Rule 18 is the section of code or policy that applies to submetering of RV parks, along with marinas, small craft harbors, and cold-ironing load. Each agency can apply to the PUC for a Rule 18.

So, yes, it depends. 

​Each agency can write Rule 18 to meet their needs. If you have parks across the state, you may be dealing with multiple agencies, each with a unique policy pertaining to Rule 18. 

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In the case of PG&E, Rule 18 states that:

• Under no circumstances shall an RV park owner/operator install submeters and bill the tenants for submetered energy use unless condition a., b., or c. below applies and the provisions of Section D. below are met:

Item B states that ALL spaces must be rented on a pre-paid monthly basis to qualify for service under Schedule ESR. ESR is the rate schedule. Item C gets more complicated:

• Where a master-metered RV park owner/operator rents RV spaces on a prepaid monthly basis to permanent-residence RV units and on a daily/weekly basis to transient RV units and arranges the electric distribution system in accordance with PG&E's applicable tariffs so that all electricity to the permanent-residence RV spaces is supplied through a separate PG&E meter. In this situation, only the separately metered portion of the RV park where all of the spaces are rented on a prepaid monthly basis to permanent residence RV units can be submetered and would qualify for service under Schedule ESR.

 
So, to answer the question; you cannot submeter in an RV park in California under PG&E Rule 18 unless your park is 100% long term OR your long-term sites are on a separate meter. 

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SCE has a different set of guidance where Rule 18 is concerned. The SCE rate schedule DM special conditions (4,5) states:

4. Qualifying RV Park: An RV park which has at least 50% of its spaces on the same meter occupied at least nine months of the year by a tenant in a Qualifying RV Unit used as a permanent residence and renting on a month to month basis. Such meter shall not include nondomestic enterprises as described in Special Condition 7.
 
5. Qualifying RV Unit: An RV Unit that is used as a permanent single-family residence at the same location in an RV park for at least nine months out of the year. Baseline allocationsshall be based on the number of units that meet this criteria.
SCE will allow submetering as long as 50% of your sites are long term and you follow the rate schedule. 
 
Here’s the bottom line: before electing to submeter, each park must check for a Rule 18 with their utility company to determine what policies have been set regarding submetering in an RV park, and you must follow the appropriate rate schedule. We will have more information about submetering on CampCalNOW.org very soon, but in the meantime, please feel free to call the office with questions.

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