Most manufactured housing communities buy utilities the way a factory does — one large meter at the property line — and then have to work out how to get the cost back from several hundred households who each own their own home.

That single structural fact drives everything in this article. It creates the largest recoverable expense line in the business, the fastest-growing regulatory exposure in the sector, and, in 2025 and 2026, a run of state attorney general actions against operators who got the arithmetic wrong.

This guide covers what master-metering actually means for your books, why manufactured housing utility billing follows different rules from multifamily, the four methods available to recover the cost, the no-markup principle that governs almost all of them, and how to choose the right method for a given community.

Key takeaways

• The community usually owns the pipes. Past the master meter, the distribution system — and every leak in it — belongs to the operator, not the utility.
• There are four recovery methods: bundled into lot rent, allocated by formula (RUBS), submetered by actual consumption, or direct service from the utility to the resident.
• Almost every state that regulates this imposes cost recovery only. Texas, Minnesota, Colorado, Oregon, Arizona, Nevada and California all cap what you can bill at what you paid. Several ban administrative fees outright.
• Manufactured housing is regulated more tightly than apartments in the same state. Arizona permits apartment RUBS with an administrative fee, and bars both for mobile home parks.
• If you run your own water system you are probably a public water system under the Safe Drinking Water Act — at 15 service connections or 25 people.
• Enforcement is now active. Arizona, Minnesota, Colorado and Indiana all produced utility-billing actions or investigations against community operators in 2025–2026.

The structural fact: you are buying wholesale and delivering retail

In a typical apartment building the landlord owns the building, the plumbing, the fixtures and often the appliances. In a manufactured housing community the operator owns the land, the roads and the utility infrastructure — but the resident owns the home, and everything inside it.

That splits the utility system in two at the meter, and the split is written into law. California's Public Utilities Code §739.5 states it plainly: "Every master-meter customer is responsible for maintenance and repair of its submeter facilities beyond the master-meter, and nothing in this section requires a load-serving entity or gas corporation to make repairs to or perform maintenance on the submeter system" (Cal. Pub. Util. Code §739.5). Colorado's Division of Housing describes the same division for water: utilities manage service up to the park's meter, and "parks manage systems beyond the meter to individual pads" (Colorado DOH).

So you buy one bill and you own the network that delivers it. Everything that leaks between the meter and the home is bought and not sold.

How much of the sector is still master-metered

There is no national survey. That is worth saying plainly, because plenty of published guidance quotes a percentage with no source behind it.

The most rigorous jurisdiction-wide count available comes from California, where the Public Utilities Commission runs a programme specifically to convert master-metered parks to direct utility service. Its 2025 priority list identifies 1,526 parks covering roughly 168,400 still-master-metered spaces in that state alone. As of February 2026 the programme had converted 44,673 electric and 51,643 gas spaces, with utilities having invested $1.57 billion in construction and programme management (CPUC, 24 February 2026).

For scale against that: the sector runs roughly 43,000 communities and 4.3 million homesites nationally (Manufactured Housing Institute), housing somewhere between 17 and 22 million people depending on whose count you use — the Environmental Protection Agency has used 22 million, a 2025 Associated Press investigation used 17 million.

And converting out is expensive

One utility's annual report to the CPUC on four converted parks put the cost at $6,225 per space to the meter plus $3,454 per space beyond it — $9,679 per space all in (Southwest Gas MHP Program Annual Report). At a 200-space community that is a $1.9 million project, which is why most master-metered parks stay master-metered and why getting the billing method right matters more than escaping it.

Why manufactured housing is not multifamily

Operators moving from apartments routinely assume the utility rules travel with them. They do not. Four differences matter.

1. You cannot touch the fixtures. In an apartment, a landlord facing high water cost installs low-flow fixtures. In a land-lease community the toilets, taps and water heaters belong to the resident. Your only levers are the distribution system, the billing method and the price signal.

2. Tenancy is measured in years, not lease terms. Moving a manufactured home costs thousands of dollars and often is not physically possible, so residents stay. A billing change is not something a resident absorbs and forgets at renewal — it is a permanent change to a household budget, and it will be contested accordingly.

3. The statutes are separate, and stricter. The clearest proof is Arizona, which regulates both in the same title. For apartments, A.R.S. §33-1314.01 permits submetering or RUBS, allocation by tenant count, square footage, unit type or "other fair method," and recovery of the utility's charges "plus an administrative fee for actual administrative costs only." For mobile home parks, A.R.S. §33-1413.01 requires individual meters, caps the charge at "the prevailing basic service single family residential rate charged by the serving utility," requires opening and closing meter readings and dates on the bill — and authorises no administrative fee at all (A.R.S. §33-1413.01; A.R.S. §33-1314.01).

Same state, same legislature, two different regimes. Anyone who imports an apartment RUBS programme into an Arizona community is in violation on day one.

4. You may be a regulated utility, or a public water system, or both. Whether reselling water makes you a utility is a state question with different answers. California says no, provided you charge what the water corporation would have charged (Cal. Pub. Util. Code §2705.5). Nevada says yes — the PUCN asserts jurisdiction over park landlords reselling utilities under NRS 704.905–704.960 (PUCN Mobile Home Park Guide). Texas requires registration with the commission rather than utility status (16 TAC §24.277).

Separately, and regardless of the billing question: if your community operates its own water source and serves at least 15 service connections or 25 people for 60 days a year, you are a public water system under the Safe Drinking Water Act, with the testing, reporting and notification duties that carries (EPA).

That obligation is widely missed. An Associated Press investigation published in July 2025 found that nearly 70% of mobile home parks running their own water systems violated safe drinking water rules over a five-year period, and more than half failed to conduct required contaminant testing or report results properly. Regulators could not always locate the systems: Utah's database listed four park water systems until a keyword search found 33 more, and Colorado identified 79 parks with unknown water sources after a 2023 testing law took effect (AP, 25–26 July 2025).

The four billing methods

Oregon codifies almost exactly this menu — direct billing by the utility, inclusion in space rent, pro rata division, submetering, or a park-specific method approved by majority tenant vote (Oregon Housing and Community Services).

A caution on adoption data: there is no credible national survey of which method US communities actually use. Vendor blogs quote figures freely; none of them cite a primary source. Treat any percentage you see with suspicion, including ours — we do not have one either.

Allocation and RUBS, briefly

RUBS divides the master bill by a formula rather than by measurement — occupants, bedrooms, square footage, or a blend. Texas, for instance, codifies several permitted formulas and requires the operator to subtract common-area use such as irrigation, pools and laundry before allocating (PUCT Tenant Guide).

It is cheap to start and produces no conservation signal, because a resident's bill does not move when their consumption does. It also carries the most legal exposure of the four. The full method comparison — how each is calculated, where each fits — is in our guide to RUBS versus submetering.

Submetering, briefly

Submetering puts a meter on each homesite and bills actual consumption. It is the only method that produces a real price signal, and the measured effect is large: a Santa Clara Valley Water District study of four parks and 754 installed submeters recorded consumption falling between 15% and 30% per park, attributed partly to the price signal and partly to leaks that only became visible once each home was measured (SCVWD, 2007).

The trade-off is capital, permitting and licensed-installer requirements. Cost per lot, phasing, and how to move residents off a flat fee without a revolt are covered in water submetering for mobile home parks.

The rule that governs almost everything: cost recovery only

If you take one principle from this article, take this one. In most states that regulate manufactured housing utility billing, you may recover what you paid and nothing more. Not a margin, and frequently not even your administrative costs.

• Texas — the owner "may not impose on the tenant any extra charges, over and above the cost per gallon and any other applicable taxes and surcharges charged by the retail public utility." A service charge is capped at 9% of submetering-related costs and barred entirely for LIHTC units and Section 8 voucher holders (Tex. Water Code §13.503).
• Minnesota — a park owner "may not charge a resident a commodity rate that exceeds the commodity rate at which the park owner purchases utility service," and may not charge "any administrative, capital, or other expenses… including but not limited to disconnection, reconnection, and late payment fees." The operator must also supply a sample bill in each of the three months before billing begins, and may not raise lot rent for 13 months after starting utility billing where the lease previously included it (Minn. Stat. §327C.04).
• Colorado — no charge beyond "the actual cost of water billed to the management." The methodology must be reasonable, equitable, consistent and disclosed. You may not bill residents for water lost to a leak in a park water line, and you must notify residents of a known leak within 24 hours (C.R.S. §38-12-212.4).
• Oregon — "A landlord may not make a profit from the utility or service, nor charge the tenant any of the landlord's administrative expenses." Converting to submeters requires a month's notice plus three trial billing periods (ORS 90.568).

The pattern repeats in Nevada, Arizona and California. Where an administrative fee is permitted at all it is small and specific — California caps the mobilehome water administrative fee at the lesser of $4.75 or 25% of the resident's volumetric usage charge (AB 604 Senate Judiciary analysis, 2023).

Two operational consequences follow, and both are systems problems rather than policy problems.

First, your recovery rate is capped at 100% by law. Utility billing is not a profit centre in a regulated state. It is a leak to be closed. The money is in billing accurately and completely, not in marking up.

Second, you have to be able to prove the number. Colorado requires each monthly bill to show the resident's amount, the all-resident total, and the total the management actually paid the provider. Minnesota requires three months of sample bills before you start. Arizona requires opening and closing readings and dates. None of that is reconstructable from a spreadsheet at year end — it has to be produced by the system that issues the bill, at the moment it issues it.

The full state-by-state position, including where RUBS is outright prohibited, is in where RUBS is restricted: utility billing laws by state for manufactured housing.

What is actually going wrong: the 2025–2026 enforcement record

This stopped being theoretical.

Arizona
The Attorney General issued a statewide compliance reminder in August 2025 telling every mobile home park in the state that it "shall not charge more than the prevailing basic service single family residential rate," must show opening and closing meter readings and dates, and must compute charges "generally in accordance with the serving utility company billing format" — adding that overbilling "may also separately violate Arizona's consumer fraud laws" (Arizona Attorney General, 15 August 2025). Two weeks later the office announced an action against a Tucson community that had overcharged residents for water from 2017 through June 2025, with credits issued on September statements — some exceeding $1,000 per household (Arizona Attorney General, 28 August 2025).

Minnesota 
A 209-lot community had submeters installed by an unlicensed out-of-state contractor without permits. The meters leaked. One resident's bill went from $154.67 in January 2026 to $213 in February; another faced eviction over $415.81; the city assessed $22,990 in doubled permit fees and only 129 of 209 units had passed inspection months later (Minnesota Reformer, 23 April 2026).

Colorado
The state's Mobile Home Park Oversight Program logged roughly 373 alleged violations in FY2023–24 across 761 registered parks, including 36 for failure to maintain landlord-owned utility lines, 17 for improper water charges or missing disclosures, and 17 for failure to give timely leak or shutoff notice (Colorado MHPOP Annual Report FY2023–24).

Indiana
The Attorney General sued several community operators in June 2026, with allegations including a water shutoff lasting more than 60 days over unpaid utility bills while residents continued to be billed for rent and utilities (Indiana Public Radio, 5 June 2026).

Read those four together and a pattern emerges that is not really about greed. Three of the four are record-keeping and process failures: an unlicensed install without permits, missing disclosures, no timely leak notice, a rate that drifted above the utility's residential rate over eight years and nobody checked. Utility billing in this sector fails quietly, over years, in the gap between what the statute requires and what the billing process can actually produce.

The other half of the problem: the water you buy and never bill

Cost recovery only matters if you know what there is to recover.

The EPA reports that "on average, 14 percent of the water treated by water systems is lost to leaks" and that some systems have reported losses exceeding 60% (EPA, Water Efficiency for Water Suppliers) — though the agency does not name or date the underlying studies, so treat it as directional. On the household side, EPA WaterSense estimates the average family wastes 180 gallons a week to leaks (EPA WaterSense).

In a master-metered community those two numbers stack, and both land on your P&L. We have not found any dataset giving a typical unaccounted-for-water percentage specific to manufactured housing, and we would not publish one without it. What we can say is that the gap is measurable in your own numbers: total consumption at the master meter, minus total consumption billed to residents and common areas, is your loss. If you are not producing that figure monthly you do not know what your utility line is really costing you. Finding and closing that gap is covered in finding the water you're paying for and not billing.

The cost of not knowing is rising. Combined water and sewer bills across 50 major US cities rose 5.1% in 2025, are up 24.2% cumulatively since 2020, and have risen 207% since 2000 against 93% general inflation (Bluefield Research, 9 March 2026). An unrecovered utility gap compounds at that rate.

Choosing a method: a decision sequence

Work through these in order. The first question that returns a hard answer decides it.

1. What does your state permit for manufactured housing specifically? Not what it permits for apartments. In several states this eliminates RUBS immediately. Check the MH statute, not the general landlord-tenant act.

2. Is the community already master-metered, and what would direct service cost? If the local utility runs a conversion programme, price it. If conversion is uneconomic — and at roughly $9,700 per space it usually is — you are choosing among the remaining three.

3. What does the existing lease say, and what does changing it require? Oregon requires three trial billing periods. Minnesota requires three months of sample bills and freezes lot rent for 13 months afterwards. Colorado requires 60 days' notice to change methodology. These are not formalities; they are the compliance record.

4. What is your water loss? If unaccounted-for water is high, submetering pays for itself twice — once through recovery and once by making leaks visible. If your system is tight and your bills are modest, the capital case is weaker.

5. Can your billing system actually produce what the statute demands? Opening and closing readings with dates. Resident amount, all-resident total, and total paid to the provider on the same bill. Common-area consumption subtracted before allocation. A method disclosed and applied consistently. If the answer is a spreadsheet, the answer is no — and the Minnesota and Arizona cases above are what that looks like eighteen months later.

Where the numbers actually land — recovery rate, payback period and the effect on valuation — is worked through in the submetering business case.

How RIOO handles utility billing

RIOO is a property management platform built natively on Oracle NetSuite, and utility billing is one of the clearest places that architecture earns its keep — because utility recovery is not a billing problem, it is an accounting problem that ends in a bill.

The chain runs: the utility's master invoice arrives as a vendor bill; consumption is captured per homesite or allocated by a stored formula; the resulting charge posts to the same resident receivable as lot rent; and the difference between what you paid the provider and what you recovered from residents is a number you can read off the general ledger rather than assemble by hand.

• Meter reads and allocation are captured against the homesite, so submetered and allocated communities run side by side in one portfolio with different methods and different rates.
• One invoice, one receivable. Lot rent and utility charges bill together to a single resident balance and a single ageing line, rather than a second system that has to be reconciled against the first.
• The vendor bill and the recovery sit in the same ledger, so utility expense and utility income report against each other by community — which is what makes a recovery rate a live metric instead of an annual guess.
• Bill content is configurable per state, so a Colorado bill can carry the resident amount, the all-resident total and the total paid to the provider, and an Arizona bill can carry opening and closing readings with dates.
• Submeter installs capitalise properly. The hardware is a fixed asset with a depreciation schedule, while the water you buy is an operating expense — the CapEx and OpEx split enforced when the invoice is coded.
• Leaks become work orders. A consumption anomaly at a homesite raises a maintenance work order against that homesite, with the cost posted back to it.
• Multi-entity consolidation rolls utility recovery across the LLC-per-community structures most operators run.

The test is simple: can you answer "what did we pay for water last month, what did we bill, and what is the gap by community" without opening a spreadsheet? If you would like to see that against your own portfolio, book a demo.

Conclusion: the money is in accuracy, not margin

Utility billing in manufactured housing is unusual among operating decisions in that the upside is capped by statute and the downside is not.

You cannot mark it up. In most regulated states you cannot even recover your administrative cost. What you can do is recover all of what you actually paid, which almost nobody does, because the losses hide in three places at once: water leaking from lines you own, consumption never billed because nobody measured it, and charges that were correct in 2019 and drifted out of compliance since.

The four enforcement matters from 2025 and 2026 have that in common. None of them look like a deliberate scheme. They look like a process that could not produce what the statute required, running unchecked for years.

So the questions to be able to answer on any community, on any day:

1. What method are we using here, and does this state permit it for manufactured housing?
2. What did we pay the provider last month, and what did we bill residents?
3. What is the gap, and is it leak, mis-measurement or under-billing?
4. Can we produce the bill content our statute requires — readings, dates, totals — from the system, not from a reconstruction?

An operator who can answer those four has turned the largest recoverable expense in the business into a managed line. An operator who cannot is funding their residents' water and finding out during an investigation.

Frequently asked questions

Q1. What is utility billing in a mobile home park?
It is the process of recovering the cost of water, sewer, gas, electricity and trash from residents when the community buys those utilities on a master meter rather than each home being served directly. The operator receives one bill from the provider and recovers it through the lot rent, an allocation formula, or individual submeters.

Q2. Can a mobile home park make a profit on utility billing?
In most states that regulate it, no. Texas, Minnesota, Colorado, Oregon, Arizona and Nevada all limit the operator to recovering the cost actually paid, and several — including Minnesota and Oregon — explicitly prohibit charging administrative expenses on top. Where an administrative fee is allowed it is capped and specific.

Q3. What is RUBS in a manufactured housing community?
RUBS, or a ratio utility billing system, divides the master utility bill among homesites using a formula such as occupancy, bedroom count or square footage rather than measured consumption. It is cheaper to implement than submetering but produces no conservation incentive, and it is restricted or prohibited for manufactured housing in several states.

Q4. Is submetering better than RUBS for a mobile home park?
Submetering bills actual consumption, so it is more accurate, more defensible in a dispute, and produces real conservation. One California study of four communities measured consumption falling 15% to 30% after submetering. The trade-off is capital cost, permitting and licensed-installer requirements.

Q5. Who owns the water pipes in a mobile home park?
Generally the community owns the distribution system past the master meter, and the utility owns everything up to it. That means the operator pays for water lost to leaks in park-owned lines — and in Colorado, may not bill residents for it.

Q6. Is a mobile home park a public water system?
If the community supplies water through pipes to at least 15 service connections, or serves an average of at least 25 people for at least 60 days a year, it meets the EPA's definition of a public water system and carries testing, reporting and notification obligations under the Safe Drinking Water Act.

Q7. Do apartment utility billing rules apply to manufactured housing?
No, and assuming they do is a common and expensive error. Arizona permits RUBS plus an administrative fee for apartments under A.R.S. §33-1314.01, while requiring individual meters and no administrative fee for mobile home parks under §33-1413.01. Check the manufactured housing statute specifically.

Q8. How much notice is required to change utility billing methods?
It varies and can be substantial. Colorado requires 60 days to change methodology. Oregon requires one month's notice plus three trial billing periods before submetered billing begins. Minnesota requires a sample bill in each of the three months before billing starts, and freezes lot rent for 13 months afterwards where the lease previously included utilities.

Q9. How do you calculate utility cost recovery rate in a mobile home park?
Divide the total utility cost billed to residents and common areas by the total utility cost paid to the provider for the same period, by community and by month. The gap is your loss, and it is some combination of leaks in park-owned lines, consumption that was never measured, and charges that were never issued.

RIOO is a property management platform built natively on Oracle NetSuite, used by manufactured housing community operators to manage homesites, lot rent, park-owned homes, utility recovery and multi-entity accounting in one system.