In the hot summer months, Jose Verdugo had a strategy for how to best cool the mobile home he shared with his wife: turn on the window air conditioner in one room for an hour or two when just coming home, turn on the ceiling fans and open all the doors.
“Cool it off, and it will be ok for a couple more hours before you have to turn it on again,” Verdugo said. “We’re really frugal, and we got a swamp cooler. We only ran the AC unit like a couple hours during the course of the day just to get cooler.”
Most months in the summer of 2024, his electricity bill was somewhere around $60 a month.
Then one August afternoon, the manager at his 55+ mobile home park dropped of a bill that baffled, and then concerned, Verdugo: his electricity bill due Sep. 1 had ballooned to $416.19.
Verdugo knew something was very wrong at Flowing Wells Mobile Gardens.
“It’s virtually impossible. Everybody already knows that a mobile home will not generate that much, even if you’re running your AC all the time,” says Verdugo, a resident of the north side park.
If that wasn’t strange enough, the empty mobile home Verdugo inherited from a neighbor he helped care for in the final years of his life had a $311.29 electricity bill due in September.
“Nobody was living in there since July 13, and the only electricity (that) was being generated was from the refrigerator,” he says, throwing up his hands in frustration.
That moment would set off a months-long quest for answers, pitting Verdugo and his neighbors against an antiquated utility system with a history of overcharging problems and a legal system that leaves some of the state’s most vulnerable residents with few avenues for redress, and can lead to them losing their homes.
In master-meter parks, the utility company owns a meter that measures usage for the entire park, while meters stationed at individual mobile homes and often owned by the park itself measure the usage of individual homes.
Under a process called sub-metering, the manager is then responsible for dividing billing for each individual manufactured home based on readings from the stand-alone meters.
Unlike a direct customer of the utility, residents in master meter parks have no access to direct customer service support from utilities, and must rely on their landlord or park manager to resolve the dispute.
The lack of direct information to tenants makes it difficult to know exactly what causes a utility bill to spike. In the case of Flowing Wells, possible explanations that emerged over several months of eviction court and administrative hearings were a misreading by park staff during the manual meter readings or a mistranscribed number when sending meter readings to a billing service.
In addition, in parks where utility charges are billed as part of their rent, a landlord can take a resident to eviction court.
“If they were a customer directly with the utility, you couldn’t get evicted over a high water bill,” said Raye Winch, an organizer with Poder Casas Móviles, a group of mobile home residents and housing advocates. “A lot of people end up paying bills that they know are incorrect that are hundreds of dollars a month higher because they don’t want to lose their homes.”
Verdugo wasn’t the only one in his park community facing concerns about the park overcharging for utilities.
In the summer of 2024, Verdugo and 35 of his neighbors at Flowing Wells Mobile Gardens, a park specifically for residents over the age of 55, reported unusual electricity charges. The park is owned by Skyline Real Estate, a company with its corporate headquarters in California. Skyline owns over 60 mobile home parks across the United States, with at least 10 others in the Tucson area.
After reaching out to park management for clarification and getting few concrete answers, the neighbors held a meeting to discuss the high utility bills.
On August 31, residents of the park met at the clubhouse, where they held a regular Saturday morning coffee and donuts meeting. They also reached out to the Arizona Association of Manufactured Home Owners, an advocacy group for people who own their mobile homes on leased or rent land.
Kim Lucas, Tucson-area organizer with the group and herself a mobile home resident, was present at the August meeting. Flowing Wells problem was one she was seeing in parks across Tucson and Pima County.
“We’re talking about hundreds and thousands of people that are being overbilled,” Lucas said. “To me, this is unconscionable, predatory elder abuse.”
The residents signed a petition to the Arizona Department of Housing sharing their concerns about the high utility bills, and on Sept. 16 they mailed the petition. The petition was officially filed on Sept. 23.
For Verdugo and the other residents, the stakes were high: hundreds of extra dollars in utility bill payments for seniors on fixed incomes or the risk of losing their housing altogether.
One of their neighbors, Mike, would go through the eviction process as he tried to fight his high utility bill. Less than a year after he first received his unusually high bill, Mike would pass away.
Few avenues to resolve high bills
At parks across Pima County, mobile home residents may struggle with massive and unexpected bills: water bills over $1,000, ballooning gas payments and electricity bills that don’t reflect their expected usage.
Manufactured homes in Pima County make up around 10% of the region’s housing stock, according to county officials.
A 2024 survey by Poder Casas Móviles of 60 mobile home residents in 30 different parks in Pima County, the majority of them Spanish speakers, found 67% of residents reported problems with overcharging for utilities.
Residents who say they overpaid for incorrect utility bills want their money back. They also want public agencies and utilities to implement immediate reforms that strengthen accountability for master-meter customers who want to dispute their utility bills without fear of eviction.
The ultimate fix could come from state regulators, either consumer protection advocates like the attorney general or lawmakers who have the power to mandate all master meter mobile home parks be converted to direct utility, so people like Verdugo can challenge overcharges — without being forced to go through park managers — like most renters can.
In the 50-plus years that mobile and manufactured homes have been part of the Arizona housing landscape, lawmakers have held hearings about addressing the problems with master meter mobile home parks and in 2018 the Arizona Corporation Commission introduced state-mandated safety checks to gas meters in master meter parks.
But unlike some other states, Arizona does not have a state-level fix to protect residents from landlords’ overcharging on utility fees.
If Verdugo and his Flowing Wells neighbors lived in California, they could call a county agency to check the accuracy of their meter readings or file an informal complaint with the state’s Public Utilities Commission. The commission can refer “these complaints to the serving utility to work out with the park management.” And if the landlord uses a third-party billing company, the park management is required to disclose the contact information on residents’ bills.
Under California’s Mobilehome Residency Law Protection Program, residents under rental agreements also can submit complaints related to health and safety, sales or other areas of concern to the state’s Mobilehome Assistance Center, where “staff provides information, coordinates, and other assistance to help resolve these complaints.”
To further protect the rights of mobile home park residents, California lawmakers passed a bill to create a Mobilehome Residency Law Protection Program to help resolve certain disputes between tenants and managements.
California also requires master-meter park owners to provide residents any discounts received for low-income utility customers.
“Under the state Public Utilities Code, master-meter customers (parks) shall charge no more than the local serving utility would charge a resident, including passing through any low-income rebates or discounts,” according to the handbook.
In Arizona, tenants in traditional homes who want to dispute their utility charges must “first object in writing to the landlord regarding the utility billing. If the dispute is not resolved, the tenant may file a civil complaint in justice court to enforce this section,” according to the Arizona Residential Landlord and Tenant Act.
The Mobile Home Parks Residential Landlord and Tenant Act does not have comparable language.
Some Arizona mobile-park landlords have raised concerns that converting dated master-meter systems is cost prohibitive. Under a decade-old program in California, local utilities carry the construction costs of converting master meters to individual meters.
Other states prohibit sub-metering in general. In Massachusetts, electricity sub-metering isn’t allowed because it is the re-selling of a utility.
And while Arizona is very unlikely to get new master-meter parks — Arizona Administrative Code already prohibits master meters in new mobile home parks or expansions of existing parks, and Tucson Electric Power and Southwest Gas won’t hook up new utility service to a master-meter park — organizers say enough master-meter parks exist that thousands of residents are impacted.
An uncertain regulatory environment
When they first got their high utility bills, Flowing Wells residents trickled into the office of park manager Brianna Hall one by one. They called Brianna’s father, regional manager Mike Hall, and rang Skyline Real Estate’s regional office.
Skyline Real Estate and local park management did not respond to multiple requests for comment.
“When those bills came the first day, everybody that had those high bills started going into the office and screaming and complaining,” Verdugo says, describing an atmosphere of confusion and concern among the mostly fixed income residents at the 55-and-over community.
By September, they signed a petition and filed a complaint with the Arizona Department of Housing. The core of that petition was the argument that the Mobile Home Parks Residential Landlord and Tenant Act placed a limit on how much a park could bill for utilities, and the unusually high bills that landed on residents’ doors were too high.
“All of us were really morbidly pissed off,” Verdugo says.
The issues with their bills were varied — some had mismatched numbers between the end of the billing period and the start of the next. Some bills were hundreds of dollars higher despite residents reporting a minimal change in usage, according to bills analyzed by Poder Casas Móviles.
What the residents had in common was that pleading with the park manager to explain the discrepancy seemed to be their only recourse. The electricity meters stationed at individual mobile homes in Flowing Wells park were not owned by the utility. Skyline Real Estate employs the park manager who takes reading from residents’ meters and submits those numbers to a third-party billing platform.
The Mobile Home Parks Residential Landlord and Tenant Act includes language on utility billing that says the “the landlord shall not charge more than the prevailing basic service single family residential rate charged by the serving utility or provider.” Tucson Electric Power releases residential rate schedules for electricity usage by master meter customers in Tucson and Pima County, which show the expected charge for a certain number of kilowatt-hours of usage.
The law also says a landlord must state the opening and closing meter readings, and the dates of the readings, at each billing period. The bill should also generally show the computation of the charge in accordance with the utility company’s billing format.
How this is followed at the park level varies widely, say organizers.
Arizona Luminaria contacted public and utility officials to determine whether a pathway existed to manage utility complaints from individuals served by master-meter park owners. In most of those cases, the regular routes for direct utility customers are not applicable to people who receive utilities through a master-meter system.
Tucson Electric Power, which has 125 master-meter communities in its service area, says it has no role in billing individual tenants or analyzing usage beyond the park-wide master meters it owns.
“TEP has no specific insight into how energy is used after delivery to a customer’s service address,” spokesperson Joe Barrios said. “TEP has no recommendations on this matter. Mobile home communities or apartments with master meters determine their own billing procedures. They are also responsible for operation and maintenance of their own equipment.”
TEP serves more than 410,000 residential customers. That could include a large family in a home or a single person living in an apartment, but all are direct, individually metered customers of TEP.
Direct utility customers can make a complaint to the Arizona Corporation Commission about rates or the responsibility for a bill.
The Corporation Commission, in an April statement to Arizona Luminaria, said they would refer a customer living in a mobile home community with a master meter to the owner or manager of the park.
“We typically hear from a consumer that is on a master meter due to being in an apartment complex, mobile home and/or RV park, golf course or a condo. These folks are not customers of the master meter,” Arizona Corporation Commission spokesperson Nicole Garcia said. “We would refer them to the owner or property manager to resolve billing issues.”
The Arizona Department of Housing accepts petitions and processes the $50 payment for complaints related to the Mobile Home Parks Residential Landlord and Tenant Act, like that filed by the Flowing Wells residents, but the hearings are adjudicated by the Arizona Office of Administrative Hearings.
The Department of Housing does oversee installation permits for when a manufactured home is moved into a park and ensures that utilities are safely connected, but has no utility-related authority beyond the installation.
The state-level Residential Utility Consumer Office, which represents the position of utility customers in efforts to establish utilities’ rates and charges, also does not intervene in utility rate disputes between individuals residents and park managers.
An additional hurdle for residents is that even though an employee of the park may physically walk around a mobile home community and read each individual’s utility meter, they often work with a third-party billing company to bill for the utilities.
Flowing Wells residents said they received their utility bills through Spectrum Utilities. The company has offices in New Jersey, Ohio, and Arizona and describes their sub-metering services as “utility cost recovery” for park owners.
Spectrum’s online pitch says its target markets are manufactured housing communities and other multi-family residential properties, and the company helps clients find financing solutions to “make the strategic move to submetering.”
“We achieve value for our clients through recovering their utility costs (for water & sewer, gas and electric), eliminating operating costs (for meter reading, billing, and processing), and minimizing utility consumption rates,” Spectrum writes on its website.
The Better Business Bureau notes that Spectrum is not a BBB accredited business and marks the company with a B- for failing to respond to a customer complaint. “My Oct. 1 and Nov. 1 rent bills are wrong, and I have no one to discuss this with. You call Spectrum, she tries to hang up the phone fast,” said the 2023 complaint.
Spectrum did not respond to repeated requests for comment.
Residents struggle in evictions over contested utility bills
In the case of Flowing Wells, most residents paid their unexpectedly high utility bills.
Several residents still faced retaliation because they organized against utility overcharging and for other tenants’ rights, said Winch, the housing advocate with Poder Casas Móviles. Winch said there is a dangerous loophole — tied to how Flowing Wells billed utility charges as part of rental payments — that allows landlords to kick out residents.
“If someone is being evicted within six months of having made a formal complaint, they are legally protected under the Mobile Home Park Landlord Tenant Act against retaliation,” Winch said. “However, that doesn’t apply in non-payment of rent.”
Under Arizona law, mobile home tenants are protected from retaliation after filing a complaint with government housing code officials, the landlord or a court, as well as for becoming a member of a tenants union or similar organization. Specifically, landlords “shall not retaliate by increasing rent or decreasing services or by bringing or threatening to bring an action for eviction,” the law states.
But when park owners tack utility fees onto rent bills and a resident doesn’t pay utility charges that are in dispute, a predatory mobile home park owner can claim the tenant is in default of rent and evict them regardless of a standing complaint.
Residents can still sue the park owner in small claims court to recover damages for violating utility billing policies or other issues outlined in rental agreements but that’s burdensome for a low- or fixed-income mobile home resident who’ve been evicted from their home.
The case of one Flowing Wells resident, Mike, shows the difficulties of challenging utility bills during an eviction proceeding and the extent to which the burden of proof in a utility overcharging case falls on residents.
Mike, who asked that his last name not be used in order not to jeopardize his future housing options, had electricity bills due June and July that fluctuated between $165 and $179. Then he received an unusually low bill of $40.80 due August. That followed a skyrocketing bill due Sept. 1, of $656.92, according to documents shared as part of the Flowing Wells administrative hearing.
“I had to have a machine shop attached to my house for that kind of electricity and I know that’s not right,” Mike said.
In the summer of 2024, Mike was among the residents at Flowing Wells who went to the manager to complain about a high bill. He was also one of 36 residents who had signed the complaint to the Arizona Department of Housing in September.
He paid his bill, including lot rent, home loan and his undisputed utilities on Sept. 6 by check, according to his statement during eviction court. That check was accepted by the park manager, Mike said.
Soon after, Mike said his check for September was returned to him. Later that month, he received a 30-day notice for nonpayment of rent.
Mike was taken to court by the two companies that have formal ownership of Flowing Wells — Central MHP LLC and Flowing Wells Estates LLC. The park representative was regional manager Mike Hall.
In November, Mike, the Flowing Wells resident, faced Hall and park owners in a Tucson courtroom.
Mike was able to secure a pro bono lawyer, who made the case he was being unfairly overcharged for utilities — and he was being pushed out of his home in retaliation for joining a group of vocal tenants organizing for their legal rights.
Hall said during the hearing that the bill discrepancies could have resulted from an error when park staff was reading the meter. “It could be as simple as a misread or a misinterpretation of a number,” said Hall during the hearing.
Still, that information didn’t change the outcome. Judge Ron Newman, who oversees Pima County’s evictions court, said multiple Flowing Wells residents with the same problem didn’t change whether Mike should have paid rent.
“I understand that the majority of residents feel that the excessive utility bills are unwarranted,” said Newman during the November hearing. “I sympathize, but I have to get to the determination of what the actual issue is in the rent.”
Mike, along with other Flowing Wells residents, were awaiting a hearing related to their complaint to the Arizona Department of Housing about the high bills in their Skyline Real Estate park. That fact was immaterial, Newman said.
“A complaint has been filed and is pending, so it hasn’t even been set — I don’t think that is appropriate for this hearing,” Newman said. “The landlord is still permitted to go forward for non-payment of rent.”
Neither Skyline Real Estate nor attorneys with Zona Law Group, who represented the park, responded to multiple requests for comment.
Newman also dismissed concerns about the high utility bill because he said Mike and his attorney didn’t offer enough evidence to explain why the bill was so high.
“Has anyone come out from Tucson Electric Power? Has anyone checked the meters? Has anyone done an audit?” Newman asked. “I don’t have any of that evidence. That is what I need in this particular case. I’m sympathetic to the tenants, but unfortunately that is not why we’re here.”
Ultimately, Newman ruled in favor of the Flowing Wells park manager on Jan. 14.
“The evidence presented by defendant does in fact indicate that his electrical bills have been higher, however, this is not a defense for withholding rent,” wrote Newman in his ruling.
Mike was ordered to pay $5,458.31, which included $2,850 in back rent, $370 in late fees, $115 in costs and $970 in attorney’s fees.
Months later, a hearing for residents moves ahead
More than six months after Flowing Wells residents mailed their complaint to the state department of housing, they had their first hearing with the Office of Administrative Hearings, the agency charged with hearings related to how Arizona residents experience state regulations.
A handful of residents gathered in the mobile home park’s recreation room and crowded around Winch’s computer to watch it online.
The clubhouse is a squat brick building, and the bright midday sun filtered through the rectangular windows. The air conditioner wall unit read 69 degrees but as the hearing went on it climbed to 81 degrees.
The argument of Winch and Flowing Wells residents in the April 14 hearing was that the park had violated the Mobile Home Parks Residential Landlord and Tenant Act in regards to the high utility bills. Under the complaint process, the landlord had 20 days to respond to the department.
The hearing focused on resident testimony. Verdugo, the primary complainant in the case, said he eventually paid his high bill, but it meant cutting back on food and gas.
He told administrative hearing judge Kay A. Abramsohn, along with the regional park manager and an attorney representing the park, that he wanted his bill payment back.
“We weren’t looking to go and sue them for thousands and thousands of dollars,” Verdugo told Arizona Luminaria. “We were just wanting them to reimburse us the amount of money that they overcharged us.”
The second hearing was April 28. It focused on how Flowing Wells residents’ utilities were read. Park manager Brianna Hall said there was likely a mistake. Hall read the meter by hand and could have written down a wrong number. The mistake may also have been on the side of the third-party billing company Spectrum, she said.
“Simply a number was read wrong or misinterpreted, that is really what this all comes down to,” regional manager Mike Hall, and Brianna’s father, said at the hearing. “An error did occur.”
Still, the attorney representing the park, Scott Baluha from Zona Law Group, called the residents’ petition vague. “It makes it very difficult to mount any type of response,” Baluha said in his closing remarks. He also argued any assessment of the bills must be done on a one-by-one basis, and “can’t be done as a whole.”
The administrative hearing judge, Abramsohn, said she would make her determination in several weeks. Even as they felt heard, some residents expressed frustration with the timeline. Several residents had left, while others were working to sell their homes amid the tension over the utility conflict.
“We just want justice to be prevailed,” Verdugo said in his final hearing statement.
Organizing landscape shines a light on utility bill issue
Residents’ push for their rights is finally garnering attention from local officials and has brought utility-overcharging issues to the fore.
Last fall, Poder Casas Móviles coordinated a meeting between Tucson city council member Kevin Dahl and mobile home residents struggling with high utility bills. In December, residents met with state regulators during a meeting at Valencia Library. And in March, a group of residents attended a housing justice forum held in Tucson by Attorney General Kris Mayes.
They urged a swift response before more people face eviction.
“You’re our last hope and I’ve been to every department in the state,” organizer and longtime manufactured home resident Mary Alice Theroux said at the meeting. “ Nobody seems to think that they have the authority to enforce the Arizona Mobile Home Landlord-Tenant Act. We desperately need help here.”
Mayes was ready to act. “All I can promise is that I will act as quickly as I can,” said Mayes, speaking to the press after the forum. “We will take this back to the attorney general’s office.”
Mayes is a former member of the Arizona Corporation Commission. During her tenure, she focused on oversight of utilities and had power to address consumer complaints. At the April meeting, she promised to hold utility companies accountable.
“That’s not acceptable,” Mayes said. “I believe there is a massive problem in Arizona.”
For Winch, the competing timelines of Mike’s eviction and the housing department hearing show a system that doesn’t work for residents who receive unusually high or are overcharged for their utility bills.
“They made a complaint in August, and there still hasn’t been a decision made,” Winch said of Flowing Wells residents. “If someone’s being evicted, a Department of Housing complaint isn’t going to address that. People are kind of in a really precarious position.”
Winch last heard from Mike in mid-March, when he texted to let Winch know he was sick but appreciated the ongoing fight around the utility bills. This spring, Winch learned Mike had passed away.
“The stress of losing a home, the stress of going to court and doing all of these things. It’s a real burden on people and I think that human cost here is important,” Winch said.
Verdugo and his wife took out a personal loan to pay the additional $700 in electricity costs in September.
The incident contributed to a strain on their marriage. After the utility bill issue, their relationship broke down. The couple is now separated.
He briefly moved to a shelter, living in a dormitory setting, before finding a Tucson apartment with a roommate.
“I got some stuff and clothing and stuff — put it in the van and I drove away,” Verdugo says of his rushed move out of Flowing Wells.
At his new apartment complex he shares a common wall with neighbors who can be loud, he says. It’s not like living in his own home in a 55-and-over community with people his own age. Still, he’s come to appreciate his space, and his neighbors. He set the photo he keeps of him and his mother atop a speaker in his living room.
Since last summer, some of the meters stationed at residents Flowing Wells homes have been replaced.
It’s been almost a year since Verdugo got that first $400 utility bill. He’s trying to get settled in his new home but after all he and his former Flowing Wells neighbors have been through – some losing their homes, Mike dying – it’s hard not to worry about how the judge will rule.
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