national multiple family submetering and allocation billing program ...

sector only reduced usage by 18% (AWWA WCD 2001). This result is not surprising since
master metering does not provide the end users (the residents) with a price signal and because
emergency demand reduction typically comes from reducing outdoor irrigation and multi-family
use is predominantly for indoor purposes. It is thought that direct billing could make multifamily
customers more aware of water usage and more responsive to drought rate increases. If
the utility were directly involved with billing, bill stuffers could inform the public of drought
severity, as well as provide conservation tips and other educational materials. Utilities have
historically been hesitant to take on the task of individual metering of multi-family units. It is
uncertain whether cooperative arrangements between utilities and third party billing companies
could be reached so that educational bill stuffers could be forwarded to privately billed
customers during shortages. Since many different billing companies operate in each service area
coordinating such an effort would be a challenge.
Perceived Concerns
Water utilities have not led the way for individual metering in multi-family housing for a
variety of legal, liability, and revenue reasons. Many utilities have financial and logistical
concerns over the prospect of substantially increasing their current client base. The multi-family
sector has a high resident turnover rate, which would require for some utilities to bill more
frequently. Individual customer billing in the multi-family sector also has a higher uncollected
bill rate, which would have financial implications for utilities. Also, utilities are generally only
responsible for the water line up to the master meter, so if utilities installed individual meters
within a property, leaks within the property could cause access and liability issues. In addition,
lack of regulation of the RUBS and submetering industry limits legal protection for utilities.
If future legislation does require water utilities to become directly involved in
submetering, more concerns will inevitably surface. Plumbing configuration will become more
important, as utilities opt for the best placement of meters to insure efficient reading. Also,
utilities will have to rethink how the rate structures will be determined for multi-family
customers that were previously subject to master meter rates. These concerns diminish
considerably when third party companies and owners manage the separate billing independently.
However, as a public service provider, most utilities would want to ensure that any billing
provided by a third party is done in a manner that is fair to their customers.
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