national multiple family submetering and allocation billing program ...

of how well these regulations (or lack thereof) are understood by key staff within the agencies
charged with their administration. Discussion of these discrepancies follows in the final section
of the review.
Bureau of Weights and Measures Results
The state Bureaus of Weights and Measures (BWM) are tasked with regulating
commercial measurement devices used within the states. The survey was intended to canvass the
Bureaus to determine their level of involvement with the submetering of water, their processes
for regulation, and the standards used for regulation. The results, despite being limited (and
perhaps because of it), suggest that state BWMs have not been active in regulating water
submeters. While most respondents identified a standard to be used should they be called upon
to regulate a specific meter, none of the responses indicated that water submeters are frequently
regulated.
A total of 53 surveys were sent out followed by one round of fax follow-ups and one
round of phone follow-ups. The nine responses received are summarized in Table 7.5. The
survey results from respondents from states with BWMs that partially regulate water
submetering through the regulation of submeters, New York, Idaho, and California are
summarized in the following sections.
State
Table 7.5 Survey responses from state Bureaus of Weights and Measures
Allows Submetering
or RUBS
Regulates Water
Submeters
Uses NIST Handbook
for Equipment Standard
New York Yes Yes Yes
Idaho Yes Yes Yes
California Yes Yes Yes
Oregon No Answer No Yes
Arizona No Answer No Yes
Maryland No Answer No Yes
Minnesota No Answer No No
Connecticut No Answer No No
Pennsylvania No Answer No No
New York. The state of New York’s Bureau of Weights and Measures regulates the usage
of water submeters according to the mandatory NIST Handbook 44 standard. The respondent
indicated that the property owner notifies the Public Service Commission (NY PSC) when a
submetering system is placed in service. The NY PSC then alerts the Bureau of Weights and
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