national multiple family submetering and allocation billing program ...

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DISCUSSION - KEY EXAMPLES OF STATE AND LOCAL POLICIES It is clear from the foregoing that the regulatory environment for multi-family water and wastewater billing systems is unsettled, both at the federal level and in many states. To further understand regulatory frameworks and issues, it is helpful to outline the broad policy directions taken thus far by states, based on the responses to the surveys and information in the available literature. A limitation of the survey framework described above is that it reports perceptions of individuals regarding the submetering and RUBS regulations. To enhance the usefulness of this policy overview, follow-up interviews and background material (such as previous surveys and state specific literature searches) were used in the formation of this typology. At least five types of regulatory environments are identified in this discussion: ! Landlord/Tenant Law ! Public Utility Regulation ! Safe Drinking Water Regulation ! Weights and Measures Regulation ! Local policy, legislation in progress, or no policy Landlord/Tenant Law In Arizona, submetering and RUBS are regulated under the Residential Landlord and Tenant Act – 2000 revision (Arizona Revised Statute Title 33, Chapter 10 33-1314.01). Under this act, the building owner is allowed to submeter or allocate billing to tenants. Owners are not required to report submetering to a state agency under the code. As long as the billing measure is clearly stated in the landlord/tenant agreement, the obligation of the building owner has been satisfied. The relative simplicity of this code is likely responsible for the lack of confusion on the part of utilities. Three utilities were interviewed in Arizona, and although none of them referred to the code, all understood that submetering and RUBS were allowed, and that individual utilities were not responsible for installation or maintenance of metering equipment. One of the utilities, the City of Tucson, does offer individual meter installation service to building owners for a fee. The Phoenix City Code (Section 6. Subsection 14-445) for the rental, leasing, and licensing for use of real property requires a multi-family building owner to pay .08 percent of the gross income from the rental property in taxes. Charges that the owner collects for utilities are 228
considered part of the owner's gross income. Part (b) of the subsection indicates that if individual meters have been installed for each dwelling unit and the owner does not charge for more than the cost of water, the revenue collected is not considered part of the gross income. The residential landlord-tenant code of Delaware (25 Del. C. Section 5312) authorizes water submetering in multi-family buildings, if separate charges are provided for in the rental agreement. A property owner cannot charge more than the actual cost of utility service to the resident. The "metering system" may be inspected and must be approved by the state's Division of Weights and Measures. All other aspects of the law fall under the jurisdiction of the Consumer Protection Unit of the state Attorney General's office. The code also stipulates that except for "metering systems already in use prior to July 17, 1996," a property owner may not separately charge residents for utility service unless that service is separately metered, language that clearly bars new RUBS systems from being initiated. Under Delaware’s system, residents are allowed to request testing of the meter, which is provided by the owner, and the Consumer Protection Unit is authorized to conduct tests on the premises. If the submetering equipment is found to be accurate, the renter is responsible for paying for the testing. If the device is inaccurate, the cost of testing and replacement is covered by the owner. Notably, Delaware's statute explicitly bars a property owner who submeters from being deemed a public utility, and removes submetering practices from the jurisdiction of the Public Service Commission. Mississippi's recently enacted statute (SB 2797 2002) specifically authorizes submetering of multi-family water and wastewater service in the interest of the conservation of water resources. Property owners seeking to submeter must obtain an acknowledgment of the submetering arrangement in writing from the resident, and charges are capped at the pro rata share of all water and wastewater services used by residents. Property owners may not disconnect water and wastewater service for nonpayment of submetered bills, and submeters must meet "standards for accuracy" of the American Water Works Association. Illinois’ Tenant Utility Payment Disclosure Act (765 ILCS 740) requires that apartment building owners and condominium associations provide residents and condominium owners with the formula for allocating the cost of utility services from a master meter, in writing, before demand for such payments can be made. Copies of the public utility bill must be made available upon request. Charges by apartment owners to residents may not exceed the total public utility 229
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NATIONAL MULTIPLE FAMILY SUBMETERIN
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CONTENTS LIST OF TABLES............
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Matched-Pair Analysis .............
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LIST OF TABLES Table ES.1.1 Breakdo
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Table 6.6 Elasticity values, analys
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Figure 4.30 RUBS water bill #6 ....
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investigated local water savings as
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We are grateful to the members of a
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quantitative aspects of separate bi
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3. Owner/postcard survey: To identi
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"averages" of impact property water
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in-rent properties, others used the
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of these models included the billin
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70 Average Annual Water Use Per Uni
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COSTS AND BENEFITS Beyond quantifyi
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service charge, then the resident w
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Billing Method Efficient Fixtures?
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70 Avg. Water Use per MF Unit (kgal
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REGULATORY FRAMEWORK REVIEW The fra
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Table ES.1.12 NSUAA Summary of Stat
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above, the researchers offer the fo
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service is preferable, and would he
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practices (BMPs) should be implemen
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infrastructure of the building and
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multi-family housing. The transfer
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CHAPTER 1 INTRODU CTION More and mo
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In 1998, 15.0%, or 15.4 million, of
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TERMINOLOGY AND DEFINITIONS OF BILL
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submetering. With utility-submeteri
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all the two bedroom units for $20 p
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HOW TO USE THIS REPORT This report
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CHAPTER 2 LITERAT URE REVIEW As the
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A review of the literature unearthe
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The price elasticity of water deman
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expected. Additionally, McClelland
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submetered and five control (in-ren
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Another study might want to target
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CHAPTER 3 RESEARC H METHODS, APPROA
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1. Selection of participating study
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STUDY SITE SELECTION The Study aime
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Figure 3.2 National Multiple Family
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Matched pair protocol/survey - conf
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information given the available bud
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survey. Service companies that prov
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in “business to business” calli
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MATCHED PAIR SAMPLE The purpose of
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The second part of the visit requir
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epresentative of a known population
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51 Table 3.7 Postcard survey statis
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Table 3.8 Comparison of annual wate
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postcard survey. Nevertheless, exam
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confidence interval ranged from 49.
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particular property (e.g., the mont
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State PUC officials - water commiss
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10. The PROPID number appearing on
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These costs represent the commodity
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The postcard survey provided inform
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Table 4.4 Average number of units f
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Two-thirds of the properties that r
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Percent of Surveyed Properties with
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$700 Average Rent Per Bedroom ($) $
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Percent of Surveyed Properties with
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Impact properties were also more li
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Table 4.8 Issues considered before
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Percent of Surveyed Impact Properti
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60% Percent of Surveyed Properties
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From the visits, it was found that
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100% Percent of Surveyed Residents
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Roughly similar proportions of resi
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inserts for toilets (21%) or low-fl
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proportion were unsure, 37% from su
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Table 4.18 Ownership and rental rat
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Figure 4.17 Submeter water bill #1
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wastewater rates are not shown so t
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Figure 4.23 Hot water hybrid water
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RUBS Sample Bills Seven sample RUBS
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wastewater rates are not shown so t
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Figure 4.28 RUBS water bill #4 from
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Figure 4.30 RUBS water bill #6 RUBS
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directly to and then paid by the th
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never subtracting for common area w
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Late Fees At the start of water bil
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124
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intuitively clear, and matches comm
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Indoor water use was normalized on
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Table 5.3 Summarized water use anal
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easonable assumption since there is
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Figure 5.1 shows the frequency dist
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40 Difference in Annual Water Use p
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after 1995. By including only those
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Table 5.11 Statistical tests compar
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Factors that Influence Water Use Th
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Table 5.12 Association of categoric
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Indoor Water Use per Unit in 2001 I
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Table 5.13 Continuous factors from
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Multivariate Models to Determine Im
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properties built before 1995 were c
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A = Beta coefficient for “Propert
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substantially reduces the sample si
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Table 5.17 Model #2 coefficients an
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0.00 indicating that whatever fit d
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commodity charge for water and wast
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properties having generally lower w
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110 Average Annual Water Use Per Un
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analysis, intended to control best
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Table 5.27 Paired samples test, all
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Table 5.30 Estimated water use befo
Page 230 and 231: Table 5.33 Comparison of water savi
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Page 234 and 235: sector only reduced usage by 18% (A
Page 236 and 237: Table 6.1 Avoided costs from submet
Page 238 and 239: submetered. Complete responses of c
Page 240 and 241: included in this cost/benefit analy
Page 242 and 243: Table 6.3 Cost and benefit for owne
Page 244 and 245: Perceived Concerns In the resident
Page 246 and 247: With a service fee, residents could
Page 248 and 249: Table 6.4 Economic return for a res
Page 250 and 251: ANALYSIS OF PRICE ELASTICITIES Econ
Page 252 and 253: concluded that if a single elastici
Page 254 and 255: esults from this analysis point to
Page 256 and 257: over which they have control than d
Page 258 and 259: According to the basic consumer cho
Page 260 and 261: The consumer choice problem can be
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Page 264 and 265: water systems from compliance with
Page 266 and 267: and methods of practice. NIST publi
Page 268 and 269: Table 7.1 NSUAA Summary of State Re
Page 270 and 271: New Surveys of State Agencies and W
Page 272 and 273: the AWWA WaterStats 1999 database.
Page 274 and 275: Measures, which dispatches a public
Page 276 and 277: Mississippi, Missouri, Pennsylvania
Page 278 and 279: 226 Table 7.6 Summary of utility re
Page 282 and 283: ill. Condominium associations are g
Page 284 and 285: under construction after January 1,
Page 286 and 287: Weights and Measures Regulation In
Page 288 and 289: from the submetering. Meter testing
Page 290 and 291: clean and decent housing or the lac
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Page 294 and 295: NATIONAL ORGANIZATIONAL STRUCTURE F
Page 296 and 297: complaints in all 50 states and app
Page 298 and 299: - Meters must demonstrate in testin
Page 300 and 301: - Plumbing systems are space constr
Page 302 and 303: (2) Twisted or kinked flex supply l
Page 304 and 305: 252
Page 306 and 307: Estimated Water Use By Different Bi
Page 308 and 309: there are clear benefits to these s
Page 310 and 311: study site. These values were then
Page 312 and 313: immediately strengthens the owner's
Page 314 and 315: among the nation's key strategies f
Page 316 and 317: all repair and replacement decision
Page 318 and 319: These findings underscore the obser
Page 320 and 321: varies with volume of use) for mult
Page 322 and 323: Recommendation 6 - Efficient plumbi
Page 324 and 325: financially responsible for their o
Page 326 and 327: individual unit, the volume allocat
Page 328 and 329: RECOMMENDATIONS FOR FURTHER RESEARC
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Fixed rates - Part of a master mete
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Total-capture submetering - a type
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282
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Corral, L.R. 1997. Price and Non-Pr
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McClelland, L. 1980. Encouraging En
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Young, C.E., K.R. Kinsley and W.E.
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