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from the submetering. Meter testing and performance requirements are also included. The ordinance incorporates property owner/resident issue resolution through a detailed explanation of notification and billing practices. To fit within existing building and plumbing codes, the ordinance requires, in applicable situations, that owners or remeterers present building permits in their initial or annual requests to submeter. The Miami-Dade Ordinance is included in Appendix E. The Washington State PUC does not regulate submetering or RUBS, under the Washington Administrative Code (WAC) 480-110-255 section 2(g): the commission does not regulate entities or persons that provide water only to their residents as part of the business of renting or leasing. The agency does allow for submetering and RUBS, however, as well as allowing the selling of water, and the collection of variable, fixed, service, late, and installation fees. The agency notes that they do not regulate submetering due to a potential increase in administrative costs to the utilities. The state code is unclear as to how submetering is regulated. It seems, both according to the code as well as the three public utilities interviewed in Washington, that there are no regulations for submetering, but that it is allowed by the state. In the absence of state regulation in Washington, local governments may step in with regulations on billing allocation, including submetering. In reaction to the potential for fraudulent billing by third party entities, the city of Seattle has implemented an ordinance entitled the Third Party Billing Regulation (Seattle Municipal Code, Chapter 7.25). This ordinance was designed primarily to protect residents from deceptive and fraudulent billing for utilities, but has the ancillary effect of defining that submetering and RUBS are allowed, as long as appropriate notice is given to residents and property owners abide by the rules of unit entry described in the other parts of the Residential Landlord Tenant Act of 1973. The ordinance describes the way that property owners must inform the resident of metering changes, and also caps the amount of money that can be charged as an administrative fee ($2 per utility per month; $5 for all utilities per month). Elsewhere, other localities considering action on billing systems include Howard County, Maryland. During its 2003 session, the Maryland General Assembly considered but failed to act on HB 976, a bill that would have barred any further installation of RUBS systems in the state, and require that any separate utility charges to residents be based upon actual use. Howard County has under consideration a more sweeping set of recommendations from a 236
consumer advisory board working on the issue since 2002. The board has recommended that all new multi-family construction be submetered; all existing apartments be converted to submetering within ten years; and that administrative fees be capped at $1 per unit per month. The city of Ventura may become the first city in California to require submetering in newly constructed apartment buildings. The city council directed its staff to review the issue in 2003, and is now considering a staff recommendation to require meter installation for each new multi-family unit (Ventura County Star, 4-5-04). One additional legislative proposal dealing with submetering should be noted. On February 24, 2004, a bill addressing submetering was introduced to the Minnesota legislature (2003 MN S.B.2281). This bill authorizes cities in Minnesota to establish water submetering programs and create grant and loan programs using federal, state, private, and city funds to assist owners with the financing of submetering projects. TENANT ADVOCACY GROUPS Tenant advocacy groups in the US are dedicated to protecting the rights of people who pay rent for housing. These organizations have an inherent interest in programs such as third party billing for water and wastewater that directly impact renters. To further explore how utility billing affects residents, tenant advocacy groups and organizations were contacted by the research team. The investigation aimed to find out if tenant organizations have taken any stance on submetering and RUBS, and what action (if any) has been taken by these groups. Over 60 tenant organizations across the country were contacted by phone or e-mail in 2003. The effort yielded responses from 20 organizations. Respondents ranged from those who were barely aware of submetering and RUBS to others who were actively involved with these billing systems. Nine of the respondents reported that they were not involved with any of the issues associated with separate utility billing. 37 Of these respondents, most indicated that they had not been confronted with the issues of submetering or RUBS, and that they focused their efforts on other issues. A representative from the Ecumenical Community Development Organization of New York said, “Most of our advocacy is entered into to address immediate needs of affordable, 37 The organizations were California Coalition for Rural Housing (CA), Coalition for Economic Survival (CA), Santa Monicans for Renters Rights (CA), People's Regional Opportunity Program (ME), Minnesota Housing Partnership (MN), North Carolina Low Income Housing Coalition (NC), Ecumenical Community Development 237
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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
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Table 5.33 Comparison of water savi
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180
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sector only reduced usage by 18% (A
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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
Page 262 and 263: 210
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 280 and 281: DISCUSSION - KEY EXAMPLES OF STATE
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 290 and 291: clean and decent housing or the lac
Page 292 and 293: 240
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
Page 330 and 331: Fixed rates - Part of a master mete
Page 332 and 333: Total-capture submetering - a type
Page 334 and 335: 282
Page 336 and 337: Corral, L.R. 1997. Price and Non-Pr
Page 338 and 339:
McClelland, L. 1980. Encouraging En
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Young, C.E., K.R. Kinsley and W.E.
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