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REGULATORY FRAMEWORK REVIEW The framework of regulations and related policies for multi-family water and wastewater billing systems is complex, quickly evolving, and unsettled, both at the federal level and in many states. During the time this research study has been in preparation, significant changes in the policy framework have been adopted by the federal government, several states, and major local jurisdictions, and important issues remain in flux. Safe Drinking Water Regulation In August 2003, seeking to encourage water conservation benefits attributed to submetering, the Assistant Administrator for Water proposed a significant re-interpretation of the Safe Drinking Water Act regarding submetered systems. In a policy shift that was finalized in December 2003, EPA noted that the "sale" of water had not actually been defined in the Safe Drinking Water Act, and that henceforth a multi-family property with submetered billing to residents would not be subject to the national primary drinking water regulations. Calling submetering an "effective but little-used tool" to promote water conservation, EPA clearly signaled a pullback from any insistence at the federal level that submetered systems would be required to perform the monitoring and record-keeping tasks of public water utilities, even if they nominally remained "public water systems." But citing a lack of evidence to support water saving benefits, the new policy pointedly excluded RUBS and hot water hybrid allocation systems from its scope, and urged states to consider whether flexibility was warranted for such systems as well. A challenge to EPA exclusion of RUBS and hybrid systems from this new policy has been mounted by a consortium of interested parties. State Regulatory Survey A survey of state policies toward multi-family billing systems is maintained by the National Submetering and Utility Allocation Association (NSUAA), a trade association for companies involved in multi-family billing for all types of utility services, i.e., water, wastewater, electric, natural gas, solid waste, etc. NSUAA attempts to track state and local policies toward both submetering and RUBS, as well as whether service fees are allowed as part of a billing system. xxxviii
NSUAA cautions readers not to rely on this summary information as legal advice, noting that information is subject to frequent change and deals with matters of interpretation. With the permission of NSUAA, the latest (March 2004) overview of state policies regarding water and wastewater billing systems is presented in Table ES.1.12. xxxix
Page 1 and 2: NATIONAL MULTIPLE FAMILY SUBMETERIN
Page 3 and 4: CONTENTS LIST OF TABLES............
Page 5 and 6: Matched-Pair Analysis .............
Page 7 and 8: LIST OF TABLES Table ES.1.1 Breakdo
Page 9: Table 6.6 Elasticity values, analys
Page 12 and 13: Figure 4.30 RUBS water bill #6 ....
Page 14 and 15: investigated local water savings as
Page 16 and 17: We are grateful to the members of a
Page 18 and 19: quantitative aspects of separate bi
Page 20 and 21: 3. Owner/postcard survey: To identi
Page 22 and 23: "averages" of impact property water
Page 24 and 25: in-rent properties, others used the
Page 26 and 27: of these models included the billin
Page 28 and 29: 70 Average Annual Water Use Per Uni
Page 30 and 31: COSTS AND BENEFITS Beyond quantifyi
Page 32 and 33: service charge, then the resident w
Page 34 and 35: Billing Method Efficient Fixtures?
Page 36 and 37: 70 Avg. Water Use per MF Unit (kgal
Page 40 and 41: Table ES.1.12 NSUAA Summary of Stat
Page 42 and 43: above, the researchers offer the fo
Page 44 and 45: service is preferable, and would he
Page 46 and 47: practices (BMPs) should be implemen
Page 48 and 49: infrastructure of the building and
Page 50: multi-family housing. The transfer
Page 53 and 54: CHAPTER 1 INTRODU CTION More and mo
Page 55 and 56: In 1998, 15.0%, or 15.4 million, of
Page 57 and 58: TERMINOLOGY AND DEFINITIONS OF BILL
Page 59 and 60: submetering. With utility-submeteri
Page 61 and 62: all the two bedroom units for $20 p
Page 63 and 64: HOW TO USE THIS REPORT This report
Page 67 and 68: CHAPTER 2 LITERAT URE REVIEW As the
Page 69 and 70: A review of the literature unearthe
Page 71 and 72: The price elasticity of water deman
Page 73 and 74: expected. Additionally, McClelland
Page 75 and 76: submetered and five control (in-ren
Page 77 and 78: Another study might want to target
Page 81 and 82: CHAPTER 3 RESEARC H METHODS, APPROA
Page 83 and 84: 1. Selection of participating study
Page 85 and 86: STUDY SITE SELECTION The Study aime
Page 87 and 88: Figure 3.2 National Multiple Family
Page 89 and 90:
Matched pair protocol/survey - conf
Page 91 and 92:
information given the available bud
Page 93 and 94:
survey. Service companies that prov
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in “business to business” calli
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MATCHED PAIR SAMPLE The purpose of
Page 99 and 100:
The second part of the visit requir
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epresentative of a known population
Page 103 and 104:
51 Table 3.7 Postcard survey statis
Page 105 and 106:
Table 3.8 Comparison of annual wate
Page 107 and 108:
postcard survey. Nevertheless, exam
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confidence interval ranged from 49.
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particular property (e.g., the mont
Page 113 and 114:
State PUC officials - water commiss
Page 115:
10. The PROPID number appearing on
Page 118 and 119:
These costs represent the commodity
Page 120 and 121:
The postcard survey provided inform
Page 122 and 123:
Table 4.4 Average number of units f
Page 124 and 125:
Two-thirds of the properties that r
Page 126 and 127:
Percent of Surveyed Properties with
Page 128 and 129:
$700 Average Rent Per Bedroom ($) $
Page 130 and 131:
Percent of Surveyed Properties with
Page 132 and 133:
Impact properties were also more li
Page 134 and 135:
Table 4.8 Issues considered before
Page 136 and 137:
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
Page 144 and 145:
Roughly similar proportions of resi
Page 146 and 147:
inserts for toilets (21%) or low-fl
Page 148 and 149:
proportion were unsure, 37% from su
Page 150 and 151:
Table 4.18 Ownership and rental rat
Page 152 and 153:
Figure 4.17 Submeter water bill #1
Page 154 and 155:
Page 156 and 157:
Page 158 and 159:
wastewater rates are not shown so t
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Figure 4.23 Hot water hybrid water
Page 162 and 163:
RUBS Sample Bills Seven sample RUBS
Page 164 and 165:
wastewater rates are not shown so t
Page 166 and 167:
Figure 4.28 RUBS water bill #4 from
Page 168 and 169:
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
Page 174 and 175:
Late Fees At the start of water bil
Page 176 and 177:
124
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intuitively clear, and matches comm
Page 180 and 181:
Indoor water use was normalized on
Page 182 and 183:
Table 5.3 Summarized water use anal
Page 184 and 185:
easonable assumption since there is
Page 186 and 187:
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
Page 192 and 193:
70 Average Annual Water Use Per Uni
Page 194 and 195:
Table 5.11 Statistical tests compar
Page 196 and 197:
Factors that Influence Water Use Th
Page 198 and 199:
Table 5.12 Association of categoric
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Indoor Water Use per Unit in 2001 I
Page 202 and 203:
Table 5.13 Continuous factors from
Page 204 and 205:
Multivariate Models to Determine Im
Page 206 and 207:
properties built before 1995 were c
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70 Average Annual Water Use Per Uni
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A = Beta coefficient for “Propert
Page 212 and 213:
substantially reduces the sample si
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Table 5.17 Model #2 coefficients an
Page 216 and 217:
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
Page 226 and 227:
Table 5.27 Paired samples test, all
Page 228 and 229:
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
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
Page 262 and 263:
210
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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
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the AWWA WaterStats 1999 database.
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Measures, which dispatches a public
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Mississippi, Missouri, Pennsylvania
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226 Table 7.6 Summary of utility re
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DISCUSSION - KEY EXAMPLES OF STATE
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ill. Condominium associations are g
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under construction after January 1,
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Weights and Measures Regulation In
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from the submetering. Meter testing
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clean and decent housing or the lac
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240
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NATIONAL ORGANIZATIONAL STRUCTURE F
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complaints in all 50 states and app
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- Meters must demonstrate in testin
Page 300 and 301:
- Plumbing systems are space constr
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(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
Page 340:
Young, C.E., K.R. Kinsley and W.E.
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