national multiple family submetering and allocation billing program ...

(i) Toll free or local telephone number for customer complaints and billing disputes,
and a brief description of the dispute resolution process.
Policies for the US Environmental Protection Agency
Recommendation 9 – Property owners should not be subject to the full suite of
National Primary Drinking Water Regulations. Property owners should not be subject to the
full suite of National Primary Drinking Water Regulations, with attendant registration and
monitoring requirements, solely by virtue of their action to adopt a billing system for water and
wastewater service, whether submetering or RUBS. The implementation of either billing system
is unlikely to change the quality of water provided to customers on the property.
During the course of this study, EPA’s interpretation of the requirements of the Safe
Drinking Water Act have undergone substantial change on this issue, and the Assistant
Administrator’s memorandum to Regional Administrators dated December 16, 2003, goes a long
way toward adopting this recommendation. The new guidance was drawn to focus on
submetering, due to the potential of submetering to support full-cost pricing and the lack of
documented water savings attributable to RUBS. EPA should, however, recognize that the value
added to a property owner's balance sheet by instituting a billing system – either RUBS or
submetering – creates an opportunity to fund the conversion of long-lasting but inefficient
plumbing fixtures and fittings to EPACT compliant plumbing. Plumbing conversion will
achieve immediate and significant water use reductions in properties of either billing type.
Recommendation 10 – EPA should promote water efficiency in multi-family
housing. As part of its “Sustainable Infrastructure Program,” the EPA Office of Water should
devise a road map for the research, demonstration, and deployment of emerging technologies and
practices that can make significant breakthroughs in multi-family water use efficiency. Property
owners and their trade associations, water and wastewater utilities, state and local governments,
tenant associations, landscape contractors, building contractors, and environmental advocates are
all potential stakeholders and partners in such an effort. EPA should help accelerate the
transformation of water and wastewater billing practices in multi-family housing through
targeted research, technical assistance, model ordinances, voluntary bench-marking, and public
recognition. While this report advances our understanding of the benefits of submetering, the
report has also found several other variables that significantly effect the water consumption of
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