
EPA's revised policy regarding sub-metering only applies to properties that already receive water from a regulated public
water system. This change will encourage more tenant sub-metering by removing the potential regulatory burden currently
faced by apartment building owners and other similar property owners who install sub-meters and bill tenants separately
for water. This policy is one way that EPA continues to promote water efficiency, an important part of watershed protection
and infrastructure cost reduction.
Do we have to install meters in order to start a utility billing program?
No, owners commonly implement what is known as a RUBS program for billing purposes. This type of Ratio Utility Billing
program does not require meters. This is especially useful for older buildings that may require expensive upgrades to the
electrical and plumbing in order to install meters. Bills are based on number of bedrooms, square footage, number of
occupants, or a combination of these factors to calculate estimated usage. Many owners like this method because the
start-up cost is zero and utility reimbursements begin immediately.
How does a billing program help to conserve water?
Studies have shown that when residents are aware that they are paying for water usage, they tend to use from 14% to
38% less than when the property owner pays for the water.
Is the cost of water continuing to rise?
Yes, all over the U.S., water prices are continuing to rise from 15% to 50% per year and decreases are not expected
anytime soon. Properties that have not implemented a billing system are severely effected, especially when rents have
remained stable.
Are there any other benefits of sub-metering an apartment complex?
Yes, with a metered system, leaks can be detected quickly, potentially saving thousands of dollars yearly. Also, it is
easier to keep rental prices competitive when the cost of water is not added.
How do I choose a third party billing provider?
Choose a company known for providing top-notch customer service. When a property manager has a question, be sure
you can get hold of a live person to help. Also, ask if they accept online payments. Not all billing companies offer this
service. Check references and records at the Better Business Bureau. Even if the company is not a member, the BBB
can register complaints. And, make sure that the billing provider you choose can provide a custom program designed for
your specific needs. Make sure you don't get surprised by hidden fees such as setup fees, or late payment fees that are
kept by the billing company. Some may even keep a percentage of collections.
Who is responsible for collections?
Your third party billing provider should give you the choice of whether to collect or not. Payments can be made at the
leasing office and forwarded to the billing company for processing. The billing company then sends a check to the
property owner for the amount of collections less a billing fee. Or, the apartment staff can handle the collections by
accepting the payments at the same time rent is due. But, this is usually only done when the apartment complex has a
large enough on-site staff to handle the extra workload.
Will leases need to be amended if a sub-metering or RUBS program is implemented?
Yes, in most states, a lease addendum is required in order to start a billing program. The utility billing can start with new
residents and renewals and gradually all residents will be included.
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How can I be sure that I will not be considered a public utility if I charge the residents for water?
In order to promote water conservation, EPA is changing its regulatory policy under the Safe Drinking Water Act (SDWA)
regarding apartment buildings and other properties with similar characteristics to apartment buildings. Property owners
who install sub-meters and bill their tenants for actual water consumption will no longer be treated as public water
systems subject to the full regulatory requirements of the SDWA.
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