National Multi Council Housing Challenge
by Guest Blogger, 6/16/2004
Ten organizations submitted a request for correction to the Environmental Protection Agency (EPA) March 10 under the agency's data quality guidelines. The petition challenges a statement contained in a Federal Register notice on ratio utility billing systems (RUBS) and other allocation billing systems for water use. Background RUBS (Ratio Utility Billing System) uses a formula to calculate utility usage for individual homes in a community and the exact formula can vary. The most frequent calculations look at the number of residents, square footage or a combination. This type of tracking system is used in buildings where the plumbing configuration does not allow single meters for each apartment or home. Studies show that payments tied directly to water usage through single meters encourage water conservation. However, when a renter pays a flat fee for all utilities, water is less likely to be conserved. Therefore, buildings that cannot directly monitor water usage often apply RUBS or other allocation systems to estimate resident water use and promote conservation. Unfortunately, a RUBS system does not link individual water use and costs, therefore renters pay an average of the overall costs, including the allocation and billing costs. Renters may be unfairly charged for othersâ¦¡mp;#8364;? excessive use or water wasted on the property and have no way to enforce conservation. Request for Correction The parties submitting the request for correction included the National Multi Housing Council, the National Apartment Association, the Builders Owners and Managers Association, the Institute of Real Estate Management, the National Association of Industrial and Office Properties, the National Association of Real Estate Investment Trusts, the National Association of Realtors, the National Leased Housing Association, the Real Estate Roundtable, and the U.S. Chamber of Commerce. The statement being challenged is contained in a revised policy regarding regulatory requirements under the Safe Drinking Water Act (SDWA) for submetered properties. While the petitioners agree with most of the revised policy, they are challenging the sentence â¦¡mp;#8364;“ "â¦¡mp;#8364;?EPA believes that RUBS or other allocation billing systemsâ¦¡mp;#8364;?do not encourage water conservation." Under EPA's revised policy the allocation billing systems are subjected to a higher level of regulatory compliance involving water quality testing because EPA asserts they do not promote water conservation. The petitioners believe that this statement is erroneous and does not adhere to EPAâ¦¡mp;#8364;?s data quality guidelines. They assert that a number of other studies reveal that allocation billing systems can promote water conservation, and the EPA's revised policy should allow the properties using allocation billing and RUBS to avoid requirements under the SDWA. The petition does not make any claim whether these other studies meet the data quality standards for use or not. Specifically, the petitioner state the sentence should be corrected for the following reasons:
- The statement is erroneous in light of published open literature that contradicts the statement;
- It is unclear if this statement was subject to pre-dissemination review;
- The statement violates the "objectivity" standard of the guidelines because it is no presented in an accurate, clear, complete and unbiased manner; and
- It violates the "utility" standard because it is not useful to stakeholder.