I have a MHP in TX. The water is metered through a single large meter. The municipality is charging per lot on a base fee then billing on actual usage + sewer, trash, etc. The billing is the normal per residences base fee. The single tap charge is several hundred a month less.We tried to sub-meter but they would not do it. Is this typical that the utility would charge a base fee per lot even though they only supply the one large meter?
I have this setup. Im not sure what you mean by the single tap charge being several hundred less. When you submeter the water, are you saying they will not do it or will not allow you to do it?
In our scenario , i asked if they would consider taking over the meters (sub meters) and they advised they could install new ones but really needed to run all new water lines which would have been cost prohibitive but a nice convenience. Typically you would need to do the submitter yourself.
Here is a good resource for substring in TX and i believe you need to register with TCEQ . https://www.tceq.texas.gov/assets/public/legal/rules/rules/pdflib/291h.pdf
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And with the Texas PUC
This is a newly built community, 10 yrs old. It has a 6in compound meter and no sub-metering. It was asked of the utility to sub-meter but due to roads not meeting the required width they will not install. I tried to get assistance through PUC but this is a municipal owned utility and PUC has no authority. They are currently billing a base rate per unit even though they do not each have a meter. The rate sheet gives a price for a 6" tap at just $96 for residential or commercial. We are currently billed 11.35 base rate per unit. I would think if they charge per unit they would have to install their own meter at each unit as the base rate should take in to account costs for line maintenance up to their meter. In this case we are responsible for everything passed the compound meter but have to pay utility per unit, still. Adds about $600 to the bill by billing by unit. Thank you for the responses so far. Your thoughts?
PUC has authority for submetering in the context that they need to know you’re passing those charges along to the tenants. There is a registration form on this page: >Water and Sewer Submetering or Allocation
Thank you jhutson for that information! I guess my last question is it really fair for the municipal utility to charge per unit if they will only supply the master meter? We asked them to submeter and denied the request. They however do not want to be liable for our private roads and water lines, anything past their compound meter. Seems they should be as a single entity and based on their rates for a commercial entity with a 6in tap. Any thoughts or experience with this situation?
Hello,
Appears your outstanding issues are one main water meter and high base fees per home.
Regarding only one municipal main meter: The municipal supplier most likely does not want the cost and maintenance of the individual meters at each home; Reading one main meter is far easier than traversing through your MHP reading individual meters.
Municipal water/sewer base rates charged per home or MHP are typically used if municipality is unable to charge for all of the actual water usage; Noting older and larger meters are unable to capture 100% water consumption (yes, as in inaccurate);
Private sub-meters allow 100% pass-through of the municipal charges, along with a reasonable billing fee. Based on our 20+ years of sub-metering, your MHP’s Water - Sewer usage will drop 25 to 35%, and you can accurately track water use, leaks, and wastes.
Call me or e-mail me at anytime, We’re here to answer your sub-metering questions.
Sincerely
Dan Helton
President
Southern Water Management cell 727-421-9695
727-827-4509 Dan@SouthernWaterManagement.com
http://SouthernWaterManagement.com
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I would probably ask a muni and/or utilities attorney about this setup and whether the city has any obligations to your tenants if they are base charging per unit (e.g. must offer city meters, garbage, road maintenance, etc) as part of that. It doesn’t sound fair on the surface, but I don’t know if it’s legal or not in your specific situation - unfortunately they’re not always the same.
@Dan Helton The municipality put in a compound meter with low and high flow. So they charge for the entire 515,600 gallons on top of the base rate.
@Jhutson Great advice! That was going to be my next move. These city owned utility companies seem to just do what they want.
Thank you gents! Merry Christmas!!
What are they specifying the charge as?
I’m sure there could be some argument in court if they are refusing to meter yet proceeding to charge a base fee per unit for “Water” specifically…
If trash and other charges are included then i would assume they are trying to recoup of some of the loss that they are most likely taking.
We call Texas and its munis the wild west, seems like anything goes! 
So on the bill I have a base charge that is equal to units X their base resi/commercial charge per month of 11.35.
Then I have the water charge for 515,600 gallons at 3.70 per 1000 gallons.
Then I have sewer… havenet figured out the charge breakdown. Costs about 200 more than water.
Then I have garbage charges for 3 4 yard dumpsters.
In the end I am paying like 5200 for 61 units!!
So with all that has been said… One question very specific to Texas MHP’s.
Can the lease just include a flat rate that will go towards utilities? Or can a landlord just say rent is XXX and water, sewer, garbage, electric, and lawn care are included? Or, do utilities have to be allocated according to PUC and TECQ policies?
The latter - tenant is responsible for these utilities (gas, water, electric) and here are the required disclosures on how it works. The PUC disclosures outline how allocated vs sub metering is billed.
Do a search for the TMHA Space Rent form.
Based on what I have read regarding PUC and TCEQ, I cannot charge the tenants the base rate I am charged? Seems to only allow me to charge for water, sewage, and garbage and then I have to pay the 11.35 per unit and sales taxes. Am I not fully understanding? I own the land and the homes. Can I not just “build in” the charges and call it rent? Is it illegal to do so? This would at least give me time to work on pressure adjustments to each unit, changing out aerators and toilets. Seems TCEP and PUC require within one year of moving to sub or allocated metering I have to replace all toilets that are over 3.5 gpf.
The base charge is called out in the PUC disclosure as one of the items due: “Amount due for dwelling unit base charge or customer service charge, or both, if applicable;” I also don’t see how anyone could require you have your tenants upgrade the efficiency of their toilets. Maybe for the POH though.
Could you provide where I can find your quoted charges? I am looking at Chpater24 as shown and it indicates the opposite…
CHAPTER 24. SUBSTANTIVE RULES APPLICABLE TO WATER AND SEWER
SERVICE PROVIDERS.
Subchapter H. WATER UTILITY SUBMETERING AND ALLOCATION.
§24.124-2 effective 9/1/14
(P 42190)
(e) Calculations for allocated utility service.
(1) Before an owner may allocate the retail public utility’s master meter bill for water and sewer
service to the tenants, the owner shall first deduct:
(A) dwelling unit base charges or customer service charge, if applicable; and
(B) common area usage such as installed landscape irrigation systems, pools, and
laundry rooms, if any, as follows:
(i) if all common areas are separately metered or submetered, deduct the
actual common area usage;
(ii) if common areas that are served through the master meter that provides
water to the dwelling units are not separately metered or submetered and
there is an installed landscape irrigation system, deduct at least 25% of the
retail public utility’s master meter bill;
(iii) if all water used for an installed landscape irrigation system is metered or
submetered and there are other common areas such as pools or laundry
rooms that are not metered or submetered, deduct at least 5% of the retail
public utility’s master meter bill; or
(iv) if common areas that are served through the master meter that provides
water to the dwelling units are not separately metered or submetered and
there is no installed landscape irrigation system, deduct at least 5% of the
retail public utility’s master meter bill.
(2) To calculate a tenant’s bill:
It was on page two of the link I provided earlier in the thread.
You’re pointing out the calculations for allocated billing - I was talking about sub metering, which is section D of that code.
(d) Calculations for submetered utility service. The tenant’s submetered charges must include the dwelling unit base charge and customer service charge, if applicable, and the gallonage charge and must be calculated each month as follows…
I see… Yeah I am stuck with master meter until we have the cash flow to support self sub-metering. So the utility charges per lot at $11.35 and will not sub-meter due to roadways in park not being 24 ft wide… So right now I am looking at putting pressure regulators on each unit, dual flow aerators limited to 1gpm, and eventually new efficiency toilets.Anything to reduce consumption from the current 515,600 gallons per month. All the units are POH so once we go to allocated billing then I have one year, by code, to reduce toilets to below 3.5 gpf. The expenses seem to be forever increasing to run a park in Texas!