The PUC now oversees RUBS billing in Texas and I think this is a good thing. The PUC attempts to be hyper-organized and very fair and impartial regarding billing disputes. For RUBS billing errors the PUC has a resident hotline and call/email center set up, the same as they do for deregulated power or other utility billing disputes. My point is that there are processes in place to handle billing disputes and there are solutions and precedents regarding error correction. Unfortunately, the above issue is not that... as this is not a RUBS billing error issue. There is no real case law for this. The legal arguments being made are that properties never had authority or compliance to ever do RUBS billing in the first place, post 2001 Chapter 291 revisions and that every RUBS bill to every resident since 2001 was submitted and collected by a property that was not allowed to do so.
I bring this to your attention for a few reasons:
1) If you are lucky enough to be using our company, SW Utility Solutions, LLC for our RUBS/Water Conservation program then your toilets meet the TNRCC requirements. Our RUBS Billing & Water Conservation Program qualifies the property for, and meets the standards set out in, the 2001 Chapter 291 revisions.
2) Whomever your RUBS billing company is, make sure your leases being signed are in-line with what your RUBS billing company is charging residents to minimize billing errors. This isn’t the basis for the above issue but it’s an important aspect to RUBS billing.
3) We are offering a free, no obligation analysis to determine if your properties are in compliance with the above. If this analysis leads to new business for us, that’s great; if our free analysis leads to simply a new relationship in the industry, that is great too.
If you have any questions about this or anything else, please let me know. Also, if the above sounds inconsistent with what you know or are hearing or you have more to add, I’d love to hear what you know…knowledge is power and we want to support all our customers as best we can.