Client has 180-unit complex in Corpus Christi served by AEP Texas. They want to install sub-meters and bill tenants directly. I know Texas has specific rules about this under the Public Utility Regulatory Act. Anyone familiar with Chapter 184 requirements?
Texas sub-metering regulations - what's allowed?
Texas is pretty strict on sub-metering. Property has to register with PUCT if they're going to bill tenants. There's also a requirement that tenants can't pay more than they would pay if served directly by the utility.
The 'cost pass-through' rule is key. Landlord can recover actual utility costs but can't mark up for profit. Also need to provide tenants with monthly statements showing utility rates and usage calculations.
Don't forget about the meter accuracy requirements. Sub-meters have to meet ANSI standards and be tested annually. I've seen PUCT fine property managers $25,000 for non-compliance.
Texas Utilities Code Section 184.003 covers most of this. The key is that sub-metering is allowed but heavily regulated. Property owners often underestimate the compliance costs and recordkeeping requirements.
Had a similar case in Sioux Falls with a smaller complex. Even though South Dakota rules are different, the principle is the same - you can't profit from reselling utility service without proper registration.