NEW SUBMETERING REGULATIONS

The main proposed changes to the regulations state that:

• apartments in buildings under construction and or being substantially renovated must be directly metered "unless a petition demonstrates that master metering with submetering is necessary for on-site co-generation, demand-response programs or alternative, advanced energy efficiency initiatives";

• there sill be a more streamlined reviews process of submetering applications, and that senior living facilities no longer have to obtain a waiver of individual apartment-meter requirements, so that developers of such housing don't need special permission to submeter; and

•  that in buildings in which heat is from electricity and not oil or other fuel, a case-by-case review will be conducted and that the landlord or co-op / condo board "must show that a substantial majority of the tenants will benefit or be unharmed financially as a result of submetering," as well as install programmable thermostats.

How does a board show that the great bulk of residents will not pay higher rates? A PSC spokesman tells Habitat that no energy audit is required. Rather, "[T]hey would have had to submit shadow billing data. This requires that submeters be installed before receipt of [a] Commission Order allowing submetering. The proposed regulations allow for a study of a similarly situated building. So if a building comparable to [Co-op A] wants to submeter they could submit a study of [Co-op B] (if one were available) which shows it passed the no-harm test. The no-harm test means that a majority of the tenants would not be financially harmed by the conversion."

No, Tell Us How You Really Feel

One longtime advocate for submetering, engineer Herbert E. Hirschfeld, who has consulted on the topic over 30 years, has written widely cited policy papers and was lead writer on the NYSERDA Residential Electrical Submetering Manual, runs the website SubmeterOnline.com. He questions the sincerity of the PSC's new push. "There are people on the PSC staff who have told me because they wish submetering would go away because they don't want to deal with residents' complaints," he claims, and which the PSC disputes. "The people who run the programs don’t want to be bothered because it's more work and more aggravation."

Despite what particular individuals may or may not feel, the PSC's policy stance is to promote subemetering for all the reasons the Commission has given. But the spokesman acknowledges that residents' complaints are a factor. "It is not likely that building owners have objections to submetering," he says. "They might not want to do it because of the cost of installation, but not the concept. Typically, it is the tenants who complain about submetering."

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