RUBS and submeters

At last Thursday’s Rent Control Board meeting, I proposed to my colleagues that we as a body encourage the City Council to consider whether RUBS water billing in multi-family apartments helps Santa Monica achieve the water conservation targets we’ve set.  Under this “system,” known as “ratio utility billing,” a landlord devises some arbitrary way of billing his/her tenants for water. S/he could divvy up amounts of the building’s water bill based on unit size, number of occupants, number of bathrooms, or some other factor – but certainly not using any real data informing them of how much water each unit actually used.

My belief is in line with environmental organizations, who attest that RUBS billing is capricious and unscientific, and does not lead to genuine water conservation. Therefore, I believe the practice should be forbidden in multi-family housing in Santa Monica. But before the meeting, the Daily Press ran an article on Wednesday, Feb. 8, that misled the public about the intent of my proposal.

The article put words in my mouth by stating, “Rent Control Board Commissioner Todd Flora has asked for a discussion at the board’s Feb. 9 meeting to debate a citywide mandate to outlaw Ratio Utility Billing Systems and require landlords to move to submeters as the means of establishing water costs.” The first half of this statement is true. But, the second half is not. The Board did not recommend that landlords be required to install submeters in all buildings.

Water conservation is a goal we all share:  landlords, tenants, homeowners and business owners alike.  And finding the best way to encourage conservation is a challenge.  But, it’s my belief that RUBS billing is not the answer. Such systems are rife with abuse.

The following is the ONLY action intended, and taken by, the Rent Board on February 9th with regard to renters being billed for their water use:  We asked our City Council to consider banning the use of “ratio utility billing,” or “RUBS,” in order to protect renters from what we perceive to be an unscientific, arbitrary, possibly illegal but certainly cynical means by which to extract funds from renters for water use…. That’s it.

Now, it is certainly true that a natural extension of this discussion is that by removing RUBS, those landlords who own newer buildings and DO have the infrastructure ready to take on submeters should do so. After all, it would prompt sincere and genuine water conservation among their tenants. With submetering, renters in submeter-ready buildings would know exactly what their water use is, take responsibility for it, and can adjust behavior accordingly.

But it is important to note that many buildings in Santa Monica lack the infrastructure for anything more than a master-metered water billing system, and I do not, nor did not, advocate for the overhaul of our water infrastructure throughout the city, as the article would seem to imply.

Those interested in watching the Board’s discussion of the proposal can do so at our website:


Todd Flora is a member of the Rent Control Board