Water Submetering Vs. RUBS in Missouri - PSC & DNR Regulation

[Mark G.]

Need some advice from fellow Missouri investors.

We own a mobile home park in central Missouri. The park is situated with submetered water which we bill back to each resident along with a sewer charge. We source our water directly from the county and flow our sewer to the municipality, we have no well/lift station/treatment plant or any chemicals. Just pipes in and pipes out.

There is a surprising amount of regulation between the Missouri DNR and PSC which comes with submetering and billing so wondering how others have their utility billback situated. This likely is not unique to mobile home parks but also any multi-family investment.

1. For investors who bill back, what billing methodology do you use and what corresponding regulation do you have to follow (certified DS1 water system operator on staff, monthly sampling programs, annual CCRs, rate tarriffs, etc.)?

2. Does anyone use RUBS, and if so, is there any regulatory requirement with PSC or DNR?

3. Does anyone have experience going through a decertification process with the PSC or delisting with the DNR? Any advice or useful contacts would be helpful.

We are evaluating whether to transition to just lumping water into rent to reduce the administrative burden, but prefer to keep the meters running to hold residents responsible for conservation and their own individual usage.

Thanks in advance!