Comment on FR Doc # E7-11731

In a number of areas, owners of tax credit properties pay utilities directly to the utility company through a master-metered system. In order to encourage conservation of resources and reduce utility costs, owners often bill the tenants for the cost of utilities. The cost of the utilities are paid directly by the tenant to the owner, who in turn passes the payment onto the utility company. By requiring that the tenants pay the cost of utilities (either through a "check metering" or "ratio utility billing system [RUBS]"), utilities are conserved and costs are minimized. While the current regulation does not prohibit the use of such billing systems, it does not specifically permit them either. The regulation should clearly permit the use of such billing systems as long as owners can demonstrate that the amount being collected from residents is not more than the cost of utilities for the residential units. Owners should be required to demonstrate that common area utilities are not being paid for directly by residents, since such costs are already factored into unit rents. HFA's should be given to authority to approve or disapprove such arrangements.