Utility recovery can be one of the highest-impact operational levers in a manufactured housing community and, as of 2026, one of the fastest-moving areas of regulatory exposure. Several states changed or tightened their rules in 2025 and 2026, and an operator running the same billing method across a multi-state portfolio may now be compliant in one state and not in another.

This article describes general operational practice and reports regulatory developments, distinguishing between those verified against primary sources and those reported by industry publications. It is not legal advice. Utility billing rules are set at state level, frequently through public utility commissions, and are changing rapidly. Verify the current position in each state you operate in before changing or continuing any billing practice.

Four Models, Three Separate Decisions

Most discussion of this topic frames it as submetering versus RUBS. That is too narrow. There are three separate decisions underneath.

Who owns the utility relationship? The utility, or you.

How is consumption measured? Individual meters, or one master meter.

How is cost recovered? By actual use, by allocation formula, or absorbed into rent.

Combine those and you get four working models.

That last column is the one operators underweight, and it becomes the article's central point later.

The Master-Metered Problem

A master-metered community buys water and sewer on one bill and absorbs the cost. When residents do not pay based on their own consumption, they have less direct financial incentive to reduce usage, while the operator remains exposed to the full master-metered bill.

Operator commentary puts the scale at roughly $72,000 to $120,000 a year for a master-metered 100-lot community, or $6,000 to $10,000 a month. Keel Team's analysis frames that as $1.0 to $1.7 million of value at a 7% cap rate, on the basis that recovered utility cost flows to NOI.

Treat those figures as illustrative. The underlying economics are straightforward: where utility costs can lawfully be recovered, reducing unrecovered consumption expense can improve NOI, and NOI is what your community is valued on.

Aging infrastructure compounds it. In older communities on master-metered water, distribution leaks, running toilets inside homes and failed shutoff valves all arrive as one number, and the operator pays all of it without knowing which is which.

What Changed in Ohio, and Why It Matters Elsewhere

On 22 April 2026 the Supreme Court of Ohio held that a submetering company is a "public utility" subject to regulation by the Public Utilities Commission of Ohio. Per Court News Ohio, the decision in In re Complaint of Ohio Power Co. v. Nationwide Energy Partners, Slip Opinion No. 2026-Ohio-1406, reversed a PUCO order that had found the company was not a public utility, and remanded the case for further proceedings.

Read the facts carefully, because they have been mischaracterised in industry commentary. The case concerned a third-party company that contracted with landlords of Columbus-area apartment complexes to buy electricity from the utility at commercial rates and resell it to tenants. It was not about manufactured housing communities, and not about an operator submetering its own water.

Why it still matters to you. Ohio law defines a public utility as an entity "engaged in the business of supplying electricity for light, heat, or power purposes to consumers within this state." PUCO had reasoned that landlords, not tenants, were the consumers. The Court disagreed, reasoning that from the tenant's perspective the submetering company was for all practical purposes the supplier of their electricity.

That reasoning turns on the substance of the arrangement rather than the property type. Any operator using a third-party billing vendor that buys and resells utility service should be asking counsel what the precedent means for that arrangement in their state.

The position continues to move. Ohio Capital Journal reported that the Governor vetoed submetering legislation in June 2026, and Columbus City Council passed its own regulatory ordinance in December giving submetering companies until December 2026 to comply.

And Ohio is not the only state where this is moving. Industry commentary through 2025 and 2026 describes legislative and regulatory activity affecting allocation billing in several states, including Minnesota, Colorado, Arizona, California, Washington and New York. Rather than repeat claims I have not verified against primary sources, the honest advice is this: if you operate in any of those states, treat your current billing method as an open question and check it with your state commission. The NARUC directory of state public utility commissions is the starting point for finding your regulator.

Recent developments suggest increased scrutiny of allocation methods, stronger disclosure requirements, and tighter limits on how utility costs can be recovered or marked up.

Where the Rules Live

Utility billing in this sector is governed differently from almost everything else operators deal with, and that catches people out.

It is frequently public utility commission territory rather than landlord-tenant law. In Texas, operator guidance from a law firm serving the sector describes community owners as needing to register with the Public Utility Commission of Texas and comply with rules on billing frequency, allowable charges and resident notices. Confirm the current requirement with the PUCT directly rather than from any secondary summary, including this one.

The point generalises. The answer to "can I bill this way" may not be in your state's manufactured housing statute at all. Our 50-state index of manufactured housing community laws covers the landlord-tenant layer, but utility billing frequently sits in a different body of regulation entirely.

Submetering: What It Costs

Installation. Traditional submeter installation is reported at $300 to $500 per lot, with newer clamp-on and non-invasive technologies at lower cost.

Published estimates vary widely depending on whether they include installation labour, plumbing modifications, communications equipment, billing software and ongoing service. Treat any per-lot figure as a starting point for a quote rather than a project budget, and be specific about scope when you ask for one. In an older community, plumbing modification where the existing configuration does not accommodate a meter is usually the variable that moves the number.

Payback. Reported periods differ meaningfully by source. Vendor material from SimpleSUB cites traditional installations paying for themselves within 12 to 24 months, and describes a Colorado community using clamp-on meters where usage dropped by about a third and $35,000 was saved in the first year. Keel Team's operator commentary suggests three to five years.

That gap is worth noticing. A vendor payback estimate and an operator payback estimate are not the same document. Model it on your own consumption data and your own quotes.

Why it works. The mechanism is behavioural. When a resident pays for what they use, consumption tends to fall. Under allocation billing, the marginal cost of an extra gallon to any individual household is close to zero because the cost is spread. SimpleSUB cites the EPA to the effect that allocation billing systems do not encourage water conservation.

Submetering Is Also a Maintenance Sensor

The billing system tells you what the resident owes. The consumption data can tell you what is breaking.

A home reading substantially above its own trailing average means something is probably wrong. A running toilet. A failed shutoff. A leak under the home. On a master-metered community you would never see it, and you would pay for it every month until somebody happened to notice.

The workflow that pays for the system: meter read, variance calculated against that home's own history, anomaly flagged, work order raised, repair completed, consumption verified back to normal.

If your consumption data sits in a billing system and your maintenance queue sits somewhere else, that chain breaks at step three and the leak runs for months. Connecting utility and asset data to the operational record is what turns a chart into a job, and connecting it to service request and task management is what closes the loop.

Track a recovery ratio monthly, per community: what you billed residents divided by what you paid the utility. Most operators have never calculated it. The ones who do are frequently surprised.

RUBS: How It Works and Where the Exposure Is

RUBS allocates the master bill by formula rather than measuring anything. Common bases are home square footage, occupancy count, or a flat per-lot division.

It can be cheaper to implement than submetering, and some states permit it subject to specific formulas, disclosures, lease terms or regulatory requirements. It is also where regulatory attention is currently concentrated.

Common requirements to check before implementing RUBS

Depending on the jurisdiction, operators may need some combination of:

• A lease addendum explicitly authorising utility pass-through billing

• Written notice to residents with adequate lead time, reported at 30 to 90 days depending on state

• A documented, consistently applied allocation formula

• Transparency to residents about how the charge was calculated

• Compliance with any prohibition on markup above actual utility cost

That last point deserves attention. If your formula generates more revenue than the utility bill costs, you are not recovering a cost, and several states treat those differently.

Before implementing RUBS, budget for a state-specific legal review of the lease language, the allocation methodology and the applicable utility rules. Against a five or six figure annual utility bill, that is not a meaningful cost.

And check whether the ground has moved. A programme that was compliant when implemented in 2021 may not be compliant now.

Read Discipline

Whatever method you use, the reads have to be defensible, because a resident challenging a bill is challenging your record.

Treat reads the way you would treat bank deposits. Capture, per read:

• Date and time

• Meter serial number

• Current read value

• Any access notes, including failed access

The shorter the gap between the meter read and the resident bill, the easier it is for residents and staff to connect consumption with the amount charged. Long gaps produce bills that feel disconnected from anything the resident did, and disputes follow.

When a Resident Disputes a Bill

They will, and the quality of your response determines whether it becomes a pattern.

Have the record ready. Read date, meter serial, value, prior reads. If you cannot produce that in the meeting, you have already lost the argument regardless of who is right.

Check for a leak before defending the bill. A high bill is frequently a real problem rather than a billing error, and finding a running toilet turns an adversarial conversation into a helpful one.

Know your escalation path. If your state regulates submetering or allocation billing, residents may have a route to the regulator, and you should know what it is before they use it.

Watch for patterns. One disputed bill is a household. Twenty in a quarter is a system problem, usually either the read cycle or the allocation formula.

What to Do Now

Five things, in order.

1. Audit by state, not by portfolio. Establish what billing method each community uses and what that state currently permits.

2. Get a legal review in any state where the rules may have moved, and anywhere you use a third-party billing vendor that buys and resells utility service.

3. Calculate your recovery ratio per community. If you have never done it, that number is the single most useful thing you will learn this quarter.

4. Model submeter conversion on your own consumption and your own quotes, with scope specified, rather than on a published payback range.

5. Connect consumption data to the maintenance queue. A variance that does not become a work order is a chart nobody reads.

Conclusion

Utility billing in manufactured housing has spent years as an operational afterthought, handled by whatever method the previous owner used and rarely revisited. That is no longer a safe position.

Recent developments in several states suggest increased scrutiny of allocation methods, stronger disclosure requirements, and tighter limits on how utility costs can be recovered or marked up. Ohio's Supreme Court has confirmed that a third-party reseller of utility service can be a public utility subject to commission regulation, on reasoning that turns on the substance of the arrangement rather than the property type.

Three things worth carrying away.

1. Know which body of law governs you:
   Utility billing frequently sits with the public utility commission rather than in your state's manufactured housing statute, and operators looking in the wrong place conclude there are no rules.

2. Calculate your recovery ratio:
   If you are recovering 70% of what you pay the utility, the unrecovered 30% is an operating cost you should be able to explain, every month. If you cannot explain the gap, you have a recovery, billing or infrastructure problem to investigate.

3. Submetering's real return is the data, not the bill:
   Anyone can allocate a cost. Only measured consumption tells you which home has a leak.

The operational lesson is clear even where the legal details are not: a billing method that worked in one state, or five years ago, should not be assumed to work today.

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Frequently Asked Questions

1. What is RUBS in a mobile home park?
Ratio Utility Billing System. Instead of measuring each home's consumption, the master utility bill is allocated across residents by a formula, typically home square footage, occupancy count or a flat per-lot split. It requires no meters and little capital, but it does not measure actual usage and it is the method currently attracting most regulatory attention.

2. Is RUBS legal in mobile home parks?
It depends on the state, the utility involved, the property type and the billing structure. Regulatory and legislative activity in several states during 2025 and 2026 has affected what operators can do. Before implementing or continuing RUBS, verify the current rules with the applicable public utility commission and with counsel.

3. How much does submetering a mobile home park cost?
Traditional installation is reported at $300 to $500 per lot, with newer non-invasive technologies lower, but published figures vary depending on whether they include plumbing modifications, communications equipment, billing software and ongoing service. Reported payback ranges from 12 to 24 months in vendor material to three to five years in operator commentary. Model it on your own consumption and a scoped quote.

4. Did the Ohio Supreme Court rule on submetering in manufactured housing communities?
Not directly. The April 2026 decision in In re Complaint of Ohio Power Co. v. Nationwide Energy Partners concerned a third-party company reselling electricity to apartment tenants, and held that it is a public utility subject to PUCO regulation. The reasoning turns on the substance of the arrangement rather than the property type, so operators using third-party billing vendors should take advice on what it means for them.

5. How do I find leaks in a submetered community?
Compare each home's consumption against its own trailing average rather than against other homes. A reading substantially above that home's normal pattern signals a probable problem, most often a running toilet, failed shutoff or under-home leak. The value is only realised if the variance generates a work order, so connect the consumption data to your maintenance queue.