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How do we dispute a high master-metered water bill with the utility?

By OurHOA · General information · Revised

How an HOA disputes a high master-meter or irrigation water bill: find the leak or meter error, request a meter test and leak adjustment, and pay only what's owed.

Part of the HOA board handbook: treasurer and money.

The short answer

When a master meter or common area irrigation meter bill jumps, the treasurer has three jobs, in this order. Find out whether the water was really used: a leak, a stuck irrigation valve, or a meter that is reading wrong. Then ask the utility for the remedy that fits, which is a meter test for a bad meter and a leak adjustment for a repaired leak. And keep paying the part of the bill that is not in dispute, in writing, so the association does not pick up late fees or a shutoff notice while it argues about the rest. Who hears the dispute depends on who owns the utility. Most HOAs in Texas, Florida and Colorado buy water from a city or a water district, and those utilities run their own adjustment and appeal process. A state commission steps in mainly when the utility is investor-owned. Every utility's rules differ, and so do governing documents on who can sign for the association. This guide is general education, not legal advice.

Find out who regulates your utility

Look at the bill. The utility's name and the fine print usually tell you whether it is a city department, a district or a private company, and that decides where an appeal goes. Texas: inside city limits, the city has exclusive original jurisdiction over its water rates and services, and the Public Utility Commission has no power over a city-owned utility's rates or service there (Tex. Water Code 13.042(a), (f)). The PUC says it regulates the rates and billing practices of investor-owned, for-profit water utilities and does not regulate municipal utilities, water districts or water supply corporations. Customers outside city limits can appeal a city utility's rates to the PUC under 13.043(b). Florida: the Public Service Commission regulates investor-owned water companies in the counties under its jurisdiction, including meter and billing accuracy. It does not regulate utilities owned by cities or counties. Colorado: the PUC states that it does not regulate municipal systems, water districts or water and sanitation districts. Denver Water, for example, handles disputes under its own Operating Rules. So for most associations, the utility's own adjustment desk and hearing process are the whole game. Learn them before you call.

Rule out a leak before you call

Pull the last 24 months of bills into a spreadsheet: billing period, days, gallons or cubic feet, and dollars. Compare the bad month to the same month last year, not to last month, because irrigation season distorts everything. Ask the utility for daily or hourly reads if the meter is a smart meter. A leak shows up as a usage floor that never drops overnight. A meter error tends to look like a jump that matches no change in weather, occupancy or watering. Then test the meter yourself. EPA WaterSense suggests reading the meter, using no water for two hours, and reading it again; if the number moved, there is probably a leak. On a building master meter that means picking a quiet overnight window and asking residents not to run water, or simply logging the overnight change for a week. On an irrigation meter, turn the controller off and watch the dial. EPA estimates that an irrigation leak as small as 1/32 of an inch can waste about 6,300 gallons a month. If you find a leak, fix it first and keep the paid invoice. Almost every adjustment program requires proof of repair. Our guides on cutting an HOA water bill with an irrigation audit and running a water leak prevention program cover the hunting in more detail.

Ask for a meter test when the numbers make no sense

If nothing is leaking and the usage still looks wrong, ask in writing for a meter test, and ask to be present for it. Texas utilities under PUC rules must test a meter on the customer's request without charge. If the customer asks again within two years and the meter passes American Water Works Association standards, the utility may charge for the second test, capped at $25 for a residential customer (16 Tex. Admin. Code 24.169(d)). If the meter fails, past readings are corrected for up to six months (24.169(g)). The same rule lets a utility treat a condominium on one meter as a single commercial facility (24.169(a)(4)), so do not assume the residential cap applies to a master meter. Florida PSC-regulated utilities must run a field test on written request at no charge, if the meter has not been tested recently, and the customer may watch and get a written report (Fla. Admin. Code R. 25-30.266). A fast meter earns a refund for half the period since the last test, up to 12 months (25-30.340(2)). City utilities set their own terms. Denver Water tests on request and charges the customer if the meter is accurate (Operating Rules 6.04.5(a)); its fee schedule lists $125 for a displacement meter and $145 for a compound or turbine meter, waived if the meter fails. Large master meters are usually the compound kind, so budget for the higher fee.

Apply for a leak adjustment on time

A leak adjustment is a credit for water lost to a leak you have fixed. It is a policy, not a right, and the deadlines are short. Calendar the deadline the day the plumber leaves. Austin Water: submit within 90 days of the repair, with the paid receipt or invoice, the account number, the property address and the dates of high use (City Code 15-9-141). Austin notes that a customer who takes certain bill adjustments cannot also request an administrative hearing for that billing period, so decide which route you want before you file. San Antonio Water System: apply within 60 days of the repair; SAWS says it has no legal obligation to grant one and adjusts part of the leak usage for up to two months. Irrigation main breaks and broken heads qualify; a bad controller setting does not. Denver Water: the leak must not have been reasonably discoverable, the loss is measured against the account's three-year average for the same part of the year, one adjustment covers no more than three consecutive bills, and no more than two adjustments are allowed in a rolling 12 months (Operating Rules 6.04.5(c)). Colorado Springs Utilities allows two adjustments per premises in 36 months and wants the request and proof of repair within 60 days of the bill's due date. Tampa allows one adjustment in 12 months and accepts paid receipts, not estimates.

Pay the undisputed part and put the dispute in writing

Do not hold the whole bill hostage. On a master meter, a shutoff notice reaches every unit in the building, and Denver Water's rules charge a delinquency on a shared meter to all users on that service pipe (6.04.4). Texas PUC rules let a customer register a dispute in writing or in person and pay an amount equal to its average monthly usage at current rates, averaged over the prior 12 months; the utility cannot demand the disputed amount above that while the dispute is open (16 Tex. Admin. Code 24.165(l)). In a Florida PSC complaint, the utility may not cut off service over the disputed amount, but the customer must pay the undisputed part (Fla. Admin. Code R. 25-22.032(3)). Denver Water requires a written dispute within one year of being billed, and that letter is a prerequisite to its hearing process (6.04.6); service continues during the process only if current charges are paid (2.10.2(b)). SAWS and Tampa both tell customers to keep paying at least their average bill while a review is pending. Sample letter paragraph: 'The [Association] disputes the charges for account [number] for the period [dates]. Usage of [X] gallons is [Y] times the same period last year. We tested for leaks on [date] and found none [or: repaired a leak on [date], invoice attached]. We request a meter accuracy test, with an association representative present, and a review of this bill. We are paying $[amount], our average monthly bill, while the dispute is open.' Send it the way the utility's rules require and keep a copy.

A sample timeline and a motion

Day 1: the treasurer flags the bill and pulls 24 months of history. Days 2 to 5: overnight meter checks, irrigation off, a plumber or irrigation contractor if the dial moves. Day 7: written dispute and meter test request; pay the average amount. Within the program deadline: leak adjustment application with the paid invoice. Day 30 to 90: utility response; if denied, decide at the next board meeting whether to request the utility's hearing or, for an investor-owned utility, file with the state commission. Texas PUC rules require the utility to tell a dissatisfied customer about the commission complaint process (16 Tex. Admin. Code 24.153(b)). The Florida PSC's consumer line is 1-800-342-3552. Motion: 'I move that the board authorize the treasurer to dispute the [month] water bill for account [number], request a meter test and any available leak adjustment, pay the account's average monthly amount while the dispute is open, and approve up to $[amount] for leak detection and repair.'

Mistakes that cost associations the credit

Missing the window. Sixty or ninety days goes fast when the board meets monthly. The treasurer should be able to file without waiting for a meeting, within a spending limit the board sets. Sending an estimate instead of a paid invoice. Tampa says so outright, and most programs work the same way. Paying nothing. A late fee is small; a disconnection notice taped to every door is not. Fixing nothing. A second adjustment in Denver triggers an audit and inspection, and every program assumes the leak is gone. Forgetting the budget. If the dispute fails, the overage has to come from somewhere. Note it in the treasurer's report, and if water is a recurring problem, raise the utility line in next year's budget instead of hoping for credits.

Sources

These guides are general education for HOA boards and residents, not legal, tax, or financial advice. Rules vary by state and by your community's governing documents - check with a professional for your situation.

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