Connecticut RUBS Ban: How Apartment Owners Switch to Submetering

Connecticut RUBS law: Northland and Public Act 26-113

A Connecticut law firm, Pullman & Comley (opens in a new tab), reported in 2025 that PURA has applied the Northland reasoning to commercial properties as well, a reading the firm said could be challenged. If you own mixed-use buildings, have counsel look at the commercial leases too.

Options for Connecticut landlords after the RUBS ban

Keeping RUBS is off the list. That leaves three ways to handle utilities on a master-metered Connecticut property.

For most properties over 80 units, the choice comes down to building water into rent or submetering it. Here's how the two compare in dollars.

Utilities included in rent vs water submetering: the cost

Take a 200-unit master-metered property paying $60 per unit per month for water and sewer, $144,000 a year. Your own bill is the one to use, and the utility expense recovery calculator will run it.

Submetering older Connecticut apartment buildings

A lot of Connecticut's rental housing is old. Census figures for 2020 to 2024 show half of Hartford's rental housing was built in 1956 or earlier, and half of New Haven's in 1957 or earlier. Stamford's is newer, with a median of 1984. NES has local pages for Hartford, New Haven and Stamford.

Age matters because a submeter measures one water line. A garden building with one line into each unit takes one meter per unit. An older building with a kitchen riser and a bathroom riser takes two, and some take more. That changes the install cost, and in some buildings it changes whether meters make sense. NES surveys the plumbing at every property before quoting, so the number you get is the number for that building.

How to get PURA approval for water submetering

Water submetering in Connecticut needs state approval. A regulation dating to 1966, Conn. Agencies Regs. 16-11-55 (opens in a new tab), allows it only with the commission's approval, and PURA is that commission now. PURA's own FAQ (opens in a new tab) says approval is for a specific location and runs as a formal legal proceeding, a docket, that anyone can look up.

Owners file these regularly. PURA's list of 2023 final decisions (opens in a new tab) includes six water submetering applications, for properties in Stamford, Greenwich, Canton, Seymour and Haddam, plus several electric ones.

The approval came with standing orders. The owner must:

• Follow the state rules water companies follow on bill format, correcting bills for meter errors, keeping complaint records and testing meters.
• Never shut off a resident's water, for any reason.
• Submit any change to billing or customer service, including a new vendor or a fee change, for PURA approval at least 10 business days before it takes effect.
• Tell residents within 30 days when the water utility changes its rates.

1. 1File the application. Copies go to PURA, the Office of Consumer Counsel and the electric utility, Eversource or United Illuminating. PURA opens a docket.
2. 2Completeness review. Within 30 days PURA says whether the application is complete or needs more.
3. 3Notify residents. In an occupied building, the owner notifies residents within 10 calendar days of getting the docket number. Residents then have 30 days to send comments, and no hearing is held before that.
4. 4Decision. PURA tries to decide within 60 days of a complete application. Silence is never an automatic approval.

Two more points from those instructions are worth knowing if you buy and sell. Meters installed before approval are at the owner's own risk. And an electric approval belongs to the applicant, not the building, so a buyer has to apply again after closing. PURA publishes no timeline for water, so file well ahead of the lease renewals you want to bill.

How to switch from RUBS to submetering, step by step

This is the order NES works in for a Connecticut property, so recovery keeps going where the law allows it and no stretch goes unbilled.

1. 1Check every lease form. Find the RUBS or utility clause in each lease template in use. From October 1, 2026, any new or renewed lease that still carries it has an unenforceable clause. Have Connecticut counsel review what goes in its place.
2. 2Survey the plumbing. NES walks the property, counts water lines per unit, and checks access. This sets the meter count and the install cost.
3. 3File with PURA. Water submeters need PURA approval before the first bill. NES prepares and files the application while the install plan is being finished.
4. 4Decide what renewing leases say in the meantime. Units that renew before their meter is billing still need lawful lease terms. One option is to build an estimate into rent for that stretch, then move to metered billing at the next renewal.
5. 5Install in phases, bill after approval. Meters go in building by building, and billing starts once PURA approves. The 337-unit NES community above did it as leases renewed, which kept the change in step with the lease cycle.
6. 6Tell residents first. A notice, a sample bill and a number to call that a real person answers, in English or Spanish. Residents who understand the bill dispute it less.

Connecticut submetering services from NES

NES handles all of it with its own staff, from the PURA filing to the resident who calls with a question about their bill.

• PURA filing and compliance. NES's in-house compliance team prepares the water submetering application, answers PURA and Consumer Counsel questions, and keeps the property inside the approval afterward: rate-change notices to residents, the required bill format and meter test records.
• Plumbing survey and meter install. NES W-2 technicians survey every building, count the water lines per unit, and install the meters in phases that follow your lease renewals.
• Daily reads and leak alerts. Meters report every day to MyReads, so a running toilet or a leak inside a unit shows up in days, not on the next water bill.
• Resident billing. NES bills residents for what their unit used, plus the service fee PURA approved, on the bill format PURA requires. Common-area water stays off resident bills.
• Resident support in English and Spanish. Residents call NES, not your leasing office, with questions about their bill. NES keeps the complaint records PURA requires.
• Repairs and replacements. When a meter or transmitter fails, NES repairs or replaces it so the unit keeps billing on a real reading. That matters in Connecticut, where the state meter rules let a resident ask for a meter test, and a meter found running more than 2% fast means a bill adjustment.
• Collections and reporting. Monthly recovery reporting by property, and collections on balances residents leave behind.

Already submetered in Connecticut with another company? NES can often keep the existing meters, adding nonproprietary transmitters where the old radios only talk to one vendor, and files the vendor change with PURA, which PURA required at a Stamford property in 2021. There is no long-term contract lock-in.

Connecticut submetering billing rules: fees, shutoffs and common areas

• Common areas stay with the owner. NES never bills residents for hallways, laundry, irrigation, pools or other shared use. For electric, 16-19ff bans it outright.
• No markup on electric. Where electric submetering is allowed, the rate can be no higher than the utility charges that customer class (16-19ff (opens in a new tab)). The same section tells PURA to cap a resident's cost at what the owner paid for that energy.
• No water shutoffs. In the Stamford approval above, PURA barred the owner from shutting off a resident's water for any reason. Plan on the same condition.
• Gas stays on the master meter. Gas submetering is not allowed in Connecticut, so gas cost is recovered through rent if at all.
• Fees. No statute sets a water service fee. PURA approves it docket by docket, $3.50 a month at the Stamford property above, and any change goes back to PURA. On electric, 16-19ff caps the rate at the utility's own rate and the energy cost at what the owner paid, so don't plan on adding a separate fee.

Connecticut's rules changed twice in two years, so have counsel review your lease language before it goes out.

Advertising rent with utilities in Connecticut: Public Act 25-44

A 2025 law changed how Connecticut rent is advertised. Since October 1, 2025, Public Act 25-44 (opens in a new tab) requires the advertised rent to include every fee, charge or cost the tenant pays on a periodic basis. A landlord who breaks the rule owes the tenant one month's rent, and the court can add the tenant's attorney fees.

• Utilities built into rent. They are part of the rent, so the full amount goes in the listing.
• What the act leaves out of advertised rent. Utilities submetered under 16-19ff (the electric submetering law), and utilities the tenant pays straight to a utility company that vary from month to month.
• Submetered water. The act does not mention water submetered under PURA's water rules. Ask counsel how to show a submetered water bill, and any monthly billing fee, in your listings.
• Lease paperwork. Since April 1, 2026, a written lease must start with the state's rental terms summary form, and tenant payments go to rent first, then to other charges.