The owner, a Starret Corporation affiliate, filed its Response May 14, 2010.
The Northbay Tenants Association filed its Reply June 10,2010. The tenants argue that submetering should not be imposed because:
- No assessment of the impact of submetering electricity for heatupon 542 low-income tenant households at Oceangate has ever been completed or even initiated;
- Commission experience and precedent necessitates an assessment and mitigation of financial harm to tenants before submetering of electricity for heat is permitted, and Respondent did not submit information to the Commission sufficient for it to make such an assessment;
- The owner failed to satisfactorily submit necessary information;
- The owner failed to satisfy requirements of PSC and HUD regulations designed to protect tenants;
- The prior order was issued by the PSC without timely and adequate notice to tenants of any opportunity to participate in the proceeding, in violation of lawful procedure and of the tenants' rights to due process of law required before issuance of an order affecting their homes, their leases, and their property.