Law Office of Miguel A. Huerta, PLLC

REQUEST CONSULTATION

(512) 502-5544

Law Office Of Miguel A. Huerta, PLLC | Texas Utility Regulatory Counsel

Navigating the Complex Landscape of Utility Regulation with Law Office Of Miguel A. Huerta, PLLC

Law Office Of Miguel A. Huerta, PLLC provides the dedicated advocacy and experienced counsel necessary to navigate complex utility regulation and overcharge disputes in Texas. By offering a solution-focused approach, we deliver the reliable guidance you need to protect your interests, ensure compliance, and secure your bottom line.

Consultation

Protect Your Business From Costly Regulatory Penalties

If you are facing a tenant PUC complaint, need to verify your billing methodologies, or require expert representation for your retail electric provider business, contact us immediately. Fill out the form below to schedule your free consultation with an experienced Texas utility law attorney.

Miguel A. Huerta has been practicing regulatory law in general, and specifically utility law, since 1993. During that 32-year period, he gained experience representing and advising both private businesses and governmental entities on a wide array of utility matters including regulatory issues, transactional matters, and administrative litigation.

Mr. Huerta represents and advises property owners, property management companies, and rv/manufactured home parks facing issues related to submetered or allocated water/wastewater and electric service. Mr. Huerta’s clients have also included industrial and commercial end-use customers, governmental and public entities, retail electric providers, competitive local exchange companies, and a variety of other entities needing legal assistance with electric, telecommunications, gas, water and sewer supply and rate issues.

Mr. Huerta received his Juris Doctorate from Harvard Law School in 1993. His professional memberships include the State Bar of Texas, the Administrative Law and Public Section, and the Public Utility Law Section.

Our Core Regulatory Legal Services

  • Retail Electric Provider Representation
  • Submetering & Allocation Compliance
  • PUC Advocacy & Dispute Resolution
  • Defense Against Overcharge Accusations
  • Transitioning from master-metered accounts to individual submetering or allocated billing (RUBS)
  • Reviewing utility addendums and mandatory landlord disclosure notices
  • Conducting thorough regulatory audits of allocation and submetered rate-setting formulas
  • Reviewing proposed tenant invoice formats for state-level compliance
  • Ensuring physical submeters meet testing standards and record retention requirements
  • Managing administrative litigation before the State Office of Administrative Hearings (SOAH)

Frequently Asked Questions

Your Title Goes Here

Your content goes here. Edit or remove this text inline or in the module Content settings. You can also style every aspect of this content in the module Design settings and even apply custom CSS to this text in the module Advanced settings.

What is the difference between submetering and allocated billing (RUBS) under Texas law?

Submetering relies on specific physical hardware installed at your property to measure the exact utility usage in each individual dwelling unit, providing highly accurate data for tenant invoicing. In contrast, allocated billing, commonly known as a Ratio Utility Billing System (RUBS), does not use physical meters but instead utilizes a strict mathematical formula based on unit square footage, occupancy, or a combination of both to distribute utility costs. Because allocated billing does not measure direct usage, it is heavily scrutinized by the Public Utility Commission of Texas (PUC) and requires highly precise lease disclosures and absolute adherence to state-approved billing formulas.

Can a landlord charge tenants more for utilities than the actual cost of the service?

No, Texas law explicitly prohibits landlords, property management companies, and manufactured housing communities from making a profit when billing utility services to their tenants. You are permitted to pass through the actual costs and collect a small, legally mandated administrative fee specifically for water submetering, but nothing more. Overcharging tenants, whether intentionally or through a calculation error, carries severe consequences, including significant administrative penalties from the PUC, the potential forfeiture of one month’s rent to the tenant, and potential charges of illegally acting as an uncertified retail electric provider.

What steps should I take if a tenant files a formal or informal PUC complaint against me?

If a tenant files a complaint with the Public Utility Commission of Texas, you must take immediate, proactive legal action because the Commission holds broad power to audit your records and levy severe administrative penalties. You should immediately preserve all historical billing data, gather your lease agreements, and review your utility addendums. It is critical to retain experienced regulatory counsel to perform a comprehensive audit of your billing data, identify any mathematical or clerical errors, and draft a formal, data-driven legal response to the Commission to mitigate your financial and legal liability.

Are landlords required to register with the Public Utility Commission of Texas (PUC)?

The requirement to register with the Public Utility Commission of Texas depends entirely on the specific utility service you are billing to your tenants. For electricity billing, property owners are not required to register with the PUC. However, for water and wastewater utilities, any property owner who intends to bill tenants for either submetered or allocated (RUBS) service is legally required to register with the PUC. Furthermore, you are legally mandated to report any subsequent changes made to the specific methodologies or formulas used to bill your tenants.

Why should I hire the Law Office Of Miguel A. Huerta, PLLC to handle my utility regulatory matters?

You should choose the Law Office Of Miguel A. Huerta, PLLC because Miguel Huerta has been practicing directly before the Public Utility Commission of Texas for over 30 years, and is an experienced utility submetering and allocation attorney. The firm possesses the deep technical expertise, diligence, and integrity required to navigate complex state statutes and Commission regulations. We provide clear communication and reliable representation, helping you defend against complaints, ensure total compliance, and protect your bottom line.