Heat, Water, Sewage RUBS in West New York, NJ

[Patrick Ma]

Hi BP Community, 

Need your advice on the best approach here on implementing Ratio Utility Billing in my 3 family property in West New York, NJ.  The building has a single furnace as well as water meter.  Upon signing a new lease with tenants to have them pay a straight 1/3 of the heat bill, I was quickly referred to the Rent Control Board and the Town Code/Ordinance 312-10,11(https://ecode360.com/7058058).  Even though there is no conversion being done, seems like they still want me to supply documents and pay for the application.  The most troubling seems to be section 11 where the rent would be reduced by the amount of the utility bill transferred to the tenant.  Anyone have experience with this?  Seems like this requirement applies to both water and heat but not sewage.  However, my agent tells me it is the current market norm to have tenants pay for heat but not water/sewage.  

Without much info from the Board except to read the code, I'm tempted to move forward with RUBS on Sewage only and leave the heat/water alone.  Any advice from your experience would be much appreciated.