Northland Investment Corp. v. Public Utilities Regulatory Authority

Summary

The court affirmed the judgment upholding PURA’s determination that a landlord may not use ratio utility billing to charge tenants estimated shares of building-wide utility costs in a master-metered building. The court held that the governing statute is ambiguous as to whether a tenant may be held liable to a landlord for utilities not exclusively used by that tenant, and construed the statute broadly in light of its remedial consumer-protection purpose. The court distinguished the prohibited ratio utility billing method from incorporating estimated utility costs into fixed rent through the building-in approach.