This manual will cover the RUBS program including allocation methods, addenda, and conservation. Utility Allocation Guide and Policies

This manual will cover the RUBS program including allocation methods, addenda, and conservation. Utility Allocation Guide and Policies Milestone Management 2/2014

Table of Contents RUBS Program Overview... - 3 - Regulation... - 3 - United States Environmental Protection Agency... - 3 - Texas Commission on Environmental Quality... - 3 - RUBS Allocation Methodology... - 3 - Exclusions... - 3 - Inclusions... - 3 - TAA - RUBS Calculation Based on Average Occupancy for # of Bedrooms -Sample... - 5 - NAA - RUBS Calculation Based on # of Bedrooms -Sample... - 5 - RUBS Calculation Based on Actual Number of Occupants -Sample... - 5 - RUBS Calculation Based on Square Footage and Number of Occupants - Sample... - 6 - RUBS Calculation Based on Occupancy Ratio... - 6 - Sub-metering... - 7 - Glossary of Utility Terminology... - 8 - Ocius... - 9 - Convergent Billing... - 9 - Utility Expense Management/Utilities Plus... - 9 - My Resident Network... - 9 - Life of a Utility Bill... 10 Data Transfer Preparation... 11 Data Verification... 11 Resident Statement... 12 Expected Monthly Cost... 14 Extraordinary Usage of Water/Sewer... 14 Lease Contract... 14 Utility Addenda... 15 Texas Utility and other RUBS Addenda... 17 NAA Utility and Other RUBS Services... 27 Energy Information... 29 Deregulation... 29 Vacant Recovery... 29 Utility Expense Management... 30 Milestone Action Plan for Unexpected Interruption of Power (Electric or Gas)... 31 Disconnection Policy at Move In (Electric/Gas)... 32 Disputed Electric/Gas Recovery... 33 Billing Final Utilities on Deposit Accounting... 34 Move-Out Calculator... 34 Billing Multiple Gas Charges at Move Out... 36 Conservation... 38-2 - P a g e

RUBS Program Overview Transferring to residents, the responsibility to pay for water, sewer, trash and other types of utility services is the trend to strongly encourage conservation of utilities, due to rising costs and limited resources. Apartment residents are billed for utilities in two basic approaches, Sub-metering or RUBS, to allow each resident to take personal responsibility for resource usage. RUBS bills residents through the use of a Ratio Utility Billing System method that allocates via a mathematical formula. The total usage is measured as a master meter and then the bills are allocated according to the formula selected, which is a fair, equitable calculation. RUBS methods of billings are used for many reasons, but primarily because the plumbing configuration on a particular property makes it difficult, if not impossible, for such sub-metered installation. Other reasons include that it may be impractical or a financial burden. Regulation Water allocation is governed by agencies in order to ensure that all laws and state statues are being followed. United States Environmental Protection Agency (USEPA) favors water conservation and encourages an equitable method of distributing costs. Owners who bill residents are subject to state monitoring requirements under the Safe Drinking Water Act (SDWA). The main issue in each state is whether billing for water and sewer services is more than the utility expense. The rule is that a property owner may not charge more to all residents combined than they paid to the utility company for the commodity and service. (This is the law in about 90 percent of the states.) RUBS programs are regulated at the state level and may be regulated at the local level. Texas Commission on Environmental Quality TCEQ (Previously known as TNRCC - Texas Natural Resource Conservation Commission) is the governing agency that regulates the Texas Law on the Allocation of Water/Wastewater with specific rules and guidelines. Texas is one of the few states that has addressed the water and sewer sub metering, RUBS allocation and billing business in detail through state agency rules. Other states have modeled after the TCEQ. RUBS Allocation Methodology From the retail public utility invoice to the property, the owner adjusts the gross amount as follows: Exclusions Charges billed to tenants for sub metered or allocated utility services shall only include bills for water or wastewater from the retail public utility and shall not include any fees billed to the property by the retail public utility for any deposit, disconnect, reconnect, late payment, or other similar fees. The property shall not bill tenants for any dwelling unit base charges applicable to unoccupied dwelling units. Inclusions Gross Water and wastewater charges If the retail public utility s rate structure includes a dwelling unit base charge, the property shall bill each dwelling unit for the base charge applicable to that unit If the retail public utility s rate structure includes a customer service charge, the property shall bill each dwelling unit the amount of the customer service charge divided by the total number of dwelling units, including vacant units that can receive service through the master meter serving the tenants - 3 - P a g e

Before a property may allocate the retail public utility s master meter bill for water and sewer service to the tenants, the property must first deduct: Dwelling unit base charges or customer service charge, if applicable Common area usage such as installed landscape irrigation systems, pools and laundry rooms, if any, as follows: o If all common areas are separately metered or sub metered, deduct the actual common area usage o If common areas that are served through the master meter that provides water to the dwelling units are not separately metered or sub metered and there is an installed landscape irrigation system, deduct at least a minimum percentage of the retail public utility s master meter bill o If all water used for an installed landscape irrigation system is metered or sub metered and there are other common areas such as pools or laundry rooms that not are not metered or sub metered, deduct at least 5% of the retail public utility s master meter bill; or o If common areas that are served through the master meter that provides water to the dwelling units are not separately metered or submetered and there is no installed landscape irrigation system, deduct at least 5% of the retail public utility s master meter bill or if common areas that are served through the master meter that provides water to the dwelling units are not separately metered or sub metered and there is an installed landscape irrigation system, deduct at least 5% of the retail public utility s master meter bill - 4 - P a g e

TAA - RUBS Calculation Based on Average Occupancy for # of Bedrooms -Sample NAA - RUBS Calculation Based on # of Bedrooms -Sample Total utility charges for community for one month $12,661.33 30% deducted for common area <$3,798.40> Total utility charges billed back to residents $8,862.93 Divided by average occupancy by number of occupants per bedroom in occupied units 571.6 (this number will change based on how many efficiencies, 1 bd, 2 bd, and 3 bd are occupied on the 1 st Wed of the month and is calculated by Ocius) Utility bill per occupant ratio = total charges back to residents / Ocius calculation $15.50 8862.93 / 571.6 = 15.50 Occupancy ratio for 2 bedroom = occupant ratio x 2 bedroom $43.40 15.50 x 2.8 = $43.40 Flat rate trash per unit $5.00 Actual electric/gas consumption vacant recovery *if applicable $12.76 (utilities billed in our name while the resident occupied the unit) Vacant Recovery Fee $5.00 1 st offense $5.00, 2 nd offense $20.00, 3 rd or greater offense $50.00 Resident Statement Fee Texas $2.90/All other states $3.40 Total billed to resident $69.06/$69.56 Average # of Occupants Method Calculation Numbers Dwelling unit with an efficiency = 1 Dwelling unit with one bedroom = 1.6 Dwelling unit with two bedroom = 2.8 Dwelling unit with three bedrooms = 4 RUBS Calculation Based on Actual Number of Occupants -Sample Total residents at the apartment community 200 Total utility charges for community for one month $4,000 25% deducted for common area <$1,000> Total utility charges billed back to residents $3,000 Total charge per occupant = 100% of charges / total # of occupants 3000/200 = 15 $15.00 Apartment with 2 occupants = # occupants x total charge per occupant 2 x 15 = 30 $30.00 Flat rate trash per unit $5.00 Actual electric/gas consumption vacant recovery *if applicable (utilities billed in our name while the resident occupied the unit) $12.76 Vacant Recovery Fee $5.00 1 st offense $5.00, 2 nd offense $20.00, 3 rd or greater offense $50.00 Resident Statement Fee Texas $2.90/All other states $3.40 Total billed to resident $55.66/$56.16-5 - P a g e

RUBS Calculation Based on Square Footage and Number of Occupants - Sample Total residents at the apartment community 200 Total square footage of the apartment community 90,000 Total utility charges for community for one month $4,000 25% deducted for common area <$1,000> Total utility charges billed back to residents $3,000 **800 sqft unit example square footage portion** (Billable utility / by ½ bill) x (800 sqft / by total sqft) (3,000/2 = 1,500) x (800/90,000) $13.33 1,500 x.008888 = 13.33 ** 200 total occupants 1 st Wed of month example ** (Billable utility / ½ bill) x (occ in unit / total occ) (3,000/2 = 1,500) x (2 / 200 =.01) $15.00 1,500 x.01 = 15.00 Total utilities billed to resident (sum of both halves) 13.33 + 15 = 28.33 $28.33 Flat rate trash per unit $5.00 Actual electric/gas consumption vacant recovery *if applicable (utilities billed in our name while the resident occupied the unit) $12.76 Vacant Recovery Fee $50.00 1 st offense $5.00, 2 nd offense $20.00, 3 rd or greater offense $50.00 Resident Statement Fee Texas $2.90/All other states $3.40 Total billed to resident $98.99/$99.49 RUBS Calculation Based on Occupancy Ratio Total utility charges for community for one month $12,661.33 25% deducted for common area <$3,798.40> Total utility charges billed back to residents $8,862.93 Total occupancy (this number will change based on how many units are occupied on the 1 st Wed of the month and is calculated by Ocius) 570 Utility bill per occupant = billable utility/ total occupants 8,862.93/570 = 15.55 $15.55 Utility bill for 2 occupants = (utility bill per occ x occ ratio) 15.55 x 1.6 =24.88 $24.88 Flat rate trash per unit $5.00 Actual electric/gas consumption vacant recovery *if applicable (utilities billed in our name while the resident occupied the unit) $12.76 Vacant Recovery Fee $50.00 1 st offense $5.00, 2 nd offense $20.00, 3 rd or greater offense $50.00 Ratio Occupancy Method Calculation Numbers Resident Statement Fee Texas $2.90/All other states $3.40 Total billed to resident $50.44/51.04 Dwelling unit with one occupant = 1 Dwelling unit with two occupants = 1.6 Dwelling unit with three occupants= 2.2 Dwelling unit with more than three occupants = 2.2 +.04 per each additional occupant - 6 - P a g e

Sub-metering A few properties managed by Milestone are individually sub-metered. Each apartment home has its own water and/or gas meter that is read by an outside company. The resident receives their bill directly from the outside company, and payment is made to them. These types of properties will have their vacant recovery process supported by Ocius even though they will not receive a water or gas billing. The upload to YARDI will include all other utilities and fees excluding the sub-metered utility. - 7 - P a g e

Glossary of Utility Terminology Utility Allocation Guide and Policies Milestone Ecova Allocation Common Area CSA Deregulation Meter Resident Billing Statement RUBS Service Provider Sub-metering TCEQ Utility Units of Measure Water US Gallons Gas - Therms Electric Kilowatt Hour UtilitiesPLUS An Ocius Partner Company, Ecova is an accounts payable and utility monitoring/auditing company. They directly receive property utility bills from the local utility and then fully audit and pay them. They then forward the data to Ocius to use for Vacant Recovery Billing, reporting, and on-line storage. The basis by which utility expenses are apportioned to users by means of a formula rather than measured usage. The method we use is approved by state legislation and has been concluded as a fair and accepted formula. Accounting for the common area utility usage by a pass through percentage amount deducted off the master metered utility bill for the irrigation system, pools, vacant units, etc.. Continuing Service Agreement for uninterrupted electric service upon disconnect of a resident s service. Deregulation is the elimination of some or all regulations from a previously regulated industry or sector of an industry. In this case, electricity and gas sectors of the energy industry have been deregulated in some areas of the country offering competition between providers and choice for consumers. There are three elements to typical energy consumption - generation, delivery and retail sales. Deregulation typically applies to retail sales as those companies buy from generation sources and the delivery companies add their expenses which are either negotiated or passed through to the consumer. In some areas the generation is deregulated so the consumer selects that component although the retail sales side, who produces the monthly bill, remains the same. A device that measures actual utility usage or consumption. Monthly bill sent by Ocius to the resident each month detailing the current rent, utilities etc. due to the property. Statements can be mailed to alternate addresses or e-mailed via the www.myresidentnetwork website. An acronym that stands for Ratio Utility Billing System, which is a calculation method that uses a compensation factor to allocate utility costs among users. A company that provides billing services, either sub-metered and/or RUBS. The practice of using meters to measure master metered utility consumption by individual users. Texas Commission on Environmental Quality (previously known as TNRCC) regulates the Texas Allocation of Water/Wastewater with specific rules and guidelines. Used alternately to describe a provided natural resource commodity, such as water, gas or electric. Consumption of a natural resource commodity. 1 Cubic Feet equals 7.48 gallons. 1 of each equals 100 cubic feet. Delivery rate of 1000 watts per hour. Vacant Cost Recovery on occupied units for electric/gas service in the community s name after a resident moves in and does not transfer service or a resident disconnects service before moving out. This amount is calculated by Ocius and billed back to the resident. - 8 - P a g e

Ocius Ocius is our service provider for RUBS - Ratio Utility Billing System. They save us time and money with their convergent billing and utility expense management systems for property managers by simplifing the billing, payment, and utility management processes for our on-site staff and residents. Below are some of the services provided. Convergent Billing Ocius' Convergent Billing Solution represents a simple, comprehensive, and easy to deploy approach to billing for resident's rent, utility, and ancillary charges in a timely and efficient manner. Property Benefits Customized Resident Statements Support green initiatives with e-billing options Seamless integration with YARDI Resident Benefits Comprehensive and consolidated statement of resident charges including: rent, utilities, submetering, late fees, and unpaid charges Customized, dynamic messaging driven by your property management software Paperless billing to resident's email Ability to utilize the statements as an advanced resident communications tool Utility Expense Management/Utilities Plus The Utilities Plus solution greatly reduces your administrative burden. Ocius' Utilities Plus represents an innovative, easy to deploy system for processing, paying and consolidating a property's recurring utility bills. Ocius' leading-edge solution offers property owners and managers the following: Property Benefits Pays all utilities, including electric, gas, and water/sewer from one consolidated, payables program. The automated expense payables system receives each utility bill, audits the charges, and processes each for payment Billing errors, late fees, double payments, and labor costs to pay individual utility bills are all eliminated Comprehensive analysis of all energy use/costs Ability to collect and report on benchmark data Robust reporting functionality offers search capabilities, including on-line access to scanned images of bills and invoices Recovers vacant unit charges to help reimburse costs when tenants have not promptly transferred their utility service after moving in through automated resident chargeback Integrates with Ocius' Convergent Billing Service Vacant Unit Recovery stops utility theft and removes the responsibility of processing vacant unit electric invoices by the property Utility rate and tariff audits My Resident Network My Resident Network offers residents the following: Resident Benefits Easy to navigate No start-up or ongoing maintenance fees Support your organization's green initiatives - 9 - P a g e

Life of a Utility Bill Local Utility Bill Generated Local Utility Bill Mailed to Ecova/Ocius Ocius billing representative pulls utility bills from Ecova website Ecova audits and pays local utility bill(s) and then forwards data to Ocius Ocius uses YARDI data to allocate charges back to the resident Ocius compares vacant electric, gas, and, water bills to YARDI data Ocius notifies Milestone corporate that Prebill Report is ready for approval Property logs onto Ocius website and reviews Prebill Report. RAC notified with errors or problems Milestone corporate approves Prebill Report Milestone imports monthly utility charges into YARDI Resident Statement mailed or emailed Ocius adds Vacant Recovery charges to Resident Statements Ocius compiles Utilities Plus Reports and posts them to the Ocius website for property review - 10 - P a g e

Data Transfer Preparation Ocius will receive a copy of your YARDI database from your corporate office weekly. It is crucial that Ocius has the most current information to reflect on the monthly Resident Billing Statements. The first Wednesday of each month will be used to calculate bills The data for resident balances will be transferred to Ocius as per the Resident Statement Data Dates in the Dates to Remember on the Portal Items to complete before data transfer: Update number of occupants in Utility Two 1. Ensure the Invalid Number of Occupants in Utility 2 validation is clear. Complete Daily and Weekly/Reconciliation checklists prior to Close Leasing Week Complete Month End Close Checklist if close date is prior to the Resident Statement Data Date for the month Data Verification The Ocius system pulls its information from your YARDI database. The following is a list of information that Ocius uses for billing and the data that needs to be audited and corrected daily. Current Residents On Notice Residents New Move-Ins Transfer Residents Recurring Charges for all status All current recurring charges and scheduled renewals will pull from the Lease Charge screen. The resident balance will pull from the ledger. Activity that occurs after the data transfer WILL NOT appear on the resident statement. - 11 - P a g e

Resident Statement The Resident Statement is mailed to residents the last week of the month and are normally received a few days before the 1 st of the month. These statements reflect all charges from YARDI, credits, previous balances, applicable utility charges and other fees. Resident Statement messages and other information can be edited in Administration on the Ocius Website. Remittance Stub Can be submitted with resident payment but is not required - 12 - P a g e

Resident Statement Layout Billing Summary Information Summary of all charges and credits to date Billing Detail Information Includes previous month s balance/credit with detail on current month s charges. If applicable, Carport, Garage, Storarge, Concess Carport, Concess Garage, Concess Storage, Upgrade Rent, and Rent Discount and Rent will be shown on one line as Rent. Utilites charges will list the consumption period. Resident Reminder - Should be updated to an applicable message by the site by the 10 th of each month for the following month. RM approval required. Additional Information Must NOT not be changed in the state of Texas. Reflects the water municipality and explains that water bill disputes should be communicated directly to the property. All other states can enter additional information such as events, reminders, etc. Service Requests Informs residents that they can submit service requests online at yourresidentloung.com, over the phone, in person, or in writing. Payment Instructions Informs residents that rent is due on the first and that payments can be made in the management office, night drop, or online at yourresidentlounge.com. There are a few properties that have property specific URLs. Late Payment Policy Explains that rent is due on the first and that late fees will be applied as per the signed lease contract. Lease Renewal Message Will only print on Resident Statements when the lease will expire in the next 60 days. My Resident Network App Informs residents of the app which will allow them to access other services on www.myresidentnetwork.com. - 13 - P a g e

Expected Monthly Cost RUBS Billing Averages are calculated based upon the previous calendar year, utilizing the actual utility invoice and the residents RUBS bills. The schedule includes RUBS fees, common area percentage adjustments, and the average monthly bill for all dwelling units. Averages are calculated per month for the lowest and highest water bill for any unit in the apartment community. Utility addendums are required to be completed for all Move-ins and Renewals. In Texas, the RUBS Billing Averages for Previous Calendar Year, indicating the average monthly bill per unit, with the range of the lowest to the highest month s bills for any unit is required. This information is not required on the addendum for states other than Texas, however, this information is provided to the properties to share with their prospects and residents so that they know what to expect. These averages are only a guide based on the previous calendar year s expenses and actual RUBS bills will vary based on consumption, utility rates, and length of service period. These rates are provided each January by Ocius based on the previous year s history. If a property is new to Milestone, we may not have this information and high, low, and average information will remain blank until a history is accumulated. Previous year s averages will be provided to all sites to educate the residents however, not all states require this information on the addendum. Extraordinary Usage of Water/Sewer If extraordinary usage occurs in the common areas, such as power washing exterior, pool or spa filling or repair, etc. please contact the utility company and inquire about receiving a credit for the sewer portion of the monthly expense. In addition, contact the corporate office at utilityadjustment@milestone-mgt.com and include a description of the usage, an estimate of the number of gallons used and the date of usage. An analysis of the usage will be reviewed and the appropriate expense reduction will be determined prior to the RUBS allocation of the expense. Do not expect or promise the residents a reduction in cost. For water line breaks, follow the same procedures as other extraordinary usage, but ask the utility for a credit of both the water and sewer portions of the bill for the approximate number of gallons lost. If the break occurred on the cities portion of the pipe or due to any act by their personnel they will credit both the water and sewer portions. Otherwise a credit for the sewer portion is all we expect. Lease Contract Do not check any utilities as paid by the management company, including water, wastewater, gas, trash, electric, master antenna and cable TV on any lease documents. Your lease should reflect a $50.00 fee for not having utilities in the resident s name if there is an applicable paragraph (individual states vary). If your default lease does not reflect correctly, please contact YARDI Support. - 14 - P a g e

Utility Addenda Each property has its own unique RUBS program. You must never contact a sister property regarding RUBS information as it is property specific. Below are some of the methods available on Blue Moon addenda and used at Milestone properties: Water/Sewer Is allocated by one of the following methods. Check your community s method. Actual occupancy Square footage Ratio occupancy Number of bedrooms Average occupancy Combination of square footage and number of Actual number of occupants persons Trash or Valet Service NAA #1 - #10 Allocation Method on All In One Utility Addendum TAA Number of people in unit/# of the people in entire apt community for the month Square footage/your share of the people in entire apt community for the month Per Dwelling Unit Other formula (described on a separate page) Gas Per Dwelling Unit Average occupancy Other formula (described on a separate page) Actual number of occupants Actual occupancy Square footage Ratio occupancy Number of bedrooms Combination of square footage and number of persons Percentage reflecting unit s share of total people living in apartment community Half unit s share of total square footage and half share of total people living in apartment community Pest Control Per dwelling unit/flat fee Cable Per dwelling unit/flat fee Other Property specific, fee or allocation Utilities Plus Actual prorate electric/gas service in Milestone s name during occupancy - 15 - P a g e

The following chart outlines the various addendums that should be completed in order to charge utilities and fees that are allocated, sub-metered, or billed as a flat fee to our residents. All In One Utility Addendum (Non-Texas) FORM COMMENTARY AZ CO D.C. FL GA MD NJ NV PA TN TX UT VI Lease Addendum for Allocating Water/Wastewater Costs (Texas) Water/Wastewater Submetering Addendum (Texas) Lease Addendum for Allocating Natural Gas Costs (Texas) Natural Gas Allocation - Formula Description (Texas) Lease Addendum for Trash Removal and Recycling Costs Flat Fee (Texas) This addendum should be used by all properties NOT in Texas for all utilities and/or other fees, e.g. pest control, resident statement fee, etc. This form is used for allocation and flat fee methods. This addendum must be given to residents in the state of Texas if their water/sewer is allocated. In addition, the TCEQ guide that prints after the addendum in Blue Moon must be given to the resident. This handout is mandatory. This addendum must be given to residents in the state of Texas if their water/sewer is submetered. In addition, the TCEQ guide that prints after the addendum in Blue Moon must be given to the resident. This handout is mandatory. This addendum is for Texas properties that allocate gas. This addendum is for Texas properties that allocate gas using ratio occupancy (an allocation method used that is not listed as an option on the addendum). This addendum is for Texas properties that charge a recurring flat fee for trash and/or recycling costs. BM BM N/A BM BM BM BM BM BM BM - BM BM - - - - - - - - - - BM - - - - - - - - - - - - BM - - - - - - - - - - - - BM - - - - - - - - - - - - BMC - - - - - - - - - - - - BM - - Lease Addendum for Allocating Trash Removal and Recycling Costs Electrical Submetering Addendum Lease Addendum for Allocating Services and Government Fees - Texas Pest Control and Statement Fees ( If Applicable) (Texas) BM Blue Moon BMC Blue Moon Custom Forms This addendum is for Texas properties that allocate trash and/or recycling costs. Use if electricity is sub-metered and residents pay property. Use if charging pest control or a statement fee in Texas. - - - - - - - - - - BM - - - - - - - - - - - - BM - - - - - - - - - - - BM - - All defaults in Blue Moon are set by the corporate office. If you feel that any of your default setting information is in error, please contact YARDI Support immediately. - 16 - P a g e

Texas Utility and other RUBS Addenda Sample Water/Wastewater Submetering Addendum - 17 - P a g e

Mandatory Resident Handout for all move-ins and renewals - 18 - P a g e

Sample Lease Addendum for Allocating Water/Wastewater Costs - 19 - P a g e

Mandatory Resident Handout Pg 1 for all new move-ins and renewals - 20 - P a g e

Mandatory Handout Pg 2 for all new move-ins and renewals - 21 - P a g e

Mandatory Handout Pg 3-22 - P a g e

Lease Addendum For Trash Removal and Recycling Costs-Flat Fee - 23 - P a g e

Lease Addendum For Allocating Trash Removal and Recycling Costs - 24 - P a g e

Lease Addendum for Allocating Natural Gas Costs - 25 - P a g e

Lease Addendum for Allocating Services and Government Fees - 26 - P a g e

NAA Utility and Other RUBS Services Utility and Services Addendum Non Texas - 27 - P a g e

Pg. 2-28 - P a g e

Energy Information This section will discuss information regarding basic electric and gas industry information, Milestone policies concerning residents and electric/gas, vacant recovery, and the cycle between the City, Ocius, and Milestone, etc. Deregulation Deregulation is the power of choice by the consumer to select their electric/gas buying decisions. Deregulation separates electric service into three distinct functions. Generation Creates the power from resources Transmission & Distribution Regulated Builds and maintains the poles and wires Transports electricity Reads meters Retail Electric Provider (REP) Powers the customers Sends Bills Price Component Negotiable A Continuing Service Agreement (CSA) has been filed for Milestone properties where available to ensure electric/gas service continues to our apartment homes in the event a resident disconnects their service, either during occupancy or upon physically vacating the unit. The property will begin paying for the electric/gas usage immediately when the resident stops their service. Vacant Recovery Due to the separation of the electric/gas service in a deregulation market, execution of a request for service by a resident can by delayed a minimum of 3 7 business days. It may take up to two weeks to get service established in a residents name once they place their initial order with the company of their choice. The property will continue to be billed for service until it begins on the residents account. Ocius will pay all utility bills and will recover vacant electric/gas bills when the unit is occupied, utilizing resident occupancy dates in YARDI. Meter read dates of the Vacant Utility Bill compared to occupancy dates for that unit number The Pro-rate Charges for Vacant Recovery will be calculated based on average daily expense for the service period multiplied by the days occupied during that service period by the resident The Resident Statement will reflect the electric/gas charge as a separate line item, indicating the applicable service dates Once a resident moves out there will be no more vacant utility charges billed by Ocius and placed on their account in Yardi. If you feel a resident had service removed from their responsibility prior to their move-out date you can review your vacant bills on the Ocius website and manually calculate what the resident should owe and revise the Deposit Accounting. For properties utilizing BluTrend s CSA Secure product you can identify end-of-lease violators from their emails. Also any resident that was billed for vacant electic/gas on their last statement likely will have not put service in their name and should be billed from that usage end date to the date of move out on their Deposit Accounting An Electric/Gas Processing Fee (penalty) will be assessed for each Vacant Recovery charge period. While properties may have a different fee as allowed by law and desired by ownership most properties use an escalating fee: 1 st Offense - $5.00, 2 nd Offense - $20.00, 3 rd or more Offenses - $50.00 Vacant Recovery units can be viewed/researched under Utility Expense Management on the Ocius website. - 29 - P a g e

Utility Expense Management There are several reports available on the Ocius website under Utility Expense Management that can help you manage expenses. Some examples of ways to lower vacant utility costs include: Only breakers used for make ready process should be turned on o If the unit is a show unit, the breakers will be left on Turn lights off in the models when not in use Breakers should be marked by maintenance staff for clear identification Individual water heaters should not be turned on until they are to be used Refrigerator thermostats should be set to the warmest setting reasonable Vendors who provide turnaround service should be advised on energy use. Vendors who continually waste our electricity will be charged back costs Air conditioners or heaters should not be set excessively high or low Instead of light timers, photocells should be used wherever possible Porch lighting should be checked for dirty lenses or diffusers, using lower wattage bulbs if they provide sufficient lighting Clubhouse Utilities Thermostats should be set back when unoccupied or programmable thermostats used Ceiling fans may be installed to better circulate conditioned air Mini-blinds should be installed and used to eliminate excessive heat buildup in summer and to retain heat in the winter Weather stripping will diminish heating and cooling loss Door closures help speed the closing of doors For more policy and information regarding energy conservation, see Asset Preservation in the Policy and Operations Manual. - 30 - P a g e

Milestone Action Plan for Unexpected Interruption of Power (Electric or Gas) If the power (electric or gas) goes off on any part of your community, please follow the below instructions: 1.) Make sure it is not a blown fuse or an area outage. Contact the following Ocius Representatives IMMEDIATELY PLEASE DO NOT LEAVE A VOICE MAIL ONLY. Continue to contact until you actually talk with a person. Ocius UtilitiesPlus Dept. ( UtilitiesPlus@Ocius.Net ) Phone 866-850-3500 x 205 Ocius UtilitiesPlus Dept. ( UtilitiesPlus@Ocius.Net ) Phone 866-850-3500 x 228 Sydney Niblack Cowie, Account Manager (Sydney.Niblack@Ocius.Net) Phone - (312) 850-3500 x 230 Additionally, contact the following Milestone Associates IMMEDIATELY PLEASE DO NOT LEAVE A VOICE MAIL ONLY. Continue to contact until you actually talk with a person. Jeff Sherman, Vice President Information Technology (jsherman@milestone-mgt.com) Desk 214-561-1270 Mobile phone 469-446-4114 Gina DeBerry, Operations and Implementation Manager(gdeberry@milestone-mgt.com) Desk 214-561-1272 Mobile phone 972-880-5414 Beth VanWinkle, Regional Vice President (bvanwinkle@milestone-mgt.com) Desk 713-361-7176 Mobile phone 713-539-7047 Eve Horn, Regional Vice President (ehorn@milestone-mgt.com) Desk 214-561-1260 Mobile phone 214-234-6158 Kellie Jackson, Regional Vice President (kjackson@milestone-mgt.com) Desk 904-739-9107 Mobile phone 904-509-6575 2.) What information you will need to have Your community name Your community address The provider (if known) that disconnected the power The meter number that has the red tag on it Approximately when the interruption of service occurred 3.) What to tell your residents? Until we know what caused the interruption of service, please do not speculate as to the cause Let the resident know that as soon as we can determine why the power is out, we will let everyone know We will push to have our power restored IMMEDIATELY; however, we are at the mercy of the power company If you notice the power provider standing next to a meter and they are holding a red tag, please request the provider s employee come to your office. Contact the Ocius Representatives and Milestone Associates as if power has been disconnected. This will allow research and contact to the correct people to stop the disconnection before it begins. - 31 - P a g e

Disconnection Policy at Move In (Electric/Gas) Utility expense is something that Milestone monitors closely and strives to keep under control. One way to keep this expense in line is to require residents to have electricity/gas put in their name upon move in as required in their lease. Milestone has implemented a policy to help ensure the electricity/gas account number has actually been placed in the resident s name. Upon move-in, the Community Director is required to contact their utility provider to request service be discontinued in the community s name for the newly occupied unit Remind the new resident at lease signing that they are required by the lease to have utilities set up in their name and provide an account number Inform your new resident that within 3-5 days service in the community name will be disconnected; so if they have not established service in their name, they will be without power (Note: Even if your community does not have a Continuing Service Agreement the electricity in the apartments has been placed in our name in order to do the make ready. You will still be required to contact the utility provider to disconnect service in the community s name upon move in of a new resident.) A few things to keep in mind: This process usually takes 3 to 5 days By removing the unit from our CSA you will NOT suspend any service that a resident has already established in their name Some utility providers will charge a small fee to disconnect the unit Milestone will pay this Remember that electric providers guidelines and policies may vary. Be sure to use your specific local procedures Below you will find some of the more common electric providers used in various markets and methods of contacts to disconnect from Milestone s name: Electric Provider Phone Number Fax Number Website E-Mail Gexa 713-961-9399 713-961-7997 www.gexa.com apartmentservices@gexa.com N/A TXU 800-316-2135 972-507-0809 www.txu.com/apartments master@txu.com N/A Reliant 800-894-6678 888-773-9647 www.reliant.com\multifamily multifamily@reliant.com N/A Austin 512-494-9400 512-505-4035 www.austinenergy.com N/A Nashville Electric 615-736-6900 615-747-3672 www.nespower.com N/A Jacksonville Electric 904-665-6000 904-665-7990 www.jea.com cojmail@jea.com Tampa Electric 813-223-0800 N/A www.tampaelectric.com N/A City Public Service 210-353-2222 N/A www.cpsenergey.com N/A Green Mountain 866-484-8409 NA www.greenmountain.com vip@greenmountain.com N/A - 32 - P a g e

Disputed Electric/Gas Recovery There can be a time lag in set-up of service with utility providers. If an electric or gas recovery was billed, then the utility service for that unit was in Milestone s name during the period indicated on the Vacant Recovery Bill. The following information must be obtained for ALL types of disputes: Resident must provide a copy of their bill from the Utility Company, indicating service in their name Obtain a copy of the RUBS VCRO (vacant recovery) bill from the Ocius website that Milestone paid so that the ESI# or account#, address, and service dates can be compared If the resident paid electric or gas recovery to Milestone and was billed by the Utility Company, the following must occur: Provide the resident with a copy of the actual Utility Invoice, indicating the service in Milestone s name during occupancy dates of the resident and a copy of their payment to the property, recorded in YARDI. The resident will need to contact the Utility Company to resolve the issue Copy all documents and forward to Regional Accounting Coordinator If a refund is received: Resolution will be distributed by email notification to the site and supervisor, from the RAC/YARDI Support Reverse charge in YARDI after receiving approval email with a description of Paid to Milestone If the resident paid the Utility Company and then receives a RUBS bill from Milestone, the following must occur: Resident to provide copy of the method of payment to the Utility Company Copy all documents and forward to Regional Accounting Coordinator If it is determined that the utility was double billed: Resolution will be distributed by email notification to the site and supervisor, from the RAC/YARDI Support Reverse charge in YARDI after receiving approval email with a description of Paid to the Utility Company If the resident paid the Utility Company and paid the Milestone RUBS bill: Resident to provide a copy of the method of payment to the Utility Company Copy all documents and forward to Regional Accounting Coordinator/YARDI Support. If it is determined that the utility was double billed: Resolution will be distributed by email notification to the site, supervisor from the RAC/YARDI Support Reverse charge in YARDI after receiving approval email with a description of Paid to the Utility Company and Milestone Note: Green Mountain bill images are not available on the Ocius website. You will need to provide the electronic file that is available. - 33 - P a g e

Billing Final Utilities on Deposit Accounting Move-Out Calculator Ocius will only calculate and create utility and fee charges for current and on notice residents based on information received at the time of data transfer (see Dates to Remember on the portal). For residents that were already a Past status at the time of the last data transfer, see the Not In List section of this chapter. Using the expected move out date, this function should be used to calculate final utilities and charged on the applicable past resident s Deposit Accounting. While in Monthly Prebill, Click on Move Out Calculator Select the Move out link next to the desired resident The Move-Out Calculator screen will be displayed. Enter the actual/expected move out date Click Process twice The final utility charges that should be charged on the Deposit Accounting will be displayed. Click Process The Final Utility Statement must be printed and retained in the file as supporting documentation of final utility charges and fees. Residents will continue to receive statements until they are moved out in YARDI and have a status of Past. To change the date, simply enter the new date and process again. - 34 - P a g e

Not In List This function should be used to calculate final charges for a resident not listed under Move-Out Calculator. This will apply to any resident that was already a Past status at the time of the last data transfer to Ocius per the Dates to Remember on the portal. Click Not In List link The Rub Unit Manager will be displayed. Select the applicable unit number Enter the actual move-out date Click Process twice The final utility charges that should be charged on the Deposit Accounting will be displayed. Click Process The Final Utility Statement must be printed and retained in the file as supporting documentation of final utility charges and fees. Residents will continue to receive statements until they are moved out in YARDI and have a status of Past. To change the date, simply enter the new date and process again. - 35 - P a g e

Billing Multiple Gas Charges at Move Out There are properties that have 2 separate gas bills that are charged back to the residents. If you are one of these properties, you will see two links. In this example, one is for the furnace gas and the other is for everything else. When processing Deposit Accounting for EACH resident, you must create, print for the file, and charge BOTH amounts and include in their final utilities. In this example, a move out was processes on the Ocius Website for Nancy Luke. Notice that the Charges Summary for the Landings at Pine Lakes and Landings at Pine Lakes Furnace look identicle from this screen. Not until you click on the Move-Out link will you see the separate charges. If Nancy were to move out today, her final utility bills charged on her Deposit Accounting should not only include the trash, and gas of $14.33, it should also include a separate charge/ line item for the furnace gas in the amount of $6.22. - 36 - P a g e

Resident Statement There will always be a separte line item on the Resident Statements mailed out by Ocius for Domestic Hot Water AND Furnace. Deposit Accounting When processing Deposit Accounting, you will always need to add Hot Water and Furnace in front of Gas and the last read dates. These amounts should always match up to the last Resident Statement, see above screen shot. You must manually add a Final Hot Water Gas charge and a Final Furnace Gas charge AND the final read dates as per the Charges Summary of the Move Out processed on the Ocius Website. Both Charge Summaries must be printed and retained in the file. This exact terminology is very important. Final gas charges should never be added together on one line. - 37 - P a g e

Conservation A study by NAA shows that implementing a RUBS program can reduce a property s water consumption by up to 20%. In turn, Milestone conserves water and lowers expenses by repairing leaks, fixing dripping faucets, and installing low flow. - 38 - P a g e

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