Existing law regulates the hiring of real property and imposes various requirements on landlords relating to the application for, and leasing of, residential rental property. Existing law prohibits a landlord or its agent from charging a tenant a fee for serving, posting, or otherwise delivering a notice of termination of a hiring of residential property, as specified. Existing law also prohibits a landlord or its agent from charging a tenant any fee for payment by check for rent or security deposit, as provided.

This bill would also require that any payment received from, or on behalf of, a tenant be applied to rent, rental debt, and any outstanding fees in a specified order, and would prohibit late fees from being charged to a tenant whose only delinquency is attributable to nonpayment or late payment of a late fee. The bill would specify that a decrease in housing services, as defined, is an increase in rent.

The bill would provide that a landlord or landlords agent who violates these provisions is liable to a tenant in a civil action for damages, including treble damages. The bill would provide that its provisions do not prevent a landlord from recovering damages otherwise permitted by law. The bill would establish a 4-year 3-year statute of limitations to bring an action under these provisions.

The bill would provide that a waiver of its provisions is contrary to public policy and void, that the bills provisions do not preempt a local government from imposing additional requirements upon a landlord or providing greater protection to tenants, and that its void and unenforceable, and the bills provisions are severable.

Existing law provides that the hiring of residential real property or commercial real property by a qualified commercial tenant for a term not specified by the parties, is deemed to be renewed at the end of the term implied by law unless one of the parties gives written notice to the other of the partys intention to terminate the tenancy, as specified.

Existing law defines a qualified commercial tenant for these purposes to mean a tenant of commercial real property that is a microenterprise restaurant with fewer than 10 employees, or a nonprofit organization with fewer than 20 employees, that has provided the landlord a specified written notice that the tenant is a qualified commercial tenant and a self-attestation as to the number of individuals it employs.

This bill would increase the maximum number of individuals employed by a nonprofit organization for these purposes to fewer than 25.

By expanding the scope of the crime of perjury, this bill would impose a state-mandated local program.

The California Constitution requires the state to reimburse local agencies and school districts for certain costs mandated by the state. Statutory provisions establish procedures for making that reimbursement.

This bill would provide that no reimbursement is required by this act for a specified reason.

ASSEMBLY THIRD READING

ATR Bill Id:AB 1248

Author:(Haney)

As Amended Ver:June 2, 2025

Majority vote

SUMMARY

Limits the fees that a landlord may charge in addition to rent and requires that any housing services provided by the landlord must be included in the rent and not charged as a separate fee.

Major Provisions

1. Requires on or after April 1, 2026, a landlord or landlord's agent who advertises, displays, or offers residential property for rent to include in any advertisement, display, or offer the price, including all required fees or charges, and a description of all available optional housing services, as defined, including the associated fees for each optional housing service.
2. Prohibits a landlord or landlord's agent from using a ratio utility billing system to allocate, demand, or collect fees or charges from a tenant, except for fees or charges for water or sewer service, as provided.
3. Prohibit the landlord from charging any fee or charge other than required fees and charges, as defined, and fees or charges for optional housing services.
4. Provides that a waiver of its provisions is contrary to public policy and void and unenforceable, and the bill's provisions are severable.
5. Makes a landlord or landlord's agent who violates the provisions of this bill liable to a tenant in a civil action for damages, including treble damages, and establishes a three year statute of limitations to bring such an action. Specifies that nothing in this bill would prevent a landlord from recovering damages otherwise permitted by law.

COMMENTS

Existing laws, some only recently enacted, place limits on the ability of landlords to charge additional fees or payments that go beyond rent. For example, a landlord is authorized to demand a security deposit, but the deposit cannot be more than one month's rent. Landlords may charge late fees and applicant screening fees, but existing law sets limits on the amounts and manner in which they can be charged. Existing law prohibits a landlord from charging a fee for a tenant to pay by check, and prohibits the landlord from charging a fee for posting, serving, or otherwise delivering any notice of termination of the tenancy. However, existing law imposes few, if any, limits on a landlord's ability to charge additional fees for housing services or amenities that the landlord provides to tenants. According to many media reports, these additional fees and charges are not always presented to the prospective tenant as clearly as they should or could be; or if they are, the prospective tenant would have no means of knowing, at the time of signing the lease, whether the services or amenities are worth the price. As a result, many tenants who assume that they are renting a dwelling for certain price subsequently discover that the true cost of their "rent" is much higher than advertised or reasonably expected.

This bill addresses the problem by providing that, for tenancies created on or after January 1, 2026, tenants will only be liable for "rent," as defined, and a few other expressly authorized fees or charges. Specifically, the bill requires a landlord or landlord's agent who advertises, displays, or offers residential property for rent to include in any advertisement, display, or offer the price, including all required fees or charges, and a description of all available optional housing services, as defined, including the associated fees for each optional housing service.

The bill also prohibits a landlord's agent from using a ratio utility billing system to allocate, demand, or collect fees or charges from a tenant, except for fees or charges for water or sewer service, as provided. Finally, the bill makes a person who violates the provisions of this bill liable to the tenant for damages, as specified.

According to the Author

According to the author, "while the Tenant Protection Act (TPA) of 2019 placed necessary limits on rent increases, certain landlords have found ways to exploit perceived loopholes by imposing excessive fees that circumvent these protections. These hidden or misleading charges—including Ratio Utility Billing System (RUBS) fees, trash concierge fees, pest control fees, and other unbundled costs—unfairly drive up the true price of housing, making it harder for tenants to budget, compare rental costs, and maintain stable housing." The author contends that by "prohibiting landlords from imposing new or increased fees outside of rent, the bill prevents workarounds that artificially inflate housing costs beyond the [TPA] rent cap."

Arguments in Support

According to California Attorney General (AG) Rob Bonta, who is one of the co-sponsors of this legislation, AB 1248 will "protect tenants from unfair rental housing fees and other increases to their monthly rent [and provide] necessary clarity about what fees may be charged to tenants in addition to the advertised rent." The AG hopes that this measure will "end practices designed to circumvent state law rent cap protections and misleading advertisements that use an artificially low stated rent and add additional fees, which tenants often cannot control or predict."

Arguments in Opposition

The California Apartment Association (CAA) opposes this bill. They contend that restricting fees – including voluntary fees for optional services – will simply mean that landlords either will not provide the services or they will fold them into the price of the rent, thereby doing nothing to affect the affordability of rents. Specifically, CAA makes the following arguments against this bill:

For decades, separate fees and charges—imposed by both small and large housing providers—have been a standard part of the rental housing industry. These fees often help illustrate the costs associated with operating rental housing and can give tenants the ability to manage and reduce certain expenses, such as utilities and water. Mandating that all fees be folded into rent will not reduce the overall cost of housing. Instead, it will reduce transparency and limit tenants' ability to understand or control specific costs. AB 1248 so severely restricts the types of fees and charges that can be passed on separately to tenants that it is likely to increase overall rent prices, particularly for new tenants. The bill also fails to account for voluntary fees—charges for optional services that tenants may choose to utilize. As a result, tenants may ultimately lose access to convenient services that enhance their rental experience. That said, CAA strongly supports transparency in how fees and charges are advertised and communicated. We believe tenants should have a clear understanding of their total housing costs, including any fees, both when reviewing listings and at the time of signing a rental agreement. This is the approach we encourage you to pursue with AB 1248, rather than one that gives the impression, inaccurately, that housing costs will decrease as a result of AB 1248.

FISCAL COMMENTS

None

VOTES

ASM JUDICIARY: 8-3-1

YES: Kalra, Bauer-Kahan, Bryan, Connolly, Harabedian, Lee, Stefani, Zbur

NO: Dixon, Macedo, Sanchez

ABS, ABST OR NV: Pacheco

UPDATED

VERSION: June 2, 2025

CONSULTANT: Tom Clark / JUD. / (916) 319-2334 FN: 0000954

ASSEMBLY THIRD READING

ATR Bill Id:AB 1248

Author:(Haney)

As Amended Ver:March 24, 2025

Majority vote

SUMMARY

Limits the fees that a landlord may charge in addition to rent and requires that any housing services provided by the landlord must be included in the rent and not charged as a separate fee.

Major Provisions

1. Requires, for new residential tenancies beginning on or after January 1, 2026, that a tenant only be obligated to pay rent and the following fees or charges to a landlord:
   1. A security deposit in the amount permitted by law.
   2. Rent stabilization fees or other similar fees or charges, other than taxes, imposed by a government.
   3. Fees or charges that the tenant pays directly to the landlord or landlord's agent for submetered water.
   4. Fees or charges for a tenant's late payments to the extent permitted by law.
2. Requires, for residential tenancies that began before January 1, 2026, that a tenant only be obligated to pay rent, the fees and charges described in 1) above, any fees or charges that were charged at the start of the tenancy, and fees or charges for specified utilities, including the use of a ratio utility billing system, as defined, if it meets specified criteria.
3. Defines "rent" to mean a single periodic payment and nonmonetary consideration to the landlord in exchange for the use or occupancy of a rental unit and premises and the provision of housing services under a rental contract or agreement, oral, written, or implied.
4. Defines "housing services" to mean all services provided by the landlord related or connected to the use or occupancy of residential real property, including, but not limited to, trash collection, electrical service, water service, sewer service, gas service, other utilities, elevator service, storage, facilities, laundry, repairs, maintenance, heat, hot water, pest control, or any other benefits, privileges, or services, whether express or implied.
5. Provides, for residential tenancies beginning before or after January 1, 2026, that if a tenant is given a discount on rent or fees or charges in exchange for signing a rental agreement, then the rental agreement must clearly state specified information about the amount and timing of the discount.
6. Specifies that nothing in the bill prevents a tenant from being charged for individually metered utilities if the rental agreement meets prescribed requirements.
7. Requires that any payment received from a tenant be applied to rent, rental debt, and any outstanding fees in a specified order, and would prohibit late fees from being charged to a tenant whose only delinquency is attributable to nonpayment or late payment of a late fee.
8. Provides that a decrease in housing services, as defined, is an increase in rent.
9. Makes a landlord or landlord's agent who violates the provisions of this bill liable to a tenant in a civil action for damages, including treble damages, and establishes a four year statute of limitations to bring such an action. Specifies that nothing in this bill would prevent a landlord from recovering damages otherwise permitted by law.

COMMENTS

Existing laws, some only recently enacted, place limits on the ability of landlords to charge additional fees or payments that go beyond rent. For example, a landlord is authorized to demand a security deposit, but the deposit cannot be more than one month's rent. Landlords may charge late fees and applicant screening fees, but existing law sets limits on the amounts and manner in which they can be charged. Existing law prohibits a landlord from charging a fee for a tenant to pay by check, and prohibits the landlord from charging a fee for posting, serving, or otherwise delivering any notice of termination of the tenancy. However, existing law imposes few, if any, limits on a landlord's ability to charge additional fees for housing services or amenities that the landlord provides to tenants. According to many media reports, these additional fees and charges are not always presented to the prospective tenant as clearly as they should or could be; or if they are, the prospective tenant would have no means of knowing, at the time of signing the lease, whether the services or amenities are worth the price. As a result, many tenants who assume that they are renting a dwelling for certain price subsequently discover that the true cost of their "rent" is much higher than advertised or reasonably expected.

This bill addresses the problem by providing that, for tenancies created on or after January 1, 2026, tenants will only be liable for "rent," as defined, and a few other expressly authorized fees or charges: a security deposit in the amount permitted by law; any rent stabilization or similar fees imposed by government; charges paid to the landlord for submetered water; or charges for late payments as permitted by law. For tenancies created before January 1, 2026, the tenant could be charged all of these same fees, as well as any fees or charges that were charged at the start of the tenancy, and fees or charges for utilities that rely on a "ratio utility billing system," which is essentially any proportional billing system that does not rely on individually metered units. The bill specifies that nothing in its provisions would prevent a tenant from being charged for individually metered utilities, so long as this is clearly provided for in the rental agreement.

To fully understand the scope of the bill, one must look closely at its definitions. The bill defines "rent" to include any periodic payment made to the landlord for the use and occupancy of the dwelling and for any "housing services" that are "provided by the landlord." "Housing services" is defined, in turn, to mean any services "related or connected to the use or occupancy of residential real property." These services could include "trash collection, electrical service, water service, sewer service, gas service, other utilities, elevator service, storage, facilities, laundry, repairs, maintenance, heat, hot water, pest control, or any other benefits, privileges, or services, whether express or implied." Of course, many of these services – like electrical and gas services or "other utilities" – are typically not part of the rent and are not paid to the landlord. However, in cases where the landlord provides or pays for these services, the landlord could not charge the tenant a separate fee for those services. The landlord would, at least for tenancies created on or after January 1, 2026, pass the cost of the services onto the tenant in the form of increased rent. For tenancies created before January 1, 2026, a landlord could continue to charge for such services, but only subject to certain conditions, and only if they had already charged for those services and charge the tenant no more than the actual cost of those utilities.

Transparency vs prohibition. While the author and co-sponsors claim that the fees and charges that prompted this bill are often "hidden" or deceptively presented, it is important to stress that this bill is not just a disclosure or transparency bill. It would not merely require the landlord to be transparent about additional fees beyond rent in advertising, rental agreements, or other communications with a tenant or prospective tenant; rather, it would prohibit the landlord from charging such fees in addition to the rent. The "rent," that is, must include those services and the landlord is barred from charging for those services through extra fees, regardless of whether the fees are disclosed in an advertisement or rental agreement.

Definition of "housing services" and parking. The bill defines "rent" as a payment made for the right to use and occupy the property, the usual definition of rent. Yet "rent" under the bill also includes any "housing services" that the landlord provides. The examples provided in the definition is not an exhaustive list, and some of things expressly included (like electricity, gas, and "other utilities") are things that are not typically included in rent. Given recently enacted legislation that expressly requires landlords to "unbundle" parking from the price of rent, the lack of any reference to parking is striking. Since the list of examples in the definition of "housing services" includes the oft used phrase "included, but not limited to," this means that parking might be considered a "housing service," since it is arguably "related or connected to the use or occupancy of residential real property." If it is considered a housing service, then a landlord could not charge a separate parking fee even though an existing law requires the landlord to unbundle it from the rent and charge it separately.

A "decrease in housing services." The bill declares that "a decrease in housing services is an increase in rent." Apparently, this provision relates to the presumption that landlords are redefining what is considered "rent" in order to circumvent the Tenant Protection Act (TPA). If the landlord that previously provided laundry, storage facilities, or water services to tenants, and then decided to stop providing those services without lowering the rent, then that would effectively be an increase in the rent. (It might also be a breach of the rental contract under existing law.) However, it is not entirely clear how one would calculate this to determine whether or not the reduction of services constituted a rent increase in violation of TPA.

The utility of ratio utility billing systems. This bill would prohibit the use of "ratio utility billing systems" (RUBS) for any tenancy created on or after January 1, 2026, and would only permit it for tenancies created before that date under specified conditions. RUBS, a system that has been used for many years, refers to the allocation of utility costs to tenants through any billing system other than individual meters. Since January 1, 2018, California law has required all new multifamily construction to include an individual meter (or submeter) for each individual rental unit. If a landlord wants to charge a tenant separately for water, they must use a submeter and disclose this charge to the tenant. However, many older multi-unit rental buildings do not have individual meters and, the cost of providing them may be prohibitive. RUBS relies on a formula, based on square footage and the number of occupants in each unit, with deductions for common areas, to allocate the total cost of the utility among the various tenants. This is not a perfect match, since a frugal large household might use less water than a profligate small household. But in the absence of RUBS, the landlord would either charge each unit an equal share of the cost (regardless of unit size or number of occupants) or do what amounts to the same thing: not charge the tenants but increase the rent across the board to cover the cost of the utility.

According to the Author

According to the author, "while the Tenant Protection Act (TPA) of 2019 placed necessary limits on rent increases, certain landlords have found ways to exploit perceived loopholes by imposing excessive fees that circumvent these protections. These hidden or misleading charges—including Ratio Utility Billing System (RUBS) fees, trash concierge fees, pest control fees, and other unbundled costs—unfairly drive up the true price of housing, making it harder for tenants to budget, compare rental costs, and maintain stable housing." The author contends that by "prohibiting landlords from imposing new or increased fees outside of rent, the bill prevents workarounds that artificially inflate housing costs beyond the [TPA] rent cap."

Arguments in Support

According to California Attorney General (AG) Rob Bonta, who is one of the co-sponsors of this legislation, AB 1248 will "protect tenants from unfair rental housing fees and other increases to their monthly rent [and provide] necessary clarity about what fees may be charged to tenants in addition to the advertised rent." The AG hopes that this measure will "end practices designed to circumvent state law rent cap protections and misleading advertisements that use an artificially low stated rent and add additional fees, which tenants often cannot control or predict."

Arguments in Opposition

The California Apartment Association (CAA) opposes this bill. They contend that restricting fees – including voluntary fees for optional services – will simply mean that landlords either will not provide the services or they will fold them into the price of the rent, thereby doing nothing to affect the affordability of rents. Specifically, CAA makes the following arguments against this bill:

For decades, separate fees and charges—imposed by both small and large housing providers—have been a standard part of the rental housing industry. These fees often help illustrate the costs associated with operating rental housing and can give tenants the ability to manage and reduce certain expenses, such as utilities and water. Mandating that all fees be folded into rent will not reduce the overall cost of housing. Instead, it will reduce transparency and limit tenants' ability to understand or control specific costs. AB 1248 so severely restricts the types of fees and charges that can be passed on separately to tenants that it is likely to increase overall rent prices, particularly for new tenants. The bill also fails to account for voluntary fees—charges for optional services that tenants may choose to utilize. As a result, tenants may ultimately lose access to convenient services that enhance their rental experience. That said, CAA strongly supports transparency in how fees and charges are advertised and communicated. We believe tenants should have a clear understanding of their total housing costs, including any fees, both when reviewing listings and at the time of signing a rental agreement. This is the approach we encourage you to pursue with AB 1248, rather than one that gives the impression, inaccurately, that housing costs will decrease as a result of AB 1248.

FISCAL COMMENTS

None

VOTES

ASM JUDICIARY: 8-3-1

YES: Kalra, Bauer-Kahan, Bryan, Connolly, Harabedian, Lee, Stefani, Zbur

NO: Dixon, Macedo, Sanchez

ABS, ABST OR NV: Pacheco

UPDATED

VERSION: March 24, 2025

CONSULTANT: Tom Clark / JUD. / (916) 319-2334 FN: 0000255

ASSEMBLY THIRD READING

ATR Bill Id:AB 1248

Author:(Haney)

As Amended Ver:March 24, 2025

Majority vote

SUMMARY

Limits the fees that a landlord may charge in addition to rent and requires that any housing services provided by the landlord must be included in the rent and not charged as a separate fee.

Major Provisions

1. Requires, for new residential tenancies beginning on or after January 1, 2026, that a tenant only be obligated to pay rent and the following fees or charges to a landlord:
   1. A security deposit in the amount permitted by law.
   2. Rent stabilization fees or other similar fees or charges, other than taxes, imposed by a government.
   3. Fees or charges that the tenant pays directly to the landlord or landlord's agent for submetered water.
   4. Fees or charges for a tenant's late payments to the extent permitted by law.
2. Requires, for residential tenancies that began before January 1, 2026, that a tenant only be obligated to pay rent, the fees and charges described in 1) above, any fees or charges that were charged at the start of the tenancy, and fees or charges for specified utilities, including the use of a ratio utility billing system, as defined, if it meets specified criteria.
3. Defines "rent" to mean a single periodic payment and nonmonetary consideration to the landlord in exchange for the use or occupancy of a rental unit and premises and the provision of housing services under a rental contract or agreement, oral, written, or implied.
4. Defines "housing services" to mean all services provided by the landlord related or connected to the use or occupancy of residential real property, including, but not limited to, trash collection, electrical service, water service, sewer service, gas service, other utilities, elevator service, storage, facilities, laundry, repairs, maintenance, heat, hot water, pest control, or any other benefits, privileges, or services, whether express or implied.
5. Provides, for residential tenancies beginning before or after January 1, 2026, that if a tenant is given a discount on rent or fees or charges in exchange for signing a rental agreement, then the rental agreement must clearly state specified information about the amount and timing of the discount.
6. Specifies that nothing in the bill prevents a tenant from being charged for individually metered utilities if the rental agreement meets prescribed requirements.
7. Requires that any payment received from a tenant be applied to rent, rental debt, and any outstanding fees in a specified order, and would prohibit late fees from being charged to a tenant whose only delinquency is attributable to nonpayment or late payment of a late fee.
8. Provides that a decrease in housing services, as defined, is an increase in rent.
9. Makes a landlord or landlord's agent who violates the provisions of this bill liable to a tenant in a civil action for damages, including treble damages, and establishes a four year statute of limitations to bring such an action. Specifies that nothing in this bill would prevent a landlord from recovering damages otherwise permitted by law.

COMMENTS

Existing laws, some only recently enacted, place limits on the ability of landlords to charge additional fees or payments that go beyond rent. For example, a landlord is authorized to demand a security deposit, but the deposit cannot be more than one month's rent. Landlords may charge late fees and applicant screening fees, but existing law sets limits on the amounts and manner in which they can be charged. Existing law prohibits a landlord from charging a fee for a tenant to pay by check, and prohibits the landlord from charging a fee for posting, serving, or otherwise delivering any notice of termination of the tenancy. However, existing law imposes few, if any, limits on a landlord's ability to charge additional fees for housing services or amenities that the landlord provides to tenants. According to many media reports, these additional fees and charges are not always presented to the prospective tenant as clearly as they should or could be; or if they are, the prospective tenant would have no means of knowing, at the time of signing the lease, whether the services or amenities are worth the price. As a result, many tenants who assume that they are renting a dwelling for certain price subsequently discover that the true cost of their "rent" is much higher than advertised or reasonably expected.

This bill addresses the problem by providing that, for tenancies created on or after January 1, 2026, tenants will only be liable for "rent," as defined, and a few other expressly authorized fees or charges: a security deposit in the amount permitted by law; any rent stabilization or similar fees imposed by government; charges paid to the landlord for submetered water; or charges for late payments as permitted by law. For tenancies created before January 1, 2026, the tenant could be charged all of these same fees, as well as any fees or charges that were charged at the start of the tenancy, and fees or charges for utilities that rely on a "ratio utility billing system," which is essentially any proportional billing system that does not rely on individually metered units. The bill specifies that nothing in its provisions would prevent a tenant from being charged for individually metered utilities, so long as this is clearly provided for in the rental agreement.

To fully understand the scope of the bill, one must look closely at its definitions. The bill defines "rent" to include any periodic payment made to the landlord for the use and occupancy of the dwelling and for any "housing services" that are "provided by the landlord." "Housing services" is defined, in turn, to mean any services "related or connected to the use or occupancy of residential real property." These services could include "trash collection, electrical service, water service, sewer service, gas service, other utilities, elevator service, storage, facilities, laundry, repairs, maintenance, heat, hot water, pest control, or any other benefits, privileges, or services, whether express or implied." Of course, many of these services – like electrical and gas services or "other utilities" – are typically not part of the rent and are not paid to the landlord. However, in cases where the landlord provides or pays for these services, the landlord could not charge the tenant a separate fee for those services. The landlord would, at least for tenancies created on or after January 1, 2026, pass the cost of the services onto the tenant in the form of increased rent. For tenancies created before January 1, 2026, a landlord could continue to charge for such services, but only subject to certain conditions, and only if they had already charged for those services and charge the tenant no more than the actual cost of those utilities.

Transparency vs prohibition. While the author and co-sponsors claim that the fees and charges that prompted this bill are often "hidden" or deceptively presented, it is important to stress that this bill is not just a disclosure or transparency bill. It would not merely require the landlord to be transparent about additional fees beyond rent in advertising, rental agreements, or other communications with a tenant or prospective tenant; rather, it would prohibit the landlord from charging such fees in addition to the rent. The "rent," that is, must include those services and the landlord is barred from charging for those services through extra fees, regardless of whether the fees are disclosed in an advertisement or rental agreement.

Definition of "housing services" and parking. The bill defines "rent" as a payment made for the right to use and occupy the property, the usual definition of rent. Yet "rent" under the bill also includes any "housing services" that the landlord provides. The examples provided in the definition is not an exhaustive list, and some of things expressly included (like electricity, gas, and "other utilities") are things that are not typically included in rent. Given recently enacted legislation that expressly requires landlords to "unbundle" parking from the price of rent, the lack of any reference to parking is striking. Since the list of examples in the definition of "housing services" includes the oft used phrase "included, but not limited to," this means that parking might be considered a "housing service," since it is arguably "related or connected to the use or occupancy of residential real property." If it is considered a housing service, then a landlord could not charge a separate parking fee even though an existing law requires the landlord to unbundle it from the rent and charge it separately.

A "decrease in housing services." The bill declares that "a decrease in housing services is an increase in rent." Apparently, this provision relates to the presumption that landlords are redefining what is considered "rent" in order to circumvent the Tenant Protection Act (TPA). If the landlord that previously provided laundry, storage facilities, or water services to tenants, and then decided to stop providing those services without lowering the rent, then that would effectively be an increase in the rent. (It might also be a breach of the rental contract under existing law.) However, it is not entirely clear how one would calculate this to determine whether or not the reduction of services constituted a rent increase in violation of TPA.

The utility of ratio utility billing systems. This bill would prohibit the use of "ratio utility billing systems" (RUBS) for any tenancy created on or after January 1, 2026, and would only permit it for tenancies created before that date under specified conditions. RUBS, a system that has been used for many years, refers to the allocation of utility costs to tenants through any billing system other than individual meters. Since January 1, 2018, California law has required all new multifamily construction to include an individual meter (or submeter) for each individual rental unit. If a landlord wants to charge a tenant separately for water, they must use a submeter and disclose this charge to the tenant. However, many older multi-unit rental buildings do not have individual meters and, the cost of providing them may be prohibitive. RUBS relies on a formula, based on square footage and the number of occupants in each unit, with deductions for common areas, to allocate the total cost of the utility among the various tenants. This is not a perfect match, since a frugal large household might use less water than a profligate small household. But in the absence of RUBS, the landlord would either charge each unit an equal share of the cost (regardless of unit size or number of occupants) or do what amounts to the same thing: not charge the tenants but increase the rent across the board to cover the cost of the utility.

According to the Author

According to the author, "while the Tenant Protection Act (TPA) of 2019 placed necessary limits on rent increases, certain landlords have found ways to exploit perceived loopholes by imposing excessive fees that circumvent these protections. These hidden or misleading charges—including Ratio Utility Billing System (RUBS) fees, trash concierge fees, pest control fees, and other unbundled costs—unfairly drive up the true price of housing, making it harder for tenants to budget, compare rental costs, and maintain stable housing." The author contends that by "prohibiting landlords from imposing new or increased fees outside of rent, the bill prevents workarounds that artificially inflate housing costs beyond the [TPA] rent cap."

Arguments in Support

According to California Attorney General (AG) Rob Bonta, who is one of the co-sponsors of this legislation, AB 1248 will "protect tenants from unfair rental housing fees and other increases to their monthly rent [and provide] necessary clarity about what fees may be charged to tenants in addition to the advertised rent." The AG hopes that this measure will "end practices designed to circumvent state law rent cap protections and misleading advertisements that use an artificially low stated rent and add additional fees, which tenants often cannot control or predict."

Arguments in Opposition

The California Apartment Association (CAA) opposes this bill. They contend that restricting fees – including voluntary fees for optional services – will simply mean that landlords either will not provide the services or they will fold them into the price of the rent, thereby doing nothing to affect the affordability of rents. Specifically, CAA makes the following arguments against this bill:

For decades, separate fees and charges—imposed by both small and large housing providers—have been a standard part of the rental housing industry. These fees often help illustrate the costs associated with operating rental housing and can give tenants the ability to manage and reduce certain expenses, such as utilities and water. Mandating that all fees be folded into rent will not reduce the overall cost of housing. Instead, it will reduce transparency and limit tenants' ability to understand or control specific costs. AB 1248 so severely restricts the types of fees and charges that can be passed on separately to tenants that it is likely to increase overall rent prices, particularly for new tenants. The bill also fails to account for voluntary fees—charges for optional services that tenants may choose to utilize. As a result, tenants may ultimately lose access to convenient services that enhance their rental experience. That said, CAA strongly supports transparency in how fees and charges are advertised and communicated. We believe tenants should have a clear understanding of their total housing costs, including any fees, both when reviewing listings and at the time of signing a rental agreement. This is the approach we encourage you to pursue with AB 1248, rather than one that gives the impression, inaccurately, that housing costs will decrease as a result of AB 1248.

FISCAL COMMENTS

None

VOTES

ASM JUDICIARY: 8-3-1

YES: Kalra, Bauer-Kahan, Bryan, Connolly, Harabedian, Lee, Stefani, Zbur

NO: Dixon, Macedo, Sanchez

ABS, ABST OR NV: Pacheco

UPDATED

VERSION: March 24, 2025

CONSULTANT: Tom Clark / JUD. / (916) 319-2334 FN: 0000255

Date of Hearing: April 22, 2025

ASSEMBLY COMMITTEE ON JUDICIARY

Ash Kalra, Chair

ABPCA Bill Id:AB 1248

Author:(Haney) – As Amended Ver:March 24, 2025

SUBJECT: Hiring of real property: fees and charges

KEY ISSUE: should “housing services” that a landlord provides to tenants be included within the price of the rent, instead of being charged as a separate fee in addition to the rent?

SYNOPSIS

Six years ago, the Legislature passed and the Governor signed AB 1482 (Chap. 597, Stats. 2019), which created the Tenant Protection Act (TPA) of 2019. Among other things, the TPA imposed a statewide cap on rent increases, so that in a given year, a landlord could not raise the rent by more than five percent, plus the annual increase in the consumer price index per year, but not to exceed an overall increase of ten percent. The author and co-sponsors of this bill claim that some landlords are attempting to circumvent the TPA rent cap by charging a separate “fee” for housing services that used to be included within the rent. While landlords have long unbundled certain services from the cost of rent and charged them as separate fees, the author and supporters of this measure claim that the practice has increased since the enactment of the TPA, supposedly in an effort to circumvent the TPA.

For tenancies that begin on or after January 1, 2026, this bill would require landlords to include any “housing services” that they provide in the cost of the rent, instead of charging for those services as a separate “fee” in addition to rent. Under this bill, a tenant could only be required to pay rent plus the following charges: a security deposit in the amount permitted by law; any rent stabilization or similar fees imposed by government; charges paid to the landlord for submetered water; or charges for late payments as permitted by law. While the bill would not necessarily prevent a landlord from charging a tenant for individually metered utilities, any other housing-related services that the landlord provides (such as trash collection, laundry, pest control, maintenance, etc.) must be included in the price of the rent and could not be charged as an additional fee. The bill also would prescribe the order in which payments shall be applied to rent, rental debt, or other fees or charges. The bill would declare that any decrease in housing services would constitute a rental increase. Finally, the bill would make a landlord who violated its provision subject to as much as treble damages in a civil action.

The bill is co-sponsored by California Attorney General Rob Bonta, California Rural Legal Assistance Foundation, Consumer Federation of California, and National Housing Law Project. It is supported by several housing and legal aid advocates, among others. The bill is opposed by the California Apartment Association, the California Association of Realtors, and several regional property owner associations. As noted in the analysis, while the intent of the bill seems clear and admirable, some of its provisions and definitions raise operational questions.

SUMMARY: Limits the fees that a landlord may charge in addition to rent and requires that any housing services provided by the landlord must be included in the rent and not charged as a separate fee. Specifically, this bill:

1. Requires, for new residential tenancies beginning on or after January 1, 2026, that a tenant only be obligated to pay rent and the following fees or charges to a landlord:
   1. A security deposit in the amount permitted by law.
   2. Rent stabilization fees or other similar fees or charges, other than taxes, imposed by a government.
   3. Fees or charges that the tenant pays directly to the landlord or landlord’s agent for submetered water.
   4. Fees or charges for a tenant’s late payments to the extent permitted by law.
2. Requires, for residential tenancies that began before January 1, 2026, that a tenant only be obligated to pay rent, the fees and charges described in 1) above, any fees or charges that were charged at the start of the tenancy, and fees or charges for specified utilities, including the use of a ratio utility billing system, as defined, if it meets specified criteria.
3. Defines “rent” for purposes of 1) and 2) above to mean a single periodic payment and all nonmonetary consideration to or for the benefit of the landlord in exchange for the use or occupancy of a rental unit and premises and the provision of housing services under a rental contract or agreement, oral, written, or implied.
4. Defines “housing services” for purposes of 3) above to mean all services provided by the landlord related or connected to the use or occupancy of residential real property, including, but not limited to, trash collection, electrical service, water service, sewer service, gas service, other utilities, elevator service, storage, facilities, laundry, repairs, maintenance, heat, hot water, pest control, or any other benefits, privileges, or services, whether express or implied.
5. Provides, for residential tenancies beginning before or after January 1, 2026, that if a tenant is given a discount on rent or fees or charges in exchange for signing a rental agreement, then the rental agreement must clearly state specified information about the amount and timing of the discount.
6. Specifies that nothing in the bill prevents a tenant from being charged for individually metered utilities if the rental agreement meets prescribed requirements.
7. Requires that any payment received from, or on behalf of, a tenant be applied to rent, rental debt, and any outstanding fees in a specified order, and would prohibit late fees from being charged to a tenant whose only delinquency is attributable to nonpayment or late payment of a late fee.
8. Provides that a decrease in housing services, as defined, is an increase in rent.
9. Makes a landlord or landlord’s agent who violates the provisions of this bill liable to a tenant in a civil action for damages, including treble damages, and establishes a four year statute of limitations to bring such an action. Specifies that nothing in this bill would prevent a landlord from recovering damages otherwise permitted by law.
10. Declares that a waiver of the bill’s provisions is contrary to public policy and void, and that nothing in the bill preempts a local government from imposing additional requirements upon a landlord or providing greater protection to tenants.

EXISTING LAW:

1. Regulates the hiring of real property and imposes various requirements on landlords relating to the application for, and leasing of, residential rental property. (Civil Code Sections 1940 to 1954.07. Subsequent citations refer to this code.)
2. Prohibits a landlord from demanding or receiving security, however denominated, in an amount or value in excess of an amount equal to one month’s rent, in addition to any rent for the first month paid on or before initial occupancy. (Section 1950.5(c).)
3. Prohibits a landlord or its agent from charging a tenant a fee for serving, posting, or otherwise delivering a notice of termination of a hiring of residential property, as specified. (Section 1946.1(i).)
4. Prohibits a landlord or its agent from charging a tenant any fee for payment by check. (Section 1947.3(b).)
5. Prohibits an owner of residential real property from, over the course of any 12-month period, increasing the gross rental rate for a dwelling or a unit more than 5 percent plus the percentage change in the cost of living, or 10 percent, whichever is lower, of the lowest gross rental rate charged for that dwelling or unit at any time during the 12 months prior to the effective date of the increase. Creates exemptions to this restriction, including a new tenancy in which no tenant from the prior tenancy remains in lawful possession; housing that has been issued a certificate of occupancy within the previous 15 years; and single-family houses owned by a natural person. (Section 1947.12.)

FISCAL EFFECT: As currently in print this bill is keyed non-fiscal.

COMMENTS: According to the author, “while the Tenant Protection Act (TPA) of 2019 placed necessary limits on rent increases, certain landlords have found ways to exploit perceived loopholes by imposing excessive fees that circumvent these protections. These hidden or misleading charges—including Ratio Utility Billing System (RUBS) fees, trash concierge fees, pest control fees, and other unbundled costs—unfairly drive up the true price of housing, making it harder for tenants to budget, compare rental costs, and maintain stable housing.” The author contends that by “prohibiting landlords from imposing new or increased fees outside of rent, the bill prevents workarounds that artificially inflate housing costs beyond the [TPA] rent cap.”

Existing law and permissible fees. Existing laws, some only recently enacted, place limits on the ability of landlords to charge additional fees or payments that go beyond rent. For example, a landlord is authorized to demand a security deposit, but the deposit cannot be more than one month’s rent. Landlords may charge late fees and applicant screening fees, but existing law sets limits on the amounts and manner in which they can be charged. Existing law prohibits a landlord from charging a fee for a tenant to pay by check, and prohibits the landlord from charging a fee for posting, serving, or otherwise delivering any notice of termination of the tenancy. However, existing law imposes few, if any, limits on a landlord’s ability to charge additional fees for housing services or amenities that the landlord provides to tenants. According to many media reports, these additional fees and charges are not always presented to the prospective tenant as clearly as they should or could be; or if they are, the prospective tenant would have no means of knowing, at the time of signing the lease, whether the services or amenities are worth the price. As a result, many tenants who assume that they are renting a dwelling for certain price subsequently discover that the true cost of their “rent” is much higher than advertised or reasonably expected.

This bill seeks to resolve this problem by providing that, for tenancies created on or after January 1, 2026, tenants will only be liable for “rent,” as defined, and a few other expressly authorized fees or charges: a security deposit in the amount permitted by law; any rent stabilization or similar fees imposed by government; charges paid to the landlord for submetered water; or charges for late payments as permitted by law. For tenancies created before January 1, 2026, the tenant could be charged all of these same fees, as well as any fees or charges that were charged at the start of the tenancy, and fees or charges for utilities that rely on a “ratio utility billing system,” which is essentially any proportional billing system that does not rely on individually metered units. The bill specifies that nothing in its provisions would prevent a tenant from being charged for individually metered utilities, so long as this is clearly provided for in the rental agreement.

To fully understand the scope of the bill, one must look closely at its definitions. The bill defines “rent” to include any periodic payment made to the landlord for the use and occupancy of the dwelling and for any “housing services” that are “provided by the landlord.” “Housing services” is defined, in turn, to mean any services “related or connected to the use or occupancy of residential real property.” These services could include, but are not limited to, “trash collection, electrical service, water service, sewer service, gas service, other utilities, elevator service, storage, facilities, laundry, repairs, maintenance, heat, hot water, pest control, or any other benefits, privileges, or services, whether express or implied.” Of course, many of these services – like electrical and gas services or “other utilities” – are typically not part of the rent and are not paid to the landlord. Instead, the tenant contracts with a third party – a utility company – to provide the service. However, in cases where the landlord provides or pays for these services, the landlord could not charge the tenant a separate fee for those services. The landlord would, at least for tenancies created on or after January 1, 2026, pass the cost of the services onto the tenant in the form of increased rent. For tenancies created before January 1, 2026, a landlord could continue to charge for such services, but only subject to certain conditions, and only if they had already charged for those services and charge the tenant no more than the actual cost of those utilities.

Transparency vs prohibition. While the author and co-sponsors claim that the fees and charges that prompted this bill are often “hidden” or deceptively presented, it is important to stress that this bill is not just a disclosure or transparency bill. It would not merely require the landlord to be transparent about additional fees beyond rent in advertising, rental agreements, or other communications with a tenant or prospective tenant; rather, it would prohibit the landlord from charging such fees in addition to the rent. The “rent,” that is, must include those services and the landlord is barred from charging for those services through extra fees, regardless of whether the fees are disclosed in an advertisement or rental agreement. The California Apartment Association (CAA), which opposes this bill, has informed the author and the Committee that they “strongly support transparency in how fees and charges are advertised and communicated,” because tenants should understand the total costs “both when reviewing listings and at the time of signing a rental agreement.” CAA might support a bill that required transparency. However, it is not clear how much a bill requiring transparency in advertising and rental agreements would alter existing law, which already prohibits false advertising and misrepresentation in contracts, including in a rental agreement.

Other pending legislation, most notably SB 381 (Wahab), prohibits certain fees outright, including pet fees and parking fees. However, that bill would also, more consistently with the “transparency” approach, prohibit a landlord from charging “any fee that is not specified in the rental agreement.” (Note: The provisions of SB 381 were recently added to SB 681 (Wahab), which includes several other landlord-tenant provisions not related to this bill.)

Have landlords increased their use of separate fees since the enactment of the TPA? The author and co-sponsors all claim that this practice of unbundling services that were once included in the rent and charging for those services as separate fees has been “increasing” since the enactment of the Tenant Protection Act (TPA) in 2019. Because the TPA prevents landlords from raising the rent, landlords allegedly circumvent the rent cap by keeping the rent steady but charging a fee for services that were once included in the rent. In fairness to the landlords, it should be stressed that the evidence for this rather serious allegation is anecdotal at best. The only source cited for this claim in the letters of support is a 2023 report by the National Consumer Law Center, entitled “Too Damn High: How junk fees add to skyrocketing rents.” However, this report does not cite any data comparing practices before and after the TPA’s operative date. The only thing in the report that comes remotely close to supporting this assertion is a single sentence claiming that “two California advocates commented that since the passage of a state law that limits rental increases, they have seen an increase in landlords finding any other way to charge renters more money.” We know nothing about these “two California advocates.” This is not to dispute the co-sponsors’ contention, for the statement may very well be true; but no empirical data has been provided to the Committee that supports the claim.

Possible Amendments and Clarifications. The overall purpose of this bill is clear enough: to prohibit landlords from charging fees for services that most tenants would reasonably assume should be part of the rent. For example, charging a tenant a fee for things like maintenance, pest control, and amenities that attract more applicants are part of the cost of doing business. However, there are some provisions in the bill, three of which are discussed below, that may need clarification.

Definition of “housing services” and parking. The bill defines “rent” as a payment made for the right to use and occupy the property, the usual definition of rent. Yet “rent” under the bill also includes any “housing services” that the landlord provides. The examples provided in the definition is not an exhaustive list, and some of things expressly included (like electricity, gas, and “other utilities”) are things that are not typically included in rent. Given recently enacted legislation that expressly requires landlords to “unbundle” parking from the price of rent, the lack of any reference to parking is striking. Since the list of examples in the definition of “housing services” includes the oft used phrase “included, but not limited to,” this means that parking might be considered a “housing service,” since it is arguably “related or connected to the use or occupancy of residential real property.” If it is considered a housing service, then a landlord could not charge a separate parking fee even though an existing law requires the landlord to unbundle it from the rent and charge it separately. If the bill moves out of this Committee, the author may wish to consider either adding “parking” to the list, or add it to the list of fees that may be charged.

A “decrease in housing services.” One provision of the bill declares that “a decrease in housing services is an increase in rent.” Apparently, this provision relates to the presumption that landlords are redefining what is considered “rent” in order to circumvent the TPA. Presumably, if the landlord that previously provided laundry, storage facilities, or water services to tenants, and then decided to stop providing those services without lowering the rent, then that would effectively be an increase in the rent. (It might also be a breach of the rental contract under existing law.) While this principle seems clear enough, it is not entirely clear how one would calculate this to determine whether or not the reduction of services constituted a rent increase in violation of TPA. For example, if a landlord provided water services, and the water bill per unit ran $100 per month, would this constitute a $100 increase in the rent? Or would the landlord, in order to stay within the limits of the TPA, be required to lower the rent? If the bill moves out of this Committee, and if the intent of this provision is to make a decrease in services an increase that might violate the TPA, then the author may wish to consider clarifying how one would calculate the increase for purposes of the TPA. Perhaps the answer to this is that either a court or a local rent control board will decide on a case-by-case basis if a tenant raises a challenge under either the TPA or a local rent control ordinance.

The utility of ratio utility billing systems. This bill would apparently prohibit the use of “ratio utility billing systems” (RUBS) for any tenancy created on or after January 1, 2026, and would only permit it for tenancies created before that date under specified conditions. RUBS, a system that has been used for many years, refers to the allocation of utility costs to tenants through any billing system other than individual meters. Since January 1, 2018, California law has required all new multifamily construction to include an individual meter (or submeter) for each individual rental unit. If a landlord wants to charge a tenant separately for water, they must use a submeter and disclose this charge to the tenant. However, many older multi-unit rental buildings do not have individual meters and, the cost of providing them may be prohibitive. RUBS relies on a formula, based on square footage and the number of occupants in each unit, with deductions for common areas, to allocate the total cost of the utility among the various tenants. Thus, tenants with larger units and more occupants would pay a higher share than tenants with smaller units and fewer occupants. This is not a perfect match, since a frugal large household might use less water than a profligate small household. But in the absence of RUBS, the landlord would either charge each unit an equal share of the cost (regardless of unit size or number of occupants) or do what amounts to the same thing: not charge the tenants but increase the rent across the board to cover the cost of the utility.

Conservice, a company that manages utility billing for rental properties based on a RUBS formula, opposes this bill because it will prohibit RUBS in tenancies created on or after January 1, 2026, and will greatly restrict them for tenancies created before that date. Conservice, citing a single study, claims that tenants will consume more water if they do not receive any bill for their water; rather, the cost of the water is effectively hidden and fixed within the rent. Conservice makes an interesting point and, indeed, the purpose of requiring new units to have individual meters was to promote water conservation by making consumers more conscious of their usage. However, the water conservation benefits of RUBS is not nearly as great as individual meters. That is, even though RUBS apportions bills based on reasonable factors like unit size and number of occupants, it clearly does not promote water conservation in the same way as individual meters, because under RUBS, the tenant’s water bill will be based on the size of the unit and the number of occupants, not on the amount of water that they consume. Conservice contends, however, that simply receiving a bill for water makes tenants more conscious of the fact that water is not free. Nonetheless, if the bill moves forward, the author may wish to consider whether prohibiting RUBS serves the purpose of this bill. After all, while RUBS may be less equitable that individual meters, it is arguably more equitable than simply requiring all tenants to pay the same amount in the form of higher rent.

ARGUMENTS IN SUPPORT: According to California Attorney General (AG) Rob Bonta, who is one of the co-sponsors of this legislation, AB 1248 will “protect tenants from unfair rental housing fees and other increases to their monthly rent [and provide] necessary clarity about what fees may be charged to tenants in addition to the advertised rent.” The AG hopes that this measure will “end practices designed to circumvent state law rent cap protections and misleading advertisements that use an artificially low stated rent and add additional fees, which tenants often cannot control or predict.”

The AG contends the practice of unbundling housing services from the price of rent and charging them as separate “fees” increased after the passage of the Tenant Protection Act (TPA) in 2019, which, among other things, capped annual rental increases to 5% plus CPI, not to exceed 10%. “By imposing and increasing additional fees,” the AG contends, “some of these landlords increase the gross rental rate far above the TPA’s maximum of 10%, making it even more difficult for tenants to afford adequate housing. This practice places significant burdens on tenants, including uncertainty about monthly housing costs due to variable or increasing fees. If the combination of rent increases and new fees exceed the TPA’s rent cap, these landlords are also violating California law.”

AB 1248 will address this problem, the AG contends, by requiring “landlords to include all costs in the rent rather than charging separate fees, with narrow exceptions specified in the bill. By requiring all costs to the tenant to be included in the rent, the bill will also allow those searching for housing to compare the true prices of different options, and will create a fair marketplace for landlords. This change to the law will also help prevent attempted evasions of state rent caps and help ensure that tenants’ housing payments to their landlords remain stable and predictable.”

The California Rural Legal Assistance Foundation, the Consumer Federation of California, and the, and National Housing Law Project (co-sponsors) argue that AB 1248 will “address the practice of charging unnecessary or deceptive fees to tenants.” Like the AG, the co-sponsors contend that landlords use separate fees, at least in part, to evade TPA. They write: “unscrupulous landlords are evading the law by increasingly charging separately for services the landlord previously included in the rent, or charging additional, unnecessary mandatory fees.

Even in properties not covered by the TPA, these unfair and deceptive practices are on the rise. AB 1248 will end these practices by defining rent, prohibiting landlords from charging additional fees separate from the rent with a few narrow exceptions, and requiring that a tenant’s rent payment be applied to rent first and only after that to any other allowable fees.”

ARGUMENTS IN OPPOSITION: The California Apartment Association (CAA) opposes this bill. They contend that restricting fees – including voluntary fees for optional services – will simply mean that landlords either will not provide the services or they will fold them into the price of the rent, thereby doing nothing to affect the affordability of rents. Specifically, CAA makes the following arguments against this bill:

For decades, separate fees and charges—imposed by both small and large housing providers—have been a standard part of the rental housing industry. These fees often help illustrate the costs associated with operating rental housing and can give tenants the ability to manage and reduce certain expenses, such as utilities and water. Mandating that all fees be folded into rent will not reduce the overall cost of housing. Instead, it will reduce transparency and limit tenants’ ability to understand or control specific costs.

AB 1248 so severely restricts the types of fees and charges that can be passed on separately to tenants that it is likely to increase overall rent prices, particularly for new tenants. Additionally, while the bill implies that it permits late fees, the actual language prohibits them. This is misleading and will create confusion.

The bill also fails to account for voluntary fees—charges for optional services that tenants may choose to utilize. As a result, tenants may ultimately lose access to convenient services that enhance their rental experience.

That said, CAA strongly supports transparency in how fees and charges are advertised and communicated. We believe tenants should have a clear understanding of their total housing costs, including any fees, both when reviewing listings and at the time of signing a rental agreement. This is the approach we encourage you to pursue with AB 1248, rather than one that gives the impression, inaccurately, that housing costs will decrease as a result of AB 1248.

While the California Association of Realtors and several regional rental associations oppose this bill for substantially the same reasons articulated by CAA, Conservice Utility Billing and Management (Conservice), a company that manages utility billing for rental properties, opposes this bill primarily because it would prohibit the use of “ratio utility billing systems” (RUBS) for most rental properties. Conservice claims that “in many older apartment buildings, individual submeters are not possible or are cost prohibitive . . . In these cases, RUBS is the only fair method to allocate water costs and encourage conservation, without increasing rents.” Conservice cites data suggesting that when tenants pay for water separately from rent they tend to use less water. However, when utilities “are ‘free’ or included in rent, consumption increases.” As such, Conservice contends, “AB 1248 will lead to significantly higher water consumption among tenants throughout the state.”

REGISTERED SUPPORT / OPPOSITION:

Support

California Attorney General Rob Bonta (co-sponsor)

California Rural Legal Assistance Foundation (co-sponsor)

Consumer Federation of California (co-sponsor)

National Housing Law Project (co-sponsor)

ACCE Action

Bay Area Legal Aid

California Center for Movement Legal Services

California Low-Income Consumer Coalition

California Nurses Association

Community Legal Aid SoCal

Elder Law & Advocacy

Housing and Economic Rights Advocates

Housing California

Leadership Counsel for Justice and Accountability

Legal Aid of Marin

Legal Aid Society of San Diego

Legal Services of Northern California

National Consumer Law Center

Pico California

Public Counsel

Rise Economy

Techequity Action

Tenants Together

Western Center on Law & Poverty

Opposition

Apartment Association of Greater Los Angeles

Apartment Association of Orange County

Berkeley Property Owner's Association

California Apartment Association

California Association of Realtors

California Building Industry Association

California Business Properties Association

California Rental Housing Association

Conservice Utility Billing & Management

East Bay Rental Housing Association

Nor Cal Rental Property Association

North Valley Property Owners Association

Santa Barbara Rental Property Association

Small Property Owners of San Francisco Institute

Southern California Rental Property Association

Analysis Prepared by: Tom Clark / JUD. / (916) 319-2334