Decree 354 comments on the withdrawal of metering devices. VI. The procedure for calculating and making payments for utilities. II. Conditions for the provision of public services

Now, in the Rules for the provision of public services to owners and users of premises in apartment buildings and residential buildings, the following concepts are given and clarified: “in-house engineering systems”, “in-house equipment”, “home ownership”, “individual metering device”, “performer”, “collective (common house ) metering device”, “utilities”, “utility resources”, “room metering device for electric energy”, “non-residential premises in an apartment building”, “utility consumption standard”, “general (apartment) metering device”, “consumer” , "distributor", "resource-supplying organization", "centralized networks of engineering and technical support" and "degree of improvement of an apartment building or residential building".


The Rules determined the conditions for the provision of public services and the terms of the contract containing the provisions on the provision of public services, and the procedure for its conclusion.

Now the agreement will specify the measures of social support for paying for utilities provided to the consumer of utilities in accordance with the legislation of the Russian Federation (if such measures are provided).

The agreement containing provisions on the provision of public services, concluded with the owner or user of a residential building (household), additionally indicates

the details of the act on determining the boundary of the division of intra-house engineering systems and centralized networks of engineering and technical support (if any), as well as in the absence of an individual metering device, are indicated:

A) information on the directions of consumption of utilities when using the land plot and outbuildings located on it (lighting, cooking for people, preparing feed for livestock, heating, heating water, watering, etc.);

B) species and number of farm animals and birds (if any);

C) the area of ​​the land plot not occupied by a residential building and outbuildings;

D) regime of water consumption for irrigation of the land plot;

E) the power of the devices used, with the help of which the consumption of communal resources is carried out.

In addition, the grounds for refusing to conclude a contract were determined, such a ground may be the degree of improvement of an apartment building or residential building, which does not allow the provision of utility services to the consumer.

The submission by the applicant of an incomplete package of documents or their incorrect execution is not a basis for refusing to conclude an agreement containing provisions on the provision of public services.


A special role in the Decree is occupied by the section “Rights and obligations of the contractor” and “Rights and obligations of the consumer”.

The consumer has the right:

Require the representative of the contractor to present documents confirming his identity and the availability of his authority to access the residential or non-residential premises of the consumer in order to check the status of metering devices,

Reliability of information provided by the consumer about the readings of metering devices,

Taking meter readings, to inspect the technical and sanitary condition of the in-house equipment, to carry out repair work, eliminate an accident and to perform other actions specified in these Rules and an agreement containing provisions for the provision of public services (order, order, assignment of the contractor to send such persons for the purpose of carrying out the specified check or other similar document).

The consumer is obliged:

Inform the contractor about an increase or decrease in the number of citizens living (including temporarily) in the residential premises occupied by him, no later than 5 working days from the date of the changes, if the residential premises are not equipped with an individual or common (apartment) metering device.

Also, the owners of the premises have the right to decide on the conclusion of an energy service agreement (contract) aimed at saving and (or) increasing the efficiency of consumption of communal resources when using common property (hereinafter referred to as the energy service agreement for general house needs), with a managing organization, a homeowners association, a housing , a housing-construction cooperative or other specialized consumer cooperative or on empowering the said organization, partnership or cooperative to conclude in the interests of the owners on its own behalf or on behalf of the owners of an energy service contract for general house needs with an organization providing energy services.

An energy service contract for general house needs with a managing organization is concluded separately from the contract for managing an apartment building.

In the case of direct management of an apartment building, the owners of premises in an apartment building have the right to decide on the conclusion of an energy service contract for general house needs with a resource supply organization or another organization providing energy services.

The decision of the owners of the premises is taken at the general meeting of the owners of the premises and must contain, among other things, the following conditions for concluding an energy service contract for general house needs:

The amount of savings in utility resources in physical terms (reduction under comparable conditions in the volume (quantity) of utility resources consumed for general house needs), which must be ensured as a result of the execution of an energy service contract for general house needs, and the period required to achieve such a savings value;

The price of an energy service contract for general house needs and the procedure for its payment;

Validity period of the energy service contract for general house needs.

Approximate terms of an energy service contract for general house needs are approved by the Ministry of Regional Development of the Russian Federation in agreement with the Ministry of Economic Development of the Russian Federation.

Payment of the price of an energy service contract for general house needs is carried out separately from utility bills and fees for the maintenance and repair of a dwelling.

The price of an energy service contract for general house needs is determined by agreement of the parties to such an agreement.


Particular importance in the Government Decree was given to Ch. VI. "The procedure for calculating and making payments for utilities."

Now in Appendix No. 2 to the Rules for the provision of public services to owners and users of premises in apartment buildings and residential buildings the calculation of the amount of payment for utilities.

Also in Appendix No. 1 to the Rules for the provision of public services to owners and users of premises in apartment buildings and residential buildings given the requirements for the quality of public services.

Now, the common property includes an in-house engineering drainage system, consisting of sewer outlets, fittings (including bends, transitions, branch pipes, revisions, crosses, tees), risers, plugs, exhaust pipes, drain funnels, cleaning, branches from risers to the first butt joints, as well as other equipment located in this system.

If the owners of premises in an apartment building before January 1, 2013 did not ensure that such a house was equipped with a collective (common house) meter for the used communal resource and, at the same time, in accordance with Part 12 of Article 13 of the Federal Law “On Energy Saving and on Increasing Energy Efficiency and on Amendments to Certain Legislative Acts of the Russian Federation” a collective (general house) metering device was installed, the owners of the premises are obliged to pay the costs of installing such a metering device on the basis of the invoices and in the amount specified in paragraph two of this clause, except for cases where such costs were taken into account as part of the payment for the maintenance and repair of residential premises and (or) as part of the mandatory payments and (or) contributions related to the payment of maintenance costs, current and capital repair of common property.

Invoices for the payment of expenses for the installation of a collective (common house) metering device, indicating the total amount of expenses for the installation of such a metering device and the share of the costs for installing such a metering device, the burden of which is borne by the owner of the premises, are issued to the owners of the premises by the organization that carried out in accordance with Part 12 of Article 13 of the Federal Law "On Energy Saving and on Increasing Energy Efficiency and on Amending Certain Legislative Acts of the Russian Federation" installation of a collective (common house) metering device.

The share of expenses for the installation of a collective (common house) metering device, the burden of which is borne by the owner of the premises, is determined based on his share in the common ownership of common property.

In case of disagreement with the amount of expenses indicated in the invoice for the installation of a collective (common house) metering device and (or) the share of expenses attributed to it, the owner of the premises has the right to contact the organization that installed such a metering device and issued the invoice with disagreements, and if disagreements are not settled, he has the right to appeal issued invoice in the manner prescribed by the legislation of the Russian Federation.

The concept is revealed incomplete payment by the consumer of utility services- this is the consumer's debt to pay for 1 utility service in an amount exceeding the amount of 3 monthly fees for the utility service, calculated on the basis of the utility consumption standard, regardless of the presence or absence of an individual or common (apartment) meter and tariff for the corresponding type of utility resources in force on the day of restriction of the provision of public services, provided that there is no agreement concluded by the consumer-debtor with the contractor on repayment of the debt and (or) if the consumer-debtor fails to comply with the terms of such an agreement.

Also in the Rules, attention was paid to: the features of the provision of utility services for cold water supply through a water column, the features of the provision of utility services for gas supply to consumers through a centralized gas supply network, the features of the sale of domestic gas in cylinders and the sale and delivery of solid fuel.

State control over the compliance of the quality, volume and procedure for the provision of public services with the requirements established by these Rules is carried out by the authorized executive bodies of the constituent entities of the Russian Federation in the manner established by the federal executive body authorized by the Government of the Russian Federation in accordance with Article 20 of the Housing Code of the Russian Federation.

What owners and owners of premises should require from management companies, homeowners associations and resource supply companies for processing payment documents in order to achieve fair payment for utilities

demandalready now from the Criminal Code, Homeowners' associations, Resource supply companies, payments with a set of information according to Article 69 of the Rules approved by the Government, mandatory for all performers!

Make a request in the form of a written statement with the listing of all data in accordance with part 69 of the Rules for the provision of utility services to owners and users of premises in apartment buildings and residential buildings, approved by Decree of the Government of the Russian Federation of May 6, 2011 No. 354 “On the provision of utility services to owners and users of premises in apartment buildings and residential buildings and a link to these Rules.

Send the application by registered mail with a notification and a description of the attachment, keep the second copy with a mail mark and a payment document for the letter!

In case of refusal or no response within the prescribed time, you can apply to the court with a mandatory assessment of non-pecuniary damage! The chances of winning are 100%.

According to the data obtained, it is easy to determine the correctness and fairness of the calculations using the Rules!

Every citizen is interested in what rule for calculating the cost of utilities is currently in effect. Therefore, the paragraph of Art. 354 can reveal important questions, and provide answers in the way that the law has established.

Decree 354 as last amended 2016,

The regulation from the government of the Russian Federation on public services was created in June 2011. After that, the law needed to be amended, so every year in April, March, July, May, mid-June and in other months a new draft was introduced with changes. The Russian law for this period is valid according to the latest amendments. It is worth examining this right before considering amendments.

Federal law in resolution 354 contains the following sections:

  • Provision of services to be received by the user and the owner of the premises;
  • The condition and main order of how the service is served;
  • Metering devices and calculation of the amount of the fee;
  • Recalculation and accrual for heating, electricity, water;
  • Question about the cancellation of the provision of services;
  • An application where there are calculation rules, as well as a formula and a rate standard;
  • Changes to be made to the Act.

The current version with the latest changes has some amendments in accordance with the current situation in the housing and communal services. As of December 2015, it was necessary to approve the amendments, which will come into force in 2016. The federation also made changes to the government's vision of this document in September, April, at the end of January and other months. Many portals, such as consultant plus, pay attention to the text of this provision, so it is worth considering each part of it in the latest edition. for different types of services.

About utilities

Regulation number 354 regulates the consumption of housing and communal services for owners and users of residential apartments or non-residential premises. The new edition of the law of the Russian Federation contains consumption standards and fees for them. For example, the document explains when the power of billing for a utility package starts. The entry into force begins at the moment of the emergence of ownership rights, from the day the lease for the premises is concluded, from the day of hiring and entering the apartment building. Judicial practice confirms the guarantor of compliance with Decree 354 throughout the Russian Federation, including the Moscow region, Kirov and Perm.

Heating

This section describes the general house needs for the provision of heating to citizens. This paragraph explains in examples how much, according to the rules, the length of heating should be charged in terms of time and temperature in the apartment. According to the approved norms, the temperature and heat are regulated, the amount of payment for heating is calculated.

For electricity

This subparagraph determines the procedure for the supply and distribution of electricity. the voltage standards, the period that is possible due to a temporary lack of energy, the verification of lines and energy saving are indicated. During the year, there is a limit on the time of absence. The edition contains requirements for voltage lines in accordance with GOST.

Common house needs Decree 354 to pay or not to pay?

Many people ask whether or not to pay the bill for common house needs. The Housing Code provides that the cost of water supply and other services for common house needs will be paid evenly on each separate receipt. This payment is important in relation to the provision of utilities, so everyone pays receipts.

Recalculation for heating according to a common house meter according to Resolution 354, calculation formula

The contractor bills for electricity or hot water on the day the receipt for the meter is issued. The recalculation for cold water is carried out according to the formula, where the volume for non-residential premises, the volume for individual apartments, the volume of hot water and the volume of water supply costs are subtracted from the unaccounted volume of water for the accounting period and multiplied by the area of ​​​​the apartment divided by the area of ​​\u200b\u200ball apartments. Today you can download an application for free that contains order 354, where there is a calculation form, adjustments and comments.

Posted on the official website of the Ministry of Regional Development of Russia

ANSWERS TO QUESTIONS ON THE APPLICATION OF THE RULES FOR THE PROVISION OF PUBLIC SERVICES APPROVED BY THE DECISION OF THE GOVERNMENT OF THE RUSSIAN FEDERATION OF 06.05.2011 N 354

ANSWERS TO QUESTIONS ON THE APPLICATION OF THE RULES FOR THE PROVISION OF PUBLIC SERVICES,
APPROVED BY THE DECISION OF THE GOVERNMENT OF THE RUSSIAN FEDERATION OF 06.05.2011 N 354

DETERMINATION OF THE SIZE OF THE PAYMENT WITH THE APPLICATION OF STANDARDS FOR THE CONSUMPTION OF PUBLIC SERVICES

Question
Considering that the number of consumers will be determined on the basis of citizens actually permanently and temporarily residing in a residential building, can the contractor carry out the calculation based on the data he has on the number of registered, or only be guided by the information provided by the consumer himself? And if such information is not provided or does not coincide with the number of registered ones (it will be less), what actions of the performer will be lawful?

Answer
The contractor determines the amount of payment for utilities based on the number of registered citizens and is obliged to recalculate only if the consumer provides documents confirming his temporary absence from the residential premises.
As for citizens temporarily residing and not registered in the residential premises, information about them is provided by the consumer himself to the contractor.


Question
There is no individual water meter in an apartment or residential building. The actual number of residents without registration exceeds the number of those registered. Who is authorized to record the actual number of residents for accrual according to the standards?

Answer
There are no rules on this issue in Rules N 354.
As practice shows, Managing organizations, unilaterally or with the involvement of citizens living in this MKD, draw up acts on living in the living quarters of citizens, on the basis of which they begin to charge utility bills based on the established number of residents.
However, if the owner of such a dwelling applies to the court with a statement about the illegality of the accruals, the courts do not in all cases evaluate the acts of residence drawn up by the managing organization as sufficient evidence of the fact of residence of citizens.
In our opinion, when drawing up such acts of the MA, it is advisable to involve the district police officer, since it is this official who, under the Code of Administrative Offenses of the Russian Federation, is authorized to draw up protocols on administrative offenses for living at the place of stay without registration.
Based on the check conducted by the district police officer, it becomes possible to establish the personal data of living citizens and subsequently involve them in the trial as witnesses or 3 persons.
In addition, the relevant verification materials may be attached to the case as evidence.

Question
The owners of the apartment are not registered, the tenants actually live in the apartment. How to calculate the payment for cold water supply in the absence of ISP and OPU?

Answer
In this case, it is possible to apply the norm of part 11 of article 155 of the RF LC that the owner’s non-use of the premises (due to the lack of his residence permit) does not exempt such an owner from paying utility bills and charge fees according to consumption standards for the number of owners, guided by and the norm of part 2 of article 153 of the HC RF on the obligation for the owner to pay utility bills from the moment the right of ownership to the premises arises. Or it is possible to establish by a management agreement the procedure for activating the facts of consumers' residence in residential premises with the subsequent presentation of such an act and invoices for payment to the owner of the corresponding premises. However, the owner's refusal to pay utility bills based on the number of tenants living with him who are not declared by him as residents will not allow the managing organization to receive the appropriate payment.


Question
If the owner is not registered in the apartment, are accruals made on him?

Answer
In accordance with part 2 of article 153 of the LC RF, the owner is obliged to pay utility bills from the moment of acquiring ownership. In accordance with part 11 of article 155 of the LC RF, non-use of the premises is not a basis for non-payment of utility bills. In case of temporary absence of consumers, the amount of the fee determined on the basis of the consumption norm is recalculated for the period of temporary absence. We believe that when using part 11 of article 155 of the LC RF, it is possible to charge a fee to the owner of the premises in the absence of a statement about the temporary absence of consumers in the corresponding premises.


Question
If the apartment is not owned by one owner, but by 1/2, 1/3, etc. then accruals according to the standards are made for each owner of the apartment?
Answer

Yes, utility bills are determined according to the number of owners (considered to be living before the submission of an application for temporary absence - in accordance with Part 11 of Article 155 of the RF LC), regardless of the share of each owner in the common shared ownership of the dwelling.


Question
The owner gives notice of his absence within five years. We do not charge services to him, and three other people live in his apartment for all five years (for example, he rents an apartment without notice). How to be in such a situation with accruals?

Answer
In this situation, it is necessary to identify and record the facts of citizens' residence in residential premises and make charges based on the number of citizens living and the established period of their residence. We recommend that the facts of residence of citizens be recorded with the participation of the district authorized police officer, since it is this official who, in accordance with the Code of Administrative Offenses of the Russian Federation, is authorized to consider cases of residence of citizens without registration.

Question
How to make accruals for utilities if unregistered citizens live in the apartment and the owner of the premises does not register them?

Answer
The amount of the fee is calculated based on the number of registered citizens until the fact of residence of other citizens is established and recorded in order to verify compliance with the requirements of administrative legislation on the registration of citizens, or by the managing organization independently with the involvement of other persons.


Question
How to force the owner to send an application to the MA about the presence of unregistered residents living in his apartment. What sanctions can be applied to them? Can a court order them?

Answer
The court cannot oblige the owner to send such a statement.
The sanction that can be applied to the owner is compensation for damages.
The way to protect the right of the managing organization in this case is the claim for compensation for losses caused by the inaction of the owner, who did not report about the residents. The fact of inaction is obliged to prove the managing organization.


Question
If a constituent entity of the Russian Federation has established consumption standards with their entry into force on 01/01/2013, do we have the right to charge according to the old standards?

Answer
Before 01/01/2013 - yes, after - no. At the same time, during the period of application of the old standards for the consumption of utilities, the amount of payment for utilities is to be determined using the calculation formulas specified in Rules N 354, except for the case when Rules N 307 are applied for heating payments in accordance with Decree of the Government of the Russian Federation N 857.


Question
How to calculate payment for utilities to managing organizations if the subject of the Russian Federation has not accepted
no regulations ? We don't have old standards or new ones!

Answer

The new norms for the consumption of public services are understood as the norms adopted by the constituent entity of the Russian Federation with the introduction of them into force after 1.09.2012. and established in accordance with Rules N 306 as amended by Decree of the Government of the Russian Federation of March 28, 2012 No. N 258 "On Amendments to the Rules for Establishing and Defining Standards for the Consumption of Utilities". The old standards mean the standards that were in effect for calculating utility bills before 1.09.12, incl. previously approved by the local government in the period up to 27.07.2010. If, on the territory of the municipality, the standards for the consumption of utilities that were previously approved by the CHI were canceled, then the consumption standards that were in effect before the approval of the canceled ones are most likely to be applied. For these purposes, it is necessary to look at the wording of the canceled normative legal acts of compulsory medical insurance. In the period before the entry into force of the new standards for the consumption of utilities after 1.09.2012. when determining fees for utilities, those standards for the consumption of utilities should be applied that were used in settlements with consumers of utilities during the validity period of Rules N 307, i.e. up to September 1, 2012


Question
How will the payment for CU (specifically for electricity supply) be charged in a communal apartment in the absence of an apartment meter?

Answer
According to clause 50 of Rules N 354, the calculation of the amount of payment for a utility service provided to a consumer living in a room (rooms) in a communal apartment is carried out in accordance with formulas 7, 16 and 19 of Appendix N 2 to the Rules. In accordance with the procedure established by Rules N 354 (the indicated formulas), the readings of room metering devices in a communal apartment that is not equipped with apartment metering devices are not taken into account when calculating the amount of payment for electricity supply services. For such accounting, it is necessary to equip the apartment with an apartment metering device.

Question
How is the amount of payment for utilities calculated in the cases provided for by the Rules in the absence of norms for the consumption of utilities in relation to households approved by the state authorities of the constituent entities of the Russian Federation?


Answer
The payment for utilities consumed when using the land plot and outbuildings is determined according to the current standards for the consumption of utilities, if any. In the absence of such standards, the volume of consumption of the relevant utilities is determined by calculation.

DETERMINING THE AMOUNT OF THE PAYMENT IN THE PRESENCE OF IPU

Question
As in the case of transferring evidence by telephone, identify the subscriber. After all, mistakes, forgeries are possible, how then to prove that the organization did not invent these testimonies? When sending by e-mail, the Subscriber himself indicates his postal address in the application and all messages coming from the specified mailbox are accepted unconditionally, as a written trace remains. With oral transmission, nothing remains.

Answer
When accepting readings from metering devices, it is recommended to set a code, password, etc. for each personal account, allowing the payer to be identified.


Question
According to the period of taking the testimony of the IPU. Rules N 354 determine the deadline for submitting IPU testimony from the 23rd to the 25th (no later than the 26th). It is very problematic to obtain OSS decisions on changing these terms in a short time. Question: if citizens submitted testimonies to the IPU, for example, on the 29th (or on any other day), do we have the right to take into account these testimonies or consider these testimonies not submitted within the period established by Rules N 354 and calculate the average monthly expense?

Answer
According to paragraphs. c) clause 34 of Rules N 354, the consumer is obliged:
- take readings of the IPU in the period from the 23rd to the 25th day of the current month;
- transfer the received testimony to the contractor or a person authorized by him no later than the 26th day of the current month, (except when, in accordance with the Rules, an agreement containing provisions on the provision of public services, and (or) decisions of the general meeting of owners of premises in an apartment building, actions on taking readings of such metering devices, the performer (a person authorized by him) or another organization is obliged to perform.
Thus, the term for the acceptance by the executor of the IPU testimony is from the 23rd to the 26th, inclusive. If the consumer has not fulfilled these obligations within the specified period, the amount of the fee is calculated based on the average monthly volume of consumption in the manner prescribed by clause 59 of Rules N 354.
At the same time, we believe that the readings of metering devices provided after the 26th day of the billing month can be used by the contractor to calculate the payment for utilities for the corresponding month, if this does not violate the deadline for submitting a payment document to consumers established by an agreement with the utility services contractor containing the conditions for providing utilities.

Question
How to determine for what billing period meter readings were taken if consumers transmit these readings by phone, via the Internet?

Answer
Consumers are required to take readings of the IPU in the period from the 23rd to the 25th day of the current month and transfer the received readings to the contractor or a person authorized by him no later than the 26th day of the current month (clause 34 of Rules N 354). If the consumer did not submit the IPU readings to the contractor on time, then the amount of the fee is determined based on the average monthly volume of consumption (clause 59 of Rules N 354). Based on the deadlines established by the Rules, all information about the testimony of the IPU received during the specified period is accepted by the contractor for calculating the amount of the fee for the billing period in which in a timely manner testimonies were transferred, and in case of a long non-submission of testimonies of the IPU - for the settlement periods determined between the dates timely presentation of IPU readings.

Question
How to determine for what period and in what period the readings of the IPU were taken if they were transferred out of time?


Answer
There is no need to establish which indications refer to which period, since in case of late submission of IPU readings in accordance with paragraph 59 of Rules N 354, the volume of utility consumption in the billing month is assumed to be equal to the average monthly volume (if the readings are not provided for more than 3 months - according to consumption standards) . In the month of the timely submission of IPI readings, the volume is determined based on the submitted IPI readings minus the amount billed for payment for previous months for which IPU readings were not provided or were not provided on time.


Question
Is it possible for consumers to take and transmit readings of individual or room metering devices at times other than those specified in paragraphs. "c" clause 34 of Rules N 354?

Answer
Possibility of withdrawal and transfer consumers indications of an individual, general (apartment) or room metering device at a time different from the time specified in paragraphs. "c" clause 34 of Rules N 354 is missing.


Question
On the possibility of taking readings of an individual, general (apartment) or room metering device at other times, except from the 23rd to the 25th day of the current month.

Answer
In pp. “c” clause 34 of Rules N 354 contains a provision that the consumer is obliged, in the presence of an individual, general (apartment) or room meter, to take his readings monthly from the 23rd to the 25th of the current month and transfer the received readings to the contractor or a person authorized by him no later than the 26th day of the current month, except in cases where, in accordance with the Rules, the contract, containing provisions on the provision of public services, and (or) decisions of the general meeting of owners of premises in an apartment building, actions to take readings from such metering devices must be performed by the performer (a person authorized by him) or another organization.
In pp. g) of the same Rules states that “The Contractor is obliged: ... In the cases established by these Rules, as well as in cases and terms specified in the contract containing provisions on the provision of public services, and (or) by the decision of the owners of premises in an apartment building , take readings of individual and common (apartment), room metering devices , enter the readings received in the register of readings of the indicated metering devices and use them when calculating the amount of payment for utilities for the billing period for which the readings were taken.
The following conclusions can be drawn from the above paragraphs of the Rules:
If the consumer independently takes and transmits the readings of an individual, general (apartment) or room meter, then in this case he is obliged to do this within the time limits established by paragraphs. c) Clause 34 of Rules N 354, i.e. is obliged to monthly take his testimony in the period from the 23rd to the 25th day of the current month and transfer the received testimony to the executor or a person authorized by him no later than the 26th day of the current month. The specified terms established by the Rules, in our opinion, cannot be changed.
If actions to take readings of individual and common (apartment), room metering devices are required to be performed by the performer (a person authorized by him) or another organization (if such an obligation is assigned to the indicated persons by an agreement containing provisions on the provision of public services, and (or) decisions of the general meeting owners of premises in an apartment building), then the timing and cases of taking readings of the indicated metering devices by the contractor (authorized person) or other organization are established by the relevant agreement or decision of the general meeting of owners of the premises.


Question
Is it possible to take into account the readings of the IPU not in the month in which it was put into operation, but from the 1st day of the next month?


Answer
The obligations of the contractor and the consumer to take into account the readings of the IPU from the 1st day of the month following the month in which the IPU was put into operation are established in paragraphs. "y" p.31 and in paragraphs. "and" clause 33 of Rules N 354.


Question
How to apply clause 31 "y", clause 33 "and" and clause 81 paragraph 3 of Rules N 354 with a discrepancy in these paragraphs?

Answer
In our opinion, the provisions of clause 31 “y” and clause 33 “i” should be applied, since they correspond to the procedure for starting calculations based on the readings of newly installed metering devices, based on the provisions of Law N 261-FZ. Discrepancies in these paragraphs are planned to be eliminated by amending the Rules. However, according to such changes previously posted on the website of the Ministry of Regional Development, it is planned to bring the provisions of paragraph 31 "y" and paragraph 33 "and" in accordance with paragraph 81 of Rules N 354.

DETERMINING THE FEES FOR DHW SERVICES WITH OPEN DHW SYSTEM AND AUTONOMOUS DHW SYSTEM

Question
If the cold water and heat supply networks are centralized, can it be considered that the hot water heated in the house is supplied through the centralized ITO networks?


Answer
The current legislation does not contain the concept of centralized IT networks. In accordance with Laws N 190-FZ and N 416-FZ, the concepts of "centralized heat supply system" and "centralized hot water supply system" are given.
Centralized hot water supply refers to the supply of MKD hot water using the municipal infrastructure systems of the settlement, which does not include the equipment of an apartment building involved in the preparation of hot water. Since hot water is prepared inside the house, and only cold water and thermal energy (resources) are supplied to the house, it cannot be considered that the house is connected to the centralized hot water supply networks of the municipal infrastructure of the city.

Question
Is there a regulation for hot water?

Answer
Rules N 306 established the procedure for determining the gas consumption standard for water heating. The standard for the consumption of thermal energy for heating water is not provided for by Rules N306.

Question
How is the volume of thermal energy for heating and hot water supply determined during the heating season in houses with an individual heat point with a thermal energy control unit - common for heating and hot water supply?


Answer
The volume (quantity) of thermal energy used in the production of utility services for hot water supply (heating water) during the heating period, in the presence of a meter that records the total amount of thermal energy used in the production of utility services for heating and hot water supply, is determined by the formula:

where:


The volume (quantity) of thermal energy for heating needs (V (T) OT) is determined as the difference between the readings of the thermal energy (V (T)) and the volume of thermal energy for the needs of hot water supply (V (T) HW):
V (T) FROM \u003d V (T) - V (T) GV
The amount of the fee is calculated according to the formula 18, 20 of Appendix No. 2 to Rules N354.
In the non-heating period, V (T) HW should be recognized as equal to V (T) due to the fact that heating services in accordance with Rules N 354 are provided only during the heating period, while utility bills for general house needs in accordance with clauses 54, 70 Rules N 354 is not separately allocated. In this case, the amount of heat energy consumed according to the indications of the operating cost (including losses of heat energy associated with the circulation of hot water in risers and heated towel rails, independent of the volume of hot water consumption and being technological losses to be accounted for in the volume of services at the ODN) in in accordance with formula 20 of Appendix No. 2 to Rules No. 354, it will be distributed among consumers of premises in proportion to the volume of hot water consumption in the premises, which, in our opinion, does not correspond to the essence of the formation of utilities at the ODN (Rules No. 306), as well as the principle of their payment in proportion to the area of ​​\u200b\u200bthe premises.


Question
Please explain the procedure for calculating payment for heating and hot water services in accordance with paragraph 18 of Government Decree N 307, provided that it is not possible to separately account for fuel consumption for heating and hot water supply (ITP)?

Answer
The volume (quantity) of thermal energy used in the production of utility services for hot water supply (heating water), in the presence of a meter that fixes the total amount of thermal energy used in the production of utility services for heating and hot water supply, is determined by the formula:

where:
- the volume (quantity) of hot water determined for the billing period in the i-th residential premises (apartment) or non-residential premises in an apartment building;
- water density, taken equal to 1000 (kg / m3);
- heat capacity of water, equal to 1 kcal / (kg H (o) C);
- temperature of hot water at the tapping point, which meets the requirements for the quality of utilities, for the billing period (°C). In the absence of actual data, it is assumed to be 60°C;
- the average temperature of the initial cold water: in the non-heating period 15°C, in the heating period it is assumed to be 5°C (°C).

The volume (quantity) of thermal energy for heating needs (V (T) OT) is determined as the difference between the readings of the thermal energy (V (T)) and the volume of thermal energy for the needs of hot water supply (V (T) HW):
V (T) FROM \u003d V (T) - V (T) GV
The fee is charged:
for heating services - according to the formula 7.8 of Appendix No. 2 PNavil No. 307;
for hot water services - according to formula 20 of Appendix No. 2 to Rules No. 354.

In the non-heating period, V (T) HW should be recognized as equal to V (T) due to the fact that heating services in accordance with Rules No. 307 are provided only during the heating period, and Rules No. 307 do not provide for payment for utility services consumed on one heating unit. At the same time, payment for utilities for general house needs in accordance with clauses 54, 70 of Rules N 354 is also not allocated separately. In this case, the amount of heat energy consumed according to the indications of the operating cost (including losses of heat energy associated with the circulation of hot water in risers and heated towel rails, independent of the volume of hot water consumption and being technological losses to be accounted for in the volume of services at the ODN) in in accordance with formula 20 of Appendix No. 2 to Rules No. 354, it will be distributed among consumers of premises in proportion to the volume of hot water consumption in the premises.

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Clause 61 of the Rules for the provision of utility services to owners and users of premises in apartment buildings and residential buildings, approved by the Government of the Russian Federation of 05/06/2011 No. 354 (hereinafter referred to as Rule 354) provides for the obligation of the utility service provider to recalculate if, when checking the accuracy of information about the readings of an individual meter (hereinafter - IPU) discrepancies between the information provided by the consumer and the actual testimony of the IPU were revealed. In this article, we will analyze the cases in which the recalculation is carried out in accordance with paragraph 61 of Rule 354, and the cases in which this rule is not applicable.

What does paragraph 61 of Rule 354 state?

To quote paragraph 61 of Rule 354: 61. If during the verification of the reliability of the information provided by the consumer about the readings of individual, general (apartment), room meters and (or) verification of their condition by the contractor, it is found that the meter is in good condition, including the seals on it are not are damaged, but there are discrepancies between the readings of the checked meter (distributors) and the volume of the communal resource that was presented by the consumer to the contractor and used by the contractor when calculating the amount of the utility service fee for the billing period preceding the check, then the contractor is obliged to recalculate the amount of the utility service fee and to send to the consumer, within the time limits established for payment of utility services for the billing period in which the contractor carried out the check, the requirement to pay additional charges for the utility services provided to the consumer or a notification of the amount of the utility fee is unnecessarily charged to the consumer. Excessive amounts paid by the consumer are subject to offset when paying for future billing periods.

The recalculation of the amount of the fee must be made on the basis of the readings of the meter being checked taken by the contractor during the verification.

At the same time, unless the consumer proves otherwise, the volume (quantity) of the communal resource in the amount of the identified difference in the readings is considered to be consumed by the consumer during the billing period in which the contractor conducted the check».

From the above rule it follows:

1. The recalculation of payment for a utility service is carried out in compliance with a number of requirements:
1.1. " The recalculation of the amount of the fee must be made on the basis of the readings of the meter being checked taken by the contractor during the verification»;
1.2. " The contractor is obliged ... to send to the consumer, within the time limits established for payment of utilities for the billing period in which the contractor conducted the check, a request for additional charges for utilities provided to the consumer or a notice of the amount of utility fees overcharged to the consumer. Excessive amounts paid by the consumer are subject to offset when paying for future billing periods»;
1.3. " The volume (quantity) of the communal resource in the amount of the revealed difference in the readings is considered to be consumed by the consumer during the billing period in which the contractor conducted the check», « unless proven otherwise by the consumer».

2. Recalculation is made in the event of a number of circumstances:
2.1. " There are discrepancies between the readings of the checked meter (distributors) and the volume of the communal resource that was presented by the consumer to the contractor and used by the contractor when calculating the amount of payment for the utility service". It is important to note that the norm directly indicates the discrepancy between the actual readings of the device not with the normative volume of consumption, not with the average monthly volume, not with some information received by the performer from other sources (predicted, calculated, taken by analogy, from the words of neighbors, etc. ) and not with the readings of previous settlement periods, namely with " amount of communal resource, which was submitted by the consumer performer»;
2.2. This discrepancy was found in the course of the verification of the reliability of the information provided by the consumer on the indications of individual, general (apartment), room metering devices and (or) verification of their condition»;
2.3. " The meter is in good condition, including the seals on it are not damaged».

Inspection cases

Since paragraph 61 of Rule 354 establishes that the discrepancy between the readings of the meter being checked and the volume of consumption provided to the contractor by the consumer is established during the check, we will indicate what kind of check we are talking about and in what cases such a check is carried out.

The analyzed norm, in terms of describing the nature of the verification, literally establishes: “ checking the reliability of information provided by the consumer about the readings of individual, general (apartment), room metering devices and (or) checking their condition”, that is, we are talking about three options for checking:
1. verification of the reliability of information provided by the consumer about the readings of individual, general (apartment), room metering devices;
2. checking the status of individual, common (apartment), room metering devices;
3. verification of the reliability of information provided by the consumer about the readings of individual, general (apartment), room metering devices and checking the status of individual, general (apartment), room metering devices.

It should be noted that when conducting a check for the purpose of applying paragraph 61 of Rules 354, in any case, a third type of check is necessary (a comprehensive check of both the readings of the device and its condition), since the performer, by virtue of the requirements of paragraph 61 of Rules 354, must establish that " the meter is in good condition, including the seals on it are not damaged”, that is, when checking only the reliability of information about the readings of the device, in any case, it is necessary to check its condition, and when checking only the state of the device to assess the reliability of its readings, these readings must be checked. Thus, a textual construction that allows considering three types of checks separately seems to be absolutely redundant, although legally no violation is seen.

Therefore, in this article we will talk about a comprehensive check of both the readings of the meter and its condition (hereinafter referred to as Check).

According to subparagraph "g" of paragraph 31, the contractor is obliged to carry out Checks, however, this rule does not establish the timing and frequency of such Checks.

Paragraph 82 of Rule 354 confirms the above rule:
« 82. The contractor is obliged:
a) check the condition of installed and commissioned individual, common (apartment), room metering devices and distributors, the fact of their presence or absence;
b) to verify the reliability of the information provided by consumers about the readings of individual, general (apartment), room metering devices and distributors by comparing them with the readings of the corresponding metering device at the time of the check (in cases where the readings of such metering devices and distributors are carried out by consumers)».

Section 83 of Rule 354 sets limits on the frequency of Checks:
« 83. The checks specified in paragraph 82 of these Rules must be carried out by the contractor at least once a year, and if the metering devices being checked are located in the consumer's living quarters, then no more than once every 3 months».

Subparagraph “d” of paragraph 32 of Rules 354 partially duplicates paragraph 83 and additionally establishes restrictions on the frequency of Checks for devices installed in non-residential premises and outside premises and households. According to subparagraph "d" of paragraph 32 of Rules 354, the contractor has the right to conduct Checks, but not more than 1 time in 3 months if the meter is installed in a residential area or household, and not more than 1 time per month if the meter is installed in a non-residential indoors, as well as outside the premises and households in a place that the performer can access without the presence of the consumer. At the same time, according to subparagraph “g” of paragraph 34 of Rules 354, the consumer is obliged to allow the contractor to the occupied residential premises or household for Checking at a time agreed in advance in the manner specified in paragraph 85 of Rules 354, but not more than 1 time in 3 months.

The above norms do not establish specific terms for conducting Inspections, but only establish restrictions. Some regulations establish more specific deadlines for conducting Inspections in individual cases.

For example, according to subparagraph "k (4)" of paragraph 33 of Rules 354, the consumer has the right to demand Checks from the contractor. The Contractor, in accordance with subparagraph "e (2)" of paragraph 31 of Rule 354, is obliged to carry out the Verification at the request of the consumer within 10 days after receiving such an application.

The parties to the agreement containing the provisions on the provision of public services, i.e. the contractor and consumers of public services, are vested with the right and obligation to determine specific deadlines for conducting inspections. Subparagraph “i” of paragraph 19 of Rule 354 establishes: “ An agreement containing provisions on the provision of public services should include: the frequency and procedure for the contractor to check the presence or absence of individual, common (apartment), room metering devices, distributors and their technical condition, the reliability of information provided by the consumer about the readings of such metering devices and distributors».

Non-submission of IPU readings by the consumer

Another case of verification is regulated by paragraph 84 of Rule 354, which establishes: “ If the consumer fails to provide the contractor with the readings of an individual or common (apartment) meter for 6 months in a row, the contractor no later than 15 days from the date of expiration of the specified 6-month period, another period established by the contract containing provisions on the provision of utility services, and (or) decisions general meeting of owners of premises in an apartment building, is obliged to conduct the verification specified in paragraph 82 of these Rules and take readings from the meter».

Previously, an article "" was published on the AKATO website, which caused a lot of controversy on the issue of whether the service provider, having carried out the Verification on the basis of paragraph 84 of Rules 354, recalculates the amount of payment for the utility service in accordance with paragraph 61 of Rules 354, since the volume of service actually consumed , determined according to the readings of the device for the period of non-submission of readings, does not coincide with the volume presented for payment for the specified period, calculated according to the average monthly volume and / or consumption standard.

Let's analyze this question.

Paragraph 84 indeed obliges to carry out a Check after 6 months of non-submission by the consumer of information about the readings of the meter. Paragraph 61 indeed establishes that, based on the results of the Check, the contractor is obliged to make a recalculation, however, it should be noted that the recalculation is made in the case, “ if during the verification of the reliability of the information provided by the consumer about the readings of individual, general (apartment), room meters and (or) verification of their condition by the contractor, it is established by the contractor that the meter is in good condition, including the seals on it are not damaged, but there are discrepancies between the readings of the checked meter (distributors) and the volume of the communal resource that was presented by the consumer to the contractor ».

If the consumer did not provide the contractor with information about the readings of metering devices, that is, the volume of consumed communal resource presented by the consumer is not defined, then it is impossible to determine the discrepancy between the actual readings of the metering device and those presented by the consumer, and since it is the cost of this discrepancy volume that is the size recalculation, then the size of the recalculation is not subject to determination.

Therefore, it is precisely in the event that the consumer does not provide information about the readings of the metering device, clause 61 of Rules 354 is not applicable.

At the same time, paragraph 84 of Rules 354 obliges the contractor, when conducting the Check, after a 6-month period of non-submission of meter readings by the consumer, to take readings of this meter. However, not a single rule indicates that the contractor is obliged to apply the testimony taken when determining the amount of the recalculation, including the use of the testimony taken by the contractor is not provided about and paragraph 61 of Rule 354.

Application of paragraph 61

Based on the foregoing, clause 61 of Rules 354 applies only if, during the Verification, the fact of the consumer transmitting unreliable meter readings is revealed. Such a Check can be carried out either at the initiative of the contractor (subparagraph "g" of paragraph 31, subparagraph "d" of paragraph 32, paragraph 82 of Rule 354), or at the initiative of the consumer (subparagraph "e (2)" of paragraph 31 and subparagraph "k (4 )" of paragraph 33 of Rules 354), or in accordance with the approved contract for the provision of public services in the manner and frequency (subparagraph "i" of paragraph 19 of Rules 354).

Consider examples of the application of paragraph 61 of Rule 354.

Example 1

Let the performer check the consumer metering device on the first day of the month N1 and find that the readings of the IPU of cold water consumption are 100 cubic meters. In month N2, the consumer submitted meter readings of 102 cubic meters, the contractor presented for payment the consumption of 2 cubic meters of water for month N1. In month N3, the consumer informed the executor of IPU readings of 105 cubic meters, the executor presented for payment the consumption of 3 cubic meters of water for month N2. In month N4, the consumer informed the executor of IPU readings of 107 cubic meters, the executor presented for payment the consumption of 2 cubic meters of water for month N3. In the same month, N4, the contractor conducted a Check of the meter and found that the transmitted readings of the meter are unreliable, and in fact the device at the time of the Check shows 110 cubic meters. In this case, the performer applies paragraph 61 of Rule 354, namely:
- sets the discrepancy volume in the amount of 3 cubic meters (110-107);
- sends to the consumer, within the period established for paying for the volume of water for the month N4, a request for making an additional charge in the amount of the cost of 3 cubic meters of water;
- if the consumer in the month N5 transmitted the readings of the device in the amount of 112 cubic meters, then the contractor in the month N5 presents for payment for the month N4 the discrepancy revealed in the volume of 3 cubic meters and the volume transferred by the consumer is 2 cubic meters (112-110), then there are only 5 cubic meters.

On a monthly basis, the contractor presents to the consumer for payment: Month N1 - 2 cubic meters, Month N2 - 3 cubic meters, Month N3 - 2 cubic meters, Month N4 - 5 cubic meters, total - 12 cubic meters. It is 12 cubic meters that makes up the difference between the readings of the meter at the time of the Check in month N1 (100 cubic meters) and the readings of the device transmitted by the consumer in month N5 (112 cubic meters).

Example 2

Let the performer in the above Example 1, during the Check in month N4, establish that the actual readings of the IPU are 106 cubic meters. In this case, the performer applies paragraph 61 of Rule 354, namely:
- sets the discrepancy volume in the amount of 1 cubic meter (107-106);
- sends to the consumer, within the period established for paying for the volume of water for the month N4, a notice on the amount of the overcharged consumer for water in the amount of 1 cubic meter;
- if the consumer in the month N5 transmitted the readings of the device in the amount of 109 cubic meters, then the contractor in the month N5 takes into account the overpaid volume of 1 cubic meter and the volume transferred by the consumer of 3 cubic meters (109-106), that is, only 2 cubic meters .

On a monthly basis, the contractor presents to the consumer for payment: Month N1 - 2 cubic meters, Month N2 - 3 cubic meters, Month N3 - 2 cubic meters, Month N4 - 2 cubic meters, total - 9 cubic meters. It is 9 cubic meters that makes up the difference between the readings of the meter at the time of the Check in month N1 (100 cubic meters) and the readings of the device transmitted by the consumer in month N5 (109 cubic meters).

Inapplicability of paragraph 61

Example 1

The contractor presented to the consumer for payment in the month N5 for the month N4 the volume of 3 cubic meters, in the month N6 for the month N5 - 3 cubic meters and in the month N7 for the month N6 - 3 cubic meters. In month 7, the contractor conducted a Check and found that the readings of the meter are 15 cubic meters. The performer defines these readings as the initial readings of the IPU for calculating the volume of consumption for Month N7, while no recalculation is made, since the readings were not transmitted, and recalculation in accordance with paragraph 61 of Rule 354 is possible only if the unreliability of the IPU readings is revealed.

Despite the fact that, according to the testimony of the IPU, for 6 months the consumer consumed 15 cubic meters (15-0), he was presented with payment: Month N1 - 2 cubic meters, Month N2 - 3 cubic meters, Month N3 - 4 cubic meters. meters, Month N4 - 3 cubic meters, Month N5 - 3 cubic meters, Month N6 - 3 cubic meters, total - 18 cubic meters.

The consumer actually paid for 3 cubic meters not consumed by him, but this is exactly the procedure established by the current legislation.

Example 2

Let the executor take into account the IPI of the consumer from the first day of the month N1 and establish that the indications of the IPI of cold water consumption are 0 cubic meters. In month N2, the consumer submitted meter readings of 2 cubic meters, the contractor presented for payment the consumption of 2 cubic meters of water for month N1. In month N3, the consumer informed the executor of IPU readings of 5 cubic meters, the executor presented for payment the consumption of 3 cubic meters of water for month N2. In month N4, the consumer informed the contractor of IPU readings of 9 cubic meters, the contractor presented for payment the consumption of 4 cubic meters of water for month N3.

Further, the consumer stopped transmitting meter readings to the contractor, and the contractor began to calculate according to the average monthly meter readings (), which for three months amounted to (9-0) / 3 = 3 cubic meters

The contractor presented to the consumer for payment in the month N5 for the month N4 the volume of 3 cubic meters, in the month N6 for the month N5 - 3 cubic meters and in the month N7 for the month N6 - 3 cubic meters. In month 7, the performer conducted a Check and found that the meter reading was 20 cubic meters. The performer defines these readings as the initial readings of the IPU for calculating the volume of consumption for Month N7, while no recalculation is made, since the readings were not transmitted, and recalculation in accordance with paragraph 61 of Rule 354 is possible only if unreliability is detected transferred by the consumer to the contractor IPU readings.

Despite the fact that according to the testimony of the IPU for 6 months, the consumer consumed 20 cubic meters (20-0), he was presented with payment: Month N1 - 2 cubic meters, Month N2 - 3 cubic meters, Month N3 - 4 cubic meters. meters, Month N4 - 3 cubic meters, Month N5 - 3 cubic meters, Month N6 - 3 cubic meters, total - 18 cubic meters.

The consumer actually consumed 2 cubic meters of water more than he paid for, but this is exactly the procedure established by the current legislation. The indicated 2 cubic meters will increase the amount of communal resources consumed in the maintenance of common property, and will be a loss for the utility services provider.

conclusions

Establishes that the contractor is obliged to recalculate if, during the verification of the reliability of the information provided by the consumer about the readings of individual, general (apartment), room meters and (or) checking their condition by the contractor, it is established that the meter is in good condition, in including the seals on it are not damaged, but there are discrepancies between the readings of the checked meter (distributors) and the volume of the communal resource that was presented by the consumer to the contractor and used by the contractor when calculating the amount of payment for the utility service for the billing period preceding the verification.

The specified norm is applicable only if the consumer provided the contractor with false information about the readings of the meter, but is not applicable if the consumer did not report the IPU readings to the contractor at all.


Note: The analysis of paragraph 61 of Rules 354 was carried out at the request of Yugo-Zapadnoye LLC.
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Comments on the Rules for the Provision of Public Services (Resolution No. 354)
Information of the Ministry of Regional Development of the Russian Federation. Non-normative information.

1. PROCEDURE FOR DETERMINING THE AMOUNT OF PAYMENTS FOR PUBLIC SERVICES CONSUMED IN A RESIDENTIAL AND NON-RESIDENTIAL PREMISES
1.1. Determining the amount of the fee using the standards for the consumption of utilities
1.2. Determining the amount of the fee in the presence of IPU
1.3. Application of utility tariffs
1.4. Determining the size of the fee in the hostel
1.5. Determining the amount of payment for heating services
1.6. Determining the amount of payment for DHW services with an open DHW system and an autonomous DHW system
1.7. Determining the amount of payment for wastewater services
1.8. Determining the amount of payment for utilities in non-residential premises
1.9. About payers for utilities

2. PROCEDURE FOR DETERMINING THE AMOUNT OF PAYMENT FOR
2.1. Application of consumption standards for ODN
2.2. Application in the calculation of payment for utility services GTC
2.3. About the areas of common areas in the MKD
2.4. Determination of fees for utilities at ODN by type of service
2.5. Determination of utility bills for ODN for non-residential premises
2.6. Determination of utility bills for ODN in dormitories

3. RECALCULATION OF THE AMOUNT OF THE FEES IN THE TEMPORARY ABSENCE OF CONSUMERS
3.1. About consumer-provided documents
3.2. Procedure and cases of recalculations

4. SPECIAL CASES FOR DETERMINING THE AMOUNT OF PAYMENTS FOR UTILITY SERVICES
4.1. Cases of determining the amount of payment for utilities without using the readings of the IPU, if consumers have them
4.2. Cases of determining the amount of payment for utilities without using the readings of the GTC, if available
4.3. Unauthorized connection

5. CHANGING THE AMOUNT OF THE PAYMENT WHEN THE QUALITY OF UTILITY SERVICES IS DISTURBED
5.1. Foundations and general procedure
5.2. Change in the amount of payment for water supply and sanitation services
5.3. Changing the amount of payment for heating services

6. LIMITATION AND SUSPENSION OF PUBLIC SERVICES
6.1. Procedure and cases
6.2. On determining consumer debt

7. PAYMENT DOCUMENT AND PAYMENT PROCEDURE
7.1. Type of payment document and its presentation to consumers
7.2. Filling out a payment document
7.3. Providing installment payment
7.4. Participation of RCC in payments for utility services
7.5. Payment for utility services in the RSO

8. CONTRACT WITH THE PRODUCER OF PUBLIC SERVICES
8.1. On the possibility of RSO to be a utility service provider in the presence of a managing organization
8.2. Limits of operational responsibility of the utility service provider
8.3. Relations with property owners
8.4. Relations of the Contractor with consumers of utility services
8.5. Relations with the contractor of public services with the direct method of managing MKD
8.6. Provision of public services in residential buildings
8.7. About the Contractor of public services in new apartment buildings

9. GAS SUPPLY
9.1. On the application of Regulation No. 549
9.2. On the application of Regulation No. 354

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