Recommendation for Commission Consideration

The preceding chapters examined water conservation policy, conservation-oriented residential rate design, New York's existing regulatory framework, household occupancy, comparable utility implementation, administrative feasibility, and the findings supported by the available research. The purpose of this final chapter is not to revisit that evidence, but to present a recommendation for Commission consideration that is consistent with the conclusions established throughout the report.

The research demonstrates that water conservation remains an important public policy objective and that conservation-oriented residential rate structures continue to serve an important role in encouraging efficient water use. Nothing in this report suggests that these conservation principles should be abandoned. Instead, the evidence indicates that conservation objectives, occupancy-based adjustments, verification or staff-review procedures, administrative feasibility, and customer privacy have been successfully integrated by several water utilities through documented administrative practices.⁵¹

Accordingly, this report recommends that the New York Public Service Commission evaluate the implementation of an optional adjustment to the initial residential water allocation based on verified household occupancy within future conservation-oriented residential rate proceedings involving investor-owned water utilities.

The proposed adjustment would not replace existing conservation-oriented residential rate structures. Nor would it reduce the conservation price applicable to higher residential water use. Rather, the proposal would allow participating households, upon verification of household occupancy, to receive an adjusted initial residential allocation before higher conservation prices apply. All water consumed beyond the adjusted allocation would continue to be billed under the existing conservation-oriented rate structure.

Participation should remain entirely voluntary. Households choosing not to request an adjustment would continue receiving service under the standard residential tariff without any additional administrative requirements. This voluntary approach respects customer privacy by ensuring that no household is required to submit occupancy documentation unless it chooses to participate.

Eligibility should be based upon verified household occupancy using reasonable documentation established by the utility and approved through the Commission's regulatory process. Consistent with practices documented in comparable utility programs, customers should be permitted to provide one or more forms of acceptable documentation demonstrating the number of residents sharing the household. Utilities would retain the authority to review submitted information, request additional documentation when appropriate, deny unsupported applications, and establish reasonable renewal requirements to maintain program accuracy.⁵²

Administration should build upon existing utility practices whenever possible. Online application forms, electronic document submission, staff review, and established customer-service procedures already used in the programs examined provide practical mechanisms for administering occupancy verification while protecting customer information and limiting administrative burden.⁵³

The purpose of an occupancy adjustment would not be to reduce the overall cost of water service or weaken conservation incentives. Instead, it would recognize that households with more residents naturally require more essential water for ordinary daily activities before discretionary consumption becomes a meaningful consideration. By adjusting the initial residential allocation while preserving progressively higher conservation prices beyond that allocation, the proposal seeks to maintain the existing conservation framework while recognizing documented differences in ordinary household water demand.

Any consideration of such a program should occur through the Public Service Commission's established regulatory process. Utilities, Department of Public Service Staff, consumer advocates, municipalities, and other interested parties should have the opportunity to review the available evidence, evaluate administrative procedures, consider implementation costs, and assess potential customer impacts before any policy changes are adopted. This collaborative regulatory process is consistent with the Commission's longstanding approach to utility regulation and conservation policy.

This report does not conclude that a particular adjustment formula, occupancy threshold, or verification standard should be adopted. Those implementation details require utility-specific analysis and regulatory review. Rather, the research supports a narrower conclusion: the available evidence demonstrates that conservation-oriented residential rate design, occupancy-based adjustments, verification or staff-review procedures, customer privacy, and practical administration have been successfully combined within documented utility practice.

For that reason, the report recommends that the Public Service Commission evaluate an optional adjustment to the initial residential water allocation based on verified household occupancy in future residential water rate proceedings involving New York's investor-owned water utilities. Such an evaluation would allow the Commission to determine, based upon evidence developed through its existing regulatory processes, whether implementation would further the public interest while preserving the conservation objectives that remain central to New York's water policy.