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Chapter 2

Why Water Utilities Use Tiered Residential Water Rates

Having established conservation as an important public-policy objective, the next question is how residential rate design contributes to that objective. Education, outreach, rebates, leak reduction, and infrastructure improvements can reduce unnecessary consumption. Utilities also use the structure of water rates themselves to influence customer behavior.

Water rates serve more than one purpose. They must recover the utility's authorized revenue requirement and reflect the allocation of costs among customer classes, while the design of volumetric charges can also create incentives for more efficient use. Conservation-oriented pricing therefore sits at the intersection of revenue recovery, cost of service, customer impacts, and behavioral incentives.

Under an inclining block rate structure, residential consumption is divided into successive usage blocks or tiers. Water within the first block is billed at one rate; additional water is billed at higher rates as consumption moves through later blocks. The progressively higher prices are intended to strengthen the conservation signal as total use rises.13

An initial block may be designed to encompass a level of ordinary or basic residential demand, but that design objective does not guarantee that every household's basic indoor needs remain within the first block. A fixed meter-level threshold does not by itself identify why consumption is higher. Additional volume can reflect household occupancy, outdoor use, leaks, inefficient fixtures, unusual circumstances, or a combination of factors.

New York's conservation-oriented residential tariffs illustrate the use of inclining blocks as a policy tool. In approving Veolia Water New York's recent rate plan, the Commission described the structure as conservation-oriented and designed to discourage discretionary usage, particularly in summer. That statement identifies the behavioral purpose of the higher blocks, but it does not establish that all use entering a higher block is necessarily discretionary.

The historical SUEZ record also shows that conservation pricing and cost recovery were considered together when the Rockland three-block structure was developed. The company's rate witness described the volumetric rates as serving both conservation and movement of revenues toward cost of service. That history is examined in detail in Chapter 4 because it is directly relevant to the rate-equity question now presented.14

Contemporary New York utility testimony reflects the same broader rate-design considerations. In Liberty Utilities' 2026 filing, the company's cost-of-service and rate-design consultants described fair rates in cost-causation terms and identified among traditional ratemaking principles both discouraging wasteful use while promoting justified types and amounts of use and fairness in allocating total costs. They described rate design as balancing cost causation, economic efficiency, customer equity, rate stability, and broader policy goals.15

Liberty Utilities provides another example of why rate design remains subject to factual review after a tariff is adopted. The Commission-approved Threshold Analysis asked whether indoor-only household demand could reach the highest conservation tier during non-peak months. The existence of that inquiry reflects an important regulatory principle: a conservation structure should be assessed using actual usage conditions rather than assuming that every high-tier occurrence has the same cause.

The economic rationale for inclining rates remains strong. Some water uses are more responsive to price than others. Higher prices can encourage customers to repair leaks, reduce unnecessary outdoor use, improve fixture efficiency, or otherwise lower demand where practical. Nothing in the household-occupancy inquiry requires abandoning those incentives.

The rate-equity question is narrower. A uniform starting threshold applies the same numerical limit to each account within a service class, but total meter volume is not the same as per-person efficiency and does not reveal the cause of higher use. When materially different household occupancies share the same threshold, regulators may reasonably examine whether the resulting conservation signal is distinguishing the kinds of use it is intended to influence while still recovering authorized revenues fairly.16

That inquiry requires a clearer understanding of basic indoor water needs and discretionary demand. The next chapter examines those concepts and explains why conservation responsibility applies to households of every size even as occupancy remains relevant to total indoor demand.


Footnotes

13 American Water Works Association, Water Conservation Programs - A Planning Manual (Manual M52), 2nd ed. (2017); New York State Public Service Commission, Order Adopting Joint Proposal as Modified and Establishing Rate Plan, Case 23-W-0111 (issued May 16, 2024). Return to text

14 Paul R. Herbert, Direct Testimony, SUEZ Water New York Inc., Case 16-W-0130, at 11-13; Paul R. Herbert, Rebuttal Testimony, Case 16-W-0130, at 3-4. Return to text

15 Willis P. Geffert and Christopher R. Galantino, Direct Testimony of Cost of Service and Rate Design Panel, Liberty Utilities (New York Water) Corp. (May 29, 2026), associated with Case 26-W-0358, at 5 and 14. Return to text

16 New York State Public Service Commission, Order Establishing Rate Plan, Case 16-W-0130 (issued January 24, 2017); Liberty Utilities (New York Water) Corp., Threshold Analysis Study 2024, Case 23-W-0235. Return to text


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