Comparable Utility Implementation

The preceding chapter establishes why household occupancy is relevant to indoor residential demand. The next question is practical: have utilities preserved conservation pricing while allowing a household-size adjustment to the amount of water available before higher prices apply? Comparable programs answer that question, but their role in this report is deliberately limited. They demonstrate workable approaches; they do not dictate New York's formula, eligibility rules, or cost allocation.

Irvine Ranch Water District uses budget-based residential rates in which the indoor water budget is tied to the number of people in the household. Current District materials assign default resident assumptions by property type and allow customers with additional permanent occupants to request a variance. The District requires supporting documentation for additional occupants and requires those variances to be renewed annually. Higher-priced conservation rates continue to apply when usage exceeds the applicable water budget. This is a direct example of a utility treating household occupancy as relevant to the conservation baseline rather than eliminating the conservation signal.³¹

Las Virgenes Municipal Water District likewise uses water budgets and allows a customer to request an adjustment based on permanent-resident count. The materials reviewed for this report require the customer to report the number of permanent residents and provide for District review before the water budget is changed. As with IRWD, the adjustment concerns the budget or baseline; it does not remove the higher prices that apply when use exceeds the adjusted budget.³²

The City of Boulder provides a third example. Boulder uses individualized water budgets to encourage conservation and allows water-budget adjustments under defined circumstances, including household-size adjustments under its governing rules and application process. Boulder also makes the basic billing principle clear: customers are billed only for the water they actually use, while water used above the budget is charged at higher rates. The budget changes the threshold for the conservation price signal, not whether the water is billed. As of August 2026, Boulder is reviewing its broader water-budget policy as part of a Utilities rate study; the City continues to publish its Water Budgets page and adjustment application while that review is underway.³³

Taken together, these programs establish a modest but important point. An occupancy adjustment is not merely theoretical. Utilities can incorporate resident count into a conservation baseline, review a customer request, and continue charging progressively higher prices once the adjusted amount is exceeded. That operational experience is directly relevant to the question whether conservation and rate equity can coexist in one residential rate framework.

The examples do not establish that New York should copy another utility's gallons-per-person amount, default household size, proof requirements, renewal schedule, or rate levels. They also do not answer Veolia-specific questions concerning cost of service, revenue recovery, or bill impacts. Those matters depend on New York law, the applicable service classification, current customer data, and the evidentiary record developed before the Commission.

The comparable programs are therefore best understood as feasibility evidence. They show that utilities have developed administrative methods to recognize differing basic indoor needs while retaining conservation pricing. They also demonstrate that a final program can include defined eligibility, documentation or review, renewal, and privacy protections rather than relying on an unlimited or automatic adjustment.³⁴

This distinction keeps the proposal narrow. The research does not ask New York to import another jurisdiction's water budget. It asks whether New York can use the documented experience of other utilities, together with its own regulatory record, to develop an appropriate optional adjustment for the applicable residential class. The next chapter examines the administrative questions that such an approach would have to address.