Administrative Feasibility: Verification, Privacy, and Program Administration

The preceding chapter demonstrated that several conservation-oriented water utilities have incorporated household occupancy into their residential conservation programs while maintaining tiered rate structures. An equally important question, however, is whether such programs can be administered in a practical, reliable, and cost-effective manner.

The evidence reviewed for this report indicates that the answer is yes. The utilities examined use established customer-service functions, online application processes, staff review, and documentation procedures where required. Rather than creating entirely new administrative systems, these programs build upon functions already used to manage customer accounts and adjustment requests.³⁰

A common feature among the utilities examined is that occupancy adjustments are voluntary rather than automatic. Customers who believe their household occupancy differs from the assumptions underlying the standard residential allocation may submit a request for review. Customers who do not seek an adjustment continue receiving service under the standard residential rate structure without any additional administrative requirements.

This voluntary approach offers two important advantages. First, it significantly reduces administrative complexity because utilities review only those applications submitted by customers requesting an adjustment rather than verifying every residential account. Second, it respects customer privacy by ensuring that households who prefer not to provide occupancy documentation are under no obligation to do so. Participation remains entirely optional, allowing customers to decide whether the potential benefit of an occupancy adjustment outweighs the need to submit supporting information.

Verification procedures rely upon administrative practices that utilities already perform in other contexts. IRWD requires proof of permanent residency for each additional household member and provides multiple examples of acceptable evidence. Boulder permits applications to be audited and authorizes staff to require additional documentation when necessary. LVMWD’s current form requires customers requesting a resident-count change to report the total number of permanent residents and states that all adjustments are subject to District review, although the form does not specify residency documents for that category. The evidence therefore shows that verification and review requirements can be tailored by utility rather than imposed through one uniform document standard.³¹

Modern utility technology has further simplified program administration. The utilities reviewed provide online application forms or account-management channels through which customers can submit requests, attach documents where required, and communicate with customer service. Electronic submission and digital processing can reduce paperwork and support efficient administrative review.³²

In practice, much of the administrative process can be completed electronically. Customers submit an online request and, where required, attach supporting documentation; utility personnel then review the request under established program rules. This approach combines digital submission with staff judgment and allows utilities to administer adjustments through existing customer-service operations.³³

Privacy protections are not identical across the programs reviewed. IRWD’s rules expressly provide that documents submitted during the variance process are reviewed and then returned upon request or destroyed to protect customer privacy, subject to information the District must retain. LVMWD and the City of Boulder publish privacy policies governing information submitted through their websites. These examples demonstrate that occupancy-adjustment programs can be paired with privacy controls, while any New York program would need clearly defined standards for collection, access, retention, and deletion.³⁴

Periodic renewal or reconfirmation requirements are also used in documented programs. IRWD requires approved variances to be reconfirmed by the expiration date specified by the District, and Boulder’s governing rule states that household-size adjustments are renewable on an annual basis. Because household composition can change over time, renewal or reconfirmation procedures help ensure that an adjustment continues to reflect current conditions.³⁵

Program integrity is further supported by utility authority to review requests, require additional documentation, deny unsupported applications, and limit or reconfirm approved adjustments. IRWD’s rules authorize proof requirements, written denial, specified validity periods, and reconfirmation; Boulder permits audit and additional documentation; and LVMWD subjects adjustments to District review. These safeguards provide mechanisms for addressing incomplete or inaccurate information without affecting customers who remain under the standard residential rate structure.³⁶

The research also demonstrates that administrative feasibility should not be viewed solely in terms of cost. Administrative processes must also be evaluated according to their accuracy, transparency, consistency, and ability to protect customer information. The utilities examined throughout this report illustrate that these objectives are not mutually exclusive. Verification procedures, privacy protections, renewal requirements, and conservation-oriented pricing can operate together within a single administrative framework.

Importantly, the evidence reviewed does not suggest that occupancy-based conservation programs require utilities to verify every aspect of a customer's household. Instead, they rely upon reasonable documentation sufficient to administer the program fairly and consistently. This approach reflects a practical balance between administrative efficiency, customer privacy, and program integrity.

Taken together, these administrative practices demonstrate that household occupancy adjustments are not merely theoretical concepts. They are operational programs that have been implemented, administered, and maintained by water utilities using established customer service procedures while continuing to support broader conservation objectives.

The next chapter brings together the evidence developed throughout this report by examining how the research fits within New York's existing regulatory framework. Rather than introducing recommendations, it integrates the findings from the preceding chapters to identify the conclusions that naturally emerge from the evidence.