Chapter 9
Research Findings
The preceding chapters examined water conservation policy, conservation-oriented residential rate design, New York's regulatory framework, household occupancy, comparable utility implementation, and administrative feasibility. Based upon the evidence reviewed throughout this report, the following findings are supported by the documented research.
Finding 1
Water conservation is an established public policy objective.
The evidence demonstrates that water conservation is a longstanding objective of public policy. New York regulatory proceedings, conservation programs, and water resource management policies consistently recognize efficient water use as an important means of protecting water resources, supporting reliable utility service, and promoting long-term sustainability. Conservation therefore serves as the policy foundation for modern residential water rate design.41
Finding 2
Conservation-oriented residential rate structures encourage efficient water use through pricing.
Tiered, or inclining block, residential water rates increase the cost of water consumed beyond an initial allocation. Rather than reducing the price of essential household water use, these rate structures encourage efficient water use by applying progressively higher prices to additional consumption. The evidence demonstrates that conservation-oriented pricing remains an established regulatory tool used by many water utilities, including investor-owned utilities regulated by the New York Public Service Commission.42
Finding 3
Conservation policy distinguishes between essential household water use and discretionary demand.
Government guidance, industry research, and utility conservation programs consistently distinguish between water required for ordinary household living and water use that presents greater opportunities for voluntary conservation. This distinction forms an important part of modern conservation policy and provides context for understanding conservation-oriented residential rate design.43
Finding 4
Household occupancy is a significant determinant of ordinary residential water demand.
The research consistently demonstrates that ordinary household water demand increases as more people share a home. This relationship reflects the cumulative effect of essential daily activities—including drinking, cooking, bathing, sanitation, laundry, and other routine household uses—rather than inherently inefficient water use. Household occupancy is therefore a documented factor influencing residential water demand.44
Finding 5
New York's regulatory framework recognizes the importance of evaluating conservation-oriented rate structures using actual customer data.
The Liberty Utilities Threshold Analysis demonstrates that the New York Public Service Commission's regulatory framework supports evaluating conservation-oriented residential rate structures through evidence gathered under actual operating conditions. Rather than assuming that all higher residential consumption reflects the same causes, the Commission-approved process recognized the importance of examining indoor household demand, seasonal usage patterns, and other relevant factors before drawing broader conclusions.45
Finding 6
Comparable utilities have incorporated occupancy-based adjustments into conservation-oriented rate structures while preserving conservation objectives.
The comparable utilities examined in this report demonstrate that household-occupancy adjustments have been incorporated into conservation-oriented rate structures without eliminating higher-priced conservation tiers or abandoning broader conservation goals. These examples illustrate documented administrative practices rather than legal precedent for New York.46
Finding 7
Occupancy-based conservation programs have been administered through established utility practices.
The research demonstrates that utilities have administered occupancy-based adjustments using voluntary applications, staff review, online submission, documentation where required, privacy policies or document-handling rules, and periodic renewal or reconfirmation in some programs. These practices demonstrate that occupancy verification and review can be incorporated into routine utility operations without requiring fundamentally new administrative systems.47
Finding 8
Conservation objectives, occupancy-based adjustments, verification or review procedures, administrative feasibility, and customer privacy are compatible within documented utility practice.
The evidence reviewed throughout this report demonstrates that these objectives are not mutually exclusive. Comparable utility programs show that conservation-oriented pricing, occupancy-based adjustments, verification or staff-review procedures, customer privacy, and practical administration can operate together within a single regulatory framework while continuing to encourage efficient water use.48
Finding 9
The evidence identifies no inherent conflict between conservation-oriented residential rate design and the use of verified household occupancy to adjust the initial residential water allocation while preserving higher-priced conservation tiers.
Nothing in the research reviewed for this report suggests that using verified household occupancy to adjust the initial residential water allocation is fundamentally incompatible with conservation-oriented residential rate structures. Instead, the documented evidence demonstrates that multiple utilities have successfully integrated occupancy-based adjustments while maintaining higher-priced conservation tiers and supporting broader water conservation objectives.49
Finding 10
The evidence supports evaluation of whether an optional household-occupancy adjustment to the initial residential water allocation can be implemented within New York's existing conservation-oriented residential rate structures using documented customer usage and established administrative practices.
The research assembled throughout this report demonstrates that evaluation of an optional household-occupancy adjustment should be based on documented customer usage, practical administrative experience, and objective evidence. Such evaluation is consistent with New York’s existing regulatory approach and provides an evidence-based foundation for determining whether the adjustment can be implemented within the Public Service Commission’s established framework while preserving conservation objectives.50
The findings presented above are derived from the evidence examined throughout this report. They do not constitute policy recommendations. Rather, they identify the principal conclusions supported by the documented research. The final chapter builds upon these findings by presenting a recommendation for Commission consideration within New York's existing regulatory framework.
Footnotes
41 New York State Department of Environmental Conservation, “Water Use & Conservation” and “Water Conservation Requirements”; 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
42 New York State Public Service Commission, Order Adopting Joint Proposal as Modified and Establishing Rate Plan, Case 23-W-0111 (issued May 16, 2024); American Water Works Association, Water Conservation Programs—A Planning Manual (Manual M52), 2nd ed. (2017). Return to text
43 U.S. Environmental Protection Agency, WaterSense, “How We Use Water”; William B. DeOreo et al., Residential End Uses of Water, Version 2: Executive Report, Water Research Foundation, Project 4309, Report 4309A (2016); American Water Works Association, Water Conservation Programs—A Planning Manual (Manual M52), 2nd ed. (2017). Return to text
44 William B. DeOreo et al., Residential End Uses of Water, Version 2: Executive Report, Water Research Foundation, Project 4309, Report 4309A (2016); U.S. Environmental Protection Agency, WaterSense, “Understanding Your Water Bill”; Liberty Utilities (New York Water) Corp., Threshold Analysis Study 2024, Case 23-W-0235. Return to text
45 New York State Public Service Commission, Order Adopting Terms of Joint Proposal and Establishing Rate Plan, Case 23-W-0235 (issued August 15, 2024); Liberty Utilities (New York Water) Corp., Threshold Analysis Study 2024, Case 23-W-0235. Return to text
46 Irvine Ranch Water District, “Residential Water Rates” and “Request A Water Variance”; Las Virgenes Municipal Water District, “Water Budgets” and “Water Budget Adjustment Request”; City of Boulder, City Manager Rule 11-1-3.A(21), Attachment A, § 6. Return to text
47 Irvine Ranch Water District, “Request A Water Variance” and Rules and Regulations, §§ 12.7.1–12.7.2; Las Virgenes Municipal Water District, “Water Budget Adjustment Request” and “Privacy Policy”; City of Boulder, City Manager Rule 11-1-3.A(21), Attachment A, § 6, “Water Budget Adjustment Application,” and “Privacy Policy.” Return to text
48 Irvine Ranch Water District, “Residential Water Rates,” “Request A Water Variance,” and Rules and Regulations, §§ 12.7.1–12.7.2; Las Virgenes Municipal Water District, “Water Budgets,” “Water Budget Adjustment Request,” and “Privacy Policy”; City of Boulder, City Manager Rule 11-1-3.A(21), Attachment A, § 6, and “Privacy Policy.” Return to text
49 Irvine Ranch Water District, “Residential Water Rates,” “Request A Water Variance,” and Rules and Regulations, §§ 12.7.1–12.7.2; City of Boulder, City Manager Rule 11-1-3.A(21), Attachment A, § 6. Return to text
50 New York State Public Service Commission, Order Adopting Terms of Joint Proposal and Establishing Rate Plan, Case 23-W-0235 (issued August 15, 2024); Liberty Utilities (New York Water) Corp., Threshold Analysis Study 2024, Case 23-W-0235; Irvine Ranch Water District, “Request A Water Variance”; Las Virgenes Municipal Water District, “Water Budget Adjustment Request”; City of Boulder, City Manager Rule 11-1-3.A(21), Attachment A, § 6. Return to text
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