Research Findings

The preceding chapters examined conservation policy, residential rate design, New York's regulatory history, household occupancy, comparable utility implementation, administrative feasibility, and competing rate-equity considerations. Based on the evidence reviewed, the following findings are supported.

Finding 1

Water conservation is an established public-policy objective.

New York regulatory proceedings, conservation programs, government guidance, and utility practice consistently recognize efficient water use as an important means of protecting water resources, supporting reliable service, and limiting unnecessary demand. Conservation remains a foundation of residential water-rate design.⁴⁴

Finding 2

Conservation-oriented pricing is an established rate-design tool, but total meter volume does not by itself identify why usage is higher.

Inclining block rates use progressively higher prices to strengthen conservation incentives as consumption rises. Higher total use, however, can reflect outdoor demand, leaks, inefficient fixtures, household occupancy, unusual circumstances, or a combination of factors. The conservation purpose of a higher block therefore does not establish that every unit entering that block is discretionary.⁴⁵

Finding 3

Rate equity and conservation are related, not mutually exclusive, regulatory considerations.

A rate structure must support conservation while also recovering authorized revenues and operating reasonably across customer circumstances. Equal numerical thresholds can produce different effects when the number of residents behind a meter differs materially. This makes the treatment of basic indoor water needs a legitimate rate-design question rather than an argument against conservation.

Finding 4

Household occupancy is a documented factor affecting indoor residential water demand.

New York utility-specific research, Liberty's Threshold Analysis, and broader residential end-use research all identify the number of residents as an important factor in indoor demand. Occupancy is not the only determinant of use, but it is analytically distinct from leaks, discretionary use, and inefficient fixtures. The current record does not quantify how much of Veolia customers' higher-tier use is attributable to occupancy, how many customers experience a material occupancy-related effect, or the resulting dollar impact.⁴⁶

Finding 5

The Rockland residential blocks were developed with household-size variability expressly recognized, while the original record also identified a larger-household limitation.

The 2016 SUEZ record tied the 5-CCF first block to the basic needs of an average household and a roughly three-person Rockland reference. Black & Veatch explained that the second tier recognized variability in household size and was intended to accommodate most single-family households most of the time, while third-tier usage should generally reflect discretionary use. Rockland County's consultants warned that larger households could exceed the first block even in winter, and SUEZ's rate witness acknowledged that an inclining-block structure can place a large household's basic-needs usage into the second and third blocks.⁴⁷

Finding 6

The current Veolia New York Rate District retains the historic 5/12-CCF separately metered residential thresholds while treating master-metered multi-family service under materially different blocks.

The 2019-2020 proceeding continued the SFR structure, and the current tariff retains first 5 CCF, next 7 CCF, and over 12 CCF for the applicable separately metered residential class. Master-metered multi-family service uses first 20 CCF, next 380 CCF, and over 400 CCF, reflecting a different service-class and usage context.⁴⁸

Finding 7

The direction and amount of any revenue shift or cross-subsidy cannot be assumed from bill levels alone.

Historical SUEZ testimony shows that moving customer-related costs between fixed and volumetric charges can change which customers bear those costs, and the witness specifically connected higher volumetric recovery to larger households' basic needs. That history does not establish the direction or amount of any current Veolia cross-subsidy. It does show why the present allocation should not simply be assumed neutral. Current Veolia cost-of-service, billing, usage, and revenue evidence would be required before concluding that either smaller or larger households presently subsidize the other.⁴⁹

Finding 8

New York has examined household-size effects, but the Veolia separately metered residential occupancy-equity question remains unresolved.

The PSC-required 2019 study was a genuine service-classification review, but it focused primarily on multi-family building type and size rather than household occupancy within the separately metered residential class. Liberty's later analysis identified a possible larger-household effect, while subsequent testimony described the issue as not requiring further study at that time and lacking sufficient data for redesign. The record therefore supports further resolution, not a claim that the occupancy question has already been answered.⁵⁰

Finding 9

Comparable utilities demonstrate that occupancy adjustments can coexist with conservation-oriented pricing and ordinary utility administration.

IRWD, LVMWD, and Boulder use water-budget or baseline adjustments that account for resident count while preserving higher conservation prices beyond the adjusted amount. Their procedures also demonstrate practical approaches to application review, verification, renewal, and privacy. These examples establish feasibility, not the required New York formula or cost.⁵¹

Finding 10

Conservation, rate equity, revenue recovery, customer impacts, verification, privacy, and administrative practicality can be addressed within one rate-design process.

The evidence identifies no inherent requirement to choose one of these objectives at the expense of all others. A final New York design would need to balance them, but documented utility practice and New York's own regulatory history show that they are capable of being considered together.⁵²

Finding 11

The evidence supports Commission consideration directed toward a practical optional occupancy adjustment rather than further abstract study alone.

The record does not establish one correct gallons-per-person formula or eligibility threshold. It does, however, provide a sufficient factual and administrative basis for the Commission to determine whether a workable occupancy-adjusted starting allowance should be implemented for Veolia's applicable separately metered residential class and, if supported by the record, to develop that adjustment while preserving conservation.

These findings are evidence-based conclusions rather than a tariff formula. The final chapter states the regulatory action that follows from them while leaving the precise design to the Commission's record.