![Aerial view of a water treatment facility](/sites/g/files/omnuum10826/files/styles/hwp_21_9__1920x825/public/datasmart/files/ivan-bandura-ac97oqawdvg-unsplash.jpg?itok=czLpX7Dw) # How to Use Data to Lower Bills and Increase Revenue Water Utility Assistance Programs April 01, 2025 [ Betsy Gardner ](/betsy-gardner) In January 2023, the Data-Smart team wrote about the work[ Philadelphia leadership was doing to improve the enrollment and participation in the city’s Tiered Assistance Program](/using-data-prevent-water-shutoffs-philadelphia) (TAP), which assists low-income residents with their water utility bills by[ setting them as a percentage of income](https://www.nrdc.org/sites/default/files/water-affordability-toolkit-section-8.pdf). This was done by data-matching, identifying residents who were enrolled in other income-based assistance programs yet were not in TAP and alerting them to their eligibility. This helped prevent water shutoffs as well, as the Philadelphia Water Department (PWD) wouldn’t shut off water if the data showed that the resident or household was qualified for TAP. At that time Julia Hinckley, then serving as director of policy and deputy chief of staff, stated that the city was interested in starting up auto-enrollment in the future; as she explained in late 2022, the data matching showed eligibility, but the city still had to reach out to those eligible individuals to enroll in TAP. This new article serves as an update on the auto-enrollment component, which moved TAP from opt-in to opt-out, and will also review how increasing the number of people receiving TAP actually increased PWD revenue. ## Move to Automatic Enrollment The Philadelphia Office of Integrated Data for Evidence and Action (IDEA) conducted the initial data-matching to help set up auto-enrollment. Established as a unit within the Managing Director's Office in 2022,[ IDEA maintains the city’s integrated data system](https://www.phila.gov/departments/office-of-integrated-data-for-evidence-and-action/). As the city’s Department of Revenue manages billing for the Water Department, IDEA has a memorandum of agreement (MOA) to cross reference the data. Once the IDEA team finds the intersection, i.e. when the data-matching reveals an eligible individual or household that isn’t in TAP, the city automatically enrolls them. According to PWD, they “[worked with IDEA to prequalify customers](https://www.phila.gov/media/20241030151234/Quarterly-Report-to-Rate-Board-2024-10-28.pdf) who had participated in programs with similar eligibility requirements as TAP,” without needing to provide additional documentation or residency verifications.1 Importantly, auto-enrollment doesn’t exclude anyone from applying for TAP otherwise, so there are still multiple venues to be connected to the water assistance. However, while the PWD took steps to simplify the application process in 2023, the automatic process is the easiest way to be enrolled. Rob Ballenger, a senior attorney at Community Legal Services, has a unique role in this work; he is the primary attorney tasked with performing CLS’s contract with the city to serve as a public advocate before the independent Water, Sewer, and Storm Water Rate Board. When PWD proposes rate and/or charge changes, the Board can “[approve, modify, or reject the proposed rates](https://www.phila.gov/departments/water-sewer-storm-water-rate-board/about/) and charges.” Ballenger had been involved in the very early development of TAP, in 2014 working with[ City Councilmember Maria Quiñones-Sánchez who championed income-adjusted water debt assistance](https://nextcity.org/urbanist-news/how-philadelphia-has-tried-to-address-water-debt) in Philadelphia. According to[ data from PWD’s Quarterly Report](https://www.phila.gov/media/20241030151234/Quarterly-Report-to-Rate-Board-2024-10-28.pdf), IDEA’s auto-enrollment work more than doubled TAP participation from February to September 2024, which Ballenger described as “phenomenal.” He did point out that this resulted in an increase in the water bill surcharge,2 which serves to cover the revenue gap from the assistance program; this is applied to all customers that aren’t receiving a discount from TAP. The Rate Board approves the surcharge annually, and in September 2024 PWD estimated that increased surcharge rates would "result in an[ overall bill increase of $3.19 per month](https://www.phila.gov/media/20240702112838/board-determination-2024-06-26.pdf).” ## The “Paradoxical” Revenue Increase This thread is related to another previous Data-Smart feature, on[ the right-sizing of fines and fees](/problem-one-size-fits-all-fines-and-fees). In[ Episode 21 of the Data-Smart City Pod](/rethinking-fines-and-fees-jean-pierre-dub%C3%A9-bryan-glenn-and-shayne-kavanagh), host Stephen Goldsmith interviewed Jean-Pierre Dubé, Bryan Glenn, and Shayne Kavanagh, co-authors of the [Segmented Pricing for Fines and Fees](https://www.gfoa.org/materials/segmented-pricing) report. During this episode they discussed the “paradoxical” premise that lowering fees or fines results in increased revenue, as data shows that those lower rates lead to greater payment fidelity. This holds true in the water utility space, according to the Natural Resources Defense Council’s (NRDC) Larry Levine. As a senior attorney focused on environmental health, Levine works on policies around urban water quality and infrastructure, and affordable access to safe water and sanitation, at all levels of government. In a case study published by NRDC, researchers reported that “by providing discounts to TAP participants,[ PWD also collects an increased percentage of the revenue that it bills to those low-income customers](https://www.nrdc.org/sites/default/files/2024-03/energy-water-utility-bill-discounts-case-studies-report-20240318.pdf).” The same report stated that “while low-income customers paid 34.3% of their bills before receiving a discount, they paid 72.5% of their bills after receiving their discount” in fiscal year 2022. [Webinar from NRDC](https://www.youtube.com/watch?v=Avl5cgJcu8w) For city, county, or utility leaders that are interested in the revenue generation that comes with these assistance programs, NRDC has a[ downloadable Water Affordability Business Case tool](https://www.nrdc.org/resources/water-affordability-business-case-downloadable-tool) that allows utility providers to “assess the business case for implementing a discount program for low-income customers,” by modelling the net financial impacts of different types of low-income discount programs. TAP falls under the percentage of income program (PIP) type, but users can also test percentage-of-bill discounts and fixed dollar discounts. The tool combines data input from the internal utility records and the U.S. Census Bureau. ## Making Multiple Cases for the Work While the financial case is strong, some utility providers balk at holding debt, especially when discounted bills are paired with the possibility of arrears forgiveness. Ballenger stressed that these programs are more successful than other tactics like residential liens, which Philadelphia was heavily relying upon in 2014, increasing liened residential debt by more than $30 million in a single year. The aging of these liened debts did not show any collection improvement, and the city developed TAP, which [includes debt forgiveness for participating customers](https://cap.phila.gov/tap/debt-forgiveness/), pursuant to legislation passed the next year. ![A pyramid-shaped diagram of water shutdown costs with city costs (weighing lost revenue with other costs, children in foster car](/sites/g/files/omnuum10826/files/styles/hwp_1_1__960x960_scale/public/datasmart/files/peach_lab_.png?itok=huSytWYc) [Graphic from PEACH Lab](https://peachlab.org/wp-content/uploads/2022/06/PennAltarumPhilllyWaterInsecurityReport_2022-05-04.pdf) He also emphasized the social benefits that come from programs like TAP: “Having fewer families living without services and experiencing disruption — those are all positives we don’t experience through the rate system, but we experience them in our city, broadly speaking.” Outlined in a[ 2022 water insecurity report from the University of Pennsylvania’s Psychology of Eating and Consumer Health](https://peachlab.org/wp-content/uploads/2022/06/PennAltarumPhilllyWaterInsecurityReport_2022-05-04.pdf) (PEACH) Lab, costs of water shut-offs at the community-level include vacant homes and homelessness, while costs at the individual or household level include missed work and/or school, housing loss, and mental and physical health problems. “These costs aren’t ones that are picked up in a traditional rate-making cost-of-service study,” Ballenger said, “but these are the kinds of things that, if you’re an advocate for water affordability, you view as avoidable social costs.” Similarly, Levine pointed to a recent report from the Environmental Protection Agency (EPA) that discusses the benefit of expanding the traditional cost-of-service framing. The [EPA advisory committee water affordability report](https://www.epa.gov/system/files/documents/2025-01/efab-water-affordability-report.pdf) stated that “several recent water industry efforts have focused on expanding the cost-of-service framework to better recognize water as a public good," which would further strengthen the case for "rate structures that improve affordability." Reframing cost-of-service to include the benefits that Ballenger discussed helps make the case that “[all customers benefit from water utilities’ support of public health](https://www.epa.gov/system/files/documents/2025-01/efab-water-affordability-report.pdf).” As the city of Philadelphia has shown, and continues to show, there are a multitude of reasons to preserve water access, work with residents on their bills and debts, and support water utility revenue. The commitment to this work and trust of data and evidence is an inspiration for other cities. *1 Residents eligible through the federal Low-Income Household Water Assistance Program (LIHWAP) were auto-enrolled by a collaboration with Philadelphia’s Department of Human Services, separately from the IDEA enrollments. For more information:*[ *https://www.phila.gov/media/20241119141233/Tiered-Assistance-Program-TAP-2023-annual-report1.pdf*](https://www.phila.gov/media/20241119141233/Tiered-Assistance-Program-TAP-2023-annual-report1.pdf) *2 The annual reconciliation adjustment to the Tiered Assistance Program Rate Rider (TAP-R) is a surcharge “applied to all customers who do not receive the discount and are intended to recover the revenue losses associated with the customer assistance program.” For more information:*[ *https://www.phila.gov/media/20240702112838/board-determination-2024-06-26.pdf*](https://www.phila.gov/media/20240702112838/board-determination-2024-06-26.pdf) ## About the Author ### Betsy Gardner ![Headshot of Betsy Gardner](/sites/g/files/omnuum10826/files/styles/hwp_1_1__100x100_scale/public/2025-05/Betsy%20Headshot%20resize.jpg?itok=k2OsSp1g) Betsy Gardner is the editor of Data-Smart City Solutions and the producer of the Data-Smart City Pod. Prior to this, Betsy worked in a variety of roles in higher education, focusing on deconstructing racial and gender inequality through research, writing, and facilitation. She also researched government spending and transparency at the Lincoln Institute of Land Policy. Betsy holds a master’s degree in Urban and Regional Policy from Northeastern University, a bachelor’s degree in Art History from Boston University, and a graduate certificate in Digital Storytelling from the Harvard Extension School. See also:- [ Equity ](/topics/equity) - [ Housing ](/topics/housing) - [ Public Health ](/topics/public-health) Share on:- [ Facebook ](#) - [ Twitter ](#) - [ Linkedin ](#)