The Sewage-Free Streets and Rivers campaign reviewed the combined sewer overflow (CSO) Long Term Control Plans with a focus on water quality, environmental justice, green infrastructure, financing, climate change, and public participation. We also developed a series of fact sheets on 10 of the CSO Long Term Control Plans (LTCPs) to summarize the content of the reports based on these categories and to facilitate community groups’ review and development of comments on the plans.

Overall, we found that the LTCPs are designed to meet existing water quality standards but do not consider future water quality standards. The reports do not address the level of water quality the local community wants to attain, nor do they address improving access to our waterfronts.

Environmental justice consideration varies from plan to plan. For example, environmental justice considerations informed the approach that was taken by the Camden County Municipal Utilities Authority and led it to focus on the near-term community benefits.  However, the majority of the plans do not mention environmental justice issues nor do they anticipate future environmental issues as a result of the selected controls.

Similarly, the approach to green infrastructure ranged from pilot projects to implementing green infrastructure projects on 10% of hardened surfaces. We paid close attention to the implementation schedules to ensure that communities would benefit from green infrastructure in the near future and found that some of the plans either delayed implementation or spread out implementation throughout the entire schedule, which in some cases was 40 years. All of the CSO permit holders used an updated design storm year of 2004 to account for increased precipitation. Some of the reports go further to include sea-level rise data, and some indicate that climate change is an external change that could require changes to the plans.

The financing of the plans focus on the ability of the municipality and taxpayers to pay for them. Most permit holders found that the rate increases over 20 years would exceed the 2% of median household income that the Environmental Protection Agency deems as burdensome.  Permit holders propose extending the implementation plan for as long as 40 years to spread out the costs. This assessment is flawed because it does not consider innovative financing such as stormwater utilities, which  would generate revenue for the projects and distribute the costs more equitably.

The Sewage-Free Streets and Rivers campaign has focused on public participation throughout the five years of the CSO permit, advocating for a public conversation and for the plans to reflect the communities’ values. We found that while all of the permit holders could be in compliance with the public participation requirements of the CSO permit, most did not demonstrate the two-way dialog that is recommended in the NJDEP public participation guidance documents. Although public participation was not robust in all of the municipalities, a foundation for community involvement in the development of these plans was established and should be built upon as we move forward with the next CSO permit.

We have an opportunity to learn from the last CSO permit, and we now have a commitment from the Governor to address climate change and environmental justice issues. In comments submitted to the New Jersey Department of Environmental Protection, we recommend including requirements for the permit holders to use the latest data on climate change and to specifically engage environmental justice communities in the implementation of these plans. The plans should prioritize these overburdened districts for projects that will reduce flooding and the impacts of CSOs. We also recommend including stronger requirements for public participation in the next CSO permit. Read the full Sewage-Free Streets and Rivers comments on the CSO Long Term Control Plans here.


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