Specific requirements for public participation, green infrastructure, environmental justice, and climate change were recommended in a letter that Sewage-Free Streets and Rivers (SFSR) partners sent to the New Jersey Department of Environmental Protection (NJDEP) on August 4, 2021. SFSR partners and members of the Jersey Water Works (JWW) Combined Sewer Overflow (CSO) Committee collaborated to review the technical comments that the NJDEP sent to the CSO permit holders on their Long Term Control Plans (LTCPs). Both groups submitted letters with recommendations to the NJDEP that were based on their technical response letters and focused on requirements for the next CSO permit. 

SFSR’s letter built off the NJDEP’s comments and included specific recommendations to ensure that:

  • Future public participation is inclusive, accountable, and transparent. 
  • Plans are implemented within 20 years and address flooding and the impacts of climate change.
  • Green infrastructure is implemented within the first five years of the plans, and gray infrastructure projects with the greatest impact are prioritized.
  • Environmental justice is part of the implementation and decision-making processes. 
  • Costs for rate-payers are reduced through cost sharing between regional utilities and municipal permit holders, utilizing the I-Bank, and evaluating stormwater utilities.

Read the SFSR letter and detailed recommendations here

Additionally, the groups asked the NJDEP to jointly host a series of public meetings—within the next six months—with the regional, utility, and municipal permit holders for each of the regional LTCPs. The purpose of the public meetings is for the permit holders and the NJDEP to respond to comments and questions from the public on the CSO LTCPs and to enable the public to provide input on public participation in the next CSO permit. The groups also asked the NJDEP Office of Environmental Justice and the Division of Water Quality to coordinate efforts related to the CSO permit and rulemaking for the New Jersey Environmental Justice Law

All of the NJDEP’s technical comments on the CSO LTCPs have been sent to the CSO permit holders and posted on the NJDEP website. The CSO permit holders have 60 days from the date that the letters were sent to respond to the NJDEP’s comment letters. 

After both technical issues and implementation schedules are adequately addressed, the NJDEP Division of Water Quality will make a decision on the LTCPs. SFSR partners are advocating for changes to the proposed LTCPs and requirements for the next CSO permit that are needed to ensure equitable wastewater infrastructure investments. 

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