As we entered the new year, New Jersey passed a quiet yet long-awaited milestone in its journey toward cleaner and healthier waterways for all New Jerseyans. All combined sewer overflow Long-Term Control Plans (LTCPs) and the associated five-year permits have now been released and commented on. Six out of the seven regional plans have been finalized.
This process has been a multi-phase and multi-year effort. From 2019 to 2021, this was the phase during which permittees submitted their LTCPs, and from December 2022 to 2025, draft permits were released for public comment and finalized. These permits and the structured CSO implementation process are crucial for impacted community members to influence policy and infrastructure decisions that affect flooding in their overburdened neighborhoods and pollution in their water bodies.
The Sewage-Free Streets and Rivers (SFSR) Campaign and its partners played a crucial role in this regulatory review process. Over these past three years, SFSR partners have reviewed and submitted recommendations on the seven regional draft permits released by the New Jersey Department of Environmental Protection (NJDEP). The comments focused on the following issues:
- Timing, Financing, and Affordability
- Public Health: Notifications
- Strong Public Engagement
- Adapting to Climate Change and Updating Models
- Construction, Operations, and Maintenance: Transparency and Enforcement
- Maximizing High-Impact Green Infrastructure
Thank you to the following individuals who have participated in the permit review team over the last three years: Michele Langa, Vin Rubino, Nicole Miller, Dan Van Abs, Andy Kricun, Jose Amarante, Amy Goldsmith, Rosana Pedra Nobre, and Chris Obropta.
Our Recommendations
Overall, the review team found that NJDEP and the permit holders incorporated stringent requirements in certain areas, including public participation, resilient design standards, and infrastructure maintenance. Some of these requirements directly resulted from prior advocacy during the LTCP process and earlier regional permit releases. However, the team identified areas that needed strengthening across the permits, including affordability, shortening timelines, diversifying funding sources, reevaluating project sequencing, and ensuring meaningful community participation.
Final CSO permits have been issued for six regions, based on the draft permits and written and oral comments submitted. The seventh and final region, comprising the Middlesex County Utilities Authority and the City of Perth Amboy, had its draft permits released in November 2025, followed by a comment period that closed on January 5, 2026. Although the final plans have yet to be finalized, we recognize the plan submissions and the extensive review process as a significant milestone and a step forward toward cleaner, healthier waterways for all New Jerseyans.
While the permit review process may have ended, the work does not end here.
What Comes Next?
With the staggered release of the regional CSO permits completed, New Jersey has shifted to an implementation phase. Here are the main things we will be monitoring:
- Transparency and accountability. Ensuring the transparency of implementation schedules and projects, as well as accountability for permittees meeting their requirements, will take precedence for SFSR and its partners. Accountability around finalized permits will require monitoring by impacted community members and grassroots organizations.
- Public engagement and participation. Even after permits are finalized, advocacy will be necessary to engage with municipalities directly and, in partnership with community organizations, to ensure the public is involved and participating on the NJDEP-required CSO Supplemental Teams. The CSO Supplemental Teams serve as a mechanism for community members to provide input and hold permit holders accountable for timelines and results.
- Equitable funding and affordability. Ongoing advocacy to ensure these permit holders explore equitable funding structures and affordable financing opportunities for low-income ratepayers.
As SFSR continues to raise awareness and educate more people about CSOs and accountability in implementation, we also look forward to 2029, when the CSO permits will be up for renewal.
The Big Takeaway: We Cannot Do This Alone
Throughout this process, the SFSR campaign has met and expanded connections with community groups on the ground in the CSO communities of Camden, Jersey City, Newark, Perth Amboy, and Paterson. SFSR successfully provided them with resources on how to best engage during the public hearings and comment period, working toward building collective knowledge.
SFSR recognizes that local groups are continuously educating their communities on CSOs and flood mitigation efforts. As a statewide campaign working within the 21 CSO communities, we enter these spaces, often as outsiders, with respect for the boundaries we traverse and authenticity in our relationship-building efforts. Our hyper-local partners on the ground act as the bridge between the communities they serve and us. SFSR is committed to transparency and to co-creating programs with and for community members that are responsive to their communities’ specific needs.
Stay Updated on SFSR and Join Your Local CSO Supplemental Team!
Join the SFSR Campaign! With increased precipitation impacting CSO communities, now is the time to join the Sewage-Free Streets and Rivers campaign to keep sewage and dirty wastewater out of our waterways, streets, and basements. Sign up to receive the latest combined sewer overflow developments!
CSO Supplemental Team Information: The permittees listed below have finalized their permits and established their CSO Supplemental Teams. SFSR and its local partners are monitoring the progress of permit implementation and attending the CSO Supplemental teams for North Hudson Sewerage Authority (NHSA) and Camden County Municipal Utilities Authority (CCMUA).
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- NHSA Long Term Control Plan Community Advisory Board webpage: https://www.nhudsonsa.com/csoltcp
- CCMUA Long Term Control Plan and Supplemental Team webpage: https://www.ccmua.org/combined-sewer-overflow/
- More websites will be added as the CSO Supplemental Teams form.
Related Articles and Resources
- SFSR Comment Letters
- April 8, 2025 Public Workshop Recording
- CSO Fact Sheets
- JWW 10-Year Reflection on CSOs
