All of the combined sewer overflow Long Term Control Plans were submitted to the New Jersey Department of Environmental Protection (NJDEP) on October 1. These plans are now publicly available for download on the NJDEP CSO website. Public comments will be accepted by the NJDEP on these plans through January 31.
Here is what we are looking for in the CSO plans:
- The financing considerations section includes details on how the plans will be financed. This section includes projected rate increases. We will also be looking for innovative revenue streams that have been identified to offset rate increases as well as restructuring of rates to ensure that rate increases will not disproportionately impact low-income residents.
- The implementation schedule outlines the projects that have been selected and the ratio of green and gray infrastructure that will be used to reduce sewage overflows. We will also be looking at plans to see if green infrastructure (GI) is being used as a first response to flooding.
- The executive summary describes how the CSO reduction goals will be met. We will also be looking to see if the plans go further than the CSO requirements to address flooding, community benefits, and the public health impacts of sewage overflows.
- The public participation section explains how public input was used in the selection of these projects, how the public was engaged, and who from the CSO communities was involved.
- How sea level rise and precipitation have been considered in the selection, siting, and design of projects. We will be looking to see if there is any reference to New Jersey’s Protection Against Climate Threats initiative and the data that is coming out of the state’s reports on climate change.
- How environmental justice communities, which we define as communities of color, low-income populations, or geographic locations that potentially experience disproportionate environmental harms and risks, are prioritized in the plans for addressing flooding and sewage overflows.
- If the water workforce was considered in these plans. We already know that two CSO communities, Newark and Camden, have workforce development programs in place to ensure that their residents are prepared for the work that will be generated through these plans. All of the CSO communities would benefit from workforce development training and a first-hire approach to ensure that the money invested in infrastructure goes back into their community. We will be looking to see if there is any reference to job training and hiring locally in these plans.
The Sewage-Free Streets and Rivers campaign will be working with community groups to review these plans. We want to know what you will be looking for in these plans. And how we can assist you with reviewing them. Please contact info@sewagefreenj.org for more information or assistance in reviewing the CSO plans.
