What’s Next for the CSO Permits?

Multi-billion dollar plans to stop sewage overflows have been submitted to the New Jersey Department of Environmental Protection (NJDEP), and communities and stakeholders have reviewed the plans and have sent in comments to the NJDEP. Now what?

Step one: Review by NJDEP Division of Water Quality

Currently, the NJDEP Division of Water Quality is reviewing the combined sewer overflow Long Term Control Plans (LTCPs) and the public input that were submitted. The NJDEP Division of Water Quality is also thinking about what happens next and is coordinating an additional stakeholder meeting to solicit input on a future public participation process.

Step two: Finalize the CSO Long Term Control Plans

Once the NJDEP Division of Water Quality has finished its review, it will issue technical comment letters back to the municipal and utility combined sewer overflow permit holders. These letters will be posted on the NJDEP website. The technical comment letters will require that the permit holders update their LTCPs and submit them back to the NJDEP. After both technical issues and implementation schedules are adequately addressed, the NJDEP Division of Water Quality will make a decision on the LTCP.

Step three: Issue the New Jersey Pollutant Discharge Elimination System (NJPDES) CSO permits

The Division of Water Quality will prepare a draft five-year New Jersey Pollutant Discharge Elimination System (NJPDES) combined sewer overflow permit, based on the approved Long Term Control Plan. Releasing the draft permit will trigger a public comment period which will allow for public input. The Division of Water Quality will respond to all public comments as part of a final NJPDES permit action. After this public comment period, the NJDEP will finalize the permits and the first five years of implementing the Long Term Control Plans will begin.

Communities Make Recommendations for Multi-Billion Dollar Plans to Stop Sewage Overflows

Community groups submit recommendations to the New Jersey Department of Environmental Protection on the combined sewer overflow Long Term Control Plans.

TRENTON, 2021 – The Sewage-Free Streets and Rivers campaign, a coalition of community organizations from towns with combined sewer systems, is advocating for the Long Term Control Plans developed by municipal and utility permit holders to include equitable solutions to combined sewer overflows (CSOs). Twenty-four municipal and utility permit holders submitted combined sewer overflow Long Term Control Plans to the New Jersey Department of Environmental Protection (NJDEP) on October 1, 2020, kicking off a four-month comment period during which many community groups, environmental organizations, and other stakeholders weighed in on the plans, including the Sewage-Free Streets and Rivers campaign and its partners.

“These plans represent billions of public infrastructure dollars,” said Nicole Miller, principal, MnM Consulting and co-chair, NewarkDIG. “Our residents and business owners deserve the maximum benefit from each dollar spent. We hope NJDEP will take our concerns into consideration when preparing responses to the permit holders.”

“We are hopeful that the NJDEP’s commitment to environmental justice will be reflected in their review of these plans and that the final Long Term Control Plans will promote equity in affordability and in the implementation of solutions to sewage overflows,” said Mo Kinberg, New Jersey Future community outreach manager.

“The Clean Water Act is intended to ensure that our nation’s waters no matter where you live, color of your skin, or economic situation are free of sewage and toxins with the ultimate goal of zero pollution discharge over time,” stated Amy Goldsmith, NJ state director, Clean Water Action. “Approving, funding, and enforcing the best Long Term Control Plans possible is key to ensuring water justice for all.”

The plans detail large wastewater infrastructure projects that will impact communities for decades and will be paid for primarily by taxpayers. Comments by the coalition focus on water quality, environmental justice, green infrastructure, public participation and climate change. “We are elated to see these plans move forward after over five years of community input and discussion,” stated Drew Curtis, Ironbound Community Corporation. “We want to see these plans address many of the issues facing environmental justice communities like Newark, such as abating stormwater flooding and increased green infrastructure. And, we want to see the plans paid for in an equitable manner. Newark, as the host community for PVSC, already bears the brunt of the negative impacts from the plant; other, more affluent communities within the PVSC service area should pick up more of the financial costs of these plans.”

“There has been an enormous effort by the CSO permit holders and NJDEP over the last five years to get us to this critical point of addressing CSOs through the adoption of the Long Term Control Plans,” stated Rosana Da Silva, New York-New Jersey Harbor & Estuary Program and technical advisory board member to the campaign. “These plans specifically focus on the reduction of CSOs. Implementation will improve water quality in the Estuary. But this process is also an opportunity for stakeholders, including ratepayers and local government officials, to envision the future of their communities and how they can best benefit from cleaner waterways.”

The coalition is asking the NJDEP and permit holders for innovative solutions that put the health and wellbeing of the residents of these communities first. “It is time to address the impacts of CSOs with a sense of urgency,” stated Greg Remaud, NY/NJ Baykeeper. “Our urban communities have suffered the public health and environmental insult of raw sewage flowing freely into their streets and waterways after it rains for far too long. This will require the leadership and cooperation on the local, state and federal level that has yet to emerge.”

What more local advocates are saying:

“As a resident of the South Ward of Newark and an environmental justice organizer, it is extremely important that residents have meaningful participation in the Long Term Control Plans and their voices are heard in their communities’ plan,” stated Kim Gaddy, director, South Ward Environmental Alliance.

“We see what happens during a ‘normal’ rainfall event in Camden: raw sewage floods the streets and residential homes. Residents should be the first priority. We must develop an equitable public outreach and engagement plan to ensure ALL residents have a voice and are heard.“—Shaniqua Biles, Sewage-Free Streets and Rivers Advisory Board member and Camden resident.

“Bayonne’s Long Term Control Plan is inherently inequitable in its financing, lacking in public input and nearly devoid of green infrastructure. Bayonne inexplicably failed to consider more equitable means of funding for this project, resulting in an unconscionable economic plan that will exacerbate income inequality and reward polluters.”—Jill Pustorino, Morris Park Neighborhood Association

“I find it very disturbing to have to wait until 2040 to address some of the worst flooding in Paterson. The flooding that is coming into our homes and cars has raw sewage in it, which creates health issues.”—Martha Arencibia, Paterson Green Team Chair

“There is an urgent opportunity for Jersey City to reduce costs of its Long Term Control Plan by investing in green infrastructure,” stated Debra Italiano, founder, Sustainable Jersey City.  “Grey infrastructure costs could be brought down by prioritizing green infrastructure first. The City of Jersey City indicated it would consider participation in a Regional Plan if ‘adaptive remedies’ were available in the agreement, like a green infrastructure first strategy—municipal alignment around this focus is needed.”

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Sewage-Free Streets and Rivers is an action-oriented campaign that empowers community organizations to engage residents and small business owners to shape their communities’ solutions to reduce localized flooding and the raw sewage dumped into rivers and streams due to combined sewer overflows (CSOs). These solutions were submitted to the New Jersey Department of Environmental Protection (NJDEP) on October 1, 2020, and will be adopted in the next CSO permit.

For more information on the campaign and our partners visit SewageFreeNJ.org

Community Comments Focus on Climate, Costs, Equity, and Justice

Organizations, individuals, coalitions and collaboratives, worked tirelessly to submit comments on the combined sewer overflow (CSO) Long Term Control Plans (LTCPs) to the New Jersey Department of Environmental Protection (NJDEP) before the January 31 deadline. The people who live, work, and own businesses in these communities experience the impacts of these antiquated sewer systems and will pay for the upgrades. And they have a lot to say about these plans.

The Sewage-Free Streets and Rivers campaign submitted general comments, endorsed by 21 organizations from across New Jersey, focused on the following issues:

  • Improving water quality and access.
  • Making environmental justice part of all aspects of these plans.
  • Ensuring equitable financing of these plans.
  • Implementing a green infrastructure first approach.
  • Informing, engaging, and empowering communities.
  • Using the most recent climate change data in the selection, implementation, and evaluation of these plans.

Other collaboratives such as the Jersey Water Works CSO committee, and municipal action teams like Perth Amboy SWIM (Stormwater Infrastructure Management), JC START (Jersey City Stormwater Treatment and Resiliency Team), and NewakDIG (Doing Infrastructure Green) also submitted comments. Community-based organizations in Jersey City came together to submit joint comments, and many individual organizations like New Jersey Future, New Jersey Clean Water Action, NJ/NY Baykeeper, the Passaic River Coalition, Morris Park Neighborhood Association, South Ward Environmental Alliance, the Urban Systems Lab, and the Association of New Jersey Environmental Commissions submitted comments.

Read comments submitted by the following organizations:

The NJDEP is now considering the public comments that were submitted as they complete their review of the CSO Long Term Control Plans. The NJDEP may ask CSO permit holders to make changes to their plans before they are approved. Once the plans are approved, the NJDEP will issue another round of five-year CSO permits based on the final LTCPs. The need for public input does not end here. There will be an official public input period for the next round of CSO permits and the people who live, work, and own businesses in these communities must have a voice in the implementation of these plans.


CSO LTCP Comments Workshop Report Back

The Sewage-Free Streets and Rivers campaign’s third workshop on the CSO Long Term Control Plans focused on assisting community members develop comments on their towns’ LTCPs. The workshop started off with a few tips for writing comments:

  • Share your personal experiences and stories.
  • You are not expected to be a technical expert.
  • Your experience as a community member is valuable and needed input.
  • Share how these plans could impact your community/neighborhood/city
  • Ask questions.
  • You do not need to comment on every aspect of the report.

Six speakers addressed water quality, environmental justice, green infrastructure, financing, climate change, and public participation. Here are key takeaways from the presentations:

The Program Director of the NY – NJ Harbor Estuary Program, Rob Pirani presented water quality goals of the CSO permit and led a discussion on the water quality issues to consider in the LTCPs. Pirani pointed out that, while the CSO permits may not solve the overall water quality issues, decisions related to the CSO permits will affect how people access outdoor recreational spaces and the use of water bodies.

Environmental justice considerations were presented by New Jersey Environmental Justice Alliance Executive Director Melissa Miles. She emphasized that an environmental justice lens should be used to evaluate all of the aspects of the plans, from the siting of green infrastructure to rate structures. Cumulative impacts should be considered as we implement solutions to CSOs. Miles suggested that we need to develop educated and cooperative municipalities on environmental justice issues.

One of the solutions to CSOs that has multiple benefits for communities is green infrastructure (GI). Rutgers Water Resource Program Director Chris Obropta shared the many types of GI that could be implemented through these plans. He stressed that GI needs to be implemented immediately rather than pushed to later phases of the plans. Hesitation to implement GI typically comes from uncertainty about the cost. Obropta explained that “cost is variable” but is generally cheaper than gray infrastructure and requires minimal maintenance. He emphasized the need to get the community involved and think creatively about where GI can be used. Shaping the CSO permits to optimize the use of GI will have health benefits, transform communities, and improve the quality of life.

Financing looked at through an environmental justice lens reveals that right now the plans may be compliant but are not equitable, and overlooking this will perpetuate inequities. Director of Urban Water Infrastructure and senior attorney in NRDC’s Healthy People and Thriving Communities Program, Larry Levine, explained how using financing alternatives can actually be used as a tool to help solve inequalities. He walked through various financing options and considerations, including partnerships, various rate structures, stormwater utility fees, rules and regulations, as well as loans and grants. He said that if you rely on rate increases to fund the plans but don’t look to solve the affordability issues, you’re going to perpetuate inequalities and use a longer compliance schedule as an excuse to fall back on.

Principal and founder of Meliora Designs, Michele Adams, explained the relation of climate change to rainfall considerations in the CSO plans. Resilience is the ability to recover or adapt easily to stress and disturbance. Climate change induced stressors include more frequent hurricanes, increased flooding, higher temperatures, and these stressors will most directly impact infrastructure. The CSO plans should consider infrastructure solutions and locations in relation to sea level rise, increased rainfall volume, and effects of rising temperatures on humans. Green infrastructure is key for restoring natural processes to manage water and mitigate urban heat islands. Communities benefit from investments in multiple projects that address multiple issues.

Meishka Mitchell, vice president at Cooper’s Ferry Partnership spoke about the importance of public participation in the CSO planning process. Current guidelines include having a two-way dialogue with the public and the creation and engagement of a supplemental CSO team. However, beyond these minimum requirements there is a spectrum of levels of public participation. Participation levels ranging from lowest to highest include: inform, consult, innovate, collaborate, and empower. The goal is to engage cities at the collaborate and empower levels and push them to be forward-thinking. Higher level participation can include surveys and activities to understand public preferences, as well as participatory and active decision-making power. Currently, most LTCPs are far from the highest public participation levels.

The overall message from speakers to participants was of the importance of reviewing the CSO plans with an awareness of inequity, and opportunities to address multiple issues. It is easy to fulfill the minimum requirements and be in compliance without advancing equity. Attendees were encouraged to look through an environmental justice lens, at the makeup of the town, and its vulnerabilities, through every section of the plans. Plan comments should evaluate how these plans can take into account vulnerable populations, whether they perpetuate inequality, and where they could include creative solutions to multiple issues. Consider how you would like to spend your money and how to take advantage of opportunities to ensure best results. The LTCPs will impact the quality of life within communities over the next 30 years. These plans are a serious milestone and how they are shaped will impact future generations.

Sewage-Free Streets and Rivers Comments on the CSO Long Term Control Plans

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.


Fact Sheets on the CSO Plans

Communities in New Jersey with combined sewer systems have submitted their plans to reduce combined sewer overflows into local waterways. The implementation of these plans could cost between $2.5 billion and $3.8 billion, and the proposed timeframes for implementation span 20 to 40 years. Facts like these can be found in the Long Term Control Plans but you need to know where to find them.

The plans include all of the reports that were submitted to the New Jersey Department of Environmental Protection (NJDEP) over the last five years as well as the most recent Selection and Implementation of Alternatives Report. To assist community members and those who are interested in the contents of these plans, the Sewage-Free Streets and Rivers campaign has developed a series of fact sheets that highlight the most pertinent information for communities to know, such as the cost of the projects and implementation.

Download the fact sheets for Bayonne, Camden County Municipal Utilities Authority, Harrison, Kearny, Jersey City Municipal Utilities Authority, Newark, North Hudson Sewerage Authority, Paterson, and Perth Amboy.

The fact sheets provide summaries of the projects that have been selected, the implementation schedules, costs, how public participation was conducted, how climate change and environmental justice were considered. They also include information on how to submit comments on the plans and who to contact for more information. While these sheets will be helpful for at-a-glance summaries, the full reports may be helpful for a fuller understanding of how the projects were selected.

Comments on these plans can be submitted to the New Jersey Department of Environmental Protection until January 31. The full combined sewer overflow Long Term Control Plans can be downloaded from the NJDEP website.

Get the Facts On the Plans To Sewage Overflows

Get the facts on the combined sewer overflow (CSO) Long Term Control Plans (LTCPs). The plans include the selected water infrastructure projects, costs and project timeline. Each of the selected options will cost millions of dollars and impact neighborhoods for decades. Please use this sample fact sheet to assist with developing comments to submit to the New Jersey Department of Environmental Protection (NJDEP). The deadline for submitting comments to the NJDEP is January 31.

Sewage-Free Streets and Rivers partners along with members of the Jersey Water Works CSO Committee have been busy reviewing the LTCPs. The information gathered from these reviews is being used to develop two-page fact sheets on municipal and regional plans from the hundred-plus page reports. The goal of the fact sheets is to make the information in these reports more accessible to the public and to assist community members in submitting comments.

The front of the fact sheet displays the volume of sewage overflows that will be reduced, the cost of each project, and the project timeline graphically.

The back of the fact sheet has sections on some of the issues that the Sewage-Free Streets and Rivers campaign has focused on: green infrastructure, public participation, financing, environmental justice, and climate change considerations. Information on how to submit comments, links to where you can download the full report and contact information for the permit holder are on page 2 of the fact sheet.

The first fact sheet posted was for the North Hudson Sewerage Authority LTCPs: Adams Street and River Road. In the upcoming weeks we will post fact sheets for the regional and municipal plans. The fact sheets will be posted on the Sewage-Free Streets and Rivers website’s resource page.

Community Driven Solutions to Sewage Overflow Plans Workshop

Thursday, January 7, 1:00 pm – 3:00 pm, and Friday, January 8, 10:00 am – noon. Register here.

Do you need help reviewing your town’s combined sewer overflow (CSO) Long Term Control Plan (LTCP)?

The New Jersey Department of Environmental Protection is accepting comments on the plans until January 31. Community voices are needed to ensure that the proposed projects, timelines, and costs, are the best solutions for your municipality.

This two-day workshop will explain the overarching issues addressed in each of the plans, like financing and green infrastructure, followed by breakout groups to discuss the specific proposals for each of the municipal and regional plans. Participants will leave with draft comments and guidance to finalize them. This workshop will create a basis of understanding of the CSO LTCPs and the new CSO permit process.

The Sewage-Free Streets and Rivers campaign is offering a $250 stipend for organizations to send up to two members to participate in this virtual workshop. Stipends will be awarded on a first-come, first-served basis. If your organization receives a stipend, the designated representative(s) is committing to participate in both sessions of the workshop and to review their town’s plan in advance. Organizations are welcome to send additional participants, and individuals are welcome to register, but stipends are not guaranteed.

Please fill out this registration form to participate in the workshop and indicate if your organization is interested in applying for a stipend by November 25.

The Sewage-Free Streets and Rivers campaign is also looking for guides to assist workshop attendees with reviewing the combined sewer overflow Long Term Control Plans (LTCPs) for the following utilities and municipalities: Perth Amboy/MCUA; Jersey City; PVSC, Paterson, Bayonne, Newark, East Newark, Harrison, Kearny, North Bergen/NBMUA/Guttenberg; Camden, Gloucester, CCMUA; Hoboken/NHSA; Elizabeth/JMEUC; BCUA/Hackensack, Fort Lee, Ridgefield Park.


  • Intimately familiar with the CSO permit process and the issue of CSOs.
  • Able to answer basic questions about the LTCP process.
  • Comfortable speaking in front of a group and working with community members

Guide agreement:

  • Complete the LTCP review before the workshops.
  • Attend a preparation meeting.
  • Prepare topical points from the LTCP to discuss with the group during the two-day workshop to be held on January 7 and 8.

Guides will also be compensated with a $500 stipend. Please indicate if you are interested in applying to be a guide in the registration form.

For more information on participating in the workshop or being a guide please contact Mo Kinberg at mkinberg@njfuture.org


What We’re Looking for in the CSO Long Term Control Plans

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.

Your Voice Is Needed In Water Infrastructure Decisions

Now that the October 1 submittal deadline for the combined sewer overflow plans has come and gone, what should you do?

The deadline not only kicked off the Department of Environmental Protection (NJDEP) review of the plans, but also a public review of the plans and provides an opportunity for community members to submit comments. All of the plans that were submitted to NJDEP will be  posted online here.

The plans will tell you the projects that have been selected to stop sewage overflows, locations, timeline, and the costs. The plans will answer some of the questions we have been asking and will also likely generate more questions, such as: Will flooding be addressed? How will your community be impacted? What are the community benefits? What will it cost and the financing plans?

Your voice is needed to ensure that the solutions are affordable; keep residents healthy; invest in local jobs, businesses and neighborhoods; and create more green spaces that promote climate resiliency.

Comments on the Long Term Control Plans (LTCPs) can be submitted to the appropriate NJDEP contacts. For all comments, we suggest copying Susan Rosenwinkel (Susan.Rosenwinkel@dep.nj.gov), bureau chief of surface water permitting at NJDEP, as well as the relevant permittee contact. Use the guide we developed to assist you with your reviews in  the blog post, “How to Review the Draft CSO Long Term Control Plans and Submit Comments.

After submitting comments to NJDEP and your CSO permit holder, make sure to share your comments with your local officials, environmental commission, and planning/zoning boards.