Author: Mo Kinberg

The draft combined sewer overflow (CSO) Long Term Control Plans (LTCPs) are due on October 1. The second CSO LTCP review workshop, hosted by NewarkDIG, Sewage Free Streets and Rivers, and Jersey Water Works, armed attendees with the tools needed to navigate the LTCPs and prepare comments to submit to the New Jersey Department of Environmental Protection.  According to New Jersey Future, 17% of the state’s population live in a CSO community, and population growth in CSO cities has only grown in the last decade.

During the first half of the workshop, speakers discussed how to provide the greatest amount of benefits for CSO communities, primarily through the implementation of green infrastructure (GI) and similar strategies. Scott Schreiber,  executive director of Camden County Municipal Utilities Authority (CCMUA), explained the goals of CCMUA’s LTCP, including a 10% reduction in directly connected impervious areas, which means removing 145 acres city-wide (30 acres per 5-year permit cycle). Partnerships with non-profit organizations and community groups through Camden SMART (Stormwater Management and Resource Training) and the Camden Collaborative Initiative helped shape the CCMUA’s plan and steered the authority to address stormwater management as well as other environmental problems such as street flooding and the heat island effect. Schreiber said that implementing green infrastructure will provide immediate opportunities compared to gray infrastructure, lead to local employment opportunities, engage community members and businesses/organizations, and ease coordination with ongoing infrastructure projects. In the future, the CCMUA is looking to scale up its GI projects, continue working with the community, and create a holistic maintenance plan.

Rosana DaSilva, water quality manager for the New York–New Jersey Harbor & Estuary Program, expanded on the benefits of including GI projects in LTCPs. A flyer created by Earth Economics with input from the Sewage-Free Streets and Rivers Campaign highlights how GI can be a part of the solution. GI is a cost-effective solution for CSOs from an operations and maintenance perspective, and tends to store more gallons of water per dollar invested. Additionally, GI supports emissions reductions and utility energy bill savings, supports adaptation/resilience, and spurs local economic development.

Andy Kricun, Jersey Water Works CSO Committee co-chair, discussed six strategies and tips for community benefit considerations for LTCP submissions:

1. Authorities should make sure that ongoing operations and maintenance of CSO systems are done equitably. These CSO systems, no matter how well they are designed, are only effective if they are kept clean and available for full capacity usage.
2. Underserved communities should not be excluded from the planning process; equity is critical.
3. Underserved communities should not be taken care of last; these plans take a considerable amount of time, and certain neighborhoods should be prioritized.
4. LTCPs should not only  implement projects that project underserved or environmental justice communities from combined sewage flooding, they should also look for opportunities to not only be protective but beneficial as well.
5. CSO communities should utilize funding from the NJ Infrastructure Bank to the maximum extent possible to realize the lowest possible annual debt service for implementation of the LTCPs.
6. CSO communities should also implement stormwater fees for owners of larger impervious surfaces. If a stormwater fee is not charged, residential ratepayers will be forced to cover the cost of pumping and treating the sewage generated.

In the second half of the workshop, speakers talked about reviewing LTCPs before the October 1 deadline. Kimberley Irby, policy analyst at New Jersey Future, presented a  LTCP review worksheet that serves as a guide for community members to review the plans and provides questions and a framework for reviewing them. Comments and concerns on the LTCP can be submitted to Susan Rosenwinkle from the NJDEP Division of Water Quality (Susan.Rosenwinkle@dep.nj.gov) and the appropriate CSO permit holder.

Community members should encourage their CSO permit holders to share the draft CSO LTCPs with the public for comment and hold a public meeting before they submit their plans to the NJDEP. The period for public comment will extend beyond October 1; there will be another opportunity to comment on the plans once they are submitted and posted on the NJDEP website in mid-October. Make sure your community is informed and has a voice in these plans. Furthermore, look out for future Sewage-Free Streets and Rivers campaign workshops and resources that will assist CSO communities with reviewing these plans and submitting comments.

The draft combined sewer overflow (CSO) Long Term Control Plans (LTCPs) that detail proposed solutions to reduce flooding and waterway pollution will be posted on the New Jersey Department of Environmental Protection (NJDEP) website after October 1. To date, there are two plans that have already been posted—one each for North Hudson Sewerage Authority’s River Road treatment plant and Adams Street treatment plant.

Community members should review plans that impact their communities to ensure that the proposed solutions maximize benefits and submit comments to the NJDEP as soon as possible. NJDEP will review comments through January 31, 2021. This example review provides an idea of what to look for when reading the LTCPs.

What to Look For

The documents that will be released may contain 1,000+ pages, but only the first 40 or so pages will contain relevant information for the review. The first section is called the “Selection and Implementation of Alternatives” and, in the case of the North Hudson Sewerage Authority plans linked above, it is contained in the first 35-40 pages. This section will contain most of the relevant information as it is the most recent addition since the Development and Evaluation of Alternatives Reports (DEARs) were published in July 2019. The remaining pages of the report are appendices that will likely include the system characterization, the DEAR, and details on the public participation process and financial capabilities assessment.

Assuming the LTCPs follow the same format as the North Hudson Sewerage Authority plans, you can expect to see the following sections that will be useful to review:

• Executive Summary: This will include the selected approach (presumptive vs. demonstrative) and a table of the implementation schedule for the projects selected.
• Methodology: This may also include the selected approach and details on existing percent capture in a typical year.
• Selected Alternatives: This will include technical details about the projects selected and details on expected percent capture after LTCP implementation.
• Public Participation: This will include details on the type of public outreach and number of meetings held, as well as public input that was considered for the project selection.
• Implementation Schedule: This will include the table of the projects selected, with expected construction cost and start dates; it may also include the financial capability assessment.

Using the Review Tool

When reviewing the plans, you can use this Google Form that was created to help guide you through the process and direct you to certain elements of the plan. Alternatively, you can download a word document of the questions. Following the first page of preliminary information, there are eight sections that contain 3-12 questions each:

1. Executive Summary
2. Presumptive vs. Demonstrative Approach
3. Projects Selected
4. Balance of Green and Gray Infrastructure
5. Financing Considerations
6. Public Participation
7. Additional Questions to Consider
8. Other Notes/Comments

Questions include multiple choice, checkboxes, and open-ended.

Tip: When reviewing the plan, it is best to have the Table of Contents section readily available. For example, if viewing the PDF in Preview on a Mac, select View > Table of Contents to have a pane show up with a clickable table of contents. If viewing the PDF in Google Chrome, the top-right “Bookmarks” icon will reveal a clickable table of contents. This will allow you to easily find and maneuver to particular sections without having to scroll.

The form collects email addresses for two reasons: 1) this will allow you to save your progress and return to the form at a later time; and 2) when you submit the form, you will receive an email containing your responses, which you can save as a PDF if needed. Please note that your email address will not be collected for any purpose other than these two reasons. At the end of each section, except for the first and last, you will see this question: “Do you want to save your results and quit for now?” If you choose “Yes,” you will be asked to submit the form. After you submit, you will receive an email with a link to edit your response. Alternatively, you will see a link to “Edit my response” right after you submit, and you can save or bookmark that link if needed. If you choose “No,” you will be able to move on to the next section.

Most sections of the Google form will feature a final, open-ended question that allows you to record your comments, concerns, and questions. Ideally, your answers to these questions will comprise the comments that you ultimately submit to NJDEP. The very last section of the Google form, “Other Notes/Comments,” features a single open-ended question for you to add any additional thoughts you wish to include, beyond the topics that were covered in the form.

Submitting Your Comments

Once you have formulated your comments, please submit them in a single email to these three contacts:

1. The appropriate NJDEP contact, which you can find in the table below or on NJDEP’s website
2. Cc: Susan Rosenwinkel (Susan.Rosenwinkel@dep.nj.gov), bureau chief of surface water permitting at NJDEP

Cc: The appropriate permittee contact, which you can find in the permittee directory

Communities with combined sewer overflows (CSOs) need solutions that will prevent flooding and reduce waterway pollution. One such solution is to bolster traditional gray infrastructure with green infrastructure. Green infrastructure (GI) refers to methods of stormwater management that reduce stormwater volume by allowing it to be uptaken by vegetation, filtered by soils, or stored for reuse. Implementing GI programs (which includes trees, rain gardens, porous pavements, and green roofs) keeps polluted runoff out of municipal systems and out of waterways, rivers, and oceans.

GI not only helps to manage stormwater, but also maximizes communities benefits. To explore these benefits and the practical side of implementing GI, including planning and funding, New Jersey Future hosted a virtual event, “From the Ground Up: Designing a GI Program.” Chris Sturm, managing director of policy and water at New Jersey Future moderated a discussion with Jessica Brooks, director of green stormwater infrastructure implementation at the Philadelphia Water Department (PWD), and April Mendez, the CEO of Greenprint Partners, a GI delivery partner that helps cities achieve high-impact, community-driven stormwater solutions.

After Sturm framed the conversation on implementation and the importance of public-private partnerships moving forward, Brooks discussed Philadelphia’s program for CSO control. The program, Green City, Clean Waters, seeks to protect and enhance Philadelphia’s watersheds by managing stormwater with GI. The 25-year program that began in 2011 sets recommended milestones for every 5 years that are in compliance with national regulatory obligations. By 2036 the city plans to have 10,000 greened acres—meaning that one-third of the CSOs will be managed through GI—and an 85% overflow reduction. The PWD is projected to spend more than 2.4 billion dollars over the next 25 years, with commitments made by many local stakeholders and partners to implement GI projects. The Green Stormwater Infrastructure Implementation Plan provides a road map for implementing projects highlighted in the CSO control plan, outlining action items in order to keep the program on track. In the plan, land area is broken down into rows (streets) and parcels (parks, commercial, facilities, schools, vacant land, residential, and campuses), which influence the types of GI that can be implemented in those areas. Through its public program, the PWD works with other city departments to incorporate GI into public space improvements. Incentivized retrofits allow PWD to access GI opportunities on residential and commercial properties. In order to fund the projects, Philadelphia modified its monthly stormwater fees, collected through a stormwater utility, to reflect each property’s relative contribution to stormwater runoff; properties with larger impervious areas that produced more runoff would pay the highest fees. The stormwater grant programs, SMIP (Stormwater Management Incentive Program) and GARP (Greened Acre Retrofit Program), also help develop more public-private GI partnerships. Finally, regulations on new development and redevelopment projects require the installation of GI. These projects have the advantage of having no upfront investment by the city. Development has a 1230 greened acre target, and has been the most successful so far. One reason why is because COVID-19 has slowed municipal projects down, while private projects have continued, with less budgetary concerns. Private landowner involvement has been critical to reaching GI development and stormwater runoff reduction goals in Philadelphia.

So far, the PWD has exceeded its first 5-year target for GI implementation, and is expected to hit its 10-year target following the coronavirus pandemic. Furthermore, the PWD has undertaken a “triple bottom line” analysis in order to evaluate the total societal, environmental, and economic benefits of GI against the initial financial investments. Although this can be difficult to quantify, it can help compare a green approach to traditional infrastructure. Some benefits highlighted by the PWD include:

1. Jobs in green stormwater infrastructure will help reduce the social cost of poverty.
2. GI enhances recreation and the appearance of public places.
3. GI will enhance quality of life, thereby increasing property values near installations.
4. GI will reduce the effects of excessive heat in the summer.
5. GI will have tremendous environmental benefits by improving air quality, offsetting carbon dioxide emissions, and restoring ecosystems.

Following Brooks’ presentation,  Mendez discussed strategies for the implementation of GI. When municipalities are first creating GI programs, they face many initial challenges, including difficulties to scale, not enough funding, slow rollout, and more financial risk for utilities. As a result, utilities often begin implementing piecemeal projects on public land or small scale residential programs to minimize these risks. This allows the utility to choose projects that are less complex and costly to begin with. Mendez explained that the main tools utilized to overcome barriers to scale GI were development regulations, private property incentives, public-private incentives, and outcomes-based contracting. Many cities, including Philadelphia, Buffalo, and San Francisco, are using multiple approaches for their sewer system improvement programs. Standard public-private partnerships (P3) programs allow the water utility to directly contract with a third-party administrator to manage the initiative and deliver greened acres on a pay-for-performance basis. The private partner is provided with the tools to develop and market the GI program, and contract with landowners to deliver greened acres. P3s help simplify procurement, thereby accelerating timelines for certain projects. Furthermore, the utility is able to control the budget for the GI project while distributing risk with the private partner.

Also central to this discussion was the importance of equity and inclusion in GI. There are a couple of ways to systemically level the playing field. First, Mendez says to focus on location. Install GI in communities that need it most, for example, low-income neighborhoods, communities of color,  areas with health disparities, where there is a lack of green space, or high flood risk zones. Furthermore, utilities should saturate GI across these communities. According to Mendez, one of the “sweet spots” for GI retrofits are with anchoring institutions that serve low- and moderate-income communities, such as schools, public housing, local nonprofits and businesses, and houses of worship. These areas present sufficient impervious land for cost-effective GI solutions, while also impacting a large number of daily site users. Second, utilities should be intentional about who is involved in the planning, implementation, and stewardship of GI. Locals in these neighborhoods are key stakeholders in conversations regarding GI, and their priorities need to be considered beforehand. Third, utilities and private partners should design to maximize benefits based on community priorities besides simply considering stormwater performance. The final lever for increasing equity is providing job opportunities and training programs to residents in the community. Racial and economic segregation has been the lasting legacy of systematic racism in land use policies, and GI, if done right, presents one opportunity to reconfigure investment priorities for these groups.

During the current pandemic, it is crucial that municipalities and utilities plan and budget their GI projects to stay on track. As Brooks emphasized, it is important to set internal targets when creating a program to evaluate it and adapt it to future circumstances. Implementing sound GI programs can drive green job growth in these communities, provide clean air and water, reduce localized flooding, and enhance public health conditions equitably. Stormwater-related investments are pivotal for a more resilient future, and perhaps, we will be more prepared to “weather” future storms.

 

Due to the COVID-19 pandemic, the New Jersey Department of Environmental Protection (NJDEP) extended the deadline to submit draft Long Term Control Plans (LTCPs) from June 1 to October 1, 2020. To date, two plans have been submitted before the October deadline, each representing one of North Hudson Sewerage Authority’s (NHSA) two treatment plants—Adams Street and River Road.

Implementing plans for both plants will cost the authority $307.3 million and will occur over a period of at least 29 years. Most of the 12 distinct projects focus on storage tanks and increasing capacity either at the wastewater treatment plant (WWTP) or within the conveyance system. Both plans indicate the authority will ensure that additional debt service on loans or bonds needed to finance the LTCP projects is “manageable within the overall debt burden and affordable to the customer base.” The table below outlines the selected projects for both plans, as well as expected construction costs and project start dates.

Both plans call for exclusively gray solutions but refer to supplementary green infrastructure projects constructed by cities within the authority’s service area. Neither plan prioritizes water conservation or green infrastructure but the River Road plan highlights a current service area leak detection program that minimizes the effects of inflow and infiltration. The program involves the authority identifying infiltration into the collection system from water main leaks and meeting with SUEZ Water to isolate and repair the leaks. Thus far, the program has resulted in reduced flow rates to the River Road plant from 11 million gallons daily (MGD) to eight MGD, which ultimately allows for more CSO flow to the plant. The plans indicate that public input, which called for minimizing disruptions to public activity, shaped the selection of the CSO controls. Lastly, implementation of the plans will be funded by a combination of rate increases, bonds, and grants and loans from the state Infrastructure Bank.

Green infrastructure projects are briefly mentioned in the Executive Summary, which are intended to “work in parallel” with the plans. The Adams Street plan refers to the Hoboken Green Infrastructure Strategic Plan, submitted in October 2013, but does not name the specific strategies. It also notes the green infrastructure projects like permeable pavements and rain gardens at various resiliency parks in the service area and the Washington Street Rehabilitation and Redesign Project, which features 15 rain gardens. The River Road plan notes general “green infrastructure practices” at Union City schools and the West New York Parking Authority, as well as bioswales along Park Avenue. Additionally, the authority has been requiring stormwater management in the form of detention systems for all new development and redevelopment projects. This will be included in the next iteration of the LTCP.

Although the plans document the number of public meetings, the only public comment recorded in the report refers to concerns for projects proposed on public property and along the Hudson River, as well as ones that involved in-street construction. Since those projects would potentially impede community actions, the LTCP focused on expanding the capacity of the wastewater treatment plant and increasing the volume that can be conveyed to the plant. The plan acknowledges that other alternatives such as storing or treating outside of the plant would be effective, but would ultimately cause more disruption to public activity. The plan does not mention additional community benefits such as improved public health and local jobs.

Both plans are being funded by rate increases, bonds, and grants/loans from the New Jersey Infrastructure Bank. The authority does not have proposed rate increases by income level. Instead, rates will increase uniformly by 2.0% per year for the next 10 years, followed by 3.0-3.5% increases per year. Normally, NHSA does not have customer assistance programs, but due to COVID-19, the authority is offering assistance by delaying the due date for its next two quarterly bills and not charging interest penalties for late payment for three months.

To find the two North Hudson Sewerage Authority reports, as well as other permittee reports when posted in the fall, please visit the NJDEP Long Term Control Plan Submittals website. Comments on the LTCPs can be submitted to the appropriate NJDEP contacts (contact information found here). 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 (please refer to the permittee directory here).

Earth Economics, a global leader in science-based economics, worked with the Sewage-Free Streets and Rivers partners to develop a New Jersey-specific flyer highlighting the benefits of using green infrastructure (GI) to reduce combined sewer overflows. As 21 New Jersey communities select solutions to reduce combined sewer overflows, it is important for decision-makers to fully understand costs and the benefits of green infrastructure. The flyer is an outreach tool to inform local communities, organizations, permit holders, and policymakers as they select the solutions to stopping sewage overflows.

The flyer that Earth Economics developed shows how GI is a cost-effective solution from a capital and operation and maintenance perspective, especially when paired with an established gray infrastructure system. According to Earth Economics, “green infrastructure projects tend to store more gallons of stormwater per dollar invested than conventional gray infrastructure. Also, operations and maintenance costs tend to be similar or lower than gray infrastructure as a percentage of capital costs.” Earth Economics also quantifies the broader benefits of green infrastructure. For one acre of rain gardens installed in New Jersey the estimated value of improving stormwater quality is $111,796, the aesthetic value is $841,134, and the value of heat island reduction is $21,756. The same rain garden is associated with an estimated value of carbon sequestration of $6,880 and flood risk reduction of $7,174.

Another broader benefit of GI is local job creation. Earth Economics found that for every million dollars invested in GI programs, between 11 and 13 jobs are supported, compared to approximately 7 total jobs for traditional gray infrastructure projects. They note that GI programs support local jobs when they “are planned in tandem with local workforce development efforts, and permit holders prioritize local hiring programs.”

By capturing and slowing water where it lands, green infrastructure can reduce the strain on sewer systems, treatment plants and reduce greenhouse gas emissions.

Pumping stormwater to sewer treatment plants is energy intensive and expensive. Green infrastructure projects in Camden were estimated to capture about 125 million gallons of stormwater per year. This saved the City of Camden the cost of pumping that flow to the CCMUA as well as the pollution associated with that energy usage. Andy Kricun, former Director of the CCMUA estimates the savings in treatment and pumping costs of around $250,000 per year.

The deadline for the Combined Sewer Overflow Long Term Control Plans is October 1, 2020. Several municipalities in the Passaic Valley Sewerage Commission Region have already presented plans for reducing CSOs that include minimal or no GI solutions. While reducing combined sewer overflows can be accomplished without GI, communities that move forward with plans that rely on gray infrastructure will miss the cost-benefits, community benefits, and environmental benefits associated with GI.

 

Tuesday, August 18 10 am-noon

In this CSO LTCP review workshop we will focus on reviewing the LTCPs and submitting comments to municipal and utility permit holders and then to the New Jersey Department of Environmental Protection. In this hands-on workshop we will use the LTCPs that have been submitted to the NJDEP and draft plans that have been made available to the public as well as the most recent updates on the remaining eight regional plans to guide participants through the evaluation process with a particular focus on environmental and engineering specifications, green infrastructure specifications, local job impacts, and financial analysis. NewarkDIG is hosting the workshop in partnership with the Sewage-Free Streets and Rivers campaign and the Jersey Water Works CSO committee.

In Part 1 of the CSO LTCP review workshop we focused on the nine requirements of the CSO Long Term Control Plans to guide participants through sections of the report. We discussed the regional gray infrastructure projects under consideration by the municipalities in the Passaic Valley Sewerage Commission Region. Michele Adams, founder of Meliora Design, explained private property opportunities for implementing green infrastructure (GI). Larry Levine, Director of Urban Water Infrastructure & Senior Attorney at the Natural Resources Defense Council and member of the JWW Asset and Finance Committee, presented equitable and affordable ways to finance CSO LTCPs. Kim Irby, New Jersey Future Policy Analyst, presented the water workforce opportunities associated with green infrastructure, and Drew Curtis, Ironbound Community Corporation, led a brainstorm on how to conduct community engagement on these plans during COVID-19. You can watch the presentation here: https://www.youtube.com/watch?v=UedgFOiC62E&feature=youtu.be

The coronavirus crisis has reminded us of the vital role of our water infrastructure and, accordingly, has highlighted the impact of when it fails. Regardless of a contagious and deadly virus, public health is threatened without safe and reliable water services, both drinking water and wastewater. Along with reminding us how important water infrastructure itself is, the pandemic has also underscored that the water workforce is composed of essential workers. Although office managers may be able to work from home, that flexibility is not afforded to plant operators and others who must work in the field to keep unseen, but critical, functions running.

In New Jersey, as the coronavirus threatens public health in the state with the second-highest number of cases and deaths, the water sector has to work even harder to ensure that services continue unimpeded, while also managing the issues of lead in drinking water, combined sewer overflows, and aging infrastructure in general. The crisis has spurred calls to include funding for water infrastructure in federal stimulus packages, some with an emphasis on sustainability. However, considerations for a shrinking and demographically homogeneous water workforce have largely been missing from these conversations.

Nationwide, the water workforce is anticipated to dwindle due to older professionals, most of which are white and male, retiring. It is estimated that within the next 10 years, approximately one-third of water utility operators in the U.S. will be eligible to retire. This presents a challenge to fill vacancies with qualified candidates who will ensure that we have safe, clean drinking water and reliable wastewater services. However, this also presents an opportunity to fill vacancies with demographically diverse, local candidates – ideally those who also understand the importance of investing in upgrades and sustainability like green infrastructure (GI). In Camden and Newark, there are water workforce programs that have been created relatively recently to try to address these issues by training residents of communities that suffer from a combination of economic, health, and environmental burdens in GI maintenance and/or connecting them to professional opportunities in the water industry.

Camden

PowerCorps Camden is a training program for opportunity youth ages 18-26 who have a high school diploma. It blends environmental stewardship with support services, provided by a nonprofit called the Center for Family Services (CFS). Nearly half of the funding for the program is sourced from the Corporation for National Community Service (CNCS) and a little more than half is leveraged through matched dollars from other funders. Every six months, 30 members learn how to maintain green infrastructure, develop professional skills, and receive counseling to improve their confidence and guide them through the transition to working full-time.

In Camden, the PowerCorps program has succeeded as a second of its kind, as the original one started in Philadelphia. This shows that a workforce training program of this sort is not only replicable, but adaptable to a given city’s circumstances. For instance, the City of Camden was unable to manage the program alone, but the Camden County Municipal Utilities Authority (CCMUA) and the non-profit CFS, along with other partners, have been able to both secure funding from a federal agency and administer the variety of services necessary for the program.

Camden Works is a program open to any Camden resident looking for employment. It is not a technical training program like PowerCorps; rather, the focus is on helping participants refine their professional skills and connect them to local job opportunities. Similarly to PowerCorps, the Center for Family Services (CFS) serves as the resource for both professional development and social support. There is no educational requirement; if an individual wishes to get their GED, the program can help them do so.

Both PowerCorps and Camden Works offer services to their members on a personal level. For example, if a member is dealing with childcare or transportation issues that will hinder their ability to get a job, the programs will help them mitigate the issues as much as possible so that when they get a job offer, they are ready to start without worrying about those types of hurdles. Additionally, members have control over what they want to prioritize and which barriers they want to address. Ultimately, the programs prepare their participants so that when the time comes, they are ready to fully dive into employment.

Newark

In Newark, the Ironbound Community Corporation (ICC) has trained 21 Newark residents to take the National Green Infrastructure Certification Program (NGICP). Certification requires a high school diploma or equivalent and completion of a GI training course. ICC owns a training license to do this and is the only certified trainer in the state. This is part of a larger job training program, funded through EPA Brownfields Grants, in partnership with the County of Essex.

Besides the green infrastructure installation and maintenance classroom training, residents receive basic literacy training, as well as OSHA-10, OSHA-40, and OSHA Hazardous Waste and Emergency Response certifications. Due to COVID-19, they are delayed in delivering the second cohort of this training that would include hands-on training in installing and maintaining green infrastructure on several Blue Acres sites in the Ironbound that were bought out after Superstorm Sandy.

As a multi-service, community-based organization, ICC blends early childhood education and social services with community organizing and advocacy work to serve as a neighborhood anchor organization for the predominantly low income residents of color in the community. One of their goals is to “address unmet needs and service gaps, particularly for under-served individuals and families.” Another goal is to help “develop self-esteem, self-efficiency, and civic participation.” Though ICC’s other services are not directly tied to the NGICP, residents that participate in the training would have access to those social support services all the same.

On June 9, NewarkDIG (Doing Infrastructure Green), in partnership with Sewage-Free Streets and Rivers and the Jersey Water Works Combined Sewer Overflow (CSO) Committee, held a workshop to help community advocates around the state prepare for reviewing the CSO Long Term Control Plans (LTCPs) now due on October 1, 2020.  Watch the workshop here.

In 21 NJ communities, CSO Long Term Control Plan (LTCP) decisions are being made alongside a flood of other political, social and environmental storms. Nicole Miller, NewarkDIG chair, explained how the CSO LTCPs fit in the context of our current realities. “This is absolutely an environmental justice issue, and so when we think about the world we are living in right now and all of the things that are happening, this is also part of that conversation. We hope that all of you take this seriously. We hope that you are thinking about the communities that are affected like Newark, where I live, Trenton, Camden, Paterson. These are communities that have cumulatively been impacted by environmental damage. So we want to make sure we are providing healthy safe water and waterways for people to recreate and live and sewage free streets at the very least.”

Speakers emphasized the importance of communities having a voice in the plans that will include the multi-million dollar projects selected to reduce sewage overflows, a timeline for implementation, what will be prioritized, costs, and the financial capability of the municipality or utility to be able to pay for the plans. Presenters discussed what’s new, where to focus and what to look out for in these plans. A major component of the plans that has not been sufficiently communicated to the public are the regional alternatives, like the very large tunnels and parallel interceptors being considered for the Passaic Valley Sewerage Commission Region. Participants expressed concerns about the cost of these large projects and how the City of Newark would specifically be burdened by the construction.

Michele Adams, founder of Meliora Design, touched on another issue that has not been part of the plans: private property opportunities for implementing green infrastructure (GI). She explained how the City of Philadelphia updated its stormwater ordinance to capture the private property opportunities for new and redevelopment projects as part of their Long Term Control Plan. She stressed that the most cost-effective time to implement GI is when you are building something and that the ordinance has not stopped development or redevelopment. This is especially relevant in New Jersey as the state just released a new stormwater rule and all of the CSO municipalities are now in the process of revising their stormwater ordinances.

Larry Levine, Director of Urban Water Infrastructure & Senior Attorney at the Natural Resources Defense Council and member of the JWW Asset and Finance Committee presented on equitable and affordable ways to finance CSO LTCPs. “Do not take the existing rate structure for granted. Evaluate more equitable rate structures, which can reduce burdens on low-income customers, or on residential customers generally” said Levin. He suggested that community groups and advocates ask utilities if they are considering equitable financing options like a stormwater utility fee.  Even within the context of the presentation there were debates about the use and efficacy of a stormwater utility.

Another aspect of ensuring that these plans benefit CSO communities is through a focus on water workforce development. Connecting water workforce opportunities with local hiring and the local economy was one strategy proposed in the workshop. Green infrastructure projects, more than any other alternative, lend themselves to towns working with local contractors. Prioritizing green infrastructure training in these communities along with local hiring ordinances that are tied to municipal contracts would bring money back into the community.

While the new deadline extension allows more time for public outreach, the limitations of physical distancing require new tactics and strategies for gathering feedback from the public on the selection of alternatives to CSOs. The group discussed the importance of continuing public outreach and using multiple methods for outreach including online and offline tactics.

The presentation discussed these things and more. Feel free to watch the presentation at the link above or view the slide deck on the Sewage-Free Streets and Rivers website. A second installment of this workshop will be held in August. Please join us as we focus on reviewing a draft of the LTCP with the express purpose of developing useful comments from community groups for NJDEP consideration.

The submittal deadline for the Combined Sewer Overflow (CSO) Long Term Control Plans (LTCPs) has been postponed until October 1, 2020. The submittal deadline was extended because of the impacts of Covid-19. Public outreach on the plans has come to a standstill but it should not stop. In fact, municipalities and utilities now have more time to inform and engage the public in the selection of solutions to stop sewage overflows.

The need to upgrade archaic combined sewer systems that dump sewage into our waterways onto streets needs to be addressed. Residents who are impacted by flooding and sewage overflows still need a say in the final Long Term Control Plans. Questions still remain as to whether these plans will be affordable, keep residents healthy, invest in local jobs, businesses and neighborhoods, and create more green spaces that promote climate resiliency. Stay involved to make sure that these multi-billion dollar plans deliver community benefits and are not decided behind closed doors.

1. Email and call your CSO permit holder and ask them to hold a series of public virtual meetings on your combined sewer overflow Long term Control Plans before the October 1, 2020 submittal deadline.
2. Ask your CSO permit holder to release their draft CSO LTCP to their supplemental CSO team and the public for comments 60 days before the plans are due. This will allow for CSO permit holders to review the public input and incorporate it into their plans before they are submitted to the New Jersey Department of Environmental Protection (NJDEP).
3. Participate in the June 9, 2020, CSO LTCP Review Workshop hosted by NewarkDIG in partnership with the Sewage-Free Streets and Rivers campaign and the Jersey Water Works CSO committee and learn how to review the plans and submit comments.
4. Follow the Sewage-Free Streets and Rivers campaign on Facebook and Twitter for the latest news on the CSO LTCPs.

The Covid-19 crisis has had a severe impact on all of our communities and utilities. The Sewage-Free Streets and Rivers campaign would like to thank the CSO permit holders for requesting an extension and the NJDEP for granting it. Now, let’s use this time to ensure that the people who live, work, and run businesses in these cities have a say in these plans.