Mo Kinberg

Climate-Ready CSO Solutions Forum

New Jersey Communities Discuss Climate Change Impact on Multi-Billion Dollar Sewer Improvement Plans

In New Jersey, 21 fast-growing communities with outdated sewer systems that combine rainfall with industrial and domestic sewage are finding they are particularly vulnerable to the effects of climate change. When it rains in these communities, raw sewage pours into rivers and backs up into basements and onto streets, known as Combined Sewer Overflow (CSO). Increased flooding from sea level rise, more intense storms, and extreme heat due to climate change are compounding the existing environmental and health concerns in New Jersey’s CSO communities. 

New Jersey Future hosted this event in partnership with the Sewage-Free Streets and Rivers campaign and the New Jersey Climate Change Alliance on January 28 in the city of Elizabeth to discuss the importance of the state’s CSO communities incorporating climate change as a critical factor in planned upgrades to wastewater infrastructure systems. 

Attendees were concerned about the impact of climate change on their communities.

Approximately 80 community members, engineers, utility directors, environmental advocates, students, design professionals, and media attended the forum at which CSO and climate change experts discussed integrating climate change solutions into CSO Long Term Control Plans (LTCPs). The communities’ LTCPs are due to the New Jersey Department of Environmental Protection (NJDEP) by June 1 and will be implemented over the next 30-50 years while towns are simultaneously battling climate change. Governor Phil Murphy recently signed Executive Order 100, which requires the integration of climate change and sea level rise into the state’s regulatory and permit programs, including CSO permits. 

Forum panelists included New Jersey Future Executive Director and panel moderator Pete Kasabach; Elizabeth Mayor J. Christian Bollwage; Dave Rosenblatt, New Jersey’s first Chief Resilience Officer; Janice Brogle, Acting Director of Water Quality for NJDEP; Dr. Marjorie Kaplan, Associate Director of the Rutgers Climate Institute; Andy Kricun, Executive Director and Chief Engineer for the Camden County Municipal Utilities Authority; Alan Cohn, Managing Director of Integrated Water Management for the NYCDEP; Kim Gaddy, Environmental Justice Organizer for Clean Water Action; and Jackie Park Albaum, Director of Urban Agriculture for Groundwork Elizabeth. 

The panelists discussed adding green infrastructure to towns as a solution to help reduce CSOs as well as flooding and extreme heat due to climate change. The need for creative solutions to address the impacts of climate change related to CSOs was highlighted, as was the importance of environmental justice and engaging communities in solutions. Cost was a prominent topic of discussion, given that the wastewater infrastructure improvements are expected to cost billions of dollars. Implementing the plans will have significant effects on residents and business owners in the CSO communities for generations to come.  

Go Home and Ask Questions 

Attendees were urged to continue the conversation started at the forum in their own communities and with their elected officials and utilities by asking them how they are considering climate change in selecting alternatives to CSOs. Three important questions residents can ask are:  

  1. How are the alternatives to CSOs being designed to withstand the impacts of sea level rise and increased precipitation caused by climate change? 
  2. How are social vulnerabilities to climate change being taken into consideration? For example, are maps being developed that show flooding and combined sewer outfalls in relation to income, minority status, race, and age? 
  3. Are the communities who will be impacted by climate change being taken into consideration in the selection and siting of alternatives to CSOs? 

New Jersey Future is a state leader in the area of wastewater infrastructure, including CSOs, as part of its mission to make smart investments in infrastructure to increase New Jersey’s competitiveness and support healthy communities where people want to live and work. 

Join the Sewage-Free Streets and Rivers campaign today to stay up-to-date on the process and opportunities to review and comment on the CSO LTCPs. 

Resources: 

Sewage-Free Streets and Rivers – Community engagement and outreach resources on combined sewer overflows and contact information for municipal and utility permit holders.

New Jersey Climate Change Alliance – Information on sea level rise and the impacts of climate change on New Jersey. 

New Jersey Department of Environmental Protection Combined Sewer Overflow Basics – New Jersey Combined Sewer Overflow permit submissions and information on the permit process. 

Groundwork USA Climate Safe Neighborhoods – Maps that show the connection between housing discrimination and climate change and how Groundwork communities are using maps and data to build resilience to extreme heat and flooding.

 

Mo Kinberg

Passaic Valley Sewerage Commission’s Regional Supplemental CSO Team Meeting Recap

“The permit requires a public participation process that engages the affected public, including hydraulically connected communities, throughout the three phases of the LTCP and through the use of various outreach methods.” NJDEP Public Participation Guidance.

Supplemental CSO teams have an important role in community outreach. These teams meet periodically and provide feedback on the Long Term Control Plan planning process, review new information and share that information with impacted communities. The Passaic Valley Sewerage Commission held a regional meeting on Jan. 9 with its members: City of Bayonne, Borough of East Newark, Town of Guttenberg, Town of Harrison, Jersey City Municipal Utilities Authority, Town of Kearny, City of Newark, City of Paterson, and the North Bergen Municipal Utilities Authority. 

Key Takeaways:

  1. Act Now: Now is the time to talk to your municipal leaders about the alternatives to combined sewer overflows that will benefit your community and stop sewage overflows. Find contact information for you municipal leaders and CSO contacts here.
  2. Financial Capabilities Assessment: Financial capability assessments showed the median household income for each municipality and the calculation of a two percent rate increase on water bills. More information is necessary to determine if this is a sustainable option, and permit holders will decide whether to investigate further.  
  3. Water Quality: Water quality models showed that combined sewer overflows are impacting water quality and that some, but not all, of the water bodies are meeting water quality standards. 
  4. Public Engagement: There will be at least one more public meeting before the June 1, 2020 submittal deadline for the CSO Long Term Control Plans. A decision has not been made about meetings past that date. 
  5. Comments on Development and Evaluation of Alternatives Reports: In total, 134 comments were submitted. Three areas received the most comments: green infrastructure, public input and outreach, and the Development and Implementation of Regional Alternatives. 

Missed the meeting? You can watch it here. 

You can also look through the presentation here. 

For more information on the Passaic Valley Sewerage Commission’s regional team visit: https://www.njcleanwaterways.com/

Mo Kinberg

Paterson Launches Adopt A Catch Basin Program

By Sue Levine, Great Swamp Watershed Association

“Everyone has a basin on their block. It is the drainage on the corner. With all of the trash, when it rains, and it floods, it all ends up in this basin. So if we all get out and clean those basins, it will help the water stream flow.” Chrystal Cleaves, Paterson Green Team member.

With support from the Sewage-Free Streets and Rivers campaign, the Paterson Green Team and the Great Swamp Watershed Association launched Paterson’s adopt a catch basin program. Inspired by Newark’s adopt a catch basin program, the groups worked together to develop a program unique to Paterson. The program kicked off in August 2019 at Barbour Park with a community barbeque, coordinated by Councilwoman Ruby Cotton and the Paterson Fireman – Bronze Heat Team. At the event, residents picked up adopt a catch basin kits, learned about combined sewer overflow issues in Paterson and the need to have a Long Term Control Plan to reduce contaminate that flows into the streets and rivers.

Since August, 40 adopt a catch basin kits, equipped with instructions on cleaning the basins, a tracking sheet, gloves and trash bags were delivered to community members in most of the six wards. The organizing groups have received positive feedback and are seeing the program gain traction. After Councilwoman Ruby Cotton and her husband decided to adopt a basin, her husband expanded his reach, and now oversees 10 basins near his home. She feels this initiative has helped reduce basin flooding in her immediate neighborhood.

Educational meetings were held at City Hall and also in community settings including the Freedom Village Senior Center, the Great Falls Youth Center, and the Boys and Girls Club of Paterson. At the evening meetings, the community shared flooding experiences and residents learned about the impact of combined sewer overflows and the alternatives Paterson is considering. Residents gained a better understanding of how best they can get involved and have a voice in the process. The Paterson Green Team and the Great Swamp Watershed Association look forward to increasing the number of adopted catch basins to help reduce flooding in the City of Paterson. 

Mo Kinberg

DEP Releases Comments on Proposed Solutions to CSOs

The New Jersey Department of Environmental Protection (NJDEP) posted its comments on the Development and Evaluation of Alternatives Reports that were submitted by the 16 municipalities and nine regional sewerage utilities that have combined sewer systems.  

Over the summer, NJDEP conducted a thorough 60-day review of the reports that included accepting public comments. NJDEP’s review letters, posted on Oct. 3, 2019, include comments on how each municipality and utility evaluated the alternatives to combined sewer overflows and how they engaged the public. The comments also ask for additional information to be added to reports and reflect the comments received from the public. These comments are a significant step as municipalities and utilities go on to develop the final plans know as Long Term Control Plans are due on June 1, 2020.

Residents who live in these communities can read DEP’s comments to gain insight into the options being considered for their communities and if issues they care about, like climate change and flooding, were part of the review. Residents should submit preferences or concerns to their municipality or utility. 

NJDEP’s comments on the Development and Evaluation of Alternatives reports are the result of permits issued by NJDEP in 2015 to 25 municipalities and utilities in New Jersey with combined sewer systems, requiring them to develop plans to reduce the number and severity of combined sewer overflows. These overflows happen when stormwater overwhelms the system. As a result, a combination of stormwater and sewage is released into nearby waterways, and sometimes floods area streets and backs up into basements.  

Mo Kinberg

Climate-Ready CSO Solutions

Twenty-five New Jersey municipalities and utilities are developing plans to upgrade their century-old combined sewer systems. These upgrades will take decades to build and should serve communities for another hundred years. Thus far, the development of these plans has not required climate change to be taken into consideration.

Here are five reasons sewer upgrades should be climate-ready.

1) New Jersey’s sewers have already been impacted by climate change.

2) New Jersey is at the center of a national trend toward increased temperatures and rainfall.

3) Combined sewer overflows could be contributing to climate change.

4) The same communities that are on the front-lines of climate change impacts are also affected by combined sewer overflows and flooding.

  • “Rising sea level and more frequent and erratic precipitation will exacerbate challenges like flooding and CSOs that already disproportionately affect vulnerable communities.” —US Water Alliance, “An Equitable Water Future: Camden”

5) The process of treating wastewater is energy-intensive and contributes to climate change.

  • “The process of treating wastewater emits relatively large amounts of the heat-trapping gas methane (CH4) into the atmosphere. Among other processes that emit methane, wastewater treatment is the fifth largest anthropogenic source of the gas.” — U.S. Climate Resilience Toolkit

Nearly every aspect of upgrading our sewers relates to climate change. More precipitation not only increases the amount of sewer overflows, but it could be eroding wetlands that capture carbon. Wastewater treatment plants, which we will spend billions to upgrade, are also greenhouse gas emitters. The people most impacted by sea level rise are also impacted combined sewer overflows. Upgrades to our sewer systems need to take climate change into consideration, in order to develop solutions that fit our changed environment and minimize wastewater’s contribution to climate change.

Over the next few months, wastewater utilities and municipalities with combined sewer systems will select alternatives to combined sewer overflows. These solutions should be climate-ready and carbon neutral.

Ask utilities and municipalities to take climate change into consideration in sewer infrastructure upgrades.

Mo Kinberg

Comments on the Remedies to Sewage Overflows

Sewage-Free Streets and Rivers partners reviewed all of the Development and Evaluation of Alternative reports from a community and quality of life perspective to ensure that communities have access to waterways and benefit environmentally and economically from these plans.

Here is what we found in the reports:

All of the municipal and utility permit holders will choose how they will measure the solutions to sewage overflows. They can either measure the solutions by demonstrating that they are capturing 85% of the flow or by using by using the presumptive approach based on reducing the number of system wide overflows.

Presumptive vs. Demonstrative Approach:
Most permit holders have not officially selected an approach, but the general trend is toward an 85% capture, which equates to approximately 20 overflows a year, depending on the community. Our concern is that by focusing on the minimum requirement of the permit, other combined sewer overflows issues impacting communities like flooding, sewer back ups onto streets and parks and into basements, water quality, and toxicity will not be adequately addressed. Permit holders should select alternatives based on information that shows that not only will permit requirements be met, but community impacts of flooding, sewage backups, water quality and toxicity are also addressed.

Climate Change:
Although the permit does not require climate change or sea level rise to be considered when evaluating the alternatives, several permit holders and Supplemental CSO Teams considered climate change in their reports:
JCMUA, Ridgefield Park, Elizabeth, and Harrison included or discussed sea level rise.
CCMUA noted that climate change would be considered in the selection of alternatives.
Perth Amboy and PVSC’s Supplemental CSO Teams asked that climate change be considered in the evaluation of alternatives.
We recommend that NJDEP provide clear guidance on how permittees can include climate change data in the selection of alternatives so that they use the same baseline data for precipitation, storm intensity and frequency, and sea level rise. Permit holders reference 2004 as the design year, though baseline data within reports vary when discussing alternatives. These climate impacts could render CSO solutions ineffective or result in unintended consequences, unless they are taken into consideration in the design and selection of alternatives. For example, the Ridgefield Park report noted that sea level rise would reduce the amount of overflows. Less overflows into waterways could result in polluted water backing up into basements and onto streets.

Public Participation:
Other than attendance at Supplemental CSO team meetings, many of the permit holders and their consultant representatives had little to no interaction with the public when considering which alternatives to evaluate. This is despite a clear guidance document from the NJDEP recommending an ongoing public engagement process: The Supplemental CSO teams should not be considered as public engagement; rather, they should be treated as public engagement strategy sessions. These teams are designed to give municipal permit holders in-depth access to a key group of stakeholders with the goal of sharing the ideas developed in those meetings with the wider community–ideally, with the assistance of those stakeholder groups. Most of the reports indicated that the permit holders convened or participated in a regional and/or municipal Supplemental CSO Team, but they did not describe the preferences, questions, or any other input from stakeholder groups either at CSO Supplemental Team meetings or other public participation activities. We recommend that the permit holders be required to revise their evaluation of alternatives reports to include the following information to ensure that the preferences of Supplemental CSO Team members and the public are considered:

  • A list of Supplemental CSO team meetings with the date, time, and location.
  • A list of local LTCP process public meetings with the date, time, and location for each meeting along with the methods used for attracting attendees.
  • Number of attendees for each meeting.
  • A list of the types of people and organizations represented at the meetings, for example, community members, elected officials, community organizations, businesses or business associations, municipal employees, municipal consultants, home owners, etc.
  • Agendas presented at the meeting as well as a summary of the preferences, concerns, and input gathered at the meetings.
  • How the the Supplemental CSO Team was involved in a two-way conversation with the permittee beyond being a passive recipient of information.
  • Explicit plans should be shared for how municipalities plan to engage directly with the public on the final report beyond the Supplemental CSO team meetings.

Green infrastructure (GI):
A thorough evaluation of GI is needed in order to determine the optimal amount of green infrastructure and select and site green infrastructure installations that produce the desired stormwater management and community benefits. Like all of the other alternatives, a thorough evaluation is needed to ensure that the technology is utilized properly.

The evaluation of green infrastructure in the evaluation of alternatives reports ranged from extensive to minimal. The CCMUA and JCMUA utilized a triple bottom line approach, which considers the social benefits of the alternatives evaluated. Some permit holders like Newark worked closely with community groups to understand their priorities. These permit holders also prioritized green infrastructure in a balanced approach. Other permit holders like North Hudson Sewerage Authority and Bayonne stated that GI will be implemented on a system wide basis or as a secondary alternative without any indication of what that actually meant.

We recommend that permit holders follow NJDEP’s “Evaluating Green Infrastructure: A combined sewer overflow control alternative for Long Term Control Plans” guidance manual related to modeling and explain the hydraulic and hydrological model used and the results. We recommend the reports include:

  1. Evaluate land uses, drainage areas and other community specific drivers and benefits to establish the goals and milestones for the GI program.
  2. Compile a GIS Database for GIS Parameters including flood prone areas
  3. Use one of the hydrologic and hydraulic modeling tools referenced by NJDEP (Arc Hydro, SWIMM, infor works) to model potential stormwater reduction volumes. The NY-NJ HEP worked with the City of Perth Amboy to undertake such an analysis for two model sewersheds, demonstrating that green infrastructure interventions that met preliminary feasibility tests and community support reduced peak stormwater volumes could be reduced by 20%.

We also recommend the use of a triple bottom line approach, as described in NJDEP’s “Evaluating Green Infrastructure: A combined sewer overflow control alternative for Long Term Control Plans” guidance manual to assess the selection of alternatives and articulate the community benefits of green infrastructure and a quantitative value of these benefits. The cost-benefit analysis should include the full range of community benefits.

We are concerned that permit holders like the North Hudson Sewerage Authority and Bayonne have stated that GI will be implemented on a “system wide basis” or as a “secondary alternative” without a quantitative measure (like gallons of stormwater captured or volume of stormwater reduction that shows how GI is contributing to the goal of 85% capture or 4 overflows annually) are not considering a meaningful GI program. We recommend that permittees be required to revise the evaluation of alternatives to include targets for gallons of stormwater captured or reduction of CSO volumes for GI. We are concerned that without a designated contribution goal reducing combined sewer overflows the GI component of the plan will be minimal and ineffective.

We recommend that the evaluation of alternatives describe the strategies that will be used to implement green infrastructure goals. For example:

  • Identify all public land that can be utilized for GI (parks, schools, city, state and county owned lands and facilities).
  • Develop a goal for stormwater capture from GI projects on private land as well as ordinances or incentive programs to achieve the goal.
  • Choose locations for GI that will not replace existing green space with impervious cover.
  • Plant trees as part of the GI plan.
  • Use a cost analysis for GI based on economies of scale, procurement by quantity, and relate to cities of similar size and socioeconomic status.
  • Implement GI in conjunction with community groups to ensure community engagement from the start of these projects and community acceptance.
  • Ensure that consultants working on these plans are certified and experienced in GI design and construction.

Storage:
Storage is an alternative that all of the permit holders are considering. Some of the reports provide more detailed information on the proposed locations and dimensions of the storage tanks, tunnels or shafts being considered. We recommend that all of the reports include this information and that community members provide input on storage options being proposed and locations identified. It was unclear how the locations of the storage site were identified or if there had been any community input on the sites identified. We recommend that:

  • The public have input into the selection of sites for storage.
  • Land ownership be identified and verified.
  • Identify the communities impacted and engage them in a two-way dialog on the proposed project.
  • Dimensions of the storage tanks should be included in the reports and if they are surface or subsurface.
  • Acquire private land for storage tanks rather than utilizing the traditional approach of bottom of the river end of pipe tank storage.
  • Odor control should be discussed and evaluated.
  • Include improvements on the surface that relate to needed amenities, like parks, parking, or GI opportunities.

Disinfection:
The Sewage-Free Streets and Rivers partners have concerns about the use of disinfection as a primary alternative to combined sewer overflows. To our knowledge, disinfection does not account for sewer back-ups and street flooding or the water quality that is in direct contact with residents. We are concerned that disinfection could have a negative impact on quality of life and cause health and safety issues because the water residents are interacting with will still be polluted. The bi-products are unknown as well as the long term impacts on the NY-NJ Harbor’s ecosystem. Disinfection on its own does not address solids. Holding tank location and land acquisition issues need to be addressed in addition to the safety of the public near disinfection systems. We recommend that NJDEP review the potential impacts disinfection could have on the quality of life and water quality in these communities.

Inflow and Infiltration Reduction (I & I):
I & I is a cost effective alternative that should be considered for further evaluation by all of the permit holders – documentation of the condition of the pipes and ways to address leaks should be made public and included in the reports.

Sewer Separation:
Spot separation can address local flooding issues and reduce overflows. Utilities, such as gas and electric, should coordinate to identify opportunities to separate sewers with new development or redevelopment and when other utilities are doing road work. We recommend coordination between utilities to reduce costs and maximize efficiency.

Evaluation of Alternatives:
We recommend that NJDEP require permittees to include a quantitative metric (such as gallons of stormwater capture or CSO volume reduction) to show the relative contribution of each alternative being considered for the LTCP. Some of the reports noted that GI would be implemented on a system-wide basis or implied that GI would be implemented as part of the plan but did not include the percent of CSO reduction or wet weather volume GI would account for in their evaluation of alternatives. The report should clearly show the options that the permittee is considering to reach the goal of 85% capture or 4 overflows annually add up and the percentage of CSO reduction each alternative will account for in the proposed plans.

The evaluation of alternatives should also include how funds will be allocated to ensure public participation for the selection of alternatives and implementation of the LTCP and statements by the permittees addressing plans to advertise, and monitor public participation in the selection and implementation of the LTCP.

Additional Alternatives to Evaluate:

  • Water conservation was evaluated by several permit holders including Newark and Bayonne, but not all of the permit holders. This is a low cost solution that should be considered for further evaluation and included in the budget for the LTCP.
  • Ordinances, zoning changes, and public education efforts to reduce stormwater entering the system were generally considered but should be considered for further evaluation as low cost solutions to CSOs and require budget considerations.
  • Coordination with municipal, county and state government should be included in the LTCPs but was not mentioned in the evaluation of alternatives.
  • Adaptive management was considered by one permit holder and would be beneficial to all of the permit holders to consider in their plans.

Comments on Specific Municipal and/or Utility Alternatives Reports focused on public participation:

Bayonne

Bayonne participated in the regional Supplemental CSO Team and formed a municipal supplemental CSO team. Specific details on the meetings, who was in attendance, agendas and preferences related to the alternatives were not included in the report.

The Supplemental CSO Team is hardly mentioned in the report, only being discussed briefly in section D.1.4, but the preferences of the CSO Supplemental Team are not mentioned.

There is no mention of outreach to public outside the supplemental team and no documentation of any preferences.

Bergen County Utilities Authority

On page 34, the BCUA LTCP discusses alternatives as they relate to “public acceptance” however, input from the Supplemental CSO team was not included. BCUA should hold community meetings where members can voice their opinions and concerns about each alternative.

CCMUA/Gloucester City/Camden City

The report considered public input and noted specific preferences of the Supplemental CSO Team related to several alternatives:

  • The CSO Supplemental Committee has reinforced the desire among Camden stakeholders that the Final LTCP include as much green stormwater infrastructure as quickly as possible.
  • The CSO Supplemental Committee noted that a satellite facility in the vicinity of G4 and G5 would impinge on the municipal park.
  • The report noted that the Supplemental CSO Team would be included in the siting of satellite facilities.
  • The feasibility of siting satellite facilities will be evaluated further in close cooperation with the neighborhood stakeholders and the CSO Supplemental Committee during the development of the Final LTCP.

Section 6.2 of the CCMUA LTCP states that climate change will be addressed in the final plan.

Section 6.4 described the triple bottom line approach being used to evaluate the alternatives.

East Newark

The Supplemental CSO Team is mentioned only briefly in section D.1.4, and the preferences of the CSO Supplemental Team are not mentioned at all. We recommend that a summary of feedback from the Supplemental CSO Team be included.

Elizabeth/Joint Meeting of Essex and Union Counties

Section 8 of the Evaluation of Alternatives report is dedicated to CSO Supplemental Team coordination. The report summarizes meeting notes, outlines community outreach activities and educational events such as Community Organization and School Events and discusses signage and notification systems. This is a good example of including community input in the report.

Guttenberg

Guttenburg did not consider public input or any input from a Supplemental CSO Team. The report speculates on the perceived desires of community members and private developers.

Section D.2.7 of Guttenburg’s report notes that Guttenburg will only be evaluating very limited GI measures which will only be implemented across three streets.

Harrison

Section A.5 discusses a local community group known as “Harrison TIDE”. It is important to state that this community group neither replaces a Supplemental CSO Team nor the community at large.

Jersey City

The report included preferences that were gathered through community meetings and from stakeholder groups related to green infrastructure and included some of this input into the evaluation of alternatives. This was a good example of including community input in the report related to green infrastructure.

The report noted community preferences related to green infrastructure but did not include the comments received or provide more specific details on the content of the meetings, attendance, or community represented.

We recommend more specific information be included in the report on the extent of the outreach, as well as the preferences of the Supplemental CSO Team and public related to the grey alternatives reviewed.

Kearny

Section C.2.2 of the report states that Kearny enlisted a local group known as Kearny AWAKE to give comments on the proposed solutions. It should be noted that this does not count as representation of the entire community.

Newark

Section D.1.4 of the report states that Newark has taken comments from the quarterly region Supplemental CSO Team meetings run by PVSC. These quarterly meetings are not sufficient for procuring public comments and preferences, and additionally, the comments that were made were not reflected in the reports. It is necessary to hold publicized and well-attended public meetings, and then provide the statements made by community members, not just a statement noting that community input was recorded.

Community groups have stated that no tanks should be installed and disrupt Riverfront Park.

Newark did hold 14 public meetings in partnership with community groups and its municipal action group Newark DIG, however the specific feedback from community members was not included or used in the alternatives analysis.

North Bergen Municipal Utilities Authority

Section D.1.4 of the report states that North Bergen has taken comments from the quarterly region Supplemental CSO Team meetings run by PVSC. These quarterly meetings are not sufficient for procuring public comments and preferences, and additionally, the comments that were made were not reflected in the reports.

Perhaps it was done accidentally, but it appears that North Bergen, after considering GI measures in the report, neglects to include GI as part of the final solution in section D.3.3. This warrants further investigation to ensure that North Bergen is, in fact, planning on implementing GI as part of their LTCP.

North Hudson Sewerage Authority (Adams St. and River Road)

The report noted that a workshop was held to evaluate the alternatives but does not indicate that Supplemental CSO Team members were included in the workshop or the preferences of the team.

North Hudson Sewerage Authority does own the land in the four communities that it serves. Although the reports states that it will seek GI to be used systemwide. It is unclear where the GI will be used. NHSA should include more specific information about their proposed plans for utilizing GI as an alternative, how sites were chosen, and how they are optimizing GI in the four towns. There is a need for the municipalities to be more involved in the development of NHSA LTCP.

Paterson

The terms “CSO Team”, “CSO Supplemental Team”, and “Supplemental Team” were not found in the City of Paterson’s report, indicating that input from these teams was not reported.

Perth Amboy/Middlesex County Utilities Authority

The report includes a few specific preferences and comments from the Supplemental CSO Team and how they were taken into consideration. Section 6.7 of the report is a place-holder for discussion and commentary from the Supplemental CSO team. We recommend that this section be added as well as additional information on how the Supplemental CSO Team and the public were engaged, and their feedback on the alternatives that were evaluated in the plan.

As with other permittees, the report states that it will seek GI to be used systemwide. It is unclear where the GI will be used. Perth Amboy has been the subject of several assessments by Rutgers University as well as the NY-NJ Hep that identifies and evaluates specific GI opportunities. The report should include more specific information about their proposed plans for utilizing GI as an alternative.

Ridgefield Park

Public participation captured by the Supplemental CSO Team meetings, Village Caucus Meetings, Earth Day event, and other outreach efforts. Of the six controls evaluated, favorability of the public was given a 15% weight though it was not identify what the public actually supported (seems like they are using general public perceptions to distribute weights) (see Table 7-31, pg 151).

Mo Kinberg

Tips on Reviewing CSO Alternatives Reports

The Regional CSO Supplemental Team meeting in Kearny

All of the municipal and utility permit holders submitted reports on July 1, 2019 describing the options they are considering to reduce combined sewer overflows. While these reports are not the final plans they include the options being recommended for further evaluation and combinations of solutions that would be feasible to reduce overflows.

 

What you need to know:

All of the reports have been posted on New Jersey Department of Environmental Protection CSO site and can be downloaded here.

Comments can be submitted to the NJDEP CSO team leaders listed here: https://www.nj.gov/dep/dwq/cso-contacts.htm

Your permit holder is also obligated to educate, engage and facilitate a two-way dialogue with the public. In addition to the NJDEP, please submit your comments and questions to your permit holders and ask them to hold public meetings to explain the evaluation of alternatives reports and get input from the public. 

Do not be alarmed by the length of these reports! While many are roughly a thousand pages, most of it is background information or appendices. Feel free to read the whole thing if you have the time, but the actual substance of the reports tends to be between 100 – 200 pages.

All permit holders were required to evaluate these seven alternatives to combined sewer overflows.

Focus on these sections (titles may be different depending on the reports):

  • Development and Screening of General CSO Controls – This section describes the alternatives that were looked at and makes recommendations for further evaluation.
  • Development and Evaluation of Alternatives: This section evaluates the recommended alternatives based on reduction of flows and frequencies as well as examples of how the alternatives could be combined and includes costs.

Questions to consider when reviewing the reports:

  • Were community benefits like green space, clean air, or job creation included in the evaluation of alternatives?
  • Were low-cost solutions like fixing the pipes thoroughly evaluated?
  • Was climate change or sea level rise taken into consideration?
  • What percentage of green infrastructure was evaluated? And what was recommended for further evaluation?
  • What do you think is missing?
  • Will residents of all incomes, races, and ethnicities participate in and benefit from these decisions?

Use this worksheet to assist you in reviewing the reports.

Please email info@sewagefreenj.org if you have any questions about reviewing these reports or anything related to combined sewer overflows.

Mo Kinberg

Dialogue Needed on Potential Solutions to Reduce Sewage Overflows 

All of the Development and Evaluation of Alternatives reports that were submitted to the New Jersey Department of Environmental Protection (NJDEP) on July 1, 2019 have been posted on the NJDEP’s website for the public to review.  The reports, submitted by municipal and utility Combined Sewer Overflow permit holders, describe the options being considered to reduce flooding and pollution caused by combined sewer systems.

“Communities will be investing billions of dollars to stop sewage from overflowing into waterways and backing up onto streets and into basements,” said Kim Gaddy, Newark resident and Environmental Justice Organizer for Clean Water Action. “The question is what will this investment look like and how will it benefit our communities?” 

While the Evaluation of Alternatives reports are not final plans, they provide a first look at the possible solutions and a breakdown of which ones are likely to be the most feasible. NJDEP recognizes the importance of public input in this process and is soliciting feedback from community members as part of their review of the reports and have required permittees to educate and engage the public in the selection of alternatives. Comments can be submitted until September 1, 2019.

A combined sewer outfall on the beach of Perth Amboy

“As of July 1, 2019, communities have less than a year until  the final plans, known as Long Term Control Plans (LTCPs), are due,” said Nicole Miller of NewarkDIG (Doing Infrastructure Green). “Once the final plans are approved by the NJDEP they will take decades to complete and cost millions of dollars to implement. With proper community input, LTCPs have the potential to provide benefits. Now is the time for the community members to make their voices heard by submitting comments to NJDEP and participating in local and regional stakeholder meetings. The next few months are critical for the residents and business owners who will be impacted by these plans and who will ultimately pay for them.”

“These reports show that local communities are very concerned about sewage overflows into nearby streets and waterways and that they expect green solutions to be incorporated into the next phase of planning because while reducing sewage flows it also provides open space, improved air quality and heat island temperature reductions that aren’t realized with traditional infrastructure,” said Greg Remaud, NY/NJ Baykeeper. 

“These alternatives plans are a critical step in gathering local knowledge from communities suffering from polluted stormwater and sewage flooding. The people who live in these communities understand these problems and their effects the best. Projects in these alternatives plans, specifically green infrastructure, will reduce flooding and sewage overflow, and will improve the environment of the community, the health of its citizens, and property values,”  said Jennifer M. Coffey, ANJEC Executive Director.

The Evaluation of Alternatives reports are the result of permits issued by NJDEP in 2015 to 25 municipalities and utilities in New Jersey with combined sewer systems requiring them to develop plans to reduce the number and severity of combined sewer overflows. These overflows happen when stormwater overwhelms the system. This combination of stormwater and sewage is released into nearby waterways, and sometimes floods area streets and backs up into basements.  

For more information on participating in stakeholder meetings and other ways to get involved go to SewageFreeNJ.org. 

All of the Development and Evaluation of Alternative reports can be downloaded from the NJDEP website.

Comments can be sent to the respective NJDEP team leader.

Armando Alfonso Armando.Alfonso@dep.nj.gov (609) 633-7021 for comments on the Camden County Municipal Utility Authority, The City of Camden, The City of Gloucester, Trenton Sewer Authority reports.

Nancy Kempel, Nancy.Kempel@dep.nj.gov 609-292-4860 for comments on the Bergen County Utilities Authority, Fort Lee Boro, Hackensack City, Ridgefield Park Village, The Joint Meeting of Essex and Union Counties, The City of Elizabeth reports.

Joe Mannick, Joe.Mannick@dep.nj.gov, 609-292-4860 for comments on North Hudson Sewerage Authority, North Bergen Woodcliff Sewer Treatment Plant, Town of Guttenberg reports.

Dwayne Kobesky, Dwayne.Kobesky@dep.nj.gov 609-292-4860 for comments on the Perth Amboy, Middlesex County Utilities Authority, Passaic Valley Sewerage Commission, Bayonne, Jersey City Municipal Utilities Authority, Newark, North Bergen Township Municipal Utilities Authority, East Newark, Harrison, Kearny, Paterson reports.

Local perspectives from Sewage-Free Streets and Rivers campaign partners: 

Jersey City:

“This is an important first step to assess the optimal set of solutions for managing the impact of stormwater from future storm events in Jersey City and our surrounding waterways.  Sustainable Jersey City supports a combination of both gray and green infrastructure (GI) and feel strongly about leveraging GI opportunities FIRST, to both save on the enormous cost of grey infrastructure and also to gain the varied additional quality of life benefits GI can provide.  We are particularly interested in the expansion of urban forestry initiatives in Jersey City as we can solve multiple problems and provide a healthier environment for people simply by substantially growing our tree canopy. We will do our part to educate and engage the public over this next year, encouraging community feedback about possible solutions during this next decision-making phase by the Jersey City Municipal Utilities Authority.” 

Debra A. Italiano, Founder & Chair, SustainableJC.org

“I was so pleased that our Board of Commissioners recently passed a resolution to evaluate the creation of a Green Infrastructure Incentive program.  The study will evaluate the use of various green infrastructure incentives to help reduce combined sewer overflows (CSOs), enhance drainage in certain neighborhoods, improve the tree canopy, and access to green space. Offering incentives like storm water fee reduction credits to developers for using green roofs or pervious pavement, has been shown to work in several other communities and we think it may work here as well.”  

Tom Gibbons, Commissioner, JCMUA/Hamilton Neighborhood Association

Bayonne:

“With the recent increase in building development and the loss of many of the mature street trees, Bayonne is at a turning point, as the planet is at a tipping point, environmentally. We need to affirm a plan that will not only improve green and open space while protecting our waters, but maintain what we have. The report does not include the location of projects. I am concerned that people can not have informed input without knowing where they will be placed and worried that some of the proposed projects could actually destroy our green spaces. This will only be mitigated by robust public input. This is the challenge for individuals and community groups. What is at stake in this decision is a livable future and a government that is responsive and accountable to its residents, where decisions this far reaching are made by, and for the benefit of all.”

Jill Scipione, President, Morris Park Neighborhood Association

Perth Amboy:

“The alternative reports recently submitted by the 21 NJ cities forces residents and public officials, on all levels, to think about effective solutions that will fix this serious problem we’re faced with combined sewage overflows. We can no longer sweep this issue under the rug and hope that someone else will come and solve it.  The surging of waste in our waterways has been detrimental to our ecosystem, local sea creatures, and even the water quality within our homes. We must all play a role in being a part of the solution by limiting the use of water in our homes, implementing green infrastructures that captures rainfall, and finding ways that fund gray infrastructure improvements, which will cost millions, if not billions of dollars per city. I’m hoping that we can create a culture shift that steps up to this challenge before it impacts our property taxes.”

Joel Rosa, Perth Amboy Civic Trust

Mo Kinberg

The Capacity Building Grant Program

The Sewage-Free Streets and Rivers campaign funded partner organizations to conduct public outreach. The goal was to educate families, small businesses, and community members on the impacts of combined sewer overflows. Public outreach provides opportunities for community input in the development of solutions and education on the benefits of green infrastructure. 

Here is a report back on some of the activities that were held as part of the Sewage-Free Streets and Rivers capacity building grant program.  

The Perth Amboy Civic Trust held a Solutions Forum on Combined Sewage Overflows (CSO’s) on Wednesday, June 19, 2019, at the Alexander Jankowski Community Center. Civic Trustees and community leaders gathered together to learn about the issues with stormwater drainage and its effects on our waterways, but more importantly, they learned that CSO’s will cost residents millions of taxpayer dollars if they don’t begin addressing the problem together. At the forum, panelists spoke about policies that could be adopted to help address this issue and what they believe should be included as part of the plan. Having the community involved in these discussions helps generate more solutions that can potentially be adopted and help save taxpayer dollars.

The Perth Amboy Civic Trust will host a second Solutions Forum on Combined Sewage Overflows that will focus on alternative solutions. To RSVP: https://docs.google.com/forms/d/e/1FAIpQLSf-pNep9mFGFVXq6L0UBDlo3wJ3Kuxb3NT77ashZ9IerahJgQ/viewform, or email Joel@thecitizenscampaign.org. 

On May 22nd the Bayonne Water Guardians held a rain barrel workshop where 17 rain barrels were raffled off.  Watershed Ambassador Christine Favorito gave an educational presentation on rain barrel use, rain gardens, and how citizens can participate in mitigating flooding that can occur during rainstorms.  Tim Boyle, Executive Director Bayonne Municipal Utility Authority, also spoke about the Long Term Control Plan and what Bayonne is doing to comply with government mandates regarding CSOs. Mike Rusigelio of the Bayonne Nature Club also spoke about the importance of maintaining clean waterways and how we benefit as a community.  

Sustainable Jersey City’s (SJC) initiative focused on assisting the Jersey City Municipal Utilities Authority (JC MUA) with their public outreach on behalf of their Long Term Control Plan (LTCP) Assessment. SJC replicated a survey that was created by the JC MUA to gather feedback and set out to collect responses from community stakeholders to share back with them. SJC got the word out through a blogpost and additional educational messaging about the LTCP and how important it was for the public to engage, and then also ran a social media campaign through the end of June to create additional awareness. The social media campaign also lent support for a project SJC set up to work with Ferris and Dickinson High School Student Council groups. In partnership with the Sewage-Free Streets and Rivers campaign, SJC gave presentations at high schools to provide context and to educate the students about the stormwater management issues and the various options the JC MUA LTCP were considering to address these challenges. The students volunteered to reach out to other students, parents and their communities to share the educational materials and messaging SJC provided them. SJC used the funding from the Capacity Building Grant to provide Amazon Gift Cards to the 22 students who participated in the campaign, also giving them Civic Service Certificates for their hard work. The Students were also treated to lunch the week before the semester ended!

 

Mo Kinberg

Potential Solutions

All of the Evaluation of Alternatives reports will soon be made public. On July 1, 2019, the Development and Evaluation of Alternatives reports are due to the NJDEP and will be posted online.

Although this is not the final selection of solutions to combined sewer overflows, this report will provide an idea of the directions the CSO plans are taking, including, for example, how much green or gray is your city considering and how much it will cost. The report includes an evaluation of each of the seven technologies required for review in the permit and more. Each of the alternatives are evaluated based on meeting water quality and CSO reduction goals. Recommendations on which alternatives and/or combination of alternatives will also be included.  

What is the NJDEP looking for?

The NJDEP will begin a review of the reports once they are submitted on July 1, 2019. The NJDEP will be looking to make sure each of the 7 alternatives were considered and that the reports present a few options or combination of options.  They will also be looking at how public input was taken into consideration.

What happens next?

Once the NJDEP has reviewed the reports, permit holders will receive comments. These comments will be extremely important as permit holders go  on to develop the final Long Term Control Plan. Members of the public can, and should, also send comments to the NJDEP while the reports are being reviewed.

What can you do now?

Over the last few months, Supplemental CSO Team members and some members of the public have seen draft reports and presentations on their evaluation of alternatives. If you were not able to attend these meetings, ask the utility or municipality who owns the combined sewer outfalls to share the evaluation of alternatives presentations or reports. Use the CSO Directory to find your CSO contact.