Author: Mo Kinberg

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

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

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

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

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

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

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

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

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

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

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

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

Qualifications:

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

Guide agreement:

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

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

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

 

All of the combined sewer overflow Long Term Control Plans were submitted to the New Jersey Department of Environmental Protection (NJDEP) on October 1. These plans are now publicly available for download on the NJDEP CSO website.  Public comments will be accepted by the NJDEP on these plans through January 31.

Here is what we are looking for in the CSO plans:

• The financing considerations section includes details on how the plans will be financed. This section includes projected rate increases. We will also be looking for innovative revenue streams that have been identified to offset rate increases as well as restructuring of rates to ensure that rate increases will not disproportionately impact low-income residents.
• The implementation schedule outlines the projects that have been selected and the ratio of green and gray infrastructure that will be used to reduce sewage overflows. We will also be looking at plans to see if green infrastructure (GI) is being used as a first response to flooding.
• The executive summary describes how the CSO reduction goals will be met. We will also be looking to see if the plans go further than the CSO requirements to address flooding, community benefits, and the public health impacts of sewage overflows.
• The public participation section explains how public input was used in the selection of these projects, how the public was engaged, and who from the CSO communities was involved.
• How sea level rise and precipitation have been considered in the selection, siting, and design of projects. We will be looking to see if there is any reference to New Jersey’s Protection Against Climate Threats initiative and the data that is coming out of the state’s reports on climate change.
• How environmental justice communities, which we define as communities of color, low-income populations, or geographic locations that potentially experience disproportionate environmental harms and risks, are prioritized in the plans for addressing flooding and sewage overflows.
• If the water workforce was considered in these plans. We already know that two CSO communities, Newark and Camden, have workforce development programs in place to ensure that their residents are prepared for the work that will be generated through these plans. All of the CSO communities would benefit from workforce development training and a first-hire approach to ensure that the money invested in infrastructure goes back into their community.  We will be looking to see if there is any reference to job training and hiring locally in these plans.

The Sewage-Free Streets and Rivers campaign will be working with community groups to review these plans. We want to know what you will be looking for in these plans. And how we can assist you with reviewing them. Please contact info@sewagefreenj.org for more information or assistance in reviewing the CSO plans.

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

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

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

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

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

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

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.