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Review of North Hudson Sewerage Authority Long Term Control Plans

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 (, bureau chief of surface water permitting at NJDEP, as well as the relevant permittee contact (please refer to the permittee directory here).

From the Ground Up: Designing a Green Infrastructure Program

A virtual presentation hosted by New Jersey Future

Tuesday, August 11 12:30pm–1:30pm

Presenters from GreenPrint Partners and the Philadelphia Water Department will focus on the initial questions that municipalities and utilities should ask internally when thinking about starting a GI program, cover how these questions guide the type and design of a GI program, and discuss different strategies for funding and financing these efforts. Learn how GI installations are designed to maximize community benefits, delivered at scale, and maintained for the long-term. Attendees will leave with a better understanding of a private property program’s foundations and steps to take to create a program locally. This program is for anyone who is responsible for CSO LTCPs and green infrastructure plans in CSO communities.

Speakers include:

  • Jessica Brooks, PE, Director Green Stormwater Infrastructure Unit, Philadelphia Water Department
  • April Mendez, Co-founder and VP of Strategy, Greenprint Partners
  • Chris Sturm, Managing Director, Policy and Water, New Jersey Future (moderator)


Register here (Please note registration is limited).

Green Infrastructure is Part of the Solution

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.


Save the Date: CSO LTCP Review Virtual Workshop #2

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:

Bolstering the Water Workforce During COVID-19 Recovery Current Programs in New Jersey

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.


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.


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.

CSO LTCP Review Workshop Report Back

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.

How to stay involved

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.


Lessons we are Learning from the Covid-19 Crisis

What are we learning from the Covid-19 crisis?

In a matter of months, Covid-19 has changed our world dramatically. The lessons we are learning have as much to do with what our world looked like before the coronavirus as what it looks like now.

We are learning that:

Water and wastewater utilities and workers are essential. The Covid-19 crisis has made clear what and who is essential: those treating patients and keeping our hospitals running, our grocery stores open, and our utilities functioning.  Water utilities and workers not only deliver a basic necessity for hydration but especially during Covid-19 deliver a necessity for hygiene when sheltering at home.  In March, Governor Murphy stepped in to ensure that no New Jerseyan would be left without water during the Covid-19 crisis and called on water utilities to suspend water shut-offs.  We are also learning how many households are on the brink of having water, a basic necessity, shut-off.

Our crumbling water infrastructure needs to be repaired before we have a crisis.  Water main breaks in New Jersey have left communities without water needed for hygiene and hydration during a health crisis. Combined sewer systems that needed to be repaired before the crisis will need to be repaired after it. The need to upgrade our water infrastructure remains during COVID-19, only now CSO communities, many of which are economically distressed, are faced with budget gaps, in addition to the cost of upgrading their water infrastructure.

Our environment impacts health outcomes. Worldwide stay-at-home orders have given us a glimpse of how the environment can regenerate when polluting industries are put on hold. Here in New Jersey, we have seen a significant drop in pollution levels that cause much of the health problems associated with unhealthy air quality.  At the same time, our history of poor air quality has been associated with higher levels of Covid-19 fatalities.  Air pollution is not spread evenly, low-income residents and people of color are disproportionately exposed to health-threatening environments in their homes, neighborhoods, and workplaces. We are learning that the pandemic is not just a health crisis, it’s an environmental justice crisis.

Water main break

The pause caused by Covid-19 has made room for reflections on what needs to be done when we hit the start button.  This crisis has magnified the inequalities in our society.  Now we need to amplify these lessons in the solutions that are implemented in the recovery.


CSO LTCP Review Workshop: Learn how to review your town’s Long Term Control Plan and develop comments

NewarkDIG, in partnership with Sewage-Free Streets and Rivers and the Jersey Water Works CSO Committee, is hosting a workshop to help community advocates around the state learn how to evaluate this complex document and develop comments for submission to the New Jersey Department of Environmental Protection (NJDEP). This understanding is also crucial to advocacy organizations helping to spread the word to residents, business owners, and other stakeholders about the stormwater infrastructure changes that will be decided upon by the 21 CSO communities this year.

The submittal deadline for the final CSO Long Term Control Plans has been postponed 90 days due to the COVID-19 crisis and now must be submitted by October 1, 2020. Draft plans will be made available to the public for comment before the plans are submitted to the New Jersey Department of Environmental Protection. Using a draft of the Newark LTCP, this workshop will guide participants through the evaluation process with a particular focus on environmental and engineering specifications, green infrastructure specifications, local job impacts, and financial analysis.

The virtual workshop is being held on Tuesday, June 9th, 2020 from 10 am-noon.

RSVP for the workshop here.

Keep Our Sewer Clean During COVID-19

The coronavirus is changing the world rapidly but some things remain the same—toilet paper is the only thing that should be flushed. Anything else clogs our sewers during a time when our water infrastructure is already in need of repair. reporter, Alexis Shanes, interviewed wastewater experts about the impacts of flushable wipes on our sewers during the coronavirus in her article, “Coronavirus cleaning: Flushing that disinfectant wipe? Think again, experts say.” In the article, Shanes describes how flushed wipes can clog sewers. “Flushed items go first to waste pipes in homes and then to town sewer lines that run beneath streets, which can be as small as 18 inches. The flushed wipes eventually end up in larger pipes owned and operated by county utilities, which are as wide as 96 inches. Sewer systems rely mostly on gravity.  If wipes collect in a system, they can prevent water from flowing, like leaves in a yard drain.”

An important reminder for people who are using “flushable” wipes to disinfect groceries and take-out orders from the coronavirus is that “flushable” wipes are not biodegradable and will clog sewers and cause sewer back-ups.

Walter Marlowe, Executive Director at Water Environment Foundation, makes another important point about keeping our sewers clean during COVID-19 in Shane’s article, saying, “being self-quarantined at home can be tough. Being self-quarantined at home with a backed-up sewer is much, much worse. Do not flush things that shouldn’t be flushed.”

Plastic gloves littered across a Walmart parking lot. Photo Credit: Hudson TV page member.

On Monday, April 6, Hudson TV posted a photo on its Facebook page of plastic gloves that customers used as protection from the coronavirus, littered across a Walmart parking lot with the caption, “Please, throw away used gloves to a trash container.”  Similar posts of images of gloves and masks littered on city streets in New Jersey have been posted recently on Facebook. If these plastic gloves get into our sewers they will also cause clogs and back-ups, and put an additional strain on our water infrastructure and essential wastewater workers.

On March 27, ABC News reported on back-to-back water main breaks in Jersey City during the coronavirus. Workers were sent out to repair the water main break and a water truck was sent to neighborhoods without running water. The water main breaks sparked concerns about sanitary conditions for residents left without running water, a necessity year-round, but especially during a pandemic. While the timing of this water main break was unfortunate, it was not surprising as New Jersey’s water infrastructure is in need of repair.

Water and wastewater workers are deemed essential. They continue to repair and operate our aging water infrastructure during the coronavirus. Let’s help them keep us (and themselves!) safe and keep our sewers clean.