Fact Sheets on the CSO Plans

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

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

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

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

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

Flooding Concerns Raised At Environmental Justice Listening Session

On Wednesday, March 4, 2020, the New Jersey Department of Environmental Protection (DEP) held an environmental justice listening session in the City of Paterson. Riché Smiley Outlaw, the Director of the Office of Environmental Justice opened the listening session. According to the Office of Environmental Justice website, the office “aims to guide the DEP’s program areas and state agencies in working to achieve environmental justice, empower residents who are often outside of the decision-making process of government, and address environmental concerns to improve the quality of life in New Jersey’s overburdened communities.

This listening session is part of the DEP’s efforts to support environmental justice in New Jersey.  DEP Commissioner Catherine McCabe and Paterson Mayor Andre Sayegh greeted a full room of Paterson residents to hear and about the environmental issues facing the community. Commissioner McCabe engaged residents by saying that, “we need you to point us to where we need to focus here in Paterson.” She brought representatives from her department and other departments integral to supporting environmental justice, such as the Department of Economic Development and the Attorney General’s office, to answer questions brought up by community members.

Commissioner Catherine McCabe responds to community concerns.

Several community members raised concerns about flooding. One resident described a sewer stench during rainstorms. Susan Rosenwinkle, Bureau Chief from the Division of Water Quality explained that Paterson is one of 21 cities with combined sewer systems and that the City of Paterson is working on a plan to reduce combined sewer overflows. She also committed to looking into the specific source of the odor.

Illegal dumping was another major concern that was raised as well as air pollution, water quality, and the impacts of contaminated sites on surrounding neighborhoods. The DEP stressed the importance of identifying problems and making them aware of it. Although the DEP could not address every issue raised, they said that they would work with the City of Paterson to address these issues and that this would be part of a continued effort.

NewarkDIG Council Presentation

By Nicole Miller, NewarkDIG Co-Chair

On Tuesday, January 28, 2020, several members of NewarkDIG (Doing Infrastructure Green), a Sewage-Free Streets and Rivers partner, made a presentation to the Newark City Council on the upcoming final report of the Combined Sewer Overflow (CSO) Long Term Control Plan (LTCP). NewarkDIG presented for 45 minutes bringing council members up to speed on the basics of CSOs, a brief history of the permit regulations, a review of the considered alternatives and a breakdown of the costs. A key component of the presentation was a discussion of the importance of community outreach and input. We specifically asked the Council members to take action in partnering with us and other community groups to host meetings sharing information about stormwater and the LTCP. Additionally, we asked that the Council approve the upcoming sewer rate study to be proposed by the Water & Sewer Dept., to begin work on stormwater ordinance changes for developers, monitor regional plans to be certain that the needs of the City of Newark are not ignored and to stay involved and aware as they will need to approve the final LTCP in order to secure funding for implementation. Council members present remained engaged, following along with the slide deck, and were prepared with questions at the end of the official presentation.

NewarkDIG members Drew Curtis and Nicole Miller presenting to the Newark City Council.
NewarkDIG members Drew Curtis and Nicole Miller presenting to the Newark City Council.

After a history of the NewarkDIG collaborative by Kim Gaddy of Clean Water Action and the NewarkDIG Green Infrastructure Reformer Coordinator, Nicole Miller emphasized the importance of Newark administrative and council officials taking ownership of the process to keep our streets and rivers clean and safe. After all, they are the final decision-makers and action-takers with regard to the LTCP, which is due to be completed by June 1.

Drew Curtis of Ironbound Community Corporation stressed the important role of speaking to and hearing from the community on these long-range infrastructure plans. The goals of the LTCP permit process require a reduction of CSO events or volume along with a reduction of harmful pathogens in waterways as a result of CSOs. Drew brought up the many community meetings we and our partners have held that have identified the additional goals of reduced basement and street flooding, the need for community funds to be used for community benefits (such as green space) and the importance of local jobs to come out of this local infrastructure spending. In fact, there are two pilot programs focused on national green infrastructure training certification happening in the city that could be expanded.

Dr. Chris Obrupta with the Rutgers Water Resources Program explained that green infrastructure’s benefits extend beyond stormwater retention and can even aid in job creation, climate resiliency, heat island reduction, among other efforts. Dr. Obrupta noted that none of the alternatives would solve the problem on their own and recommended that the Council consider not just the base requirements of the permit but also what additional benefits could be gained by combining alternatives creatively.

Council President Crump suggested an internal committee set up within the Council to monitor and focus on the CSO Long Term Control Plan. Councilman Gonzalez was especially interested in making sure our community outreach was more robust and he volunteered to chair the subcommittee. Councilman Osbourne also volunteered to join the committee. Councilman Gonzalez was also vocal about Newark requiring new building development to have stormwater control. He suggested to his fellow council members that they should amend the zoning ordinance to meet this requirement.

The response of the council members was precisely what NewarkDIG was looking for when we set up the meeting. We have plans to re-engage with the Council’s internal committee as more information becomes available on the LTCP. NewarkDIG and partners will also continue to bring members of the community from different wards forward to speak to the Council on street and basement flooding and the need for infrastructure changes that address those issues.

Educating Youth On Combined Sewer Overflows

By Michelle Doran-McBean, CEO, Future City Inc.

Students from Winfield Scott School #2 in Elizabeth learned about combined sewer overflows, as part of a new education and outreach program implemented by Future City Inc. The program provided 88 students from third, seventh, and eighth grades with Rotary International dictionaries as a vehicle to for information about Combined Sewer Systems and the Sewage Free Streets and Rivers campaign. Most students, like most adults, did not know about CSOs until Future City Inc.’s presentation.

Each student received a dictionary and used it to complete crossword puzzles with words relating to CSOs. Students discussed the challenges of CSOs and brought home flyers in English, Spanish, and Kreol to continue the discussion with their families. During these discussions, students explored what they can do to keep their streets clean. Students left the program reporting that they gained new understanding and appreciation of the importance of keeping litter out of their streets, and pledged to help prevent overflows.

This outreach and education program was supported by a capacity building grant from the Sewage-Free Streets and Rivers campaign.

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. 


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.


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/

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.  

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.

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 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.

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 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.


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.


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.


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.


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.


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).

How Syracuse Won the Battle for Green Infrastructure

Onondaga County, New York, found itself in an exciting position in 2012. Struggling, as many cities and towns are to reduce combined sewer overflows (CSOs), Onondaga county was going to use an all gray infrastructure approach, until Joanie Mahoney, then County Executive, stepped in to recommend a newer approach to the issue in the form of green infrastructure.

Though green infrastructure was gaining traction, it was not yet readily accepted as a viable solution by municipalities and towns. In fact, it wasn’t until Mahoney read NRDC’s Rooftops to Rivers: Green Strategies for Controlling Stormwater and Combined Sewer Overflows that she began to recognize the plethora of benefits possible with green infrastructure. Despite considerable obstacles standing in the way of convincing the public and municipalities of the efficacy of green infrastructure, New York Water Environment Association Government Affairs Committee Chair Matt Millea and Mahoney both recognized that the journey toward successfully implementing green infrastructure in Onondaga County would begin with ambitious thinking about the possibility of a green Syracuse.

As part of its Save the Rain program, Onondaga hit the ground running and installed green roofs, cisterns, and permeable parking lots. These alternatives quickly became conversation pieces and points of public introduction to green infrastructure; most notable, perhaps, was the use of recycled rainwater for ice at Syracuse’s War Memorial hockey rink. After demonstrating the efficacy of green infrastructure through its completed projects, both as a tool for reducing CSOs and as a tool for public engagement, Syracuse began the journey of widespread implementation, going on to successfully construct green public parks, parking lots, and city streets with features like bioswales, permeable pavement, and rain gardens in city sidewalks. 

Syracuse’s success is also owed in part to the use of the EPA’s Storm Water Management Model (SWMM), a tool that allows municipalities to measure the type and amount of runoff from a sewer system. Using SWMM, Onondaga County was able to select ideal locations for GI and quantitatively demonstrate that, in combination with gray infrastructure, green infrastructure was an ideal way to tackle CSOs.

As a result of extensive efforts using SWMM and city buildings to shift public opinion on how CSO events might be tackled, Syracuse and Onondaga County have ended up with a cleaner and healthier Onondaga Lake, which now attracts more fishers, bald eagles, and boaters than in any time in recent memory. In fact, Onondaga Lake now even attracts performers and the community-at-large to the recently completed St. Joseph’s Health Amphitheater, a lakeside venue that is thriving due to the renewed cleanliness of the body of water upon which it rests. Let Syracuse and Onondaga County be an example; if we push for green solutions to CSOs, in combination with gray solutions, our communities will not only be greener, but also cleaner and more unified.