A Major Milestone for Jersey Water Works: Submission of the CSO Long Term Control Plans

Combined sewer overflows (CSOs) refer to the mix of sewage and stormwater that pollutes waterways during rain events and can cause sewer backups into basements and streets. This issue, caused by combined sewer systems, has long plagued 21 of New Jersey’s municipalities. In 2015, the New Jersey Department of Environmental Protection (NJDEP) issued 25 permits covering these 21 municipalities intended to meet requirements of the Clean Water Act and national CSO policy by reducing or eliminating New Jersey’s remaining CSO outfalls.

The recent submission of the draft Long Term Control Plans (LTCPs) by 24 of the CSO permit holders is the final step in the first five-year cycle of the permit. Essentially, these plans propose an approach that will reduce or eliminate the CSO discharges as well as a plan and implementation schedule to do so. In January 2021, the Jersey Water Works CSO Committee, with support from the three other committees, submitted comments on the plans for NJDEP to consider as it reviews them. Though the plans have yet to be finalized and the next permit has yet to be issued, we laud the plan submissions and ensuing review process as a major milestone in the history of the Jersey Water Works collaborative.

Jersey Water Works (JWW) was born out of the recognition that CSO solutions were going to require a significant amount of investment. At the outset, the collaborative wanted to ensure that the plans were developed with a triple bottom line in mind: minimize cost (especially to low-income, vulnerable communities), maximize community benefit, and maximize environmental benefit (e.g., green infrastructure, green jobs, etc.). JWW also wanted to ensure that as many stakeholders as possible were included in the conversation: environmental stakeholders, community stakeholders, regulators, utilities, educational institutions, and others.

Thus, the submission of the LTCPs and subsequent review process represent a significant event in JWW’s history. The careful review by dozens of dedicated volunteers and backbone staff focused on how well the plans achieved triple bottom line outcomes. This review informed the Jersey Water Works comments on the LTCPs, which was crafted by the CSO Committee and submitted on behalf of all four JWW committees. The comments identify both strong proposals and opportunities for improvement. 

Now that the JWW CSO Committee has submitted its comments and celebrated this significant milestone, it looks forward to engaging with permittees and the NJDEP during the comment review period to ensure that CSO solutions reflect these triple-bottom line opportunities to the maximum extent possible. Moving forward, JWW remains committed to doing its utmost to advocate for equitable CSO control plans that protect public health and the environment in an affordable manner.