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There is Not Enough Water To Support New Egypt Sewer Plan

Critical Low Stream Flows Have Declined Significantly in Last 20 Years

Town’s DEP Water Allocation Permit Allows Only 274,000 Gallons Per Day

Sewer Plan Calls For 600,000 Gallons Per Day

New Development Would Require An Additional 500,000 GPD Or More

Something odd is going on in the Crosswicks Creek watershed, as evidenced by dramatic reductions in stream flows.

Take a look at the critical stream low flows, and note how deeply they have declined in the last 20 years, by a remarkable and inexplicable 44% (1Q10) – 45% (7Q10), based on USGS data, presented in the applicant’s own analysis:

Source: PMUA anti degradation analysis

Source: PMUA anti degradation analysis

This is unusual and is strong evidence to suggest that something wrong is going on in the watershed – even DEP’s most recent 303(d) impairment list cites potential depletive/consumptive use or export of water from the watershed as a cause of water quality impairments in Crosswicks Creek. [Clarification: it is not clear whether it is export or imported water].

Groundwater elevations may be similarly declining.

The sewer plan would make both stream flows and groundwater elevations worse by pumping groundwater and then discharging it to the Crosswicks Creek for export out of the watershed.

Low flow conditions in the Crosswicks Creek are extremely important, because that’s when the stream is flowing so low – when stream temperatures and pollutant levels are higher and dissolved oxygen levels are lower – that fish and other aquatic life that depend on adequate flowing clean water in the stream are severely stressed and can die.

These declining low flows in the stream shine a very bright light on a basic flaw in the DEP’s proposed Plumsted sewer plant permit.

The DEP’s own water quality standards and NJPDES permit regulations require that water quality standards be met during these critical low flow conditions (when no dilution of sewer plant discharge is available) – see NJAC 7:9B-1 et seq. and NJAC 7: 14A-1 et seq.

Other DEP regulations require that no sewer plant permit can be issued unless and until a watershed based “water quality management plan” is adopted by Ocean County and the permit is consistent with the areawide WQMP, see NJAC 7:15 – 1 et seq.

A key requirement on the DEP WQMP regulations is consideration of whether there is adequate water supply available to support the wastewater flows in the sewer plant and the new development it would serve.

The proposed flow capacity of the permit is 600,000 gallons per day (GPD).

The Plumsted Municipal Utilities Authority (MUA) has a big math problem – their numbers are not even close to working.

As I said, let’s repeat: the DEP draft permit for the proposed new sewer plant is for 600,000 gallons per day (GPD).

As I wrote previously, the is significantly more capacity than necessary to serve current existing development, plus the proposed new 400 – 600 unit retirement development.

That accounts for less than 300,000 GPD of the 600,000 GPS in the draft permit.

But Plumsted MUA’s DEP water allocation permit only provides 274,000 GPD of water supply. Here is the well permit data from DEP’s approved Source Water Assessment for the PMUA wells:

Source: NJDEP

Source: NJDEP


The sewer plan is not approvable under DEP regulations as a result of this failure to identify adequate water supply to meet wastewater permit flows.

Specifically, DEP water quality management regulations  (NJAC 7:15 – 1 et seq.) require that municipalities conduct a “Build out” analysis of development allowed under local zoning. Counties are required to consolidate local build out and water supply and wastewater demands and capacity in County Water Quality Management Plans.

An important element of the local build out analysis is an estimate of the amount of water supply required to serve the amount of development allowed under local zoning.

Ocean County planning, Plumsted Township, and DEP have failed miserably to develop a workable plan that can be approved by DEP under DEP regulations.

In addition to DEP, it is unlikely that their current plans could obtain required approvals of the Delaware River Basin Commission (DRBC) who must approve new sewer plants and water withdrawals from the basin, particularly in light of the unexplained decline in stream low flows.

There is no way the current DEP proposed permit 600,000 GPD flow can be approved.

There will need to be at least 2 more water supply wells drilled to provide the additional 300,000+ GPD flows to supply water for the planned capacity of the treatment plant and new development it would serve.,

The Plumsted MUA knows about this but is not telling the public.

The first thing not being explained to the public is the DEP requirement and failure to secure an Ocean County Wastrewater Management Plan amendment: ( see PMUA 9/16 minutes)

Mr. Ylvisaker said the critical issue was getting the NJDEP pre-permit by October 1st and hopefully having the surface water discharge permit by the end of the year. This is problematic as the permit cannot be issued until the County Wastewater Management Plan is approved.

But more importantly, local officials know they need to drill new water supply wells, and that DEP and/or DRBC may not approve.

Take a look at the August PMUA minutes:

njaw plumsted

Even more significantly, look at all the problems with new water supply wells discussed during the July PMUA meeting:

Executive Director Report: Mr. Ylvisaker updated the members on NJ American Water’s (NJAW) plans regarding the new wells in town. He indicated NJAW is pursuing the purchase of a private property adjacent to the Verizon building on Lakewood Road for the third well. The third well is scheduled to be in operation by the spring of 2016. NJAW has not finalized their decision or committed to construct the fourth well which will be necessary to serve the PRRC development. He noted this was in part due to whether the site for the third well could support a fourth well. This information will not be known until NJAW completes pumping tests at the site.

Mr. Dancer said that with respect to the meeting with BPU and NJAW, the issue had come up regarding whether American Water had a current and valid franchise to the Township and whether NJAW has been responsive in providing for the needs for water within the Town Center. Based on this, he felt that the discussion on the fourth well, and who pays for it is needed. Mr. Bronson also noted that American Water needs to have the fourth well permitted but did not have to invest in it until it is known what was being built. It was felt if they were already applying for the third well, they should also pursue allocation for the fourth well as well. Mr. Dancer said, as he understood it, the PRRC could not be done without the fourth well. Attorney McGuckin said the fourth well is a critical issue and steps should be taken to resolve this issue. Attorney McGuckin felt a letter should be sent to NJAW confirming our understanding regarding their financing the third well and NJAW’s plans to include a fourth well in their well tests and permitting to NJDEP.

Mr. Dancer reviewed the Bureau of Water Allocation notice to the Township on July 9th regarding an application by the Joint Base for approval of plans to divert 155 million gallons of water per month and 1.860 million gallons of water per year from 15 existing and 2 new wells. The notice states the diversion is to be used for public water supply. Mr. Ylvisaker was asked to look in to this to make sure Plumsted would not be negatively impacted.

Plumsted MUA and local officials know that they face huge regulatory hurdles from DEP, the DRBC, BPU, and possibly the Pinelands Commission regarding possible water supply.

How much will these new water wells costs local consumers?

Why are they putting the sewer plant cart before the water supply and planning horse – which is exactly what DEP regulations are designed to prevent?

As proposed, the sewer plan is not remotely ready for prime time.

It must be withdrawn.

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  1. Marc Covitz
    December 30th, 2014 at 14:43 | #1

    Has the DRBC and the Delaware River Keeper (DRK) been notified of this proposal? Do you think the DRK would pursue litigation (if it needed to get to that point) against Plumsted Twp and the DEP? They do have a staff attorney? Do you think it is worth contacting DRK to fill them in?

  2. December 30th, 2014 at 21:44 | #2

    @Marc Covitz
    Marc – Yes, I’ve contacted Maya and Tracy at Delaware Riverkeeper. Maya is a lawyer and they have legal resources.

    But haven’t heard back anything yet.

    Anyone with relationships is encourage to have at it!

  3. December 30th, 2014 at 21:53 | #3

    @Marc Covitz

    Marc – I think your point is that there is huge litigation risk here.

    I’ve also reached out to Pinelands Preservation Alliance and Sierra Club, who have interests and expertise on these issues and legal resources as well.

    However, lets take these kinds of strategic issues off line – call or email me.

  1. January 13th, 2015 at 11:38 | #1
  2. December 1st, 2015 at 11:01 | #2
  3. June 21st, 2016 at 00:05 | #3
  4. July 6th, 2016 at 09:11 | #4
  5. August 27th, 2019 at 17:54 | #5
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