Home > Uncategorized > Billions Of Dollars Spent On NJ Infrastructure “Resilience” Is Already Obsolete, As DEP Fails To Update Regulations To Reflect Climate Science

Billions Of Dollars Spent On NJ Infrastructure “Resilience” Is Already Obsolete, As DEP Fails To Update Regulations To Reflect Climate Science

DEP Stormwater Regulations Are Based On the 100 Year Storm Event

Ida rainfall was a 200 – 500 year event

Statistical frequencies of storm events based on historical data are no longer valid

Billions of Dollars Spent on Resilience Literally Down The Drain

Lambertville, NJ (Hurricane Irene flooding, August 2011). Swan Creek in background.

Lambertville, NJ (Hurricane Irene flooding, August 2011). Swan Creek in background.

[Update below]

NJ Spotlight reporter David Cruz opened Pandora’s box is his interview of Jersey City Mayor Fulop.

Here’s the critical exchange: (emphasis mine)

Cruz intro: This block was the scene of a year long, multi-million dollar sewer pipe replacement project, the City’s attempt at resilient infrastructure. Not so resilient looking, right? …

Cruz to Fulop: Is that a failed project?

Fulop response: No, No. Ida, based on the rainfall we had here in Jersey City and the national weather standards we had a 200 year storm. But the thing about it is that you are seeing 200 year storms very, very frequently.

Cruz: So this is a project, once it was done, it was already obsolete, yea?

Fulop: Well, I don’t know if it was obsolete because the pipes are bigger and can handle more water.

I’ve seen other news reports from NY City that Ida was a 500 year storm.

Regardless of whether it was a 200 year storm or a 500 year storm, the DEP stormwater regulations that determined the engineering design of the Jersey City project (and the size of the pipes) was based on the volume of water from a 100 year storm event.

The Murphy DEP just updated the DEP’s Stormwater Management Best Management Practices (BMP) Manual in April of 2021.

Chapter 5 of the BMP Manual provides the methodology for calculating stormwater volumes and the 100 year storm event, based on the DEP stormwater regulations: (see: N.J.A.C. 7:8-5.7).

The Murphy DEP stormwater BMP update did not consider and was not based upon climate science.

The same 100 year storm event is the basis for other DEP regulations that govern infrastructure projects (flood hazard control act, stream encroachment regulations, flood maps, CAFRA coastal permits, NJPDES, etc). 

Here is the scientific and technical core of the issue (BMP manual, at page 17):

5. Rainfall distribution for the stormwater runoff quantity control design storms: In addition to the rainfall depth, knowing how rain falls during a storm event is important in calculating the peak flow rate of the stormwater runoff generated. Keep in mind that, generally, a precipitation event typically begins with a lighter intensity of rain falling, followed by a period during which rain falls at a higher intensity before gently tapering off. To achieve the goal of estimating rainfall events for design and planning purposes, between 1961 and 1977, NRCS developed synthetic rainfall distributions from historical records from the different regions of the country. These rainfall distributions were based upon the assumption that the rain distribution is bell-shaped, meaning it has less rainfall in the beginning and at the end of the rain event.

Climate science demonstrates that the future will not be like the past (i.e. 1961 – 1977), so statistical frequencies of storm events based on historical data are no longer valid.

DEP and FEMA know this. As I wrote (see: FEMA Flays Murphy DEP Stormwater Proposal)

FEMA flagged many significant and fatal flaws in the DEP proposal, FEMA wrote: (emphasis mine)

“To highlight, FEMA finds that the abandonment of the nonstructural stormwater management in design and the absence of restrictions in the increase in runoff volume post-development to be significant deficiencies.

FEMA is also concerned that the proposed rule does not consider future conditions of increasingly intense precipitation that is expected with climate change. 

The use of the term Green Infrastructure will not offset the proposed changes to the nonstructural stormwater management strategies and the multiple missed opportunities to reduce riverine and urban flooding impacts.”

The DEP has NOT revised the stormwater management regulations and the numeric standards and methods for calculating stormwater volumes to reflect climate science.

All the billions of dollars spent in NJ since Superstorm Sandy on “resilience” and adaptation projects is obsolete.

DEP knows this and still refuses to update their regulations to reflect current science and climate projections. 

Over 7 YEARS Ago, DEP proposed to upgrade some individual permits – not comprehensive Statewide regulations – for sewage treatment plans to accommodate the 500 year storm – a story I broke, as reported by NJ Spotlight:

In an effort to prevent raw sewage from spilling into New Jersey’s waterways, the state is beginning to require sewer plants to plan for 500-year storms and to prepare for extended outages of up to 14 days. […]

“It’s extremely significant,’’ said Bill Wolfe, director of the New Jersey chapter of Public Employees for Environmental Responsibility, who first reported the changes on his blog, wolfenotes.com. “It will make a difference.’’

Why haven’t all NJ resilience projects been designed for the 500 year storm?

All the billions more in the pipeline under federal infrastructure legislation will also be obsolete, because Congress and federal agencies refuse to update federal standards and methods to reflect climate science.


Conclusion: “Building Back Better” is a bullshit slogan

Here’s my note to Mr. Cruz:

David – just watched your interview with Mayor Fulop. Follow my point, it is critical.

You raised THE essential issues in your observation that the stormwater project was “obsolete” and that the rainfall was a 200 year event.

Fulop likely doesn’t understand stormwater run-off volumes and how they are calculated (known as the “runoff hydrograph”) and how that impacts the engineering design of a project, which must comply with DEP regulations

The DEP stormwater management rules provide the methodology.

In April 2021, the Murphy DEP just updated the DEP “Stormwater Best Management Practices” (BMP) manual – the “design storm” under that BMP and current DEP regulations is the 100 year storm.

So, all the billions NJ is spending on “resilience” and “adaptation is already obsolete!!!!!

DEP knows this and had done nothing to fix the problem –

and the Christie DEP weakened DEP regulations and DEP has not even brought us back to pre-Christie regulatory standards.

You opened Pandora’s box – please do a follow up!

[Update: 9/5/21 – National Climate Assessment findings agree: (WSWS)

Along with the climatic impacts, scientists have also long sounded the alarm over the abysmal lack of preparedness. “Much of the infrastructure in the Northeast, including drainage and sewer systems, flood and storm protection assets, transportation systems, and power supply, is nearing the end of its planned life expectancy,” the US National Climate Assessment stated in its latest report in 2019. “Current water-related infrastructure in the United States is not designed for the projected wider variability of future climate conditions compared to those recorded in the last century.” The authors stressed that “significant new investments in infrastructure” are needed to protect life and property.

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