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Comments on SFY24 Drinking Water and Clean Water Intended Use Plans

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02/22/23
Jersey Water Works Asset Management and Finance Committee

Comments on SFY24 Drinking Water and Clean Water Intended Use Plans

Submitted on Behalf of the Asset Management and Finance Committee of the Jersey Water Works Collaborative

Every day we depend on drinking water, wastewater, and stormwater systems to deliver essential services. But much of the underlying infrastructure requires significant investment to be brought into a state of good repair, to remedy legacy problems like lead, and to manage climate change impacts like flooding and drought.

Jersey Water Works is a collaborative effort of many diverse organizations and individuals who embrace the common purpose of transforming New Jersey’s inadequate water infrastructure by investing in sustainable, cost-effective solutions that provide communities with clean water and waterways; healthier, safer neighborhoods; local jobs; flood and climate resilience; and economic growth. One of the collaborative’s four shared goals is “Effective and Financially Sustainable Systems,” which aims for communities to maintain and improve drinking water, wastewater, and stormwater infrastructure systems to deliver quality water services that meet community needs, and that operating budgets and capital investment are adequate and affordable, resulting in systems that operate efficiently and in a state of good repair.

The Jersey Water Works Asset Management and Finance Committee submits the following comments on the proposed Clean Water (CW) State Revolving Fund (SRF) and Drinking Water (DW) SRF Intended Use Plans (IUPs) for SFY24, with this goal in mind.

We recognize the immense efforts devoted to developing the IUPs by the New Jersey Department of Environmental Protection and are grateful for the opportunity to submit our comments. Last year, Jersey Water Works Asset Management and Finance Committee submitted comments to the SFY23 IUP in April 2022 elevating many issues of importance, specifically the need to prioritize funding for water infrastructure projects in underserved communities. We appreciate the steps taken to offer technical assistance programs and recognize that this important step will help remove barriers for under-resourced communities and help to proactively identify projects with the greatest environmental benefit. In the proposed FY24 IUP, it is obvious that not all of the prior year’s available principal forgiveness was utilized, thus leaving a balance to roll into this year. Moving forward, we would like to see additional efforts to encourage participation in the SRF program as it takes advantage of additional funding from the Bipartisan Infrastructure Law. Question: How is the State considering tracking which projects are considered “ready to proceed” so that projects in under-resourced communities do not languish for long?

Affordability is an important goal of Jersey Water Works Asset Management and Finance Committee and work over the years has included multiple work products including the 2021 research study that presented a NJ Affordability methodology and was applied to assess the extent to which water and sewer costs pose a major financial burden for NJ households. Reviews on the national level have highlighted the problems of using median household income as an affordability indicator. Question: Is the State considering using additional indicators beyond the sole indicator currently referenced- the Median Household Income ( MHI)?

We thank you for your consideration and are grateful for the opportunity to submit these comments.

Sincerely,

Jersey Water Works Asset Management and Finance Committee

Asset Management and Finance Committee Co-Chairs:

Christine Ballard, CDM Smith and Zachary Greene, Raftelis

Jersey Water Works Contact Person:

Jyoti Venketraman

jvenkentraman@njfuture.org

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