The New York City Department of Environmental Protection is finalizing plans to reduce sewage discharges in waters throughout the five boroughs. So far, the city has been content to allow billions of gallons of sewage to continue fouling our waters. If we don’t act now, NYC will lock in its #1 ranking for the most sewage pollution in the country for at least a generation. Strong action is needed now to improve the city’s sewer system and achieve safer and healthier waterways.

On days when it hasn’t recently rained, city waters are typically safe for kayaking and recreation. Really! But almost every time it rains, polluted stormwater runoff mixes with raw sewage in the combined sewer system andoverflows into our waterways where people swim, fish, and boat. These are called “combined sewer overflows.” New York City discharges more than 20 billion gallons of sewage each year.

The problem is as gross — and as dangerous — as it sounds. People who come into contact with contaminated water areat risk of developing intestinal illnesses, rashes, and infections.

Under an enforcement order from the state, New York City is now developing a proposed plan to reduce sewage overflow to the city’s major waterways, including the Hudson River, Harlem River, East River, New York Bay, Staten Island’s Kill Van Kull and Arthur Kill, and the western portion of Long Island Sound. In the map below created by our friends at Open Sewer Atlas, the red dots show the sewage overflow discharge points that will be affected by the plan (officially known as the “Citywide & East River/Open Waters Combined Sewer Overflow Long Term Control Plan”). The red shaded areas reflect parts of the city that discharge to those waters.

The plan is due at the end of the year and will be subject to review by state regulators. With just two months to go, DEP still hasn’t revealed the options it is considering, much less invited public input on a draft plan. The public must demand strong pollution controls.

This Citywide Long Term Control Plan will be the last of 11 individual plans developed for the city’s waterways. Previous plans have focused on smaller waters, including Bronx River, Flushing Bay, Gowanus Canal, and Newtown Creek. The state has signed off on all of them (except for Jamaica Bay’s plan, which is still under consideration), but not one of them complies with the water quality standards required under the Clean Water Act, and some actually increase pollution in our waterways. This year, over 50% of City Council members sent a letter to the Mayor asserting the need for stronger action on sewage controls than currently proposed by DEP. Those plans leave hundreds of milions, and in some cases over a billion, gallons of sewage overflow annually in each waterbody, with overflows occurring dozens of times per year. We’re especially concerned because the Citywide plan has a much larger scope than those plans. It will affect waterways in all five boroughs.

The Citywide plan has to be better and go further than earlier plans. It must comply with the Clean Water Act and make sure raw sewage will no longer makes our waters unsafe to touch. To meet this goal, the plan must:

The Citywide plan must be subjected to public scrutiny. Removing pollution sources from our waters requires meaningful collaboration among state and federal agencies, the city, community and environmental organizations, and local elected officials. Yet the city and state finalized the previous ten Long Term Control Plans without subjecting them to meaningful public review. Public engagement could have ensured that those plans comply with the Clean Water Act. This time, the city must publish the draft Citywide Long Term Control Plan for public review and respond to comments received before submitting it to the state.

The Long Term Control Plan must ensure that open waters are clean enough to comply with the federal Environmental Protection Agency’s currentrecreational water quality standards instead of the state’s outdated standards, which the Environmental Protection Agency has found do not protect public health. Even Alabama and Texas have adopted the federal standards, while New York’s health protections are lagging. New Yorkers deserve better.

The city must reduce sewage pollution by maximizing the use of green infrastructure and by capturing remaining overflows for full treatment. The term “green infrastructure” refers to methods to divert stormwater away from the sewer system to areas where it can be reused or infiltrated. These methods include green roofs, rain barrels, permeable pavement, and tree boxes and other vegetated areas. Green infrastructure can stop or slow precipitation runoff from reaching our sewers, relieve “sewer gridlock,” and reduce the overflow problem. The city must focus on ensuring low income and environmental justice communities receive both green and gray infrastructure investments, including prioritized siting. Green infrastructure’s co-benefits of heat reduction and air quality improvement can maximize health, quality of life, and economic growth for underserved communities.

The volume and frequency of sewer overflows throughout the city must be addressed head on, not with band aid fixes that merely mask the symptoms of the problem. The city must not simply inject disinfectants into the overflows, install underwater aeration, or relocate outfalls to less polluted waters, as called for in earlier plans. Adding chlorine disinfectants to untreated sewage can be especially dangerous, causing toxicity in waterways and endangering wildlife and human health. All investments should be directed to addressing the real problem – the city’s capacity to treat its sewage.

Some of the previous Long Term Control Plans will take decades to implement. People who are swimming, paddling, and fishing in our waters now will be left without any improvement in water quality for a generation. Notably, the plans for Newtown Creek aren’t expected to be completed until 2042! We can’t kick the can down the road. These problems must be addressed today.