Trenton NJ Environmental Justice History and its Relation to Trenton Water Works' Services

BACKGROUND 
Utility Overview 
Trenton Water Works (TWW) provides potable water to approximately 217,000 customers in Trenton, parts of Hamilton Township, Ewing Township, Lawrence Township, and Hopewell Township in Mercer County, New Jersey. Established over 200 years ago, TWW’s system has 683 miles of water mains varying in size from 4 to 48 inches in diameter, three pump stations, water storage reservoirs, and six interconnections between TWW and other water suppliers. TWW operates and maintains a Water Treatment Plant (WTP) and a water distribution system providing approximately 28 million gallons per day (MGD) of drinking water and has the capacity to treat and distribute up to 60 MGD. TWW sources its water from the Delaware River, the longest undammed river in the United States east of the Mississippi. Over 13 million people rely on the water of the Delaware River Basin, stretching from the Catskill Mountains in New York to Delaware Bay where it meets the Atlantic Ocean.  
In the past, TWW has experienced severe flooding incidents at the WTP, which disrupted its ability to provide drinking water. In 1955, 10-20 inches of rain caused the Delaware River to reach the Calhoun Street Bridge and extended flooding to the WTP’s parking lot on the other side of the River. On September 3, 1975, one valve in the WTP malfunctioned, causing the reservoir to drain into the clear wells and flood the WTP. It took two days for the water to recede and eight days to repair the wet pumps and meters, totaling 10 days of outages and service disruption. Emergency regulations were lifted on March 8, 1976. Though Trenton is at upper reaches for tidal flooding in the Delaware River, most flooding events have been caused by heavy precipitation. The WTP, lying on the bank of the River, would be inundated were the River to drastically flood. 
TWW is in the process of planning and implementing numerous capital projects across its facilities to ensure compliance which will also increase the resilience of the water system. However, TWW faces budget issues related to high debt, low Operations and Maintenance budget, and more need for regulatory improvements than TWW or the City of Trenton Board can fund. TWW utilized CREAT to assess potential climate impacts, prioritize assets, and consider relative risk reduction across different adaptation options.  
In 1975 when Trenton and the neighboring areas suffered a widespread interruption in water services, it was noted that equipment failure, human failure, and design flaws affected the Trenton water filtration plant. 10 The lack of interconnection with the neighboring water systems and damage to the filtration plant exacerbated the water crisis as there had been poor maintenance of the facility and poor funding. The success of the water delivery system partly depends on interconnection, and the lack of interconnection has made it challenging to mitigate the water supply issues.
As late as 2006, the water plant had also faced challenges in treating highly turbid water, and TWW mainly treated water from a storage facility when water was highly turbid. However, the turbidity in 2006 almost affected the storage system, and turbidity affects water quality. The inadequate interconnections have since been improved, focusing on more enhancements and linking with the New Jersey American Water, Elizabethtown System.
Trenton Water Works (TWW) operates the Pennington Reservoir, but TWW has failed to comply with federal regulations and 2018 ACO requirements. 11 Thus, TWW is in the place of replacing the reservoir and creating a decentralized water storage system in two phases. The reservoir has an 80 MG of storage capacity and is an intermediate source of supply to the Central Pumping Station, pumping up water to 70% of TWW's targeted customers. 
Environmental Justice Overview 
The City of Trenton, New Jersey, is a small post-industrial city and is rated 12th of the 607 U.S. cities with the lowest median household income with populations of 65,000 or more.1 Trenton’s population is 87% “minority” or non-white. Trenton has the highest poverty rate in Mercer County with 28.7% of residents living below the Federal poverty level and a median...