We commend many of the policies and goals to foster development around existing urban areas and transportation infrastructure, following principles of “smart growth” which are more economical and environmentally sustainable.
We understand some of the reasons that the Office of Policy and Management (OPM), in recent years, has streamlined its PCD, but we join with the American Water Works Association and the South Central Connecticut Regional Water Authority in expressing concern that much of the detail and clear commitment that characterized former plans has been stripped out. The broad-brush language used, perhaps meant to be flexible, is often nebulous and seems to indicate that existing environmental and health protections are negotiable and should be balanced against development objectives. A number of the broad policy goals appear contradictory or to ignore the benefits and protections for our natural resources.
Too many of the draft PCD’s good recommendations are undermined by weak language and lack of specificity. Every time an action is “encouraged” or “supported” or the like, please specify how and by whom. We support in general the comments from the Weantinoge Land Trust and its request that the PCD incorporate more climate science into planning principles. We support in particular one of its comments calling attention to a vague call for encouragement and suggesting that incentives in support of goals should be described.
One of the primary goals of Rivers Alliance is the protection of natural open space. Open space kept as forest or fields is the best, most economical protector of water quality. State policy has traditionally ranked protection of drinking-water lands as its highest land protection goal; once lost, these lands cannot be recovered. The priority is protection not just of sources used currently as drinking water but of all high-quality waters that can be classified as potentially future drinking-water sources. Protection of source-water land provides many unique services enhancing human and ecological health, in addition to providing reliable water supplies.
Grants for the above programs will be based on the merit of the project and the level of funds available. Funding for these grants is derived from State Bond funds and/or from the Community Investment Act (CIA). DEEP is accepting applications, but awards will not be made until funding becomes available.
The State Office of Policy and Management (OPM) updates the State Conservation and Development Plan once every five years. Each 5-year revision to the State C&D Plan is prepared with consultation from regional councils of governments, municipalities, state agencies, and the public. In summer 2016, OPM began the State C&D Plan revision process for the 2018-2023 State C&D Plan, which must be submitted to the General Assembly by December 31, 2017. Check their web page for information and updates concerning the 2018-2023 State C&D Plan revision. The Public Review & Comment Period ends October 16, 2017
OPM invites all interested persons to express their views on the Draft Plan, either verbally or in writing, at any of the public hearings scheduled across the state. In addition, OPM will accept written comments on the Draft Plan at any time up to the close of business (5:00 PM) on October 16, 2017. Written comments may be emailed, postal mail, or faxed to:
Daniel Morley, Office of Policy and Management
450 Capitol Avenue, MS #54ORG
Hartford, CT 06106-1379
Written comments and proposed edits to the Locational Guide Map may also be submitted using an interactive web-based map editor (soon available), or by way of GIS shapefiles, digital/PDF maps, or printed maps. For example, if a new sewer service area in your municipality is not properly reflected in OPM's PFA boundaries, please submit a map of the new sewer service area boundaries. Specifically, OPM is requesting all municipalities to update the following data layers as appropriate:
Village Priority Funding Areas: request edits to the boundaries of existing VPFAs or the establishment of new VPFAs.
Local Conservation Priorities: areas deemed to be of high conservation priority by the municipality
Protected Lands: update the boundaries of properties that are legally protected from development (water company owned lands, deed restricted lands, etc.)
Local Historic Districts: update the boundaries of Local Historic Districts as applicable
The Green Plan is Connecticut's open-space acquisition plan. It is a report on the state's open space program and policy. The Connecticut Department of Energy and Environmental Protection (DEEP) has updated the 2016-2020 Comprehensive Open Space Acquisition Strategy (Green Plan), which guides the state's effort to meet its goal of conserving 21% of Connecticut's land base as open space by year 2023. The Green Plan and information on Connecticut open space is available for viewing and downloading at http://www.ct.gov/deep/cwp/view.asp?q=511558. Questions or comments may be directed to Jamie Sydoriak at Jamie.Sydoriak@ct.gov
In their press release DEEP reports: "The plan recommends the acquisition of certain lands for environmental and public recreation conservation centers around four major themes: "Natural Waters and Drinking Water Resources," "Areas Significant to the Coast," "Natural Heritage Resources," and "Natural Resource-based Outdoor Recreation." The Green Plan's statewide open space acquisition priorities were developed in coordination with and support of other key State planning documents related to open space, such as the Climate Change Preparedness Plan, Forestry Action Plan, Wildlife Action Plan, and Statewide Comprehensive Outdoor Recreation Plan. In addition, a series of meetings and discussions were held with internal and external conservation partners. A draft version of the plan was revised based on a public comment period."
Please write to CT DPH Commissioner Raul Pino if you wish to communicate concern about a plan to convey wastewater from the Woodridge Lake Sewer District to the Torrington wastewater treatment facility in Harwinton. This sewer crosses a section of Class II reservoir land belonging to Torrington Water Company, and extends for a mile along the drinking-water watershed on land not belonging to the water company (and therefore not legally Class II). DEEP believes that the portion of the pipeline that crosses the property of the water company is not “in” Class II land because it will be in the right-of-way for Route 4 (which runs through the property.)
Commissioner Raul Pino, MD, MPH
CT Department of Public Health,
410 Capitol Avenue, Hartford CT 06134
Email is Raul.Pino@ct.gov (mailto:Raul.Pino@ct.gov) cc to Lori.Mathieu@ct.gov (mailto:Lori.Mathieu@ct.gov)
In NW Connecticut, the Torrington Water Company is opposing a proposal by the Woodridge Lake Sewer District (WLSD) and the Department of Energy and Environmental Protection (DEEP) to run a wastewater pipe through Torrington Water Company Class I/II land to convey sewage from the lake community in Goshen to the City of Torrington's wastewater treatment plant in Harwinton. In Connecticut policy and law, Class I/II lands have the highest priority for protection. They are water company-owned recharge areas for drinking water sources.
Excerpt from Rivers Alliance letter (1/3/17) to Commissioner Pino:
The proposed plan would pipe the wastewater from the Woodridge Lake community across Class I and II land belonging to the Torrington Water Company. As you know, Class I and II lands have the highest priority for protection under Connecticut law. No projects are allowed therein, except certain infrastructure directly related to water supply. The Department of Public Health (DPH) has the chief responsibility for upholding this protection.
Our first worry has to do with the precedent. This is the same worry that led so many groups in 2015-2016 to oppose the proposed Kinder-Morgan Tennessee Gas pipeline under the Class II reservoir recharge lands belonging to the Metropolitan District in West Hartford. That project was eventually abandoned by its proponents.
Second is the risk of direct harm in the field associated with construction, maintenance, and accidents, including pipe flaws and failures. DEEP and others say that the pipe will he engineered with extra safeguards against accidents. All engineered sewer lines are designed to be safe. Nevertheless, accidents happen.
Third, the proposed project will convey thousands of gallons of water daily out of one watershed and into another. As this summer's drought illustrated, basins in the northwest corner can readily run dry. Whenever possible, water should he kept local. Moreover, the waters in the relevant areas are of unusually high quality: almost all are classified as AA, that is, water used for or suitable for drinking. The less disruption of these watersheds, the better.
Finally, there appear to be feasible alternatives for the wastewater problems in the WLSD. There are alternative routes that would avoid Class I and II land. There is also an opportunity for local treatment making use of the 90-acre property now acting as a treatment and leach held. Our research indicates that technology exists that is suitable for wastewater treatment in an area in need of remediation.
We ask that you oppose this project, at least insofar as it would enter the protected recharge land of the Torrington Water Company.