Rivers Alliance and Connecticut Fund for the Environment have created a website called Our Water Connecticut (ourwaterct.org) to assist the public in understanding and advising our state government regarding the Draft State Water Plan. We will provided updates and guidance as the comment period proceeds. To sign up for Rivers Alliance emails, please click here. To sign up for news alerts from the Connecticut Water Planning Council, register at www.ct.gov/water or send an email to email@example.com requesting to be added to the e-alert distribution.
Here are links to the state's plan, to comments that have already been submitted so far, and how YOU can comment on it.
Public Informational Meeting Oct 26 hosted by Connecticut State Representative Jonathan Steinberg at Earthplace Nature Discovery Center Greenwich 6:30 pm – 8:30 pm
State Water Plan Public Hearing Oct 30 at DEEP, 79 Elm Street, Hartford, 6:30 pm - 8:30 pm
Water Planning Council Joint Public Meeting Nov 8 in conjunction with State Representative Mary Mushinsky at Wallingford Town Hall 6:30 pm – 8:30 pm
RA Comments on PRIVATE RESIDENTIAL WELLS
in the draft Water Plan
Approximately one quarter of Connecticut residents get their water from private residential wells. Residential wells are spread across the state in mostly rural and suburban areas making management as a water resource challenging.
The state Department of Public Health, working with local Health Districts, provides the majority of regulatory oversight for these wells. While drinking water quality rules are established, there is no requirement for testing after a well has been installed. Looking at the water quantity side of private wells, with no required pumping data, quantities used by private well owners can only be rough estimates. Much of the actual data for private wells either is not available or has not been converted to useful digital formats. Consequently, the role private wells play in the use Connecticut’s water resources is murky, at best.
More Education: Recommendation for more effort educating private well owners on best practices
Digital Well Reports: Requiring well completion reports in a digital format, and converting older reports into a digital, searchable format.
Periodic Water Testing: Recommendation for a water quality testing and reporting program for private wells.
The first two recommendations are very doable, not expensive, and would be a big step forward in understanding the private well component for any state wide water resource evaluation. We feel there should be more urgency in moving forward on these.
Periodic Water Testing: The requirement for water quality testing of private wells is critically important to ensure public health, but is not discussed in detail and with enough urgency. We think this might be because more testing is expensive and may lead to discovery of expensive problems. What do you do if you find out your well water is no longer safe to drink? Potential costs are one reason why both home owners and regulatory agencies are reluctant to do periodic water quality testing.
We believe people should know they have a safe water supply to keep their families healthy. Exploration of cost effective ways to test private wells should be proposed in the Plan. For instance, local health districts could offer information and support for homeowners to collaborate and negotiate a group rate for testing.
Who should be part of this discussion? Certainly the private well owners, but we note their omission in the Plan recommendations to bring; “Homebuilders, real estate associations, and laboratories” into the discussion about private well testing and water quality reporting (p. 5-69).
Outreach to Private Well Owners: While outreach to well owners for best practices is proposed in the Plan, we are concerned it may be passive outreach, such as a website. A more vigorous outreach program needs to be included, especially considering the large percentage of Connecticut residents who rely on their own well for water supply. While wells likely fall into most homeowners’ concern only if they are “broken;” educational messages about preventing contamination and understanding that ground water is a shared resource need to be emphasized. Also as noted above, well owners should be included in any discussions about residential water quality testing.
Water Supply Protections: Private residential well owners do not have any legal protection if a nearby well pumps the local groundwater source dry. This should be acknowledged in the Plan, along with suggestions to move forward to find a solution.
RA Comments on WATER REGISTRATIONS in the draft Water Plan
Here are a few topics Rivers Alliance of Connecticut feels are important and should be commented on related to WATER REGISTRATIONS in the Plan. We hope this will help you in formulating comments of your own. Rivers Alliance of Connecticut stands ready to answer any questions you may have relating to the Plan. Email firstname.lastname@example.org.
REGISTRATIONS: Registered Water Diversions (“Registrations”) were established in 1982-1983 (under the Water Diversion Policy Act). The Registrations are grandfathered rights to take (divert) large amounts of water. (A “diversion” is any artificial alteration in a water body, whether by damming, pumping groundwater, gravity-piping, etc.). The law was meant to protect natural waters via a permitting requirement for diversions in excess of 50,000 gallons per day; the required permit includes a strict environmental review. (The quantity requiring a permit is any quantity in excess of 50,000 gallons per day.) But an unfortunate compromise in the law provided an exemption from the permitting process for all existing diversions registered with the state by the user. These registered diversions, or “Registrations,” account for more than 80 percent of the number of water diversions under the state’s permitting system. Frequently, the quantities authorized in a registration exceed the water in the source. It is in fact legal in Connecticut to pump a river dry. There is no environmental review and no legal recourse.
GOOD: The Plan strongly recommends that obsolete registrations should be taken off the books as a potential water demand. For example, on paper it might appear that, because of a registration, there is no water available in a given aquifer. But, in fact, the registration may be obsolete or unusable. An example would be a registration for agricultural irrigation, but now the farm and farmer are long gone; a residential subdivision has replaced the farm. That registration should be taken off the books. (There is less agreement over whether “unused” registrations should be retired because these allow diversions that the water utility or other registration holder might want to use in the future.)
BUT: The draft Water Plan tiptoes quietly around the fact that Registrations are a major roadblock to good water resource planning. Almost all major water conflicts in Connecticut have involved registrations, and these conflicts are the main reason the state decided that a comprehensive water plan is needed. Over and over in the Plan, when Registrations are mentioned, they are acknowledged as an obstacle to understanding or solving an issue. But the Plan is weak on recommendations for removing or breaching this roadblock. Here’s a review of several of the policy areas in which Registrations are problematic.
Conservation: Registered water diversions are not required to implement water conservation measures.
Ecological Needs: Registered water diversions were granted with no environmental review and allow pumping volumes that dry up streams. There is still no process for environmental review now.
Regional Water Planning: A number of the regional basins are shown with critical water needs. Some basins have real water deficits that need to be addressed and others do not, but because of registrations included as water claims, realistic planning cannot proceed.
Public Trust Resource: There is no discussion that water is a public trust resource, held in trust by the state for the benefit of current and future uses. When registrations are regarded as “carved in stone” claims on water resources, but no longer benefit current or future uses, the state is not conducting responsible management of our public trust water resources.
No “Pathway Forward” Proposed: Lack of any discussion of revisions to or retirement of registrations in the draft Plan, because it is a politically difficult issue, means the draft Plan does not seriously address improvements in future water resource planning. If we can’t address current problems, how will the draft Plan help us going forward? The Plan needs a bold and brave proposal for a commission to study and prepare a plan recommending how to retire registered water diversions.
RA Comments Regarding CONSERVATION OF WATER
in the Draft Water Plan
In this section, we offer our ideas on some of the key issues regarding CONSERVATION OF WATER in the draft Water Plan. Our comments are based on references to water conservation in the Plan. We hope this will help you in formulating comments of your own. As always, Rivers Alliance stands ready to answer any questions you may have relating to the Plan.
GOOD: The draft Plan has a unanimous goal of encouraging water conservation. Yay! Everyone likes conservation! (We, of course, feel that conservation of natural waters is as important as conservation of water running in pipes.)
BUT: We find the following areas in need of improvement if the goal is a robust and effective water-conservation policy.
Conservation Effort: The Plan is biased toward modest water-customer conservation efforts, led by the water utilities. But water use by customers has dropped significantly (about 12 percent) in recent years. And, since water conservation normally means less revenue for water utilities, one can hardly expect an energetic and enthusiastic conservation program with utilities in the lead.
Water Conservation Pricing: One promising approach to water conservation that does not unduly stress water utilities is water pricing that separates the direct connection between volumes of water sold and revenue gained. The approved water rate is sufficient for infrastructure maintenance. This is sometimes called “decoupling.” Connecticut has adopted decoupling provisions for private water companies. Public utilities have not been enthusiastic. They do not want state rate regulation.
Drought Planning. Connecticut has been working on an updated drought plan for more than 10 years. There is universal agreement that we need a plan that provides for fair and prudent water management in times of drought (such as the summers of 2015 and 2016). But in the state draft Plan, there is no urgency with respect to moving a state drought plan forward for approval. It is critical to have a better drought plan in place before the next drought.
Water Conservation and Ecological Health: The Plan states that droughts or other water shortages that harm streams must be addressed in planning. Having water available in pipes while streambeds are dry is not acceptable. But, in general, there is little emphasis on using conservation measures to protect natural streams. Taken as a whole, the Plan implies that meeting instream or ecological needs will be difficult or impossible, as if the impracticality of saving high-quality streams is a foregone conclusion.
Municipal Conservation Efforts: The draft Plan gives only slight attention to the role of municipalities and the need for adoption of enforceable municipal water conservation measures. This is important in times of drought and emergency as water utilities have no enforcement powers. The state governor has authority (yet to be exercised) to declare a statewide drought emergency. But often drought and water emergencies occur on a local or regional scale. A local lawn-watering ban might be what is needed, enforced by the municipality. But if the town hasn’t enacted an emergency water conservation ordinance, it can’t enforce a lawn-watering ban or any other water conservation measures.
Water Conservation = Energy Conservation: The Plan needs to give more attention to the relationship between water conservation and energy conservation. Energy is used to treat water before distribution, during distribution, and for wastewater treatment after use. Water is used for cooling power facilities and delivering hydropower. One of the most effective approaches to conserving water and energy is to control peak demand. Entire streams are diverted and power plants built to meet demand in peak-use times. For example, a hydro facility may impound a river year round so that the plant can supply a small amount of electricity for, say, three months of the year.