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FORMAL COMMUNICATION TO THE CONNECTICUT WUCCS AND THE WATER PLANNING COUNCIL

River Alliance of CT > Priority Topics > State Water Planning >

Formal Communication to the Connecticut WUCCs and
the Water Planning Council

Click here to see the Response from the WUCC Chairmen to Our Formal Communication

September 12, 2016

To the Water Planning Council: Chairman Jack Betkoski (Public Utility Regulatory Authority, PURA); David LeVasseur (Office of Policy and Management, OPM); Lori Mathieu (Department of Public Health, DPH); and Mike Sullivan (Department of Energy and Environmental Protection, DEEP; and

To The Chairmen of the Water Utility Coordinating Committees (WUCCs):

Western WUCC - Dan Lawrence (Aquarion Water Company); Russ Posthauer (Candlewood Springs Property Owners Association).

Central WUCC - Bart Halloran (Metropolitan District Commission); David Radka, Connecticut Water Company).

Eastern WUCC -Bob Congdon (Town of Preston); Mark Decker (Norwich Public Utilities); Patrick Bernardo (Town of Putnam/SUEZ).

We the undersigned urge you, in your process of water-supply planning, to reconsider your decision to delay evaluation of environmental issues until after water-supply exclusive service areas (ESAs) have been assigned.   As has been referenced in your meetings and communications, the statute dealing with Water Utility Coordinating Committees requires each coordinated water system plan to include provisions for “water quality, flood management, recreation and aquatic habitat issues; ..”    (Sec. 255-33h).    These words were added in PA 14-163, the law mandating development of a comprehensive state water plan.

Your determination as WUCC leaders has been that it will be acceptable to prepare the statute-based assessment of water supply conditions and problems and to establish exclusive service area boundaries (Sec. 25-33g) without identifying or addressing the issues of water quality, flood management, recreation, and aquatic habitat.   The reasoning seems to be that, because these issues must be specifically addressed only in each WUCC region’s coordinated water system plan, it is acceptable to do all the water supply planning and exclusives service area delineations without consideration of the environmental effects.

This postponement of environmental analysis was not the intent of PA 14-163;   it is not consistent with other language in the statute, and it is entirely impractical if one seriously intends eventually to identify environmental concerns in the WUCC regional and state water supply plans.  

The position of the WUCCs has been that these factors can be integrated later and, if necessary, the supply assessments and ESAs can be altered - but evidently without the public and agency review required for the creation of these documents.

We believe, too, that even if the new language explicitly calling for environmental analysis were not in the statute, the original language applying to supply assessment and ESA boundaries implicitly requires consideration of environmental factors. Here is the language for assessments.

Sec. 25-33g. Assessment of water supply conditions and problems. Exclusive service area boundaries. (a) Each water utility coordinating committee, in consultation with the Commissioners of Public Health and Energy and Environmental Protection, the Secretary of the Office of Policy and Management and the Public Utilities Regulatory Authority, shall develop a preliminary assessment of water supply conditions and problems within the public water supply management area. The committee shall solicit comments on the preliminary assessment from municipalities, regional councils of governments, state agencies and other interested parties and respond to any comment received. The committee shall thereafter prepare a final assessment.

Note that the assessment is supposed to be done in consultation with DEEP and is to include “water supply conditions and problems” (emphasis added).   We believe that these problems necessarily include the recurring problems of dry streambeds due to supply diversions, over-pumped groundwater, flooding in source locations, and contamination past and present.   We believe also that well-known plans for alterations in current supply arrangements, such as the New Britain plan for rock mining and a new reservoir, should be taken into account, especially if extensive (and intensive) environmental alterations are projected.

We realize that integrating environmental factors into the supply assessments and ESA decisions will take more time than you hope to allot for WUCC work.But the present schedule was elected by the WUCCs themselves.   It is only one-third of the time originally proposed by DPH.  It has no relation to statutory requirements.   (The deadlines in the WUCC law blew by some 30 years ago.)   We ask you to take the time to do the work in a manner that will give the public an opportunity to see the entire water-supply picture at one time.

Thank you for your attention.

Signed in alphabetical order:

Lori Brown, Connecticut League of Conservation Voters

Len DeJong, Pomperaug River Watershed Coalition

Sarah Faulkner, Collinsville

Kathy Fay, River Advocates of South Central Connecticut (added 9/13/2016)

Eileen Fielding, Farmington River Watershed Association

Aaron Goode, River Advocates of South Central Connecticut (added 9/13/2016)

Robert Gregorski, Naugatuck River Watershed Association

Rick Haeseler, Sierra Club Connecticut Chapter (added 9/14/2016)

Barbara Henry, First Selectman, Roxbury

Anne Hulick, Clean Water Action

Martha Klein, Sierra Club Connecticut Chapter (added 9/14/2016)

Colleen Lake, Administrator, Ridgefield Conservation Commission (added 9/13/2016)

Sharon Lewis, Connecticut Coalition for Environmental Justice

Martin Mador, River Advocates of South Central Connecticut, Sierra Club Connecticut Chapter, Rivers Alliance 

Kevin McCarthy, River Advocates of South Central Connecticut (added 9/13/2016)

Peter McKnight, Sierra Club Connecticut Chapter (added 9/14/2016)

Margaret Miner, Rivers Alliance of Connecticut

Bill Moorhead, Consulting Field Botanist, Litchfield

Rep. Mary Mushinsky, Wallingford, River Advocates of South Central Connecticut

Roberta Paro, Sierra Club Connecticut Chapter (added 9/14/2016)

Amy Blaymore Paterson, Connecticut Land Conservation Council (added 9/14/2016)

Lenka Peterson, Roxbury

Chris Phelps, Environment Connecticut (added 9/13/2016)

Judy Preston, Natural Resource Consultant, CT River Estuary

Dennis Richardson, River Advocates of South Central Connecticut (added 9/13/2016)

Donald F. Rieger, Jr., Secretary, Simsbury Conservation Commission (added 9/21/2016)

Sally Rieger, Chairman, Lower Farmington River and Salmon Brook Wild and Scenic Study Committee

Donald and Sally Reiger, Simsbury (added 10/10/2016)

Barrett S. Robbins-Pianka, Middletown

Hugh Rogers, Rivers Alliance Volunteer, Washington

Valerie Rosetti, SaveOurWaterCT

Leah Lopez Schmalz, Connecticut Fund for the Environment / Save the Sound

Cory Slifstein, River Advocates of South Central Connecticut (added 9/13/2016)

David Sloane, River Advocates of South Central Connecticut (added 9/13/2016)

Martha Smith, West River Watershed Coalition

Louise Washer, Norwalk River Watershed Association (added 9/13/2016)

Lynn Werner, Housatonic Valley Association

Marcie Wilkins, Sierra Club Connecticut Chapter (added 9/14/2016)

Bob Workman, River Advocates of South Central Connecticut (added 9/13/2016)

Paul E. Zagorsky, Zagorsky Zagorsky & Galske P.C., Plainville (added 9/16/2016)


NOTE: Some signers sent comments. Here are two:

 

Sally Rieger: “Maintaining adequate flows in both the brook and stream in order to protect biodiversity (one of our official "Outstandingly Remarkable Values") is one of the official "actions " in our Management Plan {for Farmington River and Salmon Brook]. What could be more in line with that than the position expressed in the letter?”

Martin Mador: “We spent several years when fighting for the streamflow regs advocating that the environment is also an important consumer of water. This was breaking news at the time. No process should minimize the importance of this.”


And another(added 9/13/2016), Rep. Mary Mushinsky: "It is inappropriate to assign new service areas to utilities without addressing stressed flows within a utility's existing service areas. How can a water company serve new customers if the company's existing resources are stretched so thin that native streams and wells are already in trouble?

It is also inappropriate to destroy pristine watershed and native habitat to create surplus water storage if a utility's service area customers have plentiful water.

Examples like these are the reason why the legislation included assessment of aquatic habitat and other needs as well as water supply in the creation of WUCC plans.

Our email address is: rivers@riversalliance.org

Our post office mailing address is:
Rivers Alliance of Connecticut
P.O. Box 1797, 7 West Street, Litchfield CT 06759

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Rivers Alliance of Connecticut
PO Box 1797, 7 West Street 3rd Floor, Litchfield, CT 06759-1797
860-361-9349
rivers@riversalliance.org, www.riversalliance.org