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Dear Environment Committee Members:

If SB1020 AAC Water Resources and Economic Development is sent to the Environment Committee, LWVCT urges you to oppose it based upon our position in support of policies and programs that protect our state’s watercourses. This bill undermines a multi-year stakeholder process and blocks overdue reforms to protect water resources.

Since the passage of Public Act 05-142 An Act Concerning The Minimum Water Flow Regulations, DEP undertook a five year effort to develop regulations consistent with the law by seeking input from and balancing needs among a wide variety of stakeholders including public officials, water utility representatives, land use lawyers, real estate agents, developers and environmental advocates.   The Regulations Review Committee rejected the proposed regulations without prejudice. Stakeholders are working to address concerns. After years of work and an ongoing effort, it would be extraordinarily wasteful and inefficient to taxpayers to “start from scratch” by establishing a totally new process for adoption of overdue regulations to protect our water resources.

In addition to squandering 5 years of work, the proposal will not lead to the balanced approach needed to manage the competing needs for water. Specific provisions of concern include undefined exemptions (what does “not financially viable” mean?); repetitive processes (why propose a new process for the creation of new classification process when a negotiated classification process was already proposed?); “grounds for dismissal” (allows for an easy reversal of a protective classification for economic development without recognition of competing needs for wildlife and recreation).

According to the bill's OLR analysis  “The regulations must provide for the needs of public health, flood control, industry, public utilities, water supply, public safety, agriculture, and other lawful water uses...The regulations must also provide for the needs of stream and river ecology, aquatic life, wildlife, and public recreation. ”  Is it any wonder it took 5 years to develop the proposed regulations given these competing demands for a limited resource?

LWVCT was among the sponsors of the 2005 Conference “Water Law In Connecticut: Balancing Needs for Fish and Faucet.”   All agreed that water is allocated through a patchwork of policies that don’t fit together well. 

We do not need another process which fails to provide balance among competing needs for our water resources.  Please oppose SB 1020.

Sincerely,

Cheryl Dunson,   Drinking Water Specialist