To:  CGA Planning and Development Committee for 
March 9, 2012 Public Hearing
Re:  Opposition to SB 343 AAC Intervention In Permit Proceedings Pursuant To The Environmental Protection Act Of 1971

Comments submitted by Karen Burnaska, Natural Resources Director

Raised Bill 343 should not go forward.  Citizens and nonprofits opposing environmentally destructive projects would have levels of proof and pleading that far exceed normal requirements. 

Section a(1) turns that burden of proof squarely onto the complainant.   Sections a(2), a(3) and a(4) puts in place unreasonable – and not mutually required
of the applicant – disclosure provisions and damage awards. The most undemocratic part of this bill is section a(5) - There shall be no right of appeal from any decision of a board, commission or other administrative agency or court rendered pursuant to this section on a verified pleading.This in particular strikes the LWVCT as wording that goes against the grain in our democracy. 

The disproportionate burdens placed upon interveners as proposed in this bill are completely unwarranted. The September 2010 “State of Connecticut
Department of Environmental Protection Permitting Assessment Report” reflects that far from an abundance of “frivolous” suits, the exact opposite is the case “…of the total permits issued by the Department over the past five years, CEPA was invoked
0.2 percent of the time or in less than one-quarter of one percent of the time a permit is issued by DEP.” (State of Connecticut Department of Environmental Protection Permitting  Assessment Report, P. VII-3).

The current law has served the public well by enabling citizens to have input into the decisions that affect them, their health and their communities. 

We urge you to oppose SB 343.

To:     Executive Secretary, Public Utilities Regulatory Agency 


From: Karen Burnaska, Director, Natural Resources, League of Women Voters of Connecticut 

Re:     Doc. No. 12-01-07, Application for Appeal of Holding Company Transaction Involving Northeast Utilities and NSTAR 

Date:  February 18, 2012      

The League of Women Voters of Connecticut and its more than 1,800 members support the preservation and protection of open space and watershed lands.      The Public Utilities Regulatory Agency (PURA) is now reviewing the merger application between Northeast Utilities (NU) and NSTAR.      

NU owns nearly ten thousand acres of critical conservation land across Connecticut.  Some parcels are large and well-known, like Maromas near Middletown.  Many form greenbelts along miles of rivers like the Housatonic, Farmington and Naugatuck Rivers.  Together they contribute valuable open space that preserves green landscapes, filters water entering our rivers, and provides recreational opportunities.  These lands are protected by an existing Memorandum of Understanding (MOU). The League of Women Voters of Connecticut requests that PURA strengthen and extend the MOU in order to ensure that the nearly 375 parcels of land on the Conservation List be protected.       

I thank you in advance for your consideration and hope that PURA will preserve agreements now in place between the owner of the open space land, NU, and any future owner, keeping these lands forever green.  

Dear Governor Malloy,

          On behalf of the over 1,800 members of the League of Women Voters of CT, I urge you to veto Bill 1196, the “Haddam Land Swap.”

          The League of Women Voters believes that the public should have confidence in the integrity of its government.  If you sign this bill into law, it will send a message that special interests have trumped the public interest. The land in question was purchased by the State for conservation purposes.  In order to maintain the integrity of the process followed and to retain the trust of the electorate, we ask that the covenant on the land be honored and the land remain open space.       

          Thank you for your consideration.

                             Cheryl Dunson, President

                             LWVCT