CBIA has weighed in on the proposed State Water Plan, commenting on behalf of its members who need a reliable water supply to run their businesses, create jobs, and help drive the state's economy.

The state Department of Energy and Environmental Protection sought comments through Nov. 20 on the draft plan, designed to frame future water management policies, laws, and regulations.

CBIA Senior Counsel Eric Brown wrote to the State Water Planning Council on behalf of "thousands of small, medium, and large businesses across the state that depend on a reliable supply of water to provide jobs and wealth for Connecticut and its citizens."

While thanking council members for their work, Brown sought clarification to the draft plan in four specific areas. He asked that it:

  • Provide better context for its role in addressing the state's long-term economic health
  • Clarify how it will be used
  • Revise the council's role and authority moving forward
  • Increase the focus on education and conservation

The draft plan states that its purpose is not to prioritize one water use over another.

Understates Economic Importance

But Brown suggests that the draft plan understates the importance of water to the economic growth that's so critical to the state's future.

"We did not find a definitive statement in the draft plan that one of its goals is to ensure sufficient quantities of water for future economic development," Brown wrote.

We did not find a definitive statement that one of the goals is to ensure sufficient quantities of water for future economic development.
— CBIA's Eric Brown
He also notes that the plan indicated it is a repository of scientific information and a "framework for future decision making," but also contains recommendations for future legislation and regulations, which are characterized as having a strong consensus.

"CBIA urges that the draft plan clarify that it includes possible strategies and options for policymakers and the public to consider, but that it not imply these as broadly supported recommendations meriting enactment by the General Assembly or state regulatory agencies," Brown wrote.

Caution Urged

CBIA urges caution on the council's future authority based on one section of the plan that indicates the council will need to be consulted and perhaps approve a wide variety of state and regional plans to ensure they are consistent with the final water plan.

"We are very concerned about the Water Planning Council having any manner of veto power over these other plans," Brown wrote.

He said CBIA is further concerned that the plan or the council's authority could be used to justify future proposed legislation, regulations, or permit decisions in a way that suggests that comments from the public or other state agencies are less valid due to the "broad consensus" reflected in the draft plan or its adoption by the General Assembly.

He said it was important that neither the plan nor the council be "the definitive resource or arbiter on future water policy decisions."

Lastly, given the vital role water has in the environment and economy, he said the state must "educate the end users as to the importance of water stewardship and conservation at all times."


For more information, contact CBIA's Eric Brown (860.244.1926) | @CBIAericb