E2 Engages DEEP on Proposed Air and Waste Permits

This summer, Connecticut’s Department of Energy and Environmental Protection issued two proposals that combined could impact thousands of small, midsize and large businesses in the state. 

The DEEP proposals are for general permits—documents designed to define enforceable compliance requirements applying to large numbers of businesses.

Using general permits eliminates the need for DEEP to issue, and for businesses to obtain, individual permits designed for specific facilities.   

Recycling/solid waste 

One of the new general permits, concerning recyclable materials and some other solid wastes, could have a major impact on many small and large retail businesses that deliver cardboard-packaged products to commercial and residential customers. 

Under the proposal, a business that takes the cardboard packaging back to its store for recycling would have to register for the new permit, pay a fee, and comply with all the permit’s provisions. 

This would also apply to businesses with multiple locations that bring office paper, cardboard, or other recyclable materials to one of their locations for processing and/or pickup by a recycling vendor. Management of other solid wastes is also covered in the proposal.

Air permit

DEEP issued the other general permit under pressure from the federal Environmental Protection Agency.

Primarily, it would impact some manufacturers, businesses that use spray booths, and other facilities that emit relatively small amounts of regulated air pollutants (less than what would define them as a “major source” under federal regulations). 

Many of these sources already have an existing general permit to cover their emissions but the proposal would force dozens of these to obtain individual permits and subject the rest to additional monitoring, training, and other requirements.

The E2: CBIA Energy & Environment Council is engaging its members and DEEP officials to address the many concerns of its members with the proposed general permits. 

E2 has filed comments with the agency on both general permits, requested a hearing on the waste general permit, and may request a hearing on the air general permit.

For more information about these proposed new requirements, whether they may impact your business, or to get involved with E2 members working to impact the final versions of these proposals, contact CBIA’s Eric Brown at 860.244.1926 | eric.brown@cbia.com | @CBIAericb