Posted Apr 11, 2024
Nature for a Resilient Connecticut – harnessing nature’s power to combat climate change

We stand at a critical juncture where the interconnected crises of climate change and biodiversity loss demand immediate and urgent attention. Scientific evidence unequivocally demonstrates that the changing climate wreaks havoc on habitats and ecosystems, while the erosion of biodiversity further amplifies the impacts of climate change. We cannot address one crisis without confronting the other.

Intact natural systems – our soils, forests, wetlands, watercourses and diverse ecosystems that Connecticut is so fortunate to have in abundance – offer nature’s own solutions to mitigate and adapt to climate change. Nature itself is a formidable ally in the fight against climate change. Natural systems not only sequester and store carbon, but they also provide essential ecosystem services such as nutritious food, clean water, clean air, flood control, and drought resilience. However, their efficacy relies on their richness as both a carbon pool and for species diversity.

Protecting biodiversity encompasses safeguarding a plethora of life forms, from soil microbes and pollinators to myriad plant and animal species. These organisms are the backbone of our natural systems, ensuring their resilience and our ability to adapt to a changing climate.

The science is clear – Natural Climate Solutions (NCS) can provide over one-third of the cost-effective climate mitigation needed by 2030 to stabilize warming below 2°C. Alongside aggressive reductions in fossil fuel emissions, NCS offer Connecticut a powerful arsenal of strategies for fulfilling its obligations under the Global Warming Solutions Act while simultaneously enhancing soil productivity, improving air and water quality, and safeguarding biodiversity.

We must protect nature and biodiversity in order to protect our well-being, our communities, and our economy.


Riparian Buffers

Riparian buffers protect and improve water quality, attenuate flooding, and provide a myriad of additional ecosystem services. Unfortunately, Connecticut’s current regulatory framework provides no specific protections for riparian buffers along wetlands and watercourses. Indeed, we have the least protective buffer standards of all the New England states. There must be a comprehensive review of Inland Wetlands and Watercourses and Planning and Zoning statutes and regulations to incorporate protections specifically for riparian buffers. Redundancy should be provided
to reduce risk. We must address weaknesses in our inland wetlands and watercourses protection that result in loss of wetlands and cold-water habitat.

There are several areas that need to be addressed in our IWWC statutes and within DEEP:

  • Update the required number of members of an Inland Wetlands Agency that must be trained from a minimum of one member to all members being required to obtain training. Utilize conservation districts to assist DEEP with training.
  • Expressly prohibit the merging of Inland Wetlands Commissions with Planning, Zoning, and Planning and Zoning Commissions within a municipality.
  • DEEP’s Inland Wetlands and Watercourses program is severely under-resourced, providing little support for local commissions. Dedicated staff at
    DEEP in the Inland Wetlands and Watercourses program must be increased.

Update State and Municipal Plans of Conservation and Development

Land use planning in Connecticut is implemented at the local level and starts with municipal Plans of Conservation and Development (POCD). All municipalities should be considering the threats of climate change and loss of biodiversity in their planning efforts and incorporate protection of our natural systems into the POCD. Existing state statutes should be updated to require cities and towns to consider the role of nature and natural systems in the POCD as part of resiliency planning.

Open Space & Forests

Despite the essential role that nature plays in addressing the dual environmental crises of climate change and biodiversity loss, as well as a myriad of other benefits to communities, Connecticut has not met its land conservation goal (protecting 21% of its land base by 2023), and the state’s natural and working lands are being lost at an alarming rate. For
example, of the 59%of the state that is forested, ~53% is core forest—large blocks fundamental for wildlife habitat, drinking water supply protection, and ecological resilience.

Core Forests of 500+ acres are declining rapidly—losing ~120,000 acres from 1985-2015 to fragmentation and development.

Connecticut should enact legislation that prioritizes the support and maintenance of an ecologically functional landscape that sustains biodiversity, conserves landscape connectivity, supports watershed and airshed health, promotes climate resilience, supports farms and forests, provides opportunities for recreation and appreciation of the natural world, and offers resilience while supporting sustainable development patterns.

Such legislation should authorize and incent the use of nature-based solutions as the preferred alternative, where appropriate, across all agencies and appoint an interdisciplinary scientific advisory council consisting of experts in climate science, ecology, forest science, soil science, wildlife biology, environmental economics, and other appropriate disciplines to help establish and inform the use ofnature-based solutions, including:

  • Reenacting comprehensive forest conservation policy to keep forests as forests, protect healthy, intact forests, offset planned or permitted forest losses, protect urban forests.
  • Add more parks, and evaluate and revise the state’s land conservation goal as set forth in Section 23-8 et seq. of the general statutes.
  • Revising existing or promulgating new rules and regulations, establishing systems for NBS and ecosystem service data collection.

Global Climate Solutions Act (Negative Emissions)

Connecticut should amend the Global Warming Solutions Act to incorporate “negative emissions.” According to Commissioner Katie Dykes written testimony date March 10, 2023 to the Environment
Committee on Senate Bill No. 11452 (2023): “Negative emission practices and technologies include but are not limited to reforestation and management, wetland management, soil management, and direct air capture.” These techniques not only provide climate change mitigation benefits but can also support critical ecosystem services such as air pollution reduction, biodiversity protection, and water filtration.

Often referred to as carbon capture and storage, these approaches – both bio-based and technology-based – are critical components in most IPCC pathways that keep global warming to below 1.5°C.

Incorporating negative emissions into Connecticut’s Global Warming Solutions Act while also adding a net zero emissions target for 2050 will realign Connecticut with the latest science and will support Connecticut’s ability to identify the most cost-effective path to a decarbonized economy.

Natural and working lands provide tremendous negative emissions benefits to Connecticut as our climate changes. Numerous scientific reports through various models have documented carbon and other greenhouse gas pollutants sequestered or absorbed and stored underground in soil, roots, and above ground in tree trunks and branches. Avoiding the deforestation or development of natural and working lands is the most effective means of maintaining and enhancing the “negative emission” benefits of this landscape type.

Posted Feb 13, 2020
Updates to the General Permit for the Discharge of Stormwater and Dewatering Wastewaters from Construction Activities

A draft of the General Permit for the Discharge of Stormwater and Dewatering Wastewaters from Construction Activities was out for public comment in early January and contains special conditions for Solar Arrays (Read to the notice).

Comments are due Tuesday February 18, 2020. We don’t want to miss this opportunity to ensure that our valuable and necessary renewable energy projects do not continue to cause unintended environmental harm. Particularly in the realm of water quality.

Rivers Alliance has submitted comments on the permit (click here to download our comments) and we hope you will weigh in as well if only to reinforce the need to include special conditions for solar arrays due to the fact that:

“… [t]he large amount of impervious surface inherent in the construction of large-scale solar arrays is unlike most other construction activities regulated under the General Permit for the Discharge of Stormwater and Dewatering Wastewaters from Construction Activities and entails challenges not encountered in traditional development projects.”

— From the January 8, 2020 Guidance Regarding Solar Arrays by DEEP

You may submit comments via email to or postal mail to Christopher Stone, P.E.,Water Permitting and Enforcement Division, Bureau of Materials Management and Compliance Assurance, Department of Energy and Environmental Protection, 79 Elm Street, Hartford, CT 06106-5127

Please feel free to reach out to us if you have any questions or concerns.

Rivers Alliance comments on updates to DEEP’s Construction Stormwater Permit

Comments referenced in Rivers Alliance’s comments:

Posted Dec 15, 2019
Sewage Bypasses and Combined Sewer Overflows Dec 13-15, 2019

Below is a map made from CT Department of Energy and Environmental Protection (DEEP) data that shows sewage spills reported to CT DEEP during the storms of 13-15, 2019. If no town names and location symbols appear at first, try refreshing the page. You can zoom in by double-clicking between symbols. If you click on a symbol and the pop-up box is too small to read, try the “enlarge” button in the upper right of the box.

If you click the link above the map, it should open a new, larger page that can be zoomed, adjusted for better viewing, and clicked on for more information.

Sewage Spills Electronically Reported Dec 13-15, 2019

Heavy rainfall that gets into sewage treatment systems through damaged pipes, leaky manhole covers, illegal connections from storm drains, and other ways, often causes sewage to overflow at treatment plants or from manholes, or to back up into the basements of homes and businesses. Most sewage treatment systems now report these “bypasses” to the CT DEEP, and then they are mapped out on DEEP’s Sewage Right To Know website.

Posted Dec 13, 2018
Rivers Alliance comments to MDC on their proposal to delay CSO elimination

For: Scott W. Jellison, Chief Executive Officer, The Metropolitan District Commission, Hartford, Connecticut

From: Rivers Alliance of Connecticut

Thank you for the opportunity to comment on the MDC Long Term Control Plan (LTCP) Draft Update for control of its combined sewer overflows (CSOs). The mission of Rivers Alliance is to protect the health of all state waters. For 25 years, we have advocated directly or through our Board for cessation of the sewage spills from the MDC system. We appreciate that you have made  progress, and urge you to pick up the pace.

The 2006 Consent Decree from the EPA and the CT DEP was long overdue. The schedule for remedial action was reasonable, and the state has responded positively to the MDC’s requests for help with the costs of the project. Nevertheless, the MDC is now proposing a dramatic slowdown in meeting the terms of the Consent Decree and the diversion of resources to other projects. It appears that the MDC wants to change the deadline for completion from 2029 to 2058. That’s another whole generation of people who will be exposed to raw sewage.

The MDC should proceed on the schedule for CSO work that it has agreed to. We oppose further delay.We support the points made by our expert colleagues at Connecticut Fund for the Environment/Save the Sound and at the Connecticut River Conservancy, and will not repeat them here. I am sure that we all agree to the overarching principle that it a basic social responsibility of individuals and communities not to subject their neighbors to raw sewage. Sewage treatment is expensive, for households as well as municipalities. But it is not an obligation one can put off without serious consequences. Exposure to raw sewage is disgusting and dangerous. It is obviously harmful to human health. It is even more harmful (though less obviously) to aquatic life.

I’ve read comments sent you by the Jorgensen family on the North Branch of the Park River. Connecticut residents should not have put up with the constant close encounters with river sewage that they describe. Many MDC customers and visitors to the region praise the excellent quality of your drinking water. The same high professional standards should be applied in the wastewater side of your business. Those standards include, in our view, staying on schedule.

Thank you for your consideration.

Margaret Miner, Executive Director, Rivers Alliance of Connecticut

Posted Dec 12, 2018
MDC Proposes Delayed Elimination of Combined Sewer Overflows

The Metropolitan District Commission (MDC) held a public hearing Dec 11 on it’s proposal to modify it’s 2014 agreement to eliminate combined sewer overflows (CSOs) by 2034 using a massive tunnel system under Hartford. MDC wants instead to separate the sanitary sewers from the stormwater drains in the north end of the city and put off building part of the tunnel system until well beyond 2034. It calls its plan their Clean Water Project.

In a 2017 letter to MDC, the CT Department of Energy and Environmental Protection (DEEP) reiterated the need to eliminate CSOs. Here’s an excerpt:

“For the past eleven years, DEEP has worked with MDC in order to meet the changing needs of the Clean Water Project. DEEP modified Consent Order WC5434 and supported revisions to the LTCP that resulted in more cost-effective ways to meet the environmental goals. DEEP agreed to schedule modifications in the CO to extend compliance deadlines by eight years. DEEP agreed to merge the solution to salutary sewer overflows and CSOs into the South Hartford Conveyance and Storage Tunnel (SHCST) and provided a very favorable is grant award for the project. To date, DEEP has provided $1.2B in financing to support MDC’s two funding authorizations of $1.6B, or 75% of project funding with CWF participation.”

“DEEP intends to continue to work with MDC in implementing the approved LTCP and LTCP Updates as we move forward. We recognize future updates may include additional alternatives analyses evaluating means of keeping this project as cost-effective as possible. However, the standards of elimination of CSO’s tributary to the North Branch Park River and Wethersfield Cove and control of CSO to the one-year level, established in Consent Order WC5434, shall not change.”

The deadline to submit public comments is December 13, 2018 at 6:00pm and may be submitted to the District Clerk via email at or via mail at: The Metropolitan District 555 Main Street Hartford, CT 06103 Attn: District Clerk

Links to more information: