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 email@example.com 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:
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.
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.
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
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 DistrictClerk@themdc.com or via mail at: The Metropolitan District 555 Main Street Hartford, CT 06103 Attn: District Clerk
Links to more information: